ML20050E359
| ML20050E359 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/05/1982 |
| From: | Geiger J, Hawn C, Krisha D BECHTEL GROUP, INC., EBASCO SERVICES, INC., HOUSTON LIGHTING & POWER CO. |
| To: | |
| Shared Package | |
| ML20050E354 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8204130244 | |
| Download: ML20050E359 (44) | |
Text
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REMTED C01UnaiwDENN l6 82 jpp _g g,,.
UNITED STATES OF AMERICA I 9 NUCLEAR REGULATORY COMMISSION j
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 25 l
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j In the Matter of:
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HOUSTON LIGHTING & POWER S
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5 Docket Nos. STN 50-4980L l
5 STN 50-4990L i
(South Texas Project, S
Units 1 and 2)
TESTIMONY ON BEHALF OF HOUSTON LIGHTING & POWER COMPANY, ET AL.
OF j
MR. JAMES E. GEIGER l
MR. DONALD T. KRISHA 31 MR. CLYDE L. HAWN REGARDING 13]4 i THE QUALITY ASSURANCE PROGRAM FOR STP
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E 8204130244 820405 PDR ADOCK 05000498 T
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5 UNITED STATES OF AMERICA (6
NUCLEAR REGULATORY COMMISSION 7
g BEFORE THE ATOMIC SAFETY AND LICENSING BOARD I
I9 In the Matter of:
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HOUSTON LIGHTING & POWER S
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9 Docket Nos. STN 50-4980L i
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STN 50-4990L i
4t (South Texas Project, 9
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Units 1 and 2)
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7i gl Testimony of Mr. James E. Geiger, Mr. Donald T. Krisha gi and Mr. Clyde L. Hawn regarding the Quality 0l Assurance Program for STP 1i 2i Q.1 Panel, please state your names and current positions.
3l 4I A.1 (JG):
James E. Geiger.
I am the Project Quality I
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6 Assurance (QA) Manager, South Texas Project (STP), of the 7
8 Houston Lighting & Power Company (HL&P).
j (DK):
Donald T. Krisha.
I am the QA Manager for 31 l
the Houston Area Office of Bechtel Power Corporation (Bechtel) l and currently assigned as the Project QA Manager for the g
STP.
37 (CH):
Clyde L. Hawn.
I am the Quality Program Site Manager for Ebasco Services, Inc. (Ebasco) on the STP.
i 80 l l
Q.2 Panel, please describe your professional experience 63 and educational background.
A.2 (JG):
I graduated from California State Univer-66 sity at Sacramento with a Bachelor of Science degree in 8
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I5 Industrial Engineering in 1961.
I am a Registered Professional 6
7l Engineer in Quality Engineering in the State of California.
8 From 1957 to 1972 I was employed by Aero-jet 9
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0 General Corporation.
I began as a clerk in Receiving In-2l spection and progressed-through a number of other assignments, 3i 4{
including Supervisor, Receiving Inspection Planning and Data 5
6 Section and Manager, Documentation Center.
My final position 7i g
was that of Manager, Quality Systems.
In that capacity, I i
had responsibility for QA design review activities, data collection and analysis, training, and systems and procedures 3i for the various programs including Titan, Apollo, and 25 Transtage.
7 From 1972 to 1974 I was self-employed outside of 28 l
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the QA field.
In 1974, I joined Vayo, Inc. as a contract QA l 50 'I Engineer.
My assignments varied, but included procedure 31 f
writing, requisition review, and inspection s,upervision.
34 From 1976 to 1978 I was employed-by the Ari[onne National Laboratory as a QA Engineer with responsibility for QA 37
'g8 systems and procedures.
39 l 40 In February 1978, I joined Bechtel.
My initial t' i
' i2 '
assignment was as a Senior Engineer on the QA staff.
In 43 July 1978, I was appointed QA Supervisor of field activities 14 5
for the San onofre Units 2 & 3, where Bechtei was the architect-46 47
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5 engineer, construction manager and constructor. In May of 6
7 1979, I was promoted to Project QA Manager for Ean Onofre 18 Units 1, 2 & 3.
As Project QA Manager I_was responsible for 9
0f, the total QA program, including design,- procurement, construc-
~
2I tion and startup.
3l 4i In June 1981, I joined hL&Ps as Project QA Manager
's 5l 6l for STP, reporting to Mr. G. W. Oprea,
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Executive Vice-7i gl President.
In that capacity, I have the respcnsibility for 19 l O:
the QA program as described in the response te, 'g.5.e 7'
I1f.
Q.3 Mr. Krisha, describe your professional experience
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22 1
and educational background.
, 'v 25 {
A.3 (DK):
I attended Solono College'from 1958 to x.
1960.
Froin 1960 to 1972, I was employed by Mard 'Jsland 28
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39 Naval Shipyard where I. served a 4-year apprenticeship as a g;
s 31 machinist, 2 years as a journeyman and 6 yebrs as a nuclear x
inspector.
In my capacity as a nuclear inipector, I wa'ss 34 I responsible for conducting inspections cd mechanical and
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piping systems on nuclear submarine and surface craft.
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l was also responsible for performing inspections during ship l
refueling and core loading operations.
s I joined Bechtel in 1972 as a CcDstretion 'ieId u
Engineer and was assigned to the construction management organization at the Rancho Seco Nuclear-Generating Station where I was responsible for overseeing the 'contr' actor's t
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~3I Fl J;5 f installation of the Nuclear Steam Supply System.
From 1973 I
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- to 1975, I was assigned to work for the Sacramento Municipal l
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g Utility District as a Test Coordinator during the Startup i
and Preoperational Test Program at Rancho Seco.
l'2 In December 1975, I was transferred to the San
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Onofre Nuclear Generating Station (SONGS 2 & 3) Project ELS !
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where I was assigned as a liaison between construction and 7i gl the design office.
In September 1976, I transferred to the
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QA Department where I was assigned as a QA Engineer on the SONGS 2 & 3 Project.
In October 1977, I was promoted to D
Startup QA Supervisor where I was responsible for di.recting re4 5
and supervising the QA/QC activities for the SONGS 2 & 3 6i 7!
Startup and Prerequisite Test Program.
8 9.
In April 1979, I was promoted to t2A Manager / Domestic 0l 31 Projects where I have been responsible for managing Bechtel 3
QA activities on the Palo Verde, Vogtle and Rancho Seco 34 Nuclear Generating Stations.
Shortly thereafter, I was also 6!
designated as the QA Manager of the Bechtel Houston Area I37 h3 Office.
59 i
)40i I am a member of the American Society for Quality Control, and served on the committee organizing the 1981 43 4
Annual ASQC Energy Division Conference in Phoenix, Arizona.
5 Q.4 Mr. Hawn, describe your professional experience l46 7
and background.
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[3 A.4 (CH): I attended Columbia Basin College, Pasco, 7
Washington, from 1967 to 1970, where I received an Associate O
Arts & Science Degree.
