ML20132B317

Testimony of Tw Brombach Re Conam Insp Activities (Conservation Council of North Carolina Contention WB-3). Related Correspondence

ML20132B317
Person / Time
Site:	Harris
Issue date:	09/23/1985
From:	Brombach T CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML20132B240	List: ML20132B235 ML20132B242 ML20132B246 ML20132B259 ML20132B289 ML20132B317
References
OL, NUDOCS 8509260160
Download: ML20132B317 (16)

Text

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'85S4EeneElis 1985

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY ) Docket No. 50-400 OL and NORTH CAROLINA EASTERN )

MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

Plant) i APPLICANTS' TESTIMONY OF THOMAS W. BROMBACH ON CONAM INSPECTION ACTIVITIES (CCNC CONTENTION WB-3) i e

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Q.1 Please state your name.

A.1 Thomas Walter Brombach..

Q.2 Mr. Brombach, by whom are you employed and what is your position?

A.2 I am employed by Carolina Power & Light Company

("CP&L") at the Shearon Harris Nuclear Power Plant as a Project Specialist / Inservice Inspection. In this capacity I am respon-sible for Non-Destructive Examination ("NDE") of Class 1, 2 and l

3 components, piping'and their supports to ensure applicable requirements of ASME Code Section XI and 10 C.F.R. S 50.55a are met.

Q.3 Please state your professional cualifications and ex-perience related to your present position.

A.3 I have been actively engaged in NDE and inservice in-spection programs at nuclear power plants since 1976. I have received extensive NDE training, including ultrasonic testing, visual inspection and eddy current testing / examination. While employed by Virginia Electric & Power Company ("VEPCO") from 1976 until.1982, I was certified as an NDE examiner. From 1978 to the present I have been employed in supervisory positions, overseeing NDE and inservice inspection activities. Beginning with my early training and experience,in'the United States

' Navy, I have sixteen years of hands-on experience in power i

plant operations, maintenance and testing. A complete state-ment of my professional qualifications and experience are ap-pended hereto as' Attachment 1.

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Q.4 What is the purpose of this testimony?

A.4 The purpose of this testimony is to_ respond to cer-tain allegations set forth in an " Affidavit of Patti Miriello,"

dated September 6, 1985,'and attached to the " Conservation

. Council's Response to Applicant's Motion for. Summary Disposi-tion of Contention WB-3," dated September 6, 1985. In that Af-fidavit Ms. Miriello alleges that certain persons employed by Conam Inspection ("Conam") of Richmond, California, who provid-ed contractor services to the Harris Plant, used drugs. In the Affidavit Ms. Miriello accuses the.following individuals of ei-A ther dealing in, selling or using drugs:- Richard Marlow, Jr.,

Vice President of Conam; John Camburn; John Funanich; a Mr.

Dugas;'a Mr. Dobson; Mark Matheson and Mel Matheson. She implies that such activities may have impacted on work per-formed by certain of those individuals on the Harris steam gen-erators. My testimony attests to the' quality of the work per-formed by Conam.

Q.5 Did' Conam provide' contractor services to CP&L at the Harris Plant?

A.5 Conam is a' division of Nuclear Energy Services, Inc.

("NES"). CP&L contracted with NES,to perform baseline preservice eddy current testing / examination of heat exchanger tubing, including.the Harris steam generator tubes.1 NES'-Conam Inspection Division provided these eddy current testing ser-vices.

Q.6 Do you personally know the individuals named in the Miriello Affidavit?

A.6 My resonsibilities at the. Harris Plant in.;1ude overseeing and supervising Conam's testing and examination ac-tivities on site. In that capacity I have a professional rela-tionship with each of the individuals named in the Miriello Af-fidavit. My professional acquaintance and relationship with some of the individuals began while I was employed by VEPCO and

' Conam performed eddy current testing on VEPCO's. Surry and North Anna nuclear plants. My personal knowledge of the named indi-viduals can be summarized as follows:

Richard Marlow is Senior Vice President of Conam.

