ML20151A439

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Rev 0 to Dept QA Procedure E&C 24-10-19, Development, Review,Approval & Release of SCE Limited Change Packages (Lcps) San Onofre Nuclear Generating Station 1,2 & 3. Proposed Change Notice 1 Encl
ML20151A439
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 02/01/1988
From: Eastman
SOUTHERN CALIFORNIA EDISON CO.
To:
Shared Package
ML20151A165 List:
References
E&C-24-10-19, NUDOCS 8807190373
Download: ML20151A439 (52)
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f Southern Cahtornia Edison Comoany ggg g4,3g_39 Engineering and Construction Department T

$P l REV. 0- l l EFFECTIVE:n2/m /RR j DEVELOPMENT, REVIEW, APPROVAL AND RELEASE OF SCE LIMITED CHANGE PACKAGES (LCPs)

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

This procedure documents the process for the preparation, review, approval, (LCPs). release, implementation, and closeout of limited Change Packages LCPs provide a method by which design changes of limited scope may be implemented through a review process consistent with the reduced complexity and safety aspects of the design change. Additionally, the LCP is used to document required by the review of the design change for unreviewed safety questions as 10CFR50.59.

Tnerefore, if the Proposed Design Change meets the criteria for preparation of an LCP, a separate Proposed Facility Change (PFC) is not required.

2.

Any Proposed Design Changes requiring a long form PFC may not be implemented by an LCP (see E&C QA Procedure E&C 24-10-15, ACTION II).

3.

The Quality Class of an LCP shall be the same component, as the Quality Class of the system or structure being modified. The design criteria for the design change shall be in accordance with the Updated Final Safety Analysis Report (UFSAR), Updated Fire Hazards Analysis (UFHA), Security Plan (SP), and Emergency Plan (EP) (reference E&C QA Procedure E&C 24-7-13) for SONGS 2&3 and E&C 24-7-13 for SONGS 1.

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Southern California Edison Company (gg ,

Engineering and Constructior. Department T

$P REV. 0 1 EFFECTIVE: 02/01/88ll 4.

FORM 26-179-1, Interim Design Change Notice (IDCN)/ Design Change Notice 1, 2&3, and FORM 26-179-2, (DCN) SONGS Interim Design Change Notice (IDCN)/ Design Change Notice (DCN) Supplemental Page SONGS 1, 2&3, are used to document design changes and their approval to design disclosure document. The preparation of IDCNs when issued within an LCP will be processed in accordance with E&C QA Procedure E&C 24-10-17. Upon construction completion and Station acceptance of an LCP, all 10CNs within the LCP are converted to DCNs and are

' distributed to the field against the latest drawing revision to reflect the "As-Built" condition in accordance with E&C QA Procedure E&C 24-8-7. Under no circumstances shall a design change be incorporated into a design disclosure document prior to the actual construction completion and Station acceptance.

5.

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 QA Procedure 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 Mocitoring Stations
f. Circulating Water Conduits and Structures 9

Onsite and Offsite Probable Maximum Flood (PMF) Facilities

h. Facilities, systems or components outside the Protected Area which interface with and affect 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 Operating Facility (E0F)
6. This procedure complies with the requirements of the applicable documents referenced in the Matrix of Regulatory Reference Material for E&C QA Procedures.

Page 2 of 14

Southern Caltlornia Edison Company E&C 24-10-19 Engineering and Construction Department T

$P l REV. 0 l l EFFECTIVE:n?/m /g9_ l B. PROCEDURAL ACTIONS e ACTION I - PREPARATION, REVIEW, APPROVAL, RELEASE AND REVISION OF LCP Pro.iect Enaineer (E&C) or Manaaer. Station Technical (NGS) 1.

Assign the design change to a Lead Discipline Group Leader (E&C) or Supervising Engineer 1 (NGS) who will assign a Responsible Engineer (RE) and identify affected disciplines.

Responsible Enaineer (RE)

2. Review Exhibit 1, Limited Change Package (LCP) Criteria, to determine if an LCP may be prepared. Proceed if LCP criteria is satisfied, otherwise prepare DCP/PFC in accordance with E&C QA Procedure E&C 24-10-16.

3.

Identify all affected design documents known at this time, and prepare a brief description of, and the technical basis for changes.

a.

Complete Page 1 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.)

NOTE:

Page 2 of CC(123) 183 is completed by Configuration Control after LCP approval in accordance with Site Configuration Control Procedure S0123-XIV-4.2, Site Design Change Process.

b. List affected design documents on FORM CC(123) 184, San Onofre Nuclear Generating Station Configuration Documents Requiring Change, for each major category identified cn the CC(123) 183.
4. Prepare IDCNs in accordance with E&C 24-10-17 utilizing Forms 26-179-1 and 26-179-2. Obtain IDCN numbers from SCE Project Administration as required and assign numbers to form 26-179-1.

Page 3 of 14 t

-0 Southern Cahtornia E& son Company

- ESC 24-10.I9 DEPARTMENT Engineering and Construction Department QA PROCE0VRE l lilV. 0 l l EFFECTIVE: 02/01/8a.l

5. Indicate LCP number on FORM 26-360-1, Limited Change Package sheet (Exhibit 3) and complete FORM 26-360-2, List of Design Change (LCP) cover (Exhibit 7). Documents NOTES:

(1) LCP number detemined in accordance with Budget and Cost Control Procedure S0123-XIX-3.0, Site Work Request Process and Station Engineering Procedure S0123-V-5.11, Station Engineering Review of Preliminary Design Change Packages.

