ML17354A488

Rev 31 to Fpltqar 1-76A, Topical QA Rept, Consisting of Attachments A-D

ML17354A488
Person / Time
Site:	Saint Lucie, Turkey Point
Issue date:	04/16/1997
From:	FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17354A487	List: ML17354A486 ML17354A488
References
FPLTQAR-1-76A, NUDOCS 9705050401
Download: ML17354A488 (218)

Text

TOPICAL UALITYASSURANCE REPORT T R 1.0 Rev. 31 ORGANIZATION 04/16/97 APL Date Pa e 1 of 5 1.1 GENERAL RE UIREMENTS The Florida Power 8c Light (FPL) organizational structure shall be defined such that the responsibilities for establishment and implementation of the Quality Assurance Program are clearly identified. The authority and duties of individuals and organizations performing quality assurance and quality control functions shall be described, and shall illustrate the organizational independence and authority necessary to identify problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions.

In addition, the description shall illustrate that persons or groups responsible for verifying the correct performance-of an activity are independent of the person or groups responsible for performing the activity.

1.2 RESPONSIBILITY The FPL Chairman of the Board and Chief Executive Officer is ultimately responsible for the execution of the Quality Assurance Program for FPL nuclear power plants.

Authorities for developing and verifying execution of the program are delegated to the President Nuclear Division and the Director Nuclear Assurance, respectively.

The President Nuclear Division has overall responsibility for the Nuclear Division's activities including corporate responsibility for overall plant nuclear safety.

The Vice President - St. Lucie Plant and Vice President - Turkey Point Plant are accountable for the operation, maintenance, and modification of their respective nuclear plant. The plant Vice Presidents have overall responsibility for implementation of the Environmental Protection Plans at their respective sites.

The Plant General Manager - PSL and Plant General Manager - PTN, through the respective plant Vice President, are responsible for the safe operation of the nuclear plant.

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TOPICAL UALITYASSURANCE REPORT T R 1.0 Rev. 31 ORGANIZATION Date 04/16/97 Pa e 2 of 5 The Director Nuclear Assurance is responsible for verifying execution of the FPL Quality Assurance Program and initiating Quality Assurance policy and program changes when necessary. The Director Nuclear Assurance is also responsible for the Nuclear Safety Speakout program (employee concerns program) and administration of the Company Nuclear Review Board (CNRB) Subcommittee. The Director Nuclear Assurance serves as the CNRB chairman.

y5 The Vice President Nuclear Engineering is responsible for nuclear plant design and engineering support.

The Manager Nuclear Licensing and Special Programs is responsible for selected licensing support activities and other assigned programs at the Juno Beach<<Office.

The Director Nuclear Business Services is responsible for Nuclear Division business and financial planning and analysis and nuclear plant support in the areas of document control and QA records management, division-based and staff computer systems, security, emergency preparedness, and radiological services.

The Director of Protection K Control Systems is responsible for test, calibration and maintenance of certain high voltage electrical protective relays. for safety related systems of the nuclear plant and for related support functions.

The Director Environmental Services is responsible for providing technical support on environmental regulatory matters.

The Vice President of Information Management is responsible for ensuring the integrity of the computer operating environment and the applications used by the Nuclear Division.

II TOPICAL QUALITYASSURANCE REPORT T R 10 Rev. 31 ORGANIZATION Date 04/16/97 Pa e 3 of 5 The Corporate Records Supervisor is responsible for storage, retrieval and control of Quality Assurance records received from the nuclear plants and corporate office. The Corporate Records Supervisor also serves as the Records Official and chairman of the Quality Assurance Records Storage Evaluation Team (QARSET).

The head of each department or organization performing activities affecting quality is responsible for: a) identifying those activities within the organization which affect quality as defined by the Quality Assurance Program; b) establishing and clearly defining the duties and responsibilities of personnel within their organization who execute those

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activities affecting quality; and c) planning, selecting, and training personnel to meet the requirements of the Quality Assurance Program. The responsibility, authority, and organizational relationship for performing activities affecting quality within each organization shall be established and delineated in procedures, organizational charts and (

written job, or functional descriptions.

Activities affecting quality may be performed by FPL or be contracted. Should, any of these functions be contracted, the contractor may perform the activities under their own )

Quality Assurance Program, which must have prior approval by FPL Quality Assurance, or the contractor may directly adopt the requirements of the FPL Quality Assurance Manual. If the contractor implements the Quality Control function directly to the FPL Quality Assurance Manual requirements, the contractor's Quality Control Supervisor shall have the authority and freedom to administer the Quality. Control program.

45 TOPICAL QUALITYASSURANCE REPORT TQR 1.0 0 ORGANIZATION Rev.

Date 31 04/16/97 FRL Pa e 4 of 5 1.3 ORGANIZATIONALRELATIONSHIPS The organizational charts in Appendix A show the lines of authority, responsibility and communication from the highest management level through intermediate levels to, and including the on-site. operating organizations.

The Plant General Managers have control of the on-site resources necessary for the safe operation and maintenance regardless of organizational reporting.

The organizational freedom of the Quality Assurance function is accomplished through the corporate structure, illustrated in. Appendix A, which provides independence from those departments responsible .for design, procurement, engineering, construction and operation. With quality assurance as its sole function, the Quality Assurance Department, both on-site and off-site, is completely free from the cost and scheduling pressures of design, procurement, construction.and operation. The Quality Assurance Department has the freedom and authority to: a) identify quality problems; b) initiate, recommend or provide corrective action; c) verify implementation of the corrective action; and d) recommend the stoppage of work or operations adverse to quality, when necessary. The QA Supervisor Performance Assessment, QA Supervisor Procurement Quality, Quality Manager - St. Lucie,.and Quality Manager. - Turkey Point report administratively and to the Director Nuclear Assurance. These reporting relationships assure that 'unctionally the Quality Assurance Department has direct access to the levels of management necessary to assure effective implementation of the Quality Assurance Program.

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TOPICAL QUALITYASSURANCE REPORT T R 1.0 Rev. 31 ORGANIZATION Date 04/16/97 Pa e 5 of 5 1.4 REVIEW AND AUDIT COMMITTEES The Plant Nuclear Safety Committee (PNSC) at Turkey Point Plant and the Facility Review Group (FRG) at the St. Lucie Plant are comprised of key plant management and staff personnel as described in the plant Technical Specifications. The PNSC/FRG serves the Plant General Manager in a technical advisory capacity for the review of all safety related procedures and activities that impact plant safety and the facility operating license.

The Company Nuclear Review Board (CNRB), reporting to the President Nuclear Division, is comprised of executive level members of management with responsibilities for the execution of the Quality Assurance Program. The CNRB composition is described in Section 6.0 of each facility's Technical Specifications. Subjects within the purview of the CNRB are listed in the appropriate plant Technical Specifications. The CNRB has the authority to carry out its responsibilities by way of written action letters, verbal directions, meeting minutes or appointed subcommittees. Where necessary, the CNRB may use consulting services to perform required reviews. Periodic audits of the Quality Assurance Department are performed by a team independent of the Quality Assurance Department. The results of these audits are presented to the CNRB.

A Quality Assurance Program Review Committee (QAPRC) has been established to )

review changes to.the Quality Assurance Program and to provide an interface for quality matters in each department affecting. quality. The QAPRC is an interdepartmental organization with the responsibility to.review and resolve recommended changes to the Quality Assurance Program. This committee is administered by, the Quality Assurance Performance Assessment group.

A Quality Assurance Program Review Committee (QAPRC) Member shall be, designated by the head of each department or organization. The QAPRC Member is the prime interface for coordination of quality matters within the member's department, with the Quality Assurance Department, and with other departments.

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ATTACHMENT8 TQR 1.0 Revision 30 Current Revision

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 30 ORGANIZATION Date 03/28/97 Pa e 1 or 20 1.1 GENERAL RE UIREMENTS The Florida Power Ec Light. (FPL) organizational structure shall be defined such that the responsibilities for establishment and implementation of the Quality Assurance Program are clearly identified. The authority and duties of individuals and organizations performing quality assurance and quality control functions shall. be described, and shall illustrate the organizational independence and authority necessary to identify,problems; to initiate, recommend, or provide solutions; and to verify implementation of. solutions.

In addition, the description shall illustrate that persons or groups responsible for verifying the correct performance of an activity are independent of the person or groups responsible for performing the activity.

1.2 IMPLEMENTATION The'FPL Chairman of the Board and Chief Executive Officer is ultimately responsible for the execution of the Quality Assurance Program for FPL nuclear power plants. The authority for developing and verifying execution of the program is delegated to the President Nuclear Division and the Director Nuclear Assurance. The reporting relationship of each department involved with the Quality Assurance Program is shown in Appendix A.

To provide for a review and evaluation of Quality Assurance Program policies and activities, the President Nuclear Division has established the Company Nuclear Review Board (CNRB). This organization's responsibilities are defined in Section 1.3.1.

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, TOPICAL UALITYASSURANCE REPORT TQR 1.0 Rev. 30 ORGANIZATION Date 03/28/97 Pa e 2 or 20 In addition, a Quality Assurance Program Review Committee (QAPRC). has been.

established to review changes to the Quality Assurance Program and,to provide an interface for quality matters in each department affecting quality. The QAPRC is an interdepartmental organization with the responsibility to review and resolve recommended changes to the Quality Assurance Program. This committee is administered by the Quality Assurance Performance Assessment group. Quality Assurance Program changes reviewed by the QAPRC are reviewed and signed by the affected department heads.

A Quality Assurance Program Review Committee (QAPRC) Member shall be designated by the head'f each department or organization. The QAPRC Member is the prime interface for coordination of quality matters within the member's department, with the Quality Assurance Department, and with other departments.

