ML18059A459
| ML18059A459 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/20/1993 |
| From: | Rogers D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18059A460 | List: |
| References | |
| TAC-M87760, NUDOCS 9310280208 | |
| Download: ML18059A459 (10) | |
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consumers Power l'OWERINli
/llllCHlliAN'S l'ROliRESS Palisades Nuclear Plant:
27780 Blue Star Memorial Highway, Covert, Ml 49043 October 20, 1993 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 David w. Rogers Plant Safety and Licensing Director DOCKET 50-255 - LICENSE DPR PALISADES PLANT - RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING THE RECENT PRESSURIZER SAFE END CRACK TO SUPPORT THE BROOKHAVEN ANALYSIS (TAC No. M87760)
An NRC letter, dated October 8, 1993, requested additional information concerning the recent pressurizer safe end crack. This request was to support the Brookhaven National Laboratory's independent evaluation of the Palisades preisurizer power operated relief valve nozzle safe end crack.
In a meeting that was held in Washington at NRC Headquarters on October 12, 1993 to discuss results of our actions and analyses taken in response to the crack, we stated that we would submit the information to support the Brookhaven independent analysis by October 20, 1993.
The attachment to this letter contains the requested information except for the sketch requested in item 6 of your request leter. That sketch will be provided by October 29, 1993.
As requested in the October 8, 1993 NRC letter, a copy of this information has been sent directly to Mr. Carl Czajkowski at the Brookhaven National Lab.
Combustion Engineering, Incorporated considers the information provided in to Attachment 1 to be proprietary.
In accordance with 10CFR2.790(b), to support the NRC withholding proprietary information, an affidavit from CE is attached. It is therefore requested that the CE proprietary information be withheld from public disclosure.
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David W. Rogers Plant Safety and Licensing Director 280005 CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachments
AFFIDAVIT PURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc.
State of Connecticut County of Hartford SS. :
I, s. A. Toelle, depose and say that I am the Manager, Nuclear Licensing, of Combustion Engineering, Inc., duly authorized to make this affidavit, and have reviewed or caused t:,o have reviewed the information which is identified as proprietary and referenced in the paragraph immediately below.
I am submitting this affidavit in conjunction with the application of Consumers Power Company and in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations.
The information for which proprietary treatment is sought is contained in the following document: to Consumer.s ?ower '* Company Letter, "Docket 50-255 -
License DPR Palisades Pl~nt *...: Response to Request for Additional Information Regarding
- the., *Recent Pressurizer,Safe End Crack to
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sup~*ort the Brookhaven Analysis *(TAC No*.. MS776b}',' 11** October 20, 1993.
- 1 This document has been appropriately designated as proprietary.
I have personal knowledge of the criteria and procedures utilized by Combustion Engineering in designating information as a trade secret, privileged or as confidential commercial or financial
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informat:iori.
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Pursuant to the provisions of paragraph (b) (4) of Section 2.790 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure, included in the above referenced documents, should be withheld.
- 1.
- The information sought to be withheld from public disclosure, which is owned and has been held in confidence by Combustion Engineering, is specific fabrication specification and material test data associated with the Palisades Plant pressurizer built by Combustion Engineering.
- 2.
The information consists of test data or other similar data concerning a process, method or component, the application of which results in substantial competitive advantage to Combustion Engineering.
- 3.
The information is of a type customarily held in confidence by Combustion Engineering and. not customarily disclosed to the public.
Combustion Engineering has a rational basis for determining. the types of i~f ormation customarily held in confidence by it and, in *that c;:9nnec::tion, utilizes a system to
'd~termine when:. and *~hethei to h,old ce~tai'n *types of information in confidence.
The details of,.the aforementioned system were provided to the Nuclear Regulatory Commission via letter DP-537
3 -
from F.
M~ stern to Frank Sqhroeder dated_ December 2, 1974.
This system was applied in determining that the subject document herein is proprietary.
- 4.
