IR 05000361/1985022

Insp Repts 50-361/85-22 & 50-362/85-21 on 850812-23.No Violation or Deviation Noted.Major Areas Inspected:Mgt Controls Re Procedures,Policies & Administrative Orders & Mgt Involvement in Implementation as Applied to Operation

ML20133H339
Person / Time
Site:	San Onofre
Issue date:	09/19/1985
From:	Albert W, Bosted C, Crews J, Dangelo A, Andrew Hon, Ivey K, Andrea Johnson, Padovan M, Richards S, Thomas Young, Zwetzig G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20133H338	List: IR 05000361/1985022 ML20133H335
References
50-361-85-22, 50-362-85-21, NUDOCS 8510170054
Download: ML20133H339 (14)

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U. S. NUCLEAR REGULATORY C0tetISSION

REGION V

Report Nos. 50-361/85-22, 50-362/85-21 Docket Nos. 50-361, 50-362 License Nos. NPF-10, NPF-15 Licensee: Southern California Edison Company P. O. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Facility Name: San Oncfre Units 2 and 3 Inspection at: San Onofre, San Clemente, California gust 23, 1985

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Inspection conducte : August 12 through Inspectors: ) 7 ,f S

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k-2-Summary: .

Inspection on August 12-23, 1985 (Report Nor. 50-361/S5-22, 50-362/85-22)

Areas Inrpected: Annual unannounced team inspection of the San Onofre Nuclear Generating Station, Units 2 and 3 (SONGS 2/3), fccused on the management controls (procedures, policies, administrative orders, etc.) and the involvew nt of management in the implementation of these controls as they are applied to the operation and maintenance of SONGS 2/ The following activities of the' licensee were examined:

1) Technictl Specification Surveillance ,

2) .Ccatrol of TecLnical Manual Changes.in the Field 3) Plant Madifications . , -

4) Maintenance Programs 5) Control of Plant Procedures- ,

6) Onsite/Offsite Safety, Committee Activities

?) Non-licensed Stefi Training '

8) QA Audit Program 9) M&TE Calibratioa Program-To the maximum extent feasicle, the effectivene"ss.of these activities were assessed as they apply to the following plant physical systems:

1) Auxiliary Fredwater System (AFWS)

2) 125 Volt D.C. Power System (125 VDC)

3) High Pressure Safety Injection System (HPSI) (

4) Diesel Generator System (DG)

It in estimated that 60% of the inspection effort was directej to these safety related system.. The systems were selected on the basis of probablistic risk >

assersmen The inspection involved 566 hours0.00655 days <br />0.157 hours <br />9.358466e-4 weeks <br />2.15363e-4 months <br /> on site by ten NRC inspectors, inspection procedures 92706, 42700, 40702, 40301, 41400, 92717, 62702, 35750, 61725, '

37102, 35743, 37055, 37700, 37701, 37702, 37828 and 62700 were cpplicable to

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Results: Of the areas inspected, no violations or deviations of NPC l tequirements were foun !

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DETAILS Persons Contacted

• H. B. Ray, Site Manager

• H. E. Morgan, Station Manager J. W. Bellamy, Operations Procedures Supervisor

• D. P. Breig, Project Manager

• J. Curran, Quality Assurance (QA) Manager

• R. C. Douglas, Compliance Engineer

• L. C. Falcone, Supervising Procedure Writer N. M. Ferris, QA Auditor

• M. Flower, Compliance Engineer

• G. T. Gibson, Compliance Supervisor

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• J. F. Grosshart, QA Enginee *A. J. Haamons, QA Enhi neer

• C. R. Horton, Metrology Manager (Westminster, CA)

• R. A. Joyce, Maintenance Manager, Units 2/3

• B. Katz, Operations and Maintenance Support Manager

• C, A. Kergis, Lead Compliance Eagineer

• P. R. King, Operations QA Supervisor

• W. M. Lazear, QA Supervisor D. J. Lokker, Plant Coordination Supervisor, Units 2/3

• W. C. Marsh, Plant Superintendent, Units 2/3

• M. C. Metz, Compliance F,gineer

• G. W. Mcdonald, Program audit and Assessment QA Supervisor

• D. E. Nunn, Nuclear Generation Services Manager

• M. B. Reardon, Program Development Supervisor (Westminster, CA)

• J. T. Reilly, Station Technical Manager

• D. B. Schone, Site QA Manager

• W. M. Schwab, Construction Manager

• D..E. Shull, Maintenance Manager

• K. A. Slagle, Material and Administrative Services Manager

• D. C. Stonecipher, Site QC Manager

• W. W. Strom, Nuclear Safety Group Supervisor -

• J. R. Tate, Operations Assistant Manager, Units 2/3

• J. J. Wambold, Nuclear Training Manager

• W. G. Zinti, Compliance Manager Various other, personnel *

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• Denotes those' attending the final exit meeting on August 23, 1985. Maintenance- .

