ML071770463

Procedure STARS-ENG-5000, Rev. 001, Engineering Configuration Management Program.

ML071770463
Person / Time
Site:	Wolf Creek
Issue date:	06/30/2005
From:	Strategic Teaming & Resource Sharing (STARS)
To:	Office of Nuclear Reactor Regulation
References
ET 07-0022 STARS-ENG-5000, Rev 001
Download: ML071770463 (15)

Text

Enclosure 10 to ET 07-0022 WCNOC Procedure STARS-ENG-5000, "Engineering Configuration Management Program"

4.

STRATEVGIC TEAiNI IN(. AM ) RESOURCt(E SHlARIN(;

2 ENGINEERING CONFIGURATION M,'ANAG;EtMENTr PROGRAM-STARS - ENG - 5000. revision 001 Approvals:

STARS Process Owner Plarticipating, STARS Member Si ARS Mana~cnicnt CounIcil DC50 06-30-2005

STARS - ENG - 5000, revision 001 STARS ENGINEERING CONFIGURATION MANAGEMENT PROGRAM Table of Contents 1 Scope........................................................................ 2 2 Discussion ................................................................... 2 3 Definitions ................................................................... 3 4 Responsibilities...............................................................9 5 Instructions .................................................................. 9 6 Records ..................................................................... 11 7 References.................................................................. 11 8 Attachments................................................................11 I of 11

STARS - ENG - 5000, revision 001 STARS ENGINEERING CONFIGURATION MANAGEMENT PROGRAM I SCOPE 1.1 This procedure provides guidance for and establishes the requirements and 13 responsibilities for the development of changes to the facility or documentation to satisfy the requirements of ANSI N45.2.l1 based upon INPO AP-929 and EPRI's Guidelines for Optimizing the Engineering Change Process for Nuclear Power Plants.

2 DISCUSSION

Ž22 2.1 The basis for controlling design originates with IlOCFR5O, Appendix B, Criterion III.

2.2 The need for a MODIFICATION can be identified through the plants 55 corrective action program, the MODIFICATION authorization process, or other means established by the participating STARS plant. The STARS change process begins after the need is identified and approved.

2.3 The STARS change process utilizes a graded approach to configuration management established in the EPRI Guidelines for Optimizing the Engineering Change Process for Nuclear Power Plants. The level of rigor given to a MODIFICATION for a structure, system, or component (SSC) is commensurate with the safety significance and complexity of the design.

2.4 The STARS process categorizes changes utilizing an assessment matrix. The categories of change are described below.

2.4.1 DESIGN CHANGEs are the highest level of ENGINEERING CHANGE and require the most extensive and formalized documentation. The change is a DESIGN CHANGE if, for example.

it:

a. Adds or removes an ENGINEERING CONTROLLED SSC

b. Adds or changes a function or failure mode of an existing ENGINEERING CONTROLLED SSC

c. Alters the bounding parameters used to define the established DESIGN BASIS of the plant.

2.4.2 A CONFIGURATION CHANGE results in changing the configuration, either the hardware or the documentation, of an ITEM which meets the functions of both the ITEM and applicable interfaces, and does not introduce new failure modes. CONFIGURATION CHANGES include REPLACEMENT ITEM EVALUATIONS.

2.4.3 ADMINISTRATIVE CHANGE. If the change is categorized as administrative, it is processed with minimal review and no HAZARDS SCREENING or PROGRAMS SCREENING is required.

2.4.4 COMMERCIAL CHANGE. If the change has been categorized as a COMMERCIAL CHANGE, by Change Assessment Matrix screening or inclusion in the sites Commercial Control Exemption List, the 2 of 11

STARS - ENG - 5000, revision 001 STARS ENGINEERING CONFIGURATION MANAGEMENT PROGRAM change is processed using the STARS Commercial Change procedure.

Nuclear Plant Engineering is not required for specifying equipment and performing analysis prior to making the change. However, Engineering is available, upon request, to provide input as needed.

