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Mike Blew Interview

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Introduction

Guest Name: Michael W. Blew

Company: Progress Energy – Carolina Power & Light

Plant Name: H. B. Robinson, Unit 2 (RNP)

Position or Title: ISI Coordinator

ASME Section XI/OM Code of Record: ASME Section XI, 1995 Edition, and 1996 Addenda

ASME Section XI/OM Inspection Interval and Period: Fourth Interval, First Period (Starts 2/19/02)

E-Mail Address: mike.blew@pgnmail.com

Phone Number: (843) 857-1527


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.?

Blew: Robinson is set up as follows:

ISI

Engineer A

Eng Programs

NDE

Engineer B

Eng Programs

System Pressure Test

Engineer B

Eng Programs

Repair/Replacement Programs

Engineer B

Eng Programs

Risk Informed

Not applicable at this time

Not applicable

Pump and Valve

Engineer C

Eng Programs

Check Valve Program

Engineer C

Eng Programs

Relief Valves

Engineer C

Eng Programs

Containment (IWE/IWL)

Engineer D

Eng Programs

Snubber

Engineer E

Rapid Response

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?

Blew: Currently, the Engineering Programs Group performs no physical nondestructive examination.

Non-Outage - RNP plant QC (2 persons) performs NDE as required as a result of a repair/replacement activity. These examinations are typically VT-1, VT-2, VT-3, PT & MT. If UT is required, RNP would rely on bringing a qualified person from a sister plant (shared resource). If RT were required, RNP would contract outside resources.

Outage - The applicable ISI NDE vendor would perform the UT required as a result of a repair/replacement activity.

RNP is currently aligning its implementing procedures for the Fourth Interval starting on 2/19/02. The implementing plan identifies performing online examinations outside containment by RNP plant QC for VT-1, VT-2, VT-3, PT, MT and UT. This would reduce reliance and cost associated with vendor contract support, but would not eliminate it. RNP QC would be implementing approximately 20 to 40 percent or more of a typical outage work scope, leaving the more complicated exams for contract resources. Outages are planned as major scope being inside or outside containment. Based on the increased costs associated with outside resources, due to the implementation of Appendix VIII, this was deemed an acceptable alternative to having outside resources perform 100% of the outage scope.

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

Blew: There have been no changes in our organizational structure or reporting functions since the Engineering Programs group was initiated in 1998. The Engineering Program includes the following programs;

ISI, IST/Check Valve, IWE/IWL, MOV, AOV, Welding, and Appendix J

Other programs that are assigned outside the programs group are;

Snubbers and Eddy Current

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?

Blew: Updating a program from one code to a new code may sound insignificant, but in fact is a major project that requires significant resources from within a utility. Some code updates from the past were accomplished in a relatively short period of time with little impact on resources, but newer updates have cost considerable time and dollars associated with updates. RNP has completed the ASME code update from the 1986 Edition to the 1995 Edition, 1996 Addenda. This encompassed approximately 260 primary procedure changes and ancillary procedure changes as well as the program and plans for ISI/IST.

Bolting examinations have consumed considerable resources and dose associated with these examinations. Some plants have even been required to perform these examinations by regulators, even though they do not operate with a borated water environment. The process required when boric acid is identified can triple the dose at a specified location for trivial amounts of boric acid. Once identified, an engineering evaluation is required to resolve it. These safety related systems are walked by system engineers on a quarterly basis, operators on daily rounds, but along comes ASME and requires insulation to be removed, bolting examined, and evaluated if boric acid is present, even though the "system" may be borated, but this valve is on a drain leg which contains no fluid during operation, and provides no safety function. Seems there has to be a better way.

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

Blew: We have several relief requests/code cases that have been initiated for the Fourth Interval. One deals with the ASME Requirement to pressurize the entire Class 1 boundary at or near the end of the interval. This presents a problem with alignments such as two check valves in series (accumulator lines) with the latter being the Class 1 boundary. One could use jumpers but that conflicts with Plant Technical Specifications to maintain RCS integrity in mode 3 when the pressure test is being performed. Older plants that do not have dual isolation on vents/drains have to open the isolation valve and pressurize to the Class 1 boundary, which is the cap. Then close the valve and leave the portion of the pipe from the valve to the cap with a pressurized slug. Then come back when the RCS is depressurized, (next RFO) and open the drain again to release the pressurized slug of water.

A web site posting relief requests from all utilities would be a tremendous help for ISI/IST personnel. The ASME Code has so much information; it is difficult to be absolutely sure that all areas for relief have been identified. The web site would be a great asset when building a ten-year program to benchmark against. No one likes last minute relief requests, but as we all know they happen. It can also serve as an exchange point for ideas between ISI/IST personnel via a message board.

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?

Blew: RNP has not, and probably will not implement a risk based examination scenario for ISI or IST. For ISI, we do not see a payback on the investment cost when realistic dollar and dose values are incorporated into a cost benefit analysis. Of the dollar numbers I have seen utilized by other utilities invoking risk-based examinations, they are grossly inflated to show a quick dollar return and dose savings. I have seen values as high as $8K per examination point. Our mean average cost including set-up, NDE and restoration is approximately $1K per examination point. For plants with relatively high radiation levels (BWR) that dollar return is much faster compared to low dose plants (PWR). I have not seen the dollar amounts associated with maintaining these programs, which are on a level of effort basis, but need to be factored in.

