ML20138H423

Testimony of HR Banks & RM Parsons Re Conservation Council of North Carolina Contention WB-3 Concerning Const QA Program.Related Correspondence

ML20138H423
Person / Time
Site:	Harris
Issue date:	10/25/1985
From:	Banks H, Parsons R CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML20138H418	List: ML20138H413 ML20138H423 ML20138H435 ML20138H455 ML20138H464
References
OL, NUDOCS 8510290035
Download: ML20138H423 (37)

Text

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UNITED STATES OF AMERICA -

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD b'/ jgp g) \

In the Matter of )

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CAROLINA POWER & LIGHT COMPANY )

and NORTH CAROLINA EASTERN ) Docket No. 50-400 OL MUNICIPAL POWER AGENCY )

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(?hearon Harris Nuclear Power )

. Plant) )

APPLICANTS' TESTIMONY OF HAROLD R. BANKS AND ROLAND M. PARSONS ON THE CONSTRUCTION QUALITY ASSURANCE PROGRAM (CCNC CONTENTION WB-3) 8510290035 851025" PDR ADOCK 05000400 T PDR

Q1. Mr. Banks, by whom are you employed and what is your position?

A1. (HRB) I am employed by Carolina Power & Light Com-pany as Manager, Corporate Quality Assurance Department.

Q2. Please summarize your professional qualifications.

A2. (HRB) I have over twenty-five years of naval and commercial nuclear power experience. I joined CP&L in 1968 and i have been actively involved with the company's quality assur-ence programs since that time. In February 1981 I assumed the

, position of Manager--Corporate Quality Assurance. In this po-cition, I have overall responsibility for assuring the effec-tiveness of the quality programs, both at the individual 4

nuclear plant sites and at the corporate level. A complete statement of my professional qualifications is appended as Attachment 1 to this testimony.

Q3. Mr. Parsons, by whom are you employed and what is your position?

A3. (RMP) I am employed by Carolina Power & Light Com-pany as Project General Manager, Harris Nuclear Project Depart-ment.

Q4. Please summarize your professional qualifications.

A4. (RMP) I received a Bachelor of Science degree in Civil Engineering from Fresno State College in 1959. I am a

registered Professional Engineer in five states, and am a mem-ber of the American Society of Civil Engineers. I have worked on the construction of nuclear power plancs for over 18 years, and have been actively involved in the construction of the Harris Plant since 1976. From January 1978 through August 1984, I had the prime responsibility for assuring the safe con-struction and completion of the Harris Plant. Since August 1984, I have been responsible for conducting an overview of the entire Harris Plant Project in order to assure readiness for operation and have participated in other construction close-out activities. A complete statement of my professional qualifica-tions is appended as Attachment 2 to this testimony.

QS. What is the purpose of this testimony?

AS. (HRB, RMP) The purpose of this testimony and the

' companion pieces of testimony sponsored by Dr. DuPont, by Messrs. Banks, Parsons, Forehand and Brombach and by Mr. Trainor is to respond to the allegation in CCNC Contention WB-3 that Applicants have failed to ensure the quality of cafety-related work perforraed by known drug users. In this

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testimony we describe the construction Quality Assurance Pro-gram at the Harria Plant Project and explain how the sequential layers of review, inspections and surveillances of safety-related construction work ensure that deficiencies are identi-fied and corrected. The construction Quality Assurance Frogram is designed to identify deficiencies in construction work --

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l whether caused by drug use or any other cause. We identify the l objective indicators that demonstrate the effectiveness of the Quality Assurance Program in ensuring that the Harris Plant is constructed to regu'.atory and design requirements.

Q6. Have Applicants previously testified regarding the Quality Assurance Program for the construction of the Harris Plant?

A6. (HRB) Yes. I described in general terms Applicants' QA organization and program elements during hearings on manage-ment capability. See Applicants' Joint Testimony of E. E.

Utley, M. A. McDuffie, Dr. Thomas S. Elleman and Harold R.

Banks on Joint Intervenors' Contention I (Management Capabili-ty), following Tr. 2452.

(RMP) Applicants also discussed various parts of the QC and CI inspection program in Applicants' Testimony of James F.

Nevill, Alexander G. Fuller, David R. Timberlake and Kumar V.

Hate in Response to Eddleman Contention 41 (Pipe Hanger Welding), following Tr. 6663, and in Applicants' Testimony of George A. Kanakaris, Roland M. Parsons and Larry F. Garner in Response to Eddleman Contention 65 (Concrete Containment Struc-ture), following Tr. 5764.

Q7. Gentlemen, how is the remainder of your testimony or-ganized?

l A7. (HRB, RMP) We first outline the Quality Assurance Program for construction of the Harris Plant and the many se-quential layers of review which ensure quality construction.

We deceribe the QA attribute surveillance program and the re-sults of reinspections which demonstrate the effectiveness of the Quality Assurance Program. Finally, we identify outside organizations which have performed evaluations of thc quality of construction of the Harris Plant and briefly describe their findings -- consistent with our own -- that the Harris Plant Construction Quality Assurance Program is well-conceived and properly implemented.

Q8. Please outline the Quality Assurance Program for con-9truction of the Harris Plant.

A8. (HRB) The Quality Assurance (QA) Program at the

' Harris Plant Project provides the necessary steps to ensure that a safe and reliable power plant is constructed in accor-dance with regulatory and design requirements. Responsibility for achieving quality work in the first instance lies with the individual craft worker responsible for accomplishing the work.

