ML20151A661

Rev 4 to Dept QA Procedure E&C 40-9-21, Nuclear Safety Group Review,Evaluation & Audit Responsibilities for San Onofre Nuclear Generating Station. Proposed Change Notices 1 & 2 Encl

ML20151A661
Person / Time
Site:	San Onofre
Issue date:	04/18/1986
From:	Curran J, Henrikson P 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-40-9-21, NUDOCS 8807200078
Download: ML20151A661 (18)

Text

e.

E& C 40-9 21 4

South 1rn CaMornia Edson Company DEPARTMENT ogpgocgoung s Engineering and Construction Department Rev.4 EFFECTIVE: 04/18/s6 NUCLEAR SAFETY GROUP REVIEW, EVALUATION Ato AUDIT RESPONSIBILITIES FOR SONGS 9 A. GEMRAL IWORMATION b. The OSRC is composed of station monogers 1, and group supervisors. The OSRC reviews safety The purpose of this procedure is to generally ospects of station odministration, maintenance, ed describe the overall Compey plan for nuclear safety operations octivities to ensure they are consistent review, evoluotim and audit of SONGS and to provide R with SCE policy, approved procedures and operating specific instructions for the composition of the Nuclear license provisions. The OSRC requirements are Safety Group (NSG), its o>thority, records and functions.

established in the Technical Specifications, Section 6.S.1, and implemented by Station Orders.

2. The afministration of ruclear safety of Edison is The OSRC reports to the NCB ond NSC.

based on the premise that the facility octivities are being performed by krowledgeoble, experienced personnel who c.

have a direct personal concem for safe operations. The The NSG is a Stoff Orgmization composed of facility line mmogement personnel cre responsible to a minimum of three staff specialists md a super-visor. Their primary function is to review facility complete safety reviews and implement facility changes and procedure changes, tests, experiments and within o ronge of constroints in schedule and resources, unplanned events that potentlolly offect nucleor These tasks are in addition to routine day-to-day safety. The NSG staff also hos ovalloble for responsibilities for safe ed efficient operoflons. consultation personnel from other SCE organiza-Therefore, to minimize possible oversights on safety tions and outside consultants with expertise In related matters, a system of checks and balances has been established. special creas. The NSG reports to the Monoger, This system uses interdisciplinary Nuclear Softy, and odvises the NCB on significant reviews prior to approval followed by reviews by safety issues. The requirements for NSG review and specialists in the NSG. In oddition, standing safety audit are established in the Technical Spect-committees have been established at the Station and the fications, Section 6.S.3, and implemented in this Corporate Office to odvise the Station Manager and procedure.

Executive Vice President on significant safety issues.

However, it is recogrilzed that the day-to-day responsibility for soiety rests with the cognizant line monogers, the supervisors and the focility personnel assiped to them. Thus, the administration of nuclear safety is a basic responsibliity of the Chief Executive Officer.

3. The bosic purpose of the safety review process is to ensure that the safety aspects of plant operating prc'>lems, changes, tests md experiments have been properly assessed and proper precastions taken such that the pimt is operating within the bounds of the License, and that an unreviewed sofety question does not exist.

4. Four separate independent review organizottons have been established for SONGS. They are not Intended R to be complimce organizations. However, they provide j competent technical review of all lewls of operoflons to ensure maximum safety. Exhibit I illustrates the relationship between these groy>s. Prepared By: , , bM$/en M-n o.

AuthoF Date The Nuclear Control Board (NCB) is composed of Compey officers and technical monogers and is Approved By: f E d),jA f

. the highest level of corporate review for nuclear m 7 -J/ 4%

Responsible Division Manoger Date safety matters. Information on sipificont safety problems is forwarded to the NCB by the Onsite Review Committee (OSRC) and NSC. The NCB Approved Bys, N WA Orgmi hMonoger M 86 organization and functions are established by its Date p,

charter. Approved By: . r. /M Engineefirig'QA 5teering te Committee Chairmm Page iofS 8807200078 880715 PDR ADOCK 05000361 p PNU 4

Souticm Caldomaa E& son company E& C 40-9-21 DEPARTMENT Engineering and Construction Department OA PROCEDURE REV. 4 EFFECTIVE: 04/18/s6

d. 8. OA Practices The Independent Safety Engineering Group (ISEG) is composed of a minimum of five dedicated full-time engineers. NOTE: The NSG Supervisor shall use specialists Off-duty quellfled Shift Technical Advisors (STA's) may be used as needed to from other SCE technico' organizations supplement the ISEG staff. The purposes of the to augment NSG experilse in the above ISEC we 1) To examine plant operating chorocter- disciplines. Such specialists shall meet istics and sources of operating experience informo- the some quollfication requirements os tion which may indicate areas for Improving plant the NSG members.

safety; and, 2) To molntain surveillance of plant B. _NES&L Specialists:

octivities to ensure that they are performed Specialists in the i

i correctly and that humm errors are reduced os following Nuclear Engineering, Safety and Licensing much as possible. The group receives technical (NES&L) Department organizations are typically direction from and reports to the Monoger, Nuclear avoilable to the NSG to augment their expertise in Sofety. The responsibilities of the 15EG are the creas indicated:

estabilshed in the Units 2&3 Technical Specifico- R I.

tions, Section 6.2.3. ISEG composition and their Health Physics and Environmental R octivilles related to plant surveillance are imple. Group - Rodlochemistry and Radiological mented by E&C QA Procedure E&C 40-9-22. ISEG Sofety octivities related to operating experience feedbock

2. Nuclear Systems Engineering - Instro- 8 ore established in E&C GA Procedure E&C 40-9-19.

mentation and Control, Nuclear Engineering, S. A comprehensive system of planned end documented Mechanical and Electrical Engineering, oudits is corried out by the Ovality Assurance (GA) Quality Assurance Proctices i

