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5, TESTIMONY OF RICHARD A. FRAZAR6i REGARDING CHANGES MADE TO ADMINISTRATIVE CONTROLS7j IN RESPONSE TO THE ORDER TO SHOW CAUSE
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I Q. 1 Please state your name and current occupation.g,
11 A. 1 Richard A. Frazar. I am the Manager, South Texas12 !13 Project Quality Assurance of the Houston Lighting & Power1419 Company (HL&P).16 :17 i Q. 2 Describe your professional qualifications, educational
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9g| background, and involvement in the South Texas Project{g
(STP). ,
122 A. 2 These are set forth in my testimony on the current,
! 23 t ,
24 ! Quality Assurance (QA) program for STP. !2926 , Q. 3 What is the pIrpose of your testimony?27 |
| 28 i A. 3 ihe principal purpose of my testimony is to ,
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2 9 |> describe the changes made in the STP administrative controls3039 in response to items 5, 6, 9 and 9 of the NRC's Order to3733
| i Show Cause of April 30, 1980, (Order) and to explain how| 34 !
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35 ! these administrative controls satisfy the requirements of36 | ,
Appendix B to 10 CFR Part 50. Preliminarily, however, I37 !38 i39 1 will describe a number of improvements to the STP QA program
40 i41 | that we initiated even prior to the issuance of the Order as
42 l43 | a follow-up to meetings with the NRC in December 1979 and
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#^""U 1980-4546 ;
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2.3|415 Q. 4 Please describe the improvements to the STP QA6;7I program that were undertaken in December 1979 and January8i 1980.9
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.1 '|A. 4 As described in Mr. oprea's testimony, after a
*2 meeting with Mr. Seyfrit, Director of NRC's Region IV Office.3.4 of Inspection and Enforcement (IE) on December 28, 1979,.5.6 HL&P committed to a nine-point plan for specific improvements.7 i,g | to the STP QA Program. These can be summarized in the'9O, f llowing nine elements:
}!n First, it was committed that B&R would hold a seminar
13 to review with both Construction and QC personnel the funda-14 ;U5 mental philosophies and standards of STP QA program. The16 ,|7 i seminar was to emphasize the respective roles of Construction.8up . and QC in assuring quality construction and a safe facility.10 i1 Thesycondelementofourprogramwastochangeproce-
'2';3 i dures to clarify when to use a Field Request for Engineering
Action (FREA) as opposed to using a Nonconformance Report5
i ;6 (NCR). One source of frustration on the part of the QCi
17 ||S ! Inspectors was Construction's use of the field design changei9 ! '
:0 | system in instances where it might not be fully appropriate.. .I.
,2 , It appeared to the Inspectors that in some inv.ances, Construc--3 i,,g |
tion personnel would avoid correcting nonconforming conditions
by obtaining Engineering's approval of the deviation in the
'7 ! form of field design changes (FREA's). Although both systems,8
| d3 , resulted in review by Engineering and an appropriate disposition,;0 ,!
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3|4i5, when the FREA system was used the conditions were not iden- ;
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7i tified as nonconformances. This limited the" ability of the
3g{' QA system to detect underlying problems. We changed the
h0| FREA and NCR procedures to make clear when each was appropriate.JL *L2 i Third, B&R issued a written policy describing theL3L4 process for resolving any disagreements between ConstructioL9L6 and QC personnel. The policy specifically stated thatL7 iLg | threats or intimidation would not be tolerated.
L9 '! Fourth, because NRC questioned the qualifications of202' some B&R QA and QC personnel, we undertook a management2223 assessment of the overall qualifications of the B&R QA and24 '35 QC personnel to provide the basis for upgrading the caliber2637 ' of personnel.28gg , Fifth, HL&P directed B&R QA and Construction management'~Og, to implement strict procedures for concrete preplanning and
32 '33 j placement activities. HL&P QA and Construction personnel
34 would participate in the preplanning and placement process3a36 :
.to make sure the work was done in a thorough fashion.
37 !38 sixth, procedu,res were revised to provide a controlled39 i40 | method for judging when reinspection of a concrete placement41 |42 ! is necessary prior to sign-off of the pour card.
43 !44 | Seventh, three key HL&P QA personnel, including the
5j Projects QA Manager, were assigned to the site to strengthen
47 ! HL&P's role in the short term, to be directly and visibly48 |49 ' involved in the work in the field and to facilitate the50 1
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1i |2.3;45 e ntinuing investigation by the NRC Staff. HL&P further
617j added to its staff at the site during 1980 to underscore its
II active role in assuring that procedures were adequate and9i.0 | that implementation was thorough. Distinctive identifi-.1 i.2 | cation would be provided for HL&P personnel to increase.3 ,,4 their visibility on the jobsite.5 '
.6 Eighth, a refresher training course would be imple-
mented for B&R Construction and QC personnel to reinforce
;9 i their understanding of their assigned duties and the proce-.0 '
11 ; dures governing their work.!2 i!3 ' Ninth, a study was conducted in which there were inter-14 !IS . views of B&R personnel, starting with top level management
S
5'7 .
and proceeding throughout the B&R organization, to determine
SS{g! the cause of the perception of harassment or undue pressurc
10; on QC personnel.
32 | As also pointed out in Mr. Oprea's testimony, after the3334 ! exit interview with I&E on January 24, 1980, the additional35 !36 !37 !
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following improvements were undertaken:
33 We ins-ituted a program to upgrade the system for
39 !'
40|analyzing _ rends in honconfo*mances. A new system for
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4. ,T, coding NCRs and FREAs would be adopted and all past and
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44 Ifuture FREAs and NCRs would be coded to permit analysis.
I 45 There would be quarterly Trending Reports and identifiedj 46' 47 trends would be investigated to determine if there were
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34'5' common causes. When common causes were identified, appro-6':7i priate corrective action would be taken.
8'9 The assessment of qualifications of QA/QC personnel was
I continued. Only one QC Inspector was found to have question-
12 ! able credentials.1314 Meetings were held by P4R to reemphasize to QC Inspectors15 -
16 that they must take as much time as needed to perform thorough17ig inspections; HL&P QA and Construction personnel were directed9a.j~ ' to ensure by their involvement in concrete preplacement and21 placement activities that adequate time is allowed for2223 inspection prior to and during the placement of concrete.24 ;
39 In addition, a memorandum was issued to QA/QC personnel2627 ! directing that all nonconforming conditions were to be
' 23 ,
29 documented as soon as they were identified.''O
g HL&P surveillance personnel were directed to document
all nonconforming conditions, even those documented by334 ' others.3936 .
. EL&P Audit schedules were revised to make sure that there!37
30 was an annual corporate audit of B&R construction, and HL&P*39 i
40 j audit procedures were revised to state that procedure imple-I
4{9 . mentation is to be verified by direct observation of work !
