ML19343D369
| ML19343D369 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/27/1981 |
| From: | Briskin J, Frazar R, Oprea G HOUSTON LIGHTING & POWER CO. |
| To: | |
| Shared Package | |
| ML19343D370 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8105040351 | |
| Download: ML19343D369 (54) | |
Text
{{#Wiki_filter:.. 1: 2. 4! 5 UNITED STATES OF AMERICA
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75)N egd-goS 6l I NUCLEAR REGULATORY COMMISSION: 7l 1 8 9l
.g BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 1,
2i In the Matter of: 5
.' 4 g 3 HOUSTON LIGHTING & POWER S Docket Nos. 50-4980L 6 COMPANY, ET AL. 50-4990L
-- 5 7 5 S' l (South Texas Project, 5 9l Units 1 & 2) 5 0! 5 1l 2
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}; TESTIMONY ON BEHALF OF HOUSTON LIGHTING & POWER COMPANY, ET AJ.
3 OF 6i 7I MR. GEORGE W. OPREA, JR. 3i MR. JOSEPH W. BRISKIN 9l MR. RICHARD A. FRAZAR l 0l MR. JOHN M. AMARAL 1 l 2: ON ! 3l1 4 THE EXPERIENCE OF HOUSTON LIGHTING & POWER COMPANY 5l IN THE CONSTRUCTION OF THE SOUTH TEXAS PROJECT AND THE ACTIONS TAKEN AS A RESULT OF THE 6! 7 NRC ORDER TO SHOW CAUSE. 8l , m q f?' l W ,~ \ 1; w , a s 2l re g [, -
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L 2 3, 4 3 UNITED STATES OF AIERICA 6 NUCLEAR REGULATORY COMMISSION 7 3 9 BEFORE THE ATOMIC SAFEW AND LICENSING BOARD
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- *g In the Matter of
- 5
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'3 EOUSTON LIGHTING & POWER 5 Docket Nos. 50-4980L 'f4 ,- COMPANY, EAl. 5 50-4990L '
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. (South Texas Project, 5 '7 . Units 1 & 2) 5 '5 . 5 ,3 10 97 APPLICANTS' TESTIMONY ON CEE EXPERIENCE OF N
EOUSTON LIGHTING & POWER CCMPANY IN THE
] CCNSTRUCTION OF THE SOUTH TEXAS PROJECT AND THE .s ACTIONS TA E AS A RESULT OF THE NRC SHOW CAUSE ORDER The following is testimony presented on behalf of 17 Ecuston Lighting & Power Company, et al. (Applicants) on the 13 !9 experience of Houston Lighting & Power Company (EL&P) in the 10 31 construction of the South Texas Project (STP) and the actions 12 I
33 taken as a result of the NRC Order to Show Cause dated 34 IS April 30, 1980 (Show Cause Order). The panel of witnesses Ik is presenting this testimony consists of Mr. George W. Oprea, IS Jr., Mr. Richard A. Frazar, Mr. Joseph W. Briskin and Mr. 19 10 John M. Amaral. 11 - l 12 The testimony consists of the following segments: l 13 l t.$ (1) Mr. Georga W. Cprea, Jr. with respect to the I 18 l gj development and implementation of the Quality Assurance (QA) Program at STP and the EL&P management reaction to
*o l the NRC Show Cause Order; 20 1 5L ;
l
1 2. 3 . 4 5 (2) Mr. Joseph W. Briskin with respect to HL&P's Task 6t 7i Force approach to responding to the NRC Show Cause Order; 8 9 and 0 j, (3) Mr. Richard A. Frazar with respect to changes made 2 to administrative controls in response to the NRC Show Cause 4 Order;
.= . .6 (4) Mr. John M. Amaral with respect to Bechtel's recom- .7 , ,3 ' mendations concerning alternative QA organizational structures .9 : 'O , for STP. !1 !2 '3 i !4 !5 !6 !7 T. Hudson:11:02:E !8 !9 l 10 11 12 13 14 !
15 16 , 17 18 ~ 19 ' 10 : 11 , 12 l 13 ' ! 14i l 15 ! ' l 16! 87 ' 58 I 19 l 30 . 1
L 2; ' l 3: ' 4! l 5! TESTIMONY OF GEORGE W. OPREA, JR. . 6! REGARDING DEVELOPMENT AND IMPLEMENTATION OF THE 7! QA PROGRAM AT STP AND HL&P MANAGEMENT REACTION 8l TO THE NRC ORDER TO SHOW CAUSE 9i 0l 1l Q. 1 Please state your name and occupation. 2'
^* 1 I am Ge rge W Oprea, Jr., Executive Vice President 3 !
of Houston Lighting & Power Company (HL&P) and a member of 6 the HL&P Board of Directors. 7' E: 9' O! Q. 2 Describe your professional qualifications and 1! 2i ecucational background. 3 4j A. 2 I graduated from Rice University in 1952 with a Bachelor of Arts and.a Bachelor of Science in Electrical 7l 3. Engineering. That same year, I joined HL&P in the Distribu-9I tion Planning Section of the Engineering Department where I Oi 1l 2; participated in computer applications engineering for system i 3l 4 planning. In 1965, I was named superintendent of the Enginear-5j ing Planning Division and two years later. assumed responsibility 6! as Project Manager, Energy Control Center. In 1970, I was 7l 1 8! 9i promoted to Manager of the Energy Control and Dispatching 0l Department. I was elected Vice President of Operations in l 1! 2i 1971 and Group Vice President of Operations in 1973. I 3 4I assumed my present position as Executive Vice President and 5 6 member of the Board of Directors in 1974. ! 7i 8 9 0l l 1i J
L 2 3 4 5 I am a registered Professional Engineer in Texas. 6 7 Q. 3 What are your responsibilities as Executive vice 3 g President? O 1 A. 3 I am the senior corporate officer in charge of n EL&P's nuclear program. With respect to the South Texas
}
4 Project (STP), I am responsible for both Project management
.6 and quality assurance (QA) direction. The EL&P staffs that .4 .5 '
perform Project management and QA activities at the STP do
.o so under my direction and control.
4 Q. 4 What has been the extent of your involve =ent in
- i STP?
.c A. 4 I have been involved in STP since the earliest
- S
;7 planning for the project, primarily from the standpoint of 'S
- 9 administration and manage =ent control.
l 10 i ;1 Q. 5 Please describe the purpose of your testimony. 12
;3 A. 5 The purpose of my testimony is to describe the I4 development of the QA program on STP and our experience in i
l f.6 , implementing the program. This will provide a perspective 64 I II against which to evaluate the NRC's Order to Show Cause and 19 iO , Notice of violation of April 30, 1980. My testimony briefly el i2 discusses the NRC findings that supported issuance of those i3
;.g documents and how we have acted to improve the QA program.
, 15 : k6 I will explain'how and why we have made changes in the l .. program and why I believe that our QA program is a sound [#3 i9 , 10 I., { l .
i 1 2, 3i 4 5 program that is adequate to complete this Project in accor-6 7 dance with all applicable requirements. Finally, my testi-8, 9 many describes the performance I have been seeing on the
*0 y l Project over the past year, since we made the major changes .2 to ensure that the HL&P and Brown & Root, Inc. (B&R) QA .3 +4 programs are properly implemented. I think that by covering .6 this ground I can best explain my view that our QA program .7 .E l has been, and continues to be, in compliance with applicable .9 !O requirements.
n . {} Q. 6 Please describe in general terms how HL&P devel-l3 oped its management team for STP prior to the fall of 1979. A. 6 In the initial planning of the STP, HL&P and the 17 ! co owners of STP decided to contract with B&R for Architect-18 ' 19 > Engineer and Constructor services. B&R is one of the world's 10 l 11 largest construction companies and it had nuclear experience 12 33 as the Constructor of Carolina Power & Light's Brunswick 14 l 33 Nuclear Plant and the Comanche Peak Steam Electric Station Ik 3s , being constructed for Texas Utilities, Inc. and other 38 utilities. The contract provided for B&R to perform QA 39 i 10 i services applicable to its scope of design and construction l 11 12 work. This is a fairly typical contracting practice in the 43 : 34 l nuclear industry. l 85 1 : 46 We planned to handle QA management in a manner similar gg to the way other utilities had managed their nuclear projects, 19 50 , 51 l l 1
L 2 3l 4' 5r i.e., the AE/ contractor'was to provide and implement the QA 6' 7- program for activities within the scope of its contract, but 8 9{ HL&P would maintain ultimate responsibility for the program
'O y; and changes thereto. To perform our review and approval f role, we required B&R to submit certain periodic reports of its progress on the Project and in the QA program.
