ML19343D379

Transcript of Testimony Re Alternative QA Organizational Structures

ML19343D379
Person / Time
Site:	South Texas
Issue date:	04/27/1981
From:	Amaral J HOUSTON LIGHTING & POWER CO.
To:
Shared Package
ML19343D370	List: ML19343D369 ML19343D374 ML19343D377 ML19343D379
References
ISSUANCES-OL, NUDOCS 8105040361
Download: ML19343D379 (9)

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5i TESTIMONY OF JOHN M. AMARAL 6i REGARDING ALTERNATIVE OA ORGANIZATIONAL STRUCTURES 7i 3l 9l Q. 1 Please state your name and occupation.

A. 1 John M. Amaral. I am Manager of Quality Assurance h2i of Bechtel Power Corporation (Bechtel).

.3 4 Q. 2 Please describe your educational and professional L6 background.

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, A. 2 I am a graduate of the University of Southern to,

,iG ! California where I studied Industrial Management and Industrial n i Engineering. I have over thirty years of industry. experience.

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3 Prior to joining Bechtel, I was the Manager, Quality 15 Systems with Aerojet Nuclear Systems Company. I also held 16 17 several other upper positions with that corporation in ZS :

l 19 , various aspects of quality assurance (QA), reliability and 30 31 program management.

32 In June, 1972 I joined Bechtial as QA Manager for the 33 3 '

LMFBR, Fast Flux Test Facility. I served as Deputy QA 36 - Manager of the San Francisco Power Division. In 1976, I was 3,

38 promoted to Manager,, QA at the Bechtel Gaithersburg Division.

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to i I am now Manager of QA for Bechtel.

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42 I am a registered Professional Engineer in California 43 '

g4  ! and certified as a Reliability Engineer by the American 45 I am currently Chairman of the 46 ,

Society for Quality Control.

II ! Energy Division of the American Society for Quality Control.

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-lle-l 8105040361

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3l 4l 5; Q. 3 What is the purpose of your testimony?

6i 7 A. 3 I will describe Bechtel's recommendations to 0

9 Houston Lighting & Power Company (HL&P) concerning alterna-0  !

tive QA organizational structures for the South Texas Project 1

2l (STP), and explain the basis for Bechtel's recommendations.

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.4 , Q. 4 How did Bechtel become involved in reviewing the

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.6 ; QA program for STP?

g; l7i A. 4 In January 1980, HL&P requested that Bechtel

'3 I review the QA program which was being implemented at SJP.

Ot l! The requested review was to include both the deficiencies in 2

.3 the QA program which had been discovered in HL&P's own

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.5 reviews of the program, and those preliminarily identified in

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,7 discussions between HL&P and NRC Region IV personnel, as 3!

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,9 well as alleged deficiencies which had appeared in the news 0'

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media. This was before the NRC I&E Report 79-19, the Notice l2 i of Violation or the Order to show cause were issued.

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4 ! Q. 5 How did Bechtel perform its review of the QA

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l6 l program?

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[8 ! A. 5 Under my supervision,. selected personnel from 19i

,o ; three of the power division offices of Bechtel were assigned il !

>2 ; t perform a comprehensive, in-depth audit of the construction 3

QA program at STP. For these purposes we examined celected

{4l i5 ! elements of the STP quality assurance activities. Our 66 i 67 review involved a check of QA manuals and procedures in use 18 19 !

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5l by both B&R and HL&P; an examination of design control 6'

7j procedures (especially field-initiated changes); a review of 3I special processes (primarily welding and NDE activities); an

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'$j audit of the nonconformance reporting system and several CL !

L2l other areas. The review identified a number of concerns L3 I (4 which we were able to trace to six " root causes" which are L5 '

(g l discussed in the testimony of Mr. Oprea.

L7 (g j The results of the comprehensive audit were contained b3 in the Final Quality Assurance Management Report to HL&P 20 <

21 dated July 24, 1980 which was attached to EL&P's response to 22 13 the Show Cause Order.

24 25 Q. 6 When did HL&P request Bechtel to review alterna-25 1 27 tive QA organizational structures at STP?

