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Company: Southern Nuclear Operating Company
Plant Name: Plant Hatch (2 unit BWR)
Position or Title: Senior Engineer / ISI, BWRVIP, and R&R
Coordinator, Pressure Test
ASME Section XI/
ASME Section XI/OM Inspection Interval and Period: 4TH
Interval for both will start on
E-Mail Address: email@example.com
Phone Number: (912) 366-2000, x3632
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.?
start with R&R.† Currently, we have
5 personnel who may complete all documentation and perform all reviews, and
they are classified as
Next, we have 11 personnel who may generate an R&R plan, and they are classified as Qualified Individuals.† They generally are personnel who have a good working knowledge of what constitutes R&R, and they may also complete the normally required operating pressure test packages that go hand in hand with most R&R activities.
Next, we have 13 personnel who may answer some to all of the questions on a screening form to evaluate if work is R&R or not.† These personnel are generally planners who are involved in work order packaging and generation.
As far as ISI, Iím the Site Coordinator, and there are several people at SNC Corporate who provide assistance and outage support as necessary.† Most of the pressure testing performed that Iím involved with are the ISI Pressure Tests, and as Pressure Test Engineer, I coordinate most of them, as well as performing a good deal of the inspections.
For IST, we have an IST Coordinator and a component engineer for relief valves and check valves.† The IST Coordinator and component engineers track the IST testing of valves and pumps as applicable.† Coincidentally, the IST Coordinator is also the Appendix J, or LLRT, Coordinator.
For snubbers, we have a snubber component engineer and program owner, but we also have a relief request to use our own snubber program, which gets us out of VT-3ís on snubbers, as well as any IST testing of them.† Admittedly, Iím not as familiar with how much IST governs our snubber program, although the snubber program owner is a member on various O&M groups.
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?
Fechter: We have 6 Code certified NDE personnel, and all of the non-outage work is performed by them.† During an outage, weíll bring in some additional contractors for general NDE, like weld exams, pressure testing, etc. .† Other than ISI Pressure Tests, most of the ISI performed during the outage will be done by GE personnel, and all of the IVVI will be performed by GE or a subcontractor of theirs.† There has been an increasing effort to use fewer and fewer contractors, and we have been bringing in fewer extra NDE personnel during the outages.† Not sure about savings, but I know itís there, as well as convenience, having our own in-house personnel.
Question: What changes have you made in your organizational structure or reporting functions that you have found to be beneficial?
Fechter: We really havenít made any changes in this area.† While SNC is going to go thru a reorganization, that is on a company wide level at all 3 SNC sites (Hatch, Farley, Vogtle).† These changes are being made more so for business reasons than reporting functions.
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?
Fechter: In September 2003 we implemented a new computerized work management system onsite at Plant Hatch, and I had to figure out ways to make it work with the R&R procedure and program.† But the issues I dealt with are so site specific that I canít think of suggestions to benefit personnel outside the company.† Plant Farley and Vogtle will be implementing this same system later in 2004.† The only point I can think of is make sure you evaluate how the computerized system will interface with your program/procedure, and with who can sign for what on electronic versus hard copies of work orders and other documentation.
Question: What code cases or relief requests have you implemented that have proven to be very helpful and cost effective?
Fechter: I believe that the relief request to use Code Cases N-416-1, N-508-1, and N-532 have been the most beneficial from an R&R standpoint.† Since we can now use N-416-2, which doesnít have the surface exam of the root pass requirement, due to it being accepted in Reg. Guide 1.147, we can also get out of that exam in addition to exempting the hydro.
N-508-1 has been used some but not a whole lot.† Weíre still doing a lot of mechanical to hydraulic snubber swap-outs.
N-532 has definitely saved the most time with the ease of its administrative requirements.† Even the new NRC caveat of having to get the OAR-1 Report submitted within 90 days doesnít create a problem.
We have a good deal of relief requests for ISI, but they are too numerous to list here.† I wouldnít expect that we have anything out of the ordinary here, though.
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?
Fechter: I know personnel at SNC Corporate are evaluating the implementation for risk-informed ISI for Plant Hatch, but that effort is being done on a programmatic level at SNC Corporate.† The program, as I understand it, should be in place by the end of 2004.
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?
