Text

Rev 6 to Dept QA Procedure E&C 24-10-15, Preparation,Review & Approval of Proposed Facility Changes (Pfc) & Pfc Packages (Pfcp) for San Onofre Nuclear Generating Station 1,2 & 3. Proposed Change Notices 1,2 & 3 Encl
	ML20151A417
Person / Time
Site:	San Onofre
Issue date:	02/01/1988
From:	Eastman L; SOUTHERN CALIFORNIA EDISON CO.
To:	;
Shared Package
ML20151A165	List: ML20151A162; ML20151A335; ML20151A360; ML20151A364; ML20151A388; ML20151A390; ML20151A404; ML20151A414; ML20151A417; ML20151A427; ML20151A436; ML20151A439; ML20151A651; ML20151A661; ML20151D441; ML20151D513;
References
	E&C-24-10-15, NUDOCS 8807190366
	Download: ML20151A417 (49)
	v • d • e

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' Southern Cantornia Edison Company ggc g4.gn.;5 Engineering and Construction Department DEPARTMENT QA PROCEDURE REV. 6 l EFFECTIVE: 02/oyas !

PREPARATION, REVIEW, AND APPROVAL OF PROPOSED FACILITY CHANGES (PFC) AND PROPOSED FACILITY CHANGE PACKAGES (PFCP)

FOR SONGS 1, 2&3 A. GENERAL INFORMATION 1.

The purpose of this procedure is to establish the process for initiation, preparation, review and approval of Proposed Facility Changes (PFC) and Proposed Facility Change Packages (PFCPs) prepared by the Engineering & g Construction Department (E&C) or Nuclear Generating Site Department (NGS). It is applicabl: to either permanent or temporary modifications to the plant configuration.

2. The originator for a non-Station PFC is the Responsible SCE Engineer (E&C). The originator for a Station initiated PFC is the System Cognizant Engineer (NGS).

3. Design changes to the base plant design which require physical R modifications must be authorized by Station and/or Project approval of a PFCP (and attachments) which provides the following:

a. A written engineering evaluation / construction sa fety assessment, prepared in conformance with the Code of Federal Regulations, Title 10

1) Part 50.59, Changes, Tests and Experiments, to evaluate the proposed facility change and determine that it does or does not involve a change in the Technical Specifications incorporated in the License and does or does not involve an unreviewed safety question l

I Prepared By: b,g 7 'i -

/2/4 t/d7 I ppfo,p' U ~Dite l l Approved By:_ k k M r w3 NI.M') l l Responsible ivision Manager Da'te {

Approved By: / t R"/2' 7/h?

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Date l l

Approved By: $hbbM/

QA Organization Manag'er LN0 '0 7 Date l l l 8807190366 880715 Page 1 of 21 DH ADOCK 0500 %

Southern California Edison Company ggg g4 g9_y5

Engineering and Construction Department

$"$"$I g l REV. 6 l EFFECTIVE: 02/01/88 ll

2) Part 50.54 (p)(q), Conditions of Licenses, to evaluate the proposed facility change and determine that it does or does not decrease the effectiveness of the Security Plan or the Emergency Plan

b. A written environmental evaluation to ensure that the proposed facility change does not result in an unreviewed environmental question

c. A written evaluation to ensure that the pr<, posed design change will conform to and preserve the "As low ts Reasonably Achievable (ALARA)" criteria in accordance with Nuciear Regulatory Commission g (NRC) Regulatory Guide 8.8, Informatior. Relevant to Ensuring that Occupational Radiation Exposures at Ncclear Power Stations will be As low As Reasonably Achievable (ALAR',)

d. An evaluation of the proposed design change to ensure that it does not adversely impact the fire protection system / program or violate the Updated Fire Hazards Analysis (UFHA)

e. An evaluation of the proposed design change to ensure that it achieves its desired result, is complete, constructible, operable and maintainable

4. This procedure shall apply to all design work regardless of safety class within and along the boundary (including the outside isolation zone) of the SONGS 1, 2&3 Plant Protected Area. It shall also apply to facilities outside the Protected Area as follows:

Facilities not excepted by the conditions of E&C 24-10-15, Exhibit 1, Criterion B.5, which include:

a. Switchyard

b. Condensate Storage Tank and Transfer Piping System

c. Meteorological Instrumentation

d. Emergency Siren and Paging System

e. Radiation Monitoring Stations

f. Circulating Water Conduits and Structures

g. Onsi,te and Offsite Probable Maximum Flood Facilities Page 2 of 21

Southern California pdeson Company E&C 24-10-15 9gppggggy;

Engineering and Construction Department QA PROCEDURE l REV. 6 l EFFECTIVE: 02/01/88 ll

h. Facilities, systems or components outside the Protected Area which interface with and a ffect the performance or operation of facilities, systems or components inside the protected area (e.g.,

Fire Protection, including components stored for use on dedicated /

alternate shutdown systems, Communications, etc.)

1. Emergency Offsite Facilities (EOF)

5. For clarification, the PFC developed under the auspices of this procedure N' for Design Change Packages (DCPs) only, will be combined with DCPs described in E&C QA Procedure E&C 24-10-16,

6. This procedure complies with the requirements of the applicable documents referenced in the Matrix of Regulatory Reference Material for E&C QA Procedures.

8. PROCEDURAL ACTIONS e

ACTION I - DETERMINING NEED FOR A PFC Oriainator (SCE or Desianeel

1. Receive the proposed design change, and review in accordance with the criteria in Exhibit 1 to determine whether a PFCP is required.

a. If a PFC is not required, review the design change in accordance with ACTION V.

g

b. If a PFC il required, proceed to ACTION II.

. ACTION II - DETERMINING LONG AND SHORT FORM ATTACHMENTS Oriainator

1. Review the proposed design change against the following criteria:

a. The facility change does not involve a change in the License, and/or Technical Specifications.

b. The facility change does not involve an unreviewed safety question (as defined by 10CFR50.59) and/or unreviewed environmental question.

c. The facility change does not affect or change the design bases of the Updated Final Safety Analysis Report (UFSAR) for Units 2&3 or Final Sa fe ty Analysis (FSA) for Unit 1 or Updated Fire Hazards Analysis (UFHA), Security Plan or Emergency Plan.

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' Southern California Edison Company ESC 24-10-1S

" Engineering and Construction Department

$"$$In REV. 6 EFFECTIVE: 02/01/88;l 2.

If all of the criteria are met, prepare a short form PFC (see Exhibit 2) in accordance with ACTION IV; otherwise, a long form PFC (see Exhibit 3) is prepared in accordance with ACTION III.

= ACTION III - PREPARATION OF LONG FORM PFC Oriainator

1. Review the proposed design change in accordance with ACTION V.

2. Initiate preparation of proposed facility change evaluation as shown in Exhibit 3.

a. Notify Supervisor, Configuration Control of the intended change and request proposed facility change number and revision number,

b. Complete the following on FORM 26-294, Proposed Facility Change (PFC cover sheet): , . ,

K

1) Originator - Name of originator

2) Number -

Insert PFC number obtained from the Supervisor, Configuration Control - Include revision number

3) Date and affected Unit number - Date of PFC preparation and affected unit (s)

4) Block 1 - Provide title of PFC, a one or two sentence synopsis describing the facility change (including all applicable Design Change Package [0CP] number [s] and revision number, if applicable), Quality Class (I, II, III, IV or Safety Related, Non-Safety Related or Non-Safety Related - Fire Protection) and the Seismic Category (I, II, III, II/I or A, B, C, B/A)

c. Obtain a Construction Safety Assessment (CSA) in accordance with Exhibit 2 of E&C 24-10-16.

NOTE: The CSA will generally be prepared by the Constructing or Testing Organization for an Engineering Construction Project (ECP) or by Station Technical for non-ECP, concurrent with review of the proposed facility change.

i l

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' Southern Cahfornia Edison Company ESC 24-10-15

. Engineering and Construction Department DEPARTMENT QA PROCEDURE l REV. 6 .

l l EFFECTIVE: 02/01/38_l

d. Complete or obtain page one of FORM CC(123) 183, San Onofre Nuclear '

Generating Station Configuration Document Checklist. (Responsible Engineer (E&C) and Station Originator (NGS) shall complete the form as instructed by keypoints on the reverse side.] Check as applicable if the proposed facility change will affect any of the g configuration document categories as shown on FORM CC(123) 183, San Onofre Nuclear Generating Station Configuration Document Check List.

NOTES: (1) Page two of CC(123) 183 is completed by Station personnel after DCP approval in accordance with' Site p4 Configuration Control Procedure S0123-XIV-4.2, Site

Design Change Process.

(2) As a minimum, the Originator must identify on Form CC(123) 183, the Design Disclosure Document Categories affected by this facility change. If any document categories are a f fected, complete FORM CC(123) 184, San Onofre Nuclear Generating Station Configuration Documents Requiring Change. Complete forms as instructed by Keypoints on reverse side of form.

If Forms 183 and 184 were prepared as part of a proposed decign change, these notes are redundant. However, the subject forms are h. -

required to be included in the PFC section.

e. Complete or obtain FORM 26-292, Fire Protection Design Check List, in accordance with Exhibit 4.

3. R Assemble the PFC consisting of:

Proposed Facility Change (Form 26-294)

Engineering / Safety, Environmental, and ALARA Evaluation (Exhibit 3)

Design Change Package Plant Hazards Requirements (Form 26-182)

ALARA Design Review Check List, if required (Form 26-247)

Fire Protection Design Check list (Form 26-292)

Configuration Document Check List and Attachments [ Form CC(123) 183, m g'

Form CC(123)184)

Security Plan Check List (Exhibit 7)

The DCP containing Construction Safety Assessment (CSA)

(see Exhibit 2 of E&C 24-10-16) or other proposed design changes (e.g., Temporary Facility Modification, Field Change Notices (FCNs)

Special Test Procedures, etc.)

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' Southern Cahtornia Edison Company I5

. Engineering and Construction Department QA PROCEDURE REV. 6 [

EFFECTIVE: 02/01/88 [

Others (as appropriate)

List of Licensing Commitments Design Criteria Document Changes System Description Changes Emergency Plan Changes Security Plan Changes License and/or Technical Specification Changes UFSAR, FSA and UFHA Changes Environmental Qualification (EQ) Haster List Changes N, NOTE: For Unit 1 only, reference Design Criteria M-Number in Reference Section of PFC (or attach Design Criteria Waiver letter).

Cover letter (only) that forwards any necessary Security Plan changes in accordance with Step 6.

NOTES:

(1) Clearly indicate which items are included in the PFC by R checking the appropriate boxes in Section 2 of Form 26-294. If compliance document revisions are not required as a result of design changes, indicate by writing the word "N0" in the appropriate boxes.

(2) Refer to Exhibit 6 for guidelines in determining the R effect a design change may have on the Emergency Plan.

4. The- need for a change in the License, and/or the Technical Specifications, UFSAR, UFHA and any unreviewed safety and/or environmental question and/or decrease in the effectiveness of the Security Plan or the Emergency Plan shall be identified in a memorandum to Nuclear Licensing.

Forward signed a copy of the memorandum to the Manager, Station Technical (if not by same), Cognizant Station Supervising Engineer Engineering Group Leader.

and Nuclear NOTES: (1) In those cases where the PFC is initiated early in the design phase, and the full requiremcnts of this Procedure R cannot be met, the PFC must identify the deviations.

Approval of the PFC in this case will be for design only, and this will be so stated on Form 26-294. A revised PFC which meets the requirements of this Procedure must subsequently be submitted and approved prior to the implementation of the change. All approvals must be in accordance with the normal PFC review / approval cycle.