However, confirmation of quality for safety-related work is ac-complished by sequential layers of review; namely:

a. First line craft supervision;

b. Independent inspection organizations l (Quality Control (QC) and Construction l

Inspection (CI));

c. Supervisory audits of inspectors and in-dependent QA surveillance of inspectors' work; l

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d. QA records review;

e. System walkdowns jointly by Construc-tion, Start-Up and QA personnel to veri-fy the system is complete and no obvious deficiencies exist;

f. Start-up testing to verify the system will function as designed during opera--

tion; and

g. Corporate QA audits.

This multi-tier approach, which is described in more detail below, provides sufficient checks and cross-checks to provide adequate confidence that plant construction meets regulatory and design requirements.

Q9. What role do the craft worker and first line craft supervisor play in assuring quality of construction work?

• A9. (RMP) The first line craft supervisor is responsible for supervising work activities within his scope of responsi-bility in accordance with the design requirements. ~4nce he is.

directly responsible for production, it is important that the work being accomplished by his personnel be done correctly in order to meet not only quality but also cost and schedule requirements. He '.a responsible for assuring that his person-nel have the proper training, materials and information neces-cary to perform their work correctly. Poor quality work will result in a high reject rate, rework, and loss of production.

Craft ~ supervisors are held accountable for reduction of rework and recognize that defective work will be identified by quality

inspectors. In this respect quality of work and production goals are compatible. Craft workers are held accountable for the quality of their work. In fact, the majority of craft work l is performed in teams where one worker's performance is sub, :.t to the scrutiny of fellow workers. Teamwork. leads to fewer er-rors. Performance of the craft and first line craft su-pervision is confirmed through an independent inspection pro-gram.

Q10. Mr. Banks, please describe the independent inspec-tion units.

A10. (HRB) Safety-related component installations are inspected for conformance with project design requirements by an inspection organization independent of the organization per-forming the work. It is important to recognize that these 1

inspections are not conducted on a sampling basis, but rather address all safety-related construction work. At the Harris Plant Project, this function is performed by the Quality Con-trol (QC) Unit and the Construction Inspection (CI) Unit.

These units now report to the Director QA/QC -- Harris Plant, who in turn reports through the Manager QA/QC -- Harris Plant Section to me. There are presently on site over 500 quality inspection personnel to carry out quality inspections on con-struction and start-up activities. The CI Unit previously re-ported to Mr. Parsons; however, this unit has always been inde-pendent of the construction line organization.

Inspections are documented and the inspection results are reviewed by qualified personnel to assure that applicable requirements have been met. Deficiencies identified are for-warded to appropriate supervision for corrective action and tracked by QC/CI through satisfactory resolution. As one indi-cation of the extent of the QA effort at the Harris Plant Project, we have estimated that quality inspectors have logged-

.in over-2.5 million man-hours on inspection activities and over three million pages of QA documents have been generated.

Qll. How does CP&L assure that its quality inspectors are qualified and properly trained?

All. -(HRB) The inspection organizations at the Harris Plant have established programs to assure inspection personnel are adequately trained and qualified in their respective areas of responsibility. These programs meet the requirements of NRC Regulatory Guide 1.58, " Qualification of Nuclear Power Plant Inspection, Examination & Testing Personnel," to which.Appli-cants committed.in the Harris Plant Preliminary Safety Analysis Report ("PSAR").

- Generally, only personnel with previous training and expe-rience, who meet or exceed Harris Plant requirements, are hired for inspector positions. Inspector candidates who do not meet the training and experience requirements for an intended as-signment are provided additional classroom and practical /on-

.the-job. training under the supervision of qualified personnel.

4 Prospective inspection personnel are provided the following training as required by site procedures:

1. Indoctrination: An introduction to specifications, codes, standards, procedures and other project controlling documents.

2. . Required reading and self study of specifications, procedures and other controlling documents applicable to the intended assignment.

3. Classroom training: Prospective inspectors attend regularly scheduled training classes designed to improve the inspection program, to inform inspectors of changes in specifi-cations and procedures, and to improve the inspectors' knowl-edge and understanding of project requirements. cpecial classes are conducted for inspector candidates when the materi-al cannot be adequately presented during on-the-job training.

4. Practical /on-the-job training: Inspector candidates are assigned to work under the supervision of an experienced, cert..fied inspector. This provides an opportunity to perform and become proficient at the required functions. The length of the on-the-job training is dependent on the prospective inspec-tor's previcus experience and training and his/her ability to demonstrate proficiency.

5. Examination and testing: Inspector candidates must successfully pass written and oral examinations prior to con-sideration for certification as an inspector. Candidates for the position of visual welding inspector must also demonstrate

functional proficiency during the examination process. Non-destructive examination (NDE) inspectors must meet the require-ments of the American. Society for Nondestructive Testing (ASNT document TC-1A) prior to certification.

6. Certification: The inspector candidate's qualifica-tion and training records are reviewed by appropriate levels of supervision. When the requirements for the intended inspection or NDE assignment are met, the candidate may be recommended for i

certification by supervision. Certification of visual inspec-tors is approved by the Director QA/QC -- Harris Plant. NDE inspection personnel are certified by a Level III examiner.

Q12. What actions are taken to assure that quality in-spectors maintain their proficiency?

'A12. (HRB) Supervisors audit or monitor each inspector's work to. identify performance problems so that appropriate cor-rective action can be taken. Inspectors attend regularly scheduled classes designed to cover changes to specifications and procedures, to emphasize requirements in areas where prob-lems are encountered, and to improve the inspectors' knowledge i and understanding of applicable codes, specifications and pro-cedures. Each certified inspector must be recertified at least every two years (three years for NDE methods) based on docu -

mented annual evaluations of the inspector's performance. An unsatisfactory performance evaluation will result in removal of the individual from inspection activities pending appropriate

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retraining, satisfactory demonstration of proficiency and reex-amination.

