ML20214S127

Affidavit of Tw Brombach Re Allegations Raised in Ps Miriello 860728 Affidavit Concerning QA Filed in Support of 860915 Motion to Reopen Record.Allegations W/O Factual Basis.Util s to Jn Grace Re Insp Encl

ML20214S127
Person / Time
Site:	Harris
Issue date:	09/25/1986
From:	Brombach T CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML20214S087	List: ML20214S083 ML20214S105 ML20214S127
References
OL, NUDOCS 8609290402
Download: ML20214S127 (11)

Text

\ ENCLOSURE 4 l 4 .

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

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CAROLINA POWER & LIGHT COMPANY

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and NORTH CAROLINA EASTERN ) Docket No. 50-400 OL

MUNICIPAL POWER AGENCY )

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(Shearon Harris Nuclear Power )

Plant) )

AFFIDAVIT OF THOMAS W. BROMBACH County of Wake )

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State of North Carolina )

Thomas W. Brombach, being duly sworn according to law, de-poses and says as follows:

1. 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 3 components, piping and their supports to ensure applicable requirements of ASME Code Section XI and 10 C.F.R. S 50.55(a) are met. I testified before the Licensing Board on November 12,

. 1985. See " Applicants' Testimony of Harold R. Banks, Roland M.

Parsons, George L. Forehand and Thomas W. Brombach on Evaluation and Reinspection of Work Performed by Employees Implicated in 8609290402 860925 PDR ADOCK 05000400 0 PDR

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6 Possible Drug Activity (CCNC Contention WB-3)," ff. Tr. 10,077.

My professional qualifications and experience are described in that testimony.

2. I have been actively engaged in NDE and inservice inspection 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 and Power Company 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. These du-ties formerly included direct supervision of Ms. Miriello. Be-ginning with my early training and experience in the United States Navy, I have seventeen years of hands-on experience in power plant operations, maintenance and testing.

3. The purpose of this affidavit is to address certain allegations raised in the Affidavit of Patty S. Miriello con-cerning quality assurance ("Miriello QA Affidavit"), dated July 28, 1986, which was submitted in support of " Motion to Re-open the Record Pursuant to 10 CFR 2.734 by Coalition for Alter-natives to Shearon Harris, Wells Eddleman and Conservation Coun-cil of North Carolina," dated September 15, 1986. I do not here attempt to address each of Ms. Miriello's allegations because l

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some of them are repetitive of those previously responded to in my affidavit dated August 6, 1986, which was filed in support of

" Applicants' Response to CASH's Show Cause Petition," dated August 15, 1986. I have reviewed the Miriello QA Affidavit and do not believe that it refutes the accuracy of my August 6, 1986 affidavit. In this affidavit, I shall demonstrate that Ms.

Miriello's QA allegations are without any foundation whatsoever.

4. Ms. Miriello acknowledges that Phil Temple and I offered her an opportunity to discuss any problems that she might want to discuss in her Quality Check exit interview of February, 1985. See Miriello QA Affidavit, 1 4, p. 2. I typi-cally speak with employees who are changing departments or who are leaving the site in order to ascertain whether they had any problems concerning their work or observations. If they do, I am interested in knowing what the problem was and whether they believe the problem has been resolved adequately. If they do not believe that the problem has been addressed and corrected, I ask them to describe the problem fully so that it may be inves-tigated and resolved. I offered Ms. Miriello this opportunity in advance of her exit interview, yet she declined my offer. By way of explanation, Ms. Miriello states only that: ... I felt that it would have been unwise for me to restate problems which I had already. brought,to their attention in the past." Miriello l

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4 QA Affidavit, 14, p. 2 (emphasis in original). Ms. Miriello further indicated that she did not believe that the Quality Check exit interview was of any value and she therefore did not mention that she had or knew of any problems with the plant at that time. Id. at Y 6, p. 3. Ms. Miriello thus refused two opportunities to express any concerns she may have had.

5. Before I address Ms. Miriello's concerns individually, it is noteworthy that Ms. Miriello's allegations are bound by a common theme. Each concern focuses on a problem of which Ms.

Miriello was once aware, but the subsequent resolution of which she may not have gained personal knowledge.

6. Ms. Miriello states: "In November 1984, [ Thomas Brombach] was told of Conam inspection personnel missing a row of steam generator tubes during the eddy current inspection."