Known nuclear HAZARDS and plant impacts have been considered and determined to not apply when the SSC was categorized as "Commercial", however, some HAZARDS such as fire protection, control room habitability, and flood HAZARD still need to be considered.

2.4.5 ENGINEERING EVALUATION. This is a form of communication between Engineering and other departments that clarifies existing design and licensing information. It does not require a new Engineering analysis to form the basis for the information nor does it require the generation or modification of design output documents.

This information communicated remains consistent with all existing licensing and design information. Evaluations may, for example:

a Interpret, clarify or communicate existing design requirements.'

b Identify REWORK dispositions.

2.5 The change is then processed in accordance with the category selected in the matrix.

2.6 Where required, the PROGRAMS review and HAZARDS review extends the gradation process by identifying areas requiring in depth evaluations such as fire protection or seismic 1111 issues.

3 DEFINITIONS 3.1 Basis 3.1.1 Licensing Basis The set of NRC requirements applicable to the plant, and the licensee's written commitments for assuring compliance with and operation within applicable NRC requirements and the plant specific design basis (including all modifications and additions to such regulations, orders, license conditions, exemptions, and technical specifications).

It also includes the plant specific design basis information defined in IOCFR5O0.2 as documented in the most recent SAR as required by IOCFR71 and the licensee's commitments remaining in effect that were made in docketed licensing correspondence such as licensee responses to NRC bulletins, generic letters, and enforcement actions, as well as licensee comnmitments documented in NRC safety evaluations or licensee event reports (Taken with some minor editorial modification from the definition of Current Licensing Basis in GL 91 -

18, rev 1).

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STARS - ENG - 5000, revision 001 STARS ENGINEERING CONFIGURATION MANAGEMENT PROGRAM 3.1.2 Design Bases (Design Basis)

Design bases means that infonrmation which identifies the specific functions to be performed by a structure, system, or component of a facility and the specific values or ranges of values chosen for controlling parameters as reference bounds for design.

These values may be (1) restraints derived from generally accepted "state-of-the-art" practices for achieving functional goals or (2) requirements derived from analysis (based on calculations and/or experiments) of the effects of a postulated accident for which a structure, system, or component must meet its fuinctional goals. (From I1OCFR 50.2).

3.1.3 Design Function The operation an item is required to perform to meet the component or system design basis. [EPRI NP-6406]

3.1.4 Engineering Design Bases (Engineering Design Basis)

The entire set of design constraints that are implemented, including those that are (1) part of the current licensing bases and form the bases for the [regulator] staff s safety judgments and (2) those that. are not included in the current licensing bases but are implemented to achieve certain economies of operation, maintenance, procurement, installation, or construction. (As defined in NUYREG-1397).

3.1.5 Technical Requirements These parameters define the function or performance of a given SSC in a particular application/end-use or group of applications/end-uses.

3.2 Change 3.2.1 Administrative Change An inconsequential revision to a controlled engineering document that does not affect the design, functions or method of performing the function of a structure, system or component (SSC).

3.2.2 At-Risk Field Change Notice The process of implementing a Field Change Notice (FCN) in the field while the corresponding engineering disposition is being prepared and reviewed. At-Risk FCN use is limited. There is a risk that the work performed may not agree with the approved disposition. At-Risk FCNs are subject to the following conditions:

a The affected SSCs must remain out-of-service and not be declared operable until the At-Risk FCN is reviewed and approved b At-Risk FCNs are limited to the scope of the original Modification Package 4 of 11

II STARS - ENG - 5000, revision 001 IM STARS ENGINEERING CONFIGURATION MANAGEMENT PROGRAM 3.2.3 Commercial Change A change to SSCs that have been screened out of the Engineering processes by the Design Authority. Changes are performned in accordance with commercial codes and standards. Configuration 22 management may be needed.

Ei 3.2.4 Concurrent Change A Concurrent Change is a hardware change that is being implemented in the field while the corresponding Modification Package is being prepared. Concurrent Changes are not often performed because there exists an inherent risk that the work performed in the field may not agree with the final approved and released Modification Package.

