ML20134B218
Text
' - -
g.
]
o c eMar t.
l 4i 5
UNITED STATES OF AMERICA 6l NUCLEAR REGULATORY COMMISSION 9i to l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 11 '
12 !
l3 In the Matter of:
14 i g
13 HOUSTON LIGHTING & POWER Docket Nos. 50-4980L 16 CCMPANY, ET AL.
5 50-4990L 17.
S li '
(South Texas Project, 13 l Units 1 & 2) 20 ;
5
. 21 l 22
'3 l TESTIMONY ON BEHALF OF HOUSTON LIGHTING & POWER COMPANY, ET AL.
y f'
OF MR. GEORGE W.
OPREA, JR.
28 I MR. JOSEPH W.
BRISKIN 29 :
MR. RICHARD A.
FRAZAR 30 '
MR. JOHN M. AMARAL 31 '
32 i CN 33 *
,34 l THE EXPERIENCE OF HOUSTON LIGHTING & POWER COMPANY
'g3 l IN THE CONSTRUCTION OF THE SOUTH TFJAS PROJECT AND THE ACTIONS TAKEN AS A RESULT OF THE NRC ORDER TO SHOW CAUSE.
@8 l89 i
~
p0 l 61 !
02 i 03 :
\\
04 l c-i
'N Q9 l 8508150551 050703 gg Q,gg 0
L M7 t
L!
~
c 4
5i UNITED STATES OF AMERICA 6!
NUCLEAR REGULATORY COMMISSION 9 I BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 10 l 11 l In the Matter of:
5 13 5
HOUSTON LIGHTING & POWER Docket Nos. 50-4980L 14 CCMPANY, ET AL.
5 50-4990L L5 !
5 15 (South Texas Project, 5
17 +
Units 1 & 2) 5 13 5
L9 l 20 i 2' !
APPLICANTS' TESTIMONY ON THE EXPERIENCE OF fI HOUSTON LIGHTING & POWER COMPANY IN THE 73,
CONSTRUCTION OF THE SOUTH TEXAS PROJECT AND THE ACTIONS TAKEN AS A RESULT OF THE NRC SHOW CAUSE ORDER g,
2#
The following is testimony presented on behalf of k23 ;
Houston Lighting & Power Company, et al. (Applicants) on the 29 !-
experience of Houston Lighting & Power Company (HL&P) in the 30 i 31 :
construction of the South Texas Project (STP) and the actions 32 I 33 ;
taken as a result of the NRC Order to Show Cause dated 34 I 33 l April 30, 1980 (Show Cause Order).
The panel of witnesses 36 presenting this testimony consists of Mr. George W. Cprea, 38 Jr., Mr. Richard A. Frazar, Mr. Joseph W. Briskin and Mr.
39 i 40 i John M. Amaral.
41 I 42 l The testimony consists of the following segments:
43l!
44 (1)
Mr. George W.
Oprea, Jr. with respect to the
/
development and implementation of the Quality Assurance f
(QA) Program at STP and the HL&P management reaction to the NRC Show Cause Order; da,
51 ;
i m1=
s.
Li l.
l4j i5-(2)
Mr. Joseph W. Briskin with respect to EL&P's Task 6'
Force approach to responding to the NRC Show Cause Order; 9l and RO l
{y (3)
Mr. Richard A. Frazar with respect to changes made
,2,
to administrative controls in response to the NRC Show Cause
$3 14 order; 13 16 (4)
Mr. John M. Amaral with respect to Bechtel's recom-17,
13 mendations concerning alternative QA organizational structures 49 '
h0 for STP.
21 !
22 23 :
24 ;
29 F
T. Hudson:11:02:E 28 l 29 ;
30 I 31 32 -
33 '
34 !
35.
36 37 !
38,
39 40 l 41 -
42 ;
43 !
44 :
g-i 47 i 49 l l
s 50 '
51 -
'l i
1I 7;
4:
II TESTIMONY OF GEORGE W.
OPREA, JR.
6i REGARDING DEVELOPMENT AND IMPLEMENTATION OF THE QA PROGRAM AT STP AND E&P MANAGEMENT REACTION TO THE NRC ORDER TO SHOW CAUSE 9!
10 g
Q. 1 Please state your name and occupation.
u!
A. 1 I am George W.
Oprea, Jr., Executive Vice President 73 of Houston Lighting & Power Company (HL&P) and a member of 16 ;
the HL&P Board of Directors.
17 1r i 2.9 i 20 i Q. 2 Describe your professional qualifications and 21 22,
educational background.
,3 i yj A. 2 I graduated from Rice University in 1952 with a b~* i Bachelor of Arts and. a Bachelor of Science in Electrical 7
L 6
Engineering.
That same year, I joined HL&P in the Distribu-
'23,
i 59 !
tion Planning Section of the Engineering Department where I
~
30 !
'1, participated in computer applications engineering for system 3
'2' 3
33 :
planning.
In 1965, I was named superintendent of the Engineer-34 !
35 l ing Planning Division and two years later assumed responsibility 36 l pl as Project Manager, Energy Control Center.
In 1970, I was 38 I promoted to Manager of the Energy Control and Dispatching 39 I
$0 l Department.
I was elected Vice President of Operations in
%1 l 42 1 1971 and Group Vice President of Operations in 1973.
I 63 '
I
$4 assumed my present position as Executive vice President and g1 member of the Board of Directors in 1974.
(
67 1 68l 6
50' !
l
- 52. i a
1 i
4l 54 I am a registered Professional Engineer in Texas.
6\\
Q. 3 What are your responsibilities as Executive Vice 9l President?
10 A. 3 I am the senior corporate officer in charge of g
HI.&P 's nuclear program.
With respect to the South Texas S4 Project (STP), I am responsible for both Project management L3,
86 '
and quality assurance (QA) direction.
The EL&P staffs that
&7
&S' ;
perform Project management and QA activities at the STP do 19 l go i so under my direction and control.
81 l 82 Q. 4 What has been the extent of your involvement in b
STP?
84 '
A. 4 I have been involved in STP since the earliest b
SS ;
planning for the project, primarily from the standpoint of 89 !
administration and management control.
80 !
81 ;
Q. 5 Please describe the purpose of your testimony.
82 l g3 :
A.
5 The purpose of my testimony is to describe the 94 !
95 l devel pment of the QA program on STP and our experience in 86 implementing the program.
This will provide a perspective 87 l
^
88 against which to evaluate the NRC's Order to Show Cause and 89 i 00 l Notice of Violation of April 30, 1980.
My testimony briefly 01 1 02 1 discusses the NRC findings that supported issuance of those 3.; !
documents and how we have acted to improve the QA program.
O I will explain how and why we have made changes in the 3
program and why I believe that our QA program is a sound
+
1 60 91 C
l i o
t 4l 5i program that is adequate to complete this Project in accor-
&l dance with all applicable requirements.
Finally, my testi-9(
mony describes the performance I have been seeing on the 10 I ty i Project over the past year, since we made the major changes to ensure that the E&P and Brown & Root, Inc. (B&R) QA 14 programs are properly implemented.
I think that by covering 15 16 this ground I can best explain my view that our QA program 17 i 1E !
has been, and continues to be, in compliance with applicable 19 !
20 ;
requirements.
2]1 l Q. 6 Please describe in general terms how HL&P devel-2 l
oped its management team for STP prior to the fall of 1979.
['
A. 6 In the initial planning of the STP, E&P and the d
co-owners of STP decided to contract with B&R for Architect-28 '
29 i Engineer and Constructor services.
B&R is one of the world's 30 '
31 -
largest construction companies and it had nuclear experience 32 l 33 ;
as the Constructor of Carolina Power & Light's Brunswick 34 -
35 Nuclear Plant and the Comanche Peak Steam Electric Station 36 being constructed for Texas Utilities, Inc. and other 38 utilities.
The contract provided for B&R to perform QA 39 !
40 i services applicable to its scope of design and construction 41 i 42 l work.
This is a fairly typical contracting practice in the 43 1 44 l nuclear industry.
/
We planned to handle QA management in a manner similar g
47 l to the way other utilities had managed their nuclear projects, 4,
4 i
90 i 51 l i
a$o
l 1
/
Li 4,
5i i.e.,
the AE/ contractor was to provide and implement the QA
$a program for activities within the scope of its contract, but g i.
HL&P would maintain ultimate responsibility for the program 10 !
gy ;
and changes thereto.
To perform our review and approval
{2 role, we required B&R to submit certain periodic reports of 1
3 14 its progress on the Project and in the QA program.
L3 10 Of course, at the beginning of the Project B&R activities 17
&E,
were limited and EL&P's Project staffing was consistent with SS ;
20 that level of activity.
The resources EL&P devoted to R'jj ;
Project management in the early stages were greater than
'3 g4,
those HL&P had devoted to fossil Projects, but were nonethe-h"'
less quite limited in comparison to the Project team that b.
has since grown.
As design and construction progressed, 83 l 89 EL&P's staff on the Project expanded, and we went to a 80 g1 i matrix management system with a separate STP Project organi-82 g3 ;
sation.
By 1978, we had expanded from the initial 36 HL&P 84 !
g3 ;
personnel involved in the Project to about 180, including a
@6 l corresponding increase in our QA staffing.
By the fall of 8e i
88 !
1979, with accelerated design and construction activities 09 i 00 I EL&P's staff on the Project had grown to about 202, including 01 ;
62 i 17 professionals in the QA organization.
The increase was 03 !
e4 l not alone in numbers but also in the diversity of the technical 9
and engineering skills necessary to develop a Project of 3
37 '
this size and complexity.
g, ;
b 90 01
l L:
41 I
5 Q. 7 Describe the HL&P QA Organization prior to the 6:
fall of 1979.
9l A.
7 Mr. E. A.
Turner, then Vice President, Power
~0 !
1 11 Plant Construction and Technical Services, reported to me, 12 '
,3 and was responsible for both the QA Department and the
' 4 Project Management Team.
Under Mr. Turner, the Manager, QA, la.
16 was in charge of the QA Department.
Within the QA Department 17 i 15 '
there were a Projects QA Manager and, reporting to him, an 13 '
20 i STP Project QA Supervisor.
The Project QA Supervisor was g],<
2 stationed in Houston, and he directed the activities of the 23 l 24 ;
Site QA Supervisor, who was stationed at the site.
2-Under the Manager, QA there was a Houston-based QA h, f services group that was responsible for procurement QA and 29 :
the auditing of all quality related activities on the Project.
30 31 '
The HL&P QA staff at the Project site was supervised by 32 1 33 l the Site QA Supervisor.
The staff under the Site QA Super-34 1 35 i vis r was divided into four groups:
general, civil, electrical 36 37 l and mechanical.
28 39 ;
Q. 8 During the period up to the fall of 1979, what 40 l was the role of HL&P's QA staff?
41 '
42 '
A.
8 As discussed by Mr. Frarar in his testimony on 43 6
44 l the management of the HL&P QA program, B&R provides QA 3
q services on the activities within the scope of its design 67 f and construction contract.
Other QA services are supplied 4p 4
50 51 i i
7
i
,i 4;
5l by the various vendcrs (including Westinghouse Electric 6l Corp.) and subcontractors.
The E&P QA staff has performed 9!
an oversight function and provided direction to the contrac-LO l g!
tors on implementation of the STP QA Program requirements.
L2 g3 In the early stages, the Project activities were devoted T4 7,
to design and procurement, both of which were handled out of L6 '
the Houston offices.
The E&P QA staff was based in Houston L7,
LI !
and its attention was focused on these activities and on L9 20 Writing procedures for the QA functions during construction.
21 :
22 !
As construction progressed, EL&P's site QA staff was expanded.
\\
93 I.4 The E&P QA staff reviewed Project documents such as the Nonconformance Reports described in Mr. Frazar's testi-many, monitored on-site QA/QC activities, and provided ZS i 29 i direction to B&R on the QA Program.
The E&P QA staff in 30 '
31 '
Houston continued to be responsible for EP's Project audit; 32 ;
33 activities and vendor surveillance.
The E&P site QA staff 34 !
35 i monitored the on-site activities of B&R and its subcontractors.
36 The HL&P site QA group developed a plan which identified 37f 38!
those functions of B&R construction and QA/QC to be monitored 39,
60!.
and the frequency of surveillance.
Checklists were developed il 62 l to implement the planned monitoring and surveillance.
If, 63 t 64l during the course of monitoring and surveillance, a noncon-e formance or procedural deviation was identified, the HL&P QA L7 '
gp j personnel had several alternative procedures to direct i
10 t
51j
____c s _ _ _______ ________________________ _ _____________ -____________
l e*
O
' 5' 1
!L i 2[
i i4i
,6l correction of the condition, depending on its scope and 5
significance.
They could request the cognizant B&R QA/QC 9
Inspection Supervisor to initiate a deficiency report; note lloiti the unsatisfactory condition on the inspection checklist and yigi draft a memorandum or letter to the responsible party; or l14 '
L9 request the E&P Site QA Supervisor to issue a Stop Work c
l16 !
Notice.
The E&P site QA group reviewed and approved the
- 17 i l13' !
planning, development and implementation of B&R QA and
- 19 !
20 i construction procedures and participated in the resolution
i2 23 '
and Construction, and the NRC.
24,
25 i Q. 9 During the period up to the fall of 1979, were i
there regular inspections performed by the NRC Office of 29 l Inspection and Enforcement (I&E)?
!30 !
l31 l A. 9 Yes.
NRC inspections began even before the con-
!32 !
33 l struction permits were issued and there were unannounced NRC 34 l 85 i inspections on an average of once a month.
The NRC sta-tiened a full-time resident reactor inspector at STP in S8 September 1979.
Prior to November 15, 1979 there had been
.89 i
- 60 '
59 NRC inspections and investigations, which we understand 41 62 l l03 I to have involved about 2,700 inspector-hours of effort.
l l64l Q. 10 During that time, did the NRC inspectors find 0~ \\
any incidents of noncompliance with NRC requirements?
G'l 68 9u \\l (91 l l
a*
l L;
y; 1
4l 5:
A.
10 Yes.
There were findings of noncompliance in 6i several of the inspection reports.
Up to November 15, 1979, 9;
there had been 33 such findings.
{O '
Q. 11 How were those findings classified by NRC?
A. 11 NRC has three classifications for noncompliances:
14 (i) violations, (ii) infractions, and (iii) deficiencies.
g, 16,
violations are the most serious noncompliances and deficien-17 i LE !
cies the least serious.
The NRC found 27 were infractions 19 i 20 '
and 6 were deficiencies.
There were no violations.
2]T 2
Q. 12 How did the Company react to those NRC findings?
13 !
A.
12 Any citation of noncompliance is disturbing and 24 :
f our initial reaction was to question the HL&P QA staff as to i
why these problems had not been identified first by HL&P.
28 i 29 '
The HL&P st'aff immediately prepared responses to the citations 30,
31 1 and HL&P management approved each response.
I realized that 32 !
33 ;
in such a large and complex undertaking there were bound to 34 i 33 j be some deficiencies, but I hoped to keep them to a minimum.
3$ l So, I was kept informed of the HL&P staff reports concerning 3s i 38 the circumstances of.the noncompliances and of the corrective 39 '
40 l actions taken.
41 i 42 Q. 13 Did the NRC notices of noncompliance prior to 43 44 late 1979 indicate to you that there were serious deficiencies e
i in the QA program?
i 47 1 4A i 00 ;
51 i
c.
l 4
I i
ILj 2,
1 4
l l5l!
A.
13 No.
As I just said, every finding that we were l
<6j not in compliance with the NRC requirements concerned me, t
9 but I knew that with a project as large and complex as STP, 30 l there were bound to be some of these incidents.
It was my g
judgment that these were isolated events on a project that 11 was achieving generally good quality work, but we were 12 16 '
intent on maintaining as low a rate of noncompliance as 37 i
%El possible.
In addition to our site QA grcup, EL&P was monitor-SS I go i ing the implementati.on of the STP QA program with our staff l82, I l82 l f QA auditors.
The auditors conducted periodic formal audits of the design and construction activities and prepared l85 !
written audit reports.
Our own audits, confirmed that construc-3 tion was generally proceeding in compliance with NRC require-e 188 l i89 l ments and Project design requirements.
i80 I lgl l Q. 14 During that period before the fall of 1979, were 82 i
- g3 ;
you aware of confrontations between construction personnel 84 !
@7 l A.
14 Yes.
I was informed of a physical altercation 86
[89 :
between a Civil QC Inspector and a concrete foreman in June 88 60 1977.
The testimony of Mr. Charles Singleton describes the 01 l62 l incident in detail.
HL&P's QA staff investigated the matter 03 le.g \\
and was involved with B&R at the Project level in deter-19- \\
mining the appropriate response to prevent the incident from 67 i ggl adversely affecting the morale and attitudes of Project 8
personnel.
,9u l91 :
l I
{
I 1
7
'4i 5l E&P Project personnel held discussions with the B&R 6!
Construction Project Manager and a policy aimed at minimizing 9j friction and altercations was developed.
Additionally, I R0 !
Q:
was briefed on the report of the NRC investigation regarding 12
.g i the June 1977 incident and the E&P Site QA Supervisor's S
action on the incident.
I did not get directly involved 16 with the action taken on this incident because I felt that 87 ;
15 !
it had been thoroughly investigated by my staff and the NRC, 89 I l80 !
and that the action taken was satisfactory.
'81 82 :
Similarly, I was informed of the incident which took 83 g,
place between a B&R Construction Engineer and a Civil QC Inspector much later, in March 1979.
This incident is also 6
described in the testimony of Mr. Logan Wilson and Mr. Warnick 8s i 89 I and, as they indicated, was also investigated by the NRC.
80 !
31 !
Again, no further action on E&P's part was warranted since 82 !
g3 !
the incident had been investigated by my staff and the NRC, 84 !
g3l and the action taken by B&R was satisfactory.
When Mr. Swayze was fired in August 1978 as discussed 38 I in the testimony of Dr. Broom, we were concerned that his 39 I 40 !
firing might be improperly interpreted by other QC Inspectors 01 42 l as a form of intimidation.
But, as described by Mr. Logan 43 i 44 l Wilson, our increased surveillance showed that Mr. Swayze's
/
i firing had no adverse impact on the QC Inspectors' job 47 performance, and this matter was, of course, also investi-p i
1 i
gated by the NRC.
- 20 i
,{
51 i
__NS?_--________--____-----__--------_--_----------------__-------------------U
4 b!.
41 5i Q. 15 Were there other instances of friction between S.i QC and Construction personnel?
ei gi A.
15 Yes.
As pointed out in Mr. Logan Wilson's j
j SO !
l g;
testimony there is always some friction between construction U
and QC, if QC is performing its job, and the degree of 81 14 friction varies from time to time.
Prior to about mid-1979,
,' 0 l
'86 there were some isolated ~ instances of threats or minor 87 LE l harassment between construction and QC personnel, but neither SS i 80 our utvestigations nor those of the NRC found additional y<gi specific allegations of serious threats or abuse being l23 directed to QC Inspectors.
Thus, although EL&P staff at the f84,
f'~
site remained on the al.ert with respect to such matters and b.
thoroughly investigated all allegations, there were no l
88,
89 !
serious problems during this time frame.
When several 80 i g1 allegations of abuse or threats directed at QC Inspectors 82 g3 ;
arose between August 1979 and year-end, these were jointly 84 !
g3 investigated by HL&P and B&R and, as described by Mr. Logan j
Wilson appropriate actions were taken, including reprimands 88 and terminations.
89 I 60 l Q. 16 Were there at times indications of low morale Q1. \\
62 l among the B&R QC Inspectors?
03 I g.g l A.
16 There were some indications of morale problems among the QC Inspectors.
Towards the end of 1977 and early 7 I
,j 1978 members of our QA staff brought to my attention their ua !
judgment that there was low morale among the Inspectors.
92,,!
i I
L mW
-r I
1l
- P i
41 5 !
The Inspectors were performing their work adequately, but we had some concern that if the condition persisted their 10 {
9 performance would be adversely affected.
l ty i Q. 17 What action did you take?
12 ii A.
17 I directed our QA Manager, Mr. Frazar, to express 3
S4 '
our concern to B&R.
In January, 1978, Mr. Frazar made a 1.
16 ;
presentation of our views at a meeting of the B&R QA Manage-17.
15 l ment Review Board, which is an executive level board that 19 I 20 i meets periodically to review the effectiveness of the B&R QA 27 -
23 I program.
B&R took a nwnber of actions to improve the situa-43 !
}4 ;
tion including holding meetings with Site Construction hi Superintendents and QA/QC supervisors at which B&R manage-ment emphasized B&R management support of the QA program and 23 i 29 l the importance of conformance to project procedures.
In 30 i 31 l addition the QC training program was improved, Project 32 l 33,
procedures were reviewed to improve their clarity, and B&R 34 !
35 l stepped up its efforts to recruit new personnel to strengthen 36 the B&R QA organization.
Mr. Frazar instructed the EL&P QA 37 38 i staff to perforn extra surveillance over the following few 39 !
40 l months.
They reported to the EL&P Projects QA Manager that 41 1 62 B&R had implemented a number of corrective actions and that (3
64 l improvements had been observed.
Mr. Frazar returned to the i
QAMRB in May 1978 to report on EL&P's observations.
During 7'
p the same time period, B&R appointed a new Project QA Manager 6!O,!
51 i i
i
-M-
a L;
.i 45l who was experienced in nuclear QA and we viewed his appoint-A!
ment as a further step in improving the B&R QA program.
9 l Q. 18 Did the NRC Staff also express concern regarding 10 l
{y ;
the morale of QC. inspectors?
12 A. 18 Yes.
13 In the summer of 1978 the officials of 14 Region IV of NRC I&E met with Mr. Turner and members of the 15 '
16 HL&P QA staff to express concern about morale among B&R QC 17 i ig !
Inspectors.
In response, EL&P and B&R took a number of 13 !
20 i steps.
These included direction to the B&R Project QA 21 2} !
Manager to spend more time in the field, an increase in the S3 84 l number of Construction Engineering personnel, changes in i
t 9~ ;
project procedures and increased HL&P surveillance of con-l struction activities.
These changes, coupled with the 23 29 personnel chqnges and other improvements which had been made 30 I 31,
earlier in the, year, appeared to bring about improvements in 32 '
33 !
the morale of QC personnel.
4 3
Q. 19 Were there, at times, conditions that warranted 16 action to stop work at STP?
37 38 !
A.
19 Yes.
39 i A 4 top work procedure is commonly employed toj by companies involved in nuclear plant construction to atop LL i 62 j an activity when there is reason to believe that the work L3 :
9;l will not be performed in accordance with the applicable t
requirements.
Generally, a stop work order is issued by QA 7l Management when they have doubts about the quality of work
!Oi il 1 E
s' i
l l!
-i 45' being performed, the adequacy of implementation of a proce-6i dure or the qualifications of the construction or QC personnel u,
involved.
When a stop work order is issued, the Construction 9l LO !
Manager is required to cease work in the affected area until
,y ;
authorired to resume work by the QA Manager.
Issuance of 14 stop work orders reflects the fact that the QA Manager is 15 '
16 ;
exercising the authority and independence he is required to L7 i Lg l have under the NRC's regulations.
L9 20 Q. 20 How often were such work stoppages ordered by QA 99'I personnel prior to the fall of 1979? 3 A. 20 There were 16 stop work orders issued on specific 1" site activities through November 15, 1979, and in each case 1. the conditions were corrected and the work resumed. As an 28 i 29 ! illustration, the site QA Manager stopped work on all safety 30 i 31, related concrete placements in both Units 1 and 2 in June 32 ' 33 ; 1979 as a result of the discovery of voids in lift 8 of the 3 Unit i reactor containment (RCB) shell wall. An investigation 36 ! was conducted to determine the cause of the voids and as a 37 ! 38 i result, a list of corrective actions was defined that would 39 : 40 i preclude recurrence. QA reviewed the planned corrective 41 i 42 l actions and issued a partial release of the stop work order 43 ! 44l on June 29, 1979, permitting placements of safety related concrete in areas other than the RCB shell walls. After [ actions were taken to integrate these corrective actions 4 50 : $1 ; 1 - M -__________ _ l
i l' t 41 5! into construction and inspection procedures, the stop work 6! order on RCB shell placements was lifted on September 6, 9lr 1979. ) 10 l LL ; This procedure is characteristic of how work is stopped, 12 13 l corrected and resumed in an orderly manner. 2 4' Q. 21 Please describe EL&P's QA audit program prior to 16, the fall of 1979. 17 i LE l A. 21 EL&P's Houston based QA auditors performed 19 l 20 periodic formal audits of both HL&P organizations and the 21 ' 22 ' organizational components of B&R, Westinghouse and other 23 ' contractors and vendors. Audits were generally performed 24 ; 2'0 annually, but the audits of the EL&P and B&R QA/QC organi-e .ations were scheduled semiannually. In addition to the 29 I specified minimum audit frequency, additional audits were 3 0,. 31 l performed at the request of Project QA management when there 32 i 33 I were apparent problems in a particular area. The EL&P 34 ! 35 j auditors reviewed the records of each organization to verify 36 l compliance with the applicable QA requirements. Whenever 37 38 their audits identified problems in various aspects of the 39 t 40 l project, the Audit Deficiency Reports were sent to the 41 i 43lI 42 audited organizations and their corrective actions were 44 l verified through follow-up audits. J g Q. 22 During the period prior to the fall of 1979, 47 l 4p j when you considered the NRC notices of noncompliance, the 4 r 50 ' 51, -17.
1: 4l 5 number of stop work orders, the results of HL&P audits of 6i the project and your own observations, what was your judgment o 9! of the QA program performance? 10 ! 3l A. 22 From the start of the Project until well into lT2 y3, 1979, it was my belief that the QA program was working well. h4 The kinds of problems found on the Project during that 15 ' 16 : period were typical of those being experienced on other 17 + 15 ' nuclear construction projects. Basically, it appeared that 19 ' 20 the QA program was identifying the quality concerns that it 2}1 2 was designed to detect. Because neither we nor the NRC i I 23 identified major QC problems, we had no reason to question 24, 2; the adequacy of our QA function -- our tool for detecting
- 2. :
fundamental problems in our management of the quality program. N: 29 t Q. 23 During 1979 were there indications to you that 30 1 <1; there were problems developing in the implementation of the '2 <3; STP QA program? <41 A. 23 During the first part of 1979 I noticed an <5, increase in the number of noncompliances identified by NRC '8' inspections. This trend continued in the balance of the <g; 0I year, however, I attributed the increase to heightened 1! 2l regulatory scrutiny in the wake of the TMI incident and to 3!fl the increase in the pace of construction as the Project 4 progressed. When the NRC special inspection team identified 7! P \\ O i 1; l l i 1 -1#-
.i i ':I I 4; 5 6 [s. preliminary information from their activities in late 1979, I however, I realized that the trend I had been seeing was gi associated with some fundamental problems. As I reflected 10 11, on the information developed during 1979, I was struck not f so much by the seriousness of each item (with the exception 14 of the allegations of harassment and intimidation) as by the 15 15 fact that, underlying these specific instances of noncompli-17 ;i 1Tl ance, was the possibility that they might be traceable to 19 j 20 : more basic management problems -- specifically the effective-2tgj ness of the QA program. Against this background, I decided 23 ; 24 : to get. an independent evaluation of our QA/QC program and hi retained the Bechtel Power Corporation (Bechtel) to perform i such a study. This was a valuable step because Bechtel's 28 i 29 l study later provided a perspective against which we were 30 ! 31 l able to address the NRC's Notice of Violation which was 32 ! 33 ; issued about four months later. Rather than dealing with 34 I 35 l twenty-tw separate and apparently unrelated. matters, many 30 l of which were relatively minor, we were able, with insight 38 gained from the Bechtel study, to address causes rather than 39 s' mptoms in responding to the Commission's Order. 44 I y 41 ! 41 j Q. 24 Did you meet with Mr. Karl Seyfrit, Director of 43 ' 44 i Region IV and his staff during the course of the NRC investi-I / gation? 47 l 49 A 50 l 51 i ,19,
i L! - s -l 4t 5! A. 24 Yes. On December 21, 1979, Mr. Turner and I met CI with Mr. Seyfrit to discuss the preliminary findings of that 9{ investigation. We were told that there were serious problems f in the QA/QC program related to concrete placement; that QC 12 ' inspectors had experienced harassment; and that there had 13 14 t been noncompliances with certain concrete placement require-L3 > la ments. 17 i Lg l Q. 25 How did HL&P react to that information? 13 i 20 A. 25 Upon hearing that such problems existed on the 27 2j 4 project, EL&P decided to stop placing safety-related concrete 23 ' until we could review the situation and determine what 24 l I' l corrective actions were needed. A week later, on December 28, I 1979, Mr. Frazar, various other HL&P staff members and I 6. 23 t 29 l Went to see Mr. Seyfrit and discussed the elements of a ' 30 ' 31 program to correct the conditions the NRC staff had found. 1 32 33 I confirmed our commitment to a specific nine-point program 34 in a letter that same day. The details of the program are 35 36 ' in Mr. Fra:ar's testimony. Briefly, however, we committed 37, 38 ! to renewed training and indoctrination; clarification of 39 1 40 l procedures on field design changes and, finally, we decided 41 i 42 l to keep in effect the stop work, while limiting it to safety-t 43 1 44 related complex concrete pours. Q. 26 Did HL&P fulfill those commitments? 47 l
- l 50 i 51 Io 1
\\ 1! 7 4l 5: A. 26 Yes, we did. We kept NRC informed as we completed 65 the various elements of the program and NRC verified our 7l implementation. 3 80 i gi Q. 27 Was there another meeting at which NRC dercribed 1 more fully the findings of its investigation? S4 ! A. 27 Yes, there was an exit interview held on January 24, 1_= &S : 1980, at the STP site. I attended that meeting along with S7 ! 15 l Mr. Turner, Mr. Fra:ar, and other members of the HL&P QA SS 80 t staff. 91 t y! Q. 28 What were the NRC findings described at the meeting? 'hC A. 28 The NRC Staff reiterated the findings described to me in the previous meetings, that the placement of concrete 23 1 29 ' was not being performed in accordance with project procedures. l 30 i 32, ; In addition, the NRC identified noncompliances in the welding, 32 ' 33 ! non-destructive examination (NDE) and backfill placement 34'l 35 pr grams. They found that de Project QA orgn=ations were 36 j not effectively analyzing trends in the occurrence of noncon-37 ; 38 I forming conditions and not fully implementing the audit 39 ! 40 l programs and that there were inadequacies in the control of 41, i 42 documents on the job site. 43 44 l Q. 29 How did you react to the exit interview? A. 29 The earlier meetings with the NRC Staff had 4 forewarned me of the seriousness of the findings.