LS , Of course, at the beginning of the Project B&R activities L7 , LE ' were limited and HL&P's Project staffing was consistent with L9 1 10 that level of activity. The resources HL&P devoted to n jj Project management in the early stages were greater than
'3 ;, those HL&P had devoted to fossil Projects, but were nonethe-IU less quite limited in comparison to the Project team that 16 17 has since grown. As design and construction progressed, !S !
l 29 i HL&P's staff on the Project expanded, and we went to a 10 ' 31 matrix management system with a separate STP Project organi-32 l 13 zation. By 1978, we had expanded from the initial 36 HL&P 34 l 33 ; personnel involved in the Project to about 180, including a 16 i - corresponding increase in our QA staffing. By the fall of 37 , l 38; 1979, with accelerated design and construction activities 1 39 to l HL&P's staff on the Project had grown to about 202, including 11 i i 12 17 professionals in the QA organization. The increase was i 13 l g4l not alone in numbers but also in the diversity of the technical 15 l and engineering skills necessary to develop a Project of 16 i 17 this size and complexity. l gg 19 l 50 - 51 ! i i l l
L' 2. 3i 4 5 Q. 7 Describe the HL&P QA Organization prior to the 6,, 7i fall of 1979. 8; 9! A. 7 Mr. E. A. Turner, then Vice President, Power 0! hl Plant Construction and Technical Services, reported to me,
.2 and was responsible for both the QA Department and the .3 *f Project Management Team. Under Mr. Turner, the Manager, QA, a . .6 was in charge of the QA Department Within the QA Department ./ : .5 ' there were a Projects QA Manager and, reporting to him, an .9 ;
10 STP Project QA Supervisor. The Project QA Supervisor was 11
*j stationed in Houston, and he directed the activities of the Site QA Supervisor, who was stationed at the site.
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;* Under the Manager, QA there was a Houston-based QA .6 17! services group that was responsible for procurement QA and !S 19 the auditing of all quality related activities on the Project.
10 11 The HL&P QA staff at the Project site was supervised by 12 13 the Site QA Supervisor. The staff under the Site QA .'uper-14 ! gg visor was divided into four grcups: general, civil, electrical 16 I,s > and mechanical. 38 l Q. 8 During the period up to the fall of 1979, what 19 10 ' was the role of HL&P's QA staff? I 11 l 12 A. 8 As discussed by Mr. Frazar in his testimony on l 13 ! ! 14 l the management of the HL&P QA program, B&R provides QA 15 l 16 , services on the activities within the scope of its design 17 gg and construction contract. Other QA services are supplied 19 i 50 ; il : L
L 2 3 - 4 5 by the various vendors (including Westinghouse Electric 6 7; Corp.) and subcontractors. Tha EL&P QA staff has performed 8 9+ an oversight function and provided direction to the contrac-LO : (1 i tors on implementation of the STP QA Program requirements. L2 ' In the early stages, the Project activities were devoted L3 94 to design and procurement, both of which were handled out of {g 16 the Houston offices. The HL&P QA staff was based in Houston L7 4 13 and its attention was focused on these activities and on 19 30 writing procedures for the QA functions during construction. 21 22 As construction progressed, EL&P's site QA staff was expanded. 23 The HL&P QA staff reviewed Project documents such as 24 25 the Nonconformance Reports described in Mr. Fra:ar's testi-l 26 , 27 ' mony, monitored on-site QA/QC activities, and provided 83 29 direction to B&R on the QA Program. The HL&P QA staff in 30 31 Houston continued to be responsible for HLP's Project audit. 32 ' 33 activities and vendor surveillance. The HL&P site QA staff i 34 35 l monitored the on-site activities of B&R and its subcontractors. 36 ~ The HL&P site QA group developed a plan which identified 37 0 39 , those functions of B&R Construction and QA/QC to be monitored 40 i and the frequency of surveillance. Checklists were developed 41 42 ' to implement the planned monitoring and surveillance. If, 43 44 l during the course of monitoring and surveillance, a noncon-45 1 46 i formance or procedural deviation was identified, the HL&P QA 47 ' -j 4g l personnel had several alternative procedures to direct 49 ! 50 51 i i li 2, 3; 4t 5 correction of the condition, depending on its scope and 6l ; 7: significance. They could request the cognizant B&R QA/QC 8 9; Inspection Supervisor to initiate a deficiency report; note LO ' (1 ; the unsatisfactory condition on the inspection checklist and L2 ' draft a memorandum or letter to the responsible party; or (3 li, request the HL&P Site QA Supervisor to issue a Stop Work Lo , - L6 ; Notice. The HL&P site QA group reviewed and approved the L7 LE l planning, development and implementation of B&R QA and L9 ; 10 construction procedures and p.rticipated in the resolution 11 {{! of problems identified by HL&P QA and Construction, B&R QA
*3 and Construction, and the NRC.
f Q. 9 During the period up to the fall of 1979, were 17 i there regular inspections performed by the NRC Office of 18 19 i Inspection and Enforcement (I&E)? 10 ' il A. 9 Yes. NRC inspections began even before the con-12 ' 33 struction permits were issued and there were unannounced NRC 34 ;
- 15. inspections on an average of once a month. The NRC sta-
! 16 - tioned a full-time resident reactor inspector at STP in 37 1 I8! 19 ! September 1979. Prior to November 15, 1979 there had been 10f 59 NRC inspections and investigations, which we understand 11 i 12 i to have involved about 2,700 inspector-hours of effort. 13 '
- 14 l Q. 10 During that time, did the NRC inspectors find l !.5
! 16 any incidents of noncompliance with NRC requirements? 17 ! l 18 I ! 19 : l 30 i ill l t l .. . - - _ .
L 2 3l 4 5 A. 10 Yes. There were findings o f noncompliance in 6; 7I several of the inspection reports. U1 to November 15, 1979, 8' 9i there had been 33 such findings.
*0l 1 Q. 11 How were those findings classified by NRC?
3, A. 11 NRC has three classifications for noncompliances:
.3 (i) violations, (ii) infractions, and (iii) deficiencies. ,'6 . Violations are the most serious noncompliances and deficien- .1 . '. E ' cies the least serious. The NRC found 27 were infractions '.9 i 10 and 6 vere deficiencies. There were no violations.
n ' {}, Q. 12 How did the Company react to those NRC findings?
'3 ;, A. 12 Any citation of noncompliance is disturbing and IU our initial reaction was to question the HL&P QA staff as to 16 17 why these problems had not been identified first by HL&P.
13 29 The HL&P staff immediately prepared responses to the citations 30 ' , 31 and HL&P management approved each response. I realized that ! 32 ! 33 ; in such a large and complex undertaking there were bound to 34 I 35 ; be some deficiencies, but I hoped to keep them to a minimum. 36 So, I was kept informed of the HL&P staff reports ccecerning l 37 ;i 38 ' the circumstances of.the noncompliances and of the corrective 39 . 40 : actions taken. 11 I 42 Q. 13 Did the NRC notices of noncompliance prior to 43 late 1979 indicate to you that there were serious deficiencies 44l 45 i 46 in the QA program? 47 ! 48 i 49 ! 50 ; 51 i i
L 2, 31 4: 5, A. 13 No. As I just said, every finding that we were 6i 7i not in compliance with the NRC requirements concerned me, 8i 9j but I knew that with a project as large and complex as STP, 0' 'y ! , there were bound to be some of these incidents. It was my judgment that these were isolated events on a project that .4 was achieving generally good quality work, but we were .2 '6 . intent on maintaining as low a rate of noncompliance as .7 i 'El . possible. In addition to our site QA group, HL&P was monitor- '9' 10 ing the implementati.on of the STP QA program with our staff n ! {} of QA auditors. The auditors conducted periodic formal '3 audits of the design and construction activities and prepared j4 15 written audit reports. Our own audits confirmed that construc-16 17 tion was generally proceeding in compliance with NRC require-23 : 29 : ments and Project design requirements. 30 ; 31 Q. 14 During that period before the fall of 1979, were 32 ' 33 ; you aware of confrontations between Construction personnel 34 ! and QC Inspectors at STP? 35 36 37 ; i . A. 14 Yes. I was informed of a physical altercation 38 ! between a Civil OC Inspector and a concrete foreman in June 39 ; 40 i 1977. The testimony of Mr. Charles Singleton describes the il i 42 l incident in detail. HL&P's QA staff investigated the matter 43 : 44 l and was involved with B&R at the Project level in deter-45 i mining the appropriate response to prevent the incident from 46 Y g adversely affecting the morale and attitudes of Project 49 I personnel. 5G ! 51 ! 1
1 i 2 3! 44 5i HL&P Project personnel held discussions with the B&R 6i 7! Construction Project Manager and a policy aimed at minimizing 8: 9i friction and altercations was developed. Additionally, I I Ol 3 was briefed on the report of the NRC investigation regarding 2i i 3l the June 1977 incident and the HL&P Site QA Supervisor's 4 action on the incident. I did not get directly involved S -
.6 with the action taken on this incident because I felt that .7 .