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Southern CaMornia Edison Company ELC 24-10-15 DEPARTMENT I

Engineering and Construction Department QA PROCEDURE i REV. 6 [

EFFECTIVE: 02/01/881 (2) If the proposed facility change involves changes to the License or Technical Specifications; or reduces the effectiveness of the Security Plan or Emergency Plan as described in 10CFR50.54 (p) and (q); or if the PFC involves an unreviewed safety or environmental question, R the PFC cannot be approved by the Station until the changes are approved by the Nuclear Regulatory Commission (NRC) or dispensations are received. Nuclear Licensing will obtain NRC approvals in accordance with E&C QA Procedure E&C 40-9-10 and/or E&C QA Procedure E&C 40-9-13 Absence of approval should not prevent PFC preparation proceeding to Step 10. The PFCP is not to be transmitted to the Station for ECPs until NRC approvals are received.

(3) If the proposed facility change involves Technical Specification changes which are not applicable in the operational MODE during which the facility changes are to be installed (e.g., MODES 5&6), then the PFC can be R approved by the Station with precautionary notes which prevent the entry into an operational MODE where the Technical Specifications are applicable until NRC approval is received. These restrictions should be noted in Block 7 of the PFC cover sheet (Fom 26-294).

5. For modifications requiring revision to the Security Plan, prepare a transmittal memorandum to the Supervisor, Security Compliance forwarding an attachment identifying the recommended / required changes to the Security Plan.

Forward copies to the appropriate Supervisor of Nuclear Licensing and Manager, Station Technical. Forward in accordance with the requirements for 10CFR73.21 materials. The transmittal memorandum shall not contain Safeguards information and shall be annotated to indicate that when separated from the Attachment, it is "decontrolled." (See Exhibit 5 -

00 NOT USE O "0ECLASSIFIE0".)

6. Complete Block 3 of Form 26-294 as follows:

a. Indicate if the proposed facility change requires review by Station Health Physics (ALARA), Fire Protection or Security becauSe of impacts to these systems:

1) ALARA - based on considerations in Section VIII of Exhibit 3.

Complete or obtain FORM 26-247, ALARA Design Review Check List, R if required

2) Fire Protection - based on the criteria listed on Form 26-292 and in Exhibit 4 R l

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Southern Cahtornia Edison Company ESC 24-10-15

. Engineering and Construction Department 0P i l REV. 6 l EFFECTIVE: 02/01/88

3) Security -

based on whether the facility change impacts security systems and/or vital or protected area boundaries (Exhibit 7) R 7.

Request safety review from Nuclear Systems Engineering (NSE) Group R Leader.

NOTES: (1) For a.sembly with a DCP (PFCP) see E&C 24-10-16, ACTION II.

(2) Draft review coments shall be incorporated upon M' completion of the PFCP review.

Nuclear Systems Enaineerina (NSE) Group Leader

8. When reviewing the PFC or PFCP, verify correctness of the determinations made in respect to the following:

a. Engineering and Safety Evaluations O

b. Quality Class and Seismic Category

c. ALARA Considerations

d. Implementation

e. Changes to the License and/or Technical Specifications or to the design basis of the UFSAR, FSA, UFHA, Security Plan or Emergency Plan, as appropriate, have been initiated and properly reflect the design change.

f.

Proposed design change q.d_ogi or does not involve an unreviewed safety R question.

g. Design Change Package Hazards Requirements (Form 26-182) i .'

h.

If Steps (e) and (f) indicate such changes and/or a review is g required, identify this need in a memorandum to Nuclear Licensing.

9. Sign Block 4 of Form 26-294 and forward, along with the PFCP, to the SCE Project Engineer (E&C) for E&C prepared PFCPs. Forward to Supervisor, Configuration Control (NGS) for NGS prepared PFCPs and proceed to Step 13.

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Southern Calsfornia Edison Company E&C 24-10-15

$ Engineering and Construction Department

$P l REV. 6 l EFFECTIVE 02/01/88 l l SCE Pro.iect Enoineer (E&C)

10. Review the PFCP to assure that the following exist:

a. Environmental Evaluations N

NOTES: (1) If the change involves activities whose nonradiological effects are confined to onsite areas previously disturbed during site preparation and plant construction, the Manager, Station Technical / Project Engineer shall provide the Environmental Engineer approval signature.

(2) When a proposed change involves activities or impacts whose nonradiological effects impact offsite areas, then the PFCP must be sent to the Environmental Engineering Group for further evaluation.

(3) If an unreviewed environmental question exists, the PE, N' shall notify Licensing by written memorandum.

b. Certification that an unreviewed safety and/or environmental question does or does not exist

c. Certification that the proposed design change does or does not R involve a change to the License and/or Technical Specifications, or to the design basis of the UFSAR, FSA, UFHA, Security Plan or Emergency Plan

d. Approval that the proposed design change achieves its objective, is R complete, constructible, operable, and maintainable

e. Approval of changes to:

Piping and Instrumentation Diagrams (P& ids)

One Line Diagrams Elementary Diagrams Control Panel Drawings General Arrangement Drawings

f. ALARA, Fire Protection, and Security review requirements on Form 26-294 are correct

11. Approve Form 26-294, Block 4, if all the above criteria are met.

NOTE: Steps 10 and 11 are performed by Manager, Station Technical for N' NGS prepared PFCPs.

12. Forward the PFCP to the Supervisor, Configuration Control.

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Southern CaMornia Edison Company ESC 24-10-15 IEngineering and Construction Department DEPARTMENT QA PROCEDURE l REV. 6 l LEFFECTIVE: 02/0U881 Supervisor. Confiauration Control (For Information Only)

13. Process Blocks 5 through 7 of Form 26-294 in accordance with Station Engineering Procedure S0123-V-4.14, Proposed Facility Change.

NOTES: (1) Step 13 is applicable to all NGS initiated PFCPs.

(2) Upon completion of Blocks 1 through 7 of Fonn 26-294, implementation of the PFCP may proceed subject to any restrictions noted.

(3) In the case of PFCs involving Technical Specifications changes, the PFCP will be forwarded to the Nuclear Safety N.

Group prior to completing all signatures on Block 5.

14.

Return a copy of the signed Form 26-294 to the Originator to provide feedback as to whether PFCP is approved or disapproved.

15. Obtain signature from Quality Assurance verifying PFCP meets quality requirements (Block 8).

16. Forward PFCP to the Nuclear Safety Group.

Construction / Retrofit (F&C)/ Maintenance (NGS1 p,

17. Implement the change i_n accordance with the approved design disclosure documents, using the appropriate Work Process Procedures.

Nuclear Safety Group

18. Upon receipt of the PFCP from Station, review the safety evaluation to verify that the change does not involve an unreviewed safety question or Technical Specification change.

19. Complete Block 9 of Form 26-294 and return along with the PFCP to the Supervisor, Configuration Control.

Supervisor. Confiouration Control (For information Only)

20. Process Blocks 10 and 11 of Form 26-294 to obtain required signatures from Station personnel.

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'Southem Cahtomia Edison Company ESC 24-10-15

. Engineering and Construction Department DEPARTMENT QA PROCE0VRE l REV. 6 l EFFECTIVE: 02/01/88,l a

ACTION IV - PREPARATION OF SHORT FORM PFC R Oriainator

1. Review the proposed design change in accordance with ACTION V. R

2. Identi fy any non-design basis changes to UFSAR, UFHA, SP or EP for Units 2&3 and to the UFHA, SP, or EP for Unit 1 in a memorandum to Nuclear Licensing.

3. Initiate preparation of proposed facility change evaluation as shown in Exhibit 2.

a. Notify Supervisor, Configuration Control of the intended change and request proposed facility change number and revision number.

b. Complete the following on the PFC cover sheet Form 26-294. [.

1) Originator - Name of originator

2) Number -

Insart PFC number obtained from Supervisor, Configuration Control. Include revision number

3) Date of affected Unit number - Date of PFC preparation and ;7 affected unit (s)

4) Block 1 - Provide title of PFC, a one or two sentence synopsis describing the facility change -(including all applicable DCP number (s) and revi:lon number, if applicable), Quality Class (I, II, III, IV or Safety Related, Non-Safety Related or Non-Safety Related - Fire Protection) and the Seismic Category (I, p' II, III, II/I, or A, B, C, B/A)

c. Obtain a CSA in accordance with Exhibit 2 of E&C 24-10-16.

NOTE: The CSA will generally be prepared by the Constructing or Testing Organization for an ECP or by Station Technical for non-ECP, concurrent with review of the proposed design change.

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toutnern CaMornia Edison Company ESC 24-10-1S DEPARTMENT

. Engineering and Construction Department QA PROCEDURE l REV. 6 l l EFFECTIVE:n?/m /99 l

d. Complete or obtain page one of Form CC(123) 183. (Responsible Engineer (E&C) and Station Originator (NGS) shall complete the form as instructed by keypoints on the reverse side.] Check as R applicable if the proposed design change will affect any of the configuration document categories as shown.

NOTES: (1) Page two of CC(123) 183 is completed by Station personnel after DCP approval in accordance with Site Configuration @'

Control Procedure S0123-XIV-4.2.

(2) As a minimum, the Originator must identify on Form CC(123) 183, the design disclosure document categories affected by this change. If any document categories are affected, complete Form CC(123) 184. Complete forms as instructed by Keypoints on reverse side of fonn.

If Forms 183 and 184 were prepared as part of a proposed design change, these notes are redundant. However, the subject forms are required to be N included in the PFC section.

e. Complete or obtain Form 26-292 in accordance with Exhibit 4. g

4. Assemble the PFCP consisting of:

PFC Section Proposed Facility Change (Form 26-294)

Engineering / Safety, Environmental, and ALARA Evaluation (Exhibit 2)

ALARA Design Review Check List, if required (Form 26-247)

Fire Protection Design Check List (Form 26-292)

Design Change Package Plant Hazards Requirements (form 26-182)

Configuration Document Check List and Attachments (Form CC(123) 183, R Foi'm CC(123)184]

Security Plan Check List (Exhibit 7)

Station Emergency Planning Design Change Check list (Exhibit 6)

The DCP containing CSA (see Exhibit 2 of E&C 24-10-16) or other proposed design changes (e.g., Temporary Facility Hodification, FCNs, Special Test Procedures, etc.)

Others: (as appropriate)

List of Licensing Commitments Design Criteria Document Changes System Description Changes Emergency Plan Changes Security Plan Changes License and/or Technical Specification Changes p*i UFSAR, FSA and UFHA Changes Page 12 of 21

Southern Cahtornia Edison Company ggg g4,39_l5 Engineering and Construction Department $P T

REV. 6 l l

EFFECTIVE: n?/n1/Ra l Cover letter (only) that forwards any necessary Security Plan changes in accordance with Step 6.a.3.

n NOTES: (1) Clearly indicate which items are included in the PFC by checking the appropriate boxes in Section 2 of Form 26-294. If compliance document revisions are not required as a result of design changes, indicate by writing the word "N0" in the appropriate boxes.

(2) Refer to Exhibit 6 for guidelines in determining the R effect a design change may have on the Emergency Plan.

5. For modifications requiring revision to the Security Plan, prepare a transmittal memorandum to the Supervisor, Security Compliance forwarding an attachment identifying the recommended / required changes to the Security Plan.