Q13. How do inspection supervisors audit their inspec-tors' work?

A13. (HRB) Inspection supervisors audit the work of newly certified visual inspectors on a weekly basis for a mini-mum of four weeks and monthly thereafter to ensure a thorough understanding of requirements and the adequacy of inspections.

These audits are performed in accordance with Harris Plant In-struction.QAI-1.3, "QC Supervisory Audits."

The supervisor checks both in-process work and completed work in each inspection area in which the inspector is working.

The in-process audits consist of unannounced visits by the su-pervisor to observe the inspector's performance in the field.

Inspectors are questioned on the activity being performed, pro-cedural requirements, acceptance criteria and the handling of applicable inspection documentation. Any weaknesses and prob-lem areas are discussed and resolved.

Supervisory audits have been highly effective in providing early indication of problems with individual inspectors and ge-neric inspection problems. They also provide supervision a high level of confidence that the inspection force is per-for=ing in accordance with program requirements. The indicated overall inspector proficiency from cata developed by su-pervisory' audits is approximately 99%. This closely parallels overall inspector proficiency rates of greater than 99% as de-termined by QA attribute surveillances performed in accordance with Harris Plant Procedure CQA-7, " Evaluation of Program Effectiveness," as described below.

The NDE supervisors monitor NDE inspectors' performances and review their inspection reports. In addition to this su-pervisor review, an independent review of completed NDE inspec-tion reports is conducted by certified NDE technicians to de-termine completeness of the report and that recorded indications have been correctly interpreted in accordance with applicable acceptance criteria.

Q14. What role does nondestructive examination (NDE) of construction activities have in assuring the quality of con-struction?

A14. (HRB) Nondestructive examinations of materials and vorkmanship used in construction provide assurance of quality characteristics which cannot be determined by visual inspec-tions. The NDE methods are designed to detect and identify in-herent process flaws as well as those which may result from im-proper application of the process (e.g., welding). NDE is performed in accordance with comprehensive written procedures by NDE personnel certified to the American Society of Non-destructive Testing requirements.

NDE is comprised of two basic types of examinations; sur-face and volumetric. Surface examination methods are liquid penetrant and magnetic particle. Volumetric methods are radi-t ography, eddy current and ultrasonic examinations. These exam-inations are used to detect physical evidence of weld and base material defects.

Design engineers specify appropriate NDE processes consis-tent with applicable code requirements that take into consider-ation the thickness and type of base material; the difficulty of welding; and the application of the material (e.g., high temperature, high pressure fluid system piping), when visual inspection may not be adequate to verify the intended level of integrity or strength.

An expanded discussion of NDE is found in Applicants' Exhibit at Section IV.

Q15. Describe how this independent inspection program is applied to,the installation cf a specific plant system to en-cure the' quality of craft work.

A15. (RMP) Installation of a piping system provides a good example of the checks and cross-checks provided by the in-dependent inspection program. A piping system is comprised of piping, valves, supports and mechanical equipment-(e.g., pumps, tanks, heat exchangers). At the site, the process begins with

-the preparation of a work package. The Construction engineers assemble the appropriate drawings along with procedure and cpecification references for a unit of work into the work pack-age. They also initiate and add to the package those i

inspection forms needed to specify hold points for inspection and indicate mandatory hold point's on the inspection forms.

The work package st this point contains the design information necessary to erect the pipe and weld it into its permanent po-sition in accordance with design and procedural requirements.

Prior to allowing work to start on an item described in the work package, the package is forwarded to the inspection personnel who verify that applicable design requirements have been incorporated and that mandatory inspection hold points have been correctly identified. The inspection personnel also assign any additional hold points they fdB1 are necessary for inspection verification. As specified by procedure, " Travel-ers" for ASME,Section III Code Work are sent to the Authorized Nuclear Inspector (ANI) for review of completeness and accuracy end for assignment of hold points for verification. (A "Trav-oler" is a process control document that identifies the steps to be performed by craft and inspection personnel; the function of the ANI is described in greater detail below.)

The work package is then forwarded to craft personnel.

Craft supervisory and field personnel review the work in the field to ensure that no interference problems exist. Craft personnel then prepare items for installation by cleaning, marking, scribing, bevelling, etc., as required and notify the inspector for verification prior to fit-up.

Following pre-fit verification and acceptance, craft per-connel perform fit-up and notify the inspectors for inspection

as required by design und applicable codes for the particular item. The inspector verifies material type and other inspec-tion points, such as verification that an item is adequately supported or that mating surfaces are free of damage. Visual inspections of interim and completed welds are performed to en-sure that welds comply with applicable codes. If required by ASME Code,. design specification or site procedure, preheat and post-weld heat treatment is performed by the workers and docu-mented by inspection personnel. If required by code, the in-spector requests that applicable nondestructive examinations be performed. In addition, inspectors observe and document the torquing of bolts in a mechanical connection. When work and inspection progresses to a point where a preselected ANI manda-tory hold point is encountered, the inspector notifies the ANI.

The work is not resumed until the inspection and acceptance has been established by the ANI.

When all of the specified attributes for the work de-scribed in the package have been inspected and accepted by the inspectors and the ANI, the completed package is forwarded to a final review group. This group reviews the package to ensure that the required inspections have been performed, reports are properly executed and the package contains required documenta-tion. After the' review by the final review croup, the ANI re-views the package, if it is an ASME Code Class 1, 2 or 3 item; if acceptable, he indicates his approval by adding his signa-ture to the appropriate inspection forms.

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Completed systems are released to the start-up and testing group for further functional testing, hydostatic testing and I

preoperational testing. However, prior to the turnover, the system is subjected to a walkdown inspection by craft su-pervisory personnel as well as QA personnel as a final check.

