1. 2010 CMBG Conference Temporary Design Changes Tony Hathcock Duke Energy - Oconee June 20 - 23, 2010 Charlotte, NC

2. 2010 CMBG Conference Types of Changes We all have various methods that allow configuration changes at our sites. Let’s be sure we’re comparing “apples to apples”.

3. 2010 CMBG Conference Types of Changes Maintenance Rule 10 CFR 50.65 (a)(4) –Any temporary alteration (in-service or out-of-service) is evaluated for risk prior to performing the work to ensure the activity does not impact the ability of the SSC to perform it’s function. –Examples include lifting electrical leads, jumpering electrical termination points, and bypassing equipment trips and/or alarms. –50.59 required if temporary alteration is expected to remain place longer than 90 days of power operation.

4. 2010 CMBG Conference Types of Changes Temporary Configuration Changes: –Pre-approved configuration changes controlled by a procedure or program for simple and routine activities for in-service SSCs. –Procedurally controlled configuration changes.

5. 2010 CMBG Conference Types of Changes Temporary Design Changes (Temp DCs) : A “formal“ Engineering Change package with a scheduled removal date.

6. 2010 CMBG Conference Guiding Principle All changes must be analyzed prior to installation for their design requirements.

7. 2010 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.”

8. 2010 CMBG Conference Oconee INPO Mid-cycle Performance Deficiency Five temporary design changes have been installed greater than 18 months (one refueling cycle), resulting in a red CM Performance Indicator. The indicator is based on INPO Performance criterion CM.3-6 "Temporary modifications are normally removed within a refueling cycle."

9. 2010 CMBG Conference Problem – Lack of Ownership Majority developed by Rapid Response Team (RRT) System Engineer not engaged after initial request for the Temporary DC No one continued to “bulldog” the removal of Temp DCs after installation Scheduled removal dates would “slide” during outages due to Work Control being unaware of the urgency to remove the Temp DCs

10. 2010 CMBG Conference Revised Criteria Temporary Design Changes are not to be installed without a plan for removal within one year (on-line) or one refueling cycle (outage).

11. 2010 CMBG Conference CM Performance Indicators

12. 2010 CMBG Conference CM Performance Indicators

13. 2010 CMBG Conference Breakout Discussion Criteria used for determining if a Temp DC is required Mechanism to ensure removal of the Temp DC Required actions when removal schedule is not met Measures used for monitoring Temp DCs