- Candidly, t
1 50 t 52.! l i 1' 1p oi 5' however, I had not expected that noncompliances would be 6! identified in so many aspects of the Project. I decided y: that our response to the findings would not await documen-RC l gl tation of the inspection findings in a formal report. We ~ immediately set about determining the needed corrective b4 actions and within two weeks we sent NRC a letter outlining 15 ' SS further actions we would take in response to these noncom-17 i SS' l pliances to improve performance on the Project. 13-l ,2 c ; Q. 30 What improvements did you make as a result of 81, 22 the exit interview? A. 30 We made a number of significant changes. We !2fI improved our program for reporting and trending noncon-2. I: formances; revised our audit activities; and modified our
- 2b i
- 2 9 !
welding, NDE and backfill placement programs. We also O't I committed to an independent audit of our QA/QC program. c2, ay These changes are described more fully in Mr. Fra ar's a41 =5 j testimony. a6 Q. 31 Did E&P keep the NRC advised of these changes? "8=9 f A. 31-Yes. The NRC was advised of our progress and ~ yo ! documented the results of its inspection of our implemen- ~ 31 i p2; tation in its inspection reports. The specific reports are 33 ' b4, l numbers 80-17, 80-19, 80-24, 80-30, 80-38 and 81-03. 30 1 Q. 32 How did E&P implement its commitment to an l l independent audit of its STP QA Program? ) w ! -1 l L L2$ s ! 5 A. 32 As I previously mentioned, we retained Bechtel i 6) to undertake a thorough review of the STP QA program. Our 3i objective was to obtain a top.to bottom evaluation of the 10 l 11 program by an organization experienced in nuclear construc-f tion projects. We selected Bechtel because it has more experience designing and constructing nuclear plants than 15 l any other organization in the United States, and of course, 17 : li ' its QA experience on large nuclear projects is extensive. 19 20, Bechtel committed a number of senior QA specialists to 33lI 2' conduct the review. John Amaral, then Manager of the Divi-22 sion of Quality Assurance at Bechtel's office in Gaithersburg, 23 ! Maryland, supervised the effort. Q. 33 What were the results of the review conducted by 2u 29{i Bechtel? 30, 31 ; A. 33 Bechtel's activities continued over several 32 I 33 months during which Bechtel made progress reports to me. 34 ; 35 ! Bechtel made a number of recommendations for improvements in f. the QA program to eliminate the " root causes" of the short-3e 38 comings identified in the audit. The Bechtel findings and 39 40 recommendations are discussed in more detail below. 41 42 l Q. 34 On April 30, 1980, NRC issued its formal investi-43 44 gation report (I&E 79-19) accompanied by a Notice of Violation, 40 l an order to Show cause and a Notice of Proposed Imposition fj of Civil Penalties in the amount of $100,000. Describe the 4, Sw 51 ! L li Oj 5i noncompliances identified in those documents and the actions 6i ordered by the NRC. g A. 34 The Notice of Violation identified 22 instances R0 gl of noncompliance and the Show Cause Order directed HL&P to f.3 study alternative organizations for the quality assurance S4 program; to perform studies of the adequacy of the backfill, 13 $6 concrete and welding work already completed on the project; 17 83'l to cause B&R to rescind and revise a January 1980 brochure 19 i 2.0 i and lecture on QA (discussed more fully belcw); and to 21 22 clarify or strengthen the Project systems related to stop work authority, the procedures for identifying and correct-25 l ing the root causes of nonconformances, the procedures for [ control of field design changes, the Project record controls, o!9! and the audit programs. There was also a question regarding =0f 1i the accuracy of two statements in the FSAR, which will be 2l 3i discussed further in the testimony of Mr. Pettersson and 4l ,3 ! Mr. White. Q. 35 How did EL&P management respond to the NRC '8l actions? <9' so A. 35 From the first meeting with Region IV persoluiel 21 J2 i in December, 1979, both Don Jordan, the President of HL&P, 33 I .g ' and I recognized the seriousness of the findings. Copies of ~ the NRC investigation report, Notice of Violation and Show f Cause Order were sent to the members of the HL&P Board i I u1I l l t Li 2: O, 5i of Directors. our Board has evidenced a continuing interest 6, in the enforcement action and our response to it. I cannot 91 recall a meeting within the last 18 months that Mr. Jordan 10{' or I have not been asked que.stions about STP by other Board I yy ff members. S4 Q. 36 15 ' How did HL&P go about responding to the NRC 16 enforcement actions? 17, if ' A. 36 We were anxious not only to correct the deficien-19 i '2 0 i cies identified by NRC, but also to determine whether there 2}5 were other, perhaps more fundamental, quality related problems 2 '3 34 on the Project. The meetings during December 1979, and 25 ; January 1980, had forewarned us of the NRC findings, although 2 I not of the nature of NRC's enforcement action. We had l 20 i 29 ! l already taken a number of corrective actions, most of which l 30 t 31 ; are enumerated in my December 28, 1979, and February 7, 32 33 l 1980, letters to NRC Region IV. We had also commissioned the Bechtel audit of the STP QA program. Nevertheless, I 6 recogni=ed that more extensive measures were required. 38 i 39 i The Notice of Violation and Notice of Proposed Imposition 40 j of Civil Penalties required a response within 25 days, 'Ne 41 i 42, had to investigate the allegations and determine if they 43 l '4j could be substantiated or disproved. We created a special 4 13 l l task force under Mr. Frazar to perform the investigation. j Upon completion of the investigation we assigned Mr. Joseph kw 31 l i 1.t l 5li Briskin, E&P's Manager, Houston Operations, on the STP to 8l take over direction of the Task Force, conduct the needed 9{ studies and propose responses to the Show Cause order. Mr. Briskin's testimony describes the Task Force and. how it 12 accomplished its mission. !14 Q. 37 How did you respond to the findings of noncom-is $6 pliance in the Notice of Violation? 17 i 4r, A. 37 After investigating the findings, we determined y 50 that although we could not substantiate each of the findings in detail, they suggested a need to examine the effectiveness of parts of our QA program. Consequently, rather than 2" ! developing responses to details of the findings, with the (83 l' help of the Bechtel audit we set about identifying the 29 causes of these problems and putting into effect changes to 80 i 32, ' correct and upgrade the QA program. '3 2 ' 3 Thus, the May 23, 1980 response to the Notice of f Violation did not challenge the 22 findings, but described 6 the specific actions EL&P had already taken or would take in 87 03 ' the future to correct the condition and prevent its recurrence. 99 ' 00 ; our response was not confined to these specific findings. 01 l 02 i We pointed out that E&P's studies of the underlying causes 03 \\ c4 l identified six areas where performance should be improved, I and we stated that the necessary improvements would be made. 07 ! 4 00 !
- 01 '
I 1: 2 4i Q. 38 What are the six areas listed in EL&P's response 6' to the Notice of Violation? 9l A. 38 We identified the need for improvement in the 80 ! gi following six basic areas: f2 l (1) translating specifications and job requirements into 84 ' clear, simple procedures; L3 86 (2) documenting nonconforming conditions and trending them 87 r 85 l to identify Project weaknesses; 89 l 80 ' (3) training and indoctrination of personnel at all levels 212] ' regarding the quality program with special emphasis on the g'3 Project goals of reliability and safety; 4 83 ; (4) system controls to assure that quality related activities ? are initiated, controlled and properly documented; o 83 ' 89 l (5) verifying through an effective audit system adherence 80 ! 81 ; to procedures; and 82 i g3, (6) visibility of, and participation by, upper management 84 I g3 ; in QA activities, b6 j HL&P's studies and the review conducted by the consul-84,- 88 ; tants indicated that.the specific problems in the QA program 89 ' 00 I were traceable to one or more deficiencies in these six 01 l C2 i areas. The response to the Notice of Violation advised the 03 i 04 l NRC staff of HL&P's intent to concentrate on improvements in 6-l these six areas. l F G7 ! 08 I 4 Ou OS r
L, 4' 5! Q. 39 What actions were taken by HL&P and B&R in 6I connection with allegations of incidents of intimidation and I harassment of QA/QC personnel referred to in the NRC Notice 9 10 ; 11 l of Violation of April 30,.19807 12 ' g3 l A. 39 As set forth in detail in our response of May 14 23, 1980, EL&P and B&R took a number of actions. They L3 16 involved improvement in procedures to minimize Construc-87. 85, tion-QC friction; institution of an extensive recruiting 89 ; 80 ! program to increase QA/QC staffing; upgrading of job 21 ! 82 ' classifications and salaries, and other actions to improve 23 I g4 morale; changes in personnel and assignments; improvements [' in contacts between QA management and site personnel; b increased HL&P involvement in the QA/QC program at the site, 88. 39 heightened HL&P QA vi,sibility in the field, and enhanced 80 81 activities of HL&P site Surveillance personnel; and improved 32 i 33 i training of and communication with both QA/QC and Construc-l34 l35, tion personnel. Additional information concerning B&R's actions are contained in Dr. Broom's testimony. 38 Q. 40 The Order to show cause (the " Order") required a '39, 40 i written response on ten separate matters. How did HL&P 41 ' 42 i prepare its response? 43 l 144 l A. 40 The ten areas covered by the Order can be placed in four basic categories: 7' >= ; 4 50 51 l
\\ 1 ~, 4l 5 (1) the QA/QC organization (item 1); e (2) verification of the adequacy of already completed 9! ~ construction activities related to backfill, concrete and 90 {1 welding (items 2, 3 and 10 ) ; 12 (3) rescission and replacement of the B&R brochure on QA i 73 14 Program implementation (item 4); and 1.2 16 (4) improvement of administrative controls (items 5, 6, 7, 17 1T i 8 and 9). 19 l 20 The Task Force directed by Mr. Briskin was assigned to 21 l 22 l study the issues raised by the order. Mr. Briskin's testimony 23 describes how the Task Force approached its assignment. f When the Task Force recommendations were'made, including 1-draft responses, senior management of B&R and I reviewed 28 i 29 those recommendation and the response was submitted to the 30 l 31 : NRC. The responses concerning verification of completed 32 : 33 ! construction activities are discussed in the testimony of 34 I 35 l Mr. Pettersson, et al. (Backfill); Mr. Murphy, et al. (Con-3f crete); and Mr. Saltarelli, et al. (Welding). The responses 38 l we submitted regarding the administrative control items are 39 40 l described in detail in the testimonies of Mr. Briskin and 41 ! 42 l Mr. Fra:ar. 43 ! 44 l Q. 41 What was EL&P's response to item 4 of the order, t 4 regarding the B&R QA brochure? 47 ! 48 i 4 50 ! 51 : 49.
1 L! -I 4' 5' A. 41 Item 4 concerns a seminar B&R conducted in $L January 1980. It was one part of the nine-point program I 9 described above that was initiated in response to the pre-Rog,' liminary NRC investigation findings. Its purpose was to 12 ' reduce friction between Construction and QA/QC personnel. 13, S4 The presentations at the seminar were videotaped for use in L3 ' B6 training and were printed as a brochure and distributed to S7 i LK ! project personnel. The NRC Investigation Report found that L9 l 80 ; one of the presentations at the seminar contained the sugges-81 ! 82 tion that QA/QC personnel should be conscious of cost and 23 ! scheduling considerations. 84 : 3" QA/QC personnel have never had any responsibility for the cost or scheduling of construction work on this Project.
- .i 83 ',
29 ! They have always been expected to determine the acceptabil-80 i g1
- ity of construction work without regard to Project cost and 32 i 33 !
schedule considerations. To eliminate any suggestion to the fj contrary, our response to the order submitted a copy of a 36 i revised presentation re-emphasi=ing the independence of 37 38 l QA/QC personnel from.such pressures, as well as reiterating
- 39 i l40 l the important role of QA/QC on the Project.
41 l 42 ; The revised presentation also repeated a discussion of 43l1 144 the formal procedure for resolution of disagreements between construction and QC personnel by submitting them to manage-ment. It was delivered orally to B&R Construction and QA 'O' $1 l ns w
.\\ L, i 4 5 personnel by the B&R Group Vice President for Power, and was 6 circulated in printed form to B&R Project personnel at the 9 job site. A brochure reproducing the presentation is fur-fI nished to new B&R site personnel as part of their orientation. h2 Q. 42 Itsn 1 of the Order required consideration of a A3 ' 14 number of aspects of the Project QA management organization. L3 16 How did EL&P go about preparing its response to the require-17 1 15 ment that it evaluate alternative management organizations 19 20, for the QA Program. 2 2j, A. 44 Item 1 f the Order required HL&P to utilize the n,j-services of an independent expert consultant to evaluate the 1 management of the QA program, giving consideration to alterna-L f tive organizational responsibilities for control of the 23 1 29 ' Project QA activities within the scope of the contract with 30 ' 31 l B&R. Since Bechtel was already conducting an audit of the 32 ' 33 QA Program and was thus already familiar with the STP program, I felt that it was best qualified to do the independent 36 l evaluation required by the Order. Accordingly, Bechtel 37 ! 38 analyzed the advantages and disadvantages of the various 39 40 alternative QA organisational structures. Its report was 41 42 submitted to NRC as an attachment to the HL&P response to 43 44 l the Order. I also discussed the alternatives with Mr. Amaral of s 4f l Bechtel, with another QA consultant, Management Analysis 4 50 1 51 v. )
'+ l-2: 4l 5i Corporation (MAC) and with Mr. Frazar. Based on all of 6l these discussions and the Bechtel report which focused on 9l the organization issue, I reviewed with Mr. Jordan what was 10 l g1 ultimately submitted as E&P's response to item 1 of the order. 1 Q'. 43 What were the alternative QA/QC management 16 l organizations the order required E&P to consider? 17 i li l A. 43 There were 5 alternatives listed in the order, 19 i 20 i and our review did not disclose any other alternatives that 21 ' 22, would have a potential to offer significant advantages over 83 I 24 : the alternatives that were listed. The alternatives listed were: o (a) the present organizational structure, where B&R has SS, 89 implemented a QA/QC program under E&P; 80 81 i (b) an organizational structure where all levels of the B&R 82 I 83 QA/QC organization would report to E&P yet remain B&R 84 35 l employees; 86 l (c) an organizational structure where HL&P establishes a 37 38 ! total QA/QC organira. tion to conduct the current B&R QA/AC 39 I 40 41 ( functions; 42 l (d) an organizational structure where HL&P contracts with 43 I 44 l another independent organization to perform the current B&R J QA/QC functions; 47 ! 48 ' 4 50 1 151 ! I i 1 1 7' 4; 5! (e) an organizational structure where EL&P establishes a 6L duplicate QA/QC organization, in whole or in part, to that w,9! of B&R with both groups performing duplicate functions. j 10 L1 j Mr. Amaral's testimony discusses the pros and cons of 12 each alternative. 3, Q. 44 Which alternative did EL&P select? 16 A. 44 We decided on an alternative which, in broad 17 i 15 ! terms, resembles alternative (a) of the order in that it 19 ' 20 r preserves B&R's responsibility for QA activities. At the 21 ! 22 ! same time, however, we strengthened HL&P's programmatic role 93 l 24 in the QA program, and made major changes to strengthen the f infrastructure of both the HL&P and B&R QA organisations to ]; q assure that every major function of a good QA/QC organization m-29 i is addressed. 30 ; 31 l Q. 45 What were the major considerations that led HL&P 32 l '3 to select that organizational structure? 3'4! 3 $5 l A. 45 our analysis of the NRC Inspection Reports and 36ll the Bechtel review identified three general management areas 37 8 in need of improvement, each of which had to be addresse,d in 40l considering reorgani:ation of the QA/QC program. These 41 1 42 l were: 43 i 44 l (1) Management involvement in the QA program. 4 (2) Strengthening the quality assurance or " problem preven-47 ! gg ; tion" arm within EL&P and B&R. 4. 50 ' 51 :
I 1: ~ 1 i 4! 5: (3) Reinforcament of a positive quality attitude on the 6, part of all levels of management within EL&P and B&R. I The management organi=ation had to effect improvements 9 10t1 i in these areas without introducing significant new problems f into the program. We identified five criteria which the QA 14 organi=ation should meet to achieve improvements in these 15 16 areas: 17 i LE { (1) Owner control and visibility -- The owner's QA organiza-19 i 20 t tion must be able to monitor effectively the performance of 21 ' 22 B&R and have sufficient authority to effect necessary program-23 matic changes. That authority can emanate only from a well h9 informed HL&P executive management, fully apprised of the b status of Project quality activities. 23 i 29 ^ (2) construction responsibility for quaJ ity -- The construc-30 l 31. tion organization must have the principal responsibility for 82 ! 83 doing quality work in the first instance. The QA/QC role is 84 i g3 i to verify that the quality is there; it cannot of itself 6 produce quality. After considering those alternative organi-08 ' =ations set forth in. the NRC Order which would have the, 89 ! 00 i effect of relieving B&R of QA responsibility, we determined
- 0 1 i 02 j that such a move would be counter-productive in that the 03,
04 ! construction organization's sense of responsibility for building quality into the work could be impaired. Therefore, 3 07 gg we concluded that the constructor should be accountable for G 00 01,
s i 1 i 4i 5l implementing an effective QA program internal to its organi-c' =ation and fully understood and supported by all levels of 9i management. 10 gy (3) Cwner's programmatic direction -- The organi:ation must 1 emphasize the owner's role in providing QA programmatic 14 direction as contrasted with the constructor's role of 15 16 implementing the details of an ongoing quality program. The 17, 15 ! owner's programmatic direction establishes the overall 19 i 20 : objectives of the QA program. This requires the inclusion 2] f a diagnostic function -- analy:ing problems and trends 2 }'3 and maintaining overall project control. The constructor is 4 2"' charged with the responsibility of implementing the QA program which meets the programmatic objectives established 2S ' 29 ' by the owner. The constructor must also have a diagnostic 30 i 31 function as described above, and must also execute programs 32 ' 33 ' for day-to-day verification of Project QA in accordance with 34 l 35, systematic delegations of QA responsibilities from the 6l owner. 38 (4) Quality Assurance independence -- The QA organizati,on ,l. 39 i 40 must be insulated from any pressures of cost or schedule 41 42 ; frem within either the EL&P or the B&R organization. The QA 43 44 function, which is organi:ationally independent of Project i management of engineeriag, construction and purchasing j l activities should have direct access to the same senior s 50 51, 1E
e 1I 2 4i 5 executive having responsibility for these functions. This 6i assures that executive management, Project management and gl the QA organi=ation are kept fully aware of Project activi-10 I gl ties. l (5) Capability of implementation -- The new organization 14 lL5+ should be one that could be readily implemented by drawing 16 upon existing personnel and systems whenever possible. 17 i 15 Similarly, the implementation of the program could be helped 19 \\ l20 : by building, to the maximum extent, on existing procedures, 12 1 ! 22 checklists and records in place, i f3 l We determined that alternative (a) best satisfied these 4 h' 5 criteria, particularly when coupled with significant a 4 improvements in the E&P and B&R QA organizations, and funda-29 mental modifications of QA/QC procedures, greater maiiagement 30 l l31 involvement, and significant upgrading of the QA/QC staff. 32 33 Q. 46 What improvements were made in the B&R and E&P 34 ! 35, QA/QC organizations? A. 46 We selected a management structure which provided 38 for strong E&P cont,rol of the QA Program and also strength-39 ! %0 ened B&R's controls. As with the previous structure, B&R 41 ! h2 I wculd implement a QA/QC program under E&P's direction, thus 43 d4 ' preserving B&R's responsibility to E&P for quality. As L* L discussed below, the reorganization strengthened E&P 's 47 4p programmatic role in guiding the QA program. The B&R QA k, 50 51 ! c1so
\\ 1l 2< 4; 5; controls were strengthened by upgrading the quality engineer-6! ing organization and expanding that organization at the job 9j site to give it the resources to carry out its enlarged R0 I [1 l role. The changes in the B&R organi=ation are also discussed 12 below. 93 Q. 47 Describe the strengthened HL&P QA management 16 structure. 87 i 15 l A. 47 The HL&P Project QA organization has been restruc-13 1 80 I tured to include five distinct components: Discipline QA; 81 : g2 ' Quality Control; Quality Systems; Procurement QA and Opera-83 I g4 tions QA. h5 ! Of these components, the Discipline QA organization may represent the most dramatic change. Within this organiza-3 BS,i 29 ; tion, there is a quality engineering function with separate 80 i 31 ' Project QA Supervisors in each of'the major disciplines: 32 ' 33 l civil / structural; mechanical / nondestructive examination; and 34 ! 35 l electrical / instrumentation and controls. Each Project QA 36 37 Supervisor provides programmatic direction to B&R Quality 38 ' Engineering on all QA matters related to his discipline. 39. 40 41 l This programmatic direction consists of review and approval i 42 i of the system features initially and continued monitoring, 43 1 44 l refinement, and revision of those systems during implementa-tion. Project QA Supervisors assess B&R's implementation of s 4 7 'l its quality engineering and inspection functions by reviewing 48 4 i 30 31, -3,o
L 2, l 4' 5l and approving procedures, performing implementation reviews, 6+ and observing work activities in the field. This activity 10 { 9 involves a virtually continuous contact between the HL&P i (1 Project QA Supervisors and B&R Quality Engineers. 12 73 The Quality Systems organization prepares HLaP STP QA 14 procedures, reviews trend data developed by B&R and analyzes L5 16 ' audit findings. It administers the training and certifica-
- 17,
!15 tion program for BL&P STP QA personnel and develops and 19 : 20 ' administers the HL&P Project QA Plan. The Quality Systems l21 g2 ; organization prepares information on the quality status of '3 4 the STP which is compiled in a monthly report which I receive. 5 i This supplements the information I receive in frequent discussions with Mr. Fra:ar. The EL&P Quality Control organization performs periodic ou. inspections to verify the results reported by the B&R QC 32 ! 33 l inspection program, assures proper nonconformance identifica-34 l 33 tion and assures that personnel performing inspections are t 3 properly cortified. The Quality control organization conducts 30 its inspections in accordance with instructions and checklists 39 ! 40 l reviewed by Discipline QA Supervisors. 41 i 42 i The Operations QA group develops and implements the 43 i Operations QA program which will apply to HL&P's activities 44 i l l in operating the plant. The Procurement QA group provides 47 ' 4g programmatic direction to B&R vendor surveillance and auditing functions. 51 : 3 i '1l 2V 4i 5! This revised organizational form generally conforms to li 6i i a pattern which has been used successfully in the construction 9l of a number of nuclear power plants. 80 l gy g Q. 48 What changes were made in the B&R Quality Engineer-h2 ! ing Organization? '13 : IS4 i A. 48 12 I The B&R Quality Engineering function was previously &S i performed by organisations located both at the site and in i 87 i l&E } Houston. The site organization was staffed by QA engineers SS l $0 j and QC engineers whose primary responsibilities were to 21 ! 1 2 assist field QC Inspectors in the resolution of problems, 3 84, interface with the construction organi=ation on the develop-ment of construction procedures, and to implement the various 6 deficiency control programs. The Houston organization was 88 ;; 89 i staffed with QA engineers who were primarily responsible for 80 31 interface with the Engineering organization on the QA aspects 12 a 3 l! of the design program, procurement quality assurance, the 14 J5 l d***1 P"*"t *"d **i"t*"*"C" f QA P# C*d"#**' ""d th* t#*i"- 6i ing and certification of inspection personnel. The Houston 38 ! organization, however, performed these responsibilities for as j 40 all B&R Power Group projects, not only for STP. -1 2 As part of the improved program, the B&R quality engi-3 q neering function for STP was expanded and personnel were relocated to the site to provide rigorous quality engineer-7 8 ing guidance to the QA program. In addition to the previous i Su ; 51 ! l 9' ~
I, 1I -i 4l 5 i responsibilities, the Project Quality Engineering responsi-Si bilities now include review and approval of nonconformance o il 9l reports, review and approval of construction procedures, 80 l gi preparation of QC inspection plans, review and approval of 12 quality related construction record packages and coordination L3 14 of the "as-built verification" program. The site Quality 15, 86 ; Engineering staff has been more than doubled to enable it to &7 &g l handle its increased responsibilities. This expanded quality 89 l 80 ; engineering function substantially strengthens the QA program. 81 82 l It is a management approach with proven effectiveness. S3 Q. 49 What changes have been made in staffing levels 8,,, 8' and personnel qualifications in the HL&P QA organization for c. I STP? 83 i 89 l A. 49 Since the beginni.ng of 1980 there has been a 80 ! g1 l substantial upgrading of the HL&P QA department. As described 82 l g3 i in detail in Mr. Frazar's testimony there have been increases
- 84l in the number of personnel in certain positions, qualifica-g3 l86 !
tion requirements for QA/QC personnel have been upgra ted, &l 88 and the personnel in, key QA positions have been suppleme.nted l39 ! 60 i with expert consultants from outside the HL&P organization 41 1 42 l with extensive nuclear QA experience. This effort was aided l43 ! !4.t j by Bechtel's review of the qualifications of key project QA l personnel. i47 ! 50 ! 51 ;
.s li -i 4; 5i Q. 50 What changes have there been in the staffing K i levels and personnel qualifications in the B&R QA organiza- . Igj tion? 1 {0 l A. 50 The primary area in which the B&R QA Organization {1 i was found to need more people was in the Site Quality Engineer-1 3, 14 ing group. When the function was transferred to the site 1: ! 16 and its responsibilities expanded, its staff was substantially 17 1 15 l upgraded in terms of numbers and experience levels. 13 l 20 l B&R has also added highly qualified individuals to its 21 ! 2] ' QA rganizati n in three key positions: Corporate QA Manager, '{3 Project QA Manager and a consultant to the Quality Engineering 4 2~ i Manager. The new corporate QA Manager joined B&R in August -j of 1980. His 26 years of QA experience include 13 on nuclear 23 29 i projects and 23 in management positions. The B&R Project QA 30. 31 i Manager has been relocated to the site and the position is 32 ' now temporarily filled by a consultant with 20 years QA 33 34 ! 33 l experience including 8 years as QA manager at other nuclear 36 l power projects. The B&R Quality Engineering Manager also 37 i 38 I relocated to the site, and he is being advised by a consul- ~ 39 ! '40 l tant with 23 years experience as a Quality Engineer, includ-41 ' 42 i ing 9 years in the nuclear field. 43 i '44 Q. 51 Please describe the changes that have been made to increase management involvement in the STP QA program. '4 7 l 1a ; i 50 ' '51 i ~
1 4< 5 A. 51 We have made several changes in organization to eliminate management levels between my position and the site ,-e jgl QA organization, and we have taken steps to increase my 10 ; g! involvement in the QA Program. 12 At the start of the NRC investigation the senior on-site HL&P employee responsible for QA was the HL&P Site QA Super-5' visor. He reported to the Project QA Supervisor, whose 7, ~5 ' office was in Houston. The Project QA Supervisor reported 1S i '0-to the Projects QA Manager who in turn reported to the 2 6, c h. Manager of the HL&P QA Department. The Manager of QA reported n3 i {4 ; to the Vice President, Power Plant Construction and Technical 23 ! Services, who reported to me. Thus, there were four layers I L of supervision between the site QA organization and the 23. 39 ' Executive Vice President (see Attachment No. 1). All four 30 31 > layers have been removed. 32 ' a3, The Manager of the HL&P QA Department has assumed the c4i ,3 responsibilities of HL&P STP QA Manager and has relocated to c6 the site. The Project QA Manager now reports directly to me. 7 '8 (See Attachment No. 2 ). We are currently recruiting qualified, c9 i a0, experienced people to fill the two key on-site positions of 31 : 42 l Project QA Manager and Project QA General Supervisor. 63 '4; So I can devote essentially all of my time to STP, I 6 + have largely given up my non-nuclear duties. In addition, a L7 I 59 k 50 51 .N I l i I 4j 5i new position, Vice President, Nuclear Engineering and Construc-Gi tion, has been added to the HL&P organization. The position 9 has been filled by Mr. Jerome Goldberg, who has had 26 years 10 gy experience in nuclear engineering, design and construction, 12 l 17 of them as a manager. His extensive experience is proving 13 ' 14 ' an invaluable asset in the management of the design and La ~ 16 ; construction of STP. 17 ! The addition of Mr. Goldberg to our ig l staff allows me to devote more of my time to the STP QA 13 i 30 l program. I also participate in the meetings of the B&R QA j 21 1 22 j Management Review Board, a committee of B&R top management f.3 personnel that regularly assesses the status of Project 4 1" l quality activities. I should also add that B&R has taken steps to increase 23 i 39 i the involvement in the QA program of its senior executives 30 { 31 ; and even its Board of Directors. Those steps are described 32 1 33 ^ in the testimony of Dr. Broom. 34 33 j Q. 52 In the process of all of these changes has 36 ! EL&P's role in Project QA changed? 37 ! i 38 A. 52 Yes. There has been a significant increase in 39 ! 40 the depth to which HL&P is reviewing the B&R QA activities 41 i 42 ' and providing programmatic direction. This increase can be 43 44 seen at all levels of the QA organization, from HL&P's discipline QA personnel reviewing draft procedures and i 67 4A procedure implementation, up through me, including my personal l 3 20 l 91 ! i
- i.
1l 7V i 4' 5l observation of program implementation and my participation 6l in the B&R QA Management Review Board. HL&P had been providing direction to B&R throughout the Project, and is now even i9i
- 10 [
more fully involved in the details of the planning and l11 : l12 ! implementation of the QA program. We are making sure, by l l3 ' l14 direct observation, that the improvements in the B&R QA l10'( '16 program are working. Our staff will continue to fill this l l7 i g role through Project completion. 13 ! Q. 53 Are you satisfied that the QA program complies ,20 t 21 l with the. requirements of Criterion I of Appendix B to 10 CFR i22 ! i 23 t Part 50? ! 24 i '24 ; A. 53 Yes, I am. Criterion I requires that the persons and organizations performing QA functions have sufficient SS I jg i authority and organizational freedom to identify quality i 20 i g problems; to initiate, recommend or provide solutions; and ! 32 [ to verify implementation of solutions. They must report to l 33 l l 34 ! a level of management such that they have this required i 35 ! ! 36 j, authority and organizational freedom, including sufficient 37 33 ! independence from cost and schedule as opposed to safety 39 I 4o [ considerations. 49 f j The program we have established has been organized to 3 achieve the required organizational freedom and authority. 4 'I The QA organization of HL&P is independent of all other 1 47 I organizations and responsibilities. It reports directly to 48 l 50 i 'i I 51 i i 1 .s l 1i l 4l 5, me. similarly the B&R QA organization reports directly to 6i the office of the Group Vice President, the highest executive -i 9j position in its Power Group, independently of Engineering 70 ! 73 and Construction. f2 : of course that organizational independence has always 14 i been there. It was in its implementation that shortcomings LS ! 16 I were identified. A number of actions have been taken over 17 i 15 j the last year to make certain that there is follow-through 19 20 in implementation. These actions have included not only the 21 ! 22 ! presentation by the B&R Group Vice President, which I men-3, { tiened earlier, and the many training and retraining sessions 2" i that have been conducted, but a number of other actions to i make clear the seriousness with which we view this matter. 23 ' 29 I For example, construction workers have been suspended or 30 ; 31 removed from the Project for displaying a poor attitude. 32 l 33 i The training program and qualifications of QC personnel have 34 l '1 33 ; been upgraded and QC pay scales have been increased to 33 l attract more qualified personnel. These and other actions 3e : 38 ! to maintain a positive attitude are described in EL&P's 39 i 40 l May 23, 1980 response to the Notice of Violation. They are 41 ! 42 ! also discussed in detail in Dr. Broom's testimony. 43 44 l Q. 54 How well has the QA Program performed since all of these changes were made? 47 ! 48 i i ,s 50 i 51 l
ll 4l 5l A. 54 In my observation, the performance of the QA A! Program is greatly improved. I have been at the site fre-gl quently over the past year. I have talked to the workers 10{y and observed their work. Although it is impossible in a 2 project involving thousands of people to make a universally 14 applicable judgment, the attitudes of construction and QC L3 I5 personnel appear to be positive. QC personnel, in particular, 17 Lg ; appear to feel that there has been a major improvement in 'S'
- 20 l attitudes towards quality on the job.
We recognize that ' 2}' '- this does not mean that we can foreclose the possibility of 2 23 individual instances of improper behavior by QC personnel or ,24 l2" l others. No QA program, however detailed in both its proce-dures and its implementation, can possibly do that. We 123. l29 i continue to be concerned that NRC Inspection Reports since
- 30 '
31 the Show Cause Order (e.g., Reports Nos. 80-14 and 80-21) 32 33 have disclosed instances of unprofessional conduct, including falsification of records, by personnel employed at STP. 36. Any incidents of this type are serious. Obviously, in l37 ! 33 ! a job involving thousands of people with literally millions 39, l40 i of records, the potential exists for individuals -- whether 41 i 42 to protect their jobs or for other motives -- to hide infor-43 i 44 j mation, falsify documents or engage in similar unprofessional conduct. It is extremely difficult -- if not impossible -- to s 47 l ro ! l\\ l50. 51 l
- _46,
1i i 4l t 5 preclude such incidents by audit and surveillance, regardless 6: of the effectiveness of one's QA program. w i 9j Throughout my testimony and that of others being presented j {O i{ on behalf of Applicants, we have described the many steps that we have taken to instill positive attitudes among all 14 personnel at STP, to encourage full and free communication LU 16 with management and to place the quality, safety and reli-17 i 15 ' ability of the Project as the uppermost goal of all workers 19 ! 20 i and management personnel at STP. It is an unfortunate fact, 25 I fi however, that notwithstanding all of these measures, incidents of this type can occur. Ne will remain vigilant but, equally fI important., by example, make clear that such incidents will i not be tolerated. I f, after an investigation conducted with 28 ; 29 1 due regard for the rights of involved employees, we determine 30 i 31, that there has been an instance of unprofessional conduct, 32 l 33, firm disciplinary action will be taken promptly. 34 l 33, Q. 55 One of the issues in this proceeding concerns 36 l the question of whether E&P has kept itself informed about 3 e, : 38 I the Project. In your opinion has E&P kept itself properly 39 i 40 i informed? 41 ! 42 l A. 55 Yes. We have taken appropriate steps to keep 43 1 4.g l ourselves informed of day to day conditions. E&P employees i have been located at the B&R engineering offices and on-site, g l monitoring and auditing construction and QA activities, 4 00 51 .c-
1i o; 4i 5{ reviewing records, participating in numerous meetings and 6 i through these and the many other personal contacts with the 9{ B&R staff, have been staying in touch with Project activities. 10 l i 11 The knowledge gained by the EL&P staff is communicated 12 ' g3 to management. From the outset of the Project we have 14g assigned a group of top HL&P managers to a QA Program Evalua-16 17;! tion Committee to periodically review the status and adequacy li of the QA Program. The committee was formed for the express t 19 : 20 : purpose of monitoring the effectiveness of the QA Program, 21 ! 22 performing surveillance on the activities of the QA-Department 93, 24 i and reporta.ng to me on the need for improvements. Until So 7 recently Mr. Turner, now Group Vice President, Fossil Plant Engineering and Construction chaired the committee, and 23 29 i minutes of each meeting were sent to me. Now I am chairman 30 1 31 ; and Mr. Goldberg, Mr. Frazar and the other FTM executives 32 l 33 ' and managers involved in nuclear activities as well as 34 ! 35 ! Mr. Turner are members. 36 37 Aside from this formal mechanism, I continue to regularly 38 ( receive and review correspondence related to the Project, as 40 i have the other members of HL&P management, and we hold 41 i 02 i numerous informal meetings and conversations to review the 03 i 44 l status of the Project and the QA Program. I am in regular i communication with Mr. Frazar and participate in periodic 3 07 ! gg i meetings with B&R management. As I have previously mentioned. n' 90 1 91 l -4e-
l-
- 1. ;
i. i -!4l 5; it is not possible in a job involving thousands of people
- i with literally millions of records, to assure that any QA i
program, however effective, will preclude isolated instances yl 10 j of unprofessional conduct. It is similarly not possible to 11 ! 12 < assure that steps taken to encourage full and free communica- .' 13 14 tion with management will be effective in every case.
