ML20127M294
| ML20127M294 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 06/21/1985 |
| From: | Ramsey W SOUTHERN COMPANY SERVICES, INC. |
| To: | |
| Shared Package | |
| ML20127M179 | List: |
| References | |
| OL, NUDOCS 8507010178 | |
| Download: ML20127M294 (24) | |
Text
-
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
.In the Matter of
~
GEORGIA POWER COMPANY, et al.:
DOCKET NUMBERS 50-424 and 50-425 (Vogtle. Electric Generating Plant, Units 1 and 2)
AFFIDAVIT OF W.
C.
RAMSEY COUNTY-OF BURKE STATE OF GEORGIA-Before the undersigned officer duly authorized to administer oaths did appear W.
C.
Ramsey, who after being duly sworn, did state as follows:
1.
My name is W.
C.
Ramsey.
My business address is Vogtle Electric Generating Plant, Route 2, Waynes-boro, Georgia 30830.
I am employed by Southern Company Services as Manager-Nuclear Plant Projects Licensing, Nuclear Safety and Fuel.
I am assigned to the Vogtle Project as Readiness Review Program Manager.
In that position, my p'rimary responsibility has been the overall scope, direction, and schedule of the VEGP pilot Readiness Review Program.
I am a mechanical engineer and I have been involved in a nuclear power plant design for the past fourteen years.
I am a member of ASME.
8507010178 850624
{DR ADOCK 05000424 PDR
E l
~2.-
I make this Affidavit in support of Applicants' Motion for Summary Disposition of Joint Intervenors' Con-
'tention No. 8 (Quality Assurance).
I have personal
' knowledge'of the matters stated herein and I believe them tofbe true and correct.
I will describe the organiza-tional structure and the purpose.and program of the VEGP pilot Readiness. Review program.
READINESS REVIEW Overview 3.
Georgia' power Company has long been concerned about the inability of a' number of utilities to satis-factorily complete nuclear plants under construction on time, within budget,=and in compliance with Nuclear
~
Regulatory Commission requirements.
A number of these problems appear'to.have been the result of major quality-related breakdowns in the management of plant con-
.'struction or the utilities' inability to demonstrate the requisite quality.
In.a report to Congress on Improving Quality and the Assurance of Quality in the' Design and Construction of Nuclear Power Plants (NUREG-1055), the Nuclear Regulatory Commission addressed these issues.
In response to the question, "Why have the Nuclear Regulatory Commission and the utilities failed or been slow to detect and/or respond to these quality-related problems?, the Nuclear Regulatory Commission defined a number of short-comings'and' recommended actions.
One ot the acticas recommended for further analysis was the feasibility, and
.~
-.. _.~
' benefits,'of readiness reviews which would involve formal assessments.by'the utility of their readiness to proceed at~ critical phases of a Project'and would include possible-involvement of Nuclear Regulatory Commission staff.
4.
In order to gain.added assurance of the opera-tional readiness of the Vogtle Electric Generating Plant (VEGP), Georgia-Power Company is conducting a pilot
'Readi' ness Review Program.
This program does not eliminate or diminish.any authorities or regulatoty responsibilities now assigned to or. exercised by the Nuclear Regulatory Commission or Georgia Power Company.
Further, the pilot Readiness Review Program.does not fundamentally change the techniques of inspections or assurance of quality program activities.
Rather, the program is a management system which provides for the more orderly. planning and pre-dictable execution of existing authorities and.respon-
-sibilities.
5.
In summary, the Readiness Review Program actions include-a clear definition and description of.all work activities in terms of governing regulatory commitments, an1in-depth Georgia Power Company self-assessment of the.
work activities, Nuclear Regulatory Commission review and actions on:both the programmatic and work implementation aspects of the work activities and a methodology for scheduling the separate Readiness Review Program actions of Georgia Power Company and the Nuclear Regulatory Commissi'n.
o '
6.
This program incorporates several important features such as a Readiness Review Board, outside tech-nical experts in the various disciplines, and a separate design review group all of which serve to provide independent oversight and review of Readiness Review Program actions and results.
7.
Georgia Power Company considers that the Readi-ness Review Program, including the Nuclear Regulatory Commission's agreement to participate, will result in significant benefits.
These benefits include improved planning which will enhance the effective use of critical Nuclear Regulatory Commission and Georgia Power Company resources and improved predictability resulting from the early Nuclear Regulatory Commission determination of program adequacy.