(2) LCPs are not necessarily related to established Work Requests. Therefore, not all LCP numbers will be based on established Work Requests.

6.

Revise and/or prepare calculations as required in accordance with E&C 24-7-15.

7. Coordination the preparation of affected discipline 10CNs.

NOTE:

Each affected discipline shall prepare Interim Design Change Notices (IDCHs) against the drawings in their area of cognizance.

8. Prepare Description and Engineering Exhibit 6. Evaluation in accordance with 9.

Prepare the necessary LCP Plant Hazards Summary Checklist as described in Exhibit 4.

NOTES:

(1) The existing detailed hazards Checklist (E&C 24-10-15 and 24-10-16) shall be completed and utilized as guidance in preparing the Sumary Checklist. The completed existing detailed checklist shall be signed by the RE only, and forwarded and filed with the original revision number coments.

(2) "YES" answers on the Sumary Checklist require a brief explanation on the checklist qr in the LCP Engineering Evaluation. Additionally, the specific detailed checklist (e.g. for Security, Fire Protection, attached. etc.) must be (3) If the sole basis for checking "YES" under Item 9, Fire Protection, is the need for F8RRRs during construction, then so state only on Fom 26-361. In this case, i

attachment of the detailed Fire Protection Checklist is not required, i

l

Page 4 of 14
c Southern Cahtornia Edison Company ggc g4_yn_g9 Engineering and Construction Department T

$P REV. 0 l 1

EFFECTIVE:02/01/88 l 10.

Prepare Test Procedure Guidelines (or indicate and justify in Engineering Evaluation that Test Procedure Guidelines are not required) (Exhibit 8).

11. Prepare the LCP Safety Evaluation in accordance with Exhibit 5.

12.

Prepare changes to the UFSAR, UFHA, EP, SP, System Descriptions, etc., as required.

13.

CSA shall be obtained from the implementing organization, (prepared during 24-10-16,theExhibit Rev. A2.review) and submitted with the review comments per E&C

14. Prepare Bill of Material Worksheet-F0RM A (FORM 26-93).
15. Assemble the LCP in accordance with Exhibit 2. Indicate the page count on the LCP cover sheet.
16. Distribute or direct Project Administration (PA) to distribute the LCP for interdisciplinary review in accordance with the Document Review and Approval Distribution Matrix (DRADM) for the LCP and contents (i.e., IDCN requirements).

Reviewers

17. Perform an Engineering Review in accordance with the Design Review Responsibility Matrix (DRRM) to ensure that all design requirements are included. Document the review on FORM E0 165-1, Document Transmittal / FORM E0 165-2, Review / Comment Documentation 262, (E&C)/ FORM CC(123) Document Transmittal (NGS).

NOTE: An IRE from the responsible discipline (E&C) or group (NGS) issuing the IDCN as part of the LCP will utilize the criteria on the reverse side of the E0 165-1 as a minimum, and document any coments on the E0 165-1/-2 (E&C) or on the CC(123) 262 (NGS). (Only one E0 165-1 will be required from each discipline.) The IRE shall also review any pertinent calculations.

Nuclear Systems Enaineerina (NSE) Group Leader

18. Perform a safety review and verify correctness of the determinations made with respect to the following:
a. Safety Evaluation
b. Quality Class and Seismic Category
c. ALARA Considerations Page 5 of 14

[

- Sournern Cahtornia Edison Comoany ELC 24-10-19 DEPARTMENT Engineering and Construction Department QA PROCEDURE l REV. O l l EFFECTIVE: 0?/m /R8 l d.

Verify that the LCP does not involve a change to the License and/or Technical Specifications, or does not change the desian basis of the UFSAR, FSA, UFHA, Security Plan or Emergency Plan, and does not involve an unreviewed safety question.

NOTE: For a design change that d_qn involve changes to the items listed in (d) or involves an unreviewed safety question, use of an LCP is not allowed and a long form PFC/DCP (PFCP) shall be prepared in accordance with E&C 24-10-15 and 24-10-16.

19. Sign and return FORM E0 165-1 to the RE or PA (as indicated on the E0 165-1), with comments as required utilizing FORM E0 165-2, as necessary.

Pro.iect Administration (PA)

(If E0 165-1 specifies PA to receive comments)

20. Receive comments and forward to the RE.

Responsible Enaineer (RE)

21. Incorporate and resolve coments and document resolution on Form E0165-1/-2 or CC(123) 262. Assemble package in accordance with Exhibit 2.

Forward the Rev. O LCP for approval in accordance with the ORADM to obtain Lead Discipline approval on 10CNs in accordance with the ORADM.

NOTES: (1) Resolution of review coments and approval of the LCP through Block II of Form 26-360-1 may be accomplished in a design review meeting. Meeting Minutes shall be prepared by the RE to document coment resolution. Meeting minutes shall be signed by the RE and included in review package when fomarded to CDM for retention with the review coments. Documentation of coment resolution with appropriate reference to these meeting minutes is required on the E0 165-1. '

(2) For modifications requiring revision to the Security Plan, prepare a transmittal memorandum to the Supervisor, Security Compliance fomarding an attachment identi fying the recomended/ required changes to the Security Plan.

Fomard copies to the appropriate Supervisor of Nuclear Licensing and Manager, Station Technical. Fomard 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. A copy of the memorandum only shall be attached to the LCP.

Page 6 of 14

Southern California E6 son Company O'I9 Engineering and Construction Department QA PROCEDURE l REV. 0 l l EFFECTIVE 02/01/88__l Pro.iect Administration (PA)

22. Receive the discipline approved LCP and E0 165's with comment resolutions, Rev. O. 0btain additional approvals as required by the DRADM.

