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UNITED STATES OF AMERICA N
l NUCLEAR REGULATORY COMMISSION T,
S, 9'l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 10 i
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In the Matter of:
5 14 5
15 HOUSTON LIGHTING & POWER 5
Docket Nos. 50-4980L 16 COMPANY, ET AL.
5 50-4990L 5
17 l (South Texas Project, 5
ig 19 l Units 1 & 2) 5 20 i 5
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22 23 TESTIMONY ON BEHALF OF HOUSTON LIGHTING & POWER COMPANY, ET AL.
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OF
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(7 MR. JEROME H. GOLDBERG i
13 l MR. RICHARD A.
FRAZAR
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42 l HOUSTON LIGHTING & POWER COMPANY'S CURRENT MANAGEMENT OF THE SOUTH TEXAS PROJECT 43l
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UNITED STATES OF AMERICA j
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NUCLEAR REGULATORY COMMISSION I
l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l
In the Matter of:
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HOUSTON LIGHTING & POWER 5
Docket Nos. 50-4980L COMPANY, ET AL.
5 50-4990L i
5 (South Texas Project, 5
l Units 1 & 2) 5 5
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APPLIC..WIS ' TESTIMONY ON CURRENT MANAGEMENT OF THE SOUTH TEXAS PROJECT l
t The following is testimony presented on behalf of i
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Houston Lighting & Power Company, et al. (Applicants) on I
Houston Lighting & Power Company (HL&P) management of the
,l overall project activities of the South Texas Project (STP).
The panel of witnesses presenting this testimony consists of LI; j
Mr. Jerome H. Goldberg and Mr. Richard A.
Frazar.
The i
j-testimony consists of the following segments:
1.
Mr. Jerome H. Goldberg with respect to HL&P's organization and staff resources for management of the I
design and construction of the STP and how HL&P is fulfilling I
its management responsibilities.
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Mr. Richard A.
Frazar with respect to HL&P's 3i 7
organization and staff resources for management and implemen-8 tation of its Qi responsibilities relating to design and 9,
construction, and how those responsibilities are being 3
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properly discharged.
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TESTIMONY OF JEROME H.
GOLDBERG ON THE CURRENT MANAGEMENT OF STP Q. 1 State your name and current employment.
A.
1 Jerome H. Goldberg.
I am Vice President, Nuclear Engineering and Construction, of Houston Lighting & Power Company (HL&P).
Q. 2 Describe your professional experience and educa-r tional background.
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A.
2 I received a Bachelor of Science degree in Marine Engineering from the U.S. Merchants Marine Academy in 1953 and a Master of Science degree in Nuclear Engineering from Marsachusetts Institute of Technology in 1960.
I joined HL&P as Vice President, Nuclear Engineering '
cnd Construction in October 1980 where I have responsibility j
for engineering and construction of the South Texas Project (STP) and HL&P's planned Allens Creek faci [ity.
l From 1971 until October 1980 I was employed by Stone &
W;bster, where I began as a nuclear engineer and was promoted l
to positions of increasing management responsibility up to tha position of Vice President and Deputy Director of Construc-I tion.
During the course of my employment with Stone &
l Uabster I also served as Project Engineer and Project Manager I
of the Beaver Valley I Nuclear Project and as Chief Engineer f
of the Engineering Mechanics Division.
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Prior to joining Stone & Webster, I was employed from 5l 6i 1955 to 1971 at the Quincy, Massachusetts ship building yard 7I g
in various positions involving engineering, design, construc-I tion and fueling of nuclear surface warships and submarines.
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11 I became the Nuclear Construction Manager and was responsible 12 l 13 l for all nuclear construction activities associated with four 14 '
15 l submarines built at the Quincy facility.
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17 i I served on active duty in the U.S. Navy from 1953 15 '
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to 1955.
20 I am a member of the American Nuclear Society and a 21 l 22 23 l registered professional engineer in seven states:
24 l New York, Pennsylvania, Rhode Island, California, Virginia 25 26 and Texas.
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28 Q. 3 What has been your involvement on the STP?
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A.
3 Since joining HL&P in late October 1980, I have 31 '
32 j been responsible for the management of STP and have supervised 33 i 34 l the activities of the STP Project Manager and his staff for 35 !
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design, engineering and construction.
concurrently, I have 3I been providing direction for the continued upgrading of HL&P 38 33 !
staff qualifications and administrative and technical ~proce-
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dures associated with the management of STP engineering, 42 '
43 t design and construction.
44 49 Q. 4 What is the purpose of your testimony?
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4 The purpose of my testimony is to describe how HL&P is currently managing the engineering, design and conatruction of STP, and to explain the bases for my opinion that HL&P is fulfilling its management responsibilities in full compliance with applicable requirements and standards of professional competence.
Q. 5 What is EL&P's role in the management of STP?
A.
5 Under the Participation Agreement among the co-cwners of this Project, HL&P's responsibilities include mnnagement of engineering, design, construction and operation o f STP.
HL&P administers the contract with the architect-cngineer-constructor, Brown & Root, Inc. (B&R) and the contract with Westinghouse, the company which is supplying tha nuclear steam supply system.
As is often the case with nuclear plant construction contracts, these contractors provide engineering, design, procurement, f abrication, conctruction and quality assurance (QA) services for the cctivities within the scope of their respective contracts.
