Temporary Alterations in Support of Maintenance and Temporary Modifications Beth Kernes Krause - Cooper Station February 24, 2019 Cleveland 2005

Temporary Alteration in Support of Maintenance Definition A Temporary Alteration in Support of Maintenance is a Temporary Configuration Change that directly relates to and is necessary to support maintenance. Definition comes from USA Resource Manual and NEI 96-07 document, clarifying that found in 10CFR50.59 February 24, 2019 Cleveland 2005

Maintenance Activity Definition Maintenance activities are activities that restore SSCs to their As-Designed condition, including activities that implement approved design changes. See note for slide above February 24, 2019 Cleveland 2005

Authorized Design Definition Traceable documentation which is recognized as reviewed and approved under a 10CFR50, Appendix B Program for the use of establishing the basis for either existing plant design or a modification to the plant design. February 24, 2019 Cleveland 2005

Regulatory Control Maintenance activities are not subject to 10CFR50.59, but are subject to the provisions of 10CFR50.65(a)(4) as well as the facility technical specifications. Maintenance related testing is assessed and managed under 10CFR50.65(a)(4). Clarifies that this IS a controlled activity, but controlled by 10CFR50 Appendix B, Criterion V, rather than Criterion III. February 24, 2019 Cleveland 2005

Maintenance Activity Control A Temporary Alteration in Support of Maintenance is controlled by the work control process and is restored to the authorized design upon completion of the maintenance activity. February 24, 2019 Cleveland 2005

Screening Does the Maintenance activity include a temporary alteration to the facility or procedure(s) that directly relates to and is necessary to support the maintenance? This question asks “who wants it?” (Comment: You might want to be prepared to cite examples where CNS has missed this boat on this criteria. This is the most important criteria because it truly responds to the screening line of, “Who wants it?”) February 24, 2019 Cleveland 2005

Screening Will the plant be restored to its original condition upon completion of the maintenance activity? NOTE: This allows implementation of approved design changes – see definition of maintenance activity. February 24, 2019 Cleveland 2005

Screening Will the temporary alteration planned to be implemented be credited with restoring or maintaining operability of Technical Specification equipment? This question asks “why do we need it?” February 24, 2019 Cleveland 2005

Screening Will the temporary alteration be credited as a compensatory measure established to address a degraded or nonconforming condition and be left in place for a period of time prior to conduct of the maintenance to restore the SSCs condition? This question also asks “why do we need it?” If this is a YES, then Appendix B, Criterion XVI (CAP) applies. (Comment: See earlier comment on CNS examples) February 24, 2019 Cleveland 2005

Time Limitations If the temporary alteration in support of the maintenance will be in place # 90 days during at-power operations (Modes 1 and 2), then the activity must be reviewed under 10CFR50.59. This does not affect its determination as a temp alt in support of maintenance – only whether 50.59 applies. February 24, 2019 Cleveland 2005

Example If tube plugging limits are not specified, it may be necessary to do an analysis to assure that normal and accident heat removal capability is preserved and pumps continue to deliver adequate flow with some tubes plugged. Because plugging tubes permanently alters the facility, 10CFR50.59 screening and, if necessary, evaluation should be performed for this activity. February 24, 2019 Cleveland 2005

Example (continued) If tube plugging limit is specified (e.g., a tube plugging limit defined in the UFSAR), a planned activity to plug tubes up to the limit would be considered a maintenance activity that is not subject to 10CFR50.59. If this limit is to be altered to allow additional tube plugging, this is a change to the facility as described in the UFSAR, and 10CFR50.59 should be applied. February 24, 2019 Cleveland 2005

Additional guidance When evaluating the situation to determine if a temporary alteration in support of maintenance is appropriate, consider the following: Who is requesting the change (e.g., Maintenance, Operations, Engineering, other)? February 24, 2019 Cleveland 2005

Additional guidance (cont) What other activities are accompanying or in conjunction with the temporary change being evaluated? February 24, 2019 Cleveland 2005

Additional guidance (cont) What other organizations or individuals will use the temporary change and what are these uses? All uses must meet the criteria for temporary alteration in support of maintenance for the temporary change to qualify as such. February 24, 2019 Cleveland 2005

Site Support During transition to ‘new’ 50.59, we began discussions with Work Planning to ensure we captured temp alts which were already outside temp mod space (scaffolding, temporary shielding, etc.) February 24, 2019 Cleveland 2005

Site Support (continued) Engineering, E-FIN and Work Planning (included Work Control Center SROs) worked together to develop temp alt screening criteria and process interfaces to ensure tracking and 50.59 ‘trigger’ in Work Order space. February 24, 2019 Cleveland 2005

Site Support (continued) Engineering, E-FIN and Work Planning maintain communication on individual issues as well as the process interfaces, to ensure appropriate and efficient use of temp alts. (Comment: The only other thing I can think of is to present the CNS specific logistics for executing a Temp Alt (I.e., WO w/TSP, attach and complete text from procedure and provide clear and complete supporting justification, CNF) February 24, 2019 Cleveland 2005