NOTES:

(1) for NGS generated LCPs, this step is performed by SONGS Configuration Control.

(2) The HSE GROUP LEADER (or his designee or Site Representative) reviews and approves the LCP indicating that the review required by Step 18 was completed and that NSE comments were incorporated or satisfactorily resolved.

(3) The PROJECT ENGINEER or MANAGER, STATION TECHNICAL will review and approve the LCP verifying:

a) The change involves activities whose nonradiological effects are confined to onsite areas previously disturbed during site preparation and plant construction. The Manager, Station Technical or Project Engineer can provide the Environmental Engineer approval signature.

NOTE: When a proposed change involves activities whose non-radiological effects are not confined to onsite areas previously t

disturbed or impacts offsite areas, the LCP must be sent to the Environmental l

Engineering Group for futher evaluation.

b) That an unreviewed safety or environmental question does not exist.

I c) That the design change 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.

NOTE: For a design change that does involve an unreviewed safety or environmental question or changes to Item c) listed above, use of an LCP is not allowed, and a long form DCP/PFC (PFCP) will be required in 1 accordance with E&C 24-10-15 and 24-10-16.

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

Page 7 of 14 l

l

. Sournem California Edison Company ESC 24-10-1g DEPARTMENT Engineering and Construct. ion Department QA PROCEDURE l REV. 0 [

l EFFECTIVE: 02/01/8%l e) LCP Plant Hazards Summary Checklist is complete.

f) The LCP identifies the Responsible Work Organization (RW0) in Block III of the LCP cover sheet.

(4) Editorial changes are allowed during or after the approval process by lining out and initialing the change. Design content changes are not allowed except in accordance with E&C 24-10-17 and ACTION I, Step 26, Notes (1) and (2).

23. Log the LCP and forward to SONGS Configuration Control Supervisor.

Supervisor. Confiauration Control (CC)

(Information Only)

24. Receive the approved Rev. O LCP and E0165's and obtain additional NGS approvals.
25. Retain the oriainal of Paae 1 of the LCP Cover Sheet (26-360-1, Page 1) and obtain Block IV Nuclear Safety Group (NSG) and QA approvals.
26. Prepare FORM 26 89, Document Issue Request, and forward a copy of Paae 1 of the approved LCP Cover Sheet and the remainder of the approved LCP and all comments to COM SONGS Orawing Processing for distribution.

NOTES: (1) After an LCP has been released for construction, no additional documents shall be added to the LCP without causing a revision to the LCP, except as allowed by E&C 24-10-17, Exhibit 1. Any additions shall be recorded on the list of Design Change Documents.

(2) Changes to the 10CFR50.59 Evaluation (or Description or Engineering Evaluation) can be made on the original LCP by lining out old text and adding new. Approval by NSE Site Representative and Site PE (or Station Technical Manager for NGS generated LCPs) is required. Concurrence will be noted by initialing and dating the original LCP and by stating changes have been assessed and approved on Page 2 of Form 26-360-2. (The Site PE shall contact the Unit PE for concurrence, as deemed necessary.)

27. Identify distribution to COM-SONGS.

Page 8 of 14

. South:rn Cantornia E6 son Company ggc g4_gg,gg Engineering and Construction Department $P T

l REV. 0 l EFFECTIVE: 02/01/88 CDM - SONGS. Drawina Processina (For Information Only)

28. Log the LCP and associated documents as approved and prepare or update the LCP history records in accordance with Site Administration Procedure S0123-VI-28, Corporate Documentation Management Drawing Control Revision Controlled Document Processes.
29. Return a say of the entire LCP cover sheet and the oriainal LCP to SCE Project Administration (E&C) for file, with FORM 26-22-2, Data Transmittal, for acknowledgement.
30. Forward a coov of Pace 1 of the LCP cover sheet, the oriainal Paae 2 of the LCP cover sheet, the oriainal List of Design Change Documents (Forms 26-360-1 and 26-360-2), and a copy of the LCP to the Retrofit Supervisor or Station Technical Cognizant Engineer (as appropriate). Forward one copy cf the LCP to the Project Retrofit Engineer (PRE)/ Responsible Engineer (NGS).

NOTE: The LCP cover sheet identifies the Respensible Work Organization (RW0).

Retrofit Supervisor / Station Technical Coonizant Enaineer

31. Coordinate the implementation of the change (including the partial turnover process) with the organization responsible for construction in accordance with Retrofit Program Administrative Procedure AP-10, Design Change Process, or other applicable maintenance procedures.

Imolementina Oraanization

32. Construct LCP in accordance with Retrofit Administrative Procedure AP-10, Design Change Process, and other applicable maintenance procedures. Upon completion, process turnover package in accordance with Retrofit Administrative Procedure AP-32, DCP Turnovers. Sign Block V, Step 1 of the LCP Cover Sheet (original 26-360-1, Page 2). Forward the LCP to the Retrofit Supervisor / Station Technical Cognizant Engineer (as appropriate).

Retrofit Supervisor / Station Technical C9anizant Enaineer

33. Ensure that testing is complete and Block V, Step 2 of the LCP Cover Sheet is signed.
34. Ensure Field Generated Interim Design Change Notices (FIDCNs) (and other field generated design change documents) are listed on the original 26-360-2 form, Page 2. Obtain Site Project Engineer or Station Supervising Engineer i

signature on original 26-360-1, Page 2 (as appropriate) (Block V, Step 3) signifying additional design documentation is listed on the 26-360 2.