This check is performed to inspect the system and components for damage that may have inadvertently occurred since final acceptance by the inspection personnel.

As part of the start-up testing process, a hydrostatic test is performed. In this test, the piping system is sub-jected to a specified internal pressure greater than the normal operating pressure to confirm that no leaks exist. This test is witnessed by inspection personnel who examine pressure boundary joints for leakage. The ANI also witnesses these pressure tests and monitors the inspections. On most tests, he will also select a random sample of joints to examine himself.

Applicants' Exhibit at Section III includes a de-scription of the inspection process for safety-related pipe hangers; instrumentation erection; mechanical and pipe welding; heating, ventilation and air conditioning (HVAC) system instal-lations; civil; electrical and seismic Category I equipment in-stallation.

Q16. Describe the QA surveillance program.

A16. (HRB) The QA Surveillance program at the Harris Plant Project was established and is implemented in accordance m

with Harris Plant Procedure CQA-28. Although not a regulatory requirement, this program wac established by Project management very.early in the Harris Plant construction stage and has pro-

'vided an additional level of assurance that the inspection or-ganizations have confirmed construction of a' quality plant and i

have prepared-and retained the required supporting documenta-tion. The program provides for surveillance of the Harris Plant Project's nuclear safety-related work through reinspec-i i

tion (actual physical duplication of the original inspection),

examination, evaluation, direct observation and comprehensive

reporting. The surveillance program provides a means of as-1

sessing the adequacy and effectiveness of the construction and i

inspection elements of the QA Program. Scheduling of surveil-lances is governed by such factors as: importance to nuclear safety; level of work activity; results of past surveillances, NRC inspections and Corporate QA audits; historical and poten-tial problem areas; and time elapsed.since last surveillance. s Surveillances are conducted by specially dedicated Quality Assurance (QA) inspectors in the Harris Plant QA/QC Unit and consist of sample reinspections of safety-related construction work. Surveillance is also performed on the QA Program itself l

through surveys of calibration of instruments; receiving

inspections; in-process welding; welder qualifications; nonde-structive examinations; weld material control; weld machine control; storage control; equipment maintenance; procurement control; document control; training / qualification /

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. I certification; QA records control; nonconformance control and

-hoisting and lifting activities. .These surveillances evaluate the effectiveness of programs and' systems that indirectly in-fluence the quality of plant components, while reinspection of the attributes on installed safety-related components evaluate directly the effectiveness of construction and inspection ac-tivities.

Q17. How does QA's confirmation of' complete, available records help ensure-quality of construction?

A17. (HRB) QA personnel review work packages and other documents against QA check-off lists to confirm that required inspections and tests have been performed and found acceptable.

l Q18. -Describe the system walkoowns and indicate how t-l deficiencies can be. discovered during the system walkdowns.

i A18. (RMP) As mentioned earlier, the plant operations organization is responsible for functional checkout, start-up testing and preoperational testing of systems after construc-l tion is finished. In practice, the completed parts of systems

-are transferred to the Start-up Group for testing as they are completed. The process of transferring responsibility and con-trol of a system to the start-up personnel is a formal one involving several verifications -- one of which is a physical walkdown in the field by representatives of the Construction,

' Start-up and QA organizations.

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The primary objective of the walkdown is to. verify.that the system and components have not been inadvertently damaged ,

or altered since the final inspection. This process has been successful in identifying damage and incomplete work. It pro-vides a= final verification'that no obvious deficiencies exist in the system or components being turned over for testing.

Q19. How does the start-up testing program verify that

. construction work has been accomplished in a quality manner?

A19. (RMP) The Harris Plant start-up testing program, as a key element in the broader context of overall site quality assurance activities, provides assurance and verification that the completed. systems and components perform in accordance with the design criteria and regulatory commitments. The start-up testing program also. contributes significantly.to verification of-auality during functional testing activities when simulation methods are used to verify' correct electrical circuits and in-strumentation-hookups. The proc 's conducted by members'of

.the plant operating staff in three sequential subprograms: the component' testing and initial testidg program, the preopera-tional: test program, and the start-up power ascension test pro-gram. '

The component testing and initial operation program is conducted during the final phases of construction when systems, or parts of systems, are completed to the point that testing

can begin. At this point systems are tested functionally by simulation. During this time equipment is operated to estab-b lish operating performance characteristics of individual compo-nents such as electric motors, switchgear, and valves. Pumps  !

and valves are also operated during the piping system cleaning I and flushing operations. Hydrostatic testing of the piping

system pressure boundary to verify leak tightness is also per-formed at this time.

The preoperational test program begins when equipment or systems are completed according to construction specifications.

This program verifies that specific systems and equipment per-

-form-as intended by design. Preoperational tests are performed by. running systems through various testing modes and comparing actual test results with the design performance criteria. Pre-operational tests are detailed, step-by-step tests of major equipment components and system functions.

.The start-up power ascension test program begins upon re-ceipt of the operating License and includes the initial reactor core loading. It verifies the ability of systems to perform as designed as the entire plant is brought through stages to a full' power condition.

The control of activities which affect quality during the entire start-up testin'g program is provided by the Start-Up QA program. This program operates under approved procedures.

Start-Up procedures which involve safety-related systems are reviewed independently by QA ps- .innel. All preoperational tests are reviewed by the design engineering organization for conformance to design parameters.

The start-up _ testing program is describ'ed in more detail in Applicants' Exhibit at Section V.

Q20. Describe the Corporate QA audit program for Harris Plant construction activities.

