Fukushima Impacts CM

Configuration Management of
Post-Fukushima Regulations
June 2013
David Gambrell
Director, Severe Accident Management
Southern Nuclear
• 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
– 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
• 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
• Programmatic
– NEI 12-06, Section 11 defines the scope of
programmatic controls necessary to implement and
maintain compliance with Order EA-12-049.
– NEI 12-06, Section 11.8 specifically defines the
configuration control requirements.
Configuration Management
• 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
• 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
• 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
Provides direction to
perform Project
specific duties
Establishes plant
Performs specific
(Life of Project)
((Life of Plant)
(Life of Plant)
Walk downs
Licensing Reviews
Project Charters
Project Files
Oversight Plan
FLEX Program Document
Equipment Labeling
PM / ER Classification
Design Control
Operating Procedures
EP/ERO Procedures
Testing and Calibration
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
More Q&A in afternoon Breakout Session