E' it had been thoroughly investigated by my staff and the NRC, 9i 0i and that the action taken was satisfactory. 9 j' Similarly, I was informed of the incident which took 3
, place between a B&R Construction Engineer and a Civil QC 5 Inspector much later, in March 1979. This incident is also 6
7i d2 scribed in the testimony of Mr. Logan Wilson and Mr. Warnick 8i 9I and, as they indicated, was also investigated by the NRC. 0 1' Again, no further action on HL&P's part was warranted since 2i 3, the incident had been investigated by my staff and the NRC, 4i 3; and the action taken by B&R was satisfactory. 6 j - When Mr. Swayze was fired in August 1978 as discussed 7 8i in the testimony of Dr. Broom, we were concerned that his 9i 0l firing might be improperly interpreted by other QC Inspectors i 1i 2, as a form of intimidation. But, as described by Mr. Logan 3 4l 1 Wilson, our increased surveillance showed that Mr. Swayze's 5I 6! firing had no adverse impact on the QC Inspectors' job a i f performance, and this matter was, of course, also investi-9 gated by the NRC. Oi
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1; 2 1 35 4[ 5i Q. 15 Were there other instances of friction between 6; 7i QC and Construction personnel? 8i 9! A. 13 Yes. As pointed out in Mr. Logan Wilson's I
*0 ;gi testimony there is always some friction between Construction *! and QC, if QC is performing its job, and the degree of 3 friction varies from time to time. Prior to about mid-1979, a - .6 there were some isolated instances of threats or minor .7 4 .6 ' harassment between Construction and QC personnel, but neither .9 '
go ; our investigations nor those of the NRC found additional n ,
*j specific allegations of serious threats or abuse being .h, directed to QC Inspectors. Thus, although HL&P staff at the 15 site remained on the alert with respect to such matters and 16 ,
17 ' thoroughly investigated all allegaticns, there were no 13 19 , serious problems during this time frame. When several 10 ' 31 allegations of abuse or threats directed at QC Inspectors 12 i 33 arose between August 1979 and year-end, these were jointly I 14 33l investigated by HL&P and B&R and, as described by Mr. Logan 16 j 17 Wilson appropriate actions were taken, including reprimands 38 ! and terminations.. . 19 ! i 10 i Q. 16 were there at times indications of low morale 11 ' 12 4 among the B&R QC Inspectors? l 13 l g4l A. 16 There were some indications of morale problems 15 ; 16
! am ng the QC Inspectors. Towards the end of 1977 and early II g 1978 members of our QA staff brought to my attention their i I9 judgment that there was low morale among the Inspectors. $0 !
il ,i
1. 2, 3' 4 5 The Inspectors were performing their work adequately, but we 6 7i had some concern that if the condition persisted their 8 9, performance would be adversely affected. LO (y Q. 17 What action did you take? L2 A. 17 I directed ur QA Manager, Mr. Frazar, to express 3 ! b4 our concern to B&R. In January, 1978, Mr. Frazar made a La, ~ L6 presentation of our views at a meeting of the B&R QA Manage-L7 , LE ment Review Board, which is an executive level board that L9 10 meets periodically to review the effectiveness of the B&R QA n
*j ' program. B&R took a number of actions to improve the situa- '3 tion including holding meetings with Site Construction 1,.
25 superintendents and QA/QC supervisors at which B&R manage-16 17 ment emphasized B&R management support of the QA program and 23 l 29 the importance of conformance to project procedures. In ! 30 l 31 addition the QC training program was improved, Project 32 33 procedures were reviewed to improve their clarity, and B&R ! 34 ! l 35 i stepped up 1,s efforts to recruit new personnel to strengthen Ikt le the B&R QA organization. Mr. Frazar instructed the HEAP QA 38 staff to perform extra surveillance over the following i < 19 10 i months. They reported to the HL&P Projects QA Manager that 11 12 B&R had implemented a number of corrective actions and that 13 14 improvements had been observed. Mr. Frazar returned to the 15 ! l 16 , QAMRB in May 1978 to report on EL&P's observations. During 1 l~ n gf' the same time period, B&R appointed a new Project QA Manager 19 , 30 i il ! l
l l 1 l I L i 2 3' 4 5, who was experienced in nuclear QA and we viewed his appoint-6 7, ment as a further step in improving the B&R CA program. 8 9 Q. 18 Did the NRC Staff also express concern regarding
*0 i y the morale of QC. inspectors?
A. 18 Yes. In the summer of 1978 the officials of
.'2 '3 hj Region IV of NRC I&E met with Mr. Turner and members of the .= '6 . HL&P QA staff to express concern about morale among B&R QC .' 7 , ,5 Inspectors. In response, HL&P and B&R took a number of 'o
[0 steps. These included direction to the B&R Project QA n i {} Manager to spend more time in the field, an increase in the h* ' number of Construction Engineering personnel, changes in 15 project procedures and increased HL&P surveillance of con-16 17 struction activities. These changes, coupled with the
!S 19 personnel changes and other improvements which had been made 10 31 earlier in the year,
; appeared to bring about improvements in 12 33 the morale of QC personnel.
lo Q. 19 Were there, at times, conditions that warranted 16 i action to stop work at STP? 17 18 A. 19 Yes. A stop work procedure is commonly employed 19 ! 10 ; hy companies involved in nuclear plant construction to stop i 11 ; 12 an activity when there is reason to believe that the work l 13 ; t g4 l will not be performed in accordance with the applicable 15 I requirements. ' Generally, a stop work order is issued by QA 16 17 l Management when they have doubts about the quality of work 18 l 19 50 31 l 3' 4
$i being performed, the adequacy of implementation of a proce-6-
7 dure or the qualifications of the construction or QC personnel B gl involved. When a stop work crder is issued, the construction 0' Manager is required to cease work in the affected area until yj 2 authorized to resume work by the QA Manager. Issuance of
.3 .4 stop work orders reflects the fact that the QA Manager is .9 .6 exercising the authority and independence he is required to .7 , ,gl have under the NRC's regulations. .9 i 0, Q. 20 How often were such work stoppages ordered by QA 9 -
personnel prior to the fall of 1979?
}
3 A. 20 There were 16 stop work orders issued on specific
.5 site activities through November 15, 1979, and in each case .5 .7 ' the conditions were corrected and the work resumed. As an l .3 .
I ;9 l illustration, the site QA Manager stopped work on all safety
;0 ' ;l related concrete placements in both Units 1 and 2 in June
- 2
;3 ; 1979 as a result of the discovery of voids in lift 8 of the do Unit 1 reactor containment (RCB) shell wall. An investigation ;6 .
was conducted to determine the cause of the voids and as a
;7 l8 result, a list of corrective actions was defined that would is i r0 ; preclude recurrence. QA reviewed the planned corrective 2; actions and issued a partial release of the stop work order i3 i ,,g j on June 29, 1979, permitting placements of safety related i5 !
concrete in areas other than the RCB shell walls. After
.6!
,l actions were taken to integrate these corrective actions i8 i i9 l l iO -
il I i 1 2 3! - 41 5l into construction and inspection procedures, the stop work 6i 7! order on RCB shell placements was lifted on September 6, 8i 9! 1979. LQ \ (1 l This procedure is characteristic of how work is stopped, L2 ' c rrected and resumed in an orderly manner. L3 i b3 Q. 21 Please describe HL&P's QA audit program prior to La . L6 the fall of 1979. L7 , LE ' A. 21 HL&P's Houston based QA auditors performed L9 ; 20 ' periodic formal audits of both HL&P organizations and the 31 ! 22 organizational components of B&R, Westinghouse.a and other 23 ' contractors and vendors. Audits were generally performed 24 annually, but the audits of the HL&P and B&R QA/QC organi-27 . zations were scheduled semiannually. In addition to the 38 i 39 I specified minimum audit frequency, additional audits were 30 i 31 ; performed at the request of Project QA management when there 32 i The EL&P were apparent problems in a particular area. 33 l 34 1 auditors reviewed the records of each organization to verify 35 l 36 ' i mpliance with the applicable QA requirements. Whenever 37 38 i their audits identified problems in various aspects of the 39 : 40 l project, the Audit Deficiency Reports were sent to the 41 ! 42 l audited organizations and their corrective actions were 43 l 44 l verified through follow-up audits. 45 l Q. 22 During the period prior to the fall of 1979, 46 l 47 ' 4g l when you considered the N".J 1otices of noncompliance, the 49 j 50 l i 51 ] 4
1i 2, 3! 4 1 5, number of stop work orders, the results of HL&P audits of 6' 7l the project and your own observations, what was your judgment 8 9 of the QA program performance? OI yl A. 22 From the start of the Project until well into 2i! 3 1979, it was my belief that the QA program was working well. 4 The kinds of problems found on the Project during that a . 6* period were typical of those being experienced on other 7 E' nuclear construction projects. Basically, it appeared that 9i 0 the QA program was identifying the quality concerns that it 9 , j' was designed to detect. Because neither we nor the NRC 3'
, identified major QC problems, we had no reason to question 5 the adequacy of our QA function -- our tool for detecting 6,
7 fundamental problems in our management of the quality program. S ! 9' Q. 23 During 1979 were there indications to you that 0i 1' there were problems developing in the implementation of the 2 3, STP QA program? 4 g- A. 23 During the first part of 1979 I noticed an 6: J increase in the number of nonccmpliances identified by NRC 8, inspections. This trend continued in the balance of the 9i 0 year, however, I attributed the increase to heightened 1l 2; regulatory scrutiny in the wake of the TMI incident and to 3: 4l the increase in the pace of construction as the Project 5I 6
! progressed. When the NRC special inspection team identified 7!