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{g , A. 6 In April, 1980, after Bechtel had begun its

}'O' , review of the STP construction QA program, the NRC requested 32 ' that EL&P evaluate five options for the STP QA organiza-33 34 ; i tional structure. Since Bechtel was in the midst of its

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audit of the QA program, HL&P requested our assistance in 37 ! I 38 evaluating the options suggested by the NRC.

no i l Q. 7 How was the Bechtel review of alternative QA 41 4j ; organizational structures conducted? 43 l A. 7 The review of alternatives was conducted in 44 l 45 parallel with. the Bechtel audit of the STP construction QA 46 { 47 i program and overlapped the audit schedule. Our conclusions 43 l 49 l l 50 i I l 51 1  ! I i i ) _1 v_ 1 1 1

L 2. 3I 4 5l and recommendations were based on consultation with the 6 audit teams, with other Bechtel Quality Assurance Managers 7! 3' and with other managerial personnel in Bechtel whose exper-9: 60! ience in the nuclear power industry is both broad and success-61 i L2 ; ful. L3 ' (4 Q. 8 What were your basic conclusions and recommenda-(j L tions on organizational structure? l A. 8 Our conclusions were contained in my letter to 19 ; HL&P of May 9, 1980, which addressed the alternative organi-20 ! 31 ' zations suggested by the NRC. I pointed out that the solu-22 l 23 tions to the root causes of the QA problems were not dependent 24 , 25 , upon the particular QA organizational structure. As I 36 t 27 I stated, "Since these root causes exist, the organizational g i structure of the Quality Assurance Departments is of lesser 30 concern." I emphasized the need for positive attitudes 32 ! toward quality management. 33 ; 34 i on the basis of our review, Bechtel recommended an 35 ' . 36 i . expanded version of the first alternative or " option A"  ! 37 i 38 i mentioned by the NRC (i.e., the existing organization with 39 ! 40 upgraded staffing). 4k.; 4 i We described our approach as encompassing ". . . mainte-43 ' nance of the existing basic assignment of QA program responsi-44 45 bilities of both HL&P and Brown and Root; acquisition of 46 47 ! qualified quality professionals with credentials that indicate 48 I i 49 j j 50 1 51 i i

1i 2; l 3i 4j 5; successful performance of similar functions; and dedication 6i 7i to fully implement the upgraded QA plan, with particular 8' 9{ attention to performance of the QA Tasks and functions. . . . 0l 1! As part of this alternative, we recommended "that as an 2! 3 interim step HL&P acquire the services of an outside organiza-4 tion dedicated to and possessing the expertise required for 5 6 performing this type of function. The personnel of the 7i gj third party organization could be integrated into the HL&P 9 0t and Brown & Root organizations in supervisory positions 9 g, until such time as permanent personnel can be obtained by both companies." We felt that this was the quickest and 5 easiest way to fill the apparent voids in the STP QA organi-6 7t zation, but, much more importantly, we concluded that this S: 9; alternative retained the fundamental precept that the " doers" l 0' l 9

 -            have responsibility for both doing and controlling the work.

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It is a concept which has been implemented successfully in

numerous utility /AE Constructor combinations over the years 6

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       .      in nuclear power construction. Admittedly, this alternative 8!           does not represent a dramatic change in organizational 9:

0 arrangements but, in concert with the significant upgrading 1 2 of both organizations' QA/QC staffs (which we recommended), i 3 4l It was our view that these steps addressed most directly the 5l 6i concerns we had identified. 7i a! ! 9i 0 1l i I

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1 L; ' 2l 3l 4i l 5l Q. 9 Why did Bechtel not recommend a new structure 6i 7i giving QA responsibilities to a third party organization? llI 3: l 9 A. 9 There are some QA functions that a third party