The information is being transmitted to the Commission, in confidence under the provisions of 10 CFR 2. 790 with the understanding that it is to be received in confidence by the Commission. _
- 5.
The information,.to the best bf my knowledge and belief, is not ayailable in ptfblic sources,.and any:.disclosure to third I>arties.
h_as been made pur::;;uant to r.egulatory provisions or proprietary agreements which provfde for maintenance of the.information-in confidence.
- 6.
- Public disclosure of the information is likely to cause
- substantial harm to the.. competitive position of. Combustion Engin~ering because:
- a.
A similar product is manufactured and.s_old by maj'o~
pressurized water reactor competitors of Combustion
- Engineering.
- b.
Develqpment of this information by C-E required thousands of manhours and hundreds of thousands of dollars.
To the best.of my knowledge and belief, a competitor would have to
- undergo similar expense in generating equivalent information.
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- c.
In order to acquire-such information, a competitor woul~
also require considerable time and inconvenience to ascertain the specific material properties pertaining to the Palisades Plant pressurizer.
- d.
The information required significant effort and expense to obtain the licensing approvals necessary for application of the information.
Avoidance of this expense would decrease a
competitor's cost in applying the information and marketing the product to which the information is applicable.
- e.
The information consists of specific fabrication specification and material test data associated with the Palisades Plant pressurizer built by Combustion.
Engineering, the application of which provides a
competitive economic advantage.
The availability of such information to competitors w:ould enable them to modify their product to better compete with Combustion Engineering, take marketing or other actions to improve their product's position or impair the position of Combustion Engineering's product, and avoid *developing similar data and analyses in support of their processes, methods or apparatus.
- f.
In pricing Combustion Engineering's products and services, significant research, development, engineering, analytical, manufacturing, lic*e~sin.g,*'quality assurance and other costs and expenses must pe included.
T~e ability of Combustion
5 Engineering's competitors to utilize such _ ~_nformation
- without similar expenditure of "resoU:rc'es may enable them to sell at prices reflecting significantly lower costs.
- g.
Use of the information by competitors in the international marketplace would increase their ability to market nuclear steam supply systems by reducing the costs associated with their technology development.
In addition, disclosure would have an adverse economic impact on.Combustion Engineering's potential for obtaining or maintaining foreign licensees.
Further the deponent sayeth not.
Sworn to before me S. {).---di_
S. A. Toelle Manager Nuclear Licensing
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this o<D day of -t~,..,.....~~------' 1993
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1My ;eomm'i.ssion expires:
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ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 REQUESTED INFORMATION FOR ALL FIVE INCONEL SAFE ENDS/FLANGES October 20, 1993 3 Pages
NRC request:
REQUESTED INFORMATION FOR ALL FIVE INCONEL SAFE ENDS/FLANGES
- 1.
Certificate of Material Test Reports on the Inconel.
CPCo response:
Certificate of Material Test Reports (CMTR) of the Inconel 600 used for the pressurizer relief valve, spray nozzle, and three safety valve safe-ends, all fabricated from heat NX5222 forged by Western Forge and Flange Company, are provided in Enclosure 1.
NRC request:
- 2.
Inconel grain size from the manufacturer and final grain size from failure analysis and/or field metallography.
CPCo response:
Grain size determination was not required by the procuring documents and is not reported on the CMTR.
The grain size determined by our failure analysis for the base metal and heat affected zone of the pressurizer relief valve nozzle safe-end was ASTM 0.
NRC request:
- 3.
Detailed information regarding materials procurement, specifications, manufacturer, manufacturing process, chemistry, tensile and hardness test reports, and heat treatment details (solution annealing temperatures and stress relieving temperatures.)
CPCo response:
The procurement specifications are also presented in Enclosure 1.
The CMTRs, (reporting tensile, chemical, and hardness test results) are presented in Enclosure 1. There were no requirements to report forging and temperature or annealing heat treatments.
The shop welds were stress relieved at 1150°F.
The field welds (stainless to Inconel 600 with Inconel weld wire) were not stress relieved.