The head of each department or organization performing activities affecting. quality is responsible for: a) identifying those activities within the organization which affect quality:as defined by the Quality Assurance Program; b) establishing and clearly defining the duties and responsibilities of personnel within his organization who execute those activities affecting quality; and c) planning, selecting, and training personnel to meet the requirements of the Quality Assurance Program. The responsibility, authority, and organizational- relationship for performing activities affecting quality within each organization shall be established and delineated in organizational charts and written job or functional descriptions.

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TOPICAL QUALITYASSURANCE REPORT T R 1.0 Rev. 30 ORGANIZATION Date 03/28/97 Pa e 3 of 20 Activities affecting quality, may be performed by FPL or be contracted. Should any of these functions be contracted, the contractor may perform the activities under his own Quality Assurance Program, which must have prior approval by FPL Quality Assurance, or, the contractor may directly adopt the requirements of the FPL Quality Assurance Manual. If the contractor implements the Quality Control function directly to the FPL Quality Assurance Manual requirements, the contractor's Quality Control Supervisor shall have the authority and freedom to administer the Quality Control program; 1.3 RESPONSIBILITIES The organization charts in Appendix A illustrate the lines of authority and areas of responsibility for each of the organizations that are involved in activities affecting quality.

Below are listed the departments and organizations that have quality assurance responsibilities. Organizational responsibilities for implementation of the Quality Assurance Program are described in the Topical Quality Requirements (TQRs).

1.3.1 Nuclear Division 1.3.2 Su ort De artments 1.3.1.1 Plant Vice Presidents. 1.3.2.1 Corporate Records 1.3.1.2 Licensing and Special Programs 1.3.2.2 Environmental Services 1.3.1.3 'uclear Engineering 1.3.2.3 Protection 8t; Control Systems 1.3.1.4 Nuclear Assurance 1.3.2.4 Information Management 1.3.1.5 Nuclear Business Services 1.3.1. Nuclear Division Throughout, plant life, the Nuclear Division maintains control of and responsibility for nuclear power plant design, preoperational and start-up testing, operation, maintenance, refueling, and modification of the plant in accordance with written and approved procedures.

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 30 ORGANIZATION Date 03/28/97 CPL Pa e 4 or 20 The President Nuclear Division has overall responsibility for the Nuclear Division's activities including corporate responsibility for overall plant nuclear safety.

Reporting to the, President Nuclear Division are: the Vice President - Turkey Point Plant, Vice'President - St. Lucie Plant, Director Nuclear Assurance, Vice President Nuclear Engineering,.Manager of Licensing:and Special Programs, and the Director Nuclear Business Services.

The Company Nuclear Review -Board (CNRB), reporting to the President Nuclear Division, is comprised of executive level members of management with responsibilities for the execution of the Quality Assurance Program. The CNRB reviews, or directs the performance of reviews of, activities concerning the technical aspects of the operating nuclear power plant insofar as they impact plant safety, the health and safety of the public, and laws, regulations and licensing commitments. In addition, audits of these areas are performed under the cognizance of the CNRB.

The CNRB composition is described in Section 6.0 of each facility's Technical Specifications. Subjects within the purview of the CNRB are listed in the appropriate plant Technical Specifications. The CNRB has the authority to carry out its responsibilities by way of written action letters, verbal directions, meeting minutes or appointed subcommittees. Where necessary, the CNRB may use consulting services to perform required reviews.

The CNRB is responsible for reviewing and evaluating Quality Assurance Program policies and activities. Quality Assurance Program status reports shall be periodically given by the Quality Assurance Department.

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TOPICAL UALITYASSURANCE REPORT TQR 1.0 Rev. 30 ORGANIZATION Date 03/28/97 Pa e 5 or 20 CNRB meetings shall be held by the Chairman to keep members apprised of conditions including significant problems that require management attention.

Periodic audits of the Quality Assurance Department shall be performed by a team independent of. the Quality Assurance Department. The results of this audit are presented to the Director Nuclear Assurance and the CNRB.

1.3.1.1 Plant Vice Presidents The Vice President - St. Lucie Plant and Vice President - Turkey Point Plant are accountable for the operation, maintenance, and modification of their respective nuclear plant, as well as the selection, development and direction of the assigned staff. They will act as liaison between the plants and corporate headquarters, and are accountable for ensuring that company policies and procedures are properly implemented and continued at the nuclear site, including procurement and control of material. The Plant Vice President has overall responsibility for implementation of the Environmental Protection Plans at their respective sites.

Other responsibilities of the site Vice President include the following:

Nuclear Services o Configuration management.

Nuclear Trainin Preparation of policy documents regarding nuclear training; Support to secure the necessary resources to ensure that site personnel are adequately trained. They must have adequate technical and job related skills to provide safe and efficient operation while complying with NRC requirements.

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TOPICAL UALITYASSURANCE REPORT TQR 1.0 Rev. 30 ORGANIZATION Date 03/28/97 Pa e 6 or 20 Nuclear Securit o Coordinate with the opposite plant site for overall development and implementation of the FPL Nuclear Security program.

Nuclear Business S stems o Coordinating contract activities.

o Reviewing contracts to assure that technical and quality requirements developed by. others are incorporated into the procurement documents which it authorizes.

o Ensuring that site-based information management programs are in compliance with FPL software QA commitments.

0 Business Systems Departments at PSL and PTN are accountable for directing the identification, design, development, implementation, on-going maintenance, and control of all nuclear site specific data processing information management systems (excluding process applications), and identifying applicable site specific software in a Computer Software Index (CSQ.

Nuclear Licensin o Maintenance of the operating license; o Interface with the NRC; o Resolution of NRC safety and regulatory issues; o Administering the Operating Experience and Feedback System.

Nuclear Materials Mana ement o Negotiation, generation, issuance of procurement documents for required items and services supporting the operation, licensing, maintenance, notification, and inspection of FPL nuclear plants, and for materials and equipment to support Nuclear Division staff;

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 30 ORGANIZATION

'03/28/97 FPL Date Pa e 7 ot 20 o Reviewing procurement documents to assure that technical and quality requirements developed by others are incorporated into the procurement documents which it authorizes.

The organization of Turkey Point Plant and St. Lucie Plant is shown in Appendix A.

The Plant General Manager - PSL and Plant General Manager - PTN, through the respective Plant Vice President, are responsible for the safe operation of the nuclear plant. The Plant General Managers have control of the onsite resources necessary for the safe operation and maintenance regardless of organizational reporting.

The Plant Nuclear Safety Committee (PNSC) at Turkey Point Plant and the Facility Review Group (FRG) at the St. Lucie Plant are comprised, of key plant management and staff personnel as described in the plant Technical Specifications.

The PNSC/FRG serves the plant manager in a technical advisory capacity for the review of all'safety-related procedures and activities that impact plant safety and the-facility operating license.

1.3.1.2 Licensing and Special Programs The Manager Licensing and Special Programs is responsible for selected licensing support activities at the Juno Beach Office. This includes:

o Advising senior Nuclear Division management on a regular basis of important developments in licensing areas which could significantly affect the Nuclear Division; o Coordinating with the Law Department for Nuclear Division licensing hearings and legal services;

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TOPICAL UALITYASSURANCE REPORT T R 1.0 Rev. 30 ORGANIZATION Date 03/28/97

@PL Pa e 8 of 20 o Administering special programs, such as:

o Plant license renewal, o Environmental issues,,

o Self assessment, o INPO coordination, o Serving as FPL liaison in matters of high level waste disposal.

1.3.1.3 Nuclear Engineering The Vice President Nuclear Engineering is responsible for nuclear plant design and engineering support.

The Nuclear Engineering organization is shown in Appendix A.

a. Nuclear Engineering Nuclear Engineering includes personnel located at both nuclear sites and at the corporate office. Nuclear Engineering performs design-related activities and delegates design-related activities to qualified contractors.

For activities performed by Nuclear Engineering, the work is governed by FPL's Quality Assurance Program, and Nuclear Engineering is responsible for approval of the design output.

'Delegated activities are performed in accordance with an FPL approved Quality Assurance Program and the contractor is responsible for approval of design output. Nuclear Engineering is responsible for defining the scope of delegated activities and the responsibilities of the contractor.

Prior to the release of design outputs by contractor organizations, Nuclear Engineering ensures that the contractor is technically qualified to perform the design-related activity.

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TOPICAL UALITYASSURANCE REPORT TQR 1.0 Rev. 30 ORG'ANIZATION 03/28/97 APL Date Pa e 9 or 20 The Manager - Turkey Point Engineering and the Manager - St. Lucie Engineering provide on-site engineering support and direct the engineering aspects of all FPL nuclear power plant projects during construction and operation to assure efficient, economical and reliable power plant design, conformance with engineering schedules and budgets and compliance with regulatory requirements.

