A Brief History of CM in the Nuclear Industry and the CMBG Presented By: Keith Reinsmith CMBG Steering Committee June 20, 2011 Philadelphia, PA Brief chronological History of Nuclear Configuration Management in the US CMBG’s role in that history CM documents developed and in use in the industry CM Fundamentals Workshop this afternoon. Discuss the concepts and processes mentioned in this presentation in more detail. Presentation is somewhat chronological with some segways along the way

A Brief History of CM in the Nuclear Industry Configuration Management in military and aerospace industry geared towards product conformance to facilitate interchangeability of parts while still satisfying the overall design requirements MIL-STD-973 (1992), ”Configuration Management” (later replaced by ANSI/EIA-649-1998) First couple of slides are focused on U.S. govt CM initiatives Military CM started in the post WWII era of jet aircraft development. Many contractors and parts manufactures involved. Rapidly evolving designs. Needed programmatic tools to ensure the evolving configuration of aircraft design and fabrication was controlled.

A Brief History of CM in the Nuclear Industry DOE STD 1073-93 “Configuration Management” Applicable to DOE nuclear facilities in the operational phase. DOE-STD-1073 was updated in 2003 DOE had numerous facilities for handling nuclear materials and needed to define controls of the processes to change these facilities. This became the early model for nuclear CM

A Brief History of CM in the Nuclear Industry Nuclear plants in mid 60’s to early 80’s were typically designed by AEs under contract Final design documents typically turned over to the utility at the end of construction Little knowledge transfer of design info to utility engineering organization Utilities struggled to deal with long term design maintenance and related document upkeep Commercial nuclear power

A Brief History of CM in the Nuclear Industry Early indicators that the nuclear plant design basis knowledge was becoming disconnected from the physical plant IE Bulletin 79-14 uncovered calculation discrepancies undocumented modifications document discrepancies as-built problems A series of commercial nuclear industry events led to regulatory actions. IE- NRC Inspection and Enforcement bulletins are predecessors to Generic Letters IE Bulletin 79-14 was focused on hangers/pipe supports

A Brief History of CM in the Nuclear Industry Salem ATWS event (1983) Generic implications identified in NUREG-1000 and NRC Generic Letter 83-28 compliance with vendor recommendations part and procurement issues vendor manual controls Industry initiatives by INPO, NUMARC and EPRI to provide guidance and consistency INPO formed shortly after 1979 TMI accident.

A Brief History of CM in the Nuclear Industry Davis Besse Loss of Feedwater event (1985) Led to NRC Safety System Functional Inspections (SSFIs) and NUREG-1154 difficulties maintaining operational readiness of safety systems lack of understanding design bases Voluntary design basis reconstitution, DBDs created and self-evaluations performed NUREG-1397, NUMARC 90-012, INPO 87-006 and NUREG/CR-5147 A range of industry regulation and guidance issued as a result of these inspections. NUREG 1397 and NUMARC 90-012- Design control and design reconstitution\ INPO 87-006 and NUREG/CR-5147 Fundamentals for CM program for Design control

A Brief History of CM in the Nuclear Industry Browns Ferry (1985) Browns Ferry fire in Unit 1 (1975) led to changes in NRC standards for Fire Protection All three Browns Ferry units shut down voluntarily in March 1985 due to CM related problems - containment isolation testing (Unit 1), reactor water level instrumentation (Unit 2) Unit 1 restarted in May 2007 after 22 year shutdown Led to creation of Appendix R to 10CFR50

A Brief History of CM in the Nuclear Industry NRC specialized SSFIs for safety systems Electrical Systems (EDSFI) Service Water Systems (SWOPI) SECY-92-193: intent to issue generic letter to require utilities to address how they were dealing with the problems – letter withdrawn prior to issue SSFI’s in late 80’s SSFI concept developed by NRC as another means to find deficiencies in the industry. Used as a proactive deep dive into utility programs/ processes. Revealed that serious CM problems existed. Utility documentation, change control, information accuracy, retrievability were very poor. SECY is a letter from the NRC secretary.

