CMBG XVII 2010 A Brief History of CM in the Nuclear Industry and the CMBG Presented By: Keith Reinsmith CMBG Steering Committee June 21, 2010 Charlotte, North Carolina 1 CMBG XVII 2010 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) 2 CMBG XVII 2010 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 3 CMBG XVII 2010 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 4 CMBG XVII 2010 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 5 CMBG XVII 2010 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 6 CMBG XVII 2010 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 7 CMBG XVII 2010 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 8 CMBG XVII 2010 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 9 CMBG XVII 2010 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” 10 CMBG XVII 2010 The Configuration Management Benchmarking Group is Born • 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 11 CMBG XVII 2010 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 12 CMBG XVII 2010 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. 13 CMBG XVII 2010 CMBG Accomplishments • Annual Conferences • Participation in development of industry documents (e.g.; ANSI-NIRMA CM 1.0-2000, INPO AP-929, INPO AP-932) • Web Site (www.cmbg.org) – 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 14 CMBG XVII 2010 Year Host 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 CMBG Conferences PP&L Ontario Hydro Houston Lighting & Power Commonwealth Edison NAESCO Duke Power Consolidated Edison Progress Energy PSEG Nuclear PPL Susquehanna Wolf Creek Nuclear First Energy Dominion SCE&G Pacific Gas and Electric Entergy Duke Energy Location Poconos, PA Ontario, Canada Galveston, TX Chicago, IL Boston, MA Charlotte, NC Tarrytown, NY Raleigh, NC Atlantic City, NJ Hershey, PA Kansas City, KS Cleveland, OH Richmond, VA Charleston, SC Shell Beach, CA Boston, MA Charlotte, NC 15 CMBG XVII 2010 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 16 CMBG XVII 2010 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 17 CMBG XVII 2010 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 18 CMBG XVII 2010 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. 19 CMBG XVII 2010 A Brief History of CM in the Nuclear Industry INPO AP-929 (1998) • “Configuration Control Process Description” • Focused on changes to plant configuration Configuration Control Business Need: Change Configuration Configuration changed 1 12 Accept changed configuration Define the configuration change needed 11 2 Does need meet definition of configuration change? No Implement configuration change Change does not alter configuration Yes 4 3 Does change require altering hardware or approved design ? Prepare nondesign operational configuration change No Yes 6 5 Does change require altering approved design? No Yes Prepare hardware equivalency changes Configuration Change 10 7 Does change require altering design basis? Yes Prepare design requirement change No Design Change 8 9 Prepare safety, licensing, and design basis documents Obtain licensing approval of proposed change Design Basis Change 20 CMBG XVII 2010 CMBG Contributions to Industry CM Guidance Documents ANSI/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 21 CMBG XVII 2010 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) 22 CMBG XVII 2010 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 23 CMBG XVII 2010 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 margin Operating Point Limit ( 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 ) 24 CMBG XVII 2010 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 25 CMBG XVII 2010 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 26 CMBG XVII 2010 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) 27 CMBG XVII 2010 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) 28 CMBG XVII 2010 CMBG Contributions to Industry CM Guidance Documents • ANSI/NIRMA Standard-CM-1.0, Rev 1 (August 2007) “Configuration Management of Nuclear Facilities” 29 CMBG XVII 2010 CMBG Contributions to Industry CM Guidance Documents • INPO Good Practice 09-003 Excellence in the Management of Design and Operating Margins 30 CMBG XVII 2010 CMBG Contributions to Industry What’s next? 31 CMBG XVII 2010 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 32