Nuclear Engineering is responsible for:

o power plant design related aspects of the FPL Quality Assurance Program throughout all phases of plant life; o development and maintenance of the design control program governing design-related activities performed by Nuclear Engineering and for providing technical- support to the Quality Assurance Department for assessing the adequacy, implementation and effectiveness of contractor design control programs; o the preparation, revision, approval and distribution of plant design records that are.identified to be maintained as "as constructed" drawings during plant operation; o the development, control,, and performance of certain aspects of items and services procurement, including establishment of procurement standards, the technical'valuation, equivalency evaluation, and commercial grade dedication of replacement parts/components for nuclear plants; o review of the technical and quality requirements in procurement requisitioning documents and changes thereto for safety related and quality related items and services, as well as configuration, control activities for controlled design documentation associated with procurement. The review shall be performed by individuals other than the document originator;

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 30 ORGANIZATION 03/28/97 PPL Date Pa e 10 of 20 Aspects of the above activities are performed by the Juno Beach Engineering organization as determined by the Vice President Nuclear Engineering.

b. Nuclear Fuel I The Manager Nuclear Fuel is responsible for nuclear fuel engineering (

and procurement activities. including the following:

o assuring that technical and quality requirements (including inputs from other FPL departments) are incorporated in fuel contracts and letters of authorization; o administering and managing contracts for nuclear fuel and related services to assure that technical and quality obligations are met, and serving as FPL liaison in all matters of nuclear fuel and fuel-related contracts; o administering and managing spent fuel disposal contracts with Department of Energy and serving as FPL liaison in matters of nuclear fuel; o all fuel related design, analyses, reviews, and technical assistance necessary to ensure the safe, reliable, and'economic operation of the nuclear plants; o the development and/or review of fuel and nuclear physics design; o implementing and maintaining the FPL corporate nuclear material accountability program as outlined in the FPL Special Nuclear Material Control Manual; o providing support to the Quality Assurance Department for their auditing of nuclear fuel design and fuel assembly manufacturing;

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o performing audits and coordinating accountability reporting on all nuclear fuel.

c. Component Support and Inspections The Manager Component Support and Inspections is responsible for providing support to the plants as follows:

o providing technical support of activities associated. with component reliability, materials evaluations, inspections, corrosion protection, non-destructive examination, and'SME Section XI implementation/problem resolution for nuclear plant components; o providing specific component expertise, metallurgical support, and non-destructive examination and inspections; o establishing the FPL Welding Program to meet the requirements of the Quality Assurance Program and applicable codes and standards; o developing, maintaining, and controlling the procedures and instructions to implement the FPL Welding Program; and o originating and qualifying welding procedure specifications; and

d. Reliability and Risk Assessment The Supervisor of Reliability and Risk Assessment is responsible for providing support to the plants as follows:

o prepare and maintain Probabilistic Safety Assessment (PSA) for each plant; o perform Risk Assessments in support of Maintenance activities; o perform Risk Assessments in support of the NRC Maintenance Rule.

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TOPICAL QUALITYASSURANCE>> RE>>PORT T R 1.0 Rev. 30' ORGANIZATION 03/28/97 FPL Date Pa e 12 or 20 1.3.'1.4 Nuclear Assurance The Director Nuclear Assurance is responsible for the selection, technical direction, administrative control (e.g. performance appraisalsalary review, hire/fire, position assignment) staffing, training and development of personnel

.required for supervisory and operating continuity of the Quality Assurance Department, Nuclear Safety Speakout, and the CNRB Subcommittee. The Director Nuclear Assurance serves as the CNRB Chairman. The Director Nuclear Assurance also initiates QA Program policy changes when necessary.

In addition, the Director Nuclear Assurance is responsible for selecting a team independent of the Quality Assurance Department to perform periodic audits of the Quality Assurance Department. The results of these audits are presented to the Director Nuclear Assurance and the Company Nuclear Review Board (CNRB).

The Nuclear Assurance organization is shown in Appendix A.

a. Nuclear Safety Speakout The Nuclear Safety Speakout Program provides a forum for employees and contractors to communicate their concerns to FPL. Concerns are documented, investigated'nd corrective actions are taken when necessary. The program offers confidentiality.

b. Quality Assurance Department The Quality Assurance Department is responsible for administering the FPL,Quality Assurance Program. This includes developing and verifying implementation of corporate policies, plans, requirements, and procedures affecting quality. The Quality Assurance. Department retains responsibility for delegated portions of the-Quality Assurance Program

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 30 ORGANIZATION Date 03/28/97 Pa e 13 of 20 by performing initial evaluation and subsequent periodic audits of the contractors'uality Assurance Programs.. The Quality Assurance Program, responsibility further extends to the performance of audits within the Company to assure management that the established requirements and procedures are being implemented, and that the Program complies with the baseline document requirements.

The organizational freedom of the Quality Assurance function is accomplished through the corporate structure, illustrated. in Appendix A, which provides independence from. those departments responsible for design, procurement, engineering, construction and operation. With quality assurance as its sole function the Quality Assurance Department, both on-site and off-site, is completely free from the cost and scheduling pressures of design, procurement, construction and operation. The Quality Assurance Department has the freedom and authority to: a) identify quality problems; b) initiate, recommend. or provide corrective action; c) verify implementation of the corrective action; and d) recommend the stoppage of work or operations adverse to quality, when necessary. The QA Supervisor Performance Assessment, QA Supervisor Procurement Quality, Site Quality Manager -.'St. Lucie, and Site Quality Manager - Turkey Point report administratively and functionally to the Director Nuclear Assurance. These reporting relationships assure that the Quality Assurance Department has direct access to the levels of management necessary to assure effective. implementation of the Quality Assurance Program.

The duties, responsibilities, and authorities of each Quality Assurance group are described in the sections which follow.

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TOPICAL UALITYASSURANCE REPORT TQR 1.0 Rev. 30 ORGANIZATION 03/28/97 FPL Date Pa e 14 of 20

1) Performance Assessment The QA Supervisor Performance Assessment directs and administers the Corporate Quality Assurance Program assuring compliance with the'baseline documents listed in Appendix C of this Topical Quality Assurance Report. Quality Performance Assessment activities include the following:

o develop and maintain the corporate-Quality Assurance Manual, including the administration of the Quality Assurance Program Review Committee (QAPRC);

o develop and implement a Quality Assurance indoctrination program for FPL personnel; o prepare reports on Quality Assurance Program activities for review by the CNRB; o plan, coordinate and implement a comprehensive system of periodic internal audits with support from the other Quality Assurance groups, when necessary; o perform periodic activity audits of FPL procurement and associated documents and changes to these documents to assure that the necessary quality requirements are imposed; o provide NDE Level IIIservices including technical direction and monitoring of NDE activities performed by Quality Control at the plant sites (PTN and PSL).

2) Procurement Quality The QA Supervisor Procurement Quality directs and administers the Procurement Quality program in support of both nuclear plants.

Procurement Quality activities include the following:

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 30 ORGANIZATION Date 03/28/97 Pa e 15 ot 20 o perform appropriate surveillance of hardware during manufacture; o develop and implement a program for auditing of supplier Quality Assurance/Quality Control programs including Architect Engineer/Nuclear Steam Supply System Suppliers; o assist other FPL departments in the identification of quality problems associated with procurement and storage; initiate, recommend, or provide solution; and verify implementation of solutions; o maintain the Quality Assurance Department list of approved suppliers; For purchased items and services, the responsibility of this group extends through receipt of shipment or performance of contract.

3) Site Quality Assurance Turkey Point Nuclear (PTN) and St. Lucie (PSL)

Quality Assurance activities at the plant sites (PTN and PSL) are accomplished'y the respective site Quality Assurance groups, reporting to the Site Quality Manager. The Site Quality Manager has responsibility for on-site development and implementation of the Quality Assurance Program, including the following:

o coordinate the development and implementation of quality assurance policies, plans, requirements, and procedures at the plant site; o perform audits, assessments and other observations as specified in procedures and instructions to verify compliance with Quality Assurance Program commitments;

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TOPICAL UALITYASSURANCE REPORT TQR 1.0 Rev. 30 ORGANIZATION Date 03/28/97 Pa e 16 of 20 o perform periodic activity audits of site generated FPL procurement and associated documents and changes to these documents to assure that the necessary quality requirements are imposed; o recommend stoppage of work or operations adverse to quality at the plant site in accordance with the appropriate instructions; o review and comment on Quality ~Instructions or equivalent quality administrative procedures prior to issue, with respect to the requirements of the FPL Quality Assurance Program, the applicable Final Safety Analysis Report, and the applicable Technical Specifications; o perform audits of the architect engineer and Nuclear Steam Supply System suppliers both on-site,and off-site, in conjunction with the Procurement Quality group.

The interface with the Procurement Quality group ends with the receipt of a shipment of nuclear safety-related equipment at the plant site. The Quality Assurance program for the shipment is then within the purview of the Site Quality Assurance group.

I The Quality Manager - Turkey Point and Quality Manager - St. Lucie are additionally responsible for the establishment and implementation of quality control aspects of the Quality Assurance Program at the plant site. Reporting directly to the Site Quality Manager are the Quality Control Supervisors who have the authority and freedom to administer the Quality Control program and, when necessary, to stop activities adverse to quality. The Quality Control Supervisors and

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TOPICAL UALITYASSURANCE REPORT TQR 1.0 Rev. 30 ORGANIZATION Date 03/28/97 Pa e 17 or 20 personnel performing Quality Control inspection functions are required to be independent of groups or persons performing activities that they.may be required to verify or inspect.

Quality Control responsibilities include:

o inspection, monitoring, surveillance, and review of plant activities to verify compliance with the provision of the facility operating license and the'Quality Assurance Manual; o acceptance of the installed items; 1.3.1.5 Nuclear Business Services The Director Business Services is responsible for Nuclear Division business and financial planning and analysis and nuclear plant support in the areas of document control and QA records management, division-based and staff computer systems, security, emergency preparedness, and radiological services.

Nuclear Business Services is shown in Appendix A.

• Accountabilities related to division-based and staff computer systems encompass:

o directing the identification, design, development, implementation, on-going maintenance, and control of division-based information management systems; o identifying applicable division-based software in a Computer Software Index (CSI);

o Coordinating and directing computer hardware and telecommunication planning and control;

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TOPICAL UALITYASSURANCE REPORT TQR 1.0 Rev. 30 ORGANIZATION Date 03/28/97 Pa e 18 of 20 o ensuring that the information management programs are in compliance with FPL software QA commitments.

1.3.2 'Su ort De artments Providing support activities for the Nuclear Division are Corporate Records, Environmental Affairs, Protection 8c Control Systems, and:Information Management. The reporting relationship of each department is described in the following sections and is shown in Appendix A.