Other benefits include enhanced assurance of the overall program acceptability resulting from Georgia Power Company's self-assessment combined with the phased independent Nuclear Regulatory Commission reviews, and improved stability by minimizing the po-tential for last minute identification'of major programmatic problems.
The Readiness Review Program Plan 8.
The purpose of the VEGP pilot Readiness Review Program is to provide a systematic and disciplined review of Georgia Power Company's implementation of design, con-struction and operational preparation processes to
_4_
L
increase the assurance that quality program activities at Plant Vogtle have been accomplished in accordance with regulatory requirements.
9.
The Readiness Review Program will be conducted on a' schedule to provide added operational readiness as-surance to GPC management-in support of the VEGP Unit 1 operating license.
However, conclusions reached regarding programmatic and technical adequacy through review of VEGP Unit l will be indicative of Unit 2 since both units are being designed and constructed, together under a single o
Quality Assurance program and like management and to the same specifications and criteria.
10.
The Readiness Review Program is a management system developed to accomplish the following objectives:
(a)
Define the individual work processes involved in the quality program at Plant Vogtle and describe how.these processes comply with regulatory commitments; (b)
Provide a phased in-depth self-assessment of safety-related work processes and a separate management overview of the self-assessment process, including an expert evaluation of both-the Readiness Review assessment and its conclusions; (c)
Enhance the identification of problems or concerns and ensure their correction in a timely manner;-
(d)
Provide a mechanism for the early resolution of any differences in the Nuclear Regulatory Com-mission and Georgia power Company interpretation of regulatory-requirements and the resulting acceptance criteria; (e)
Provide a system that will facilitate the Nucleat Regulatory Commission's review, inspection, k
appropriatelaction-and approval of.the accept-ability of Plant Vogtle work processes'on an advanced Readiness Review ~ basis; (f)
Provide a planning system, including Georgia Power! Company prepared and Nuclear Regulatory Commission accepted milestone schedules, for the orderly conduct of.the separate actions of Georgia Power. Company and Nuclear Regulatory Commission.
11.
The VEGP Review Program is not intended to eliminate or diminish any authorities or regulatory responsibilities now assigned to or exercised by the Nuclear Regulatory Commission or Georgia Power Company.
Further, the Readiness Review Program is not intended to change the techniques of inspections or assurance of
' quality program activities.
Rather, the VEGP Readiness Review Program is an added program initiated by-GPC management to assess the VEGP, and provide additional
- feedback to management'so that.they may' initiate any needed corrective actions in an orderly and timely manner.
1:2.
The scope of the Readiness Review. Program encompasses the review of safety-related aspects of design, construction and preparations for operation at Plant Vogtle.
The overall scope of the program is divided
- into five' bro ~ad generic functions:
civil, mechanical, electrical, and operational readiness for Plant operations.
These generic. functions are further divided
' into. specific work activities, for example:
Civil i
concrete,.rebar and caldwelds; structural steel;
. miscellaneous steel and embeds, welding, and backfill..
~a
- wea,
<-r
~ ~ - -
n,--:
<w-
,-ww,,,---
v
.From there'the division is divided into individual work-elements.
13.
The Readiness-Review program actions are being conducted at the work element level to review, assess and verify performance.
The individual work elements in one j
1
~or;more' work activities will be packaged and presented to the Nuclear Regulatory Commission for review and accep-tance one package at a time, in general accordance with an established schedule.
Such a package is defined as a Readiness Review " Module."
The total scope of work will be divided into approximately 20 Readiness Review Modules.
14.
Each Module will provide a brief description of the method of complying with project licensing commit-ments,- pertaining to the' Module scope, found in the Final
. Safety Analysis Report (FSAR).
It is not intended to make further commitments or revise in any way prior commitments.
15.
Activities common to several Modules will be provided as General Appendixes.
There will be approx-imately eleven (11) appendixes.
These appendixes, as appropriate, will be referenced in the Modules and augmented in each Module with' module-scope-specific details as needed.
16.
Having so defined and described each work element or logical group of_ elements, GpC will formally assess the elements to determine that the quality program and its implementation have complied-with Georgia power Company m-commitments and Nuclear Regulatory Commission regulatory requirements.
