ML20127M256

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Affidavit of Ej Turner Supporting Applicant Motion for Summary Disposition of Joint Intervenors Contention 8 Re QA
ML20127M256
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 06/20/1985
From: Eric Turner
GEORGIA POWER CO.
To:
Shared Package
ML20127M179 List:
References
OL, NUDOCS 8507010167
Download: ML20127M256 (16)


Text

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UNITED-STATES OF. AMERICA NUCLEAR REGULATORY COMMISSION

-Before the Atomic Safety and Licensing Board On the matter of  :

GEORGIA POWER COMPANY, et al.,  : DOCKET NUMBERS

50-424 and 50-425

.(Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

AFFIDAVIT OF E. J. TURNER COUNTY OF BURKE STATE OF GEORGIA Before the undersigned officer duly authorized to administer oaths did appear E. J. TURNER, who after being

~ duly _ sworn, did state as follows:

1. My name is Ed Turner. My business address is.

Vogtle Electric Generating Plant, Route 2, Waynesboro, Georgia:30830. I am employed by Georgia Power Company as Vogtle Project Procurement Manager. In that position I am primarily responsible for the management and direction of activities of the Vogtle Project Procurement Group. I am a professional engineer. A summary of my professional qualifications and experience.is attached hereto as Exhibit "6A."

'2. I make this Affidavit in support of Applicants' Motion- for Summary Dispu :t tion of Joint Intervenors' Contention No. 8 (Quality Assurance). I have personal s

8507010167 850624 fR ADOCK 05000424 PDR L

knowledge of the matters stated herein and believe them to lue true and correct. I will describe the Procurement practices atLVEGP,;and I will include within that dis-cussion a description of the organizational responsibility relative to Procurement.

PROCUREMENT PRACTICES

3. Georgia Power Company Vogtle Project Procurement has overall management responsibility for the procurement of equipment,! material, and services for Plant Vogtle.

GPC ensures that. equipment, material and services ne-

cessary for. construction and Plant operation are delivere'd to the job site on time to meet construction schedules, and in conformance to purchase orders and specification requirements. The Vogtle Project Procurement Group pur-chases exclusively for the Project and has no other pro-curement responsibilities within GPC. VEGP Procurement is under the' direct management control of the Project Pro-curement-Manager (PPM) Vogtle who reports to the Vice

" President and General Manager Vogtle Project for Project direction, and to the Manager of Procurement and Traffic-GPC, for technical and functional direction.

4.- Procurement teams from GPC, Southern Company Ser-vices, Inc., ("SCS") and Bechtel Power Corporation-("Bech-

't e l " ) participate in Procurement' activities. These groups report either directly or indirectly to the PPM, and are assigned specific Procurement responsibilities.

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5. Each of the' participating Procurement groups is responsible for soliciting bids for specific kinds of equipment, material and services, and for either making purchase recommendations to'GPC or for actual purchase of the required items. Safety-related equipment and mate-rials are only purchased based on specifications developed and approved by Bechtel.

Commitments and Method of Implementation

6. The applicable requirements for Procurement are

-found in 10 C.F.R. 50 Appendix B Criterion IV (Procurement Document Control), and Criterion VII (Control of Purchased Materials, Equipment, and Services). The specific methods by which these requirements are implemented are described in several documents.

7. The Project Reference Manual, Part C, Sections 8 and 24, and Part D, Section 1-9, set forth requirements for purchase of material, equipment'and services for Bech-tel Procurement activities.
8. The Bechtel Power Corporation Supplier Quality Manual.provides the requirements for quality surveillance activities performed by the Bechtel Procurement Supplier Quality Department to determine supplier compliance with contractual quality requirements.
9. The Bechtel Power Corporation Contracts and Pur-

! chases Manual-establishes the accepted methods of imple-menting Bechtel. management policies and procedures

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o uniformly throughout Bechtel Procurement in'the formation of' contract and purchase commitments.

s 10 . - The Bechtel-' Power Corporation Expediting Manual contains general instructions which are intended tx) form the basic guidelines for expediting functions.

11. The_ Georgia Power Company Project Procurement

-Procedures Manual establishes the procedures and policies for GPC procurement' activities on the Vogtle Project.

