ML20052F144

Affidavit of Dn Chapman in Support of Summary Disposition of Citizens Assoc for Sound Energy Contention 5 Re Qa/Qc. Prof Qualifications Encl

ML20052F144
Person / Time
Site:	Comanche Peak
Issue date:	05/07/1982
From:	Chapman D TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20052F140	List: ML20052F139 ML20052F144 ML20052F149 ML20052F151 ML20052F153 ML20052F155 ML20052F162 ML20052F170
References
NUDOCS 8205120161
Download: ML20052F144 (15)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION yet \\ h9 03 BEFORE THE ATOMIC SAFETY ANd3, LICENSING BOARD

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In the Matter of- )

TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 and COMPANY, ~et al. ) 50-446

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(Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating Licenses)

AFFIDAVIT OF DAVID N. CHAPMAN REGARDING THE QA/OC ORGANIZATION AT COMANCHE PEAK I, David N. Chapman, being first duly sworn, do depose and state: I am employed by Texas Utilities Generating Company in the position of Manager, Quality Assurance. As ,

such, I am familiar with the Quality Assurance /Ouality Control Organization (OA/QC) for the construction of the Comanche Peak Steam Electric Station. The purpose of this affidavit is to demonstrate that an effective OA/OC Organiza-tion has been maintained at Comanche Peak during the cons-truction phase. Further, this' affidavit will demonstrate that Texas Utilities Generating Company has taken all measures necessary during construction to assure that l

l the OA/QC Organization remains effective and meets the applicable NRC Regulations. A statement of my educational and professional qualifications was received into evidence at the hearings in December 1981 (Tr. at 509) and is attached hereto as Attachment 1 for the convenience of the Board.

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8205.20161 820510 PDR -DOCK 05000445 i o PDR

4 I. HISTORY OF OA/OC AT COMANCHE PEAK From the beginning of the Comanche Peak project, Texas Utilities Generating Company ("TUGCO"), as the lead Applicant, has maintained ultimate responsibility for the construction OA program at Comanche Peak. In this position, TUGCO carefully monitors and/or conducts all aspects of the OA program to assure that construction of the facility is performed in conjunction with an effective OA/OC program.

Initially, Brown & Root, Inc., the Construction Manager /

Constructor, managed the OA/OC program applicable to work per-formed by them and their contractors for the early stages of the .

project. Brown & Root met its responsibilities in this role. As the project progressed and became more complex, TUGCO determined that a more aggressive program was essential to meet TUGCO's i

OA/OC goals for the project. One area where more aggressive action was needed was Brown & Root's implementation of its OA program with respect to its suppliers. In July 1977, TUGCO initiated action requiring TUGCO involvement in all Brown & Root t

l vendor release inspections. Subsequently, upon assessing the I

success of such direct involvement by TUGCO, it was determined' j

that TUGCO would provide overall technical management of OA/OC functions for CPSES except for those activities under the i

jurisdiction of the ASME Boiler and Pressure Vessel Code,Section III, Division 1 (ASME Code). Although Brown & Root i

retained functional managment of ASME Code work under their I

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OA program, TUGCO continued to have the ultimate responsi-bility for all such work.

The measures taken to restructure the QA organization at Comanche Peak brought about significant improvement in the quality function for the project. A positive relation-ship has developed among OA, QC, and construction personnel resulting in a teamwork approach that focuses attention on identifying and solving problems. In sum, the measures have resulted in a OA/QC Organization tailored specifically for and responsive to the needs of the Comanche Peak project.

In addition to TUGCO and Brown & Root, Gibbs & Hill, as Architect-Engineer, and Westinghouse Electric Corporation

( "We s tinghou s e " )', as nuclear steam supply system ("NSSS")

i supplier, provide OA programs for activities within the scope of their responsibilities. Their basic roles have remained constant throughout the life of the plant and are described more fully below.