A20. (HRB) The Performance' Evaluation Unit (PEU) of the Corporate QA Department conducts audits, whose scope and fre-

.quency are specified by.the.PSAR. The PSAR reflects the requirements of American National Standard Institute Standard 45.2.12, " Requirements for Auditing of Quality Assurance Pro-grams for Nuclear Power Plants", as endorsed by NRC Regulatory Guide 1.144. CP&L's commitment to Regulatory Guide 1.144 in-ciudes audits of construction activities at least annually or

_at least once within_the life of the activity, whichever is shorter. These audits not only cover craft construction, de-sign engineering and preoperational activities, but also in-clude reviews of inspection and surveillance programs. Docu-mentation reviews, personnel qualification assessments and observations of work in process and completed are conducted in sufficient numbers and depth during the audits to enable objec-tive evaluations to be made. Verbal and written audit reports present the results to the appropriate levels of management including the President / Chief Executive Officer and the Senior Executive Vice President, Power Supply and Engineering & Con-struction. Nonconformances identified during the audits are followed-up by the PEU to verify completion of corrective action.

L Q21. Are there.any other activities undertaken by CP&L to l ensure the effectiveness of the construction-QA Program at the Harris Plant?

A21. {HRB, RMP) Yes. In June 1984, CP&L began imple-

. mentation of its QA attribute surveillance program -- a sample reinspection program of safety-related work at the Harris Plant.

Q22. Please describe the QA attribute surveillance pro-gram and discuss its purpose.

A22. (HRB, RMP) The methodology of the QA attribute sur-veillance program is based on the precedent established by the reinspection plan approved in Commonwealth Edison Co. (Byron Nuclear Power Station, Units 1 and 2) LBP-84-41, 20 N.R.C.

1203, 1220-1233, affirmed, ALAB-793, 20 N.R.C. 1591, 1598-99, 1607 (1984). Attribute surveillances are performed in accor-dance with Harris Plant Procedure CQA-7, " Evaluation of Program Effectiveness" (Applicants' Exhibit ) and provide a statis-l tical sampl ng method to assess empirically the overall adequa-cy and effectiveness of the inspection program for nuclesr i

safety-related work. It may also be used to determine the "ac-ceptablity rate" or proficiency of an individual inspector,

based on a statistical sample of items and attributes inspected i

and accepted by that inspector.

The following steps describe the implementation of the QA 4,

attribute-surveillance program:

1. Determine the total population of the component in question (i.e., piping spools, pipe hangers, electrical equip-ment, instruments) for the project.

2. . Determine the statistical sample size required to de-termine inspection proficiency level. (This part of the proce-dure is based on Military Standard lOS-D, Table I General Inspection Level II.)

3. Schedule reinspections of completed components in ap-proximately equal numbers each month until work related to the components in question is complete and the full sample has been reinspected.

4. Each month:

a. Randomly select completed work for reinspection and determine' attributes to be reinspected;

b. Review documentation for acceptability;

c. Reinspect components for quality attributes;

d. Report deficiencies as nonconformances for engineering evaluation and disposi-tion; and

e. Report statistical data to management for review.

Steps 1, 2 and 4 may also be applied in the event an individual inspector's work is questioned. The Director QA/QC -- Harris Plant.is responsible for the proper implementation of the QA cttribute surveillance program.

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Q23. Under the QA attribute surveillance program, how is the proficiency of inspectors determined?

A23. (HRB, RMP) Inspection effectiveness or proficiency is calculated by comparing the number of acceptable attributes with the total number o'f attributes reinspected and is ex-pressed as a percent. Minimum acceptable inspection effective-ness levels of 95% for objective inspection attributes and 90%

for subjective inspe tion attributes were established in Harris Plant Procedure CQA-7, based on the Byron reinspection plan.

Objective inspection attributes are measurable and are not greatly affected by human factors (e.g., physical dimensions).

-Conversely, subjective inspection attributes are subject to in-terpretation and result in the recording of qualitative data (e.g., weld overlap and surface profile).

Repeatability for objective inspection attributes is ex-pected to be high (at least 95% for a proficient inspector) and high, but'somewhat lower, for subjective inspection attributes (at least 90% for a proficient inspector). The CQA-7 accep-

.tance criteria recognizes that some inspector errors will exist; however, the errors nay only relate to minor defects which have no impact on nuclear safety. The acceptance criteria do not accept defects which have nuclear safety sig-nificance. The definition of a deficiency with nuclear safety significance is found at f0 C.F.R. 6 50.55(e):

"a deficiency four:d in design and construc-tion, which, were it to have remained uncorrected. could have affected adversely the safety of operations of the nuclear plant at any time throughout the expected lifetime

'of the plant."

Q24. What have been the results thus far of reinspections conducted in carrying out this QA attribute surveillance pro-gram?

A24. (HRB, RMP) In the one and one-half year period that the CQA-7 surveillance program has been in effect, 3,183 compo-nents, out of a total ss?ected sample size of 4,269 components, have been reinspected as of October 1, 1985. The components reinspected thus far encompass 54,560 attributes, of which only 269 were found to be deficient. This indicates the Harris Plant quality inspection program is 99.5% effective overall, with~the lowest individual component (structural steel instal-lation inspection) at 95.3%. No deficiency with safety signif-icance has been identified. The data generated by these reinspections are presented in Attachments 3 and 4 hereto. The results of this QA attribute surveillance program demonstrcte L cmpirically and conclusively the effectiveness of the Harris Plant Construction QA program.

Q25. Identify the outside organizations which have per-i

! formed evaluations of the Harris Plant.