8i i 9! l 0l 1: i l L 2 3 4 5, preliminary information from their activities in late 1979, 6 7i however, I realized that the trend I had been seeing was 82 9; associated with some fundamental problems. As I reflected LO gi , on the information developed during 1979, I was struck not L2 < so much by the seriousness of each item (with the exception l L3 L4 of the allegations of harassment and intimidation) as by the LB - L6 fact that, underlying these specific instances of noncompli-Le . L3 ance, was the possibility that they might be traceable to L9 10 more basic management problems -- specifically the effective-11 gj ness of the QA program. Against this background, I decided
'3 J, ,. to get an independent evaluation of our QA/QC program and retained the Bechtel Power Corporation (Bechtel) to perform f
17 such a study. This was a valuable step because Bechtel's
!S 19 ' study later provided a perspective against which we were 10 11 able to address the NRC's Notice of Violation which was 12 33 . issued about four months later. Rather than dealing with 14 l 33 twenty-two separate and apparently unrelated matters, many 16 i
- i. '
s of which were relatively minor, we were able, with insight 38 gained from the Bechtel study, to address causes rather than 19 10 i symptoms in responding to the Commission's order. Il ! 12 Q. 24 Did you meet with Mr. Karl Seyfrit, Director of 13 I4 , Region IV and his staff during the course of the NRC investi-15 ! 16 : gation? > 17 ! 18 i 19 ' 10 : 11
1 1 l 2: 3l 4 o 5, A. 24 Yes. On December 21, 1979, Mr. Turner and I met 6i 7I with Mr. Seyfrit to discuss the preliminary findings of th&t 8i investigation. We were told that there were serious problems 9, in the QA/QC program related to concrete placement; that QC f0 ; 12 f inspectors had experienced harassment; and that there had 14 been noncompliances with certain concrete placement require , , 13 , 16 ments. 17 i lg : Q. 25 How did HL&P react to that information? 99 20 A. 25 Upon hearing that such problems existed on the project, HL&P decided to stop placing safety-related concrete 2}9 2 23 ' until we could review the situation and determine what 24 ' 25 corrective actions were needed. A week later, on December 28, 26 27 , 1979, Mr. Frazar, various other HL&P staff members and I 28 j 29 went to see Mr. Seyfrit and discussed the elements of a 30 l 31 ! program to correct the conditions the NRC staff had found. 32 ' I c nfirmed ur commitment to a specific nine-point program 33 ; 3j l in a letter that same day. The details of the program are 32 l 36 . in Mr. Frazar's testimony. Briefly, however, we committed 37 38 to renewed training and indoctrination; clarification of 39 , 40 procedures on field design changes and, finally, we decided 41 , 42 , to Keep in effect the stop work, while limiting it to safety-43 : 44 l related complex concrete pours. l I 45 l Did HL&P fulfill those commitments? 46 i Q. 26 l 47 i 48 i 49 ! 50 j 51 1
L' 2' 3l - 4 5, A. 26 Yes, we did. We kept NRC informed as we completed 6 7i the various elements of the program and NRC verifieu our 8' 9; implementation. LO i (y ; Q. 27 Was there another meeting at which NRC described 2i more fully the findings of its investigation? L4 A. 27 Yes, there was an exit interview held on January 24, La L6 1980, at the STP site. I attended that meeting along with L7 i Lg l Mr. Turner, Mr. Frazar, and other members of the HL&P QA L9 , 10 staff. l' gj Q. 28 What were the NRC findings described at the meeting? f3 I3 A. 28 The NRC Staff reiterated the findings described 16 ' 17 to me in the previous meetings, that the placement of concrete IS 19 was not being performed in accordance with project procedures. 30 31 In addition, the NRC identified noncompliances in the welding, ; 32 1 33 ; non-destructive examination (NDE) and backfill placement 34 pr grams. They found that the Project QA organizations were 35 36 ' not effectively analyzing trends in the occurrence of noncon-
- 37
38 I forming conditions and not fully implementing the audit j 39 I I 10 i programs and that there were inadequacies in the control of 11 ' 12 documents on the job site. 13 g4l Q. 29 How did you react to the exit interview? 15 ! 16 ' A. 29 The earlier meetings with the NRC Staff had I7 forewarned me of the seriousness of the findings. Candidly, g 49 ( 50 l 51 l i i I 1 ._ - . .-
L: 2c 3[ 41 - 5l 6! however, I had not expected that noncompliances would be 7i identified in so many aspects of the Project. I decided 8 9l that our response to the findings would not await documen-0l tation of the inspection findings in a formal report. We 3,,, oi immediately set about determining the needed corrective
}l 4 actions and within two weeks we sent NRC a letter outlining .a .6 further actions we would take in response to these noncom- .7 i .5l pliances to improve performance on the Project. .9 l 0; Q. 30 What improvements did you make as a result of 9 }! the exit interview?
A. 30 We made a number of significant changes. We
}3 S' improved our program for reporting and trending noncon- .6 .7 ' formances; revised our audit activities; and modified our .8 < .9 welding, NDE and backfill placement programs We also 0l ;1 committed to an independent audit of our QA/QC program. ;2 ' ,3 ; These changes are described more fully in Mr. Frazar's 4! testimony.
5j Q. 31 Did HL&P keep the NRC advised of these changes? 8 A. 31- Yes. The NRC was advised of our progress and 9 ,:
- 0 l documented the results of its inspection of our implemen-1l 2; tation in its inspection reports. The specific reports are r3 !
, .g ' numbers 80-17, 80-19, 80-24, 80-30, 80-38 and 81-03. ,5 i
Q. 32 How did HL&P implement its commitment to an 6l 7 lg j independent audit of its STP QA Program?
,9 l iO l il l
l t
L 2. 3 4, 5 A. 32 As I previously mentioned, we retained Eechtel 6 74 to undertake a thorough review of the STP QA program. Our 8 9 objective was to obtain a top to bottom evaluation of the 10 11 program by an organization experienced in nuclear construc-12 tion projects. We selected Bechtel because it has more {3 experience designing and constructing nuclear plants than 16 any other organization in the United States, and of course, 17 li its QA experience on large nuclear projects is extensive. 19 ' 20 Bechtel committed a number of senior QA specialists to 21 gj conduct the review. John Amaral, then Manager of the Divi-3 sion of Quality Assurance at Bechtel's office in Gaithersburg, 25 Maryland, supervised the effort. 26 27 Q. 33 What were the results of the review conducted by 23 39 Bechtel? 30 31 A. 33 Bechtel's activities continued over several 32 33 months during which Bechtel made progress reports to me. 34 Bechtel made a number of recommendations for improvements in 33 6 the QA program to eliminate the " root causes" of the short-3e 38 comings identified in the audit. The Bechtel findings and 39 40 : recommendations are discussed in more detail below. I 41 ' 42 Q. 34 On April 30, 1980, NRC issued its formal investi-43 44 ' gation report (I&E 79-19) accompanied by a Notice of Violation, 45 i an Order to' Show Cause and a Notice of Proposed Imposition l 46 of Civil Penalties in the amount of S100,000. Describe the 49 90 51 l l l t 2. 3l 4' 5l 6' noncompliances identified in those documents and the actions 7i ordered by the NRC. 8, 9 , A. 34 The Notice of Violation identified 22 instances LO;t (y of noncompliance and the Show Cause Order directed HL&P to L2
- study alternative organizations for the quality assurance 3
L4 program; to perform studies of the adequacy of the backfill, Ls L6 concrete and welding work already completed on the project; L7 . LE ' to cause B&R to rescind and revise a January 1980 brochure L9 t 20 , and lecture on QA (discussed'more fully below); and to 31 i jj ; clarify or strengthen the Project systems related to stop
'3 work authority, the procedures for identifying and correct-
{4 5 ing the root causes of nonconformances, the procedures for 17 control of field design changes, the Project record controls, 18 . 29 and the audit programs. There was also a questien regarding 30 31 the accuracy of two statements in the FSAR, which will be 32 i 33 , discussed further in the testimony of Mr. Pettersson and 34 ! 35 l Mr. White. 36 - Q. 35 How did HL&P management respond to the NRC 33 actions? . I 19 10 A. 35 From the first meeting with Region IV personnel 11 ! 12 ; in December, 1979, both Don Jordan, the President of HL&P, l 13 : 34l and I recognized the seriousness of the findings. Copies of 15 l 16 l the NRC investigation report, Notice of Violation and Show g Cause Order were sent to the members df the HL&P Board 19 50 j 31 !
