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Temporary Alterations in Support of Maintenance and Temporary Modifications

Temporary Alterations in Support of Maintenance and Temporary Modifications

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Temporary Alterations in Support of Maintenance and Temporary Modifications

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  1. Temporary Alterations in Support of Maintenance and Temporary Modifications Beth Kernes Krause - Cooper Station Cleveland 2005

  2. Temporary Alteration in Support of Maintenance Definition • A Temporary Alteration in Support of Maintenance is a Temporary Configuration Change that directly relates to and is necessary to support maintenance. Cleveland 2005

  3. Maintenance Activity Definition • Maintenance activities are activities that restore SSCs to their As-Designed condition, including activities that implement approved design changes. Cleveland 2005

  4. Authorized Design Definition • Traceable documentation which is recognized as reviewed and approved under a 10CFR50, Appendix B Program for the use of establishing the basis for either existing plant design or a modification to the plant design. Cleveland 2005

  5. Regulatory Control • Maintenance activities are not subject to 10CFR50.59, but are subject to the provisions of 10CFR50.65(a)(4) as well as the facility technical specifications. Maintenance related testing is assessed and managed under 10CFR50.65(a)(4). Cleveland 2005

  6. Maintenance Activity Control • A Temporary Alteration in Support of Maintenance is controlled by the work control process and is restored to the authorized design upon completion of the maintenance activity. Cleveland 2005

  7. Screening • Does the Maintenance activity include a temporary alteration to the facility or procedure(s) that directly relates to and is necessary to support the maintenance? Cleveland 2005

  8. Screening • Will the plant be restored to its original condition upon completion of the maintenance activity? • NOTE: This allows implementation of approved design changes – see definition of maintenance activity. Cleveland 2005

  9. Screening • Will the temporary alteration planned to be implemented be credited with restoring or maintaining operability of Technical Specification equipment? Cleveland 2005

  10. Screening • Will the temporary alteration be credited as a compensatory measure established to address a degraded or nonconforming condition and be left in place for a period of time prior to conduct of the maintenance to restore the SSCs condition? Cleveland 2005

  11. Time Limitations • If the temporary alteration in support of the maintenance will be in place # 90 days during at-power operations (Modes 1 and 2), then the activity must be reviewed under 10CFR50.59. Cleveland 2005

  12. Example • If tube plugging limits are not specified, it may be necessary to do an analysis to assure that normal and accident heat removal capability is preserved and pumps continue to deliver adequate flow with some tubes plugged. Because plugging tubes permanently alters the facility, 10CFR50.59 screening and, if necessary, evaluation should be performed for this activity. Cleveland 2005

  13. Example (continued) • If tube plugging limit is specified (e.g., a tube plugging limit defined in the UFSAR), a planned activity to plug tubes up to the limit would be considered a maintenance activity that is not subject to 10CFR50.59. If this limit is to be altered to allow additional tube plugging, this is a change to the facility as described in the UFSAR, and 10CFR50.59 should be applied. Cleveland 2005

  14. Additional guidance • When evaluating the situation to determine if a temporary alteration in support of maintenance is appropriate, consider the following: • Who is requesting the change (e.g., Maintenance, Operations, Engineering, other)? Cleveland 2005

  15. Additional guidance (cont) • What other activities are accompanying or in conjunction with the temporary change being evaluated? Cleveland 2005

  16. Additional guidance (cont) • What other organizations or individuals will use the temporary change and what are these uses? All uses must meet the criteria for temporary alteration in support of maintenance for the temporary change to qualify as such. Cleveland 2005

  17. Site Support • During transition to ‘new’ 50.59, we began discussions with Work Planning to ensure we captured temp alts which were already outside temp mod space (scaffolding, temporary shielding, etc.) Cleveland 2005

  18. Site Support (continued) • Engineering, E-FIN and Work Planning (included Work Control Center SROs) worked together to develop temp alt screening criteria and process interfaces to ensure tracking and 50.59 ‘trigger’ in Work Order space. Cleveland 2005

  19. Site Support (continued) • Engineering, E-FIN and Work Planning maintain communication on individual issues as well as the process interfaces, to ensure appropriate and efficient use of temp alts. Cleveland 2005