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1 CMBG 2009 PSEG Nuclear Vendor Technical Document Program Deficiencies, Successes, and Cost Savings Presented By: Paul Davis PSEG Nuclear, Engineering Services – Configuration Management

1 CMBG 2009 PSEG Nuclear Vendor Technical Document Program Deficiencies, Successes, and Cost Savings Presented By: Paul Davis PSEG Nuclear, Engineering

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1

CMBG2009

PSEG Nuclear Vendor Technical Document Program

Deficiencies, Successes, and Cost Savings

Presented By:Paul Davis

PSEG Nuclear, Engineering Services – Configuration Management

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CMBG2009 PSEG Nuclear

Salem Unit 1 PWR 1,228 MWeSalem Unit 1 PWR 1,228 MWe

Salem Unit 2 PWR 1,216 MWeSalem Unit 2 PWR 1,216 MWe

Hope Creek BWR 1,268 MWeHope Creek BWR 1,268 MWe

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CMBG2009 Background

• As a result of the Feb 1983 Salem Anticipated Transient Without Scram (ATWS) event, PSEG Nuclear was committed, via response to NRC Generic Letter 90-03 and Salem/Hope Creek UFSARs, to the maintenance of Vendor Technical Documents (VTDs) associated with certain key safety-related equipment.

• The PSEG Nuclear VTD Program consists of two elements: Recontact program and “Daily” program.– The Recontact program maintains the requirements of

GL 90-03 (periodically contact vendors of key safety related equipment and a program with Nuclear Steam Supply System (NSSS) vendor to cover all safety-related components within the NSSS scope of supply).

– The Daily program maintains the safety related documents not required in GL 90-03 and non safety-related documents (everything else).

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CMBG2009 History

• Feb 22, 1983 – Salem ATWS event • July 8, 1983 – Generic Letter 83-28• Mar 20, 1990 – Generic Letter 90-03• May 14, 1990 – Generic Letter 90-03 Supplement 1• Oct 7, 1992 – Generic Letter 83-28 Supplement 1• Mar 1996 – PSEG formed a Vendor Engineering

Group • Nov 2005 – Elimination of Vendor Engineering

Group IAW the Exelon OEM• Aug 2008 – Nuclear Oversight (NOS) audits

program – finds three areas of concern

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CMBG2009 What Happened

• As a result of the implementation of the Exelon model, starting in 2005, the Vendor Engineering Group was eliminated and its functions were not turned over to Vendor Document Coordinators (VDCs), SMEs, and System Managers.

• NOS identified the VTD Program as an Area Requiring Management Attention (ARMA) based on the aggregate of three issues.

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CMBG2009 Issues

1. Vendor recontact documents have not been updated in a timely manner when Subject Matter Expert (SME) reviews are required.

2. Several vendor recontact documents were closed in SAP with “no action required” when they actually required SME reviews to satisfy procedural requirements and GL 90-03 requirements.

3. The Engineering Services Director has not assessed Vendor Information Services (VIS), the vendor that performs the recontact program activities, every two years to ensure program compliance in accordance with VTD procedure.

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CMBG2009 Upon Further Investigation…

1. The Salem FSAR still stated we would interface with vendors for EVERY safety-related component.

2. Review (again) of key-safety related documents showed not all documents are required to be in the program.

3. The Vendor Engineering Group had been updating “Daily” VTDs with parts lists, Bills of Material, catalog information, Certificates of Conformance, and other material not related to vendor instructions.

4. One vendor publication may be part of multiple VTDs. For example, pub XYZ is part of multiple VTDs and therefore, every pub revision would require multiple VTD revisions.

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CMBG2009 Fixes

• Revised Procedure• Created “Desk Guides” on how to administer and

evaluate documents in the VTD Program• Updated the Salem UFSAR to state Key vs. All• Station Management ownership• Eliminated unnecessary document updates• Reviewed all documents in the Recontact program

and eliminated documents that are not required• Created department PIs• Audited recontact vendor• Changed vendor audit frequency from two to three

years (to align with contract)• Added VTD Program to Corporate Self

Assessment schedule

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CMBG2009 Benchmarking

• October 2008, a VTD benchmarking questionnaire was sent to the CMBG contacts database list

• While the questionnaire was geared towards staffing, basic VTD “demographics” was asked

• 17 Utilities, 21 sites responded• 7 sites had 1 FTE administering the

program, 5 sites had a VTD group• The number of documents in recontact

program varied between 35 and 4,400 (average of 538)

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CMBG2009 Cost Savings

• Do a Self Assessment of your program– Prevents any findings from INPO, NRC or your QA

Department• Review document updates for unnecessary

updates– PSEG Nuclear eliminated 65% of the items sent to the

document coordinator• Review documents in your recontact program

– PSEG Nuclear eliminated ~ 15,000 documents from the program in 2003. This resulted in a $375,000 annual savings.