II. CURRENT QA/QC ORGANIZATION AT COMANCHE PEAK l

A. Principal Organizations As discussed above, TUGCO, as the lead Applicant, has ultimate responsibility for the engineering, design, procure-ment, construction, and quality assurance activities for Comanche Peak. TUSI 1/ is designated by TUGCO to have the 1/ Te'xas Utilities Services, Inc..("TUSI") is the engineering service organization for Texas Utilities Company.

4 authority to conduct the required engineering, design, procurement, and construction technical support activities for CPSES, including implementation of the QA program at the site.

Gibbs & Hill provides TUSI with certain engineering, design, and procurement services as requested. Gibbs &

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Hill provides the OA program for QA activities within its scope of work. Westinghouse provides the QA program governing work done on the NSSS structures, systems and components. As discussed above, Brown & Root manages the OA program for ASME Code work and may perform other QA functions ,

as requested by the TUGCO Quality Assurance Manager.

An organization chart for the project QA organization is presented as Attachment 2.

B. Responsibilities of OA Organization

1. TUGCO/TUSI The TUGCO QA organization was established to provide effective control of safety-related activities at Comanche Peak. This control extends to all organizations performing services affecting nuclear safety during the engineering, design, procurement, and construction. phases. The TUGCO/TUSI QA organizations participating in the design and construction phase of nuclear power plants are shown in Attachment 3.

This chart illustrates the organizational structure and lines

of reporting for each organization. These are described in the corresponding sections.

a. TUGCO Quality Assurance Division The TUGCO QA Division is responsible for developing and assuring the implementation of the CPSES QA program for design and construction. The QA Division is headed by the Manager, Quality Assurance. He reports directly to the Vice President, Nuclear. This independent reporting arrange-ment assures that safety considerations are not influenced by cost and scheduling. He reviews the performance of the QA program on a regular basis with the Vice President, Nuclear, reporting on quality status and the overall ef fectiveness of the QA program.

In addition, the Manager, Quality Assurance has the duty and authority to identify quality-related problems; to initiate, recommend or provide solutions; and to verify the implementation and effectiveness of solutions. He has authority to "stop work" in the engineering, design, procurement, and construction phases. He also supervises the Site QA Supervisor at Comanche Peak who is responsible for assuring the implementation of the QA program on a daily basis at the site. The QA Manager has the following qualifications:

(1) Minimum of 10 years experience in design, construction, or operations of power plants.

(2) College degree in an engineering discipline (BS minimum).

(3) Demonstrated ability to manage people and projects.

(4) Knowledge of quality assurance requirements for nuclear plants including a minimum of one year experience in the implementation of a nuclear quality assurance program.

(5) Registered Professional Engineer.

b. TUSI Project Management For the Comanche Peak project, the Vice President and Project General Manager (TUSI) coordinates and controls engineering, procurement, and constructica activities. He is responsible for cost and schedule and for implementing -

design and construction quality requirements. The Vice President and Project General Manager reports to the f

Executive Vice President of TUSI.

Reporting to the Vice President and Project General Manager is the Engineering and Construction Manager who is responsible for project design, engineering and procurement.

These activities are normally delegated to Gibbs & Hill, Inc.,

Westinghouse and other contractors / vendors. TUSI, however, l

l retains overall responsibility for these activities and performs design functions as necessary.

2. Gibbs & Hill TUGCO has retained Gibbs & Hill to provide experienced personnel as needed to assist TUGCO OA with the overall OA program. The Gibbs & Hill Project Manager

directs the engineering, design, and procurement functions and establishes and maintains project relations with TUSI.

The Project Manager is responsible for assuring that esta-blished procedures are implemented. The Project Manager has the authority to "stop work" on engineering and design activities performed by Gibbs & Hill.

The Gibbs & Hill OA Department, headed by the OA Manager, assures the implementation of the Gibbs & Hill OA program through engineering and design audits. Further, the OA Manager is responsible for development of detailed -

QA procedures. He can require the Project Manager to exercise his "stop work" authority. Further, the OA Manager audits the activities of independent Design Review engineers who determine compliance with safety-related design concepts. The OA Department is completely separate and functions independently from those persons or groups having specific project design, scheduling, or budgetary responsibilities. Independence is maintained further by having the OA Manager report to the Vice President.