1.3;2.1 Corporate Records The'Supervisor Corporate Records is responsible for:

o storage, retrieval and control of Quality Assurance records received from other departments; o assisting with the development and implementation of records and micrographics programs; o maintaining a QARSET approved storage facility; o serving as the Records Official.

1.3.2.1.a The Records Official, reporting to the General Counsel and Secretary is responsible for:

ensuring the Quality Assurance records program activities are managed in accordance with applicable recordkeeping requirements; locating acceptable record storage areas when requested; io leading the evaluation of specially designated QARSET approved storage facilities, maintaining records of this evaluation, and establishing schedules to assure'that-re-evaluations are performed every two (2) years.

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TOPICAL UALITYASSURANCE REPORT TQR 1.0 Rev. 30 ORGANIZATION Date 03/28/97 Pa e 19 or 20 1.3.2.2 Environmental Services Environmental Services is responsible for obtaining the federal'nd state environmental permits required for FPL facilities and operations.

Environmental Services is also responsible for providing technical support on environmental regulatory requirements, including regulatory development, enforcement actions, compliance with environmental requirements and environmental assessments and clean-ups at all company facilities, as well as technical support and/or advice on non-radiological environmental monitoring (federal and state) programs at the nuclear power plant sites.

The Site Vice President has overall responsibility for implementation of the Environmental Protection Plans (EPPs), at nuclear power plant sites.

The Environmental Services Department through its functional areas is responsible for providing technical support and/or advice on non-radiological environmental monitoring programs and oversight of other requirements related to the Environmental Protection Plans. The Department, provides review of proposed changes to the Environmental Protection Plans, review of plant changes, tests or experiments and review of other plant activities which may be subject to environmental regulations to ensure their compliance.

The Department provides information as necessary to the CNRB Chairman on environmental matters for which requirements are included in Environmental Protection Plans.

1.3.2.3 Protection.& Control Systems The Director of Protection & Control Systems reports to the Vice President of Power Delivery.

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TOPICAL UALITYASSURANCE REPORT TQR 1.0 Rev. 30.

ORGANIZATION Date 03/28/97 Pa e 20 or 20 Protection A Control Systems is responsible for:

o test, calibration and maintenance of certain high voltage electrical

.protective relays for safety-related systems of the nuclear plant; o final wiring connection. checks; o preoperational check-out and test of system, protection devices; o providing inspection of equipment under their cognizance; o providing certain setpoint and checkpoint values for protective devices.

1.3.2.4 Information Management The Corporate Information Management organization is shown in Appendix A.

Information Management is responsible for ensuring the integrity of the operating environment and-the applications used by the Nuclear Division.

The Director of IT Operations and the Director of Business Systems report to the Vice President of Information Management.

1.3.2.4.a The Director of IT Operations is responsible for:

o the installation and-maintenance of operating system software and the operation of computer hardware for FPL's corporate computer system; o executing software, production release and change control activities.

1.3.2.4.b The Director of Business Systems is responsible for administering physical databases and providing on-going technical support.

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ATTACHMENTC TQR 1.0 Proposed Revision 31 Redline

TOPICAL QUALITYASSURANCE REPORT T R 1.0 Rev. 31 Draft A ORGANIZATION 03/28/97 FPL Date Pa e 1 or 25 1.1 GENERAL RE UIREMENTS The Florida Power & Light (FPL) organizational structure shall be defined such that the responsibilities for establishment and-implementation of the Quality Assurance Program are clearly identified. The authority and duties of individuals and organizations performing quality assurance and quality control functions shall be described, and shall illustrate the organizational independence and authority necessary to identify problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions.

In addition, the description shall illustrate that persons or groups responsible for verifying the correct performance of an activity are independent of the person or groups responsible for performing the activity.

1.2 RESPONSIBILITY The FPL Chairman of the Board and Chief Executive Officer is ultimately responsible for the execution of the Quality Assurance Program for FPL nuclear power plants. The authority for developing and verifying execution of the program is delegated to the P id* N 1* Dii'i d h D'i N I A The President Nuclear Division has overall responsibility for the Nuclear Division's activities including corporate responsibility for overall plant nuclear safety.

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TOPICAL QUALITYASSURANCE REPORT T R 1.0 Rev. 31 Draft A ORGANIZATION Date 03/28/97 Pa e 2 or 25 The Vice President - St. Lucie Plant and Vice President - Turkey Point Plant are accountable for the operation, maintenance, and modification of their respective nuclear plant. The plant Vice Presidents have overall responsibility for implementation of the Environmental Protection Plans at their respective sites.

The Plant General Manager - PSL and Plant General Manager - PTN, through the respective plant Vice President, are responsible for the safe operation of the nuclear plant.

The Director Nuclear Assurance is responsible for verifying execution of the PPL Quality Assurance Program and initiating Quality Assurance policy and program changes when necessary. The Director Nuclear Assurance is also responsible for the Nuclear. Safety Speakout program (employee concerns program) and administration of the Company Nuclear Review Board (CNRB)'ubcommittee. The Director Nuclear Assurance serves as the CNRB chairman.

The Vice President Nuclear Engineering is responsible for nuclear plant design and engineering support.

The Manager Nuclear Licensing and Special Programs is responsible for selected licensing support activities and other assigned programs at the Juno Beach Office.

The Director Nuclear Business Services is responsible for Nuclear Division business and financial planning and analysis and nuclear plant support in the areas of document control and QA records management, division-based and staff computer systems, security, emergency preparedness, and radiological services.

il TOPICAL QUALITYASSURANCE REPORT T R 10 Rev. 31 Draft A ORGANIZATION

'ate 03/28/97 Pa e 3 ot 25 The Director of Protection & Control Systems is responsible for test, calibration and maintenance of certain high voltage electrical protective relays for. safety related systems of the nuclear plant and for related support functions.

The Director E<nvironmental Services is responsible for providing technical support on environmental regulatory matters.

The Vice President of Information Management is responsible for ensuring the integrity of the computer operating environment and the applications used by the Nuclear Division.

The Corporate Records Supervisor is responsible for storage, retrieval and control of Quality Assurance records received from the nuclear plants and corporate office.

The Corporate Records Supervisor also serves as the Records Official and chairman of the Quality Assurance Records Storage Evaluation Team (QARSI<'.T).

The head of each department or organization performing activities affecting quality is responsible for: a) identifying those activities within the organization which affect quality as defined by the Quality Assurance Program; b) establishing and clearly defining the duties and responsibilities of personnel within Ms their organization who execute those activities affecting quality; and c) planning, selecting, and training personnel to meet the requirements of the Quality Assurance Program. The responsibility, authority, and organizational relationship for performing activities affecting quality within each organization shall be established and delineated in procedures, organizational charts and written job or functional descriptions.

TOPICAL UALITYASSURANCE REPORT TQR 1.0 Rev. 31 Draft A ORGANIZATION 03/28/97 FPL Date Pa e 4 or 25 Activities affecting quality may be performed by FPL or be contracted. Should any of these functions be contracted, the contractor may perform the activities under his their own Quality Assurance Program, which must have prior approval by FPL Quality Assurance, or the contractor may directly adopt the requirements of the FPL Quality Assurance Manual. If the contractor implements the Quality Control function directly to the FPL'uality Assurance Manual requirements, the contractor's Quality Control Supervisor shall have the authority and freedom to administer the Quality Control program.

1.3 ORGANIZATIONALRELATIONSHIPS The organizational charts in Appendix A show the lines of authority, responsibility and communication from the highest management level through intermediate levels to, and including-the on-site operating organizations.

The Plant General Managers have control of the on-site resources necessary for the safe operation and maintenance regardless of organizational reporting.

The organizational freedom of the Quality Assurance function is accomplished through the corporate structure, illustrated in Appendix A, which provides independence from those departments responsible for design, procurement, engineering, construction and operation. With quality assurance as its sole function, the Quality Assurance Department, both on-site and off-site, is completely free from the cost and scheduling pressures of design, procurement, construction and operation. The Quality Assurance Department has the freedom and authority to: a) identify quality problems b) initiate, recommend or provide corrective action; c) verify implementation of the corrective action; and d) recommend the stoppage of work or operations adverse to quality, when necessary. The QA Supervisor Performance Assessment, QA Supervisor Procurement Quality, Ate

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TOPICAL QUALITYASSURANCE REPORT TQR 1.0 Rev. 31 Draft A ORGANIZATION Date 03/28/97

@PL Pa e 5 of 25 Quality Manager - St. Lucie, and Re Quality Manager - Turkey Point report administratively and functionally to the Director Nuclear Assurance. These reporting relationships assure that the Quality Assurance Department has direct access to the levels of management necessary to assure effective implementation of the Quality Assurance Program.

1.4 REVIEW AND AUDIT COMMITIKES The Plant Nuclear Safety Committee (PNSC) at Turkey Point Plant and the Facility Review Group (FRG) at the St. Lucie Plant are comprised of key plant management and staff personnel as described in the plant Technical Specifications. The PNSC/FRG serves the Plant General Manager in a technical advisory capacity for the review of all safety related procedures and activities that impact plant safety and the facility operating license.

The Company Nuclear Review Board (CNRB), reporting to the President Nuclear Division, is comprised of executive level members of management with responsibilities for the execution of the Quality Assurance Program. The CNRB composition is described in Section 6.0 of each facility s Technical Specifications.

Subjects within the purview of the CNRB are listed in the appropriate plant Technical Specifications. The CNRB has the authority to carry out its responsibilities by way of written action letters, verbal directions, meeting minutes or appointed subcommittees. Where necessary, the 'CNRB may use consulting services to perform required reviews. Periodic audits of the Quality Assurance Department are performed by a team independent of the Quality Assurance Department. The results of these audits are presented to the CNRB.