While it is true that Conam initially failed to inspect a row of steam generator tubes, Conam identified and corrected the over-sight pursuant to procedures I imposed which required Conam to ensure that a record existed for every tube. Therefore, Conam did not report the missed row to CP&L, and there was no reason to do so. Had Conam failed to notice that it had missed a row of tubes, this would have been easily discovered and corrected upon CP&L's review of the eddy current tapes. Nonetheless, based on the information presented to me by Ms. Miriello, I

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instigated a review or the eddy current tapes of the steam gen-erator inspection to ensure that every tube had been inspected.

Each tube was properly inspected by Conam. In addition, CP&L later contracted with EPRI to conduct a 5% eddy current tape inspection review which verified the quality of Conam's inspec-tion.

7. Ms. Miriello alleges that the inspection reports on 10-20 welds are incorrect. See Miriello QA Affidavit, 1 4, p.2.

The basis for Ms. Miriello's allegation is her belief that these welds were inspected prior to being cut out and reworked, and that they were not reinspected subsequent to being so repaired.

See i.d. During the summer of 1984, with the initiation of the pre-service inspection program, it had become apparent that some welds were being reworked after pre-service inspection. I therefore asked Ms. Miriello to investigate that possibility.

It was then that Ms. Miriello discovered, as I had suspected, that a few welds had been reworked post inspection, without being reinspected. These welds were subsequently reinspected.

In order to correct this situation, CP&L and its contractors de-vised a new communications system consisting of daily morning meetings to ensure that all welds were reinspected after they ,

l had been reworked. In addition, all weld changes are docu-mented. These records are routed to Inservice Inspection l

("ISI") by controlled distribution, so that ISI is kept abreast of any welds that may require reinspection. CP&L is therefore 4

confident that its inservice inspection reports are complete, accurate and up-to-date.

5.

In conclusion, Ms. Miriello has identified past con-cerns which have already been identified and corrected, notwith-standing her lack of personal knowledge concerning these correc-tions. As such, Ms. Miriello's allegations are without factual basis.

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Thomas W.(Ercunba@

subscribed and sworn to before me this M ay of September, 1986 Notary Public Hy Cossnission Expi$es 8E 3f .

ENCLOSURE 5 Y V Cp&L Catchna Power & Light Company SHEARON HARRIS NUCLEAR PROJECT AU3141$26 P. O. Box 101 New Hill, North Carolina 27562 File Number: SHP/10-13510E Latter Number: Ho-860328 (0)

Dr. J. Nelson Crace NRC-469 United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest (Suite 2900)

Atlanta, Coorgia 30323 Dear Dr. Crace In reference to your letter of July 15, 1986, referring to RII:

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50-400/85-48-01, the attached is Carolina Power & Light Company's reply to the violation identified in Enclosure 1. -

It is considered that the corrective actions taken are satisfactory for resolution of the ites.

Thank you for your consideration in this matter.

Yours very truly, R. A. Watson Vice President Harris Nuclear Project RAW / css Attachment cci Messrs. C. Maxwell (NRC-SHNPP)

8. C. Buckley (NRC) l MEM/HO-8603280/ PACE 1/051

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Attachment to CP&L tter of Response to NEC Report RII: 50-400/85-48-01 Regereed Violation 10 CFR 50.554 paragraph (g) subparagraph (2) allows the licensee to use the American Society of Mechanical Engineer (ASME) Code Section XI, 1980 Edition with addenda through the winter 1981. Carolina Power and Light Company's Inservice Inspection Program delineated in Procedure Number ISI-201 Revision I, the ASME Code, 1980 Edition, with addenda through winter 1981.

Contrary to the above, Nuclear Energy Service, Inc. (NES) Inservice Inspection Procedure IST-501 (Rev. 1) and 157-401 (Rev. 1) were written to the ASME Code, 1980 Edition with addenda through winter 1982.

This is a Severity Level V violation (Supplement II).

Denial or Admission and Reason for the Violation:

The violation is correct as stated.