Forward copies to the appropriate Supervisor of Nuclear Licensing and Manager, Station Technical. Forward in accordance with the requirements for 10CFR73.21 materials. The transmittal memorandum shall not contain Safeguards Information and shall be annotated to indicate that when separated from the attachment, it is decontrolled. (See Exhibit 5 -

DO NOT USE "DECLASSIFIED". )

6. Complete Block 3 of Form 26-294 as follo.is:

a. Indicate if the proposed facility change requires review by Station Health Physics ( ALAPA), Fire Protection or Security because of impacts to these systems:

1) ALARA - based on considerations in Section VIII of Exhibit 3.

Complete Form 26-247, if required

2) Fire Protection - based on the criteria listed on Form 26-292 and in Exhibit 4 .

Security - based on whether the facility change

3) impacts security systems and/or vital or protected area boundaries (Exhibit 7) R

7. Request safety review from Nuclear Systems Engineering (NSE) Group Leader R

Nuclear Systems Enqineerina (NSE) Group Leader

8. When reviewing the PFCP, verify correctness of the determinations made in respect to the following:

a. Engineering and Safety Evaluations

b. Quality Class and Seismic Category Page 13 of 21

Southem Catitomia Edison Company ELC 24-10-15 DEPARTHENT

. Engineering and Construction Department QA PROCEDURE l REV. 6 l l EFFECTIVE: D2/01/88 l

e. Design Change Package Hazards Requirements (Form 26-182) N'

f. The design change dg_qi or does not involve a change to the License and/or Technical Specifications or to the desian basis of the UFSAR, FSA, UFHA, Security Plan or Emergency Plan and does or does not j involve an unreviewed safety question.

R NOTE: For a design change that does involve changes to the items listed in 8.f above or involves an unreviewed safety question, a long form DCP/PFC (PFCP) will be required in accordance with i

ACTIONS II and III of this procedure.

9. Sign Block 4 of Form 26-294 and forward, along with the PFCP, to the SCE Project Engineer (E&C) for E&C prepared PFCPs. Forward to Supervisor, Configuration Control (NGS) for NGS prepared PFCPs and proceed to Step 13.

SCE Pro.iect Enaineer (E&C)

10. Review the PFCP to assure that the following exist:

a. Environmental Evaluations N'

NOTES: (1) If the change involves activities whose nonradiological effects are confined to onsite areas previously disturbed during site preparation and plant construction, the

! Hanager, Station Technical / Project Engineer shall provide the Environmental Engineer approval signature.

(2) When a proposed change involves activities or impacts

whose nonradiological effects impact offsite areas, then the PFCP must be sent to the Environmental Engineering l Group for further evaluation.

(3) If an unreviewed environmental question exists, the PE N' shall notify Licensing by written memorandum.

b. Certification that an unreviewed safety or environmental question does noi exist

c. Certification that the design change does nol involve a change to the License and/or Technical Specifications or to the design basis of the UFSAR, FSA, UFHA, Security Plan or Emergency Plan NOTE: For a design change that does involve an unreviewed environmental question, a long form DCP/PFC (PFCP) will be

, required in accordance with AClIONS procedure.

II and III of this R Page 14 of 21

I South:rn Cahtornia Edison Company

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. Engineering and Construction Department QA PROCEDURE l REV. 6 l EFFECTIVE: n240VSS

d. Approval that the pr.' posed facility change achieves its objective, is complete, constructible, operable, and maintainable

e. Approval of changes to:

Piping and Instrumentation Diagrams (P& ids)

One Line Diagrams Elementary Diagrams Control Panel Drawings General Arrangement Drawines

f. ALARA, Fire Protection, and Security review requirements on Form 26-294 are correct,

11. Approve Form 26-294, Block 4, if all the abou criteria are met.

NOTE: Step 11 applies only to E&C initiated PFCPs.

1;! . Forward PFCP to the Supervisor, Configuration Contial.

Supervisor. Confiouration Control (For Information Only)

13. Process Blocks 5 through 7 of Form 26-294 in accordance with Station Engineering Procedure S0123-V-4.14.

NOTES: (1) Step 13 is applicable to all NGS initiated PFCPs.

(2) Upon completion of Blocks 1 through 7 of Form 26-294, implementation of the PFCP may proceed subject to any restrictions noted.

14. Return a copy of the signed Form 26-294 to the Originator to provide feedback as to whether PFCP is approved or disapproved.

15. Obtain signature from Quality Assurance verifying PFCP meets quality requirements (Block 8).

16. Forward PFCP to the Nuclear Safety Group.

Construction / Retrofit (E&C)/ Maintenance (NGS) R

17. Implement the change in accordance with the approved design disclosure documents, using the appropriate Work Process Procedures.

Nuclear Safety GrouD

18. Upon receipt of the PFCP from Station, review the safety evaluation to veri fy that the change does not involve an unreviewed safety question or Technical Specification change.

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QA PROCEDURE Engineering and Construction Department l REV. 6 l l EFFECTIVE: 02/01/88l

19. Complete Block 9 of For:n 26-294 and return along with the PFCP to the Supervisor, Configuration Control.

Supervisor. Confiauration Control (For Information Only)

20. Process Blocks 10 and 11 of Form 26-294 to obtain required signatures from Station personnel.

m ACTION Y - REVIEW 0F PROPOSED DESIGN CHANGE R Oriainator D

1. Identify affected disciplines / organizations.

2. Prepare FORM E0165-1 (E&C) or CC(123) 262 (NGS), Document Transmittal, for each Discipline Group Leader (E&C) or Group Supervisor (NGS) whose discipline is identified as affected by the design change and transmit to R Discipline Organization Group leader for review.

Discipline Group Leader (E&C) or Group Supervisor (NGS)

3. Review in accordance with the Design Review Responsibility Matrix (DRRM).

(Review considerations are noted on the back of Form E0165-1.)

NOTES: 1. The general criteria for review of the proposed design change shall be to establish the following:

a. The design change does not result in an unreviewed R safety and/or environmental question.

b. The design change accomplishes its intended R objectives.

c. The design change achieves its objective, complete, constructible, maintainable and operable.

is R

2. To satisfy these criteria, particular attention shall be given to the review of the following drawings as they are identified as those selected for review and approval by SCE in accordance with the Document Review and Approval Distribution Matrix (DRADM).

Piping and Instrumentation Diagrams (P& ids)

One Line Diagrams Elementary Diagrams Control Panel Drawings General Arrangement Drawings Page 16 of 21 1

Southem Cahtomia Edison Comoany ESC 24-10-15 DEPARTMENT

. Engineering and Construct. ion Department QA PROCEDURE l REV. 6 1 l EFFECTIVE: 02/01/88l

4. Complete Form E0 165-1 (E&C) or CC(123) 262 (NGS) and return with all comments, telephone notes, etc., to the Originator.

Oriainator

5. Resolve comments.

6. Identify the Design Organization and forward commen+.s on Form EG 165-1 (E&C) or CC(123) 262 (NGS) to the Design Organization as appropriate through Project Administration for E&C activities or directly for NGS activities.

Desion Oroanization

7. Incorporate comments in the desigr , rt urn the design change to the Originator.

NOTE: All coments murt be resolved in writing on the Form E0 165-1 (E&C) or CC(123) 262 (NGS)-

0_r_ioi n a tor

3. Veri fy incorporation of comments. Prepare Form E0 165-1 (E&C) or

/,C(123) 262 (NGS) documenting verification, and forward to CDM, Documentation for retention.

= ACTION VI - REVISIONS TO THE PFC Oricitiator

1. Receive the proposed alteration to the design change and review the Criteria for Determining When a PFC is Required (see Exhibit 1).

2. Based on this review, determine whether or not a PFC revision is R required.

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l Pagc 17 of 21

Southern California Edison Company ggc gz.59 35

' Engineering and Construction Department OEPARTMENT QA PROCEDURE l REV. 6 l EFFECTIVE:02/0U88 ll

3. If a PFC revision is required, handle in accordance with ACTION I. R NOTES: 1. A change to an approved PFCP shall be processed as a PFCP revision totally superseding all of the previous revisions as follows:

a. Prepare a totally revised Fonn 26-294, and Engineering / Safety, Environmental and ALARA evaluation. Prepare totally revised ALARA Design Review Check List and Fire Protection Design Review Checklist if required. Revised parts of the evaluation narrative shall be identified by vertical lines in the right hand margin together with the appropriate revision number,

b. Attach DCP and/or other changes to design documents p and changes to other documents comprising the PFCP (see ACTION III.3 and ACTION IV.4) which result from the revision.

4. If a PFC revision is not required, note on Form E0 165-1 (E&C) or R CC(123) 262 (NGS) and in a memorandum to Supervisor, Configuration Control.

C. REFERENCES l

1. NE&O P-001, ALARA Design Review l

i 2. Station Engineering Procedure S0123-V-4.14, Proposed Facility Change

3. Station Configuration Control Procedure S0123 XIV-4.2, Site Design Change R l

Process

4. Station Health Physics Procedure S0123-VII-3.1, ALARA Design Review S. Station Procedure 50123-XV-5.0, Nanconforming Material, Parts or i Components

6. Station Procedure S01(123)-VIII-I, Recognition and Classification of Emergencies i 7. E&C QA Procedure E&C 24-10-11, Interface Procedure for Review and l Approval of Engineering Services Contractor (ESC) Prepared Documents and i Services Purchased by SCE for SONGS 1, 2 and 3 1

) 8. E&C QA Procedure E&C 24-10-16, Development, Review, Approval and Release l of SCE Design Change Packages (DCP) and Assembly With Proposed Facility R Changas (FFC) SONGS 1, 2&3 Page 18 of 21 l

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Southern California Edison Company ESC 24-10-15 DEPARTMENT

. Engineering and Construct. ion Department QA PROCEDURE l REV. 6 l MrFFCTIVE: m /m /n9l

9. E&C QA Procedure E&C 24-10-17, Interim Design Change Notices (IDCN)/

Design Change Notice (DCN) SONGS 1, 2&3

10. E&C QA Procedure E&C 24-10-21, Preparation, Review, Approval and Release of the Field Change Notices for Issue to Construction /Startup/ Maintenance Without an SCE Design Change Package SONGS 1, 2&3

11. E&C QA Procedure E&C 37-30-63, Development, Issuance, Revision and Cancellation of the Document Package to Establish the Environmental Qualification (EQ) of Electrical Equipment Listad on the EQ Master List for SONGS 1, 2 and 3

12. E&C QA Procedure E&C 40-9-10, Preparation of Amendment Applications for the SONGS 1 Provisional Operating License and the SONGS 2&3 Operating Licenses

13. E&C QA Procedure E&C 40-9-13, Control of SONGS Licensing Document Changes and Coordination of Documents Prepared for Submittal to the NRC in Support of an NRC Operating License for SONGS 1, 2 and 3

14. FORM E0 165-1, Document Transmittal (E&C)

15. FORM 26-247, ALARA Design Review Check list

16. FORM 26-292, Fire Protec+. ion Design Check List

17. FORM 26-294, Proposed Facility Change

18. FORM 26 294-1, Design Change Package (DCP)/ Proposed Facility Change g Package (PFCP) Contents Page

19. FORM CC(123) 183, Configuration Document Check List

20. FORM CC(123) 184, Configuration Documents Requiring Change

21. FORM CC(123) 262, Document Transmit +.) (NG5)

22. ANSI N18.7-1976, Administrative '.ontrols and Quality Assurance for the Operational Phase of Nuclear Power Plants

23. ANSI N45.2-1977, Quality Assurance Program Requirements for Nuclear Facilities

24. ANSI N45.2.ll-1974, Quality Assurance Requirements for the Design of Nuclear Power Plants

25. American Society of Mechanical Engineers (ASME)

26. Code of Federal Regulations, Title 10, Part 21, Reporting of Defects and Noncompliance Page 19 of 21

' Southern Cahtornia Edison Company ELC 24-10-15 DEPARTMENT

' Engineering and Construction Department QA PROCEDURE l REV. 6 l EFFECTIVE: 02/01/88[

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27. Code of Federal Regulations, Title 10, Part 50.54 (p)(q), Conditions of Licenses

28. Code of Federal Regulations, Title 10, Part 50.59, Changes, Tests and Experiments

29. Code of Federal Regulations, Title 10, Part 51.53(a), Supplement to Environmental Report, (a) Operating License Stage

30. Code of Federal Regulations, Title 10, Part 73.21, Requirements for the Protection of Safeguards Information

31. Design Review Responsibility Matrix (ORRM)

32. Document Review and Approval Distribution Matrix (0RADM)

33. Emergency P1an

34. Final Safety Analysis (FSA)

35. NUREG 75/087

36. Nuclear Regulatory Commission (NRC) Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations will be As Low As Reasonably Achievable (ALARA)

37. Security Plan

38. Technical Specification, Unit 1

39. Technical Specification, Units 2&3

40. Topical Quality Assurance Manual (TQAM)

41. Updated Final Safety Analysis Report (UFSAR)

42. Updated Fire Hazards Analysis (UFHA)

43. Station Procedure 50123-V-4.70, Software Modification and Verification D. DEFINITIONS

1. Proposed Desian Chance Any change proposed for implementation into the plant configuration (i.e., DCPs, FCNs, FIOCNs, Temporary Modifications, etc.).