- But, L5 16 we are taking every reasonable step to keep informed about 17 i ig i the Project and, as I have indicated, we will act decisively To;{
to deal with any situation of unprofessional conduct or lack 2' ' of candor among Project personnel. 23 ; Q. 56 In your opinion, has HL&P abdicated its respon-24 ! sibility for QA on STP? A. 56 No, we have not abdicated our responsibility. 28 29 l We have hired B&R to perform certain QA services and certain 30 31, other QA services are being performed for us by other con-32, 33 : tractors, such as Westinghouse, but we have always recognized 34 that the responsibility for the QA Program is ours. I 35 l 36 believe that the steps we have taken to keep ourselves 37 ! 38 ! informed and in control of the Project have matured over the 39 I 40 j years. Our involvement has deepened as the Project has 41 1 42 progressed. The administrative machinery to control QA l 42 l ql activities now in place will serve to keep us informed of programmatic deficiencies should any occur. Our management has become increasingly sensitive to the importance of the 2d D1 Mo-
i 1i s I 4i 5I quality function and, through the mechanisms I have described, 6i lines of communication have been established which are 9l keeping us currently informed of quality-related matters. RO i y: So our actions demonstrate that we recognize that we, as an NRC licensee, are responsible to NRC for the activities t &3 S4 ' carried out under the Construction Permits, and eventually L5 16 l the Operating Licenses. 17, 15 j I do not believe that our record demonstrates an abdica-19 ! l0; tion of either knowledge or responsibility for the STP. We 2 '27fl have not at any time surrendered by our actions, or otherw.:.se e3 i g relinquished, our responsibility as a licensee of the NRC. f' Q. 57 'Do you have any concluding remarks concerning i the HL&P reaction to the Order to Show Cause and the underlying rS,
- 9' findings of the NRC Staff?
=0al ' A. 57 Yes. I believe that we have acted in a responsible c2 i ,3 i and timely fashion in dealing with the matters underlying 1 4,' the Order to Show cause. ,g t6 i I do not wish to understate the importance of I&E's 67 ! '8 findings, but they should not be overstated. Our concrete 69, 0l and backfill work has been adequate and the product has been 1 32 j demonstrated to be satisfactory. Although deficiencies were 3l .g,! found in the welding program, these problems were detected by the B&R QA audit program. In no aspect of our work to 7' g date has the safety of the Project been jeopardized. t 0, -1 ; ) 50
l-L! 2 4-5 As I have pointed out, we were immediately responsive 6i to the deficiencies identified by the NRC Staff, and had 9l undertaken major corrective action before the investigation 1 ~0 l report was issued. We have followed through on all of those y 12 I Corrective measures and the improvements in our QA/QC program f 14 have been apparent. LS i 16 We have accepted responsibility for the deficiencies 17 i 15 l noted in the NRC's Investigation Report but, more importantly, 19 i 20, we have turned the lessons of the entire enforcement action 2T : g} ' into an opportunity for upgrading our QA/QC functions and, n,;~,i more generally, our management control of the STP. We 25 believe the entire Project will be stronger for the experience. 23, 39 ! TH:08:A 30 1 31, 32 i 33{- 34 35 i '36 : '37 ! 38 i 39 i '40 i
- 41 i 42 i
.43 i 44 I .e i
- 47 !
48 ! e i 70 51 i
Attachment No. 1 EXECUTIVE VICE PRESIDENT VICE-PRESIDENT POWER PLANT CONSTRUCTION & TECHNICAL SERVICES MANAGER QUALITY ASSURANCE ' OPERATIONS PROJECTS QA QA SUPPORT QA MANAGER MANAGER SUPERVISOR f l l l PROJECT QA ~~ SUPERVISOR i SITE QUALITY SSURANCE SUPERVISOR
0 h O e e EXECUTIVE VICE PRESIDENT VICE PRESIDENT MANAGER MANAGER - NUCLEAR ENGINEERING SOUTil TEXAS IlOUSTON & CONSTRUCTION PROJECT QA QUALITY ASSURANCE tt $n if B tt h
I e L 'l .Jl ~ ~ 4l TESTIMONY OF JOSEPH W. BRISKIN 5 ON HL&P'S TASK FORCE APPROACH TO 4 RESPONDING TO THE NRC ORDER TO SHOW CAUSE i Oi 9! Q.1 Please state your name and current occupation. 10 l 11 ! A. 1 I am Joseph W. Briskin. South Texas Project 12 ' 13 I (STP) Manager, Houston Cperations, of Houston Lighting & 14 15 ' Power Company (HL&P). 16 17 i Q. 2 What are your responsibilities as Manager, Houston 15' 79, Operations? i og ' A. 2 I am responsible for directing the work of the 22 ' components of HL&P's Project Management Team that are located 23 - 24 : in' Houston. This includes engineering, procurement, project '5 control services, accounting and project administration. 23 ; Q. 3 Describe your professional experience in construction 29 ; 30 ' project management and control. 3 3{ ! A. 3 I have been actively engaged in project control ~3 i 7 4j and project management for twenty years, including about ten 35 j years on nuclear projects. This includes four and a half 36, 37 i years as supervisor of project planning and scheduling for 38 2 39 l Florida Power & Light Company, where my responsibility - 40 ; 41 l included the St. Lucie and Turkey Point nuclear plants. I 42 l 43 ; also was employed by Westinghouse Corporation for three and 44 i q a half years as Manager of construction scheduling on Consolidated 47 i Edison Company's Indian Point nuclear plant. I have held my 48 present position since I joined HL&P in March of 1980. ) a0 ' 51 l 1 /,, ' i 1, 1: J' 4! Q. 4 What is the purpose of your testimony? 5 A. 4 6l The purpose of my testimony is t? describe the l organization and functioning of the Task Force I headed that 4 i 9! reviewed the NRC Investigation Report No. 79-19 and the NRC 10 ; 11 i Show Cause order, and developed the HL&P responses to such 12,' 13 order. My testimony will show how the Task Force systematically 14 ' 13 analyzed the issues posed by the NRC Order to Show Cause 16 17, dated April 30, 1980, (Show Cause order), perforned thorough ig! {g ; studies of the adequacy of the safety-related concrete, 20 l structural backfill and welding at STP, and designed effec-21 i 22 tive revisions of the administrative controls for the quality 23 ! 24 ' assurance (QA) program. The details of the results of the 25il Task Force work responding to Item 7 of the Order (control 28 of field design changes) are contained in my testimony, 29, 30 l while all of the other detailed results are presented in the 1 3'9 3 l testimony of the various witness panels on the welding, 33 ; 34 l c nerete and backfill, and in Mr. Frazar's testimony on the 35 ! revised administrative controls. My testimony will also 36 37 describe the control system HL&P has adopted to assure that 38 39 ! the resulting commitments made by HL&P are fulfilled on. a 40 6 41 l timely basis. 42 l 43 i Q. 5 Describe the Task Force approach to preparing the 44l! 45 response to the Show cause Order. i 47 ; 48 '9 .0 51 i l 1l 'r ij A. 5 The NRC enforcement action in April of 1980 5' 6[ included both a Notice of Violation and a Show Cause Order. 1 <f The answer to the Notice of Violation was due in 25 days and 9 10 l the response to the Show Cause Order was due in 90 days. To
- 12. !
investigate the twenty-two items of noncompliance and prepare 12 13 a response within 25 days required an intensive effort. 14 15 Mr. Frazar was given responsibility for the investigation, 16 17, which he conducted with the aid of the EL&P Houston-based QA 'S {g audit staff headed by Mr. Robert Ulrey. 2 After EL&P filed its response to the Notice of Violation, 23'! we had a little over 60 days left to analyze the Show Cause 22 24 Order, organize the efforts necessary to examine the adequacy 25 of the backfill, concrete and welding,' to study alternative 23 administrative controls and to develop revised systems. To 29 i 30, Perform so much work thoroughly and carefully in that amount 3~1 of time required that special attention be given to the 3 1 33 [ task. 34 It was recognised that this effort had to be given 35 highest priority, that it would require personnel of the 36 ; 37 l highest qualifications and that the people working on the 33 i 39 l response should be relieved of all other duties that could 40 j 41 ' keep them from devoting adequate time to the Show cause 42 j 43 ; response. 44 ; 5 i I was placed in charge of the effort, and I organized a ,7; Task Force of senior EL&P and Brown & Root (B&R) employees 48 3 .O 51 l l -s4-
e' L: 'L J I 4l and consultants to do the necessary work. The Task Force 5l 4 was assigned responsibility for preparing draft responses to eight of the ten Show cause order items. Responsibility for 9 10 l drafting of responses to Items 1 and 4, regarding QA organiza-11 l tion and the QA brochure was assigned to the QA group, 12 i 13 ! headed by Mr. Frazar. 14 15, Q. 6 Why were you selected to head the Task Force? 16 ' 17 l A. 6 The primary role of the Task Force leader was to 3g! {g l provide management direction in order to assure that the 20 ! 21 Task Force effort was given proper priority, that the people 22 working on the Task Force were functioning properly and that 23 : 24 the work was proceeding on schedule. My position as Manager, '5, i Houston operations was an appropriate one to head the effort 2 3 ', because I had sufficient aurhority to direct the proper 29 l 30 ! allocation of resources to the Show cause response, and to 31 r 32 l assign additional personnel to the Task Force as the need 33 ! 34 l might arise. 35 i Q. 7 Who assisted you on the Task Force? 36 ; 37 A. 7 The eight Show cause order items that were my 38, 39 ! responsibility were divided into two areas: examination of 40! 41 l the adequacy of completed construction work and revision of 42 : 43 ' certain administrative controls. We designated Mr. James 44 't Hawks, the B&R Engineering Project Manager, to direct efforts 47 l in the first area: Items 2, 3 and 10 dealing with the 48 l 1I 20 ! 51 l -ss-
L; j completed construction work and the FSAR statements regard-5 ing backfill placement. The group working on Items 5 through ? 9, which dealt with Project administrative controls, was 0l 9! under Mr. Robert Ulrey, then EL&P's Supervisor, QA Support 10 t 11 - Division. 12 ; L3 l Q. 8 How did you organire the work under Mr. Hawks? 14 13 A. 8 Under Mr. Hawks, we set up a separate subgroup 16 i 37 ; for each of the three disciplines, backfill, welding and II concrete, each headed by the Lead B&R Project Engineer for 19 i 20 that area. These were Mr. Gerald Murphy for concrete, Mr. 21 l 22 Bernt Pettersson for backfill and Mr. N. J. Nataraj an for 23 : 24 ! welding. ,Each of these men was assigned a sufficient number as, l of B&R and HL&P personnel trained in the respective disci-i 23 { pline to perform in-depth. studies of the completed work. In 39 30 ! addition, we decided to obtain the services of prominent 9 jj { consultants in each of the three areas so that we would have 33 ! independent assurance that our investigative programs were ' 34 l 35 well conceived and that the results of our investigations j 36 37 were correct. Thus, we obtained the services of three 38 : 39 l experts in geotechnical engineering, three experts in non-40 j 41 l destructive examination of welds and three experts in various 42 ! 43 l aspects of the examination of concrete placements. We also 44 I j hired a statistician to advise the subgroup working on o 4j concrete verification. In all there were approximately 120 l 48 i l ) i l 30 i ' 51 l I j i -se-
1 1: 4ll B&R and EL&P engineers and consultants, and over 150 techni-5i 6l cians and craftsmen, working on these three Task Force efforts. The results of the work of these groups is dis-l 9! cussed in detail in the testimony of our witnesses on concrete, 10 l 11 ; backfill and welding. 12 ! 13 l Q. 9 Describe the organization of the group on admini-14 ' 13 strative controls working under Mr. Ulrey. 16 ; 17 i A. 9 Mr. Ulrey's group had responsibility for Show ,g' ~ gj Cause Order Items 5 through 9. It was clear that the primary 2 effort in this area was required for Items 6 and 7, which 22 ! involved the related syctems for reporting of nonconformances 23 1 24 ' and for field design changes. We established a subgroup on 25
- those areas under Mr. Richard Feverley, the B&R Assistant 48 !
Engineering Project Manager-Special Services, whose project 29'! 30 ; responsibilities routinely include the QA requirements of 3' i 32 engineering design. Mr. William N. Phillips, then EL&P's 33 ; 34 ! Pr ject QA Manager, was responsible for Item 5 on stop work; 35 l Mr. R. J. Purdy, B&R's QA Records Control Manager was put in 36 t 37 ! charge of the efforts to respond to Item 8 on records control; 38 i 39 ! and Mr. Paul W. Ratter, an experienced EL&P QA Specialist, 40 l ~~ 41 l in the audit group was given responsibility for the work on 42 ! 43 i Item 9 on audit programs. In each case we designated suffi-44 l 45 cient qualified personnel to thoroughly analy=e the issues ,f, and design workable systems. We also obtained the advice of 48 consultants. 9 Ji 51 i i 1l te J' 4l Q. 10 You mentioned that the subgroup headed by Mr. 5i 6i Peverley was a particularly important part of Mr. Ulrey's effort. How was Mr. Peverley's subgroup organized? J 9I A. 10 Mr. Peverley was responsible for Items 6 and 7, 10, 11 I which dealt with two related systems, nonconformances and 12 ; 13, field design changes. Under Mr. Peverley separate teams 14 ' 13 l were set up for the two items. 16 17, The responsibility for Item 6 was divided into two ~g ' i distinct teams: one for nonconformances reporting and another .9 i 2 for trend analyses. In each instance the team was ccmposed 22 ! of personnel intimately familiar with the subject being 23 > 24 reviewed. The team reviewing the nonconformance reporting 25 i' (NCR) system was initially headed by Mr. E. C. McKenney, a t 23 ; member of the Engineering Site group. Mr. McKenney has 29 30 : considerable experience in the use of the NCR system. 3' ' i Mr. Donald Harris of Management Analysis Corporation, who is 32 '~34; now the advisor to the B&R Quality Engineering Manager, was 35 ! a consultant to the team. The representatives of the Engineer-36 i 38,l; 37 ing and Construction organizations were Mr. A. S. Goewey 39 i and Mr. B. N. Kesarinath, both of whom also have had exten-40 i 41 i sive experience in using the NCR system. Mr. Ulrey partici-42 i 43 i pated in many of the team's working meetings. This team 44 I 5i included not only representatives of the major B&R organiza- ,j j tions that utilize the system, but also included individuals 48 j '9 j .0' 51 ! l i i l' 2r 4l whose broad experience with the system encompassed several 5' 6j rganizati nal perspectives. wI l The team reviewing trend analysis was headed by Mr. B. F. I Mitchell who is a member of the B&R Engineering (Design 10 11 : Quality Engineering) organization. Mr. Mitchell has extensive 12 13 ! experience in reliability analysis and statistical evaluation, 14 15 t both of which apply to trend analysis. Mr. Mitchell was 16 17 i assisted by several members of the B&R Engineering and QA 15 ' gg organizations. 2 After both of these teams had completed their initial 22 f studies and had provided recommendations for the reorganiza-23 24 : tion of these tasks, this work was turned over to Mr. R. A. 25 ~4 Frazar and Mr. L. Zwissler of Management Analysis Corporatice .a l who, with the assistance of various members of the EL&P and 29 ' 30 ' B&R QA organizations, completed the task. 3,, 32 : The team reviewing the field request design change 33 l1 system was headed by R. W. Peverley, who has extensive 34 3 experience in quality programs and reliability analyses on 37 ! various projects. 38 1 39 i Q. 11 How were all of the groups comprising your Task 40 1 41 ! Force directed to perform their tasks? 42 i 43 i A. 11 Each group was instructed to analyze its area of 44 l 45 l responsibility, to identify the underlying NRC concerns and ,j to determine any additional aspects of the respective systems 4a ! 49 ! ) t 51 ! I o L 2, i 4} that might be improved. In some of the areas there were 5 ! 6{ findings in the NRC Investigation Report which clearly indicated the problem as perceived by NRC. In other areas 9l we were less sure of the problem perceived by NRC. With 10 ; 11 ' respect to administrative controls, most of the NRC concerns 12 ; 13 ; had been identified during the exit interview in January 1980, 14 ' 15 and studies and procedure changes had already been initiated. 15 17 ; Each group was directed to go beyond the findings 'E {g identified by the NRC staff and to determine the necessary 2 l improvements. A good example is the NCR system. It appeared 22 to us that the primary NRC concern was that the trend analysis 23 24 ' on the Project was ineffective. Mr. Frazar's testimony goes 25 into the purposes and procedures for trend analysis, and I .4 will not attempt to duplicate his discussion. The point I 29 l 30 i want to make is that we completely reexamined the NCR system 3~9 3 and proposed changes to improve the system and make it more 33 34 responsive to the needs of the Project organirations. A 35 I similar approach was used by each of the groups. As a 36 ; 37 ! result, we have made significant improvements in our administra-38 ' 39 ! tive controls, as Mr. Fra:ar's testimony explains in de, tail. 40 t 41 ! Q. 12 Were all of the recommendations of the Task 42
- 43 Force concerning administrative controls accepted and adopted?
44 l 45 l A. 12 Every recommendation was carefully examined by EL&P and BAR management with the aid of consultants. Most ,i 48 i 49 l J: 51 i I LI L a 4l of the recommendations were adopted but the management 54j review did result in changes to some of the proposed new I' procedures. The primary changes were in the response to 9 10 li Item 6. One example concerns the forms used. The Task 11 ! Force recommended the adoption of three new forms, to be 12. 13 ', called an Inspection Report, a Squawk and a Discrepancy 14 13 Report. These forms would be used to identify concerns 16 l 17 about construction work and to escalate the level of review f ig! 'g if resolution could not be achieved at the QC Inspector-Construction Foreman level. Based on the consultant's 22 i advice the system was simplified; a single NCR form is used Za 24 i instead of the three forms proposed by the Task Force.
- Also, 95,
l the initial level for resolution of NCR's was changed from i 28 'i the level of QC Inspector-Construction Foreman to the level 29 l 30 ! of Lead QC Inspector-Construction General Foreman. This 31 1 3{ l eliminated a potential source of friction between QC Inspec-33 ' 34 tors and Construction personnel. This simplified the process, 3f but retained the essential features of the system proposed 37 : by the Task Force. 38 ' 39 i In general, however, the management review found.the 40 i 41 i Task Force proposals to be well conceived, and the basic 42 i 43 i changes proposed by the Task Force were adopted and imple-44 ! s! mented on the Project. 47 ! 48 t 1 40 ; 51 l -el-
i 1l t. Jll 4 Q. 13 How were the results of these Task Force and 5i ,j management reviews documented? l A. 13 HL&P submitted its written response to the Show 0l 9 Cause Order on July 28, 1980. That response described the 10 l 11 ! studies undertaken regarding the backfill, concrete and 12 l 13 ! welding, as well as the changes to be made in the QA organi-14 ~ 13 l =ation, personnel and staffing, and in the administrative 16 17, controls. These changes involved many procedure revisions. sgi {g j Work had already been started on those changes well before I the July 28 response was submitted. 22 l Q. 14 Item 7 of the Order required that HL&P develop 23 - 24 I and implement a more effective system to provide for the a5 ! l control of field changes in order to assess the impact of 23 ! these changes on the design. Please explain the meaning of 29 ! 30 : the term " field change". 31 32 l A. 14 A field change is a change in the plant design 33
- 34 ;
that is initiated by a request from the job site. That does ,36)! ~ 35 not mean that the construction crew changes the plant design; i 37 l it does not. It means that Construction identifies to 38 l ! 39 ! Engineering a design detail that is difficult or impossible 40 , 41 l to build exactly as designed. One example is an interference. l 43 : ' 43 i The designer may have required that a concrete wall have l 44 i
- l vertical steel reinforcement bars (rebar) throughout its
- 47 length at specified intervals.
At the same time, the design j 48 ! i i : i 30 ' ( 51, I l -
I Li l i 4! may also require that a pipe pass through that wall at a 5i 6! particular point. If it happens that rebar is located I just where the pipe should go, that is an interference which. i 9i 10 l was not anticipated by the designer. Procedures are 11 ]{ provided for Construction to notify Engineering of such ' 3 p situations so that the design may be changed, perhaps by moving the pipe, or by moving the rebar. 17 : Q. 15 At the time of the NRC investigation, what was 15 ; 19 the procedure for control of design changes? 20 - 21, A. 15 Under the procedures in effect at the time of 22 ! 23 ; the NRC investigation, the B&R construction forces and the 24 - ga EL&P start-up organi=ation utilized a form entitled " Field Requests for Engineering Actions" (FREA) to propose design 23 f changes from the field. The FREA was partially filled out 29 30 ' by construction personnel and transmitted to B&R Engineering. 3L, l32 rngineering, if it approved of the design change, would l33l1 34 complete the balance of the FREA. The completed FREA form 35 ! 36 ! could serve as the design change mechanism or the change f could be made on a Document Change Notice. 39 I The N was also used by B&R Engineering to document 40 l 41 design changes or deviations that could not readily be 42 43 l incorporated on the design drawings, and other minor design t44 l I changes that did not appear to merit implementing the proce-47 dure for issuing a Document Change Notice. Deviations from 49 ; s l50 51, ~63-
l i 11 9 i 4) design could also be approved by procedures involving an l NCR. Q. 16 What changes were made in response to the NRC 9' order? 10 l 11 ' A. 16 The field design change system has been changed 12 ' 13 ' in a number of respects to provide more follow-through 14 13, information to the QC Inspectors; to enable more rapid and 16 17, efficient determinations through enhanced engineering staffs 'E {g ' at the site; and to require complete documentation, including 20 l justification of all change requests. These changes include: 21 ; 22 (1) revision of the forms utilized for design changes; 23, 24 : (2) an enhanced on-site B&R Engineering staff; (3) addition 25 of a B&R Engineering board, the Change Review Board, to 48, review design changes; and (4) establishment of a design 29 i 30 ; change tracking system. Each change is discussed in the 3T I 3 2 ', remainder of this testimony. All of this enhances and 33 i facilitates the assessment of the individual and cumulative 34 35 l impact of field changes on the plant design. 36 37 Q. 17 Describe the revisions that have been made to 38 39 : the design change forms. 40 l 41 ; A. 17 To assure that the new system for controlling 42 i 43 : field changes is properly implemented, and to preclude the 44 I 45 j use of field change requests in the place of NCR's to report i ,f ; nonconforming conditions, a new system of forms has been 48 i 9 ; J l 51 '
1 .z, l j, adopted. The old FREA form has been eliminated. Construction 56l a d start-up now propose field changes by submitting Field Change Requests (FCR's) to the Project Site Engineering l 9l organzation. 10 i 11 l An FCR is only used to request a change when a need to 12 i 12 ! depart from design requirements is identified in the planning 14 13 i stage or discovered while work is in progresc, but prior to 16 ' i 17 reaching a planned inspection point. If a nonconforming ~g ! 1 9 ;l condition is found to exist during a planned inspection of 20 ! work, an NCR'must be prepared. An FCR cannot be used as a 21 22 l 23 I substitute for an NCR; nonconformances are not approved for 24 ! "use-as-is" or " repair" without the filing of an NCR. 25 i j When either the Project Site Engineering organization 4S I or the Engineering office in Houston approves an FCR, it 29 i 30 r issues a Design Change Notice (DCN). No such design changes 31 32 ; are approved without issuance of a DCN. The DCN is controlled 33 34 to ensure that there is objective evidence that all of the 35 { essential design control elements -- justification for the 36 ; 37 I change, engineering evaluation of the change, assessment of 38 i 39 ! the effect of the accumulated changes ic plant design, i 40 41 Change Review Board action, and Jr Vi'. of related documents -- 42 ; 43 l are satisfied. It is the DCN which is reviewed by the 44 ' 45 Change Review Board and carefully controlled and integrated . / li into the document control system for as-built verification. 48 - '9 i .J ! 51 I l l I -es-
L'! I ?, i {j Q. 3 3 What improvements have resulted from the change l f{ of forms? A. 18 One purpose for changing the forms was to make a, 9! sure that Project employees fully appreciate the prohibition 10 ! 11 ! against using the field design change system to get approval 12 13 ' for "use-as-is" disposition of nonconformances. By changing 14 13 the form, and the name of the form, we eliminated the use of 16 ' 17 the Field Change Request in the same way as the old FREA had ,e t (( ; been used. We also changed the forms to require additional 20 documentation of the design review process. Thus we have 21, 22 tightened our controls. %3 24 l Q. 19 How well is the new system for field design 75 > l changes working? 29 ' A. 19 The new procedures were made effective on October 1, 29 30 l 1980. EL&P has reviewed the content and the rate of generation 3'3 of FCR's since then. The new system was implemented gradually, 3 33 34 and a few minor procedural adjustments have been necessary. 35 ' The new FCR and DCN forms have resulted in better documenta-36 ; 37 l tion of the impact of and justification for design changes. 38 ! 39 ' Q. 20 What is the function of the B&R on-site Engineering 40 { 41 - staff? 42 1 43 l A. 20 All design changes proposed at the STP site are 44 i q{ submitted on an FCR form to the Project Site Engineering 47 l organization, a staff of Design Engineers located at the 48 i 3 ) i s0 51 j
li t' d site. This group is led by the Site Engineering Project 5 li 6l Manager, who reports to the B&R Engineering Project Manager. I l The Site Engineering Project Manager is the principal inter-e 9 face between B&R Engineering, which is primarily located in. 10 11 ! Houston, and the B&R Construction and QA organizations, 12 ; 13 l which are located at the site. 14 i 15 If the Project Site Engineering organization has the is : 17 ; necessary technical resources to evaluate the requested 9gt [g change, and the request is approved, the Site Engineering 'O}' Project Manager issues a DCN. If the proposed change requires }g 22 l technical resources not available at the site, he forwards 85l1 the proposal to the B&R Engineering Office in Houston for 24 l evaluation. 28 The design verification process, whether at the site or 29 i 30 I in Houston, includes independent engineering review and 31 i 32 verification to assure that the design change is consistent i 33 34, with the intended design criteria for the affected structure, 35 I system, or component. 36 37 38 li Q. 21 What is the composition of the B&R Project Site 39 Engineering Group, and how has it been enhanced? 40 41 ! A. 21 The Project Site Engineering organization is 42 43 made up of a group of qualified Engineers from each of the 44 di design disciplines and the Engineering Quality organization. ,7 Qualification and training records are maintained on these 48 !, 9 .0 51 t 1i i {f personnel. Each Project Site Engineer is responsible to the 5' 4{ Project Engineer of his discipline for the technical aspects l of the job, is a member of that design discipline, is competent a I 10 l in the requirements and objectives of the original design, 9 11 ! and has access to pertinent background information. 12 l 13 ' In response to the Order the Project Site Engineering L4 13. organization was expanded from 40 to 80 engineers. 16 ' 17 l Q. 22 How does the upgrading of the Project Site lE ! gg Engineering Staff improve the design change system? 2 A. 22 In the past, the Project Site Engineering organiza-22 ! tion had limited capability to approve design changes without 23 ! 24 l the prior approval of the Discipline Project Engineer at 95 I B&R's Houston Engineering Office. With the new design i 28 I change control system, however, both the responsibilities 29 ; 30 l and capabilities of the Project Site Engineering organization 31 ! 32 have been significantly expanded. This has resulted in more 33 timely and competent design review of the proposed changes 34 35 i at the site. 36 j 37 I The NRC Investigation Report stated that some QC Inspectors 38 ! 39 i expressed uncertainty about whether Engineering was adequately 40 41 informed of the conditions at the site when they were reviewing 42 l 43 FREAs. By locating more of the Engineering on field changes 44 l at the site, we have substantially enhanced the ability of s 47 l the Engineer to see for himself. At the same time, we have 48 7 sd 51 l l 1 i L ~j '4l increased the access of the QC Inspector to the Engineer. 5i 6l Q. 23 How well has the upgrading of the on-site Engineer-ing Staff worked? 9' A. 23 The increased staff should permit Engineering to 10 : ) 11 expedite the resolution of Field Change Requests. Thus far l 12, 13 the number of FCR's dispositioned on site has been consistent 14 15 with that experienced before the changes, however the trend 16 17, is toward increased on-site disposition. ig! To l B&R Site Engineering, with its enhanced staff, is now 2b 21, able to resolve at the site certain problems which previously 22 23 { required considerable communication with Houston Engineering. 24, For example, the Site Engineering staff was instrumental in 25 ' coordinating all of the final design effort required to 28 h support the last phase of the construction of the main 29 30 t reservoir and essential cooling pond embankments. 3'l 33 Q. 24 Describe the composition and function of the new 33 1 34 l B&R Engineering board, the Change Review Board. 3f f A. 24 The Change Review Board has been established \\ 3d 38 l within B&R Engineering as a further means of ensuring that i 39 ' the impact of site-initiated design changes on plant de. sign 40 ; 41 l have been assessed. The primary function of this Board is 42 : 43 l to provide a mechanism to ensure that design reviews have 44 :
- q been conducted by the proper engineering disciplines within
,7 the B&R Engineering organization. 48 ! .J i 51 i li 4 The Board is composed of representatives of the major 5l engineering disciplines and Engineering Quality with a 6 Chairman appointed by the Engineering Project Manager. i 9 Copies of each DCN are issued to the Board members 10 l 11 I prior to each meeting. Each Board member assesses the 12 13 impact of the change on his area of design responsibility 14 15, and identifies additional changes required to accomodate the 16 17. proposed change in question. During the meeting, the Board 15: {g l Chairman assures that such reviews have been conducted, all 20 ! 21 additional changes have been identified, and the change has 22 been found technically acceptable. When all of these matters 23 24 have been resolved, the Board Chairman signs the DCN form, 25 signifying Board approval of the change. 28 The prerequisites for issuance of a DCN include documenta-29 30, tion of the reason for the change, justification for the 393] change, engineering evaluation of the change, and an assess 3 33 - 34 ment of the effect of the change on the plant design. It is f5 not the function of the Board to perform detailed reviews of 37 l changes, but to ensure that such reviews have been completed 38 ' 39 i and to review the results thereof. 40 t 41 i Q. 25 Can you describe how this system has operated 42 43 ' with respect to a recent DCN? 44 l
- qi A. 25 An example of how the Change Review Board has
,pi carried out this function is illustrated by a recent change 48. 9' .J' l 51 l l t
L, 7 O 4! to the Technical Reference Document on " Piping Erection and 5 6 Field Fabrication Criteria". This proposed change was processed and sent to the Board by the Mechanical Discipline 9I 10 to provide a more practical tolerance for fillet weld sizes l1 T(( on pipe supports. The Board representative from the Supports Discipline determined that the Technical Reference Document, 13 " Criteria for the Design of Pipe supports" should also be 16 17 i revised. Based on this determination another change was 45 ' 19 l generated by the Supports Discipline. '0i 2 1 Q. 26 How does the addition of the Change Review Board 21 l 22 4 improve the design change system? m3 f! A. 26 The NRC Investigation Report questioned whether the design change process adequately considered the cumula-kl 28 tive impact of design changes. The Change Review Board 39 i $0 ! provides added assurance that each design change-receives an 31ll 32 adequate interdisciplinary review and that Engineering 33 : '4l adequately considers the cumulative effect of design changes. 3 35 l Q. 27 How well has the Change Review Board system 36 j 37 I worked? 38! 39 ! A. 27 The Change Review Board has worked well to -date. '0t 4 41 The Board provides added assurance that the impact of a 42 %3 site-initiated design change will be fully evaluated by all 44 f disciplines. Although EL&P does not participate directly on 4 67 l the Change Review Board, EL&P Engineering reviews and approves 48 I 4. 50 l 51 i i IL, z 4! all DCN's written against basic design documents. EL&P 5i g, Engineering also reviews selected DCN's written against detailed design documents. 9i g Q. 28 Describe the new design change tracking system. A. 28 We are now using a computer based control system L3 ' to keep track of design changes and provide "real-time" L4 L5 information on the status of design. Each day a description LS t7, of each DCN processed that day is entered into the computer rg' [3. ; by Engineering personnel at the site and in the Houston 20 ' office. Each morning, a computer printout is made available ,i ' 12 to users of the design documents. The printout, with respect .3 -, Z4 ' to a particular document, lists each approved DCN and its 25 7 effective date. This assures that each document user will Zg ; have up-to-date information, including all changes, on the 19 ' !O ' relevant portion of the facility design described in that 'f document. g !3 ! Q. 29 What are the benefits of the automated design 24 15 I change tracking system? 16, 17 A. 29 The NRC Investigation Report found an instance IS ~ 19! where the records indicated that a design change used.in lo I ill construction was not used by the QC Inspector. This automated L2 4 g3 ; system will assure that everyone is using the same design. I l4 l It will also be used by Engineers considering design changes g. l to verify that their review fully considers all design 7 L8! changes up to the time of their review. h' l0 1 ili i -i2-
I L, 1: 4[ Q. 30 Does the present field design change system 5, 6j comply with Appendix B to 10 CFR Part 50 and applicable Regulatory Guides and industry standards? 9 gg A. 30 Yes. The present field design change system complies in all respects with 'the requirements of Appendix B, 13 ! Criteria III and VI, and with the applicable industry stand-L4 L3 ards as set forth in ANSI. L6 ' L7 i Q. 31 Did the July 28 response to the Show Cause Order LT (3 : include a number of commitments by HL&P? RO A. 31 Yes. The response described a number of changes E3 E2 l to be made and other commitments to be fulfilled. We have (3 c 4I compiled a list of each of those commitments and developed a 5 control system to make sure the commitments are fulfilled on bl a timely basis. These are identified in Attachment No. 1 to 9< 10-my testimony.