A0 the Project manager, EL&P bears the responsibility for cocing that those services are properly performed in accordance with applicable contractual requirements and the commitments to the Nuclear Regulatory Commission, as set forth in the Safety Analysis Report.
Q. 6 How does HL&P make sure that its contractors parform adequately?
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A.
6 To carry out its responsibilities, HL&P has 5;
6i assembled a professional staff to oversee the work of the 7
contractors and provide the necessary direction to them.
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'I HL&P's Executive Vice President, George W. Oprea, Jr.,
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charge of this effort.
As shown in the attached organization 13 ;
chart (Attachment No. 1 to this testimony), Richard A.
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Frazar, the QA Manager for the STP, and I, as Vice President -
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Nuclear Engineering and Construction, report directly to Mr.
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19 l Oprea.
The STP Project Manager, David Barker, reports to 20 t He is responsible for engineering, construction, procure-me.
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and schedule of the Project.
Mr. Barker has a ment, cost, 23 24 staff of 230 personnel that' comprise HL&P's Project Management 25,
25 team.
I meet frequently with Mr. Barker and his key project 27 i 28 i team members, and together we review engineering and construc-29 30 tion management issues related to STP.
HL&P's staff is 31 '
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physically located at the engineering and design offices of 33 '
34 B&R, the architect, engineer and constructor, as well as at 35 the construction site.
This places our staff in direct 36 contact with both the work and the contractor's team respon-39 sible for performing the work.
40 l 41 i Q. 7 Is Quality Assurance a part of the HL&P Project 42 43 Management team?
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A.
7 No.
As shown by the QA Department organization 46 47 chart (Attachment No. 1 to Mr. Fra:ar's testimony), the QA 48 i
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6 To carry out its responsibilities, HL&P has 5i 6!
assembled a professional staff to oversee the work of the 7
c ntractors and provide the necessary direction to them.
8
'i HL&P's Executive Vice President, George W. Oprea, Jr.,
is in 10 11 charge of this effort.
As shown in the attached organization 12 13,
chart (Attachment No. 1 to this testimony), Richard A.
14 13 l Frazar, the QA Manager for the STP, and I, as Vice President -
15,
17 i Nuclear Engineering and Construction, report directly to Mr.
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Oprea.
The STP Project Manager, David Barker, reports to 20 1 He is responsible for engineering, construction, procure-me.
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22 ment, cost, and schedule of the Project.
Mr. Barker has a 24 '
staff of 230 personnel that ccmprise HL&P's Project Management 25 26 !
team.
I meet frequently with Mr. Barker and his key project 27 l 28 l team members, and together we review engineering and construc-29 30 tion management issues related to STP.
HL&P's staff is 31 l 32 ;
physically located at the engineering and design offices of 33 l 34 l B&R, the architect, engineer and constructor, as well as at 35 I the construction site.
This places our staff in direct 36 j contact with both the work and the contractor's team respon-39 !
sible for performing the work.
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Q. 7 Is Quality Assurance a part of the HL&P Project 42 i
43 Management team?
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A.
7 No.
As shown by the QA Department organization 46 47 chart (Attachment No. 1 to Mr. Fra:ar's testimony), the QA 48 i
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Manager on the STP reports directly to the Executive Vice Prcsident.
There is also a separate HL&P corporate QA group that has offices in Houston, and its manager also reports directly to the Executive Vice President.
Q. 8 How is the Project Management team organired?
A.
8 As shown in the Project organiration chart (Attach-m:nt No. 2 to this testimony), reporting to Mr. Barker, the FrCject Manager are Joseph 3riskin, the Manager, Houston Cperations, and Leon English, the Project site Manager.
Thcy are responsible, respectively, for the Houston office and on-site portions of the Project team.
Mr. Briskin, the M: nager, Houston Operations, is responsible,for engineering, procurement, project control services, accounting and project t
cdminis tration.
The persons reporting to him include the
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Project Engineering Manager, the Project Control Manager, tha Project Purchasing Manager and the Project Controller.
Mr. English, the Project Site Manager, directs the cn-site efforts of HL&P and its prime contractors in the i
l creas o f construction, site purchasing, security, startup, cccounting, construction control and site engineering.
R: porting to him are the Construction Superintendent, the i
Construction Control Supervisor, the Supervising Project Engineer, the General Supervisor STP Accounting, and the l
Startup Manager.
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The total staffing for the Projec-Management team 5:
6l includes 230 HL&P employees of whom about 195 are profes-7 g
sional employees.
This does not, of course, include the QA I
staff or the plant operations personnel.
g 11 Q. 9 How do you stay in touch with Messrs. Barker, 12 13 Briskin, and English?
14 13 A. 9 I am in touch with Mr. Barker almost on a daily 16,
17 basis regarding a variety of matters.
In addition, I attend li !
19 j the Project Review Meetings and also the B&R Quality Assurance 30 '
Management Review Board Meetings which are held at the site 21,
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n a m nthly basis.
24 I My contacts with Mr. Briskin and Mr. English are through 25,
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Mr. Barker on an organizational basis.
However, I meet with 47 (
23 i them directly on a case-by-case basis whenever the need 29 !
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arises.
31 1 32 l Q. 10 Describe the qualifications of HL&P's Project 33 !
