ML20080L060

Affidavit of LO George Re Date Accumulated by Reinspection Program Final Rept.Evaluation Will Clearly Indicate That Quality of Work Performed Is Satisfactory.Certificate of Svc Encl

ML20080L060
Person / Time
Site:	Byron
Issue date:	02/13/1984
From:	George L COMMONWEALTH EDISON CO.
To:
Shared Package
ML20080L026	List: ML20080L019 ML20080L042 ML20080L060
References
ISSUANCES-OL, NUDOCS 8402160231
Download: ML20080L060 (7)

Text

i c, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD  :

In the Matter of )

)

COMMONWEALTH EDISON COMPANY ) Docket Nos. STN 50-454 OL

) STN 50-455 OL (Byron Nuclear Power Station, )

Units 1 & 2) )

AFFIDAVIT OF LOUIS OWEN DEL GEORGE I, Louis Owen Del George, being first duly sworn do hereby depose and state:

1. I am an Assistant Vice-President for Common-wealth Edison Company. I have held that position since November, 1983. My responsibilities include management of the Company's Station Nuclear Engineering, Nuclear Fuel Services and Nuclear Licensing activities. Prior to that time, I held various positions in the Station Nuclear Engineering and Nuclear Licensing Departments. I joined the Company in February,-1974, after resigning from the position of lead design engineer at the Bettis Atomic Power Lab-oratory. I received a Bachelor of Science degree in Engineering Science from the Illinois Institute of Tech-nology (1970). I have a Juris Doctor degree from the Chicago Kent College of Law of the Illinois Institute of Technology (1977). I am also a member of the Bar of the State of Illinois.

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2. In 1982, in my capacity as Director of Nuclear Licensing for the Company, I managed the development of a' program for verifying the effectiveness of Contractor practises for the qualification and certification of QA/QC L

inspectors at'the Byron site, hereafter referred to as the

" Reinspection Program."

3. At the time the Byron hearing record was closed in August, 1983, the conduct of the Reinspection

. Program was still ongoing. Although a great deal of data had been developed from the reinspection of work previously inspected, all reinspections had not been completed, and conclusions relative to the data then available were not fin:1.

4. On October 28, 1983, a preliminary report containing a portion of the data gathered under the Re-inspection _ Program was submitted to the NRC Staff. A subsequent submittal was made on January 12, 1983 in which the data for all Contractors but one (Hatfield Electric Company)~were finalized. This latter document stated that final results for all contractors would be available on February 10, 1984, and that the evaluation of those results would also be completed by that time.

5. The Byron Reinspection Program was completed on February 4, 1984. A report of the final results of that Program, as well as the evaluation of those results and the Company's conclusions drawn from the results is in final

e. preparation and will be available shortly.

6. a. The final report will set forth all of the data accumulated by the Reinspection Program (over 200,000 inspections having been performed). The report will discuss the' reliability of inspectors certified prior to September, 1982, as well as the conclusions to be drawn from the data on the effectiveness of individual Contractors practises for the qualification of QA/QC inspectors. A thorough review of the bsses for and implementation of the Reinspection Program will lx3 provided to validate the integrity of the conclusions drawn from the Program. In addition, an extensive evaluation of the results is provided, from which it can be concluded that former inspectors were qualified, and Contractor practises for qualification and certification of inspectors were effective.

b. The' final report will discuss in detail those limited exceptions where inspector qualification or Contractor effectiveness could not be demonstrated. In this regard, the expension of the reinspection effort in those areas where anomalies were identified-will be addressed.

c. The final report will. discuss in depth the engineering evaluation made of all observed discrepancies

' identified in the Reinspection Program. This evaluation effort'will clearly indicate that the quality of work performed at.the Byron site is good.

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7. It is expected that other corporate officers and_ employees of the Company, and I will be the principal witnesses offered by the company to testify with respect to the Reinspection Program report and, if appropriate, to des-cribe those activities undertaken by the Company's Quality Assurance Department to assure adequate oversight of con-tractors' QA/QC programs. Certain additional witnesses may be_provided to explain detailed aspects of the Program, such as the evaluation of the visual weld discrepancies and, among other subjects, the statistical significance of inferences to

> be drawn relative to inspector qualification and construction quality.

