A Brief History of CM in the Nuclear Industry and the CMBG

1. A Brief History of CM in the Nuclear Industry and the CMBG Presented By: Rick Harris CMBG Steering Committee June 17-20, 2007Charleston, SC

2. 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)

3. A Brief History of CM in the Nuclear Industry DOE-STD-1073 was updated in 2003 • DOE STD 1073-93 “Configuration Management” • Applicable to DOE nuclear facilities in the operational phase.

4. 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

5. 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

6. 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

7. 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 90-012, INPO 87-006 and NUREG/CR-5147

8. 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

9. 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 - withdrawn

10. 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”

11. A Brief History of CM in the Nuclear Industry • First Nuclear CM benchmarking conference hosted by PPL in Fall 1994 • 17 US utilities represented • Each utility made presentation about their CM program • No motivational speeches • No sales promotions by service providers

12. The CMBG Idea Grows • Second conference hosted byOntario 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

13. CMBG is not affiliated with any other single organization • No funding from any agency • No membership fees • Conference costs are paid by registration fees and supplemented by host utility • Host utility pays for web site • CMBG makes no position statements or endorsements

14. CMBG accomplishments • Annual Conferences • Participation in development of industry documents • Web Site (www.cmbg.org) • CMBG history • Conferences (future conferences and proceedings from previous conferences) • Steering Committee • IAEA Activities • CM Links • Papers and publications • Contact Database

15. CMBG Conferences YearHostLocation • 1994 PP&L Poconos, PA • 1995 Ontario Hydro Ontario, Canada • 1996 Houston Light & 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, KS • 2005 First Energy Cleveland, OH • 2006 Dominion Richmond, VA • 2007 SCE&G Charleston, SC

16. 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

17. 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

18. 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 and demonstrated how the CMBG "network" could be used to find and distribute valuable CM information between utilities, including good practices and lessons learned

19. 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.

20. A Brief History of CM in the Nuclear Industry INPO AP-929 (1998) • “Configuration Control Process Description” • Focused on changes to plant configuration

21. CMBG Contributions to Industry CM Guidance Documents ANS/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

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

23. CMBG Contributions to Industry CM Guidance Documents 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)

24. A Brief History of CM in the Nuclear Industry 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 INPO - Margin Management (2003) • INPO reorganization emphasized, “Evaluating Configuration and Margin Management”

25. 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

26. 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

27. 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)

28. CMBG Contributions to Industry CM Guidance Documents • IAEA Draft Safety Report. “Application of Configuration Management in Nuclear Power Plants”(to be issued in 2007) • Elements of AP-929 (Rev 1)

29. CMBG Contributions to Industry CM Guidance Documents • ANSI/NIRMA Standard-CM-1.0, Rev 1 “Configuration Management of Nuclear Facilities” (to be issued in 2007) • Input by several CMBG participants

30. CMBG Contributions to Industry What’s next?