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44 ; being performed in the field as well as by reviews of docu-
45 mentary evidence. We also decided to have our QA program I
47 ' audited by an outside consultant at least once a year.48 i
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L,2,3I4'5 B&R competely revised the Welder Training Program and6*7- added a ceneral Superintendent to coordinate the work of theS9, welders on the project, to monitor their capabilities and.0 |JL ' progress, to initiate retraining where needed, and to workJZ ,;g closely with the welding engineers and welder training
*4 department. In addition, a new B&R Chief Welding Engineer.
.adi assumed responsibility for working closely with construction,.7 ,
JI I- welder training, B&R corporate welding engineering, and.9 i|Q QA/QC groups to institute programs to further improve welding!! '
:2 performance.;34;4 Radiography on the site was temporarily limited to work
'y \Sunder the direct supervision of Level III QA Engineers. All
14
site NDE personnel were retrained and recertified. A new
|9 ' procedure was implemented for the control of film processing10 jll " and another new procedure prohibited the shooter of radio-1213 graphic film from also doing the film interpretation. In14;5 , addition, B&R personnel performing liquid penetrant examina-16 '
tions were retrained.;7 ;
! 18 'A review of all radiographs on the Project was undertaken.;g ,
Both HL&P and B&R surveillance teams were to conduct speciali2 reviews and surveillance of the NDE program..3i4 | Backfill procedures were changed to specify depths foriS Iys ' conducting in-place density tests and a test program was'
*7'. ,
;g ; initiated on site to determine whether proper density had'
|0 | been obtained thus far on the Project. The results of that
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123'45 program are described in the testimony of Mr. Pettersson and6-7; Mr. Hedges.
89, The foregoing improvements have been completed and the
} NRC has verified their implementation in its inspection
2' reports. Some of the improvements related to administrative.3.4 controls and were carried over into items of the Show Cause.S.6 order that I will discuss below..7,g Q. 5 The first Item of the Show cause order which
[9 relates to administrative controls is Item 5, which required0n
{} that HL&P define more clearly the stop work authority,
f*temporary or otherwise, including implementation of the stop
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IU work authority. Please explain the meaning of the term1617 "stop work authority."1319 A. 5 This term refers to the authority of certain1031 Project personnel to require that construction work be
1233
stopped. The construction work affected by a stop work
Ii' order can be of broad scope, such as stopping all construc-la16 tion on the Project or all welding; or it can be narrow,17 '18 such as stopping a,particular craftsman from working ori
i 19 ,
| 10 | prohibiting use of a particular piece of equipment. On STP,I 11
52 as on most other projects, the term "stop work order" is| 13 !
g4 only used for the broad scope work stoppages. The narrowi
ff scope work stops are called " holds."t
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L23i45' Q. 6 What conditions led NRC to order a clarification6i7 of the stop work authority?3i9! A. 6 The Order does not state explicitly. However,Oi1i the NRC'c April 28, 1980, Investigation Report 79-19 (NRC
2',3 i Investigation Report) on which the Order is based, states
d that the B&R QC Inspectors expressed uncertainty regarding.3.6 their authority to stop work and also that a Construction.7 i.3 ' Foreman and QC Inspector expressed conflicting views regard-.90 ing the stop work authority of QC Inspectors.1
3 Q. 7 Are you familiar with the HL&P-B&R Task Force
34 described in Mr. Briskin's testimony that was established to
5 prepare responses to the Order?
I' A. 7 Yes. I was in charge of the Task Force until.39 HL&P responded to the Notice of Violation on May 23, 1980.01 Thereafter Mr. Briskin was given responsibility for the Task2-3, Force's preparation of the response to the Show Cause Order.4-5 I was put in charge of drafting the response to Item 1, andi
6-- several members of my staff participated in the other sub-!
78 groups of the Task Force. I participated in meetings with
1|,0 those subgroups and have reviewed working papers of the Task
2 Force subgroups that described findings a.nd proposed changes'34| to procedures. Upon completion by the Task Force of proposed5i6 procedure changes, I participated in the decisions on those
7i,g ; changes.
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5 Q. 8 What were the findings of the Task Force concerning
6 stop work authority?73 A. 8 The Task Force found that HL&P had procedures in9
10 effect which designated certain EL&P QA personnel as havingL112 stop work authority, and that B&R had comparable procedures.1314 However, it also found that neither the site procedures of
HL&P nor those of B&R clearly addressed the stop work author-
'7{g ity of personnel below the Supervisors level.
13 ' Q. 9 What was EL&P's response to Item 5 of the Order?2031 A. 9 HL&P stated that both EL&P and B&R had defined2223 the stop work authority more clearly. It went on to identify24gg the positions in each organization which have stop work2627 authority, and explained how they can exercise such authority.
23Q. 10 What positions in the EL&P organization havegg
}'O stop work authority?
32 A. 10 The EL&P QA Staff organIization is described in3334 - the answer to Question 7 of my previous testimony concerning
| 30| 36 the current QA program for STP.'
3739 The.EL&P procedures distinguish between two types of
39t 40 , stop work authority: a temporary oral order, called an
!4;9 Emergency Stop Work Order, and a written order of indefinite,
4.
43 duration called simply a stop Work Order. The HL&P site4445 QA/QC supervi.sory positions and the STP QA Manager have
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4647 authority to issue a written Stop Work Order. All othert ,
! 48 *
| 49 EL&P QA/QC personnel have authority to issue Emergency Stop9051
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2,3!45 W rk orders, which remain in effect until an HL&P QA or QC
Supervisor issues either a written Stop Work Order or a
3I written rescission of the Emergency Stop Work Order. The9|0 affected organization is then prohibitea from resuming the1'2 work activity until receipt of a written release from HL&P34 QA.nj Q. 11 What positions in the B&R organization have stop7 work authority?g9' A. 11 The B&R QA organization is described in the01 answer to Question 8 of my previous testimony concerning the23 current QA program for STP.43 B&R procedures also provide two types of stop work5,7 authority: the authority to issue a hold tag, which places
[S ' a hold or work stoppage on some construction activity of90 narrow scope; and a stop work order, which is used to stop a
;2 broader range of construction activities.i3 >|4 i QC Inspectors apply hold tags at the time they identify
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I ;6 on a Nonconformance Report (NCR) a condition that does not17 iis conform to design requirements. A hold tag is a standard
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;o . form that is physically attached to the nonconforming material
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or work. The hold tag prohibits continuation or commencemente.
I3 of the designated activity until there is a disposition of14 ,15 I the NCR as a result of the procedures described below. When16
17 | the nonconforming condition is corrected or resolved in some
18}gg other way the hold tag is removed by a QC inspector. Thus30 j51 |
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L2,3'4'5| all QA/QC personnel have the authority to stop work immedi-
6'ately through identification of a nonconformance on an NCR7;
3I and issuance of a hold tag.