' Orgelzation to verify compilance with all aspects of the Technical Specification administrative controls md the 3. Nuclear Analysis Group - Metallurgy, QA Program. Specific oudit octivities are listed in the Nuclear Engineering, Reactor Physics and Technical Specificottons, Section 6.5.3.5. Completion of Reactor Systems Transient Response oudits re wired by the Technical Specifications is j 4.

reported by the Meoger of GA, to the Mmoger, Nuclear Nuclear Affairs and Emergency Planning Sofety, on m annvol basis. The Monoger, Nuclear Sofety, Group - Of fsite Emergency Preparedness is promptly informed of deficiencies detected during the S.

ouditing process and their resolution. Nuclear Licensing Groups -

NRC Regulations and License Conditions

1. ORGANIZATION R C. Other SCE Specialists: In addition to the NES&L organizations listed above, specialists are A. Composition: The NSG shall consist of a reodily available from other deportments to minimum of three stoff specialists and a augment NSG expertise. A comprehensive listing swervisor. The swervisor shall have o Bochebr's would require an extensive report. The following degree in engineering or physical science and six examples litustrate the resources availobles years of professional level managerlot experience in ,

the power field. Eoch staff specialist shall have o Oroonization Available Expertise Bochelor's degree in engineering or physical science and five years of professional lew! experience in 1. Engineering All major angineering the fleid of his speciolfy. Stoff specialists shovid be Division disciplines including selected with the goal of molntolning Individvols in electricol, mechanical, the group with expertise in each of the following civil, and controls with creas: specialists In com-poters, metallurgy, and I. Nuclear Power Plant Operations specific opporotus

' important to power

2. Nuclear Engineering plont operoflon and electrical transmission

3. Chemistry and Rodiochemistry 2. Reseorch and Scientific disciplines Development j

4. Metallwgy including biological, environmentoi, physi-S.

Instrumentation and Control col cod chemical science

6. Radlological Sofety

7. Mechanical ond Electrical Engineering Page 2 of 5

__ -_____L-_ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - _ _ - - ---- -

Southern CaMom:2 Edison Company E&C 40-9-21 DEPARTMEN Engineering and Construction Department ggy, ,

EFFECTIVE:04/18/86 Oroonization _Available Expertise NOTES: o.

Site procedures are prepared,

3. Steam Power plant operoflons revised, and reviewed in Generoflon including maintenonce occordance with Site Admin-and operating istrative Procedure sol 23-VI-l.0, 8 practices, equipment Documents - Review and Approval experience, chemistry for Site Orders, Procedures, and control, a wide range instructions. FORM PF(123) 109, R of laboratory analyses. Routing and Document Control, or metallurgy and FORM SO(123) 110, Temporary  !

radiological safety Change Notice, is used of the

4. System Station to document the results of Electricci distribution the safety evolvation, review, and Operation md approval. Af ter Stetlon approval, protection of electricol equipment Corporate Documentation Manuge-D. ment (CDM) Jobsite forwards Outside Consultants: In addition, outside copies of the changes to the NSG consultants should be utilized by the NSG Supervisor for review in occordonce with the to provide expert odvice to the NSG, if required. Site Document Matrix.

E.

FORM 26-22-2, Data Transmittal, Authority: The NSC has authority to obtain is signed by on NSG staff reviewer occess to plant records and personnel necessary to and is returned to COM for file to identify md investigate problems to request document NSG review of the safety g assistance or corrective action from o,ther Monogers evolvations. The changes are through the Monoger, Nuclear Sofety, and to verify screened in occordonce with the the odequacy and completeness of ecch response. criteria given in Exhibit 2, and a Sipificant safety problems are reported by the NSC review is conducted as described in Supervisor the ACTION below.

to the Monoger, Nuclear Sofety, and higher levels of monogement are advised if oppropriate. The authority and responsibility to b. Station design changes are prepored control the conduct and quality of the work rests in occordance with E&C QA with the cognizant monogement chain. Procedure E&C 24-10-15 and reviewed by NSG in occordonce F. Functions: The NSG is responsible for with this procedure. FORM 26-294, reviewing the subjects listed below in order to Proposed Focility Change, is used provide independent verification that plant to document the resvits of the octivities are consistent with operating license safety evolvation. After QA provisions md deviations are promptly investigated approvol, the Supervlsor, Con-and corrected in such a manner os to reduce the figuration Control, forwards the probobility of recurrence of such events. change pockoge to the NSC where o G. review is conducted as described in Functions the ACTION below. 8

3. Proposed tests or experiments which (Review of Chonoes. Tests, and Experiments) involve on unreviewed safety question os

l. The safety evolvations for I) changes to defined in 10CFR 50.59 procedures required by the Technical NOTE:

Specifications Section 6.8, equipment or Tests and experiments are conducted in systems and 2$ tests or experiments completed occordonce with approved Station under the provision of Code of Federal procedures which are reviewed in Regulations, Title 10, accordance with the ACTION below.

Port 50.59 R (10CFR 50.59), to verify that such octions did not constitute on unreviewed safety question

2. Proposed changes to procedures, equipment or systems which involve on unreviewed safety question as defined in 10CFR 50.59 Page 3 of S i

Soutaarn CaMomia EQson Company . E&C 40-Mi DEPARTMENT 3

Engineering and Construction Departrnent OA PRCOEDURE REV. 4 EFFECTIVE: 04/18/86 H. -

Furv:tions 2.

Members of the NSG will porticipate (Review of License Amendments) with the oppropriate members of OA In the planning and conduct of selected audits os l.. Proposed changes to Technicol determined appropriate by the NSC Specifications or the Operating License Supervisor. The result of oudits are reviewed os described in the ACTION below. R NOTE: Changes to the Operating License 3.

including the Technical Specifications The ISEG, os requested by the Superviso-are prepared in occordance with EAC QA of the NSG, may assist in review of the Procedure E&C 40-9-10. NSG cpproval subjects listed in Steps F, G H and H.I of of these changes prior to submittal to Section I.

the Nuclear Regulatory Commission K.