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The inspectors examined three elements of the licensee's Maintenance Program: (1) the control and performance of maintenance; (2) the certification status of Quality Control Inspectors who had witnessed or

verified selected maintenance activities and (3) the backlog of

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maintenance activities. The inspection focustd on corrective and preventive maintenance performed on the following safety-related systems:

Safety Injection System, Diesel Generator Systems, 125 V DC System, Valve i.

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Motor Operators and the Event V Pressure Isolation Valves listed in Table 3.4-1 of the Technical Specifications for both Units 2 and Regarding the. control of maintenance, the inspectors reviewed portions of the licensee's administrative procedure, S023-I-1.2 (TCN 4-2), which covers Maintenance Order Preparation, Use and Scheduling. Based on this review, the inspectors determined maintenance was administratively controlled, in part, by a computerized system which covered a range of activities in a step-wise fashion, from the initial generation of Maintenance Orders (M0s) through the storage of the completed M0 in a History file. Additional control was provided by procedure, S023-0-13,

" Work Authorizations," which established clearance procedures for the actual conduct of work. Based on their review of portions of both of the above procedures, the inspectors identified no significant weakassses in the licensee's control of maintenance. The inspectors were favorably impressed by structure and discipline imposed on maintenance planning and execution of maintenance planning by the computerized control syste Notwithstanding the foregoing, there was one aspect of the licensee's program that constituted a concern. This relates to the provisions of paragraph 6.4.18.7 of procedure S023-I-1.2, which state that if no (approved maintenance) procedure exists, work instructions or drawings appropriate to the circumstances will be drafted and utilized in the Work Pla In-as-much as facility technical specification 6.8.1.a requires that maintenance be performed in accordance with written procedures; and specification 6.8.2 requires that such procedures be approved at the Department Manager level; and because Work Plans are not approved at the Department Manager level, the referenced provision appears to potentially conflict with the technical specification requirements. On the other hand, regulatory guidance also provides (in ANSI N18.7-1976) that " Skills normally possessed by qualified maintenance personnel may not require detailed step-by-step delineations in a written procedure." The concern arose because s_ome of the Work Plan's. examined by the inspectors contained four to six steps and thus were beginning to resemble a step-by-step procedure. None of.the examples,.however, was considered sufficiently clear-cut to constitute.an item of, noncompliance. Licensee management

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was advised of this concern during the Exit Meetin Regarding performanch of maintenance, the inspectors examined about 35 maintenance orders for the following:1'(1) administrative approval of the maintenance, (2) Limiting' Conditions for Operations were satisfied, (3)

approved procedures were u' sed, (4) Quality Control (QC) inspections were performed as required by'the procedure, (5) calibration of measuring and test equipment was. current and'(6) post-maintenance testing was performed as required. A-concern related,to the use of approved procedures was discussed in the1 preceding paragraph. However, no items of noncompliance or deviations were identifie The inspectors reviewed the certifications of some of the QC inspectors

.who had witnessed work covered by the M0s reviewed. All of these QC

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inspectors were found to be properly certified in the appropriate discipline (s). ,

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The inspectors reviewed the backlog of H0s for the following systems:

Safety Injection' System, Diesel Generators and 125 V DC System. A total of 368= items were on.the list of outstanding maintenance items for these

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systems for Units'2'and Many of these items, however, were placed on the list in anticipation of.a refueling outage in the near future. Other items were awaiting delivery of parts or an appropriate operating mode (e.g. Cold Shutdown). Still other items represented components which were not installed in plant, but had been removed for rework or overhau When allowance was made for these items, only 56 items on the list could be performed at the time of the inspection. Considering that two units are involved, the: inspectors concluded this was not an unreasonable backlog and maintenance was being performed in a timely manne During a plant tour cf the High Pressure Injection System (HPSI), it was noted that motors which drive the pumps in this system had not been doweled to their bases. This was also observed for the component Cooling Water Pump In later discussions the licensee stated that they had reviewed the situation by examining manufacturer's recommendations, design documents and common practices. As a result of this preview it was the licensee's position that doweling is for maintenance convenience only, that it is optional with the manufacturers and that it was not a consideration in any seismic analyse No violations or deviations were identifie . QA Audit Program The inspectors examined the following licensee documents to ascertain whether the licensee's quality assurance audit program and activities during the period of 1984 and 1985 to date conformed with regulatory requirements, commitments, and industry guides and standard ~

