1. Temporary Configuration Change Mike Hayes Exelon Nuclear

2. 2 Objective This presentation focuses on the CM good practices as well as challenges associated with the varied types of temporary configuration changes such as: Equipment in use Measurement and Test Equipment (M&TE) Procedurally Controlled Temporary Configuration Changes (Pre-Engineered) Temporary Alterations Evaluated under Maintenance Rule Temporary Configuration Change Packages (temporary modifications)

3. 3 Controlled Exclusions the Temporary Configuration Change Process Maintenance activities, replacements, troubleshooting and surveillance functions that are conducted in accordance with an approved procedure, or Work Order Temporary configuration changes to SSCs included within an Operations Clearance that do not affect the system beyond the clearance boundary Temporary changes required to support the implementation of a permanent modification, that have been evaluated as part of permanent modification process

4. 4 Equipment in Use Connection of portable equipment to permanently installed plant power feeds at 120/480 Volt outlets (i.e., electrical outlets, or welding receptacles) Service Air hoses and water drops Hoses connected from system drains and vents to floor drains during the conduct of an approved procedure Hoses/tubing, and their connecting fittings, connected from non-safety related sample points for the purpose of obtaining chemistry samples and routed to drains, that do not affect equipment operation either upstream or downstream of the sample point Air movers that are used to establish general area work conditions while work is being done in the area, not used to replace, augment, or add a design function of permanent HVAC systems

5. 5 Measurement and Test Equipment (M&TE) Temporary M&TE installed for troubleshooting efforts on equipment must meet the following requirements: M&TE does not change the system’s design function M&TE is installed and controlled in accordance with an approved procedure or work package instructions. The system is returned to normal configuration 90 days at power after installation. Risk significance has been assessed in accordance with WC-AA-101. A TCCP is required for M&TE installed on equipment that does not meet these requirements.

6. 6 Procedurally Controlled TCCs (Pre-Engineered) Operations abnormal lineup procedure (i.e. Operational configuration change – no physical change to SSC) (e.g. Ventilation Dampers out of Normal Position) Temp Lead Shielding Plant Barrier Impairments – includes Fire, Ventilation, Security, Radiation, Flood, High Energy Line Break, and Missile Barriers Scaffolding mounted or attached to structures Temporary Leak Repairs Freeze Seals Rigging Surveillance and Inservice tests controlled through specific station procedures that call for temporary configuration change (e.g., installation of a jumper to conduct a trip and cal test) Catch Basins controlled under procedure.

7. 7 Procedurally Controlled Temporary Changes Temporary configuration changes may be controlled through approved procedures. Procedurally Controlled Temporary Changes allow the Installer to place the detailed instructions for implementation, removal and configuration restoration directly into the work package used for performing the work without the need for a TCCP. Procedurally Controlled Temporary Configuration Changes are used to control changes that are performed on a regular basis (i.e. evolution related, repetitive maintenance or repetitive repair) and would benefit from a more specifically detailed process.

8. 8 Maintenance Rule Temporary Changes Temporary changes in direct support of maintenance activities that meet the criteria for Maintenance Rule (a)(4) applicability Necessary for personnel or equipment protection. Necessary to establish work conditions, or provide equipment necessary to perform work. Removes operator distractions (e.g., bypassing invalid nuisance alarms). Prevents potentially adverse impacts on associated or interfacing systems or equipment (e.g., defeating output signals that would trip interfacing systems or equipment). Necessary to reduce the overall risk impact during the maintenance activity.

9. 9 Maintenance Rule Temporary Changes Consider the need addressed by the temporary configuration change when determining the type. If the TCC is needed to support continued operation of an SSC, it is most likely a TCCP or procedurally controlled TCC, not an Maintenance Rule Temporary Change. Evaluation by Engineering is required if the plant will not be restored to its approved design configuration following maintenance activities such as replacements, troubleshooting and surveillance functions prior to returning the SSC to service.

10. 10 Temporary Configuration Change Package (TCCP) A formal package of information controlled and presented to the Installer as an Engineering deliverable for use in implementing and eventual removal of a planned temporary configuration change to the fit, form or function of any System, Structure or Component (SSC) that does not conform to approved design drawings or other approved design documents Changes that require a TCCP are: Temporary Configuration Changes that are used for operational decision making. Compensatory measures for a degraded or nonconforming condition for continued operation. Temporary installation or alteration not in direct support of maintenance that is not completely performed within a clearance boundary. Temporary installation or alteration of SSCs to add or augment a design function. Temporary installation or alteration of SSCs not controlled under maintenance.

11. 11 How to recognize a authorized TCC Completed Temporary Configuration Change (TCC) Tag/Card(s) should be displayed/hung on the TCC.

12. 12 How to recognize a authorized TCC This is a VALID Temporary Configuration Change (TCC) TCC Tracking Log has been filled out with the necessary information The appropriate TCC Tag is hung on the degraded component

13. 13 How to recognize an unauthorized TCC A rubber dam is placed around the Radwaste Building Vent System Supply Air Handling Unit which is blocking the floor drain This is an unauthorized Temporary Configuration Change (TCC) The rubber dam is prohibiting the floor drain from performing its design function It is not in support of current maintenance and not been evaluated by engineering It is not tagged per station procedures

14. 14 Should have been processed as a TCCP Rope used to support electrical cable to eliminate signal noise This is an unauthorized Temporary Configuration Change (TCC) The rope is an alteration to the SSC as compensatory measure for a degraded or nonconforming condition

15. 15 Examples of Configuration Not Maintained Restore the plant be to its approved design configuration following maintenance Temporary power that was no longer required to the Spent Fuel Pool Pump Cubical Coolers was not removed, resulting in an unauthorized TCC. Tape left securing circuit card to pin connector after troubleshooting determined pin connection as cause of intermittent signal issue, resulting in an unauthorized TCC.

16. 16 Examples of Configuration Not Maintained Be aware of inadvertently made changes to the configuration of the plant. During the removal of a hypochlorite tank and associated piping, a different tank was connected to the system to continue operation of the system, resulting in an unauthorized TCC. An instrument air compressor drain line cross-tie installed by Maintenance since 2007 was not recognized as a configuration change to the plant. Panel doors were left open in order to cool components internal to the panel, resulting in an unauthorized TCC.

17. 17 Examples of Configuration Not Maintained Be aware of the potential impact on operable structures, systems, or components (SSCs). Adding additional loads to operating systems or structures outside of that allowed by seismic analysis. Removal of supports for operating systems or structures outside of that allowed by seismic analysis. Installation of M&TE that affects an operating circuit being monitored.

18. 18 Physical Plant Configuration Control Maintain the physical plant configuration of Company nuclear facilities within their design documentation Evaluate and control changes to the design bases, design documentation, and physical plant configuration of Company nuclear facilities to ensure consistency

19. 19 Maintain Plant Configuration within Design Be aware of the potential impact on operable structures, systems, or components (SSCs). Restore the plant be to its approved design configuration following maintenance (including troubleshooting). Be aware of inadvertently made changes to the configuration of the plant.

20. 20 Evaluate Changes to Plant Configuration Temporary installation or alteration of SSCs as compensatory measures for degraded or nonconforming condition must be evaluated as a TCCP. Temporary installation or alteration of SSCs that add or augment a design function must be evaluated as a TCCP. Temporary alterations in direct support of maintenance activities under Maintenance Rule (a)(4) must be evaluated technically by Engineering and for risk under the work order implementing the maintenance activity as an Maintenance Rule Temporary Change.