ML20133C505
| ML20133C505 | |
| Person / Time | |
|---|---|
| Site: | Catawba, 05000000 |
| Issue date: | 09/24/1983 |
| From: | Davison L DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20132B649 | List:
|
| References | |
| FOIA-84-722 NUDOCS 8507200513 | |
| Download: ML20133C505 (43) | |
Text
. _ _ _. __
t Applicants' Exhibit UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
.)
DUKE POWER COMPANY, et al. )
Docket Nos.
50-413
-)
50-414 (Catawba Nuclear Station,
)
Units 1 and 2)
)
TESTIMONY OF LARRY R. DAVISON 1
Q.
STATE YOUR NAME AND BUSINES3 ADDRESS.
2 A.
My name is Larry R. Davison, and my business address is Catawba 3
Nuclear Station,
P.O.
Box 223, Clover, South Carolina 29710.
4 Q.
STATE YOUR PRESENT JOB POSITION WITH DUKE POWER 5
COMPANY AND DESCRIBE THE NATURE OF YOUR JOB.
6 A.
I am the Project Quality Assurance Manager responsible for Quality
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7 Assurance during construction of the Catawba Nuclear Station.
8 Quality Assurance consists of planned activities to assure that the 9
Catawba plant will be designed, constructed and operated in a 10 manner consistent with all applicable regulatory requirements and in 11 a manner to protect the health and safety of the public.
During 12 construction these activities consist of inspection of actual work, 13 review of materials used in constructing the plant, review and 14 approval of construction procedures used in construction, and
(
)
15 review and approval of documentation generated in the above 16 activities.
These activities are conducted in accordance with 17 procedures contained in the Duke Quality Assurance Manuals for 18 construction.
There are approximately 230 Quality Assurance 19 employees at Catawba consisting of engineers, technicians,
(
20 inspectors and clerks.
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.s, i
1 Q.
DESCRIBE YOUR PROFESSIONAL EXPERIENCE AND C-2 QUALIFICATIONS, INCLUDING YOUR PRIOR POSITIONS HELD 3
WITH DUKE POWER.
4-A.
I am a registered Professional Engineer in both North Carolina and 5
I received. a Bachelor of Science degree in Mechanical Engineerkng from the Georgia Institute of Technology in 6
7 1967.
My experience has included four years in the United States 8
Navy where I attended both nuclear power and submarine schools.
9 The nuclear power school consisted of six months of theoretical 10 training in nuclear power and six months at a prototype nuclear 11 power plant actually learning to operate the plant.
After completion 12 of both schools, I was assigned on-board an operating ballistic 13 missile submarine for approximately two and one-half years.
14 I started working for Duke Power Company in 1971 as an 15 Assistant Field Engineer at the Oconee Nuclear Station.
I was 16 responsible for generating welding construction procedures.
In 17 1973 I was promoted to Associate Field Engineer, with responsibility 18 for welding inspection at Oconee.
With the completion of Oconee, I 19 was transferred to the Catawba Nuclear Station in 1974.
I had the 20 assignment of Senior Quality Control Engineer and was responsible 21 for Quality Control inspection activities at Catawba in all the 22 disciplines of work that was being performed.
I remained in that 23 position until February,1981 when I was appointed QA Manager for 24 the Projects Division of the Quality Assurance Department.
With 25 this assignment, I was transferred from the Catawba site to the 26 Charlotte Office.
I held that position until approximately 27 September, 1982 when I was transferred back to Catawba Nuclear y
28 Station as the Project QA Manager.
In my current position, I have.
responsibility for all of the QA activities at the Catawba site during f
I 2
the construction of the plant.
I have attended several schools involving welding and welding l
3 4
inspection, including a one week course at the University of 5
Tennessee dealing, with the technical aspects of welding, and a 6
training course at Magnaflux Corporation in interpretation of i
7 radiographic film.
I have been certified as a Level III welding inspector examiner by Duke Power Company at Catawba, although I 8
9 do not presently hold that certification.
I held this certification 10 from 1978 to 1980.
During 1980 the Level III examiner duties were 11 consolidated during a reorganization in the QA Department.
I 12 allowed my certification to lapse in 1980 since I was no longer 13 performing the Level III examiner duties.
My resume is 14 to my testimony.
HAVE YOU BEEN INVOLVED IN THE PROCESS WHICH SETS THE 15 Q.
16 PAY CLASSIFICATION FOR INSPECTORS?
I was part of a group that updated all inspector position analyses 17 A.
18 in the spring of 1980. This updating of inspector position analyses 19 was done with input from inspection supervision.
The position 20 analyses were then evaluated and assigned a
pay grade 21 classification.
22 Q.
DESCRIBE WHAT HAS OCCURRED OVER THE YEARS WITH i
23 RESPECT TO THE PAY CLASSIFICATION.
When Catawba construction began in 1974, there were no position 24 A.
25 analyses for inspectors.
Quality Assurance Procedures governed 26 training and certification, but did not cover pay.
The pay 27 classifications that existed were administered by each supervisor
(
.m.
I with increases or promotions originating with the supervisor's 2
recommendation.
3 Position analyses were developed for the various inspector 4
positions in 1977 at McGuire.
These position analyses and 5
corresponding pay grade classifications were initiated in February 6
1980.
7 Because of the time lag between when the position analyses 8
were completed in 1977, and their implementation in 1980, all the 9
position analyses were reviewed and updated as necessary soon 10 after implementation.
Upon completion of this
- updating, the 11 positions were evaluated and classified for pay purposes.
These 12 revised pay classifications were implemented in July 1981.
~
13 Q.
WHAT WAS THE RESULT OF THE 1981 ANALYSIS ON THE PAY 14 CLASSIFICATION OF WELDING INSPECTORS?
[L.
15 A.
It resulted in the pay grade for the new position of Welding 16 Inspector A being reduced one pay grade below the previous 17 Welding Inspector position.
With this reduction in pay grade, the 18 Welding Inspector A position was a few cents per hour higher than 19 the craft welder pay.
20 Q.
WHAT CAUSED THE WELDING INSPECTOR POSITION TO BE 21 LOWERED A PAY GRADE?
Prior to 1981 there were two levels of welding inspectors for pay 22 A.
The welding inspector learner and welding inspector.
23
- purposes, pay classification for these positions was based on the qualifications 24 25 requirement of two years experience in welding fabrication or 26 welding inspection.
In June, 1978, the two years experience 27 requirement was changed when the certification procedure for inspectors established unifom experience requirements and' levels of 28.
d-1 inspector certification for all inspector disciplines.
The welding inspector position evaluation by the pay classification committee in 2
3 1980 took into account the changes in the required experience.
This change in the experience requirement was one of the reasons 4
5 the pay classification was lowered to Grade 10.
This evaluation of 6
positions included all inspector positions, and resulted in some 7
inspector positions,
such as Mechanical Inspector A,
bring 8
upgraded by one pay grade.
9 Q.
DID THIS CHANGE IN THE REQUIREMENTS FOR WELDING
. INSPECTORS RESULT IN LESS QUALIFIED WELDING INSPECTORS?
10 11 A.
No.
Qualification and certification of welding inspectors was still based on successful completion of the training and testing progr'am.
12 13 When the two year welding inspection or welding fabrication 14 experience requirement was dropped, the procedure introduced
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15 levels of welding inspectors.
These were Level I, II and III.
Since all our welding inspectors at Catawba at the time had met the 16 17 two year experience requirement, they met the requirements for 18 Level II inspector certification.
Any new inspectors hired would have to move through the Level I certification to gain experience 19 20 before being qualified to Level II. The experience requirement was 21 not simply
- dropped, it was replaced with requiren.ents for 22 inspection experience.