L 2 3: 4i 5 of Directors. our Board has evidenced a continuing interest 6; 74 in the enforcement action and our response to it. I cannot 8: 9i recall a meeting within the last 18 months that Mr. Jordan 0'
'y or I have not been asked questions about STP by other Board *2 members. .3 ;4 Q. 36 How did HL&P go about responding to the NRC .= - '. 6 enforcement actions? '7 L3 ' A. 36 We were anxious not only to correct the deficien-L9 10 cies identified by NRC, but also to determine whether there n
{{ were other, perhaps more fundamental, quality related problems f3 on the Project. The meetings during December 1979, and 13 January 1980, had forewarned us of the NRC findings, although 16 , 27 + not of the nature of NRC's enforcement action. We had ZS 29 already taken a number of corrective actions, most of which 30 31 are enumerated in my December 28, 1979, and February 7, 32 33 , 1"80, letters to NRC Region IV. We had also commissioned 34 ! the Bechtel audit of the GTP QA program. Nevertheless, I 35 36 recognized that more extensive measures were required. 38 The Notice of Violation and Notice of Proposed Imposition 39 l 40 i of Civil Penalties required a response within 25 days. We ! 41 42 , had to investigate the allegations and determine if they 43 44 , could be substantiated or disproved. We created a special 45 i 46 task force under Mr. Frazar to perform the investigation. Upon completion of the investigation we assigned Mr. Joseph 49 50 ; 51 ! Li 2, 3! 4: 5i Briskin, HL&P's Manager, Houston Operations, on the STP to 6i 7i take over direction of the Task Force, conduct the needed 3! studies and propose responses to the Show Cause Order. 9j f Mr. Briskin's testimony describes the Task Force and how it L2 accomplished its mission. L3 l l4 Q. 37 How did you respond to the findings of noncom-L5 ; L6 pliance in the Notice of Violation? L7 , Lg ' A. 37 After investigating the findings, we determined L9 : 20 ; that although we could not substantiate each of th'e findings 21 gj : in detail, they suggested a need to examine the effectiveness Ih, 2% of parts of our QA program. Consequently, rather than 23 developing responses to details of the findings, with the 26 i 27 ! help of the Bechtel audit we set about identifying the 23
- 29 ' causes of these problems and putting into effect changes to l
30 ' 31 correct and upgrade the QA program. 32 33 Thus, the May 23, 1980 response to the Notice of Violation did not challenge the 22 findings, but described ( 36 i . the specific actions HL&P had already taken or would take in l 37 ,! l 38 1 the future to correct the condition and prevent its recurrence. 39 ! 40 i our response was not confined to these specific findings. l 41 ' 42 , We pointed out that HL&P's studies of the underlying causes 43 i 44 ! identified six areas where performance should be improved, 45 ! 46 i and we stated that the necessary improvements would be made. 47 i 48 49 00 l. 51 i i
L 2 3[ - 4 5 Q. 38 What are the six areas listed in HL&P's response 6 71 to the Notice of Violation? 8 9, A. 38 We identified the need for improvement in the 0 y, following six basic areas: o (1) translating specifications and job requirements into 4 clear, simple procedures; D - 6 (2) documenting nonconforming conditions and trending them 7 E to identify Project weaknesses; 9 0 (3) training and indoctrination of personnel at all levels t j regarding the quality program with special emphasis on the ) Project goals of reliability and safety; 5 (4) system controls to assure that quality related activities 6 7 are initiated, controlled and properly documented; 3 9 (5) verifying through an effective audit system adherence 0 1 to procedures; and 2 3 (6) visibility of, and participation by, upper managenant 4' 5, in QA activities. 6
, HL&P's studies and the review conducted by the consul-8 tants indicated that.the specific problems in the QA program 9,
0i were traceable to one or more deficiencies in these six 1 2 areas. The response to the Notice of Violation advised the 3' 4l NRC staff of EL&P's intent to concentrate on improvements in 5! 6 i these six areas. 7' 8-9 0, 9 , l 4 1 2 3' 4 5' Q. 39 What actions were taken by HL&P and E&R in 6 7i connection with allegations of incidents of intimidation and 8, 9 harassment of QA/QC personnel referred to in the NRC Notice
.0 1; of Violation of April 30,.1980?
2-
,3 A. 39 As set forth in detail in our response of May 23, 1980, HL&P and B&R took a number of actions. They .6 involved improvement in proc <adures to minimize construc- .7 .
E' tion-QC friction; institution of an extensive recruiting 9 0 program to increase QA/QC staffing; upgrading of job t j classifications and salaries, and other actions to improve 3 4 morale; changes in personnel and &ssignments; improvements 5 in contacts between QA management and site personnel; 7 increased HL&P involvement in the QA/QC program at the site, S 9 heightened HL&P QA visibility in the field, and enhanced 0 1 activities of HL&P Site Surveillance personnel; and improved 2; 3 ,, training of and communication with both QA/QC and Construc-4' 5 tion personnel. Additional information concerning B&R's 6 7l actions are contained in Dr. Broom's testimony. 0 9, : Q. 40 The Order to Show cause (the " Order") required a '
! written response on ten separate matters. How did HL&P 2, prepare its response?
3 4l A. 40 The ten areas covered by the Order can be placed 5l 6i in four basic categories: 7' l 8 l-l 9: l 0 l 1: i
El 2. 3' 4I 5' (1) the QA/QC org'anization (item 1); 6i 7I (2) verification of the adequacy of already completed 8 9 construction activities related to backfill, concrete and 0 l3, weJding (itema 2, 3 and 10);
'2 3 l (3) rescission and replacement of the B&R brochure on QA
( '.f Program implementation (item 4); and
.1
.6 ; (4) improvement of administrative controls (items 5, 6, 7, !
.7 !
.5l 8 and 9).
.9 1 l0 : The Task Force directed by Mr. Briskin was assigned to
'1
}'l study the issues raised by the Order. Mr. Briskin's testimony
}3 ' describes how the Task Force approached its assignment.
S When the Task Force recommendations were made, including
.6 '7 - 1 draft responses, senior management of B&R and I reviewed !S l l9 > those recommendation and the response was submitted to the 10 I il , NRC. The responses concerning verification of completed
- 2 !
;3 i construction activities are discussed in the testimony of ;4 !
gg j Mr. Pettersson, et al. (Backfill); Mr. Murphy, et al. (Con-l
' .6 crete); and Mr. Saltarelli, et al. (Welding). The responses l7 l U3 I we submitted regarding the administrative control items are 19 'O l described in detail in the testimonies of Mr. Briskin and il ;
j d! l Mr. Frazar. i di i
,4 Q. 41 What was EL&P's response to item 4 of the Order, 15 , 6 regarding the B&R QA brochure?
I i7 i l
'8!
i l i9 ' l i0 il
1 2. 3l - 4. 5l A. 41 Item 4 concerns a seminar B&R conducted in 6 7i January 1980. It was one part of the nine-point program I 8' 9i described above that was initiated in response to the pre-0i liminary NRC investigation findings. Its purpose was to j
'2 reduce friction between Construction and QA/QC personnel.
4 The presentations at the seminar were videotaped for use in -
.D ,6 training and were printed as a brochure and distributed to .7 ,5 ' project personnel. The NRi: Investigation Report found that .9 ; 'O one of the presentations at the seminar contained the sugges-o tion that QA/QC personnel should be conscious of cost and *}!
scheduling considerations.
!5 QA/QC personnel have never had any responsibility for 16 17 i the cost or scheduling of construction work on this Project.
13 19 ' They have always been expected to determine the acceptabil-10 ; 31 ity of construction work without regard to Project cost and 12 ' To eliminate any suggestion to the 33 , schedule considerations. 14 ! ntrary, ur response to the order submitted a copy of a 15 ' 36 revised presentation re-emphasizing the independence of 37 38 l QA/QC personnel from.such pressures, as well as reiterating 39 I to i the important role of QA/QC on the Project. 11 !
$2 ! The revised presentation also repeated a discussion of 43 i 34l the formal procedure for resolution of disagreements between 1
45 I Construction and QC personnel by submitting them to manage-46 ! 4{ i4j ment. It was delivered orally to B&R Construction and QA 49! 50 ! 51 ; i l l l 1 -
-. l l
l 1 l 2r 3i 4 5 personnel by the B&R Group Vice President for Power, and was 6! 7i circulated in printed form to B&R Project personnel at the 8 i 9' job site. A brochure reproducing the presentation is fur-
*0 y nished to new B&R site personnel as part of their orientation.
, h2
.3 Q. 42 Item 1 of the Order required consideration of a number of aspects of the Project QA management organization.
L6 How did HL&P go about preparing its response to the require-L7 i
',6 , ment that it evaluate alternative management organizations o,
0; for the QA Program. n . A. 44 Item 1 of the Order required HL&P to utilize the {} services of an independent expert consultant to evaluate the f.3'
*1 15 management of the QA program, giving consideration to alterna-16 17 i .
tive organizational responsibilities for control of the 28 19 : Project QA activities within the scope of the contract with 10 ! 31 ; B&R. Since Bechtel was already conducting an audit of the 32 ' 33 QA Program and was thus already familiar with the STP program, 34 ! 35 I felt that it was best qualified to do the independent 36l 37 ; evaluation required by the Order. Accordingly, Bechtel 38 I analyzed the advantages and. disadvantages of the various 39 i ! 10 i alternative QA organizational structures. Its report was 11 i 12 submitted to NRC as an attachment to the HL&P response to 13 g4l the Order. 45 1 46 ; I also discussed the alternat nes with Mr. Amaral of i 47 gg l Bechtel, with another QA conc z? r Management Analysis 19 l 50 ; 51 l
L 2 3l 4 5 ', Corporation (MAC) and with Mr. Frazar. Based on all of 6t 7i these discussiens and the Bechtel report which focused on 8! 9 the organization issue, I reviewed with Mr Jordan what was
.0 ,' ,1 , ultimately submitted as HL&P's response to item 1 of the o ,
Order.
}
Q. 43 What were the alternative QA/QC management
.6 organizations the Order required HL&P to consider? .1 , .3 ' A. 43 There were 5 alternatives listed in the order, .9 ;
l0 : and our review did not disclose any other alternatives that 3 !
