temporary design changes

2010 CMBG Conference2010 CMBG Conference

Temporary Design ChangesTemporary Design Changes

Tony HathcockDuke Energy - Oconee

June 20 - 23, 2010

Charlotte, NC


Types of ChangesTypes of Changes

We all have various methods that allow configuration changes at our sites.

Let’s be sure we’re comparing “apples to apples”.



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.



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.



Temporary Design Changes (Temp DCs) :

A “formal“ Engineering Change package with a scheduled removal date.


Guiding PrincipleGuiding Principle

All changes must be analyzed prior to installation for their design requirements.


BackgroundBackground• 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.”


Oconee INPO Mid-cycle Performance Deficiency 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."

Temp DC is LATE


Problem – Lack of OwnershipProblem – 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


Revised CriteriaRevised Criteria

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


CM Performance IndicatorsCM Performance Indicators

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec ProjYTD 1 0 0 0 0 0Min 1 1 1 1 1 1 1 1 1 1 1 1Target 0 0 0 0 0 0 0 0 0 0 0 0

This measure reflects timeliness for removal of Temporary Design Changes

Green = 0 Yellow = 1 Red > 1

Oconee Nuclear StationTemporary Design Changes Beyond Committed Removal Date

Data Analyst: Tony Hathcock (864-873-4189)

Coloring Logic

Site Historic Trend

Definition / Basis for Target

Data Date:

EDM-601.5.2.5 requires that the Responsible Engineer establishes the removal date in the Scope Description when the Temporary Design Change (TDC) is installed. This date is the next refueling outage for TDCs that require an outage for outage for removal and one year for TDCs than can be removed on line. This measure counts the number of TDCs installed beyond their committed removal date.

Measure is aligned with INPO Performance Criteria CM. 3-6 (Ref INPO 05-003, May 2005):"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."

May 31, 2010

0

1

2

3

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec


CM Performance IndicatorsCM Performance Indicators

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec ProjYTD 3 2 1 2 2 0Min 15 15 15 15 15 15 15 15 15 15 15 15Target 10 10 10 10 10 10 10 10 10 10 10 10

This measure reflects total number of Temp Design Changes outstanding

Based on site count from Temp Mod logbook on Data Date

Red: > MinimumL. Beck Yellow: >Target, but ≤ Minimum Green: ≤ Target

May 31, 2010

Oconee Nuclear StationTemporary Design Changes - Total Number Outstanding

Data Analyst: Tony Hathcock (864-873-4189)

Coloring Logic

Site Historic Trend

Measure is aligned with INPO Performance Criteria CM. 3-6 (Ref INPO 05-003, May 2005):"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."

Data Date:

Definition / Basis for Target

0

5

10

15

20

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec


Breakout DiscussionBreakout 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

temporary design changes

Documents