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-4 l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
-10l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 13 l 14 In the Matter of:
5 13 5
16 HOUSTON LIGHTING & POWER 5
Docket Nos.
5 50-4990L 15 '
5 19 (South Texas Pr'oject, 5
20 :
Units 1 & 2) 5 21 l 5
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23 TESTIMONY ON BEHALF OF HOUSTON LIGHTING & POWER COMPANY, E %.
26 l op 4o DR. KNOX M. BROOM, JR.
29 :
MR. RAYMOND J. VURPILLAT 30 i 32, '
ON 32 ;
33 j B&R MANAGEMENT AND STP QA PROGRAM 34 ;
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
5 i
HOUSTON LIGHTING & POWER Docket Nos.
50-4980L COMPANY, E AL.
50-4990L 5
(South Texas Project, 5
Units 1 & 2) 9 5
TESTIMONY OF DR. KNOX M. BROOM, JR.
AND RAYMOND J. VURPILLAT ON B&R MANAGEMENT AND STP QA PRCGRAM Q. 1 State your names.
A. 1 Knox M. Broom, Jr. (KMB) and Raymond J. Vurpillat (RJV).
Q. 2 Dr. Broom and Mr. Vurpillat, by whom are you l
I employed?
l A. 2 (KMB, RJV):
Brown & Root, Inc.. (B&R) 1 Q. 3 Dr. Broom, what is your position and what are your current responsibilities?
A. 3 (KMB):
I am Senior Vice President of the B&R Power Group and Ass'istant to the Group Vice President.
The Quality Assurance (QA) Department of the Power Group, which hcs responsibility for the B&R QA Program for the South i
l Tcxas Project (STP), reports to me.
Q. 4 Mr. Vurpillat, what is your position and what are your current responsibilities?
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A. 4 (RJV):
I am the Manager of the B&R Power Group 4
QA Department and report to Dr. Broom.
I am responsible for 5;
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the management and direction of all QA Programs implemented 7l 3
within the B&R Power Group, including the B&R STP QA Program.
9' 10 l Q. 5 Dr. Broom, please summarize your professional 11 '
12,i qualifications.
13 14 '
A.
5 (KMB):
I have a Ph.D. in chemistry from the 15 16 l University of Arkansas and a Master of Science Degree from 17 -
g; the University of Arkansas, where the bulk of my studies 13 involved nuclear chemistry and physics.
I have a BA degree 20 21 !
from the University of Southern Mississippi where I majored 22 23 I in chemistry and mathematics.
I have worked in nuclear 24 25 -
power and nuclear power research for more than 17 years.
I 9,
/j am a member of the American Nuclear Society, American Chemical
'S' 39 Society, American Society for Quality Control; and other 30 !
37,
professional organizations.
I am a registered nuclear 32 ;
engineer in the state of California.
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34 :
Q. 6 when did you join B&R?
35 I 36 j A. 6 (KMB):
I joined B&R in August of 1972.
37 38 Q. 7 What did you do prior to joining B&R?
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40 l A. 7 (KMB):
My position immediately preceeding,my 41 i 42 joining B&R was Manager of Nuclear Activities for Middle 43 4,g !
South Services, a subsidiary of Middle South Utilities, Inc.
45 l There, I assisted in the project management of five nuclear 16 -
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units at the operating companies of the Middle South System, 48 l 49 :
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and a-part of my responsibilities included helping establish the early QA/QC Programs which were required for these nuclear power projects.
Prior to my work at Middle South SOrvices, I worked. for one year at the Atomic Energy Commis-cion, where I administered research contracts involving fuels and materials development pert mining to nuclear power.
Prior to that, I was employed by Atomics International, a subsidiary of North American Rockwell, where I was involved in research work pertaining to nuclear reactors.
Q. 8 Describe the positions you have held with B&R and give approximate dates.
A.
8 (KMB):
On joining B&R in 1972, I worked for one ycar in Business Development following which I transferred to the Power Engineering Department where I was responsible for Nuclear Licensing and QA.
In June of 1975, the Power Group was formed, and shortly thereafter, my responsibility for the QA Department was transferred to report directly to tha Group Vice President for Power.
I was promoted to Vice Prcsident of Power Engineering in December 1976.
My responsi-bilities from June of 1975 until June of 1979 continued in tha engineering area.
In June of 1979, I was made Assistant-to the Group Vice President of Power Group.
In this position, tha QA Department again reported directly to me and the Group Vice President.
In summary, my responsibilities with regard to the B&R QA Department for the Power Group began in,
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1973 and continued through the formative stages of our 4i program for the STP until a period of approximately six 5;
6 i months before the construction permits were issued.
Then, I T.
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assumed responsibility for the QA Department again in the 9
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summer of 1979, and the QA Department has continued to 11 !
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report to me since that time.
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14 Q. 9 Mr.Vupillat, when did you join B&R?
IS A. 9 (RJV):
I joined B&R in August of 1980 in my 16 17 i gg {
present position.
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Q. 10 Please summarize your professional qualifications 20,
21 and experience.
22 23 '
A. 10 (RJV):
I have a Bachelor of Science degree from 24 25 ;
Purdue University.
I am a Registered Professional Engineer
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(PE) in Indiana and California.
I am also a member of the 23 29 American Society for Quality Control, and a member of various 30 t 31 j American Concrete Institute (ACI) and American Society of 32 ;
Mecha al Engineers (ASME) committees.
Prior to joining 33 34 B&R, I spent eight years as the district manager for Pittsburgh 35 36 Testing Laboratory where I was responsible for planning and l
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38 l supervision of all phases of inspection and testing functions 39 i
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40l related to medium to large construction projects; four years l
41 i 42 i as Director of Quality control (QC) for the Warner Company, 43 44 l a construction materials company, where I was responsible 45 l
for attaining and maintaining the quality of concrete materials 46 i
4y" j and ready mixed concrete production; one year as a partner i
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i in a construction business involved primarily in'.Educrete construction related to medium-sized private and commercial projects; and twelve and one-half years as Assistant QA l
Manager for United Engineers and Constructors where I was f
involved in the planning, management, and supervision of QA L
I Programs related to design and/or construci: ion of 16 commer-t cial nuclear power plants, and QA planning related to 7 other nuclear plants that never reached the construction I
'l parmit stage.
I was also involved in the same functions related to many non-nuclear projects including more than 10 fossil-fueled power plants.
Q. 11 Dr. Broom and Mr. Vurpillat, please describe the t
i purpose of your testimony.
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j A. 11 (KMB, RJV):
The purpose of our testimony is to describe the B&R organiration, the development of the B&R QA Program for STP, the management involvement in the STP QA Program, and the responses of B&R to the NRC enforcement actions against STP.
Q. 12 Dr. Broom, briefly describe the history and organizational structure of B&R.
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A 12 (KMB):
B&R is a subsidiary of Halliburton, Inc.
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and is one of the world's largest engineering and construc-l tion firms offering its services to a broad spectrum of i
industries including power, petroleum and chemicals, marine, i
manufacturing, forest products, mining, heavy civil, and i
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-t others.
Currently, B&R employs more than 70,000 people.
In 5 ;!
its more than 60 year history, B&R has performed engineering, 6i
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7i construction, and project management services on a wide l
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variety of projects worldwide.
These projects have ranged 10 I g
in size from small local' maintenance services to multi-billion dollar grass roots projects of many types.
~ 14 i B&R is organired into industry groups, each headed by a 12 i 16 l senior executive who reports to the President and Senior 17 i
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Executive Vice President.
The group executives, the President, 19 20 :
and the senior Executive vice President form the operating
- 22. I 22 l Committee of the company which meets regularly to establish
'93 i gj corporate policy and review the company's performance and
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planning.
Attachment No. 1 shows this organizational 25 i
'F' structure of B&R.
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J 29 i The B&R industry group that is directly responsible for i 30 ;
l 32-l the STP is the Power Group, which is headed by W.
M. Rice, 1 32 ;
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Group Vice President.
This group performs engineering and l34lI c nstruction of power generation projects for many utility 3D l36 j and industrial clients.
To date, the Power Group has per-a7 !
38 j formed engineering,and/or construction activities for over i 39 i
!40l 100 fossil or nuclear power units (with over 75 units in
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operation) consisting of more than 40,000 MWE of power 43 4.g l generation.
The organization of B&R Power Group is shown in 45 l yl Attachment No. 2.
The primary elements of this organiration are engineering, ccustruction, operations (which include 49 i 50 ;
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J project management) and QA--all which report separately and independently to Power Group Management..
Our company is. affected by numerous government laws and rtgulations which apply to various areas of our business.