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TOPICAL UALITYASSURANCE REPORT TQR'.0 Rev. 31 Draft A ORGANIZATION 03/28/97 FPL Date

'a e 6 or 25 Q li A' i C i* (QAP C)h b established to review changes to the Quality Assurance Program and to provide an interface for quality matters in each department affecting quality. The QAPRC is an interdepartmental organization with the responsibility to review and resolve recommended changes to the Quality Assurance Program. This committee is administered by the Quality Assurance Performance Assessment group.

A Quality Assurance Program Review Committee (QAPRC) Member shall be designated by the head of each department or organization. The QAPRC Member is the prime interface for coordination of quality matters within the member's department, with the Quality Assurance Department, and with other departments.

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ATTACHMENTD TQAR Appendix A (For Reference Only)

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CHNRUAN Of THC SOARD CNKF EXECUTIVE O FUCKA PRKSENNT CENKRILCCV NSKL PRKUDKNT FLDROA POWER AND IS)CLEAR NVNNN A UCNT SKCRCTARY COUPANY NVCLEAR REVIEW SCARC tKC FERRIC 11 VICE PRKSNKNT Of'ACC 2 Of 2 INFORUAllON UANACEINNT DRKCTOR VICE PRESDKNT NVCLEAR NltllESS TINNCYPOSIT PIANT SKIMCKS SEC FICVRC 11 OFPACKSOf 2 StKCIRC SNC ORSAISZAllON SPKOFK'ITE IN FSL 1 4 ORCAISZATION CA SUPERVISOR VICE PR KSNCNT IN IUL 14 PERFONNANCE POWER DmVKRY ASSKSSU OIT IIANACKR UANACER tASttORT SERVICES INCLEAR UCENSSNI AND SPECTRAL UANACKR PROCRAUS COUtONENT SVPPORT SKC RCVRC S SIC PECTNN OVAUlYASSVRACC 1.1

~ ROCRAII RKIRKW OFPACECOF2 COUUITTKC SV PKRVNOR COSINESS PIANNPKI IIANACER tE LVCN OANIPKRVItOR 4 PCRIOIUIANCC PROCISIKUKNT CVAUTY ENOSIS EIYNC NANICKR NVCLEAR fVKL SUPERVISOR REUINUIYAND ISSE ASSKttUKNT IIANACKR

~ SL SCRt ENCUIEERVNI OVAUTYNANACUI ST. WCIC DNCSNDIC CHEF KNCSIEKRS TOPICAL QUAUTYASSURANCE REPORT ORGANIZATIONOF DEPARTMENTS AFFECTING QUAUTY FIGURE 1-1 APPENDIXA PAGE1OF2 NUCLEAR DIVISION

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CHAIRIIANOF THE BOARD CISEF EXECUTIVE OFFICER PRESIENT FLORIDA POWER

& UGHT IXRECTOR ENVIRONNENTAL SERVICES llANAGER IXRECTOR BUSINESS SVSTDIS CORPORATE RECORDS SUPERVISOR DIRECTOR VT OPERATIONS DSIECTOR PROTECIION &

CONTROL SVSTENS IXRECTOR PLANMNO &

CONTROL OPICAL QUALITYASSURANCE REPORT ORGANIZATIONOF DEPARTMENTS AFFECTING QUALITY 04/16/97 FIGURE 1-1 APPENDIX A NUCLEAR DIVISION PAGE20F2

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41

VICE PRESIDENT TURKEYPOINT PLANT'LANT

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MANAGER'ERVICES GENERAL MANAGER'ESOURCES MANAGER MANAGER'USNESS UCENSNG SYSTEMS MANAGER PTN ENGINEERING MANAGER'rEOHIIcAL sUppoRn SUPERVISOR'RAIMNG MANAGER'ECURI1Y OPERATORS ENGNEERNG

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~'REACTOR ENGNEERNG)'TAs)'AND FIRE SAFETY SUPERVISOR UTIUZATION SITE SUPERINTENDENT WORK CONTROL MANAGER MANAGER'AINTENANCE OPERATIONS MANAGER

'ac SUPERVISOR'YSTEMS MAINTENANCE ENGINEERING MANAGER MAINTENANCE HEALTH H ss PHYSCSCBDSSTRY SUPERVISOR'ECHAMCAL NUCLEAR PIANT SUPERVISOR SUPERVISOR'HEMISTRY PHYSICS SUPERVISOR TECHNICAL SUPERVISOR ELECTRICAL MAINTENANCE SUPERVISOR

'Indicates position with accountabilities in Technical Specifications.

TOPICAL QUAUTYASSURANCE REPORT

~ Although Operations Support Engineering (OSE) personnel may report to the REVISION12 site Engineering Manager, the Plant General Manager shall have direct and unfettered control over those activities necessary for safe operation and TURKEY POINT PLANT maintenance of the plant. SITE ORGANIZATION PIGURE 1-2

~ The Health Physics Supervisor shall have direct access to the Plant General APPENDIX A Manager for matters relating to the radiological health and safety of employees PAGE 1 OF 1 and the public.

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VICE PRES DENT ST. LUCE PLANT

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PSL ENGINEERIMG MANAGER'ERVICES PLANT GENERAL MANAGER' CENSING MANAGER'TEAM GENERATOR REPLACEMENT MANAGER BUSNESS SYSTEMS MANAGER MANAGER'NFORMATION SUPPORT ENOMEERNG

~'REACTOR SERVICES SUPERVISOR ENGTIEERNG('STAs)'ROTECTION PLANT ENGINEERNG MANAGER SERVICES SECURITY SUPERVISOR SUPERVISOR UWD (mUZATIOM SUPERVISOR OPERATIONS MANAGER'EALTH

'UPERVISOR'UPERVISOR'ac PHYSICS SUPERVISOR OPERATIONS CHEMISTRY MAINTENANCE SUPERVISOR'LECTRICAL MAINTENANCE SUPERVISOR'AINTENANCE PROCEDURES SUPERVISOR ROTATING EOVIPMEMT SUPERVISOR'MECHAM GAL)

VALVES 8 WE(DING SUPERVISOR'ECHAMCAL TOPICAL QUALITYASSURANCE REPORT REVISION 9 Indicates position with accountabilities in Technical Specifications.

ST. LUCIE PLANT, UNIT 1 & 2 SITE ORGANIZATION 5QIE FlGURE 14 Although Operations Support Engineering (OSE) personnel may report to the Site Engineering Manager, APPENDIX A PAGE 1 OF 1 the Plant General Manager shall have direct and unfettered control over those OSE resources necessary for safe operation and maintenance of the plant.

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ATTACHMENT1 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 INSERVICE. INSPECTION PROGRAM - RELIEF REQUEST NO. RR-4

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Code Class Code Reference IWB-2500 Table IWB-2500-1'xamination Category 8'-D Item Number 83.130 Component Description Steam Generator. Nozzle to Head Welds, 1-104-251, 1-102-251A, 1-102-2518, 2-104-351, 2-'102-351A, 2-102-3518 Reference Drawings RSG90-C251-001 and RSG90-C251-003 Figure IWB-2500-7(a) t Section XI, Table IWB-2500-'1- requires all steam generator nozzle to volumetrically examined. once during-each inspection interval.

head welds to be 100%

A relief request from the code required examination volumes is necessary as the code required volumes, cannot be achieved due to the physical geometries of the nozzles within the steam generator vessel heads.

For purposes of discussion, Figure IWB-2500-7(a) (attached)-will be used to describe the 4 required weld volumes. With:the exception of the nozzle inner radius~section, this figure is the closest configuration to our actual nozzles.

Consumers Energy working with EPRI have developed'the attached report. The,EPRI report identifies the code required examination volumes, exam volumes within the areas of limitations, exam volumes where no limitations exist and the composite exam volumes which

,. can be examined. The EPRI report was also compared to past field examinations to verify

,these examination limitations.

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The attached package includes:

1) Figure defining exam volumes.

2) Inlet nozzle inner radius coverage table followed by supporting figure.

3) Inlet nozzle-to-head weld exam volume.

4) Axial scan coverage table for inlet nozzle-to-head weld followed by supporting figures.

5) Transverse scan (no probe skewing) coverage table for inlet nozzle-to-head weld followed by supporting figures.

6) Transverse scan (+/-20'robe skewing) coverage table for inlet nozzle-to-head weld followed by supporting figures.

7) Outlet nozzle inner radius coverage table followed by supporting figure.

8) Outlet nozzle-to-head weld. exam volume.

9) Axial scan coverage table for outlet nozzle-to-head weld followed by supporting figures.

10) Transverse scan (no probe skewing) coverage table for outlet nozzle-to-head weld followed by supporting figures.

11) Transverse scan (+/-20'robe skewing) coverage table for outlet nozzle-to-head weld followed by supporting figures.

There are 2 acronyms used in the EPRI report for identification, they are Consumers Power-Steam Generator Project Inlet Nozzle (CP-SGPIN) and Consumers Power - Steam Generator Project Outlet Nozzles (CP-SGPON).

The computer based modeling was performed on one steam generator and this is intended to address all primary head nozzle welds in both steam generators. The steam generators are identical in design..

The probe. skew. angle for the axial exams are identified as 0'nd 180'ithin the coverage tables. The probe skew angle for the transverse exams were modeled using a 90'nd then offset using a 70'and 110'kew to increase exam volume coverages.

In summary, the examination volumes are limited and the maximum achievable volumes. within the areas of limitations are accurately identified.

The accessible weld volumes, as identified in the EPRI report, will be. examined once per interval in lieu of the ASME'Section XI 100% volumetric examination requirements.