Additional reviews, inspections or audits will beEconducted, wherever necessary, to verify proper
. accomplishment of.the work elements.
Each-Module will be signed off by an individual responsible for the assessment certifying that-the work elements have been addressed properly and are ready ~for Nuclear Regulatory Commission review.
17.
In additional to the self-assessment of Module work. elements discussed above, Georgia Power Company will establish a Design Review Group within the Readiness Review Task Force consisting of three or more experienced senior design engineers who are independent of those personnel who performed the work.
The function of this group will be to conduct a point-in-time review of the design p'rocess to provide a higher level of assurance that the design activities defined and described in the Readiness Review Module'have been performed in accordance with all commitments.
A'particular focus of this group will-be-to. examine the interface actions among design disciplines to insure that there are no discontinues in Ldesign work covered by the various Readiness Review
-Modules.
' 1,8.
When all work elements in'the Readiness Review
. Module have been assessed and certified as properly imple-mented,-an independent Geotgia power Company Readiness 5
.a_
Review. Board will. conduct an evaluation of the Readiness Review Module to verify that the overall work activities have been addressed satisfactorily and that all Readiness Review Program actions have been completed properly.
19.
Upon satisfactory completion of the Readiness
' Review Board evaluation, the Vice President and Project General Manager of the Vogtle Project will make a final determination of acceptability of the Readiness Review Module.
20.
Upon determining that the Readiness Review Module is: satisfactory, the Vice President and Project General
?.
h Manager of the Vogtle Project will formally _ submit the i
Readiness Review Module to the Regional Administratoroof the Nuclear Regulatory Commission for review and accep-tance.
The presentation process will include a brief meeting to outline the scope of the Readiness Review Module and' identify any particular aspects that. Georgia Power Company may want to highlight to the Nuclear Regu-latory Commission.
It is expected that the Readiness I
Review Module would thereafter undergo a multidiscipline f
review by applicable Nuclear Regulatory Commission or-
.ganizations to verify the effectiveness of the Georgia
-Power. Company quality program for work areas covered in the Module.
It is expected that this review will examine definition of' commitments, adequacy of commitment applic-a' tion and proper' interpretation of criteria for work
_9_
acceptance.
Further, it is expected that either a positive finding of program adequacy will be identified to Georgia Power Company, or any concerns with the program defined.in the Readiness Review Module will be conveyed for action, as appropriate.
21.
Upon completion of Nuclear Regulatory Commission review of the Readiness Review Module, it is expected that the Nuclear Regulatory Commission will identify selected work activities covered by the Readiness Review Module for additional Nuclear Regulatory Commission inspection.
For these instances, Georgia Power Company will take all necessary actions to support and' assist the Nuclear Regulatory Commission inspection, including the collection and assembly of documentation, having-requested personnel' readily available for interviews or inspection assistance, and the resolution of all questions or requests for additional information.
Georgia Power Company will make every effort to address all inspectors' requests and questions during the Nuclear Regulatory Commission on-site inspection process.
22.
Upon completion of additional Nuclear Regulatory Commission inspections of the Readiness Review Module work acti'vities, it is expected that the Nuclear Regulatory Commission will identify any-significant areas of non-compliance in accordance with existing Nuclear Regulatory Commission inspection and enforcement policies (e.g.
==
at W.
p d*
- 10.C.F.R., Appendix C). (Georgia power Company will L
?:
. invest'igate,-' assess and correct any items so identified in 9
Jy /
,e fa thorough and rigo'roudly scheduled manner in order <to
+promptiyrand cortpletely -resolve all concerns and to avoid
.\\,
ara v
',' -any recurring questions or concerns in subsequently scheduled' areas of' readiness.
23.
Upon; satisfactory completion of Nuclear Regula-ory Commissio'n. inspections of Readiness Review Module jwork activities, including satisfactory resolution of any t'.
resulting concerns, iti is expected that the, Nuclear
.s
[
)Regulato y, Commission will formally identify to Georgia f ;powe'r Company that the scope of work covered by the Readi-C
. p. 2,pness Review Module hd[k been reviewed programmatically for
. implementation,'and was deemed satisfactory subject to completion of'remai'ning work in full compliance with all commitments.
It s further expected that.any work covered
, r.
.by'the scope'of the Readiness Review Module that had not
.I.
r
..yet been completed duo,to the project work sequence will t
i
~(~
be factored into normal Nuclear-Regulatory Commission site N'
inspectionactivitit$swith'theGeorgiapowerCcmpany-n.