} would have a potential to offer significant advantages over '3 . ~e the alternatives that were listed. The alternatives listed 'S Were: } !I '
(a) the present organizational structure, where B&R has 18 l9 ' implemented a QA/QC program under BL&P; 10 1 (b) an organizational structure where all levels of the B&R
- 2
;3 ; QA/QC organization would report to HL&P yet remain B&R ;4 ,
! ,3 i "mP loyees;
'6 7
I - (c) an organizational structure where HL&P establishes a total QA/QC organiza. tion to conduct the current B&R QA/AC
.'9 O 0i i functions; 3
- 2. (d) an organizational structure where HL&P contracts with
-3 ,
- 4l another independent organization to perform the current B&R 51 6! QA/QC fnnctions; 7l
.a i 9
O; 1i 1
1i 2e 3! 4: _1 3 (e) an organizational structure where HL&P establishes a 6l - 7i duplicate QA/QC organization, in whole or in part, to that 8l 9! of B&R with both groups performing duplicate functions. 0l ' 1; Mr. Amaral's testimony discusses the pros and cons of 2! ' 3 each alternative. i 3 Q. 44 Which alternative did HL&P select? . 6, A. 44 We decided on an alternative which, in broad 7, i I! terms, resembles alternative (a) of the Order in that it i 9 t 0 preserves B&R's responsibility for QA activities. At the 7 ji same time, however, we strengthened HL&P's programmatic role 3 4 in the QA program, and made major changes to strengthen the 5 6 infrastru ture of both the HL&P and B&R QA organizations to 7l 8 assure that every major function of a good QA/QC organization l 9l is addressed. l 0i 1' Q. 45 What were the major considerations that led HL&P 2 3, to select that organizational structure? 4! gl A. 45 Our analysis of the NRC Inspection Reports and l
% 6 7l the Bechtel review identified three general management areas 8!
9! in need of improvement, each of which had to be addressed in 0 considering reorganization of the QA/QC program. These 1-l 2 were: 3 4l (1) Management involvement in the QA program. l 1 5l 6; (2) Strengthening the quality assurance or " problem preven-7! - g tion" arm within HL&P and B&R. l 1 9l l 0j 1' L 2, 3i . , 4, ' 5' (3) Reinforcement of a positive quality attitude on the 6i 7i part of all levels of management within HL&P and B&R. 8i 9i The management organization had to effect improvements
*0
y in " ese areas without introducing significant new problems
*2 '
into the program. We identified five criteria which the QA i .3
*4 .3 organization should meet to achieve improvements in these .6 areas: .7 , .5 (1) Owner control and visibility -- The owner's QA organiza- .9 ;
10 : tion must be able to monitor effectively the performance of n {} B&R and have sufficient authority to effect necessary program-
'3 matic changes. That authority can emanate only from a well 'g informed HL&P executive management, fully appriscd of the II status of Project quality activities.
13
!9 (2) Construction responsibility for quality -- The construc-10 '
l1 ' tion organization must have' the principal responsibility for 12 ' l3 ; doing quality work in the first instance. The QA/QC role is 14 ! 15 to verify that the quality is there; it cannot of itself 16 produce quality. After considering those alternative organi-17 l IS 19 :
=ations set forth in.the NRC Order which would have the 10 l 11 ;
effect of relieving B&R of QA responsibility, we determined i2 that such a move would be counter-productive in that the i3 1 64 l construction organization's sense of responsibility for 15 l 66 - building quality into the work could be impaired. Therefore, y;
..i we concluded that the constructor should be accountable for 19l 10 :
il ! i i
1! 2; 3l 4l 5I implementing an effective QA program internal to its organi-6I 7! zation and fully understood and supported by all levels of 8l 9; management. O!
'yj (3) Owner's programmatic direction -- The organization must
! emphasize the owner's role in providing QA programmatic
.a 4
direction as contrasted with the constructor's role of i
.6 implementing the details of an ongoing quality program. The .1 i .5 l owner's programmatic direction establishes the overall .9 to ! objectives of the QA program. This requires the inclusion n '
{}I of a diagnoc+ic function -- analyzing problems and trends
'3 and maintaining overall project control. The constructor is !5 charged with the responsibility of implementing the QA !6 l'7 l program which meets the programmatic objectives established !8 !
19l by the owner. The constructor must also have a diagnostic 10 i l1 , function as described above, and must also execute programs 12 : l3 l for day-to-day verification of Project QA in accordance with 14! gg ; systematic delegations of QA responsibilities from the 16 : owner. 17 l 18 ! (4) Quality Assurance independence -- The QA organization 19 ! 10 i must be insulated from any pressures of cost or schedule il ! 12 j from within either the HL&P or the B&R organization. The QA 13 1 g4l function, which is organizationally independent of Project 15 ! ggl management of engineering, construction and purchasing g f activities should have direct access to the same senior 19l 10 ; 31 l i i
1 2 3i 4, 54 executive having responsibility for these functions. This 6* 7j assures that executive management, Project management and 8' 9; the QA organization are kept fully aware of Project activi-0 y ties. 2 3 (5) capability of implementation -- The new organization 4 should be one that could be readily implemented by drawing 9 6 upon existing personnel and systems whenever possible. 7 6l Similarly, the implementation of the program could be helped 9 o, by building, to the maximum extent, on existing procedures, s j checklists and records in place. j, We determined that alternative (a) best satisfied these 9 5 criteria, particularly when coupled with significant 6 7 improvements in the HL&P and B&R QA organizations, and funda-8 9 mental modifications of QA/QC procedures, greater management 0 1 involvement, and significant upgrading of the QA/QC staff. 2 3 Q. 46 What improvements were mada in the B&R and EL&P 4, 3 QA/QC organizations? 6 - A. 46 We selected a management structure which provided 1 8 for strong HL&P control of the QA Program and also strength-l l 9-1 0i ened B&R's controls. As with the previous structure, B&R 1 2l would implement a QA/QC program under EL&P's direction, thus 3 4l preserving B&R's responsibility to RTAP for quality. As ! 5l t 6 discussed below, the reorganization strengthened EL&P's g programmatic role in guiding the QA program. The B&R QA 9! l l 0i ! 9 . l '! ' l l l _
1 2. 3l 4i 5! controls were strengthened by upgrading the quality engineer-6 7I ing organization and expanding that organization at the job 8i 9j site to give it the resources to carry out its enlarged 0: 1i role. The changes in the B&R organization are also discussed 2 below. 3
'4 D
Q. 47 Describe the strengthened HL&P QA management
~
6 structure. 7 i A. 47 The HL&P Project QA organization has been restruc-9' 0 tured to include five distinct components: -Discipline QA; 9 3 Quality Control; Quality Systems; Procurement QA and Opera-3 4 tions QA. 3 Of these components, the Discipline QA organization may 6 7i represent the most dramatic change. Within this organiza-S 9- tion, there is a quality engineering function with separate 0 1 Project QA Supervisors in each of the major disciplines: 2-3 civil / structural; mechanical / nondestructive examination; and 4' 3l electrical / instrumentation and controls. Each Project QA 6 Supervisor provides programmatic direction to B&R Quality 7 S Engineering on all QA matters related to his discipline. 9 1 0 This programmatic direction consists of review and approval , 1l : ! 2: of the system features initially and continued monitoring, l 3 4i refinement, and revision of those systems during implementa- ! 51 6: tion. Project,QA Supervisors assess B&R's implementation of l g its quality engineering and inspection functions by reviewing 9i 0, 1I
1 2i 3 4, 5 and approving procedures, performing implementation reviews, 6 7 and observing work activities in the field. This activity 8: 9i involves a virtually continuous contact between the HL&P LOl yt { Project QA Supervisors and B&R Quality Engineers. L2 ! The Quality Systems organization prepares EL&P STP QA L3 bf Ls
' procedures, reviews trend data developed by B&R and analyzes L6 ! audit findings. It administers the training and certifica-L7 LE tion program for HL&P STP QA personnel and develops and L9 i 20 ' administers the HL&P Project QA Plan. The Quality Systems 7T l jj l organization prepares information on the quality status of 23 i the STP which is compiled in a monthly report which I receive.
j4 ; This supplements the information I receive in frequent f 27 i discussions with Mr. Frazar. i 38 i 29 ! The HL&P Quality Control organization performs periodic 30 : 31 j inspections to verify the results reported by the B&R QC 32 1 33 ' inspection program, assures proper nonconformance identifica-34 tion and assures that personnel performing inspections are i 35 i ! 36 ! propedly certified. The Quality Control Organization conducts 37 38 its inspections in accordance with instructions and checklists 39 ,i 40l reviewed by Discipline QA Supervisors. 41 l 42 i The Operations QA group develops and implements the 43 : 44 l Operations QA program which will apply to HL&P's activities 45 l in operating the plant. The Procurement QA group provides 46 l 47 i programmatic direction to B&R vendor surveillance and auditing 4g j l $9 functions. I
=0 51 l l
1! 2. 3i 4i 5 ', This revised organizational form generally conforms to 6i 7i a pattern which has been used successfully in the construction 8! 9{ of a number of nuclear power plants.
}0{' Q. 48 What changes were made in the B&R Quality Engineer-
,2 ing organization?