A Brief History of CM in the Nuclear Industry Nuclear Information and Records Management Association (NIRMA) CM Committee developed solution control of technical information by engineering and operations personnel mature records management and document control process PP02-1994 “Position Paper on Configuration Management Program” In the early ’90s

The Configuration Management Benchmarking Group is Born First Nuclear CM benchmarking conference hosted by PPL Susquehanna in Fall 1994 Forum to exchange information on CM processes and methods at work in the industry 17 US utilities were represented Each utility made presentation about their CM program No motivational speeches No sales promotions by service providers So here’s where CMBG comes into the picture. The next several slides focus on the history and operations of CMBG

The CMBG Idea Grows Interest from industry to hold another similar conference Second conference hosted by Ontario Hydro in 1995 Drafted plans for continuing organization - approved in 1996 Adopted name: Configuration Management Benchmarking Group Formed a Steering Committee Wrote a Mission Statement “…forum for peer-level information sharing…” Defined ground rules for holding future conferences

CMBG is not affiliated with any other single organization Independent of regulatory and oversight agencies Conference costs are paid by registration fees and supplemented by host utility Host utility pays for web site Activities limited to information exchange Written Principles and Practices guide our endeavors. P & P’s on CMBG.org website

CMBG Accomplishments Annual Conferences since 1994 Participation in development of industry documents (e.g.; ANSI-NIRMA CM 1.0-2000, INPO AP-929, INPO AP-932) Web Site (www.cmbg.org) CMBG history Conferences (proceedings from all previous conferences and info on upcoming conference) Steering Committee members IAEA Activities CM Links Papers and publications Industry Contact Database CMBG Google Group

CMBG Conferences Year Host Location 1994 PP&L Poconos, PA 1995 Ontario Hydro Ontario, Canada 1996 Houston Lighting & Power Galveston, TX 1997 Commonwealth Edison Chicago, IL 1998 NAESCO Boston, MA 1999 Duke Power Charlotte, NC 2000 Consolidated Edison Tarrytown, NY 2001 Progress Energy Raleigh, NC 2002 PSEG Nuclear Atlantic City, NJ 2003 PPL Susquehanna Hershey, PA 2004 Wolf Creek Nuclear Kansas City, MO 2005 First Energy Cleveland, OH 2006 Dominion Richmond, VA 2007 SCE&G Charleston, SC 2008 Pacific Gas and Electric Shell Beach, CA Entergy Boston, MA Duke Energy Charlotte, NC 2011 PESG Nuclear Philadelphia, PA Make a pitch of prospective future sites for CMBG. Talk to steering committee members if potentially interested. Provides great industry and regulator visibility of your fleet/ station’s commitment to CM.

A Brief History of CM in the Nuclear Industry NIRMA TG19-1996 “ Configuration Management of Nuclear Facilities” Built on the NIRMA PP-02 document Presented elements and attributes that facilities needed to establish of a good CM program. Later became basis for ANSI/NIRMA CM-1.0-2000 Criteria Program management Design requirements Information Control Change control Assessment Training TG= Technical Guide Effort driven out of early CMBG conferences with involvement of participants in Tech Guide development.

A Brief History of CM in the Nuclear Industry Millstone Spent Fuel Pool Cooling (1996) NRC had lost confidence in utility’s ability to know and maintain its design basis and to implement design and licensing requirements 10CFR50.54(f) letter in October 1996 to all licensees that required a response on how design basis information was controlled and maintained. More far-reaching implications than letter that NRC was persuaded not to issue in 1993 10CFR50.54(f) simply a provision that requires licensees to submit responses under oath if requested by the NRC.  

A Brief History of CM in the Nuclear Industry Millstone Spent Fuel Pool Cooling (1996) 10CFR50.54(f) letter helped to solidify CMBG as a viable resource for the industry Demonstrated how the CMBG "network" could be used to find and distribute valuable CM information between utilities, including good practices and lessons learned

A Brief History of CM in the Nuclear Industry DC Cook Design issues (1997) Extended shutdown due to inability to respond to design basis event and other configuration issues Contributed to INPO decision to modify the evaluation performance objectives and criteria to include configuration management and to the formation of a new CM evaluation department.

A Brief History of CM in the Nuclear Industry INPO AP-929 (1998) “Configuration Control Process Description” Focused on changes to plant configuration AP’s were intended to apply to the expected next generation of nuclear reactors. INPO applied these guidelines to existing nuclear fleet. Again CMBG participants worked with INPO on development of this document.