Restrictions apply to the use of a Concurrent Change.

3.2.5 Configuration Change A change in configuration that can be either physical or in documentation/analysis that preserves the functions and does not introduce new failure modes. This includes a change to the configuration of a replacement item which is not a like-for-like replacement of the present design.

3.2.6 Design Change A change where a fuinction is changed or a new failure mode is introduced.

3.2.7 Engineering Change Any change to the design or configuration of an Engineering Controlled SSC.

3.2.8 Field Change Notice The process of identifying and resolving, including review and approval as needed, changes to the engineering change package made after its release for implementation. Field work associated with a FCN must stop and be put in a safe condition until the FCN is appoved.

3.2.9 Hardware Change A physical change to SSCs, including instrument seipoint changes and electronic software changes.

3.2.10 Modification A change to the configuration of a SSC. It is a change to the physical plant and/or the documentation associated with it. The term encompasses all categories of change.

3.3 Design Input 5 of II

STARS - ENG - 5000, revision 001 I ii STARS ENGINEERING CONFIGURATION MANAGEMENT PROGRAM Those criteria, parameters, bases or other design requirements upon which E detailed final design is based (from ANSI N45.2.1 1-1974).

3.4 Design Verification The process of reviewing, confirming or substantiating the design by one or more methods to provide assurance that the design meets the specified design 10 inputs. Independent verification is performed by any competent individuals or groups other than those who performed the original design but who may be from the same organization. (from ANSI N45.2.1 1).

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~0 3.5 Documents 3.5.1 Affected Document A document which requires revision to reflect the modification but is not required to implement the modification. Affected documents are revised prior to change package closure and can be approved and issued following implementation of the Modification Package.

3.5.2 Controlled Document A document, whose release, distribution and maintenance are verified, recorded and authorized by an assigned organization.

3.5.3 Design Document A controlled document that specifies technical and/or quality requirements for the design, fabrication, installation, test, or operation of a structure, system, or component and that is verified as required by 10 CFR5O0 Appendix B, Criterion 111.

3.5.4 Modification Document An interim or as-built change to an existing or new document that is included in and released with a change package. Modification documents are utilized when required to implement or support the implementation of a change package and/or to update engineering documents to reflect as-built conditions 3.5.5 Work Document A generic term used to identify the forms and associated documents used by site-specific work control organizations.

3.6 Engineering Evaluation This is a form of communication between Engineering and other departments that clarifies existing design and licensing informnation. It does not require a new Engineering analysis to form the basis for the information nor does it require the generation or modification of design output documents. This information communicated remains consistent with all existing licensing and design information.

3.7 Margin 6 of 11

STARS - ENG - 5000, revision 001 STARS ENGINEERING CONFIGURATION MANAGEMENT PROGRAM 3.7.1 Design Margin The range of plant operation above the operating limit and below the analyzed design limit. Design Margin is controlled by Engineering.

The analyzed design limit is documented in engineering calculations.

Tech Spec and Regulatory limits fall within the Design Margin.

3.7.2 Operating Margin The range of plant operation above the normal operating range and below the operating limit. Operating Margin is controlled by Operations, and is specified in design documents. LO, LO-LO, HI and HI-HI alarms fall within the Operating Margin.

3.8 Repair The process of restoring a nonconforming characteristic to a condition such that the capability of an item to function reliably and safely is unimpaired, even though that item still may not conform to the original requirements

[ANSI N45.2.10-1973].

3.9 Rework The process by which a nonconforming item is made to conform to a prior specified requirement by completion, re-machining, reassembling or other corrective means [ANSI N45.2.10-1973].

