United States Nuclear Power
Federal Regulations, Codes, & Standards
Users Group ©
Doug Ramey Interview
Guest Name: Doug Ramey
Company: Energy Northwest
Plant Name: Columbia Generating Station
Position or Title: Principal Engineer
ASME Section XI/OM Code of Record: 1989 Edition
ASME Section XI/OM Inspection Interval and Period: 2nd Interval, 3rd Period
E-Mail Address: firstname.lastname@example.org
Phone Number: (509) 377-2298
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.?
Ramey: ISI and IST are in two separate departments. IST is in the technical services department under operations and ISI is in the materials department under engineering. The materials organization also includes the NDE services.
The Program Lead Engineer is responsible for all Code repairs/replacements (Section XI and Section VIII).
NDE services has three NDE specialists and one NDE lead. They are responsible during outages for field supervision of all NDE work, which includes ISI, FAC, and eddy current. Non-outage time is spent on NDE examinations, Infrared surveys, and Flow measurements, among other tasks.
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?
Ramey: Essentially all NDE is done in house during non-outage periods. During outages very little in house personnel are used for NDE due to their responsibilities of supervising vender personnel.
Question: What changes have you made in your organizational structure or reporting functions that you have found to be beneficial?
Ramey: The biggest benefit we found was separating the ISI and IST functions and placing them in organizations with similar functions. IST is a function concerned with operations and testing so placing it in the operations department makes sense. ISI and NDE are concerned with material conditions, so placing these functions in the materials group made sense. With this change, which was made over 15 years ago, I feel we developed 3 very strong areas.
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?
Ramey: We implemented an RI-ISI program for Code Category B-J welds using the EPRI method. We performed the first examinations under this program at the last refuel outage. I believe we saved enough to have paid for the development costs during that outage. In addition we avoided several Rem exposure. The biggest benefit I see to this program is we are examining areas based on damage mechanisms and risk, which increases the plant safety. This has been the biggest positive change to ISI in my 20-year association with ISI. We did not have major unexpected problems associated with developing the program. We received one request for additional information.
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?
Ramey: Yes. We submitted several relief requests that were approved. We adapted the EPRI relief requests to our needs, which did save us preparation time.
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?
Ramey: No. We are a Code plant and have had no difficulty with boundaries.
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?
Ramey: We do not plan on implementing entire later editions and addenda. We did request to update our program to portions of later editions and addenda.
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?
Ramey: We do not make it a policy of sharing calibration blocks.
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?
Ramey: We are working longer hours. We bring in more people to do the job. We have supplemented our staff on a very limited basis.
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?
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?
Ramey: We developed software in 1978 to manage our ISI program during the PSI and into the ISI phase. About 10 years ago we converted this software into Paradox. We are exploring converting it into Access in the next several years. The software more than meets our needs.