(NRC) is documented on FORM 26-185, Stoff Meetinos: A monthly NSG stoff meeting Proposed License Amendment. NSC will be held for the purpose of fostering interaction review Is conducted as described in the in reviews. The following items should be included ACTION below. in the discussion:

1. Functions 1.

Results of NSC reviews conducted since the previous meeting (Review of Violations ed Operatino Deficiencies) 2. Violations of requirements and review of operating deficiencies since the lost meeting

l. Violations of codes, regulations, orders, Technical 3. Results of OA ovdits performed under Specificottons, license requirements, or of Internal procedures or the cognizonce of the NSG which have been instructions having nuclear safety significance completed since the previous meeting

2. 4. Assessments of overall plant safety Significant operating abnormalities or devlotions from normal and expected L. Records: A summary of NSG reviews and performance of unit equipment that offect nuclear safety ovdits is complied once each calendor month and distributed to the Station Manager and Management

3. All reportable occurrences positions responsible for the orecs reviewed or audited and permanently retained in Corporate

4. All recognized Indications of an Documentation Monegement (CDM) files-General.,

unanticipated deficiency in some aspect of Office (G.O.), Documentation. M destp or operoflon of structures, systems or 6.

components that coutd offect nuclear sofety This procedure complies with the requirements of the opplicoble documents referenc3d in the Matrix of S. Reports and meeting minutes of the Regulatory Reference Material for E&C OA Procedures.

OSRC ,

NOTE: B. PROCEDURAL ACTIONS These items are Identified through

• OSRC Meeting Minutes, GA oudit reports or correspondence from mother ACTION - NSG SAFETY REVIEWS orgmization directed to the NSG f Supervisor. NSG review is conducted as SUPERVISOR, NSG OR DESIGPEE described in the ACTION below. I. Receive document for review and assign to on NSG J. Functions staff reviewer. A copy of a checklist from Exhibit 3 should be used where opplicable.

(Review of OA Audits)

NSG STAFF REVIEWER I. Audits of unit octivities (os defined in 2.

the Technical Specifications, Section 6.S.3.5) Review the document to ensure that the effect of performed by the GA Organization under the the ,nroblem or intended action on the safe operoflon of cognizance of the NSG. the plant has been properly essessed, Poge 4 of 5 4

E&C 40 941 Southem CcJdomia Edson Ccmpany DEPARTMENT Oh pnocEOung .

Engineering and Construction Department REV. 4 EFFECTIVE: 04/18/46 SUPERVISOR, NSG OR DESIGEE S.

E&C OA Procadure E&C 40-9-19, Review of Opero-3.

Review the results of the evolvation performed by ting Experience Reports for SONGS 1,2&3 the NSG staff reviewer and sign the completed review 6.

checklist when used. E&C OA Procedure E&C 40-9-22, independent Sofety Engineering Group (ISEG) Surveillance of Plant

4. Activities For SONGS I,2&3 When the NSG determines that a previously opproved change, test or experiment hvolves on 7.

unreviewed safety question or requires a change to the E&C OA Procedure E&C 41-1-2, Ovality Assurance Tectn: col Specifications, the NSG Supervisor notifies the $ Trainhg of NES&L and E&C Personnel Station Monoger who is responsible for corrective oction.

S. 8. FORM SCE 26-22-2, Dato Transmittal When the NSC reviews unopproved changes, tests, or experiments that have been previously determined to 9.

involve on unreviewed safety question, and it determines FORM SCE 26185, Proposed License Amendment that revision to the d>.Jment or justificotton is 10.

necesscry, o memorandum frorn the NSG Supervisor is FORM 26-294, Proposed Focility Chonge prepared which directs the request for revision to the oppropriate supervisor or monoger and requests a 11. FORM PF(123) 109, response in writing. The originating organization is Unit Routing and Document Control lt

-responsible for working with Nuclear Licensing to obtain NRC @ proval of the desired changes prior to SCE 12. FORM SO(123) 110, Temporcry Change Notice opprovol.

13. Son Onofre Units I,2&3 Technical Specificottons 6.

When the NSG reviews license omendments and ' 14 determines that changes are necessary, the changes are $ Nuclear Control Board Charter documented and resolved prior to submittal.

IS.

Codes of Federal P.egulations, Title 10, Ports 50.59,

7. When the NSG reviews reports on violations or 50.34 and 50.36o operating deficiencies ed determines that odditional oction is necessary, o memorandum from the NSC Super- 16. Topicol Ovality Assurance Monvol visor is prepared which directs the NSC's comments to the oppropriate supervisor or monoger and requests o 17. Environmental Protection Pim response to my safety issues in writing.

8. D. DEFINITIONS A file, of Exhibit 3 cover forms documenting NSG review will be molntoined by the NSC Supervisor. The reviews are summarized in the monthly report, and all Refer to the E&C OA Reference Procedures Monval Glossary.

review forms are molntained by the NSC Supervisor for one year offer opproval. Other routing forms are processed in accordance with the @p!!coble procedure.