The training and testing program remained 23 essentially the same.
COMMUNICATE THE DECISION CONCERNING THE PAY 24 Q.
DID YOU 25 RECLASSIFICATION TO THE WELDING INSPECTORS.
This decision was communicated to all the inspectors through 26 A.
Yes.
27 their supervision and in meetings with the inspectors.
s
i 1
Q.
WHAT WAS THE RESPONSE OF THE WELDING INSPECTORS TO 2
THIS PAY RECLASSIFICATION?
Several 3
A.
They were not happy over this reduction in pay grade.
4 welding inspectors followed Duke's recourse procedure to seek 5
management review of the reclassification.
6 Q.
WERE YOU INVOLVED IN PROCESSING THE PAY RECOURSES?
7 A.
Not directly.
The recourses were handled in accordance with the 8
corporate recourse policy.
Step 1 was to the Department Head, step 2 to Corporate Employee Relations, and step 3 to the President 9
I was involved to the extent of being interviewed 10 of the company.
or asked questions by persons working on the responses during 11 12 these steps.
13 Q.
WHEN DID YOU FIRST BECOME AWARE OF THE CONCERNS 14 EXPRESSED BY WELDING INSPECTORS AT CATAWBA WHICH APPEARED TO AFFECT THE QUALITY OF PLANT CONSTRUCTION?
15 16 A.
In December 1981 I was informed by Mr. Wells, Corporate QA Manager, that some concerns of this nature had been expressed and 17 that a Task Force had been appointed by Mr. Owen to investigate 18 19 the concerns.
DESCRIBE YOUR INVOLVEMENT WITH THE INITIAL TASK FORCE, 20 Q.
WHAT IS NOW REFERRED TO AS TASK FORCE I.
21 l
I was not directly involved with Task Force I.
They interviewed 22 A.
me as part of their investigation, and I made arrangements for them 23 24 to have a place to work at Catawba.
25 Q.
DESCRIBE YOUR INVOLVEMENT WITH THE TECHNICAL TASK 26 FORCE.
After Task Force I completed its inv3stigation, I was advised that 27 A.
s concerns had been expressed by the welding 28 additional specific i
1 inspectors.
I called a meeting with all welding inspectors at 2
Catawba on January 11, 1982 and asked them to specifically list all of their concerns so they could be investigated. This request was 3
4 made again on January 21, 1982, in a letter from Jim Wells to all 5
Catawba welding inspectors.
When these concerns were turned in, I delivered them to the Technical Task Force.
I was not involved 6
in the Task Force investigation of these concerns.
7 When the Technical Task Force completed its work and issued 8
I worked with George Grier, Neal Alexander, Wayne 9
its report, 10 Henry and Bill Bradley to review the Technical Task Force recommendations and develop implementation objectives based on the 11 12 Task Force recommendations.
13 Q.
DESCRIBE YOUR INVOLVEMENT WITH LEWIS ZWISSLER OF lr 14 MANAGEMENT ANALYSIS COMPANY.
L I was -interviewed by Mr. Zwissler during the time the Technical 15 A.
16 Task Force was investigating the inspector concerns.
DESCRIBE YOUR INVOLVEMENT WITH THE NONTECHNICAL TASK 17 Q.
18 FORCE.
i I had no involvement with the Nontechnical Task Force.
19 A.
20 Q.
WERE YOU INVOLVED IN THE IMPLEMENTATION OF RECOMMENDATIONS ISSUED BY ANY OF THE TASK FORCES?
j 21 22 A.
Yes.
DESCRIBE YOUR ROLE IN IMPLEMENTING THE RECOMMENDATIO 23 Q.
24 OF THE TECHNICAL TASK FORCE.
I participated in the review of the recommendations of the Technical 25 A.
26 Task Force.
George Grier, Neal Alexander, Wayne Henry, Bill Bradley, and I developed implementation objectives from the general 21
-y
1 and programmatic recommendations made by the Technical Task 2
Force.
3 I participated in the assignment of individuals to carry out the 4
specific recommendations of the Technical Task Force, and the 5
implementation objectives based on the general and programmatic 6
recommendations.
7 I personally developed the action to be taken on three of the 8
implementation objectives,
9(3)a 1,
2 and 3; 9(3)d and 9(3)h 9
(Technical Task Force, Volume I, Section 9).
In doing this, I 10 reviewed the recommendations of the Task Force, developed actions 11
'to be taken, and either carried them out myself or assigned them to 12 be carried out.
13 The three implementation objectives I worked on resulted in
[
14 action to 15 1) involve inspector supervision in QA Procedure revision 16 process; 17 2) establish periodic meetings between representatives from 18 QA, Construction Engineering and Craft to discuss any process 19 control problems; and 20 3) to conduct training of Projects QA Supervision and 21 Inspectors.
22 The training of QA supervision included a flow chart of how to 23 resolve technical questions from inspectors, sometimes referred to 1
24 as the " stickman" process, when to give direction to inspectors, 25 and to never direct an inspector to accept anything he is 26 uncomfortable with.
The training of Inspectors was to be sure they 27 understood that they should not accept any item they felt was not
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I acceptable even if they felt they were directed to do so.
The 2
" stickman" flow chart is Attachment 2 to my testimony.
3
-Q.
HOW WOULD YOU DESCRIBE THE PRIMARY CONCERN OF THE 4
WELDING INSPECTORS?
5 A.
In my view, they were" concerned about two things:
6 1.
The reduction in their pay grade 7
2.
Decisions made by several individuals in their management 8
which they did not understand or did not agree with.
This is based on my discussions with inspectors and my review of 9
10 the task force reports.
11 Q.
ARE YOU AWARE OF ANY OTHER SPECIFIC CONCERNS OF THE 12 WELDING INSPECTORS?
13 A.
Yes, I am aware of several concerns that welding inspectors have
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14 raised.
These include:
15 1.
welds on systems where only a final visual inspection is 16 performed; possible damage to structural steel after it has been inspected; 17 2.
18 3.
NCI-9085; and 19 4.
additional concerns of G.E.
Ross since the technical Task 20 Force PLEASE EXPLAIN THE SITUATION WITH REGARD TO WELDS ON 21 Q.
22 SYSTEMS WHERE ONLY A
FINAL VISUAL INSPECTION IS 23 PERFORMED.
There are various classes of piping systems ranging from Class A 24 A.
25 to Class H, A being the highest.
Inspections performed on welds Class 26 in these systems are based on Class and Code requirements.
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27 A gets cleanliness, fit up, visual, surface and volumetric NDE as opposed to Class E which receives only a final visual inspection.
28
s, 1
The classification of piping systems is determined by Design Lower 2
Engineering based upon the safety function of the system.
classes receive less inspection because significance to safety is less 3
and the degree of assurance is correspondingly less.
In addition to 4
5 inspection, all safety related systems are hydrostatically tested in 6
accordance with ASME Code requirements. This provides additional 7
assurance of weld integrity.
WHAT IS THE SITUATION WITH REGARD TO POSSIBLE DAMAGE 8
Q.
TO STRUCTURAL STEEL AFTER IT HAS BEEN INSPECTED?
9 This involves a recent concern about removal of welds on previously 10 A.
inspected structural steel without the removal area being inspected.
11 Procedures are in place that provide that when temporarily attackled 12 welds are removed, the removal area is to be inspected. We are in 13 14 the process of evaluating this concern.
We will review the
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instances cited to determine their significance and if significant will 15 16 take proper corrective _ action.
In addition, we will determine if our 17 procedures should be modified in some way.
WHAT IS THE SITUATION WITH REGARD TO NCI-9085?
