ML20137X511

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Testimony of Hs Phillips Re Util Sys for Reporting Design & Const Deficiencies
ML20137X511
Person / Time
Site: South Texas, 05000000
Issue date: 06/21/1985
From: Phillips H
NRC
To:
Shared Package
ML20137X502 List:
References
FOIA-85-519 NUDOCS 8603100114
Download: ML20137X511 (4)
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t June 21, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COPHISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of HOUSTON LIGHTING AND POWER COMPANY, Docket Nos. 50-498

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50-499 (South Texas Project, Units 1 & 2)

Testimony of H. Shannon Phillips Q.1. Would you plet,te state your narre, businesse address, employer and position.

A.I. My name is H. Shannon Phillips.

I am employed by the U. S. Nuclear Regulatory Comission as senior resident inspector (construction) at the Comanche Peak huclear Station. My address is Box 38, Glen Rose, Texas, 76043.

Q.2. Mr. Phillips, have your professional qualifications been made a part of the existing record previously in this proceeding?

A.2. Yes. My professional qualifications appear following Transcript 9205 of page 64, Appendix B.

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Q.3. Are there any changes you wish to make with regard to those qualifications?

A.3. Yes. Since January 19,192, (the date of prior admission of qualifications) I have held the position of Chief. Equipment Ve o. W Qualifications Section, undsc Programs 8 ranch, U. S. NRC to March 18, 1984. 'Since that time to the present. I have been senior resident inspector (construction) at the Comanche Peak Nuclear Station.

Q.4. What is the purpose of this testimony?

A.4. The purpose of this testimony is to provide rqy views with respect to HL&P system for reporting design and construction deficiencies.

A.S. Do you have personal knowledge of the HL&P system for reporting construction deficiencies?

A.S. Yes.

Q.6.'On what experience or duties is this knowledge based?

A.6. I was the senior resident inspector at the South Texas Project from September 1979 to January 11, 1982. During that time I routinely inspected HL&P's system for reporting deficiencies. My testimony provides my observaticr.s for that time period.

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'>1' M Gld O d'8 C3 O Q.7. Can you describe the system for reporting construction deficiencies during this period?

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A.7. Yes. HL&P Procedure PEP-11, Revision 0, was issued July 26, 1979, and described the process for reporting 10 CFR Part 50.55(e) deficiencies.

HL&P Engineering Procedure STP-DC-021-D and Revisions A through C (dated February 1978 through January 1981) specifically describe how engineering organizations report engineering design deficiencies. Basically, anyone can report a construction or design deficiency which in turn is fed to the STP Project QA supervisor or appropriate engineering group $

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the reportability per 10 CFR 50.55(e). pThe item is then refer to an incident review comittee for a safety evaluation eft:r :th:r: h ve p-4...d.::9 hd :;ih:ti=, Procedure PEP-11 states that deficiencies shall fall into one of four categories outlined in paragraph 5.3.3; i.e., QA, final design, construction or deviation from performance specifications.

Page 10 of 17 also indicates that potentially reportable items were to be reported.

Q.8. How would you assess HL&P's candor and truthfulness in reporting matters to the NRC during the period identified above?

A 8. My experience with this utility is that they were forthright in identifying deficiencies to the NRC when they were found to be reportable.

They also reported a large number of deficiencies, when they may have taken a more conservative approach, and reported fewer.

I was also impressed by their sincere desire to do a good job even though their A3

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inexperience or oversight sometimes resulted in violations of 10 CFA 50.55(e) reporting requirements.

0.9. Have you seen any indication from the utility that it was abdicating or refusing to accept its responsibility to protect the health and safety of the public?

A.9. No.

Q.10.What is your conclusion as to the remedial steps taken by HL&P since 1981 with regard to its character and competence to operate a nuclear plant?

A.10.These steps were adequate and reflect positively on the character and competence of HL&P.

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