Topical QA Program

Quality Assurance Procedures

Organization and Responsibilities

Master Audit Schedule and Updates

Qualifications of Twenty Members of the QA Staff

• Reports of 14 of 28 QA Field Surveillances and 4 Audits Related to the Diesel Generators, Auxiliary Feedwater, High Pressure Safety Injection, and 125 V DC Power Systems

Corrective Action Requests, Resolutions and Weekly Status Reports to Corporate Management

QA Reports to the Nuclear Safety Group

QA Weekly Reports to Corporate Management

Quarterly and Annual Summary Reports of QA Activities

Minutes of the Nuclear Control Board

QA's Agendas for Bimonthly Meeting with the Executive Vice President At the time of this examination, the licensee's QA organization employed 217 individuals to accomplish the program mission. The QA management and audit personnel were found to be qualified pursuant to the pertinent standards. The number, frequency and scope of audits appeared to be proper. For example, the QA manager reported to the Nuclear Control Board on March 27, 1985 that 152 audits had been conducted during the

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period of September 26, 1984 to March 20, 1985. During these audits 163 corrective action requests were issued by the QA organizatio .

Based on the information contained in the licensee's records and discussions with audit and management personnel, the QA program audit activities appeared to be organized, extensive and comprehensive with appropriate management involvement and oversight to ensure the continued -

effectiveness of the progra The inspectors made the following observations to the licensee, Corrective Action Requests (CAR) have been transmitted to the Nuclear Safety Group along with the related approved audit reports !

and, therefore, may not always be timely. The QA Manager added the Nuclear Safety Review Group to the distribution list for CAR's involving technical specification requirements and others having nuclear safety significance to preclude such an occurrence, Although apparently individuals that have conducted audits have knowledge and expertise of the ac.tivities audited, audits performed pursuant to the reqtiirements of the program are not required to encompass a determination concerning the technical adequacy of work, but rather, only that the work was performed and checked by technically qualified individuals using appropriately approved procedure .

t No violations or deviations were identifie .- No'n-licensed Staff Training , t The following areas'of non-licensed staff training were reviewed by the inspectors:

INPO Accrediation Progress General Employee Orientation, .

Relevant Operating Experience Feedback Staff Qualification Requirements Training Records Licensee Management Involvement A discussion of each of these areas is provided below. Interviews of selected licenser personnel, regarding adequacy of training received, was not part of this inspection activity. These interviews were previously conducted during a July 1985 NRC inspection documented in Inspection '

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Report Number 50-206/85-27, 50-361/85-26 and 50-362/85-25 INPO Accrediation Progress The licensee has committed to accreditating ten training programs with INPO. Self-evaluation reports (SERs) for four programs (RO, SRO, STA and non-licensed operator) have been submitted to INP Three of the remaining SERs (I&C, electrical maintenance, and mechanical maintenance) were due to be submitted by 12/85. The remaining three SERs (chemistry, radiological protection and

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technical staff / managers) _were scheduled to be submitted by 6/8 However, the licensee. expected to submit the radiological protection SER to INPO by the end of August 1985. Accordingly, the inspectors concluded that licensee progress toward INPO accrediation of the ten training programs is in accordance with the established schedul General Employee Orientation Training (GEOT)

Several GEOT classes were attended by the inspectors during his initial site badging process. The inspectors noted the emergency plan training contained numerous references to the " Thunderbolt Siren," without the sound of the siren being presented on the training video recordings. Training management agreed to consider incorporating the sound of the siren into the GE0T video recordin During training on plant controlled access (security) procedures, a