34 Engineering group for STP.
33 36 j A.
10 HL&P's Project Engineering Manager has a staff 3f of 50 engineers.
They review analyses, designs and specifi-39 !
cations.
In addition, there is a seven-man licensing and 40 41 ;
technical staff reporting directly to Mr. D.trker that is 42 !
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responsible for providing the licensing interface with the 44 l
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NRC.
The 57 full-time members in these two technical support 46
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t grcups have substantial (over 265 man-years) nuclear experi-cnco.
Another 40 individuals provide part-time support.
Tcchnical support staff are located at both the B&R Houston offices and at the STP site.
The qualifications of some of the key individuals in cur management organization are:
(1)
The Project Manager, Mr. David Barker, has a Masters d gree in nuclear engineering and 16 years experience in various areas of the design, maintenance, testing, QA, construction and management of nuclear projects.
(2)
The Manager, Houston Operations, Mr. Joseph Briskin, hcs over 20 years of' experience in power plant project mencgement, including 10 years related to nuclear power plcnt construction.
(3)
The Site Manager, Mr. Leon English, has over 29 l
yocrs experience in power plant construction management including 12 years related to nuclear power plant construction.
(4)
The Supervising Engineer-Houston Engineering has a 8 chelor of Science degree in mechanical engineering and has hcd 8 years design e).serience with HL&P.
(5)
The Supervising Engineer-Site Engineering has a Bcchelor of Science degree in nuclear engineering and 6-1/2 yocra nuclear experience, including 3 years in startup cngineering at the Tennessee Valley Authority's Browns Ferry Nuclear Plant, and 3-1/2 years at ML&P.
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'4 l The Houston engineering group includes all the major 5t 6!
engineering disciplines plus licensing, health physics and 7l nuclear fuel.
The site engineering group also includes all gj 9
the major engineering disciplines plus health physics and LO nuclear licensing.
13 i Q. 11 What is the function of HL&P's STP Project L4 13 Engineering group?
16 17 i A.
11 The Project Engineering group gives programmatic li !
19 i direction to the B&R design and technical support effort.
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B&R has a large staff of Design Engineers responsible for 22 '
the engineering and design of the power plant.
EL&P performs 23 reviews of these activities.
The reviews are designed to 16 ensure that B&R has considered the applicable industry codes 47 l 28 l and standards, regulatory requirements and HL&P's preferences.
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30 i Q. 12 Describe the process by which HL&P performs this 31 :
32 l engineering review.
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A. 12 our Project Engineering group reviews and approves 35 l basic design documents, provides owner's direction to B&R 36,
and Westinghouse design activities, and participates in I
resolution of problems in project engineering, construction 41 and procurement ai:tivities.
4 42 The HL&P Project Engineering team is structured along 43 I
44 45 discipline lines, much the same as the structure of B&R 46 47 engineering.
The HL&P Engineers are in contact with their 43 49 50 1
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B&R counterparts virtually every working day.
HL&P informs B&R of its questions, concerns, design preferences, etc.
At times HL&P Engineers work closely with B&R Engineers to find cngineering solutions to important design problems.
At cther times, HL&P involves itself in decisions on manpower IcVels and in the assignment of B&R personnel.
We have directed that certain design studies be performed or design options be implemented, and we have directed changes in the procedures used by B&R.
HL&P Engineering uses all of these tools to ensure that B&R's Engineering team is properly addressing the Project d:cign requirements.
Q. 13 Please present some specific examples of action HL&P has recently taken as part of its direction of B&R construction and design efforts.
A.
13 Based on operating experience, or technical cycluation of a system, component or structure, we frequently direct B&R to incorporate a modification to the design.
For instance, HL&P instructed B&R to utili:e the criteria of 10 CFR 50, Appendix d, and added criteria developed by HL&#'
intended to increase the protection for redundant safety-related circuits from seismic events, flooding, fires, and cissile hazards.
In addition to establishing certain basic criteria, HL&P has and will continue to review and monitor
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raceway design efforts to ensure they meet the established 5'
6' criteria.
'i As another example, HL&P established the basic criteria 9i 10 l for the instrument and station air systems both in system 11 i 12 layout and specification of component materials and sizing.
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{4 Criteria established by HL&P were based on previous experience 13 +
in our fossil plants and included significant operations and 16 17 '
maintenance input intended to increase the reliability of 1.1 l 1,3 these systems.
HL&P drawings and specification comments 40 11 !
Were transmitted to B&R for this purpose.
',2 Finally, HL&P has taken the lead in evaluating the 3
'4 I proposed design changes resulting from the TMI experience.
'5 We are actively involved in providing direction to S&R in
'43 i this matter.
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Q. 14 Are you able to express an opinion on how HL&P's
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current management of design and construction on this Project
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compares to generally accepted practice for nuclear construction?
5i A.
14 Yes.
In the course of my 26 years of experiences, 16 I have been significantly involved in the construction of 12
)01 nuclear power plants.
I believe that I am in a positi'on to 9
41 l compare HL&P's management structure and competence to that 4
i 43 1 of other owners involved in complex nuclear projects.
44 i 30 l Q. 15 How does HL&P compare?
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15 Since each project.is different it is not possible
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to draw any precise conclusions from a comparison of results.