I also attended the University of r9 0
Washington, Seattle, Washington, on a part-time basis from 2
1957 to 1962, majoring in aeronautical engineering.
I am a l
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4I Registered Professional Engineer in Quality Engineering in
.5 6
the State of California.
7; l
Following graduation from high school, I enlisted j
in the military service as a private.
I served from 1948 to t2li 1
1956, and was honorably discharged as a first Lieutenant.
I was employed by the Boeing Company from 1956 to i
t5 1964, first as a tooling inspector, and then as a tool and production planner'on various aerospace projects.
(8 '
From 1964 to 1971 I was employed by Combustion 1
y' Engineering as a Manufacturing Engineer, Development Engineer, and Construction Supervisor.
As a Manufacturing Engineer, I 4l was responsible for sequential planning of the manufacturing I
l of numerous nuclear reactors, pressurizers, heat exchangers 7'
and similar items.
As a Development Engineer, I worked j
primarily on product improvement on various fossil-fueled boilers.
The last assignment, for over four years, was as a Construction Supervisor for the retubing of the main heat exchangers and graphite cooling heat exchanger at "N"
- Reactor, Hanford, Washington.
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5 From 1971 to 1972, I was employed by J. A. Jones 6
7 Construction Company as a QA Engineer and Assistant QA Manager for the waste processing and storage facilities at 1l Hanford, Washington.
I had as many as 40 QA and QC Engineers 0
t 2
under my supervision.
l e a 4i From 1972 to 1974 I was employed as Lead QA Engineer
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o6l by Burns and Roe, Inc. on WPPSS Nuclear Project No. 2, 7
8 Richland, Washington.
I had 10 QA Engineers under my super-l vision, with the responsibility to perform audits and sur-1i veillances over the various site construction contractors.
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3I I was also responsible for review and approval of the con-s4 h 25 l struction contractors' QA Manuals and procedures.
16 !
7l For six months, during late 1974 and early 1975, I 28 9.
was employed as a Consultant by Control-X Corporation, 10 '
Richland, Washington.
I prepared QA Manuals and procedures 37 for various contractors for use in nuclear construction.
34 l Since May, 1975, I have been employed by Ebasco.
16 l 5t My assignments have been Senior QC Supervisor, Construction 37 l 19li Superintendent, QA Supervisor, Quality Program Site Manager, 3
40 l and QA Manager of a satellite corporate office.
I have been
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involved on WPPSS Nuclear Project Nos. 3 & 5, Laguna Verde, 1.3 1 Waterford Unit 3, and Tokamak Fusion Test Reactor prior to 4
my assignment to the STP.
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E4 g5 Q.5 Mr. Geiger, what are your responsibilities for the 6
A.5 (JG):
As Project QA Manager for STP, my respon-0!
sibilities include assuring th'at HL&P and other major project 1i 2l participants have an effective QA program that fulfills the 3l 4
requirements of 10 CFR Part 50, Appendix B and the regula-5l 6l tory commitments for STP.
Additionally, I have responsibility 7
8 to assure that STP subcontractors and suppliers have a quality program which meets those requirements of Appendix B 0
Tli and the regulatory commitments which are appropriate to 22 13 i their scope of work.
These responsibilities are fulfilled 4l 5!
through a complex program including review and approval of 6!
7l various documents, audits, surveillances, monitoring, and 28 9,
inspections performed by my staff.
1O'I 31 Q.6 Mr. Krisha, what are your responsibilities for the QA program for the STP?
34 l A.6 (DK):
In my capacity as QA Manager of the Houston 56 l 5i Area Office, I have been involved with the STP beginning 37 '
with preparation of Bechtel's proposal to HL&P for STP.
I la !
9 40 i was designated as the Project QA Manager for STP during the transition.' In my capacity as Project QA Manager, I am 43 i responsible for managing and directing all of Bechtel's j
QA/QC activities at STP.
I receive support in specialized 47 g8 9
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,5 areas such as the ASME Code and welding processes from P6 L7 Bechtel's Codes and Standards group and in metallurgy from 8
9 Bechtel's Materials and Quality Services group.
I was also 0-l responsible for the preparation of Bechtel's portion of the 2l STP Quality Assurance Program Description (QAPD), Revisions t
3 i 4i 2 and 3, and Bechtel's Project Quality Program Manual (PQPM).
45l i6l Mr. Lester Hurst, who is presently the Project QA Manager 7i o8 !
for Bechtel at the San Onofre Nuclear Project, will soon be b9'i O
assigned to replace me as Bechtel's STP Project QA Manager.
1 In that position, he will receive technical and administrative 62 3
direction from me.
4 5
Q.7 Mr. Hawn, what are your responsibilities for the 6!
38 l 9!
A.7 (CH):
As Quality Program Site Manager, I am 10 I lgt responsible for the overall management of the Ebasco QA/QC department at STP.
I was involved with STP beginning with ja4 l the preparation of the proposal made by Ebasco for perform-l5 t6l ing the role of constructor on STP.
Where necessary, I call l87 18 on support from the various specialized disciplines within 9
p0 the Ebasco QA Department, such as materials application, 1I 2:
NDE, and codes and standards.
3!
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Q.8 Panel, what is the purpose of your testimony?
4 A.8 (JG, DK, CH):
The purpose of our testimony is to 6
7 describe the QA program for the STP as it has been recently 8
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5 revised to incorporate the new roles of Bechtel as architect-engineer and construction manager and Ebasco as constructor.
7 0l Q.9 Is the revised QA program described in Revision 3 9l0i of the STP Quality Assurance Program Description (QAPD) 1i 2l which was submitted to NRC by letter of March 9, 1982?
3i 4l A.9 (JG, DK, CH):
Yes.
5l 6l Q.10 What was your involvement in the preparation of 7;
8l Revisions 2 and 3 to the QAPD?
9 0 ;l A.10 (JG):
The QAPD consists of three Parts.
Part A, 1
which summarizes HL&P's QA Program for the STP, describes 2
3l the responsibilities and quality requirements pertinent to 4
5 HL&P and all other participants including Bechtel, Ebasco 6l 7I and Westinghouse.
Part B describes Bechtel's Quality Program 28 9
for STP, which consists of Bechtel's Topical Report, BQ-TOP-1, 1O l i
Revision 3A, as modified to reflect Bechtel's specific 31 responsibility at STP for engineering, procurement, con-34 l struction management and QA.
Part B also describes the responsibilities of Ebasco and other contractors for sub-37 l mitting to Bechtel, for approval, a quality program which is la t 9!
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40 l consistent and compatib1e with the applicable sections of Bechtel's Topical Report.
Part C describes Ebasco's Quality Program for STP, which consists of Ebasco's Topical Report, 5
ETR-1001, Revision 10A, as modified to reflect Ebasco's 46 7
responsibility at STP for construction and associated QA/QC 8
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5 senices, and to be consistent with the HL&P a d Bechtel QA I0 Programs.