Page 9 of 14 l

4

- South:rn Cahtornia E@ son Company ggg g4_;n_gg Engineering and Construction Department gPggT l REV. 0 l l EFFECTIVE: 02/01/88[

35.

Upon completion of Step 32 and construction and testing, sign the LCP cover sheet (Block V, Step 4) and process in accordance with AP-10 (for the Retrofit Supervisor) or Site Engineering Procedure S0123-V-4.15, Structure, Equipment, and System' Turnover (for the Station Technical Cognizant Engineer).

36. Forward a rapy of the entire LCP Cover Sheet, (stamped "COMPLETE") and a q

topl of the List of Design Change Documents to Project Administration.

Forward the oriainal Pace 2 of the LCP Cover Sheet, the oriainal List of Design Change Documents and pertinent attachments to Configuration Control (CC).

Confiouration Control (CC)

(For Information Only)

37. Receive the package from Retrofit and insert the criainal Pace 1 of the LCP Cover Sheet (with Block IV Quality Assurance and Nuclear Safety Group signatures).
38. In accordance with Site Configuration Centrol Procedure S0123-XIV-4.2, Configuration Document Change Control for Proposed Facility Changes, notify affected groups utilizing FORM CC(123) 183, San Onofre Nuclear Generating Station Configuration Document Checklist / FORM CC(123) 184, San Onofre Nuclear Generating Station Configuration Documents Requiring Change (hereafter referred to as CC(123) 183/CC(123) 184) that a change has been implemented and that revision of desiga documents and procedures shall be prepared to reflect as-built condition.
39. Sign Block VI after acceptance of a turnover package by Station (Block VI) for LCPs, forward a Memorandum Directing DCN Conversion to Project Administration, a rapy to CDM-SONGS and the IDCN/DCN Conversion ESC (as applicable). Per the "TURNOVER ACCEP1ED" distribution listed on Form 26-360-1, forward a ropl of the approved LCP to NSE and Site Project Engineering (both without IDCNs). Forward a rap _y of the approved LCP Cover Sheet and the List of Design Change Documents (Forms 26-360-1/2), to the Retrofit Supervisor.

Pro.iect Administration (PA)/IDCN/DCN Cc, version ESC

40. Receive Memorandum Directing DCN Conversion and Acknowledgement Receipt.

Convert IDCNs to DCNs. Initiate incorporation of DCNs in accordance with E&C 24-8-7 and issue all As-Built drawing:;.

NOTE: Upon completion of conversion, return the signed Part II of the Memorandum Directing DCN Conversion to Configuration Ccntrol.

Page 10 of 14

Southern California EGuson Comoany ESC 24-10-19 Engineering and Construction Department DEPARTMENT QA PROCEDURE REV. 0 EFFECTIVE:02/01/88jl Pro.iect Gro'Jo leader (NSE)

41. Receive copy of the LCP from Configuration Control.
42. . Prepare memorandum, as appropriate, to the Unit Supervising Licensing Engineer, forwarding marked up UFSAR, UFHA, Emergency Plan (EP), or Design Criteria document changes.

Confiauration Control (CC)

(For Information Only)

43. Receive signed Part II of the Memorandum Directing DCN Conversion from Project Administration and close LCP. Forward original LCP Cover Sheet and copy of LCP to CDM, SONGS for file, and final distribution. Update history record.

CDM SONGS. Drawina Control (For Information Only)

44. Receive, encode and sign the original LCP cover sheet (Block VII) and distribute the LCP in accordance with the "CLOSE 0UT COMPLETE" distribution list on Form 26-360-1. File the original LCP cover sheet and balance of package, a

ACTION II - REVISION AND CANCELLATION OF LCPs SCE Responsible Enaineer/ Pro.iect Enaineerina Site Reoresentative

1. Evaluate the condition requiring a change with the Project Retrofit Engineer (E&C) or Maintenance (NGS). Review the criteria in accordance with E&C 24-10-17, Exhibit 1, to determine if an FIDCN may be written or if a revision to the LCP is required.

NOTES: (1) If a field generated change does not meet the criteria stated in E&C 24-10-17, Exhibit 1, Section 1, initiate a revision to the LCP and repeat ACTION I.

(2) If a field generated change meets the criteria in E&C 24-10-17, Exhibit 1, Section 1, initiate an FIDCN and process in accordance with E&C 24-10-17, ACTION II.

(3) List FIOCNs on Form 26-360-2, Page 2.

Page 11 of 14

i ren Cahtoinia Edison Company ESC 24-10-1g neering and Construction Department URE 4

l REV. 0 L EFFECTIVEin?/01/Ra , t 2.

When it becomes necessary to void an LCP, the term "V010" shall be used and the action taken shall be as follows:

For voided LCPs, the Resp'onsible Engineer shall prepare a new LCP cover sheet, Form 26-360-1, and document the action by noting "V010--To be Revised" in the description area of the form.

i 3.

When it becomes necessary to cancel an LCP, the term "CANCEL" shall be used and the action taken shall be as follows:

For cancelled LCPs, the Responsible Engineer shall prepare a r.ew LCP cover sheet, Form 26-360-1, and document the action by noting "CANCEL."

Once an LCP is cancelled, as indicated by the "CANCEL" LCP cover sheet, a new revision of F10CNs shall not be initiated against that LCP number.

If any modifications and/cr revisions related to the LCP are found to be necessary, a new LCP shall be prepared having a new LCP number assignment.

-The Responsible Engineer shall also revise any calculation which may be a/fected by the voided or canc.elled LCP (refer to E&C 24-7-15) and confirm that no construction physically altering the plant configuration has taken place as a result of the voided / cancelled LCP.