12. The Georgia Power Company Field Procedures Manual establishes the procedures.and-policies for the re-

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-quisition of equipment, material and services by'GPC con-

-struction personnel.

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13. The Southern _ Company Services Quality. Assurance Department-Procedures Manual establishes the procedures c and : policies for' SCS QA activities on the -Vogtle Project, arsi for the administration of. the supplier quality sur-

. .veillance program used.to control-supplier'conformance.to- ,

= procurement documents.

A Description of the Procurement Program.at VEGP

- 14 . .It is'the intent of the Vogtle Project to com-petitively_ procure equipment, material and services at the lowest overall cost consistent with Project policies, technical specifications, quality requirements, and con-struction schedules. -Various procedures address the eval-uationiand selection of bidders; the processing of pro-posals; the preparation, review, approval, and issue of 4-l'

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requisitions,. purchase orders,.and purchase order changes; source surveillance inspection (as required), and ex-

.pediting of' drawings, documentation, and hardware to meet established schedules.

15. ~ Purchasing actions, whether initiated by GPC, SCS,Jor Bechtel Procurement groups, are the result of l

l written requests or direction received from the appro-priate engineering group. Project Procurement-does not have the authority to purchase equipment, material or services without receiving such a request or direction.

Engineering provides Procurement.with the complete tech-

.nical~and quality requirements.

16. GPC Procurement prepares and issues all formal purch'ase; orders,: contracts, and change orders'for safety-related items based on the.results of engineering-evaluation and selection. The purchase orders and con-tracts-incorporate the requirements of the engineering
requisition and technical specification. Procurement cannot change technical'or quality requirements which are

-imposed by engineering.

17. The procedures utilized at VEGP ensure that only

. conforming equipment, material and services are procured and delivered to the job site by qualified suppliers and contractors.

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Approved Bidder List Developments and Approval

18. GPC is responsible for the review and approval of bidder lists generated and submitted by Bechtel and SCS, and for developing bidder lists for the equipment, mate-rials and services under its own scope of purchasing. The specific details of developing the bidder lists are set forth in the GPC Project Procurement Procedures Manual.

In summary, bidder lists are developed by GPC as follows:

19. For purchases of non-safety-related (referred to as'Non "Q") materials and equipment and services, the assigned GPC buyer' selects the bidders based upon GPC's previous experience with the supplier, the quality of ser-vice: rendered, and the supplier's ability to deliver the commodity on schedule. Input from various groups is solicited as needed.
20. The process for selecting suppliers for the pur-chase of safety-related "Q" material, equipment and ser-vices is more detailed then for Non "Q" purchases, and Involves a review of'each potential supplier's ability to provide safety-related items which will conform to both technical and quality requirements.
21. For " code" items (ASME Boiler and Pressure Vessel Code,Section III) used in piping systems covered under the BPC "N" certificate program, the GPC Material Supplier program is followed. Suppliers of code items must be an ASME material supplier or manufacturer's quality system certificate holder,.or'be an approved supplier on the

.Bechtel Evaluated 5upplier List (ESL). Bechtel must qualify-suppliers that are not previously qualified to the above requirements prior to GPC awarding' purchase orders or contracts to them.

22. Bidders for Non-Code "Q" items are selected from either Bechtel ESL or the GPC Qualified Suppliers List (QSL), or are evaluated and qualified through a review and approval of the Suppliers QA Manual, a shop survey of the supplier's facility, or documentation that the supplier of commercial grade'"Q" items has successfully performed for

'GPC in the past.

23. Bechtel and SCS are responsible for developing and' forwarding to GpC for approval bidders lists for the equipment, material and services for which they issue
inqui ries , evaluate proposals, and make purchase recom-mendations. These bidders lists are developed from sup-pliers, manufacturers and contractors who expressed an interest in. bidding, and who appeared to offer products or services which were included in the specifications. They are included.in the bidders list only after they are eval-

.uated and approved in accordance with the criteria esta-

.blished-in Project procedures.