W3 have many formal procedures which are followed.to ensure compliance with these laws and regulations.
Examples of these are our system of procedures for OSHA, financial rcporting, EEOC, and, of course, QA.
These systems provide for internal audits, as well as audits by outside agencies, to verify compliance.
Q. 13 What is B&R's prior experience with large scale construction projects?
A. 13 (KMB):
B&R has performed engineering, construc-tion, and project management services on many large scale
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projects.
Included have been many projects for the U.
S.
- Government, Corps of Engineers, Department of Defense, NASA, and other agencies which have required compliance with cxacting codes, standards, and military specifications.
Examples of projects we have developed are the manned space-l craft center in Houston, Texas, minuteman missile installa-tions, highways, bridges, dams, airfields, and shipyards to, name but a few.
I A wide variety of large scale industrial projects
< completed by B&R include power plants of all types (coal, oil, gas, nuclear, and hydro-electric), refineries, pipelines,
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offshore oil and gas platforms, papermills, mines and smelters, 4}
and petro-chemical complexes.
5j 6l Q. 14 How does B&R organize and manage a large project?
7 9i A. 14 (KMB):
For most large projects B&R utilizes a 10 l 1.Li Project Management System and a Project Task Force concept.
12 l A Project Manager is given full authority and responsibility 13
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I 14 for execution of a given contract and all'of the necessary 13 i 3,g,
resources--manpower and material--are assigned to the Project 17 !
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Manager as long as required for the project.
We assign 13 !.
people and dedicate the required office space for the per-20 21 !
formance of the home office functions--engineering, pro-22 23 !
curement, scheduling, cost control, administration--and at 24 1 25 !
the project site, we assign the construction forces and 26 }
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'i equipment required for the project.
The Project Manager is 1.8 l 29 given full control over these resources.
Similarly, on
- 30g, nuclear power projects, we dedicate the necessary QA personnel as a project team under the direction of a Project QA Manager 34 35 l who reports independently from the Project Manager to Power 36 j 37 i Group Management.
38 I On all major projects, B&R proyides frequent executive
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39 i 40 i contacts between the client management and B&R management to 41 !
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42 assure our client of our interest in and attention to his 43
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44 project and to provide an overview of the status and progress 45 l
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Q. 15 How did B&R first become involved in the nuclea.
field?
What were its qualifications to design and construct a nuclear power plant?
A. 15 (KMB):
B&R began its efforts to enter the field cf nt:, clear power in the mid-1960's by recruiting employees experienced.in the nuclear field, and in 1967, received its first contract from Carolina Power & Light Company to perform construction, field procurement, and related quality assurance activities for the Brunswick Steam Electric Station.
This project consisted of two-821 BWR units located at Southport, North Carolina.
In 1973, as the Brunswick Project was n2aring completion, B&R was awarded a contract of similar scope by Texas Utilities, Inc. for its comanche Peak Steam l
Electric Station consisting of two-ll50 Mw PWR units located naar Granbury, Texas.
l These two projects established a sound base in construc-tion and QA activities associated with nuclear power plants.
However, B&R was also interested in performing nuclear plant design and engineering.
Through the latter part of I
the 1960's, recruiting efforts continued to obtain experienced personnel in the nuclear design field and in November 1970, l
B&R purchased an equity position in the NUS Corporation, a
company highly respected for engineering and consulting
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activities related to nuclear power.
By 1973, we had g
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assembled a good nucleus of design personnel and with our e'
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association with NUS and access to its personnel, were
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prepared to provide design engineering services for a nuclear 5i 6j power plant project.
In that year, we initiated work on STP Tt Il for the design, procurement, construction, and related QA 9l 10 l activities for the STP.
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12 l Q. 16 At the time you.became involved in B&R's QA-13 i 14 I Program for STP, how was the program organized?
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A. 16 (KMB):
Originally, when the STP PSAR was prepared l
in 1974, the QA Department reported to the Engineering 19 !
Department and was separate from the Construction Department.
20 4 21 i The internal organization of the QA Department followed in 22 '
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the traditional lines of quality engineering, inspection, 24 i 25 i services to support the various organizations, a vendor 29 surveillance section, and an auditing section.
23 l 29 ;
Prior to the-issuance of the construction permits for 30 '
3g; STP, the B&R Power Group was formed under which engineering 32 and construction both reported to one group executive.
The 33 :
34 l QA organisation was transferred to report directly to the 35 1 36 head of the Power Group, thereby being entirely independent 37 38 from the engineering and construction organizations.
That 39 l 40 i organizational arrangement has continued to the present_.
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Q. 17 Was this organiration in compliance with applicable 43 i 44 l industry practices and NRC requirements?
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A.
17 (KMB):
Yes, the QA Program, including a descrip-I !
tion of the organization, was described in the PSAR for the 48 !
49 l 50 l
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l STP and was thoroughly reviewed by the NRC as well as EL&P
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and found to be acceptable as evidenced by the approval of this program in the NRC Safety Evaluation Report and the iesuance of the construction permits for the-STP in December 1975.
The B&R QA organization is very similar to that which in found in many engineering and construction companies cngaged in nuclear power plant activities.
Q. 18 Was this organization similar to those used on other projects with which you are familiar?
A. 18 (KMB):
Yes, the STP QA Program provided by B&R is entirely analogous to that found on most nuclear projects.
D; tails of the organizational structure vary from project to project, but no significant differences exist of which I am aware.
From the outset, the QA organization for STP has provided QA/QC services for design, procurement, and construc-tion activities supplied by B&R, with HL&P providing oversight 1
or surveillance activities in all of the' corresponding i
areas.
This arrangement is quite common.
Q. 19 At the time you first became involved in the QA Program at B&R, what was B&R's attitude toward quality?
A. 19 (KMB):
I first became involved in nuclear QA at.
B&R in 1974 in conjunction with B&R's construction activities i
at the Brunswick Steam Electric Station for Carolina Power &
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i Light Company.
This project was underway when the original L
QA/QC criteria (10 CFR 50, Appendix B) were issued which
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Z required a formal QA Program in compliance with these regula-tions.
A program had been established in compliance with 6i these regulations and was in effect at the Brunswick project.
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S-From my first involvement, I believe-that B&R's management 9
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10 had the proper attitude concerning nuclear QA/QC requirements, 11 12,
- and that our project personnel generally reflected this same
, 13 14 i attitude.
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Management's commitment to the importance of QA/QC on 17y' nuclear projects was expressed on many occasions to.its 13 personnel both at the Brunswick project, and at the Comanche 20 i 21 I Peak and the South Texas Projects, which were in the early 22 '
23 planning stages.
These expressions were designed to impress 24 i 25 :
upon pro]ect personnel that nuclear QA requirements are 26 l
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l especially stringent and should be fully complied with.
23 29 i Furthermore, in that period of the history of the nuclear 30 !
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industry, the QA/QC requirements were evolving quite rapidly.
We encountered problems in adding requirements in mid-stream 35 l and ensuring that personnel met these additional requirements.
34 36 '
As a result, B&R management was directly involved in these 37 38 !
projects and aware of the importance of an adequate QA/QC 39 i 40 i program.
As an example of B&R management's early recognition 41 i 42 i of the importance of the nuclear QA/QC project requirements, 43l!
44 a policy was established for STP in 1976 under which all new 45 l 46 l B&R employees at a nuclear project received a formal nuclear
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j,l QA orientation program.
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- ,r Q. 20 Describe the senior B&R management activities which evidenced their commitment to QA/QC in nuclear projects.
A. 20 (KMB):
The senior management of B&R has been involved in our QA activities from my earliest knowledge of our projects.
At the Brunswick station, our management, including senior officers and an executive vice president, attended meetings frequently with the client at the site to i
discuss specifically the status of our QA Program and the i
I ateps being taken to ensure that all requirements were met prior to the operating license.
l In October of 1973, the Executive Vice President of B&R l
G3tablished the QA Management Review Board (QAMRB) which was composed of senior management executives of B&R in order to provide an oversight of our QA programs for nuclear as well as fossil power plant projects and to report periodically to tha top management of the company.
The membership of this Board presently includes the Group Vice President of Power, all of the senior officers in the Power Group, a representa-tive from our Procurement Group and the Power Group QA Manager.
This Board.has met regularly since its establishment to receive reports from the QA Manager concerning the status.
of our QA program.
In addition to these periodic meetings, tha QAMRB members regularly receive a compendium of significant QA documents as an additional means of staying abreast of QA Program activities.