1
NRC request:
- 4.
Details of the original weld and the repairs, including whether the same materials were used, the weld metal composition, dimensions, fit up details, whether cold springing was a77owed, and special controls used.
CPCo response:
The details of the original weld are shown in Enclosure 2 on Drawing 1.
This drawing is a compilation of information available from Combustion Engineering (CE} drawings, Bechtel welding procedure specifications (WPSs}, and field measurements.
2 The stai.nless pipe to inconel safe end weld was a field weld performed by Bechtel. While no records have been found which specify exactly what WPS Bechtel used to make this weld, the most probable WPS used was P43, P8-AT-Ag Rev. 2, dated October 13, 1969. This WPS is believed to have been used because of the application, the date, the fact that it was found among other historical WPSs in our document control, and the joint design matches that which CE prepped the safe end for.
This Bechtel WPS was for welding lnconel 600 to stainless steel using open-butt joints with internal argon purge.
The joint was made using the Gas Tungsten Arc Welding (GTAW} process for the root and hot pass with the remainder of the joint made using the Shielded Metal Arc Welding (SMAW}
process.
For the root and hot pass ERNiCr-3 (lnconel 82) filler metal was used.
ENiCrFe-3 (lnconel 182) was used for the SMAW portion of the weld.
While it appears that repairs were made, no details on these repairs are available.
Drawing 2 shows the location of the first cut removing the original safe end to pipe weld.
After making this first cut, the remaining safe end was machined (shown on Drawing 2 and Drawing 3) for making the new repair weld.
Drawing 3 also shows the fit up details for making the new repair weld.
Essentially, all of the materials used for the new repair weld were identical to that used for the original weld.
The existing SB166 lnconel safe end was welded to a replacement section of SA376 type 316 stainless steel pipe using an open butt joint with argon backing.
The joint was welded by GTAW and SMAW using ERNiCr-3 and ENiCrFe-3 inconel filler metals respectively.
Drawing 4 shows the completed repair weld.
Note that the repair weld has a thicker section at the safe end than the original weld.
Also, the root of the weld was ground flush and flapped smooth from the inside to remove any discontinuities. After welding, the safe end was ground to achieve a flat surface across the weld cap and safe end.
This was performed to facilitate UT examination from the safe end side of the weld.
Pipe end movement upward when the first cut near the nozzle was made, was approximately 1 1/2 inches.
Cold spring was not specified for the installation of this piping.
Cold spring was not specified during the installation of any piping at Palisades because of the relatively low operating temperatures.
The normal service temperatures for piping are less than 6S0°F.
3 The only special controls used for the new repair weld outside of adherence to the welding procedure involved access to the inside diameter (ID) of.the weld.
Sufficient pipe had been removed above the nozzle to allow access to the ID of the nozzle.
Replacement of this piping was performed in two steps. First, a 3-inch long stainless spool piece was welded to the nozzle. This step allowed both visual and physical access to the ID of the weld root area. Visual access allowed a second welder to monitor the root pass from the ID and provide feedback to the welder making the root pass.
Physical access allowed grinding and polishing the root ID to remove any physical discontinuities. The second step completed the piping system with the installation of approximately 1 foot of pipe.
NRC request:
- 5.
Similarities and differences in materials, stresses, and environments for the five safe ends/flanges.
CPCo response:
As noted in the response to item 1 above, the five safe-ends were all fabricated from the same heat forged by Western Forge and Flange Company.
Differences in stress and environment are discussed in Sections 7 and 10 of our report entitled, "Pressurizer Safe-End Crack Engineering Analysis and Root Cause Evaluation," whith was submitted on October 7, 1993.
NRC request:
- 6.
A sketch with dimensions to show the location of the weld repair relative to the locations of cracks and lack of fusion.
Show all locations of lack of fusion.
CPCo response:
The sketch is incomplete at this time.
It will be provided by October 29, 1993.
It will not show all the locations of lack of fusion as that will not be possible without further cross sectionalizing of the samples that are now at Brookhaven.