Attachment 4 is a chart of the Gibbs & Hill OA Organization.

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3. Brown & Root Brown & Roo't provides the OA program for ASME Code construction and other QA functions as may be requested by the TUGCO OA Manager. Brown & Root's OA personnel have the freedom to identify quality problems, to recommend solutions, and to verify that solutions have been implemented. This organization has sufficient independence and authority to carry out the program in an orderly, effective manner. It employs a documentation system which provides necessary record retention and access capability. The Brown & Root OA organization for its Houston office and for site activities

• is shown in Attachment 5.

The Brown & Root Project OA Manager is responsible for implementation of the B&R OA Manual requirements in the fabrication and installation of ASME Code,Section III, Division 1 systems and components. Direction of all site l OA and OC activities other than ASME Code work is provided by the TUGCO Site OA Supervisor. For technical and adminis-i trative supervision of ASME' Code work and for administrative i

supervision in all other areas, the Brown & Root Project

! OA Manager reports to the Brown & Root QA Manager in Houston.

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i C. Organizational Interfaces For Comanche Peak, TUGCO/TUSI has established the interfaces of the participating organizations in the OA program which are summarized as follows:

1. Brown & Root Project GA Manager reports to the Brown & Root OA Manager for technical and administrative supervision of ASME Code work, and for administrative supervision in all other areas. Direction of the Brown &

Root Project OA Manager in areas other than ASME Code work is provided by the TUGCO Site OA Supervisor.

2. Construction site inspections are performed under the direction of TUGCO and Brown &

Root (ASME Code work only) or by contractor ,

or subcontractor.

3. Periodic audits and surveillances of site Oc and construction activities are performed by TUGCO to verify conformance.

j 4. Vendors are required to provide internal, independent OA programs unless working under the TUGCO OA program.

5. TUGCO OA and/or its consultants or agents conduct vendor audits, surveillance and inspections to verify performance.

6. Westinghouse provides the OA program for NSSS components.

7. Gibbs & Hill provides the OA program for design and engineering.

8. TUGCO OA periodically audits Westinghouse, Gibbs & Hill, Brown & Root and internal TUGCO/TUSI safety-related activities.

9. Brown & Root periodically audits their ASME OA program onsite, as required.

In summary, the OA/QC organization established for the construction of th'e Comanche Peak facility has been care-fully structured and functions to provide assurance that applicable codes, statidards, and regulatory requirements are met and to assure the safe operation of the facility.

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' DavicVS.' Chapinan 1 'Q Subscribed to and sworn before me this 7 day of May 1982. .:-

4 Notary Public

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GLENDA BENSON, N:tary Public g in and for Da!!as Cou ty, xas

- = , My Commission Spir" -

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n ATTACEMENT 1 DAVID N. CHAPMAN STATEMENT OF EDUCATIONAL AND PROFESSIONAL QUALIFICATIONS POSITION: Manager, Quality Assurance FORMAL EDUCATION: 1959-1964, B.S.M.E. Mechanical Engineering, Texas A&M University EXPERIENCE:

1976 - Present Texas Utilities Generating Company, Dallas, Texas, Manager, Quality Assurance. Responsible for assuring effective implementation of the CPSES Quality Assurance Program in nuclear safety-related activities including design, procurement, construction and operations.

1972 - 1976 Texas Utilities Service Incorporated, Dallas, Texas, Project Engineer. Duties included re-

• viewing selected CPSES design documents, PSAR drafts and environmental report drafts. Addi-tional duties included such special projects as site evaluation studies for future genera-ting plants.

! 1967 - 1972 Texas Electric Service Company, Forth Worth, Texas, Senior Engineer, General Office En-gineering Department. Activities included review of design and construction specifi-cations, drawings, and purchase documents for four gas / oil fired generating units.

i l 1966 - 1967 Texas Electric Service Company, Forth Worth, Texas, Associate Engineer, Handey Steam Electric Station. Involved primarily in

, training through " hands-on" operation, main-l tenance, and plant chemistry duties.

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