ML18059A698

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Reactor Vessel Integrity Project Plan.
ML18059A698
Person / Time
Site: Palisades Entergy icon.png
Issue date: 02/23/1994
From:
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18059A697 List:
References
PROC-940223, NUDOCS 9403080175
Download: ML18059A698 (23)
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ATTACHMENT 2 Consumers Power Company Palisades Plant Docket 50-255 REACTOR VESSEL INTEGRITY PROJECT PLAN February 23, 1994 7 Pages 9403080175 940223 PDR ADOCK 05000255 p PDR

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Attachment 2 Page 1 of 7 REACTOR VESSEL INTEGRITY PROJECT PLAN I. REMOVAL OF STANDARD REFERENCE MATERIAL FROM THE PALISADES REACTOR VESSEL AND THE INITIATION OF A SUPPLEMENTAL SURVEILLANCE PROGRAM CPCo removed surveillance capsule W-110 from the Palisades reactor vessel (RV) on June 21, 1993. In compliance with 10CFRSO Appendix H, the test report will be submitted to the NRC on or before June 21, 1994.

The results of the analysis of this capsule are important because of the additional fluence information they provide and because the cap~ule contains standard reference material (SRM). It is CPCo's intent to *use this information to support the credibility of a supplemental surveillance program which should accurately assess the condition of the Palisades reactof' vessel .. This program would require NRC acceptance of the similarity of Palisades welds and operating environment to

  • surveillance specimens irradiated in the Inrli°an Point 3, Millstone 1 and Diablo Canyon 1 surveillance programs. The results would be submitted after the results of the WllO surveillance capsule have been reported.

CEOG Topical Report CEN-405-P, Revision 2, "Application of Reactor Vessel Surveillance Data for Embrittlement Management", July 1993, which would be used to support this program, is currently being reviewed by the NRC.

Attachment 2 Page 2 of 7 II. FUEL MANAGEMENT CPCo plans to maintain our aggressive fuel management program. Neutron flux has been maintained below those levels assumed in our June 15, 1992 submittal. It is our intent to continue our enhanced dosimetry program to ensure we have the best available information to ascertain reactor vessel fluence. Preliminary core designs have been developed in the event additional flux reduction is required.

III. RETIRED STEAM GENERATOR WELD SAMPLING PROGRAM A.* CPCo will remove and test weld material from the recently retired Palisades steam generators. The welds in the steam generators were fabricated using the same procedures and weld materials as the Palisades reactor vessel beltline axial welds. We will remove that weld material and use it to measure* copper and nickel content and to determine unirradiated material properties. Since the steam

  • generator welds are essentially identical to the reactor vessel beltline welds, we expect to use the results to represent reactor vessel beltline measured data. At this time, CPCo is in the process of acquiring additional documentation from ABB/CE.

Once the additional supporting information is verified, we will remove the material considered most representative of the reactor vessel beltline axial welds from the steam generators. Some of the removed material will then be shipped to a laboratory for chemical

Attachment 2 Page 3 of 7 analysis. Other samples of the weld material representing each weld wire heat will be shipped to a laboratory for determination of measured initial RTNor and Upper Shelf Energy (USE). We will use these values of the measured initial RTprs in the manner prescribed by IOCFR50.6l(b)(2) to again revise, if justified, the projected value of RTPrs at the end of licensed life.

B. CPCo plans to install weld material from the retired steam generators in the Palisades reactor vessel as accelerated surveillance specimens to monitor the effect'of the Palisades operating environment on that material. Two surveillance capsules could be installed as early as the next refueling outage which is scheduled for the beginning of 1995. The first capsule could then be removed during the refueling outage scheduled for mid 1996. The test results from the first capsule would then be available in 1997.

The second capsule could then be removed in 1998 and test results obtained six months later. Details of this sampling and testing**

program will be discussed in a meeting with the staff tentatively scheduled for early March 1994.

