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NUCLEAR REGULATORY COMMISSIONyet \\ h9 03

BEFORE THE ATOMIC SAFETY ANd3, LICENSING BOARD

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In the Matter of- )TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 andCOMPANY, ~et al. ) 50-446

)(Comanche Peak Steam Electric ) (Application forStation, Units 1 and 2) ) Operating Licenses)

AFFIDAVIT OF DAVID N. CHAPMANREGARDING THE QA/OC ORGANIZATION

AT COMANCHE PEAK

I, David N. Chapman, being first duly sworn, do depose

and state: I am employed by Texas Utilities Generating

Company in the position of Manager, Quality Assurance. As ,

such, I am familiar with the Quality Assurance /Ouality

Control Organization (OA/QC) for the construction of the

Comanche Peak Steam Electric Station. The purpose of this

affidavit is to demonstrate that an effective OA/OC Organiza-

tion has been maintained at Comanche Peak during the cons-

truction phase. Further, this' affidavit will demonstrate,

that Texas Utilities Generating Company has taken all

measures necessary during construction to assure that

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|the OA/QC Organization remains effective and meets the

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applicable NRC Regulations. A statement of my educational'

and professional qualifications was received into evidence

at the hearings in December 1981 (Tr. at 509) and is

attached hereto as Attachment 1 for the convenience of the

Board.

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8205.20161 820510PDR -DOCK 05000445

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I. HISTORY OF OA/OC AT COMANCHE PEAK

From the beginning of the Comanche Peak project, Texas

Utilities Generating Company ("TUGCO"), as the lead Applicant,

has maintained ultimate responsibility for the construction

OA program at Comanche Peak. In this position, TUGCO carefully

monitors and/or conducts all aspects of the OA program to assure

that construction of the facility is performed in conjunction

with an effective OA/OC program.

Initially, Brown & Root, Inc., the Construction Manager /

Constructor, managed the OA/OC program applicable to work per-

formed by them and their contractors for the early stages of the .

project. Brown & Root met its responsibilities in this role. As

the project progressed and became more complex, TUGCO determined

that a more aggressive program was essential to meet TUGCO'si

OA/OC goals for the project. One area where more aggressive

action was needed was Brown & Root's implementation of its OA

program with respect to its suppliers. In July 1977, TUGCO

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initiated action requiring TUGCO involvement in all Brown & Roott

| vendor release inspections. Subsequently, upon assessing theI

success of such direct involvement by TUGCO, it was determined'

that TUGCO would provide overall technical management of OA/OCj

functions for CPSES except for those activities under thei

jurisdiction of the ASME Boiler and Pressure Vessel Code,

Section III, Division 1 (ASME Code). Although Brown & Root

i retained functional managment of ASME Code work under their

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- OA program, TUGCO continued to have the ultimate responsi-

bility for all such work.

The measures taken to restructure the QA organization

at Comanche Peak brought about significant improvement in

the quality function for the project. A positive relation-

ship has developed among OA, QC, and construction personnel

resulting in a teamwork approach that focuses attention on

identifying and solving problems. In sum, the measures

have resulted in a OA/QC Organization tailored specifically

for and responsive to the needs of the Comanche Peak project.

In addition to TUGCO and Brown & Root, Gibbs & Hill,.

as Architect-Engineer, and Westinghouse Electric Corporation

( "We s tinghou s e " )', as nuclear steam supply system ("NSSS")i

supplier, provide OA programs for activities within the

# scope of their responsibilities. Their basic roles have

remained constant throughout the life of the plant and are

described more fully below.

II. CURRENT QA/QC ORGANIZATIONAT COMANCHE PEAK

|A. Principal Organizations

,As discussed above, TUGCO, as the lead Applicant, has

ultimate responsibility for the engineering, design, procure-

ment, construction, and quality assurance activities for

Comanche Peak. TUSI 1/ is designated by TUGCO to have the

1/ Te'xas Utilities Services, Inc..("TUSI") is the engineeringservice organization for Texas Utilities Company.

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authority to conduct the required engineering, design,

procurement, and construction technical support activitiesfor CPSES, including implementation of the QA program at

the site.