.3 4 A. 48 The B&R Quality Engineering function was previously
.=
.6 performed by organizations located both at the site and in
.7 i
.5 { Houston. The site organization was staffed by QA engineers o*
@l and QC engineers whose primary responsibilities were to n
g2 assist field QC Inspectors in the resolution of problems, f3 interface with the construction organization on the develop-15 ; ment of construction procedures, and to implement the various 16 17 deficiency control programs. The Houston organization was ZS ' 29 i staffed with QA engineers who were primarily responsible for 30 ' 31 , interface with the Engineering organization on the QA aspects 32 ' 33 of the design program, procurement quality assurance, the 34 l _ development and maintenance of QA procedures, and the train-33 36 ! ing and certification of inspection personnel. The Houston 37 ! 38 organization, however, performed these responsibilities for 39 , 40 i all B&R Power Group projects, not only for STP. 41 l l 42 , As part of the improved program, the B&R quality engi-i 43 ' 44 j neering function for STP was expanded and personnel were 45 i 46 rel cated to the site to provide rigorous quality engineer-47 ing guidance to the QA program. In addition to the previous 4g 49 i ( 50 : 51 i i i l
L> 2 31 4j 5 responsibilities, the Project Quality Engineering responsi-6! 7i bilities now include review and approval of nonconformance 3' 9 reports, Leview and approval of construction procedures, O y preparation of QC inspection plans, review and approval of n 3; quality related construction record packages and coordination 4 of the "as-built verification" program. The site Quality 2 -
.6 ! Engineering staff has been more than doubled to enable it to .gl; handle its increased responsibilities. This expanded quality .9 l 0i 11 engineering function r ubstantially strengthens the QA program. . } It is a management ipproach with proven effectiveness. .3 ' Q. 49 What changes have been made in staffing levels .4 .5 ' and personnel qualifications in the HL&P QA organization for .6 .7 i STP? 'S i 19l A. 49 Since the beginning of 1980 there has been a 10 l ;1 : substantial upgrading of the HL&P QA department. As described 3
12
;3 ll in detail in Mr. Frazar's testimony there have been increases '4 l i in the number of personnel in certain positions, qualifica-
{5 16 j . tion requirements for QA/QC personnel have been upgraded, l 17 l , i 18 ! and the personnel in. key QA positions have been supplemented
- 19 !
I 10 I with expert consultants from outside the HL&P organization il ! L2 l with extensive nuclear QA experience. This effort was aided . 63 i g4l by Bechtel's review of the qualifications of key project QA 19 1 personnel. i 16l 67 l 18 l 19l 50 il i L l 2 3 4 5 Q. 50 What changes have there been in the staffing 6i 7, levels and personnel qualifications in the B&R QA organiza-8; 9i tion? '0 3 A. 50 The primary area in which the B&R QA Organization 9 ! was found to need more people was in the Site Quality Engineer- {{ '4 ing group. When the function was transferred to the site .6 and its responsibilities expanded, its staff was substantially .7 ,o ' upgraded in terms of numbers and experience levels. .S !O ' B&R has also added highly qualified individuals to its n {} QA organization in three key positions: Corporate QA Manager, ,'* ,3 Project QA Manager and a consultant to the Quali*y Engineering 15 Manager. The new corporate QA Manager joined B&R in August 16 , !I of 1980. His 26 years of QA experience include 13 on nuclear 13 19 projects and 23 in management positions. The B&R Project QA ' 10 11 Manager has been relocated to the site and the position is 12 [3 now temporarily filled by a consultant with 20 years QA 14 ; g3 i experience including 8 years as QA manager at other nuclear 16 power projects. The B&R Quality Engineering Manager also le , 18 ' relocated to the site, and he is being advised by a consul-19 50 I tant with 23 years experience as a Quality Engineer, includ-11 , 12 , ing 9 years in the nuclear field. 13 : [.g , Q. 51 Please describe the changes tnat have been made 15 ! 16 to increase management involvement in the STP QA program. 17 ! 18 19i 10 ; il I 1i 2: 3! 4i 5 A. 51 We have made several changes in organization to 6 7i eliminate management levels between my position and the site 8 9j QA organization, and we have taken steps to increase my 0 1, involvement in the QA Program. 7
}, At the start of the NRC investigation the senior on-site i
a HL&P employee responsible for QA was the HL&P Site QA Super-6 visor. He reported to the Project QA Supervisor, whose
/ !
E! office was in Houston. The Project QA Supervisor reported 9 0 to the Projects QA Manager who in turn reported to the 9 j Manager of the HL&P QA Department. The Manager of QA reported to the Vice President, Power Plant Construction and Technical 5 Services, who reported to me. Thus, there were four layers 6, 7* of supervision between the site QA organization and the S 9! Executive Vice Presil;nt (see Attachment No. 1). All four 0 1 layers have been removed. 2 3 The Manager cf the HL&P QA Department has assumed the 4! responsibilities of HL&P STP QA Manager and has relocated to 3; 6
.l the site. The Project QA Manager now reports directly to me.
1 J 8' (See Attachment No. 2 ) . We are currently recruiting qualified, t 9. OI experienced people to fill the two key on-site positions of l 1 l 2 Project QA Manager and Project QA General Supervisor. 3' 4l So I can devote essentially all of my time to STP, I 5! 6 t have largely given up my non-nuclear duties. In addition, a 7 8! 9' O i l!
l 1 1 l 2 3 4 5 new position, Vice President, Nuclear Engineering and'Construc-6 7, tion, has been added to the FTAP organization. The position 8 g has been filled by Mr.~Jerome Goldberg, who has had 26 years
- 0
. experience in nuclear engineering, design and construction,
'2 17 of them as a manager. ,= 3 His extensive experience is proving L4 an invaluable asset in the management of the design and Ln L6 construction of STP. The addition of Mr. Goldberg to our L7 (g staff allows me to devote more of my time to the STP QA '9 [0 pr gram. I also participate in the meetings of the B&R QA 71 j} Management Review Board, a committee of B&R top management , j~ personnel that regularly assesses the status of Project 23 quality activities. 26 27 I should also add that B&R has taken steps to increase 23 29 the involvement in the QA program of its senior executives 30 31 and even its Board of Directors. Those steps are described 32 33 in the testimony of Dr. Broom. 3* 3.] Q. 52 In the process of all of these changes has 36 EL&P's role in Project QA changed? 3e 3S A. 52 Yes. There has been a significant increase in 39 40 the depth to which EL&P is reviewing the B&R QA activities ; 41 j 42 and providing programmatic direction. This increase can be 8 43 4 44 seen at all levels of the QA organization, from EL&P's ; 45 i
' discipline QA personnel reviewing draft procedures and !
'.6 ! 3 l' procedure implementation, up through me, including my personal ; 48 4 49 ! 50 , ! 51 ' L 2 3l 4 5' observation of program implementation and my participation 6* 7 in the B&R QA Management Review Board. EL&P had been providing 8I direction to B&R throughout the Project, and is now even 9i
.0 more fully involved in the details of the planning and 1\
2 implementation of the QA program. We are making sure, by
.3 ,4 direct observation, that the improvements in the B&R QA '
3
;6 , program are working. Our staff will continue to fill this l role through Project completion. *q .
{gi , Q. 53 Are you satisfied that the QA program complies Il ' with the requirements of Criterion I of Appendix B to 10 CFR 12 13 Part 50? Z4 ' 15 A. 53 Yes, I am. Criterion I requires that the persons 26 27 ' and organizatic.s performing Qs functions have sufficient 28 29 , authority and organizational freedom to identify quality 20 ' problems; to initiate, recommend or provide solutions; and 3 32 ! to verify implementation of solutions. They must report to l 33 j 34 - a level of management such that they have tnis required 35 36 authority and organizational freedom, including sufficient 37 ' 33 independence from cost and schedule as opposed to safety 39 , , 40 j considerations. 41 i 4 ,. i, The program we have established has been organized to 43 44 achieve the required organizational freedom and authority. 45 ! The QA organization of HL&P is independent of all other 46 ! 47 organizations and responsibilities. It reports directly to 48 l 49 i 50 51 l
f 2 3' 4 5' me. similarly the B&R QA organization reports directly to 6l 7i the office of the Group Vice President, the highest executive 8' 9, position in its Power Group, independently of Engineering .gl, and construction. '2 of course that organizational independence has always L3 , L4 been there. It was in its implementation that shortcomings L: - L6 i were identified. A number of actions have been taken over L7 L5 the last year to make certain that there is follow-through L9 in implementation. These actions have included not only the 20 2' Presentation by the B&R Group Vice President, which I men-23 , 3,
- , tioned earlier, and the many training and retraining sessions 25 that have been conducted, but a number of other actions to 26 27 make clear the seriousness with which we view this matter.