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I had responsibility for the preparation of the 9
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HL&P section (Part A), as well as responsibility for approv-1!
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ing the Bechtel and Ebasco portions, Parts B and C, respec-3!
4l tively.
Revision 2 of the QAPD was written after Bechtel f
5 6
had been selected as architect-engineer and construction g
manager, but prior to the selection of Ebasco as constructor.
9 Thus, it contained Part A, for which I was responsible, and 0
1i Part B, which I reviewed and approved.
2!
l 3i After Ebasco was selected as constructor it-prepared 4
5 Part C, which I also reviewed and approved; and minor revisions 6!
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were made to Parts A and B to reflect the division in the l
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scope of responsibilities between Bechtel and Ebasco.
These l31 then comprised Revision 3 of the QAPD submitted to the NRC by letter of March 9, 1982.
l34 l (DK):
Prior to beginning preparation of Part B, IS i 6l I met with Mr. Geiger and other HL&P and Bechtel personnel 13 7 la to iden(ify those portions of BQ-TOP-1, Rev. 3A, that would 9
%0 l need to be modified in light of HL&P's overall QA program at STP and to reflect Bechtel's responsibilities at STP.
My 3'
staff then prepared Part B, which, after review and approval by HL&P, was submitted to NRC as part of Revision 2 of the se 7
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2 l 3 H4 QAPD.
After Ebasco was selected as constructor, we made
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minor revisions in Part B as described by Mr. Geiger.
We also reviewed Part C to assure that it satisfied the require-
!9 0i ments of Bechtel's QA program.
1!
,2 (CH):
As Quality Program Site Manager for Ebasco
'34l at STP, I was responsible for preparation of Part C of the 5
6 QAPD.
I reviewed Parts A and B of the QAPD, and analyzed both the interface requirements among Ebasco, Bechtel, and HL&P, and the role Ebasco would play as the constructor.
I, P1I along with my staff, modified ETR-1001, Rev. 10A, the Ebasco 1
3i Nuclear Quality Assurance Program Manual, to make it consistent 41
[
and compatible with Parts A and B.
The draft revision of l
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ETR-1001, Rev. 10A, modified for STP, was submitted to both Bechtel and HL&P for review and comment, and their comments o
1 were resolved in the final version of Part C contained in l
134 i Q.11 To the best of your knowledge and belief, are the I
l contents of Revision 3 of the QAPD a true and correct des-37 cription of the QA program for the design and construction 40 l of the STP?
A.ll (JG, DK, CH):
Yes.
Q.12 Mr. Geiger, since Mr. Frazar's May 1981 testimony concerning the program for accomplishing QA, including QC, 46 I
n:
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I ll I2 l34 I5 on STT, has there been a basic change in the framework of the QA program at STP?
18 A.12 (JG):
Since Mr. Frazar's testimony, HL&P has 9
O replaced B&R as architect-engineer and construction manager l2I with Bechtel and has replaced B&R as constructor with Ebasco.
3 4i Coincident with these changes, HL&P has modified, and, in my 5l 6l judgment, improved the QA program at STP.
7i 8j As described in more detail below, Bechtel, which O
has a vast amount of nuclear experience, is implementing a l
l QA program at STP based upon successful Bechtel programs in place at other projects.
As architect-engineer and con-25 {
struction manager, Bechtel has the responsibility not only 7
- for its own QA program, but also for assuring that Ebasco, l28 l the constructor, ha's an acceptable program.
Verification of 31 implementation of both Bechtel's and Ebasco's program is 3
achieved through a series of document reviews, surveillances, l34 l audits, and redundant inspections by Bechtel.
Thus, except 15 i l 6I in those areas in which Bechtel will have first-line QC 37 l responsibilities in the field, there is an additional level (40i of QA review of construction that did not exist when one 1}
2 contractor performed all of these functions.
As constructor, 3
4 Ebasco has the primary responsibility for its own QA/QC 5
6 program, including responsibility for first-line inspection 7
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5 of Ebasco activities.
As discussed in more detail below, t 6 7
Ebasco additionally assures appropriate implementation of l
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its program through document review and approval, surveil-0!
lance and audit.
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2l As co-owner and licensee, HL&P has ultimate respon-3; 4i sibility for the entire Project QA program and fulfills that l5l 6j responsibility through various actions.
Included are review 7i 8!
and approval of selected documents, an aggressive surveil-O lance and audit program (which is discussed in more detail in response to Questions 14 and 19) and a limited program of redundant inspection of selected characteristics / components.
l25 Q.13 Since Mr. Frazar's testimony,.have there been any 56 i
. 7l changes in the way the HL&P Project QA staff is organized?
l28 If,so, please describe.
l31 A.13 (JG):
A chart depicting the current HL&P QA
.j organization for STP is attached as Figure 1.
As shown on l34 I Figure 1, the Project QA Manager will report to the Manager, QA.
Since the latter position is now vacant, I report 137 8
directly to the Executive Vice President.
l40l The major responsibilities of the groups shown on 1!
2l Figure 1 are unchanged.
Minor revisions have been made to 3i 4
some group titles to reflect their duties more accurately, e.g., Quality Systems is now entitled Quality Systems /
7 Administration.
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There has been only one other minor change in the 5
7 HL&P Project QA organization since Mr. Frazar's testimony.
O The position of Licensing Support Project QA Supervisor was 0{
eliminated because it was determined that its functions 1!
2 could more effectively be assigned within the STP Licensing 34!
Department.
5l 6l 7i Q.14 Since Mr. Frazar's testimony, have there been any p8 9
significant changes in the way that HL&P Project QA performs 0
j'1 l its QA program verification activities?
2
3 A.14 (JG):
There has been one change which, in my 4
5, judgment, is significant.
The process of verifying compliance 6l 7!
to the QA program requirements by HL&P Project QA is currently 8l 9;
accomplished by the implementation reviews described in Mr.
i lO' Frazar's testimony.
All HL&P audits of the Project, including t
audits of performance of both HL&P and the contractors, are l34 j performed by the HL&P corporate QA Audit Section.
I6 l Si We are now in the process of establishing an audit 37 {
l program to be implemented by the Project QA staff.
As l40 l described in A.19, under this program the Project QA staff will perform audits instead of implementation reviews and 14 3 the corporate QA Audit Section will audit only HL&P QA activities on the Project; the audit of Bechtel and Ebasco l46 activities will be performed by HL&P Project QA.
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Implementation reviews and audits are virtually 6
identical; both require written checklists, documented 8
results, etc.
The difference is in the qualifications of 9
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the personnel who perform them.
Briefly, stated, personnel 1 1!
2!
who perform audits must be certified to the requirements 3
4 specified in ANSI N45.2.23.
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6l Since in order to be certified as an auditor, an 7i 8j individual must have performed a specific number of audits 9l under the direct supervision of a certified lead auditor, 0;
1i the certification of Project QA staff members as auditors 23I will occur gradually over the course of 1982.