C. REFERENCES 1.

E&C QA Procedure E&C 24-7-13, Design Criteria Documents for Engineering Construction Project (ECP) Activities for SONGS Units 1, 2&3 2.

E&C QA Procedure E&C 24-7-15, Performing Design Analysis and Verification for SONGS 1, 2&3 3.

E&C QA Procedure E&C 24-8-7, Development, Review, Approval i.nd Release of New and As-Built SCE Drawings and Obsoletion of Existing SCE Orawings for SONGS 1, 2&3 4.

E&C QA Procedure E&C 24-10-15, Preparation, Review, and Approval of Proposed for SONGSFacility 1, 2&3 Changes (PFCs) and Proposed Facility Change Packages (PFCPs)

5. E&C QA Procedure E&C 24-10-16, Development, Review, Approval and Release of SCE Design Change Packages (DCPs) and Assembly With Proposed Facility Changes (PFCs) SONGS 1, 2&3
6. E&C QA Procedure E&C 24-10-17, Development, Review, Approval and Release of SCE Interim Design Change Notices (10CN)/0esign Change Notice (DCN)

SONGS 1, 2&3 Page 12 of 14

Southsm Cahtomia Edoson Company ggg g4_l0,l9 Engineering and Construction Department l[P T -

l LEV. 0 .

l EFFECTIVE: 0? /m /88 '

26. FORM CC(123) 184, San Onofre Nuclear Generating Station Configuration Documents Requiring Change
27. FORM CC(123) 262, Document Transmittal (NGS)
28. Design Review Responsibility Matrix (DRRM)
29. Document Review and Approval Distribution Matrix (DRADM)
30. Engineering Specification, S0123-701-01
31. Updated Final Safety Analysis Report (UFSAR) for Units 2&3,Section III
32. Updated Fire Hazards Analysis (UFHA)

O. DEFINITIONS Refer to the E&C QA Reference Procedures Manual Glossary.

Page 14 of 14

1

\

Southern CaMornia Edison Company E&C 24-10-19 DEPARD a r Engineering and Construction Department GA nummE l PEV. 0 l 1 r=ME102/01/Ba.I LIMITED CNANCE PACKACE CRITERIA '

l Criteria '

A limited Change Package (LCP) may be issued if the following criteria are satisfiedt

1. Modifications to a single system, component, group of identical components performing similar functions, or single structure (RCP motor, valve, pump) that will not change the design basis.
2. Limited to 25 IDCNs per package or as approved by the Project Engineer or Manager, 3tation Technical.

NOTE: This waiwr applies to the number of IDCNs in the package only, not to other criteria listed herein.

3. Design chunges to correct clearly identified nonconformances in the original design identified by SPR, NCR, etc.
4. Allow reptscement of proven / documented unreliable components with engineering evaluated substitutes (as evaluated by SPEERS). ,
5. Documentation for implementing acceptable / proven temporary modifications as permanent changes within the existing plant design bests and specifications.
6. Allow addition of instrumentation which will not change process or control other system functions (i.e., provide additional monitoring function only).

7 Rerouting / addition of plant piping, cable, conduit, tubing (no change 6 to plant system parameters, or functions that affwet overall system performance or design bases).

8. Re'.ocate plant equipment which will not change plant design basis.

9 Addition / deletion of pipe supports within single system.

10. Addition of piping to facilitate system perf ormance witnout changing overalt system function.
11. Addition / deletion of equipment access structures (platforms, ladders, etc).
12. Removal of abandoned equipment (functionalty terminated by other changes o* etherwise operationally isolated).

General Wates and Guidance kOTES: (1) If a the Field Change Notice (FCN) or LCP criteria cannot be met, modifications shall be implemented by DCP in ac cordanc e with ESC QA Procedure ELC 24 10 16 (2) Any Proposed Design Changes normally requirine a larg form PFC carrut be implemented by an LCP (see E&C QA Procedure ESC 24 10 15, ACTION II).

(3) Criteria that are consistent with the intent of the criteria listed above (but may not be specifically identified above or possibly may not meet the literet interpretation cf the criteria) sury be attled try PCN ard approved in accordance with ESC QA Procedure ESC 41 1 7.

EXHIBIT 1 Page 1 of 1

Southern Calotornia Edison Company

- E&c 24-10-19 DEPAMMD7r Engineering and Construction Capartment oA mxmmE l REV. 0 [

j EmxTIVE: 02/01/88 l EXHIBIT 2 C05 TENTS OF LCP SECTION TITLE

1. FORM 26 360 1, Limited Change Package (LCP) Cover Sheet (Exhibit 3)
2. FORM 26 360 2, List of Design Change Documents (Exhibit 7)
3. Description of Change (Exhibit 6) 4 Engineering Evaluation (Exhibit 6)
5. LCP Safety Evaluation (10CFR50.59 Evaluation) (Enhibit 5)
6. FORM 26 361, LCP Plant Natards Summary Checklist (and as required, any detailed specific hazards checklist)
7. Construction Safety Assessment
8. Test Procedure Guidelines, as necessary (Enhibit 8)
9. Changes to UFM A, UFSAR, Emergency Plan (EP), Security 5lan changa memorandum, Systems Descriptions, as required / appropriate
10. FORMS CC(123) 183 and 164
11. FORM 26 93, sill of Material Worksheet FORM A
12. FORM 26 179 1 and 26 179 2 NOTES: LCP Plant Matards Summary Check lIst shall be suf ficiently ccrplete such that other checklists shall not be necessary (see Exhibit 4 for additional guidance).

i l

l EXHIBIT 2 Fage 1 of 1

Southern CaMornia Edison Company E&c 24-10-19 DEPARDE2Tr Engineering and Cor.struction Department oA PaocEcuaE l REV. 0 [

l r.rm;nVE: m/01/28.I EXHIBIT 3 ~~

LIMITED CHANGE PACKA;E UN!T . LCP *$.