– PSEG Nuclear eliminated an additional 10 documents from the program in 2008. This resulted in a $850 savings.

• If possible, maintain only one publication in one Vendor Document

– Reduces updated time and administrative processing and time

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CMBG2009 Cost Savings (continued)

• Compare your program to the generic letter and your companies response to the NRC.

– PSEG Nuclear was just removing any document from vendors that went out of business or were unresponsive – now have to review 145 documents that were removed.

• Utilize a vendor to do your recontacting.– Vendors charge a flat fee (between $85-$100 per

document) and supply a comparison report.– Vendors have all of the equipment manufactures contact

information– Vendors know who bought who– Vendors have a rapport with equipment manufactures

• Update your recontact documents in a timely manner

– If you use a vendor to do your recontacting, they may recontact the same document if not updated within three years.

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CMBG2009 OE

• As a result of numerous company buyouts and mergers, it is now recommended to re-re-contact vendors of documents whose policies may have changed.

• Specifically, those vendors who stated that their publications:– are not subject to revision and should be used

for the life of equipmentOR

– may be revised but revision provided with equipment at time of purchase should be used for the life of equipment

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CMBG2009

Vendor Information Received

Recontact info from VIS

(CC-AA-204-1001)

Daily info from various sources

(CC-AA-204-1002)

DCP related vendor info

(CC-AA-103)

See section 4.11 (VTDs related to

Configuration Change

Packages) ofCC-AA-204

END

Is the End Code 0, 7, 9,

10, or 12

VDC process “No Review Required” and remove doc

from program

Yes

Is the End Code 00, 000,

or 11

VDC process “Review Required” Assign to SME for

Evaluation

END

Yes

No

Evaluation 1

No

Is the End Code 1, 2, 3, 4,

or 5

VDC process “Out of Program”

Assign to SME for Evaluation

Yes

No

Evaluation 2

Is the End Code 6

VDC process “Obsolete

Equipment” and remove doc from

program

Yes

No

END

B

Ispublication a C of C, Cert Report, Catalog,

etc. and PC 4material?

If PC 4, discard.If PC 1, 2, or 3,

return to Material Center

Yes

VDC process “Daily Review Required” and

send to Knowledgeable Individual (KI)

No

KI complete screening Criteria inCC-AA-204-1002-F1

VDC Assign to SME for

Evaluation

SME perform Evaluation

(CC-AA-204-1003)

Utilize CC-AA-204 Attachments 3 & 4

as guidance for new and existing

documents

A

Evaluation 1

Evaluation 2

B

Is the End Code 8

VDC process “Missing Info” and send info back to

VIS

Yes

Return to Beginning

Revise/Issue VTD

Review the VTD to assure that sufficient attention is paid to

equipment maintenance, replacement, and repair to compensate for the lack of

vendor backup

Revised to the next revision level with an annotation to reflect this event

List actions taken in SAP long text

and print

Insert long text in from of publication

up-rev VTD

Review and Approve VTD

Issue NEW VTD Revision

END

A

If submittal needs to be added to

DCRMS, request new VTD # via

CC-AA-1032-F1

If multiple VTDs, consider voiding

all but one

Create or Update VTD(s)

Associate the Material Master to

the Equipment Master and cross reference the VTD to the Equipment

If applicable, send VTD for Discipline Interface review and signature

Send VTD for Supervisor Approval

Return VTD to VDC for Issue

Issue NEW VTD Revision

END

Associate the Material Master to

the Equipment Master and cross reference the VTD to the Equipment

If applicable, send VTD for Discipline Interface review and signature

Send VTD for Supervisor Approval

Return VTD to VDC for Issue

Issue NEW VTD Revision

END

Utilize CC-AA-204 Attachments 3 & 4

as guidance for new and existing

documents

Utilize CC-AA-204 Attachments 3 & 4

as guidance for new and existing

documents

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CMBG2009 Advertisement

•CM Café 1

•Vendor Technical Information

•Library Room

•13:00-16:30

•(1:00-4:30)

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CMBG2009 Questions

•Questions?

•Paul Davis•PSEG Nuclear•856-339-1689

[email protected]