However, it is possible to compare the numbers and qualifi-i entions of professionals each utility employs to manage its construction project, and to examine the level and extent of i
corporate management attention that is applied to the project.
l I can confidently state that HL&P is devoting adequate recources to its management of the STP.
Not only is the staffing adequate, but HL&P has taken steps to assure that l
direction and control is exercised at appropriate levels and that lines of responsibility are simple and direct.
HL&P hcs added the position I hold, Vice President, Nuclear Engineering and construction, to expand its management offort in its nuclear. program.
I personally communicate with whatever level of B&R management that I feel is required to ensure their awareness of our needs and the importance of i
proper and timely execution of the work.
Q. 16 From your own personal observations, is HL&P's cenagement program working effectively?
A. 16 Yes.
In my opinion, HL&P's management program.
io fulfilling appropriately its responsibility to the public 4
and to NRC to have GTP engineered and constructed in &
quality manner.
I intend, however, to ef fect even further 1
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improvements through a combination of additional training of 51 6i existing personnel and an upgrading of our staff by the
- I addition of more engineers with nuclear experience.
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O Attachment No. 1 A
EXECUTIVE VICE PRESIDENT G.W. OPREA, JR.
I VICE PRESIDENT NUCLEAR ENGINEERING
& CONSTRUCTION J.H. GOLOBERG
-SOUTH TEXAS PROJECT
-NUCLEAR FUELS 0.G. BARKER R.P. MURPHY
-ALLENS CREEX PROJECT
-NUCLEAR OPERATIONS (VACANT)
(VACANT)
-NUCLEAR SERVICES
-QUALITY ASSURANCE J.R. SUMPTER R.A. FRAZAR
- NUCLEAR LICENSING C. G. ROBERTSON
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e i 5i TESTIMONY OF RICHARD A.
FRAZAR 6i ON THE CURRENT QA PROGRAM FOR STP 9i Q. 1 State your name and current employment.
10 l 11,
A.
1 Richard A. Frazar.
I am the Manager, South Texas 12 !
y3 l Project Quality Assurance of the Houston Lighting & Power fj Company (HL&P).
16 Q. 2 Describe your professional experience and educa-is i
li i tional background.
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A. 2 I graduated from Lamar University with a B.S.
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12 Chemical Engineering in 1968.
From 1968 until 1972, I was
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empi yed by Monsanto company in the Material Technology 24,
(5 Section as a corrosion engineer.
In this capacity, I was responsible for conducting corrosion studies and field 13 ;
29 I investigations in support of chemical operations.
During
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this time I gained extensive experience in the use of metal-42 )
'<3, lographic techniques for failure analysis and nondestructive 34 l 45 l testing techniques for flaw detection purposes.
In 1972, I 36 i transferred within Monsanto to the Manufacturing Department 37 l 38 !
where I supervised the operation of a pressurized reaction 39 I 40 l copolymer resin unit.
I joined HL&P in 1973 as a Metallur-41 t 42 '
gical Engineer in the Quality Assurance (QA) Department.
43 l Since joining HL&P, I have been associated with QA.
In 44 l
89 t 1974, I was named Supervising Engineer for the STP QA program.
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47 I was promoted to Project QA Manager for STP in 1975 and then 43 l
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promoted to Manager of the QA Department on April 1, 1977.
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s-In June, 1980 in response to growing concerns about the STP QA Program, I relocated to the Site and temporarily ccoumed responsibility as Project QA Manager.
Q. 3 What has been your involvement in the QA Program for the South Texas Project (STP)?
A. 3 As I have stated previously, I have been involved in the QA program since I joined HL&P in 1973, and particularly in the STP QA Program.
From 1974 to 1977 I worked full time on STP QA - first, as Supervising Engineer and later as Project QA Manager.
In 1977, I was promoted to Manager, QA.
In this capacity, I was responsible for all of the HL&P cctivities related to QA in both the nuclear and fossil plcnts.
Nonetheless, I continued during this time to devote th0 majority of my time to STP QA matters.
In June, 1980 I rolocated to the STP and assumed responsibility as the STP GA Manager.
Q. 4 What is the purpose of your testimony?
A. 4 The purpose of my testimony is to describe the current organiration of the B&R and HL&P QA staff for STP.
Q. 5 Please define the term " quality assurance" and cxplain how it is distinguished from " quality control" (QC).
A.
5 QA is defined in the Introduction of Appendix B ca ccmprising "all those planned and systematic actions nccessary to provide adequate confidence that a structure, F
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system or component will perform satisfactorily in service."
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In this context QA includes the systematic actions of engineer-7 S'
ing, procurement, construction and the services used to 9
control quality.
It includes a separate QA group that 12 !
functions as an arm of management whose responsibilities are 13,
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to develop policy; verify implementation of policy; diagnose, 13 16 anticipate and prevent problems.
QA includes QC which is an 17 i Lg ;
independent check to verify that requirements have been met.
9ali QC activities involve physical inspections of completed ja 31 !
r in-process construction work such as measuring the spacing 22 f3 of reinforcement steel (rebar) before pouring concrete or 25 l radiographic examination of a weld.
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27 l The QA requirements for a particular activity depend on 23 ;
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the nature of the activity and its relationship to safety.
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Appendix B states that the QA program shall provide control 32 i 33 over an activity "to an extent consistent with its importance 34 I 35 j to safety."
