ML20070U187

Affidavit of a Vega Re Rk Combs Concerns.Investigation of Concerns Conducted.Combs Refused to Provide Component Identifications or Physically to Identify Items of Concern on Advice from Citizens Assoc for Sound Energy

ML20070U187
Person / Time
Site:	Comanche Peak
Issue date:	02/04/1983
From:	Vega A TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20070U182	List: ML20070U180 ML20070U187 ML20070U193
References
NUDOCS 8302100242
Download: ML20070U187 (10)

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ATTACHMENT A UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AMD LICENSING BOARD In the Matter of _

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TEXAS UTILITIES GENERATING Docket Nos. 50-445 and COMPANY, et al. J 50-446

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(Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating Licenses)

AFFIDAVIT OF ANTONIO VEGA REGARDING CONCERNS OF ROY KEITH COMBS My name is Antonio Vega. I am employed by Texas Utilities Generat,ing Company.as Supervisor, Quality Assurance-Services. My business address is 2001 Bryan Tower, Dallas, Texas. I was previously sworn and gave testimony in this proceeding (Tr. 506, 531, 1419).

When the intervenor CASE filed its motion with the NRC Appeal Board on January 11, 1983, it included with it the affidavit (and an unsworn statement) dated January 9,1983, of one Roy Keith Combs, a structural welder at Comanche Peak. Mr. Combs expressed in his affidavit his desire to bring what he perceived as construction problems at Comanche Peak "to someone's attention who will see that they are corrected without my being fired because of it."

Affidavit, at 4.

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. ~e As Supervisor, Quality Assurance Services, one of my duties is to perform special investigations into allegations of impropriety which might have nuclear safety-related consequences at Comanche Peak. Applicants' Exhibit 43A Section 1.1. It is the responsibility (and a condition of employment) of every employee at Comanche Peak to report items of non-conformance promptly to their' supervisors or to the Quality Assurance Department (see %ction 16.2 of the Brown & Root QA Manual, attached hereto). This requirement is a fundamental aspect of the Construction and QA Programs at Comanche Peak. Tr. 1698-1701.

In fullfilling my responsibility, I conducted an investigation of the allegations made by Mr. Combs. in his affidavit and unsworn statement. The investigation was conducted on January 20, 21, 24 and 25, 1983, at the Comanche Peak site. All interviews with Mr. Combs were tape recorded. This affidavit provides the results of my investigation.

During the first day cf the interview with Mr. Combs, he stated that he was aware of what he felt were problems in ccnstruction at Comanche Peak. He expressed concerns ralated to (1) plug welds (fillet welding) , (2) weld rod -

' control on low hydrogen electrodes, (3) improperly welded tube steel, (4) use i of non-Q material in lieu of Q material on pipe hangers, (5)limitedaccess l

wel ds , (6) work assignment in the hottest and coldest parts of the plant, (7)

I knowledge of other construction problems, and (8) a twelve-inch pipe in which he thought a consumable insert had been left. However, he refused to provide the component identifications or physically tc identify the items of concern to t

me. He stated that he refused to do so on advice from Mrs. Juanita Ellis, president of intervenor CASE and one Billie Garde, an attorney with the Government Accountability Project (GAP), an organization in Washington, D.C.,

that apparently advises " whistle blowers." I advised Mr. Combs that the e

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Cananche Peak QA program requires all snployees on site (including Mr. Combs)

I to identify any non-conforming conditions to their supervisor or the QA depa rtment, and showed him a copy of Section 16.2 of the B&R QA Manual as we discussed it. I further advised Mr. Combs that failure to comply with this condition of employment i.s a basis for termination. I concluded the first day of the interview by requesting that Mr. Combs consult with his advisors on the

! implications of his refusal to divulge information in his possession which his employer would need in order to correct any non-conforming conditions which might exist.

On the next morning, Mr. Combs provided additional details on the ' items of concern to him and agreed to identify them physically. I discuss the details of these items below.