Page 20 of 21

Southern Cahtornia Edison Company ggg g4_gn_y5

. Engineering and Construction Department $ PENTURE l REV. 6 .

l l, EFFECTIVE: 02/01'/88l

2. Proposed Facility Chanae (PFCl The written engineering and safety assessment prepared in conformance with 10CFR50.54 and 10CFR50.59 to determine if the proposed design change:

a. does or does not involve a change in Technical Specifications or and unreviewed Safety Question R

b. does or does not- decrease the effectiveness of the Security Plan or the Emergency Plan 3 ProDosed Facility Chance Packaae (PFCPl A package of documents, as specified in ACTIONS III and IV, which describes and evaluates a proposed design change. R

4. Refer to the E&C QA Reference Procedures Manual Glossary for additional definitions.

Page 21 of 21

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EK 241015 Southern CaYorna E6 scan Company DEPARTHENT QA PROCEDURE Engineering and Construction Department j REY. 6 EXHIBIT 1 l EFFECTIVE: 02/01/88l l

l CttittIA FOR Stiftnistus WBlu A ptop08t3 FACILITY CgAutt pattAtt 18 algw'*tt A. Cittt4L C017t01A the proposed FaclLity Change Package (PFCP) f s a seems of comewnicating to the twc Leer Generetten $lte Department the details of a plant change, the safety implicatten of nating that change, sad a means of entwelog contret of plant configuret ten. A PFCP le generally prepared f or all plant changes, tests or esperiments to the plant's physical c on f igur a t t en, to let t rument set points, cellbration requireeents, and coopwter sof tware, regardless of the saf ety or quality class.

g. Eiftefteel 70 TSE Ctetest fiffletA A PFC say not be required if any of the f altevir$g design change tenditlens are sett

1. The design change corrects a steerly identlflatie nonconf ormance di sposi t t eeed

repalr* or *wse as le* se desselbed by a n onc on f or manc e teport (act) in accordance with Stetten Procedure lo123 av 5.0, menconfereing materiet, parts or Components, and the design change is categorized as a *elace change

consistent with t&C CA Precedures t&C 24 10 17 (Enhibit 1) er Ele 24 10 21 (tahlble 13.

h0ft: Design thenges are not te be prescribed in the body or the NCt bwt twst be issued on en approved Design Change Pechese (DCP) er fletd Change document. Any DCP or Flete Change sotice (FCe) laswed to leptesent a facility change shall be reviewed for PFC requirements in accordance ulth E8C 24 10 17 and Ett 24 10 21 Inctwding those which reswLt in

eccept as Is* er "repaire dispoeltlens.

In this case, final steswee of the utt ulti met be done until att cocweents are correct in the document file.

2. Record dreving changes (Design Change setices (0Cus), FCus, fletd Generated Interia Design Change seteles (fl0Cus), etc.) which cor rect draeleng errors, tot de not change the plant physically or alter prevlowsty approved design.

3. Changes to set points and Instrument estitrations which are not ref erenced in the SCtGS Unitt 283 Uf$AR, 303G1 Unit 1 F34, feChnical Specifiestlens er suppletental commitment tetters (see (8C GA Precedure t&C 26 713, section A.1, t4c).

30fts Orlfices are not censidered setpoints.

4. Computer softmore changes are governed by 30123 V 4.70 and, as such, do not require a PFC unless the criterte of Actlen Il are not set, in this case, a toes form PfC in accordance ulth Astlen lit awst be prepared.

S. utner revlelens to approved facility changes which have deveioped dwelag construction e M startup and de not etter verbetle coepilence ulth the approved PsCP. Alterat tens which change verbatim cespilence ulth the omreved PFCP re@ ire that it be revised.

einer restelens are defined as dreming clari f ic a tlees and other c ons t ruc t i on and startup changes which do not result in subse dent changes to or f altwee to comply vita n e fellowing (See tahlbit 1 et t&C 24 10 17 and 26 10 21 for fwrther swidelines):

Plant Arrangeoents Piping and teatrumentatten Olegrass (P410*s)

One time Olegress Elementary Olegress Control Penel crewings lafety teleted materiets Components American loclety of mechanicst Engineers ( Alat) Code design requirements American aatlenal Standards Institwte ( Ast!) piping er parts design re b i re*ent Plaat Perf orsence Characteristics

6. Additlena er modificatione to facilltles. systees or compoeents outside the Protected Area which de not interf ace with or affect the perf ereance er operet t en of facilities, systems er components inside the Protected Area.

EXHIBIT 1 Page 1 of 1

Southem Catalomia Edison Company E&C 24-10-15 agprag m Engineering and Construction Department * "CE" l REV. 6 l rJru;nVEL 02/01/88[ l EXHIBIT 2 PROPOSED FACILITT CNANGE ATTACPMENT ENGINEERING /SAFETT, ENVIRONNENTAL, AND ALARA EVALUATION (SNORT FORM)

FORMAT AND CONTENT REQUIREMENTS I. DESCRIPTION -

Suf ficiently detailed as to the reason, purpose, method, assumptions and design input such that a person technically qualified in the subject can review and understand the change without recourse to the Originator.

Include a brief description of the physical plant changes. Address location of modification piping / conduit routing, watts penetrated, major equipment addition / deletions. Use sketches or marked up P&lDs, general arrangement, etc., as necessary. N*

!!. ENGINEERING EVALUATION -

Review the effects on design parameters and operations, including as required design analysis. Describe the impact of construction on the plant (this may be accomplished through the use of an attachment). The engineering evaluation shall include a definitive statement that the plant modification has been reviewed, is complete, achieves its objective, is constructible, is operable and R maintainable. Refer to ESC QA Procedure E&C 37 30 63, Development, issuance, Revision and Cancellation of the Document Package to Establish the Environmental Qualification (EQ) of Electrical Equipment Listed on the EQ Master List for SONGS 1, 2 and 3, for required environmental quellfication information.

Include a discussion of the origina! plant design basis and the impact of this modification on the original design basis. Also include a discussion of the functional changes imposed by the proposed modification.

Key results which effect Technical Specifications /Survelltance Procedures (e.g.,

battery calculations) shall be described in the Engineering Evaluation section of the N

PFC, even if the Technical Specification basis remains unchanged.

III. SAFETY EVALUATION - This portion of the PFCP shall set forth the basis and criteria used to determine that the proposed change does or does not involve en "unreviewed saf ety question." In making this determination, the following questions shall be answered:

A. Will the probability of occurrence of an accident or malf unction of any equipnent important to safety previously evaluated in the UFSAR/FSA be increased?

Response: (Yes/No) The response to this question shall include a discussion of the overall effect of the change on the probability of occurrence of accidents analyzed in the ref erences in Exhibit 2 A. This discussion shall be suf ficiently detailed such ther it is clear that those a:cidents analyzed, which are in any yw affected by the change are or are not increasingly probable due to change or its installation.

Simple statements, without discusalon of the accidents and development of a logical argument for or against *his item, shall require rejection of the proposed facility change.

Exhibit 2 A provides guidance to references to complete this section.

EXHIBIT 2 Page 1 of 4

Soumem CaMomia E6 son Company

. Esc 24-10-15 DEPAREDTP Engineering and Construction Department m PaxmmE ll REV. 6 mwnVE: p2W88[;

EXKIBIT 2 B. Will the consequences of an accident or malfunction of equipment important to safety previously evaluated in the UFSAR/FSA be increased?

Responses (Yes/No)

The response to this question shall include a discussion of those accidents analyzed in the references in Exhibit 2 A which may in any way be ef fected by the change. These discussions shall be sufficiently detailed as to demonstrate clearly whether accident analyses bound any and all conditions created by the change or its installation. Exhibit 2A provides guidance to references for accident analyses to be considered.

Simple statements, without discussion of the accidents and development of a logical argument for or against this i t em, shall require rejection of the proposed facility change.

C. Will the possibility of an accident or malfunction of a different type than any previously evaluated in the UFSAR/FSA be created?

Response (Yes/Wo) -

The response to this question shall contain a discussion of any non analyzed accidents impacted by the change or its installation.

References in Exhibit 2A shall form the basis (but not be the sole means) of responding to this question. A simple statement of conclusion is not sufficient and shall be grounds for rejection of the proposed facility change.

D. Will the margin of safety as defined in the basis for any technical specification be reduced?

Response (Yes/Wo) -

The response to this question shall contain a reference to those fechnical Specifications (if any) which in any way relate to the change and a suf ficiently detailed discussion of the basis for each specification such that it is clear whether that basis is compromised. Key results which offect Technical Specifications /Surv91Llance Procedures (e.g., battery calculations) g.

I shall be described in the Engir.eering Evaluation section of the PFC, even if the Technical Specification basis remains unchanged.

IV. EhVIRONMENTAL EVALUATION This portion of the PFCP shall set forth the basis and criteria used to determine that the proposed change does or does not involve an "unreviewed environmental question." To make this determination, the following question must be answered:

A. Will the change involve activities whose nonradiological effects are confined to the onsite areas previously disturbed during site preparation and plant construction?

Responset (Yes/No) - The response to this question shall include a discussion of the overeil offeet of the change on the environment. The evaluation will address itself to toecific sections of the UFSAR/FSA, Technical Specifications, or Final Env i ronmen t M Statement (FES) as applicable. If the answer is "yes", the following statement shall be made in the PFCP: "The work and associated nonradio-Logical effects involved in this modification are confined to areas previously disturbed during site preparation and plant construction. As such the Proposed Plant Modification does not involve an unreviewed environmental question."

If the effects are not confined to such onsite areas, the following questions shall be answered to datermine if an unreviewed environmental question is involved:

1. Will the change result in a significant increase in any aWerse envircrenental impact previously evaluated in the FES?

2. Will Ge changt result in a significant c h ange in ef fluents or power level in accordance with 10 CFR, Paat $1.53 (a) ?

3. Does the change involve a mattea not previously reviewed and evaluated in the FES which may have a significant aowese environmental impact?

EXHIBIT 2 Page 2 of 4

Southem Cahtornia Edison Company Esc 24-10-15 DEPAnmarr

. Engineering and Construction Department cA PaxmmE l REV. 6 l l-. EFFECTIVE: n? /n1/ AR l EXHIBIT 2 The PFCP shall contain the Originator's recommended finding. For consfrtency if the responses are negative, it is recommended that the following statement be used following a discussion of the above concerns:

"8ased on the analysis above, this proposed facility change does not (does) involve an unreviewed environmental question."