O The on-site authority to issue a stop Work order is1!2< limited to the B&R Project QA Manager. These are written34 orders to organizations involved in design or construction5 ~
.6 activities, which must be acknowledged in writing by the
;7 i affected organization.gi
3! In situations where IMJL QA/QC personnel believe that a
1 Stop Work Order should be considered, they submit a written23 notice of deficiencies to the B&R Project QA Manager. If.4.3 the Project QA Manager decides a Stop Work Order is required,.6.7 ' he orally notifies the Supervisor of the organization perform-;S ,
9 ing the work and the HL&P STP QA Manager and transmits a
written Stcp Work Order to the organization performing the,
2!,3 work. The Stop Work order must be signed, dated and returned
i! to the B&R Project QA Manager by the organization performingla l
16 ,.
the work, thereby acknowledging receipt and verifying thati
17 ''
| 18 , the work has been stopped. If the Project QA Manager deter-,
| 19 :10j mines that a Stop Work order is not required, he so notifies
o({i the QA/QC personnel who reported the condition and the;
l 13 cognizant Construction Supervisor together with his reasonsg15 I for so acting.,
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17 ! Q. 12 What role does HL&P have in Stop Work Orders18{19 i issued by B&R?
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4'5' A. 12 Authorization to resume all or part of the' work67 affected by a B&R Stop Work Order may be given only by the8|9t B&R Project QA Manager. He will issue such authorization0j, only after he has determined that all responses, corrective2'jg actions, recurrence controls and other requirements have
4 been satisfied, and the HL&P Manager, STP QA, has determined.'_.6 the resolution to be acceptable. Written approval of the.7.3 ' HL&P Manager, STP QA is a prerequisite for issuance of a.9 ;
|0 total or partial release to the organization performing the1112 work.
13,4 Q. 13 Do the procedures of HL&P and B&R that control'S stop work authority comply with Appendix B to 10 CFR Part*
.O- 50, applicable NRC regulatory guides and other applicable{{'
19 industry standards?10 '31 A. 13 Yes. Appendix B Criterion II and Regulatory3233 Guide 1.28, which endorses ANSI N45.2, andress the require-34 !35 , ments for stop work authority being placed within the QA
36 . .
37 - #9""l**tl "'
38 | The revised HL&P and B&R procedures provide the author-39
i 40 i ity for QA/QC personnel to stop work verbally whenever a41 '42 safety related noncompliance is identified. Provisions for43 -44 ,' formal stop work documentation follow-up is also provided.49 !46 These procedures address all activities of fabrication and
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construction as well as engineering, design, hardware and QA |47 '
gg.
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1!23|4i5i program deficiencies and identify the internal organizational6!7| activities as well as EL&P/B&R interface responsibilities8i9| for imposing and releasing the Stop Work Order.
LO |;3, i Q. 14 Have the new stop work procedures been properly.'f,2 | implemented?3
lf' A. 14 The new B&R Stop Work Procedure, ST-QAP-15.2,lo -
L6 : Revision 1, was made effective on January 26, 1981. TrainingL7 iLE | on the procedural requirements was completed prior to thatL9 !10 ! date. The procedure has been fully implemented since.l' !gj l Since the issuance of QAP-15.2,.there have been two B&R Stop23yj Work Orders invoked. In one case the discrepancy was resolved
in one day. The other has undergone two partial releases,
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with the remainder currently being resolved. In both cases-
19 ! the Stop Work procedure was properly implemented.30 i'
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31 4 HL&P Prcject QA procedure PSQP-A-7 was issued on July32 |33 ; 25, 1980 and HL&P QA Department procedure QAP-12-A was34 !35 | issued on September 22, 1980. These procedures more clearly
16||- delineate which positions have stop work authority. In I&E
1
|373839| Inspection Report 80.-27, the NRC Staff reviewed the procedures
i
10| and found that stop work authority is adequately described.| 11 !| 12 j Q. 15 Item 6 in the Order required HL&P to develop andi 13 I| 14| implement a more effective system to provide for the identi-
15 |16 } fication and correction of the root causes of the nonconfor-17 !gg j mances which occur. Please explain the meaning of the term
i !9 "nonconformance."a0
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A. 15 A nonconformance is a condition that is not in56! accord with Project requirements such as job specificatio'ns, d7I
3| procecures for the control of special processes, etc. That91.0 | could include a concrete structure that does not have all of1|2| the steel reinforcement' required by the design drawings or a.3, .; welder not being certified for the type of weld he is doing,
|B or any other deviation from Project requirements.'
6,
*7| Q. 16 How are nonconformances identified and documented?,,
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9I A. 16 It is the job of QC Inspectors to verify that:0CL
|2|construction work is being done in accordance with the
C3 < applicable requirements. When the QC Inspector identifies a!4 :15 condition that does not comply with the requirements there'S[7 ! is a procedure he must follow that is designed to assureio :
jg* that the nonconforming condition is properly dispositioned
! (i.e., either correc'ted or reviewed by Engineering and found'
32 I to be acceptable). At the STP the procedure involves the13 |14 initiation'of a document called a Nonconformance Report15 i16 , (NCR). This is the same NCR I mentioned in ccnnection with17 i33 I my discussion of stop work authority. The QC Inspector's
,
19 i10| initiation of an NCR is the primary way that nonconformances
;
p; i are identified during construction.j 1. 4,
13| Q. 17 So that it will be clear when the subject comes1415 up later, please describe the field design change procedure.1647 , A. 17 The field design change procedure is described18 i49| in detail in Mr. Briskin's testimony. Prior to the Show
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1|- Cause Order the field change procedure involved use of a$.
' document called a Field Request for Engineering Action7II' (FREA); now the appropriate form is a Field Change Request33i (FCR). Field design changes are changes to design that are1'2' requested by personnel at the job site. A typical reason
34 for such a change may be that there is an interference
9 between piping and cable trays which could not be antici-6I
i pated by the designer, but which was realized as constructiong9i work was planned in the field. The NCR and the FCR are01 similar in that each reports a condition that appears to23 require evaluation by Design Engineers and in either case a415 change in the design may result.
'6,7 Q. 18 Please explain what the systems are that identify
's ,
{g and correct the und . lying causes of nonconformances.
A. 18 The idenrification of the underlying causes ofl, ;
12 ' nonconformances involves the analysis of NCR's to determine13 4
14 I what condition on the Project might have led to the error in15 !16 question. For example, a particular type of error may
17 i33
result from ambiguous construction procedures, from a particu,,
19 ; lar construction worker's misunderstanding of a procedure,10 !
1}9or from an inadverrent error by a worker. The Project must
g
33 have a system to attempt to identify which among these or,
14 i
45 ! other possible causes is actually involved. One tool in46 '
47 ! identifying the casues of nonconformances is an analysis of48 I
49 data regarding incidents of nonconformance. Such analysesi50 ,
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5! as ased to detect problems that might indicate the existence
6 \
71 of a common, underlying cause. This process is referred to ;
84as " trend analysis" or " trending."g
.0 once the underlying cause of a nonconformance is identi-
.1 ._~ ~ ~ . _
.2 fied, it may be possible to prevent the same type cf condition
.3
.4 from recurring by correcting the underlying cause. T3us if!3 .