Forward all correspmdence from the NSG to CDM Documentation-G.O., to be permeently retained. ,

C. REFERENCES 1.

Site order sol 23 CCO-001, Organlzotion mdh Responsibilities of the On-Site Review Committee I'

2. Site Administrative Procedure SO l 23.VI-l .0, 'q

• Documents - Review and Approval For Site Orders, Procedures, and Instructions

3. E&C OA Procedure E&C 24-10-15, Processing b Proposed Foc111ty Change Pockoges for SONGS 1,2&3 l'

4. E&C OA Procedure E&C 40 910, Preparation of Amendment Applicottons fx the SONGS l Provisional Operating License ed the SONGS 2&3 Operating Licenses Page S of 5

-- ~

E&C 40 9 21 Southern CaWornoa Edsson Company DEPARTMENT Ergiinring and Construction Department U REV. 4 EFFECTIVE: 04/18/86 EXHl81T I i

NUCLE AR CONTROL 00ARO MANAGER, NUCLEAR A w d tt R e e v e's t s MANAGER, Y OU ALITY vdH Re sults SAFETY 4 ASOURANCE OFFICERS AND '

TECHNIC AL MANAGERS L______, 37 37 i SUPERVISOR I NUCLEAR SAFETY I3 E G I GROUP I

S UP E R VIS O R I

I I -

Y V ONSITE REVIEW COMMITTEE lf y

lSEO STAFF SPECIALISTS ENGINEERS

. ST ATION M AN AGERS '

AND GROUP SUPERVISORS i

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SAN ONOFRE INDEPENDENT REVIEW ORGANIZATIONS 1

• --- --- . C O O R DIN A flO N F UNC TION A L DIA C C TIO N l

l EXHIBIT I pog, g og i l

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EA C 40 9-21 DEPARTMENT Southem CaMomoa E6 son Corrpany QA PROCEDURE Engineering and Construction Department REV. 4 EFFECTIVE: 04n8/86 EXHIBIT 2 SCREENING CRITERIA FOR PROCEDURE REVIEW An NSG staff reviewer will be assigned responsibuify for procedure screening and review of the safety evaluation. As each set of procedures is received from CDM, the staff reviewer signs the dato transmittel form (26 22-2) and reviews the safety evolvation.

All procedures which mpeor to involve en unreviewed safety q;estion or require a change to the Technical Specifications prior to implementation must be reviewed by on NSC staff reviewer. All other procedures are screened on a discretionary bosis for detailed review using the following guidelines for high priority sebetion.

l. Sicrificant changes to Emergency Operating Instructions and Special Nuclear Materials Safeguards Procedures E shovld be reviewed by the NSG or another capable reviewer.

2. Startup proced>res which place the p!1nt in a condition wtside of normal Technical Specification requirements by utilizing Special Test Exceptions (3/4.10 serics) and procedures which place plant systems in an unusvol configuratim that could result in increased risk of on occident scenario occurring should be carefully reviewed by the NSC md other orgonizations os necessory to ensure that the potential for error and the risk to the public ard the plant is reduced os much as possible.

Other criterio fcr screening include:

3. Special Procedures (SP series) are used to control unusvol evolutions performed only once or for a short period of t ime. . TSc lewl of complexity and degree of previous review should be noted to determine if further review is warranted.

4. Procedures revised os o result of a Proposed Focility Change (PFC) Technical Specification change, or operating problems observed during other work or highlighted dui: g the monthly meetings.

S. Procedures that are used to occomplish Technical Specification Surveillance requirements.

6. The complexity and extent of chmge of Temperary Change Notices (TCN's) should be noted and riotentially significant changes selected for o detailed review. These reviews are assigned to NSC staff reviewers or other oppropriate Company organizations.

To facilitate management decision making and planning, all NSG requests for changes in procedures will be categorized os:

1.' "Suggest!an" - A procedure change which is editolial or would improve plant reliability or a technical process but does not inwive plant safety

2. "Sofety improvement" - A proce6;re change which represents a worthwhile improvement in pimt safety but is not urgently required to correct an unsofe condition

3. "Sofety Concern"- A comment which merits prompt attention to oddress a safety concern When proced>re reviews indicate a need for further revision, followup oction is requested from the appropriate orgonization in occordance with the following guidelines:

1. Letters dealing with "Sofety Concerns" will be issued over the signature of the Monoger, Nuclear Sofaty.

2. "Sofety improvements" and "Suggestion" comments will be issued over the signaivre of the Supervisor, Nuclear Sofety Group.

Responses to "Solety Concerns" will be tracked by the NSG.

i i t Copies of comments classified os "Sofety Improvements" are sent to the Cognizont Station Manager who is requested R l fo return the dispositioned comments to the NSC. I Implementation of "Suggestion" comments is the responsibility of the Cognizant Station Monoger. They are not

(' trocked by the NSC. The cognizont organization is requested to provide feedbock by returning the dispositioned comments to the NSG.

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I EAC 40-9-21 Southsm CaMoma Ecson Company DEPARTMENT QA PROCEDURE Engineering end Construction Dep:rtm:nt ggy, y ,

EFFECTIVE: 04/t8/86 l EXHlBIT 3 6 ALAA $Af TTY GPMP T101. Aft 0m 4.wJ CptRAT1MC ETTNT UVTW Chf CXL117 Document Isa be r s teacriptise:

Specific Concern er Review lastructionsi Lo g me. : Due La t e s Assagnes to; 1 New Due Cate s Raasos 2 New Na Datei Rassee _

m. era m .v,.. en. s.o r . ci-a :

1. De purpose of the review to to ensure the root cause of the event is understood and appropriate corrective action is betog takes. De report should contata a clear description of the sigstlicant events and consider significant ledividual evente, events which could have been sigstf tcant had there been an additions 1 sal-function or dif ferest operator response, and events which. la cesbir.ation with several sist1st occurrences, become as isportsat trend.

1. Specifically, verify that a prudent and thorough tevestigattoa was coupleted with the following itens incivded whers a,propriate s A. gwpervisory involvement in day-to-day activities is suf ficient.