18 Q.
19 A.
This NCI originated as a result of three different heat numbers being marked on a piece of Class B pipe installed in a Class E pip-20 One number was valid, two were invalid.
Class E piping 21 ing System.
22 systems do not require heat number traceability (i.e. ability to 23 identify the origin of the material) and thus the matter was 24 acceptable as is.
The concern is that this piece of installed Class 25 B pipe could be removed and used in a Class B piping system 26 without proper traceability.
Such is not the case because of the i
heat number check that is performed at fit up inspection of Class B 27
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This check verifies the heat number with a log of 28 piping systems. -
1 valid heat numbers.
The two invalid numbers on this piece of pipe 2
would not pass that check.
Accordingly for traceability purposes, 3
only one number, and that the valid one, will be associated with 4
this piece of pipe.
5 Q.
WHAT IS THE SITUATION WITH REGARD TO THE ADDITIONAL 6
CONCERNS OF G. E. ROSS?
7 A.
I have discussed the additional concerns with G. E. Ross. He has 8
indicated he is satisfied with one exception.
We have agreed to 9
action to be taken to resolve this one concern.
This action is 10 ongoing.
11 Q.
THE CONCERNS EXPRESSED BY THE WELDING INSPECTORS WERE 12 INITIALLY CHARACTERIZED AS CONCERNS AFFECTING T'HE.
13 QUALITY OF WORK OR THE SAFETY OF THE CATAWBA PLANT.-
14 IN YOUR VIEW, DID THE CONCERNS EXPRESSED BY THE WELDING l
15 INSPECTORS AFFECT THE QUALITY OR THE SAFETY OF THE 16 CATAWBA PLANT?
17 A.
No.
Based on my review of the results of the Technical Task 18 Force's investigations, I saw nothing that indicated that any of the would have affected the quality or safety of Catawba.
19 concerns 20 The concerns involved misunderstandings, less than desirable 21 communications, and room for improvement in procedures; but, none 22 of these concerns resulted in less than acceptable quality or safety 4
23 at Catawba.
24 Q.
IN YOUR VIEW, DID THIS EXPRESSION OF CONCERNS BY THE 25 WELDING INSPECTORS INDICATE THAT THERE WAS A
i 26 BREAKDOWN IN THE QA PROGRAM AT CATAWBA OR THAT THE 27 QA PROGRAM WAS NO LONGER WORKING AT CATAWBA?
i
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1 A.
No.
In fact, the expression of concerns indicated that the QA C-2 Program was working because of the openness where the concerns' 3
were brought up, investigated, and resolved in such a manner to 4
improve the Program.
Any program will always have room for 5
improvement; but, that does not mean it does not work.
The 6
dedication to quality by Duke management and employees is 7
evidenced by the continual review of the QA Program with emphasis 8
on making it even better, and the avenues set up to allow anyone 9
to raise concerns to higher levels of management through recourse.
10 These are elements of a successful QA Program rather than 11 one that does not work.
12 Q.
HAVE YOU EVER PRESSURED AN INSPECTOR OR SUPERVISOR TO 13 APPROVE FAULTY OR DEFICIENT WORKMANSHIP?
14 A.
No.
I have based my decisions in evaluating NCI's or other 15 nonconformances on applicable technical standards.
16 Q.
WHAT IS THE QA DEPARTMENT'S POLICY AND PRACTICE WITH 17 RESPECT TO EMPLOYEE'S ACCESS TO THE NRC TO EXPRESS 18 CONCERNS OR RAISE TECHNICAL QUESTIONS?
19 A.
It has always been both the policy and practice of the QA 20 Department that all employees have free access to the NRC on any 21 matter involving quality or safety at its nuclear plants.
This is not 22 only a QA Department policy, but it is the Company's policy.
The 23 Catawba site QA organization is a primary interface with the 24 Resident NRC Inspector, particularly as it relates to their periodic 25 inspections.
At one time or another, practically all QA employees 26 at Catawba have direct. access to the NRC.
It would be simply
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27 unrealistic to attempt to restrict employee access to the NRC.
M.
1 This policy of open access to the NRC was the same when the C
2
'QC inspection group was part of the Construction Department.
It posted on company bulletin boards at the site in 1977 in a 3
was 4
document signed by Mr. R. L. Dick.
This document contained the 5
NRC's Regional Office telephone number, and a statement that the 6
NRC would accept collect calls.
It has also always been clear to me 7
that the company policy is that employees have a right, but more 8
importantly, the responsibility to bring up any concerns they have 9
of a technical or nontechnical nature through Duke's recourse 10 procedures.
This policy in no way restricts employee contact with 11 the NRC.
12 Q.
HAVE YOU EVER DIRECTED INSPECTORS TO NOT EXPRESS 13 CONCERNS OR RAISE TECHNICAL QUESTIONS WITH THE NRC?
14 A.
No.
I have encouraged inspectors to express their concerns and 15 questions to their supervisors and company management and 16 through recourse procedures before going to the NRC.
In 1980, I 17 held meetings with all welding inspectors to be sure they 18 understood that the recourse procedure applied to any concern, 19 technical or nontechnical.
I advised the inspectors that they had a 20 responsibility to follow this procedure prior to going to the NRC, 21 but, that this responsibility in no way would replace their right by 22 law to go to the NRC at any time.
There are several reasons why 23 I encouraged inspectors to raise concerns within the company 24 structure.
The company has established a comprehensive, set of 25.
procedures to
- receive, review and resolve technical. and 26 nontechnical concerns.
It is extremely important to encourage
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27 employees to discuss matters with their supervisor.
This is an effective method of both problem identification and problem solving.
28
1 If employees raise concerns with their superviscrs, the concerns 2
can get resolved expeditiously, leading to better communications and 3
better work.
It provides the kind of feedback necessary to have a 4
good QA program.
5 Q.
WHY DID YOU HAVE A MEETING WITH WELDING INSPECTORS IN 6
1980 TO DIRECT THEM TO EXPRESS CONCERNS AND RAISE 7
TECHNICAL QUESTIONS WITH DUKE MANAGEMENT BEFORE GOING 8
TO THE NRC?
9 A.
I held these meetings.with the welding inspectors because of 10 discussions I had with the Resident NRC Inspector.
During my 11 normal contact with the Resident NRC Inspector, he had indicated 12 that some welding inspectors had brought to him concerns which did 13 not involve safety-related portions of the plant.
While I did not 14 receive specific examples during these conversations, I was left 15 with the impression that these matters brought to the NRC should 16 be handled by the company, and were nonsafety related.
I felt a 17 need to ensure that our inspectors understood that we wanted them 18 to communicate with management, and that the Duke recourse 19 procedure was available to them on these matters, as well as any 20 other matter.
21 Q.
TO YOUR KNOWLEDGE HAVE QA EMPLOYEES USED THE RECOURSE 22 PROCEDURES, THE HARASSMENT PROCEDURE OR TAKEN THEIR 23 CONCERNS TO THE NRC?
I know QA employees have used the. recourse procedures and the 24 A.
25 hs.rassment procedures.
H'owever,
I do not know of any QA employees who have taken a concern to the NRC, but I understand 26
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27 such has occurred.
n.
1 Q.
TO YOUR KNOWLEDGE HAS SUCH TAKEN ANY RETALIATORY 2
ACTION AGAINST INDIVIDUALS WHO HAVE USED THE RECOURSE
~
3 PROCEDURES, THE HARASSMENT PROCEDURE OR TAKEN THEIR 4
CONCERNS TO THE NRC?.
5 A.
No.
6 Q.
ARE YOU AWARE OF ALLEGATIONS BY INSPECTORS THAT THEY 7
HAVE BEEN HARASSED IN CARRYING OUT THEIR TASKS?
8 A.
Yes.
