INPO Perspective of Industry CM Performance Steve Nichols Manager, Engineering and Configuration Management

Evaluating CM PERFORMANCE OBJECTIVE (CM.2) Plant activities are conducted in a manner that maintains configuration control and operating and design margins. PERFORMANCE OBJECTIVE (CM.3) Processes used to maintain consistency of plant configuration, design, and licensing bases are clearly defined and are implemented properly. Changes to plant configuration and design and licensing bases are effectively analyzed, controlled, and implemented.

INPO Evaluation Results

CM Areas for Improvement

CM.2 AFI Issues Caution tags for longstanding equipment conditions in lieu of modification process Temporary shielding installations in place for years without engineering evaluation No actions taken to resolve a nonconservative instrument setpoint for more than a year Operability evaluations recorded basis of inputs and assumptions not well-supported

CM.2 Causes Personnel are not sensitive to what constitutes a plant change resulting in unapproved changes Management not sufficiently involved in the review and approval of operability evaluations Expectations for addressing degraded and nonconforming conditions are not clearly established or reinforced

CM.3 AFI Issues DC supply in-rush current for inverter too high for breaker Engineers are not consistently accounting for field performance data, validating test acceptance criteria, and considering outstanding changes to design calculations Engineering did not evaluate temporary changes to the plant before installation

CM.3 Causes Incomplete design verification by the responsible engineer and reviewers due to, in part, ineffective engineering work management, prioritization and scheduling of major projects Design engineers not fully addressing underlying causes of equipment problems in developing and implementing some important modifications Management not reinforcing procedure constraints placed on temporary configuration changes

INPO Perspective CM issues continue to impact plant performance CM lessons learned vital to new plant designs Continued focus important