- 12. '
12 > Q. 32 Were any additional commitments made by HL&P as l3,pj a result of the Show Cause Order? 3-A. 32 Yes. ,6. EL&P and B&R management attended a public T! meeting in Bay City on August 19, 1980, to answer NRC ques-8I 9t i tions about HL&P's response to the Show Cause Order. The 0l 1; NRC had published notices of the meeting well in advance and 2i 3i there was a large audience. Members of HL&P and B&R manage-4' i -I ment made short presentations summarizing the July 28 response 7 and then the NRC Staff asked a number of questions about the 3! details of how our technical studies were progressing and b 1! i I how we were implementing the changes we had described in our written response. Afterward the public was invited to ask i questions and NRC, B&R and EL&P representatives responded. l Answers of HL&P and B&R to some of the questions raised at the meeting included additional commitments. These commitments and their current status are also described in Attachment No. 1. j Q. 33 Has EL&P completed satisfying all of the commit-ments made in the response to the show cause Order and at the public meeting? A. 33 As shown in Attachment No. 1, almost all of the 236 identified commitments have been completed. Of those that are not complete, many are continuing commitments that are being and will be fulfilled over the course of the project, such as the periodic meeting of the QAMRB. Other commitments require long-term efforts that are underway, l l such as the reexamination and any necessary repair of safety related welding. However, the organization, personnel and staffing changes described in the testimony of Mr. Oprea, Mr. Frada'r, Mr. Vurpillat and Dr. Broom have all been implemented. Similarly the studies of backfill, concrete and welding have been completed. The results of that work are described in the testimony of the witnesses on those technical areas. l l .i4
r I v..., i il 2 4I Q. 34 Please describe the control system that HL&P has i 5i 6i adopted to track compliance with each commitment made by b, HL&P. 9} gl A. 34 The system which we established consisted of LL ! several levels of review. The initial version of the document L2 ' L3 ' attached to this testimony as Attachment No. I was sent to 14 L5l the NRC on September 18, 1980 as a baseline document for LS k7l comparison purpose. Updates of the commitment List have lg (3i been distributed to HL&P and B&R Executive Management, and 0 y other personnel involved in our effort. As I discussed previously, this document showed the reference of the commitment 3, 4[ source, for example, the public meeting or the written Show Cause response. It also shows the in-house due date for kl completion ind the status. The List was revised in March to 9; Ol indicate the status of the NRC review. So this List is part 1 i ~ of the system. The next integral part was a weekly update of the 5l status of the items. B&R supplied EL&P with a weekly update 6\\ 7! which was then distributed. I used these documents to 8i 9l monitor the progress of B&R and HL&P on these commitments. Oi 1l The backup to these lists was a set of files kept by 2l 3j our site QA personnel. For each Show cause order commitment 4l our site QA personnel would either get a copy of the document 3j that closed out the commitment and put it in the file or SI = I' D -
L L 2 4j placed a reference page in the file. In either case EL&P 5:i 6: 1: personnel reviewed the documents to satisfy ourselves that he the commitment was being implemented. D' g Q. 35 Does this system assure that each commitment 15 will be fulfilled on a timely basis? 2 3, A. 35 Yes. The system established a working list with 6 3 assigned responsibilities and due dates. It provided a 0> p helpful mechanism for my use in determining the management [E '.
- 3. i efforts required to make sure the commitments were met on
'Ob' time. That it has worked is shown by the status of the n> commitments. 3-Action has been taken on all of the commitments h and NRC has inspected using our commitment list as a checklist J and has closed out most of the commitments, v ; S.'
- l
' i T. Hudson:09:B ,j i l l i i i - ~Jo - L
SHOW CAUSE CO VIVIT V E CS ~ EDITION 05-08-81 Page H-1 ~ l COMMITMENT REF. PARA. DUE DATE RESPONSIBILITY STATUS H1 Mr. Oprea and Mr. Grote on Due Date 10/5/80 Reso: It.A.Frazar distribution for a number of QA W. J. Friedrich Reports. Ref: Page 54 STP Status: Complete - GWO receives Audit, Trend and Monthly Activity Reports. SHG receives Audit and Trend Reports, Stoo Work Orders and Status of CAR's. NRC Status: Closed oer 81-01 H2 Mr. Grote will scend 907. of his time Oue Dato N/A Resp: S. H. Grote on STP, and he will visit the Site on STP Status: Continuous comitment - item a regular basis. closed Ref: Page 51, 54, & 55 NRC Status: Closed oer 81-04 H3 QAMRB Meetings to be held on Site. Due Date N/A Reso: R. J. Vuro111at, Jr. Ref: Page 56 STP Status: Continuous commitment - item closed NRC Status: Closed per 80-27 H4 S&R Corporate QA Manager to make a Que Date N/A Reso: R. J. Vurpillat, Jr. report once a month to the operating STP Status: Continuous commitment - item committee and board of B&R concerning-closed the status of tne STP QA Program. NRC Status: Closed oer 81-01 Ref: Page 56 HS Establish system to track each Show Que Date 9/19/80 Reso: J. W. 8ciskin Cause Commitment and supply to NRC a STP Status: Complete - See ST-HL-AE-533 timetable so they can senedule their 9/18/80. insoection consistent with schedule NRC Status: Closed oer 80-27 for work develoament. Ref: Page 58 - 59 H6 Provide uodate of FSAR Chacter 17 Que Date 11/1/S0 Reso: R. A. Frizar describing new organization and in STP Status: Comolete - See ST-HL-AE-568 addition a comparison to orevious NRC Status: Closed per 80-27 organization including ritoorting system, number and type of classification of pecole. Ref: Page 60 $ 67 H7 Coordinators from Construction and QA Que Gate 9/15/80 Reso: R. H. Leasburg ~""~ assigned for conolex concrete cours. W. J. Friedrien Ref: Page 63 STP Status: Comolete - See SQA 4280 1RC Status: Closed oer 80-38
s SHOW CAUSE COMVllTV EW S EDITION 05-08-81 Page H-2 COMMITMENT REF. P ARA. DUE DATE RESPONSIBILITY STATUS H8 AWS Welding Procedures have been Oue Date N/A Reso: R. H. Leasburg revised, ready to requalify welders, W. J. Friedrich and have completed much of the STP Status: Continuous comitment - item personnel training. closed Ref: Page 64 NRC Status: Closed per 80-38 H9 At the restart of AWS welding, work Due Date N/A Reso: W. J. Friedrich will be overseen by certified Level STP Status: Continuous commitment - item III Examiner, closed Ref: Page 65 NRC Status: Closed oer 80-38 H10 Provide to NRC a schedule of Due Date 9/12/80 Reso: M. O. Muscente outstanding comitments concerning STP Status: Complete see ST.HL-AE-545 and welding. ST-HL-AE-532. Ref: Page 66 - 67 NRC Status: Closed oer 80-38 H11 Provide to the NRC a graphical Oue Date 11/1/80 Reso: R. A. Frazar presentation c ' the kind of people and W. J. Friedrich qualifications that existed prior to STP Status: Comolete - See ST-HL-AE-568 the change and then what changes are NRC Status: Closed oer 81-01 being made so NRC can have a better understanding of what has been done and better track how things are going in future. Ref: Page 67 - 68 H12 Provide to NRC the results of analysis Oue Date 9/26/80 Reso: G. W. Oorea, Jr. of Becntel/MAC recommendations. STP Status: comolete See ST-HL-AE-548, Ref: Page 74 9/24/80. Based IR 81-07 additional review of this item will be comalete.5/.29/81. NRC Status: Ciesed per 80-27 Recoened per 31-07 H13 All construction procedures revised in Oue Date 11/28/80 Reso: R. H. Laasburg new format witn inout from Crafts /QA K. R. Cook by end of November. STP Status: Complete - See GM 76688 Ref: Page 77 NRC Status: Partial closure of civil item : 80-38 Note that the areas other than civil are seneduled to me ready for NRC review on 5/29/81 HLAP QA review of imolementation not completed. c'
SHOW CAUSE CO V MITM EN-S EDITION 05-08-81 Page H-3 COMMITMENT REF. PARA. DUE DATE RESPONSIBILITY STATUS H14 Schedules will be established whereby Oue Date N/A Reso: R. H. Leasburg in a timely manner QC Inspectors / W. J. Friedrich Craftsmen will receive adequate STP Status: Complete - This is a requirement training on revised procedures, (prior in Procedure GCP-1 orier to to procedure implementation), implementation of each revised Ref: Page 78 & 80 procedure. This is also a reouirement of the Quality ~ Assuranca Plan Section 6.1. NRC Status: Closed per 81-04 HIS Provide NRC the HL&P Quality Assurance Due Date 9/15/80 Resp: R. A. Frazar and Quality Control Organizations STP Status: Complete See ST-HL-AE-541, staffing levels, how we arrived at 9/24/80 tnem, what was the criteria for NRC Status: Closed oer 81-04 arriving at those numbers. Ref: Page 95 - 96 H16 Provide NRC with decision on frequency Due Date 2/81 Reso: G. W. Oorea, Jr. of audit by outside consultant. STP Status: Comolete Ref: Page 104 NRC Status: Closed per 80-27 H17 Check qualifi:ations of construction Oue Date 1/16/81 Reso: J. R. Geurts personnel now working on Site. STP Status: Carolete (Construction Supervisory Personnel) NRC Status: Civil part closed per 81-03 Ref: Page 109 - 113 Remainder closed per 81-07 H18 Provide to NRC tne recommendations of Que Date 9/15/80 Resp: R. H. Leasburg dynapac compaction equipment. STP Status: Complete - See ST-HL-AE-530 Ref: Page ils NRC Status: Closed per 80-38 i H19 Provide additional information to Show Que Gate 11/10/80 Reso:,,J. L. Hawks cause Item 2.8, addressing the C. 3. Pettersson question of foundation settlement. STP Status: Comolete - See GM-75521 Ref: Page 118 NRC Status: Discussed in 30-38 Closed per 80-24 H2O Provide NRC with copy of POCN to Que Date 10/1/80 Reso: J. L. Hawks backfill TRO (Rev. 3) and issue OCN C. B. Pettersson witnin 4-6 weeks. STP Status: Comolete - Ref: 3A700GP002-A Ref: Page 125 0CN 9/24/80 NRC Status: Closed per 80-38
SF OW CAUSE COMM~ MEN-S 1 EDITION 05-08-81 Page H-4 COMMITMENT REF. P ARA. DUE DATE RESPONSIBILITY STATUS H21 Final report to be available Oue Date 11/30/80 Reso: ~J. L. Hawks mid-October regarding the work of the C. 8. Pettersson Independent Review Committee in the STP Status: Comolete - See ST-8R-HL-36189 soils area. ST-SH-8R-28 Ref: Page 126 ST-HL-AE-625 NRC Status: Closed per 81-03 H22 Complete macoing of the backfill Oue Date 10/15/80 Reso: J. L. Hawks construction activities by C. 8. Pettersson mid-Septemoer and issue final report STP Status: Comolete - See ST-BR-HL-36189 by mid-October. ST-SH-8R-28 Ref: Page 127 ST-HL-AE-625 NRC Status: Closed per 81-03 H23 Modified the documentation systems for Que Date N/A Reso: W. J. Friedrich AWS welding sucn that verification can STP Status: Comolete be made of inspectors cerforming in NRC Status: Closed per 80-38 process checks on AWS welding. Ref: Page 143 H24 Socket welds to be 100% reinsoected. Due Date 11/14/80 Reso: M. O. Museente Ref: Page 145 W. J. Friedrich STP Status: Comolete - item was delayed unti 11/24/80 because ASME - restart was delayed. See ST-HL-AE-532 and 545 NRC Status: Closed oer 81-06 H25 Manager of welding to issue monthly a Oue Date 10/1/80 Reso: M. D. Muscente written recort regarding status of STP Status: comolete - See BC-30663 welding, problems being incurred, and NRC Status: Closed per 80-38 actions seing taken. Ref: Page 156 H25 Provide a copy of welding task force Oue Date 9/12/80 Reso: M. O. fiuscente report to HLaP for transmittal to NRC. STP Status: Complete. See ST.HL-AE-545 and Ref: Page 156 ST.HL-AE-532. NRC Status: Closed oer 80-38 H27 Obtain cooy of Puolic Law 96-295. Due Date 10/1/80 Reso: R. A. Frazar Evaluate for oossible incorocration STP Status: Comolete - Law.is to De costed. tnto appropriate documents. NRC Status: Closed oer 80-27
SHOW CAUSE COVV TMEW S EDITION 05-08-81 Page H-5 ~ u COMMITMENT REF. PARA. DUE DATE RESPONSIBILITY STATUS H28 Review NCR Procedure to see if Oue Date 9/15/80 Reso: W. J. Friedrich clarification is needed in cases where STP Status: Complete - Ref. St-QAP-15.1 inspectors cannot obtain NRC Status: Closed per 80-27 acknowledgement of NCR from construction. Ref: Page 165 H29 Eacn.nonth the Project QA Manager is Que Date 10/80 Reso: W. J. Friedrich to present to QAMRS a status of eacn STP Status: Continuous commitment - item outstanding A0R, (i.e. how long its closed been open and how long it is overdue). NRC Status: Closed per 80-27, 81-01 In addition NCR's & CAR's substantially past their due date will be presented. Ref: Page 174 - 175 H30 All design enanges will be documented Oue Date 10/1/80 Reso: J. L. Hawks on a Design Change Notice (OCN). STP Status: Comolete - Ref. STP-0C-028 Ref: Page 177 Effective 10/1/80 NRC Status: Closed per 81-05 H31 All S&R/HL&P Audit Recorts, including Que Date 9/8/80 Reso: R. L. Ulrey Vendor Audits Reoorts are being sent R. W. Bass to G. W. Oorea, W. M. Rice and S. H. STP Status: Comolete. Grote for review. HL3P: Audit Reoorts will continue to be sent Ref: Page 182 to Executive Management. 88R: Distribution List for 3&R has been revised to include these oersonnel for all future audit recorts. NRC Status: Closed oer 81-04
..'l' SHOW CAUSE CO M VITVEN"S EDITION 05-08-81 Page M-1 ~ l COMMITMENT REF. P ARA. DUE DATE RESPONSIBILITY STATUS ~ M1 PQAS will assess the Quality Due Date 10/1/80 Reso: R. A. Frazar Engineering and inspection functions STP Status: Complete, see PSQP-A9 Rev. O of B&R by performing mini-audits, NRC Status: Open/ Ready for NRC Review reviews and approval of procedures and observation of work activities in the field. Ref. Para: 1 - 11 (1) M2 Review has been made of the Oue Date 8/4/80 Reso: G. W. Oorea, Jr. qualifications of all key QA personnel STP Status: Complete. within HL&P/8&R by Bechtel and MAC. NRC Status: Closed per 81-04 Ref. Para: 1 - 16 (4) M3 Trending various types of deficiencies Due Date 1/31/81 Reso: W. J. Friedrich will reflect any significant failures J. Purdy to comply with procedural STP Status: Comotete - Part of the Trending requirements, and provide manaoement Program with information on which to base NRC Status: Closed per 80-27 continued improvements in training. Ref. Pars: 1-18(1) M4 B&R audit group to add five additional Oue Date 1/1/81 Reso: R. W. Bass personnel to augment Audit Staff STP Status: 51te is authorized a total 7 (NUS/SAI). auditors, Houston Office 15 Ref. Para: 1 - 19 (2) auditors. NRC Status: Giesed per 30-2;: Reopened per 81-07 Seneduled to be ready for NRC review 6/4/81 MS A requirement has been established for Due Date N/A Reso: W. J. Friedrich periodic meetings at the Site which STP Status: Initiated and is an on-going will be attended by key uocer and activity. Monthly meetings have' middle management personnel of been held since July 1980 with HL&P/8&R. Eacn meeting will include a B&R QAMR8 and G. W. Oorea and report on the status of the QA orogram Staff in attendance. nignlighting Quality orablems, trends, NRC Status: Closed cer 81-01 etc. Ref. Para: 1 - 20 (2) M6 With Senior Officers of 3&R acting as Oue Gate N/A Reso: K. M. Broom an Oversigne Committee and Line STP Status: Leem complete. Mr.. C. Snyder Managers comarising 3 Steering heads the Steering Committee. Committee the Corcorate Committee to Messrs Rice, Grote, Bazor, Quality imorovements will be exoressed Salterillo, and Dr. Broom througn training and indoctrination comprise tne Oversiant Committee. and innovative programs. These functions shall ce ongoing Ref. Para: 1 - 20 (3) for tne 11fe of ene oroject. k e em< - m sad,ar o!,n1
SHOW CAUSE CO V MITME \\ TS EDITION 05-08di ~ Page M-2 . ' TEM COMMITMENT REF. P ARA. DUE DATE RESPONSIBILITY STATUS NO. M7 The Independent Review Cocunittee has Due Date 12/15/80 Reso: 'J. L. Hawks evaluated the field and laboratory C. 8. Pettersson data and has presented conclusions in STP Status: Comolete - See ST-HL-AE-625 interim report. Final evaluation will ST-SH-BR-28 be presented in a comprehensive report ST-8R-HL-36189 upon conclusion of all planned studies NRC Status: Closed per 81-03 related to Cat.1 Structural Backfill. Ref. Para: 2 - 11 (2) M8 A comprehensive engineering study is Oue Date 12/15/80 Reso: J. L. Hawks being made of construction conditions, C. R. Pettersson placement secuence and testing of Cat. STP Status: Comolete - See ST-HL-AE-625 1 Structural Backfill placed at STP. ST-SH-8R-28 Ref. Para: 2 - 17 (2) ST-BR :".-36189 NRC Status: Ocen/ Ready for NRC review M9 Locations and sequence of various Cat. Due Date 12/15/80 Reso: J. L. Hawks i backfill placements and C. 8. Pettersson correspondence in-olace density test STP Status: Comolete - See ST-HL-AE-625 results will be documented for units 1 ST-SH-8R-28 & 2 together with summaries of the ST-8R-HL-36189 report construction methods and NRC Status: Open/ Ready for NRC review conditions. Specifically placements in support of the foundations for F.H.3., M.E.A.B., and 0.G.B. as well as backfill surrounding these buildings and against R.C.B. The bedding and backfill for the essential cooling water system piping are also to be included. Ref. Para: 2 - 18 (3) l M10 An evaluation will be made of the Oue Date 12/15/80 Reso: J. L. Hawks validity and reoresentativeness of the C. 8. Pettersson - inplace density test data based on the STP Status: Comolete - See ST.HL-AE-625 inspection recorts, considering the ST-SH-8R-28 reported construction methods, ST-8R-HL-36189 sequence, and conditions. NRC Status: 00en/ Ready for NRC review Ref. Para: 2 - 19 (2) A
SHOW CAUSE COlV VITM EW S EDITION 05-08-81 Page M-3 COMMITMENT REF. P ARA. DUE DATE RESPONSIBILITY STATUS ~ 'M11 Statistical analyses will be performed Due Date 12/15/80 Resp: J. L. Hawks using in-place density test results. C. 8. Pettersson Ref. Para: 2 - 19 (3) STP Status: Comolete - See ST-HL-AE-625 ST-SH-8R-28 ST-8R-HL-36189 NRC Status: Open/ Ready for NRC review M12 A cocorehensive evaluation is being Due Date 12/15/80 Reso: J. L. Hawks perfcrmed of FSAR Section 2.5.4 C. 8. Pettersson Ref. Para: 2 - 33 (1) STP Status: Complete NRC Status: Closed per 81-03 M13 Based on tne evaluation completed to Que Date 12/15/80 Reso: J. L. Hawks date an FSAR Amendment will be C. 8. Pettersson submitted to clarify the description STP Status: Submittal to licensing by of tne construction process. 3/10/81. Ref. Para: 2 - 33 (1) NRC Status: Ooen/ Ready for NRC review M14 A complete review of Earthwork Oue Date 12/15/80 Reso: J. L. Hawks Inspection Reoorts is being performed STP Status: complete - See ST-8R-HL-36189 to further verify compliance with the ST-SH-8R-28 construction and inspection ST-HL-AE-425 requirements. NRC Status: Closed oer 81-03 Ref. Para: 2 - 35 (3) M15 FSAR Subsection 2.5.4.5.6.2.4 will be Oue Date 9/15/80 Reso: A. H. Geisler revised. STP Status: comolete - Acend. 12 to FSAR Ref. Para: 2 - 36 (2) ST-HL-AE-527. NRC Status: Ocen/ Ready for NRC review Mid FSAR Subsection 2.5.4.5.6.2.5 will be Oue Gate 9/15/80 Reso: A. H. Geisler revi sed. STP Status: comolete - Amend. 12 to FSAR ~ Ref. Para: 2 - 36 (2) ST-HL-AE-527. NRC Status: Open/ Ready for NRC review M17 A comprehensive progran to re-assess Oue Oato 7/7/80 Reso: J. L. Hawks and verify safety related welding at T. J. Natarjan STP, and to determine wnether the STP Status: Conolate. See OCN 7/3/80 to Tt safety related work conoletect was SA700GP004 procerly performed. NRC Status: Closed per 80-38
I ~ S-iOW CAUSE COV Vir VEN S -l EDITION 05-08-81 Page M-4 COMMITMENT REF. P AR A. DUE DATE RESPONSIBILITY STATUS N %8 The task force (safety-related Oue Date 9/12/80 Reso: ~0. Muscente welding) will establish a senedule for STP Status: Comolete. See ST-HL-AE-545 and any repair work as a result of ST-HL-AE-532 discrepancies identified during NRC Status: Closed per 80-38 review. Ref. Para: 3a - 1 (2) M19 The Task Force (safety-related Oue Date N/A Reso: J. L. Hawks concrete structures) will establisn G. R. Murohy schedule on any repair work. STP Status: No repair work identified to Ref. Para: 3b - 2 (1) date. NRC Status: Closed per 81-03 M20 rcd's (Unit 1 & 2) Review to be Oue Date 9/15/80 Resp: J. L. Hawks completed by September 15, 1980 as G. R. Murphy revised by letter ST-HL-AE-521. STP Status: Complete - See ST-8R-HL-36470 Ref. Para: 3b - 2 (2) NRC Status: Closed oer 81-03 M21 MEAB (Unit 1 & 2) Review to be Oue Dato 10/15/80 Reso: J. L. Hawks comoleted by October 15, 1980 as G. R. Murony revised by letter ST.HL-AE-521. STP Status: Comolete - See ST-8R-HL-36470 Mef. Para: 3b - 2 (2) NRC Status: Closed oer 31-03 M22 FHB (Unit 1 & 2) Review to be Oue Date 10/31/80 Reso: J. L. Hawks completed by November 15, 1980 as G. R. Murohy revised by letter ST-HL-AE-521. STP Status: Comolete - See ST-8R HL-36470 Ref. Para: 3b - 2 (2) NRC Status: Closed per 81-03 M23 Samoling by coring, enicaing and Oue Date 8/15/80 Reso: J. L. Hawks l boring in Unit i RCB will be G. R. Murony I accomplisned in next two weeks. STP Status: Comolete. Ref: ST.HL-AE-513 l (August 12,1980) NRC Status: Closed cer 80-38 Ref. Pars: 3b - 4 (3), 3b - 5 (1) M24 A status report by the Task Force will Oue Date 8/15/80 Reso: J. L. Hawks be submitted to NRC I&E Region I'l by G. R. Murohy August 15, 1980. STP Status: Comolete. Ref: ST-HL-AE-513 Ref. Para: 35 - 5 (1) NRC Status: Closed oer 80-38 l \\ .J
SHOW CAUSE COVIVilTV EN S EDITION 05-08-81 Page M-6 COMMITMENT REF. PARA. DUE DATE RESPONSIBILITY STATUS M25 Documentation review for Unit #2 RCB Oue Date 8/1/80 Reso: ~J. L. Hawks is scheduled to be finished in the G. R. Murphy next month. STP Status: Comolete. Evidence of review Ref. Para: 3b - 8 (2) documented on Document Review Checklist. NRC Status: Closed per 81-03 ~ M26 Testing on Unit 1 RCS is ex::ected to Oue Date 8/15/80 Reso: J. L. Hawks be complete by August 12, 1980. G. R. Murohy Ref. Para: 3b - 12 (2) STP Status: Comolete. Ref: ST-HL-AE-513 NRC Status: Closed per 80-38 M27 3rocnure is being replaced with a new Que Date 8/1/80 Reso: K. M. Bronm QA orogram brochure approved by HLSP STP Status: Comotete. Text of the new that reflects the fundamental brochure was provided with philosophy of 10CFR50 Part 50 Aco. resoonse to Show Cause Order. "B". NRC Status: Closed per 80-18 Ref. Para: 4 - 1 (2) M23 New seminars for construction and Q.C. Due Date N/A Reso: X. M. 3 room personnel on objectives and standards STP Status: 5 tarted and on-going. of HL3P/88R QA Programs as they relate NRC Status: Closed ner 80-18 to STP will be commenced oromatly. Ref. Para: 4 - 1 (2), 4 - 2 (1) M29 Procedures defining stoo work Oue Date 8/15/80 Reso: R. A. Frazar authority (HLAP 4 8&R) will be issued '4. J. Friedrich for use by August 15, 1980. STP Status: HLap Ref. Para: 5 - 5 (3) Procedure PSQP-A7 issued definin "Stop '40rt" authori ty. STP Status: BAR Procedure QAP-15.2 issued 8/15/80. NRC Status: Closed oer 80-27, 80-38 M30 Necessary procedures describing the Due Date 9/30/80 Reso: '4. J. Friedrien Insoection Reoort System and Material STP Status: Comolete - see ST-QPA-15.1 and Review Board will be issued in 15.5 issued 10/15/80. Septemoer, 1980. NRC Status: Closed per 80-27, 31-04 Ref. Pars: 5 - 8 (3) M31 Attemot to excedite ANI 4eview of Q.A. Due Date N/A Reso: J. R. Geurts 9anual 4111 de made. STP Status: Gonalete Ref. Para: 6 - 8 (3) NRC Status: Closed oer 31-04 (Show Cause these) (5) closure included Item 1A
SEOW CAUSE COVV "lVET S 'l' EDITION 05-08-81 Page M-6 COMMITMENT REF. PARA. DUE DATE RESPONSIBILITY STATUS-N '. J. Friedrien 132 Detail orocedures for DAG will be Oue Date 8/15/80 Reso: W finalized in mid-August,1980. STP Statis: Comolete. QAP 15.4, " Trend Ref. Para: 6 - 11 (1) Analysis", was issued on 8/15/80. NRC Status: Closed oer 81-04 M33 Personnel training in DAG orocedures Oue Date 8/29/80_ Reso: W. J. Friedrien will be conducted and procedures STP Status: Complete. Training was neld on-implemented in early September,1980. 8/29/80, however training is an Ref. Para: 6 - 11 (1) ongoing activity for the life of tne oroject. NRC Status: Closed per 81-04 (Show Cause Item VA(6) closure included these) M24 OAG First Quarterly Report is expected Oue Date 1/31/81 Reso: W. J. Friedrich to be issued for fourtn quarter 1980. STP Status: Comotete Ref. Para: 6 - 11 (1) NRC Status: Closed Der 81-04 (Show Cause Item VA(6) closure included these) M35 A Change Review Board will be Oue Date 10/1/80 Reso: J. L. Hawks establisned witnin B&R Engineering, STP Status: Carolete - see STP 0C-029 botn at the Site and Houston Office. effective 10/1/80. Ref. Para: 7 - 4 (2) NRC Status: Closed oer 80-36 M36 The Engineering Project Manager will Oue Date 10/1/80 Reso: J. L. Hawks appoint a enairman at each location. STP Status: Complete - see ST-0C-029 Ref. Para: 7 - 4 (2), 7 - 5 (1) effective 10/1/80. NRC Status: Closed per 80-36 M37 All procedures for control of field Oue Date 10/1/80 Reso:, .R. W. Peverley enanges will ce issued ey August 29, STP Status: Comolete - see ST-CC-028, 029, 1980. Revised to Octocer 1, 1980. and 023 effective 10/1/80 Reference ST-AE-520. NRC Status: Coen/ Ready for NRC Review Ref. Pari: 7 - 3 (3) M38 Training seminar is being prepared and Oue Date 10/1/80 Reso: R. W. Peverley will be cresented to all 3&R memoers STP Status: Complete - see GM-70976. wno particioate in this orogram. NRC Status: Ocen/ Ready for NRC 4eview Ref. Para: 7 - 3 (4) ,q39 [nstructions for imolementation Q.A. Due 9 ate 8/1/30 Reso: W. J. Friedrien Records will be issued 5y August 1 STP Status: Comotete. 1980. NRC Status: Closed oer 80-36 Ref. Para: 3 4 (3) t
SHOW CAL SE COVM - VEN-S EDITION 05-08-81 Page M-7 COMMITMENT REF. P AR A. DUE DATE RESPONSIBILITY STATUS N M40 Comoleted generic checklist for all Oue Date 11/1/80 Reso: 'W. J. Frisjrich safety-related records will be in use STP Status: Complete - see QAI-17.1-1 and by November 1, 1980. Appendix; ST-QA'-17.1 4. Ref. Para: 8 - 4 (3) NRC Status: Closed per 80-36 M41 On-site microfilming capability will Oue Date 01/31/81 Resp: W. J. Friedrich be in place and staffing and training STP Status: Gomplete comolete by January 31, 1981. NRC Status: Closed per 81-05 Ref. Para: 8 - 4 (3) M42 B&R will increase the number of Due Date 1/81 Reso: R. W. Bass c= Resident Site Auditors. STP Status: Comolete - See Commitment No. Ref. Para: 9 - 3 (4), 9 - 4 (1) M-4 NRC Status: Gleted sep 30-27 Recoened 81-07 Scheduled to be ready for NRC review 6/4/81
SHOW CAUSE COV VF VEV S EDITION 05-08-81 Page A-1 COMMITMENT REF. P ARA. DUE DATE RESPONSIBILITY STATUS N ~ Al Computer printout of results of Due Date N/A Reso: R. A. Frazar Bechtel Audit are available at STP W. J. Friedrich Site. STP Status: Complete. Ref. Para: 1-4(2) NRC Status: Closed oer 80-27 A2 Off-site corocrate audit function has Oue Date 8/22/80 Reso: R. L. 01 rey been auqcented for puroose of STP Status: MAG personnel have been increasing number of periodic added to assure the increased independent audits. audit activities are Ref. Para: 1-10(2) implemented. NRC Status: Closed per 81-04 A3 Discipline HL&P QA Supervisor will Oue Date 01/15/81 Reso: R. A. Frazar determine the extent of Quality STP Status: Complete Control Inspections and orepare NRC Status: Closed per 81-04 necessary enecklist. Ref. Para: 1 - 11 (1) A4 Quality Systems Organization has Oue Date 11/1/80 Reso: R. A. Frazar responsibility for preparing QA STP Status: complete - PSQP-A2 and A8 procedures analyzing B&R trend data NRC Status: Closed oer 81-01 and analyzing audit findings. Ref. Para: 1-11(2) AS Quality Systems Organization will be Oue Date 11/1/80 Reso: R. A. Feszar responsible for providing coordination STP Status: complete - PSQP.A9 and control for all HLAP QA Training NRC Status: Closed mer 81-01 and Indoctrination Sessions. Ref. Para: 1-12(1) A6 HLAP QC group to oerform inspection of Oue Date01/15/91 Reso: R. A. Frazar ~ selected 1old coints witnin 98R QC STP Status: Gomoleta inspection orogrsm as defined on NRC Status: Closed oer 81-04 checklist provided by 01scioline QA. Ref. Pars: 1 - 12 (3) A7 Discipline Quality Engineers have been Oue cate01/15/81 Reso: W. J. Friedrien assigned responsibility for STP Status; a) Grqanization definition controlling til Q.A. activities corolete i related to their individual c) QAM Section 1 in soecialities. review /comrent cycle. Ref. Pars: 1 - 14 (b) c) QEI-1, Quality Engineering l Instruction on orqanization desfied for review. d) Staffino in oracess. NRC Status: Closed oer 30-27 I
SiOW CAUSE CO VV TVEN S EDITION 05 0 Page A-2 COMMITMENT REF. PARA. DUE DATE RESPONSIBILITY STA' A8 B&R Q.A.E. are resoonsible for Due Date01/15/81 Reso: W. J. Friedric cerformance of: a) Document Reviews STP Status: In process - full b) P. O. Reviews; c) Nonconformances; implementation uoon conole and d) preparation of Insoection staffing. Checklist. NRC Status: Ocen/ Ready for NRC Ref. Para: 1 - 14 (3) A9 Inspectors are advised of the Due Date 10/15/80 Reso: W. J. Friedri Discosition of Findings (NCR's) STP Status: Complete. See ST-QA215.1 Ref. Para: 1 - 15 (2) NRC Status: Closed per 80-27 A10 Upper level management of HL&P will Oue Date N/A Reso: G. W. Oorea, also participate directly in all K. M. Broom aspects of ene oroject, including QA STP Status: On-going - all uocer functions. Frequent on-site visits management have committed and meetings to review progress and frequent periods of time. proolems will be conducted. Many meetings with QA Ref. Para: 1 - 16 (2) Construction and Engineeri have occurred since June i NRC Status: Closed per 31 01 All HL&P Executive V. P. will also Due Date N/A Reso: G. W. Oorea, carticioate in oeriodic meeting of the STP Status: On-going - Mr. Oorea has BAR Q.A. Management Review Board. attended the nonenly QAMRE Ref. Para: 1 - 16 (3) meetings at the Joo Site s July 1980. NRC Status: Closed oer 80-27 A12 Review nas caen made of the Oue Date 9/a/90 Reso: G. W. Oorea, qualifications of all key QA personnel STP Status: Comotete witnin HL&P/B&R oy Bechtel and MAC. NRC Status: Closed 31-04 Ref. Para: 1 - 16 (4) A13 S&R will continue to uagrade Oue Date N/A Reso: K. M. Broom qualifications of its QA/QC Management STP Status: .itarted and on-going. Team. Upgr3 ding to be accomolisned by NRC Status: Closed oer 81 -01 forml and informal training activities and counseling of individuals. Ref. P3ri: 1 - 17 (2)
.s. S -LOW CAUSE CO MM TV ECS EDITION 05-08-81 Page A-3 COMMITMENT REF. P AR A. DUE DATE RESPONSIBILITY STATUS N 114 Tecnnical Training Programs for QA/QC Oue Date 9/15/80 Reso: ~Vurpillat personnel to ensure full knowledge of STP Status: Comoleted - ST-QAP-2.2, and procedural requirements have been and GCP-1 to be used on continuous will continue to be conducted. basis. Ref. Para: 1 - 17 (3) NRC Status: Closed per 81-04 AL5 Program of retraining Inspectors and Oue 0 ate 1/1/81* Reso: R. H. Leasburg W. J. Friedrich Crafts is currently underway. Ref. Para: 1 - 19 (3) STP Status: Required by GCP-1 and ST-QAP-6.1; enconoasses all procedures developed and revisions to proceduras. 'For Crafts NRC Status: Closed per 81-04 A16 Quality Engineers are establisning the Oue Date 1/1/81 _ Reso: W. J. Friedrich necessary training programs to uodate STP Status: See A15 acove. construction and QC oersonnel on newly NRC Status: Closed per 81-04 estaolished Quality requirernents. Ref. Pars: 1 - 19 (3) Alf In area of revised procedures, Que Date 1/1/81 Reso: R. H. l.easburg W. J. Friedrich indoctrination and training sessions are underway to educate oersonnel on STP Status: See A15 aeove. changes in QA procedures, organization NRC Status: Closed oer 81-04 interfaces and responsibilities. Ref. Para: 1 - 19 (3) A18 A reouirement has been establisnod for Que Gate N/A Reso:
- 0. G. Rarker J. R. Geurts periodic meetings at the site wnien will be attended by key uocer and STP Status:
Started and on-going. middle management personnel of NRC Status: Closed per 31 01 HL&P/84R. Eacn meeting will include a recort on ene status of tne QA program nignlignting Quality problems, trenas, etc. Ref. Para: 1 - 20 (2) ( Al9 Ine QA prograns of HL&P are being Oue Cate 10/1/80_ 4eso: R. A. Fetzar revised to include an innual audit oy STP Status: Gonalete. See PSQP A-1 an indecencent consultant. NRC Status: Closed oer 30-27 Ref. Pari: 1 - 21 (1) l l f I m
SHOW CAUSE CO VMFME\\TS EDITf0N05-08$1 Page A-4 COMMITMENT REF. PARA. DUE DATE RESPONSIBILITY STATUS A2C B&R/HL&P Cat. I structural backfill Oue Gatel2/15/80* Reso:' J. L. Hawks task force identified the following C. 8. Pettersson reviews to be perfomed. STP Status: Complete - See ST-HL-AE-625 ST-BR-HL-36189 a) Reconfim tne adequacy of the ST-SH-BR-28 construction methods used during NRC Status; a) Closed Der 30-24 Cat. I structural backfill b) Closed oer 80-24 olacements. c) Ooen/ Ready for NRC review d) Ocen/ Ready for NRC review c) Comoarison of backfill material e) Ooen/ Ready for NRC review tested for tne engineering design f) Open/ Ready for NRC review studies with material actuall.y g) Ocen/ Ready for NRC review olaced. h) Ooen/ Ready for NRC. review i) Closed oer 80-24 c) Plan views and orofiles to snow ene sequence of backfill placements and lift thickness. d) Review of all earthwork inscection recorts. e) Statistical analysis of the in place density test to detemine the costulated density distribution. f) Decemination of the relative density requirements of the oackfill. g) Analysis of the significance of density distribution witnin the surface lift, immediately below Cat. I structural foundations, n) Aaview of previous boring crogram results for evaluation of the engineering adequacy of tne backfill. i) Comoarative determination of max / min laceratory density test results by an indeoendent laboratories. j) dvaluation af all data concerning generic or scecific croolem witn construction i quality control oroqrams. Ref. Para: 2 - 3 (2) _______________a
SHOW CAUSE CO V Vill VW S EDIT 10N 05-08-81 Page A-5 COMMITMENT REF. P ARA. DUE DATE RESPONSIBILITY STATUS N S21 An independent review was established Oue Date 12/15/80 Reso: 'J. L. Hawks C. B. Pettersson to: STP Status: Complete - See ST-BR-HL-36189 a) Review laboratory test and design ST-HL-AE-625 analyses performed on the backfill ST-SH-BR-28 concerning liquification and NRC Status: a) Closed per 80-24 settlement. b) Closed per 80-24 c) Closed oer 80-24 l b) Reviewing the recommendations and d) Open/ Ready for NRC review j criteria for compaction of the e) Open/ Ready for NRC review j backfill as documented in reports f) Open/ Ready for NRC review j issued by WCC. q) Open/ Ready for NRC review h) Ocen/ Ready for NRC review c) Reviewing the construction
- 1) Closed per 80-24 specification and procedures for compaction of the backfill (including methods used in field) t d) Reviewing the prescribed and implemented inspection and testing procedures for compaction control of the backfill olacement; including QC methods and documentation imolemented in the i
I field. e) Reviewing and analyzing compaction Quality Control Test results collected and documented covering the construction period from 1976-1980. f) Reviewing the results of special investigations of placed backfill to assess adherence to design requirements including the results of tne test boring program performed in Soring 1980. g) In event of low density pockets are delineated in the backfill, reviewing tne efficiency of the metnods orocosed by 8&R engineering to treat those occkets to bring them inaccordance with design reouirements.