I am aware of two cases where formal harassment charges 9
have been made which involved disputes between a welding inspector and 10 the craft.
In both instances the matter was investigated and it was 11 concluded that harassment had not occurred.
Rather, heated arguments 12 had taken place.
In both cases the employees involved were counseled 13 on their actions.
I would note that QA is not pressured by craft to be
[k.
14 the extent that anything less than satisfactory work is approved.
Our 15 inspectors simply will not permit this.
There has been, and I imagine 16 there will continue to be, tension between craft and QA from time to 17 time.
This stems from the nature of the job.
QA inspects craft work; 18 if it is not satisfactory it will not be approved.
It is natural for craft 19 to be somewhat resentful to be told work is not satisfactory.
- However, 20 as has been noted, management of both organizations worked together to 21 assure that the interface does not impair the safety of the plant.
22 Further, our inspectors are instructed that when such situations develop 23 they should avoid becoming involved in an argument.
If any situations 24 come forward which identify a
problem representatives of both 25 departments meet and attempt to resolve the issue.
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l m.
j
PART II 1
Q.
DESCRIBE THE QA ORGANIZATION AT THE CATAWBA SITE.
2 A.
The current QA organization at the Catawba site is set forth on a 3
chart which is Attachment 3 to my Testimony.
The organization 4
consists of five groups which perform various functions, the 5
Inspection Group, the QA Technical Group, the Surveillance Group, 6
the Planning Group, and Employee Relations.
7 Q.
PLEASE DESCRIBE THE FUNCTION OF EACH OF THESE GROUPS, 8
BEGINNING WITH THE INSPECTION GROUP.
9 A.
The Inspection Group is responsible for the Quality Control (QC) 10 inspection of the work that is being done, and is headed by an 11 Inspection Superintendent.
The Inspection Group is organized by 12 discipline into several other groups.
There is a Mechanical Group, 13 Electrical and Instrumentation Group, a Civil Group, a Welding and 14 Non-Destructive Examination (NDE) Group, a Receiving Group, and 15 a Document Control Group.
The Mechanical Group is responsible 16 for inspection of mechanical work such as pipe erection, equipment 17 installation and pipe support erection.
The Electrical and 18 Instrumentation Group is responsible for inspection of electrical and 19 instrumentation work such as cable installation, electrical equipment 20 installation, and instrumentation installation.
The Civil Group is 21 responsible for inspection of structural work such as concrete 22 placement, soils work, structural steel erection and coatings.
The 23 Welding and NDE Group is responsible for inspection of welding 24 including visual inspection and non-destructive testing, such as 25 radiography (X-ray),
liquid penetrant and magnetic particle 26 inspections.
The Receiving Group is responsible for inspection of g
27 all safety related material and equipment received at the site.
The a(%
t Document Control Group is responsible for inspection of documents 1
2 in use to construct the plant to ensure they are current.
The Inspection Group has the inspectors who are responsible 3
for the actual inspection of the work activities in accordance with 4
5 the QA procedures.
Th'is inspection may be done in-process, such as welding inspection which has hold' points at various steps prior 6
7 to welding, during welding, and after welding; or the inspection 8
may be done upon completion of a work activity, such as a 9
mechanical pipe hanger.
Once the hanger is completed, then the 10 inspection is performed.
11 The Inspection Superintendent is responsible for all the inspections that are required by the Qualify Assurance Program and 12 13 Quality Assurance Procedures.
The Inspection Superintendent has 14 reporting to him four Technical Supervisors or QA Engineers.
There are two Technical Supervisors in welding and non-destructive 15 16 examination.
There is a Technical Supervisor for the mechanical 17 area, and a QA Engineer for the electrical and instrumentation area, which also includes the receiving and document control areas.
18 Each of these Supervisors has Supervising Technicians reporting to 19 20 him who are the first line supervision of inspectors.
For example, 21 in the mechanical area there is a Supervising Technician for equipment activities, a Supervising Technician for piping activities, 22 and a Supervising Technician for pipe support / restraint activities.
23 Supervising Technicians are generally qualified inspectors who 24 have demonstrated through performance the ability to supervise and 25 26 lead others.
They are certified as a Level II Inspector in the 27 discipline they supervise, or they will have inspectors who are g
28 certified to that level in their groups.
In. the Electrical Group, I
s
I there is a Supervising Technician for instrumentation and certain 2
electrical activities and another Supervising Technician for the 3
remaining electrical activities.
There is a Supervising Technician in 4
the civil area for the concrete, soils, structural steel, and coating 5
work activities.
There is a QC Supervisor who supervises the 6
receiving and document control inspection personnel at Catawba.
7 In the welding area, there are two Technical Supervisors, 8
Fred Bulgin and Charles Baldwin.
They have reporting to them 9
Supervising Technicians who have certified welding inspectors and 10 inspectors who are certified in non-destructive examination 11 techniques.
The non-destructive examination techniques used at 12 Catawba include magnetic particle inspection (MT), liquid penetrant 13 inspection (PT), radiographic inspection, and ultrasonic inspection
[(
14 (UT).
Radiography at Catawba is performed on a third shift 15 because of safety aspects involved in radiography.
16 Q.
WHAT IS THE FUNCTION OF THE QA TECHNICAL GROUP?
17 A.
The QA Technical Group is headed by a Senior Quality Assurance 18
- Engineer, R.
A.
- Morgan, and is composed of engineers and 19 technicians whose primary function is to review the process control 20 that is issued for the work at Catawba to insure it is correct, to 21 review the inspection reports that are generated by the Inspection 22 Group of QA, and insure those inspections have been completed and 23 accepted.
In addition, the Technical Group reviews documentation 24 of materials received from vendors for certain items and releases 25 the materials for use in the plant.
This group also reviews and 26 approves resolutions to inspection deficiency reports (R-2A's) and 27 nonconforming items (NCI's).
1 Q.
WHAT IS THE FUNCTION OF THE SURVEILLANCE GROUP?
2 A.
T'he Surveillance Group is headed by a Supervisor, and has technicians who are responsible for conducting surveillance on both 3
4 the construction
- work, and the inspection activities of the Inspection Group to assure that the work and the QC inspections 5
6 are performed in accordance with QA procedures.
This group is completely independent from the Inspection Group and the Technical 7
8 Group.
This supervisor has the freedom to schedule when 9
surveillance will be done.
He also schedules what areas' will be 10 looked at.
Major construction areas are covered periodically, but whenever a specific problem area is found, that area may be looked 11 12 at in more detail and more frequently.
When a problem is identified, it is noted in a surveillance report and th'at problem may 13 either be nonconformed or handled in accordance with a Quality 14 Assurance procedure for correcting the deficiency or discrepancy.
15 In addition, the Surveillance Supervisor can also notify the Project 16 Manager or the Project QA Manager of a condition that has been 17 18 observed.
Corrective action may be required for such identified 19 conditions.
The surveillance reports are communicated to the 20 Project Manager as a
means of informing the Construction Department of the results of the surveillance activities.
21 WHAT IS THE FUNCTION OF THE QA PLANNING GROUP?
22 Q.
23 A.
The Planning Group in the QA organization at Catawba is responsible for disseminating schedule information to the various QA 24 They ar'e responsible for coordinating the QA work with 25 Groups.
26 the construction work schedule so that the inspections can be 27 scheduled and accomplished in a timely manner.
a
1 Q.
WHAT IS THE FUNCTION OF THE EMPLOYEE RELATIONS 2
ASSISTANT ON SITE AT CATAWBA?
The Employee Relations Assistant is responsible for the personnel 3
A.
activities of the Quality A5surance Department at the Catawba site.