A commitment to assist the Nuc^1 ear Regulatory Commi'ssion in subsequent inspections'in~the same manner as during the Readiness Review-Module i nspect! ion activities.
The Nuclear Regulatory Commission will be formally notified of any subsequent significant changes to'the quality program
- l, that would affect the conclusions reached in the completed Module.
b jlf; 8 vg
_ty.
. h ' '. /
c.. /w 1,., ; -
l' '
' Relevant Readiness Review Modules 24.
The Readiness Review Program _will involve all aspects-of VEGP-design and construction.
The particular Modules which have relevance to the scope of this proceeding are:
Module 1:
Concrete, Rebar and Caldwelds.
Module 4:
Mechanical Equipment, Piping and Components.
Module 8:
Structural Steel.
' Appendix A:
Organization.
Appendix C:
Procurement.
. Appendix E:
Material Control.
Appendix H:
Nonconformances.
Appendix-I:
Project QA Organization.
25.
Of these Modules, Module 1 and Appendix I have been completed.
The remaining relevant Modules are due to be finalized and submitted to the NRC throughout this summer.
A review of-the scope of the completed Modules
~
will provide some indication of the detail of the review for all of these Modules.
The Concrete Module 26.
The intent of Module 1 was to verify that Category.1 reinforced-concrete structures complied with the Final' Safety Analysis Report (FSAR) commitments and that compliance is verifiable with existing Project
-documentation._
-l'-
g7
.s -
e
.1
- 27. :The verification program was'a multistage process n;!
Lbeginning:with a. description of work ~ processes for o
-engin'eering,: procurement,-and--construction that translate-
'FSAR. commitments to the implementing documents such as A7 drawings, calculations, specifications, work procedures, and process procedures.
Readiness Review Task Force groupsIthen review the-project records to. verify the existence'of documents that demonstrate compliance with procedures and' implementation of commitments.
This review was supplemented by a walk-down on reinforced concrete 3
s'tructures.
28.
.The method of identifying samples of docu-mentation to.be reviewed was designed to provide coverage over7the< current life of activities under review.
The 5
samples selected for each activity under review were established to. provide confidence that-the,FSAR commit-2 ments.were properly implemented in. documents under-review.
Five types of reviews were conducted:
(a) programmatic review of the design engineering process to verify that FSAR commitments were properly implemented into engineering documents; I'
~(b).
Technical. review of design documents to verify thatiproper design requirements-were considered 6
and.that-those documents correctly implemented
-the licensing commitments;
- (c) programmatic review of construction to verify that-constructionscomplied with design and
$4, procedural requirements as described in
]
. engineering documents; (d)
A review of construction records to verify that
- the'end products, used in the construction process, comply with FSAR commitments;
~.
s
(e)
A selection review of concrete structures for visual evidence that construction correctly interpreted design documents, that good workmanship practices were observed, and that the as-built condition of the Plant complies with FSAR. commitments.
29.
.The review' team members included specialists from Georgia Power-Company, Southern Company Services, Bechtel Power Corporation, Teledyne Engineering Services and Stone and Webster Engineering Corporation.
Stone and Webster conducted an independent design review and participated in.
the selective visual review of concrete structures.
30.
In addition to the reviews described above, past audits.and soecial investigations were described and result findings were evaluated for their individual and
-collective significance with regard to the quality of.
concrete structures.
These investigations included GPC audit findings, NRC inspections, INPO evaluations,.and self-initiated' evaluations.
31.
Verification reviews were structured to disclose discrepancies in the implementation of licensing commit-ments.
When this occurred, discrepancies were identified on'the. discrepancy' report which initiated corrective action by the Project organization.
Discrepancies were given a finding number by the Readiness Raview Task Force
-that was used as a control to assure that corrective I
action was completed.
The_ findings were evaluated for t
i individual and collective significance with respect to the Lacceptabilityfof reinforced concrete structures. 3
,--g-
i 32.
Those evaluations resulted in the identification of five. areas where the findings were considered to have-
- potential. significance.,Three areas:
inspector certi-fication, missing post-placement reports, and jet impinge-ment _' dynamic load factors were technical.
The.other two,
-Deviation Reports with wrong approval signatures and missing Quality Control documents, were programmatic.