C. CPCo is considering implementation of a test reactor research program. By irradiating weld material from the .retired Palisades steam generators in a test reactor, results could be obtained which provide preliminary confirmation of the Palisades reactor vessel weld condition (when compared to the time period required to obtain the results from capsules in the Palisades RV per Section B above

Attachment 2 Page 4 of 7 would be available). This could also address embrittlement issues th~t cannot be conveniently addressed by placing samples in the Palisades reactor.

IV. CEOG is performing a detailed through-wall chemistry analysis of 10

. welds as part of a generic weld variability study. One of those welqs was fabricated with we)d wire from the same heat (No. 27204) as the weld

  • wire used in the Palisades reactor vessel beltline circumferential weld.

If the results of this analysis invalidate any of the previously derived conclusions regarding the circumferential weld, CPCo will report this fact to the NRC.

V. CPCo plans to.continue its participation in the ABB/CE Reactor Vessel Group fabrication records task. Although CPCo has most of the records for the Palisades reactqr vessel beltline material, this activity may identify the existence of additional similarly fabricated welds.

Successful completion of this activity should reduce question~ which result .from information supplied by other 1icensees.

VI. CPCo recognizes that it may not be possible to ensure the Palisades reactor vessel integrity through the end of licensed life or planned licensed life solely by use of a comprehensive surveillance program.

Therefore we are considering alternatives in addition to fuel management to address that condition. One of these is our plan to support the proposed Westinghouse annealing demonstration project.

Westinghouse/Cooperheat, Westinghouse Owners Group, and EPRI are

Attachment 2 Page 5 of 7 attempting to establish a program to perform an annealing demonstration on the installed NSSS at Marble Hill. This would include fabrication of the annealing apparatus and development of the thermal and stress analysis methodology. The physical demonstration is planned for completion in 1995.

VI .. CPCo is considering a plant specific annealing feasibility study to define the annealing requirements and assess the degree of stress that annealing the reactor vessel would place on the Palisades Primary Coolant System. This activity is not likely to take place until after completion of the anneal in~ demonstration noted above i~ Section V.

CONSUMERS POWER COMPANY - PALISADES NUCLEAR PLANT Schedule for Palisades Reactor Vessel Integrity Project Plans Numeric/Alpha designation in () refers to preceding paragraphs Page 1of1 2/8/1994 1994 1995 1996 1997 1998 DESCRIPTION 01'94 I 02'94 I 03'94 I 04'94 01'95 I o2'95 I 03'95 I 04'95 01'96 I 02'96 I 03'96 I 04'96 01'91 I 02'91 I 03'91 I 04'97 01'98 I 02'98 I 03'98 I 04'98 *

(I) W110 SURVEILLANCE CAPSULE (I) INTEGRATED SURVEILLANCE PROGRAM (II) FUEL MANAGEMENT REPLACE/ ANALYZE DOSIMETRY (Ill.A) ACQUIRE/ TEST MATERIAL (111.B) IMPROVE SURVEILLANCE PROGRAM FABRICATE/ INSTALL TWO CAPSULES REMOVE/ ANALYZE FIRST CAPSULE 0 0 0 0 ' 0 0 0 0

  • 0 < . . . . MOnOOOOOOOOOOOOO 0000000 0000000 ''''''0'00000000 OOOoOooOOOOOOOo*OOOoOoooOO REMOVE/ ANALYZE SECOND CAPSULE (111.C) TEST REACTOR RESEARCH (IV) CEOG WELD VARIABILITY STUDY (V) FABRICATION RECORDS (VI) ANNEALING DEMONSTRATION (VII) ANNEALING FEASIBILITY STUDY c:lmiles'flls02 .mis Produced by 0uta9e Planning & Scheduling Attachment 2 Page 6 of 7

Ana~re Sqlplemental 615192, V719lend Remove Weld Capwle Sllvell~nce 2194 Slbmlllals Samples fr om wno Progamusl1'9 RetredSteam Part~"°le in Pabsades Cont lnue ReactOl Cheml&l1y froni Genen11tors We<tl"JhOO<e (Heat Nos ReaClOt VtsselE11-Ves,sel

..IJfle 1994 Pl, DC 1, l.4l1. Pilot Ve-ssel n. vessel Enhanced and W52MS. Annealong Fl.Jer<t Dela 348009) Anneal CEN-405-P

'---~~ ~t:"b:;:"ll'9 Feestuhty Sludy neratk>r\

Projected .line 1994 *Hill Reactor August t9!H EOl.RT.,.

