ML20133F249

Affidavit of Lh Jackson Re Issues Concerning Procurement & Storage Requirements Raised by Joint Intervenors Under Contention 8.Util Has Implemented Effective QA Program & Adequately Corrected Deficiencies Identified During Insps

ML20133F249
Person / Time
Site:	Vogtle
Issue date:	07/30/1985
From:	Jackson L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20133F075	List: ML20133F072 ML20133F096 ML20133F120 ML20133F147 ML20133F161 ML20133F179 ML20133F206 ML20133F226 ML20133F235 ML20133F249 ML20133F269
References
OL, NUDOCS 8508080206
Download: ML20133F249 (11)

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

. U3Nrc In the matter of )

) '85 AUS -7 5!0 :56 Georgia Power Company, et al.

) Docket Nos. 50-424

) 50-425 (Vogtle Electric Generating )

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Plant Units, 1 and 2) ) "L:,6 , p .

AFFIDAVIT OF LOUIE H. JACKSON ON CONTENTION 8

1. My name is Louie H. Jac,kson. My business address is 101 Mar.ietta Street, N.W., Suite 2900, Atlanta, Georgia 30323. I am employed by the Nuclear Regulatory Commission as a Reactor Inspector in the Quality Assurance Program Section of the Operations Branch, Division of Reactor Safety.

2. My experience with Plant Vogtle has involved multiple onsite inspections covering items related to QA requirements and document reviews associated with those inspections and associated with issues raised by intervenors under Contention 8. A copy of my professional qualifications is attached.

3. The purpose of my affidavit is to address issues related to Procurement and Storage requirements raised by Intervenors under Contention 8.

Procurement Allegations "The QA Manual In 1974 Was Inadequate" i

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4. My knowledge concerning this issue is based on my review of NRC document-ation and my overall knowledge of QA at Plant Vogtle based on my inspections of that facility.

5. The Georgia Power Company (GPC) QA program, as defined by PSAR Chapter 17, has been examined by NRC Reactor Licensing and by Region II. The PSAR was accepted as meeting the requirements of 10 CFR 50, Appendix B.

6. NRC Inspection Report No. 50-424/74-01 identified that the GPC QA manual was

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inadequate to stand on 1ts own. This does not imply that an adequate QA program was not being implemented; only that the QA progIam manual lacked sufficient prescriptive definition regarding (1) organizational functional alignment, (2) major contractor QA programs, and (3) incorporation or referencing controlling procedures and documents for specific QA requirements.

7. GPC revised their QA manual to sufficiently (1) describe Southern Company Services' involvement in the QA program, (2) address the major contractor QA program (Bechtel and Westinghouse), and (3) incorporate or reference controlling procedures.

8. Verification of corrective actions concerning these deficiencies was performed by Region II inspectors in September 1974. This was reported in NRC Inspection Report No. 50-424/74-04, i

l 9. This allegation did not identify any significant deficient condition for l which corrective action was not taken. Nothing was identified in reviewing

3-3 this sub-part of Intervenor's Contention which constitutes a threat to the health in'd safety of the public.

VECP Vendor QA Programs and Applicants Audits' of Vendors -

10. My knowledge concerning this issue is based on my review of NRC document-ation and my overall knowledge of QA at Plant Vogtle based on my inspections of that facility.

11. This allegation lacks s'pecificity and therefore can only be addressed by assessing the overall vendor QA program.

12. NRC Region II has routinely inspected activities at Vogtle Nuclear Plant.

Special assessment team inspections have been performed by Region II to evaluate the overall effectiveness of the QA program. Itens of non-compliances identified by NRC have been or, in the case of a very few items, will be resolved to the satisfaction of NRC.

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13. Vendor inspections have been performed by the NRC's Vendor Inspection Program Branch throughout preconstruction and construction activities at Vogtle. Identified problems have been resolved, and follow-up audits have been performed, where necessary, to verify implementation of corrective action.

14. This allegation did not identify any specific incident where activities affecting quality were not audited. Based on my knowledge of NRC inspections involving vendor QA for Plant Vogtle, there are no outstanding

problems which would indicate a programmatic breakdown with QA involving i Vogtle vindors. The NRC will continue to inspect these activities throughout construction of Plant Vogtle.

