2007 CMBG Conference2007 CMBG Conference

Temporary Configuration ChangesTemporary Configuration Changes

Tony HathcockDuke Energy - Oconee

June 18-20, 2007

Charleston, SC

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How do you modify your plant outside of the formal engineering change program?

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Types of ChangesTypes of Changes

• Temporary Alterations:Installed for SSC’s that are out of service per Maintenance Rule

• Temporary Engineering Changes (Temp Mod):Formal Engineering Change package with a removal date

• Temporary Configuration Changes:pre-engineered approved design configuration changes controlled by a procedure or program for simple and routine activities for in-service SSCs.

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Guiding PrincipleGuiding Principle

All changes must be analyzed prior to installation for their design requirements.

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BackgroundBackground

INPO continues to identify weaknesses with temporary change control at various sites.

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BackgroundBackground• INPO PO&C CM 2.8

“The physical configuration of the plant meets design and license basis. The configuration is consistent with procedures, drawings, and other documentation”

• INPO PO&C CM 3.6 “Temporary modifications are reviewed periodically for continued need and to identify changes that are inconsistent with the licensing and design requirements. Temporary modifications are normally removed within a refueling cycle.”

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INPO Engineering Digest 2006-01INPO Engineering Digest 2006-01

Featured Topic: “Temporary Modifications”

A formal temp mod is considered “burdensome” for simple and routine activities. “To counter this, organizations have created stand-alone procedures, processes, or engineering documents sometimes referred to as ‘mini-processes’ or ‘exemptions’…”

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Duke Energy InitiativesDuke Energy InitiativesOconee AFI in 2002: Undocumented plant changes.

• Analyzed and documented as a permanent modification• Removed• Many were controlled by existing processes and procedures• Oconee developed site directive - roadmap to existing processes, based on a similar Catawba directive

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Duke’s New Fleet ProcedureDuke’s New Fleet Procedure

• provides guidance for temporary configuration changes

• lists existing siteprocedures and programs that allow temporaryconfigurationchanges.

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Temporary Configuration ChangesTemporary Configuration Changes

Temporary Configuration Changes require:

1. Engineering evaluation of design

2. Configuration controls by procedure for

• installation

• operation

• removal 3. SSC is tagged per procedure.

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ExamplesExamples

• Installation of temporary power• Drop Cords• Installation of temporary cables (data, video, and

communication) • Installation of welding cables• Test leads and temporary electrical jumpers• Temporary RP equipment• Rubber hoses (for fire protection)• Hose attachment to service connections

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ExamplesExamples

• Online leak sealing• Leak Repair• Catch Containments to control leaks• Drains and Vents• Temporary Structures• Rigging and temporary supports• Lead shielding• scaffolding• portable measurement and test equipment• electrical cabinet doors left open & unattended

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Breakout DiscussionBreakout Discussion• Provide examples of your procedures and programs• Identify utilities that have good programs where such changes are:

– clearly identified and tracked– clearly traceable to the

supporting evaluations• Identify program weaknesses such as:

– interim abandoned equipment– temporary changes made permanent (e.g., shielding, scaffolding, etc.)