For some activities the QA requirements include 36 I 37 l a 100 percent QC inspection of the work; for example, all 30 '
ASME Safety Class 1 welds are required by the ASME, code to 40 l have 100 percent radiographic examination.
In other cases 41 42 the requirements may include only intermittent QC sampling 43 44 or periodic audit, as for example, soils compaction and con-45 l
. 46 crete batching, which require periodic sampling for verifi-47
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cation of properties as defined in ASTM and ACI codes.
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Q. 6 Describe the management organization for accom-plishing QA and QC on STP.
A. 6 As with any major construction project, STP is boing constructed from materials and components that are being procured under contracts with a great number of organ-irations.
QA requirements are established in the contracts, including the contracts with the principal contractor, Brown
& Root, Inc. (B&R), and the supplier of the nuclear steam cupply system, Westinghouse Electric Corporation, Inc.
In almost every case the contract requires the supplier to perform certain QA functions with respect to the goods or ccrvices provided under the contract, subject to audit or inspection by or for HL&P.
The contract with B&R provides for B&R to perform QA services for its design and construc-tion activities on the Project.
B&R's QA activities include QA audits of vendors and subcontractors other than Westinghouse, QA on Westinghouse supplied equipment upon receipt at the cite and the QA requirements applicable to B&R design and construction activities.
HL&P and B&R have an integrated QA Program for STP which is described in detail in the " Quality Assurance Program Description" filed with the NRC.
HL&P reviews the QA activities of B&R, providing program-matic direction and verification that the program is being
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5i properly implemented.
In addition, HL&P QA performs audits 6
of all QA activities on the Project, including the activities 49l of HL&P, B&R, and many of the vendors.
The HL&P QA program j[0 '
serves as an independent check by which HL&P can assure 1
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itself that each contractor QA program, and in particular yy ;
lj the B&R QA program, is functioning properly.
B&R, as prime 15 contractor for the Project, is responsible for implementing 17 i 15 a QA program which fully satisfies the 18 criteria of Appendix 19
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B.
The HL&P QA Staff assures that B&R is adequately fulfilling 79 l - the requirements of the project QA program. HL&P does not
- 3 duplicate B&R's QA activities, although HL&P does perform
.t., }.5 its own periodic QC inspections, review of procedures and 9. l!. records and observations of work in progress to verify that 29 i' 49 ! the B&R program is functioning properly. .40 ' 31 Q. 7 How is the HL&P QA staff organized? 12 A. 7 I am the Manager of the HL&P STP QA organization 33 j 14 l and I report directly to the Executive Vice President. 33 There are five people who report directly to me, the Project 33, QA General Supervisor; the Supervisor, Quality Systems; the 39 40 i Supervisor, QC; the Procurement Project QA Supervisor; and 41 42 i the Operations QA Manager. 43 l 44 - The Project QA General Supervisor directs the Discipline
- 5 QA personnel, providing programmatic direction to B&R and s,g,
Y interfacing with NRC. Reporting to him, are the three g ao 51 i l Diccipline Project QA Supervisors, who direct the QA personnel in the Civil / Structural, Mechanical / Nondestructive Examination end Electrical / Instrumentation and Controls groups. The Supervisor, Quality Systems directs the site quality syctems personnel, who develop and administer the HL&P Project QA Plan; evaluate the B&R QA/QC program; administer tha HL&P STP QA personnel training and certification program; provide administrative control of HL&P QA procedures and provide mechanisms to correct the QA programs. The Supervisor, QC directs the HL&P QC personnel in th3ir conduct of inspections as requested by HL&P Discipline QA personnel to provide separate spot checks of the inspec-tions performed by contractor QC personnel. These HL&P QC personnel do not inspect for acceptance of work. The Procurement Project QA Supervisor coordinates HL&P vendor surveillance / audit activities and provides program-matic direction to B&R regarding vendor surveillance and cuditing functions. The operations QA Manager directs HL&P's QA program for plant operations, and is not directly involved in the design cnd construction activities. There is also a separate Corporate QA group with offices in Houston that is headed by Mr. Robert Ulrey. That group has four sections: (1) vendor surveillance, (2) audits and ~ .....a. 1 L' 2. 1; 5 technical services, (3) Allens creek Project and (4) fossil 6; ~; projects. Mr. Ulrey reports directly to Mr. Oprea. }; 9j Attachment No. 1 is an organization chart that shows 10 l {y ! these reporting relationships. 1 Q. 8 Describe the B&R QA organization. 14 A. 8 The division of B&R performing the work on the 13 i 16 STP is the Power Group, which is headed by the Group Vice 17 i 15 ' President for Power, Mr. William M. Rice. The Power Group toja ; QA Manager, Mr. Vurpillat, reports to the office of the 11;j Senior Vice President, Dr. Knox Broom. The B&R STP QA 3 Manager reports to Mr. Vurpillat, and is located at the 7I South Texas Project site. <.. i The B&R STP QA organization is divided into five sections,
- 8 ;
- 7. 9 i which are generally parallel to the sections of the HL&P QA 10 !
