ML20127N172
| ML20127N172 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/28/1985 |
| From: | Phillips H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20127N039 | List: |
| References | |
| OL, NUDOCS 8507010464 | |
| Download: ML20127N172 (4) | |
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00CMETED WC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 85 JUN 28 P1:43 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 0FFICE OF SECRtit n In the Matte. of
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HOUSTON LIGHTING AND POWER COMPANY, Docket Nos. 50-498
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i (South Texas Project, Units 1 & 2)
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Testimony of H. Shannon Phillips on HL&P Reporting of Section 50.55(e) Matters Q.1. Would you please state your name, business address, employer and position.
A.I. My name is H. Shannon Phillips.
I am employed by the U. S. Nuclear Regulatory Commission as senior resident inspector (construction) at the Commanche Peak Nuclear Station. My address is Box 38, Glen Rose, Texas, 76043.
Q.2. Mr. Phillips, have your professional qualifications been made a part of the existing record previously in this proceeding?
l A.2. Yes. My professional qualifications appear following Tr. 9205, ff
- p. 64, Appendix B.
8507010464 850626 PDR ADOCK 05000498 PDR
V' Q.3. Are there any changes you wish to make with regard to those qualifications?
A.3. Yes. Since January 19,1982, (the date of prior admission of my qualifications) I held the position of Chief, Equipment Qualifications Section, Vendor Programs Branch, NRC until flarch 18, 1984.
Since that time to the present, I have been senior resident' inspector (construction) at the Comanche Peak Nuclear Station.
Q.4. What is the purpose of this testimony?
A.4.~The purpose of this testimony is to provide my views with respect to HL&P's system for reporting design and construction deficiencies _ under 10 CFR50.55(e).
A.S. Do you have personal knowledge of the HL&P system for reporting construction deficiencies?
A.S. Yes.
Q.6. On what experience or duties is this knowledge based?
A.6. I was the senior resident inspector at the South Texas Pro,iect from September 1979 to January 11, 1982. During that time I routinely inspected HL&P's system for reporting deficiencies. My testimony provides my observations for that time period.
q Q.7. Can you describe the system for reporting construction deficiencies during this period?
A.7. Yes.
HL&P Procedure FEP-11, Revision 0, was issued July 26, 1979, and described the process for reporting 10 CFR Part 50.55(e) deficiencies.
HL&P Engineering Procedure STP-DC-021-D and Revisions A through C (dated February 1978 through January 1981) specifically describe how engineering organizations report engineering design deficiencies.
Basically, anyone can report a construction or design deficiency which in turn is fed to the STP Project QA supervisor or appropriate engineering group that evaluates the reportability per 10 CFR 50.55(e).
The item is then referred to an Incident Review Committee for a safety evaluation.
Procedure PEP-11 states that deficiencies shall fall into one of four categories outlined in paragraph 5.3.3; i.e., QA, final design, construction or deviation from performance specifications.
Page 10 of 17 also indicates that potentially reportable items were to be reported.
Q.8. How would you assess HL&P's candor and truthfulness in reporting matters to the NRC during the period identified above?
A.8. fly experience with this utility is that it was forthright in identifying deficiencies to the NRC when these were found to be reportable. The utility also reported a large number of deficiencies, when it could have taken a more conservative approach, and reported fewer.
I was also impressed by their sincere desire to do a good job even though their
. inexperience or oversight sometimes resulted in violations of 10 CFR 50.55(e) reporting requirements.
0.9. Have you seen any indication from the utility that it was abdicating or refusing to accept its responsibility to protect the health and safety of the public?
A.9. No.
Q.10.What is your conclusion as to the remedial steps taken by HL&P since 1981
.with regard to its character and competence to operate a nuclear plant?
A.10.These steps were adequate and reflect positively on the character and competence of HL&P.
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