.6 the cause were an ambiguous procedure, the procedure :ould
.7 ,
,g be clarified and the personnel using that procedure rehrainedC
]i to the revised procedure. Several such instances mighti,
jg suggest a need for a review of how procedures of a certain
13 class are prepared and/or reviewed prior to publication. If.*
15 the cause was misunderstanding on the part of one worker.16 ,
17 , that man might be retrained or reassigned. A large number18gg of such instances could reflect the need for wider re-training
30or a refresher course for workers. There is, of course,
3, ,
3j* also the possiblity that the nonconformance is an i''-!ated3
34 i incident and that it does not demonstrate that any recurrence3D
36 ; _ control is required.37 :38 Q. 19 What was the reason that NRC ordered HL&P to
~
39 i40 ; implement a more effective system for identification and
'g,4j | correction of the underlying causes of nonconformances?
43A. 19 Here again, the Order doesn't state explicitly,
44
5! but the NRC Investigation Report found that there was no
47 ! effective system for statistically analyzing FREAs that 'I48 '
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L2,34;5, might have been used instead of an NCR to document noncon-6*7: forming conditions. As discussed further in Mr. Briskin'sag testimony, inappropriate use of the field design change
f procedures (FREA's) in lieu of an NCR could inadvertently
E2 mask an underlying reason for a given problem. NRC also.3L4 referred to the results of past trending reports and con-L5.6 cluded that there were trends in the data which were not'7.g' being picked up in the reports.,
*9.IO, Q. 20 What was the approach of the Task Force in#1
{} responding to Item 6 of the NRC Order?
f3 A. 20 The Task Force decided to review the process by.
15 which nonconformances are identified, documented and resolved.16UT , It then analyzed how to improve the trending process which13gg was the focus of the Order. Finally, the Task Force reviewed10g1 the procedures for ordering that a cause of nonconformances
12be corrected. With respect to each of these three phases ofgy
I4 the process, the Task Force - which had representatives ofIS
16j . Construction, QA/QC, Site Engineering, and Quality Engineering -17
18! reviewed the objectives of the process and proposed new19 ' ~
10 | procedures to better achieve those objectives. I. was ail :;2 thorough review of the entire process.i3 !
;,g j Q. 21 Before the Order, what was the procedure used at
f the site to identify and document nonconformances?
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23'45' their inspection and then recorded the inspection results on
one of a variety of different forms, depending on the type
8< of construction work inspected. When nonconformances were9
LO ' found in a final inspection, the QC Inspector rece: ad thatLL 'L2 fact in a draft NCR. 3hich was submitted to the Lead QCi
1314 Inspector. From the Lead QC Inspector, the draft NCR was~g -S
reviewed successively by the QC Supervisor, the QA Engineer6
17 and the QA NCR Supervisor.g13 After the QA NCR Supervisor prepared the final typed2021 NCR, it was first sent to Design Engineering for disposition2223 and then routed successively to a number of other organiza-24 '29 tions for review and approval of the disposition. The NCR,
26 -27 , with the disposition indicated, was then routed back through
23 several offices for information purposes before Construction293 re eived the form and implemented the approved disposition.332 Q. 22 What were the Task Force findings about the NCR g33 ,
|34 - system?3536 - A. 22 The Task Force found that the system was unneces-
| 3738 sarily slow and cumbersome and that consequently field39'
| personnel tried to rvoid using it. It noted th2t the inter-40 ;
4k. views with QC Inspectors summarized in the NRC Investigation4 .
,
; 43 Report showed that their morale was adversely affected by'
44
|45 i the lack of feedback on how the nonconforming conditions
| 46! 47 | they identified were corrected or why their management
48 !
49 decided not to process certain draft NCR's.'
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Q. 23 What is the new procedure for identifying and56 documenting nonconformances?
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73 A. 23 The first change is in the planning of inspec-9t0 tions. The expanded B&R Quality Engineering organization1.2 | (QE) described in Mr. Oprea's testimony participates in
.3,4 construction planning and determines inspection " hold points"
f6 f r w rk activities. When Construction reaches such a hold'7 point it cannot proceed until a QC Inspector performs the.5.3 required inspection and approves the work to that point.!O11 Sometimes " hold points" are not practical, such as.in contin-1213 uous inspection of concrete placement activities. In these
14gg cases other inspection guidelines are specified in procedures.
'S{7 ; For each inspection hold point QE determines the inspec-
f3 i tion characteristics required, and those inspection character-,
30 istics are recorded on preprinted Inspection Report forms to31 .
32 be used by QC Inspectors in their planned inspections. QC3334 ! Inspectors record the results of all planned inspections and35 '36 | , reinspections on the Inspection Report. The Inspection Report
37 i38 ; is used to track all items found in planned inspections to
39 t be unsatisfactory, from the time of initial identification40
4f to the time the items are satisfactorily resolved.,
43 j When a planned inspection for acceptance of wor 3 is4445 { being conducted, all checklist items noted on the In spection4647 ! Report are verified as "S" (satisfactory), "U" (unsatisfac-48 !
49 ; tory), or "N/A" (not applicable). The QC Inspectors, under
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45j new procedures, promptly notify the Construction Foreman or
6 General Foreman of items recorded as "U" and initiate a NCR.
8! The NCR is a pre-numbered and control'.ed form that is acknowl-9!.0 i edged by the signature of the Construction Foreman or General.1 !.2 i Foreman. Where appropriate, hold tags or other work con-.3 ',,g straints are applied by the QC Inspector at the time the NCR
is issued.'
5,
'7 Q. 24 How is the NCR processed?g9I A. 24 When nonconforming items or conditions can be
!O '11 ! reworked to the original configuration or brought into!2 |!3 compliance through a " standard repair procedure", then no!4 i!5 design evaluation is required. In such cases, the Lead CC'S{7 Inspector and the Construction General Foreman agree on theSS{g " standard repair procedure" to be used and record that
I agreement in the disposition section of the NCR. Once the
32 ' disposition is complete and approved, the QC Inspector13 ;14 ' removes the hold tags and work may proceed. The QC Inspector15 i16 :
'
also records on the Inspection Report the fact that the NCR37 l38 i has been resolved. NCR's falling into this category are
,
19 t10 then forwarded to the cognizant Quality Engineer for review.
The Quality Engineer must either give written approval or
I3 ; reinitiate the NCR.44 |45| When an item will not or cannot be reworked to the46 ,
47 i "ac-designed" configuration, the NCR is submitted to Quality48 !49 | Engineering for review. If it is determined that the NCR is
50 |51 i
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4,5 no t valid (i .e. , the QC Inspector misinterpreted the require-6'7| ment), the NCR is dispositioned by Quality Engineering, and8' explanatory comments noted in the justification section of9
.0| the form. If Quality Engineering determines that the NCR
.1 '
.2 , can be dispositioned by rework or a " standard repair pro-
.3'4 cedure", neither of which requires further design evaluation,.