SHOW CAUSE CO V VITMENTS EDlT!ON 05-08-81 Page A-6 COMMITMENT REF. P ARA. DUE DATE RESPONSIBILITY STATUS h) Inspecting the onsite laboratory facilities and equipment used by existing testing agency and reviewing this laboratory test procedures, i) Reviewing the procedures, observing field coerations and evaluating the results of the test fill program. Ref. Para: 2 - 5 (2), 2 - 6 (1) A22 Test fill program conducted in 1980 Oue Date 12/15/80 Reso: J. L. Hawks together with the results from 1976 C. 3. Pettersson program are documented in TRO 3A700 STP Status: Issued for review as GP002-8. P0CN/7-21-80. Complete Ref. Para: 2 - 10 (2) NRC Status: Closed per 80-38 A23 B&R has defined deotns for in-place Due Date 7/23/80 Reso: J. L. Hawks density testing as a means of assuring C. 3. Pettersson Systematic Field Quality Control. STP Status: Complete. Ref. Para: 2 - 12 (1) NRC Status: Closed per 80-38 A24 An evaluation nas been made by the S&R Due Date 7/14/80 Reso: J. L. Hawks task force to reconfirm the compliance C. B. Pettersson of the Category 1 structural backfill STP Status: Comolete placed at site with design basis Ref: Resoonse to Item 25. material characteristics described in NRC Status: Closed per 80-38 FSAR 2.5.4.8.3. Ref. Para: 2 - 12 (6), 2 - 13 (1) A25 Yet to be completed are tne sequence Due Date 12/15/80 Reso: J. L. Hawks of construction and remaining lift - C. B. Pettersson - thickness. STP Status: Final issue TRD 3A700GP001. Ref. Para: 2 - 17 (2) The data will be available as working documents and sill be used for Items A27, A28, and A30. NRC Status: Open/ Ready for NRC A26 The task force has comoleted a Que Date 12/15/80 Reso: J. L. Hawks tabulation of density test with deotn C. 3. Pettersson in the backfill olacements and field STP Status: Comolete - See TRD 3A700GP001 verification of lift tnicknesses in NRC Status: Closed oer 31-03 accessiole areas. Ref. Para: 2 - 17 (2)
l' SHOW CAUSE COVIMF VEW S EDITION 05-08-81 Page A-7 COMMITMENT REF. P AR A. DUE DATE RESPONSIBILITY STATUS ~ 427 The results will be used for Due Date 12/15/80 Reso: J. L. Hawks statistical analysis of the density C. B. Pettersson . distribution within the backfill, for STP Status: Complete - See ST-WC-8R-5791 evaluation of backfill placement and NRC Status: Open/ Ready for NRC compaction operations, and for assessment of the engineering adequacy of the in place backfill. Ref. Para: 2 - 17 (2) A28 The data comoiled during the Oue Date 12/15/80 Reso: J. L. Hawks evaluation will also be used as input C. B. Pettersson to the studies of the adequacy of the STP Status: Comolete existing backfill, NRC Status: Open/ Ready for NRC Ref. Para: 2 - 17 (2), 2 - 18 (1) A29 The data compilation is described in Oue Date 12/15/80 Reso: J. L. Hawks B&R TRO 3A700GP001-8. C. B. Pettersson Ref. Para: 2 - 18 (2) STP Status: Comolete NRC Status: Open/ Ready for NRC A30 Earthwork Inspection Reports will be Due Date 12/15/80 Reso: J. L. Hawks C. B. Pettersson carefully reviewed to determine whether or not the reported activities STP Status: Complete are in accordance with applicable NRC Status: Open/ Ready for NRC specification and construction procedures. Ref. Para: 2 - 19 (1) A31 The in olace density test data and Oue Date 12/15/80 Reso: J. L. Hawks statistical results will also be C. B. Pettersson evaluated in comoarison to the results STP Status: Complete - See ST-WC-8R-5797 of tne soil test boring program. NRC Status: Ooen/ Ready for NRC Ref. Para: 2 - 19 (4) A32 The indeoendent review committee has Due Date 12/15/80 Reso: J. L. Hawks reviewed all pertinent aspec s of the C. B. Pettersson structural backfill design studies, STP Status: Comolete - See ST-HL AE-625 specification criteria, construction ST-SH-8R-28 procedures and inspection and testing NRC Status: Closed per 81-03 documentation. Ref. Para: 2 - 28 (2)
SHOW CAUSE COVIVI VEN S 'l'- EDITION 05-08-81 Page A-8 COMMITMENT REF. P AR A. DUE DATE RESPONSIBILITY STATUS N A33 Future inspection activities will be Due Date 6/20/80 Reso: 'J. L. Hawks conducted under engineering direction C. B. Pettersson to assure satisfactory inspections STP Status: Complete. suoported by comprehensive Ref: TRO 3A700GP005 documentation. NRC Status: Closed per 80-38 Ref. Para: 2 - 36 (1) A34 Safety-related welds being examined by Due Date 12/31/80 Reso: J. L. Hawks tne Task Force includes all ASME T. J. Natarajan Section III Pipe & Pipe Hanger Welds & STP Status: Comolete Seismic Cat.1 Structural Steel Welds NRC Status: Closed per 80-38 made per AWS 01.1. Ref. Para: 3a - 3 (3) A35 This program defined a series of Que Date 12/21/80 Reso: J. L. Hawks activities starting with a complete T. J. Natarjan review of all welding documentation, STP Status: Comolete review of all welder & insoector NRC Status: Closed per 80-38 qualification records; examination of the traceability of all base metal & weld filler material; and finally verification and reexamination of selected welds through a random sampling program. Ref. Para: 3a - 3 (3), 3a 4 (1) A36 The Weld Review Program has been Due Date 12/31/80 Reso: J. L. Hawks documented in TRO SA700GP004 The TRO T. J. Natarjan will be updated periodically to STP Status: Comolete incorporate changes in the results of NRC Status: Closed oer 81-14 ene program. Ref. Para: 3a - 5 (3) A37 The qualifications of cersonnel wno Que Date 10/18/80 Resa: J. L. Hawks inspected ASME Pioing & Cat. 1
- 7. J. Natarjan Structural Weld are being reviewed to STP Status:
Comolete - Nutech Letter verify that eney were procerly 07U-00-006/ qualified and certified in accordance 3R0-01-006 dated with Code & Project Requirements. 10/14/80 Ref. Para: 3a - 6 (1) NRC Status: Closed per 80-38
SHOW CAUSE COVIVilTV EN S EDITION 05-08-81 Page A-9 W COMMITMENT REF. P ARA. DUE DATE RESPONSIBILITY STATUS NO. A38 For ASME Piping, the existing Due Date 12/31/80 Reso: J. L. Hawks radiographs and NDE Inspection results T. J. Natarjan cn weld data cards, weld data repair STP Status: Comolete cards, and QC Insoection Reports are NRC Status: Closed per 81-06 being reviewed for completeness and compliance to code and project requirements. Ref. Para: 3a - 6 (1) A39 A review of NDE Procedures has Due Date 9/30/80 Reso: W. J. Friedrich identified the need for improvements STP Status: Comolete. which have been and are being NRC Status: Closed per 80-38 incorporated into the N0E Procedures. Ref. Para: 3a - 6 (2) A40 Personnel qualifications will be Oue Date 10/18/80 Reso: W. J. Friedrich reviewed by the Brown & Root Level III STP Status: comolete - corrective action & Task Force Level III to determine is to re-radiograoh all the corrective action for the Task accessible safety related Force findings. welds. Ref. Para: 3a - 7 (1) NRC Status: Closed oer 80-38 A41 Further review is reouired of previous Que Date 9/22/80 Reso: W. J. Friedrich QA procedures and training manuals STP Status: complete centaining requirements for personnel NRC Status: Closed per 81-03 qual i fications. Ref. Para: 3a - 7 (1) A42 In addition the Level III Program of Que Date 9/22/80 Reso: W. J. Friedricn Certifications and NDE Examinations is STP Status: complete being reviewed. NRC Status: Closed oer 81-03 Ref. Para: 3a - 7 (1) A43 A reevaluation of all final accepted Oue Date 9/29/80 Reso: W. J. Friedrich radiographs has ',een performed. STP Status: The reevaluation has been Ref. Para: 3a - 7 (3) completed. The results will be issued in the final recor from Southwest Researcn. NRC Status: Closed oer 80-38 A44 All AWS Cat. 1 erection documentation Oue Date N/A Reso: J. L. Hawks nas been reviewed and tabulated. D. Muscente Ref. Para 3a - 9 (2) STP Status: All AWS accessiole nelds will be reexamined. NRC Status: Closeo cer 80-38
SHOW CAUSE COMMF VEW S f EDITION 05-08-81 Page A-10 COMMITMENT REF. P ARA. DUE DATE RESPONSIBILITY STATUS ~ A45 For AWS Cat. 1 shop welding, all shop Oue Date 8/18/80 Reso: J. L. Hawks work request have been reviewed to
- 0. Muscente identify tnose request which required STP Status:
Complete. welding. Ref: OCN 8/15/80 to TRO 5A700GP004-8. Ref. Para: 3a - 9 (2) NRC Status: Closed per 80-38 A46 Cat.1 Structural Steel Material Oue Date 12/31/80 Reso: J. L. Hawks Certifications are being reviewed for D. Muscente compliance with code and project STP Status: Complete requi rements. NRC Status: Closed per 81-14 Ref. Para: 3a - 9 (2) A47 AWS Welding Procedures are also being Due Date 12/31/80 Reso: J. L. Hawks reviewed for compliance with code and O. Muscente project requirements by comparison STP Status: Complete against primary documents (i.e. AWS NRC Status: Closed per 80-38 Code, AISC Manual & Design Speci fications) Ref. Para: 3a - 9 (2) A48 For ASME Piping Weld Documentation has Oue Date 6/30/80 Reso: J. L. Hawks been compiled (from isometric UWGS, D. Muscente TRO's, Welc Data Cards, et:.). STP Status: Comolete. Ref. Para: 3a - 11 (1) NRC Status: Closed per 80-38 l A49 Evaluations are being made for each Oue Gate 12/31/80 Reso: J. L. Hawks weld based on information obtained in D. Muscente l otner task (review of NDE oracedures, STP Status: Complete i inspector qualification reevaluation NRC Status: Closed per 80-38 l of existing R/T etc.). l Ref. Para: 3a - 11 (1) A50 ASME Pioing Walkdown will be performed Due Date 12/31/80 Reso: J. L. Hawks
- o anysically verify information
- 0. Muscente collected in the ASME Piping Weld STP Status:
Complete - Review comoleted by Occumentation Review. Review Team. Further review Ref. Para: 3a - 12 (1) deemed unnecessary subsequent to decision to re-examine all accessible field welds 100%. NRC Status: Closed oer 80-38 f
./.' SHOW CAUSE CO VIVilTMEW S EDITION 05-08-81 Page A-11 COMMITMENT REF. P ARA. DUE DATE RESPONSIBILITY STATUS NO. ~ A51 Fuel transfer tube and steam generator Due Date 12/31/80 Resp: J. L. Hawks supports are being investigated to
- 0. Muscente verify the basis on which changes were STP Status: Complete made in Code Classification Material NRC Status: Closed per 81-06 Traceability and Inspection / Hydro Testing.
Ref. Para: 3a - 12 (1) A52. Aporoximately 1300 ASME welds have Oue Date N/A Reso: J. L. Hawks been completed or are in process and D. Muscente applicable weld data has been STP Status: Comolete collected. NRC Status: Closed oer 81-06 Ref. Para: 3a - 12 (2) A53 Technical Review of the data collected Oue Date 12/31/80 Reso: J. L. Hawks on oipe welds will continue to
- 0. Muscente completion.
STP Status: Comolete Ref. Para: 3a - 12 (2) NRC Status: Closed per 81-06 AS4 A review of pipe supports and hangers Due Date 12/31/80 Reso: J. L. Hawks will commence as soon as the task on O. Muscente oice welds is comolete. STP Status: Complete - Review concleted by Ref. Para: 3a - 12 (2) Review Team. Further review deemed 'Jnnecessary subsequent to decision to re-examine all accessible field welds 100%. NRC Status: Closed per 81-06 A55 The investigation of the NRC concerns Oue Date 12/31/80 Reso: J. L. Hawks regarding the fuel transfer tube and D. Muscente steam generator supoorts is in STP Status: Comolete progress. NRC Status: Closed cer,81-06 Ref. Para: 3a - 12 (2) A56 The review of welder qualifications is Due Date 12/31/80 Reso: J. L. Hawks performed by reviewing welder
- 0. Muscente quali fication test records.
STP Status: Comolete Ref. Para: 3a - 13 (1) NRC Status: Closed per 80-38 A57 Continuity of certification is being Due Gate 12/31/80 Reso: J. L. Hawks checked against emoloyment records for D. Muscente welders. STP Status: Comolete Ref. Para: 3a - 13 (1) NRC Status: Closed cer 31-14 ~ I
SHOW CAUSE CO V mrv ETS l'.. EDITION 05-08-81 Page A-12 COMMITMENT REF. P ARA. DUE DATE RESPONSIBILITY STATUS TM NO. ~ 458 The associated Certified Material Test Oue Date 12/31/80 Reso: J. L. Hawks D. Muscente Reports will be reviewed for code compliance and the material type will STP Status: Comolete be checked against that required by NRC Status: Closed per 81-14 the welding procedure specification. Ref. Para: 3a - 13 (1) A59 The system for controlling Due Date 10/15/80 Reso: J. L. Hawks O. Muscente distribution of the filler metal will be reviewed for code and specification STP Status: Complete. Ref. 17ECP-8 compliance. NRC Ststus: Closed oer 81-03 Ref. Para: 3a - 13 (1) A60 Two irregularities in oracedures: 1) Que Date 10/18/80 Reso: J. L. Hawks D. Muscente use of film side versus source side penetrameters on some of the welder STP Status: Comolete - See Nutecn letter coupons tested; 2) use of less BR0-01-005 dated 10/17/80 and ~ memo GM-75698 stringent ASME acceptance criteria instead of the AWS acceptance criteria NRC Status: Closed cer 81-06 for the AWS test coupons. These concerns will be evaluated to determine the acceptable of the affected qualifications. Ref. Para: 3a - 13 (2), 3a - 14 (1) Welding filler materials used for Due Date 12/31/80 Reso: J. L. Hawks A61
- 9. Muscente I
safety-related welding, CMTR's will be evaluated for compliance to code anc STP Status: Comolete project requirements. NRC Status: Closed cer 81-14 Ref. Para: 3a - 14 (2) ) A62 Welder qualification records will be Due Date 12/31/80 Reso: J. L. Hawks ~ ~ 0. Muscente ~ l comoleted wnen all weld data cards l nave been reviewed. STP Status: Comolete Ref. Para: 3a - 14 (1) NRC Status: Closed per 31-06 4 A63 A review of the "unresol'v'ed items" Oue Date 12/31/80 Reso: J. L. Hawks D. Muscente identified in tne NRC Investigation Report is being cerformed to evaluate STP Status: Comolete and resolve tne recorted concerns. NRC Status: Ocen/ Ready for NRC review l Ref. Para: 3a - la (3) i l 1
SHOW CAUSE CO M VilT VI EN-S E01110N Os.08.e1 Page A-13 TEM COMMITMENT REF. PAR A. DUE DATE RESPONSlBILITY STATUS NO. A64 Past NRC, HL&P, B&R Audit Reports have Due Date 12/31/80 Reso: J. L. Hawks been reviewed to determine the extent D. Muscente to which audit deficiencies have been STP Status: Comolete properly dispositioned. NRC Status: Closed per 81-14 Ref. Para: 3a - 14 (4) A65 Field Generated Reports (NCR's, Due Date 12/31/80 Reso: J. L. Hawks FREA's and CAR's) have been reviewed O. Muscente to verify that each has been properly STP Status: Complete dispositioned. NRC Status: Partial closure 81-04 Ref. Para: 3a - 15 (1) A66 The PSAR/FSAR and Engineering Oue Date 7/18/80 Reso: J. L. Hawks Specifications have been reviewed to T. J. Natarjan identify the applicable edition and ST? Status: Comolete. OCN to TRO addenda for all specified codes and SA700GP004 includes results. standards. NRC Status: Closed per 80-38 Ref. Para: 3a - 15 (1) A67 The Construction and QC Procedures Oue Date 12/31/80 Reso: J. L. Hawks (current ano cast revisions) covering D. Muscente safety-related oiping and Cat. 1 STP Status: Comolete Structural Steel are being reviewed NRC Status: Closed aer 30-38 for consistency anc ccmpliance to project requirements. Ref. Para: 3a - 15 (1) A68 Past audits and field generated Due Date 12/31/80 Reso: J. L. Hawks documents such as NCR's FREA's, and O. Muscente CAR's related to welding are being STP Status: Comolete reviewed. NRC Status: Ooen/ Ready for NRC review Ref. Para: 3a - 15 (2) A69 An initial review of field generated Due Date 12/31/80 Reso: J. L. Hawks documents nas been completed, but an
- 0. Muscente evaluation of tne information gathered STP Status: Comolete is required.
NRC Status: Partial closure 81-04 Ref. Para: 3a - 15 (2) A70 The Engineering Soecifications and Due Date 12/31/80 Reso: J. L. Hawks Construction Procedures have been D. Muscente reviewed for consistency and STP Status: Carolete comoliance witn PSAR/FSAR. NRC Status: Goen/ Ready for NRC review Ref. Para: 3a - 16 (1)
SHOW CAUSE CO VIMFVETS EDZTION 05-08 '81 Page A-14 COMMITMENT REF. P AR A. DUE DATE RESPONSIBILITY STATUS N A7T. All Cat. 1 Structural Steel Accessible Oue Date N/A Reso: 'W. J. Friedrien Welds will be visually re-examined by STP Status: Complete - Task Force Review inspectors wno have been retrained to Team recommended 100". tne AWS Code 01.1-75 with special re-examination. Decision was emphasis on the detailed requirements made to re-examine and repair. 100% of all accessible welds. of the code. Ref. Para: 3a - 17 (1) Program is in progress. NRC Status: Closed oer 80-38 A72 AWS training will also include a Que Date 9/22/80 Resp: W. J. Friedrien detailed review of the welding and NDE STP Status: Comolete - Training to Procedures wnicn include code and continue for QC Inspec. tors design specification requirements. until adequate staffing is Ref. Para: 3a - 17 (1) available. NRC Status: Closed per 80-38 A73 The results of the examination will be Oue Date N/A Reso: J. L. Hawks evaluated and accessible welds will be O. Muscente repaired as required. STP Status: Canalete - Task Force Review Ref. Para: 3a - 17 (1) Team recomended 100% re-examination. Decision was made to re-examine and recair 100f. of all accessible welds. Program is in orocress. NRC Status: Closea per 80-38 ( A74 The weld cnaratteristics and other Due Date N/A Reso: J. L. Hawks D. Muscente pertinent information will be statistically classified for use in an STP Status: Complete - Information will be engineering analysis of inaccessible develooed during welds to determine their re-examination of existing welds. l acceptaoility, Ref. Para: 3a - 17 (1) NRC Status: Open/ Ready for NRC review l l A75 ASME ECW Pipe Welds, the 9&R and Task Oue Date 9/27/80 Reso: J. L. Hawks Force Level III will review the R/T T. J. Natarian l film found to have unacceptable STP Status: Comolete - Re-radiooraon all l indications in order to determine the ac::essible welds (not in or l selds requiring repair. under structures) See Nutech Ref. Para: 3a - 18 (1) letters DTU 80-002/9-22-80 and DTU-80-20/10-29-80 and memo GM-75698 NRC Status: Closed cer 80-38
SHOW CAUSE COMMF MEW S s-EDIT 10N 05-08-81 Page A-15 COMMITMENT REF. P ARA. DUE DATE RESPONSIBILITY STATUS A76 In cases where ECW Pioe with Due Date N/A Reso: ~J. L. Hawks unacceptable indications is curied in D. Muscente or under concrete, an engineering STP Status: Complete - Information will be 1 evaluation will be conducted to developed during. determine the necessity of repair. re-examination of existing Ref. Para: 3a - 18 (1) welds. NRC Status: Open/ Ready for NRC review A77 8efore commencing needed repair, on Oue Date N/A Reso: J. L. Hawks ECW Welds, the entire weld will be
- 0. Muscente examined by PT & RT metnods regardless STP Status: Comolete - Information will be of whetner SPOT or FULL RT was developed during originally emolayed.
re-examination of existing Ref. Para: 3a - 18 (1) welds. NRC Status: Ooen/ Ready for NRC review A78 Reoaired segments of ECW Welds will be Oue Date: N/A Reso: J. L. Hawks reexamined by RT and PT for final
- 0. Muscente acceptance.