" Practical Factors" (contamination protective clothing) exemption form created misunderstandings regarding the need to attend additional " dress out" training prior to entering a radiological entry permit (REP) zone. Exemption from the Practical Factors training would permit issuing of a red badge, but access to a REP zone would not be permitted. The licensee agreed to clarify the form. However, the inspectors were subsequently incorrectly permitted to enter a REP zone without having received the Practical Factors training. Licensee corrective actions were timely, thorough and effectiv Relevant Operating Experience Feedback The inspectors verified mechanisms were in place to incorporate relevant industry operating experience into training programs, including information identified by the ISEG in accordance with TS 6. Staff Qualification Requirements Qualification requirements for selected non-licensed staff positions were reviewed against the requirements and recommendations of ANSI N18.1-1971. For the job positions reviewed, qualification requirements were found to meet ANSI N1 In accordance with TS 6.3.1, qualification requirements for the Health Pyhsics Manager were also verified to be in accordance with Regulatory Guide 1.8, September 197 e. Training Records Training records for one individual in each of six non-licensed staff positions (including maintenance, chemistry, health physics and operations) were reviewed against the respective Training Program Description requirements for each discipline. With the available NRC inspection time, the licensee was unable to directly correlate documented training to Program Description requirement However, at the NRC inspection team exit meeting, the licensee indicated a previously unidentified method was available to relate

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the training records to Program requirements. Accordingly, review of training records will be considered an open item to be evaluated during a followup NRC inspection (361/85-22-01). Licensee Management Involvement Management involvement in non-licensed staff training was evidenced by division management participation in training activity evaluations. Each month, the training department issued a letter to division managers requesting their attendance and evaluation of training sessions applicable to their divisions. The manager's ;

evaluations were then specially identified, heavily weighted and factored into the training programs. The number of classroom visits by division management was tracked by month and discipline, and was displayed on charts in the Nuclear Training Department Monthly Management Visibility Report. This report is occasionally forwarded to the SONGS Vice President and Site Manager (VPSM).

The VPSM has also taken an active involvement in the INPO accrediation program. Every two weeks, he is sent a progress report to assure adherence to the implementation schedul No violations or deviations were identifie . Control and Content of Plant Procedures The inspectors reviewed the licensee's program for ensuring that technicalPr adequate procedures controlling plant activities are written and maintained in accordance with regulatory requirements. The inspectors determined that the licensee has an extensive, well documented program for the review, approval and revision of procedures. The depth of review was noted to be commensurate with the complexity of the procedure involved. ,All procedures dealing with activities under the quality assurance program were required to be evaluated for the potential of creating an unreviewed safety question. Quality assurance review was both required and evident. To~ ensure that qualified individuals perform *

the. required reviews, the licensee maintains a listing of personnel who are authorized,by management to participate in critical portions of the procedure review process. .The inspectors determined that the licensee's program for control of procedures 'was in all aspects in compliance with regulatory requirem,ent ~

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The inspectors verified proper implementation of the licensee's program by a . selective - review of completed records associated with procedures

. relating'to.the'four plant systems.on which the inspet* ion fccused. All records were= found to bej complete and in orde The licensee's program for annual / biennial' review of procedures was noted to be fully implemented with-virtually no procedures overdue for review. This was attributed to senior management involvement in the process. The inspectors also selected several procedures and verified that the correct revision was located in the unit 2 control room. One procedure was found to be in disagreement with the document configuration system index. The licensee determined the error to be administrative in nature and took t

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prompt action to correct the deficiency. The inspectors concluded that the problem was not a safety concern and appeared to be an isolated case.

l The inspectors made one observation with regard to the use of temporary

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change notices (TCN). The technical specifications and licensee procedures allow temporary changes be made to procedures provided that appropriate reviews and approval are obtained. The licensee frequently uses TCNs to correct and update procedures, however, per the licensee's l

program, TCNs may remain in effect for an indefinite period. Although

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TCNs are appropriately reviewed for correctness, their extended use l presents potential problems. TCNs are not required to be incorporated l page for page into a procedure, but rather may be simply attached to the l front of the procedure. This practice could cause difficulty in the use

of a procedure, particularly when the TCN involves many pages of an l infrequently used procedure. The licensee's program also allows for j multiple TCNs to.be outstanding against a procedure, which increases the l difficulty of ensuring that a procedure is correct and complete when l performed. The licensee's normal-practice is to incorporate TCNs into

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procedures when possible and to minimize the number of TCNs outstanding, however, the inspectors concluded that a" timely incorporation of TCNs into procedures by procedure revisions would be prudent from an administrative and usage standpoin The inspectors reviewed selected procedures associated with the operation and testing of the four systems on which the inspection centered. The nrocedures were compared with technical specification, operations, surveillance requirements, vendor technical manuals, the final safety

analysis report (FSAR) and actual plant conditions. In general, only l minor deficiencies were noted which the licensee took prompt action to