.S
.6 that disposition is also noted on the form. In either of*7g these cases the form is returned so that any needed rework
{ .or standard repairs can be completed and the QC InspectorIl can record on the Inspection Report that the condition is1213 satisfactory. As discussed below, this helps to assure that1415 QC Inspectors are aware of the disposition of their findings.1517 i .
Most nonconforming items are resolved through this18gg orderly interaction of QC, Construction and Quality Engineer-10 'gg ing. The nonconformances that cannot be resolved by these
2organizations are the conditions that require ucsign evalua-
I4 ' tion. A new on-site committee, called the Materials Review15
16 ' Board, has been created to coordinate the resolutisn of17 |18 ' NCR's requiring design evaluation. The Materials Review
'
19 ,
p3 j Board consists of a senior representative from QA (Chairman),p'gj, Design Engineering, and Construction. An Authorized Nuclear
139; Inspector (ASMI) and representatives from Westinghouse,
! I3! Purchasing, and Materials control are available on call.I 66
II The Materials Review Board members coordinate the68 |19 ' determination of a proposed disposition based on consultation10 ,il ',
i
1
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.'y with their respective organizations. When the memberu
4
07 f concur on the disposition, each member signs the NCR.
(Desim. Ch' age Notices which may be required in the case of
LO | "use-a,-is" or " repair" dispositions are discussed furtherL1 :12 in Mr. Briskin's testimony, in connection with Item 7 of the1314 Order). When necessary, on-call members are consulted1316 ' before approval of a proposed disposition. The signed NCR,
17 i with disposition noted, is then sent to EL&P QA for reviewig e'930
f the disposition to ensure concurrence that QA requirements21 , have been implemented. Thereafter it is sent to B&R Construc-2223 ' tion for implementation and to B&R QC fcr inspection.2429 ' Q. 25 In what wa' s does the n. " Nr.P c acedure represent26 ;27 i an improvement?2829 ; A 25 appeared that in the past, there were times
}' O i when an NCR was processed and the condition corrected, butg32 the QC Inspector who had written the NCR never found out33 ;34 ' about the corrective action. Because they had not heard35 I36 i .
otherwise, some of the B&R QC inspectors believed that the37 !
l 38 i nonconformances.they had identified were not corrected. Also,
39 !40 i the NRC Investigation Report said that because NCRs were
4j : occasionally revised or discarded by QC management in the course49
'
| 43 + some QC Inspectors felt that they were not supportedor review,44 |45 ! by their management. Now NCR's are prepared by the QC46 '
47 ! Inspectors without review and the new procedure does not48 |
49 | permit discarding invalid NCR's.90 |51 |
!
! it
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L234i5; The Inspection Report form was adopted so that there
6i will be a document which will record the NCR, its resolution7i89j and the final acceptance by QC. Inspectors will now know
.0 exactly where they can look to see how a matter was resolved.
.1 i
.2 ! When an NCR is improperly written, the disposition of "use
.34 as is" is noted on it by the Lead QC Inspector or the Quality
.D-
.6 Engineer and the justification is documented. Thus, there
.7|,g ' is an explanation available to the QC Inspector of how and
9| why the matter was resolved. This is also the reason QC0!1 ; will be notified of the disposition of all NCRs.!2!3 The NRC Investigation Report said that there was a14
!S tendency on the Project to document nonconforming conditions1617 , through the field design change system instead of the NCRLS .gg system. The Task Force concluded that the reason for this10 ', was that the NCR process was cumbersome and slow, and Project
,
! 3132 ' personnel found it faster and easier to use the field design33
34f change system. The new NCR system is very easy to use, and3a i
| 36 ! . with the addition of the Materials Review Board the NCR| 37 !| 38 i process is much fas,ter. In addition, as explained in
39 !toj Mr. Briskin's testimony in connection with the discussion of
4'43 the field design change system (Item 7 of the Order), the
!43 procedures now clearly require that all nonconformances be44 ;
45 documented through the NCR system.
47 !;
| 48 !49 |50 !51 i
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3|4 Q. 26 Does the revised procedure comply with Appendix56 B to 10 CFR Part 50, applicable NRC Regulatory Guides and78, applicable industry standards?9:,0 | A. 26 Yes. Our procedures in the past and the new
.1 !,2 , procedure are consistent with Appendix B Criterion XV and
*3 ANSI N45.2 Section 16 which deal directly with control of4 '
f=,j nonconformances, as well as other associated criteria such*
_
L7 , as QA records (Criterion XVII).LaL9 ! Q. 27 How well have the new nonconformance reporting20 '21 ; and disposition procedures been 3orking?
2223 A. 27 The new nonconformance crocedure was initiated
n}a} on October 15, 1980. Since that time the Material Review
f, Board (MRB) has been in operation. EL&P Discipline QA
23 ! personnel have also been directly involved in the approval2930 cycle of all NCRs initiated by HL&P as well as all B&R NCRs3432 i requiring disposition by the MRB (i.e., all NCRs other than33
I34 " rework" or " standard repair"). In addition, the MRB has
!3S36 . been providing HL&P QA with MRB meeting minutes which list
action taken on all NCRs. EL&P extends its involvement39 ! through the use of the B&R NCR system for resolution of
( 40 1
41 ! nonconformances identified by HL&P QA personnel; EL&P QA has42 ,
also performed reviews of the nonconformance control system43 i
4445 | and we have found that it is functioning adequately.
46 i
47 : Q. 28 Before the Order what was the procedure used on
48 i1 the Project to analyze the trends in nonconformances?49 ,
SO |51 !
!
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4|5 A. 38 Prior to February 1980, the trend analysis
67; function at STP was an informal process undertaken by various
89| members of B&R Project management. Results were reflected
primarily in the corrective action taken. The formal trend,
.2 analysis that was performed analyzed a portion of the STP
.34 inspection reports, NCR's, and selected Field Requests for?6 Engineering Action (FREAs). These data were not normalized.
.7,g | The identification of a trend was based solely on the number
Q
{~ ' of incidents reported in a given category of activity. HL&P
n
{-reviewed B&R trending reports and did no independent trend
analysis. In February 1980, we began to develop a formal.*
15 , trending program. This was committed to in our early response1617 , to information from the January 24, 1980 exit interview with
13gg the NRC.
| 30 Whst additional changes were made in trending"'
31 m.
32 !33|
j b performance in response to the Order?
34 i A. 29 A new Data Analysis Group, comprised of Quality39
36 j Systems Engineers within B&R QA, was established in July,37
1 38 : 1980, and is now responsible for identifying the methods to~
| 39 !40 j be used to collect data, the ways to categorize and monitor
41 '42 deficient conditions by the use of quality indicators, data
43 normalization and graphic representation, and the methods of44
4f ! reporting this information to manageatent. Formal procedures
47 ! require the collection of data from all QA records that j48 I
49 record nonconforming conditions.,
50 i '
51 |i
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L2,3;4i5; A new unif rm coding system has been developed and all
those charged with collecting data for trending have been
8 trained in the use of the system to assure uniform applica-9;
.0 ' tion. Standardized codes have been developed for a number
.1 !
