ML20090K042
| ML20090K042 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 10/07/1983 |
| From: | Wells J DUKE POWER CO. |
| To: | |
| References | |
| A-009, A-9, NUDOCS 8405230590 | |
| Download: ML20090K042 (14) | |
Text
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UNITED STATES OF AMERICA o
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7u NUCLEAR REGULATORY COIGIISSION h
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BEFORE THE ATOMIC SAFETY AND LICENSINGLBOARD9 h,\\ s X[
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4/ g h DUKE POWER COMPANY, et al. )
Docket Nos.
50-413-
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50-414 (Catawba Nuclear Station,
)
Units 1 and 2)
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TESTIMONY OF JAMES R. WELLS 1
Q.
STATE YOUR NAME AND BUSINESS ADDRESS.
2 A.
James R.
Wells, Duke Power Company, 422 S.
Church Street, 3
Charlotte, North Carolina 28242.
4 Q.
STATE YOUR PRESENT POSITION WITH DUKE POWER COMPANY 5
AND DESCRIBE THE NATURE OF YOUR JOB.
6 A.
My present position is assistant to the Executive Vice President for
.,o 7
Engineering and Construction, Mr.
W.
H.
Owen.
The duties 8
involve special assignments relating to the management of the 9
various departments reporting to Mr. Owen.
10 Q.
DESCRIBE YOUR PROFESSIONAL EXPERIENCE AND 11 QUALIFICATIONS,
INCLUDING YOUR PRIOR POSITIONS HELD 12 WITH DUKE POWER COMPANY.
13 A.
I have a Bachelors and Masters Degrees in Civil Engineering from 14 Georgia Institution of Technology.
I am a registered Engineer in 15 North Carolina and South Carolina.
I have been employed by Duke 16 Power for 26 years.
I have held several positions within the 17 Construction Departraent and I was Corporate Quality Assurance 18 Manager for 8 years beginnir.g in February 1974. For the past 1 19 years I was an on-loan employee of Duke Power assigned to the 20 Institute of Nuclear Power Operations (INPO) to assist in developing t'q/
21 their Construction Project Evaluation Program.
I 8405230590 831007 PDR ADOCK 05000413 l
C PDR t
1 returned to Duke in my present job on August 1, 1983.
I have
- V 2
attached my Resume to my testimony as Attachment I which sets 3
forth my professional experience and qualifications in more detail.
4 Q.
DESCRIBE YOUR INVOLVEMENT WITH WHAT WE NOW REFER TO AS 5
THE WELDING INSPECTOR CONCERNS AT CATAWBA.
6 A.
The concerns first surfaced while I was Corporate QA Manager.
7 The pay classification of welding inspectors at each of Dukes 8
nuclear facilicites was lowered as a result of a study made by the 9
Duke Personnel Department.
This pay reclassification resulted in a 10 lower pay range for welding inspectors.
The pay reclassification 11 was announced in July 1981.
Inspectors at the various facilities 12 disagreed with the reclassification, and some inspectors pursued the 13 matter through the company Recourse procedure.
During the 14 processing of these recourses, a number of inspectors at Catawba j
15 expressed some concerns that went beyond the pay issue and 16 appeared to raise questions about the quality of construction and 17 the safety of the plant. These concerns were first expressed to me 18 and Gail Addis of the personnel department sometime shortly after 4
19 July 1981 while we were involved in processing the pay recourses.
20 Q.
DID YOU PARTICIPATE IN ESTABLISHING THE POSITION OF 21 WELDING INSPECTOR AT DUKE POWER COMPANY?
q 22 A.
Yes.
23 Q.
DESCRIBE THE CIRCUMSTANCES SURROUNDING THE CREATION 24 OF THE WELDING INSPECTOR POSITION.
25 A.
Prior to the start of construction of its first nuclear plant, the 26 Oconee Station, Duke Power did not have a welding inspection 27 program.
The line supervision was responsible for ensuring that b
28 welds were of satisfactory quality.
During the construction of the l
-2 *
~
1 Oconee Station the NRC's predecessor, the AEC, required Duke to b
2 develop an inspection program for safety related activities.
In 3
response to the AEC, we established in 1967 an inspection program 4
at Oconee.
This program called for inspectors to have either 2 5
years prior experience as an inspector or as a welder. The initial 6
welding inspectors were those with two years welding experience, 7
since Duke, given the fact that the inspector program was just 8
comencing, did not have any in house inspectors with two years 9
experience. These welders were placed in the quality control 10 organization, which at that time was part of the Construction 11 Department.
