1. Margin Management Configuration Management Benchmarking Group
June 21, 2011
Michael Hayes
Configuration Control SME

2. Overview of Margin Management
Design and operating margins are understood, considered in decision-making, and managed consistent with design and licensing requirements.
Effects of changes on design and operating margins are identified, evaluated, and documented before the changes are approved for implementation.
Degraded conditions that reduce design or operating margins for systems important to safety and reliability are identified, evaluated, understood, and mitigated.
1/18/2019

3. Benefits of Margin Management
Operational configuration is conservatively maintained within the design requirements, and design requirements are conservatively maintained within the design bases.
Operators and plant systems have sufficient flexibility to accommodate routine activities and the capability to respond to anticipated transients and accident scenarios effectively.
Low margin concerns are identified, evaluated, prioritized, tracked, and resolved.
System Managers evaluate aggregate impact of low margin concerns associated with their system.
1/18/2019

4. Margin Model

5. Margins are Understood and Considered
Issues are identified in terms of margin within:
Corrective Action Program
System & Component monitoring programs
Operability Evaluations & Determinations
Operational Decision Making process
Site or Corporate Business Plan
Issues brought before the Plant Health Committee (PHC) – Subcommittee are evaluated in terms of margin.
Action is taken on High Risk systems that have the low Margin.

6. Changes are identified, evaluated, & documented
The effects of changes on design and operating margins are identified, evaluated, and documented before the changes are approved.
Design Input and Impact Screening documentation includes analysis of the impact of the change on margins.
Processing of Procedures includes documentation of the impact of the change on margins.
The applicable interfacing departments provide concurrence that reductions in margins have been identified and sufficiently justified.

7. Address Degraded Conditions that Reduce Margin
Engineering programs, testing, and predictive and preventive maintenance activities confirm that systems continue to provide assumed design margins.
The Corrective Action Program (CAP) Process and the Operability Determination Process are utilized to assure that degraded conditions are evaluated and addressed.
Aggregate impact of margin degradation is identified, evaluated, understood, and a need for mitigation strategies, if any, assessed.

8. Margins Maintained in Process
Processing of Procedures
Project Review Committee
Configuration Change Control for Permanent Physical Plant Changes
Document Change Requests
Temporary Configuration Changes
Control of Design Analyses
Engineering Technical Evaluations
Implementing and Managing Engineering Programs
Plant Health Committee
System Health Monitoring
System Performance Monitoring and Analysis
System Vulnerability Review Process
Operability Determinations
Corrective Action Program (CAP)
Performance Centered Maintenance (PCM) Process
Predictive Maintenance Program
Operator Work-Around Program
Operational and Technical Decision Making Process

9. Margin Issue Database
As an extra barrier in addition to these processes, Exelon has developed a margin issue database and associated lifecycle description.
An entry into the margin issue database may be made at the discretion of the individual with a concern.
The margin issue database is used to obtain PHC Subcommittee review of a concern that existing margin may not be sufficient to protect a design or operating limit. (Not when the limit has already been exceeded as in a nonconforming condition or Operability Determination.)

10. Margin Issue Lifecycle
Issue Identified
Issue owner enters issue into database
Margin Management Coordinator prepares report for PHC Subcommittee review
Margin Management Coordinator informs Issue Owner that clarification is required
PHC Subcommittee reviews issues in report
Issue sufficiently defined?
PHC Subcommittee comments as to required clarifications No
Yes
Margin acceptable as is?
PHC Subcommittee provides basis for decision and closes issue
Yes No
PHC Subcommittee prioritizes and provides action plan and action tracking number
Issue can be addressed thru LOE activity?
Yes No
PHC Subcommittee prioritizes and provides action plan and Portfolio Director number and IR number (if applicable)
PHC prioritizes and allocates resources to address the margin issue
Actions required to address margin issue are performed

11. SRM – Margin Management – Part 1

12. SRM – Margin Management – Part 2

13. SRM – Margin Management – Part 3

14. System IQ - Margin

15. System IQ – Indicator Details

16. System IQ – Action Steps
Next Presentation