During that 41 5l period, the Project QA staff's verification activities will 6l 7!
include a combination of implementation reviews and audits, 28 l 9;
in acco'rdahce with a plan that will insure complete QA Program verification of the activities on the site.
31 Q.15 Mr. Krisha, please describe the Bechtel QA organiza-34 !
tion for the STP.
IS i 6l A.15 (DK):
Figure 2 shows the Bechtel Project QA
)
53l.
37 organization.
Bechtel's QA program for STP is under the 9!
40 l auspices of Bechtel's Los Angeles Power Division (LAPD).
The Manager of Division QA reports directly to the Vice-43 '
President and Division General Manager.
The Manager of Division QA is at the same managerial level in the organi-46 7
zation as the Managers of Division Engineering, Construction 8
49 a10 I gl l m
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5 and Procurement.
He receives technical assistance from the 6
7 Manager of QA for Bechtel Power Corporation.
The LAPD Manager of Division QA has a staff of managers that includes 1l!
the QA Manager for the Houston Area Office, who is respon-0
'2l sible for a number of projects, including STP.
The QA
'3l 4i Manager for the Houston Area office provides technical and
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6l administrative direction to the STP Project QA Manager.
7igj The Project QA Manager, with the assistance of 9
higher levels of QA Management and the support of Division 0
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QA staff, is responsible for assuring the satisfactory 2:
3l implementation of the Project Quality Program.
The Project,
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QA Manager coordinates with the Project Manager on day-to-day 6!
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Project matters relative to the Quality Program.
He is 28 19.
responsible for the QA/QC Engineers' Project activities and 0l1 f r reporting the status of the Quality Program to management.
3 The Bechtel STP QA organization consists of three 14 3
i sections reporting to the Project QA Manager.
The three 16 l 5i sections are supervised by two Project Quality Assurance 37 Engineers (PQAE's) and one Project Quality Control Engineer
%0 i (PQCE).
The Design Office PQAE is responsible for assuring 43 k the orderly and adequate implementation of the Quality Program in the Design Office.
This is accomplished through 46 7
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review, surveillance, and audits of engineering and procure-6 7
ment activities.
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The site PQAE is responsible for assuring that construction activities (including field procurement) comply 3{
with approved Quality Program and engineering requirements.
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These responsibilities are accomplished by surveillance of 5'
6 in-process and completed work, reviews of documentation, and 7i 8j audits for Quality Program compliance.
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The PQCE is responsible for performing QC inspec-1 tions associated with Bechtel's job site activities, such as 3i receipt, storage and maintenance of permanent plant items.
41 5I He is also responsible for verifying the effectiveness of i
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1 7j the contractor's QC program.
This is accomplished through 28 (
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surveillance and redundant inspections of selected Work 0 l 31 activities which had previously been accepted by the con-tractor's QC personnel.
3 34 !
Under Bechtel's Quality Program the Project QA 5i 37jl Manager has stop work authority over quality-related portions 6
3 of STP activities.
This authority is also delegated to the 9
40 l Design Office and site PQAE's and to the site PQCE.
1I 2
Q.16 Please describe the overall Bechtel Quality 43 i 4
Program at STP, including the programs applicable to engineer-5 ing, construction management and procurement.
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]4 A.16 (DK):
The overall Bechtel Quality Program is g5 6
7 based on the Bechtel Topical Report, BQ-TOP-1, Rev. 3A.
This Topical Report describes tl}e measures used to comply 0!
with 10 CFR Part 50 Appendix B, Quality Assurance Criteria 1!
!2{
for Nuclear Power Plants and Fuel Reprocessing Plants.
I Additionally, the Topical Report describes the Bechtel l
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6j Position concerning certain QA related Regulatory Guides.
l 7i 8l The Topical Report and the Bechtel Regulatory Guide posi-0 I
'i tions have been approved by the Nuclear Regulatory Commission.
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The Bechtel South Texas Project Quality Program R2 :
l 3i Manual (PQPM) is based on the Topical Report.
Unique con-4 struction management subjects are addressed, as well as j
unique Project requirements.-
Bechtel QA is responsible for (1) review and l
approval of quality-related procedures and instructions, and (2) audit and surveillance of the activities and documen-
$4 l tation of organizations and individuals involved in the i
f implementation of the Quality Program.
$37 Bechtel management is notified by reports and l00 l during management meetings of the status and adequacy of the Quality Programs of divisions and projects.
Management 3'
external to the QA organization and levels above the Project review the status and adequacy of the Quality Program imple-
!66
]7 mentation through audit reports, management staff meetings d!
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and an annual review meeting which covers the status of the quality programs of the various Bechtel divisions and projects.
8 Action items are determined during these review meetings, 9
l responsibility established and results reported to the f2 division Vice President and General Managers.
34i Individuals associated with the QA organization or 5l l
6l who are responsible for verifying quality of activities are l
organizationally independent of those who perform those 9
activities.
O;l I
1i The following is a general dercription of the l
2 3!
quality programs applicable to engineering, procurement and 41 l
construction.
Engineering Project Engineering, directed by the Project Engineering Manager, is responsible for all Bechtel engineer-ing design work performed by and for the Project and for 1
34 l checking and review functions performed on the Project.
The Project Engineering Manager is also responsible for any 37 special design work conducted off the Project and for requiring
'0l that it be subjected to the same degree of checking and 4
control as that conducted on the Project.
Key design work 43 '
is also reviewed off the Project by personnel on the staffs of the Chief Engineers.
Bechtel QA is responsible for 46 17, conducting audits, surveillances and document reviews of 8
s9 engineering work activities.
I m
-u-
\\
l l
1 2
el3 4
Procurement 5
6 Procurement specifications for materials and 8
equipment are prepared by Engineering and reviewed by QA for 9
0 adequacy of specified QA program and documentation require-(1i b(2 ments.
The need for quality surveillance is determined by 34i Engineering based on the complexity and importance of the e5 6
material or item.
Procurement contracts are awarded only after a 9l supplier's capabilities to meet the Project's quality require-0; "1 i ments have been verified and his Quality Program or plan has E2 3i been reviewed by Bechtel Engineering and Procurement Supplier
-4i e5 l Quality (PSQ) and concurred with by QA.
6
,7 After contract award, PSQ performs surveillance 8
9 and inspection of supplier activities, and reviews completed
{0 !
supplier quality verification documents at the supplier's 2
facility.
Receiving inspection of items, including review 3
k4 I of records not previously examined by PSQ, is performed by 5l 6l Bechtel's QC group at the construction site.
27 3
The supplier's conformance to purchase documents dl is determined by PSQ based on surveillance reports, periodic 0
1' audits, jobsite receiving inspection results, construction
'l 3'
nonconformance reports and reports from other divisions and projects.
7 8
39 0l 1l l
n m-g l
t
I lI2 1
3 j4 QA m nitors this process and performs audits and 5
6 surveillances to assure effective implementation.