Procurement Office QA Letters

15. ' As part of the basis for their Contention 8, Intervenors have said that GPC Procurement Department "made up" letters for what is called the " qualified vendor list."

16. My knowledge concerning this issue is based on my review of NRC documenta-tion and my overall knowledge of QA at Plant Vogtle based on my inspections of that facility.

17. Bechtel Power Corporation (BPC), Los Angeles Power Division (LAPD), under contract with Southern Company Services (SCS) provides architect-engineering services; development of purchase recommendations for balance-of-plant equipment and materials; and administration of purchase orders (including the nuclear steam supply system and other purchase orders resulting from SCS-developed purchase recommendations) for Plant Vogtle.

18. Bechtel's QA program, which has been accepted by NRC, endorses Regulatory Guide 1.144 (1/79) and ANSI N45.2.13 (draft dated May 31, 1973). BPC evaluates supplier QA programs and maintains a BPC evaluated supplier list.

19. The NRC has routinely reviewed the evaluated supplier list to assess the addition and deletion of suppliers from the list. SCS and GPC have

participated in audits of BPC QA activities since 1973, and have accompanied BPC on au'dits of vendors.

20. The NRC Vendor Inspection Branch routinely follows up on vendor-identified -

problems. Vendor-identified problems must be resolved to the satisfaction of NRC.

21. GPC also maintains a " qualified vendor list." Vendors are placed on the list in accordance with the requirements of ANSI N45.2.13 which has been committed to in the accepted QA program.

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22. Based on NRC's inspections of the Vogtle QA program, the NRC has not found improper placement of vendors on the QA list.

Storage Allegations Storage of Safety-Related Equipment

23. This issue raised by Intervenors relates to Inspection Report No. 50-424/77-03 dated July 1, 1977.

24. My knowledge concerning this issue is based on my review of NRC documenta-tion and my overall knowledge of QA at Plant Vogtle based on my inspections of that facility.

25. GPC had not assigned a QA manager to Vogtle in early 1977. Audits were being performed by personnel from Plant Hatch visiting the construction

4 site. Therefore, all implementing procedures necessary to establish storage requireme'nts, receipt inspections, nonconformances, corrective actions, and records had not been written.

26. This infraction was identified in NRC Inspection Report No. 50-424/77-03.

27. The licensee implemented corrective action by notifying vendors that ware-I housing facilities were not available onsite. The Senior QA Field Representative from Plant Hatch was transferred to Vogtle. Implementing procedures were written for controlling storage, handling, and receipt

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inspection of safety-related equipment.

28. The licensee had stored the valves involved in this concern in a warehouse; therefore, no deleterious effects upon the material or equipment had taken place. l j 29. The licensee's response dated July 19, 1977, was considered acceptable by i

Region II. The inspector who identified the noncompliance reinspected the actions taken by the licensee to preclude further noncompliances. The l inspector concluded that a program had been provided which corrected the noncompliance. This item was closed in Inspection Report No. 50-424/77-4, paragraph 2.

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30. This allegation did not identify any significant deficient condition for j which corrective action was not taken. Nothing was identified which

! constitutes a threat to the health and safety of the public.

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4 l 31. In summary, based on my knowledge described above on the specific issues I raised by'Intervenors, and based on my overall knowledge of QA/QC activities at Plant yogtle as applied to my areas of expertise, GPC has implemented an effective QA program and has adequately corrected any deficiencies identi- -

fied during inspections.

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Louie { Jackson Subscribed and sworn to before me this ,

&M day of July 1985 i

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( bM4) . D llA 104/t Notary Mt/Dlic )

My Commission Expires Nots 0 Public Georgia, State et Lav M/Comrmssion Empires May 15,1955 l

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Louie H. Jackson PROFESSIONAL QUALIFICATIONS U. S. NUCLEAR REGULATORY COMMISSION My name is Louie H. Jackson. My business address is 101 Marietta Street, NW, Suite 2900, Atlanta, Georgia 30303. I am employed by the Nuclear Regulatory Commission as a Reactor Inspector. .