V. IMPLEMENTAfl0N SECfl0N a The following statements shalt be cocpteted with the correct verb included. Based on the information contained in the Safety and Engineering evaluations:

A. The alteration does or does not involve a change in the technical specification incorporated in the license.

B. The alteration does or does not involve an unreviewed safety question (as defined by 10 CFR 50.59).

C. The alteration does or does not involve a change to the UFSAR (Units 2&3) or FSA (Unit 1) design basis or analyses.

D. The alteration SLq11 or does not decrease the effectiveness of the Security Plan or the Emergency Plan (as defined by 10CFR 50.54 (p)(q)) .

E. The alteration does or does not adversely impact the Fire Protection System and/or violate the UFHA.

VI. Identify Quality Class and Seismic Category.

Vl!. ALARA REVIEW -

This section of the PFCP shall communicate to the Station that the originating organization has reviewed the proposed facility change with regard to ALARA considerations. Consult the references in Exhibit 2A for Radiologically Controlled area drawings. The following questions shall be completed with the correct verb included.

E. The alteration will or will not modify facility, system or components which will collect, store, process or transport radioactive materlats.

B. The alteration will or will not modify facility, systems or components which are located greater than or equal to 0.25 mR/hr or greaterinthan a Radiologically Controlled or equal to 1000 dpa/100areg CM (removable) .

C. The alteration will or will not create routine maintenance, inspection or surveillance requirements in a Radiologically Controtted area greater than or equal to 0.25 mR/hr or greater than or equal to 1000 dpa/100 CH2 (removable) .

D. The alteration will or will not involve construction activities which will cause personnel to come into close proximity with systems or components collecting, storing, processing or transporting radioactive materials, or which are located in a Rajlologicatty controlled area greater than o equal to 0.25 mR/hr or contaminationgreaterthanorequalto1000dpe/100CM[ removable.

If the answer to any of the above is positive, then an ALARA review is required and the ALARA Design Review Checklist (Form 26 247) must be ccepteted ord inclu$ed in the PFCP attachments.

EXHIBIT 2 Page 3 of 4

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' Southern California Edison Comoany

- E&C 24-10-15 \

DEPARIMDfr

. Engineering and Construction Department m accmmE l

t I

l RE.V. 6 l l enu.;nVEr 02/01/88l EXHIBIT 2 !

Vill. CONSTRUCTION SAFETY ASSESSMENT (CSA) t, i s t equipment to be modified, other equipment affected, ard special procedJres to be developed in constructing a design change. (Use Exhibit 2 of E&C 24 10 16 as R, Criteria.)

Review the CSA received f rom the Constructing Organization and assess the sequence methods being utilized to implement the proposed facility change. Prepare a written statement which asserts that the implementation process and sequences will not result in a violation of the Technical Specifications, License, in an unreviewed safety question, or jeopardize other equipment in service.

NOTES: 1. It is unnecessary to review approved work procedures; however, a statement must be made that only approved werk proced;res are being used and that no unique construction activities on temporary modifications are involved.

2. Actual CSA is completed by Construction and included in the DCP.

N' IX. Attachments (as appropriate). Examples include Design Change Packages (DCPs), CSAs, Drawings, Procedures, Equipment Manuals and other supporting documentation. See '

ACil0N lll.3 and IV.4 X. Include data for identifying and tracking purposes:

A. PFCP number B. Date of preparation C. Signature, name, title, and organization of originator and PAX telephone number.

Reference =

xi.

N' EXHIBIT 2 Page 4 of 4

Bouthctn California Edison Company gge 24_3n_35 ;

. Engineering and Construct!on Department EPARDert 3m I aEv. 6 i l t. m AT NE: n?/n1/Ral EXHIBIT 2-A ENGINEERING / SAFETY, ENVIRONMENTAL, AND ALARA EVALUATION REFERENCE MATRIX SHORT LONG FORM F0eM UNif 1 UNITS 283 Safety Evaluation ll! A IV 8 Hypothetical Accident -

Design Basis for Accident FSA Section 12 Analysis UFSAR Chapter 15 Mechanical Malfunction Accident and Equipment Analyses FSA Section 8 Malfunction Analysis UFSAR Chapter 6 Steam Line Break - HELS Analysis -

FSA Section 8.4 UFSAR Chapter 3 Administration FSA Section 6 UFSAR Section 17 QA UFSAR Chapter 13 Updated Fire Hazards Analysis Ill 8 IV 8 Hypothetical Accident -

Design Bas's for Accident FSA Section 12 Analysis UFSAR Chapter 15 Mechanical Malfunction Accident and Equipment Analyses FSA Section 8 Malfunction Analysis

UFSAR Chapter 6 Steam Line Break HEL8 Analysis -

FSA Section 8.4 UFSAR Chapter 3 Administration - UFSAR Section 17 FSA Section 6 UFSAR Chapter 13 Updated Fire Hazards Analysia i

III C IV 8 3 N/A NUREG 75/087 Section 15 Safety Findina V 10CFR Part 21 10CFR Part 21 Environmental Evaluation IV VI N/A Final Environmental Statement 10CFR Part 51.53(a)

ALARA Review

( Vil Vill N/A UFSAR Section 12 l

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EXHIBIT 2-A Page 1 of 1

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Southern Cahtornia Edison Comoany ggc 24_39_35 Engineering and Construction Department DEPAmer i me i l REV. 6 l EXHIBIT 3 l tmunVE: O?/01/88l l

FORMAT AND CONTENT REQUIREMENTS '

SONGS UNITS 1, 243 PROPOSED FACILITY CNANCE EVALUATION DESIGN CNANGE NO. ~~~~ 1 (DATE) '

(LONG FORM)

1. TITLE:

II. Description This portion of the PFCP shalt be sufficiently detailed as to purpose, method, assumptions and design input such that a person technicat ty qualified in the subject can review and understand the change without recourse to the originator. it shall contain statements describing:

A. Reason for Change including a brief history of events leading to the issuance of the change. For revisions to en approved PFCP the reason for the revision shall also be stated.

8. Purpose for Change shalt describe the installed change ord how it will fmetion in the system and meet new regulatory requirements.

III. Engineering Evaluation Review the effects on design parameters and operations, including as required, design analysis. Describe the Irpact of construction on the plant (this may be accomplished through the use of an attachment). The engineering evaluation shall include a definitive statement that the plant modification has been reviewed, is complete, achieves its objective, is constructible, is operable and maintainable.

Procedures (e.g.,Key results which effect Technical Specifications / Surveillance battery calculations) shall be described in the Engineering Evaluation section of the PFC, even if the Technical Specification basis remains unchanged.

A. Design Criteria shall consist of a list of design irputs considered in the change.

It shall also include a brief discussion of how each input was considered. Design inputs shall include, but are not limited to the following, where applicable NOTE: Where these specific requirements are identified in established and approved design citeria documents, the specific design criteria docunent may be referenced.

N'

( 1. Codes and Standards

2. Regulstory requirements such as NRC general design criteria and regulatory guides

3. Input parameters such as mechanical, structural, hydraulic, chemical and electrical requirements 4

Interface requirements including definitions of the functional and physical interfaces involving structures, systems and components and the possible disconnection or disabling of systems during construction

5. Material requirements including such items as compatibility, electrical insulation properties, protective coatings, corrosion resistance, etc.

6. Plant layout and arrangement requirements

7. Seismic criteria, if any l 8. Environmental conditions anticipated during storage and operation such as pressure, temperature, humidity, corrosiveness, wind direction, nuclear radiation, electromagnetic radiation and duration of exposure to these conditions 9 Operational requirements during all plant o.oerating conditions EXHIBIT 3 Page 1 of 5

Southem CaMomia Edison Comoany E&C 24-10-15 DEPAmter Engineering and Construction Department m PaocEcuaE l aEV. 6 l EXHIBIT 3 l- PJI9A.TIVEt m'~ /m /RR l 10 Accessibility, maintenance, repair, testing and Inservice inspection requirements for the installed change and conditions under which these will be performed

11. Fire protection requiren.ents

12. Security criteria

13. Safety requirements to both the installation personnel ard other requirements to prevent undue risk to the health and safety of the public 14 Restrictions on portable equipment, scaffolding and facilities in certain spaces containing safety related electrical equipment

15. Quality Class and Seismic Category

16. Environmental qualifications criteria.

for required action.)

(See E&C QA Procedure ESC 37 30 63,

8. Method shall explain, in detail, how the intended change will fulfill its purpose as described above. It shall include the basic function of each strteture, system and component.

C. Evaluation IV. SAFETY EVALUATION A written safety evaluation is required for changes to the facility as described in the Licensing documents in Exhibit 2 A. The purpose of this evaluation is to demonstrate that change and/or the construction activities associated with it do or do not involve en "unreviewed safety question" as defined by 10CFR50.59. As a minimum, this evaluation shall contain the following:

A. Basis for Safety Evaluation shall establish the necessity for performing a written safety evaluation. Should the originator determine that there is a need to perform a written safety evaluation, a simple statement to this effect is adequate. Otherwise, as a minimum, it shall address:

i

1. Speelfic sections of the Licensing documents in Exhibit 2A which could be

! affected, to inclwue dl6cussion of those sections which address the systee or portion of the plant being changed. Specific details of the change may be given as a ref erence to the "description" portion of the PFC. A declaration l of whether these sections are affected should be made at the conclusion.

2. Changes to Plant Procedures addressed in the Licensing documents in Exhibit i

2A which may be revised due to the facility change. include at the conclusion, a declaration of whether a change is required to procedures addressed in the Licensing documents in Exhibit 2 A.

3. Changes to Plant Technical Specifications to include a listing of Technical I

specifications which could require revision and a declaration of whether a I

change to the Technical Specifications ($ required.

4. Changes to commitments made to the NRC.

B. Evaluation and Basis For Safety Finding Note: Should Section Illa result in a determination that a safety evaluation is not required, this section shall read as follows: "An evaluation has i

been conducted to determine the necessity for a written safety

{ evaluation. In accordance with the criteria c ontained in 10CFt50.59 and the unit's Technical Specifications, this evaluation is not required."

EXHIBIT 3 Page 2 of 5 l

' Southern Cahtornia Edison Company E&c 24-10-15 DEPAMEC

. Engineering and Construction Department m nocmmE !

l REV. 6 l l trrrunVE: O? /01/88l EXHIBIT 3 l

This portion of the design change shall set forth the basis and criteria used to l 1

determine that the proposed change does or does not involve an "unreviewed safety '

question." In making this determination, the following questione suet be answered:

1. Will the probat$lli ty of occurrence of an accident or malfunction of any equipment important to safety previously evaluated in the UFSAR/FSA be increased?

Response: (Yes/Wo) - The response to this question shall include a discussion of the overall effect of the change on the probability of occurrence of accidents analyzed in the references in Exhibit 2 A. This discussion shall be sufficiently detailed so that it is clear that those accidents analyzed in the UFSAR/FSA, which are in any way affected by the change, are or are not increasingly probable due to the charsge or its installation.

Sleple statements, without discussion of the accidents and development of a logical argument for or against this item, shall require rejection of the proposed facility chang 4.

Exhibit 2 A provides guidance to references to complete this section.

2. Will the consequences of an accident or malf unction of eqJipnent leportant to safety previously evaluated in the UFSAR/FSA be increated?