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}j An additional and important responsibility of the QAMRB 4!
has been an annual QA/QC Program review, that is performed 5l 6,
for the QAMRB by B&R management personnel with the assistance 7i 8-i of outside consultants, Management Analysis Company and 9;
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Southwest Research Institute.
The purpose of this review is 11 i 12 !
to determine the effectiveness of the overall QA Program in i
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the B&R Power Group.
These reviews have evaluated the B&R 15 t P wer Gr up QA Program including the STP.
The reviews are 16 17 l generally broken down according to the 18 QA criteria of 10 15 t 19 !
CFR 50, Appendix B, and are used by senior B&R executives to 20 i 21 ;
closely monitor areas of the B&R QA Program which require l
22 23 i special attention or corrective action.
The results of each 24 25 of these reviews are carefully evaluated and fully discussed
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at the QAMRB meetings; and for those findings where corrective 23 i 29 action is determined to be appropriate, management makes assignments to the affected B&R organirations and requires j
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written responses describing those corrective actions.
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34 i In addition, since the beginning of the project, the 35 :
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operating Committee of B&R has received an annual review of j
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the QA Program associated with the STP presented by the QA
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40 i Manager of the Power Group.
Beginning in September 2,9.80, 41 i 42 {
the operating Committee has received a briefing on the STP 43 :
y; QA program monthly.
Such activities demonstrate that the 45 i senior management of B&R is properly involved in the project 46 47 to ensure that sufficient resources are provided for the 48 l
49 conduct of the project in a timely fashion.
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-s Management policy concerning our dedication to full compliance of all quality requirements has been communicated to project personnel through written and verbal communications.
For example, we have had letters signed by senior company officials throughout the course of the Project stating the company policy of full compliance of all QA requirements, l
and these letters have been posted in visible locations at the site and in the Houston offices and have been incorporated in the Project QA manuals.
There have also been presentations by senior officials of the B&R Power Group to Project personnel stating our management policy.
For example, in the summer of 1979, J. G. Munisteri, the Group Vice President of the Power Division, spoke to all QA/QC personnel and construction i
supervision at the project site emphasizing our full commit-1 l
m;nt to strict compliance with all QA requirements.
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Finally, since the inception of the project, senior B&R l
management officials have made frequent visits to the STP site and have met and discussed project activities with a variety of Project personnel.
This has been in recognition of the importance of direct Project visibility and involve-m2nt by senior B&R management.
In late 1979 and early 1980,.
with the increased concerns raised about management of the B&R QA Program for STP, senior management visits to the site have been more frequent.
In my own case, since the beginning of 1980, I have spent a minimum of two to three days a month at the site.
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Q. 21 Please give some other examples of specific I
4l a
ns ta en by B&R Seni r Management w ch bdicated a 5
6l commitment to the STP Quality Assurance Program.
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S' A. 21 (KMB):
One example that comes to mind is a I!
10'i meeting held in early 1978 at which M. M. Fitch, Senior Vice 11 i 12 j President, Power Construction, met at the STP site with key
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construction and QA/QC supervisory personnel.
At this i
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meeting, Mr. Fitch emphasized senior management's requirement 17 I that all Project personnel fully comply with Project quality gg.
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requirements.
He further emphasized the need for professional-20 21 l ism in Construction /QC relationships.
22 23 i Another example of Senior Management's involvement in 24 '
25 >
assuring that friction between Construction and QA was
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,7 l minimized occurred in early 1979, when J. C. Bazor, the then 28 l 29 l newly appointed Vice President of Power Construction, held a 30 3.3 ;
meeting at the site with key supervisory personnel.
At this 32 '
meeting.. Mr. Ba=or reaffirmed the B&R management philosophy 33,
34 '
that B&R Management would not tolerate any circumstance in 3S i 36 which a B&R Construction employee acted unprofessionally, 37 !
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and that Management would not hesitate to dismiss any employee 39 '
40 I violating this policy.
41 l 42 l Q. 22 Please give some examples of steps taken by QA 43 '
44 Management prior to the NRC Show Cause Order which reflect 45 46 :
QA Management's effort to maintain an effective, and well-47 motivated Project QA/QC organization.
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1 A. 22 (IO!B) :
In the area of organization, the project t
QA organization was originally conceived along traditional lines that provided for QC inspection, vendor surveillance, and. support activities.
However, this organization has not b en static through the course of the project.
In 1976, we recognized';the need for increased quality cugineering support for QC Inspectors, and technically competent discipline engineers were added at the site.
In
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1978, a full-time vendor surveillance representative was located at the site to improve coordination between vendor curveillance and site operations.
In 1978, we added full-time echedulers to the Project QA organization to assist in planning and scheduling manpower, training and procedure rcquirements.
In 1978, we reassigned Quality Engineers and QC Inspectors on the basis of plant areas rather than technical disciplines in order to parallel the Construction organization and provide better coordination and mutual understanding.
In 1979, regional vendor surveillance offices were established l
to provide closer control of suppliers.
Finally, since the l
b ginning of the Project, QA Management has recognized the L
importance of adequately staffing the Project with experienced l
personnel and has conducted an ongoing nationwide recruiting l
1 campaign.
As a result, our QA Department manpower level has 1
increased from less than 100 in 1975, to more than 500 at
- )
present.
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,i In the ar(ea of QA employee re'lations, significant l
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4f improvements were initiated by QA Department Management in 5>
6l 1979 and early 1980 in recognition of the importance of 7I 8i regular management meetings, adequate pay and benefits, and 9
10 employee recognition, including monitoring and responding to 11 !
12 l individual employee concerns arising in the course of the 13 14,
Project.
Frequent meetings were held with Project personnel L5 '
16
- and QA Management to communicate policies and to get feedback 7' g l' from employees.
Although agreement was not always reached 7
i 13 l on each employee complaint, all cases were reviewed and 20 i
22li 21 evaluated.
23 '
Through the initiative of QA management, as the Project i
24 i 25 l progressed, better working conditions were created by provid-
'6 i
,/ j ing air conditioned field offices, additional field radios 23 i 29 and trucks, increased relocation benefits, overtime pay for 30 '
31 i salaried pers nnel, better QA tools, special visible recogni-32 !
tion of QA supervisors, and improved pay levels and policies.
33 -
34 I offsite recreational activities and civic projects were 35 i 36 j sponsored and encouraged such as softball games and community 37 i
38 I clean-up projects.
Written communication was provided 39 '
40 through information memos and bulletins, and company publi-41 -
42 j cations such as the Brownline, Brown-Newser, and Brownbuilder.
43pl In 1979 as concrete activities accelerated, management 45 '
46 l instituted a requirement that a minimun of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> be set
.7 l aside for each concrete preplacement inspection (or longer 48 I 49 l c t) '
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j if required) to preclude any construction activities s,uch as personnel and trucks s+2nM ng by that could create pressure en the Inspectors to hurry their work to release a pour.
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of course, normal management functions were performed cuch as regular personnel performance evaluations.
Inter-i discipline development, reassignments, and promotions were encouraged to improve personnel opportunity and growth.
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Finally, a number of actions were taken to improve I
mutual understanding and reduce friction between Construction and QA personnel.
For example,.uz June 1978, construction I
and inspection procedures were integrated to define and clarify operational interfaces, improve planning and schedul-t j
ing, and promote cooperation.
1.n August 1979, a Task Force was established by Engineering, Construction, and QA to
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clarify the intent of specification terms such as " flat",
" straight," "no free standing watar," and similar items l
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which require interpretation.
In 1977, a weld defect report-i I
ing system was established to 12nprove construction awareness r
of 'the nature of welding problems.
In 1978, in-process punch lists to note and control actions required prior to l
formal inspection steps were entablished.
These and many other actions were taken to facilitate daily operations by improved understanding and cooperations.
Q. 23 Please give some examples of steps taken by QA i
j Management prior to the NRC Show Cause Order which reflect i
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y QA Management's effort to assure proper QA/QC personnel 4f training.
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A. 23 (KMB):
In the area of personnel training, since s7 !
9l the inception of the Project, new employees have received a S-10 l presentation relative to orientation for nuclear projects 11 i
- I2 l which emphasizes the special nature and quality requirements L3 '
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for nuclear projects.
All QA personnel also attend overview L5 16 slide / tape presentations relative to nuclear Codes and l
Standards and quality records.
A study brochure supplements 13 I these presentations.
20 21 !
Since the beginning of the Project numerous diverse 22 23 i in-depth training courses have been presented for Construction, 24 !
25 '
Engineering, and QA personnel.
In addition to technical
'6' p{
training, operating procedures and procedural changes were 28 !
29 ;
covered.