Ftt><uarr 1994 CbtalnSRl.4 Cblaln Spec mens Projected EDl ChemlStrr RTm and'11tlal RTIC>,

1994 Projected ECll RT.,.

March 1995 Place CharpyS. Place Chorpr Tensile Specimens am Tenslla I'll Tec t Reector Spec mens In Resot.ed Two capsules Projected January 199 lnPall&ades ECll RT.,. Reac10< Moy 1995 Jnnuar t99

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January 1991 tl'Yu Dec..- 1995 11c,;;;-J Projected EOL RT.,.

SeptOllC>er 1995 Remove & Test Spec mens fromNo.1 Copsule

-- January 1IJIJ6 lfT u June 1996

..mnuarr 1994 thru January 1998 E 1e of kJen<*

...mnua*r 19%

=i*=--

rt Necessary Cl DesirDble I

1.&eCycle 11

.line 1997 6fl.Jer<e ft om t998 to Resolved ECll Re*i<e ProjO<ted ~ve& Test pt'OJe<:led ECll RT.,. Specimen< ECll RT.,.

JromNo.2 Values.

oi.cOllC>er l995 Capsula June 1996 DecOllC>erl9911

~-

If Oesroble use unra LO* Leet.age Core

_Feoruary 1999 19'JB PALISADES REACTOR VESSEL PROJECT PLAN Anneal If Resolved Desk able_

IMPLEMENTATION FLOW DIAGRAM A'o)ected EOLRT.,.

.line 1999 January 2001 Attachment 2 Page 7 of 7

ATTACHMENT 3 Consumers Power Company Palisades Plant Docket 50-255 REVISED RTPTs FOR THE PALISADES REACTOR VESSEL AXIAL WELDS CONTAINING HEAT NO. W5214

{This is a non-proprietary version of Attachment 1)

February 23, 1994 8 Pages

Attachment 3 Page 1 of 8 REVISED RTPTS FOR THE PALISADES REACTOR VESSEL AXIAL WELDS CONTAINING HEAT NO. W5214 (A Vertical line in the right margin indicates proprietary information has been removed)

In accord with the conclusions -0f our meeting with the NRC on November 9, 1993, CPCo has revised its previously docketed (June 5, 1992) determination of the limitiiig best* estimate copper and nickel content in the Palisades reactor vessel beltline axial welds. Previously docketed data has been reviewed and the following changes have been tricorporated based on our improved understanding of the available data.

1. In our June 5, 1992 PTS submittal, CPCo reported an unknown weld deposit with a measured copper content of 0.20%1
  • CPCo has been unable to confirm this data by any documentation other than the then referenced EPRI report (EPRI NP-3573-SR, August 1984). Since we have been unable to trace this data back to the shop records, it has been eliminated from this revised best estimate determination of the copper content of welds fabricated with weld wire heat number W5214.
2. In our June 5, 1992 PTS ~ubmittal, the mean of the copper and nickel content of the IP2 surveillance*weld was based on 11 copper and 7 nickel 1

Slade (CPCo) to NRC, "Docket 50-255 - License DPR Palisades Plant -

10CFR50.61 Pressurized Thermal Shock - Revised Projected Values of RTpys for Reactor Beltline Materials", June 5, 1992, attachment, Table 2-10, p. 1 of 6.

Attachment 3 Page 2 of 8 measurements. 2 We have been unable to adequately trace the origin of four of the copper and four of the nickel measurements referenced in the EPRI report. Therefore those measurements are not included in the determining of the copper and nickel content of the IP2 surveillance weld which is used in this revised projection of RTPTs for the welds in the Palisades RV.