33.
In-depth evaluations by the Project of the areas of. potential significance led to the conclusion that the structures were adequate and the evaluation and dis--
position of these concerns resulted in no changes being required in the existing concrete structures.
Two of the
.five findings required corrective action which is in process.
34.
These areas of potential significance and the resulting evaluations have been reviewed by the Vogtle Project Quality Assurance organization for safety signi-ficance and reportability in accordance with Project procedures and were determined not to be reportable.
35.
Approximately 4,000 individual documents were
- reviewed to assess the effectiveness of the construction process in controlling work activities associated with the erection of concrete structures.
Records were selected for~ review on:the basis that they-reflect procedural docu-mentation. requirements and qualify as permanent plant s
records as defined in ANSI N45.2.9.
I-1 i L__
36.
Six~hundred and fifty:(650) elements were-identified for. verification in the following ten (10)
- major areas of construction activities
- material receipt, concrete : placement, grout placement, deviation reports, core drilling,-in process tests, caldweld inspections,
. receipt.of miscellaneous items, calibrations, and inspector qualification.
37.
Fifty-(50) findings resulted from the con-struction-verification process.
Each finding was individ-ually evaluated and dispositioned for corrective action.
Findings dispositioned for corrective action were evaluated ~for possible effects on'the completed and in process structures, and none was found'to require rework
.or1 repair as a result of the-Readiness Review: findings.
38.
'In^an effort to assess their collective signi-ficance, the fifty 1 findings were grouped into six (6)
' categories arranged by type of problem encountered:
missing sample, accepted records not meeting speci-fication, inaccurate records, improperly processing
- deviation reports, unique problems, and missing documents.
3 9. - The collective significance ot the findings.in each of these areas was evaluated.
Based on these evaluati~ons, the Readiness Review team concluded that an acceptable program for construction, inspection, and acceptance of reinforced concrete structures exists and I
that individually or collectively the findings did not i
i ?:
b l
indicate trends requiring a need for major revisions to the program.
40.
Two open items were identified (inspector training records and review of DRs for proper approval).
Readiness Review concluded that these open items did not require hardware rework or repair.
The Readiness Review team is satisfied with the overall acceptability of the program for construction, inspection, and acceptance of reinforced concrete structures.
41.
Despite the relatively minor and isolated findings of the Readiness Review Task Force, the task force concluded that the concrete structures at VEGP
" comply with FSAR commitments and that this compliance is verifiable with existing Project records."
- 42. 'The Readiness Review Board concluded:
The Readiness Review Board has been apprised of the scope of the Reinforced Concrete Structures Module and has reviewed the program verification and independent design review process and results.
Additionally, the Readiness Review Board has reviewed the corrective actions, both proposed and implemented, by the Vogtle Project.
Based upon this review, and based upon the collective engineering experience and professional judgment of the Readiness Review Board members, the Board is of the opinion that the corrective action proposed is acceptable.
The Readiness Review Board has also concluded that the concrete at VEGP is of sound quality and installed in a manner consistent with the commitments set forth in the FSAR and PSAR and acceptable engineering and construction practice. t.
......s
43.
A similar intensive review and verification of
~
Project Quality Assurance Department is described in Appendix I.
- 44. 'The purpose of this verification was-to ascertain whether, through representative sampling, Vogtle Quality Assurance. Organization, under the direction of the Vogtle
. Quality Assurance Manager (VQAM) has implemented a comprehensive Quality Assurance program which encompasses design, procurement, construction, preoperational testing, and ' operating activities.
The auditing and quality program oversight responsibilities of the VQAM are divided among a staff of GpC, SCS and Bechtel personnel.
These positions havefa direct reporting unit to the VQAM.
Therefore, these areas were selected for the majority of l
the reviews in this verification.
45.
An evaluation of the~results of this verification
~
indicates that the Quality Assurance organization has functioned effectively to ensure proper implementation of l'icensing commitments.
I
- 46.. Activities verified included the following:
QA independence and reporting; QA organization program control; QA audit scheduling on the basis of the
~
status and safety importance ot the activities being performed; QA audit performance in accordance with pre-established, written procedures, plans, and checklists;
QA personnel training and indoctrination (including lead auditor certification);
Documentation and review of audit results by appropriate management, correction of deficiencies identified by the audits, and. tracking and re-audit of deficient areas; Management review and assessment of the scope, implementation, and effectiveness of the QA organization
. activities; QA. audit and lead auditor certification records.