Beginning in 1978, Construction and QA personnel 30 '
37 i attended joint training programs so as to develop common 32 ;
understanding and interpretations.
opportunities have been 33 ;
34 i created for interdiscipline cross training to broaden personnel 35 !
36 j opportunities and flexibility.
This training has also 37 1 38 encouraged development of less-skilled employees so that as 39 :
40 l performances of entry level Inspectors progressed, they 41 i 42 ;
could achieve higher levels of certification.
43 44 Various management training courses by B&R, outside 45 specialists, and video tape / programmed instruction have been 46 47 !
presented.
Again many of these courses were attended jointly 48 \\
49 !
n l
6 I
i by Construction and QA Supervisors so as to improve interrela-tionships and understandings.
Although training courses were frequent within B&R both ct the site and in Houston, additional professional develop-a ment was also encouraged by other means.
Included were such activities as outside technical training by ACI, ASNT, ASME, and other outside organizations; membership on technical c:mmittees of national societies; attendance at seminars and technical conferences; and participation in the Nuclear Plant Reliability System and the Coordinating Agency for Supplier Evaluations.
Q. 24 Describe E&P's involvement in the development and review of B&R's STP Quality Program.
A. 24
('DIB ) :
B&R's QA Program for STP is under the programmatic direction of E&P.
B&R's QA Program for the STP was initially described in writing as a part of the preparation for the STP PSAR.
This description was reviewed in detail by E&P and its comments were resolved to its satisfaction to ensure that B&R's program and E&P's program wore fully compatib,le.
At various times since the develop-m:nt of the original program, modifications to the program. -
concerning various procedures and detailed instructions hLve been made.
The QA procedures were submitted to EL&P for its review and comment prior to implementation.
E&P bcs performed a surveillance function over.all of the B&R QA s'
1-l 2,
Program activiti~es since initiation of the Project.
This oI 5j includes on-site surveillance activities, E&P vendor sur-6\\
7, veillance inspection personnel accompanying B&R vendor l
1i g
surveillance inspection personnel on shop inspections, joint 10 participation in audits and, of course, separate and indepen-11 Ul dent audits conducted by E&P of B&R's QA activities.
- 13 14 '
Monthly meetings on the QA programs have been held with E&P 15 16 for virtually the duration of the Project.
There is a 17,
lg continuing dialogue on nearly a daily basis between E&P's TS' 20 l STP QA Manager and B&R's Project personnel.
Audits which 2
are performed by B&R's Audit Group are discussed in exit 22,
23 '
critiques which E&P personnel often attend.
B&R has invited 24 '
25 i and E&P has attended the exit critiques of the NRC's Vendor 74 !
23 I Inspection Branch inspections of B&R's activities.
29.i Our standard practice at B&R on the STP has been to 30 '
- 31. ;
keep E&P fully informed of all activities and problems as 32 '
they arise on the Project.
E&P has taken a strong leader-33,
34 ship role, as is expected of the Licensee, and has provided 35,
36 i guidance and direction of the entire program through the 37 I i
38 life of the Project.
E&P has performed audits of the B&R 39 :
40 ;
program by independent auditing groups separate from,i.ts STP 41 I 42,
QA organiration since the inception of the Project.
These 43 '
44 l audits have been thorough and have pointed out areas where 45 our program could be improved and the improvements indicated 3
'I !
have been implemented.
48 49 a-i S. '
- 2.3 -
... /
Q. 25 For the perio'd between the issuance of the ct;nstruction permit in December 1975, and the NRC's special j
investigation in late 1979 and early 1980, what is your personal assessment of.the QA progran for STP?
A. 25 (KMB):
During this period, the B&R QA program and the HL&P Company QA program maintained surveillance and cuditing of the STP activities.
A number of deficiencies concerning implementation of procedures were discovered.
Inspection and surveillance personnel identified many indi-vidual items of nonconformance, such as components or materials which did not precisely meet specification requirements.
The deficiencies were corrected, as is evidenced by close-outs of nonconformance reports, corrective action requests, and cudit deficiency reports.
)
In my experience, the number of findings and the types j
of findings are representative of those found on most nuclear l
construction proje' cts.- B&R and HL&P had identified problem areas in which improvements had been made and others in j
which improvements were underway at the time of the NRC
- l special investigation.
Although you can never be completely ll sctisfied with your performance, on balance, I believe the,.
QA program for the Project was effective and that areas of nonconformance were identified and under control, although 1
pctterns of nonconformances were not always picked up as promptly as they should have been, especially in the welding crea.
.I
! o E
E.-
r s.
1;
-t j
one area where I believe we might have done a better 41 5;
j b is in trending deficiencies as they occurred on the 6[
Project.
Although informal trending was done, I believe we 7!
\\
8i should have had a more formal trending program to document 9I 10 i the recurrence of nonconformances.
Also, I believe we 11 '
I2 :
should have provided a more efficient document control and L3 '
14 retrieval system.
Although basically under control, on 15 '
16 occasions it took substantial time to locate and assemble 17
{g l documentation.
13 '
Q. 26 Please comment on the STP problems relating to 20 '
21 !
soils, concrete and welding, in light of your answers to the 22 23 !
preceding questions.
What do these problems reveal about 24 i a
25 the QA program?
What do they indicate about the overall I
,/ j structural integrity of the plant?
2E I 29 :
A. 26 A nuclear QA program requires that all defi-30 '
3r ciencies or deviations from project requirements be docu-32 mented as nonconforming conditions.
As I indicated earlier, 34 l many instances of nonconformance have occurred on STP just 35 36 i as they occur on any such project.
The vast majority of 37 l 38 i these deficiencies are of little safety significance and are 39 40 i corrected quite easily.
In other instances, significant 41,
42 :
deficiencies occurred at the Project, and were recogniced as 43 i 44 l being significant and were reported to the NRC.
The voids 45 I
.t 6,
f und in some complex concrete placements are an example of Y
jg such a deficiency.
In the placement of concrete in areas of 49 I YO l
1 extreme rebar congestion, steps were taken to avoid the creation of voids.
Unfortunately, due to the configuration of embedded steel and rebar, some voids did ocqur.
This has required additional precautions which have been taken to cvoid recurrence..In all cases, these voids were detected and have been repaired.
This is not an uncommon occurrence in placing concrete in situations such as I have described.
Furthermore, it is important not to lose perspective.
The concrete problems we encountered were not atypical and the structural strength of our concrete has been found to be quite acceptable.
Similarly, while We have had procedural I
i problems in the soils area - mainly due to misunderstandings l
or poor communications -
we should not lose sight of the findi_Ja of our Task Force as to the adequacy of our soil l
compaction work.
It is only in the area of welding where we l
l fell down.
We recognice this area of deficiency and are taking steps to repair existing deficient welds and to I
prevent recurrence of such problems in the future.
our welding problems at the site were attributable to a failure to insure that the many welding and inspection procedures we had on paper were fully and properly implemented.
Our welding program, as set out in those procedures, was in recordance with all Codes and standards and, if properly j
implemented, would have produced uniformly high quality l
wolds.
However, we now know that the. welding procedures l
l l
l I
~26-
- 7... *:,.. i
.w a v.
\\*
1:
2, were not always being fully implemented, and that our 5i Inspectors were unfortunately not always picking up failures 6l 7i in procedural implementation, and were not always performing close-enough inspections of the welds themselves to assure 10 (
Code compliance.
While it is unfortunate that these pro-g cedural and inspection deficiencies occurred, it is important 14 to point out that our QA auditing system did detect the LS 16 deficiencies and focus attention on the magnitude of the 17 1E I problem. The audit findings resulted in our stopping all 19 i 20 I safety-related welding in April 1980 pending a comprehensive 21 !
22 i reassessment and revamping of the welding program.
43 i gi We have taken rigorous steps to assure that all proce-25 i dures will be fully implemented and that welds will be 2? '
properly made, and.also to assure that when non-compliances 20 l 29 l do occur they will be immediately identified by QA.
We have 30 1 31 i taken steps to control the welding procedures and inspections, 32 i to retrain and requalify welders, and to recertify inspection 33l:
34 35 !
pers nnel to make sure that any deviations from the literal 36 l interpretation of code requirements are identified as discrep-37)(
38 ancies and the appropriate repairs made.
In addition, we have 39 i 40l created the position of STP welding Program Manager and staffed 41 ;
42 i this position with a highly qualified individual.
The Program 43 :
44 l Manager is charged with coordinating implementation of all 45 I p.
i welding program procedures.
Thus, quality welding will be 48 l 49 ;
$r 51,
i r
assured not only through a tighter QA Program, but also through better control'and coordination of welding procedures.