Plug Welding: Weld Rod Control Mr. Combs' concerns regarding plug welding and weld rod control (rod cans unplugged) were basically the same concerns raised by witnesses Henry Stiner -

and Darlene Stiner at the ASLB licensing hearings. Specifically, Mr. Combs questioned the practice of using fillet welds to repair holes drilled in the wrong location in structural mer.cers, and he also expressed concern that weld rod cans were allowed to remain unplugged for an excessive amount of time. The expert testinony presented by Applicants at the hearings states that fillet welding is pennitted to repair holes of this nature (Applicants' Exhiuit 141, at 36, Tr. 4629). That testimony also addressed the worst possible result of

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allowing weld rod cans to be unplugged for longer than the prescribed time (Applicants' Exhibit 141, at 35). The result is that moisture could accumulate in the coating of the weld rods, and that the mositure in the coating could be introduced into the weld as steam. Upon escaping to the surface of the weld, i

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. a the steam would appear as porosity. Any porosity would be detected during visual inspection, and appropriate acceptance criteria would be applied in accordance with applicable inspection instructions. (id.) -

My judgment on Mr. Combs' concerns regarding plug ' welding and weld rod control was that the concerns raised matters that had been addressed previously, and in..any. event raised no questions significant to safety. I concluded on that basis that no further action on the part of QA was necessary.

Welded Tube Steel Mr. Combs cited three instances of which he was aware where in fabricating a pipe support, tube steel was cut at an angle which he believed left too much gap between the tube steel and the base plate. The first instance he identified involved Support Number SW-1-102-106-Y 33K, on which Mr. Combs stated could be found a skewed toe weld and a continuation of the weld into the structural welds on each side of the tube steel. He questioned the adequacy of the fit-up for these welds that he had performed. With this information in '

hand, I investigated the welding on the identified hanger. I reviewed the design package for the hanger to determine whether any oesign credit had been taken for the welds in question. I determined that, in accordance with the design criteria, no credit for weld strength had been taken for the toe weld or for the portions of the structural welds identified by Mr. Combs, so that even if the fit-up had been improper, there was no structural significance.

Further, I determined that the ASME Code,Section III Subsection NF, which governs the welds in question, does not impose any limiting conditions on fit-up. For these reasons we did not intend to grind off the welds. However, when part of a weld was ground off at the request of the NRC staff, we confirmed that the fit-up had not been within the limits specified in the

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construction procedure. Mr. Combs stated that he had knowingly, willfully, and on his own initiative welded over the improper fit-up even though he knew that he was violating a procedure by doing so. This weld bears the welder symbol BLU, which I confirmed is that of Mr. Combs. I also reconfirmed that there was no structural significance .to the improper fit-up.

The second instance on' welded tube steel cited by Mr. Combs involved hanger CC-1-087-004-A33A, on which he stated a 1/2 inch gap existed after fit-up and prior to welding. He stated that he had welded a series of stringer beads so as to bridge the gap. With this information in hand, I investigated ,

further. The weld in question was covered by insulation. The insulation was removed, and the fillet weld was found to measure 5/16 inch. Although I concluded that a 5/16 inch fillet weld obviously could not have closed a 1/P.

inch gap, I nevertheless investigated further because of Mr. Combs' statement that he had welded stringer beads. At my instruction, Welding Engineering performed an acid etching on the weld to define the weld boundary, weld' fusion zone, and base metal. The etching process provided a clear definition of these l items, and proved conclusively that the gap Mr. Combs discussed, in fact, did not exist.

The third instance on welded tube. steel cited by Mr. Combs involved hanger SW-1-012-010-A33R, on which he stated that a 1/4 to 1/2 inch gap existed after fit-up and prior to welding. In order to investigate the matter, the fillet weld was ground out so that a measurement of the gap could be made. The ga~p

was observed and measured to be less than 1/16 inch and thus to be of no safety I

significance.

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! My judgment on Mr. Combs' three concerns regarding welded tube steel was I that the concerns raised no matters significant to safety. I concluded on that 1

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basis that no further action was necessary.

Use of Non-Q Material Mr. Combs expressed concern that non-Q material was being used on pipe hangers in lieu of Q material and that welding crews had stamping symbols that allowed them to stamp the material.

Mr. Combs stated that he knew an individual named " Tommy" (he could provide no surname) in 1980 who cut'a steel member too short then substituted for it another piece of similar hanger material. Mr. Combs stated that the person no longer worked at Comanche Peak. My investigation revealed the following facts. First, the welding crews are required to have stamping symbols so that they can transfer material identity when the cutting of material is required, Second, material for all hangers on site, whether used for Q or non-Q hangers, is the same. This precludes any problem that could arise due to interchange of such material, whether int'entional or inadvertent.

Mr. Combs was not aware that hanger material is interchangeable. On the basis ,

of this infonnation, I concluded that no further action was necessary.

Limited Access Welds; Undesirable Work Conditions Mr. Combs stated in his affidvit that he was assigned to perform limited access welds in the hottest and coldest parts of the plant and that he thought he had been so assigned because he was interviewed by an NRC investigator.