QA has 7
8 the authority to stop supplier work and shipments until 9
required corrective action has been taken and verified.
12 !
Construction 3!
4';
The Bechtel Construction Management organization 5l 6j is responsible for the overall construction program for the STP.
Its functions consist of planning, scheduling, monitor-9f ing and evaluating the Ebasco and contractor construction 0;
1i and QA/QC activities.
Construction Management's activities 2!
3l are performed.in accordance with approved procedures and are 4
5 monitored by Bechtel QA through audits and surveillances.
6!
7{
Each contractor, including Ebasco, is held res-8l 9;
ponsible for performing construction work within the scope O i of his contract in accordance with approved procedures and 2
his Quality Program.
The Ebasco and contractor QA organi-3 1
34 l zations are responsible for first-level inspection of their I6 l S
1 respective work.
The Ebasco and contractor QA organizations 37 '
are responsible for audits and surveillances of their res-40 l pective work and QC activities.
Bechtel QA is responsible for conducting audits, surveillances and selected redundant 43 '
inspections of the Ebasco and contractor work and QA/QC I45 activities.
46 578 49 to l 1l
" E
I lI2 l
1i l
3 34 55 Q.17.
Mr. Hawn, please describe the Ebasco QA organi-6 7
2ation for the STP and summarize how Ebasco will perform QA 8
of construction at STP.
0 A.17 (CH):
The Ebasco QA organization is fully described 1l:
2{
in Part C, QAPD and is shown in Figure 3.
QA is placed in 3;
4l the Ebasco site organization such that it is independent 5l 6l from the various construction departments.
As Quality 7i 8l Program Site Manager, my line of reporting is to the Corporate 9
Chief QA Engineer in Ebasco's New York office.
I coordinate 0
1l with the STP Site Manager only to assure communication and 2!
3I administrative continuity.
Thus, the Quality Program is 4
5 free of organizational constraints, such as scheduling or 6!
7i production pressures which could compromise quality related 8
9, activities.
O I 31 Ebasco's STP QA organization consists of three basic groups, QA, QC and Quality Records, each headed by a 34 Site Supervisor who reports to me.
The QA Supervisor, the ISl 6l QC Supervisor and I all have stop work authority.
37 The QA Group is responsible for performing planned 40 and scheduled audits of Ebasco activities.
The QA group, in conjunction with our New York office, performs trend' analysis 4
of nonconformance reports, deficiency reports, etc., to 55 identify trends adverse to quality.
Where indica'ted by 46 trend analysis or other conditions, supplemental audits will 49,
af 0 l 31l
-sz-
I lI1 l 2!
3l 4
be performed.
Trend analysis may also be the basis for 5
6 corrective action requests to be generated by the QA group.
178 The QA group is the basic contact point between Ebasco and 9
HL&P, Bechtel and NRC audits and inspections, and is res-12 j ponsible for assuring timely and proper responses to those l
organizations for any deficiencies identified.
15'!
6[
The QC Group is responsible for performing inspec-tions and witnessing or performing examinations and tests of Ol; 9
all Ebasco nuclear safety-related construction activities.
1i The NDE laboratory and the on-site calibration laboratory 2 ',
3i report to the Ebasco QC Site Supervisor.
All inspections, 4
5 examinations and tests are required to be documented.
6!
7; The Quality Records Group is responsible for 8f assembling documentation packages, verifying the complete-0!
ness and accuracy of the records, providing adequate safe-1 2!
guards and retrievability of records while under Ebasco 3l 4l control, and for transmitting completed records to HL&P.
5i 6l Ebasco QA/QC personnel are required to be qualified 37 {
and certified to ANSI N45.2.6, ANSI N45.2.23, and SNT-TC-1A, 40 l as appropriate to their work assignments.
ht QA/QC of construction will be performed in accor-43 i dance with Part C, QAPD and the implementing Ebasco procedures.
545 All implementing procedures will be submitted to and approved 46 by Bechtel prior to use.
These will include QC Procedures 49 l E
I E
l i
L L
i 2i I3 1
4 5
(QCPs), which specify methods and equipment to be used in 6
performing inspections, examinations, and tests; and the 8
documents to be used to provide for recording data and 9
0l results from the inspections, examinations, and tests.
1!
2l QCP's also provide for control measures such as inspection, l
3l examination, and test status, control of nonconformances, 4
5l!
t 6
and corrective action.
Qualification and certifications of 7li QC personnel is also covered.
8 0l; 9
Ebasco also uses QA Procedures (QAPs), which h1 i specify methods of planning, performing, and documenting
'2 3'
audits and surveillances performed by Ebasco QA.
Auditor 4
i 5
qualification and certification, corrective actions, trend 6!
7{
analysis, procedure review and approval, and similar QA
~
i 8l 9!
activities are also specified in the QAPs.
l0l Q.18 Mr. Geiger, how does HL&P fulfill its ultimate responsibility for the proper implementation of the QA M4 I program at STP?
5I
, 6l A.18 (JG):
HL&P fulfills its ultimate responsibility i37 '
for proper implementation of the QA program at STP through a
$0 l system of reviews of engineering, procurement, construction management and construction activities.
$3 I our first action was our review and approval of the QA programs of the Project participants.
All sections 06 7
of the STP QAPD, Rev. 3, were approved by my office prior to 8
29l i
g
-w l
l L
1 2
[3 l 4'
submittal to the NRC.
The Bechtel Project Quality Program 5
Manual (PQPM) was reviewed and approved by my office.
The 8I 9l Ebasco Project Quality Assurance Manual,(PQAM) (which ic
{
identical to Part C of the QAPD, 'Rev. 3 ) was also reviewed 2:
and approved by Bechtel.
3l 4
HL&P conducts an audit, surveillance, and selective E
redundant inspection program described in more detail below.
6 f
This helps assure that the procedures and programs of Bechtel,
'9!
Ebasco and other contractors not only accurately reflect 0;
1i regulatory requirements, but are in fact being rigorously
'2!
3l implemented.
Close monitoring is achieved by daily activities 41 l
of various QA personnel, as well as regularly scheduled l
weekly meetings to review any outstanding problems or situa-tions.
These revie,ws comprise HL&P's performance overview l
of the Bechtel and Ebasco QA Programs.
Where a need for corrective action is identified, HL&P interfaces with Bechtel, 34 l and Bechtel is responsible for achieving any necessary correction of the Bechtel and Ebasco quality programs.
37 l Other important activities include Bechtel's and
'0j Ebasco's preparation of monthly trend reports, which are 4
submitted to my office for review and analysis, and HL&P's 43 '
preparation of a trend analysis report.
Moreover, periodic reviews of the quality status of the Project are performed se by executives of the three participants as well as by Project
$9,
management.
10l 1l
- 2. ~> -
t
t 1
2
! 3 4
I5 The performance of the HL&P QA staff is assessed 1 6 l
by the HL&P corporate audit staff on at least an annual 7
8 basis, and an independent assessment of the STP QA program j
Ol will be conducted annually throughout the life of the project.