, l A25. (RMP, HRB) The following agencies have regularly as-sessed the quality of construction at the Harris Plant:

a. the American Society of Mechanical Engi-neers (ASME), through its N-Stamp pro-gram;

b. the State of North Carolina,_ represented by the Authorized Nuclear Inspec-tor (s)(ANI);

c. the Institute for Nuclear Power Opera-tions (INPO); and

d. the Nuclear Regulatory Commission, through its normal Regional I&E and resident inspection program, the System-atic Assessment of Licensee Performance (SALP) program and the Construction Ap-praisal Team (CAT) evaluation program.

Q26. What is the ASME N-Stamp program?

A26. (RMP, HRB) ASME is an independent organization and is the primary code-setting body for nuclear vessels, piping systems and concrete containments. The NRC has adopted many aASME standerds and requires conformance to the ASME Boiler and

' Pressure Vessel Code, under 10 C.F.R. I 50.55(a), for certain safety-related systems and components. An organization must have an ASME QA Program that has been evaluated and approved (i.e., issued a Certificate of Authorization and an "N-Stamp")

by ASME in order to perform work on, or inspections of, those systems subject to the ASME Code.

The process of obtaining a Certificate of Authorization involved extensive investigations and audits of CP&L's ASME QA Program by ASME prior to issuance. CP&L was successful in

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L obtaining its Certificate upon initial application in 1979; in t.

1982 and_1985,'CP&LJsuccessfully passed ASME renewal audits necessary to maintain the Certificate of Authorization and

.N-Stamp.

t It should be noted that CP&L is one of only seven L

utilities in the c untry to have established its own ASME Code

~

l l program; most utilities rely on their constructor's N-Stamp l program.' CP&L, however, believes.that holding its own N-Stamp p _ provides an additional element in assuring the quality of the Harris Plant by allowing CP&L to have: direct control over Code

- work and inspection acitivites,.as well as being the direct re-r

.cipient of ANI inspection results.

i

! s I Q27. What is the role of the ANI?

l A27. (HRB).For piping systems designed and constructed in accordance with Section III of the ASME Code, both the Code and North Carolina. law require an independent third-party incpec-tion by an Authorized Inspection Agency ( AIA) . The AIA is rep-resented at the Harris Plant site by resident Authorized Nuclear Inspectors (ANI), who are actively involved in the in-l

. stallation, inspection and testing of code work. The. ANIS' du-

{

( ties,Lin'accordance with Article NA-5000,Section III, of the i . .

! ASME Code and ANSI N626.0, include assigning inapection hold-i l points, witnessing inspection processes and NDE activities, i.

witnessing pressure. tests, reviewing QA documentation and, most

~

importantly, monitoring the Certificate holder's compliance with the ASME quality assurance program.

4

e u

. l Q28. 96uat is-INPO.and what evaluations has it performed I

of the Harris Project?

A28. .(RMP) The Institute for Nuclear Power Operations (INPO) is an independent organization established by the nuclear utility industry for the purpose of assisting member utilities-in achieving the highest standards of excellence in nuclear plant construction and operation. In this regard, INPO has established guidelines-and criteria for the many diverse aspects of nuclear plant construction and operation which are based on "best practices," rather than minimum acceptable stan-( dards or requirements.

In August and September, 1984, INPO conducted an evalua-tion of the Harris-Plant construction project at the site and atiEbasco's principal design office. The INPO evaluation team examined ~ organization and administration, design control, con-struction control, project support, training, quality, and test control and also observed actual work and test performance.

The INPO evaluation team identified a number of " good practic-es" as well as a number of areas needing improvement; overall, INPO found that the systems in place to control the quality of design.and construction are being effectively implemented.

Also, in June, 1985, INPO conducted a "Etart-Up Assistance Visit" at the Harris Plant site. INPO reviewed site activities to assist in the station's preparation and readiness for oper-ating in a safe and reliable manner. Areas reviewed included

-._,,s_..,m. .....e..-.-.-....--- -

r-station organization and administration, operations, start-up, maintenance, t'chnical support, training and qualifications; some construct;on activities were also reviewed to assess im-pacts on completion and readiness for operation. For our present purposes,' it should be noted that INPO identified an a

" Good Practice" the QA statistical sampling method surveillance program described above, terming it an effective method for evaluating the effectiveness of the quality inspection program.

Q29. Recognizing the familiarity of the Board and parties with the NRC's inspection programs, please provide a brief overview of those programs.

A29. (RMP) The NRC's Regional I&E and Resident inspectors monitor construction performance and readiness for operation on a continual basis; these inspections support the view that the Harris Plant has been safely constructed. No escalated en-forcement actions have been taken by the Staff with respect to the Harris Plant Project and no violations of Severity Levels I, II or III have ever been identified.

In addition to the regular inspection program, the NRC performs two types of special evaluations -- the Systematic Assessment of Licensee Performance (SALP) and the Construction Appraisal Team (CAT) evaluations. The most recent SALP report (sponsored previously by Mr. Bemis and incorporated in the record following Tr. 3660) found that the Harris Plant quality programs had undergone significant improvement in staffing and organization leading to increased strength and effectiveness in the programs. In each SALP evaluation the Harris Plant has been given a rating of "2" for its QA programs, which means

" licensee resources are_ adequate and are. reasonably effective such that satisfactory performance with respect to * *

• con-struction is being achieved."

The. CAT evaluation is an in-depth review of detailed con-struction practices at the Harris Plant -- the most recent CAT report, dated December 24, 1984, is well over 100 pages in length. While'the report did identify a number of hardware Edeficiences, the' Harris Plant Project had the lowest number of cdverse findings of any of the nine formal CAT evaluations per-formed _in the country as of the date of the Harris Plant evalu-ction. Further, the CAT evaluation found evidence of good project management and construction practices at the Harris i

= Plant, including the fact that site engineering and inspection activities are primarily located and controlled on-site.