12 Q.
HAVE THESE QUALIFICATIONS CHANGED?
13 A.
Some changes have been made since we first began inspecting welds C
14 at Oconee.
In the e arly 1970's the Americe.n National Standards
! (
j 15 Institute (ANSI) c;andard on qualification of inspectors was
{
16 published.
This stsndard Nt5, 2-6 required a certain amount of 17 experience and training for inspectors.
When this standard was 18 published, all of our inspectors met the experience requirements t
because they had been doing inspections for some period of time.
19 20 The ANSI standard did not result in a change in the 21 qualifications for inspectors make the process of certification more l
22 formal and they required additional documentation.
Subsequently, 23 in April 1974 Duke formally committed to meet this ANSI standard.
l 24 Q.
WAS PRIOR WELDING EXPERIENCE ALWAYS ONE OF THE 25 REQUIREMENTS FOR THE INSPECTOR JOB?
26 A.
As noted above, prior welding experience was never an absolute 27 requirement for the job.
It was one of the ways an individual 28 could meet experience requirements.
The ANSI standard outlined.-
_m-1 the qualifications necessary to be a welding inspector.
One of S
2 those qualifications was that an inspector have a certain amount of 3
experience, and that could be obtained in a number of ways.
It i
4 could be gained by being a welder, being an inspector, or working 5
under the direction of an inspector.
After the standard was 6
published, in the mid-1970 timeframe we began establishing training 7
programs to qualify inspectors who did not have previous welding 8
experience.
9 Q.
HOW DID DUKE ASSURE THAT ITS WELDING INSPECTORS HAD 10 THE PROPER QUALIFICATIONS AND CREDENTIALS AFTER THE 11 ANSI STANDARDS WERE ESTABLISHED?
12 A.
From the very beginning of our. inspection program, Duke had 13 inspectors who were qualified. It has been our practice in the Duke 14 QA program to review new standards and adopt them, if applicable, 15 as soon as practical.
This is what we did with the standards for 16 welding inspectors. When this standard was adopted by Duke, all 17 of the inspectors qualifications were reviewed to be sure they met 18 the requirements of the standard.
When new irspectors were 19 certified, their training program consisted of classroom instruction 20 and on-the-job training to be sure that they met the standard.
21 Q.
DID THESE CHANGES IN THE QUALIFICATIONS FOR WELDING 22 INSPECTORS RESULT IN LESS QUALIFIED WELDING INSPECTORS?
23 A.
No.
In some ways it strengthened their qualifications. Aside from 24 teaching them to determine adequacy of the welds,- the training 25 program gave the inspectors some insight into the reasons welds are 26 rejected and why it is necessary to observe certs.in characteristics j
27 of the welding process.
While we feel that the original inspector C
I qualifications were entirely adequate, the later training built on this 2
and made better inspectors.
3 Q.
WHEN WERE YOU APPOINTED CORPORATE QUALITY ASSURANCE 4
MANAGER?
5 A.
February 1,1974.
6 Q.
WAS THIS A NEW POSITION?
7 A.
Yes.
8 Q.
HOW WAS THE QUALITY ASSURANCE FUNCTION HANDLED AT t
9 DUKE POWER PRIOR TO YOUR ASSUMING THE NEWLY CREATED 10 POSITION OF CORPORATE QUALITY ASSURANCE MANAGER IN 11 1974?
i 12 A.
For many years it was handled exclusively within each department.
13 In 1973, Mr. W. S. Lee took on the additional duty as Corporate QA Manager to coordinate the QA functions. At that time Mr. Lee's 14 15 position was Senior Vice President of Engineering - Construction.
j 16 Q.
WERE YOU INVOLVED IN THE ORIGINAL ORGANIZATION AND I
17 STAFFING OF THE QA DEPARTMENT?
18 A.
Yes.
19 Q.
I' LEASE DESCRIBE THE INITIAL ORGANIZATION AND STAFFING.
20 A.
Initially most of the people doing QA functions in the several 21 departments such as Design, Construction and Production were i
22 transferred to the newly formed QA Department and continued to do 23 their same jobs.
Some functions were combined for better f
u
I utilization of people.
Essentially the same people performed the 2
same. fobs they previously performed,
but with the new 3
organization, they were all in the same department.
4 Q.
DESCRIBE - THE INITIAL QA ORGANIZATION AT THE CATAWBA 5
SITE.
6 A.
There was a Senior QA Engineer at the site who was responsible for 7
the functional direction of the QA program i.e. assuring that the 8
plant was being built to meet established quality standards.
