United States Nuclear Power
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Tom Roberts Interview
Guest Name: A. Thomas Roberts
Company: PSEG Nuclear LLC
Plant Name: Salem Units 1 & 2 (PWRs) & Hope Creek (BWR) Generating Stations
Position or Title: Supervisor - Code Assurance and Welding Engineering
(Note: The following responses are provided from the perspective of R&R areas of responsibility, not ISI.)
ASME Section XI/OM Code of Record:
ASME Section XI/OM Inspection Interval and Period:
E-Mail Address: firstname.lastname@example.org
Phone Number: (856) 339-1177
Question 1: 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.?
Roberts: Fourteen ISI/IST staff including supervisor which includes responsibility for ISI, IST, Snubbers, Risk Informed efforts, Containment, Pressure Testing, State/EPA required tank inspections and Ventilation Testing. Nine R&R and welding engineering staff including supervisor.
Question 2: 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?
Roberts: All VT examinations are performed by in-house personnel. All R&R NDE is performed by two resident contract personnel. All scheduled Section XI and augmented ISI NDE, is performed by contract personnel with the total varying dependent on exam/outage scope.
Question 3: What changes have you made in your organizational structure or reporting functions that you have found to be beneficial?
Roberts: Recent alignment of the Material Engineering group along with ISI into one overall group has strengthened day to day interface relations.
Question 4: What issues proved to be very difficult, costly, or troublesome to resolve, and what would you recommend to avoid those issues in the future?
Roberts: With three units all at the same site (i.e., inside same protected area) and managed by the same staff, the delta in Code editions and addenda between each of the three units has been troublesome. Additionally, there are two PWRs and one BWR and the technology differences adds to the complexity of program maintenance.
Question 5: What code cases or relief requests have you implemented that has proven to be very helpful and cost effective?
Roberts: N-356, N-389-1, N-415, N416-1, N-432, N-436, N-446, N-448, N-479, N-494, N-495, N-496, N-498-1, N-508, N-532, N-533-1, N-524, N-566-2, N-568, N-573, N597, N-598, N-613, N-622, N-648
Question 6: 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?
Roberts: Currently in development to transition to RI - ISI, no input available at this time.
Question 7: 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?
Roberts: In-house training is used for all VT related initial and refresher training and initial, update/refresher training for R&R activities. Conventional NDE training (e.g., UT, PT, RT, etc.) we generally use external training resources.
Question 8: What new NDE techniques, technology, or special NDE situations have you encountered recently and were they successful?
Roberts: Ground penetrating radar was used to locate the specific source of an underground Class 3 Seismic 1 service water system leak.
Question 9: 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?
Roberts: Yes. The primary problem encountered to date is the exercise to assure that NDE personnel (e.g., contractor) meet the qualification/demonstration criteria.
Question 10: What do you find to be the most difficult part of your job?
Roberts: The most difficult aspect of the job, which may not be a common issue to the rest of the industry, is having three units at the same facility on three different versions of Section XI, coupled with an entirely different version of Section XI for IWE and IWL, and further exacerbated by a host of Code Cases which makes program maintenance extremely challenging.
Question 11: What do you find to be the most rewarding part of your job?
Roberts: Since my principle responsibilities rest in R&R and we possess both BWR and PWR technology, the most rewarding aspect of the job is the diversity of work activities. The breadth of events have included everything from "unplanned emergent" steam generator (S/G) replacement, where we had to redesign the entire FW, MS and vessel support systems, in order to be able to use replacement S/Gs from a cancelled unit in order to be able to restart one of the Salem units; developing unique repair parameters and a new analytical design bases for a degraded underground seismic 1, Class 3 piping system, constructed from pre-stressed bell and spigot joint concrete pipe (i.e., "sewer pipe"); designing structural weld overlays repairs for an emergent condition on a core spray reactor vessel nozzle, which required an unprecedented mixing and matching of several Code Cases and NRC relief request approval: all the way to the other end of the spectrum of the day to day R&R events as mundane as replacing SA-193 bolting in a piping system flange joint.
Question 12: What have you found to be the most humorous experience on the job?
Roberts: Being told by a frustrated ANII that the acronym ASME should stand for is "always, sometimes, maybe, except," instead of American Society of Mechanical Engineers.
Question 13: 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?
Roberts: Classification of our later vintage plant where the system classification was based on 10CFR50.2 and Regulatory Guide 1.26 has not caused many issues. The two other plants, which were classified using Atomic Energy Commission (prior to USNRC) parameters, has caused countless issues, both in the R&R and ISI arenas. There are five classification conditions that exist which include, Nuclear Class (i.e., may contain radioactive fluids), Safety Related, Non-Safety Related, QA Required and Seismic. The applicability of these classifications exist in every possible combination. While the ISI programs have been based on a "re-classification effort" for purposes of ISI, using Regulatory Guide 1.26, the original licensing bases for these systems remains the same. This often creates R&R challenges, often in the procurement and qualification of replacement items.
Question 14: 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?
Roberts: See comments to questions number 10 and 11.
Question 15: 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?
Roberts: Currently under consideration for all three units, but not implemented. The anticipated benefit would be the unification of Code requirements. See comment number 10.