0 REQUIREMENTS FOR CLASS I COMPONENTS F(g. IWB-2500-7(a) 0 I rn 1

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Corner flaw EXAMINATIONREGION, (Note (1)) EXAMINATION'VOLUME INote (2)l Shell, {or head) adjoining region C.O.E F Attachment weld region 'B.C F.G Nozzle cylinder region A.B.G H I

'Nozzle inside corner region

'MNOP'OTES:

, (1) Examination regions are identified for the purpose of differentiating the acceptance standards in IWB'3512,

,(2) Examination volumes may be determined either by direct measurements on the component or by measurements based on design drawings.

FIG. IWB-2500-7(a) NOZZLE IN SHELL OR HEAD (Exanlination Zones in Barrel Type Nozzles Joined by Full Penetration Corner.Welds)

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EPRI NDE CENTER Electric Power Research Institute Nondestructive Evatuation Center Leadership in Technology Transfer September 16, 1996 Tom Fouty Consumers Power Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 SUB JECT: Summary Report on Coverage Calculations

Dear Tom,

The attached summary report describes the coverage calculations performed by the EPRI NDE Center on the Palisades steam generator inlet and outlet nozzles. The:type of coverage documented for these nozzles was restricted to calculating where the ultrasound beam interrogated the. examination volume.

Ifyou have any comments please call me at (704) 547-6130.

Sincerely, Douglas E. MacDonald Principal Engineer EPRI NDE Center DM/ks Enc.

cc: Kim Kietzman Judy Ford/CP Larry Becker Frank Ammirato 1300 Hams Boulevard ~ Charlotte. No~:" 4'4 26252 ~ Tetephone: t704) 547 6)00 tP.O. BOx 2)7097. Chartctte. NOrtn Ca~p "4 '922ti ~ FAX:(704) 547 6)66

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Palisades Steam Generator Inlet and Outlet Nozzle Coverage Calculations Douglas E. MacDonald September 5, 1996 Introduction This report summarizes EPRI NDE Center activities to calculate the coverage obtained on the Palisades steam generator inlet and outlet nozzles using the Consumers Power Company procedure No. NDT-UT-12, Revision 4, Issued 11/21/95. The type of coverage documented for these nozzles was restricted to calculating where the ultrasound beam interrogated the ASME code examination volume.

Figure 1 defines the ASME code examination volumes, both nozzle inner radius ( M-N-0-P) and nozzle-to-head weld (A-B-C-D-E-F-G-H-I) for the Palisades steam generator inlet and outlet nozzles.

Palisades Steam Generator Inlet 1Vozzle Nozzle Inside Corner Region Table 1 shows the coverage calculated for a 35'robe, skewed and scanned on the outer blend radius. (The probe skew 90'35'/90')

convention adopted here has 0'ooking at the pipe, 90'ooking circumferentially around the nozzle, and 180'ooking at the vessel).

Figure 2 shows a cross section of the Palisades steam generator inlet nozzle upon which has been plotted the rays from the 35'/90'robe to the inside surface examination volume. As can be seen in Figure 2, the entire exam volume is covered by the 35'/90'robe scanned on the outer blend radius.

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Corner flaw EXAMINATION'REGION(Note (1)) EXAMINATION VOLUME )Note (2)I'.D.E F.

Shell (or head) adjoining, region Attachment weld region B C.F.G Nozzle cylinder. region AB.G HI Nozzle inside corner region M N.O P NOTES:

(1) Examination regions are identified for the purpose of differentiating the acceptance standards in IWB 3512.

(2)'Examination volumes may,be determined. either by direct measurements on the-component or by measurements based on design drawings.

e NOZZLE IN SHELL OR HEAD (Examination Zones in Barrel Type Nozzles Joined by Foll Penetration Corner We(ds)

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0 Table 1. Coverage Table: SG Inlet; 35'/90'blend)

Probe Angle Probe Skew 35'0'lend*

Probe Location Percentage of Examination Volume (M-N-0-P) Covered 100%

• Contoured Wed e P.ollsades S G Inlet Nozzle: 3590 (blend) Coyeqage 82 I 38/90 (blend) 78

<I 73 72 71 M

Qass I Inner Radius Exam Volume M-N~

20 21 22 23 24 25 0 27 28 29 '30 31 32 R Onches)

Figure 2. Palisades SG Inlet ~ozzie: 35'/90'blend) Coverage.

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Figure 2 shows a cross section of the Palisades steam generator inlet nozzle upon which has been plotted the rays from the 35'/90'robe to the inside surface examination volume. As can be seen in Figure 2, the entire exam .

volume is covered by the 35'/90'robe scanned on the outer blend radius.

Palisades S G ln!et Nozzle: 3550 (blend) Coverage 82 I

81 35/90 (blend}

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78 77 76 ,

Cu 75 C I N 7g 73

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'I Cass I inner Radius Exam Volume MA4 I

20 21 22 23 24 25 26 27 28 29 30 31 32 R (inches)

Figure 2. Palisades SG Inlet Yiozzle: 35'/90'blend) Coverage.

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Nozzle-to-Head Weld Region Figure 3 shows a cross section of the Palisades steam generator inlet nozzle which indicates the nozzle-to-head weld examination volume. Table 2 lists the coverage obtained from the axial scans of 45'nd 60'robes scanned on the vessel head and nozzle boss. The percent coverage is listed for the the nozzle cylinder region A-B-G-H-I; as well as, the entire weld examination volume A-B-C-D-E-F-G-H-I (See Figures 1 and 3).

Table 2. Coverage Table: SG Inlet; 45'and 60'robes scanned axially on vessel head and nozzle boss.

Probe Angle Probe Skew 45'5'0 0'8080'ead 60.

Probe Location Boss Head Boss

% Exam Vol. (C-D-E-F) Covered 100% 0% 93% 0%

% Exam Vol. (B-C-F-G) Covered 87% 0% 90% 0%

% Exam Vol. (A-B-G-H-I) Covered 53% 0% '3% 12%

Percent Total Weld Exam Volume (A-B-C-D-E-F-G-H-I) Covered 79% 0% 81% 5%

Figures 4 through 7 support. the calculated- axial scan coverage listed in Table 2. Figure 4 shows a cross section of the Palisades steam generator inlet nozzle upon which has been plotted the rays of the axial scan of the 45'/0'(head scan) probe through the weld examination volume. Figure 5 shows the cross section with the rays of the axial scan of the 45'/180'(boss scan) probe. Figure 6 shows the cross section with the rays of the axial scan of the 60'/0'robe through the weld. examination volume., Figure 7 shows the cross section with the rays of the axial scan of the 60'/180'robe.

Figure 8 shows the combined coverage achieved by all the axial. scans of the nozzle-to-head weld.'able 3 lists the coverage obtained from the transverse scans (no probe skewing) of 45'nd 60'robes scanned on the vessel head and nozzle boss.

Figures 9 through 12, support the calculated transverse scan coverage listed in Table 3.

li Examination Volume (CP-SGPIN) 85 82 81 A

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21 22 23 24 25 26 27 28 29 30 3t 32 33 5 36 37 38 39 40 4) 42 43 44 45 46 47 48

II Coverage For Probe Angle=45 Deg; Probe Skew=0 Deg (CP-SGPIN) 85 83 82 81 80 78 77 76 75 73 z

72 71 70 69 68 63 61

- 60 44 45 46 47 48

0 Coverage For Probe Angle=45 Deg; Probe Skew=)80 Deg (CP-SGPIN) 84 83 82 79 78 77 76 75 73 Z

72 I l 71 70 69 68 66 65 64 63 6t 60 23 24 25 26 27 28 29 30 31 32 33 "'5 36 37 38 39 40 41 42 43 44 45 46 47 48 0

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V Coverage For Probe Ang1e=60 Deg; Probe Skew=0 Deg (CP-SGPlN) 85 83 82 Bf 80 79 78 77 76 75 74 73 Z

72 71 70 69 68 67 66 65 64 61

.60 - I--I I I I I I -I I I I I I I I I

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"'5 I I I I I I I 23 24 25 26 27 28 29 30 31 32 33 36 37 38 39 40 41 42 43 44 45 46 47 48 O

Ii Coverage For Probe Angle=60 Deg; Probe Skew=180 Deg (CP-SGPlN) 85 83 82 81 80 79 78 77 76 75 I 74 I ~

73 l Z I 72 71 70 69 68 67 66 65 64 63 62

}I=IWI 61

- 60 I -I - I--I--I I I ] I I I I I I I I I I I I I I 22 23 24 25 26 27 28 29 30 31 32 33 35 36 37 38 39 40 41 42 43 44 45 46 47 48 0

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Combined Coverage (CP-SGPIN) 85 83 82 81 80 79 78 77 76 75 73 Z

72 71

. 70 69 68 67 66 63 62

-60 -=I. I -I-I -I. I I I I I I I I I I I I I I I I I I I I. I I 20 21 22 23 24 25 26 27 28 29 30 31 32 33 35 36 37 38 39 40 41 42 43 44 45 46 47 48

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on vessel head and nozzle boss (no probe skewing).

Probe Angle Probe Skew 45'5'0'00 90'0'0'0'ead Probe Location Boss Head Boss

% Exam Vol. (C-D-E-F) Covered 100% 0% 92% 0%

% Exam Vol.. (B-C-F-G) Covered 58% 0% 0% 0%

% Exam Vol. (A-B-G-H-I) Covered 0% 0% 0% 0%

Percent Total Weld Exam Volume (A-B-C-D-E-F-G-H-1) Covered 54% 0% 42% 0%

Figure 9 shows a cross section of the Palisades steam generator inlet nozzle upon which has been plotted the rays of the transverse scan of the 45'robe from the head through the weld examination volume with no probe skewing.