.2| of categories, including: building or area, activity,
.3 'i,4 failure type and time interval.t-
'|6 Procedures specifically identify the types of documents
L7 | to be trended and the B&R organizations responsible for,g,l9k review of each type of document, collection of data and20 :11 ' submission to the Data Analysis Group. Examples of documents2223 included in the list are: NCRs, Corrective Action Requests
'
2423 (CARS), Vendor Surveillance Reports and Audit Deficiency2627 f Reports. The Data Analysis Group is responsible for reporting
23 ;| the results of its analyses to B&R Quality Engineering.293
| Quality Engineering reviews suspect areas to determine
32 ! whether the incidents that make up a trend have a common33 ,34 ! cause.35 !36 | .
The trend analysis performed by the Data Analysis Group373g is made available to HL&P QA at the same time that it is39 I
distributed to B&R management. The HL&P Supervisor, Quality40 i
f| Systems reviews B&R data and other data collected by HL&P43 ' implementation reviews, and performs an independent trend4445 review. I include this information in the monthly report46 '
47 i that is sent to Mr. Oprea and use it in assessing the per- 1
4849 formance of the B&R QA program.
,
50 !
51 !
! .
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12,345 Q. 30- Why does this new procedure represent an improve-67 ment over the previous system? o
89' A. 30 The Task Force found that the trending efforts
prior to the NRC investigation were not effective because
2 there was no centralized responsibility for collecting data.3.4 and perform.ng trend analysis; and trending was not controlled.D
.6 by formal procedures. Now those formal procedures have been
.7
.g promulgated and a competent engineering staff has been
'9O
established with primary responsibility for collecting and,
} analyzing the data.
3 In addition, the NRC Investigation Report found that45 the effectiveness of the trending efford was reduced by the67 use of the field design change procedure in situations in.89 which an NCR would have been more appropriate. That affected .
01 trending because not all field design changes were included
2in the trending. By procedurally assuring that nonconforming3
conditions are not handled as field design changes, we have
6 eliminated this potential problem, i.e., we have taken stepss
S to eliminate the use of the field design change process for90. the resolution of what are really nonconformances.1'2 Q. 31 Does the trending program now in use on the
3. ,g Project comply with 10 CFR Part 50, Appendix 3, and appli-
5i cable NRC Regulatory Guides and industry standards?6.7 i
8|29;0 ,
il ;
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4|5 A. 31 Yes. Appendix B and ANSI N45.2 do not specifi-
6' cally require a trend analysis program or establish any7i8 criteria relative to the mandatory content of a trending9 i
10 | program. However, Criterion XVI of Appendix B requires thatL112 ' corrective action be taken to preclude repetition of signifi-13 ,14 cant conditions adverse to quality. The new trend analysis1516 system provides a method for detecting adverse trends and
17 | for initiating investigations to determine whether or notgg
corrective action to preclude repetition is required. B&R
21 performs trending rf the B&R indentified deficiencies and2223 HL&P trends EL&P identified deficiencies, evaluates the2435 B&R trend analysis and compares the results of both.26 ,27 ; Q. 32 How well have the new trending procedures been
, 38 i! 29 working?
30 i| g ThetrendingprgcedureswereimplementedinA. 32
32 f July, 1980 and the B&R Data Analysis Group issued its first33 ,
34 ! Quarterly Report in January, 1981. As a result of the B&R35 i36 | trend analysis effort, to date ten suspect Trend Investiga-37 I38 ! tion Requests have been initiated. The HL&P trend analysis39 i40 | effort has resulted in the issuance of thirteen Trend Investi-
49 If| gation Requests. We expect that in the long term the trend
'
analysis efforts will aid in reducing the number of non-
| 45 conformances,on the Project. ;- 46 ! i
47 ! !48 j
'
| 49 || 00 :| 51 !
l!
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L2'345, Q. 33 Bef re the issuance of the Order, what was the
67| procedure for directing that actions be taken to prevento
3 recurrence of nonconformances?
.0 i A. 33 Prior to the Order the B&R Project QA ManagerJL :L2 used a form called a corrective Action Request (CAR) toL3L4 direct an organization working on the Project to take action
LSL6 to prevent recurrence of nonconformances. The CAR wouldL7
identify the organization affected, the work activity andggb3 the problem in need of correction. When the corrective20Il action was taken, the affected organization would reply to2213 the CAR, describing the corrective action.24 '2D Q. 34 What were the Task Force findings about the CAR
2627 ; system?23
A. 34 The Task Force found that the CAR system generally2930 worked well, but that in some cases it took longer than
32 necessary for an affected organization to respond to a CAR.3334 ! Q. 35 What is the revised procedure for recurrence3536 ; control?
37 '38 A. 35 B&R Qual.ity Engineering now has responsibility
t 3940 , for ensuring the identification of the causes of trends and
4}5 issuing CARS for recurrence control. CARS are still issued4 j
43 to identify for correction, significant or repetitive condi-
| 45 ! tions adverse to quality and procedure inadequacies. However, |46 ! :47 ! CARS now have specified time limits for taking responsive'
1 48 i'
49 ! action and may constrain or " hold" work on specific tasks or'
50 |
| 51 j
! I
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.
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23|4i5' by specific crews until the identified problem is resolved.
6 After a CAR is issued, Quality Engineering determines whether7;
8 i corrective action has been taken, and whether it was effec-0'0 |
! tive in preventing recurrence of the problem. Quality.
.1 ''2' Engineering may initiate a Stop Work Order if corrective.
'3.L4 action is not taken within the time limits or if the inves-LU
L6 tigative finding is that the corrective action has been ineffec-
L7 itive. In addition, HL&P QA identifies problems to B&R QA for(g
{ underlying cause investigation and recurrence control
21 | via the B&R CAR system. HL&P QA reviews all CARS for con-22 -23 currence with the B&R disposition and performs periodic24 !25 follow-ups to determine the effectiveness of implementation.2527 i .
Q. 36 Why do these new procedures on reporting, trend-
23 :29 ! ing and rectifying problems represent an improvement over
,
30 the previous system?
32 I A. 36 With the creation of the Data Analysis Group,3334 ! the MRB, and the new procedures assoM ated with the noncon-|35 i36 i ,
formance reporting system, our understanding of quality37 I38 | problems is substantially strengthened. The Data Analysis
,
39 1 ;
I 40j Group has improved the process of identifying trends adverse e
41 i *
42 ; to quality. The MRB and Quality Engineering scrutinize
NCR's to determine if recurrence control by a CAR is requirec}.| 45 These changes,substantially increase our ability to identify
46 '
| 47 the need for recurrence control.
| 48l 49
i
| 50'
51; .
!
!
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1 i23|4t5| Q. 37 Does the revised system for corrective action6\7, comply with Appendix B to 10 CFR Part 50, applicable NRC0
Regulatory Guides and industry standards?