8. In addition, the Company has engaged Mr. John L. Hansel, the' President-Elect of the American Society of Quality Control Engineers, a consultant to the Kemeny Com-mission and a panel member-of the group that is reviewing NRC's approach to nuclear power plant construction and design quality assurance practises. Mr. Hansel, who has over 30 years of QA/QC experience, has been engaged as an independent third party expert to review the Byron Reinspection Program as well as the Contractor practises for qualification and certification'of QA/QC personnel at Byron. Mr. Hansel will

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provide a report of his findings, which will be made available within~30-days.

A Louis Owen Del Georgpf Subscribed and Swo to before me.this / day of February, 1984.

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i nx UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL bOdiB 15 A9 06 CFFth , -

q 7" In thc Matter of ) 00 CME TlhG'A SEP i:

) BRANCH COMMONWEALTH EDISON COMPANY ) Docket Nos. STN 50-454 OL

) STN 50-455 OL (Byron Nuclear Power Station, )

Units 1 and 2) )

CERTIFICATE OF SERVICE The undersigned, one of the attorneys for Common-wealth Edison Company, certities that he filed the original and two copies of the attached "BRIEF OF APPLICANT COMMON-WEALTH EDISON COMPANY" and " APPLICANT'S MOTION IN THE ALTERNATIVE TO REOPEN THE RECORD" with the Secretary of the Nuclear Regulatory Commission and served a copy of the same on each of the persons at the addresses shown on the attached service list, by deposit in the U.S. Mail, first-class postage prepaid, this 13th day of February, 1984. Ex-pedited means of service were used where indicated.

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One of the pttorneyd for Commonwealfh Edison Company ISHAM, LINCOLN & BEALE Three First National Plaza Chicago, Illinois 60602 (312) 558-7500

SERVICE LIST Ivan W. Smith, Chairman *Mr. Richard J. Rawson Administrative Judge Ms. Mitzi A. Young Atomic Safety and Licensing Board Office of the Executive Legal U.S. Nuclear Regulatory Commission Director Washington, D. Ce 20555 U.S. Nuclear Regulatory Commission 7735 Old Georgetown Road Dr. A. Dixon Callihan Room 9604 Administrative Judge Bethesda, Md. 20814 Union Carbide Corporation P. O. Box Y Atomic Safety and Licensing Oak Ridge, Tennessee 37830 Board Panel U. S. Nuclear Regulatory Commission Dr. Richard F. Cole Washington, D. C. 20555 Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Appeal Board Panel Washington, D. C. 20555 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Joseph Gallo, Esq.

Isham, Lincoln & Beale Docketing & Service Section Suite 840 Office of the Secretary 1120 Connecticut Avenue, NW U.S. Nuclear Regulatory Commission Washington, D. C. 20036 washington, D. C. 20555 Region III

• Christine W. Kohl U.S. Nuclear Regulatory Commission Administrative Judge Office of Inspection & Enforcement Atomic Safety and Licensing 799 Roosevelt Road Appeal Board Glen Ellyn, Illir.7is 60137 U.S. Nuclear Regulatory Commission 4350 East-West Highway Ms. Betty Johnson 3rd Floor - Call 432 1663 1907 Stratford Lane Bethesda, Md. 20814 Rockford, Illinois 61107

• Dr. Reginald L. Gotchy Ms. Euane Chavez Administrative Judge SAFE Atomic Safety and Licensing Appeal 326 N. Avon Street Board Rockford, Illinois 61103 U. S. Nuclear Regulatory Commission 4350 East-West Highway Dr. Bruce von Zellen 3rd Floor - Call 492 7663 Department of Biological Sciences Bethesda, Md. 20814 Northern Illinois University DeKalb, Illinois 60115

• Alan S. Rosenthal, Chairman Atomic Safety and Licensing

• • Jane M. Whicher, Esq. Appeal Board BPI U.S. Nuclear Regulatory Commission 109 N. Dearborn St.; Suite 1300 4350 East-West Highway Chicago, Illinois 60602 3rd Floor - Ca.ll 492 7663 Bethesda, Md. 20814 Ms. Patricia Morrison 5568 Thunderidge Drive Rockford, Illinois 61107

• service by Federal Express

• • service by Messenger