4 The The site QA organization is composed of about 230 employees.
5 6
Employee Relations Assistant handles personnel matters for these 7
employees.
The Employee Relations Assistant is also involved as an 8
aide to employees in any recourse that the employee might be involved in, and coordinates personnel matters with the QA Manager 9
of Administrative Services located in Charlotte.
10 11 Q.
HOW DID THE QA SITE ORGANIZATION DIFFER DURING 19,81?
In 1981 the QA organization was basically the same, except for some 12 A.
13 differences in reporting lines.
We did not have a position of 14 Inspection Superintendent in 1981.
The various technical supervisors in charge of the inspection areas reported directly to 15 16 the Project QA Engineer, who at that time was the senior QA The Surveillance Group was headed by one of 17 person on the site.
18 the QA Engineers, and we did not have the Employee Relations Assistant or Planning Supervisor positions. The 1981 organizational 19 structure is set forth on the chart which is Attachment 4 to my 20 21 testimony.
DESCRIBE THE QA-CONSTRUCTION MANAGEMENT INTERFACE 22 Q.
23 THE PROJECT SITE LEVEL.
Overall, there is a close interface between the management of the 24 A.
25 Quality Assurance Department onsite and the management of the 26 Construction Department onsite.
There are periodic ' meetings held 27 by site Construction and QA supervision to discuss program g
implementation; inspection supervisors are regularly discussing the 28
1 status of the work with Construction Department supervision; 2
Quality Assurance personnel regularly attend onsite meetings held by the Construction department to review the status of the project; 3
4 inspection report trend analyses ' are performed and reviewed by 5
Construction and-QA management on site; surveillance of 6
construction and QA activities is performed periodically and the
- ~
7 results reported to construction and QA management; and exit 8
meetings conducted by the Audits Division of the Quality Assurance 9'
Department and by the NRC as well as other audit teams are i
10 attended jointly by Construction and QA Projects Division 11 personnel.
12 Q.
DESCRIBE THE QA-DESIGN ENGINEERING INTERFACE AT THE 13 PROJECT SITE LEVEL.
>(
The QA-Design interface primarily exists through the specification
\\
14 A.
15 of design requirements in specifications and drawings which are The contact 16 implemented in the course of fabrication and erection.
17 with~ Design Engineering personnel generally takes place in conjunction with Construction Technical Support and QA Technical 18 19 Services Division personnel.
As Design Engineering personnel visit 20 the Catawba Nuclear Station, there is usually general discussion 21 between them and Quality Assurance personnel in the Projects 22 Division.
EXPLAIN THE ROLE OF THE INSPECTOR IN THE OVERALL QA 23 Q.
24 PROGRAM.
The QA function is carried out at Catawba primarily through the 25 A.
l 26 inspectors.
The QA Department has developed ' detailed Quality Assurance procedures that set forth the specific aspects of various
\\
27 28 construction processes that are to be inspected, and when they
I should be inspected.
Some processes, such as some classes of
~
2 welding, will have various required in-process inspection steps, or 3
" hold points".
A hold point is a point at which work must be 4
inspected before the work can continue.
When hold points are 5
established, generally process control travelers, which follow the 6
- work, are used to indicate the inspections required and the 7
acceptability of those inspections.
In other work areas, the work 8
is completed and then it is inspected, and a report is made of its 9
acceptability.
This is the primary method by which the work is 10 verified to meet the design specifications and Quality Assurance 11 requirements.
The QA procedures contain the points at which 12 inspections are completed, and provide the means for handling 13 discrepancies discovered during inspections.
(
14 Q.
HOW DO INSPECTORS KNOW THE DIFFERENCE BETWEEN 15 ACCEPTABLE AND UNACCEPTABLE WORK?
16 A.
Inspectors determine acceptability by referring to acceptance 17 standards established in QA Procedures and Design Specifications.
i 18 Prior to becoming certified, Inspectors must complete training and 19 testing in the QA Procedures they will be using.
This process 20 assures their familiarity with the procedures used to determine 21 acceptance.
During inspections the Inspector compares the work 22 being inspected to these standards to determine its acceptability.
23 Q.
WHAT DOES THE INSPECTOR DO WHEN HE IDENTIFIES A
24 DISCREPANCY BETWEEN THE WORK AND THE REQUIREMENTS SET 25 FORTH IN THE PROCEDURES, AND HOW ARE THESE 26 DISCREPANCIES RESOLVED.
27 A.
The Quality Assurance Program in use at Duke Power Company 28 during construction at Catawba has several means available ~ to a
correct discrepancies that are discovered by inspectors.
There are 1
C four basic methods available, three of which do not involve writing 2
3 an NCI.
4 (1)
The first, which is sometimes referred to in some of the 5
procedures as the " hold point" method, consists of an Inspector 6
making the craft aware of a deficiency, the deficiency being 7
corrected to the satisfaction of the inspector, and the inspector i
8 signing off the item.
In this method, the item is not signed off until all necessary action has been completed, and the inspector is 9
10 satisfied.
This " hold point" method -- is common, and has been in 11 use at Catawba throughout construction.
12 (2)
The second is the " process control" method, whereby the inspection report itself provides the means to document a repair.
13 This method is used primarily in welding where, for example, a 14 final visual inspection might detect defects which would be recorded i
15 16 on the inspection form.
The procedure for the inspection and for making the weld would provide instructions on how to correct that 17 item (or that defect) and then provide instructions for reinspection.
18 All of this would be documented on the Process Control Form, which 19 serves both as a documentation of the work and the inspection of 20 21 that work.
22 (3)
The third method is a Deficiency Report Form.
There have been several different procedures available to inspectors under this 23 24 method.
The procedure currently in use is the Discrepancy Report l
25 Form, commonly referred to as an R-2A.
By this method, the inspector would document the problem he identified, and that would 26 then be sent to the Construction Technical Support group at the 27
(.
If 28 site.
That group would determine necessary-corrective action.
f s
such action involved the craft redoing work, it would go to the j
1 C
~
2 ciaft to be done.
The form would then be routed back to the inspector who would reinspect the work and, if satisfied, sign off 7
3 4
on it.
/
5 (4) Inspectors may ' use.QA Procedure Q-1,
" Control of
,t' 6
Nonconforming Items,"
and its corresponding form Q-1A, '
7
" Nonconforming Item Report," commonly referred to as an NCI.
This method is used when the discrepancy is not handled by one of '.
8 9
the methods discussed above.
,,,. /
10 The item is described on a Nonconforming Item Report form \\
4 tNn'y<
11 (Q-1A) and this form is signed by the originator.
It is 12 serialized, and presente'd to designated individuals in QA for 13 review.
These individuals review the form for completeness and 14 validity.
If the report is found to be invalid at this point the 15 reason is explained on the form, a copy is provided to the
/-
16 originator, and the form is filed.
After review, QA assigns the report to the appropriate department for resolution, and assigns a f.
17 review for reportability under 10CRF, Part 21 and 650.55(e) to the 18 19 appropriate department.
The item is then evaluated and the disposition is placed on the gj 20
/
21 form.
If a department other than QA provided the disposition, the 22 disposition is reviewed technically by designated individuals froin 23 the department providing the disposition.
The disposition is then reviewed and approved by designated individuals in QA for clarity 24 25 and completeness.
At this point the QA reviewer determines if 26 Significant Corrective Action Evaluation (Procedure R-6) is 27 required.
If he determines that such evaluation is required,,it is
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h7~y,
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indicated on the form.
Any action required, such as rework or I
reinspection, is added to the form and approved by QA.
2
,3 The form is routed to the groups responsible for any action.
~
,f
' A' iter they complete their action they sign the form.