In the areas of safety related welding, concrete, and backfill, we have assembled special B&R/HL&P task forces, as i
l well as panels of experts from outside the Project to exten-1 cively investigate the adequacy and structural integrity of I
the work performed at the Project.
Their reports have l
cnncluded that the backfill, as placed, is entirely adequate 1
for the design requirements of this Project, and that in the cree of concrete, there is no reason to suspect any additional vaiding or substandard conditions associated with the struc-tural integrity of the concrete beyond those voids in complex areas which were identified previously.
Further, the repairs l
which have been made to those areas were found to be satis-1 fcctory to ensure the structural integrity of the concrete.
With regard to welding, our welding program has been strength-I cned substantially and reinspection and repair of previous l
wolding is underway.
Q. 27 How has EL&P kept itself knowledgeable about STP cctivities?
A. 27 HL&P kept itself' properly knowledgeable about cil aspects of STP activities by being an integral part of tho Project organization.
The vast amount of correspondence, 1
mooting minutes, and other Project documentation is evidence of this; they indicate daily involvement in the Project in l
l
~,,,...
r-
- 1. ;
2l all its aspects.
Outside of QA, E&P personnel are in residence in B&R engineering offices viewing on a day-to-day 6i basis the engineering work being performed.
Since November, 7i8!
1978 more than 90 E&P employees have been located with our 9:
10 l Project team in our Houston offices.
They participate in 11 l i
12 l our meetings and our day-to-day Project activities.
They 13 !
14 review, comment, approve, and make suggestions about those 15 16 activities.
In the construction area, more than 30 E&P
{
construction personnel are in residence at the site.
They 13 :
participate in meetings on a daily basis at various levels 20 21 of management and supervision.
They are fully aware of the 22 23 i status of the work.
They participate in the planning and 24 !
25 +
decision making process for the construction of the Project.
'6'
/- l In the QA area, as I have stated earlier, E&P is directly 28 i 29 involved through daily personal conversations, meetings at 30 -
3p; various levels, continuing surveillance activities, auditing activities, attendance at audit entrance and exit critiques, 34 '
and Project QA meetings between B&R and E&P.
There is a 35 <
36 !
variety of written correspondence that documents these many 37 i i
38
, activities.
E&P has at least 41 QA personnel at the site.
39 40 Q. 28 When individual physical disputes or other.
41 42 l serious site-level employee problems occurred among workers 43 \\
44 at the Project, was it usual for B&R Management to be aware 45 46 f such instances and to monitor and participate in the 47 '
resolution of these matters?
48 '
49 an l
.e.
.v.,.
A. 28 (KMB):
Serious disputes among workers that rise to the level of physical. abuse have been rare on the Project, and Management has made it clear that such behavior will not b3 tolerated.
However,. there have been isolated instances j
of disputes as discussed in detail in testimony by Messrs.
1 Warnick, Singleton and Wilson.
These have been known by both Houston and site QA Management, which have closely monitored or participated in the resolution of such matters.
This has also been the case with isolated record falsifi-i cntions, such as the PTL incident discussed by Mr. McKay in his testimony, where Management has been involved to assure that the responsible individual was immediately terminated and that the proper followup safety reviews were conducted.
B&R management will not hesitate to take prompt responsive action, including termination of employment where appropriate, cgainst employees who management finds have acted unprofession-l cily or dishonestly in the performance of their jcb responsi-l bilities.
The termination of Mr. Swayze in 1978 is another i
example of a sensitive issue which was closely monitored by i
l QA Management at the ite and in Houston, and other Executive l
B&R Management in Houston, to assure a fair and proper rcsolution of the matter.
In the case of the altercation between James Marshall i
i l
and Joe Barea that took place on June 30, 1977, which is
{
d scribed in Messrs. Singleton and Wilson's testimony, site i
i l
t 1-l 3 o
}
QA Management was fully aware of, and involved in, 'the 4
resolution of the matter, and Houston QA Management was kept 5
6i fully informed, from the time of the incident to final 7
8-resolution.
This was, considered to be a regrettable but 9l i
' 10 i isolated incident that was properly handled by Site Management.
11 i i
j I2 l Similarly,Iin the case of the physical exchange between
' L3 !
14 l Jerry Lacey and Gary May on March 7, 1979, swift action was 15 i 16 '
taken by site QA and Construction Management, and senior 17 l Houston QA Management closely followed the matter to assure 15 >
19 I that appropriate steps were taken at the site to react to-20 '
21 !
the physical exchange.
22 23 i When an allegation was made against Mr. Swayze in 1978 24 !
25 that he had solicited a bribe from a Construction Foreman,
,j this allegation was treated with the utmost seriousness by 28 l 29 i site and Houston Management. A comprehensive investigation was undertaken, including interviews with employees who 32 '
worked closely with the individuals involved. Senior officers, 33 34,
including the B&R Power Group Vice President, the Power 35 i 36 !
Group Senior Construction Manager, the Power Group QA Manager, 37 (
38 !
and a representative from the B&R General Counsel's Office, 39 i 40 j were directly involved in investigating the bribe allegation, 41 1 42 l in light of the seriousness and sensitivity of the charge.
43 44 It was this Senior level management group that decided to terminate Mr. Swayne after reviewing. employee statements and 47 l In consideration of Mr. Sway:e's refusal to fully cooperate 48 49 e,
e e f
h - - _ _ _.
_.__c.....,
in the investigation or to give a sworn statement in responsa
(
to the charge.
Q. 29 Was there concern within B&R management about allegations from Mr. Dan Swayze, that QC inspectors were bcing subjected to intimidation and harassment by construction parsonnel and were not performing their required inspections?
[
What was done to investigate the situation?
What were the rcsults and findings of these investigations?
f A. 29 (KMB):
It was not until March 1979 that B&R i
Management first became aware of allegations by Mr. Swayze that certain Civil QC Inspectors were involved in continuous card games and failed to perform required inspections in 1977.
Statements to this effect were first made in a deposi-l tion of Mr. Swayze taken on March 2, 1979, in conjunction l
with a lawsuit initiated by Mr. Swayze against B&R.
The i
icwsuit, which related to Mr. Swayze's termination from B&R on August 27, 1978, was dismissed with prejudice when Mr.
1
]
Swayze refused to sign his deposition.
Allegations about h
ll the card games also were made in interviews with Mr. Swayze l
I
]
which appeared on national television in October, 1979 and then again in May, 1980.
Finally, Mr. Swayze made statements about the alleged card games in his deposition in this proceeding taken on June 19, 1980.
There are numerous inconsistencies in those various statements by Mr. Swayze with respect to the time frame in l
I s
e
~
.g Li
- 2l 3
which these card games were alleged to have occurre.d, the I
identities of the alleged card players, the underlying 6
reasons for the card games, the percentage of time spent 7
8~!
each day playing cards, and the amount of inspection performed 9;
10 i by the alleged card players.
11 !
12 ';
Nonetheless, B&R and the NRC investigated Mr. Sway =e's 13 i 14 i allegations regarding card games and non-inspections.
After 15 16 Mr. Sway e's first allegation in March 1979, B&R QA Management 17 l gg interviewed the QC Inspectors who had been named by Mr.
Sway =e.
Although the Inspectors did play cards during their 21 l lunch hour and in other periods of low construction activity 22 '
23 I during late 1976 and early 1977, none of the Inspectors had 24 i 25 :
any knowledge of the extensive card games alleged to have
'6 :
7j occurred in 1977.
Furthermore, none of the Inspectors were 28 29,
aware-of any case in which QC Inspectors failed to properly 30 '
3tj inspect safety-related civil activities or in which QC 2!
f3 Inspectors signed inspection records only when requested to 34 !
do so by construction.
Our findings were confirmed by the 35 t 36 !
NRC in Inspection Report 79-14, dated October 16, 1979.
37 l 38 '
After Mr. Sway e made sweeping allegations in October 39 i 40 l 1979 about widespread card playing and non-inspections. by 41 ;
42 j Inspectors throughout 1977, B&R Senior Management directed 43 >
44 Mr. Warnick to review all civil inspection records for 1977 45 1 46 as a further means of investigating Mr. Sway e's allegations.
I 4f l This review demonstrated that civil nonconformance reporting 49 l q4
.I
~33-4 I
F l
~
\\
in 1977 correlated well with the level of civil construction cctivities during the year.
Of the 55 civil safety-related deficiency reports issued in 1977, 38 reports were issued by individuals alleged by Mr. Swayze to be card players, includ-ing 3 deficiency reports by Mr. Swayze himself.