1!
l2l For 1982, this assessment will be performed by a group of
'3 4
four utilities, which HL&P selected based on their successful 5l 6l nuclear construction projects.
7i i
g Q.19 How does HL&P conduct its audit and surveillance f the STP QA program?
O 1!
A.19 (JG):
In the response to Question 14, I described 2:
3!
how the audit program by HL&P Project QA was being introduced 41 5!
in conjunction with the continuing implementation review 6['
7 activities.
My response to this question, describes the 28 l program once a sufficient number of HL66 Project QA staff 19 i 0 I 31 f members are certified to conduct all of the audits.
The HL&P audit program at STP consists of several 3
34 parts.
The Project QA staff, under my direction, is developing 15 l t
6l an Audit Plan and an Audit Schedule.
The Audit Plan identifies 37 l 18 i the number of audits which are required to cover all the 9!
40 l major components of the STP QA Program.
The schedule specifies the time and frequency of these audits.
Both are prepared 43 for an annual period and are reviewed quarterly, at a minimum.
5 Additional or supplemental audits may be added at any time.
46 7
In general, the Project audit program is designed to accomplish 8
9 JO gl j I
-ze-g
l i
'l
\\
2i 3
4 5
several key objectives.
First, to verify that there is an effective system which takes the commitments made in specific 8
regulatory documents (e.g.,
the SAR, 5 50.55(e) reports) and F90!
accurately translates them into " work-directing" documents.
1!
2!
Second, to verify that the " work-directing" documents are I
3 4
being effectively implemented.
Any single audit may be 5l 6!
designed to accomplish either or both of these two objectives.
In addition to the Project QA staff activities, 9
the Houston QA management audit staff plays an important 0;
1 role for the STP.
The management audit staff has the res-2 3
ponsibility for conducting audits of those HL&P organizations 4
5 which provide services to the STP, such as the procurement organization.
The management audit staff also performs audits of the HL&P STP Project Manager and his staff and of HL&P STP Engineering.
Additionally, the management audit i
staff performs audits of the QA program of my organization.
34 I Close coordination exists between the management audits staff and my organization.
We are aware of their 37 audit plan and schedule, may provide input to any specific 40 l audit plan, attend the pre and post audit conferences, and are available for consultation during the conduct of any 03 specific audit.
In addition to the audit program, there is also an 26 77 aggressive HL&P surveillance program for STP.
Aggressive 8i 59 !
-2;-
E l
L I
l 12!
[4 3 I 5
surveillance, in my judgment, is the key to maintaining
{6 day-to-day control of activities.
Such a program requires 7
8 that the individual QA specialists / engineers spend a signif-FS0l icant amount of time witnessing activities, monitoring 1!
l2 performance and checking documentation.
They provide a 34l constant owner QA " presence" on the site.
This aggressive l5l surveillance strengthens and reinforces the audit program.
6l gf Finally, the HL&P QA staff will perform limited 0l redundant inspections of selected characteristics / components.
l 9
1i These characteristics / components will be selected from 2!
3i previously accepted work at the jobsite, as well as at
{
4 l 5 vendor facilities.
6{!
The overall program which I have just described 7
!28 i gl will provide assurance that the Quality Program for STP is being effectively implemented.
Q.20 Please describe how the QA program is being l34 I implemented with respect to current STP caretaker and tran-sition activities.
l37 l A.20 (JG):
By April 1, 1982, Bechtel and Ebasco com-Ig tI 9
l40 l pleted the assumption of responsibility from B&R for caretaker I
I*l '
activities at the job site.
Bechtel's responsibilities 3
j include receiving, inspection, warehousing, and maintenance ls for those items which are not released to construction.
146 U 7 8
M9,
CO l 1l r
-;o-E
f I
1 2
3 Ebasco has responsibility for the maintenance of all items 5
6 that have been issued for construction and/or installed.
8 These activities are conducted according to approved 9
tol Bechtel and Ebasco procedures.
Personnel performing these 1!
12 !
activities are appropriately trained, qualified and certified.
3!
4l Both Bechtel and Ebasco perform surveillances, audits and 5'
6 inspections over the activities within their respective scopes of work.
In addition Bechtel QA performs surveil-0l 9
lances, audits, and redundant inspections over Ebasco's 1i work, as does HL&P QA with respect to both Bechtel's and 2}
3!
Ebasco's programs.
4 5
Continuing transition activities in the areas of 6i 7!
engineering, procurement, construction and QA are being 8
conducted by Bechtel in general accordance with the transition 9
0 program (as described in the testimony of Messrs. Goldberg, 2
Lex and Crnich), the QA program and implementing procedures.
53 41 All activities are subjected to audit and surveillance by 5l 6l both Bechtel and HL&P.
37 Q.21 Mr. Krisha, please describe the expected Bechtel la9 40 l manpower levels in staffing QA for the STP and provide a 1i 2l brief description of the backgrounds of key personnel.
43 l A.21 (DK):
It is anticipated that Bechtel QA manpower 4
5 for'the STP will peak at the following levels:
46 17 8
49 101l l
E
__a-
g 9 O
/
l 2l 3 I
{4 5
Management.
~6I
_.7{
1 Project QA Manager El
{94 Design Office ^-
0 1 Project QA Engineer
"' j 1 QA Supervisor 34!
6 QA Engineers
~
5' 6 A
/
Field 1.6 i 1 Project QA Engineer
\\
3 QA Supervisors 10 CA Engine 3rs 3l 1 Project QC Engineer 4
h5 i Lead QC Engineers 30 QC Engineers
~
28 i
~
~
Key Bechtel QA personnel on the STP include the 9';
0
}31 following:
'l The Project QA Manager will be L. W. Hurst.
34 Mr. Hurst is presently assigned as the Project QA Manager at S6l SONGS Units 1, 2&3.
Mr. Hurst has.eight years of nuclear 37 8
QA experience with Bechtel.
He has held assignments on the 9
i 40 l Kuosheng Nuclear Project at both the design office and jobsite.
Mr. Hurst has a Bachelor of Science degree in 43 Industrial Technology.
The Design Office PQAE is K. R.-Dotterer.
Mr.
Dotterer has 16 years of QA/QC experience, including seven
,* 0 l 1l
,k I
g
-au-t
I t
l 1!
2l 3!
years with Bechtel.
He was previously assigned to the 6
Houston Area Office where he was the PQAE for the Nelson and 8
Parish projects.
Prior to that assignment, Mr. Dotterer-was 9
0' a Senior QA Engineer and assistant to the PQAE on the Vogtle 1i 2l Nuclear Project.
Mr. Dotterer was also assigned as a Procure-3l 4l ment Supplier Quality Supervisor for the Midland Nuclear 5i 6l Project.
Prior to joining Bechtel, Mr. Dotterer was a commissioned officer in the U.S. Navy.