L Q30. Gentlemen, provide your overall assessment of the Construction Quality Assurance Program for the Harris Plant Project.

L A30. (RMP, HRB) We believe that the Harris Plant Con-

.struction QA Program is an outstanding QA program. The results of the QA attributes surveillance program provide empirical and

conclusive evidence to support our claim. Quality Assurance is i

a pervasive ingredient of the Harris Plant construction effort )

i

] and~the Harris Plant is a quality product.

i f

}

Craft workers are human and make errors. IIoweve r, as we have described in some detail, the many sequential layers of the Harris Plant QA Program are designed to identify and cor-

~

-rect errors -- whether caused by drug use or any other cause.

As our testimony demonatrates, the QA Program is working and the Harris Plant is 99.5% error free. Most importantly, there have been no deficiencies with safety significance identified in the QA attributes surveillance program or CQA-7 reinspection program.

i l

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. - - - . . - , - . . - , - ,, ., - , , . , ,~,-e-r--

ATTACHMENT 1 Harold R. Banks Manager - Corporate Quality Assurance

-1. Date-of Birth A. March 1, 1930 II. Education and Training A. Graduated from Indiana High School, Indiana, Pennsylvania - 1948 B. Class "C" Instructor Training School - 1954 - U. S. Navy C. Basic Nuclear Power Engineering School from 7/59 to 1/60 - U. S. Navy D. Nuclear Power Training Unit from 1/60 to 6/60 - U. S. Navy E. Naval Officer's, Limited Duty, Candidate School - 10/64 to 12/64 F. Completed DUR Guide Home Study Course (CP&L) - 3/74 G. Kepner Tregte Genco Program - 4/75 I- H. .SEE'- Public Utilities Management Course - 8/78 IIT. Experience 4

A. ' U. S. Navy

1. June 1948 - June 1959 l a. Shipboard and shore base assignment in power plant operation, l maintenance,' instructor, and supervision B.. Nuclear Power Engineering School and Prototype j 1. June 1959 - June 1960

a. Student C. Nuclear Submarine Prototype, Idaho Falls, Idaho 1.- June 1960 - June 1962

a. Nuclear Power Training Unit - qualified Engineering Officer of the Watch (Shift. Chief Operator and Instructor) i i'

=. . _

~ Harold R.: Banks Manager - Corporate Quality Assurance Page 2 D. USS Andrew Jackson

1. June 1962 - October 1964

a. Leading Machinery Division Chief, supervisor in charge of the operation of the nuclear power plant - qualified Engineering Officer of the Watch E. Naval Officer's Candidate School

1. October 1964 - December 1964

a. Student F. San Francisco Bay Naval Shipyard

1. December 1964 - July 1968

a. Nuclear Ship Superintendent - New construction and overhaul G. Carolina Power & Light Company

1. August 1968 - Present

a. August 1968 - Employed as a Resident Project Engineer at the H. B. Robinson Plant in Hartsville, South Carolina

b. July 1970 - Employed as a Resident Project Engineer in the Plant Design & Construction Department at the Brunswick Plant :Ln Southport, North Carolina

c. August 1971 - Employed as Manager - Quality Assurance in the Power Plant Design & Construction Department in Raleigh, North Carolina

d. February 1972 - Employed as Manager - Quality Assurance

[ Audit in the Special Services Department in Raleigh,

! North Carolina

e. July 1973 - Employed cs Manager - Quality Assurance &

Training Audit in the Special Services Department in Raleigh, North Carolina

f. August-1975 - Employed as Manager - Corporate Quality Assurance Audit in the Special Services Department in ,

Raleigh, North Carolina

g. March 1976 - Employed as Manager - Nuclear Generation in the Generation Department in Raleigh, North Carolina

w, -

Harold R. Banks .

Manager - Corporate Quality Assurance Page 3

h. November 1979 - Employed as General Manager - Harris in the Nuclear Operations Department in Raleigh, North Carolina

1. February 1981 - Employed as Manager - Corporate Quality Assurance in the Corporate Quality Assurance Department located in the General Office IV. Professional Societies A. Member of American Society of Mechanical Engineers B. Member of American Society of Nondestructive Testing C. Member of North Carolina Society of Engineers D. Member of American Nuclear Society E. ASME Codes & Standards Main Committee for Nuclear Quality Assurance, Subcommittee for Personnel Qualification and Work Groups for N45.2.12 (Auditing) and N45.2.23 (Auditor Qualification)

F. EEI QA Committee t

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ATTACHMENT 2 ROLAND M. PARSONS Project General Manager I. Date of Birth: March 13, 1936 II. Education:

A. BS Degree in Civil Engineering from Fresno State College, 1959 III. Experience:

A. August 1964 to November 1966

1. U. S. Forest Service, Nevada City, California

a. Forest Service representative on hydroelectric developments built on Forest Service land by others. ,

B. November 1966 to September 1973

1. Ebascc Services, Inc., Hartsville, South Carolina; and Jensen Beach, Florida

a. November 1966 - Field Engineer on construction of H. B.

Robinson Unit No. 2 (700 MW Westinghouse PWR nuclear power plant),

b. November 1967 - Resident Engineer responsible for site engineering and quality control for construction of H. B. Robinson Unit 2.

c. ' April 1971 - Senior Resident Engineer responsible for all site engineering for construction of St. Lucie Unit No. 1 (810 MW Combustion Engineering PWR nuclear power plant).

C.- September 1973 to May 1974

1. Daniel Construction, Jenkinsville, South Carolina

- a. Site Manager of Engineering responsible for all site engineering for construction of V. C. Sumner Nuclear Power Plant.

