Configuration Management of Post-Fukushima Regulations CMBG June 2013 David Gambrell Director, Severe Accident Management Southern Nuclear

Introduction SNC Perspective on CM Challenges presented by the implementation of the NRC and Industry initiatives in response to Fukushima Objective – Ensure clear documentation and future control of commitments – Address both actions taken, and final plant configuration Challenge – Multiple, overlapping initiatives on different timelines – Expedited time frame resulting in parallel efforts. – “Beyond Design Basis Event”

Scope of Impact 12 NRC Recommendations with 32 items and 9 additional concerns prioritized into 3 Tiers. – 50.54(f) Letters – Required evaluations, voluntary commitments with uncertain future outcome of regulation. – Orders – Required actions, fixed implementation schedule, lagging endorsement, with uncertain final codification. – Rulemaking – Measured, public consensus approach with future required actions. – Subsequent evaluation, response, inspection, drills and audits INPO IERs, PO&Cs, Emergency Response interfaces, Regional Response Centers, etc. “Beyond Design Basis” – ultimate gray area challenge of scope, requirements, and configuration management.

Net Effect on Plants Operational strategy changes to mitigate extreme events Physical modification to plant and additional connections Portable operational and responder equipment, and storage building(s) Interface with Regional Response and INPO emergency centers Changes in staffing and/or emergency responder roles Significant changes in procedures, training, and drills Maintenance and testing of equipment

Configuration Management Impacts Licensing – Technical Specifications – Not currently expected to effect TSs – FSAR – No NRC direction yet. Expect plant specific updates for impact to existing information. Expecting industry standard approach for new section regarding Mitigation Strategies for Beyond Design Basis Events (either at Order implementation or result of rulemaking). – Plans (e.g. Emergency, Security) – Potential changes – Programs (e.g. Fire Protection) – Potential changes

Configuration Management Impacts Programmatic – NEI 12-06, Section 11 defines the scope of programmatic controls necessary to implement and maintain compliance with Order EA – NEI 12-06, Section 11.8 specifically defines the configuration control requirements.

Configuration Management Impacts Traditional Configuration Management – Implementation Stay in process – maximize use of existing processes such as design change, maintenance, testing, training, QA records, corrective action, etc. Procedure Use and Adherence - Revise or create new supplemental procedures to execute and document required actions such as: Seismic/Flooding walk downs, operability reviews of beyond design basis impacts, special reviews of licensing packages, special financial controls, project plans, configuration control expectations for project personnel, etc. Ensure adequate documentation trail for NRC inspection/audit

Configuration Management Impacts Traditional Configuration Management – Programmatic Controls Compliance – Per NEI 12-06, plants will be required to develop an overall “program document” that establishes and maintains these controls, including guidance for NRC review of changes. Existing “Control” Programs – Update existing programs / controls to sustain CM of new requirements such as: Design Control, Equipment labeling, ER/PM system classification, Risk Management, etc.

Configuration Management Impacts Traditional Configuration Management – Implementing Processes and Documentation Execution procedures and processes – Operating procedures, equipment procedures, emergency response procedures, maintenance, testing, calibration, deployment of equipment, etc. Supporting procedures and processes – (in response to a significant event) – work control, access/egress, HP control, fire protection, security, documentation access, etc. Training and Qualifications – SAT process, critical operation actions, assignment of roles, training material, drill scenarios, qualifications, etc. Interfaces – Regional Response Centers, INPO, External agencies, Memorandum of Understanding, Permitting, contracts, alliances, etc.

SNC Procedure Approach Project Execution Procedures Provides direction to perform Project specific duties (Life of Project) Walk downs Licensing Reviews Project Charters Project Files Oversight Plan Etc. Programmatic Controls Establishes plant programmatic controls ((Life of Plant) FLEX Program Document Equipment Labeling PM / ER Classification Design Control Etc. Execution Procedures Performs specific action (Life of Plant) Operating Procedures EP/ERO Procedures Testing and Calibration Etc.

Industry Fleet Approach Leverage the power of your peers – Be Aware – Be Involved – Be Aligned

Industry Activities affecting CM FLEX Program Document template Owners’ Group EOP and SAMG procedure development EPRI PM Maintenance Templates INPO ER Program Revision PIM Regional Response Centers INPO Emergency Response Training Development Working Group INPO Emergency Planning Training / Drill Working Group INPO Engineering VP Working Group (Handling of Beyond Design Basis Information) Weekly industry adhoc phone calls

Q&A More Q&A in afternoon Breakout Session