LCP Q. CLASS SEISMIC CAT.

TITU HIGHEST Q.CLUT"W ORAWING WITHIN LCP ,

UFSAR Change Required? YES Physical Security Plan?

UFHA Change Required? fES Qf ES i NO EQ Package Revision Recuired? 0 / Barrier Change Required?

ES EQ Master List Change Required? 0 Emergency Plan Change Required? O fES @ 0 (ES 0 startup Systems Affected Q. List Change Required? fES 0 1.

INTERFACE APPROVALS (AFFECTED DISCIPLINf5 PGL's)

1. Civil Engr
2. ILC Engrg.g _ Jate_ _

t, ate

4. Mech. Engrg. Date
3. Elect. E:)g'g. ~- 5. Arch. Date Orte 6. Other
4. Mech. Engrg. Date '

!!. DESIGN ATPROVAL: This change is consistent with the criteria for LCP and is satisfactory for implementation and operation.

Valver of IDCN limit (PE/ Manager Station Technical)

RE/ Station Cog. Engr.

Date Independent Review Engr.

Date Group Leader / Station !upvr.

Cate Environmental Engineering Date

, Nuclear System Engr-t Date Project Engr./ Manager, Sta. Tech.

Date Quality Assurance Ill. STATION APPROVAL:

........................... ,,,,,,,,,,,cate , , , , _ _ _ , , , , ,

Station Cog. Engr.

Supv. Engr. I One Manager, Sta. T. -ecn- Date Date l Oper.tions/ Equipment Control: Work is auth:rized during M6 5 l

SUPV. PLANT COORD.

RESTRICTIONS Date IV. REVIEW-  :...................................................... .............

Review of LCP is performed af ter Station approval for implam?atio1.

1. Quality Assurance
2. Nuclear Safety Group Date

_. Date 6DJP Suh 01STRIBUTION:

STATION APPROVAL Retrofit (3) Site Engineering Station Equipment Control Mahttenance Station Engineerlag Configuration Control 26-360-1 NEW 12/87 page 1 i j I

i EXHIBIT .1 Page 1 of 2 l

i I

Southern Cantornia Edison Company Esc 24 10 19 aEPAaner Engineering and Construct. ion Department a PaocmmE

)

1 l REV. 0 l l EFFECTIVE: 02/01/88 l )

LIMITED CHANGE PACKAGC UNIT LCP NO.

LCP Q. CLASS SEISMIC CAT.

HIGH

..................................................EST V.

Q CL U f W ORAWING WITHIN LCP lHPLEMENTATION AND TURNOVER: RWO:

1. Installation
a. LCP was accomplished by RWO using CW0s, M0s b.

The following additional docurents (attached) were issued after LCP approval for construction: (26 360 2 updated) c.

Work is covru ete, satisfactory, and ready for test with the following exceptions:

1 Date i

2. Test RWO NGR. OR MAINT. SUPT.
a. The follo.ing tests were performed:

by CW0s, H0s b.

The following additional documents (attached) were issued after LCP approval for te:t c.

Tests were the foli;. tingsatisfactorily exceptions accomplished and LCP is ready for turnover with

/_ Oate

3. TEST OPS. SUPV. STA. COG. ENGR.

Engineering Changes a.

The additional documentation listed in 26 360 2 was issued for construction and test of this LCP. The listing is complete.

Date

4. Released for Tarnover *
a. The LCP is satisfactory and ready for Station Acceptance,
b. Exception Date '

REIR0flT SUPV.

............................................./ STATION COG. ENGR.

/l. TURNOVER ,,.CEPTANCE:

The work is accepted 'e

)peration and maintenance with the following exception _

Date

~3TA. COG. ENGR. Date SUPV. ENGR. I Date CONilGURATION CONTROL Vil.CLOSE OUT 1.

2. Affected design disclosure documents and procedures reflect this modification.

All 10CNs are converted to CCNs Date

3. CONF!GURATION CCNTROL Document is on File Date CDM, SUfERVIS

........................................................OR...............................

OlSTRIBUTION:

TURNOVER ACCEPTED CLOSE OUT CCHPLETE (V/0)

Retrofit Supv. (Cover Sheet) Responsible Engineer Site Project Engineer Site Project Engineer /PE Project Administration G.0 Configuration Control (w/o 10CNs) Manager, Station Technical NSE Group leader (w/o IDCNs) Retrofit Supv. cow.soucs Configuration Control cow.co 26-360-1 NEW 12/87 Pam 2 1 EXHIBIT 3 Page 2 of 2

E6C 24-10-19 DEPARDG2/r Soutrem Cahtomia E@ son Company cA m x1y,y Engineering and Construction Department l Rr/. 0 i EatIBIT 4 l mTcTnT: 02/01/88 ;l j l

LIMITED CIAt$t PACKAtt plast EAIARDS SURRAPT CEECKLIST Are there sey specist requiraents .or the followleg effect? Esplein ary 'TfS' aruwere below '

  • er in the LCP Engleserteg f eatuation. Additteestly *?!$* answers require attachment of the '

detalled hatards checklist.