When all 5
action is complete the form is set to QA for a final review to assure s
~
.6; it is complete.
i The originator tags the item when practical to indicate it is
/8 nSn-conforming by use of an NCI tag, Form Q-1B.
This prevents
/
+9 further work on the item unless so allowed on the form.
s.10 ' s Additionally, all R-2A " Discrepancy Report" forms are reviewed y
J
.~
11 /
- t
- for possible upgrading to an NCI.
R-2A discrepancies are required 12 by QA Procedure to be upgraded to an NCI if the discrepancy 13 represents any of the following:
a design deficiency (other than minor interpretations, 14 ~(
clarifications, and editorial changes)
-13 /
requires Design evaluation
,-IS a manufactnrer discrepancy (other than minor) i 17
?
requires extensive rework 18 a bypassed inspection hold point
~
19 _
~,
an item found at other than a preplanned activity and no 40 r 21 other required activities were planned that would check f
22 for that type discrepancy.
23 Q.
HOW IS THE DISCREPANCY REPORT FORM, R-2A, PROCESSED l1 24 AFTER IT GOES TO THE CONSTRUCTION TECHNICAL SUPPORT 25 GROUP?
/
26 A.
The Construction Technical Support Group is made up of engineers
~
27 and technicians who review the discrepancy and determine what
(.
28 ction should be taken to resolve the. discrepancy.
That
- o.
1 determination would then be indicated on the form and go to the C
2 ciaftsman involved who would be responsible for taking the actien, 3
signing on the form, and returning the form to the inspector for 4
reinspection of the activity if required.
This group also reviews 5
the R-2A for upgrading to an NCI based on the criteria contained 6
in the Procedure and listed above.
After the action is completed, 7
the form goes to QA for a final approval.
8 Q.
DESCRIBE THE ROLE OF QC AND QA IN THE ORIGINATION AND 1
9 RESOLUTION OF NON CONFORMING ITEMS WHILE YOU WERE 10 SENIOR QC ENGINEER PRIOR TO 1981.
11 A.
I was the Senior QC Engineer at Catawba from 1974 until February 12 1981.
During this period there ~were several revisions to the 13 Nonconforming Item Procedure (Q-l'); but, my role was essentially f
14 unchanged during this period.
15 When an inspector determined that a deficiency could not or 16 should not be handled by a method other than the nonconforming 17 method, he would obtain a nonconforming item form (form Q-1A) 18 and complete the top portion of the form.
If there was a question 19 in the inspector's mind as to whether an item was in fact 20 nonconforming, he might talk with his supervision to make a l
21 determination.
If this determination was that the item was not, in 22 fact, nonconforming, or that another method would be appropriate 23 to handle the item, then the form (Q-1A) would not be completed or 24 would be discarded.
If the form was completed, the inspector 25 would describe the item and its condition along with other 26 information, such as location, on the top part of the form.
The
(
27 inspector would then sign the form as originator.
A review of the M
1 form by the inspector's first line supervisor was sometimes 2
conducted at this point, but was not required.
3 Next,
the NCI procedure required review by a Senior 4
Engineer.
Normally this was the senior engineer in the originator's 5
section.
For example, I was the Senior QC Engineer and reviewed 6
most of the NCI's originated by the QC group.
7 There was no requirement to have a serial number assigned to 8
the NCI form at this point, however, usually a number had been 9
obtained by the originator at this point.
An inspector might not be 10 sure the item was nonconforming and would therefore intentionally 11
~ not have a serial number assigned prior to this review.
This _was 12 not the normal case, and the vast majority of NCI's submitted to me 13 for review already had a serial number assigned to them.
The 14 assignment of a serial number was purely a clerical function and in 15 no way involved a review of the NCI for validity.
A serial number 16 was assigned by the facilities group in construction simply because 17 they maintained the NCI log book.
18 The typical situation was for the inspector to give me a L
19 completed NCI form that was signed and had a serial number.
20 would review the NCI for accuracy, completeness, and validity, and 21 I might request that additional information be added to the form by 22 the originator.
This review was to determine:
if the item is clearly identified; 23 if the problem is clearly described; 24 what requirement has been violated and is it identified; 25 whether all the available information is given such that 26 27 the party assigned resolution will have all they would
(
28 need to understand the deficiency;
4 if the form is legible; and 1
C if there is another, more appropriate way to handle the 2
3 item; 4
If the NCI form needed work on clarity or legibility, or more 5
information was needed, I would explain what was needed to the 6
originator and airect him to obtain the information or clarify it and 7
resubmit the form to me.
If I had questions about its validity or 8
thought it was invalid, I would discuss it with the originator.
This 9
discussion might also include the inspector's supervisor.
If in my 10 judgment, I determined that the NCI was not valid, I would explain 11 this to the originator and handle it in one of two ways, depending 12 on whether the form had a serial number on it.
If it had a serial 13 number, I would either explain on the form why it was invalid or 14 go ahead and approve it, or ask the QA group to assign it to me 15 for resolution, in which case I would resolve the NCI by stating 16 why it was invalid.
In both cases the form would be forwarded to 17 QA.
If it did not have a serial number, I would return it to the 18 originator explaining why it was not a valid NCI.
If the inspector 19 expressed disagreement about the validity of the NCI I would 20 usually sign it.
In some cases I would direct that the discrepancy 21 be handled by another method, such as a Corrective Action Notice 22 (R-2A) or by informing the craft to correct it.
o 23 At least 17,000 NCI's have been originated at Catawba.
To 24 the best of my recollection, only a few per year, perhaps as many 25 as 20, would be invalidated during this kind of review.
Most of 26 these situations arose because the inspector had a question as to 27 whether the discrepancy should be an NCI. More often than not, I g
m
l I
concluded that these discrepancies would probably be best handled 2
as an NCI and would sign the NCI form.
3 The NCI Procedure in effect at this time stated that if an NCI 4
was determined to be invalid, the Ieason should be stated in the 5
description block.
My interpretation of this procedure was that 6
this provision applied to NCI's that had been logged and serialized.
7 Also, since the NCI procedure was used for nonsafety related 8
items, many times I would determine an NCI to be invalid because it 9
was not on a safety related system, and the same QA requirements 10 did not apply.
Some of the deficiencies identified by inspectors 11 would not be valid nonconformances on nonsafety related systems.
12 After review by the Senior Engineer the NCI was sent to the 13 QA group for assignment of resolution responsibility.
In June 14 1978, a block was added to the NCI form to include a QA review of 15-the origination also.
This change was inconsequential because the l
16 form was always routed to QA after Senior Engineer review.
17 The QA group would determine who would be assigned to 18 resolve the NCI and route it to them through the facilities group so 19 the log could reflect the assignment.
The resolution could be 20 assigned to either the Design Engineering, Construction or QA 21 departments depending on what requirement was violated and 22 whether or not Engineering evaluation was required.
23 The resolution or disposition would be determined and added to 24 the form and approved by a competent individual for technical 25 content.
This approval was not required for resolutions developed 26 by QA because it would get the review automatically.
The QA 27 group would then review and approve the resolution and indicate 28 any action to be taken.
1 If inspection was required as part of the action, it would 0
2 irivolve the QC group and usually the originator of the NCI.
Action taken would be documented on the form by sign-offs and the 3
4 completed form sent to QA for final review to ensure that all action 5
had been taken. The NCI was then considered closed.
6 Q.
IS THERE ANYTHING IMPROPER OR INCONSISTENT WITH A 7
SOUND QUALITY ASSURANCE PROGRAM FOR A SUPERVISOR TO REVIEW AN NCI WRITTEN BY AN INSPECTOR AND VOID THE NCI 8
BECAUSE IN A SUPERVISOR'S JUDGMENT, THE NCI SHOULD NOT 9
10 BE WRITTEN.
11 A.
There is nothing improper or inconsistent with a sound Quality 12 Assurance program for QA or QC supervision to review NCI forms 13 and give direction to inspectors, or other originators, as to the 14 validity of the NCI, or the appropriateness of using an NCI or 15 other methods to handle discrepancies.