It is 1
noteworthy that during most of 1977, Mr. Swayze was a Lead QC Inspector.
Lead Inspectors would not normslly be expected to sign inspection records.
Part of Mr. Swayze's allegations suggested that Q.C Inspectors were experiencing excessive pressure from Con-otruction personnel which amounted to harassment or intmi-dation of the QC Inspectors.
Prior to the NRC special investigation beginning in November 1979, B&R Management was cware of occasional incidents involving confrontations botween Construction and QC personnel.
Each of these isolated incidents were fully investigated by B&R Site and/or Houston Management, as indicated above.
Although such occurrences l
were taken seriously and'were fully discussed with HL&P Project management, they did not reflect a generic problem i
l of intimidation and harassment of QC Inspectors by construc-tion personnel.
l Q. 30 How and when did B&R become aware of the findings of the NRC's special investigation performed in late 1979?
What actions were taken by B&R Management to respond to this information?
How was this coordinated with HL&P?
i t.
--.....m
.[
I 1l 2.j' A. 30 (KMB):
During the last week of December 1979 y
4[
Mr. George Oprea, Executive Vice President of'E&P, met with 5
6' several representatives from B&R and other personnel from 7,
8-!
E&P to discuss information that had been related to Mr. Oprea 9l 10 ;
by the NRC Region IV.
It was during this meeting that I 11 !
12 l first became aware of the-types of finM ngs which we could
- 13 i 14 '
expect in the NRC's investigation report.
Beginning with 15 16 this meeting, we were kept informed by E&P of various gj concerns or findings identified by the NRC to them in meetings 19 !
or discussions of, their investigation.
B&R and E&P jointly 20 l 21 !
assembled a team of Project personnel to immediately begin 22 '
i 23 '
defining the responsive actions necessary and to develop l
24 !
l 25 l plans for implementing corrective acticus for any and all
'6' 7l findings as we were informed of them.
This Task Force 28 l 29 !
eff rt continued through the issuance of the NRC's report and the-Show Cause Order and the preparation of E&P's 32 l formalreshonseinJuly1980.
Some of its activities continue i
33 !
34 !
even today.
35 i 36 j That is, we, jointly with E&P, assembled a team and 37 '
33 made assignments to responsible individuals to respond to 39 !
40 l various items as they were identified.
Throughout this 41 i 42 l entire process, management of both E&P and B&R were ::ept 43 44
. informed on a frequent basis through formal meetings which 4
were held to discuss the status of the various items as well 47 i as informal. discussions, memoranda, etc.
The response to 48'!
I 49 l
~ 'i,
l
,-a.
e.
e 1
h the various items was a joint effort, as has been our practice through the entire history of the Project, whereby if an item required actions by only B&R, we would develop the proposed corrective action and submit that to HL&P for its review and comment and possible modification to reflect i
their views.
If the item only required!HL&P's action, in msst cases, B&R would be asked to review and comment on their response; and, of course, any items requiring joint efforts or joint actions would be approached and resolved in a joint fashion.
Q. 31 What was the reaction of top management at B&R to the NRC's enfo coment action taken in April 1980?
i A. 31 (KMB):
To say the least, we were surprised.
While we recognized that enforcement action is designed to spotlight deficiencies, we were dismayed because the Show
.Ccuse Order failed to place the STP program in a complete 1
l pcrspective.
For example, while the NRC's Order conceded that no items of major safety significance were found, the i,
Order did not mention (1) significant evidence of HL&P and i
B&R management awareness of the key problem areas; (2) i cignificant corrective action which had already been initi.ated; (3) the extent to which Project problems had, in fact, been identified by the Project QA program; and (4)-the overall l
quality of consr.ruction of the Project.
i i
i i
f 1,
'%l Q.32 Dr. Broom, more specifically, what actions were
~
>+
f taken by B&R to investigate the NRC finding regarding alleged 6'
intimidation and harassment of B&R QC Inspectors by Construc-7!
Sl tion personnel?
9 10 l i
A.32 (KMB):
This finding from the NRC special investiga-11 !
I2 i tion was first identified to me by Mr. Oprea in a meeting in 13 l 14 +
late December 1979.
I was extremely concerned about the NRC 15 16 l findina of undue pressure on QC Inspection personnel as was
{7 i the entire B&R and HL&P management team.
We took the matter 1
gl 13 very seriously.
I immediately undertook an investigation to 20 21 i determine whether we had a " harassment and intimidation" 22 l 23 !
problem as suggested by the NRC's finM ngs, and if we did 24 i 25 i have such a problem - to determine the causes and to implement
- ' 6,
/l the proper corrective action.
23 '
29 Based on the-information verbally obtained from 30 i
the NRC (written NRC findings were not available until April 31 32 1980), I personally directed members of my staff and an 33 ;
34 !
outside consultant to conduct extensive interviews with 35 !
36 !
Construction and QC personnel to determine whether there was 37 !
38 i a perception of harassment or intimidation of QC personnel 39 !
40 l by Construction.
In addition, Construction and QC pe,rsonnel 41 i 42 i responded on a confidential basis to a written survey ques-43 i 4.g l tionaire rAgarding employee attitudes and relationships.
45 The findings of this investigation, which was 46 48 l 47 concluded in January 1980, indicated to me that there was 1
49 i en l l
not a perception on the part of QC Inspectors that they were boing inhibited from performing their work due to intimidation or harassment by construction.
My investigation, however, confirmed that we had a morale problem among our QC personnel.
This problem involved the normal types of complaints from employees about pay and benefits as well as a concern about management support which indicated to me that our supervisory pcople within the QA/QC organization were not providing fcedback in the way of explanations of the resolution of mntters which inspectors had identified as nonconformances.
Although a deficiency identified by an Inspector would be resolved by Engineering or by rework, in many cases, the Inspector who identified the item was not kept fully informed F
[
of how the matter was resolved.
While, in theory, that may ba an acceptable way of operating; in fact, it does not work
[
- wall because the Inspector can lose confidence in his manage-m::nt, can lose sight of the consequences of his inspection, and could becomer concerned that matters were not being i
j, rasolved satisfactorily.
These kinds of complaints by QC Inspectors were l
not new to me.
We had heard similar concerns expressed by,.
individual Inspectors from time to time, as Messrs. Warnick i
i and Singleton explain in their testimony.
Furthermore, I
Management had taken steps prior to January 1980 to address iij these kinds of concerns.
Examples are given in Answer 22 l
h
! i l
. ? R *
~
~
L!
'Z!
~
'above.
Nonetheless, my investigation in January 1980 con-4 firmed that additional Management attention to QC morale 5,i 6I problems was necessary.
7 !
S' Q.33 What steps were taken by B&R Management beginning 9
' IQ l in January 1980 to address QC Inspectors morale problems and 11 l 12,i to -improve communications between QC and Construction?
I 13 [
A.33 (KMB):
Even before my investigation ~was concluded, g4 1.51 we held a meeting at the jobsite on January 4, 1980, with 16 4 all QA/QC personnel, together with Construction Supervision.
19 !
This was held as part of the "9 Point Action Plan" submitted 20 21 22 l by HL&P to the NRC in late December 1979, as described in 23 i Mr. Frazar's testimony in this proceeding.
24 l 23 ;
At this meeting, Project m'anagement and QA/QC eq !
management addressed the subject of resolution of differences i
23 i 2g !
f pinion between inspection personnel and construction f
personnel and other matters.
The intent of this presentation 33l' was to emphasize to everyone that we would not tolerate 32 34 l unprofessional behavior by Construction or QC personnel, 35 I 36 l that they each had important roles to play and that there 37 i 38 I were management teams that were expected to resolve matters 39 I 40 l that might be in dispute.
Unfortunately, this presentation 47 !
i 4j j became the subject of concern to NRC personnel who felt that 43 I gi cost and schedule were overemphasized to our QA/QC inspection l
45 personnel.
I reviewed that brochure before it was presented 46
'I to the Project personnel, and I did not read that concern 48 l l
49 i I
I J
t I
t I
i
-[
=
l a
I into the presentation., My investigation subsequently showed o
I that our Inspectors did not feel cost and schedule were
[
overeinphasized.
However, our reaction was that if the NRC perceived it in that way, then our personnel might have parcei' red it in the same fashion.
In any event, pursuant to the Show Cause Order, we retracted that presentation and held another presentation at which we made abundantly clear that QA/QC personnel are expected to perform their function free from concerns about cost and schedule.
This subsequent presentation at the Site was made by W. M. Rice who heads
,i the Power Group.
J A number of other steps were taken by B&R Management btgiming in January 1980 to address concerns in this area.