Gibbs & Hill provides TUSI with certain engineering,

design, and procurement services as requested. Gibbs &~

Hill provides the OA program for QA activities within its

scope of work. Westinghouse provides the QA program

governing work done on the NSSS structures, systems and

components. As discussed above, Brown & Root manages the OA

program for ASME Code work and may perform other QA functions ,

as requested by the TUGCO Quality Assurance Manager.

An organization chart for the project QA organization is

presented as Attachment 2.

B. Responsibilities of OA Organization

1. TUGCO/TUSI

The TUGCO QA organization was established to provide

effective control of safety-related activities at Comanche

Peak. This control extends to all organizations performing

services affecting nuclear safety during the engineering,

design, procurement, and construction. phases. The TUGCO/TUSI

QA organizations participating in the design and construction

phase of nuclear power plants are shown in Attachment 3.

This chart illustrates the organizational structure and lines

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of reporting for each organization. These are described in the

corresponding sections.

a. TUGCO Quality Assurance Division

The TUGCO QA Division is responsible for developing

and assuring the implementation of the CPSES QA program

for design and construction. The QA Division is headed by

the Manager, Quality Assurance. He reports directly to the

Vice President, Nuclear. This independent reporting arrange-

ment assures that safety considerations are not influenced

by cost and scheduling. He reviews the performance of the

QA program on a regular basis with the Vice President,.

Nuclear, reporting on quality status and the overall

ef fectiveness of the QA program.

In addition, the Manager, Quality Assurance has the

# duty and authority to identify quality-related problems;

to initiate, recommend or provide solutions; and to verify

the implementation and effectiveness of solutions. He has

authority to "stop work" in the engineering, design,

procurement, and construction phases. He also supervises

the Site QA Supervisor at Comanche Peak who is responsible

for assuring the implementation of the QA program on a

daily basis at the site. The QA Manager has the following

qualifications:

(1) Minimum of 10 years experience in design,construction, or operations of power plants.

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(2) College degree in an engineering discipline(BS minimum).

(3) Demonstrated ability to manage people andprojects.

(4) Knowledge of quality assurance requirementsfor nuclear plants including a minimum ofone year experience in the implementation ofa nuclear quality assurance program.

(5) Registered Professional Engineer.

'b. TUSI Project Management

For the Comanche Peak project, the Vice President and

Project General Manager (TUSI) coordinates and controls

engineering, procurement, and constructica activities. He

is responsible for cost and schedule and for implementing -

design and construction quality requirements. The Vice

President and Project General Manager reports to the

Executive Vice President of TUSI.f

,Reporting to the Vice President and Project General

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Manager is the Engineering and Construction Manager who is

responsible for project design, engineering and procurement.

These activities are normally delegated to Gibbs & Hill, Inc.,

Westinghouse and other contractors / vendors. TUSI, however,

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| retains overall responsibility for these activities and

performs design functions as necessary.

2. Gibbs & Hill

TUGCO has retained Gibbs & Hill to provide

experienced personnel as needed to assist TUGCO OA with

the overall OA program. The Gibbs & Hill Project Manager!

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directs the engineering, design, and procurement functions

and establishes and maintains project relations with TUSI.

The Project Manager is responsible for assuring that esta-

blished procedures are implemented. The Project Manager has

the authority to "stop work" on engineering and design

activities performed by Gibbs & Hill.

The Gibbs & Hill OA Department, headed by the OA

Manager, assures the implementation of the Gibbs & Hill

OA program through engineering and design audits. Further,

the OA Manager is responsible for development of detailed -

QA procedures. He can require the Project Manager to

exercise his "stop work" authority. Further, the OA

Manager audits the activities of independent Design Review!

engineers who determine compliance with safety-related

design concepts. The OA Department is completely separate

and functions independently from those persons or groups

having specific project design, scheduling, or budgetary

responsibilities. Independence is maintained further

by having the OA Manager report to the Vice President.

Attachment 4 is a chart of the Gibbs & Hill OA Organization.