24. -The criteria include reasonable assurance that the bidder can provide the goods or perform the services under consideration; the bidder's performance based on

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l current or past work as determined from a review of avail-able data, and whether the-bidder has an established quality assurance program which has been properly imple-mented.

t l Bidding, Evaluation, Recommendation, Approval and Award of New Purchase Orders

25. Based on an approved request from an engineering or construction group, an appropriate procurement buyer (Bechtel or GPC) prepares either an inquiry package or a request for quote containing all necessary technical,

. quality and commercial requirements and/or attachment

documents-(specifications), and transmits this to the

. supplier seJected as outlined in the previous section.

Upon receipt of-the proposals, the buyer evaluates the bid Lfrom a commercial standpoint and in most cases forwards the proposal to the appropriate engineering, construction, ,.

and-QA group as needed for evaluation of technical and

-quality elements of the bids. It'is the responsibility of these groups to resolve any technical or quality issues

.which may exist and any exceptions'taken by the bidder.

For most commodity-type purchases where pricing and/or delivery is the only consideration,~the buyer may select the supplier without'f'rther u involvement from engineering uor' construction. Once the decision has been made and/or recommendation received from the appropriate engineering /

construction group the buyer.will prepare an appropriate

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Procurement document'(purchase order, contract), secure

, appropriate approvals, and issue the document to the vendor.- (NOTE: In the case of items procured by Bechtel, the Bechtel buyer will. prepare appropriate documentation and will forward this to GPC for actual preparation and issuance of the. purchase order / contract).

126. In certain cases, when time is of the essence, the' request for proposals and the actual award to the successful: supplier may be handled by tel'ephone or'by telex, telecopy,~or other such expedient communications.

However, in all cases involving safety-related materials, the appropriate paperwork, including specification and

~other technical or quality documents, is forwarded to the.

supplier as soon as possible.

l post Award Purchase Order / Contract Administration

'27. Post-award purchase order / contract administration includes:the responsibility for soliciting proposals for change's, additions and deletions to an existing supplier's

. scope of work; negotiating the commercial aspects of those

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changes, including _ procurement and delivery; resolving disputes and claims arising during the course of the sup-

_ plier's-performance under a pu'rchase order / contract; and issuing purchase order changes and-contract amendments.

.The. organizational assignments of these various respon-sibilities are outlined in procurement procedures.

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28. When it becomes necessary to modify a purchase order or contract because of added or deleted scope, changes in technical requirements, or other similar reasons, the responsible engineering / construction organi-zation will prepare an appropriate request form or letter. This request for change will be reviewed and approved, using the same controls as the original purchase request. This request is then forwarded to the appro-priate Procurement group for handling. Generally, when a request involves a change in scope or potential price changes, the appropriate buyer will solicit a proposal from the supplier for the work involved in the change request. In any case, all appropriate technical, com-mercial and quality information is forwarded to the supplier in order for him to perform the change as out-lined. Upon receipt of a proposal, the buyer generally forwards this information to the appropriate engineering /

construction group for review to determine if pricing is reasonable and to resolve any technical or quality issues or exceptions which may have been taken by the supplier.

If acceptable, the appropriate engineering / construction group communicates their approval to Procurement which is then responsible for preparing the appropriate change order document. As in the case of an original purchase order, Procurement is not allowed to make any technical or quality changes to the cnange order,and must communicate t

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all technical and quality requirements to the supplier as outlined by engineering / construction.

Supplier Quality Program

29. For all major equipment and material purchases handled by Bechtel to approved specifications and for safety-related purchases requested by GPC construction to approved specifications, the supplier is required to submit for review and approval a copy of the quality assurance program under which he operates (except in cases where exceptions are defined in the PSAR/FSAR). Prior to the award of a purchase order, a review / approval of the supplier's quality assurance program / plan is conducted by the appropriate engineering and/or QA organization.

Following the award of a purchase order, the supplier is required to submit a controlled copy of the quality assurance program description, which is reviewed and retained by the appropriate engineering QA organization.

In addition, the supplier is required to submit any and all revisions to this quality assurance program for review and acceptance by the appropriate engineering QA organi-zation.