9 The jobsite PQAE is W.
F. Houston.
Mr. Houston 0,
1i has 17 years of nuclear QA/QC experience, the last one and 2
3l one-half years with Bechtel.
He was previously assigned as 41 5l a QA Supervisor to the Grand Gulf Nuclear jobsite where he 6!
7l was responsible f6r the site audit and surveillance program.
28 9
Prior to working for Bechtel, Mr. Houston worked for Gibbs Hill, Inc. as a Senior QA Engineer; New York State Electric 31 2
and Gas Inc., on the New Site Nuclear Project as a Supervising 3
34 j Senior QA Engineer; and General Electric Corporation in N
5 6
various engineering and QA positions.
Mr. Houston has a 37 l 3l B.A. in Industrial Management.
19 !
40 l The PQCE is R. A. Meggison.
Mr. Meggison has 15 I
I.l l years of QA/QC experience, including five years with Bechtel.
- I 43 i He was previously assigned to the SONGS Units 2 & 3 Nuclear 15 4
Project where he was Assistant Project QC Manager responsible 46 7
8 9
0l 1l 1
-u-E
I I
L I
1!
2l
[3 !
5 for welding, piping, mechanical, pipe supports and receiving inspection disciplines.
Prior to joining Bechtel, Mr. Meggison 8
spent 23 years in the U.S. Navy.
9 Q.22 Mr. Hawn, please describe the expected Ebasco 2
manpower levels in staffing QA for the STP and provide a 34i brief description of the backgrounds of key personnel.
5I 6j A.22 (CH):
The expected peak Ebasco QA/QC manpower 7;l levels are as follows:
8 1 Quality Program Site Manager 0
1i 1 QA Site Supervisor 2!
3 8 QA Engineers (various disciplines) 4 5
1 QC site Supervisor 6I 7l 4 Lead QC Engineers
'8 10 QC Supervisors 9.
O'I 31 4 QC Engineers 2
138 Sr. Inspectors, Inspectors and Technicians 34l 1 Quality Records Supervisor 5i 6l 6 Quality Records Reviewers 37j 3
174 Total 9
i 80i Key Ebasco Quality Program personnel on the STP 1'gf include the QA Site Supervisor, R. A. Cummings, and the QC Site Supervisor, R. P. Grippardi.
5 Mr. Cummings has over 11 years experience in 16 7:
design, construction, and QA of power plants, both fossil 8l 9t
'O i 1l
.s t -
1 2i
-'3!
4 !
5 and nuclear.
For the past five years he has been employed by Ebasco as a QA Engineer, Principal QA Engineer, and QA 8
Supervisor.
He has worked at Laguna Verde and W.A. Parish 9
l "O !
Unit 8, and performed preliminary QA functions on Allens 1!
Z2 l Creek.
Prior to being employed by Ebasco, Mr. Cummings was 13 i4i employed by Pennsylvania Power & Light Co. as an engineer 5
6, and Project Engineer on the Susquehanna nuclear plant.
He 7;
8l has a BSCE from Drexel University and is a Registered Profes-9!
sional Engineer in the state of Pennsylvania.
O; 1l Mr. Grippardi has over 12 years experience in 2
3j power plant QA, both fossil and nuclear.
He has been employed 4l l
by Ebasco for the past seven years, and was previously employed by Ebasco from 1964 to 1968.
He has held the l 8l positions of Ass't. QA Engineer, QA Engineer, QA Site Super-f f31 visor, and QC Site Supervisor.
Projects Mr. Grippardi has been involved with include W.A. Parish Unit 8, Allens Creek, 134 l Laguna Verde, Angra Unit 1, St. Lucie Unit 1 and H.B. Robinson I
l Unit 2.
Mr. Grippardi also worked for Westinghouse for 37 {
three years as a Senior QA Engineer.
Mr. Grippardi has a (40 i Bachelor of Engineering degree from Stevens Institute of Technology.
43 1 Q.23 Mr. Geiger, please describe the expected HL&P manpower levels in staffing QA for tihe STP and provide a 7
8 N.9Ol 1!
Pi
I L
'1 2
~
3 "4
5 brief description of any changes in key personnel since Mr.
?6 L
Frazar testified.
7 0I A.23 (JG):
The HL&P Project QA peak manpower level
~9l i 0!
for STP is expected to be as follows:
professionals 25, 1!
2I supervisors 7, manager 1.
That is a total i
'3I 4 '.
of 33.
,5l l 6l The principal change in key Project QA personnel 7igj since Mr. Frazar testified, is that I replaced Mr. Frazar as 9
the Project QA Manager.
Mr. Frazar reassumed his previous
- 1f duties as the Corporate QA Manager for HL&P, but that posi-23I tion has been vacant since February 1, 1982 when he assumed
,4i
%5 I new responsibilities as Manager, Engineering Assurance 6l 7j Department.
h8 l 9!
Additionally, changes in Project QA staff include 0i 31 the following:
Mr. D. R. Keating is now the General Super-2 visor for Quality Engineering replacing a consultant who 34 l previously held that position; Mr. D. F. Bednarczyk is now 5i 6I the Civil / Structural Supervisor replacing Mr. R. Carvel, who 37 l 3:
resigned; Mr. T. J. Jordan has been reassigned from Quality 9!
}0 l Systems Supervisor to Supervisor of Design /Procurament QA 1'
2{
replacing Mr. H. G. Overstreet who was reassigned to Supervisor, QA Training and Administration in the corporate QA department; 5
and Mr. J. W.
%6 Estella was appointed Supervisor of Quality 7
Systems / Administration to replace Mr. Jordan.
8 9,
1 Ol 1j t
-h-o
"1,
~2l l 3I "4'I 5
Mr. Keating has over eight years of nuclear QA experience, including almost eight years with Consumers 8!
Power Company at its Midland Plant.
He is a Certified Level,
l 9l
'0!
III Inspector and a Certified Lead Auditor.
He received a 1!
l2l Bachelor of Science degree in mechanical engineering from 3i4l Michigan Technological University in 1970.
The qualifications 5i 6l of the others are summarized in Applicants' Exhibit 39.
Q.24 Panel, please describe the status of development g
0l of QA procedures and other preparation for implementation of 9
2,!
the QA program for design and construction activities at 1
3i STP.
4l 5!
A.24 (JG):
HL&P is currently implementing its QA 6l u7 j Program for design and construction activities at STP.
The 8l 9i Project Quality Assurance Plan (PQAP) has been issued.
Implementing Project QA procedures have been issued and 31 2
appropriate training conducted on those procedures.
The 134 l audit plan and schedule are in the approval process.
Cer-I6 l S
tification of QA personnel as auditors is currently under 37 '
way.
In the interim, as I have described, the audit plan l40 i will be implemented in conjunction with an implementation h
review plan to assure that full coverage is maintained until l43i sufficient auditors are certified.
(DK):
The Bechtel PQPM and QA procedures relatiing (46 "7
to audits, surveillance and document reviews have been 8
0l 1l Pl g* l
'l 2l 3I "4
issued.