11 ! organization. The sections are Quality Engineering, vendor ~4 2 : surveillance, QC, Quality systems and Site surveillance. 43 14 ! Each of those sections is headed by a Manager, and is divided 15 30 into a number of subsections, as shown in Attachment No. 2. - 37 i 38 ' The Quality Engineering group is divided into five sec-39 : 40 i tions that encompass the major disciplines (i.e., Mechanical, 41 ! 42 NDE, Electrical / Instrumentation & Controls, Civil / Structural, 43 and Material Procurement). Quality Engineers control QA g4 activities related to their individual disciplines. The _j Quality Engineers work closely with their lead discipline d l 51 i. _ _.
counterparts in Engineering and Construction to resolve problems that are identified during construction to assure that the cause is determined and adequate corrective action ia accomplished. The Quality Engineers perform reviews of cngineering documents, purchase orders, and nonconformance rcports for assuring conformance to quality requirements, cnd prepare quality control inspection plans. The Quality Engineers participate in planning QA activities (procedures, plans, training, etc.) associated with specific construction activites. Finally, the Quality Engineers assure that the QC Inspectors are provided clear instructions and acceptance criteria. QC inspects construction activities pursuant to inspec-tion planning instructionIs prepared by Quality Engineering. QC is divided into seven groups, each directed by a superin-tcndent who reports to the QC Manager. 'The seven groups are M;chanical, NDE, Electrical / Instrumentation & Controls, Civil, Structural, Coatings & Insulation, and Receiving, Storage and Maintenance. Reporting to the Superintendent of ccch group are Lead QC Inspectors, who direct the activities of the QC Inspectors. These B&R QC Inspectors and Lead QC Inspectors perform inspections of construction activites for cceeptance. L, 2< t' l 5, quality Systems coordinates the maintenance of QA 6l -l records, records turnover procedures, the QA training and ~l certification program, and the nonconformance trend analysis 10 i 71 program. 12 Vendor Surveillance / Houston Coordination assures that 14 inspections and audits of vendor activities are performed, 1: 16 and serves as the interface between QA and Houston Engineer-17 15 ing and Procurement activities. Site Surveillance performs surveillance over site jj activities at the direction of the Project QA Manager. Q. 9 How does Mr. Oprea keep informed of developments 13 on the Project and provide direction to you about the manage- '/ " :
- k. "
ment of the QA Program? 33 i
- 4 9 i A. 9 Mr. Oprea frequently visits the site to review 30 t 31 the progress of construction, to discuss the status of the (42 l!
primary quality concerns, and to review the progress toward 3 closure of the Show cause order items. Mr. Oprea also 36 : attends each meeting of the B&R QA Manageme,nt Review Board 37, ~3' (which are held on site) to review the status of the QA .9 l 40 ; Program. In addition to his frequent on site visits and 41 ! 42 l formal meetings, Mr. Oprea receives frequent briefings from 43 ' 44 l me and numerous QA reports from HL&P and B&R, some examples .-l +. ! of which are listed below: 1 47 t 43 ! l p. hw I 51 i i .. ~ 1. HL&P QA Monthly Status Recorts which include a project deficiency status summary and a trend analysis summary. The deficiency status summary includes Audit Deficiency / Reports, Nonconformance Reports, and Correc-tive Action Requests. 2. Copies of all Audit Recorts (HL&P and B&R) 3. NRC Ocen Item Status Recorts 4. Audit Trend Analysis Recorts 5. Corrective Action Requests Q. 10 What functions are performed by the HL&P Disci-pline QA Personnel and B&R Quality Engineering groups? A. 10 EL&P and B&R decided to give different names to thcse groups to avoid confusion, but both groups are composed of Quality Engineers with parallel responsibilities. The B&R Quality Engineers (QE's) perform their work on the Project in accordance with the programmatic direction they rcceive from the HL&P Discipline QA Personnel. The B&R Qunlity Engineering group is divided into separate sections for the various disciplines: civil / structural, mechanical, non-destructive examination (NDE), electrical / instrumentation and controls, etc. Each discipline is responsible for ccsuring that QA requirements are adequately reflected in the various phases of Project design and construction. They
m ~ -m I li 2; (' t 5i review procurement and design documents to assure that QA 6! requirements are adequately included and participate in ~ u 9i inspection planning, draft inspection checklists, and review 1 i 'y";0 j and approve the QA aspects of construction producedures. 12 l The Quality Engineers develop the criteria for training, 13 ; .14 I examination and certification of QA personnel and provide . '2Li. technical direction and support to other QA personnel for 15 l 17 l
- 1. 5 resolution of quality problems.
1.3 [ They review documentation of Project activities, such 20 i 71 l ,j : as Design Change Notices and reports of QC inspection results '3l-to assure the applicable procedures are being followed. 4 ',f l They investigate adverse quality trends and identify the 2 need to issue Corrective Action Requests, which seek to 43 i >9 l eliminate the causes of errors, and they follow up to verify 40 l 11 the adequacy of the corrective actions taken. Finally they
- 2 f review completed packages of records as work is completed 43,;
4i and assure that QC documentation is adequate. ,o l, 6l The B&R Quality Engineers perform all of this work -2 / j 38 ! under the review and direction of the EL&P Discipline QA 39 i 10l personnel. EL&P discipline QA personnel review and approve 'l, 12 l B&R QA procedures and other system features and monitor 13;4 ! their implementation. This implementation review includes j, techniques such as interviews with personnel performing the ) l activities, observations of work in progress and reviews of ^ .e completed work. =>: 31 h
- r Q. 11 How do HL&P Discipline 2A personnel interact with B&R Quality Engineers?