3. Self-discipline and professionalism among operators and craf t personnel te estatstand at a high level.

C. Operater errors are identified.

D. perseenel are properly trained to perform their required tasia.

E. Adatvate embers of skilled technical personnel are available to perfors required work.

F. Prograss that control ".splementation of design chages and sodifications are adhered to.

C. persenrel are not everburdened by encessive adsialstrative activities.

E. procedurse are adhered to and do not costata etape which are inaccurate er vanecessary.

1. Swf ficleat management tavolvessat is present la radiological aspects of station operations.

J. prepar ettenties le paid to theatstry costrel.

t K. Equipment status is properly controlled. $hif t turaavere are complete.

l L. Alaru and abaartal readings are promptly rssponded to and results of corrective actions are properly anticipated. Also saawre that the operator is act overbordened by an escessive ausber of alarsa vader

. some condittens that reflect a sorsal change of equipeest status rather then as abnersal conditten requiring acties.

M. Resource allocation and schedule for corrective acties should reflect the* sertovenese of the probles ead eet vade r er ever-re act t o the eveat .

preeles AA41ysis:

1. Eaa as adequate low estigatten been perforwed to deters.taa the cause and estest of the f ailure?

3. Vill the corrective acties selve the originating problaa er sorely treat e ersptout

, 3. If the event is a symptoe of a generie destga probles, is the generte probles belag selvedt l 6. Is aggressive acties beteg takes to evaluate the resulte of previous correettve actions is this area sad I to el'.alaste repetittve eventet I

tessite of tvaluations satety Revsew Concivatene

1. This decesat ,d,ge,e or does wt require a change to the technitel specifications er other license provisions.

Dis decaent M or does not tevolve a sigiditcast esisty concern.

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3. .Se tallrwtag seditions 1 action to retwared to address a safety isswa esa vill be tracked as an N$0 epen ic e l

l ws: staf f neviever :ste ss soervisor EXe :Bli 3 Poge i of 7 e

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E&C' 40-9-2 l Southem Cahtomia Echson Company DEPARTMENT OA PROCEDURE Engineering and Construction Department REV.4 i EFFECTIVE: 04/18/86 '

WC" f A s $A rtTY C A Ne

_frCP03 D TAC 1;!*i CMANCE RIY!!V CXfff1I1*

FFC 3ebert De s c ript ies :

Spects,1c Concera er Review Ins t rve t tena s leg so.:

Dua Da t e s _ Assigned tot 1 3ew Due Dete r e Reason:

1 New Ove Dame 8.e a sen t t-Geaeral Review Considerattens

1. De purpose of the revie. Is te ensure that the effect of the change on the safe operatten of the p"ant .

has been properly analysed and the change does met f avelve as vsreyteved safety questtos as daf tsed is

.0CTRJC.59. aer does it tavelve a change to the fechnical Specificatieta.

1. 5sectf aca11y verify that a complete and thorough evaluaties was condweted with the f allowing itama inc!wded where appropriates A. De ressee for the change is adequately explataed.

8. teviattees f rekthe TSAA. especially the descripties of system operaties and accident analysis.

are evaluated med justified.

C. Interactions with other equipment and systems are evaluated to essere their actions stil met conflict and their design criteria are not violated (e.g. EZLSA break locations, fire protettien design. floodias protection design. torsado er internal missila hasarda).

3. The seismic category and tvality classification of the device have been asistained.

E. De che.nge premetse a well engineered and reliable plast.

F. De change does not retstre untessenablF to*Ples er preleased operater action to companaste for destga taadequaties.

G. The c%eese does set rely en unreaseeable aaministrative castrels to coupessate for destas taadequactea 4 FFC Analysiss

1. Eave all deviattens free. er changes to, the TSAA and destga bases been identifiedt

1. Ias em adequate evaluatten been perferned te address the safety implia:stices of the change? *

1. iiall this modificattes esive the artstaating probles er merely treat a symptee?

Besvits et Ivaluation __

Saf ety Concivaiens t

1. nia change d.ees er dees not involve an moreviewed safety question as described ta 10C?t$0.39.

1 Dis change does vt deee s.et involve a cheese to the fechnical Spettlications.

3. nia esange deep, er does set involve as wereviewed environmental question as described ta Appendim 5 to the Operaties License.

6. Pe following additional acties is reqvtred to addresa a safes y issue and will be tracked as sa 55:

egen ites:

550 Staf f Reviewer Date ysc separviser EXHIBIT 3 Poge 2 of 7

e -

Southert1 CaMornsa Edson Company E&C 40-9-21 DEPARTMENT GA PROCEDWE Engineering and Con:tructi::n D:partment REV.4 EXHIBIT 3 rxttn stm enxv tf CTM5g APTEMDrf trvt!V CVECX11E propeedd Change Neber t Envis tes Specif ts Comeers or Review teatrwettoes t eg po. s e Dvs Ca t e s Aselgaed to:

1 sew lNe Dates lasses:

J New 'he Dates Rassen: _

General Review lastrwettomas

1. De purpose of,the review is to ensure that the ef f ect of the choose en the saf e operaties of the flest has been properly analysed, and that all esfety 1sewes are securately end wasabigwowsly presented f or trtC review.

2. Specifically, verify that a couplete sad thorough evaluatten was coniucted with the fellestag items tecluded whete apprepriate s A. Standard wording has been seep 1stely digested and all generic torna and descriptiese have been replaced with plant specif.c wording.

3. Deviatiosa free the T1AA are described and justified.

C. If a probles existe with plast destga, the design problem to alas belag selved.

9. The change enhancas manannenst's ab111ty to feeva es aigsif ttant toeves and dees'aet present se uanetassary administrative burdes. *

1. The change does set retware wareasonably coepisa er preleased operster settees is a specific eres whist 111ste their ability to maintats everall centrel of the plant.

F. Safety related egut;eest la maintaised is as operable statua durteg surveillance teostas to the maatsum estest possible.