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correct. Two questions did arise, however, which will be followed up in I a future inspection effor In comparing the technical specification

[ surveillance requirements to the licensee procedures and the FSAR, the inspectors noted that due to the wording of two surveillance requirements, the technical specifications may not be consistent with the l plant design. Surveillance requirement 4.8.1.1.2.d.6 requires that on a simulated loss of the emergency diesel generator with offsite power not available, the loads are shed from the emergency busses. The plant design for this scenario has the high pressure safety injection pumps remaining connected to the bus. Surveillance requirement 4.8.1.1.2.d. requires that on a simulated loss of offsite power in conjunction with an

[ ESF test signal, the emergency diesel generator starts and energizes the

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emergency busses within 10 seconds. As described in the FSAR, the l diesels are designed to start and load within 10 seconds of a loss of I voltage signal (LOVS), however, on a loss of power to the emergency busses, an approximately 1 second time delay occurs before the generation of a LOVS signal. The surveillance requirements are not clear concerning whether the 1 second delay is considered in the testing. In that the

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plant is functioning as assumed in the safety analysis, a safety concern does not appear to exist. The licensee agreed to discuss the wording of these surveillance requirements with the NRC Of fice of Nuclear Reactor Regulation and take action as necessary to ensure the requirements are consistent with the safety analysis (361/85-22-02).

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s TheJinspectors reviewed severillof the licensee's procedures for in service ~ testing .(IST) of 'ptmps. The procedures complied with section XI of 'the ASME code including the' requirement to declare a pump inoperable if the' differential pressure across the pump falls below 90 percent of the baseline measurement. The inspectors questioned whether the operability limit of IST' requirements was bounded by the safety analysi An example would be's pump for which the safety analysis assumed a 5 percent degradation. In accordance with the ASME code, the pump could be considered operable with up to a 10 percent degradation although the pump would be outside the safety analysis assumptions. Licensee representatives agreed.to review the IST program with regard to this concern (361/85-22-03).

In general, the inspectors concluded that the licensee's program to control the issuance and use of procedures was effectively implemented and that the technical content of the procedures reviewed was in compliance with regulatory requirements. The station commitment to procedural compliance was strongly noted through both interviews with station personnel and by review of station documentatio . Measuring and Test Equipment A programmatic review of the Measuring and Test Equipment (M&TE)

implementation procedures was conducted to assess the licensee's performance. The review included: the criteria for the assignment of calibrated equipment; marking and identification of calibrated and non or out of calibration equipment; controls for issuance of calibrated equipment; and the control of lost, broken, or out of calibration test equipment. The inspection was conducted in two parts: an onsite review of M&TE used in the calibration of plant equipment and an offsite review of the M&TE calibration progra The onsite inspection reviewed the equipment as it was received onsite from the Metrology Department, stored in the tool room, issued to maintenance personnel, collected by the tool room for recalibration, and returned to the Metrology Department for calibration. The requirements of ANSI N-45.2.4 (1972) were used to evaluate the licensee's activitie The inspection of the tool issue room verified: that calibrated M&TE was segregated Vrom noncalibrated or broken equipment; that controls were in place to prevent out of calibrated equipment from being issued; and that a record was maintained of each work order and surveillance where M&TE was used. Ten items in the tool room were sampled for proper label identification, calibration records, and permanent identification. The inspector verified.that a sample of four items of M&TE which had been used to perform Technical Specification Surveillance procedures were calibrated through the Metrology Laboratory, were issued by the tool room, had the work order. recorded, and had been recalled for calibration within the time limits required by the calibration procedur The offsite inspection of M&TE was performed to review the controls used to calibrate the M&TE per ANSI N-45.2.4. (1972). The actual calibration of the equipment is performed by contractors who have been approved by the licensee's Quality Assurance Department. The inspectors reviewed the initial and subsequent audits of a sample of contractors who perform the

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M&TE calibration. At the Westminster, CA facility the inspector observed the vehicle used to transport the equipment to and from the site, the other facilities where the licensee is establishing it's future metrology lab, and the storage area for the calibrated and non calibrated equipment. The inspector reviewed a sample of calibration records for the equipment received from the contractors and a sample of the computerized records that track the location of each piece of M&TE used by the licensee or by contractors working at the sit No violations or deviations were identfie . Technical Specification Required Surveillance The objective of this part of the inspection is to assess the licensee's program and implementation effectiveness in meeting the surveillance test requirements as specified by the Technical Specifications. The areas