This 9
included the QA direction of the inspectors, the review and 10 approval of procedures, the review of the paperwork and the 11 surveillance of work in progress.
Administratively, the inspectors 12 were on the payroll of Construction and received their day to day 13 instructions from the supervision of that Department.
We referred 14 to this as administrative direction. Simply put, QA was responsible 15 to see that the inspections were done in compliance with the 16 requirements; Construction was responsible to see that the 17 inspections were performed in a timely manner consistent with their 18 need to schedule work.
19 Q.
DID THIS QA ORGANIZATION INCLUDE THE QUALITY CONTROL 20 INSPECTORS?
21 A.
No, the QC inspectors were in the Construction Department.
22 However, they were subsequently transferred to the QA department 23 in January 1981.
24 Q.
WERE YOU INVOLVED IN THE DECISION TO TRANSFER THE QC 25 INSPECTORS FROM THE CONSTRUCTION DEPART!IENT TO THE QA 26 DEPARTMENT?
O j
O 1
A.
I was involved in some discussions with Mr. Owen and the Vice Q
2 President for Construction, R. L. Dick, in late 1980 concerning the 3
transfer of QC inspectors to the QA Department.
4 Q.
WHY WERE THE INSPECTORS MOVED TO THE QA DEPARTMENT?
5 A.
In the original organization of the QA Department it was decided to 6
put the inspectors in the Construction Department for administrative 7
reasons.
It was felt that their work could be better scheduled by i
8 Construction and that the job would flow smoother.
I am not 9
thoroughly familiar with the reasons for the transfer since it was 10 initiated by R. L. Dick, the Vice President for Construction.
I 11 agreed to the transfer at the time.
From the standpoint of a 12 satisfactory QA program, it did not matter whether the inspectors 13 were in the Construction Department or the QA Department.
I 14 believe that a QA program can function either way.
There are 15 certain advantages to assigning inspectors to either department. I 16 have seen the inspection program work either way very successfully 17 in other companies and I do not believe that this transfer had any 18 material affect on the QA Program.
19 Q.
WERE YOU INVOLVED IN THE PROCESS WHICH SETS THE PAY 20 CLASSIFICATION FOR INSPECTORS?
21 A.
Yes.
22 Q.
DESCRIBE WHAT He.S OCCURRED WITH RESPECT TO THE PAY 23 CLASSIFICATION.
24 A.
I do not know what happened prior to 1981 on the pay issue 25 because I did not have responsibility for pay administration of the 26 inspectors prior to that time.
In early 1981 when the inspectors 27 were transferred to QA, their pay classification was reexamined.
28 The Personnel Department was asked to study the pay of the L
1 welding inspectors at the construction sites as well as several 3
2 categories of inspectors at the operating plants.
This study was l
3 done in the first half of 1981.
4 Q.
WHAT WAS THE RESULT OF THE 1981 STUDY OF THE WELDING 5
INSPECTOR PAY CLASSIFICATION BY THE CORPORATE 6
PERSONNEL DEPARTMENT?
7 A.
This study resulted in a reclassification of the position and a 8
reduction in the pay grade of the inspectors.
9 Q.
HOW DID YOU COMMUNICATE THE DECISION OF THE CORPORATE 10 PERSONNEL DEPARTMENT CONCERNING PAY RE CLASSIFICATION 11 TO THE WELDING INSPECTORS?
7 12 A.
We held a series of meetings with the inspectors at each of Dukes 13 nuclear facilities.
The meetings were not limited to Catawba l
14 inspectors.
I 15 Q.
WHAT WAS THE RESPONSE OF THE WELDING INSPECTORS TO 16 THIS PAY RECLASSIFICATION?
17 A.
They disagreed with the reclassification, and were of course 18 disappointed and did not seem to understand the reasons for the 19 decision.
They said that they did not believe the people making 20 this recommendation really understood the job of an inspector.
21 They believed there job required higher skills and knowledge than l
22 the category ~ they - had been reclassified to, and therefore they i
23 should have higher pay.
24 Q.
WHAT DID THE INSPECTORS DO AFTER THE RECLASSIFICATION l
25 WAS ANNOUNCED AND YOU HAD MEETINGS WITH THEM TO 26 DISCUSS THE DECISION?
27 A.
They expressed their disagreement with. the decision.
They felt 28 that the reclassification was wrong.
A number 'of inspectors.,
1 initiated a Recourse under the company procedure to seek review of O
i i
V 2
the decision to reclassify their job.
3 Q.
WERE YOU INVOLVED AS CORPORATE QA MANAGER IN 4
RESOLUTION OF THESE RECOURSES?