LO ! A. 37 Yes. The procedures comply with Criterion XVIL1 ;L2 ! of 10 CFR 50 Appendix B and Section 17 of ANSI N45.2, asL3 '14 well as other related requirements and criteria.15 ,16 Q. 38 How well have the new corrective action proce-L7 i '
(g ! dures been working?
L9 'A. 38 Since the issuance of the new CAR system in-
2031 October of 1980, the procedures for processing CAR's have2223 been refined. Difficulties with the system were initially2425 , experienced because the CAR system was used to identify26 '
27 , minor problems, thus diluting its effectiveness in high-23 i29 - lighting information to management. To eliminate this
,
303g problem we have initiated a new form called the Field Action :
32Request for minor procedure deficiencies. The CAR system is,
-i
E4 ! now reserved for its intended purpose--significant and30 !
36 | . recurring conditions. This adjustment, together with HL&P37 :38 i QA's increased involvement and control, are leading to much
~
39 ! s
to i more effective recurrence control. The backlog of CARS'
. 9
| 43, issued under the old s1 stem makes it impossible at this time
13 ig4| to present a quantitative assessment of the new system. Its
15| strengths will, however, result in a decline in the numbers16 -II ! of NCRs and CARS. !%8 ,
i
%9 '3051 ,i '
|.
-107-|
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3!4,5! Q. 39 Item 8 of the Order required that HL&P develop6i7i and implement a more effective system of record controls.
8g How were records controlled prior to the Order?
O A. 39 Prior to the Order the QA vault, which is the
2i place where on-site QA records are stored, kept a number of34' separate files for each of several phases of records process-56 ing. Incomplete or inadequate documents were placed in a7g suspense file until the originating department was notifiedoi~! of the deficiencies and the deficiencies were corrected.9
} Completed records were placed in the pre-microfilm suspense
file pending microfilming. They were then kept in the
5 post-microfilm suspense file until film processing in Houston67i was completed and a determination made that the microfilm8-9 copies were acceptable. Thereafter, the records were placed0'g in the permanent files.
-2'3 Q. 40 What was the background behind the NRC Order
i' regarding the record controls?s6,
. A. 40 That is not clear. There was no discussion of7jS the record control system in the Investigation Report. I
9I~
0| understand that during the investigation there was an inci-| 1
2 dent in which an NRC inspector requested a record from the3i4 storage vault that was not located for several hours. Based5I on that we understood the NRC's criticism to be that it7! sometimes took too long to retrieve records from storage.8!9|0:1!
iI
,
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|-. . ,
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12;
3| !4I l5! Q. 41 What were the Task Force findings about the |6| '
7j record storage system?
8ig A. 41 The Task Force found that the system of having a
f0 separate file for each stage of record processing made it
12 ! difficult to locate certain files. There were too many13 .14 places to look. It appeared best to reduce the time required19 |16 ; for each processing stage, so that files could be quickly17 ilg ! placed in a central file and cross indexed.
19 !30 | Q. 42 How does the current records control system
3}9 | w rk?2
23 A. 42 Prior to commencement of a work activity, Quality2435 ' Engineers specify the requirements for the QA records necessary36 ;
37 i . to substantiate the individual activities. When work activities28 |29 : are completed, Quality Engineering reviews the required30 !31 , quality documents prior to turnover and testing to verify32 !33j that the documents are complete and adequate.
Si f New microfilm equipment has been acquired to speed up33
,
I ;
36|:. filming and to establish an on-site film processing labora-
| 37| 38 i tory devoted to the,QA Vault needs. This new equipment has
39 i40| reduced the time required to film documents and to develop,il i42 ! process and verify the film.
| 13 Ig4j An automated record index system now permits rapid;
1516 identification of records related in any of a variety of
17 |ta i19|50 j51
-109-,
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1!2 i'3I -
415; Possible ways (e.g., purchase order, inspector, heat number,
6 drawing number). The backlog of data to be put into the
8| computer data base has now been substantially reduced.9i
'0 I There is a single filing system, and' documents are filed.
.1 iL2| with a record " traveler" prepared by Quality Engineers. TheL3 'L4 travelers identify the records required to substantiate each
LS
L6 , activity. The index system records the status of the file,'7 and the location of documents borrowed from the file, and isg
l9 ! used to identify overdue and missing records.20 '21 ! Q. 43 Does the records control system comply.with2213 ' Appendix B to 10 CFR Part 50, applicable Regulatory Guides24 '25 ' and industry standards?
2627 A. 43 Yes. Regulatory documents which define the
23 i29 i requirements of a quality assurance record system are Appendix
30 ~ , Criterion XVII, and ANSI N45.2 Section 18. These documentsB31 .32 ' define requirements for collecting, filing, indexing, storing,3334 ! maintaining and dispositioning of records.35 !
! 36 -'
HL&P STP Site Quality Assurance Procedure PSQP-A4,37 I33 i " Control of Site QA Documentation" and B&R Quality Assurance
,
39 !40 i Procedure ST-QAP-17.1 " Records Control Procedure," adequately
4'
f' address all applicable requirements at the STP construction
43i site. Prior to any submittal of quality records to record
4445 storage facil,ities, both procedures provide for a review by4647 i QA personnel for completeness and adequacy.48 j49 i50 i
51|
'
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5| Specific procedures for control of documents filed as |
6I Iquality records are in place for handling all records in the7 !
a! record vault. These procedures are in compliance with the ;9
1|i
0 applicable regulatory requirements.!
2 Q. 44 Item 9 of the Order (the last item on admin-.3.4 istrative controls) required EL&P to develop and implement.5.6 an improved audit system. What is the purpose of an audit.7 |,g{ system?o'}| A. 44 An audit system is used to determine the adequacy1 '-i of, and compliance with, established procedures, instructions,
3 drawings, and other applicable documents, and the effective-aS ness of implementation.6,7. _ Q. 45 Which organizations perform audits at STP?.3 !.9 | A. 45 The HL&P QA Program requires that planned and0!3i periodic audits be performed to verify compliance with all
I
|3 aspects of the quality program. HL&P performs such audits
d internally as well as audits of Westinghouse Electric Corpo-,
! O i
'7 |i. ration, B&R, and of others as necessary, to determine that6
|;8 -
j the STP QA program ,has been developed, documented and imple-9,
! 0 mented in accordance with established requirements. HL&P1i2; and B&R both have responsibilities for implementing audit
I 3i, ,g ' systems at STP. B&R, as architect-engineer and constructor,
,5provides all guality functions on the project within its
t ,6'' i~
.8 ; scope, including the implementation of an audit system ini
,9 !iO
il
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'i
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3|4!
accordance with 10 CFR 50, Appendix B, Criterion XVIII.5,6i 1
HL&P also audits B&R's performance. The B&R audit respon- '
7;
8| sibility is performed by the B&R home office QA Audit Section.9,
O| HL&P's audit responsibilities are performed by the HL&P1,.2 ; corporate QA organization, which has offices in Houston..3,4 Q. 46 What was the background behind the NRC Ordera .