CMBG Contributions to Industry CM Guidance Documents ANSI/NIRMA CM 1.0 -2000 “ Configuration Management of Nuclear Facilities” Based on NIRMA TG-19 CMBG members participated in development, review and issuance. Drafts reviewed at CMBG conferences Criteria Program management Design requirements Information Control Change control Assessment Training

CMBG Contributions to Industry CM Guidance Documents 2002 CMBG Conference - initiative to reach agreement between INPO and NEI documents CMBG designated an NEI CM “Community of Practice” in 2002 CM Process and PI’s included in NEI Standard Nuclear Performance Model (2003)

CMBG Contributions to Industry CM Guidance Documents IAEA TECDOC-1335 (2003) "Configuration Management in Nuclear Power Plants“ Contained elements of INPO AP-929 and ANSI/NIRMA CM-1.0 Criteria Program management Design requirements Information Control Change control Assessment Training

A Brief History of CM in the Nuclear Industry INPO - Margin Management (2003) INPO reorganization emphasized, “Evaluating Configuration and Margin Management” Functional/Design Failure Greater than design basis range Design margin ( This is a prohibited range of operation and represents the additional conservative margin to account for uncertainties in design and construction ) Design or Tech Spec Basis Limit Analyzed transient range ( Design allows operation in the transient range. However operating restrictions consistent with the design, such as the magnitude and frequency of excursions into this range apply) Operating Point Limit Operating margin Allowed operating range ( The allowed operating range provides the normal margins operators use without violating setpoints ) Normal Operating Point

A Brief History of CM in the Nuclear Industry INPO 03-04 (November 2003) “Performance Objectives and Criteria” Configuration Management CM.1 Maintaining Margins Consistent with Design Requirements CM.2 Operational Configuration Control CM.3 Design Change Processes CM.4 Conduct of Engineering CM.5 Reactor Engineering and Fuel Management INPO began to focus on Configuration Management as a performance area.

A Brief History of CM in the Nuclear Industry INPO 05-03 (May 2005) “Performance Objectives and Criteria” Configuration Management CM.1 Maintaining Margins Consistent with Design Requirements CM.2 Operational Configuration Control CM.3 Design Change Processes CM.4 Reactor Engineering and Fuel Management Moved the Conduct of Engineering Perf Obj & Criteria to Operations area. 26

CMBG Contributions to Industry CM Guidance Documents INPO AP-929, Rev 1 (2005) “Configuration Management Process Description” “Three-Ball model” became “CM Equilibrium Model” Return to CM Equilibrium (new) Margin Model (new)

CMBG Contributions to Industry CM Guidance Documents IAEA Safety Report SR-65. “Application of Configuration Management in Nuclear Power Plants” Contains elements of AP-929 (Rev 1)

CMBG Contributions to Industry CM Guidance Documents ANSI/NIRMA Standard-CM-1.0, Rev 1 (August 2007) “Configuration Management of Nuclear Facilities” Standard was updated in 2007 to reflect new understandings regarding CM and to provide guidance on margin management. Standard is up for its 5 year review in 2012 per ANSI requirements. Presentation and breakout at this conference led by Rich Giska to discuss changes needed to standard.

CMBG Contributions to Industry CM Guidance Documents INPO Good Practice 09-003 Excellence in the Management of Design and Operating Margins Developed with partnership of INPO and industry (including many CMBG participants) Have had presentations and breakout sessions on this topic at last several conferences. Have a presentation and breakout at this conference on Exelon’s success with their margin program

CMBG Contributions to Industry What’s next?

The Next Big Thing in Nuclear CM We need your help in identifying the CM issues important to your station CM for new plants CMBG is a forum for sharing lessons learned from the current generation of operating plants in developing CM controls/ processes for the next generation of the nuclear fleet CM program effects of Fukishima Diachhi events Others?? YOUR CMBG will continue to provide a forum for industry benchmarking on CM issues Your participation and feedback are critical to keeping CMBG a meaningful forum for the industry. New plants have a significant opportunity to learn from the mistakes/ successes of the existing fleet in the area of effective CM. Several presentations and breakout sessions scheduled at this conference to continue the dialog and information sharing among key New Build stakeholders around providing effective CM from the beginning of a project thru construction, startup and into operations. In addition to this conference, we encourage you to use the network available to you on our CMBG Google Group to benchmark the industry and share your plant’s approach to current issues in CM. Next Presentation