ML20054E747

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Affidavit of Wj Shewski Describing Util QA Program.Util History of Compliance W/Applicable QA Criteria Does Not Indicate Util Unwilling or Unable to Operate Plant Safety
ML20054E747
Person / Time
Site: Byron  Constellation icon.png
Issue date: 06/03/1982
From: Shewski W
COMMONWEALTH EDISON CO.
To:
Shared Package
ML20054E730 List:
References
ISSUANCES-OL, NUDOCS 8206140132
Download: ML20054E747 (11)
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Text

9 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD f

In The Matter of )

)

)

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454 OL

) 50-455 OL

)

(Byron Nuclear Power Station, )

Units 1 & 2) )

AFFIDAVIT OF WALTER J. SHEWSKI The attached questions and answers constitute my testimony in the above-captioned proceeding. The testimony is true and accurate to the best of my knowledge, information and belief.

4 H Wayet'J. Shewski Subscribed and syorn to beforp me this A /.. day of %4o , 1982.

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/llx <.a<. e aua Notary Public O

8206140132 820607 PDR ADOCK 05000454 O PDR

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AFFIDAVIT OF WALTER J. SHEWSKI ON DAARE/ SAFE CONTENTION 1 0.1. State your name and present occupation.

A.l. My name is Walter J. Shewski and I am the Corpo-rate Manager of Quality Assurance for Commonwealth Edison Company.

Q.2. Briefly state your educational background and professional qualifications.

A.2. I received a Bachelor of Science Degree in Electri-cal Engineering from Purdue University and a Masters of Business Administration from the University of Chicago.

I am a member of the ASME/ ANSI Nuclear Quality Assurance Committee, the Edison Electrical Institute Quality Assurance Committee and the Atomic Industrial Forum Subcommittee on Inspection and Enforcement. Also, I am a member of the Institute of Electrical and Elec-tronic Engineers, American Society of Quality Control and the Western Society of Engineers.

I have been Manager of Quality Assurance for nine years. My immediately previous assignment was as General Manager of the Project Management Corporation which is managing the Clinch River Breeder Reactor Project.

I have been employed by Commonwealth Edison for approxi-mately thirty-four years in a number of technical and management positions in the areas of engineering, operations, power plant construction, and nuclear design and construction of Dresden Unit 1 Nuclear Power Station.

.- 'S 0 3. What is the purposa of your testimony?

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A.3. DAARE/ SAFE have argued in their Contention 1 that Edison's past record "... demonstrates its inability, unwillingness, or lack of technical qualifications to operate the Byron Station within URC regulations and to protect the public health and safety...." In Contention 1(h) DAARE/ SAFE cites the following as a

" fact" supporting its conclusion.

h. The history at all of Applicant's plants (whether now operating) of its failure (and that of its architect-engineers and contrac-tors) to observe on a continuing and adequate basis the applicable quality control and quality asse:ance criteria and plans adopted pursuant thereto.

The purpose of my testimony is to describe Edison's Quality Assurance Program as it applies to the Byron Station. Quality assurance plays an important role in assuring the safe operation of the Company's nuclear power plants. I also take issue with DAARE/ SAFE's conclusion that Edison's history of compliance with applicable Quality Assurance criteria i..aicate that Edison is either unwilling or not able to operate the l

Byron Station safely.

Q.4. Have there been instLnces in which the Company's operating personnel, architects-engineers or contractor personnel have failed to adhere to applicable Quality Co" trol and Quality Assurance criteria?

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.A.4. There have been deficiencies identified through

'() audits performed by contractors, Commonwealth Edison Company and the NRC. When deficiencies are identified, however, timely _ corrective action is required and steps

! are taken to prevent recurrence of the deficiencies.

Construction activities are subjected to a multi-layer series-of inspections, surveillances and audits by the contractors with an overlay of inspections, surveil-lances and audits by Commonwealth Edison Company at the construction site.

At the operating stations the operating functions are performed in accordance with written procedures and are verified by supervisors. In addition, surveillances and audits are performed by Commonwealth Edison Company Quality Assurance personnel to assure operating agtivities are performed in accordance with requirements. Similarly, maintenance and modification activities at the plants are subjected to independent inspections by Quality Control with Quality Assurance also performing independent inspections plus surveillances and audits to assure requirements are met. Surveillances and audits of all plant activities are performed to preplanned and approved schedules. Due to the thorough scrutiny given to all of the activities of the Company, it is not in any way l extraordinary that some deficiencies are identified for correction.

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_4-() 0.5. Please describe Edison's Quality Assurance Program as it applies to operation of the Byron Station.

A.S. Quality Assurance is one of the administrative controls employed to assure that activities important to safety are performed in the appropriate manner.

Edison is responsible for the assurance of quality in all phases of plant operations. The Quality Assurance group located at the Byron Station will be primarily involved in inspections, surveillances and audits of all safety-related work and activities performed by operating plant personnel, contractors and other Commonwealth Edison personnel. Audits will be planned using agenda and checklists approved, as applicable, by the Quality Assurance Supervisor or Director of Quality Assurance (Operating). A report will be written for each surveillance and audit and distributed to respon-sible management. The Quality Assurance group will also be responsible for verifying that appropriate corrective action is taken to remedy any deficiencies identified by qualified Quality Assurance auditors.

The Quality Assurance personnel assigned to spec-ific quality activities such as nondestructive exam-ination, auditing or inspection are provided training in the skills required for their work. Generally, this training is an extension of the formal education and work experience of the Quality Assurance personnel.