Examples of the actions taken are:
I held a meeting in January 1980 at which the QA j
Manager and I impressed upon our QC Supervisors 1
the need for attention to human relations and to personal discussion between supervisors and inspec-I tion personnel to ensure that full-feedback in this regard was occurring.
We instructed all QC I
I Supervisors to hold meetings with their Inspecto,rs L
at least weekly.
A complete reevaluation of the B&R salary adminis-l l
tration program for QA/QC personnel was conducted i
j under my direction during January-February 1980, i
i i
i 4
I l
g..
p
,7
.c i
L[
I!-
3~ '
and a revised QC salary administration program was 4
5l implemented on March 30, 1980.
Care was taken to 6\\
7i ensure fair and equitable compensation for QA/QC L;
personnel.
The B&R Project QA/QC organization was reevaluated 12 i during January-February 1980, and in March.1980, l
13 !
14 revisions to the organization were implemented L5 L6 ;
including an upgraded reclassification of QC 17 l ig !
supervisory personnel to provide equal stature L9 i 20 with their Construction counterparts.
bl B&R Project management has issued a procedure, 42 ;
Ul STP-PGM-02, " Procedure for Resolving Disputes 24 i 2C j.
Between Construction.and QA/QC Personnel," rev. O, 26 2~
January 7, 1980, which clearly defines a step by 2. i, 29 i step process whereby any differences of opinion 30 l 31 [
between construction and QC personnel are resolved 32 !
23 l through the use of successive levels of super-35 l vision.in order to eliminate confrontations which 34 36 '
37 could result in harassment or intimidation.
The 38 procedure has been discussed in indoctrination i
39 !
40 !
sessions for Construction supervision and QA/QC 41 !
42 l personnel.
43 l g;
In January 1980, the position of B&R Assistant QA 45 l yl Department Manager was abolished, thereby shortening 6
.48 j 49 20 '
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)
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the communication chain between site QC personnel and top QA management to facilitate communication and resolution of problems.
On February ~15-16 and February 22-23, 1980, a formal training seminar on employee motivation, human relations, and supervisory skills was held for Construction and QA/QC supervision.
This program was conducted by professors in organiza-tional behavior management from the University of Houston.
During March 1980, a meeting was held for B&R QA/QC personnel in which B&R Power Group Management and QA Department Management discussed the B&R open-door policy for all employees to express concerns as to any aspect of the STP operation or his personal treatment as an employee.
Dedication to achieving quality objectives was emphasized.
In March 1980, "QA Bulletins" were instituted throughout the QA/QC department, including all site'B&R QA/QC personnel, to provide better under-st=nM ng of overall activities, capabilities and,,
y support within the department.
The objective was to improve individual understanding of the inter-dependence of personnel in all Project quality related activities.
-sz-
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On March 27, 1980, the B&R Project General Manager v,
5 issued a statamant reiterating the mandate that 6!
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7i Project procedures, specifications and drawings be c!
[
rigorously followed.
- O(I gy A program of regular refresher training of B&R Construction and QA/QC personnel in Project proce-u.
14 '
dures has been instituted to ensure bettar under-IS i 15 i standing of procedures governing their work.
17 i 15 l A complete review of B&R QA/QC personnel qualifi-1S !
20 l cations and recertification of those personnel, 2]'!
where necessary, was completed during January-April 2
23 l 1980, to eliminate any doubt as to whether QA/QC 24 23 personnel are properly qualified.
26 f,_,
Extra radios have been provided to B&R QA/QC i
29 i personne.L and E&P site surveillance personnel to 30 i improve radio communication about field activities.
31 l :
32 i 33 l!
These radios increase communication within B&R and 34 33 j between an&P and B&a Construction and QA/QC personnel.
37 l 36 On May 8-9, 1980, B&R QA management conducted 38 >
meetings with site QC Supervisors to review NRC 39 40 Report Number 79-19.
B&R QA management will 4;
42 continue to provide additional perspective on 43 4.;
problems, the need for better communications and 45 4g proper support of inspection personnel.
,(
48 49 i 50 '
51 I
. l
s,..
a
~
In May 1980, a supe'rvisory skills course was
(]
initiated for first-line QA/QC supervision.
A course was obtained from Practical Management Associates and encompasses necessary supervisory skills, and diagnosis of causes of personnel problems.
In addition to these specific responsive actions, B&R management has accomplished other basic QA program improve-ments in 1980 and this year, which are discussed in Mr.
Vurpillat's testimony.
Q.34 Are there indications that QC Inspector. morale has improved as a result of management actions taken by B&R since January 1980?
A.34 (KMB):
Yes.
As Mr. Vurpillat indicates in his
[
tsstimony, B&R and its consultant have found that our efforts have substantially reduced the previous QA/QC management concerns expressed by some of the Inspectors.
While we are 1
of course encouraged by the apparent attitude improvements, wa understand the importance of fully and effectively imple-m2nting our program and staying alert for any signs of morale problems, and we will do so.
Q. 35 Mr. Vurpillat, describe the major changes in B&R's QA program since the Show Cause Order.
A. 35 (RJV):
As reflected in HL&P's response to the Show Cause Order, improvements to the QA program for STP L
.a-.--
1, ;
1V F
were identified in a number of major areas.
Among the
+4 5
significant ' changes made in the B&R QA program implementation i
6 7
are the following:
9\\
l.
Procedures have been clarified and simplified down
{O to the job level.
In this area, B&R has recognized El the need for improved STP procedures to facilitate u,
- 14 !
ease of compliance and to ensure consistency.
'L5 !
'16 l Significant rewriting of procedures was begun in 17 i lg l 1979 and has been accelerated since.
~19 l gg ;
Procedural revisions have been implemented to 21 l 22 j incorporate applicable criteria in the text of the 23 i procedure rather than incorporating them by reference.
24 l 25 l In addition, constructiog procedures are being
- 26.1
- 2' revised to include more specifics.
These revisions
- 2 l
29 I are intended to. remove the need for subjective 30 l 31 l tnterpretations by field personnel, and will
- 32 '
33 simplify and make more consistent both field 34
- 35 i e nstru d ens and Qc inspe d ons.
Third, con-
- 36 l struction QA Procedures currently are being improved 37 !
38 I so that the subject areas contained in each of the 39 40 10 CFR Part 50, Appendix B Criteria will be, drawn
43
, 4.g For ease of identification, the procedure numbers
'45 4g will correspond to appropriate criteria numbers.
~4
- 48 l
- 49 l 50 '
5 11
- . ;...
- _..., L. -
- p...,.
s Finally, B&R has developed a more efficient O
/
process for making these procedura.1, changes by requiring responsible STP personnel to obtain input from all organizations whose activities will be affected by the new or revised procedures.
For example, a QAP addressing the manner in which nonconformances are to be resolved must be reviewed by B&R Construction, Engineering, Materials Manage-ment and Project Manaiement personnel to ensure J
consistency within each organization's program.
In addition, all of these new or revised program procedures are submitted to HL&P for review and comments before final. implementation.
2.
An improved system for documenting and resolving non-conforming conditions has been developed.
Detailed trend analysis and data analysis proce-dures have been developed and implemented in an attempt to better provide for early detection and resolution of potential weaknesses and recurring problems.
3.
Training and indoctrination has been upgraded for,
personnel at all levels.
This training and indoctri-nation relates to quality related tasks with special emphasis on the projec't goals of reliability and safety, quality first, and "do it right the first time." l
j
.... ~
a r.
.e.,.
- i 1l 2.!
B&R has retained the Quality College consulting 4,
5i firm headed by Philip Crosby, a noted QA consultant.
6i 7i Under Mr. Crosbys guidance, a formalized Quality A;
.i Improvement' Program.has been established and 10 i gy j sem3.nars on elements of a good QA program have been attended by over 100 B&R Project Management
'14 and QA/QC management personnel, as well as by 15 ;:
15 i senior management personnel from both B&R and 17 i 15 HL&P.
This Quality Improvement Program is a 19,
20 :
long-term endeavor, and ultimately will cover all 21 22,
aspects of the QA Program at STP, including Pur-chasing, Engineering, Construction, and QA/QC.
25 ;
4.
Stronger system controls have been initiated and 26.;
~
are reflected in procedures which assure that
.c 7
29 quality-related activities are initiated, controlled, 30 31 l and properly documented.
B&R has developed an 32 i 33 j Inspection Planning Program to formalize the 34 1 35 l existing inspection plans containedin the construc-36 37 tion procedures.
This program will ensure that 38 the quality-related activities are adequately 39 40 planned,. performed as required, reviewed, evaluated, 41.
