Temporary Configuration Change Mike Hayes Exelon Nuclear.

Temporary Configuration Change

Mike Hayes

Exelon Nuclear

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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)

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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

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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

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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.

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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.

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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.

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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.

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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.

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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.

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How to recognize a authorized TCC

Completed Temporary Configuration Change (TCC) Tag/Card(s) should be displayed/hung on the TCC.

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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

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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

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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

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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.

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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.

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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.

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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

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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.

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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.