C. The bases for the Tschalesi $pecificattaae are thanged when necessary.

3.rview tasvate sed Saf ety Concluatsass

1. lave all devtstiets f ree, or changes te. the F.J.R sad desstn basse been idastifiedt

2. Ese sa adequate evaluattee bees perfereed to detersiae if the sneage tavelves a algatticast hasarse cessideraties se defined in 10CF130.92f Results of tvaluatteer 1

5$C Staf f Reviewer Da t e FSC 5wperviser l

EXHIBIT 3 Poge 3 of 7 l

1 l

l l

4 L

E&C 40-9 21 South:rn Caldomis Edson r ompa!"' DEPARTMENT OA PROCEDURE

., Engineering and Constre. : Department EXHl81T 3 REV.4 EFFECTIVE: n4 o un 7Ctf AJt 5AFEIT :p?J r.ttt urvttv cut:nist Audit Report Embers Technical Specificatten Section Awdtt Re q u t r emen t : 4. 3. 3.1. _

Area Avettedt Spectist Centers or Review Isatructtens:

• • 4 w . 4 ..e a t e 4 asuanes ses 1 New Dus Dates Reasoni 2 New Dwe Date le s se n:

Ceseral Review Considerattens:

1. De pvrposa of the review to to ensure that a coeprehensive syntes of audite la being conductos la the areas listed la Techattal $pecificaties 4.5.3.3. De sedits shev14 provide se objective evaluattee of complisace with precedwres and Licessa condittene and Ladicate the ef fectiveness and destee of ta.

ptementaties of the Qwality Assurasce program, condities.e adverse to gustity or Ladicattvi of sences.

pliance with license condittene should be identified and decwseated et a Correcrive Action Retweet (CAR),

2. Specif tss117 verify that a prudent and therewsh avit; vaa coepleted with the fo11 ewing itesa tac 1.ded where appropriates A. De QA preeres has been properly devolepel to this area to provide sa ef fective systes that asseres gus11ty without se unnecessary adataistrative burdes er unneccesary restrictions to a flestble assagement and probles-solvies approach.

S. Organtaatteest reopensintlities are clear.

C. De'ergasts ettee is at stured such that:

1) Attaineest ti quell 3b;ectives te assigned to these who are responsible for secompitettag the work (e.g destga.r. solder. eterator) and

2) Vertflaattee of confersance to establiehad qualLty requirements La accespitshed by a tech-alcally competent person who does not have direct esponsibility for the work.

D. *ratstag has been adegute to ensure that cesnisant personnel are aware of their responsibilities.

1. Activities affecstas comp 11ance and qwality are pr>perly documented and acceeplished la accordance with writtes tastructions, precedures, and drawings ehich are clear, canctee, and writtes to the level of the user.

F. practices and precedsree reflect appropriate preregutettles, envirensental condittana, special processes, test squipeens. teels. and shttle to attata the agected resvits.

C. De QA program identifies the need for appropriate verificatten of twality by inspection, esaatmatten, or test.

11 . Line saaagement does not rely selair en audits for feedback, but regularly reviews organtastional serformance and resette f or compliance and ef fectiveness.

Aud i t Analystet

1. Was the as tit adequate to evaluate the intended area?

2. bere the t.J's aM ppa's shich were issueu adequate to docwent problens which were tJentifiec R

). Were swbstantia' . pretless identified each that addit tenal actions or audits bovend these alrt .dy ident L=

fled are recomendedt 6 Are changes to the QA progree seeded to provide se ef fective systes for ensuring quality?

Resulta *f tvaluat ten: ,

Sef ety conclustema s

1. De eWit jeg er does not identify a stanificant saf ety concera.

2. De (;11eving addttlesel acties 1e retstred to address a safsty tas . and will be traches as sa 35G epen items WSC Staf f Soviewer D s.e NSC Superviser EXH10lT 3 Page 4 of 7 e

L

Souhem CaMomse E@ son Company EAC 40-9 21 DEPARTMENT Eng.ineering cnd Constructs.:n Departm:nt OA PROCEDURE REV.4 cvung1 WCitAll $ Ayr7 CBNP FtXinit Rivite OTT 1_1T _

precedere hbera levistoa , TC!t fille:

Specific Concate er Review !astructiessi Le g No . s Due Late: _ _ Assigned tas 1 Dew Dve Dater Besses: _ _

2 New Dve Date s lessen General Review Cessideretienes

1. The purpose of the review is to suure that the procedure is is conferasace with the Tschaical Specificattees and the desc-1pties of the plant s otataed ta the F1A.R. The techattal content should be completely accurate and vaanbigveve, with the poteatta; for base errer reduced as such as pose 1ble.

I. Aa adetwate rettew of a technical ptocedure is prisettly based en a sound sad thorough knowledge of the work processes described. Specialists f rom other technical organisattees shev14 be coseulted whaa necessary to assere e couplete review. We f allowing general criteria shev14 be coesidered:

A. A clear statenest of specific eni tetives is provided.

8. %s11tative er quantitative acceptance criteria for any testing activity la provided.

C. Requirements for post-a41stesso<e testing and plant restoraties are defined.

D. Werk plannias 1sta4das ceasiderations such as material, teel, and sanpower reqvtrements; laterdepartmental coordiastient safety consideratione; redtelegical protection retvirements; and gus11ty centret require-seats.

1) Quality Coettel held points are propetly established (i.e . critical parameters are verified, but oncessive signe f a are evelded).

2) .ie work methad is combina:1oe with Quality Centrol (QC) inspectice sad testing allainates the psnalbility of efective er evt of specification verk getag undetected.

3) Is telegical pt statties retutasents are proper.

a) ALAR.A pret tas used where secessary.

b) *esttavev senators are weed where radiatica dose rates could chanle significantly ever a 15ert pe r ed of time.

c) .he pesat ellity of creattag additional radiaties hasards during weth due te spills, renoval of shiels .ag, creetles of tacreased airborne contamination, etc. to sealysed and sessures taken to =1s141se everall espesure.