A. 11 HL&P QA personnel work daily with B&R Quality Engineering. This relationship includes the following activities: 1. Project problems are resolved between HL&P Discipline QA and B&R Quality Engineering staff. 2. Requirements and directives from HL&P QA to B&R QA are communicated through the HL&P Discipline QA/3&R QE interface. 3. Procedures are reviewed and approved through this interface. An example of how this relationship operates occurred during the structural and piping welding restart programs. EL&P Discipline QA personnel worked with the S&R QE's on resolution of problems prior 'to the welding restart and reviewed NDE procedures generated by B&R QE's. This involved frequent discussion between the two groups to resolve dif-forences in the procedures. This process was also used for revision of the mechanical and civil construction procedures. EL&P Discipline QA personnel and B&R QE's witnessed NDE certification tests and reviewed initial radiographs of both production and certification activities. All phases of the F c. c. i 1 2i I. restart programs were jointly surveyed by HL&P Discipline _3 6l l QA, B&R Quality Engineering and consultants. This relation-o '. 9: ship is described in more detail in the testimonies of Mr. 10 !1l Robert Carvel (Concrete Restart) and Mr. Logan Wilson ~ 17 -{~ (Welding Restart). 4'_ Q. 12 How is QC performed on the Project? o 15 A. 12 As I just mentioned, the B&R Quality Engineers 17 i 15 ' are responsible for inspection planning work and preparation T.C 20 of inspection checklists. Their inspection planning work is il ' 73 ' coordinated with the Construction organization to assure 2.3 that Construction and QC inspection planning are properly 34 33 j sequenced. 1 The B&R QC inspections are primarily performed by the 23 ' 29 i B&R QC group, although some civil QC work is performed by a 30 ! 31 I subcontractor, Pittsburgh Testing Laboratory. HL&P Disci-32 ' pline QA personnel review the documentation of the inspection I 33 l-34 35 i results, as well as the inspection planning, and provide l 36 l directi n t &R to assure that the program functions properly. 37 l 38 ! The HL&P QC group is a small group of certified inspectors 39 : 41l; in the three major disciplines who perform periodic inspec-40 42 i tions to verify the adequacy of the B&R QC inspection. EL&P 43 i 44 l-Discipline QA personnel plan the HL&P QC inspections and go ! utilize the HL&P inspection results in their evaluation of 47 ' the B&R QA program implementation. 43 I 20 51 i I i l
? .... E '. Q. 13 What are the functions of the HL&P and B&R Quality Systems groups? A. 13 In each organization the Quality Systems group is responsible for preparing and maintaining the QA program documents. The B&R QA Systems group maintains B&R ST? QA files and coordinates B&R's turnover of QA/QC records to EL&P. The HL&? Quality Systems group evaluates the B&R QA/QC program level documents, trends observed in B&R's implementation of its QA program, and provides programmatic direction to the B&R QA Systems group. In the case of both organirations it is the Quality Systems group that administers the respective programs for training and certification of QA/QC personnel. Q. 14 How is Procurement QA performed on the Proj ect? A. 14 When a requirement for new equipment or services is identified, B&R Engineering initiates the required engineer-ing documents to procure these items. Prior to release of these documents they are reviewed by B&R Quality Engineering for assurance that the required QA commitments were included. Tho B&R Quality Engineering group is also responsible for preparation of a vendor inspection, plan for use by B&R Vendor Surveillance which identifies the inspection character-istics to be verified and the frequency of inspection trips to the vendor shop for in prccess inspections. L, 2, ~ 5 It should also be noted that prior to the award of a 6i 7j contract, the vendor's QA Program is reviewed by B&R's 9l auditing section to assure the vendor has a QA program which to I {,3 is in compliance and consistent with our requirements. The 17}}, vendor's QA progrma is audited on an annual basis to assure 14 that it is properly maintained. .c 16 HL&P performs implementation reviews of B&R vendor 17 i 15 surveillance and audits to assure that B&R is adhering to 19 20 requirements and to provide the basis for programmatic
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,j : direction to B&R. ll Q. 15 What are the functions of the B&R Site Audit and 4. _ t Corporate Audit groups? 3 ~ A. 15 The B&R Site Audit group performs regular on-site ?. 3 l 29 l audits of B&R procedures and activities as part of the B&R 40 i al audit program to meet the requirements of Criterion XVIII of I 42 ' 3 Appendix B. During 1981 this group is scheduled to perform 24 ! approximately 40 such audits to provide feedback to manage- ,3 ; 46 ment on the adequacy of implementation of the QA program and de : 38 procedures. The B&R Project QA Manager uses the reports of 39, t 10 : the site Audit group to identify problems or potential 41 42 problems. The B&R Corporate Audit group performs a similar 43 .; 4 function, in that it observes work being performed and .