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Mark Ferlisi Interview

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Introduction

Guest Name: Mark J. Ferlisi

Company: Duke Energy Corporation

Plant Name: Oconee Units 1, 2 , & 3; McGuire Units 1 & 2; and Catawba Units 1 & 2

Position or Title: Senior Engineer (Containment ISI Plan Owner)

ASME Section XI/OM Code of Record: (Containment ISI Only) ASME XI 1992 Edition, 1992 Addenda. Other Section XI/OM Codes used vary by plant.

ASME Section XI/OM Inspection Interval and Period: Varies

E-Mail Address: mjferlis@duke-energy.com

Phone Number: (704) 382-3923


Interview

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.?

Ferlisi: Not sure. For Containment ISI Program, we have approximately 1-2 full-time positions assigned to program development, implementation, and program management for our three sites. I do not have information on personnel involved with other ISI programs at this time. The Containment ISI Program is managed within our Engineering organization. As such, engineering personnel also have other responsibilities outside of ISI.

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?

Ferlisi: I believe that most of our NDE work is performed in-house by Duke personnel. However, we augment our staff as needed to support outage inspection work, so we do use some contract labor.

Question: What changes have you made in your organizational structure or reporting functions that you have found to be beneficial?

Ferlisi: For the Containment ISI Program, we have not made any recent changes. However, we found that our Engineering organization was best suited to develop and implement this program. After initial development, it was decided that the program should remain within our Engineering organization and we have found this to be a good fit. Managing this program for all three sites within a single organization has resulted in uniform implementation of Code and programmatic requirements.

Question: What code cases or relief requests have you implemented that has proven to be very helpful and cost effective?

Ferlisi: For Containment ISI, we have not utilized any Code Cases, but we have submitted a number of Relief Requests pertaining to ASME Section XI, 1992 Edition with the 1992 Addenda which we have found to be both cost-effective and beneficial. The following requests were most beneficial:

1. Request for Relief (pursuant to 10CFR50.55a(a)(3)(ii)) eliminating VT-3 examination requirements for IWE-2500, Table IWE-2500-1, Category E-D, Items E5.10 (Seals) and E5.20 (Gaskets).

2. Request for Relief (pursuant to 10CFR50.55a(a)(3)(ii)) eliminating bolt torque or tension tests for IWE-2500, Table IWE-2500-1, Category E-G, Item E8.20.

3. Request for Relief (pursuant to 10CFR50.55a(a)(3)(i)) allowing the use of alternatives to the requirements of IWE-2500(c)(1) through (c)(4). The alternatives clarified requirements for VT-1 visual examinations and UT examinations on surfaces subject to examinations in accordance with Table IWE-2500-1, Category E-C. Visual examinations are required only on those surfaces that are accessible and subject to augmented examination, and UT examinations are required only when surfaces subject to augmented examination are not accessible for visual examination.

4. Request for Relief (pursuant to 10CFR50.55a(a)(3)(i)) allowing the use of alternatives to the requirements of IWA-2210 and IWA-2310(a) and (b). In lieu of these requirements, we use a 1/32" black line on 18% neutral gray card for VT-3 and VT-3C procedure demonstration and a 1/64" black line on 18% neutral gray card for VT-1 and VT-1C procedure demonstration. Illumination requirements were eliminated.

5. Request for Relief (pursuant to 10CFR50.55a(a)(3)(i)) allowing the use of sampling plans for ultrasonic thickness measurement of containment surfaces in accordance with Table IWE-2500-1, Category E-C, Item E4.12.

6. Request for Relief (pursuant to 10CFR50.55a(a)(3)(i)) allowing the use of a VT-1 visual examination in lieu of the VT-2 visual examination required by IWE-5240 following repair/replacement activities. This VT-1 examination does not need to be performed during the system pressure test.

7. Request for Relief (pursuant to 10CFR50.55a(a)(3)(i)) eliminating visual examinations required by IWE-2200(g) and IWE-2500(b) associated with removal of coatings and reapplication of coatings on containment surfaces. Our Coatings Program is used to control the quality of coatings maintenance activities on these surfaces.

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?

Ferlisi: Most of our training is provided in-house. Some training specific to IWE/IWL requirements has been provided through ASME and was beneficial. We are considering additional ASME Section XI training in the future, but I'm not aware of any other ISI/NDE training that is planned.

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?

Ferlisi: Not sure.

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?

Ferlisi: Generally, establishment of Code boundaries and Code classifications has not been a problem. We document Code classifications and boundaries on controlled documents.

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?

Ferlisi: We have had some difficulty in applying R/R requirements for metal and concrete containments. The requirements of IWE-5000 are not entirely clear as to which repair/replacement activities require system pressure tests. For example, we consider replacement of Class MC pressure retaining bolting to be repair/replacement activity, but it is not clear that this activity is exempt from system pressure testing (although it is for Class 1, 2, and 3). At this time, we have taken a conservative approach until such time that ASME can clarify this issue. We perform a VT-1 visual examination in lieu of a VT-2 visual examination, as permitted by one of our Relief Requests.

Other areas of concern involve how the system pressure test required by IWE-5000 (which could be deferred for as long as 10 years) is to be documented as completed on the NIS-2 Form when it is permissible to defer this pressure test for certain types of R/R activities. Administratively, it is not desirable to keep an NIS-2 Form open for this long, so we have allowed the NIS-2 Form to be completed by documenting that the required system pressure test (that required by 10CFR50, Appendix J) shall be performed in accordance with 10CFR50, Appendix J. When a pressure test may be deferred, we do not require that the NIS-2 Form remain open until the test is completed.

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?

Ferlisi: For Containment ISI, we plan to continue using the 1992 Edition with 1992 Addenda (with approved Relief Request provisions) until the end of our 1st Containment ISI Interval. We have established a common Containment ISI Interval for all seven of our units that has been very cost-effective and will facilitate adopting later editions and addenda of Section XI when 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?

Ferlisi: We anticipate increasing difficulty with performing ISI work during outages and are performing more of this work during plant operation to accommodate this. We continue to manage our work reasonably well using permanent staff and temporary personnel. Having seven units allows us a little more flexibility because we can keep inspection/NDE personnel busy during most of the year. During a typical year, we normally have 4 or 5 refueling outages.


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