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< At least one of the Quality Assurance people performing O surveillances and audits of operating activities will be a licensed reactor operator or have been a licensed operator.

Commonwealth Edison has the responsibility for control of purchased material, equipment and services including that supplied by the NSSS vendor. The control of the quality of purchased material, equipment and services is achieved through the evaluation of vendors, through surveillance of their operations, and through appropriate inspections. In-coming material t'

and equipment will be inspected by Edison, or its agents, to assure physical integrity and compliance with procurement document requirements. For ASME Code and safety-related items which are not inspected at the vendor's plant, specific receipt inspection measures, such as material and dimension checks against approved I

drawings and specifications will be performed to verify conformance to procurement requirements. Final inspec-tions will be performed according to written procedures or checklists approved by Quality Assurance.

The Company Station Quality Assurance organization functions independent of the Edison Station Operating Department. It is directed by the Station Quality Assurar.ce Supervisor who reports off-site to a Quality Assurance Supervisor for maintenance, and to the O

Director of Quality Assurance for operating activities.

() They in turn report to me and I report to the Vice Chairman of the Company. Conditions adverse to quality found by quality personnel which require prompt action or corrective action which cannot : . resolved at the station will be promptly reported to me or my desig-nated alternate for action. I direct the quality assurance activities for the operation, maintenance, design and modification activities of the Company's nuclear power stations and have the responsibility and the' authority to stop unsatisfactory work or plant operation and to stop further processing of unsatis-factory material during design, construction or oper-ation of the plant.

Q.6. Does the Quality Assurance Program applicable to the Byron Station meet all of the requirements of Appendix B to 10 CFR Part 50?

A.6. Yes. The Quality Assurance Program for the operation, design, procurement, maintenance, plant modification and in-service inspection of safety-related systems, structures and components of the Byron l

Station is the same Quality Assurance Program with implementing procedures which is applicable to all our nuclear power plant projects and operating stations.

This Quality Assurance Program meets the requirements i

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of each of the 18 Criteria of Appendix B to 10 CFR Part

/~T 50, as well as the requirements of Section III of the V

ASME Boiler and Pressure Vessel Code, ANSI Standard N45.2, and applicable NRC Regulatory Guides. The Company Quality Assurance Program is augmented by Quality Assurance Procedures and other procedures covering NRC Criteria and Regulatory Guides, the ASME Code and other applicable codes and standards.

Q.7. Do you believe that the Company's Quality Assur-ance Program will be satisfactorily implemented at the Byron Station during operations?

A.7. Yes. In my opinion, Edison's Quality Assurance Program as implemented is one of the best Quality Assurance programs in the nuclear industry. The

( operating nuclear stations and construction sites, including Byron construction and pre-stdrtup operation activities, have been audited many times by personnel from the Nuclear Regulatory

  • Commission's Region III.

The Program has also been carefully reviewed by Nuclear Regulatory Commission Headquarters Staff, as well as by the Illinois Office of the State Fire Marshall, Divi-sion of Boiler and Pressure Vessel Safety. No signif-icant deficiencies in our Program or its implementation have been identified during these reviews.

Our Quality Assurance Program has been evaluated fourteen times over the past seven years by ASME Survey 1

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, Teams. The Survey Teams have included representatives of the NRC and the Illinois State Boiler Board. We have passed all the surveys and ASME has issued Edison NA and NPT Certificates of Authorization for Zion, Dreden, Quad Cities and LaSalle County Stations and N, NA and NPT Certificates of Authorization to the cor-porate organization of the Company. These Certificates are an accreditation of Commonwealth Edison as having had the adequacy of their Quality Assurance Program verified for engineering (N), fabrication (NPT) and installation of ASME Code-covered items and work at our nuclear stations. The Byron operating station organ-ization will also undergo an ASME Survey in mid-1982.

In view of the Company's exemplary record in l

implementing its Quality Assurance Program, a record w ich has been repeatedly verified by independent

( reviewers, I have every reason for confidence that the

,0,uality Assurance Program will be satisfactorily imple-mented at Byron during station operation.

Q.8. Earlier you mentioned that deficiencies in adher-ence to Quality Assurance criteria by contractors and Edison Personnel have been identified by both Edison and the NRC. Is that fact consistent with your confi-dence that the Quality Assurance Program will be satisfactorily implemented at Byron Station during operation?

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A.8. Yes, it is. The mere existence of incidents of 1

kJ non-compliance with Quality Assurance criteria does not in itself indicate a lack of dedication to safety, or a lack of capability to achieve safe operations. A sufficiently thorough Quality Assurance program of inspection and audits can always be expected to i-dentify some deficiencies. In fact, a program that does not identify deficiencies would be suspect.

It is important to evaluate the significance of the individual deficiencies, the appropriateness of the corrective action taken, and the overall trend in performance. On these measures, Edison's past per-formance has certainly been adequate to assure safe operations and the trend has been one of continuing improvement.

Edison's overall adherence to quality is under-going a continuing improvement over time. This can be seen by the continuing reduction in the number of deficiencies identified by the NRC in their inspections of Edison's operating stations over the past five years. Even though our performance has improved with respect to deficiencies identified by the NRC, we have raised our internal standards in our quality assurance audits. The Company's Quality Assurance department has i

! increased the frequency and intensity of its own audits t

and I feel the downward trend is the result of our O

intensified surveillance and audit activities. These results show that Commonwealth Edison is dedicated to a comprehensive program of assuring that all require-ments are met and of ensuring the safe operation of its stations.

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