1. Configuration Management in NRC’s Reactor Inspection Program Tony Gody, Region II/DRS

2. Regulations 10 CFR 50, Appendix B, Criterion III, “Design Control” Measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in § 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. …. Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the original design unless the applicant designates another responsible organization. 2

3. Regulations 10 CFR 50.59, “Changes, Test, and Experiments” (c)(1) A licensee may make changes in the facility as described in the FSAR, make changes in the procedures as described in the FSAR analysis report, and conduct tests or experiments not described in the FSAR without obtaining a license amendment only if: (i) A change to the technical specifications incorporated in the license is not required, and (ii) The change, test, or experiment does not meet any of the criteria in paragraph (c)(2) of this section. –more than minimal increase in the frequency of occurrence of an accident previously evaluated; –more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC previously evaluated –more than a minimal increase in the consequences of an accident previously evaluated; –minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated –create a possibility for an accident of a different type than any previously evaluated –create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated –result in a design basis limit for a fission product barrier as described in the FSAR being exceeded or altered –Result in a departure from a method of evaluation used in establishing the design bases or in the safety analyses 3

4. History Safety System Functional Inspections and Safety System OM Inspections: Mid to late 80s, the NRC identified concerns that DB were not being maintained. NUMARC 90-12, “Design Basis Program Guidelines” to provide a standard framework for industry members to use in improving Design Bases (DB) information –NRC recommended making the DB reconstitution a formal initiative. –NUMARC responded this was not needed - most licensees were already conducting DB reconstitution. NUREG-1397, Feb 1991 – some results of NRC survey of 6 utilities include –DB docs should be a top-level and define the current plant configuration –Re-establishment of DB w/o reconstitution may not provide sufficient LOD for future modifications, plant operation, or event response –Minor changes should be tracked to ensure that changes in the aggregate do not affect validity of existing calcs and ability of a system to perform it’s design functions. 4

5. History Aug 1992 - NRC issued a Commission policy statement “Availability and Adequacy of Design Bases Information at Nuclear Power Plants” –DB docs should be sufficient to show the current plant configuration is consistent with the DB –DB should be understood and documented to spt operability determinations and 50.59s –NRC will continue SSFI-like inspections –GL will be issued Mar 1993 – draft GL issued for comment –Requested licensees to describe their DB reconstitution efforts, and schedules, –Licensees not reconstituting their DB requested to provide rationale –Most commenters concluded that the GL was unnecessary. –NUMARC: this request would have a negative effect on ongoing efforts and undermine licensees’ abilities to manage these efforts. Oct 1993, in SECY 93-292, the NRC staff told the Commission that the policy statement and proposed GL conveyed the Commission’s concern and recommended the GL not be issued. The NRC would continue to perform design-related inspections. 5

6. History May 1996 - NRC IG investigations found fault with the NRC for failing to recognize the problems at Millstone and impose Corrective Actions much earlier Oct 1996 - NRC issued 50.54(f) letters to all licensees requiring information that ensures plants are operated and maintained in accordance with their Design Bases. 1999 - NRC issued a revised 10 CFR 50.59 which clarified the conditions to allow licensees to make changes without prior NRC approval. Baseline design basis inspections were implemented –SSFI, revised in 1996 – included engineering design, configuration control, and 50.59/mods –SSD&PC team inspections– safety system design and performance capability –CDBIs –Mods/50.59 inspections 6

7. Recent Statistics 7 2010-20132013-2016 Criterion III Findings:326 Green 3 SLIV 1 White 1 Yellow 1 Red 311 Green 0 SLIV 7 White 2 Yellow 50.59 Findings:28 Green 23 SLIV 69 Green 12 SLIV Configuration control related (includes operations, maintenance, and some Criterion III) ~190 Green 4 SLIV 3 White 1 Yellow ~180 Green 2 SLIV 1 White

8. Trends Number of Criterion III findings relatively stable Number of 50.59 findings has increased Overall configuration control issues relatively stable 8

9. Examples Insufficient Material Evaluation of Commercially Dedicated Components –Commercial relays were procured and dedicated for use in the emergency diesel generator output breakers. The licensee used dimensional and configuration check to ensure that no unforeseen design changes had occurred. However, the use of dimensional and configuration checks were insufficient to detect the internal design change made to the relays by the supplier. Failure to adjust key parameter after replacing linear variable differential transformers (LVDT) –LVDTS in the turbine control system were replaced and calibrated to tighter tolerances. A key parameter in the turbine control digital circuits was not adjusted to reflect the new LVDTs causing the turbine control valves to open more than anticipated resulting in an RCS cooldown. 9

10. Examples Failure to maintain design features for steam admission valve –Due to inadequate maintenance drawings the licensee installed a valve packing type in the high pressure coolant injection turbine steam admission valve that was not as specified in the design control drawings. Failure to maintain configuration control of the plant during operations –Multiple examples of improperly stored equipment and inadequate control of scaffolding –Failure to conduct 50.59 screenings for scaffolding erected for more than 90 days. 10

11. Examples Failure to follow work instructions or operating procedures –Failure to follow work instructions for replacement of protective relays caused a reactor trip. –Inadequate tag out implementation resulted in two air operated valves opening and a trip of all running condensate pumps. –Failure to verify a circuit breaker was properly installed resulted in the loss of a bus and a trip of a reactor recirculation pump. –Failure to properly land wiring associated with the feed water level control system. Improperly landed wires caused intermittent losses of power. Inadequate work instructions or operating procedures –Inadequate work instructions for throttling a gland seal steam bypass valve resulted in a reactor trip due to loss of condenser vacuum. –Inadequate clearance on a station air compressor caused a reduction of control air pressure and a plant transient 11

12. Examples Failure to maintain configuration control of the plant during operations –Multiple examples of improperly stored equipment and inadequate control of scaffolding –Failure to conduct 50.59 screenings for scaffolding erected for more than 90 days. 12

13. Closing Configuration control issues continue to challenge the industry The majority of configuration control issues are caused during maintenance or operations activities –Failure to follow procedures/work instructions –Inadequate procedures/work instructions 13

14. Closing Plant modifications will grow more challenging as the industry moves forward with replacing aging equipment –Digital modifications challenges: Software development and management Making sure all variable parameters are properly entered for plant specific application –Replacement of electronic components Commercial grade dedication will need to be more intrusive to catch possible internal changes (such as CPLDs replacing solid state components) –Oversight of vendors and thorough specification of critical parameters are a must 14