ML20127N125
| ML20127N125 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/28/1985 |
| From: | Garrison D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20127N039 | List: |
| References | |
| 79-421-07-OL, 79-421-7-OL, 79-421-7OL, OL, NUDOCS 8507010437 | |
| Download: ML20127N125 (10) | |
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'85 JJN 28 Pii43 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION CFPCE OF SEcat:iA, DOC E T:.w A SE? w BEFORE THE AT0f1IC SAFETY AND LICENSING BOARD W NCH In the liatter of HOUSTON LIGHTING AND POWER C0f!PANY,
)
Docket Nos. 50-498
_ET _AL.
)
50-499
)
(South Texas Project, Units 1 & 2)
)
Testimony of Donald L. Garrison A
Q.1. Please state your name, business address, title and employer.
~
A.I. My name is Donald Lee Garrison.
I am employed as a Resident Construction Inspector by the United States Nuclear Regulatory Commission. My business address is P. O. Box 910, Bay City, Texas 77414. A statement of my professional qualifications is attached.
Q.2. Describe your responsibilities in this regard.
A.2. I have been assigned to the South exas Project since March 1, 1985, and in the course of normal work, I have evaluated the procedural requirements for processing deficient items through the existing A/E-Licensee system.
Q.3. What is the purpose of this. testimony?
B507010437 850626 PDR ADOCK 05000498 T
A.3 The purpose of this testimony is to respond to questions of the Atomic Safety and Licensing Appeal Board in its Sixth Prehearing Conference Order of f!ay 17,1985 (ASLBP No. 79-421-070L) and to explain the applicant's process for identifying, evaluating, and reporting conditions at the South Texas Project which may be significant and reportable under 10 CFR 50.55(e).
Q.4. Have you had the opportunity to observe this process?
A.4. I have observed this process.
Q.5. What is the current process for evaluating deficiencies through the existing system?
A.5. The A/E (Bechtel) processes all deficient items, other than HL&P items, generated on the site that enter the 50.55(e) program.
These are handled in a standard format that is outlined in Bechtel procedures 2.20 entitled,
" General Project Requirements-Reporting Significant Deficiencies-Federal Regulations 10 CFR 50.55(e)" and Bechtel procedure 5.3 entitled, " Review of Nonconformance Reports for Deficiency Evaluation." The procedures are summarized as follows:
a.
Nonconformances, Standard Deviation Reports and Ebasco letters concerning deficiencies are reviewed to procedural requirements and, if the item meets the deficiency criteria, a Deficiency Evaluation
Report (DER) is generated for approval by the Project Quality Assurance Engineer.
b.
Next, a technical or preliminary evaluation for potential reportability is made by the Project Engineering Manager and approved by the Project Manager.
If the item is determined to be potentially reportable, the DER is sent to the applicant.
c.
The applicant performs a review by an Incident Review Committee (IRC) to make a determination as to reportability. This IRC consists of HL&P management personnel under the direction of its Manager, Nuclear.
Licensing.
If the item is determined reportable or potentially reportable, the IRC chairman notifies the NRC via phone within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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d.
The applicant next prepares the technical evaluation which is reviewed for a final determination as to its reportability.
If the item is determined reportable, the applicant sends the written report to the NRC regional office. The NRC is also notified if the status is determined not reportable. These reports are due 30 days from the time of phone notification.
1.
The applicant's procedure for reporting deficient items is outlined in Project Licensing Procedure-02 (PLP-02), " Reporting Design and Construction Deficiencies to NRC," and basically is as follows:
(a) The individual discovering a potential deficient item generates a Deficiency Evaluation Form (DEF) which is reviewed by the supervising engineer or engineering manager; if found to be significant, the report is sent to the IRC committee for further review.
(b) If the IRC committee determines the report to be potentially reportable, the IRC chairman is notified, who in turn notifies the NRC via phone within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
(c) At this point, the technical evaluation is prepared for final IRC review and, if determined reportable, the report / evaluation is sent to the NRC within 30 days of first notification.
Q.6. How do you inspect this process in the course of your regular duties?
A.6. My inspection process utilizes the review of logs, DERs, SDRs, letters and commitments and an evaluation of the procedural methods. My inspections thus far have included a procedural review of all DERs generated since January 1,1984, in order to assess the processing sequence and procedure requirements. This review and inspection was performed on the site and in the Houston offices of Bechtel and the applicant.
