ML20205H263

Affidavit of G Trudeau in Support of Applicant Response to Joint Intervenors Motion for Reconsideration of ASLB 851003 Memorandum & Order on Summary Disposition of Contention 8 Re Adequacy of QA Program

ML20205H263
Person / Time
Site:	Vogtle
Issue date:	11/07/1985
From:	Trudeau G GEORGIA POWER CO.
To:
Shared Package
ML20205H244	List: ML20205H238 ML20205H263 ML20205H288
References
OL, NUDOCS 8511150085
Download: ML20205H263 (6)

Text

_ . - - .

-UNITED STATES OF AMERICA NUCLEAR. REGULATORY COMMISSION i

Before the Atomic Safety and Licensing Board ~

In the Matter' of )

)

GEORGIA POWER COMPANY, ) Docket Nos. 50-424

_at _al. .) 50-425

)

(Vogtle Electric Generating )

Plant, Units 1 and 2) )

AFFIDAVIT OF GEORGE TRUD1:AU Before the. undersigned officer duly authorized to cdminister' oaths did appear George Trudeau, who after being duly sworn, did' state as follows:

1. My name is George Trudeau. My business address' is: Vogtle Electric Generating Plant, Route 2, Waynesboro, Georgia, 30830. I am employed by Georgia Power Company as Deputy Rodiness Review Program Manager. In that position, my Primary responsibility is to assist Mr. W. C. Ramsey with overall scope, direction, and schedule for the VEGP pilot Readiness Review Program. I have a Bachelor's Degree in Engineering and have been working in the nuclear field for 18 years, 14-years of which has been in nuclear power plant design end construction.

2. I have read and reviewed Joint Intervenors Motion for Reconsideration. I submit this Affidavit in support of Applicants' response to that Motion. The facts set forth herein are based upon my personal knowledge.

E Exhibit "2" B511150085 851112 PDR ADOCK 05000424 g PDR

3. Joint Intervenors have cited 6 " findings" of

.the Readiness' Review Program which they suggest' provide'a

' basis to challenge the effectiveness of the VEGP QA program.

In fact, Readiness Review has discovered, as of the present, l more than 500." findings" of construction errors, defects, or  !

l deviations from PSAR/FSAR commitments. '

4 .~ As part of the Readiness Review procedure all findings are reviewed by appropriate individuals and a determination !s'made as to whether the condition is reportable within the meaning of 10 C.F.R. 50.55(e) .

5. None of the findings made by Readiness Review has involved a reportable condition within the meaning of 10 C.F.R. 50.55(e) .

6. None.of the findings has resulted in a Notice of Violation, of any level of severity, by the NRC.

7. Of the six findings cited by Joint Intervenors et p. 9 of their Brief, three are recognizable and are typical l

of-other Readiness Review findings. The other three references to: " deficient controls associated with field changes",

" weaknesses in certain design calculations," and " problems with olectrical cable separation controls" are cryptic. Therefore, a specific response to each of these findings is impossible.

Nevertheless, it remains true that no finding, or group of l findings, of whatever nature, has been found to have any cafety significance.

8. The first recognizable finding cited by Joint Intervenors is that there have been " problems with retrievability of documentation." This is most likely the conclusion Joint

~Intervenors draw after reviewing the eight findings set forth in Readiness Review Module Appendix D " Document Control." In fact, after considering those eight: findings, the Readiness Review Team concluded as follows:

Examination of project documents ,- and records ,

and discussions with project personnel provided evidence of compliance with the implementing procedures. Although discrepancies were identified and documented in the findings previously discussed, none of the findings ,

either individually or collectively, have had any adverse effect on hardware or plant design

' features or are such that the overall adequacy of lhe VEGF is called into question. Each finding was addressed by the project. Readiness Review .

has evaluated the responses and concluded that they resolve the identified discrepancies.

The appendix and its summaries have primarily highlighted only the problem areas found by an experienced review team's audit of approximately 2800 project documents.

Many positive aspects of the project were identified during their reviews and some of these are discussed to a limited degree earlier in the appendix. In summary, based on the reviews, assessments, evaluations, and the responses and corrective actions to which the project committed, it is the conclusion of the Readiness Review Team that the project document control and quality assurance records control program is effective in ensuring that-documents are properly controlled and quality assurance records are properly received, stored, and maintained. Therefore, the overall program ,

meets FSAR commitments. (emphasis added).

9. The second identifiable finding which is cited iby Joint Intervenors is that there is a " weakness in initial test program procedures." This is probably the conclusion Joint Intervenors draw after examining the twenty findings reported.in Readiness Review Module 3A " Initial Test Program".

In fact, after-considering'these finding , the Readiness Review Team concluded as follows:

Module 3A Readiness Review Team verification

! process resulted in 20 findings. Corrective actions were reviewed and found to be acceptable by the Readiness Review Team. The findings were grouped into categories which resulted in three additional findings and the collective significance

was assessed. When related to the performance of L the ITP, no individual or collective findin.g was considered to be serious enough to affect t'ae overall quality of the ITP. Timely corrective i action and continued management attention will i result in a successful Preoperational Test Program. -

I 10., The third identifiable find'ing which is cited by Joint Intervenors is that there are " problems with l

inspector certification records." This is probably the l conclusion Joint Intervenors draw from Finding 6.1-5 set forth ,

in Readiness Review Module 1 " Concrete, Rebar and Cadwelds."

That finding is as follows:

Training records for the year 1978 for R. Chao could not be located. In addition, i

1978 training records for H. Reuter did not include any record of PRM training.

l L l l

. . . - . . = _ . - _ _ _ . . ._. . _ . - . -

11. The-Readiness Review Team considered the finding and concluded as'follows:

It is recognized ~that training for the years prior to 1980 was not documented to the extent currently done. Since most of the project calculations and drawings have been revised or reissued subsequent to 1973,-. documentation of training during that time period is not a significant concern. Training records for 1980 and 1982 were reviewed and found to be satisfactory, with clear indication of requirements '

and evidence of appropriate training. Additionally, the ~overall quality of engineering documentation and .

its close adherence to project procedures is evidence of the effectiveness of training. Therefore, it was concluded that no corrective action regarding training records prior to 1980 was required. This l finding is, therefore, closed.

I j 12. .A complete review of each of the more than 500 Readiness _ Review findings would be impractical and unnecessary-in this, Affidavit. However, with regard to each and every ,

finding, a determination has been made that the matter did not cdversely affect the safe operation of VEGP.

! Further Affiant sayeth not.

/ Y l George Trudeau Sworn to an subscribed before me this day of WB) ,

i- 1985.

Notary ?ublic Eb* '

l w m, Georgia, state e4 Lue! .

W Comrmssion Empires Oct.24,1986 ,

l

.m. _ . . , _ _ . _ _ _ . _ _ _ _ _ _ . _ _ _ . . _ _ . _ _ _ _ , . _ _ - _ , _ . -