42 '
documented and verified--all in the proper sequence.
43 4.g l S.
The system of audits on the Project has been 45 improved to better verify adherence to procedures g
y and to identify deficiencies for resolution at the 49 l appropriate level of management.
50 5;,
i l d
)
i 1
I s
B&R and EL&P regularly perform audits which j
ensure that the QA Program commitments for STP continue to be implemented in conformance with all applicable requirements.
First, B&R conducts audits of its QA Program activities at least annually, and more often if necessary.
Similar audits of B&R's QA Program are performed at least annually by HL&P, and where appropriate, B&R and HL&P may perform joint audits.
Audit Reports are distributed to B&R and HL&P management as well as to the management of the audited organization, and corrective action is taken where appropriate.
In addition to these B&R and BL&P audits, the QAMRB directs an annual review of the B&R Power Group Program, including STP.
This comprehensive review is performed with the assistance of outside consultants.
Reports are reviewed and discussed by all QAMRB members.
If unresolved items are identified in the reports, the QAMRB, where it deems appropriate, assigns particular organizations within B&R to close out these items.
Written i
reports from these organizations which document l
the corrective action taken for closecut are then i
presented to and reviewed by the QAMRB.
l 4
y, s
Ll 2l' 3i 6.
Visibility of and active participation by upper 4l
$i management in QA/QC activities have been increased.
6i 7j Since September 1980, B&R's long-established r
3l
_. 9j QAMEB, composed of B&R Power Group senior manage-Nf ment er.ecutives, has held monthly meetings at the a.1 Ul STP site which HL&P management personnel have 13 ;
14 !
attended.
The Board's activities have been dis-Li i
16 :
cussed in prior testimony.
In addition to these 17 !
ig l QAMRB meetings, there have long been separate is !
20 i m nthly Project review meetings held jointly by 21
- 22l, B&R and EL&P.
At these meetings, attended by 23 f officers of the B&R Power Group and senior EL&P 24 !
25 '
Project management personnel, general Project QA 16.
.7 !
issues are discussed.
23 i 29 l On a weekly basis there are QA action item 30 '
31 l meetings, attended by the B&R Project QA Manager, 32 !
~
the grM Project QA Manager and others, if necessary.
33 l 34 '
35.I Discussions at these meetings focus on unresolved 36 l problems identified through HL&P site surveillance 37 i l
38 i activities.
B&R personnel develop and implement 39 !
40 l corrective' actions which must be reviewed-and 41 I 42 i approved by HL&P before final closecut of the 43 I
y problems.
In addition, the HL&P Project QA Super-45 visor and the B&R Project QA Manager meet at least
. 47 l weekly to discuss QA related activities.
- Finally, 48 l 49 i
'1
.L i.
1
l
.a, S
HL&P QA personnel in each discipline observe B&R QC Inspectors and Lead Inspectors on a daily i
basis.
In addition, since September 1980, I have
~
reported each month to the B&R Operating Committee regarding the status of the-QA/QC Program for the STP.
In addition to the above, changes in key personnel and reassignments have been made.
B&R has accelerated earlier initiatives to strengthen and reorganize its QA management tsam at STP.
B&R has made these personnel and organiza-tional changes by recruiting highly qualified, experienced personnel from the outside, reassigning home office personnel from 'the B&R Power Group QA staff to the STP team, relocating supervisory personnel from Houston to the STP site to facili-tate prompt decisions and problem resolutions, and reorganiz-ing the QA management staff to increase direct involvement by middle and upper level management in the STP QA process.
In my judgment the procedural changes and the increased management attention are both very important.
But most important of all has been the significant qualitative improve-m:nt in the personnel assigned to manage and carry out the QA function.
We now have an outst e M ng team of qualified and dedicated supervisory QA personnel.
. n
' y * '~,
1i 2.P In about December 1979, the Project QA Manager moved r
,+f 5l 6l' onto the STP site full-time to facilitate and speed responses 7l to problems.
He also began reporting directly to the B&R
/
Power Group QA Manager, instead of reporting through the
{O Assistant Manager, to facilitate prompt action by higher U!
levels of QA management.
Because of these changes, QA 13 !
14 Management for STP is now centered at the site where it can Ui 16 ;
exercise direct control over daily STP activities.
In 17 ;
1g ',
addition, lines of communication have been shortened between I
13 l 20 ;
STP QA Management and B&R Power Group QA Management.
21 I 22 l In mid-summer 1980, W. J. Friedrich, a QA consultant, 23 !
was temporarily assigned to STP as B&R Project QA Manager.
24 l 23 Mr. Friedrich's prior experience includes eight years as a 25 J site QA Manager at various nuclear plants and twelve years 2o 29 of additional QA experience in the aerospace industry.
30 !
31 i 2.
I was then hired in August 1980 as Power Group QA 32 !
33 ;
Manager to provide permanent Power Group QA management and 34 supervision.
I replaced Dr. Knox Broom, Senior Vice President 35 36 of the B&R Power Group, who had filled the position on an 37 38 interim basis.
39 l 40 I In addition to changes in QA Management, changes,were
- 41 l 42 I also taking place in the Quality Engineering area.
Until 43
' 4.g about October 1979, the B&R Houston Power Group QE staff had
!45 3
been spending about 50% of their time on STP and the rest of I
- I their time on various other Power Group QA projects.
In 48 49 00 51
...s
- e n.
October 1979, the B&R Power Group QE staff in Houston begah
]
d; voting virtually full time to QE activities to STP.
" In late December 1979, Mr. Gordon Purdy was transferred by B&R from Houston to the STP site to assist the Project QA Manager, and in May 1980, the function began reporting directly to the Project QA Manager instead of to the Power Group QA Manager.
In January 1980, Mr. Purdy moved six Quality Engineers from the Houston Power Group QE team to the site, to supplement the existing QE staff and to speed the QE decision-making process.
Since that time, the QE etaff at the STP site has been augmented in all disciplines with additional qualified personnel.
In May 1980, Mr. Don Harris, a QA consultant, was assigned to work with Mr. Purdy in supervising all QE activi-ties at STP.
Mr. Harris' prior experience includes nine yaars in the nuclear industry as a QE ' supervisor and QA manager, and fourteen years as a quality engineer in the acrospace industry.
Moreover, the interface between B&R and RTM has been strengthened.
Beginning with the HL&P's review and approval of B&R's initial QA Program for STP, HL&P has maintained control over the Program, and in so doing has continually interacted with B&R at all levels of management.
BL&P l
rcviews and comments on all procedural changes before imple-m;ntation.
HL&P also performs a continual surveillance of
~52-
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- 2. -
2 h all B&R QA Program activities, incluvi.ug activities at the 0
I 5
STP site, in Houston, and vendor su:-> sillance shop inspections.
6 7
B&R QA Project documents such as vendor surveillance reports, nonconformance reports and audit reports routinely are
~~O
'i presented to HL&P for review and appropriate action.
In g
12 addition, HL&P not only participates jointly with B&R in 13 14 !
certain QA audits, but conducts its own independent audits 15 l 16 ;
of B&R QA activities.
Audits patrformed by B&R Audit Group
'17 i lg !
are discussed in exit critiques which HL&P personnel often 19 !
20,
attend.
~ 23. I 22 !
In sum, the interface between the two companies concern-23 i ing B&R's QA Program has always been and continues to be 24 25 extensive.
IS !
Q. 36 Are there indications that these program changes 2a l 29 l have in fact remedied problems identified in the Show cause 30 !
32, ;
Order?
32 l A. 36 (RJV):
Yes.
First of all, programmatic changes 33 34 have been made in the areas of soils, concrete and welding,
.35 36 l and after a complete review by'the NRC, restart of the 37 1 38 !
activities that had been stopped has occurred and they are
-39 !
- 40 i being carried out well.
Second, as a result of the s. alary, 41 42 ;
personnel and organizational changes made by B&R, there has 43 i 4.g j been a marked improvement in the overall morale of personnel
'45l at the STP site.
The same conclusion has been communicated y
to us by the NRC at the August 19, 1980 public meeting.
48 49 !
This conclusion has also been reaffirmed on two separate 50 '
51 i
~53-
follow-up evaluations by our consultant.
Employees are j
asking questions of their supervisors more frequently, cupervisors and management personnel are taking more time to explain decisions to QC Inspectors, and disagreements between Construction and QA/QC personnel are being resolved more i
expeditiously.
I Finally, under the newly revised and integrated quality construction procedures, construction and inspection activi-ties conducted in the areas of welding and concrete have proved to be easier to understand and to perform.
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