23 29 For example, construction workers have been suspended or 30 i 31 removed from the Project for displaying a poor attitude. 32 ' 3 33 The training program and qualifications of QC personnel have 34 l been upgraded anc QC pay scales have been increased to 35 ; 36 attract more qualified personnel. These and other actions 37 l - 38 to maintain a positive attitude are described in HL&P's . 39 ' 40 ! May 23, 1980 response to the Notice of Violation. They are 41 l 42 also discussed in detail in Dr. Broom's testimony. j 43 . 44 l Q. 54 How well has the QA Program performed since all , 45 ' 46 of these changes were made? 47 48 49 d 50 51 I i i l 1 l 2. 3' - ( 4 5 A. 54 In my observation, the performance of the QA 6: 7i Program is greatly improved. I have been at the site fre-8i g quently over the past year. I have talked to the workers 3,l'
'.0 and observed their work. Although it is impossible in a 2 .3 project involving thousands of people to make a universally .4 applicable judgment, the attitudes of construction and QC .2 ~ .6 personnel appear to be positive. QC personnel, in particular, .7 i ,gl appear to feel that there has been a major improvement in o }l attitudes towards quality on the job. We recognize that n } this does not mean that we can foreclose the possibility of 3.e individual instances of improper behavior by QC personnel or l5 others. No QA program, however detailed in both its proce- 'S !7 dures and its implementation, can possibly do that. We !B !9 ' continue to be concerned that NRC Inspection Reports since 10 ,
g1 the Show Cause Order (e.g., Reports Nos. 80-14 and 80-21) 12 ' g3 have disclosed instances of unprofessional conduct, including io - falsification of records, by personnel employed at STP. l 16 l j . Any incidents of this type are serious. Obviously, in 17 , 18 ' a job involving thousands of people with literally millions 19 ! iO l of records, the potential exists for individuals -- whether il '
,2 to protect their jobs or for other motives -- to hide infor-63 ;; l mation, falsify documents or engage in similar unprofessional conduct.
l l'SI 6 It is extremely difficult -- if not impossible -- to
- iv
l 58 i9 ' 10 < il i l l l
L 2L 3l 4l 5! preclude such incidents by audit and surveillance, regardless 6i 7! of the effectiveness of one's QA program. 8l 9' Throughout my testimony and that of others being presented 0 1; on behalf of Applicants, we have described the many steps that we have taken to instill positive attitudes among all
.'2 3
d' personnel at STP, to encourage full and free communication
.2 .6 with management and to place the quality, safety and reli- .7 i .El ability of the Project as the uppermost goal of all workers .9 \
l0 and management personnel at STP. It is an unfortunate fact, 9 i
}; however, that notwithstanding all of these measures, incidents of this type can occur. We will remain vigilant but, equally ;5 important, by example, make clear that such incidents will ;6 !7 not be tolerated. I f, after an investigation conducted with !8 ' !9 - due regard for the rights of involved employees, we determine 10 !
UL that there has been an instance of unprofessional conduct, 12 !
;3 , firm disciplinary action will be taken promptly.
14 l gg Q. 55 One of the issues in this proceeding concerns 16l 17 , the question of whether HL&P has kept itself informed about 18 ' the Project. In your opinion has HL&P kept itself properly 19 , l 10 l informed? l CL , 12 j A. 55 Yes. We have taken appropriate steps to keep 13 i [4 ourselves informed of day to day conditions. HL&P employees 10 66 : have been located at the B&R engineering offices and on-site, I g monitoring and auditing construction and QA activities, 19 l 10 i ill , l l r 1i 2 3l 4j l 5i 6i reviewing records, participating in numerous meetings and 7i through these and the many other personal contacts with the 8-9j B&R staff, have been staying in touch with Project activities. LO l L1 ! The knowledge gained by the HL&? staff is communicated L2 I (3 i to management. From the outset of the Project we have L4 g assigned a group of top HL&P managers to a QA Program Evalua-L6 : tion committee to periodically review the status and adequacy L7 6 LE ! of the QA Program. The committee was formed for the express L9 l 20 ' purpose of monitoring the effectiveness of the QA Program, 21 ! 32 , performing surveillance on the activities of the QA-Department l {34 and reporting to me on the need for improvements. Until
>c recently Mr. Turner, now Group Vice President, Fossil Plant
{} 17 Engineering and construction chaired the committee, and 18 19 minutes of each meeting were sent to me. Now I am chairman 10 i Il ' and Mr. Goldberg, Mr. Frazar and the other EL&P executives 12 ' , 13 , and managers involved in nuclear activities as well as 14! 15 l Mr. Turner are members. 16 l 37 Aside from this formal mechanism, I continue to regularly 0 receive and review correspondence related to the Project, as to have the other members of HL&P management, and we hold 11l, , L2 i numerous informal meetings and conversations to review the 13 l 14l status of the Project and the QA Program. I am in regular t 15 l 16 : communication With Mr. Frazar and participate in periodic l 17 l l gg ! meetings with B&R management. As I have previously mentioned, 19 l 10 l l 31 l k l l
I L> l 2, 3l 4i 5i it is not possible in a job involving thousands of people 6i 7I with literally millions of records, to assure that any QA 8' program, however effective, will preclude isolated instances g 10 of unprofessional conduct. It is similarly not possible to 11 ! ( 12 I assure that steps taken to encourage full and free communica-i 13 ' I 14 tion with management will be effective in every case. But, 13 16 we are taking every reasonable step to keep informed about 17 i lg ! the Project and, as I have indicated, we will act decisively , 99 to deal with any situation of unprofessional conduct or lack 20
,,,l }~
of candor among Project personnel. 23 Q. 56 In your opinion, has EL&P abdicated its respon-24 25 sibility for QA on STP? 26 i 27 l A. 56 No, we have not abdicated our responsibility. 23 29 : We have hired B&R to perform certain QA services and certain 30 ' 31 , ther QA services are being performed for us by other con-32 i tractors, such as Westinghouse, but we have always recognized 33 : 34 that the responsibility for the QA Program is ours. 35 {i I 36 ! believe that the steps we have taken to keep ourselves 37 ! 38 l informed and in contrpl of the Project have matured over the 39 I l 40 years. Our involvement has deepened as the Project has 41 42 ! progressed. The administrative machinery to control QA 43 ' activities now in place will serve to keep us informed of 44 45 programmatic deficiencies should any occur. Our management 46 l 47 ! has become increasingly sensitive to the importance of the 48 l 49 l 50 l 51 ! Im
li 2, 3l 4! 5! quality function and, through the mechanisms I have described, 6i 7i lines of communication have been established which are al 9l I keeping us currently informed of quality-related matters. O y So our actions demonstrate that we recognize that we, as an NRC licensee, are responsible to NRC for the activities 3l 4' carried out under the construction Permits, and eventually
.: ~
6, the Operating Licenses. 7i
.6l I do not believe that our record demonstrates an abdica- .9 I Oi tion of either knowledge or responsibility far the STP. We 9 }! '
have not at any time surrendered by our actions, or.otherwise 3 relinquished, our responsibility as a licensee of the NRC. j5 Q. 57 Do you have any concluding remarks concerning
.6l, !7 ! -
the HL&P reaction to the Order to Show Cause and the underlying 13 . l l9 ' findings of the NRC Staff? l 10 . Il j A. 57 Yes. I believe that we have acted in a responsible 12 ' g3 l and timely fashion in dealing with the matters underlying I 14l g3 the Order to Show Cause. 16l - I do not wish to understate the importance of I&E's t 17 I I8l findings, but they should not be overstated. Our concrete j 19 ! 10 and backfill work has been adequate and the product has been 11 12 ; demonstrated to be satisfactory. Although deficiencies were 13 i ! g4 found in the welding program, these problems were detected 15 gg by the B&R QA audit program. In no aspect of our work to
$7 date has the safety of the Project been jeopardized.
l gg 49 50 51 i 1 L' 2L 3i 4'. 5 As I have pointed out, we were immediately responsive 6i 7I to the deficiencies identified by the NRC Staff, and had 8i 9j undertaken major corrective action before the investigation LO I We have followed through on all of those ty ! report was issued. 2 corrective measures and the improvements in our QA/QC program 9 14 have been apparent. - 12 16 i We have accepted responsibility for the deficiencies 17 i 16 ! noted in the NRC's Investigation Report but, more importantly, 19 ; 20 ; we have turned the lessons of the entire enforcement action
-9 hj ! into an opportunity for upgrading our QA/QC functions and, }34 , more generally, our management control of the STP. We 25 believe the entire Project will be stronger for the experience.
26 ,l 27 i 23 . ! l 29 TH:08:A 30 t 31 i l 32 33 34 1 35 ' 36 : 37 ! l 38 i ' 39 ! 40 i 41 I l 42 43 ; 44 45 ' 46 47 48 49 l 90 ' 51 Attr. chm:nt No. l' WXECUTIVE VICE PRESIDENT l VICE-PRESIDENT POWER PLANT CONSTRUCTION
& TECHNICAL SERVICES MANAGER QUALITY ASSURANCE OPERATIONS PROJECTS QA QA SUPPORT
.QA MANAGER MANAGER I _
SUPERVISOf) I .
' PROJECT QA SUPERVISOR
}
SITE QUALITY ASSURANCE SUPERVISOR t _ , _ _ ._ .._ , , _ _ _ _. ~ _ _ , . . . _ . _ - _ _ _ _ , - - , _ _ . , _. .
)
l 4 9 I EXECUTIVE 4 VICE PRESIDENT VICE PRESIDENT MANAGER MANAGER - NUCLEAR ENGINEERING SOUTil TEXAS IiOUSTON ! & CONSTRUCTION PROJECT QA QUALITY ASSURANCE l 4 tt rt W G U tt N f}}