)
5 A.
Yes.
6 Q.
DESCRIBE YOUR INVOLVEMENT AT EACH LEVEL OF THE '/ELDING 7
INSPECTOR PAY RECOURSE.
8 A.
The Company recourse process has three levels of review.
The l
9 first level recourse involved a response by me.
I told. the 10 inspectors, who were from Dukes various nuclear facilities, that a 11 professional group had evaluated the positions and pay grades, and 12 that I had confidence in the work and conclusions of the group. I 13 expressed my confidence in the inspectors' work and asked their 14 understanding.
15 The second level of the recourse involved the Employee 16 Relation Department.
Gail Addis, Director of Employee Relations, 17 was involved at this second level, or Step 2.
The purpose at Step 18 2 is to reevaluate the decision with the assistance of the employee 19 relations staff.
Ms. Addis and I interviewed the inspectors at each 20 of Duke's nuclear facilities, to be sure we understood their 21 recourses.
The decision on the recourse was not changed at the 22 second level.
I 23 At the third level, my involvement was minimal. The decision 24
-at this point was with the P1 esident of the company.
I was kept 25 informed of what actions were being taken, but I had no role at 26 this stage.
27 Q.
WHAT HAPPENED WITH THE PENDING RECOURSE?
l 9
1 1
A.
It was decided by the Duke Power Company President.
The 2
position reclassification was upheld.
3 Q.
DURING THESE INTERVIEWS WITH WELDING INSPECTORS, DID 4
MATTERS OTHER THAN THEIR VIEWS ABOUT THE FAY 5
RECLASSIFICATION COME TO YOUR ATTENTION?
6 A.
- Yes, some concerns that appeared to affect the quality of 7
construction were brought out at the second level of the recourse.
8 Q.
WHAT DID YOU DO AFTER THESE CONCERNS CAME TO YOUR 9
ATTENTION?
l 10 A.
I asked the inspectors to let me have a list of their concerns and I 11 would investigate them. Thereafter, I reported the matter to W. H.
12 Owen. A task force was appointed by W. H. Owen to investigate 13 the concerns.
j 14 Q.
DESCRIBE YOUR INVOLVEMENT WITH THE INITIAL TASK FORCE, 15 WHAT IS NOW REFERRED TO AS TASK FORCE I.
16 A.
The task force interviewed me but I had no other involvement with p
17 them.
18 Q.
THE CONCERNS EXPRESSED BY THE WELDING INSPECTOR WERE 19 INITIALLY CHARACTERIZED AS CONCERNS AFFECTING THE 20 QUALITY OF WORK OR THE SAFETY OF THE CATAWBA PLANT.
21 IN YOUR VIEW, DID THE CONCERh3 EXPRESSED BY THE WELDING 22 INSPECTORS A?'FECT THE QUALITY R THE SAFETY OF THE 7
23 CATAWBA PLANT?
24 A.
Not in any way.
I believe the primary concern was pay. Indeed, h
25 the concerns that were raised to me were raised in the.ontext of 26 justifying higher pay; they were not brought to me as safety 27 isr'n.s.
- l. C l
10
1 Q.
IN YOUR VIEW, DID THIS EXPRESSION OF CONCERNS BY TliE 2
WELDING INSPECTOR INDICATE THAT THERE WAS A BREAKDOWN 3
IN THE QA PROGRAM AT CATAWBA OR THAT THE QA PROGRAM 4
WAS NO LONGER WORKING AT CATAWBA?
5 A.
No.
6 Q.
HAVE YOU HAD ANY OTHLR INVOLVEMENT WITH THE WELDING 7
INSPECTOR CONCERNS, THE TASK FORCE INVESTIGATIONS, OR 8
THE IMPLEMENTATION OF RECOMMENDATIONS FROM THE 9
VARIOUS TASK FORCES?
10 A.
No.
11 Q.
. ARE YOU FAMILIAR WITH THE 1981 SALP REPORT?
12 A.
Yes.
13 Q.
THE SALP REPORT RATES THE CATAWBA PROJECT "BELOW 14 AVERAGE", BASED IN PART ON CRITICISM OF THE QA PROGRAM.
l 15 IN YOUR VIEW, DOES THIS SALP REPORT INDICATE THAT THERE 16 ARE SIGNIFICANT OR SYSTEMATIC DEFICIENCIES IN THE QA 17 PROGRAM AT CATAWBA?
18 A.
No.
In my view the SALP rating does not indicate that there were i
19 systematic or significant deficiencies in the QA Program at Catawba.