Figure 10 shows the cross section with the rays of the transverse scan of the 45'robe from the boss. Figure 11 shows the cross section with the rays of the transverse scan of the 60'probe from the head through the weld examination volume. Figure 12 shows the cross section with the rays of the transverse scan of the 60'robe from the boss. Figure 13 shows the combined coverage achieved by all the transverse scans of the nozzle-to-head weld with no probe skewing.

Table 4 lists the coverage obtained from the transverse scans (+/-20'robe skewing) of 45'nd 60'robes scanned on the vessel head and nozzle boss.

Figures 14 through 17 support the calculated transverse scan coverage listed in Table 4. Figure 14 shows a cross section of the Palisades steam generator

-inlet nozzle upon which has been plotted the rays of the transverse scan of the 45'robe from the head through the weld examination volume with

+/-20'robe skewing. Figure 15 shows the cross section with the rays of the transverse scan of the 45'robe from the boss. Figure 16 shows the cross section with the rays of the transverse scan of the 60'robe from the head through the weld examination volume. Figure 17 shows the. cross section with the rays of the transverse scan of the 60'robe from the boss.

Figure 18 shows the combined coverage achieved by all the transverse scans of the nozzle-to-head weld with+/-20'robe skewing.

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Coverage For Probe Angle=45 Deg; Probe Skew=90 Deg (CP-SGPIN) 85 83'2 Bf 80 79 78 77

~ ~

75 1

~ ~

73 Z

72 70 68 67 65 G4

0 0

4l

Coverage For Probe Angle=45 Deg; Probe Skew=90 Deg (CP-SGPIN}

83 82 81 80 79 77 I

I s a 73 Z

72 a 71 I ~

70 ~ I 69 68 67 66 63 62 61

. 60

0 Cl Cl

Coversge For Probe Angle=60 Deg; Probe Skew=90 Deg (CP-SGPlN) 85 81 r

80 /

79 78 77 75 73 ~ I Z

72 71 I I 70 1 68 67 65 60 2526272829303) 3233" 3536373839 4041 424344 4546 47 48

0 0

Coverage For Probe Angle=60 Deg; Probe Skew=90 Deg (CP-SGPIN) 85 84 82 8f 80 79 78 77 76 l I 73 I I z

72 I 1 70 I I 67 66 65 64 63 62 6l 60 . -I -I.-.I -I I I I I I I I I I I I I I I I IW I I I I I I 0 2) 22 23 24 25 26 27 28 29 30 3$ 32 33 i 3 366 37 38 3 39 40 4$ 42 43 nn 45 n6 47 48

0 Combined Coverage (CP-SGPIN) 82 81 80 79 78 77 76 75.

73 Z

72 71 70 69 65 63 62 61

--I- -I==-I- I=I 60 I 20 21 .22 23'4 I I I I I I I 25 26 27 28 29 30 31 I

32 33 '5 I I I I I I I 36 37 38 39 40 41 I

'2 I I I I I I 43 44 45 46 47 48

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Table 4. Coverage Table: SG Inlet; 45'and 60'robes scanned transversely on vessel head and nozzle boss (+/-20'.probe skewing).

Probe Angle Probe Skew 45'5'0'0'0'10'0'10'ead Probe Location Boss Head Boss

% Exam Vol. (C-D-E-F) Covered 100% 0% 100% 0%

% Ex'am Vol. (B-C-F-G) Covered 78% 0% 76% 0%

% Exam Vol. (A-B-G-H-l) Covered 19% 0% 16% 0%

Percent Total Weld Exam Volume (A-B-C-D-E-F-G-H-I) Covered 64% 0% 63% 0%

Palisades Steam Generator Outlet Nozzle Nozzle Inside Corner Region Table 5 shows the coverage calculated'or a 35'robe, skewed 90'35/90)

(looking circumferentially) and scanned on the outer blend radius.

Table 5. Coverage Table: SG Outlet; 35'/90'blend)

Probe Angle Probe Skew 35'0'lend*,

Probe Location Percentage of Examination Volume (M-N-0-P) Covered 100%

• Contoured Wedge Figure 19 shows a cross section of the Palisades steam generator outlet nozzle upon which has been plotted the rays from the 35'/90'robe to the inside surface examination volume. As can be seen in Figure 19, the entire exam volume is covered by the 35'/90'robe scanned on the outer blend radius.

0 Coverage For Probe Angle=45 Deg; Probe Skew=70 Deg (CP-SGPIN)

~

.83 82 81 80 79 78 77 76 75 74 73 ~ I Z

72 71 ~ I 70 ~ l 67 65 ..

64 63 62 l l~l 6f t

60 I l I I l I l I I I I I I I I I I l l I I 20 2f 22 23 24 25 26 27 28 29 30 31 32 33 "'5 36 37 38 39 40 4$ 42 43 44 45 46 47 4B

0 Coverage For Probe Angle=46 Deg; Probe Skew=)40 Deg (CP-SGPlN) 85 84 83 82 81 80 79 78 77 76

~ ~

.75 74 ~ I 73 ~ I Z I 72 I 71 I I 70 ~ I 68 67 66 65 64 60 -

I I- I---I- I I I I I I=I I=I I I I I I I I -I I I I I- I I I 29 30 31 32 33 "'5 36 37 38 39 40 41 42 43 44 45 46 47 48

0 0

Coverage For Probe Angle=60 Deg; Probe Skew=70 Deg (CP-SGPIN) 83 81 80 79

~ ~

75 74 73 I l Z

72 71 70 ~ I 65 '-

63 62

~

60

0 Coverage For Probe Angle=60 Deg; Probe Skew=)10 Deg (CP-SGPIN) 85 8t 80 79 77 76 75 l

~ I 73 I z I 72 71 l I 70 l 69 68 67 6) 60

0 0

Combined Coverage (CP-SGP1N) 84 83 82 81 80 79 78 77 76 75 73 ~ l Z

72 71 70 68 67 66 65 62 6f t I-I I&

I I. I--I-l- I I I I I I I I I I I I I I 20 2I 22 23 24 25 26 27 28 29 30 3$ 32 33 35 36 37 38 39 40 41 42 43 44 45 46 47 48

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p allsades 5 G Outlet Nozzle: 35/90 (blend) Coverge 84' l

83 I 35)90 (blend) 81 79 76 75 74 73 Ctaste I trier R adus I xan Votun>> M4<+

71 14 15 '16 17 18'9 20 21 22 23 24 R (Inches)

Figure 19. Palisades SG Outlet Nozzle: 35'/90'blend) Coverage.

Nozzle-to-Head Weld Regioa Figure 20 shows a cross section of the Palisades steam generator outlet nozzle which indicates the nozzle-to-head weld examination volume.

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Examlnation Yolume (CP-SGPON) 84 83 r A 82 81 80 79 70 I g D

I 77 I g 76 ~ g 75 I 74 l I I 73 H ~ ~

72 71 70 69 68 67 66 65 I I I I I I

' I l I I I 15 16 17 18 19 20 21 22 24 25 26 27 28 29 30 31 32

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Table 6 lists the coverage obtained from the axial scans of 45'nd scanned on the vessel head and nozzle boss. The percent coverage 60'robes is listed for the head adjoining region C-D-E-F, the attachment weld region B-C-F-G, and the nozzle cylinder region A-B-G-H-I; as well as, the entire weld examination volume A-B-C-D-E-F-G-H-I (See Figures 1 and 20).

Table 6. Coverage Table: SG Outlet; 45'and'60'robes scanned axially on vessel head and nozzle boss.

Probe Angle 45o 45o 60o 60o Probe Skew 0'8080'ead Probe Location Boss Head Boss

% Exam Vol. (C-D-E-F) Covered 100% 0% 100% 0%

% Exam Vol. (B-C-F-G) Covered 87% 0% 91% 0%

% Exam Vol. (A-B-G-H-I) Covered 48% 0% 60% '10%

Percent Total Weld Exam Volume (A-B-C-D-E-F-G-H-I) Covered 74% 0% 80% 5%

Figures 21 through 24 support the calculated axial scan coverage listed in Table 6. Figure 21 shows a cross section of the Palisades steam generator outlet nozzle upon which has been plotted the rays of the axial scan of the 45'/0'(head scan) probe through the weld examination volume. Figure 22 shows the cross section with the rays of the axial scan of the 45'/180'(boss scan) probe. Figure 23 shows the cross section with the rays of the axial scan of the 60'/0'robe through the weld examination volume. Figure 24 shows the cross section with the rays of the axial scan of the 60'/180'robe.

Figure 25 shows the combined coverage achieved by all the axial scans of the nozzle-to-head weld.

Table 7 lists the coverage obtained from the transverse scans (no probe skewing) of 45'nd 60'robes scanned on the vessel head and nozzle boss.

Figures 26 through 29 support the calculated transverse scan coverage listed in Table 7. Figure 26 shows a cross section of the Palisades steam generator outlet nozzle upon which has been plotted the rays of the transverse scan of the 45'robe from the head through the weld examination volume with no probe skewing. Figure 27 shows the cross section with the rays of the transverse scan of the 45'robe from the boss. Figure 28'shows the cross

0 Coverage For Probe Angle=45 Deg; Probe Skew=0 Deg (CP-SGPON) 84 83 82 81 80 79

'I I

77 76 75 73 Z

72 71 70 69 68 67 65'4 63 62 60 I H

I I I I I I I

I I I I I I I I IHH I I I I I I I 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 ." '2 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48

0 II 0

Coverage For Probe Angle=45 Deg; Probe Skew=180 Deg (CP-SGPON) 82 81 80 79 78 ~ I I

76 I

~

I I

~ ~

73 z

72 71 70 69 67 62 61 60 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 ~ 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 0

~

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Coverage For Probe Angle=60 Oeg; Probe Skew=0 Deg (CP-SGPON) 85 83 82 79 78 77 76 I I

75 73 Z

72 71 70 69 68 67 64 63 62 60

0 il

Coverage For Probe Angle=60 Deg; Probe Skew=180 Deg (CP-SGPON) 85 83 82 81 80 78 77 I 76 I

~

75 1 I I I 73 Z

72 71 70 68 67 66 64 63 62 60 14 15 16 $ 7 $ 8 19 20 2) 22 23 24 25 26 27 28 29 9 i 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 4

Cl II 0

Combined Coverage (CP-SGPON) 85 sn 83 82 81 80 79 78 77 75 73

'2 Z

71 70 69 68 67 62 60 141516171819202122232425262728298 < 323334353637383940414243444546474

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Table 7. Coverage Table: SG Outlet; 45'and 60'robes scanned transversely on vessel head and nozzle boss (no probe skewing).