Response (Yes/Wo) -

The response to this question shall include e discussion of those accidents analyzed in the ref erences in Zahlbit 2 A eich may in any n y. be affected by the change. These discussions shall be sufficiently detailed as to demonstrate clearly whether the existing accident analyses R bound any and all conditions created by the change or its installation.

Exhibit 2A provides guldance to references for accident analyses t o be considered.

$1mple statements, without discussion of the accidents and development of a logical argument for or against this item, shall require rejection of the proposed facility change.

3. Will the possPallity of an accident or malfunction of a different type than any previously evaluated in the UFSAR/FSA be created?

Response: (Yes/Wo) The resporse to this question shall contain a discussion of any non analyzed accidents impacted by the change or its installation.

References in Exhibit 2A shall f orm the basis (but not be the sole means) of responding to this question. A simple statement of conclusion is not sufficient and shall be grounds for rejection of the proposed facility change.

4 Will the margin of safety as defined in the basis for any technical specification be reduced?

Responses (Yes/No) -

The response to this question shall contain a reference to those Technical Specifications (if any) which in any way relate to the change and a sufficiently detailed discussion of the basis for each specification such that it is clear whether that basis is compromised. Cey results which effect Technical Specifications / Surveillance Procedures (e.g.,

battery calculations) shall be described in the Engineering Evaluation R section of the PFC, even if the fechnical Specification basis remains unchanged.

EXHIBIT 3 Page 3 of 5

Southem CaMomia Edison Company ELC 24-10-15 Engineering and Construct. ion Department DEmanerr a pm cE n g l REV. 6 EXHIBIT 3

m. 02/01/8q' V. SAFETf FlWDING This portion of the safety evaluation contains the Originator's recommended finding.

For consistency, it is recommended the following statement be used:

"This proposed facility change 1) does not (gqu) Involve an unreviewed safety question as defined by 10CFR50.59; 2) does not (ggn) require a change to the Technical Specifications incorporated in the License (License number of the affected Unit); 3) does not (ggu) decrease the ef f ectiveness of the Security Plan; or 4) s8n C2.1, (does) decrease the ef fectiveness of the Emergency Plan; 5) does not (ggu) impact the Updated Fire Nazards Analysis (UFMA)."

VI. ENVIRONMENTAL EVALUAfl0N This portion of the design change shalt set forth the basis and criteria used to determine that the proposed change does or does not involve an "unreviewed environmental question." To make this determination, the following question must be answered:

A. Will the change affect the nonradiological environeent of any offsite area which was previously undisturbed during site preparation and plant construction?

Response: (Yes/No) The response to this question shall include a discussion of the overall effect of the change on the nonradiological environment. The evaluation will address itself to specific sections of the UFSAR/FSA, Technical Specifications, or Final Environmental Statement (FES) as applicable. If the answer is "yes", the following statement shall be made in the PFC: "The work and associated non radiologleal ef fects involved in this modification are confined to areas previously disturbed during the preparation and plant construction. As such, t*ie Proposed Plant Modification does not involve an unreviewed enviromental question."

If an of f site area is af f ected, the following questions shall be answered in the PFC to determine if an unreviewed environmental question is involved:

1. Will the change result in a significant increase in any a&erse enviromental impact previously evaluated in the FES?

2. Will the change result in a significant ch ange in eff tvents or power level in accordance with 10CFR Part 51.53 (a)?

3. Does the change involve matter not previously reviewed and evaluated in the I

FES which may have a significant adverse environmental impact?

The PFCP shall contain the Originator's recommended finding. For consistency, if the responses are negative, it is recommended the following statement be used following e discussion of the above concerns:

"Based on the analyses above, this proposed facility change does not (does)

Involve an unreviewed environmental question."

Vll. ENVIRONMENTAL FINDING This portion of the environmental evaluation shall contain the Originator's recommended finding. For consistency, it is recommended the following statement be u s ec':

"This proposed facility change does not (does) involve an unreviewed environmental question."

l l

i l EXHIBIT 3 Page 4 of 5

'Southem Cantornia Edison Comoany

- E&C 24-10-15 DEPAM MD7r Engineering and Construction Department a mxmRE 1

l REV. 6 l {

l EFFECI'IVE:0')/m /AR l l g3 ~

Vill. ALARA Review a This section of the eFCP shall communicate to the Station that the originating organization has reviewed the proposed facility change with regard to ALARA considerations. Consult the references in Exhibit 2A for Radiologically Controlled area drawings. The following questions shall be completed with the correct verb included:

A. The alteration will or will not modify facility, system or components which will collect, store, process or transport radioactive materials.

B. The alteration will or will not modify facility, systems or components which are locatedthan in Radiologically Controlled greater than or equal to 0.25 mR/hr or aryr (emovable) greater or equal to 1000 dpm/100 CM .

C. The alteration wilt or will nai create routine maintenance, inspection or surveillance requirements in a Radiologically Controlled greater than or equal to 0.25 mR/hr or greater than or equal to 1000 dpm/100 CMareg (emovable).

r D. The alteration will or will not involve construction activities which will cause personnel to come into close proximity with systems or components collecting, storing, processing or transporting radioactive materials, or sich are located in a Radiologically Controlled area grest$r than or equal to 0.25 mR/hr or contamination greater than or equal to 'iOOO dpm/100 CM removable.

If the answer to any of the above is positive, then an ALARA review la required and the ALARA Design Review Checklist (Form 26 247) must be conpleted ard inctWed in the PFC attachments.

IX. REFERENCES AND ATTACHMENTS All appropriate references and attachments listed in the PFCP shall be included with the package. The change shall be held by the Design Control Engineer ard not sent to the Supervising Engineer until att such documentation is provided. Excepted are ref erences commonly held by all parties such as UFSAR, FSA, Technical Specificatione, Security Plan, Emergency Plan, UFMA, Codes and St andards, etc. (See ACil0N l i t .3 and IV.4).

X. IDENTIFYING INFORMATION Include data for identifying and tracing purposes:

A. PFCP number

8. Date of preparation C. Signature, name, title, and organization of originator XI. CONSTRUCTION SAFETY ASSESSMENT List equipment to be modi f ied, other equipment affected, aM pecial proced;res to be developed in constructing a design change. (Use Exhibit 2 of E&C 24 10 16 as criteria.) R Review the Construction Safety Assessment received from the constructing organitation and assess the sequence methods being utilized to implement the proposed facility change. Prepare a written statement which asserts that the implementation process and sequences will not result in a violation of the Technical Specifications, License, in an unreviewed safety question, or jeopardite other equipment in service.

NOTES: 1. It is unnecessary to review approved work procedures; however, a statement must be made that only approved work procedures are being used and that no unique construction activities or temporary modificatione are involved.

2. Actual CS A will be prepared by Cr>nstruction and added to the OCP.

EXHIBIT 3 Page 5 of 5

'Southem Cahlomia Edison Company Esc 24-10-15 DCPARDefr Engineering and Construct. ion Department 3%

l REV. 6 l mnVE: 02/01/88 ;[

EXHIBrr 4 FIRE PROTECTION DESIGN CNECKLIST (FORM 26 292)

INSTRUCTIONS Read att instructions and information below carefutty. Complete at t items on Form 26 292, Fire Protection Design Checklist, Section A, Preliminary Assessment, by checking either the "YES" or "NO" box in the right hand columns. For each "YES" box checked, provide description of change and impact in PFCP.

l. Combustible Material Identify any changes to the combustibles by checking the "YES" box and provide description of change and impact in PFCP.

The materlat which shall at least be considered ere:

- oil grease charcoal PVC (polyvinyl chloride) cable trays with greater than 30% fill (for SONGS 1) and greater than 25% fitt (for SoWGS 253) electrical cabling Class A (wood based products, cloth, etc.)

If the "YES" is checked, evaluate changed fuel load and required corrective action including UFMA Changes in PFCP.

2. Active Fire Protection Systems identify any changes to the Active Fire Protection Systems by checking the "YES" box and provide description of change and impact in PFCP. The systems which shall at least be considered are:

Automatic Wet Pipe Sprinklers Water Spray Systems Automatic Pre Action Sprinklers Special suppression Systems (Maton 1301 and CO2)

Detection and Alarm Systems Smoke Control System Water Supply (fire pumps, water mains, etc.)

3. Passive Fire Protection Systems Identify any changes to the passive Fire Protection Systems by checking the "YES" box and provide descriptf on of change and impact in PFCP. The items which shall at least be considered are:

penetrations (cabling, piping) fire rated ceilings

- shrouds -

curbs

- radiant energy shield fire doors fire rated dampers drip shields fire rated watts -

insulation fire rated floors UFMA depicts Technical Specification barriers. See Volumes 3 and 4 of the UFMA.

l EXHIBrr 4 Page 1 of 4

Southern CaMornia Edison Company ggc 24_3n_75 DEPARINDff Engineering and Construction Department-am l REV. 6 l r2rrKnVE' 02/01/8Cl l EXHIBIT 4 FIRE PROTECTION DESIGN CEECKLIST (FORM 26 292)

INSTRUCTious (Continued) 4 Manual Fire Protection Systems identify any changes to the Manuel Fire Protection systems by checking the "YES" box and provide description of change and impact in PFCP. The items which shall at least be considered are fire hose stations (houses, carts, etc.)

- hydrants portable fire extinguishers wet standpipes

5. Ventilation Systems identify any changes to the Ventilation Systems by checking the "YES" box and provide description of change and impact in PFCP. The system which shall at least be considered is Ventilation System for $moke Control Interlocks with Fire Detection Systems The Units 2 and 3 Ventilation System for smoke Control consists of a combination of fixed ventilation systems supplemented as required by six portable smoke removal fans.

6. Exposure Fire Barriers, 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Emergency Lights, RCP Lube oil Collection System Identify any changes to the following by checking the "YEsa box and provide description of change and impact in PFCP.

- 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months emergency lighting

- RCP Lube Oil Collection System exposure fire barriers The access and egress routes and the illumination of hot shutdown components shall be considered part of 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months emergency lighting.

Exposure fire barriers are listed in Drawing 39410.

Separation distance requirements for redundant trains in all areas except inside containment are:

1. 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire harrier; or

2. a) horizontal distance of more than 20 feet with no intervening combustibles; and b) fire detectors; and c) automatic suppression system; or

3. a) 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months rated fire barrier (wrap); and b) fire detectors; ano' c) automatic suppression system; or

4. a) fire detectors; and b) fixed suppression system; and c) installation of alternative or dedicated shutdown capability independent of the equipment, cabling, and associated circuits.

EXHIBIT 4 Page 2 of 4

Southern California Edoson Company E&c 24-10-15 meAmerr

$ Engineering and Construction Department a Pmcmm l PEV. 6 l j EFFECTIVE: m/m mRl EXHIBIT 4 FIRE PlotECTION DESIGN CNECKLIST (FORM 26 292)

INSTRUCTIONS (Continued)

6. Esposure Fire Barriers, 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Emergency Lights, RCP Lube Oil Co'tection System (Continued) separation distances requirements for redundant trains inside containment are any of the items listed below, or any of the above items listed for outside the Containment:

1. fire detectors and automatic suppression system; or

2. horizontal distance of more than 20 feet with no intervening combustibles; or

3. separation of cables by a noncombustible radiant energy shield.