47.
The VEGF QA organization verification was approached in.four phases to verify that:
(1) QA commitments were implemented; (2) field audits were being performed; (3) site contractors have QA programs; and (4) delegated audits were.being performed by SCS, Bechtel and Westinghouse-pursuant to procedures.
48.
To verify QA commitments were implemented (Phase I), the documents controlling the area of responsibility for each of.the applicable commitments were reviewed to. determine whether they comply with commitment requirements.
The following procedures contained in the GPC QA: Department Procedures Manual governing the activities under the direction of the Plant Vogtle QA manager.were reviewed:
QA-01 Organization and Responsibility of QA
- Department.
i c
1 e
QA-03-02. ~ Training and. Personnel Qualification.
-QA-03-05 ' Qualification of Auditors.
'QA-04 QA Department Procedures and QA Manuals.
QA-05-01 Field. Audits.
-QA-05-02 Corporate / Supplier Audits.
'This. review determined consistency between the wording of the GPC QA Department procedures and the commitment sources.
49.
In-Phase II, the GPC construction and operational audit activities were-reviewed for compliance with and implementation of Vogtle Project commitments and pre-established procedures.
This review was held at the Vogtle site QA offices.
50.
This~ verification process included a review of
-annual audit system plans for 1977 through April 1985 for conformance to and coverage of 10 C.F.R. 50 Appendix B
.activitiesLand scheduling on the basis of the status and
' safety importance of the activities being performed.
The annual QA audit schedules / plans were compared with the
-audits; completed.
As of April'1985, 577 construction field audits have been completed covering 618 activities.
It arould be noted that'these audits include
'non-safety-related work activities.
Also, seven field audits of the initial test program have been completed.
51.
To confirm that VEGP site contractors have QA programs, GPC site audits of contractors with their own QA programs were reviewed. E:
p5 52.
Audit files were' reviewed to assure that all subject areas appeared to be adequately covered, that specific industry problem areas had received appropriate attention,-and that all site contractors has been audited regularly.
I 53.
Two-contractors with their own QA program were selected to perform further reviews:
Chicago Bridge and Iron (CB&I) - Containment liner and, tank fabrication and installation, lock and hatch installation.
Pullman' Power Products (PPP) - Piping system fabrication and installation.
54.
the CB&I.QA manual showed evidence of BPC review and approval of each revision prior to implementation.
The current PPP manual was approved by the GPC site QA manager and evidence was-available for approval'of previous issues.
55.
Both contractors have a requirement for quarterly audits under their own programs.
GPC periodically revie'.ed' contractor compliance with his own aucit program.
56.
In Phase IV, the audits of the QA programs of Southern Company Services, Bechtel Power Corporation, and Westinghouse were reviewed and determined to be in compliance with programs and procedures.
57.
-Georgia Power Company has audited SCS QA Department activities 11 times from 1975 through 1984.
Seven of the audits were joint audits with Alabama Power &_
Company and included coverage of other nuclear projects.
In the audits ~where the Vogtle Project was.not specifically audited, the same programmatic elements would apply.
The' design audits conducted by SCS QA of Bechtel and Bechtel QA audits of. Westinghouse have had active participation by GPC QA personnel.
Of the 33 audits conducted, GPC personnel have participated in 31 audits.
15 8.
The audit activity,.under the direction and approval of the Vogtle QA manager (VQAM), of Bechtel Power Corporation providing architect / engineering services and Westinghouse Corporation providing the nuclear steam supply system (NSSS) was determined to be adequate.
59.
As a result of this intensive verification and review process, the Readiness Review Team force identified only two minor deviations from procedural requirements and on1.y one instance in whicn the (NA Department procedures needed to be enhanced.
60.
Based upon the review process, the Readiness Review Team and the Readiness Review Board concluded that the Vogtle Project Quality Assurance organization is and.
5 i
principally complies with the commitments set forth in the PSAR and FSAR, and that the QA organization will assure the-plant readiness for-safe operation.
Further Affiant sayeth not.
$12 _
W.
C.
RAMSE?
r Sworn to and subscribed before me this M day of Oddar>
1985.
F.
a /sd. d.
Notary Public n.
n I.
I ';.
t I
i
)