Supplier Quality Surveillance Program

30. The Vogtle Quality Surveillance Program (SQSP) was established to provide 3dditional confidence that suppliers of selected safety-related materials and equip-ment to Plant Vogtle comply with procurement and engi-

! neering document requirements. The Southern Company i

Services Project Quality Assurance Engineer (PQAE) is responsibleffor overall management and' administration of the SQSP. During the preparation of engineering speci-fications for equipment and material, it is the responsi-bility of the engineering organization preparing the specification to consider the need for surveillance and audits to be conducted in the supplier's facility, as well as for defining other inspection, testing, and witnessing requirements which should be met in the manufacture of the particular item being procured. If it is determined that surveillance and audits are required to be performed in the supplier's facility during manufacture, a recommen-dation is submitted to the SCS QA Department which is .

responsible for reviewing the recommendation and either approving or-disapproving the need for supplier surveil-lance and audits. If the recommendation.is approved, the SCS PQAE is responsible for assuring that these surveil- ,

lances and audits are conducted at proper times following the award of the purchase order. Detailed procedures describe the assignment of supplier quality represent-atives, the training and qualification of these represent-atives, the initiation and handling of surveillance / audit reports"and nonconformance reports, ano other similar requirements.

31. When replacement parts are required, or when other changes to the original purchase order are required as outlined in the previous section, it is the t

-responsibility of the appropriate engineering organization requesting the change to consider the need for further shop survellance/ audits. If the need is identified and approved, the SCS PQAE is then responsible for carrying out these survellance/ audits as outlined above.

Further. Affiant sayeth not.

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E. J NEK Sworn to and subscribed befo re me this do

  • day of 9__- - , 1985.

I L UAC'M Notaryf ublic

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RESUME EdwardJ. Turner (Ed),P.E.

138 Overlook Court E11enwood, Georgia 30049 (404)981-6219 Personal Data Born 4-7-54, Atlanta, Georgia Married, 2 children ages 3 and 6 Height: 6'0", Weight: 210 lbs.

Education Gordon High School, Decatur, Georgia - 1967-1972 Bachelor of Mechanical Engineering, with honor, Georgia Institute of Technology - 1976 Work Experience Sept.1984 - present - Vogtle Project Procurement Manager Overall responsibility for approximately 30 people involved in all aspects of procurement for the Vogtle Electric Generating Plant. (Approx. cost $4.5 billion)

. June 1983 - September 1984 - Hatch Quality Assurance Manager Responsibility for the definition, documentation and monitoring for compliance of the overall Hatch QA Program. Included was the direct supervision of the Site QA Manager and his staff of approximately 13, as well as indirect oversight and management of the corporate QA engineering / support group and Southern Company Services and Bechtel QA groups.

January 1982 - June 1983 - Assistant to the Vice President and General Manager - Vogtle Project Responsible for support and assistance for the Vice President in areas of administration, budgets, procedures, handling of project meetings and interfaces with construction, engineering, licensing, QA,etc. During the spring of 1983, functioned as Acting General Manager during extended absence of the Vice President.

January 1980 - January 1982 - Supervisor, Engineering Technical Servcies, Power Supply Engineering and Services Department Supervision of approximately nine people involved in procedure preparation and control, cost / schedule support and administrative support for the PSE&S Department.

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Work Experience (Cont'd.) l April 1978 - January 1980 - Assistant to Vice President - Power Supply Engineering & Services General administrative and technical support and interface with all groups in PSE&S concerning procedures, job planning, scheduling, environmental matters, etc.

March 1976 - April 1978 - Junior, then Associate Engineer in the Mechanical Division of Power Supply Engineering & Services Responsible for preparing specifications, designing systems and overseeing implementation for retrofit project including new pulverizers for Plant Branch Unit 1, various coal sampling systems, equipment for ash handling systems and National Pollutant Discharge Elimination System compliance.

Prior to March 1976 - various odd jobs while attending school Societies American Society of Mechanical Engineers National (and Georgia) Society of Professional Engineers Training Various Supervisory and Management Courses Southern Electric Seminar Managerial Grid Licenses / Certificates _ .

Georgia Professional Engineer #12722 Outside Interests Church activities (Ordained Deacon)

Woodworking - furniture, etc.

Building houses Tennis Softball

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