A Brief History of CM in the Nuclear Industry and the CMBG Presented By: John Parler CMBG Steering Committee June 25, 2012 Chicago, Illinois

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 )

DOE STD “Configuration Management” Applicable to DOE nuclear facilities in the operational phase. DOE-STD-1073 was updated in 2003 A Brief History of CM in the Nuclear Industry

Nuclear plants in mid 60’s to early 80’s 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 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 uncovered calculation discrepancies undocumented modifications document discrepancies as-built problems A Brief History of CM in the Nuclear Industry

Salem ATWS event (1983) Generic implications identified in NUREG-1000 and NRC Generic Letter compliance with vendor recommendations part and procurement issues vendor manual controls Industry initiatives by INPO, NUMARC and EPRI to provide guidance and consistency 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 and self- evaluation NUREG-1397, NUMARC , INPO and NUREG/CR-5147 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 A Brief History of CM in the Nuclear Industry

NRC specialized SSFIs for safety systems Electrical Systems (EDSFI) Service Water Systems (SWOPI) SECY : intent to issue generic letter to require utilities to address how they were dealing with the problems - withdrawn 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 PP “Position Paper on Configuration Management Program” A Brief History of CM in the Nuclear Industry

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 A Brief History of CM in the Nuclear Industry

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 Steering Committee Wrote 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.

CMBG Accomplishments Annual Conferences Participation in development of industry documents (e.g.; ANSI-NIRMA CM , INPO AP-929, INPO AP-932) Web Site ( 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 YearHostLocation 1994PP&LPoconos, PA 1995Ontario HydroOntario, Canada 1996Houston Lighting & PowerGalveston, TX 1997Commonwealth EdisonChicago, IL 1998NAESCOBoston, MA 1999Duke PowerCharlotte, NC 2000Consolidated EdisonTarrytown, NY 2001Progress EnergyRaleigh, NC 2002PSEG NuclearAtlantic City, NJ 2003PPL SusquehannaHershey, PA 2004Wolf Creek NuclearKansas City, KS 2005First EnergyCleveland, OH 2006DominionRichmond, VA 2007SCE&GCharleston, SC 2008Pacific Gas and ElectricShell Beach, CA 2009EntergyBoston, MA 2010Duke EnergyCharlotte, NC 2011PSEG NuclearPhiladelphia, PA 2012ExelonChicago, IL

NIRMA TG “ 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 Criteria Program management Design requirements Information Control Change control Assessment Training 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 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 A Brief History of CM in the Nuclear Industry

CMBG Contributions to Industry CM Guidance Documents ANSI/NIRMA CM “ 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

2002 CMBG Conference - initiative to reach agreement between INPO and NEI documents NEI CM Community of Practice (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 CMBG Contributions to Industry CM Guidance Documents

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

INPO (November 2003) “Performance Objectives and Criteria” Configuration Management CM.1Maintaining Margins Consistent with Design Requirements CM.2Operational Configuration Control CM.3Design Change Processes CM.4Conduct of Engineering CM.5Reactor Engineering and Fuel Management A Brief History of CM in the Nuclear Industry

INPO (May 2005) “Performance Objectives and Criteria” Configuration Management CM.1Maintaining Margins Consistent with Design Requirements CM.2Operational Configuration Control CM.3Design Change Processes CM.4Reactor Engineering and Fuel Management A Brief History of CM in the Nuclear Industry

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 Draft Safety Report. “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” CMBG Contributions to Industry CM Guidance Documents

INPO Good Practice Excellence in the Management of Design and Operating Margins CMBG Contributions to Industry CM Guidance Documents

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 YOUR CMBG will continue to provide a forum for industry benchmarking on CM issues