STP Status: Comolete - Information will be Ref. Para: 3a - 18 (1) develooed during re-examination of existing welds. NRC Status: Ooen/ Ready for NRC review 1 A79 ECW results will be evaluated witn Due Date N/A Reso: J. L. Hawks regard to inspector and welder D. Muscente performance to detarmine if additional STP Status: Comolete - Review completed by welds need inspection. Review Team. Further review j REf. Para: 3a - 18 (1) deemed unnecessary subsequent to decision to re-examine all accessible field welds 100%. NRC Status: Closed oer 80-38 j A80 ASME Pipe Welds (other than ECW) the Oue Date 10/18/80 Reso: J. L. Hawks B&R Level III will review the
- 7. J. Natarjan i
qualifications of PT Inspectors to STP Status: Comolete. See interim recort. determine whether additional welds " Reexamination, Reoair and 1 require reexamination. Welding Restart Plans" Rev. 1 i Ref. Para: 3a - 18 (2) NRC Status: Closed per 80-38 A81 3&R Level III will evaluate the Uue Date 9/27/30 Reso: J. L. Haw <s remaining RT to establisn the need for T. J. Natarjan ASME weld reoair. STP Status: Comolete - Ref. Nutacn letters Ref. Para: 3a - 18 ( 2) OTU-80-002/9-22-80 and DT'J 020/10-29-80 and memo GM-75698 NRC Status: Closed oer 30-38
SHOW CAUSE CO V VFV EWS EDITION 05-08-81 Page A-16 j ' 31 COMMITMENT REF. P ARA. . DUE DATE RESPONSIBILITY STATUS NO. '. L. Hawks A82 All accessible ASME Socket Welds and a Due Date N/A Reso: J large sample of butt welds will be D. Muscente reexamined. STP Status: Complete - Information will be Ref. Para: 3a - 19 (1) develooed during re-examination of existing welds. NRC Status: Closed per 81-06 A83 All rejectable indications will be Oue Date N/A Reso: J. L. Hawks repaired unless the welds are embedded D. Musen.nte in concrete. Welds buried in concrete STP Status: Conolete - Information will be an engineering evaluation will be develooed during performed to determine the necessity re-examination of existing of repair, welds. Ref. Para: 3a - 19 (1) NRC Status': Closed per 81-06 A34 ASME NF and Hanger Weld Documentation Due Date N/A Reso: J. L. Hawks will be reviewed and evaluated. D. Muscente Ref. Para: 3a - 19 (2) STP Status: Comolete NRC Status: Closed per 81-06 A85 A sample of the support and hanger Due Date N/A Reso: J. L. Hawks welds will be reexamined to determine D. Muscente overall ccndition of the welds. STP Status: Comolete - Review completed oy Ref. Para: 3a - 19 (2) Review Team. Further review deered unnecessary subsequent to decision to re-examine all accessiole field welds 100%. NRC Status: Closed oer 81-06 A86 NF Support and Hanger Welds performed Oue Gate N/A Reso: J. L. Hawks by unqualified personnel will be D. Muscente repeated. STP Status: Complete - Re' view comoleted by ' Ref. Para: 3a - 19 (2) Review Team. Furtner review deened unnecessary subsequent to decision to re-examine all i accessible field welds 100%. i NRC Status: Closed per 31-06 l A87 A gradual restart on a controlled Oue Date 9/12/80 Reso: J. L. Hawks casis in accordance witn a steo by Don Muscente steo crogram of planned activities has STP Status: Cccolete. See ST-HL AE-555 ceen crecared. NRC Status: Closed oer 30-38 Ref. Para: 3a - 19 (3)
SHOW CAUSE COVVF VENTS EDITION 05-08-81 Page A-17 COMMITMENT REF. P ARA. DUE DATE RESPONSIBILITY STATUS ~ A88 With respect to RCB's which are the Oue Date 12/15/80 Resp: I. L. Hawks first category of structures under G. R. Murphy review, the Task Force and Cnnsultants STP Status: Complete - See ST-HL-AE-513 Panel are examining internal ST-8R-HL-36470 placements. NRC Status: Closed per 80-38 Ref. Para: 3b - 3 (3) AG9 The Task Force and Consultants Panel Oue Date N/A Reso: J. L. Hawks are reviewing the results of previous G. R. Murohy HL&P/B&R investigations of the RC8 STP Status: Complete. Ref: ST-HL-AE-513 snells. NRC Status: Closed per 80-38 Ref. Para: 3b - 3 (3) A90 A list of unresolved concerns Due Date 12/15/80 Resp: J. L. Hawks previously identified in NRC HL&P & G. R. Murphy B&R Audits have been concileo. STP Status: Comolete - See ST-BR-HL-36470 Ref. Para: 3b - 3 (4), 3b - 4 (1) NRC Status: Closed oer 80-38 A91 Unresolved concerns will be addressed Oue Date 12/15/80 Reso: J. L. Hawks eitner in the normal course of the G. R. Murphy review or througn soecial STP Status: Comolete - See ST-HL-AE-513 investigation. ST-8R-HL-36470 Ref. Para: 3b 4 (1) NRC Status: Closed per 51-03 A92 TRO 2A700GP003 " review of Due Date N/A Reso: J. L. Hawks safety-related concrete structures G. R. Murohy including emoedments will be updated STP Status: Complete periodically to incorocrate changes in NRC Status: C1nsed per 80-38 and results of the program. Ref. Para: 3b 4 (2) A93 UT testing of concrete has found one Oue Date S/15/80 Reso: -J. L. Hawks (1) discrepancy (appears to be due to G. R. Murohy surface condition) wnich is being STP Status: Comolete. Ref: ST-dL-AE-513. further investigated and is excected to oe resolved shortly. NRC Status: Closed oer 81-03 Ref. Para: 3b - 4 (3)
SHOW CAUSE COVMF MEN S EDITION 05-08-81 Page A-18 .-_l' TEM COMMITMENT REF. P ARA. DUE DATE RESPONSIBILITY STATUS .4 0. A94 To assure all documentation has been Oue Date 10/31/80 Reso: J. L. Hawks ~ performed, all test reports, batch G. R. Murphy plant recorcs, ocur cards, inspection STP Status: Review is complete - GM-75289 reports, drawings, DCN's, FREA's, See - ST-8R-HL-36470 I NCR's, and CAR's which pertain to NRC Status: Closed per 81-03 selected placements are being reviewed and evaluated as to their correctness and completeness. Ref. Para: 3b - 7 (2) A95 Test recorts are being evaluated for Oue Date 12/15/80 Reso: J. L. Hawks the cement admixture, aggregates and G. R. Murphy water used, as well as slump, air STP Status: Comolete - See St-8R-HL-36470 content, compressive strength, unit NRC Status: Closed oer 81-03 weignt and concrete tamperature. Ref. Para: 3b - 7 (2) A96 Each report is being checked for Due Date 10/31/80 Reso: J. L. Hawks completeness, design compliance, and G..R. Murphy for proper signature of initials. STP Status: Review is complete - GM-85289 Ref. Para: 3b - 7 (2) See - ST-BR-HL-36470 NRC Status: Closed oer 81-03 A97 Batch plant records are being Oue Date 12/15/80 Reso: J. L. Hawks evaluated for completeness of record, G. R. Murchy proper signatures or initials, and STP Status: Complete - See ST-8R-HL-36470 conoliance with applicable procedures. NRC Status: Closed per 81-03 Ref. Para: 3b - 7 (2) A98 Pour cards are being checked for CC Oue Date 12/15/80 Reso. J. L. Hawks signatures, listing of NCR's, FREA's, G. R. Murohy DCN's, and drawings, and notations of STP Status: Comolete - See ST-BR-HL-36470 other unsatisfactory conditions which NRC Status: Closed cer 3-1-03 snould have resulted in the issuance of an NCR. Ref. Para: 3b - 7 (2) A99 Preplacement, placement, and curing Due Date 12/15/80 Reso: J. L. Hawks inspection checklist are being G. R. Murony reviewed for orocer signatures, time STP Status: Comolete - See ST-8R-HL-36470 scan between preplacement inspection NRC Status: Closed per 31-03 and of pour, ano notations of other unsatisfactory condition unich snould have resulted in issuance of NCR. Ref. Para: 3b - 7 (2), 3b - 3 (1)
.c SHOW CAUSE CO M VilT VIENTS EDITION 05-08-81 fage A-19 COMMITMENT REF. PAR A. DUE DATE RESPONSIBILITY STATUS N ~ 4100 Where available, punchlist are also Due Date 12/15/80 Reso: J. L. Hawks being evaluated for proper signoff of G. R. Murphy each item. STP Status: Comolete - See ST-8R-HL-36470 Ref. Para: 3b - 8 (1) NRC Status: Closed per 81-03 A101 As designed documents (including Due Date 12/15/80 Reso: J. L. Hawks NCR's, FREA's, drawings, and OCN's) G. R. Murphy are being evaluated to determine where STP Status: Comolete - See ST-BR-HL-36470 every emoedment, penetration, anchor NRC Status: Closed per 81-03 colt, construction joint, opening and dimension change should be located. Ref. Para: 3b - 8 (2) A102 The "as-built" inspection program Due Date 12/15/80 Reso: J. L. Hawks consist of obtaining field G. R. Murphy measurements for: placement location STP Status: Comolete - See ST-8R-HL-36470 and dimensions (tnickness, openings, NRC Status: Closed per 81-03 plumbness, squareness, size, and identification if available). Ref. Para: 3b - 9 (2) A103 Once the "as-Ouilt" condition is Due Date 12/15/80 Reso: J. L. haw s documented, it will be comoared to the G. R. tdur,:hy "as designed" condition ana all STP Status: Comolete - See ST-dR-HL-36470 ciscrepancies will be identified. NRC Status: Closed oer 81-03 Ref. Para: 3b - 9 (2) A104 Visual inspection is being performed Oue Date 12/15/80 Reso: J. L. Hawks by the Special Consultants Panel and G. R. tiurony selected examiners from the Task Force STP Status: Comolete - See ST-BR-HL-36470 and addresses the following areas: NRC Status: Closed per 81-03 1) General appearance of the surface ~ 2) Nature and extent of cracking 3) Evidence or volume enange 4) Evidence of cement /aggreget reactions 5) Secondary deoosit on surface 5) Secondary deposits in cracks or voids
- 7) Construction joint alignment
- 8) Construction joint cleanliness
- 9) Control joints 10)
The nature and extent of deflections
1 SHOW CAUSE CO V VlFMENTS EDITION 05-08-81 Page A-20 ~ I , COMMITMENT REF. PARA. DUE DATE RESPONSIBILITY STATUS
- 11) The nature and extent of
~ dislocations resulting in joint movement
- 12) Tilting
- 13) Shearing or misalignment of structural elements
- 14) Apparent effectiveness of curing
- 15) The extent and significance of surface characteristics
- 16) Indication of inadequate consolidation
- 17) Indications of adequace consolidation behind embedment
- 18) The adequacy of repairs based on soundness and appearance
- 19) Satisfactory embedment of cenetration
- 20) Dislocation or misalignment of embedded plates
- 21) Satisfactory embedment of plates
- 22) Apparent consolidation surrounding anchor bolts
- 23) General appearance of seismic joints
- 24) Evidence of grout leakage, and
- 25) Adequacy of existing recairs Ref. Para:
3b - 9 (3), 3b - 10 (1) l A105 Based on visual inspection results, Due Date 12/15/80 Reso: J. L. Hawks the Consultants Panel is to indicate G. R. Murphy potential areas on the selected STP Status: Complete - See ST-8R-HL-36470 placement in wnich destructive tests NRC Status: Closed oer 31-03 snould be perfomed to verify the sonic test results. Ref. Para: 3b - 11 (1) A106 The cognizant design engineer is to Que Gate N/A Reso: J. L. Hawks review and aporove the location of G. R. Murchy core holes with regard to ootential of STP Status: Reinforcing steel cut to date cutting reinforcing steel and has been accroved by design subsequent consequencies thereof. engineering. Included in TRO Ref. Para: 3b - 11 (1) 2A700GP003. NRC Status: Closed oer 81-03 i L
SF OW CAUSE CO VIMIT V EN-S EDITION 05-08-81 Page A-21 TBA COMMITMENT REF. P ARA. DUE DATE RESPONSIBILITY STATUS NO. ~ A107 The Consultants Panel is to also Oue Date 12/15/80 Reso: 'J. L. Hawks visually examine every core obtained G. R. Murphy to evaluate the quality of STP Status: Comolete.- See ST-HL-AE-513 consolid.ition and uniformity of the ST-8R-HL-36470 concrete. NRC Status: Closed per 81-03 Ref. Para: 3b - 11 (1) A108 The Consultants Panel is to direct the-Que Date 12/15/80 Reso: J. L. Hawks drilling of probe holes and using G. R. Murchy fiberootics visually examine the holes STP Status: Comolete - See ST-BR-HL-36470 to evaluate the quality of NRC Status: Closed per 81-03 consolidation. Ref. Para: 3b - 11 (1) A109 Selected cores, in addition to visual Due Date 12/15/80 Resp: J. L. Hawks examination, are to be examined using G. R. Murphy petrographics and microscooial STP Status: Comolete - See ST-8R-HL-36470 tecnniques. NRC Status: Closed per 81-03 Ref. Para: 3b - 11 (1) A110 The Consultants Panel is to address Due Date 12/15/80 Reso: J. L. Hawks previous unresolved concerns and G. R. Murphy allegations by visually inspect'ing STP Status: 'Comolete - See ST-8R-HL-36470 such areas and recommending scecific NRC Status: ?losed per 31-03 test where such methods would resolve i specific concerns or al1agations. i Ref. Para: 3b - 11 (1) i Alli The sonic correlations and reference Due Date 12/'.5/80 Reso: J. L. Hawks standard are being develooed on the G. R. Murony samole area utilizing cores or bore STP Status: Cbnolete - See ST-8R-HL-36470 noles where possible. NRC Status: C?osed per 81-03 Ref. Para: 3b - 12 (1) i All2 To orovide assurance that on-going Due Date N/A Reso: J. L. Hawks safety related concrete wort is G. R. Murchy meeting all requirements, HL&P/S&R STP Status: Ccholete have comoleted a review of all New Procedures issued concreted inspection oracedures and NRC Status: Closed oer 80-38 applicaole training oracedures indeoendent of soecial task force. Ref. Para: 3b - 15 (1)
SHOW CAUSE COVIVF MEN-S ~ EDITION 05-08-81 Page A-22 t" WO. C.OMMITMENT REF. PARA. DUE DATE RESPONSIBILITY STATUS
- 113 Q.C. inspectors have been added to Que Date N/A Reso:
W. J. Friedrich assure that proper preplacemer/- STP Status: Cocolete. inspections are being conducted. NRC Status: Closed oer 80-38 Ref. Para: 3b - 15 (3) All4 Revised procedures are now in place Oue Date 7/21/80 Reso: K. Cook and retraining is being performed STP Status: Procedures imolemented and where necessary. training acconolished 7/21/80. Ref. Para: 3b - 15 (2) NRC Status: Closed oer 80-38 All5 Consolidation refresher training is Due Date N/A Reso: R. H. Leasburg now required every 90 days for STP Status: Complete. consolidation olicement craft NRC Status: Closed per 80-38 persor" ci. Ref. Para: 3b - 16 (1) All6 Stop work authority of Q.C. inspectors Due Date 8/25/80 Reso: W. J. Friedrich is being emphasized in training of STP Status: Ccmolete; ST-QAP-15.2 issued project personnel. 8/15/80. Ref. Para: 5 - 5 (3) NRC Status: Closed oer 80-27 All7 Quality Engineering (QE) will Oue Date N/A Reso: W. J. Friedrich participate in construction planning STP Status: Insoection coints delineated and will determine insoection hold in CCP-25. points for work activities. NRC Status: Closed per 80-27 Ref. Para: 6 - 2 (3) A118 Q.E. will determine inspection Due Date N/A Reso: U. J. Friedrich cnaracteristics required and record STP Status: See All7 above. them on Inspection Reports, (IR) to be NRC Status: Closed per 80-27 used by QC Inspectors. Ref. Para: 6 - 2 (3) A119 QC inspectors will record results of Due Date N/A Reso: W. J. Friedrich all planned insoections on I.R. The STP Status: See A117 anove. I.R. will be a permanent QA record. NRC Status: Closed oer 80-27 Ref. Para: 6 - 3 (2) A120 NCR's will be acknowledged by the Oue Date 9/15/30 Reso: W. J. Friecrien signature of the construction foreman STP Status: Comolate - STP-QAP-15.1 or general foreman. NRC Status: Closed oer 80-27 Ref. Para: 6 - 4 (2), 6 - 5 (1) I
..' 1 ' SHOW CAUSE COM VilT VIE NTS EDITION 05-08-81 Page A-23 COMMITMENT REF. PARA. DUE DATE RESPONSIBILITY STATUS ~ Al2A Formal procedures (trending) will Oue Date 9/15/80 Reso: W. J. Friedrich require the collection of data from STP Status: Complete - STP-QAP-15.4 Rev. 1 all QA records recording nonconforming NRC Status: Closed oer 80-27 conditions. Ref. Para: 6 - 9 (2) A122 A new uniform coding system is being Due Date 9/15/80 Reso: W. J. Friedrich developed under wnicn all those STP Status: Complete - STP-QAP-15.4 charged with collecting data for NRC Status: Closed per 80-27 trending will be trained in the use of the system to assure uniform application. Ref. Para: 6 - 9 (3) A123 At a minimum, standard codes will be Oue Date 9/15/80 Reso: W. J. Friedrich developed for the following STP Status: Comolete - STP-QAP-15.4 categories: building or area; NRC Status: Closed per 80-27 activity; failure type; and time i r.terva l. Ref. Para: 6 - 9 (3), 6 - 10 (1) A124 Procedures will define the list of Due Date 9/15/80 Reso: W. J. Friedrich documents that will be trended. STP Status: Comolete - ST-QAP-15.4 Rev. 1 Ref. Para: 6 - 10 (2) NRC Status: Closed per 80-27 A125 Responsibility will be assigned to Que Date 9/15/80 Resp: W. J. Friedrich specific S&R organization for review STP Status: Ccaplete - STP-QAP-15.4 Rev. 1 of eacn tape of document, collection NRC Status: Closed oer 80-27 of data, and submission to Discrecancy Analysis Groua (OAG). Ref. Para: 6 - 10 (2) A126 OAG will report the results of its Due Date 9/15/80 Reso: W. J. Friedrich analysis to Q.E. STP Status: Comolate Ref. Para: 6 - 10 (2) NRC Status: Closed cer 81-01 'Al27 QE will review suspect areas to Que Date 9/15/80 Reso: '4. J. Friedrich determine if tne incidents make uo a STP Status: Comolete - ST-QAP-15.4 Rev. 1. common cause. If common cause is NRC Status: Closed cer 31-01 identified QE will issue a CAR. Ref. Para: 6 - 10 (2) A
3 SHOW CAUSE COV VF VEN S EDITION 05-08-81 Page A-24 COMMITMENT REF. PARA. DUE DATE RESPONSIBILITY STATUS A128 Trend analysis performed by DAG will Oue Date 9/15/80 Reso: W. J. Friedrich ~ be made availaole to HL&P QA. STP Status: Complete - on-going Ref. Para: 6 - 10 (3) NRC Status: Closed per 80-27 A129 HL&P QA will utilize the B&R data and Due Date 11/1/80 Reso: R. A. Frazar other data collected by HL&P STP Status: Comolete - ongoing surveillance and audits to perform an NRC Status: Closed per 80-27 independent trend review and report results to uocer management. Ref. Data: 6 - 10 (3) A130 All design changes crocosed at the STP Oue Date 10/1/80 Reso: R. W. Peverley, Site will be submitted to Project Site STP Status: Comolete - GCP-21 effective Engineering. 10/1/80 Ref. Para: 7 - 2 (2) NRC Status: Closed per 81-05 4131 Qualification and training records Due Date 10/31/80 Reso: R. W. Deverley will be maintained on Project Site STP Status: Ongoing - Records will be Engineers and Q.E.'s transferred to jobsite by Ref. Para: 7 - 2 (2) 12-15-80 NRC Status: Oceq/ Ready for NRC Review A132. Copies of DCN's will be issued to Que Date 10/1/30 Reso: R. W. Peverley 3oard Members prior to eacn meeting. STP Status: Complete i l Ref. Para: 7 - 5 (1) NRC Status: Closed per 81-05 A133 Soard Chairman will sign DCN Que Date 10/1/80 Reso: J. L. Hawks signifying aooroval. STP Status: Complete - Ref. STP-0C-029 Ref. Para: 7 - 5 (1) ef'ective 10/01/80 NRC Status: Closed per 31-05 l A134 The currently use FREA will be Oue Date 10/1/80 Reso: R. W. Peverley eliminated. STP Status: Comolete - Ref. STP-0C-023 and Ref. Para: 7 - 5 (2) GCP-21 NRC Status: Closed per 30-36 i l
^ SHOW CAUSE COVVFVET S ~ ~ ~ ~ EDITION 05-08-81 Page A-25 3 COMMITMENT REF. PAR A. DUE DATE RESPONSIBILITY STATUS ~
- 135 Each day a description of eacn DCN Oue Date 10/1/80 Reso:
R. W. Peverley processed that day will be entered STP Status: Comolete - Ref. STP-0C-028 into a computer by engineering NRC Status: Closed per 81-05 personnel at the Site and in the Houston office. Ref. Para: 7 - 7 )2) A136 Each working day, a computer printout Oue Date 10/1/80 Reso: R. W. Peverley will be provided to users of the design STP Status: Complete - Example GM-75178 documents. NRC Status: Open/ Ready for NRC Review Ref. Para: 7 - 7 (2) [ Note that by letter dated 5/1/81 ST-HL-AE-658 " morning" was revised to
- workingday"]
A137 When construction of an item has been Due Date 10/1/80 Reso: R. W. Peverley completed verification checklist will STP Status: Complete be prepared and their correctness will NRC Status: Goen/ Ready for NRC review De verified by Design and Quality Engineer. This checklist will be used by the inspector for final acceptance. Ref. Para: 7 - 7 (3), 7 - 8 (1) A138 Ouring first few weeks of new program Due Date 10/1/80 Reso: R. W. Peverley no FREA's will be issued. STP Status: Comolete - Ref. STP-0C-023 and Ref. Para: 7 - 3 (5) GCP-21 NRC Status: Closed per 80-36 A139 Evaluation of a program to be Oue Date 10/31/80 Reso: R. W. Peverley performed to determine if minor STP Status: Comolete changes are required. NRC Status: Open/ Ready for NRC review Ref. Para: 7 - 8 (6), 7 - 9 (1) A140 Any FREA not aporoved by October 1, Que Date 10/31/30 Reso: R. W. Peverley 1980 will be nandled as FCR and STP Status: Complete procesed accordingly. NRC Status: Ooen/ Ready for NRC review Ref. Para: 7 - 9 (1) A141 A system will be created by Quality Cue Date 11/1/80 Reso: W. J. Friedric'h Engineers such that, orior to STP Status: Comolete - Ref. ST-QAP-10.1 o** commencement of work, the records op. 4.1, 4.4, 4.5, 2.5.1, and required to substantiate the 4.5.2 and GCP-1 Sec. 10 indivicual activities will be NRC Status: Ocen identi fi ed. Scheduled to be ready for def. Para: 8 - 2 (6) NRC review on 5/29/31 E
SHOW CAUSE COVVITMEN S 'J'- EDITION 05-08-81 Page A-25 COMMITMENT REF. P ARA. DUE DATE RESPONSIBILITY STATUS N '142 Persons charged with creating required Due Date 11/1/80 Reso: W. J. Friedrich documents will record the status of STP Status: Complete - Ref. ST-QAP-17.1-2 those documents as the documents are Sec. 3.1.4 and 3.1.5 created. NRC Status: Open Ref. Para: 8 - 2 (6), 8 - 3 (1) Scheduled to be ready for NRC review on 5/29/81 A143 When completed document packages on Due Date 11/1/80 Reso: W. J. Friedrich individual activities are completed in STP Status: Complete - Ref. ST-QAP-10.1 the QA Vault, Quality Engineering will op. 4.5 review them to verify the documents NRC Status: Coen are complete and adequate. Ref. Para: 8 - 3 (1) Scheduled to be ready for NRC review on 5/29/81 A144 New microfilm equipment is being Due Date 10/1/80 Reso: W. J. Friedrich acquired to speed uo filming. STP Status: Complete Ref. Para: 8 - 3 (2) NRC Status: Closed per 81-05 A145 A on-site film processing laboratory Due Date 10/1/80 Reso: W. J. Friedrich devoted to QA needs is being STP Status: Ccmolete - 31dg. in place and l establishec. 3 pecole trained Ref. Para: 8 - 3 (2) NRC Status: Closed per 81-05 A146 A new filing system is being Due Date 10/1/80 Reso: W. J. Friedrien imolemented to eliminate the varicus STP Status: Complete - eliminated Pre and l suspense files. Post microfilm suspense files Ref. Para: 8 - 3 (4) NRC Status: Closed per 80-36 l A147 There will be a single filing system Due Date 11/1/80 Reso: W. J. Friedrich and the documents,111 be filed with a STP Status: Complete Ref..NAI-77-149 record traveler prepared by Quality NRC Status: Open Engineers. Scheduled to be ready for Ref. Para: 8 - 4 (1) NRC review on 5/29/81 A148 The record traveler will identify the Oue Date 11/1/80. Reso: W. J. Friedrich records required to substantiate each STP Status: Comolete - Ref. ST-QAP-17.1 activity, will record the status of and ST-QAP-10.1 the file, records borrowed from the NRC Status: Goen file and will be used to identify Scheduled to be ready for overdue and missing records. NRC review on 5/29/81 Ref. Para: 3 4 (2)
i' SHOW CAUSE COlVMF MEV S ~ EDITION 05-08-81 Page A-27 COMMITMENT REF. P ARA. DUE DATE RESPONS1811.lTY STATUS N l
- 1.49 Records already in the vault will be Oue Date08/01/81 Resp:
W. J. Friedrich reviewed for adequacy and STP Status: On Schedule completeness, based on the results of NRC Status: Open the review of records requirements. Ref. Para: 8-4(2) A150 The B&R Audit Group and Project QA Oue Date N/A Resp; R. L. Ulrey Management will regularly receive the R. W. Bass reports of the trend Analysis Group. STP Status: HL&P Ref. Para: 9 - 2 (4) HL&P is reviewing the HL&P trend on a monthly basis. STP Status: B&R Quarterly. NRC Status: Closed per 81-04 A151 The Hl.&P Audit Group and Project Due Date N/A Resp: R. L. Ulrey Management QA will revieve both HL&P STP Status: The first trend analyses and B&R trend analyses. issued by HL&P was sent to Ref. Para: 9 - 3 (1) management as cart of the August 1980 monthly report. Additional reports will be sent on a quarterly basis. NRC Status: Closed per 81-04, 01 A152 The function of the HL&P Corporate Oue Date N/A Reso: R. L. Ulrey Audit Group has been redefined to STP Status: nL&P Procedures QAP-5, SA, 58, minimize conflicting assignments and and 5C have been revised and responsibilities of auditors. Thereby are now in effect. The HL&P creating a group who's primary organization change which function is to preoare for and conduct assigns a sucervisor to the audits of safety-related activities, audits group reportinq to the Ref. Para: 9 - 3 (3) HL&P QA manager went into effect June 16, 1980. NRC Status: Closed per 80-27
~ SF OW CAUSE CO VIVil V ENTS EDITION 05-08-81 Page A-28 'EM COMMITMENT REF. PARA. DUE DATE RESPONSIBILITY STATUS NO. ~ 4153 Auditors are continually receiving Due Date N/A Reso: R. L. Ulrey additional training in the areas of R. W. Bass codes, standards, procedures and other STP Status: HL&P documents related to QA programs and T G F QA has held training ~ auditing. classes over the cast two Ref. Para: 9 - 3 (3) months to assure auditors receive training in Auditing Procedure revisions, QA Document Review functions and stop work authority. Additional training sessions will be conducted as procedures are issued / revised. In addition several personnel have attended AWS trending and received AWS Insoector certi fication. STP Status: S&R 3 carted and on-going. NRC Status: Ooen/ Ready for NRC review GS4 HL&P has developed an annual audit Oue Date N/A Reso: R. L. Ulrey plan, wnich will be reviewea every 6 STP Status: ine annual audit plan is on months and revised accordingly. file at HL&P EDC office, the Ref. Para: 9 - 4 (3) plan is dated 6/4/80. NRC Status: Closed per 80-27 A155 In addition to the annual schedule a Que Date N/A Reso: R. L. Ulrey l more detailed audit schedule is issued R. W. Bass quarterly. STP Status: HL3P l Ref. Para: 9 - 4 (3) E quarterly audit schedule l has been issued to include-the months from June-Dec. 1980. This schedule has been revised. several times to assure it is kept current. The last l revision was Rev. 4 STP Status: B&R 5 tarted and on-going. NRC Status: Closed per 80-27 l
~ SHOW CAUSE COM VirVIEN-S EDITION 05-08-81 gp ~ Page A-29 COMMITMENT REF. P ARA. DUE DATE RESPONSIBILITY STATUS. A156 The quarterly schedule provides for Due Date N/A Resp: R. L. Ulrey supplemental audits. R. W. Bass Ref. Para: 9 - 4 (3) STP Status: HL&P Rev. 4 of audit schedule reflects supplemental audits.- STP Status: B&R 7 TS-80. NRC Status: Closed per 80-27 A157 A matrix has been prepared delineating Oue Date N/A Resp: R. L. Ulrey all B&R procedures applicable to STP R. W. Bass and the corresponding audit to which STP Status: HL&P they aanly. Matrix is on file at QA EDC Ref. Para: 9 - 4 (3) office and will be updated as B&R procedures are added/ deleted. STP Status: T'R Comolete. NRC Status: Closed per 80-27 A158 This matrix is utilized by HL&P and Oue Date N/A Reso: R. L. Ulrey B&R audit groups to assure all Quality R. W. Bass activities are audited within the STP Status: HL&P required frequency. Matrix was used during HL&P Ref. Para: 9 - 4 (3) Audit BR-30 and will be used for HL&P Audit BR-34 STP Status: B&R On-going. NRC Status: Closed per 80-27 A159 At least one audit team member must be Oue Date N/A Reso: R. L. Ulrey experienced or trained in the R. W. Sass discipline being audited. STP Status: HL&P Ref. Para: 9 4 (4) During 3R'30, a tecnnical '~ advisor was used as a team member. Audits SWF-6, SRI-1, HL-84, WNSD-1, E7C, audit team members were experienced in the discipline audited. SIP Status: B&R Incorocrated into audit crocedure. NRC Status: Closed oer 81-04 I i
SHOW CAUSE COMVITMEN S EDITION 05-08-81 ~ Page A-30 COMMITMENT REF. P ARA. DUE DATE RESPONSIBILITY STATUS '160 A revised audit schedule and an update Due Date N/A Resp: R. L. Ulrey of audits conducted in the previous R. W. Bass quarter, including an evaluation of STP Status: HL&P the audits performed are issued each Gi'" July 31, 1980, status was issued to the Houston QA quarter. Ref. Para: 9 - 5 (1) Manager. STP Status: R&R Gn'~ going since January 1980. NRC Status: Closed per 80-27 A161 Follow-up audits will be conducted to Oue Date N/A Reso: R. L. Ulrey verify successful correction of R. W. Bass problems and their causes. STP Status: HL&P Ref. Para: 9 - 5 (3) TolTow-up audits are and will continue to be conducted. Ref. WPD-5, GE-16, PWRSD-5, HL-87, BR-31, HL-84, BR-35, HL-90, HL-91, HL-86, HL-92, HL-95, BR-37. STP Status: B&R Gi~ going. NRC Status: Ooen Scheduled to be ready for NRC review on 6/1/81 A162 The HL&P Corporate Audit Group has Due Date N/A Reso: R. L. Ulrey been conducting audits of B&R STP Status: HL&P construction activities since March, Audits BR-30 and 3R-34 are B&R
- 1980, construction audits completed Ref. Para:
9 - 5 (4) or in process. Additional audits are scheduled and due to the stop work in the welding area BR-33 will be conducted at a later date. . NRC Status: Closed per 81-07 A163 The matrix of S&R STP Procedures has Oue Date N/A Reso: R. L. Ulrey been prepared and both HL&P and 3&R R. W. Sass nave new schedules of future audits, STP Status: HL&P l including time and personnel Ifie~sucolemental audits are provisions for the performance of listed on the schedule within i sucolemental audits. the time frame by month, l Ref. Para: 9 - 6 (1) soecific dates or activities are not listed until the sucolemental audit is requested in accordance with HL&P crocedure. i STP Status: B&R ccmolete 9/15/80. _ NRC % @ g: Closed oer 80-27
i 1 j i 4i $i TESTIMONY OF RICHARD A. FRAZAR Aj REGARDING CHANGES MADE TO ADMINISTRATIVE CONTROLS IN RESPONSE TO THE ORDER TO SHOW CAUSE 9! Q. 1 Please state your name and Current occupation. 11 A. 1 Richard A. Frazar. I am the Manager, South Texas 12 13 Project Quality Assurance of the Houston Lighting & Power 14 12 Company (HL&P). 16 ' 17 Q. 2 Describe your professional qualifications, educational tgi {g l background, and involvement in the South Texas Project };O (STP). 22 A. 2 These are set forth in my testimony on the current 23 t 24 ' Quality Assurance (QA) program for STP. 20 Q. 3 What is the purpose of your testimony? -.l 25 A. 3 The principal purpose of my testimony is to 29 30 j describe the changes made in the STP administrative controls 3~T in response to items 5, 6, 8 and 9 of the NRC's Order to 3 3 *, -I Show Cause of April 30, 1980, (Order) and to explain how 34 ! 35 i these administrative controls satisfy the requirements of 36 j 37 ' Appendix B to 10 CFR Part 50. Preliminarily, however, I 38, 39 : will describe a number of improvements to the STP QA pr~ogram 40 t 41 that we initiated even prior to the issuance of the Order as 42 : 43 i a follow-up to meetings with the NRC in December 1979 and 44 l January 1980. d7 i 49 ! ( 50[ 51 ; l
t, i 4^ 5;' Q. 4 Please describe the improvements to the STP QA 6;i program that were undertaken in December 1979 and January 'I 1980. 9, 10 l A. 4 As described in Mr. Oprea's testimony, after a 11, 12 l meeting with Mr. Seyfrit, Director of NRC's Region IV Office L3 L4 of Inspection and Enforcement (IE) on December 28, 1979, L5, 16 EL&P committed to a nine-point plan for specific improvements L7 i Lgi; to the STP QA Program. These can be summarized in the i g: ' 20 f 11 wing nine elements: 2' t First, it was committed that B&R would hold a seminar 22, 13 to review with both Construction and QC personnel the funda-24 : 2C i mental philosophies and standards of STP QA program. The seminar was to emphasize the respective roles of Construction 23:i 29-l and QC in assuring quality construction and a safe facility. 30 l 31 The second element of our program was to change proce-32 l dures to clarify when to use a Field Request for Engineering 33 34 Action (FREA) as opposed to using a Nonconformance Report 35 ! 36 l (NCR). One source of frustration on the part of the QC 37 l 33 ! Inspectors was cons.truction's use of the field design change 39, 60 system in instances where it might not be fully appropriate. 61 62 j It appeared to the Inspectors that in some instances, Construc-63 t gj tion personnel would avoid correcting nonconforming conditions i by obtaining Engineering's approval of the deviation in the i7 ' form of field design changes (FREA's). Although both systems bF l 6 resulted in review by Engineering and an appropriate disposition, 10 ; 51 ! om
s '. L ~ c 41 5 when the FREA system was used the conditions were not iden-l 8 i tified as nonconformances. This limited the ability of the 9l QA system to detect underlying problems. We changed the 10 11, FREA and NCR procedures to make clear when each was appropriate. 12 13 i Third, B&R issued a written policy describing the 14 process for resolving any disagreements between Construction L!i 16 and QC personnel. The policy specifically stated that 17 i ig l threats or intimidation would not be tolerated. 19 t 20 ; Fourth, because NRC questioned the qualifications of 2}1 j some B&R QA and QC personnel, we undertook a management 23 ' assessment of the overall qualifications of the B&R QA and 24 - 7" QC personnel to provide the basis for upgrading the caliber
- 23 l of personnel.
