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Guest Name: Charles M Ross
Company: British Energy
Plant Name: Sizewell B
Position or Title: HQ In-Service Inspection Engineer
ASME Section XI/OM Code of Record: ASME XI 1989 Edition with 1990
ASME Section XI/
E-Mail Address: firstname.lastname@example.org
Phone Number: +44 (0) 1452 653115
Question: How many personnel do you have in your ISI/IST organization and how are the responsibilities distributed between the ISI/NDE, Risk Informed, Pump and Valve, Containment, System Pressure Test, Snubber, Repair/Replacement Programs, etc.?
Ross: IST: (at Sizewell) 1.5 persons, ISI: (at Sizewell) 2 persons, (at HQ) 2 persons, Containment ISI (at Sizewell) 1.5 persons.
Question: How much of the NDE is actually performed by your organization, if any, in lieu of utilizing outside vender support, and if so, what savings have you recognized by using your in-house personnel?
Ross: NDE in-house 6 persons, contract up to 30 persons during outages. In-house managing NDE contracts and involvement in high tech inspections. British Energy (BE) personnel along with contractors (Wesdyne, Roll-Royce, Technatom, Framatome etc.) develop and perform specialised/specific inspections. All manual NDE performed by contractors.
Question: What changes have you made in your organizational structure or reporting functions that you have found to be beneficial?
Ross: None that spring to mind.
Question: What issues proved to be very difficult, costly, or troublesome to resolve, and what would you recommend to avoid those issues in the future?
Ross: A huge amount of time is spent on assessing restrictions to test (UT), particularly on No-Break Zone (NBZ) welds, of which we have over 500 and all require 100% UT coverage. Restrictions are due to physical obstructions (hangers, pipe bends, valves and poor weld profile). I do not see how we can avoid this issue, unless we could apply risk-informed ISI to these welds. Unfortunately that is a long way off!
Question: What code cases or relief requests have you implemented that have proven to be very helpful and cost effective?
Ross: The best Code Case is N-416 alternative to pressure test on repairs. The reduction of the reactor coolant pump flywheel inspection requirements is a big saving.
Question: Has your organization implemented a risk informed ISI or IST program, and if so, what Code Cases or methodology did you incorporate and what benefits and savings have you realized? What was the scope of the program and the approximate costs to develop the program? Were there any unexpected problems encountered while developing the program? Did you receive any requests for additional information from the NRC and has your program been approved?
Ross: No, not for ISI. We are currently having discussions with our Regulator concerning the application of RI-ISI, but it will be a few years yet before we will be in a position to apply. For IST, we will be applying risk informed for the second inspection interval, which starts in September 2005. Work is currently underway in producing our RI-IST programme.
Question: What form of training has proven to be the most successful for your group; in-house instruction, vendor instruction, organizational instruction (EPRI, NSSS, etc.), conferences, technical meetings, online learning, etc.? What ISI/NDE training seminars are you considering for attendance in the near future?
Ross: The biggest headache and the most successful is the pre-outage equipment commissioning for automated UT on full-scale test pieces, personnel briefing and procedure training. Due to the extent of automated inspection we employ, this is a huge task. We run in-house courses both for our own staff and outside contractors in the use of our data acquisition systems for automated inspections. For me ISI/NDE training includes in the next 6 months: renewal of NDE qualifications (Level II/III) and attendance at ASME XI Code meetings.
Question: What new NDE techniques, technology, or special NDE situations have you encountered recently and were they successful?
Ross: BE employs automated UT for all Class 1 weld inspections (major components & pipework) with the operation of the manipulators being from outside the containment building. This was a commitment made prior to the construction of Sizewell to ensure reduced dose levels and repeatability of PSI/ISI. As discussed above, it is major area of work for BE in terms of cost, technical specialist requirements and man effort preparing for each outage.
Question: Has your organization implemented the requirements for ASME Section XI, Appendix VIII, of the 1995 Edition with the 1996 Addenda? Did you utilize the recommended EPRI format for relief requests, and if so, which ones? What is the approval status of your relief requests and what problems or successes have you encountered in implementing Appendix VIII?
Ross: Appendix VIII is not applied at Sizewell. BE has its own requirements for validation of NDE personnel, procedures & equipment. This involves use of an external organization for our equivalent of PDI.
Question: What do you find to be the most difficult part of your job?
Ross: Explaining the intricacies of ISI to non-ISI personnel.
Question: What do you find to be the most rewarding part of your job?
Ross: Developing a new manipulator for an inspection with it successfully getting through validation and then performing as planned, the required inspection.