7. Safe and Auxillary $hutdown Systems Identify any changes to the safe and Auxiliary shutdown Systems by checking the "YES" box and provide description of change and impact in PFCP. The systems which shalt at least be considered are Reactor Coolant RCS Instrumentation Shutdown Cooling Chemical and Volume Control Main Steam Atmospheric Steam Dump Steam Generator Instrumentation Auxillary Feedwater Component Cooling Water

$attwater Cooling MVAC Emergency Chitted Water Diesel Generator Systems Compressed Air l The components which shalt at least be considered for each system are:

equipment l

l piping / valves electrical power cables or instrumentation motor control centers (McCs) or switchgear ductwork redundant cogonents or cross tie components to redundant systems present in the same fire area or sone, i

l EXHIBIT 4 Page 3 of 4

l Southern Canfornia Edison Company

. gge 24_y9_35

. Engineering and Construction Department aEPAmerr 3a l l REV. 6 . [

l_ u ru;nve: n9/ot/ sal l EXHIBTT 4 '

El MI FIRE PROTECTION DESIGN CNECKLIST (FORM 26 292)

INSTRUCTIONS (Continued)

8. Essential Electric Systems identify any changes to an essential electric systems by checking the "YES" box and provide description of change and impact in PFCP. The systems which shall at least be considered are:

4160V (ac) 480V (ac)

- 125V (de) 120V (ac)

The components which shall at least be considered for each system are:

- equipment cables in conduit cables in trays motor control centers or switchgears redundant components or cross tie components to redundant systems present in the same area, i 9. Temporary impairments to Fire Protection Systems identify all temporary impairments to fire protection systems ty checking the "YES" box and provide description of change and impact in PFCP.

i

10. Other UFMA Comrnitments identify any changes to att other fire protection systems or items by checking the

"YES" box and provide description of change and impact in PFCP.

l sammmmusa v ... ~3. f . n...

EXHIBIT 4 P3'Io 4 of 4

4 Southern Cahfornia Edison Company Esc 24-10-15 EPARDeff Engineering and Construct. ion Department am l REV. 6 l tzru;nVE: 02/01/88[ l EXHIBIT 5 r ,

ENCLOSURE CONTAINS SAFEGUARDS INFORMATION L

UPON SEPARATION THIS PAGE IS DECONTROLLED l

l l

EXHIBIT 5 Page 1 of 1

l Southern California Edoson Company ggc 24_zn_75 \

oEPArment

. Engineering and Construction Department am 1

i )

l REV. 6 l 1 l EmrrIVE: 02/01/88l 1 EXHIBIT 6 I l

i i

UNIT NO. l STATION EMERGENCY PLANNING DESIGN CNECXLIST DCP/PFC Number ..___...___ .__.. ....... Date ____.........

Checklist Originator ...................... PAX __,........

PRELIMINARY ASSESSMENT A. Identify any additions. removal, relocation of changes to any of the followings

1. Emergency Response Facilities (TSC, YES NO EOF, or OSC)

2. Telecommunications or radio YES NO network

3. Radiation monitoring system YES NO

4. Site P. A . and airen systems YES NO

5. Security (Site entrances or YES em., NO h

6. Transportation / parking lota YES NO 7 Other Emergency Plan commit- YES NO ment.

B. Any itene requiring a 'YES' answer will be explained and evaluated in the DCP/PFC.

I DCP # . _.....____....__

REV _____. SNT __ ,of .... l PREPARED bye APPROVED BY ___. ....... ___

EXHIBIT 6 Pago 1 of 3

+1 Southem Cantornia Edison Company g5c 24_3n_3g aEPAmmar Engineering and Construction Department am l REV. 6 . l l r2rtA.:nVErn?/01/88 l EXHIBIT 6 STATION EMEROENCY PLANNING DESIGN CHANGE CHECXLIST INSTRUCTIONS 1

Read all instructions and information below carefully.

Complete all items on the Station Energency Planning Design Change Checklist by checking either the 'YES' or

'NO' bo x . For each 'YES' box checked, provide description of change and impact in PFCP.

1. Emergency Response Facilities identify any changes to any Emergency Response Facility by checking the 'YES' box and provide description of changes and impact in the PFCP.

The facilities which shall be at least considered ares Unita 1 and 2/3 Technical Support Centers Unita 1 and 2/3 Operational Support Centers If the 'YES' is checked, evaluate corrective actions.

2. Telecommunications Identify any changes to any Telecommunications equipment, contained within the Emergency Response Facilities specified above, by checking the 'YES' box and provide description of changes and impact in the PFCP.

The equipment which shall be at least considered ares

- Dedicated telephones PAX / Bell telephones

- Teletype / facsimile equipment If the 'YES' is checked, evaluate corrective actions.

l l

l EXHIBIT 6 Page 2 of 3

Southem Calb son Company ggc 24_3n_15 DEPARDerr Engs.w. w n Construct. ion Department m Paxmms l REV. 6 l l PJrtunVE: m /m /RR]

EXHIBIT 6 1 l

3. Sirens /Public Address Systema Identify any changes to any siren or public address I equipment, contained within the Nuclear Generation Site, by checking the 'YES* box and provide description of changes and impact in the PFCP.

The equipment which shall be at least considered ares All airen systems Dedicated evacuation beacon and strobe lighto

- Public address system If the 'YES' is checked, evaluate corrective actions.

4. Radiation Monitoring System Identify any cnanges to the Radiation Monitoring System contained within procedure SOtt2/33-VI!! 1 by checking the 'YES' bou and provide description of changes and impact in the PFCP.

The equipment which shall be at least considered ares All Radiation Monitory System equipment specified in the above procedure If the 'YES' is checked, evaluate corrective actions.

5. Other Energency Plan commitments identify any changes to the Nuclear Generation Site by checking the 'YES' box and provide description of changes and impact in the PFCP.

Itene which shall be at least considered ares Parking lot utilization et.anges

- Pus transportation changes associated with parking lot utilization

- Security Plan changes, especially those effecting traffic flow, and site / protected area ingress and egresa.

EXHIBIT 6 Page 3 of 3

outhem Cahtomia Edison Company g&c 24-10-15 EPAMErr Engineering and Construct. ion Department 3m 1

l REV. 6 i l m u;n ve: 02/01/88[g l EXHIDIT 7 '

I SECURITY CEECKLIST Evaluate the proposed design change by reviewing it against the cpestions listed below. Any "YES" answers mus t be explained in the Proposed Facility Change (PFC) and denoted on the Design Change Package (DCP) Cover Sheet as an impact to the Security System.

ASPECT OF SECURITY SYSTEM

1. PROTECTED AREA (PA) BARRIERS 2

o Does the DCP provide a pathway greater than or equal to % in under tge PA barrier?

o Does the DCP provide en opening that is greater than or equal to 96 in through the barrier?

o Does the DCP alter the structural integrity or other characteristics of the PA barrier?

o Does the DCP provide any climbing aids adjacent to the PA barrier?

o Does the DCP add any items in the Isolation Zone?

2. VlfAL AREA (VA) BARRIERS o Does the DCP provide an opening greater than or e< pal to % in 2through a VA barrier?

o Does theDfP provide pathways such as cable trays or HVAC ducts with cpenings greater than 96 in through the VA barrier?

o if the VA is not enclosed, does the DCP provide any climbing aids adjacent to the barrier?

o Does the DCP alter the character or structural capabilities of the VA barrier?

o Does the DCP alter the bullet resisting barrier around the control room, central alarm station or secondary alarm station?

o Does the DCP alter the hardware on any door that is part of a VA barrier?

l 3. ACCESS CONTROL N l

o Does the DCP affeet the personnel search equipment?

o Does the DCP affect the capability to search packages?

o Does the DCP af fect the capability to search vehicles?

o Does the DCP alter the security photo 10 badges or affect their use?

4. INTRUSION DETECfl04 SYSTEMS l o Does the DCP alter the means by which alarms from the exterior intrusion detection

system are detected and annunciated?

o Does the DCP alter the means by which access control alarms are detected evi annunciated?

5. ALARM ASSESSMENT o Does the DCP alter the view of the PA barrier or isolation tones?

o Does the DCP alter the enterior lighting on a permanent or temporary basist o Does the DCP allow the placement of buildings or objects in or near the isolation zones on a permanent or temporary basis?

6. POVER SUPPLIES o Does the DCP alter or effect the power supplies for any of the following types of equipments security computer, intrusion detection system, lighting, or any plant communications system?

7. CCMMUNICATIONS o Does the DCP af f ect or alter the SCE PAX system within the plant?

( o Does the DCP af f ect the Pacific Bell or Marine telephone systems?

I o Does the DCP affect the in plant radio systems?

o Does the DCP af fect the redlo systems used to communicate wite of f site agencies?

[ EXHIBIT 7 Page 1 of 1

. Southern Cahtornia Edison Company E&c 24-10-1c DEMRD efr

- Engineering and Construction Department m mxmms

~

l REV. 6 I r.nu; rive: 02/01/88ll EXHIBIT 8 l

I OCP No. REY. i s

DESIGN CHANGE PACKAGE / PROPOSED FACILITY CHANGE (PFCP) CONTENTS PACE REQUIRED PFC SECTION THIS REVISION

1. FORM 26 294, Proposed Facility change Coversheet YES No

2. FORM 26 294 1, Design Change Package / Proposed Facility Change Package Contents Page YES No

3. FORM 26 247, A: tRA Design Re' lew Checklist YES NO 4 Engineering /$af s ty Evaluar on 10CFR50.59 YES NO

5. FORM 26 292, Fire Proter sion Design Checklist YES NO

6. FORM 26 182, Ptart Hat,rds checklist YES No

7. FORM CC(123) 183, ; Onofre Nuclear Generating Station Configuration Document Checklist YES No

8. FORM CC(123) 184, San Onofre Nuclear Generating Configuration bocuments Requiring Change YES NO

9. Security Plan Checklist YES No N

10. Other (Describe) YES No

_ YES __ N o YES NO DCP SECTION

1. FORM 26 178 1, Design Change Package Coversheet 1 YES

2. FORM 26 178 2, Design Change Package Continuction Sheet 1 YES FORM 26 181, Design Material Takeoff (MTO) YES NO 3.

4 FORM 26 179 1, 10CN/DCN Coversheet(s) YES NO FORM 26 179 2, 10CN/DCN continuation Sheet (s) YES NO 5.

6. Construction Safety Assessment J!._ YES l

YES No

7. Test Procedure Guldetines

)

26-294-1 NEW 12/87 EXHIBIT 8 Page 1 of 1

(NotNSEmemo AND COMsteuc?som

.MO NUC L E a st E N GIN C E RIN G SAFETY ANO LIC E NSsNG

E&C_ 24 10 15 Rev* '

O t p A R T he E N T S j

Procedure Change Notice (PCN)

o 02/05/88 Foc ESC Q A Procedures ' " " " " " "

p Preparation, Review, and Approvst of Proposed Facility Changes (PFC) and Proposed Facllity Change Packages (PFCP) for SONGS 1, 213 3 dh;inator s. CarLiate - -

28509 --

p 4 Cate or grated . O'IE l00

5. Reason for Change _ PCN initiated to provide provisions to support processing PFCPs when a requested Technical Specification change has not been approved by the NRC.

6. Descro* ion Of Change.

In 5 PROCEDURAL ACTIONS, ACTION lll, Step 3, Revise as follows:

3. Others (as appropriate)

System Description Changes Software Modification Requests Emergency Plan Changes In 5. PROCEDURAL ACTIONS, ACTION !!!, Step 3, add New NOTE 3 to reads NOTES: (3) If operation of the proposed facility change requires NRC approval of a Technical Specification change, that fact shall be so noted in Block 2 of Form 26*294 by identifying the appropriate Technical Specification change request number. This Technical Specification change request shall be included with the PFCP.