. emphasized during this inspection are: HPSI, AFWS, DG and 125VDC system To assess the program effectiveness, the inspectors reviewed the

' licensee's computerized -system _ for scheduling surveillance activities according.to the Technical-Specification requirements. The inspectors also review the Licensee Event Reports (LER) and QA audit and monitor reports-related to surveillanc Tn assess the implementation:of the program, the inspectors reviewed a-sample of 27 completed daily, weekly, monthly and other periodic surveillance test procedures. These procedures were reviewed for completeness of the. test report, identification and resolution of discrepancies ~, proper use of measurement and test equipment (M&TE), and proper control of component configuration when equipment was removed and returned to servic In addition, the inspectors observed a monthly surveillance test on a DG start in Unit Based on these evaluations, the inspectors concluded the licensee met the requiremen No violations or deviations were identifie . Offsite/Onsite Committee Activities The purpose of this portion of the inspection was to verify that the offsite and onsite safety review committees or their equivalents have been established and are functioning-in accordance with Technical Specification requirements and commitments in the FSAR. The committees reviewed were the Nuclear Safety Group (NSG), the Onsite Review Committee (OSRC), and the Independent Safety Engineering Group (ISEG). The documents reviewed for this inspection included:

Procedures on each committee's activities

Resumes on committee supervisors and members

Monthly Reports for the NSG and ISEG

Monthly and Special Meeting Minutes for the OSRC l

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'* Audit Report-No.'SCES-028-85,lQA Audit of the OSRC

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The NSG is the offsite review group required by Technical

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the Engineering and Construction Department-QA Procedure E&C 40-9-21 and the T The NSG is a staff organization composed of seven staff specialists and a supervisor. Their primary function is to review facility and procedure changes, tests, experiments and unplanned evects that potentially affect nuclear safety. The inspectors examined the monthly reports written since January, 1985 (six monthly reports). The NSG appears to be meeting all of its responsibilitie Onsite Review Committee (OSRC)

The OSRC is the onsite review group required by TS 6. The OSRC organization and responsibilities are contained in Site General ,

Order S0123-GCO-1 and the T The OSRC reviews safety aspects of 1 station administration, maintenance, and operations activities to ensure they are consistent with the licensee's policy, approved

, procedures, and operating license provisions. The minutes of all meetings held since January 5, 1985 (seven monthly meetings to meet the TS requirements and twelve special meetings) were examined by the inspectors. The inspectors also attended a scheduled monthly OSRC meeting, for July, and a special OSRC meeting during the inspection. The committee is very active and appears to be meeting all of its responsibilitie Independent Safety Engineering Group (ISEG)

s The ISEG is required by TS 6. The ISEG organization and responsibilities are contained in E&C 40-9-22 and the TS. The ISEG is composed of six dedicated full time engineers and a superviso The ISEG examines plant operating characteristics, NRC issuances, indus.try advisories, Licensee Event Reports and other sources of plant design and operating experience information which may indicate areas - for improving plant safet The inspectors reviewed the monthly reports written since January, 1985 (six monthly reports).

The ISEG appears to be meeting all of its responsibilitie No violations or deviations were identifie . Plant Modifications A review.was conducted of the licensee's system for controlling modifications to the plant configuration as described in the technical specifications incorporated in the licensee. . The review encompassed a ,

examination of the licensee's procedures and also examination of six design change packages which involved modifications to Units 2 & '

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~ Modifications to the facility are controlled through the use of a construction work order, this work order package contains all the documents necessary to implement the design chang Changes to the facility which require physical modifications are authorized by the station and documented on a proposed facility change package (PFCP). The PFCP will contain a written engineering evaluation to determine if the modification involves a change _to the technical specification or the facility operating license or would involve an unreviewed safety question. This evaluation is performed to meet the requirements of 10 CFR 50.59. The review also includes an evaluation of changes to fire