During my interview of him, Mr. Combs stated that he had been assigned to perfonn limited access welds only three times, but that in fact he never actually performed the welds. He stated that he was not allowed to perfonn the welds after QC reviewed his welding qualifications and found him to be unqualified, and that a more qualified welder performed the we ds. ,

With regard to being assigned to the hottest and coldest part of the plant, Mr. Combs identified the hottest part as the heat exchanger room in the auxiliary building, elevation 790 during the summer, and the coldest part as the hallway, auxiliary building, elevation 790 during the winter when the doors are open. Mr. Combs stated that. he was not working there alone but with other members of his crew and other crews. We visited both locations during the

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physical identification tour. Numerous persons were observed in both areas.

Mr. Combs also claimed to have performed another weld where he could.not see the entire circumference of the weld, and that the weld may have been rejected by QC. When we went into the plant to locate the various items, Mr.

Combs stated that the pipe on which the weld had been. perfomed was no longer there.

On the basis of the foregoing, I concluded that Mr. Combs' complaints were either unjustified or unreasonable, and that no further action was necessary.

Other Construction Problems .

In his affidavit (p.4,) Mr. Combs stated that he knew of other problems regarding piping and pipe hangers which could be of safety significance.

However, when I asked him to elaborate on these problems, Mr. Combs stated that

,he was referring to the hangers that intervenor witness Darlene Stiner had discussed in the licensing hearings (Tr. 4124).

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He had nothing to add to the Stiner testimony.

Mr. Combs also discussed a 12 inch pipe in which he thought a piece of consumable insert had been left. (It was this matter that he discussed in the l unverified statement attached to his affidavit.) The weld in question is Field Weld 'FW-1B, on line CT-1-5B-017, a containment spray line. Upon physical

examination in the plant, I found that the weld was accessible for inspection.

The piece of insert referred to by Mr. Combs appears to be a tungsten sliver, approximately 1/16 inch long, shaped like a pencil point, and leaning,in the ,

direction of flow. The sliver is barely detectable when the finger is run in the direction of flow, and only slightly more detectable in the opposite

direction. I concluded that the sliver was a normal by-product of this type of welding, was accehtabl'e per the ASME Code, and did not constitute a non-conforming condition. As an additional check, I directed that the radiograph for the weld be pulled for immediate examination, and a certified NDE Level III examiner in radiography (Mr. Ed. Opelski) reevaluated and reconfirmed the acceptability of the weld in our presence. Present during this field inspection (and during all other field inspections discussed in this affidavit) were NRC investigator Mr. Brooks Griffin, QC personnel Messrs. Tom Brandt, Gordon Purdy, and Richard Ice, and me. Messrs. Brandt and Purdy were sworn and gave testimony in this proceeding. (Tr.4387,4655).

Conclusion of Investigation .

I asked Mr. Combs whether there were any other matters that he wanted to discuss and whether he thought any other conditions at Comanche Peak were non-confo rmi ng. He stated that he had no further concerns and that he was satisfied that his concerns had been thoroughly investigated. I thanked him for bringing these matters to our attention, handed him my business card, and asked him to call me if I could be of assistance to him or if he wished to

! discuss other matters or if he felt he was being harrassed or treated unfairly at Comanche Peak.

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Antonio Vega County of W

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State of Texas.)

Subscribed and sworn to before me this //d day of February,1983

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Notary Public BOBBIE H. MONAGHAN, Notary Public in and for Dallas County, Texas Pty Ccmmi?cion expiresg 9 77 i

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issT9/17/81 Sec. 16.0

% NONCONFORMING ITEMS ,,y, o ,,,,

1 2 16.1 SCOPE 3 *

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4 s This section establishes the methods for the identification.

• documentation, ssgregation and disposition of nonconfoming 7

materials or. items during the receipt and construction phases.

9 16.2 GENERAL 12

It is the responsibility of all site employees to report 14 items of nonconformance to their supervision or to the Site is ,

QA Manager. Alternate methods of documentation are pennitted as described herein.

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20 16.3 DOCUMENTATION METHODS 21 22 23 16.3.1 Design Chances or Deviations 24 Nonconforming conditions related to item noncomp.iance with 27 Engineering specifications or drawings which are identified prior to final QC Group acceptance, may be identified and 3o processed as design changes or deviations in accordance with

' Section 4.0 of this manual.

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! 2 38 39 40 00 NOT AEPRODWE O A-022-0 (12-81)

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