4 20 Q.
WHAT IS THE BASIS FOR YOUR VIEW THAT THE SALP REPORT 21 DOES
.NOT INDICATE THAT THERE ARE SYSTEMATIC 22 DEFICIENCIES IN THE QA PROGRAM AT CATAWBA?
23 A.
The SALP rating did not take into account the level of activity at 24 the plant.
Rather it was based on the raw number of violations 25 which were recorded during the timeframe utilized by the NRC (i.e.
26 6-18 months prior to the issuance of the 1981 SALP Report). The l
27 more violations the lower the rating. However, the number of these 28 items is not indicative of an inadequate QA Phgram.
A larger I i
J' i
1 number of violations is common and expected if construction is 2
proceeding at a substantial pace as was the case during the time 3
the NRC ccnducted it review.
Also, the SALP Report does not 4
compare the status of construction at the various plants rated.
5 Q.
ARE YOU FAMILIAR WITH THE ACTIONS ~ TAKEN BY DUKE POWER 6
IN RESPONSE TO THE VIOLATIONS THAT WERE THE BASIS FOR 7
THE SALP EVALUATION?
8 A.
Yes.
9 Q.
DESCRIBE WHAT WAS DONE IN RESPONSE TO THESE VIOLATION.
10 A.
Each violation was handled as it was identified.
Some of these i
1 11 items were resolved two years before the SALP report. There was i
12 nothing specifically to be done as a result of the SALP report l
13 because all items were corrected when they were detected. I might 14 note that a glaring deficiency of SALP was its failure to take 15 Duke's corrective action into consideration in arriving at its rating.
16 Q.
DESCRIBE THE ROLE OF QC AND QA SUPERVISION AND THE 1
17 RESOLUTION OF NONCONFORMING ITEMS (NCI's) WHILE YOU 18 WERE CORPORATE QA MANAGER.
l 19 A.
When quality control inspectors detected an item for which they felt l
20 a nonconformance should be written, they completed an NCI form i
21 and routed it to their supervision.
After their supervision -
22 approved it, the NCI was then routed to quality assurance. If _ QC 23 supervision felt that the problem could be corrected in another 24 manner, it was their responsibility to void this NCI and handle'it in 25 another manner.
This, in no way, meant that the problem was not 26 corrected, but just that. it may have been done by another means.
27 All inspectors were instructed to pursue matters up through i
I 1
management if they felt that matters were not being corrected, or 2
NCI's were improperly voided.
3 Q.
IS THERE ANYTHING IMPROPER OR INCONSISTENT WITH A 4
SOUND QUALITY ASSURANCE PROGRAM FOR A SUPERVISOR TO 5
REVIEW A WRITTEN NCI BY AN INSPECTOR AND VOID THE NCI 1
6 BECAUSE IN THE SUPERVISOR'S JUDGMENT THE NCI SHOULD 7
NOT BE WRITTEN?
8 A.
No.
The supervisors are fully qualified to make decisions as to the 9
significance of any problem identified by the inspectors. The first 10 level supervisors had experience as inspectors.
Other levels of 11 supervision above the first line were similarly well qualified to make 12 judgments about the significance of items identified by inspectors.
13 In many instances there is a range of acceptability in the inspection 14 where judgement should be exercised to determine if a specific item O
t 15 should be nonconformed.
Supervisors are required to make these 16 judgements based on their familiarity with QA procedures, and 17 applicable requirements.
18 I might note that the QA program includes random inspections 19 and audits to identify any construction deficiencies that might not I
20 otherwise be identified. Such a process serves as a check on the 21 judgement of supervisors,
,f 22 Q.
HAS THE PRACTICE OF VERBALLY VOIDING NCI"S CONTINUED 23 AT CATAWBA?
24 A.
No.
25 Q.
WHAT PERCIPITATED THE CHANGE AND WHEN WAS THE CHANGE 26 MADE.
l 27 A.
I recommended to W. H. Owen in January 1982, but the practice 28 stopped because it.seemed to concern some inspectors.
13--
9 m
w
i 1
Q.
WAS RECOhBIENDATION ACCEPTED?
2 A.
Yes, and the practice was stopped in December 1981.
3 1
4 S
6 7
I hereby certify that I have read and understand this document, and 8
believe it to be my true, accurate and complete testimony.
9 1
M 12 es R. WeHs j
13 14 15 Sworn to and subscribed before me 16 this o? 3 day of September,1983.
l' O. Om D. Am 20 Notary Public 21 22 Commission Expires 7 /2.8 i
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