1. Satistles LCP a0 Tis Celteria (tahlblt il
2. N!L94 b0 TES
3. Hydro w en to Ttt Producing materiels 4 ALAtA NO Til (26 267)
5. Electrical u0 Tis E quipmen t i Environmentet
6. foreede _ to ,, T E S Missiles
7. ,i.. die, _ .0 _ Tli l

1 i

I

8. Intereal h3 ft$

i alssiles

9. Fire to 7t5 l Protection -

FRA (26 292)

10. Plant _ 20 _ Til Esternal l Invironment ~

( (tediategical

!apact)

11. Seismic no Tis
12. Security _ uo _ Ytl ._,

(26 10 15 Enhibit ?)

13. Energency u0 Tis I

Plan l (26 10 15, tahlble 6) 14 t avi r oruneat a l _ u0 _ Til (n ear adio t egic e t )

Additfeest Commentes et Daft ._.

ligaature att DATE ligmature GL Daft Signature s$t GL DATE Sigaature 24 361 atW 12/87 DOIIBIT 4 Page 1 of 1 e

l l

E&C 24-10-19 l DEPARn e r '

QA PROCEIIJRE l RW. 0 l l EXHIBIT 5 l um;nve:02f,01/83_l LCP SAFETY EVAlbATION (10CFR 50.59)

SAFETY EVALUAfl0N -

This, portion of the LCP shall set forth the basis and criteria used to determine that the proposed change does or does not involve an "unreviewed safety question."

l In making this determination, the following questions shall be answered:

J

1. Wilt the probability of occurrence of an accident or malfunction of any equipment important to safety previously evaluated in the UFSAR/>SA be increased?

Response (Yes/No) -

The response to this question shalt include L discussion of the overall effect of the change on the probabil:ty of occurrence of accidents analyzed in the references in Exhibit 2 A of E&C QA Procedure E&C 24 10 15. This discussion shall be sufficiently detailed such that it is clear that those accidents analyzed, which are in any way af f er.ted by the change are or are not increasingly probable cbe to change or its installation.

$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.

Exhibit 2 A of ESC 24 10 15 provides guidance to references to complete this section.

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

Responsa (Yes/No - The response to this question shalt include a discussion of those accid analyzed in the ref erences in Exhibit 2A of ESC 24 10 15 which may in any wg i ected by the change. These discussions shall be sufficiently detailed as to demonss .e clearly whether accident analyses bound eny and all conditiens created by it s char,Je or its installation. Exhibit 2A of E&C 24 10 15 provides guidance to

,rences for accident analyses to be considered.

Simple statements, without d i s c'Js s i on of the accidents and development of a logical argument for or ageinst this item, shall require rejection of the proposed facility change.

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

Response: (Yes/No) -

The response to this question shall contain a discussicn of any i non analyzed accidents impacted by the change or its installation. References in l Exhibit 2A of E&C 24 10 15 shall form the basis (but not be the sole means) of I responding to this question. A slepte statement of conclusion is not sufficient and shall be grounds for rejection of the proposed facility change.

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

Response: (Yes/No) -

The response to this question shall :entain a reference to those Technical Specifications (If any) which in any way relate to the change and a suf ficiently detailed discussion of the basis for each rpecification such that it is 7

clear whether that basis is compromised. Key results which effect Technicat l Specifications / Surveillance Procedures (E.G., battery calculations) shall be described in the LCP, even if the Technical Specification basis remains unchanged.

l f

l l

l l

l l

EXHIBIT 5 Page 1 of 1

E&C 24-10-19 DEPARDerr QA PROCEWRE l

l REV. 0 l EFFECTIVE: 02/01/88l

' ~ ' * ~~

EXHIBIT 6 LCP DESCRIP*t0N AND ENGINEERING EVALUATION FORMAT AJn C0hTENT REQUIRENENTS

1. DESCRIPTION -

Sufficiently detailed 64 to the reason, purpose, method, assumptions and design input such that a person technically quellfled in the subject can review and understand the change without recourse t6 the Originator.

Include a brief desciiption of the physical plant changes. Address location of modification piping / conduit routing, welle penetrated, major equipment addition / deletions. Use sketches or marked up *i!Ds, general arrangement, etc. as necessary.

!!. 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, achievsa its objective, is constructible, is operable a nd maintainable. Refer to ESC QA Procedure ESC 37 30 63, Development, Issuance, Revision and cancellation of the Document Packact to Establish the Environmental Qualification (EQ) of Electrical Equipment Listed on the EQ Master List for SONGS 1, 2 and 3 for required environmental qualification information.

include a discussion of the original plant design basis and the impact of this modification on the original design basis. Also include a discussion of the ftretional changes imposed by the proposed m>dification, i

i l

t I

EXHIBIT 6 Page 1 of 1

E&C 24-10-1C Southern California Edisoa Company DEPAR110112 m PaxmmE Engineering and Construction Department l REV. 0 l t.cru; n vE: 02/01/88 l l EXHIBIT 7 LIST OF DESIGN CNANCE DOCUMENTS LCP UNIT IDCN DOCUMENTATION The following documents are contained in this LCP:

.......................................................... 1a...............................

ID Wo. TITLE OVG. NUMBER No.

...........................................................................IDCN .................

l l

\

l t

i i

(

l 26-360-2 NEW Page 1 of 2 12/87 EXHIBIT 7 Page 1 of 2

_____. _ - _ _ _ _ _ _ , _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ . _ _ _ _ _ . . _ . ~ _ _ _ _ _ _ _ . . _ - _ _ _ . _.-

l l

l Southern California Edison Contpany gsc 24 1n_19 DEPARDerr Engineering and Construct. ion Department

~

oA PsocmmE l REv. o l EmrrivE: 02/01/88l l EXHIBIT 7 ADDITIOWAL DOCUMENTATION (FIDCM, etc.)

