A Brief History of CM in the Nuclear

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

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) 2007 CMBG Conference

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 2007 CMBG Conference

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 2007 CMBG Conference

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 2007 CMBG Conference

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 2007 CMBG Conference

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 selfevaluation • NUREG-1397, NUMARC 90 -012, INPO 87 -006 and NUREG/CR-5147 2007 CMBG Conference

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 CMBG Conference

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 2007 CMBG Conference

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 02 -1994 “Position Paper on Configuration Management Program” 2007 CMBG Conference

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 2007 CMBG Conference

The CMBG Idea Grows • 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 2007 CMBG Conference

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 2007 CMBG Conference

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 2007 CMBG Conference

CMBG Conferences • • • • Year 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 Host Location PP&L Poconos, PA Ontario Hydro Ontario, Canada Houston Light & Power Galveston, TX Commonwealth Edison Chicago, IL NAESCO Boston, MA Duke Power Charlotte, NC Consolidated Edison Tarrytown, NY Progress Energy Raleigh, NC PSEG Nuclear Atlantic City, NJ PPL Susquehanna Hershey, PA Wolf Creek Nuclear Kansas City, KS First Energy Cleveland, OH Dominion Richmond, VA SCE&G Charleston, SC 2007 CMBG Conference

A Brief History of CM in the Nuclear Industry • • NIRMA TG 19 -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 2007 CMBG Conference

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 • 10 CFR 50. 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 2007 CMBG Conference

A Brief History of CM in the Nuclear Industry Millstone Spent Fuel Pool Cooling (1996) • 10 CFR 50. 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 2007 CMBG Conference

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. 2007 CMBG Conference

A Brief History of CM in the Nuclear Industry INPO AP-929 (1998) • “Configuration Control Process Description” • Focused on changes to plant configuration 2007 CMBG Conference

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 2007 CMBG Conference

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 2007 CMBG Conference

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) 2007 CMBG Conference

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 Design or Tech Spec Basis Limit ( This is a prohibited range of operation and represents the additional conservative margin to account for uncertainties in design and construction ) Analyzed transient range Operating Point Limit Operating 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) Allowed operating range Normal Operating Point ( The allowed operating range provides the normal margins operators use without violating setpoints ) 2007 CMBG Conference

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 2007 CMBG Conference

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 2007 CMBG Conference

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) 2007 CMBG Conference

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) 2007 CMBG Conference

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 2007 CMBG Conference

CMBG Contributions to Industry What’s next? 2007 CMBG Conference