16 A major function of QA and QC supervision is to make 17 technical judgments on problems identified by inspectors or others.
18 The supervisors in QA and QC at Catawba are experienced in the inspection areas reporting to them, and are well qualified to make 19 20 these technical judgements.
The Duke QA' Program at Catawba provides for checks on this 21 22 process.
For example, audits of the work of both craft and inspectors are continually conducted by groups independent from 23 24 the supervisors.
In addition, periodic audits are conducted by 25 groups independent of Duke to ensure that the QA Program is 26 functioning.
For example, we have the Joint Utility Management 27 Audit (JUMA) yearly,
audits by on site Authorized Nuclear
(
Inspectors (ANI), and periodic surveys by ASME teams to maintain 1
C 2
A'SME N-stamp authorization, and NRC inspections.
3 Q.
YOU SUBMITTED A SET OF RECOMMENDATIONS TO MR WELLS PRIOR TO TASK FORCE I ISSUING ITS REPORT. ONE OF THOSE 4
5 RECOMMENDATIONS WAS TO DISCONTINUE THE PRACTICE OF 6
VERBALLY VOIDING NCI'S.
WHY DID YOU RECOMMEND 7
DISCONTINUANCE OF THIS PRACTICE?
8 A.
Through my interview with Task Force I and discussions with 9
Mr. Morgan at the site, I realized that some welding inspectors considered an effort to reduce the number of NCI's on minor items, 10 11 by handling them using other established methods, improper. With this realization I recommended that what has been referred to as 12 13
" verbally voiding NCI's" be discontinued.
This was done in early.
14 January 1982.
Mr. Morgan, with my concurrence, instructed the Technical Supervisors and QA Engineers not to void NCI's.
15 Both my and Mr. Morgan's reasoning was that if this effort to 16 reduce minor NCI's in the welding area was being interpreted as 17 18 lack of support by the inspectors, then we should discontinue voiding NCI's until the QA Procedures could be developed which 19 20 would remove the concern.
The QA procedure to handle this implemented in July, 1982.
There was never 21
- problem, R-2, was 22 any effort to avoid resolving deficiencies; but rather, to handle 23 them in an appropriate way.
i WHAT OPTIONS WERE AVAILABLE TO A WELDING INSPECTOR WHO 24 Q.
BELIEVED THAT A SUPERVISOR MADE AN INCORRFJT JUDGMENT 25 26 IN INSTRUCTING HIM TO VOID AN NCI?
g 27 A.
Any inspector who felt that a supervisor had made an incorrect judgement in instructing him to void an NCI had not only the option 28
l
\\
1 but the responsibility to pursue his views about that decision 2
through the higher levels of supervision and management.
In 1977 i
3 this option was formalized in the Construction Department 4
" Personnel Policy and Practices" booklet under
" Employee 5
Relations. "
In 1979 tiiis option was formalized again in Duke's 6
" Management Procedures,"
" Employee Recourse Procedure" 7
(8901-0012).
All QC inspectors were in the Construction 8
Department at this time, and were aware of these procedures.
9 Q.
ANOTHER RECOMMENDATION WAS THAT THE CHARLES BALDWIN 10 AND ART ALLUM, TECHNICAL SUPERVISORS, SWITCH POSITIONS.
11 WHY DID YOU MAKE THIS RECOMMENDATION?
12 A.
In January 1982 when it became evident that several of the welding 13 inspector concerns involved relations between people, including 14 Charles Baldwin, I had several discussions with him about the 15 communications channels between him and the inspectors.
At that 16 time, Mr. Baldwin was the Technical Supervisor over the three 17 welding inspector crews.
It was apparent to me, through these 18 discussions, that communications between Mr. Baldwin and some of 19 the inspectors were strained.
He did not feel he had effective 20 communications with them.
I felt that switching Mr. Baldwin and 21 Mr. Allum would help to improve these lines of communication. Mr.
22 Allum was qualified for the Technical Supervisor position over 23 welding inspection by virtue of his background and experience.
He 24 had also served in that position at our Cherokee project.
Mr.
25 Baldwin was qualified for Mr.
Allum's position of Technical 26 Supervisor over NDE by virtue of his background and experience.
27 I
recommended that Mr.
Baldwin and Mr.
Allum switch
\\
28 positions.
Mr. Wells, my supervisor, concurred and the switch was
-S$-
1 made in late January 1982.
After the switch, Mr. Baldwin was the C
2 T'echnical Supervisor over two NDE crews and Mr. Allum was the 3
Technical Supervisor over three welding inspection crews.
I 4
believe this lateral move was effective in keeping lines of 5
communication between inspectors and supervisors more open than 6
they otherwise would have been.
7 Q.
DESCRIBE THE CHANGES AT THE CATAWBA SITE SINCE THE 8
EXPRESSION OF CONCERNS BY THE WELDING INSPECTORS AND 9
THE IMPLEMENTATION OF THE TASK FORCE RECOMMENDATIONS.
10 A.
There were several changes that occurred at Catawba, some as a 11 l result of the welding inspector concerns and implementation of. the 12 recommendations of the task forces that investigated those 13 concerns; other changes were the result of our ongoing effort to l(k 14 improve the way we do things.
Several procedures were revised 15 and clarified as a result of recommendations from the Task Forces.
16 Procedure Q-1, The Nonconforming Item procedure, was revised to 17 clarify what work activities could be allowed to continue on items 18 nonconformed.
Procedures H-4 and H-5, which control the 19 identification of piping materials and structural steel materials, were 20 clarified as they related to the marking requirements for 21 identification of those materials.
Procedure L-80, which is the 22 Visual Workmanship Standard for Welds, was modified by adding a 23 section that gave acceptance criteria for rounded indications.
24 Various other local site procedures or construction procedures were 25 revised as a result of specific recommendations of the Task Forces.
26 The manner of handling disputes or disagreements between 27 inspectors and their supervision or management was changed.
A
(
28 flow chart was developed for training QA supervision at Catawba in m
I how these situations should be handled.
This flow chart has come 2
to be known as " Stickman" and is attached as Attachment 2.
Any 3
inspector question, concern, or area of disagreement should be discussed with his supervisor and resolved at that level if possible.
4 5
If the supervisor is unable to answer the question or address the 6
concern because it may be out of his area of expertise or he may not know the answer, then he would refer it to this supervision, 7
8 which is the second level supervision in QA at Catawba.
The flow 9
chart indicates that this level would obtain the answer or resolution 10 to the concern or develop the answer himself if its in his area of 11 expertise.
If the answer is obtained from another source, Design 12 Engineering, Quality Assurance Technical Services Divisions, or a 13 Level -III Inspector in welding and NDE, then it would be 14 documented.
The questions and answers generated under the 15
" Stickman" process are supplied to the Technical Services Division 16 of Quality Assurance for review and possible incorporation into QA 17 procedures, and would be communicated to the inspector through 18 his first line supervision.
The inspector can pursue a recourse if 19 he is not satisfied with the answer.
This process was explained to 20 the inspectors during the implementation of the Quality Recourse 21 Procedure.
It has been clearly communicated to inspectors that 22 they have the right and the responsibility to pursue matters 23 involving quality of construction at Catawba.
In addition, training 24 of Quality Assurance Supervision emphasized that supervisors 25 should not direct inspectors to accept items that the inspector may not feel should be accepted, or may not be comfortable accepting.