Fechter: Experience has been the
best training, but Iíve had to evaluate and develop some in-house training on
R&R due to our new work management system and to ensure that personnel
completing documentation within the program are performing it adequately and
correctly.† Several personnel at Plant
Hatch and SNC Corporate have attended the ASME sponsored SC XI class, and I
attended this in 1998.† I have also
attended a Proto Power R&R training class in 1998.† Several personnel from SNC Corporate and
the sites attend SC XI and O&M Meetings.†
The EPRI RRAC (
Question: What new NDE techniques, technology, or special NDE situations have you encountered recently and were they successful?
Fechter: I donít think Iíve run into any new ones in the recent past.† I know this past Unit 1 outage Tecnatom came in with GE and some special equipment to do some exams on our jet pumps and core shroud.† But, I donít think their technology was new per se to the industry.
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?
Fechter: We have used this, but most of this has been performed at a programmatic level at SNC Corporate.
Question: What do you find to be the most difficult part of your job?
Fechter: Outages are definitely the most difficult time on the job.† Now that Iíve picked up ISI and BWRVIP Coordinator, itís gotten busier.† The RPV leakage test is also mine.† Implementing program and procedure changes to address the new electronic work management system has been pretty difficult, too.
Question: What do you find to be the most rewarding part of your job?
Fechter: The opportunity to apply
SC XI to real plant situations and workin
Question: What have you found to be the most humorous experience on the job?
Fechter: Wow, this is a different but refreshing question.† I guess seeing all the random characters and personalities that are onsite is pretty funny and interesting.
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?
Fechter: No, Iíve never seen this to be an issue.† Several years before I got to Plant Hatch, the site in conjunction with SNC Corporate developed SC XI Boundary drawings.† These make it very easy to determine if a component or piping is within the SC XI boundary.† These SC XI Boundary drawings were further modified and divided into boundaries for the various ISI Pressure Tests which have to be performed.
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?
Fechter: Between the personnel onsite and at SNC Corporate, weíve been able to work thru the issues Iím aware of.† Most of the time itís not so much difficulty in applying the rules or knowing if you have to apply them, but when we discover a post-R&R functional test is missed.† This has usually been a missed VT-2.† So, you document the situation with a condition report, and perform the pressure test as soon as possible and practical.
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?
Fechter: No, weíll use the latest approved edition/addenda noted in 10CFR50.55a.† Right now since we donít have to update at Plant Hatch until 2006, there may be a change past the 1998 Edition with 2000 Addenda.† The same will go for O&M.
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?
Fechter: Most of this type of ISI NDE is performed in accordance with SNC Corporate procedures, and while Iíve administratively processed them onsite, Iím not as familiar with them.† I do know that between these procedures, the Code, and personnel at SNC Corporate, the issues involved with examination coverage when there are obstructions or other limitations are evaluated.
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?
Fechter: No, I donít think we share cal blocks outside SNC.† Iím pretty sure we share within SNC though between Hatch, Farley, and Vogtle.† Several of the same personnel from SNC Corporate go to each of the sites regularly or as special needs arise to coordinate and perform ISI NDE as necessary.
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?
Fechter: No, you just have to buckle down and handle it.† The number of site and corporate personnel is staying the same, and may eventually get smaller as personnel retire or get downsized.† If the ISI scope is larger, weíll bring in more GE contractors, but we bring in GE now, anyway.† Same thing for larger scope IVVI outages.† As far as deferrals, you can only defer things so long.† When we went to 24 month cycles from 18 month cycles, we lost an outage.† When you couple that with some deferments, we have necessarily ended up with large scope ISI and IVVI outages in 2005 and 2006.
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?
Fechter: We have never lost accountability on any kind of sizable scale.† From time to time, we have missed a pressure test, or an activity may have been classified as not R&R applicable when in fact it was.† And then this again leads to possibly missed pressure tests or other required NDE.† Just about every situation Iíve had to address with various corrective actions has resulted from Human Performance.† I have tried to address these items with procedure revisions to make the procedure simpler and easier to use.† Also, with the new electronic work management system, Iíve incorporated automatically inserted reviews for personnel within our R&R program so that when a work order is generated, the reviews are automatically inserted into each work order based upon the specific component designation.† Over the last year and a half, we have been doing much better.
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?
Fechter: Iím not sure of any special software to track ISI program commitments.† We have some very knowledgeable personnel at SNC Corporate who are responsible for the ISI Program generation and maintenance.† From the ISI Program and Plans, I track ISI Pressure Test completion.† As far as R&R, which I suppose is a subset of ISI, thereís not been a specific need seen to have a software method of control and tracking.† But, I do maintain an Access 1997 database of R&Rís performed, which serves to assist me with generation of the NIS-2A Index to File report.