1. Adatatettative requirseests are adeq"ate to control the work. Sta.lar requirements are combined and saperf tvevs documentattes eliminated to avud overbvriening perscanel with ascensive adstatstestive activittee.

F. The precedure interf aces properly with reisted Statten and C*neral Of fice precedures.

Review Couseats:

1. All comments should be settd oe the attached fors. Where possible, reemente should incivde wording which can be directly tacerted late the preeadore.

2. Saf ety senseets are tracked by tse 383,

3. Receaseadattees are tracked by the Staties f aedures Crew, and will result ta the reviewer being added to

, ;he laterdisciplinary review 11't for tne er*t revisten.

6 $wtgestions are f ar asf ormaties only and met tracked.

lafety Conclusteet

1. This precedure is er le not is cesforment

• with the Technical specifications.

2. Tw., ,recedure fies .t does aet 1evolv - 4evevttved safety quessten as def t ed by toCym.si.

J. The felleuteg .4ditieul action to reqvtred te addresa e saf ety a..a av vill be tracked as as ws: epea tie.:

vsc sief f soviewer este use sweervtsu EX t.6li 3 Poge 5 of 7 e

e EAC 40-9-21 Southem Cahtom:a E6 son Comoany DEPARTMENT OA PROCEDURE

, Engine: ring and C:nitructi:n Department REV. 4 EFFECTIVE: 04/18/86 EXHIBIT 3 WCtyA7 5AytTT G30'!P CstC wIrT!NC RIv1N CRitntif 0310 Meeting haber: Date Specif ts Concern er Review !astructions e

tag me.: No Dates Assigned tes

. sew Due Date r *

k. aeon 2 New Na Ca t e s Besseet Ceseral Review Ceesideratiossa

1. The pvrpose'ef the leview to to mesiter the activities of the edite leview Ccealttee (C$1C) aseettsted with their reviews and tavastigations into potential safety prenlesa.

2. Srecittaally, serify that er,aplete sad accurate evaluattens are perforted, the teet causes of evente are vedersteed, and appropriate correctise setten is being taken.

Seview Esaults:

1 Was say Sew eefety problee identified which the Safety Crevy hee not been 1sferted of threwgh reuttaa reviews 1 ( e . g . , 1814, FFCa, QA Aedit s)

7. Was any new i formaties presseted se a previevety identified pedlem which verrants addittenal ESC artient Seevlts of Ivaluation Safety Ceectuelene s I.

The OstC meettsg minutes h er do not identify an wareviewee saf ety twesties.

2. The fellow 1st additieaal acties is requiree to editess a safety issue and will be tracked

es an USC open stee

l ssC Staff sevt e nate as: h ,e m .or I

l EXHIBIT 3 'oge 6 of 7 L ..

l

{ ~

Souhern CaMoma Emscn Company E&C 40-9*21 DEPARTMENT Engineering end Construction Dep rtm:nt A PROCEDURE a

REV.4 EFFECTIVE: ( /18/86

, EXHRIT 3 w.cita sirtn com tvFWwTD RIM CA T1!F BEYttV 08I"I115?

Date sed fine of geacter frtpa Valt _

Cevee of Trip Specific Concers or Review isattwctione s Les WJ. : Dve Deter Assisted tes 1 New Due t o t e s e leases:

2 Jew Due Date t lasses General Review Consideratiess a

1. De putyone of a post-trip review is to deters 3e the cause of the trip sad whether all plant protectica f eatures operated properly. Das review should be espable of identifying an ATV5 event and show14 prevent restart of the plact, when appr9priate. wat11 accessary corrective actiees have been takaa. De specific objectives of the post-trip review are to make the fellowing deterstr.ations and Laplement any required terreettve actions:

A. De cowse of the trip.

8. Whether the toccter Protectica Systes (R.78) fvactioned properly.

C. Whether the Eastasered safety Features Actestsee Systea (t$fAS) functieaed properly.

D. Wether automatic etulpsest actuated properly. operater actions were proper and timely, and any of f-sersal occurrences identified.

2. De post-trip review ta perfernes immediately af ter the trip by stattee managenest and supervieles.

engtseering specialists, and operettens and asiatenance personnel who were directly 1svelved with the events whleh led to the trip. De pvrtese of the review by the waelear Safety Crevy to to evaluate the reevite of the ?eview te verify that edequate corrective action to planaed er has been takaa to resolve ebearved problems tecluding the following as appropriates A. 34uipsett salfunctices.

8. Any damage as e result of the trip sad subsequent autenstle and manual actions (e.g., thernal shock, water hammer, chemistry escuratese).

C. Precedure errore er wanecessary steps. '

O. personnel errors.

Freelea Analysta:

1. Eas e9 edequate tavastigaties been performed to determine the cause of the trip. plast respasse, and estaat of damage !! anyt

2. Este carrettive actieaa. ceepleted prior to rest art. suf ficient la scope and depth?

3. save appropriate less teri corrective actions bees identified to redwe the probability of reewrrence er tDe sessequences of a stallar event (e.g.. destgt changes. procedure revistess, further analysis. *serater tr,taing).

Resulta of tvaluttes

$sfety Conc haser.as l

1. De post try review d,,ne er does set 1svelve a sigatticant saf ety concars.

I De follovies addittamal action is required to address a safety 1sa.e .nd will be tracked as an E50 e,e. ites:

ns staf f t,vsewer pate vsc s eerviser

~.-

EXH18113 Poge 7 of 7

I.E&C f47't Rev. 4 104GitEERING Ato CDf6TRUCTON Ato t4JCl. EAR ENGitEERING, SAFETY Ato LICEt61NG DEPARTMENTS PRO DURE CHANGE toTICE (PCN)

FOR E&C OA PROCEDURES 9.PCNto.: 1

10. 06/16/86 tJ t ECTIVE DATE 2.

