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Russ Day Interview

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Guest Name: Russ Day

Company: PPL Susquehanna, LLC

Plant Name: Susquehanna

Position or Title: Senior Engineer

ASME Section XI/OM Code of Record: 1998 Edition, 2000 Edition

ASME Section XI/OM Inspection Interval and Period: Third Interval, First Period

E-Mail Address: reday@pplweb.com

Phone Number: 570.542.1519


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.?

Day: ISI – 10, IST - 5.

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?

Day: 20% In-House, 80% Outside Resource.  With limited number of examinations non outage, it is difficult to qualify, and keep qualifications for in-house personnel.

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

Day: N/A

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?

Day: We lost confidence in our ISI database.  We needed to reverify its contents.  We need to have better controls on the system and better controls on the data input/manipulations.

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?

Day: We have requested permission to implement a Risk Informed ISI Program for the Third Inspection interval.  We are awaiting final approval from the NRC.

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?

Day: EPRI In-Vessel Visual Examination Course.

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

Day: We utilize a UT mtheodlolgy for inspection of small bore piping to detect cracking initiated at the ID by cyclic fatigue (vibrationi).  While the pipe needs to be “cracked” for this method to work, it has proven to be very beneficial and reduced plant down time.

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?

Day: Yes we have in 1999 when 10CFR50.55a made Appendix VIII mandatory.  We have a relief request for the use of the Performance Demonstration Initiative (PDI) program for implementation.  We have 6 relief requests that have been accepted by the NRC for the PDI program (using the PDI generic relief request format).  They are: PDI piping implementation, PDI RPV Implementation, use of CP-189 exclusively (retracted in 2004 when SSES started using the 1998 code edition), PDI Dissimilar Metal Weld implementation, PDI Overlay implementation, 8 hours hands on Appendix VIII Training in lieu of 10 hours of Appendix VII.

The problems were, in the beginning the inspectors were confused about what the equipment settings were and what qualified transducers to use.  This lead to qualifying transducers after the inspections by EPRI personnel.  Also the lack of qualified personnel continues to be an industry problem.  If the NRC requires Appendix VIII qualified inspectors for BOP exams (an NRC direction that is getting a lot of discussion), there will not be enough personnel to satisfy all outage needs.

The qualified procedures, equipment, and personnel have improved the inspection capabilities in the nuclear industry and are identifying problem areas that were not known before (SSES nozzle issues).

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

Day: Never having enough time to work on all my assignments.

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

Day: Helping the plant to keep running.

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?

Day: We have had difficulties with the classification of heat exchangers.  We have erred on the conservative side and brought many of them under the ISI “umbrella”.  As experience and insight increase, we are redefining that position.

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?

Day: 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?

Day: Not at this time, we are awaiting the finalization of the PDI methodology.

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?

Day: We share specialty cal blocks or if a block costs too much to make we will ask to borrow one from another utility.

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?

Day: We are supplementing with our corporate personnel and some contractor personnel.

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?

Day: We have not lost accountability, we lost confidence.  We had the records, but we were not sure that our database reflected those records.  We have spent a great deal of time and efforts reconciling the differences.

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?

Day: We are currently changing our software (purchased from outside vendor) to IDDEAL.

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