At the site, Work Plan Procedures (WPP) and QC 5
Instructions (QCI) for Bechtel caretaker activities have 8
been issued.
WPP/QCI's for Bechtel construction management
-9 1
activities are in preparation and many have been issued.
In l12 j the Design Office, Engineering Department Procedures and 3i 4l Procurement Procedures have been issued.
Training of Project l 5l 6'
personnel is in process and will be ongoing throughout the life of the Project.
g 0l:
9 (CH):
Ebasco has identified those QA and QC 1i procedures required for implementation of Part C, QAPD.
3!
Similarly and concurrently, construction and administrative procedures have been identified.
The QA/QC procedures 6!
"27 l required for caretaker activites have been completed and 28 i 9l approved by Bechtel.
Preparation of the remaining pro-0i j
cedures has been scheduled, based on planned construction 2
activities, to be completed and approved sufficiently in 93 l l4l advance of the construction activity to insure adequate 5i 6l training of QA/QC personnel in the implementation of the 37 '
procedures.
l40l Q.25 Panel, does the revised QA program for STP comply with the requirements of Appendix B to 10 CFR Part 50?
43 i A.25 (DK):
Yes, it does.
As stated earlier, the Bechtel STP Quality Program is based on the Bechtel Topical 46
'7 Report and other LAPD Quality Program documents which address 8
b9 10 i1l l
lg'
-x-
\\
'1l 2
l 3!
"4 I 5
Appendix B of 10 CFR Part 50 and specific ANSI Standards and NRC Regulatory Guides.
The Project Program contains all the 8
Quality Program elements of these documents but is more 9
j 0l expansive and detailed.
The requirements of Appendix B of 1i l 2' 10 CFR Part 50 are individually addressed in the Project 3
4 Quality Program Manual (PQPM), with the same prefix identi-
}5l 6l fication numbers as the criteria of Appendix B and the sections of the Topical Report.
This provides rapid reference g
from one document to the other.
The PQPM also contains an 1
identifying matrix of quality related manuals of all Bechtel 23I STP organizations.
The matrix provides rapid cross reference 4
5, from Appendix B and Bechtel quality related manuals to the 61 7{
PQPM.
(CH):
Yes, it does.
The Ebasco Quality Program i
131 Manua f r STP is based on ETR-1001, Ebasco Nuclear Quality 2
Assurance Program Manual.
ETR-1001 was originally approved k34 l by the NRC in 1975.
The current revision to ETR-1001, Rev. 10A, was approved by the NRC in June, 1981.
For STP, l37 ETR-1001 was modified to delete those sections that apply l40l only to responsibility for design, procurement, and con-I 1'
2 struction management and to make it consistent and compatible 43 with both HL&P's PQAP and Bechtel's PQPM for STP.
The 5
Ebasco Quality Program Manual contains a matrix identifying l46 the manual sections that show compl*_ance with the 18 criteria l49 l of Appendix B, 10 CFR 50.
0l 1l l
-M-L
i "1!
2 I r3!
L 1
4' 5i (JG):
Yes, it does.
Revision 3 of the QAPD "6
7 summarizes how the HL&P, Bechtel and Ebasco portions of the STP QA program satisfy each of the 18 criteria of Appendix Ol B.
I supervised and participated in the preparation of that 1:
- 2; document.
Preparation of that document required me to 3I 4i evaluate the STP QA Program and how it fulfills each of the 5l l 6j criteria of Appendix B and the various Regulatory Guides and 7;
8, industry standards that further interpret and elaborate upon Appendix B.
I am fully satisfied on the basis of my evaluation 1!
that the new program fully complies with the applicable 22 3l requirements.
41 25 l Q.26 Panel, what reason is there to believe that the 6l
_7l revised STP QA program will be properly implemented?
~28 l 9;
A.26 (DK):
Bechtel QS assures the quality adequacy of 0 !
g!
work and program implementation by document reviews, Project system and product audits, QA staff management audits, 34 surveillances, and monitoring activities.
Important quality 15 l i
6!
information is received from other Bechtel projects through l37 '
Division QA staff.
Such information describes problems l40I arising at other projects and defines the investigative and 1'
' 2l corrective actions taken.
In this way, the STP has the 3i 4
benefit of total Bechtel experience.
5 Information from these sources is reviewed and 7
used to provide Division and Project management with a 8
E 9 report of the status and adequacy of the Project quality
'0l 1l i
I I
-a
I l!
I2i 3!
i 5
program.
The status and adequacy of Project QA program 6
implementation is regularly transmitted to Project and 8
Division management for review and evaluation.
The informa-9 0l tion is transmitted using Project audit and status reports, 1i 2:
reports of significant deficiencies and substantial safety 3!
4 !
hazard defects and associated corrective and preventative 5i actions.
Reports to date indicate that the QA program at 6!
STP is satisfactory and is being properly implemented, and 9f the steps I have described will assure that satisfactory 0;
1i performance continues.
2' 3j (CH):
The Ebasco QA program for STP is based on 4i 5l ETR-1001, the Ebasco Nuclear Quality Program Manual.
This 6!
7!
program is currently in force at Waterford Unit 3 and WPPSS 8l Nuclear Projects Nos. 3 & 5, and has proven to be effective.
9; 0l Key points of the program that assure it will be satisfac-1 2
torily implemented at STP are:
3 34 j Independence of Ebasco QA/QC personnel from 15 i construction.
6l 37 l Stop Work authority for QPSM, QASS, QCSS.
8!
9l Planned system of inspections, audits, and 40 l surveillances, with reports going to management.
1'
., l Top management support.
'l 43 '
Access to top management of all QA/QC per-sonnel (open door policy).
46 Trend analysis cf nonconformances distributed 17 company-wide.
8 49 d0 l 31!'
I E
l El B2 14 l-3 5
Required documentation of all inspections, audits, and surveillances.
6 Planned Management audits of overall program effectiveness.
9 0!
Adequate training of all personnel in quality 1!
requirements.
2}I Staffing with adequate numbers of qualified 3
4 I personnel.
5 6
(JG):
Our testimony has explained, in some detail, the QA program for STP.
We described how the require-9 ments documents, such as the QAPD and the PQAP, were generated 21 l and approved.
We discussed the initiation, review and 2
3 approval of implementing procedures, and provided a descrip-4 5
tion of how the program will function.
The aggressive audit 6!
7{
and surveillance program by HL&P was fully explained.
The 9
QA program at STP bears the same hallmarks as viable programs mplemented by other utilities for projects that have been 31 13 2
successful.
The program is managed by experienced and 34 l capable personnel who will ensure it is diligently executed.
Feedback from my staff, review of documents, and my own 37 l personal contacts with QA management and personnel of Bechtel 13 :9!
40 l and Ebasco give me the highest confidence that the QA program at STP will be successfully implemented.
43 14 5
46 TBH:01:C 67j8 l 49 !
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