Temporary Alterations in Support of Maintenance and Temporary

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					CMBG
 2005


              Temporary Alterations
                 in Support of
                Maintenance and
                  Temporary
                 Modifications
            Beth Kernes Krause - Cooper Station

        August 28, 2010   Cleveland 2005          1
CMBG
 2005

                   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.

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                          Maintenance Activity
                               Definition

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


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           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.

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                          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).

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                     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.


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                          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?


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                          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.


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




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                          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?

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                          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.




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                          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.

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                          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.

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                          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)?

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               Additional guidance (cont)


                    • What other activities are accompanying or in
                      conjunction with the temporary change being
                      evaluated?




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               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.




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                          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.)




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                  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.



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                  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.


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