His office is in Richmond, California. I have personally known Mr. Marlow since 1976 when he first performed eddy current ex-aminations at VEPCO's Surry Nuclear Power Station. From that time until the present I have engaged Mr. Marlow and Conam to perform numerous eddy current examinations. Mr. Marlow.has only been to the Harris Plant on approximately three occasions, limiting his stay to one day or less for business purposes.

John Camburn is a Level II Data Analyst for Conam. I have known Mr. Camburn since the late 1970's. He also per-formed eddy current' examinations for me as an examiner at VEPCO's Surry and North Anna nuclear plants from approximately 1978 to 1982. While at the Harris Plant Mr. Camburn was the Data Analyst for the steam generator eddy-current baseline. He was directly supervise ~d by-me while on the Harris site during i

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the periods August 1 - September 14, 1984; October 8-13, 1984; and November 3-13, 1984.

Michael Dobson is a Level II Data Analyst for Conam.

I have known Mr. Dobson since approximately 1976 when Conam first performed eddy current examinations at VEPCO's.Surry and North Anna nuclear plants as an examiner. Mr. Dobson was di-rectly supervised by me while he was at the Harris Plant during the periods August 20-30, 1984 and January 18-30, 1985.

John Funanich is a Level II Data Analyst for Conam.

I have known Mr. Funanich since 1978 when he was an examiner doing eddy current examinations at VEPCO's Surry Nuclear Power Station. Mr. Funanich was at the Harris Site September 27-28, 1903; February 13-25, 1984 and June 10-13, 1984.

Melvin Matheson is a Level II Examiner for Conam. My first contact with him was in 1983 when he was assigned as Conam's site supervisor for performing the Harris' Plant baseline eddy current examinations. Mr. Matheson was on site during the following times: December 2-31, 1983; January 2 -

September 21, 1984; October.1-12, 1984; October 30 - November 16, 1984; November 19 - December 21, 1984; January 2 and 18-25, 1985; and March 4 - April 5, 1985.

Kenneth Dugas is a Level II eddy current examiner for Conam. I have known Mr. Dugas'about four years. He performed eddy current work for me at VEPCO's Surry Nuclear Power Station and at the Harris Plant from August 1 - September 7, 1984.

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> Mark Matheson is a laborer and an eddy current Level  !

I trainee for Conam. Mark is Melvin Matheson's son. I first met Mark Matheson when he came to Harris during the period of

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! July 30 - October 18, 1984. Other than seeing him work with i

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his father and occasionally talking to him, I never had much contact with Mark Matheson. ,

While I have only established a business relationship

. with each of the named individuals and, with the exception of

. an occasional business lunch with Mr. Marlow, have never mixed l

with them socially, I have no reason to believe that any of i

them has been involved in drug use.

Q.7 What is the purpose of eddy current examinations of l

i the Harris steam generators?

l .7 The purpose of eddy current examinations of steam generator tubing prior.to operation is to establish a baseline

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t' condition of the tubing for comparison with the examination re-sults of the first inservice inspection after commencing com-mercial service of the plant. This is consistent with NRC Reg-  ;

I ulatory Guide 1.83 (Revision 1)(1975) at Section C.3.a.

! Q.8 Are eddy current examinations required to assure the safe construction of the Harris Plant?

A.8 No. The steam generator tubing was incpected and i ,

subject to non-destructive examinations at the point of fabri- 1 cation to detect any defects and flaws. After installation at the Harris Plant, the steam generators were subjected to a hy-drostatic test to ensure integrity sufficient to meet ASME Code

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standards. The eddy current examination performed on site is i

to establish baseline information for comparison with later

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inservice test results. In fact, the contract involved here is an Operations and not a Construction contract. Further, none ,

of the employees of.Conam are quality assurance inspectors as that term is used to describe CP&L QA/QC/CI inspection person-j.

nel or vendor QA/QC inspectors.