barriers and/or the fire detection suppression system as described in the Fire Hazards Analysi PFC procedure defines the need for generating a PFCP and in addition identifies the required review and approval needed for processing of the PFC. Other disciplines which would be involved with the construction activity such as the SCE Project Engineer, the configuration control organization, construction and start-up organization and the nuclear safety group have their responsibilities defined in the PFCP Procedur The procedure also includes any necessary changes to be made to other permanent plant documents such as P&ID's, electrical one line diagrams, or if required the FSAR or FHA changes which should be processed along with the facility chang Six prepared design change packages were reviewed for compliance with the PFCP and CWO. procedure conformance. Packages reviewed involved modifications to the Unit 2 Auxiliary Feedwater System, the Emergency Diesel Generators, and Shutdown Cooling Systems. Modific,tions to Unit 3 included installation of new excore start-up channel equipment and modification of ESF panel circuit In addition to the evaluations performed to determine the effect of the permanent plant modification on plant safety, an evaluation is-performed on construction activities'which could possibly have an effect on nuclear safety related equipment. This, evaluation is performed by the

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A review was" conducted.of'the design change packages. As discussed above,ithe sampled documentation were found to be in accordance with procedures anil regulatory reiuirement l

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However, during <a . tour of the two 4.0 KV switchgear rooms in Unit 3, construction activity was observed in progress for the installation of

electrical calilet"'Some of the work that was in process was being performed directly above;and in front'of safety related switchgea In order to accommodate' access to the'switchgear cubical for removal of circuit breake'rs, scaffolding had'been erected above the switchgear so that itldid not block access.to the switchgear, but'the scaffolding had been erected and,was supported 1from safety related cable tray supports above the switchgea

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The scaffolding which had been erected was completely supported by

! ' unistruct type structural members which supported cable trays and now, in i

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addition, supported the additional weight of the scaf folding. A concern was expressed that the cable tray supports may become over loaded with the additional weight of the scaffolding during a design basis seismic event. To resolve this concern the licensee has undertaken an evaluation to determine whether the structural integrity of the cable tray supports was in question. The licensee is also reviewing the procedures which permitted the work to be performed without adequate analysis as observed by the NRC inspector The matter of cable tray support loading and construction preparations will remain unresolved pending completion of corallary examinations of modification concerns by the resident NRC inspectors at San Onofr (50-362/85-21-01).

10. Vendor Field and Technical Manual Change Notices The objective of the inspection of this area is to determine 1) whether the licensee is effectively identifying, controlling, distributing, scheduling and implementing vendor technical changes for modifications required to equipment; 2) whether technical manuals are controlled and maintained current in accordance with an adequate document control program. The licensee's response to NRC IE Information Notice and INPO Significant Event Evaluation Information Network reports related te vendor notices was also assesse The following licensee's organizations are responsible for this program:

SCE Configuration Control

SCE Independent Safety Engineering Group (ISEG)

SCE Engineering and Construction

SCE Corporate Document Management (CDM)

Bechtel Power Corporation The inspectors reviewed selected procedures and interviewed responsible staff of these organizations to verify an executive program was implemented to control vendor change notices. The inspectors also interviewed selected SCE personnel to assess their understanding of the responsibility and response to vendor change documents which might be sent to them directly. The inspectors found no evidence of lack of control of these documents. Furthermore, the inspectors noticed that SCE participated in a Bechtel program to identify deficiencies and vendor changes in other Bechtel nuclear projects that may effect San Onofr This appears to be an effective program to enable SCE to promptly identify and respond to vendor notice During the NUS audit in 1983 of vendor supplied data, a concern had been raised as to the ~ control of this data for distribution on site and maintenance of technical manuals. The finding concerned a lack of a systematic method or procedure to capture vendor supply data an distribute this data at various controlled locations on site. Following the issuance of this finding the SCE quality assurance organization conducted a surveillance to determine the extent of the identified deficienc l w________-_-_____- .

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This concern had also been previously identified by the quality assurance organization and documente In response to the above deficiencies, the Configuration Control organization responded to the concern with strengthening of configuration control procedures for the control of document change control for supplied data. This procedure described the methods to control document maintenance of vendor supplied. data which were assigned to the Bechtel Power Corporation / Corporate Document Management vendor print log. In addition, the Corporate Document management (CDM) organization implemented procedures which control the release and distribution of vendor supplied data to controlled locations. The concern identified by NUS during their early audit has been adequately satisfie No violations or deviations were identifie . Unresolved Items An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptable item, an open item, a deviation, or a violatio .

12. Exit Meeting On August 23, 1985, an exit meeting was conducted with the licensee representatives identified in paragraph-1. The inspectors summarized the scope of the inspection and findings as-described in this repor .