3. 10 Replacement Item Equivalency (RIE)

A technical evaluation performed to confirm that an alternate replacement item (not like-for-like to the original) will satisfactorily perform its (engineeri 'ng) design function. This term is synonymous with an "equal-to-or-better-than" evaluation. [Definition from EPRI NP-6406, Guidelines for the Technical Evaluation of Replacement Items in Nuclear Power Plants (NCIG- 11)]

3.10.1 Item Any level of unit assembly, including structures, systems, subsystems, subassembly, component, part, or material. [ANSI N45.2.10-1973]

3.10.2 Replacement Item An item which replaces an original or installed item (either like-for-like or alternate) for which an equivalency evaluation is performed to assure that interfaces, interchangeability, safety, fit and function are not adversely affected or contrary to regulatory requirements.

3.10.3 Alternate Replacement A replacement item not identical to the original. These replacement items require an equivalency evaluation to assure that the design function will be maintained. [EPRI NP-64061 3.10.4 Critical Characteristics for Design 7 of 11

STARS - ENG - 5000, revision 001 STARS ENGINEERING CONFIGURATION MANAGEMENT PROGRAM Those properties or attributes which are essential for the item's form, fit and functional performance. Critical characteristics for design are the identifiable and/or measurable attributes of a replacement item which provides assurance that the replacement item will perform its design function. [EPRI NP-6406]

3.10.5 Like for Like Replacement The replacement of an item with an identical item (that which has the same part, make and model number, which exhibits the same technical and physical characteristics). [EPRI NP-6406]

3.11 Responsibilities 3.11.1 Design Authority The final technical authority responsible for maintaining a plant's design basis.

3.11.2 Responsible Engineer Prepares Modification Packages, Modification Package revisions, Field Change Notices, Concurrent Changes, and directs close-out of Modification Packages.

3.11.3 Reviewer The individual assigned to performn an independent review of Engineering Changes and Engineering Evaluations.

3.11.4 Verifier Th e individual who perform-s the independent verification to determine the validity, accuracy and adequacy of the design, and who ensures that the design complies with governing procedural requirements.

3.12 Screens 3.12.1 Hazards Those events, activities or conditions that have been identified and analyzed for impact on plant safety.

3.12.2 Hazards Review The evaluation provided that documents the potential impact a modification may have to an existing hazard.

3.12.3 Programs Review The evaluation provided that documents the potential impact a modification may have to an existing site program.

3.13 Special Scope Programs designated as having selected quality requirements consistent with their effect on safety.

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STARS - ENG - 5000, revision 001 STARS ENGINEERING CONFIGURATION MANAGEMENT PROGRAM 3.14 Structures, Systems or Components (SSCs) 3.14.1 Asset A piece of equipment such as a vessel, piping, pump, valve or core support structure, which will be combined with other assets to form an assembly or system.

3.14.2 Controlled Plant Equipment (Engineering Controlled SSC)

Structures, Systems and Components that: are safety-related, or whose functions impact the plant safety analysis, or are subject to special consideration based upon management discretion ( e. g. considerations given to licensing basis, Maintenance Rule, personnel safety, plant availability, commercial risk, etc.).

3.15 Use-As-Is Disposition which may be imposed for a nonconformance when it can be established that the discrepancy will result in no adverse conditions and meet all engineering functional requirements including performance, maintainability, fit and safety. [ANSI N45.2.10-1973].

4 RESPONSIBILITIES 4.1 STARS Management Council is responsible for a final review of this procedure prior to issuance at participating member sites.

4.2 STARS Management Council Sponsor is responsible for final approval of this procedure.

4.3 Site Engineering Organization is responsible for implementation of and qualification to this procedure.

4.4 STARS Process Owner is responsible for controlling the common procedure.

This includes coordinating incorporation of any comments received from other STARS plants and working with industry groups as appropriate to maintain the procedure consistent with regulations and considering industry best practices.

4.5 STARS Contact is responsible for obtaining all required reviews of this procedure at the member site, its revisions, and act as the coordinator/communicator of any comments from their utility to the STARS Process Owner.

4.6 The individual or group responsible for performing a given step in this procedure will be stated in the step.

5 INSTRUCTIONS 5.1 Use of STARS Configuration Management procedures.

5.1.1 STARS Configuration Management procedures will be prepared, reviewed, and approved using the STARS policy on Common Process Development and Revision.