The following documents were issued and added to LCP after issue:

NO. FIDCN, etc.

l DWG. NUMBER CONST/ TEST ENTERED BY PAGE N '

........................................................................................O. ....

l l

1 10CFR50.59 Revision Approved:

Date NSE Date

$lte PE 26-360-2 NEW 12/87 Page 2 of 2 EXHIBIT 7 Page 2 of 2

Southern California Edison Comoany EEC 24~10'19 DEPARDENT Engineering and Construction Department S ""E l REV. 0 [

EXHIBIT 8 l EFFECTIVE: 07/01/llal l

l l

TEST PROCEDURE GUIDELINES PREPARATION The following outlines the format, content, and requirements for preparation of Test Procedure Guidelines. Test Procedure Guidelines must be prepared when specific engineering parameters are to be verified. If the proposed change involves no critical engineering parameters or cannot impact the existing system critical engineering parameters, so state in the LCP Engineering Evaluation and identify any standard startup tests or processes deemed necessary, (i.e., continuity check, system flush, etc.). In such case, Test Procedure Guidelines are not necessary.

When necessary, Test Procedure Guidelines shall address the following:

SECTION 1.0 - SCOPE Briefly identify the scope and description of the proposed design change including addition / deletion of significant equipment (e.g., pumps, valves, i ns t rwentation, etc.)

SECTION 2.0 OBJECT!YES Identify test objectives and critical engineering parameters to be tested snd confirmed.

SECTION 3.0 - PREREQUISITES Identify pre test riArenents including mode of operation, system conditions, system requirements, special valve / equipment status, special test equipment required, system flushes required, etc.

SECil04 4.0 - CEWER AL METN00s Briefly identify the test methods to be utilized (e.g., meggar, special continuity checks, hydrostatic tests, flow tests, pressure tests, etc.)

1ESTION 5.0 - ACCEPTANCE CRITERIA Specif y detailed acceptance critet la necessary to meet the test objectives identified in section 2.0. Acceptance criteria should identify specific quantitative parameters, equipment status (i.e., valve position expected, pump status expected, flnw requirements, instrument indication, system pressores) and/or other measurable pararacters necessary to confirm expected engineering parameters.

SECTION

6.0 REFERENCES

Reference pertinent documentation sections of FSAR-Section 14.0, existing test procedures that will facilitate test procedure preparation, per tinent ANSI Starxiards or ASME Codes, P&lDs, Elementaries, etc.

EXHIBIT 8 Pagn 1 of 1

C NosM t( SIN G m NO CO N S T RUC flo N

. *~o I E&C 24 10 19

aucuaa enciacea o s*,cev .ao uccasmo Rev 0 -

o(PA=?h.fN7s l

? PCN ho_

Procedure Change Notice (PCN) io _ 04/04/88 For ESC Q A Procedurea ' " " ' " "

p,0Cecure htfe SONGS 1, 2&3 3 Originator 0* "'II##* "88"" '

6/28378

_ PAX No.

80 4 Cate Or+nated

5. Reason For Change To provide provision to ensure that vendor documents which provide design disclo-sure information are converted to SCE drawings; and include provisione for Software Modification if a design change impacts any plant computer systems.
6. Descriotion Of Change:

In A. GENERAL INFORMATION, Step 4, revise as follows:

4 FORM 26 179 1, Interim Design Change Notice (IDCN)/ Design Change Notice (DCN) SONGS 1, 283, and FORM 26-179 2, Interim Design Change Notice fl0CN)/ Design Change Notice (OCN)

Supplemental Page SONGS 1, 283, are used to document design changes and their approval to design disclosure document. The preparation of IDCNS when issued within en LCP will be processed in'accordance with ESC QA Procedure ESC 24 10 17. New (not previously issued) SCE design and/or Vendor drawings (which provide substantive design .7 formation needed for construction) are also implemented through the LCP process. New drawings are included in the LCP in a standard SCE drawing format (issued for Construction) rather than on the 26 177 1.

Upon construction completion and Station acceptance of an LCP, all IDCNs within the LCP are converted to DCNs and are distributed to the field egainst the latest drawing revision to reflect the "AS Built" condition in accordance with ESC QA Procedure ESC 24 8 7. Under no circumstances shall a design change be incorporated into a design disclosure document prior to the actual construction completion and Station acceptance.

In B. PROCEDURAL ACTIONS, ACTION I, add new Step 4 to read:

4 If the design change impacts any plant computer systems, contact the Station Computer Group and submit a Software Modification Request in accordance with Station Engineering Procedure SO23 y 4.70, Software Modification and Ver*fication.

Renumber Items 4 through 44 to 5 through 45 in C. REFERENCES, add new Step 13 to read

13. Station Engineering Procedure 5023 V-4.70, Software Modification and verification Renumber Items 13 through 32 to 14 through 33 in EXNIBIT 2 of ESC 24-10 19, add new Section Item 13 to readt
13. Software Modification Request in accordance with Station Engineering Procedure SO23 V 4.70, toftware Modification and Verification, as applicable
7. Accrovats y-.._...LA .T,n h..,/.es ...

Yt.. y ............... 7/M..V ..

x........... . % =...c 5<cru ....

48 n L nhL a san.fer o, aua o ty Assuranee

%Ar u....... .. . ..,..

3 Pye of

_ _ _ _ _ _ _ _

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