1. 2007 CMBG Conference Temporary Configuration Changes Tony Hathcock Duke Energy - Oconee June 18-20, 2007 Charleston, SC

2. 2007 CMBG Conference How do you modify your plant outside of the formal engineering change program?

3. 2007 CMBG Conference Types 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.

4. 2007 CMBG Conference Guiding Principle All changes must be analyzed prior to installation for their design requirements.

5. 2007 CMBG Conference Background INPO continues to identify weaknesses with temporary change control at various sites.

6. 2007 CMBG Conference Background 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.”

7. 2007 CMBG Conference INPO 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’…”

8. 2007 CMBG Conference Duke Energy Initiatives Oconee 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

9. 2007 CMBG Conference Duke’s New Fleet Procedure provides guidance for temporary configuration changes lists existing site procedures and programs that allow temporary configuration changes.

10. 2007 CMBG Conference Temporary Configuration Changes require: 1.Engineering evaluation of design 2.Configuration controls by procedure for installation operation removal 3.SSC is tagged per procedure.

11. 2007 CMBG Conference Examples 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

12. 2007 CMBG Conference Examples 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

13. 2007 CMBG Conference Breakout 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.)