'
,6 : regarding the audit system?
'7i A. 46 The Investigation Report found that both the,g
9 HL&P and the B&R audit staffs were relying on a review of QA:0|1! records in their audits rather than observing work; there|2 ;
01 were several occasions when audits were conducted at less!4g5 than the required frequency, and neither staff had been
!6g7f conducting supplemental audits of problem areas.
'S| Q. 47 What did the Task Force find ibout the audit{g
program?
I2 A. 47 The TesK Force found that the primary causes of13
34! the deficiencies were lack of sufficient staffing levels on15 |36 j. the audit staffs and inadequate training. The frequency of
37 i33 { audits and the depth of audits had both been curtailed by a
19 !
10 |shortage of qualified auditors. It was also found that HL&P
g},: had not included the requirement for supplemental audits in;
13 ! its audit procedures.14 !15 Q. 48 What are the principal areas in which improvements46 ,17 ! have been made to the HL&P and B&R audit programs?48 i49 !50 j51 ;
!i
-112-
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1 !2,3i4;5| A. 48 The principal changes to the B&R and HL&P audit6'7i programs were:
8i9! (1) In both cases procedures have been changed to
*0|' assure that supplemental audits are performed.-
y;.2 | (2) Both audit staffs have been upgraded through.3 '.4 increased manpower and training..a .
.6 , (3) HL&P audit procedures have been revised to increase
.7,g | audit depth, and both HL&P and B&R procedures were revised
[9 to assure that audits cover all aspects of the QA program.0n'j;, Q. 49 What are supplemental audits and what procedure
'
changes were madt in connection with them?
|5 A. 49 supplemental audits are audits conducted in|6 ;!7 ' addition to regularly scheduled audits. Generally, a supple-!S i!9 ' mental audit is conducted when there is some reason to10 iil ! suspect problems in a given area. Although HL&P did conduct
12 'supplemental audits from time to time, the criteria for
13 ji: conducting supplemental audits were not addressed in the2
16j;7 ,
. audit procedures in effect at the time of the NRC investiga-
;8 ! tion. The procedur,es now explicitly provide for supplemental,9 |:0 l audits. In addition, the changes upgrading both the HL&P1.| ,
2j and B&R audit staffs and the HL&P and B&R audit procedures )3!..; j will result in greater audit staff resources and better
5 '|6 control over ,the scheduling of supplemental audits.7.
8!!
!of
~
Gi |
| 2. | \
; I
1 : 1
!
l -113-
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|
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i
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3i |4' l
5| An important element contributing to improvement in6i7| this area is the improvement in trending and identification ,
8:of the causes of nonconformances which I discussed above.
9
LO | The B&R audit group and Project QA management regularlyL1 :12 ! receive the reports of the trend analysis group, thereby13 !14 enabling them to identify problem areas and establish the15 ' -
16 | need for performing supplemental audits.17 |gg ! HL&P has established its own program to analyze trends
99 ' based en the B&R trending dana as supplemented by HL&P20
21 | collected data. The HL&P Site QA group has established a2223 Quality Systems group that reviews documents which record24 !25 r unsatisfactory conditions and thet monitors B&R trending2627 reports. The HL&P audit group and the EL&P Project QA28 i29 ! management receive both .T&P and B&R trend analyses.
303; Q. 50 What steps have been taken to upgrade the respec-
3 '' : tive audit staffs of HL&P and B&R?33 ,>
34 A. 50 The audit staffs of HL&P and B&R have been3536 j
. upgraded through both increases in manpower and training37 !38 i programs directed at improving the auditing skills of the39 !40| respective staffs. While HL&P and B&R have been recruiting4742 qualified personnel, consulting firms have been employed to
43provide experienced nuclear auditors to augment the audit44
45 staffs.46 '
47 ,
48 lI49
5051 '
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The function of the HL&P corporate audit group has beeng
7|!6 restructured to minimize conflicting assignments and respon-
8 sibilities of auditors. Pre.viously this staff consisted of9|,LO | five and was responsible for document reviews and procedureL1 !L2 j development in addition to its audit responsibilities. Now
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13 '14 the group's primary function is to prepare for and conduct
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{j audits of quality-related activities and the staff has been
f increased to eight. Auditors are continually receiving
19 I additional training in the areas of codes, standards, proce-20 !21 ! dures, and other documents related to QA programs and audit-22 |23 < ing. For example, EL&P has retained an outside consultant24 .23 ' to conduct an inhouse training program for its auditors.
26 | Participants have included Lead Auditors, Auditors and2720 Auditors in Training. When successfully completed, this
30 i program leads to certification as a Lead Auditor in accord-31 '32 | ance with the criteria of ANSI N45.2.23, provided other33 ' ,
34 ! procedural requirements are met.;
I 35 1 -
36 | Q. 51 What changes have been made in audit procedures
37 I3g i of HL&P and B&R?
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3940 | A. 51 The HL&P corporate audit procedure has been
41 revised to require both the review of objective evidence42 '
43 ! (records) and direct observation of work being performed to4445 assure adherence to procedures and compliance with quality
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| 46 |47 ! requirements.
i4849 !SO j51 |
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3I4;5; HL&P has developed an annual audit plan, which is
67 reviewed and rev.ised at least once every six months. In;
0I addition to the annual audit plan, a more detailed audit9
0| schedule is issued quarterly. This schedule provides for1i2! supplemental audits as well as required audits. A matrix3'
! 4 has been prepared delineating all B&R procedures applicable5 -
6, to STP and the corresponding audit (engineering, construction,
| discip line, etc.) to which they apply. This matrix is
9 utilized by the HL&P and B&R audit groups to assure that0
both groups audit all quality activities within the required,
3 frequency.45 Q. 52 Do the audit programs of HL&P and B&R comply67i with Appendix B to 10 CFR Part 50, applicable RegulatorySg Guides and industry standards?i
! A. 52 Yes. The HL&P and B&R Audit Programs meet the2' requirements of 10 CFR 50, Appendix B, Criterion XVIII. All3;4' audits are conducted in accordance with ANSI N45.2.12.5i6:7!
' Auditors are certified in accordance with ANSI N45.2.23,
8 which has been endorsed by Regulatory Guide 1.146.,
9'O| Q. 53 Does the overall Project QA Program, which you
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? have described in your testimony, including both the HL&P)1
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4, and B&R portions of the program, comply with Appendix B to |
3! 10 CFR Part 50, applicable Regulatory Guides and industry,!0
l7! standards? I
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45, A. 53 Yes. As described in my previous testimony, the )6'7| QA program for STP complies with Appendix B, applicable
,f Regulatory Guides and industry standards.
.0 | As an additional assurance that we will continue to
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.2 i remain in compliance with all requirements, HL&P is committed
.3,4 to having an independent audit of the STP QA Program at.5.6 least once every 12 months..7 ,
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