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?

Blew: Open forum conferences where exchanges of ideas would seem to be the most beneficial. Over the years I have not seen any of this kind of seminars. Code meetings are too formalized and vendor training where they read the code is not worth the effort.

Question: What new NDE techniques, technology, or special NDE situations have you encountered recently and were they successful?

Blew: None. PDI has cost utilities a fortune. First we fund the research to EPRI, then EPRI charges vendors to qualify to PDI, and then the vendors double the rates to perform these exams for the utilities. I would say 90% of the NDE personnel, who had ultrasonic certifications prior to PDI, have passed PDI and are performing exams currently. Are we finding that previously performed exams are bad, NO, are we finding cracks or indications that were not previously found, NO. Like I said, very, very expensive.

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?

Blew: Yes, we will implement the 1995 Edition with the 1996 Addenda on February 19, 2002. I do not know if the vendor who built the ISI/IST program utilized the EPRI format for proposed relief requests. If there are relief requests associated with the implementation of Appendix VIII requirements they were not identified to us. Our fourth interval program has been submitted and we are waiting a response from the regulators. We encountered a problem with Supplement 6 on the reactor vessel head. Our head is 7.75" thick and the PDI procedure is only qualified to 7.64", which required us to invoke a last minute relief request just prior to our final outage of the interval. Not good. I know there are others in the industry that have heads thicker than ours and are in a quandary as to what to do. Relief is the best option at this point.

Question: What do you find to be the most difficult part of your job?

Blew: Working with an older plant (B31.1) has significant challenges. ASME Section XI is under the assumption that all nuclear plants were built to ASME Section III, which is not the case for all of us in the industry.

Question: What do you find to be the most rewarding part of your job?

Blew: Trying to build a program, essentially from scratch, to be ultimately flawless.

Question: What have you found to be the most humorous experience on the job?

Blew: Haven’t had any humorous experiences in the 21 years of being in nuclear, too much stress, but we laugh whenever we can.

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?

Blew: Yes, yes, yes. Code boundary classification can be much more clear than it currently is. It is currently very subjective and open to interpretation.

What do you do when you have a Class 2 line that is in the Program, based on size and thickness, and it drops (via a reducer) in size to an exempt size, and the enlarges to a larger size (via a reducer) and connects to a tank/vessel? We take the position that once the size drops to an exempt size, that’s where the application of ASME rules for surface/volumetric examination ends. We would still apply the rules for pressure testing and repair/replacement to the end of the Class 2.

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?

Blew: Repair/Replacement has always been a technical nightmare at older plants. Code reconciliation’s, NIS-2’s, suitability verifications, hydro or not hydro, Construction Code requirements vs. ASME Section XI, pulling purchase orders, etc. We spend a tremendous amount of time proving that what we are doing is correct. Very costly and time consuming.

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?

Blew: No.

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?

Blew: No procedure is currently in place, but one is under development. Here is another area where we expend a tremendous amount of time to produce plots, determine coverage areas, submit costly relief requests and there is no added benefit when complete, other than to say we had a limited exam due to a physical configuration (pipe to valve). When older plants were built, the idea of performing ultrasonics was not considered throughout the design and configuration of the plant. Older plants have a significant number of "as welded" conditions that hamper complete coverage. Dose and dollars associated with "flat topping" welds is prohibitive, so we end up with more than a few limited exams. Examinations are performed, and always were performed to the extent practical. Now, massive amounts of data are gathered to identify limitations, which has not done anything but feed the paper machine and require more scrutiny from the regulators. If an exam was limited in 1982, it is still limited in 2001. True maybe they only did a 45° exam in 1982 and now the hit the weld with an arsenal of transducers, 45°, 60°, & 70°, create massive amounts of drawings to show the limitation, maybe covered more CRV, but the exam was limited in 1982 and it is still limited in 2001.

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?

Blew: Yes, we do not have a pressurizer vessel block and have to borrow it from Turkey Point.

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?

Blew: RNP utilizes shared resources from our sister plants. The NDE paper generated from an outage for ISI, required reviews and approvals, indication evaluation, processing and final report consume a tremendous amount of time. Personnel get stretched thin and accuracy and quality of vendor NDE paper is critical. We perform NDE on components outside containment during plant operation to reduce the outage workload.

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?

Blew: Luckily it does not appear that RNP fell into the lost accountability trap. We have built a database and have loaded examinations back from the first refueling outage. We still have a tremendous amount of work to do, but we do as much as we can do in a day to improve the program.

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?

Blew: Currently we utilize an access database, constructed in-house. We used Raytheon software, but it is obsolete and inefficient. We are currently evaluating IDDEAL for purchase at RNP, as well as our sister plants. Crystal River has the software and based on benchmarking, we are aligning to purchase it for the remaining nuclear sites. Currently, between the four nuclear sites, we all use different means to implement our ISI Programs. Once the purchase and installation of the IDDEAL software is complete, some burden associated with outage data will be reduced.


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