The voluntary upgrade to the winter 1982 addenda of the ASME Section XI Code, in Procedures IST-401 (Rev. 1) and IST-501 (Rev. 1), was done in the interest of keeping the SENPP ISI program up to date with current ASME code requirements. Notification to the NRC of CP&L's position to utilize the more stringent requirements of the winter 1982 addenda in the referenced NDE procedures, was not considered to be necessary by the personnel involved. -

Corrective Steps Takaa and Results Achieved:

A letter stating CP&L's position to utilise the winter 1982 addenda was submitted to the NRC (NER) on March 13, 1984 (Letter No. NLS-86-069). As of this date, no response has been received back from the NRC. 15I-201 is being revised to invoke 1980 Edition with addenda through winter 1982 for nondestructive testing and acceptance criteria.

coerective Steps Taken to Avoid Further Woncompliancet  !

ISI Personnel (Technical Support Unit) have been reinstructed in the requirements of 10CPR50.55a(s), to provide written notification to the NRC (MIR) when changes in ASME code commitments in the SHNPP ISI program are required.

Date When Full Compliance Was Achieved It is projected that a response indicating acceptance of CP&L's position will be received from the NRC (NRR) by September 15, 1986. Revision to ISI-201 is projected to be approved by August 22, 1986.

I Reinstruction of ISI personnel was accomplished on August 8, 1986.

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MEM/HO-8603280/ PACE 2/051

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ENCLOSURE 6

. V V C9&L Carolina Power & Light Compariy SHEARON HARRIS NUCLEAR PROJECT P. O. Box 101 AN 4 G86 New Hill, North Carolina 27562 File Number: SHF/10-13510E Letter Number HO-860331 (0)

Dr. J. Nelson Grace NRC-470 United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest (Suite 2900)

Atlanta, Georgia 30323 Dese Dr. Grace:

In reference to your letter of July 15, 1986, referring to RII 50-400/85-48-03, the attached is Carolina Power & Light Company's reply to the violation identified in Enclosure 1. _

It is considered that the corrective actions tchan are satisfactory for resolution of the itam.

Thank you for your consideration in this matter.

Yours very truly, i

R. A. Watson Vice President Harris Wuclear Project RAN/iae Attachtent

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ec: Messrs. G. Maxwell (NRC-SHNPP)

B. C. Buckley (NRC)

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MEM/H0-8603310/ PACE 1/051 l

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Attachment to CP&L Letter of Response to NRC Report RIIS 50-400/85-48-03 Reported Violation 10 CPR 50, Appendix B, Criterion V, requires that activities ,

affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these j instructions procedures or drawings. NES Preservice and Inservice I Data Control Procedure IST-101 Rev. 1, Paragraph 5.2.E. requires that corrections to data reports are to be completed by a single line drawn through the incorrect entry, initialed, and dated by the responsible individual when the correction is made.

Contrary to the above, on December 2-6, 1985, examination data sheets were observed where the NES Wondestructive Examination (NDE) Lead Examiner, had written " rewrite" on initial examination data sheets that had been signed by an NDE examiner and given a i

ontrol number. In some instances, technical entries of evaluations were changed on the rewritten data sheets.

This is a Severity Level V violation (Supplement II).

Damial or Adel_sion s and Reason for the Violation:

The violation is admitted as stated.

The reason for the violation can be attributed to misinterpretation of procs. dural requirements by the 151 personnel involved. The subject rewrites of data sheets were performed to correct excessive errors as required to create a clear and

' accurate final record. The involved personnel interpreted paragraph 5.2 of IST-101 to allow rewrite of data sheets during the initial review, when in fact paragraph 5.2.C only allowed rewrites prior to entering the review cycle.

Corrective Stsee Taken and Results Aehleved:

The rewritten data which was maintained in a segregate file has been reviewed against the final Weld Inspection Data Packages and incorporated with each file. The differences between these records have been reviewed and the final package reflects the baseline condition of the welds. The corrected data sheets haveIn been reviewed and stand as the final QA document for record.

the future process data sheets will be corrected pursuant to procedure 15T-101, paragraph 5.2.E.

MEM/H0-8603310/PAGE 2/0S1

Corrective Steps Ta E to Avoid Further Ecetempliance:

Applicable personnel have been instructed in the proper use of CP&L Procedure IST-101 and the correct means by which revisions to inspection data can be made pursuant to paragraph 5.2.C 5.2.E, and $.2.0 of IST-101.

Date When Full Compliance Was Achieved I

Full compliance was achieved on February 1, 1986. 1 NEM/H0-8603310/ PACE 3/051