' 29 l Fifth, HL&P directed B&R QA and Construction management 30 t
- 31,
to implement strict procedures for concrete preplanning and 32 '
- 33,
placement activities. EL&P QA and Construction personnel '34 would participate in the preplanning and placement process 35 i !36l! to make sure the werk was done in a thorough fashion. i37 ! 38 ' Sixth, procedu,res were revised to provide a controlled i39 l l40l method for judging when reinspection of a concrete placement l 41 ! 42 j is necessary prior to sign-off of the pour card. 1 43 ; 34 l Seventh, three key HL&P QA personnel, including the i Projects QA Manager, were assigned to the site to strengthen 47 ; HL&P's role in the short term, to be directly and visibly )s involved in the work in the field and to facilitate the 50 i 151 j i l -7@o
i L; ~ 4' 5, continuing investigation by the NRC Staff. BL&P further ,e, l added to its staff at the site during 1980 to underscore its 1
- i active role in assuring that procedures were adequate and 9i 80 :
that implementation was thorough. Distinctive identifi-11 - '12 ' cation would be provided for wrap personnel to increase '13 14 their visibility on the jobsite. 12 16 Eighth, a refresher training course would be imple-17' {g ; mented for B&R Construction and QC personnel to reinforce va their undarstanding of their assigned duties and the proce-20 t 21 dures governing their work. j 22 23 I Ninth, a study was conducted in which there were inter-14 7" I views of B&R personnel, starting with top level management t and proceeding throughout the B&R organization, to determine 23 ; 29 l the cause of the perception of harassment or undue pressure 30 ' on QC personnel. 3 32 I As also pointed out in Mr. Oprea's testimony, after the 33 ; 34 ! exit interview with I&E on January 24, 1980, the additional 30 i 37 ! following improvements were undertaken: 26 ; 23 i We instituted a program to upgrade the system for g '40 i analyzing trends in nonconformances. A new system for 41 i 42 l coding NCRs and FREAs would be adopted and all past and 43 ! future FREAs and NCRs would be coded to permit analysis. l There would be quarterly Trending Reports and identified s. i 47 ! trends would be investigated to determine if there were Aa l A i 90 { 51 j I i
L: I 45l common causes. When common causes were identified, appro-e4 priate corrective action would be taken. j! The assessment of qualifications of QA/QC personnel was l 10 continued. only one QC Inspector was found to have question-11 ( 12. able credentials. 13 14 Meetings were held by B&R to reemphasize to QC Inspectors IS 16 that they must take as much time as needed to perform thorough 17 ' ig ; inspections; EL&P QA and Construction personnel were directed 7eif to ensure by their involvement in concrete preplacement and 1f placement activities that adequate time is allowed.for 23 inspection prior to and during the placement of concrete. 24 '~ In addition, a memorandum was issued to QA/QC personnel .,l directing that all nonconforming conditions were to be 28 i 29 ; documented as soon as they were identified. 30 I 31 j HL&P surveillance personnel were directed to document 32 all nonconforming conditions, even those documented by 33 34 ! others. 35 1 36 l EL&P Audit schedules were revised to make sure that there 37 ! 38 ! was an annual corporate audit of B&R construction, and HL&P 39 40 l audit procedures were revised to state that procedure imple- ' 41 ! 42 mentation is to be verified by direct observation of work 43 i 34 l being performed in the field as well as by reviews of docu-i j mentary evidence. We also decided to have our QA program d ! l l 47 l audited by an outside consultant at least once a year. 1 J" s1 t -e1-
L' 7 4l 5l B&R competely revised the Welder Training Program and $\\ \\ added a General Superintendent to coordinate the work of the -i 9! welders on the project, to monitor their capabilities and La l L1 ' progress, to initiate retraining where needed, and to work L2 l 3 closely with the welding engineers and welder training 14 4 {3 department. In addition, a new B&R Chief Welding Engineer n6l assumed responsibility for working closely with Construction, o ie I! $'9l welder training, B&R corporate welding engineering, and 0i QA/QC groups to institute programs to further improve welding ,1h! performance. 23 i 24 l Radiography on the site was temporarily limited to work ,a i under the direct supe.rvision of Level III QA Engineers. All D site NDE personnel were retrained and recertified. A new r3. 'S I procedure was implemented for the control of film processing to i cl ! and another new procedure prohibited the shooter of radio-t2 i (3 j graphic film from also doing the film interpretation. In c4I c5 l addition, B&R personnel performing liquid penetrant examina-c6li tions were retrained. <7 A review of all radiographs on the Project was undertaken. 00 Both EL&P and B&R surveillance teams were to conduct special bl ?2 reviews and surveillance of the NDE program. 33 ! 34 Backfill procedures were changed to specify depths for g, conducting in-place density tests and a test program was 37 gp initiated on site to determine whether proper density had been obtained thus far on the Project. The results of that -0 -1 ) i i e
L i -i 41 5: program are described in the testimony of Mr. Pettersson and
- i Mr. Hedges.
9, The foregoing improvements have been completed and the f0 l NRC has verified their implementation in its inspection 12 ! reports. Some of the improvements related to administrative 13 14 controls and were carried over into items of the Show Cause 15 16 ' order that I will discuss below. 17 Ig l Q. 5 The first Item of the Show cause order which 19 20 . relates to administrative controls is Item 5, which required 2' 2} l that HL&P define more clearly the stop work authority, 3 temporary or otherwise, including implementation of the stop 7' i work authority. Please explain the meaning of the term ..j "stop work authority." 28 i 29 l A. 5 This term refers to the authority of certain 30 1 31, Project personnel to require that construction work be 32 l 33 stopped. The construction work affected by a stop work 34 order can be of broad scope, such as stopping all construc-35 36 ! 37 l tion on the Project or all welding; or it can be narrow, 38 i such as stopping a,particular craftsman from working or 39 i ~~ 4.0 i prohibiting use of a particular piece of equipment. On STP, 41 l 42 as on most other projects, the term "stop work order" is 43 l 1 4a only used for the broad scope work stoppages. The narrow scope work stops are called " holds." 47 l 48 4 50 > 51 j \\ 1 li -i 4: 5' Q. 6 what conditions led NRC to order a clarification e of the stop work authority? DI 9l A. 6 The Order does not state explicitly.
- However, La '
gL, the NRC'c April 28, 1980, Investigation Report 79-19 (NRC Cl ' ~ g3 Investigation Report) on which the Order is based, states b4 that the B&R QC Inspectors expressed uncertainty regarding L3 L6 their authority to stop work and also that a Construction L7 i l$l Foreman and QC Inspector expressed conflicting views regard-IS i 20 ing the stop work authority of QC Inspectors. 11l! g2 Q. 7 Are you familiar with the HL&P-B&R Task Force 4 described in Mr. Briskin's testimony that was established to .e prepare responses to the Order? I A. 7 Yes. I was in charge of the Task Force until 'S : 'S ! HL&P responded to the Notice of Violation on May 23, 1980. -0i -1 l Thereafter Mr. Briskin was given responsibility for the Task 2l 3 Force's preparation of the response to the Show Cause Order. 4! 5j I was put in charge of drafting the response to Item 1, and -6 several members of my staff participated in the other sub-7 'I-9l groups of the Task Force. I participated in meetings with i 0l those subgroups and have reviewed working papers of the Task 2 Force subgroups that described findings and proposed changes 31 t to procedures. Upon completion by the Task Force of proposed procedure changes, I participated in the decisions on those 7 changes. e i go ! )-1} l m
L 4 5 Q. 8 What were the findings of the Task Force concerning a stop work authority? A. 8 The Task Force found that HL&P h d procedures in 9; 10 effect which designated certain EL&P QA personnel as having 11, 12 stop work authority, and that B&R had comparable procedures. 13 14 However, it also found that neither the site procedures of se {6 HL&P nor those of B&R clearly addressed the stop work author-17 {g ity of personnel below the Supervisors level. 13 Q. 9 What was EL&P's response to Item 5 of the Order? 20 21 > A. 9 HL&P stated that both FrAP and B&R had defined 22 : 23 the stop work authority more clearly. It went on to identify 24 ' .P-the positions in each organization which have stop work l authority, and explained how they can exercise such authority. 28 t 29 Q. 10 What positions in the HL&P organization have 'O 31 j stop work authority? 32 i A. 10 The HL&P QA Staff organization is described in 33 34 ! the answer to Question 7 of my previous testimony concerning 35 i -37 ! the current QA program for STP. 36, 33 ! The, HL&P procedures distinguish between two types of 39 ' .40 stop work authority: a temporary oral order, called an 4}'i Emergency Stop Work Order, and a written order of indefinite 4 43 i duration called simply a Stop Work Order. The HL&P site d4 ; j QA/QC supervisory positions and the STP QA Manager have .o I 47 ! authority to issue a written Stop work order. All other sq HL&P QA/QC personnel have authority to issue Emergency Stop 50 51 L.i -i 4 5; W rk orders, which remain in effect until an EL&P QA or QC et Supervisor issues either a written Stop Work Order or a D ! written rescission of the Emergency Stop Work Order. The 9: LO ! affected organization is then prohibited from resuming the L1 ' L2, work activity until receipt of a written release from HL&P L3 : L4 QA. ,s> {} Q. 11 What positions in the B&R organization have stop L7 l work authority? .s, 19 i A. 11 The B&R QA organization is described in the 20 4 21. answer to Question 8 of my previous testimony concerning the 22 i 23 - current QA program for STP. 24 : B&R procedures also provide two types of stop work 6-l authority: the authority to issue a hold tag, which places j" ', a hold or work stoppage on some construction activity of narrow scope; and a stop Work Order, which is used to stop a 32 ' broader range of construction activities. 33 ; 34 ; QC Inspectors apply hold tags at the time they identify c3 l c7 I on a Nonconformance Report (NCR) a condition that does not c6 l a3 i conform to design requirements. A hold tag is a standard mai gf form that is physically attached to the nonconforming material hk i or work. The hold tag prohibits continuation or commencement 3l of the designated activity until there is a disposition of 4 I the NCR as a result of the procedures described below. When 7i the nonconforming condition is corrected or resolved in some other way the hold tag is removed by a QC inspector. Thus -Q 1. l
L i 4 5i all QA/QC personnel have the authority to stop work immedi-el ately through identification of a nonconformance on an NCR
- I and issuance of a hold tag.
9l 10 l The on-site authority to issue a Stop Work order is 11 ! 12 limited to the B&R Project QA Manager. These are written 13 14 orders to organizations involved in design or construction LS ' 16 activities, which must be acknowledged in writing by the 17, gg i affected organization. Se< In situations where B&R QA/QC personnel believe that a 21 Stop Work order should be considered, they submit a written 22 23 ' notice of deficiencies to the B&R Project QA Manager. If 24 ' 70 the Project QA Manager decides a Stop Work order is required, l he orally notifies the Supervisor of the organization perform-28, 29 ing the work and the HL&P STP QA Manager and transmits a 30 - 3g. written Stop Work order to the organization performing the 32 - work. The Stop Work order must be signed, dated and returned 33 ; 34 ! to the B&R Project QA Manager by the organization performing 35, 36 l the work, thereby acknowledging receipt and verifying that 37 38 ' the work has been stopped. If the Project QA Manager deter-39 ' ~ 40 mines that a Stop Work order is not required, he so notifies 41 l the QA/QC personnel who reported the condition and the 02 43 ' cognizant Construction Supervisor together with his reasons i 32 for so acting. 47 ' Q. 12 What role does EL&P have in Stop Work orders 40 ! 4 l issued by B&R? 50, 51 ! l l 9 4l 5, A. 12 Authorization to resume all or part of the work Mt affected by a B&R Stop Work Order may be given only by the i 9j B&R Project QA Manager. He will issue such authorization 10 ' 11 ! only after he has determined that all responses, corrective l12 l lg3 i actions, recurrence controls and other requirements have
- 14g, been satisfied, and the HL&P Manager, STP QA, has determined 6
the resolution to be acceptable. Written approval of the 15 - EL&P Manager, STP QA is a prerequisite for issuance of a 19 l 20 l total or partial release to the organization performing the 21 ! i work. 22 23 l 74, Q. 13 Do the procedures of HL&P and B&R that control c} e stop work authority comply with Appendix B to 10 CFR Part I 50, applicable NRC regulatory guides and other applicable r31 '9 ! industry standards? 10 l al i A. 13 Yes. Appendix B Criterion II and Regulatory a2' a3 l Guide 1.28, which endorses ANSI N45.2, address the require-a4i a5 l ments for stop work authority being placed within the QA a6 ,7 organization. The revised HL&P and B&R procedures provide the author-00 I ity for QA/QC personnel to stop work verbally whenever a 31l 32 safety related noncompliance is identified. Provisions for 33 p4 formal stop work documentation follow-up is also provided. These procedures address all activities of fabrication and g. 37 I 'p l construction as well as engineering, design, hardware and QA g S l -0i -1 l t i i n
1 t 4i 5i program deficiencies and identify the internal organizational M activities as well as EL&P/B&R interface responsibilities 9 for imposing and releasing the Stop Work Order. 10 l 11 j Q. 14 Have the new stop work procedures been properly 12 ! 33 implemented? t 14 A. 14 The new B&R Stop Work Procedure, ST-QAP-15.2, LS 16, Revision 1, was made effective on January 26, 1981. Training 17 15 : on the procedural requirements was completed prior to that 19 ! 20 i date. The procedure has been fully implemented since. 2123l! Since the issuance of QAP-15.2,.there have been two B&R Stop 23 ! W rk Orders invoked. In one case the discrepancy was resolved 24 ; 2-in one day. The other has undergone two partial releases, I i with the remainder currently being resolved. In both cases 23. 29 ! the Stop Work procedure was properly implemented. 30 ! 31 i HL&P Project QA procedure PSQP-A-7 was issued on July 82 l g3 i 25, 1980 and HL&P QA Department procedure QAP-12-A was 84 ! 85 l issued n September 22, 1980. These procedures more clearly 86 I g7 l delineate which positions have stop work authority. In I&E SI ! Inspection Report 80.-27, the NRC Staff reviewed the proc.edures 89 1 00 l and found that stop work authority is adequately described. 01 1 02 Q. 15 Item 6 in the Order required HL&P to develop and f3 l 04 l implement a more effective system to provide for the identi-fication and correction of the root causes of the nonconfor-37 i mances which occur. Please explain the meaning of the term gg f "n n nf rmance." h0l 1i O
~ 1; 4 i A. 15 A nonconformance is a condition that is not in 5 a accord with Project requirements such as job specifications, procedures for the control of special processes, etc. That w 9! 10 l could include a concrete structure that does not have all of 11 t 12 ' the steel reinforcement required by the design drawings or a R [2 welder not being certified for the type of weld he is doing, 4, LS SS r any other deviation from Project requirements. 1- (( Q. 16 How are nonconformances identified and documented? 13 I A. 16 It is the job of QC Inspectors to verify that 80 81 ! construction work is being done in accordance with the 82, 23 - applicable requirements. When the QC Inspector identifies a 84 i 9- ' condition that does not comply with the requirements there j is a procedure he must follow that is designed to assure g, 88 i gg ' that the nonconforming condition is properly dispositioned (i.e., either corrected or reviewed by Engineering and found 82 I to be acceptable). At the STP the procedure involves the 83 84 initiation of a document called a Nonconformance Report 85 l 86 j (NCR). This is the same NCR I mentioned in connection with @7 e gg ! my discussion of stop work authority. The QC Inspector's 89 ' 'o[ initiation of an NCR is the primary way that nonconformances g Q;, l are identified during construction. O* ; $3 Q. 17 So that it will be clear when the subject comes 04 : up later, please describe the field design change procedure. i.s G7 ! A. 17 The field design change procedure is described be i in detail in Mr. Briskin's testimony. Prior to the Show 90 ' l91 L -M-
L 4' 5: Cause Order the field change procedure involved use of a e document called a Field Request for Engineering Action O 9.! (FREA); now the appropriate form is a Field Change Request i 10 l (FCR). Field design changes are changes to design that are 11 i 12 } requested by personnel at the job site. A typical reason 13 14 for such a change may be that there is an interference 15 16 : between piping and cable trays which could not be antici-pated by the designer, but which was realized as construction _s, 19 ! work was planned in the field. The NCR and the FCR are 20 21 similar in that each reports a condition that appears to 22 23 ' require evaluation by Design Engineers and in either case a 24 1 change in the design may. result. a-Q. 18 Please explain what the systems are that identify and correct the underlying causes of nonconformances. 30 ; A. 18 The ide tification of the underlying causes of 3. 32 ! nonconformances involves the analysis of NCR's to determine 33 34 l what condition on the Project might huve led to the error in 35 i 36 question. For example, a particular type of error may 37 ! 38 ! result from ambiguous construction procedures, from a particu, 3g 40 l lar construction worker's misunderstanding of a procedure, 4{1 or from an inadvertent error by a worker. The Project must i 4 43 have a system to attempt to identify which among these or other possible causes is actually involved. One tool in ,e, 47 l identifying the casues of nonconformances is an analysis of s~t l data regarding incidents of nonconformance. Such analyses y 50 l 51 ! j i j
L 7., 4l 5i are used to detect problems that might indicate the existence 6\\ of a common, underlying cause. This process is referred to j as " trend analysis" or " trending." SO ! Once the underip ng cause of a nonconformance is identi-i 11 : 12 i fled, it may be possible to prevent the same type of condition 13, 34 ' from recurring by correcting the underlying cause. Thus if L3 '6 the cause were an ambiguous procedure, the, procedure could 8 87 gg l be clarified and the personnel using that procedure retrained SS t the revised procedure. Several such instances might 80 01 ' suggest a need for a review of how procedures of a certain 82 33! class are prepared and/or reviewed prior to publication. If 84 : 2D - the cause was misunderstanding on the part of one worker, 3i that man might be retrained or reassigned. A large number ,9 i of such instances could reflect the need for wider re-training 0! 1; or a refresher course for workers. There is, of course, 2 [3 also the possiblity that the nonconformance is an isolated '4 l incident and that it does not demonstrate that any recurrence =5i '6l control is required. 7 ( S Q. 19 What was the reason that NRC ordered HL&P to g O implement a more effective system for identification and t{ correction of the underlying causes of nonconformances? 3l A. 19 Here again, the Order doesn't state explicitly, 4 but the NRC Investigation Report found that there was no 47 effective system for statistically analyzing FREAs that '9 4 kto!! si,.
. ~. ) 1 .F 4: 5' might have been used instead of an NCR to document noncon-e- forming conditions. As discussed further in Mr. Briskin's 'y b testimony, inappropriate use of the field design change f procedures (FREA's) in lieu of an NCR could inadvertently U' mask an underlying reason for a given problem. NRC also 12 ' 14 referred to the results of past trending reports and con-15 16 cluded that there were trends in the data which were not 17 Ig l being picked up in the reports. 19 20 Q. 20 What was the approach of the Task Force in 2Tgl responding to Item 6 of the NRC order? 13 ! A. 20 The Task Force decided to review the process by 24 : '~i which nonconformances are identified, documented and resolved. l It then analyzed how to improve the trending process which 23 l 29 i was the focus of the order. Finally, the Task Force reviewed 30 31 the procedures for ordering that a cause of nonconformances 32 i be corrected. With respect to each of these three phases of 33, 4{ the process, the Task Force - which had representatives of 36 Construction, QA/QC, Site Engineering, and Quality Engineering - 37, 38 ! reviewed the object.ives of the process and proposed n.ew 3g 40 l procedures to better achieve those objectives. It was a 41 i 42 l thorough review of the entire process. 43 i at ! Q. 21 Before the order, what was the procedure used at i the site to identify and document nonconformances? %l A. 21 Under the procedures in effect at the time of the NRC investigation, B&R QC Inspectors planned and performed s 50 i 51, ~41-
l' 4l 5; their inspection and then recorded the inspection results on one of a variety of different forms, depending on the type oi of construction work inspected. When nonconformances were 9l 10 ! found in a final inspection, the QC Inspector recorded that 11 > 12 i fact in a draft NCR, which was submitted to the Lead QC 13 14 ' Inspector. From the Lead QC Inspector, the draft NCR was L3 16 reviewed successively by the QC Supervisor, the QA Engineer 17 and the QA NCR Supervisor. g 13 ' After the QA NCR Supervisor prepared the final typed 20 ! 21 i NCR, it was first sent to Design Engineering for disposition 22, 23 i and then routed successively to a number of other organiza-24 tions for review and approval of the disposition. The NCR, ,j { with the disposition indicated, was then routed back through 2 3 'l several offices for information purposes before Construction 29 30 received the forn and implemented the approved disposition. 31, 33l; 32 Q. 22 What were the Task Force findings about the NCR 34 I system? 35, 36 : A. 22 The Task Force found that the system was unneces-37 i 33 sarily slow and cumbersome and that consequently field q 40 i personnel tried to avoid using it. It noted that the inter-4}'\\j views with QC Inspectors summarized in the NRC Investigation 4 43 l Report showed that their morale was adversely affected by the lack of feedback on how the nonconforming conditions ,o i 47 ! they identified were corrected or why their management en decided not to process certain draft NCR's. 50 51 l l 94
L n 4 5 Q. 23 What is the new procedure for identifying and documenting nonconformances? A. 23 The first change is in the planning of inspec-9' 10 ! tions. The expanded B&R Quality Engineering organization 11 ! 12, (QE) described in Mr. Oprea's testimony participates in 13 3,4 construction planning and determines inspection " hold points" 1: gj for work activities. When Construction reaches such a hold { point it cannot proceed until a QC Inspector performs the 19 required inspection and approves the work to that point. 20 21 l Sometimes " hold points" are not practical, such as in contin-22 23 : uous inspection of concrete placement activities. In these 24 i 7c i cases other inspection guidelines are specified in procedures. i ,, l For each inspection hold point QE determines the inspec- "g'j tion characteristics required, and those inspection character-e 9 30 : istics are recorded on preprinted Inspection Report forms to 31, 32 ' be used by QC Inspectors in their planned inspections. QC 33 3 4 '- Inspectors record the results of all planned inspections and 35 i 36 : reinspections on the Inspection Report. The Inspection Report I .37 l is used to track all items found in planned inspections to 33 39 ' be unsatisfactory, from the time of initial identific'ation ~ 40 to the time the items are satisfactorily resolved. 43 ' When a planned inspection for acceptance of work is 44 i,{ being conducted, all checklist items noted on the Inspection 4 47 ! Report are verified as "S" (satisfactory), "U" (unsatisfac-t .18 I I tory), or "N/A" (not applicable). The QC Inspectors, under 50 ! 51 l 1l ~ r 4j 5i new pr cedures, promptly notify the Construction Foreman or af General Foreman of items recorded as "U" and initiate a NCR. -I The NCR is a' pre-numbered and controlled form that is acknowl-9! 80 f edged by the signature of the Construction Foreman or General 11 1 12 Foreman. Where appropriate, hold tags or other work con-13 14 ' straints are applied by the QC Inspector at the time the NCR L3 ' .1s issued. gg f7 l Q. 24 How is the NCR processed? g 19 I A. 24 When nonconforming items or conditions can be 20 ! 21 l reworked to the original configuration or brought into 22 ' 23
- compliance through a " standard repair procedure", then no 24 I to i design evaluation is required.
In such cases, the, Lead QC ,, j Inspector and the Construction General Foreman agree on the II " standard repair procedure" to be used and record that 30 ! agreement in the disposition section of the NCR. Once the 31 32 disposition is complete and approved, the QC Inspector 33 34 removes the hold tags and work may proceed. The QC Inspector 35 i 36 ! also records on the Inspection Report the fact that the NCR 37{l 38 has been resolved. NCR's falling into this category are 39 i 40 l then forwarded to the cognizant Quality Engineer for review. 4k ! The Quality Engineer must either give written approval or
- 4. I 43 !
reinitiate the NCR. 14 When an item will not or cannot be reworked to the .a l 47 ! "as-designed" configuration, the NCR is submitted to Quality to ! Engineering for review. If it is determined that the NCR is 50 ! i 51 : I l 1: 4 5 not valid (i.e., the QC Inspector misinterpreted the require-Mi ment), the NCR is dispositioned by Quality Engineering, and jl explanatory comments noted in the justification section of 10 the form. If Quality Engineering determines that the NCR 11 11 can be dispositioned by rework or a " standard repair pro-1 13 ' 14 cedure", neither of which requires further design evaluation, 15 16 that disposition is also noted on the form. In either of 17 i gg l these cases the form is returned so that any needed rework or standard repairs can be completed aad the QC Inspector 21 can record on the Inspection Report that the condition is 22 ' 23 ! satisfactory. As discussed below, this helps to assure that 24 70 QC Inspectors are aware of the disposition of their findings. Most nonconforming items are resolved through this 28 i 29 j orderly interaction of QC, Construction and Quality Engineer-30 \\ 3g l ing. The nonconformances that cannot be resolved by these 32 I organizations are the conditions that require design evalua-33 34 tion. A new on-site committee, called the Materials Review 35 1 36 j Board, has been created to coordinate the resolution of .17, 38 ' NCR's requiring design evaluation. The Materials Review 39 l 40 Board consists of a senior representative from QA (Chairman), 4{' Design Engineering, and Construction. An Authorized Nuclear 4 j 43 l 44 j Inspector (ASME) and representatives from Westinghouse, [ Purchasing, and Materials Control are available on call. 47 ! The Materials Review Board members coordinate the 4A l determination of a proposed disposition based on consultation 50 51 i L i 7, 4l 5l with their respective organi=ations. When the members 6i concur on the disposition, each member signs the NCR. (Design Change Notices which may be required in the case of 9 10 : "use-as-is" or " repair" dispositions are discussed further 11 ' 12 in Mr. Briskin's testimony, in connection with Item 7 of the 13 t 14 ' order). When necessary, on-call members are consulted 13 16 ; before approval of a proposed disposition. The signed NCR, 17 : ig ; with disposition noted, is then sent to EL&P QA for review 'S f the disposition to ensure concurrence that QA requirements 20, 21 - have been implemented. Thereafter it is sent to B&R Construc-22 ' 23 i tion for implementation and to B&R QC for inspection. -24 ' 2.9 j Q. 25 In what ways does the new NCR procedure represent f an improvement? 23 i i29 A. 25 It appeared that in the past, there were times i '30 3y, when an NCR was processed and the condition corrected, but 32 the QC Inspector who had written the NCR never found out. i34 i about the corrective action. Because they had not heard (35 ' 36, otherwise, some of the B&R QC inspectors believed that the 37 ; 38 nonconformances.they had identified were not corrected. Also l39, l40 ; the NRC Investigation Report said that because NCRs were 1 4{ l occasionally revised or discarded by QC management in the course 41 43 ' of review, some QC Inspectors felt that they were not supported 44li l l by their management. Now NCR's are prepared by the QC 47 I Inspectors without review and the new procedure does not
- 48 I h
l permit discarding invalid NCR's. Su '51 l 1 I I,
L 2, 4l 5; The Inspection Report form was adopted so that there Will be a document which will record the NCR, its resolution L and the final acceptance by QC. Inspectors will now know 9 10 ! exactly where they can look to see how a matter was resolved. 11 ! 12, When an NCR is improperly written, the disposition of "use 13 14 as is" is noted on it by the Lead QC Inspector or the Quality 15 16 : Engineer and the justification is documented. Thus, there 17 i gg i is an explanation available to the QC Inspector of how and 19 20 why the matter was resolved. This is also the reason QC 21 l will be notified of the disposition of all NCRs. 22 ; 23 I The NRC Investigation Report said that there was a 24 ! 25, tendency on the Project to document nonconforming conditions i through the field design change system instead of the NCR 28 i 29 l system. The Task Force concluded that the reason for this 30 l 3t ' was that the NCR process was cumbersome and slow, and Project 3 personnel found it faster and easier to use the field design 34 ! change system. The new NCR system is very easy to use, and 35 t 36 l with the addition of the Materials Review Board the NCR 37 : 38, process is much fas,ter. In addition, as explained in 39 ! 40 i Mr. Briskin's testimony in connection with the discussion of 41 i 42 the field design change system (Item 7 of the order), the 43 44 procedures now clearly require that all nonconformances be documented through the NCR system. t 47 ! 48 I 4 Su : 51 ! 99
L
- I 4
Q. 26 Does the revised procedure comply with Appendix 5i B to 10 CFR Part 50, applicable NRC Regulatory Guides and 3; applicable industry standards? 9i 10 A. 26 Yes. Our procedures in the past and the new 11 i 12 procedure are consistent with Appendix B Criterion XV and {3 ANSI N45.2 Section 16 which deal directly with control of 4 nonconformances, as well as other associated criteria such 17, as QA records (Criterion XVII). 15 19 ! Q. 27 How well have the new nonconformance reporting 20 ' 21 and disposition procedures been working? 22 ' 23 A. 27 The new nonconformance procedure was initiated 74 i on October 15, 1980. Since that time the Material Review Board (MRB) has been in operation. EL&P Discipline QA 7 28 ! personnel have also been directly involved in the approval 29 - 30 l cycle of all NCRs initiated by EL&P as well as all B&R NCRs 31 32 i requiring disposition by the MRB (i.e., all NCRs other than i 33 34 ! " rework" or " standard repair"). In addition, the MRB has 35 i 36 ' been providing EL&P QA with MRB meeting minutes which list ' 37 l 3g action taken on all NCRs. EL&P extends its involvement , 39 ! through the use of the B&R NCR system for resolution of 40 I 41 ! nonconformances identified by EL&P QA personnel; EL&P QA has 42 43 also performed reviews of the nonconformance control system '4 l 5 l and we have found that it is functioning adequately. 46 47 i Q. 28 Before the Order what was the procedure used on q i I ,3 the Project to analy e the trends in nonconformances? 50 si -100-
8 s l Li ~, ~\\ 4l 5, A. 28 Prior to February 1980, the trend analysis
- l function at STP was an informal process undertaken by various j[
members of B&R Project management. Results were reflected ff l primarily in the corrective action taken. The formal trend 12 analysis that was performed analyzed a portion of the STP 12 14 inspection reports, NCR's, and selected Field Requests for L3 16 Engineering Action (FREAs). These data were not normalized. 17 ig The identification of a trend was based solely on the number 13 20 of incidents reported in a given category of activity. EL&P 2f reviewed B&R trending reports and did no independent trend 23 ' analysis. In February 1980, we began to develop a formal 24, 'O l trending program. This was committed to in our early response ., I to information from the January 24, 1980 exit interview with 23 i 29 ; the NRC. 30 ' 31 ' Q. 29 What additional changes were made in trending 32 i j b performance in response to the order? 32, 34 ' A. 29 A new Data Analysis Group, comprised of Quality 35 ' 36 : Systems Engineers within B&R QA, was established in July, 37 l 38 ' 1980, and is now responsible for identifying the methods to 39 ' 40 ! be used to collect data, the ways to categorize and monitor 41 ' 42, deficient conditions by the use of quality indicators, data 43 ' 34 normalization and graphic representation, and the methods of reporting this information to management. Formal procedures 47 : require the collection of data from all QA records that 40 ! 4 record nonconforming conditions. 50 51 -101-
l.i ~\\4l 5 A new uniform coding system has been developed and all e : those charged with collecting data for trending have been o trained in the use of the system to assure uniform applica-9' 10 ' tion. Standardized codes have been' developed for a number 11 12 of categories, including: building or area, activity, 13 14 failure type and time interval. LB 16 Procedures specifically identify the types of documents f7 to be trended and the B&R organisations responsible for g 19 I review of each type of document, collection of data and 20 ' 21 ' submission to the Data Analysis Group. Examples of documents 22 13 i included in the list are: NCRs, Corrective Action Requests 24 (CARS), Vendor Surveillance Reports and Audit Deficiency Reports. The Data Analysis Group is responsible for reporting 26 i' 29 ' the results of its analyses to B&R Quality Engineering. 3 i Quality Engineering reviews suspect areas to determine 32 ' whether the incidents that make up a trend have a common 33 ; 34 cause. 35 36, The trend analysis performed by the Data Analysis Group 37 ', 38 i is made available to EL&P QA at the same time that it is 39. 40 l distributed to B&R management. The HL&P Supervisor, Quality jf Systems reviews B&R data and other data collected by HL&P 43 implementation reviews, and performs an independent trend review. I include this information in the monthly report ,o : 47 ' that is sent to Mr. cprea and use it in assessing the per-4o i formance of the B&R QA program. s
- 50 i
'51 l I l -102-
~ L ~ 4: 5l Q. 30 Why does this new procedure represent an improve-ment over the previous system? h A. 30 The Task Force found that the trending efforts fa prior to the NRC investigation were not effective because f there was no centralized responsibility for collecting data 14 and performing trend analysis; and trending was not controlled 13 16 by formal procedures. Now those formal procedures have been 17, Lg promulgated and a competent engineering staff has been '9 30 established with primary responsibility for collecting and (( analyzing the data. 3 In addition, the NRC Investigation Report found that ~ the effectiveness of the trending efford was reduced by the 3, i use of the field design change procedure in situations in 23 i 29 which an NCR would have been more appropriate. That affected 30 i 3; ' trending because not all field design changes were included 32 ' 33 in the trending. By procedurally assuring that nonconforming 3 l conditions are not handled as field design changes, we have 36 ; eliminated this potential problem, i.e., we have taken steps 3, i 38 l to eliminate the use of the field design change process for 39 40 i the resolution of what are really nonconformances. 41 ' '2; Q. 31 Does the trending program now in use on the 4'3' 4'o Project comply with 10 CFR Part 50, Appendix B, and appli-l cable NRC Regulatory Guides and industry standards? g 47 ! '9 ; 4 I., 50 t $1 i -103-
L ~, 4t 5, A. 31 Yes. Appendix B and ANSI N45.2 do not specifi-o, cally require a trend analysis program or establish any criteria relative to the mandatory content of a trending 9 10 [ program. However, Criterion XVI of Appendix B requires that 11 12 corrective action be taken to preclude repetition of signifi-L3 14 ! cant conditions adverse to quality. The new trend analysis L5 16 system provides a method for detecting adverse trends and 17 ggi for initiating investigations to determine whether or not ff corrective action to preclude repetition is required. B&R 21 performs trending of the B&R indentified deficiencies and 22 23 ' HL&P trends HL&P identified deficiencies, evaluates the 24 B&R trend analysis and compares the results of both. Q. 32 How well have the new trending procedures been ao {g ; working? f0 A. 32 The trending procedures were implemented in 32 July, 1980 and the B&R Data Analysis Group issued its first 33 34 ' Quarterly Report in January, 1981. As a result of the B&R 35 ; 36 ' trend analysis effort, to date ten suspect Trend Investiga-37 ' 13 3 ' tion Requests have been initiated. The HL&P trer.d analysis '39 4a i effort has resulted in the issuance of thirteen Trend Investi-4{'! gation Requests. We expect that in the long term the trend 4 4j analysis efforts will aid in reducing the number of non- ,i conformances on the Project. i,o 47 ! ao : 50 51 i -104-
~ L' 2 4, 5: Q. 33 Before the issuance of the Order, what was the G' procedure for directing that actions be taken to prevent jl recurrence of nonconformances? 10 l A. 33 Prior to the Order the B&R Project QA Manager 11 12 used a form called a Corrective Action Request (CAR) to 13 14 direct an organization working on the Project to take action L3 16 to prevent recurrence of nonconformances. The CAR would {7 i g identify the organization affected, the work activity and 13 the problem in need of correction. When the corrective 20 i 21 ! action was taken, the affected organisation would reply to 22 23 ! the CAR, describing the corrective action. 24 l So i Q. 34 What were the Task Force findings about the CAR system? 23 l 29 l! A. 34 The Task Force found that the CAR system generally 30 worked well, but that in some cases it took longer than 32 necessary for an affected organi=ation to respond to a CAR. 33 { 34 Q. 35 What is the revised procedure for recurrence 35 ! 36 control? 1 37 ! 33 ' A. 35 B&R Quality Engineering now has responsibility 39 l 40 'or ensuring the identi'ication of the causes of trends and 41 l issuing CARS for recurrence control. CARS are still issued 42 43 l to identify for correction, significant or repetitive condi-tions adverse to quality and procedure inadequacies.