1 i Q.9 Describe eddy current testing / examination techniques

) and analyses of eddy-current tapes. ,

A.9 The method most commonly used to check for defects or

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flaws in heat exchanger tubing is eddy current examination.

f i This method is based upon measuring the changes of an electro-1 magnetic field induced into the tubing to be tested. A differ-ential set of electric coils called a probe is drawn at a con-1

stant rate through the tubing to be tested. When these coils i

are energized, an electromagnetic current is induced in the i

) tube in the areas adjacent to the probe. This induced electro-

magnetic field generates eddy currents.

i Changes in tube wall thickness or permeability or the '

l presence of flaws will cause changes to the flux and density of 1

l the induced current, which in turn causes changes in the imped-1 i ance of the coil. From.the measurement of these impedance i

j changes the size and orientation of defects can be calculated and determined. .To assist and enhance this process the eddy 1 current probe is attached through an interface system with a

digital computer, which allows a permanent record to be made 1

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via magnetic tape of the calibration, sequence of testing, and the actual data inspection results. The eddy current test data acquired and stored is unique for each tube tested. The mag-netic tapes that are generated during an examination are re-viewed using a similar computer system by a data analyst. In this manner the validity of the test results can be 4

re-established. If necessary the magnetic tapes can be re-viewed again by a third party at any time.

Q.10 Who supervised the work of individuals from.Conam i while performing eddy current testing / examination activities at 4

the Harris site?

A.10 While Conam was at the Harris site performing eddy current testing they were directly supervised by me and I had an engineering technician work directly with them in the field on a daily basis.

Q.ll Did you ever observe any of the individuals per-forming eddy current testing or analyses of data exhibit behav-ioral traits of a person who has used cocaine or other con-trolled substances?

A.ll At no tin.e while any Conam personnel were on site did they exhibit any aberrant behavioral traits which I would as,so-ciate with an individual using cocaine or other controlled sub-stances. My engineering-technician confirmed my own observa-tion.

Q.12 Have you taken CP&L training courses designed to edu-cate supervisory personnel to be able to detect individuals

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whose performance may be affected due to use of controlled sub-stances?

A.12 I have received training both while at VEPCO and CP&L i

designed to educate supervisors to detect personnel whose per-formance may be affected by-using alcohol or controlled sub-stances.

Q.13 Have you checked the- work of individuals from Conam to ensure the accuracy of the eddy current testing / examinations i and correctness of the analysis of eddy current-tapes?

, A.13 During most of the analysis work performed by John' Camburn I worked directly with him while reading a significant amount of the test data results. If at any time an anomaly of significance was detected he brought it to my attention for re-view. The purpose of my involvement was to assure the accuracy of.the eddy current examinations and the test results. During the data acquisition phase of actual examination of the tubes, I made several trips to the field to overview the work of the examiners. Also, during data acquisition CP&L Quality Assur-ance Personnel performed surveillance checks. Because of my personal supervision of the eddy current examinations and data analyses, I have no reason to question the integrity nor cor-rectness of the test results, notwithstanding the allegations in the Miriello Affidavit. ,

Q.14 As a result of the allegations by Ms. Miriello did-you perform an evaluation of the work performed by Conam?

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A.14:Yes. Nine of the magnetic tapes acquired by Conam i during the baseline examination of Harris steam generator' tubes i

were taken to the Electric Power Research Institute ("EPRI")

1 i NDE Center in Charlotte, N.C., and EPRI was requested to per- '

form an independent third. party review, reanalysis and verifi-4 cation of the data acquired and analyzed by Conam.

Q.15 Describe the independent review of Conam's analysis

! and the results.