D. June 1974 to September 1976

1. Ebasco Services, Elma, Washington

a. Senior Resident Engineer responsible for all site engineer-ing on 1300 MW PRR nuclear power plant.

c- ~

1

._. s-4 + _ _ 4 _ ~ ~ . . s . _= ._ + w .. _ . . _ &_ a -e L Roland M. Parsons (2) l ..

t

E. September 20, 1976, to Present

1. Carolina Power & Light Company p a. September 20, 1976 - Employed as Site Manager in the Nuclear L Construction Section of the Power Plant Construction Depart-ment. , Located at the Harris site, New Hill, N. C.

b. April 27, 1979 - Reclassified as Site Manager (Harris) in the Harris Site Management Section of the Power-Plant Construction Department. Located at the Harris site, New l

Hill, N. C.

t

c. May 3, 1980 Reclassified as Site Manager - Harris Plant l Construction in the Harris Site Management Section of the

' Power Plant Construction Department. Located at the Harris site, New Hill, N. C.

d. January 31, 1981 - Reorganization - Site Manager - Harris Plant in the Harris' Site Management Section of the Nuclear Plant Construction Department. Located at the Harris site, i

New Hill, N. C.

e. March 22, 1982 - Title changed to Project General Manager.

f. September 3, 1983 - Reorganization - Project General Manager - Nuclear Generation Group, Harris Nuclear Project Department, Harris Plant Construction Section. Located at the Harris site, New Hill, N. C.

! g. August 1984 - Reorganization - Project General Manager -

Nuclear Generation Group, Harris Nuclear Project Department, Completion Assurance Section. Responsible for construction inspection, construction document assembly, and regulatory

g. 7 y

activities pertaining to canstruction. Located at the i Harris site, New Hill, N.-C.

i

h. . June 1985.- Reorganization - Project General Manager -

Nuclear Generation Group, Harris Nuclear Project Department.

Special assignment: engaged in project closeout activities.

i i

IV. Societies Memberships and Publications:

A. American Society of Civil Engineers l B. Registered Professional Engineer in North Carolina - No. 7634 C. Registered Professional Engineer in South Carolina - Nc. 3422

. - _ ~ _ . .- ._, . . - - _.

Roland M. Parsons (3)

D. Registered Professional Engineer in California - No. 16379 E. Registered Professional Engineer in Washington - No. 15111 F. Registered Professional Engineer in Florida --No. 16700 G. Publication: System for Control of Construction Quality; -

Proceedings of The American Society of Civil Engineers, Journal of The Construction-Division, March 1972 H. Publication: System for Material Movement to Work Areas; Journal of The Construction Division, March 1980.

I. Publication: Is Total CPM Really the Answer for Super Projects; Civil Engineering Magazine, November 1983.

Rev. 9/24/85 O

C.ttachment 3 Cctrber 1 ICIS OA A* TRIBUTE SURVEILLANCE

SUMMARY

' 08 SERVED C0eePONENTS C0eePONENTS COMPONENTS ATTRIBUTES DEFICIENT SURVEILLANCE IN INSPECTION

.IN REINSPECTED REINSPECTED ATTRI8UTES DEFICIENT ACTIVITY LOT (1) SAMPLE TO DATE TO DATE TO DATE TO DATE Piping Installation .2.600 200 191 16.194 11 99.9%

Mechanical 275 50 25 352 0 Equipment 100%

Cable Installation 17.100 315 308 2.583 0 100%

Cable Termination 34.000 500 343 2.689 20 99.2%

Cable Tray 7,000 200 127 1.820 16 99.1%

Conduit 8.000 200 140 1.716 0 100%

Electrical aanes 3.100 80 76 1.073 0 100%

Electrical 1.000 80 55 689 2 99.7%

Equipment Instrumentation ~ 452 50 27 1.237 8 99.4%

Long Packages Instrumentation 6.915 200 167 1.850 7 99.6%

Hangers & Supports Instrumentation 853 80 43 169 5 97%

Short Packages Instrumentation 250 32 J 8 0 100%

Electrical Packages Ptre Hangers 20.424 500 460 11.707 80 99.3%

HVAC Supports 4.500 200 62 1.235 6 99.5%

Combination 135 32 4 185 0 100%

Supports Cable Tray 84 1.959 16 99.2%

Supports 2.525 200 Eng. Conduit 97 1.193 Supports 4 99.7%

e

COtePONENTS OSSEiVE*>

COMPONE::TS C00sPONENTS A TT7.ISU TES DEFICIENT SURVEILLANCE IN IN INSPECTION REINSPECTED REINSPECTED ATTRIBUTES DEFICIENT ACTIVITY LOT (1) SAMPLE TO DATE TO DATE TO DATE TO DATE Field Run Conduit 15,000 500 395 1,520 Supports 19 98,7%

HVAC Ouctuork 6,000 315 248 5,154 17 99,6%

Structural Steet 4.328 315 330 1,227 58 95,3%

Junction Som 2,000 200 0 0 Supporta 0 NA TOTALS

• 131,453 4,249 3,183 54.560 269 99.5%

(1) Total Sample teally, Lot Size (popu:stion) is estimated based on current project figures and may be adjusted period-size may be adjusted .s made necessary by any change to the lot size.

5 O

ATTACHMENT 4 EVALUATION OF QA ATTRIBUTES SURVEILLANCE

SUMMARY

OF R ESULTS (OCTOBER I,1985) 60.000 50D00 40.000

\

<n 30000 \

y 20,000  %

x 5 N s

10DOO  %

O , .

54,560 269 ZERO TOTAL OBSERVED DEFICIENT ATTRIBUTES DEFICIENT ATTRIBUTES REINSPECTED ATTRIBUTES WITH DESIGN SIGNIFICANCE

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