Question: What have you found to be the most humorous experience on the job?
Ross: The banter between personnel, when everyone is stressed at the peak of the outage programme. It makes the outage bearable when everyone is working 14 hour 7 day weeks. The humorous “alternative” outage flyer.
Question: Have you had any difficulties or questions regarding the code classification of system components or establishing the code classification boundaries? If so, what difficulties or questions did you encounter and how did you resolve the issues? What technical positions did you take?
Ross: Not applicable.
Question: Have you had any difficulties or questions applying the Section XI Repair/Replacement Rules to components, spare parts, etc., and if so, what difficulties or questions did you encounter and how did you resolve the issues? What technical positions did you take?
Ross: We have had real problems with the Repair/Replacement Rules to such an extent we will be employing US consultants to help us out. If you require more information, please let me know as this is outside my area of expertise.
Question: Does your organization plan to implement a Section XI edition and/or addenda that is later than currently required in 10 CFR 50, and if so, what benefits do you anticipate?
Ross: We are not tied to 10CFR50. For the second inspection interval we will probably use the Section XI 2001 Edition with the 2003 Addenda, as that will be the latest version in place 12 months prior to the start of the interval.
Question: Do your NDE procedures include a methodology for calculating the examination coverage for limited examinations, and if so, how is this calculation performed and what considerations are included?
Ross: Yes, for UT the calculation is based on the % weld circumference inspected and the % weld volume swept by the beam axis. The main consideration is the reduction in defect detection capability. It should be noted that Sizewell are required to cover 100% of the pipework welds volume rather than just the inner third, as stipulated by ASME XI.
Question: Does your plant share any calibration blocks on a regular basis with other plants outside of your organization, and if so, what types of blocks do you share and who do you share them with?
Ross: No, we do not share calibration blocks as all blocks are manufactured specifically for Sizewell. Sizewell is the only PWR within BE, all the other plant are gas cooled reactors. It should be noted that the test blocks used for validation and development of new inspections are also Sizewell specific, which makes everything bloody expensive, as there is no sharing with other plant.
Question: As outages become shorter and shorter, how are you able to handle your ISI workload during the outage? Are you supplementing your staff with additional temporary personnel or are some tasks getting deferred?
Ross: Generally all the outage scope is completed. In 2000 the Sizewell outage did have a clash with outages at our other plant, which resulted in a severe shortage of manual UT personnel. We then had to defer some of the required inspections to the next outage in order to meet the planned outage end date.
Question: Has your current or prior organization ever lost accountability of their ISI/IST program due to inadequate record keeping, non-documented plant modifications, etc.? What activities were lacking that led to the situation? What efforts were required to reconcile, verify, and/or validate the database to get the program back to a state of confidence? What controls were put in place to ensure that such an incident would not occur again?
Ross: Yes, it was found at our second outage that there were pipework integral attachments that were not identified in the ISI programme. It was a result of the information not being passed between the division responsible for the construction of the plant and the division responsible for operation. It is incredible that Sizewell went back to power following the outage when the problem was identified. If we had a Regulator with any balls, he would have shut them down until the location of every integral attachment had been identified. We are still sorting this one out two years later!
Another issue was inspection of the welds between the containment liner and penetrations and certain of the welds on the containment penetration sleeves. The containment ISI (IWE/IWL) is identified in a separate programme to all the other ISI. The containment inspections are managed by our Civil department and the other inspections by our Mechanical department. Both departments assumed the other were looking after the aforementioned welds, with the result they were not identified in either ISI programme. This has given us major problems resulting in personnel performing visual inspections at the last outage of all the penetrations, to confirm the existence of welds as shown on the drawings. We are still trying to sort out this one!
There is a real lack of confidence in the state of our ISI programme. We need a huge increase in resource to sort it out.
Question: What type of software do you use to track and analyze ISI program commitments and inspection data? Was the software developed by your organization or purchased from a vender? Does it adequately meet your needs? If not, why not?
Ross: Sizewell have their own database, which lists all the inspections required (the ones they know of!) and tracks the inspections performed against the ISI programme schedule requirements. There is a company wide Outage Management Database (OMD) which not only tracks all the inspections at our eight stations, but also holds information on results of inspections, acceptance of inspection results and actions taken. This database which is internally developed is the main tool for the management and control of all ISI throughout the company. The database is also used for the control of preparation (grinding) of welds for inspection, tracking insulation removal and providing the history of the inspections of each weld from day one. It meets our needs very well, but like most things there is always room for improvement.