1 i A.15 The tubes selected for reanalysis by EPRI had either 1-been tested by and/or analyzed by the individuals identified in ~

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the Miriello affida'vit (with the exception of Richard Marlow who performed no onsite work). Three reels of data were ran-j demly selected from each of the three steam generators, repre-senting five percent of the total number of steam generator

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I tubes examined'by Conam. Included in the sample were tubes with no quantifiable indications and others that had identified j anomalies requiring evaluation.

l EPRI used the samel procedure, data analysis system '

and calibration system as those used by.Conam personnel. Based on-its review of the data on the tapes, EPRI concluded that the data acquisition had gone very smoothly and validated Conam's-  ;

use of procedures, selection and application of the defect i

sizing criteria and interpretation of the eddy. current signals.

4 Thus, EPRI confirmed Conam's eddy current testing and examina-tion results.

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h Q.14 Is the sample size of the number of tapes reanalyzed sufficient to assure a high confidence level of the validity of the original work?

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A.16 Yes. The five percent sample of data is greater than i

i the sampling requirements of NRC Regulatory Guide 1.83, which

! requires a three percent cample of the total number of tubes to

. be inspected during inservice inspections. The five percent i

sample provides greater than a 95 percent confidence level that

' the sample results are representative of the data from which 3

the sample was taken.

Q.17 Have you any reason to believe that the work per-formed by personnel from Conam was of a quality that suggests l their performance was influenced by use of controlled sub-l

stances?

A.17 I have personally supervised the Conam personnel per-

, forming eddy current examinations and analysis of data at the Harris Plant and can attest to the high quality of their work.

The independent review of a representative, statistically sig-nificant sample of the Conam analyses of eddy current tapes provides additional confirmation of the quality of the work performed by Conam. Conam has an excellent reputation in the industry for the professionalism and. quality of its employees and the quality of its testing and evaluations. My experience with the individuals employed by Conam, who performed examina-tions and provided analytical evaluations at the Harris Plant, has been entirely satisfactory. I have found them to be highly 1 1 3, - .,-- , - - - , - -

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I trained, competent and professional in a unique field of non-destructive examination. At no time have I had cause to question the physical or mental condition of a Conam employee performing examinations or analytical work at the Harris Plant.

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1 i Attachment 1 Resume

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THOMAS W. BROMBACH  ;

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i EDUCATION I MILITARY

• Basic Propulsion and Engineering School l

• Machinist Mate "A" School

• Water Treatment School

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• Power Plant Maintenance School i

• Damage Control School l

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• Fire Fighting School  !

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• Submarine School l j

• Nuclear Power School (25 weeks)

• Hydraulic and Pneumatic School

• AC & R School l

• Magnetic and Liquid Penetrant School j

• 3M Records Manacement School i

• Radiological Control School CIVILIAN

• High School Graduate f

• 5 Semesters of Collece .

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• Continuing Education Units Awarded for:

-Magnetic Particle Inspection ,

! -Liquid Penetrant Inspection  ;

t i -Ultrasonic Weld Inspection

-ASME Section XI Short. Courses .

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• Formal 5 1/2 Year Journeyman Power Plant  !

! Mechanic Apprenticeship.  ;

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• Company Sponsored Schools: j i -Dresser Valve School l -Radiation and Radiological Control School i -Grinnel Valve School i -Milton Roy Pump School j -Non-destructive Testing Schools for MT, PT, j VT and Eddy Current Tube Inspection j -Multifrequency Eddy Current Examination

-Personnel Management l j -Aberrant Behavior PROFESSIONAL MEMBERSHIPS f i

American Society of Mechanical Engineers i  !

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! EMPLOYMENT September 1982 CAROLINA POWER & LIGHT COMPANY

} to SHEARON HARRIS NUCLEAR POWER PLANT Present Project Specialist / Inservice Inspection Scope of Responsibility

, Responsible for developing and maintaining the Harris 1 Plant's inservice inspection ("ISI") program in accordance with, and as required by, ASME Code Section XI to assist in meeting NRC, plant Technical Specification, operating license, j and other related plant and regulatory requirements. The ISI

program is developed based on the latest regulatory require-i ments. The ISI program provides direction and support of inservice inspection related tests such as hydrostatic testing, l weld inspections, and eddy current testing.