I graduated from Tennessee Technical University in 1961 with a Bachelor of Science Degree in Industrial Management.

From September 1961 to March 1963, I was assigned as a Mechanical Engineer in the DivisionofConstruction,TennesseeValleyAuthority(TVA),ColbertSteamPlant, Tuscumbia, Alabama. I was responsible for the inventory of installed equipment in accordance with federal regulations. I also assisted in the planning and implementation of the acid cleaning operation for the 500 megawatt (MW) Babcock and Wilcox boiler.

March 1963 to August 1966, I was assigned as a mechanical engineer in the Division of Construction, TVA, at Bull Run Steam Plant near Oak Ridge. Tennes-see. I was responsible for installation of mechanical equipment, piping, valves, welding and preoperational testing of support systems on a 900 mw Combustion Engineering boiler and a General Electric turbine.

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2 From August 1966 to March 1967, I was assigned as a mechanical engineer, in the Division of Engineering Design, Knoxville, TN. I was responsible for the pre-paration, coordination, and verification of design for water supply and sewage disposal for miscellaneous projects.

From March 1967 to June 1969, I was assigned as a mechanical engineering group leader, in the Division of Construction. TVA, Browns Ferry Nuclear Plant Athens.

Alabama. I was responsible for leadership in welding quality cont,rol, super-vision of welding procedure development and qualification, welders performance qualification, shop and field welding and nondestructive examination activities.

From June 1969 to April 1977, I served as a materials engineer, in the Division of Engineering Design, Inspection and Testing Branch (!&T), Knoxville, Tennessee.

My responsibilities progressed from furnishing welding and nondestructive exami-nation advice to I&T branch staff and field inspectors, to staff specialist responsible for contractural and technical advice on inspection and testing of reactor vessels, pumps, valves, heat exchangers, all other equipment furnished to TVA through its Nuclear Steam Supply Systems. These included General Electric, Westinghouse, Babcock and Wilcox and Combustion Engineering.

From April 1977 to September 1978, I served as assistant construction engineer, Quality Control-A Plant, Division of Construction. TVA Hartsville Nuclear Plant, Hartsville, Tennessee. During this assignment I was responsible for supervision of mechanical, electrical, instrumentation, materials and civil, and welding quality control personnel involved in fabrication, installation, erection,

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examination, testing, and preoperational verification of the facilities at the construction s*1te.

From September 1978 to November 1980 I served as assistant construction engi-neer, Engineering Supervisor - A Plant. Hartsville Nuclear Plant. These res-ponsibilities included supervision of m. hanical, electrical, instrumentation, materials and civil, and welding, engineeris.; personnel involved in engineering coordination with General Electric /C. F. Braun on Standard Reactor Island Design (STRIDE) and NSSS equipment supplied under contract to support:the construction activities.

From November 1980 - June 1981, I served as assistant construction engineer, Engineering and Quality Control, Mechanical and Welding, Bellefonte Nuclear Plant, Scottsboro, Alabama. During this assignment I was the engineering and quality control supervisor supporting activites associated with the construction of the two unit plant.

From June 1981 to July 1982, I was assigned a:, reactor inspector in the Division of Emergency Preparedness and Materials Safeguard, Region II. I was responsible for the coordination of Licensee Event Reports, Construction Deficiency Reports, Information Notices, Circulars, and Bulletins internal to NRC.

From July 1982 - Present, I was assigned as, a Reactor Inspector, Division of l

Engineering and Radiological Safety Programs, Engineering Program Branch,

( Management Programs Section. Perform responsible quality assurance inspections l st nuclear facilities and engineering offices in the Regional area.

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During y career, I have completed several courses related to assigned respon-siblities. Th*ere courses include Welding. Hobart Brothers Troy, Ohio; Basic and Advanced Ultrasonic Inspection, Krautkramer Corporation, Stratford, Conn.;

Radiography, Kodak Company, Atlanta, Georgia; Fundamentals of Nondestructive Testing, Ohio State University 1 Welding Metallurgy, University of Tennesseee; several management development courses internal to TVA. BWR systems. PWR systems, QA construction course G-301, and Fundamentals of Inspection with the NRC, O