Q.7. In your opinion, does this process meet the requirements of 10 CFR 50.55(e)?
A.7. Yes, the process meets the regulatory requirements including the 24-hour notification and 30-day report time periods. No deficiencies in the HL&P reporting system have been observed since 1983.
Q.8. Does this process meet the NRC's current guidance on reporting deficient items?
A.8. Yes, the process meets the requirements of guidance - 10 CFR 50.55(e),
" Construction Deficiency Reporting," dated April 1, 1980.
Q.9. What is the applicant's method for trending?
A.9. The applicant first started trending in July of 1980 using Procedure PSQP-A-8, " Trend Analysis Administration." This procedure was superceeded by PSQP-16.3, " Trend Analysis" on August 1, 1983. The current revision level is 3, effective March 19, 1985. On January 1,1984, the applicant's l
l quality assurance group assumed responsibility for all trending on the l
project.
l The applicant trends 14 types of documents that generally report
(
deficiencies.
Information is gleaned from these reports which are originated throughout the project by HL&P, Bechtel, and Ebasco and include -
deviation reports (DER), deficiency notices (NCR), etc. Copies of deficiency reports are sent to the HL&P QA/ Adit group after they are validated. The items are processed into the computer base in five 4
-E.
categories: company, orgartization, discipline, group activity, and deficiency type each of which have numerous subgroups.
The analysis portion of the program separates the items by deficiency type:
hardware, systems, supplier, and engineering design with a sort performed monthly for evaluation.
For trends noted, a trend investigation request (TIR) is initiated and processed. This documer,t specifies trend, investigation results, root cause, corrective action and recurrence control and verification of results.
A quarterly report of trends include copies to the applicant's group vice president, nuclear and other management. Review of the procedure indicates that the program is satisfactory and broad enough to identify occurring trends.
O Professional Qualifications of Donald Lee Garrison United States Nuclear Regulatory Commissior.
- I am a Resident Construction Inspector, Division of Reactor Safety and Projects, Reactor Project Branch 1, U. S. NRC Region IV, assigned to the South Texas Project at Bay City, Texas, since March 3,1985.
Prior Work History 10/84-3/85 Reactor Inspector /NRC Region IV Responsible for performing construction related inspections at various nuclear facilities in NRC Region IV.
4/84-10/84 Construction Consultant /Bearean Baptist Church and School West Palm Beach, Florida Responsible for. selection of attorneys, site engineer, architect, constructor, and the sale and acquisition of property.
6/82-1/84 Quality Manager-Consultant / Daniel Construction Company Florida Power and Light, Juno Beach, Florida Responsible for writing a quality program, training personnel, evaluating programs resolution of problem areas, coordinating technical requirements in purchases of equipment.
3/82-5/82 Quality Manager / Daniel Construction Company, Greenville, South Carolina Performed work on special projects; i.e., training, monitoring of projects and procedure writing.
4/81-3/82 Quality Manager / Daniel Construction Company, Union Oil Shale Project, Parachute, Colorado l
Responsible for organizing a complete quality effort and performing civil and welding engineering functions. Managed a welding shop, NDE, and civil laboratory. Writing the program.
8/72-4/81 Quality Manager / Daniel Construction Company, J. M. Farley Nuclear Project, Dothan, Alabama Employed as Quality Assurance Engineer 1972-1975, Quality Assurance Manager 1975-1980, and Quality Manager 1980-1981.
Responsibilities
included all facets of construction in all discipline quality programs from initiation of programs to final inspection and turnover.
8/69-8/72 Senior Quality Inspector / Brown & Root, Inc., Brunswick fluclear Project, Southport, North Carolina Responsible for all civil, mechanical, and receiving inspections.
9/65-8/69 Lead Mechanical / Brown a Root /Northrup Manned Spacecraft Center, Houston, Texas Performed construction completion, testing, operation and maintenance at a large plasma laboratory (heat transfer).
9/61-7/65 Metallurgical Technical / Bell Helicopter Company, Forth llorth, Texas Assigned to engineering laboratories performing process control functions and component failure and accident analysis.
9/60/9/61 Metallurgical Technician / Texas Instruments, Inc., Dallas, Texas Performed research in solid state bonding and maintained the laboratory.
4-6/56-5/60 Technician / Chance Vought Aircraft, Dallas, Texas Performed material evaluations, experiments in welding, metallurgy, corrosion, and manufacturing methods.
Edu' cation Arlington State College, Arlington, Texas - 2 years General Science r