, Major Functions

! 1. Developing and' maintaining an inservice inspection j program for welds by working with Operations and Mainte-nance.

i 2. Coordinating inservice inspection activities and

! schedules. <

j 3. Developing, updating, and maintaining ASME Code Sec-i tion XI inspection programs.

4. Maintaining interface responsibilities among the Plant's organizations to ensure the ISI program is imple-

! mented effectively.

l S. Analyzing and providing resolution to Plant, problems I resulting from ISI.

! 6. Preparing and monitoring budcet items pertaining to l -ISI.

l 5 j 7. Staying updated on changes to, and latest require-ments of, the ASME Code.

8. Responsible for ensuring the proper maintenance of

inservice inspection records, deficiencies and resolu-tions.

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r March 1976 VIRGINIA ELECTRIC AND POWER COMPANY to SURRY NUCLEAR POWER STATION August 1982 Engineering Supervisor of Non-destructive Testina and Evaluation Scope of Responsibility Performed unit and component testing in the field of non-destructive examination and provided evaluation of test re-sults to insure component and vessel integrity.

i Major Functions

1. Conduct' inservice and preservice inspections to assure compliance with ASME Code Section XI and plant technical specifications.

2. Provide non-destructive testing services for the j station, i.e.: PT, MT, RT, VT, UT and ET, in accordance with ASME Code Sections III, IV, IX and XI and other designated applicable codes as required.

3. Coordinate inspection services with the desig-nated ANSI to ssure full compliance with the ASME Code in effect.

4. Provide eddy current examination services to meet the requirements of USNRC Reculatory Guide l 1.83 and ASME Code Section XI for steam genera-tors.

5. Provide eddy current examination services in ex-amination of condenser and other various heat exchanger tubing.

6. Prepare and submit inservice, preservice and eddy current reports.

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7. Assist Engineering in identifying generic prob-lems and working toward solutions.

8 ._ Support and implement additional training pro-grams for NDT technicians' to keep personnel abreast and trained'in new field developments.

9. Establish and maintain appropriate records man-agement of all work conducted.

10. Prepare and submit budgets for procurement of

' equipment, supplies and arrange for contractor i and vendor services.

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11. Provide schedules and commitment dates during plant outages for inspection services.

12. Review and implement non-destructive examination procedures.

13. Certified in accordance to ASNT-TC-1A as a LEVEL II in Visual, Liquid Penetrant, Magnetic Parti-cle and Eddy Current' examinations and LEVEL I in Ultrasonic Testing.

Also prior to being promoted to a supervisory position, I was a journeyman mechanic providing round-the-clock maintenance and repair to all station equipment, i.e.: oumps, valves, hy-draulic and pneumatic systems, HVAC, steam turhines and auxil-iary systems on both the primary and secondary sides of the plant. A collateral duty was to travel to various fossil fuel plants within the VEPCO system and conduct maintenance and re-pair on high pressure power boilers, coal systems and other plant systems.

September 1975 NEWPORT NEWS SHIPBUILDING AND DRYDOCK, CO.

to Newport News, VA March 1976 Power Plant Operator, Utilities Department Assigned to the operation of the main ~ power plant and all substations -- maintaining and operating 600 lb. boilers, air compressors and related equipment supplying power steam and compressed air to the shipyard.

September 1974 COLLEGE OF DUPAGE to Glen Ellyn, Illinois September 1975 Assistant Chief of Plant Operations Responsible for the operation of the. steam generating and air conditioning plant, in addition to which, performed all re-pairs as necessary to its plumbing, hydraulic, pneumatic and electrical systems. Collaterally re'sponsible for the mainte-nance of the buildings and all service support systems.

April 1974 FACTORY MUTUAL ENGINEERING CO.

to Chicago, Illinois September 1974 Boiler & Machinerv Inspector

, Conducted on-site physical inspections of steam generating power plants and machinery for compliance with ASME, state and local codes.

January 1969 UNITED STATES NAVY to E-4 Machinist Mate December 1973 l

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