In B. PROCEDURAL ACTIONS, ACTION III, Step 4, Revise NOTE 2 as follows:

NOTES: (2) If the proposed facility change involves changes to the License or Technical Specifications; or reduces the effectiveness of the Security Plan or Emergency Plan as described in 10CFR50.54 (p) and (q); or if the PFC involves an unreviewed safety or environmental question, the PFC cannot be approved by the Station untlL the changes are approved by the Nuclear Regulatory Commission (NRC) or dispensations are received. Nuclear Licensing witL obtain NRC approvata in accordance with E&C QA Procedure ESC 40 9 10 end/or ESC QA Procedure 40 9 13. There are, however, two exceptions to this requirement. as ,

discussed in NOTE (3) below. Absence of approval shoutd not prevent PFC preparation proceeding to Step 10. The PFCP is not to be transmitted to the Station for ECPs until NRC approvals are received or the criteria specified in NOTE (3) below are met.

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o 02/05/88 For ESC Q A Procedures ' " " " " " "

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FaclLity Change Packages (PFCP) for SONGS 1, 283

8. Carliste - -- -

28509

3. Originator PAX No.

4. Cate Originated

5. Reason For Change PCN Initiated to provide provisions to support processing PFCPs when a requested Technical Specification change has not been approved by the NRC.

6. Descriotion Of Change:

In B. PROCEDURAL ACTIQuS, ACTION III, Step 4, delete text in h0TE 3 and replace with the following:

NofES: (3) If the proposed facility change involves a Technical Speelfication which has not yet been approved by the NRC, the PFCP may be approved by the Station under

'the following circumstances:

a) The Technical Specification change is not applicable to the operational MODE during which the proposed facility change is to be connected to th6 plant's systems (e.g., MODES 586). In this case the Responsible Engineer shalt Indicate the operational MODE restraint In the *0ther" entry in Block 2 of Form 26 294 and shall clearly identify the MODE restraint in the PFCP description and engineering evaluation.

b) The plant may be operated safety, even after the proposed f act Lity change has been implemented, in accordance with the existing Technical Specifications. In this case the Responsible Enstneer shall include in the PFCP engineering evaluation an analysis that describes how the plant may be so operated (e.g., by use of procedural or adelnistrative controls).

In B. PROCEDURAL ACTIONS, ACTION III, Step 18, revise as follows:

18. Upon receipt of the PFCP from Station, review the safety evaluation to verify that the change does not involve an unreviewed safety question or Technical Specification change which has not been approved by the NRC. If a Technical Specification change is required, but has not yet been approved by the mRC, verify that the exemption criteria in Step 4, NOTE (3) above has been met.

In 5. PROCEDURAL ACTIouS, ACTION III, Step 19, revise as follows:

19 Ov$pVard Sign Block 9 of Form 26 294 and return along with the PFCP to the Supervisor, Configuration Control.

On FORM 26 294, Proposed Facility Change, revise Block 2 to include System Description Change and Software Modification Request (See attached FORM).

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$Cf 24 294 SEV 02/84 26-294 Page 1 of 2

Southern CaMornia Ectoson Company

.26-294 Engineering and Construction Department [ atv. 02/88 l l

FDTODf15: I GIIGDUdtR

~

1. Name cf Pespcosible SG Ergineer for ncn-statico initiated PEDS, or Systas Cbgnizant Dyineer for Statico initiated Pfts.

2. Pft ruber ard revisicn ruter cbtained fras Supervisor, Qnfiguratico Centrol.

3. Affected SCtGS Lhit(s) ruter and chte of preparaticn.

4. Title of Pfr ard a cne or two senteran syncpsis describirq the facility cfunge (incitriirq all applicable Design Charge Package (DCP) ruters) ard revisicn ruter, if applicable

5. Chock those itors ircitded in the PftT.

6. Indicate whether the follcuirg are rtquirid, ard initial and d.:*e:

AIARA Review Fire Protecticn Paview Security Paview PUIDR SYSIDE dGDEIRDG GUJP IDER DNIRNENIAL DGDEIR

7. Paview ard sign irdicat1Jg approval of PfrP.

SG HnTEIT DGDETR

8. Review, sign iniicatify approval ard forward to Supervisor, Ctnfiguratico ocntrol for approval.

SJIUNIKH, CDFIGIWrIW CINIRE

9. Ctrplete Blocks 5 throtqh 7 in a<xordance with Staticn Dyineering Precedure S0123-V-4.14, Preposed Facility Oange.

10. Obtain apprtpriate O\ signature verifying Pfr meets Quality Pequirteerits.

NUCIDR SAFEIY GUJP

11. Review, sign irdicatirg approval ard return to Supervisor, anfiguraticn Centrol.

SUIUNIKR, CINFIGJRATICN CINIBOL

12. Ctrplete Blocks 10 ard 11 to cbtain trquired sigraturus frtra Statico personnel in accordance with Station Engineerirq Prtcodure SO123-V-4.14, Prqxsed Facility Qurge.

'6-294 Page 2 of 2

. \

ENGIN E tnlNG ANO CONSTRUCTION ANO I E&C _24 10 15 - g,v,6

, NUCLE AR ENGINE E RING s APETv AND LICENSING ~

t OEPARTMENYs 9 PCN No._2 Procedure Change Notice (PCN)

,, 05/05/88 For ESC QA Procedures " " " "

2. Procecure Title.

preparation. Review, and Approval of Proposed Facility Changes (PFC) and Proposed JJt e l l i t y Chance Packages (PFCP) for SONGS 1 2S3 3 Oreginator. Staunicty 8-7522/2 8507 PAX No.

4 Cate Ooginated __ ; e i n toma

5. Reason For Change _ prw initiated to clarify ortcesses in Exhibits 2 and 3.

6. Description Of Change.

In EXNIBIT 2, Page 1 of 4 - add the following paragraph before Step Ill. SAFETY EVALU*TioW:

Each PFCand change, should state shalt whether include electrical a table loads have been added, deleted or revised by the design listing:

source and 3) the number of kilowatts changed. 1) the description of the change, 2) the power whether any electrical A statement should also be made describing calculations were revised as a result of the design change.

Additionally, any PFC tnat may affect the loading of plant emergency batteries must include a statementthe detailing in effects this section, on theeither load explaining profile. Inwhy the battery load profite is not attec+ed, or included as an attachment to the PFC. the latter case, the revised toad profile wi.t be In EXN181T 2, Page 2 of 4 - add the following paragraph before Step IV. ENVIRONMENTAL EVALUATION:

For battery-related battery PFC's, state clearly whether revision of the Surveillance Procedure for the is or is not required.

In EXHIBIT 3, Page 1 of 5 add the following paragraph before item III.A:

Each PFCand change, should state shalt whether include electrical a table loads have been added, deleted or revised by the design listing:

source and 3) the number of kilowatts changed. 1) the description of the change, 2) the power whether any electrical A statement should also be made describing calculations were revised as a result of the design change.

Additionally, any PFC that may effect the loading of atant eme.gtney batteries must include a statementthe detailing in effects this section, on theeither toad explaining profile. Inwhy the battery load profile is not affected, or in:Luded as an attachment to the PFC. the Letter case, the revised load profile vlLL be In EXMtBli 3, Page 3 of 5 - add the following paragraph after item 4's Response.

For bettery-related PFC's, state clearly whether revision of the Surveittance Procedure for the battery is or is not required.

7. Accrovals

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, ENQiNitMING ANO CONS TRuc TIO N 24.jQ j$

AND 6 NycLE AN ENQiNEE RING S AFE FY ANO LIC ENSING t E&C - Rev* ~

OSPARTMENTS

9. PCN No. 3 Procedure Change Notice (PCN) os/24/88 For EGC QA Procedures '""""'"'

2 Procedure Title ' '

Facility Change Packages (PFCP) for SONGS 1, 283

0. Schafer 2 8670 J Originator PAX No

4. Date Originated - Apr1l 15, 1988

5. Peason For Change _ ni la c art h W use M N N ts 6 and 7.

6. Descriotion Of Change:

In B. PROCEDURAL ACTIONS, ACTION IV, Step 4 (Page 12 of 21), -

revise to read as follows:

4 Assemble the PFCP consisting oft Proposed Facility Change (Form 26-294)

Engineering / Safety, Environmental, and ALARA Evaluation (Exhibit 2)

ALARA Des'Ign Review Check List, if required (Form 26 247)

Fire Protection Design Check List (Form 26 292)

Design Change Package Plant Hazards Requirements (Form 26 182)

Configuration Document Check List and Attachments (Form CC(123) 183, Form CC(123) 184)

E dddf V YY/V Vtd /qd44V /V Vt Y / VVtV YV Y Y /71 V Yt f V4d /Vdt Vttd1/ /V Vtdd Ydt /Vtf V11/7Vtdtt /qVt1V /V V$ r /VVtV VV Y Y /61 The DCP containing CSA (see Exhibit 2 of ESC 24-10-16) or other proposed design changes (e.g., Temporary Facility Modification, FCNs, Special Test Procedures, etc.)

In B. PROCEDURAL ACTIONS, ACTION IV, Step 4 (Page 13 of 21), - revise NOTES to read as foltows:

NOTES: .( 1 ) Clearly indicate which items are included in the PFC by checking the appropriate boxes in Section 2 of Form 26-794, if compliance document revisions are not required as a result of design chanJes, indicate by writing the word "NO" in the appropriate boxes.

l (2) Refer to Exhibit 6 for guidelines in determining the effect a design change may have on the Emergency Plan.

(3) Refer to Exhibit 7 for guidelines in determining the effect a design change may have on the Security Plan.

i i

l I

l E Acorovals N/A ....

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ENalNSERING AND CONsrmVC TION ANO NUCLE A R ENotNag RINo s APETY AND LICENSING i E&C24 10 15 6 OE9ANTMENTs ^R *~

9 PCN No _3 Procedure Change Not'.:e (PCN)

,o' oshv88 For E&C QA Procedures ' " " " "

2 Procedure Titte _ Preparation, Review, and Approval of Proposed Facility Changes (PFC) and Proposed

_acillty F

Change Packages (PFCP) for SONCS 1, 243 1 Orginator_ 0. Schafer 2-8670 ~

4 Cate Originated __ Apri t 15, 1988 S. Reason for Change _ PCM initiated to clarify the use of Exhibits 6 and 7.

6. Descriotion Of Change.

In 8.

PROCEDL'RAL ACTIONS, ACTION III, Step 3 (Page 5 of 21), -

revise to read as follows:

3. Assemble the PFC consisting oft Proposed Facility Change (Form 26 294)

E ng ineer in'g/S a f e t y, Environmental, and ALARA Evaluation (Exhibit 3)

Design Change Package Plant Hazards Requirements (Form 26 182)

ALARA Design Review Check List, if required (Form 26 247)

Fire Protection Design Check List and Attachments (Form CC(123) 183, Form CC(123 184]

14ddfVr//WVid/7V44V/VYtY/TVtVVVYY/71 The OCP containing Construction Safety Assessment (CSA)

(see (e.g.,Exhibit 2 of ESC 24 10 56) or other proposed design changes Temporary Procedures, etc.) Facility Modification, Fletd Change Notices (FCNs) Special Test In 8.

PROCEDURAL ACTIONS, ACTION III, Step 3 (Page 6 of 21), -

revise NOTES to read as fotLows:

NOTES:

(1) Clearly indicate which items are included in the PFC by checking the appropriate boxes in Section 2 of Form 26 294 'f compliance document revisions writing theare wordnot required "NO" as a result in the appropriate boxes.

of desig. changes, indicate by (2) Refer to Exhibit 6 for guidelines in determining the effect a design change may have on the Emergency Plan.

(3) Refer to Exhibit 7 for guidelines in determining the effect a design change may have on the Security Plan.

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