-l i reviews records to verify the implementation of the B&R QA program, but its scope is broader, in that its audits are g not restricted to on-site activities. The Corporate Audit t L. 51 i group periodically audits each element of the B&R QA program, including the Houston based engineering and vendor surveil-lance activities. Reports of the Corporate Audit group are sOnt to B&R executive management and to HL&P, and are an important tool in assessing the effectiveness of the B&R QA program. Q. 16 How does HL&P audit its own QA program? A. 16 There is a section in HL&P's Corporate QA group in Houston which performs audits of the B&R and HL&P QA programs. The audit section observes work in progress and rcviews records to determine the effectiveness of the QA program. At times it participates in audits along with B&R audit personnel and at other times it conducts its own audits. The HL&F audits compare the performance observed and the records reviewed to Project procedures, licensing commitments, NRC requirements and other applicable standards. HL&P audits cover the activities I supervise as STP QA Manager, so I know from personal experience that they do a thorough job. Copies of HL&P and B&R audit reports are distributed to ma, to HL&P executive management and to the manager directly responsible for the activities addressed in the audit report. Q. 17 Describe the manpower levels of HL&P's QA staff 1 for STP. . 1C
L, 2i 7 1 I 5l A. 17 The size of the site QA staff has been increased 6l 7< considerably. In November of 1979, there were (excluding 9 clerical) seventeen (17) QA persons assigned to the South 10 : i Texas Project Site. The 17 persons represented 83 man-years ~ 3 ~2 8 1 experience in QA and 148 man-years in nuclear power activi-14 ties. By March of 1981, the staff (excluding clerical) Ja, ' 1 6 '. increased to 43 persons representing 413 man-years experi-3 1 s 15 ence in QA and 325 man-ydars nuclear experience. O f the 1 i to, current staff of 43 persons, 18 have degrees. As a group, 29 1
- j j the staff has an average experience of 9.6 years in QA and
)3 ' 7.5 years in nuclear power. ,3 i '3 Several administrative actions have been taken to i J* I increase the staff both quantitatively and qualitatively. t 18 i '9 ! These actions included retaining consultants who specialize 0! ,1, in finding professional and technical personnel and increas- ,9 3 ing the starting level salaries in order to attract more 4i - J. experienced personnel. s- 'O Q. 18 In developing its QA program, has EL&P utilired .47 ; JS ! information concerning the staffing levels and QA organiza-29 10 ! tions of other utilities? 41 ! 42, A. 18 Yes. In 1974 and 1975 information was gathered 43 i 44, through the Edison Electric Institute (EEI) QA Task Force 45 I about staffing levels and QA organization structures of a 4 )o number of utilities, including Pacific Gas and Electric, s i ? Florida Power & Light, Commonwealth Edison, Duke Power, l 51 . a
- -. ~. _. _ Arkansas Power & Light, and Portland General Electric Company. Subsequent to our studies of 1975, we continued to evaluate information on QA organizations obtained through the EEI QA Task Force and other contacts in the industry. From 1974 through 1979, Mr. Barker, EL&P's Project Manager, and I attended EEI QA Task Force meetings. In fact, during 1974 and 1975 Mr. Barker was part of the Subcommittee on Organi-cation of the EEI QA Task Force. Q. 19 Does the QA Program for STP meet the requirements of Appendix B to 10 CFR Part 50? A. 19 Yes, it does. I have evaluated the STP QA Program (including both the HL&P and B&R portions) against the 18 criteria of Appendix B, and am assured that the program fully satisfies each of those criteria. On October 31, 1980, we submitted to the NRC a description of the current I STP QA Program which was recently revised in the April 22, ) 1981 submittal. The revised description summarizes how the L 1 program satisfies each of the 18 criteria. I supervised the preparation of that description. Preparing that document rcquired us to review how the STP QA program was functioning and how it compares to Appendix B and the various Regulatory Guides and industry standards that further interpret Appendix B. I am fully satisfied that our program fully complies with the applicable requirements. t 9 i
l L, 2, 5 Q. 20 Has that been true of the STP QA program in the 6i ,7 ' past? A. 20' Yes, it has. In originally defining the QA 9, '1 I j'0 Program for STP, HL&P addressed each of the 18 requirements 12 i of Appendix B. HL&P made sure that both the HL&P and the 13 14 B&R QA programs fully satisfied the NRC requirements in the 1.5 1,6 various regulatory guides referenced in the Preliminary 17. 1,3 ' Safety Analysis Report. As the Project has progressed, To}},, there have been a number of modifications to the QA program. )T ihose changes have further strengthened a program that ,2 ', 3 already met NRC requirements. !5 Q. 21 Is there reason to believe that the QA program 7.6 ' s' is being properly implemented?
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>9: A. 21 The NRC investigation that formed the basis for <0 the Show Cause Order found a number of instances of noncompli-41 42 ance with project procedures, that is, instances of inadequate ,3 44 ! implementation of the QA program. We have worked h&rd over j gi 50 i the past year to strengthen our QA management of the Project, 37 I 33 our administrative controls and the Project staff of both 39 l 40 ' HL&P and B&R to improve the implementation of the QA program. 41 42, The cha..ges HL&P and B&R have made in personnel, staffing, 43 organization and procedures are described in detail in my 44 f; subsequent testimony and that of Mr. Cprea and in the testi-j7 I many of Dr. Broom and Mr. Vurpillat. We have succeeded in ,3 : bringing about substantial improvements, which provide f l;
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31 l ! /
reasonable assurance that the QA program will be implemented properly. T. Hudson:11:D . L
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