- However,
.c l 47 i CARS now have specified time limits for taking responsive as l l action and may constrain or " hold" work on specific tasks or 50 51 i j 1 -105-
7 ~l 4 5 '. by specific crews until the identified problem is resolved. After a CAR is issued, Quality Engineering determines whether 3' corrective action has been taken, and whether it was effec-9, 10 ' tive in preventing recurrence of the problem. Quality 11 ' 12 ; Engineering may initiate a Stop Work Order if corrective 13 14 action is not taken within the time limits or if the inves-LS 16 tigative finding is that the corrective action has been ineffec-17 i tive. In addition, EL&P QA identifies problems to BAR QA for , I i 19 underlying cause investigation and recurrence control 20 21 via the B&R CAR system. HL&P QA reviews all CARS for con-22 23 ' currence with the B&R disposition and performs periodic 24 follow-ups to determine the effectiveness of inplementation. + i 17 ! Q. 36 Why do these new procedures on reporting, trend-28 i 29 ing and rectifying problems represent an improvement over the previous system? 32 ! A. 36 With the creation of the Data Analysis Group, 33 ; 34 ! the MRB, and the new procedures associated with the noncon-35 i 36 ; formance reporting system, our understanding of quality 37 i 33 ! problems is substantially strengthened. The Data Analysis 39 t 40 ; Group has improved the process of identifying trends adverse 41 ! t quality. The MRB and Quality Engineering scrutinine 42 43 ! NCR's to determine if recurrence control by a CAR is required. These changes substantially increase our ability to identify 46 47 the need for recurrence control. l i s. 50 51 i l t C
i Li 4i gl Q. 37 Does the revised system for corrective action comply with Appendix B to 10 CFR Part 50, applicable NRC [i Regulatory Guides and industry standards? 11 l 10 A. 37 Yes. The procedures comply with Criterion XVI 12 1 3 {. of 10 CFR 50 Appendix B and Section 17 of ANSI N45.2, as 14 well as other related requirements and criteria. 13 ' 16 Q. 38 How well have the new corrective action proce-17 ig 4 dures been working? 19 ;! A. 38 since the issuance of the new CAR system in 20 21 22 l October of 1980, the procedures for processing CAR's have 23 been refined. Difficulties with the. system were initially 24 i experienced because the CAR system was used to identify ./ i minor problems, thus diluting its effectiveness in high-23 ' 29 lighting information to management. To eliminate this 30 l 31 j problem we have initiated a new form called the Field Action 32 f Request for minor procedure deficiencies. The CAR system is 3 -e4 i now reserved for its intended purpose--significant and 3a i 36 ! ' 37 i recurring conditions. This adjustment, together with HL&P I ,38 QA's increased involvement and control, are leading to much l 391 ~ '~ 40 l more effective recurrence control. The backlog of CARS 41 42 issued under the old system makes it impossible at this time 43 : 44 l to present a quantitative assessment of the new system. Its strengths will, however, result in a decline in the numbers ,o 47 l of NCRs and CARS. Ao l 1 50 l 51 l I 1 -107-
9 t E! 2 4l 5i Q. 39 Item 8 of the Order required that EL&P develop 6i and implement a more effective system of record controls. jlI How were records controlled prior to the Order? TO A. 39 Prior to the Order the QA vault, which is the L1 ! 12 place where on-site QA records are stored, kept a number of L3, 14 i separate files for each of several phases of records process-19 16 ing. Incomplete or inadequate documents were placed in a L7. Lg l suspense file until the originating department was notified TS t 20 i f the deficiencies and the deficiencies were corrected. Z}i' Completed records were placed in the pre-microfilm suspense 13 file pending microfilming. They were.then kept in the 24 19 l post-microfilm suspense file until film processing in Houston i was completed and a determination made that the microfilm 23 ! 29 copies were acceptable. Thereafter, the records were placed 30 ! 31 l in the permanent files. 32 33 ; Q. 40 What was the background behind the NRC Order 34 regarding the record controls? 35 ' 36 1 A. 40 That is not clear. There was no discussion of 37 ! 38 ! the record control system in the Investigation Report. I 39 ! 60l understand that during the investigation there was an inci-61 62 dent in which an NRC inspector requested a record from the 63 I g4 i storage vault that was not located for several hours. Based on that we understood the NRC's criticism to be that it I sometimes took too long to retrieve records from storage. 68l 6 50 ! 51 i i -10@-
t ' r 4i 5l Q. 41 What were the Task Force findings about the 8 i record storage system? gf A. 41 The Task Force found that the system of having a 10 ! yy l separate file for each stage of record processing made it 12 ' difficult to locate certain files. There were too many 12 ' 14 ' places to look. It appeared best to reduce the time required LS ! 16, for each processing stage, so that files could be quickly 17 i ig ! placed in a central file and cross indexed. 19 { 20 Q. 42 How does the current records control system 21 i s.g i. work? 3 A. 42 Prior to commencement of a work activity, Quality 7" Engineers specify the requirements for the QA records necessary t -.j to substantiate the individual activities. When work activities 28 29 )l are completed, Quality Engineering reviews the required" 30 ! 31 quality documents prior to turnover and testing to verify 32 33 l that the documents are complete and adequate. 3 New microfilm equipment has been acquired to speed up 36 ! filming and to establish an on-site film processing labora-37 33 tory devoted to the,QA Vault needs. This new equipment has 39 40 t reduced the time required to film documents and to develop, 41 l '42 j process and verify the film. '43 44 An automated record index system now permits rapid identification of records related in any of a variety of .s i 47 ! l 48 j 50 ; 51 i 1 -109-
i 1l 4i 5l p saible ways (e.g., purchase order, inspector, heat number, drawing number). The backlog of data to be put into the oi computer data base has now been substantially reduced. 9i 10 i There is a single filing system, and documents are filed 11 ! 12 ' with a record " traveler" prepared by Quality Engineers. The 13 14 travelers identify the records required to substantiate each 10 16 activity. The index system records the status of the file,' f7 l and the location of documents borrowed from the file, and is g 19 I used to identify overdue and missing records. 20 21 l Q. 43 Does the records control system comply with 22 23 i Appendix B to 10 CFR Part 50, applicable Regulatory Guides 24 l and industry standards? ae I j A. 43 Yes. Regulatory documents which define the 23 - 29 l requirements of a quality assurance record system are Appendix 30 1 B, Criterion XVII, and ANSI N45.2 Section 18. These documents 31 ' 32 i define requirements for collecting, filing, indexing, storing, l33l 34 i (35 maintaining and dispositioning of records. t 36 : HL&P STP Site Quality Assurance Procedure PSQP-A4, 37 l 33 i " Control of Site QA Documentation" and B&R Quality Assurance 39 ! 40 i Pr cedure ST-QAP-17.1 " Records Control Procedure," adequately i ' 4 }1 address all applicable requirements at the STP construction l 4 43 I site. Prior to any submittal of quality records to record
- 4 storage facilities, both procedures provide for a review by
,o ! ,47 l QA personnel for completeness and adequacy. t ac, i l I S0 ; 51 i [ -110-
t 7i e 4l 5i Specific procedures for control of documents filed as e; quality records are in place for handling all records in the record vault. These procedures are in compliance with the g 10 j applicable regulatory requirements. 11 ! 12 ! Q. 44 Item 9 of the Order (the last item on admin-13, 14 i istrative controls) required E&P to develop and implement U 16 an improved audit system. What is the purpose of an audit 17 ! ig ! system? 19,
- ja l A. 44 An audit system is used to determine the adequacy 21 42 ;
of, and compliance with, established procedures, instructions, 23 ! drawings, and other applicable documents, and the effective-24 ! ea ness of implementation. .I 23 ! Q. 45 Which organizations perform audits at STP? 29 l 'A. 45 The E&P QA Program requires that planned and 30 l i 31 periodic audits be performed to verify compliance with all 3}" aspects of the quality program. E&P performs such audits 3 34 internally as well as audits of Westinghouse E:lectric Corpo-3o i 36 l ration, B&R, and of others as necessary, to determine that 37 38 ! the STP QA program has been developed, documented and imple-39 l 40 i mented in accordance with established requirements. E&P 41 I 42 j and B&R both have responsibilities for implementing audit 43 : y! systems at STP. B&R, as architect-engineer and constructor, provides all quality functions on the project within its .a I 47 l scope, including the implementation of an audit system in 49 50 I 51 i i, -111-
.7 I i 1l 4;i 5 accordance with 10 CFR 50, Appendix B, Criterion XVIII. HL&P also audits B&R's performance. The B&R audit respon-3 sibility is performed-by the B&R home office QA Audit Section. 9 10 l HL&P's audit responsibilities are performed by the HL&P 11 l 12 l Corporate QA organization, which has offices in Houston. 13 ' g4 Q. 46 What was the background behind the NRC Order 13 16 : regarding the audit system? g}.,. I A. 46 The Investigation Report found that both the b3 I HL&P and the B&R audit staffs were relying on a review of QA 80 l 81 l records in their audits rather than observing work; there 82 i 83 i were several occasions when audits were conducted at less 84 l than the required frequency, and neither staff had been o-I gy j conducting supplemental audits of problem areas. 83 gg Q. 47 What did the Task Force find about the audit program? S2 I A. 47 The Task Force found that the primary causes of 83 I 84 the deficiencies were lack of sufficient staffing levels on 85 ' 86 the audit staffs and inadequate training. The frequency of 87 33 audits and the depth of audits had both been curtailed by a 39 i 40 i shortage of qualified auditors. It was also found that HL&P 41gl had not included the requirement for supplemental audits in 43 its audit procedures. Q. 48 What are the principal areas in which improvements 47 ! have been made to the HL&P and B&R audit programs? J~ s 50 ; 51 -n2-
l l! l i 4i 5l A. 48 The principal changes to the B&R and EL&P audit
- I programs were:
1 gl (1) In both cases procedures have been changed to
- 0 l 1g; assure that supplemental audits are performed.
1 (2) Both audit staffs have been upgraded through 14 increased manpower and training. 12, 16, (3) EL&P audit procedures have been revised to increase 17 i li { audit depth, and both EL&P and B&R procedures were revised L9 l 20 i to assure that audits cover all aspects of the QA program. 21 22 l Q. 49 What are supplemental audits and what procedure f3 ! changes were made in connection with them? 'C A. 49 Supplemental audits are audits conducted in addition to regularly scheduled audits. Generally, a supple-28 ! 29 i mental audit is conducted when there is some reason to 30 ! 31 i suspect problems in a given area. Although EL&P did conduct 32 l 33 j supplemental audits from time to time, the criteria for 34 ' e ndu ting supplemental audits were not addressed in the 35 36 j 37 l audit procedures in effect at the time of the NRC investiga-38 ' tion. The procedures now explicitly provide for supplemental 39 I 41l! 40 audits. In addition, the changes upgrading both the EL&P 42 and B&R audit staffs and the EL&P and B&R audit procedures 43 a4 l Will result in greater audit staff resources and better i control over the scheduling of supplemental audits. 47 i 48 ' 4 I SO ; 51 -113-
1.t 'i l 4l 5i An important element contributing to improvement in at ' this area is the improvement in trending and identification t jj of the causes of nonconformances which I discussed above. 10 l The B&R audit group and Project QA management regularly 11 1 12 i receive the reports of the trend analysis group, thereby 13, 14 enabling them to identify problem areas and establish the i li : ! 16 ; need for performing supplemental audits. 17 f ig l E&P has established its own program to analyze trends 1 1
- 9 l based on the B&R trending data as supplemented by E&P 0
21 collected data. The E&P Site QA group has established a 22 23 l Quality Systems group that reviews documents which record 24 i l unsatisfactory conditions and that monitors B&R trending 'C reports. The E&P audit group and the E&P Project QA l 2s i l29 j management receive both E&P and B&R trend analyses. !30 i l 31 l Q. 50 What steps have been taken to upgrade the respec-32 ' l33 tive audit staffs of E&P and B&R? \\ 34 A. 50 The audit staffs of E&P and B&R have been
- 35 li
- 36 '
upgraded through both increases in manpower and training
- 37
- 38 programs directed at improving the auditing skills of the 39 40 i respective staffs.
While E&P and B&R have been recruiting '474j l qualified personnel, consulting firms have been employed to '43 ' provide experienced nuclear auditors to augment the audit y staffs. .o i
- 47 !
4R ! i '50 ; 51 l l -114-
k l! I 4: 5l A. 48 The principal changes to the B&R and HL&P audit "l programs were: i w9l (1) In both cases procedures have been changed to 10 f assure that supplemental audits are performed. g
- 2 '
(2) Both audit staffs have been upgraded through 14 ' increased manpower and training. 1S ' 16, (3) HL&P audit procedures have been revised to increase 17 i 15 ! audit depth, and both HL&P and B&R procedures were revised I '9 20 l to assure that audits cover all aspects of the QA program. 21 l 22 ; Q. 49 What are supplemental audits and what procedure 23 ! changes were made in connection with them? 24 : A. 49 Supplemental audits are audits conducted in addition to regularly scheduled audits. Generally, a supple-28 i 29 l mental audit is conducted when there is some reason to 30 i 31 ; suspect problems in a given area. Although HL&P did conduct 32 33 l supplemental audits from time to time, the criteria for 34 35 l conducting supplemental audits were not addressed in the 36 ; audit procedures in effect at the time of the NRC investiga-37 I 39 l 38 tion. The procedures now explicitly provide for supp,lemental 41 l 40 audits. In addition, the changes upgrading both the HL&P 42 ! and B&R audit staffs and the EL&P and B&R audit procedures 43 l 44 will result in greater audit staff resources and better control over the scheduling of supplemental audits. 47 i 48 I I 4 50 l = 51 l m
1 , r 4i 5{ An important element contributing to improvement in 8 i this area is the improvement in trending and identification I jj of the causes of nonconformances which I discussed above. 10 $ The B&R audit group and Project QA management regularly 11 12 ; receive the reports of the trend analysis group, thereby 13 : 14 enabling them to identify problem areas and establish the u. !16 need for performing supplemental audits. l ll7 i E&P has established its own program to analyze trends 1g i tg ! I 30 l based on the B&R trendng data as supplemented by E&P 82 l 21 collected data. The E&P Site QA group has established a
- 13 Quality Systems group that reviews documents which record
- 24 i Ml unsatisfactory conditions and that monitors B&R trending
<88 l reports. The MAP audit group and the E&P Project QA 0, gg j management receive both E&P and B&R trend analyses. '30 i gg ; Q. 50 What st:ps have been taken to upgrade the respec-b2 tive audit staffs of E&P and B&R? 83 !S4 A. 50 The audit staffs of E&P and B&R have been '85 86 upgraded through both increases in manpower and training i87
- 88 programs directed at improving the auditing skills of the
- 89
'~ respective staffs. While E&P and B&R have been recruiting
- col, 61 c2 j qualified personnel, consulting firms have been employed to 63 '
y provide experienced nuclear auditors to augment the audit staffs.
- .o.
67 I on i 90 ! 91, -116-
i 1: "l 4' 5! The function of the HL&P corporate audit group has been restructured to minimize ccuflicting assignments and respon-Sl 'sibilities of auditors. Previously this staff consisted of 9 10{i five and was responsible for document reviews and procedure 11 ! 12 l development in addition to its audit responsibilities. Now 13 14 the group's primary function is to prepare for and conduct LS 16, audits of quality-related activities and the staff has been f7 { increased to eight. Auditors are continually receiving g 19 I additional training in the areas of codes, standards, proce-2 20 t 21 l dures, and other documents related to QA programs and audit-22 23 ing. For example, RTAP has retained an outside consultant i 24 ! to conduct an inhouse training program for its auditors. 27 ! Participants have included Lead Auditors, Auditors and 23 29 4 Auditors in Training. When successfully completed, this 30 i program leads to certification as-a Lead Auditor in accord-31, 32 ! ance with the criteria of ANSI N45.2.23, provided other 33 34 procedural requirements are met. 39 36 i Q. 51 What changes have been made in audit procedures 37 I 33 of HL&P and B&R? 34 4f A. 51 The HL&P corporate audit procedure has been 41 ! revised to require both the review of objective evidence 42 : 43 (records) and direct observation of work being performed to lI 4: 5 l; assure adherence to procedures and compliance with quality
- l 46 47 l requirements.
.J l 00 l 51 -115-
L i t 41 5l E&P has developed an annual audit plan, which is reviewed and revised at least once every six months. In D! addition to the annual audit plan, a more detailed audit 9 i 10 ! schedule is issued quarterly. This schedule provides for 1.1 ! 12 ' supplemental audits as well as required audits. A matrix has been prepared delineating all B&R procedures applicable 13. igi to STP and the corresponding audit (engineering, construction, a7,g; discipline, etc.) to which they apply. This matrix is I utilized by the E&P and B&R audit groups to assure that r0 ! "l ! both groups audit all quality activities within the required 32 i 13 ! frequency. $4 l P-Q. 52 Do the audit programs of E&P and B&R comply Iyl with Appendix B to 10 CFR Part 50, applicable Regulatory Si 9l Guides and industry standards? O' gl A. 52 Yes. The E&P and B&R Audit Programs meet the
- 2 requirements of 10 CFR 50, Appendix B, Criterion XVIII.
All 13 14 ' audits are conducted in accordance with ANSI N45.2.12. $5i J6 Auditors are certified in accordance with ANSI N45.2.23, a 97 E a3* which has been endorsed by Regulatory Guide 1.146. ] 99. go Q. 53 Does the overall Project QA Program, which you BTj ; have described in your testimony, including both the E&P g h3 and B&R portions of the program, comply with Appendix B to l 10 CFR Part 50, applicable Regulatory Guides and industry PG i 37 I standards? 38 l 6 i 20 ! 91 l l l -116-
L'. i ~, 4 1 5, A. 53 Yes. As described in my previous testimony, the QA program for STP complies with Appendix B, applicable D Regulatory Guides and industry standards. 9,, 10 As an additional assurance that we will continue to 11 12, remain in compliance with all requirements, HL&P is committed 12 ' 14 to having an independent audit of the STP QA Program at IS ig ' least once every 12 months. 17, 15 ! 13, 20 ; 21 ! 22 ' 23
- T. Hudson:ll:A 24 l l
4/ ! 23 29 ; 30 ! 3,, 32 33, 34 35 36 ! '37 ' 38 40 i 41 ! 42, 43 i 46, 47 i 4 s i 50 i '51 l -117-
i 1i I 4i 5i TESTIMONY OF JOHN M. AMARAL e! REGARDING ALTERNATIVE QA ORGANIZATIONAL STRUCTURES 9 Q. 1 Please state your name and occupation. i A. 1 John M. Amaral. I am Manager of Quality Assurance U of Bechtel Power Corporation (Bechtel). 13 14 Q. 2 Please describe your educational and professional 15 16 background. 17. ig l A. 2 I am a graduate of the University of Southern 'S 20 I California where I studied Industrial Management and Industrial 21 ! 2} l Engineering. I have over thirty years of industry experience. 23 24 l Prior to joining Bechtel, I was the Manager, Quality Systems with Aerojet Nuclear Systems Company. I also held several other upper positions with that corporation in 23 29 ; various aspects of quality assurance (QA), reliability and 30 i . 31 ; program management. 32 ' 33 In June, 1972 I joined Bechtel as QA Manager for the 4 LMFBR, Fast Flux Test Facility. I served as Deputy QA 36 i !37 ! Manager of the San Francisco Power Division. In 1976, I was l38 promoted to Manager,, QA at the Bechtel Gaithersburg Division. l39 ' !40 l I am now Manager of QA for Bechtel. 41 ! 42 l I am a registered Professional Engineer in California 43 i ,y and certified as a Reliability Engineer by the American Society for Quality control. I am currently Chairman of the .a 3 47 f Energy Division of the American Society for Quality Control. 4 90 i 91 ! -110-
- s I
4' $l Q. 3 What is the purpose of your testimony? -1 A. 3 I will describe Bechtel's recommendations to f Houston Lighting & Power Company (EL&P) concerning alterna-10 tive QA organizational structures for the South Texas Project 11 ! 12 I (STP), and explain the basis for Bechtel's recommendations. 13 14 Q. 4-How did Bechtel become involved in reviewing the 1S 16 QA program for STP? 1 { A. 4 In January 1980, EL&P requested that Bechtel 13 i review the QA program which was being implemented at STP. 20 < 21 22 ; The requested review was to include both the deficiencies in 23 l the QA program which had been discovered in EL&P's own 24 ; reviews of the program, and those preliminarily identified in f 28 ! discussions between EL&P and NRC Region IV personnel, as 4f gg well as alleged deficiencies which had appeared in the news 30 ' l media. This was before the NRC I&E Report 79-19, the Notice 3 32 of violation or the order to Show Cause were issued. 33 34 ! Q. 5 How did Bechtel perform its review of the QA 35 36 program? 37, 33, A. 5 Under my supervision,. selected personnel from 39 ! 4o j three of the power division offices of Bechtel were assigned l 41 I t perform a comprehensive, in-depth audit of the construction 42 l 43 QA program at STP. For these purposes we examined selected ,e{. elements of the STP quality assurance activities. Our 47 l review involved a check of QA manuals and procedures in use 48 j 4 i 50 ! 51 ' l \\ 1 _m
i 1! -1 4l 5i by both B&R and HL&P; an examination of design control procedures (especially field-initiated changes); a review of 8! special processes (primarily welding and NDE activities); an 9 80li audit of the nonconformance reporting system and several 11 ! ,12 other areas. The review identified a number of concerns L3 -14 which we were able to trace to six " root causes" which are 15 i 16 ! discussed in the testimony of Mr. Oprea. 1 7l The results of the comprehensive audit were contained g 13 in the Final Quality Assurance Management Report to HL&P 20 l21 f dated July 24, 1980 which was attached to HL&P's response to
- 22 23 '
the Show cause Order. '24 l Q. 6 When did HL&P request Bechtel to review alterna- .27 l tive QA organizational structures at STP? 93 i 'g l A. 6 In April, 1980, after Bechtel had begun its review of the STP construction QA program, the NRC requested '32 ! that HL&P evaluate five options for the STP QA organiza-
- 33 !
- 34 !
tional structure. Since Bechtel was in the midst of its i35 l36 audit of the QA program, HL&P requested our assistance in '37 .38 evaluating the options suggested by the NRC. 39 i 40 Q. 7 E w was the Bechtel review of alternative QA 41 rganizational structures conducted? ! 42 43 A. 7 The review of alternatives was conducted in '4 i parallel with the Bechtel audit of the STP construction QA 46,
- 47 i program and overlapped the audit schedule.
Cur conclusions
- .j l'0
- i
- 5 i
- 51 I
4 itv-
L -i 4' 5l and recommendations were based on consultation with the i audit teams, with other Bechtel Quality Assurance Managers 3! and with other managerial personnel in Bechtel whose exper- .9: 10 l ience in the nuclear power industry is both broad and success-11 - 12 ful. 12 14 Q. 8 What were your basic conclusions and recommenda-1S 16, ti ns on organizational structure? , ~# f A. 8 Our conclusions were contained in my letter to 5, 13 ! EL&P of May 9, 1980, which addressed the alternative organi-20 ' 21, zations suggested by the NRC. I pointed out that the solu-22 ' 23 tions to the root causes of the QA prcblems were not dependent 24 upon the particular QA organizational structure. As I g7, stated, "Since these root causes exist, the organizational 28 ' structure of the Quality Assurance Departments is of lesser 29 3 concern." I emphasized the need for positive attitudes 32 l toward quality management. 33 i 34 On the basis of our review, Bechtel recommended an 35 ' 36 : expanded version of the first alternative or " Option A" 37 ! 3g, mentioned by the NRC (i.e., the existing organization with 3,, 4f upgraded staffing). 41 We described our approach as encompassing ". . mainte-i 42 i 43 l nance of the existing basic assignment of QA program responsi-4 i 46 { i bilities of both HL&P and Brown and Root; acquisition of 47 ' qualified quality professionals with credentials that indicate Ja i SG 51 { i
1 I 4! 5; successful performance of similar functions; and dedication to fully implement the upgraded QA plan, with particular l,f attention to performance of the QA Tasks and functions. 10 l As part of this alternative, we recommended "that as an 11 : 12 interim step R W acquire the services of an outside organiza-t2 14 tion dedicated to and possessing the expertise required for 15 ! is - performing this type of function. The personnel of the 17, tg > third party organization could be integrated into the HL&P 10 - Q! and Brown & Root organisations in supervisory positions 21 l until such time as permanent personnel can be obtained by 23 both companies." We felt that this was the quickest and 24 ! " i easiest way to fill the apparent voids in the STP QA organi-j =ation, but, much more importantly, we concluded that this 12 8 i l29 ; alternative retained the fundamental precept that the " doers" l30 ! 31 1 have responsibility for both doing and controlling the work. It is a concept which has been implemented successfully in lS5 numerous utility /AE Constructor combinations over the years S4 i iS3 l in nuclear power construction. Admittedly, this alternative 87 i
- 83 '
does not represent a dramatic change in organizational 89 ; '~ jeo i arrangements but, in concert with the significant upgrading l0 1 i' l62 of both organizations' QA/QC staffs (which we recommended), d3 y4 l it was our view that these steps addressed most directly the i I i concerns we had identified. mo '07 68 : l6 l90 '91 -m-i
~y ,a 1 1,-l t 4 5* Q. 9 Why did Bechtel not recommend a new structure giving QA responsibilities to a third party organization? 0 A. 9 There are some QA functions that a third party 9, 10 ! organization can perform effectively in an operation as 11 12-4 demanding and complex as the design, procurement and construc-13 > 14 ' tion of a nuclear plant. But, in my opinion, it is mandatory 12 e 16 that the organization performing a function be responsible 17 i ig ' for the quality of that function. The organization responsi-to i Q, ble for design must be held accountable for the quality of 21 the design - and the constructor must accept responsibility 22 23 for the quality of the construction. 24,i It is evident that if the organization doing the work <., I is responsible for the quality of its work, the addition cf 23 ! 29 j a third party can do nothing to improve quality. To the 30 i
- 32.,
contrary, such an addition might relieve the working organi-32 ! zati n f responsibility for quality even though the third 33 ' 4 ll 4 party cannot be expected to be responsible for something it 35 ! 36 : 07 1 cannot control. 38 : This situation would be compounded in a case such as 39 ~ 40 j STP where over half the plant is completed. What would be a 41 l 42 feasible dividing line for the transfer of QA responsibility? 43 ! 4.g l For the entire plznt? For the remaining plant? For open deficiencies? For improperly closed deficiencies? For 47 ! rework? It is obvious that the transfer of responsibility 48 ! 4 F0.
- 51. !
f " 14s J "
z. i
- 1.,
4' 5 for QA would be an extremely complex undertaking, if feasible, at all. lf It is for these reasons that we believe that a third 10 ! party QA organization is not an appropriate alternative and 11 ' 12 that we made our recommendation to: i L3 14 A. Strengthen the E&P and B&R QA organizations, and 1.5 t 16 ' B. Provide motivational indoctrination to E&P and B&R 17 i ig ! at all levels of management. 'S 20 Q. 10 Can you briefly describe the principal reasons 1 for recommending against the other options set out in the 23 ! NRC's Order to Show Cause? 24 !
- l A.
10 Yes, Option B involved the development of an organizational structure where all levels of B&R QA/QC 38 ! l29 i report to E&P. Although this has the superficisl benefit '30 I 31 ! of appearing to enhance E&P control over the QA/QC function, 32 I it would place B&R QA/QC personnel in the position of " serv-i l34, ing two masters" and raise, again, the concern about reliev- '35 l
- 36 j ing B&R " doers" of quality responsibility.
I would also be l37 ! 38 ! very concerned about miring E&P in the details of the 39 ; 40 l program and thereby detracting from their ability to maintain (41 i 42 l an overview of the quality function. I43 ; y! Under Option C, E&P would establish a total QA/QC organization to conduct those functions now performed by ,,e i47 l B&R. Again, this is a dramatic change but one which has the 48, k i 50, 51, -u,-
e .? b L 4! potentially deleterious effect of relieving B&R of responsi-5 bility for quality. It also has many of the same disadvan-8! tages cf Option B as well as a potential for a period of a9j 10 ; instability in the relationship between the two organizations 11 ! [{ as EL&P personnel move in to a more direct supervisory role 13 34 with respect to B&R's day-to-day activities. ff Option D essentially calls for a third party to execute 17 j QA/Qc functions. I believe that both organizations would 15 l 19 l suffer from their lack of involvement in quality-related 20 ' 21 l functions as I mentioned above. I can see a confusion 22 ! 23 j between the responsibilities of HL&P and the third party as 24 i well as a perturbation in the relationship between B&R and 3 EL&P by the addition of a new interface - a third party with 27 28 ! its own methods of correspondence control, procedural documents, 29 ; 30 ! etc. 31 ' 32 We also looked at Option E - establishing in HL&P a 33, 34 i duplicate QA/QC organization to match that of B&R. Although 35 i 36, this " beefs up" the organization by achieving a "one-to-one" '37 l 38 ' relationship between B&R and HL&P QA/QC personnel, it detracts 39 from " doer responsibility" on the part of B&R and, in my 40 t 4 judgment, has a large potential for gaps in implementation 43 i ("I thought he did it"). '4 i 5 I Q. 11 Has Bechtel followed the implementation of its 46 : 47 l recommendations? 1 1 .2 00 l' 51 l L .a-
5 1l 41 5! A. 11 Yes. We have recently completed a review and audit of the QA/QC program against our 1980 findings and we y, found that the concerns we expressed last year have been 10 l addressed satisfactorily. our observations also tend to 11 t 1.2 l support our judgment as to the optimum organizational arrange-13 14 ' ment for QA/QC functions at the STP. 1.5 15 17 gg l T. Hudson:8:C 13 ; 20 81 ' 22 23
- 24,
ma l =d l23 ! l2 9 ! 100 ! 31 ' B2 93 i 94 B5 i f6 L i 87 l @S $9 : 00 ; el i 62 l es - lc4 l: l la 68 80 al l l -ilo- [ )}}