26 The training included instructions on what to do in this situation.
27
~ he 28 If the supervisor is qualified and certified to perform t
- -34
1 inspection, and is comfortable that the item is acceptable, the 2
supervisor should accept the work.
3 We now have periodic meetings between Quality Assurance and Construction Engineering and Craft personnel to Management 4
discuss problems that may be encountered in the field in the use of 5
6 process control information.
These meetings have been. conducted in the major work disciplines and have been successful in -helping to 7
identify and resolve problems that may exist in the use of process 8
9 control.
Additionally, Quality Assurance Supervisors are involved 1
to a - greater extent in the review of Quality Assurance procedure 10 As a result of Train-The-Trainers Program started by i
11 revisions.
the Quality Assurance Technical Services Division, sessions are field 12 13 with site Quality Assurance Supervisors to discuss procedure These sessions include discussion of the reasons behind f
revisions.
14
{k.
15 the intent of the revisions.
In addition to these sessions, proposed 16 revisions to QA Procedures are routed to appropriate site These changes have resulted 17 supervision for review and comment.
in a better understanding of QA Procedure revisions.
18 Some of the changes that have occurred as a result of the 19 Non-Technical Task Force have involved the use of a standard color 20 4
hard hat for Quality Assurance personnel so that these personnel 21 are easily identified and feel more part of a team, a departmental 22 23 newsletter, and initiation of Quality Assurance forums.
Through 24 the Forum Procedure, Quality Assurance employees hold periodic meetings with their second level supervision to discuss any item.
i 25 26 New departmental procedures were implemented in Quality and inspectors and supervisors were trained in these 1-27 Assurance,
(
These departmental procedures were Recourse, Quality 28 procedures..
r-1 Recourse, and a Harassment Procedure. Procedures have existed at 2
the Corporate Level in these areas, but these procedures were 3
developed in greater detail for the Quality Assurance Department 4
and implemented in July of 1982.
Inspectors were instructed in the 5
existence of these procedures and how to use them.
In addition to changes that were a direct result of the Task 6
7 Force recommendations, there have been other changes that were 8
being considered prior to the concerns and have been implemented One of these areas involves the Quality Assurance 9
since that time.
10 procedures regarding nonconforming items and deficiency reports.
In 1981, we were not using Corrective Action Procedure, Procedure 11 12 R-2 in the. welding area at Catawba.
This procedure was used to handle minor discrepancies discovered by inspectors in the other 13 14 areas at Catawba, electrical, mechanical, and civil.
The reason this procedure had not been used in the welding area was that welding 15 involved more in-process inspection, such as cleanliness and fitup 16 17 inspections; and, therefore, the process control had established 18 hold points.
There did not appear to be a need to use another 19 procedure to handle corrective action for items that might be 20 discovered during _ these inspections.
This meant that any deficiencies or discrepancies would be handled either through the 21 22 hold point process or a nonconforming item.
This resulted in more 23 of the minor deficiencies and discrepancies in the welding area being documented on Nonconforming Items Reports than in the other 24 25 areas of inspection.
Revisions to Procedure R-2 were developed 26 and were implemented in June of 1982.
The use of R-2 was expanded to include discrepancies discovered by inspectors at any 27
(
planned inspection point they might be carrying out where no other 28
)
~
1.
instruction existed to handle the discrepancy.
The revision included a review of all discrepancy reports to see if they should 2
Procedure R-2 became 3
be upgraded to a nonconforming item status.
a primary method by which inspectors in all areas would document 4
discrepancies found at inspection points, if they were not handled 5
6 by informing the Crafts of the problem and having the problem 7
corrected.
All of these changes that I have discussed have had the effect 8
9 of improving the operation of the Quality Assurance Program at 10 Catawba.
It is our objective tc continue to look for ways that 11 program may be improved in the future. This is a characteristic of any good program, whether in Quality Assurance, or Construction, 12 13 or any other activity.
This is not to say that the Quality 14 Assurance Program was not effective before these changes were These 15 made.
The QA program was effective before these changes.
16 changes simply resulted in better understanding, better 17 communications,
and a
smoother operating Quality Assurance 18 Program.
l k.
. -37.
1
~
s 1
I hereby certify that I have read and understand this document, and C
(-
2 believe it to be my true, accurate and complete testimony.
3
.%]2:M/,n cL o.
m 4
5 6
Larry Jt. Davison 7
8 9
Sworn to p' d subscribed before me a'l day of September,1983.
10 this 11
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12 X
r.' L ) C ^ A. s v M r. n el I.
13
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14 Notary Public 15
> ; [. O. 4. I N b
'16 Commission Expires i
(
4
"e$
pfl RESUME LARRY R. DAVISON EDUCATION:
Graduate of Georgia Institute of Technology (Georgia Tech)
Bachelor of Science in Mechanical Engineering,1967 Completion of U. S. Naval Nuclear' Training Schools Six months, nuclear theory Six months, nuclear application (prototype)
Completion of U. S. Naval Submarine School Six months, submarine systems and operations Welding, Theory and Application, 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />, University of Tennessee Radiographic Film Interpretation, 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />, Magnaflux Corporation Duke Power Company Management Training Lake Hickory Training -Center Effective Management Registered Professional Engineer in North Carolina (8856) and South C
Carolina (7456)
EXPERIENCE:
U. S. Navy 1967-1971, Ensign - Lieutenant years schooling on nuclear systems and operation and submarines 1
24 years assigned to an operating Ballistic Missile Nuclear Submarine, USS Nathaniel Greene.
Served as Auxiliary Division Officer, Damage Control Assistant and Communications Officer.
Qualified in Engineering Plant as Engineering Officer of the Watch (EOOW) 4 One year in the shipyard undergoing major
- overhaul, conversion and nuclear refueling.
Duke Power Company,1971 - Present i
1971 - 1973 Assistant Field Engineer, Oconee Nuclear Station j
Worked in the Construction Department Technical Support welding area.
Writing welding construction procedures and i
reviewing and solving welding problems.
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. s, Resume Larry R. Davison Page 2 1973 - 1974 Associate Field Engineer, Oconee Nuclear Station Worked in the Construction Department Technical Support welding area.
Responsible for welding visual and nondestructive testing (NDE).
1974 - 1981 Senior Quality Control (QC) Engineer, Catawba Nuclear Station Worked in the Construction D'epartment QA area.
Responsible for all QA inspection in construction work at Catawba.
1981 - 1982 Quality Assurance (QA) Manager Projects, Charlotte General Office Responsible for all QA activities at three nuclear sites under construction, McGuire, Catawba, and Cherokee.
1982 - Present Project Quality Assurance (QA) Manager, Catawba Nuclear Station Responsible for all QA activities at Catawba Nuclear construction site.
Includes inspection, documentation review and filing, review and approval of construction procedures and
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deficiency reports.
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Objective 9.3.a.1 ; 9.3.a.2 : 9.3.a.3 Dicussion: Process for interpreting QA Procedures and answering QA Inspector (cont'd) technical questions.,..
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Verbal 3
1st Line Supv.
Verbal v
2nd Line Supv.
'F How to inspect Cri teri a?
Technical Meaning Document Borderline Proc., Dwg, Spec.
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v 1st & 2nc Line Level 111 Insp.
QA Tech Support Determine QA Tech Serv.
Design Eng.
Solution QA Tech Serv.
C Level til imput Const Tech Support
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.c 2nd Line Supv Periodic Review Logs Question &
With QA Tech Serv Answer Copy to.
Verbal V
1st Line S u ov..
Verbal 1P Answer to inspector i
D'sagree I
Agree N
A Quali ty Recourse e
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PRESENT QA ORGANIZATIONAL STRUCTURE re< 0A M=sen m
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