   ,0 organization can perform effectively in an operation as 1'l
   .2          demanding and complex as the design, procurement and construc-
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   .4          tion of a nuclear plant.      But, in my opinion, it is mandatory 3                                                                          .
   .6          that the organization performing a function be responsible
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   ,g- i       for the quality of that function.      The organization responsi-e'
   },          ble for design must be held accountable for the quality of 1
 }>            the design - and the constructor must accept responsibility j             for the quality of the construction.
  .5                 It is evident that if the organization doing the work
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  .7 !         is responsible for the quality of its work, the addition of
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 ,9            a third party can do nothing to improve quality.      To the
 .0 i 2             contrary, such an addition might relieve the working organi-
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3 zation of responsibility for quality even though the third 4k sI party cannot be expected to be responsible for something it l l 6 . cannot control. i 7;  : S This situation would'be compounded in a case such as

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9! 0l STP where over half the plant is completed. What would be a j feasible dividing line for the transfer of QA responsibility? I ' 31 4l For the entire plant? For the remaining plant? For open 5 deficiencies?, For improperly closed deficiencies? For

 'I8*!         rework?    It is obvious that the transfer of responsibility l

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i 1: I 2 l 3l 4l, 5 for QA would be an extremely complex undertaking, if feasible, 6\ 7I at all. gi ' - It is for these reasons that we believe that a third 9

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party QA organization is not an appropriate alternative and k2 ! that we made our recommendation to:

 '.3 L4                  A. Strengthen the HL&P and B&R QA organizations, and L3                                                                             -

L6 B. Provide motivational indoctrination to HL&P and B&R L7 i Lg i at all levels of management. 3, 50, Q. 10 Can you briefly describe the principal reasons n' for recommending against the other options set out in the {} 13 NRC's Order to Show Cause? 24 15 A. 10 Yes, Option B involved the development of an 16 ; 17 - organizational structure where all levels of B&R QA/QC IS , 29 ; report to HL&P. Although this has the superficial benefit 30 : 3; of appearing to enhance HL&P control over the QA/QC function, 32 it would place B&R QA/QC personnel in the position of " serv-33 34 i ing two masters" and raise, again, 'the cor ern about reliev-33 i 36 ; . ing B&R " doers" of quality responsibility. I would also be i 37 l 38 , very concerned about miring HL&P in the details of the 39 i , 40 i program and thereby detracting from their ability to maintain 41 l 42 ; an overview of the quality function. 43 , 34 l Under Option C, EL&P would establish a total QA/QC organization ,to conduct those functions now performed by , 4f ! 4 47 ' B&R. Again, this is a dramatic change but one which has the 48 : 49 , 50 , 51 i i

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t 2, 3! - 4l 5> potentially deleterious effect of relieving B&R of responsi-6! bility for quality. It also has many of the same disadvan-7! 8I tages of Option B as well as a potential for a period of 91

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instability in the relationship between the two organizations , .[1 2' as EL&P personnel move in to a more direct supervisory role ( '3 4' with respect to B&R's day-to-day activities. f* Option D essentially calls for a third party to er.ecute L7 i QA/QC functions. I believe that both organizations would L5 L9 i suffer from their lack of involvement in quality-related 20 ' 21 , functions . mentioned above. I can see a confusion 22 , 23 i between the responsibilities of HL&P and the third party as 24 25 well as a perturbation in the relationship between B&R and 26 27 HL&P by the addition of a new interface - a third party with 28 : 29 ; its own methods of correspondence control, procedural documents, 30 etc. 31 5 32 We also looked at Option E - establishing in EL&P a 33 : 34 ! duplicate QA/QC organization to match that of B&R. Although 35 i 36 ' this " beefs up" the organization by achieving a "one-to-one" 37 ! 3g ; relationship between B&R and HL&P QA/QC personnel, it detracts 4 from " doer responsibility" on the part of B&R and, in my 41 , judgment, has a large potential for gaps in implementation 42 : 43 ! ("I thought he did it"). 44 j 45 l Q. 11 Has Bechtel followed the implementation of its 46  : 47 l recommendatiens? 48 ! 49 i 50 l 51

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     $;                  A. 11     Yes. We have recently completed a review and 6I 7;            audit of the QA/QC program against our 198C4 findings and we 8! '

9, found that the concerns we expressed last year have been k0 i addressed satisfactorily. Our observations also tend to

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   '2 i support our judgment as to the optimum organizational arrange-
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   .               ment for QA/QC functions at the STP.
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