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3. Brown & Root

Brown & Roo't provides the OA program for ASME Code

construction and other QA functions as may be requested by

the TUGCO OA Manager. Brown & Root's OA personnel have the

freedom to identify quality problems, to recommend solutions,

and to verify that solutions have been implemented. This

organization has sufficient independence and authority to

carry out the program in an orderly, effective manner. It

employs a documentation system which provides necessary

record retention and access capability. The Brown & Root OA

organization for its Houston office and for site activities *

is shown in Attachment 5.

The Brown & Root Project OA Manager is responsible for

implementation of the B&R OA Manual requirements in the

fabrication and installation of ASME Code, Section III,

Division 1 systems and components. Direction of all site!

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| OA and OC activities other than ASME Code work is provided!

by the TUGCO Site OA Supervisor. For technical and adminis-

i trative supervision of ASME' Code work and for administrativei

supervision in all other areas, the Brown & Root Project

! OA Manager reports to the Brown & Root QA Manager in Houston.l

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C. Organizational Interfaces

For Comanche Peak, TUGCO/TUSI has established the

interfaces of the participating organizations in the OA

program which are summarized as follows:

1. Brown & Root Project GA Manager reports tothe Brown & Root OA Manager for technicaland administrative supervision of ASME Codework, and for administrative supervision inall other areas. Direction of the Brown &Root Project OA Manager in areas other thanASME Code work is provided by the TUGCO SiteOA Supervisor.

2. Construction site inspections are performedunder the direction of TUGCO and Brown &Root (ASME Code work only) or by contractor

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or subcontractor.

3. Periodic audits and surveillances of siteOc and construction activities are performedby TUGCO to verify conformance.

4. Vendors are required to provide internal,j

independent OA programs unless workingunder the TUGCO OA program.

5. TUGCO OA and/or its consultants or agentsconduct vendor audits, surveillance andinspections to verify performance.

6. Westinghouse provides the OA program forNSSS components.

7. Gibbs & Hill provides the OA program fordesign and engineering.

8. TUGCO OA periodically audits Westinghouse,Gibbs & Hill, Brown & Root and internalTUGCO/TUSI safety-related activities.

9. Brown & Root periodically audits their ASMEOA program onsite, as required.

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In summary, the OA/QC organization established for the

construction of th'e Comanche Peak facility has been care-

fully structured and functions to provide assurance that

applicable codes, statidards, and regulatory requirements

are met and to assure the safe operation of the facility.

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D A f| 'Q' DavicVS.' Chapinan 1

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Subscribed to and sworn before me this 7 day of May 1982. .:-

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Notary Public, ' ''

GLENDA BENSON, N:tary Public# -E -,,

in and for Da!!as Cou ty, xasg- =

, My Commission Spir" _-

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ATTACEMENT 1

DAVID N. CHAPMAN

STATEMENT OF EDUCATIONALAND PROFESSIONAL QUALIFICATIONS

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POSITION: Manager, Quality Assurance

FORMAL EDUCATION: 1959-1964, B.S.M.E. Mechanical Engineering,Texas A&M University

EXPERIENCE:

1976 - Present Texas Utilities Generating Company, Dallas,Texas, Manager, Quality Assurance. Responsiblefor assuring effective implementation of theCPSES Quality Assurance Program in nuclearsafety-related activities including design,procurement, construction and operations.

1972 - 1976 Texas Utilities Service Incorporated, Dallas,Texas, Project Engineer. Duties included re- *

viewing selected CPSES design documents, PSARdrafts and environmental report drafts. Addi-tional duties included such special projectsas site evaluation studies for future genera-ting plants.

! 1967 - 1972 Texas Electric Service Company, Forth Worth,Texas, Senior Engineer, General Office En-gineering Department. Activities includedreview of design and construction specifi-cations, drawings, and purchase documents forfour gas / oil fired generating units.

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| 1966 - 1967 Texas Electric Service Company, Forth Worth,! Texas, Associate Engineer, Handey Steam

Electric Station. Involved primarily intraining through " hands-on" operation, main-,

| tenance, and plant chemistry duties.l,

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FINAL SAFETY ANALYSIS REPORT Q,

UNITS 1 and 2 92:>-3

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FIGURE 17.1-2(1) IN HOUSTON APRIL 23, 1982

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