PROCEDURE TITLE: Nuclear Safety Group Review, Evolwtion and Audit Responsibility for SONGS

3. ORIGNATOR: W. W. Strom PAX to.: 2207

4. DATE ORIGINATED: June 2,1986 S. REASON FOR CHANGE:

To more occurately describe certoin NSC review octivities. Exhibit 2 revised to properly indicate how ?" procedure comments are oddressed and to correct the NSG room number.

6. DESCRIPTON OF CHANGE:

In A. GEtERAL IPEORMATON, SECTON 1.ORGANIZATON - J.2 through 3, change to read :

J. Func tions (Review of OA Audits)_

L Audits of unit octivities (os defined in the Technical Specifications, Section 6.5.3.5) are performed by the the OA Orgmization under the cognizonce of the NSG.

2.

With the following exception, each mdit performi d by the OA Organization to sothfy the requirements of Technical Speellication 6.5.3.5 is selected to a detoiled review by the NSC.

The review of Technical Specification 6.S.3.Sd,(mdits of "The performo re of octivities required by the Operational Quality Assurance Program to meet the triteria of Appendix 'O',10CFRSO, of least coce per 24 months"), is normally satisfied by NSG review of the triennlol o.sessment of the QA program performed by e outside consultant, which is rewired by the Topical Repert. Equivalent outside ossessments of the QA program may also be used if a triennial audit is not completed during the 24 month interval in the event that m assessment of the OA program is nut condwted by on outside consultant during a 24 month interval, the F6G will review the mnual OA summary report of Technical Specification mdits, and will then review mdits selected from those performed to verify the QA progrom meets the criterio of 10CFR50 Amendix T'.

3. The 'performece' portion of Technical Specification 6.S.3.56, which requires m edit of "The performance, training ed qualificotlans of the entire unit stoff of least oneo per 12 months,"is notisfied by a series of surveillmees id ntified of ttw begiming of each calendor year by the tGG Swervisor ord conducted br tSL merrbers. A summary report of these surveillances is transmitted to the Manager, Site Ovolity Assurare by the Manager,lhlear Safety of the end of each eclendor year.

7. APPROVALS:

n

, 8th 1 / -['/d N /A d /A Piocedure Author Da te Monoger,5tatim Technic esignee Da te

n D v' b b O.Y e . _ s .. _.s _ .,0 .s,gnee _

// d ya h m ,.

,m, g _. m ,.

8.PAGE I OF 2 l

i i

i t

l. E&C 40-9-11 Rev. 2 ENGitEERING Ato CDNSTRUCTON Ato t4) CLEAR ENGitEERING,5AFETY AND LlCENSING DEPARTMENTS PROCEDURE CHANGE tot 1CE (pct 4 FOR E&C OA PROCEDURES

?. PCN fo.: 1

10. 06/16/86 en LCTIVE DATE

2. PROCEDURE TITLE: Nuclear Sofety Group Review, Evolvation and Audit Responalbilityfor SONGS

3. ORIGNATOR: W. W. S trom PAXto.: 2 2497

4. DATE ORIGNATED: June 2,1986 S.

REASON FOR CHANGE: To more occurotely describe certain N$C review octivities. Exhibit 2 revised to properly indicate how '13" procedure comments are oddressed and to correct the NSG room number.

6. DESCRIPTON OF CHANCE:

In A. GEPERAL ltFORMATON, I.ORGANIZATON . J 2 to 3, change to read :

4. Members of the NSG will participate with the @propriate rnerrbers of GA In the plening md conduct of -

other selected audits os determined @propriate by the FEG Swervisor. The result of ovdits are reviewed as descrbed in the ACTON below.

S. The ISEG, as requested by the Swervisor of the NSG, may assist in the review of the ahjects listed in Steps F, C, H ed I of Section 1.

In EXHIBIT 2, Pcge 2 OF 2,chonge to reod:

Return all comment dispositions to:

Nuclear Sofety Group - Room 316 415 G.O. I Reviewer PAX Date A . "Sv'ggestion" Nonsofety comments which improve the technical process or wording

8. "Sofety It"provement"IMlJdd PASG 14 dhiId/d/d/Hl/114// /H1441 Return dispositioned form to N5G.

C "Sofety '*oncern" Resolve immediately

7. APPROVALS:

N /A MlA N/A d /A Proce&re Author Date Monoger, Station Technical / Designee Date MlA M /A N IA N/A Responsible Divisim Monoger/ Designee ~ Da te Monoger, Ovality Assuronce Date E PAGE 2 OF ?

SCE 26-271 REV.12/85 PCN Disk #3 (40-9-21o) l l

, w S

• I

$ NGIMa t etNG AMD Comt f euC f TOM AMO I E&C in.o st MUC($ A m GMCOM4 4 44MG SAFETV AND LIC E MleNG O 4 p A m f .e t M T s

_ Rev. L 9 PCN No . 2 Procedure Change Notice (PCN)

,, os/2s/88 For ESC Q A Procedures " ' " " " " "

2. Pro <ecu re Tette . Nuclear safety Group Review, Evaluet ton and Audi t Responsibility for SONGS 3 Originator i! . W. Strom PA X No._ 22A97 4 Date Originated May 16, 1988

5. Reason for Chan9e To describe action taken after the OSRC determines an event is a "Pot Nuclear Safety Hazard".

6. Description Of Change-In B. PROCEDURAL ACTIONS, ACTION.NSG SAFETY REVIEWS, revise Step 1 as foll.ws:

1.

• from Receive Exhibit 3document should befor review used where andappt1 assigncable. to en NSG staff reviewer. A copy of a check list Events which have been designated as "Potential in the monthly Nuclear NSG Safety report. Hazards" are assigncd to a staff reviewer and the results reported 6'

7. A 00f0Natt ffn/ rd;-. h

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