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Ray West Interview

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Guest Name: Ray West

Company: Dominion Nuclear Connecticut, Inc.

Plant Name: Millstone Power Station Unit Nos. 1, 2, & 3

Position or Title: Technical Specialist (ASME Codes & Standards) working within the Piping & Engineering Mechanics Group

ASME Section XI/OM Code of Record: 1989 Edition includes 1987 OM Code Reference

ASME Section XI/OM Inspection Interval and Period:

Unit 1 - (Cold & Dark Status, No Longer Operational) - GE BWR3

Unit 2 - 3rd Interval, 2nd Period - CE PWR

Unit 3 - 2nd Interval, 2nd Period - W PWR

E-Mail Address: Westra@dnc.dom.com

Phone Number: (860) 447-1791, Ext.2282

Interview (Answers to the following questions were supported by information supplied by Rich Fuller the Primary Level III.)

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.?

ISI - 6 Total

1 - Unit 2 and 3, ISI Coordinator / Pressure test / back-up level III (RT, VT)

1 - Primary Level III / Certification Program / Procedures

1 - Containment IWE/IWL/ (1998 Edition) and FAC

3 - Technicians supporting non-outage exams, BOP, etc., and outage ISI program support

IST - 4 Total

1 - Unit 2, IST Coordinator

1 - Unit 3, IST Coordinator

1 - Technician For Both Units and Snubber Program

1 - Special Programs Person for Both Units

Overall - 10 Total

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?

West: Contracted vendor personnel perform all outage examinations. Primarily in-house personnel with the exception of RT and ECT perform online NDE Exams.

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

West: We were reorganized in November 2000 with a Process Owner/Team Concept and to me this has been a professional development benefit. I have broadened my insights from the ISI/NDE Team to the Piping & Engineering Mechanics Team bringing into my personal experience a new focus on piping and component evaluations for acceptability. I still interface with the ISI/NDE Team, but bring more benefit to the company with my participation on ASME Code Committees.

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?

West: Aging management is probably the most costly and difficult issue to deal with at any nuclear power plant today. It affects license renewal and day-to-day operation. The issues have created a challenge for engineering and our experience with Alloy 600 PWSCC problems just began last outage with the RPV head repairs at Millstone 2. Regardless of the repair options the Alloy 600 issue continues to be a problem and component replacement will be the long-term fix. Service Water degradation continues to result in routine repairs at both plants and FAC replacements occur each refueling outage. I believe that we have a good programmatic handle on these issues, but planned component replacement seems to be answer to avoid these issues in the future.

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

West: We have not recently implemented very many Code Cases. Our relief requests have been centered on repair options for PWSCC and will continue that way for at least another round of refueling outages.

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?

West: We have approval for a Class 1 only RI-ISI program at Millstone Unit No. 3 using the (WOG methodology/Code Case N-577/WCAP 14572 Rev. 1-NP-1A) and we just recently submitted the same type of program for Millstone Unit No. 2. We got a 76% reduction in examinations at Millstone 3 and the Unit 2 program is expected to result in a 65% reduction. One of the key issues that are left regarding these programs is the update process. A NEI Guideline should be available within the next year to solve this problem and then Risk-Informed ISI will be a complete success.

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?

West: The most recent training that has been provided was in the area of Section XI Repair/Replacement Activities and it was conducted by a vendor here on-site.

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

West: We are in the process of using phased array UT. We have purchased the equipment and the Primary Level III is in the process of implementing the technology for our in-house staff and future vendor use.

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?

West: Appendix VIII requirements have been implemented for both units as required in accordance with 10 CFR 50.55a. We have used the EPRI formatted Relief Requests for Alternative Length Sizing, Annual Ultrasonic Retraining, and to Continue using SNT-TC-1A. All the relief requests have been granted, but the relief to continue using SNT-TC-1A was only granted for an extended period to allow sufficient time to upgrade program to CP - 189.

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

West: Getting people to agree. Sometimes it is a horrendous effort to reach consensus on an issue. When everything is said and done a lot of wasted effort is expended to satisfy one or two individuals.

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

West: Being able to give someone a needed answer to their question and participating within the ASME Code Committees.

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

West: I havenít updated the response to this question, as this is still my favorite. Several years ago while I was the Unit 1 ISI Coordinator I learned a great lesson and had big chuckle at the same time. We were in the middle of a refueling outage and had been working a lot of overtime. Everyone was a little stressed and that says it all. I sent out a NDE technician to perform a UT exam and he came back and told me that the insulation had not been removed from the weld joint. I contacted the insulation foreman and he swore they had taken the insulation off. This evolution went around at least three times between the NDE people and the insulators. Finally, completely disgusted with both individuals, I had all of us go into the drywell to look at the weld (i.e., the NDE Tech, the Insulator, and Myself). What we found was an insulated weld joint. The Insulation Foreman was beside himself, the NDE Tech. was smiling, and I just couldnít figure out what was going on. I told both of them that we were not leaving the area until we all agreed that the weld joint was ready for NDE. The Insulation Foreman cut-off a good two feet of insulation from around the weld. Problem solved!!! Right??? Wrong!!! We all turned around and started walking away from the area and we herd a big thump. When we turned to see what had happened the insulation was back on the pipe. It turns out the pipe was a vertical run and each time the insulation was removed old insulation slipped down the pipe from above and covered the weld again. We all looked at each other and just busted out laughing. Besides having one of the biggest laughs Iíve ever had related to work, I learned a valuable lesson and that was to pay attention to what people had to say before I jumped to conclusions. I will never forget it.

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?

West: Not at this time.

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?

West: Not at this time.

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?

West: We are planning to update our Repair/Replacement Program to the 1998 Edition. We believe that the clarity of the new requirements will go along way to improving our program. We anticipate some problems initially with the rules for small items, but believe that the overall change will be worth the temporary adjustments.

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?

West: Yes, this calculation is performed by placing equal weights on each of the 4 scans, axial upstream, axial downstream, circumferential clockwise, and circumferential counterclockwise.

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?

West: We do not regularly share Cal Blocks with other plants but there have been occasions where we have borrowed a block and lent blocks to other utilities upon request.

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?

West: We are performing more of our examinations online. All components that are accessible online from a temperature and location standpoint will be examined during non-outage period. Additionally, scope reductions due to the Class 1 Risk Informed Programs for Unit 2 and 3 will be very beneficial.

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?

West: Yes, some exams have been missed over the years (28 years of my experience) and I think that has happened to almost everyone. Fortunately, I do not recall any of those instances being outside the Code requirements to the point that we were not able to make up the exams or address the issue through a specific relief request. Overall, I think our programs are in pretty good shape and we do a good job of handling what we have to do.

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?

West: We use an Access based database "Datacheck" purchased from a vender which performs satisfactory.

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