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STARS - ENG - 5000, revision 001 STARS ENGINEERING CONFIGURATION MANAGEMENT PROGRAM 5.1.2 The STARS Configuration Management procedures will be incorporated into the site's ENGINEERING CHANGE program using the site's procedure processes.

5.1.3 Revisions to STARS Configuration Management procedures will be coordinated with the STARS Contacts and made in accordance with the STARS policy.

5.1.4 The STARS Engineering Change Resource Manual will be controlled by the STARS Process Owner. Changes to the Resource Manual may be made by a quorum of STARS Contacts and the Process Owner.

5.2 The RESPONSIBLE ENGINEER determines if the change is to be processed as an ENGINEERING CHANGE or a COMMERCIAL CHANGE by completing the Change Assessment Matrix or by reviewing the sites Commercial Control Exemption List.

5.2.1 Process as a COMMERCIAL CHANGE if the SSC is designated as "Commercial Controlled" on the site's Commercial Control Exemption List.

5.2.2 If the SSC is not on the site's Commercial Controlled Exemption List, complete a Change Assessment Matrix to determine the type of change.

a. If the status (i.e. Commercial Controlled) of a new SSC cannot readily be determined, evaluate the SSC per the sites SSC evaluation program. If the change is determined to be commercial, then mark question Al of the Change Assessment Matrix 'YES',

and process the change in accordance with the STARS Commercial Change procedure. Retain the Matrix for processing with the COMMERCIAL CHANGE. Otherwise continue with sections B through E of the Change Assessment Matrix.

b. The change is an ENGINEERING CHANGE if any of the questions in Sections B through E of the Change Assessment Matrix are checked YES. Follow the STARS Engineering Change procedure to process these changes. Retain the Matrix for processing with the ENGINEERING CHANGE.

5.3 Use the STARS Engineering Change Resource Manual to provide guidance for implementing the ENGINEERING CHANGE process.

5.4 A flowchart depicting the change process is included as Attachment 8.2.

5.5 Overview of the MODIFICATION process.

5.5.1 Modification Packages may be developed in-house by a utility, by another STARS utility or by non-utility sources.

5.5.2 These packages may be designated as applicable for one or multiple sites, or made applicable later when processed by a site per its STARS Configuration Management procedures.

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STARS - ENG - 5000, revision 001 STARS ENGINEERING CONFIGURATION MANAGEMENT PROGRAM 5.5.3 Modification Packages, regardless of source, are processed by each implementing site using the site's STARS Configuration Management iG procedures. This ensures a full and current accounting of configuration management issues, and licensing reviews.

5.5.4 Modification Packages use the site's document control system and 3)0 Modification Package numbering convention.

Do 5.5.5 Each Modification Package is closed out by each site after site implementation is complete.

6 RECORDS 6.1 Record retention will be as defined in the utility-specific procedures.

55 7 REFERENCES 7.1 ANSI N45.2.11 7.2 10CFR5O, Appendix B, Criterion III 7.3 EPRI TR- 103 586-RI1, Guidelines for Optimizing the Engineering Change Process for Nuclear Power Plants, October 1998.

7.4 INPO AP-929, Configuration Control Process Description 7.5 STARS Procedure Policy 7.6 STARS - ENG - 5001, STARS Engineering Change Packages procedure 7.7 STARS Engineering Change Resource Manual 7.8 STARS - ENG - 5003, STARS Commercial Change procedure 8 ATTACHMENTS 8.1 Change Assessment Matrix 8.2 Change Process Flowchart 11 of 11

STARS - ENG - 5000, revision 001 STARS ENGINEERING CONFIGURATION MANAGEMENT PROGRAM Attachment 8.2 Change Process Flowchart I of 2

STARS - ENG - 5000, revision 001 STARS ENGINEERING CONFIGURATION MANAGEMENT PROGRAM 4 2 of 2