, Probe Angle Probe Skew 45'5'0'0'0'0'0'0'ead

.Probe Location Boss Head Boss

% Exam Vol. (C-D-E-F) Covered 100% 0% 60% 0%

% Exam Vol. (B-C-F-G) Covered 14% 0% 0% 0%

% Exam Vol. (A-B-G-H-I) Covered 0% 0% 0%

Percent Total Weld Exam Volume 0%'9%

(A-B-C-D-E-F-G-H-Q Covered 0% 22% 0%

section with the rays of the transverse scan of the 60'robe from the head through the weld examination volume. Figure 29 shows the cross section with the rays of the transverse scan of the 60'robe from the boss. Figure 30 shows the combined coverage achieved by all the transverse scans of the nozzle-to-head weld with no probe skewing.

Table 8 lists'the.coverage obtained from the transverse scans (+/-20'robe skewing) of 45'nd 60'robes scanned on the vessel head and nozzle boss.

Figures 31 through 34 support the calculated transverse scan coverage listed in Table 8. Figure 31 shows a cross section of the Palisades steam generator outlet nozzle. upon. which has been plotted the rays of the transverse scan of the 45'robe from the head through the weld-examination volume with

+/-20'robe skewing. Figure 32 shows the cross section with the rays of the transverse scan of the 45'robe from the boss. Figure 33 shows the cross section with the rays of the transverse scan of the 60'robe from the head through the weld examination volume. Figure 34 shows the cross section with the rays of the transverse scan. of the 60'robe from the boss.

Figure 35 shows the combined coverage achieved by all the transverse scans of the nozzle-to-head weld with+/-20'robe skewing.

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Coverage For Probe Angle=45 Oeg; Probe Skew=90 Oeg (CP-S GPON) 85 84 83 82 81 80 79 78 77 76 Z75 74 73 72 71 70 69 68 67 66 65 14 15 16 17 18 19 20 21 2 24 25 26 27 28 29 30 31 32

0 Cl

Coverage For Probe Angle=45 Deg; probe Skew='90 Deg (CP-SGPON) 85 83 82 81 80 79 78 I 1

77 76 I

~ 1 275 t I 74

~ ~

73 I 72 71 70 69 68 67 66 65 14 15 16 17 18 19 20 21 22 24 25 26 27 28 29 30 31 32

Ci 0

Coverage For Probe Angle=60 Deg; Probe Skew=90 Deg (CP-SGPON) 85 84 81 80 79 78 ~ i 77 I ~

~ ~

76 I

Z75 I

74 "~

73 T2 71 TO 69 68 6?

66 65 l l I I I 14 15 16 17 18 19 20 21 22 24 25 26 27 28 29 30 31 32

0 0

0

Coverage For Probe AngIe=60 Deg; Probe Skew=90 Deg (CP-SGPON) 85 84 83 82 81 80 79 78 I I

~ g Z75 I I 74 I I 73 l I 72 71 70 69 68 67 66 65 14 15 16 17 18 19 2Q 21 22 " 24 25 .26 27 28 29 3Q 31 32

0 4l Cb

Combined Coverage (CP-SGPON) 85 84 82 81 80 79 78 77 76 Z75--

74 73 72 71 70 69 68 67 66 I I I

15 16 17 18 19 20 21 22 24 25 26 27 28 29 30 31 32

0 0

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Table 8. Coverage Table: SG Outlet; 45'and 60'robes scanned transversely on vessel head and nozzle boss (+/-20'robe skewing).

Probe Angle Probe Skew 45'5'0'0'P'10'0'10'ead Probe Location Boss Head, Boss

% Exam Vol. (C-D-E-F) Covered 100% 0% 100% 0%

% Exam Vol. (B-C-F-G) Covered 80% 0% 59% 0%

% Exam Vol. (A-B-G-H-I) Covered 8% 0% 0% 0%

Percent Total Weld Exam Volume (A-8-C-D-E-F-G-H-I) Covered 54% 0% 47% 0%

Summary The 35'ontoured probe gives 100% coverage for the inner radius regions of both the SG inlet and outlet nozzles (See Tables 1 and 5). Table 9 summarizes the coverage of the nozzle-to-head weld for the SG inlet nozzle (See Tables 2 and 4).

Table 9; Summary'Coverage Table: SG Inlet Nozzle-to-Head Weld.

Probe Angles 45' 6Q'O 45'& 45' 45'&

Probe Skew 60'80'oss 6Q'0'ead 6Q'10'oss Probe Location Head Percent Coverage 79% 0% 63%. -0%

Table 10 summarizes the coverage of the nozzle-to-head weld for the SG outlet nozzle (See Tables 6 and 8).

Table 10. Summary Coverage Table: SG Outlet Nozzle-to-Head Weld.

Probe Angles 45' 60'5'& 60'o 45' 60'Po 45'&

Probe Skew 6Q'10'oss 180'ead Probe Location Boss Head Percent Coverage 74% 0% 47% 0%

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Coverage For Probe Angle=45 Oeg; Probe Skevr=70 Deg (CP-SGPON) 85 83 82 80 79 77 76 Z75 74 73 72 71 70 69 67 66 65 14 15 16 17 18 19 20 21 22

" 24 25 26 27 28 "29 30 31 32

0 Coverage For Probe Angle=45 Deg; Probe Skevlt=110 Deg (CP-SGPON) 84 83 82 81 80 79 78 ~ I 77 ~ I 76 I

Z75 74 I

73 I I 72 71

?0 69 68 67 66 65 14 15 16 17, 18 19 20 21 22 24 25 26 27 28 29 30 31 32

0 Ck

Coverage For Probe Angle=60 Oeg; Probe Skew=70 Deg (CP-SGPON) 85 84 82 81 80 78

~ ~

77 l ~

74 73 72 71 70 69 67 66 65 14 15 16 17 18 19 20 21 22 24 25 26 27 28 29 30 31 32

0 0

0

Coverage For Probe Angle=60 Deg; Probe Skew=110 Deg (CP-S GPON) 85 84 83 82 81 80 79 78 I ~

77 I I 76 I

I Z75 1 I 74 I I 73 ~ ~

72 71 70 69 68 14 15 16 17 18 19 20 21 22

" 24 25 26 27 28 29 30 31 32

0 4l

Combtned Coverage (CP-SGPON) 85 84 82 81 79 78 77 76 Z75 74 73 72 71 70 69 68 67 65 14 15 16 17 18 19 20 21 22 24 25 26 27 28 29 30 31 32

ik' ATTACHMENT2 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 INSERVICE INSPECTION'PROGRAM - RELIEF. REQUEST NO. RR-4 DRAWINGS RSG90-C251-001: and RSG90-C251-003

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ATTACHMENT3 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 60-266

'INSERVICE INSPECTION PROGRAM - RELIEF REQUEST NO. RR-9 2.Pages

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Code Class Code Reference IWB-2500 Table I WB-2500-1 Examination Category B-D Item Number B3.90, B3.100 Component Description Reactor Vessel Nozzle to'Vessel Welds 5-114A, 5-114B, 5-114C, 5-114D, 5-114E, 5-114F and Inside Radius, Sections 5-114A-IRS, 5-1148-IRS, 5-114C-IRS, 5-114D-IRS, 5-114E-IRS, 5-114F-IRS-Table IWB-2500 requires that nozzle to vessel and inside radius section welds shall be volumetrically examined with a schedule to consist of at least 25% but not more than 50%

(credited) of the nozzles be exa'mined by the end of the first period, and the remainder by the end of the inspection interval. Relating to deferral of inspections, the nozzle to vessel welds are deferrable to the end of the interval provided the examinations are conducted from inside the component and the nozzle weld is examined by straight beam ultrasonic method from the nozzle bore, the remaining examinations required to be conducted from the shell inside diameter may be performed at or near the end of each inspection interval. The inside radius section welds are not deferrable to the end of the interval.

Pursuant to 10 CFR 50.55a(a)(3) and Footnote 6, the use of the following code case is requested as a relief request.

Code Case N-521 allows the examination schedule for the identified welds and inside radius sections to be deferred to the end of the inspection interval provided the welds'have not been repaired or replaced, the welds do not contain identified flaws or relevant indications that currently require successive inspections in accordance with IWB-2420(b) and the unit is not in the first inspection interval.

Additionally, all identified welds and inside radius sections were examined during the 1995 refueling outage. This was the second examination of the interval for the outlet nozzles and inside radius sections. The 1995 refueling, outage was the last outage of the second inspection interval. Therefore, granting approval of this relict request would not extend any examinations beyond a ten year interval.

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RELlEF REQUEST NUMBER - RR-9 (Contd) p p T Examination records for the nozzle to vessel and inside radius section welds have been reviewed to verify compliance to the conditions in the code case. No repairs, replacements or flaws or relevant indications have been identified with the plant currently in the beginning of the third inspection interval.

Therefore, the twelve welds will be scheduled to be volumetrically examined during the 2005 outage of the third period of the third interval.

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