3. CPCo has not included the Nine Mile Point surveillance weld in this revised best estimate determination *Of copper for welds fabricated with weld wire heat number W5214 3

After evaluation of information gained from our investigation of the chemical copper coating process and its application to weld wire at the time the weld wire from Heat No. W5214 was coated, we have determined that more than half of the copper in welds fabricated using that wire is from the copper coating on the wire. An ancillary finding of that investigation was that the thickness of the copper coating on each section of a bundle of wire or between bundles of wire can vary within certain limits. In view of this information and because the copper concentratiori of tandem arc welds represents the average copper ~ontent of two weld wires, a simple average of individual weld copper 2

1810, Page 2 of 6 3

"Surveillance Program Resources Available for the Palisades Reactor Vessel", C NPSD-913-P, September 1993, pp. 5 and 8.

~*

Attachment 3 Page 3 of 8 concentrations is not acceptable. The revised best estimate chemistry reported herein is derived by use of an averaging process which weights the*

copper measurements from confirmed tandem arc welds at twice the weight given to single arc welds. Those tandem arc welds are weld seam 4

and the torus to flange weld from the H. B. Robinson 2 reactor vessel. 5 Weighting the chemical analyses according to the number of wires associated with the weld process results in a best estimate copper content of 0.20% and a best estimate nickel content of 1.02% (the nickel content of each nickel addition weld is weighted the same because both the single arc and the tandem arc processes used a single nickel addition wire) for the Palisades axial welds.

These chemical concentrations yield a chemistry factor of 225°F from Table I of 10CFR50.6l.

Thus, using the same fiuence accumulation and calculation methodology as that reported in our June 5, 1992 submittal and including the previously omitted HBRobinson and Oyster Creek data and using the weighted average method to determine best estimate chemistry, RTp15 for the limiting axial seam is projected to exceed the 270°F screening criterion in the year 2004. Table I.I lists the data ~sed to determine the 225°F chemistry factor.

4 Byrne(ABAi to Kneeland(CPCo), "Records Search on Welds 2-112 A/C, 3-112 A/C 9-112 - Final Letter Report", P-MECH-92-025, October 12, 1992, pp. 5-6.

5 Yanichko, Williams and Kunka, "Evaluation of H. B. Robinson Unit 2 Reactor Vessel Beltline Region Weld Material Chemistry", May 1983, p; 7.

Attachment 3 Page 4 of 8 TABLE I. I

. 1111=111:1:111~111::::::1B1::::1:m1::::::111~::::1:1~111::::::111::::::m1::::::1~11 CHEMICAL COMPOSITION OF SELECTED HEAT NO. W5214 WELD SAMPLES Identifjcation Tandem arc

Attachment 3 Page 5 of 8 Table 1.1 (Con}

Identification Tandem Arc 6

6 Byrne (ABB/CE} to Kneeland (CPCo}, "Records Search on Welds 2-112 A/C, 3-112 A/C, E-112 Final letter report, P-MECH_92-025, October 12, 1992, Pp.5-6 II

Attachment 3 Page 6 of 8 Table 1.1 (Con)

Weld Wire Heat W5214 + Ni 200 Identification %Cu %Ni Tandem Arc HBR2 torus-flange weld 0. 154 0.99 0 .163 0. 90 0 .152 1.08 0.166 1.007 1:~::1:11 1:~::11 x IP2 surveillance weld 0. 23 1.02 0 .20 1. 06

0. 20 1.00
0. 19
0. 22
0. 18 8

0.20 liflill :1wo.a

                          • I 7

Yanichko, Williams and Kunka, "Evaluation of H.B. Robinson Unit 2 Reactor Vessel Beltline Region Weld Material Chemistry," May 1983, Table 4.

8 lddings, Cadena and Williams, "Reactor Vessel Material Surveillance Program for Indian Point Unit No. 2 Analysis of Capsule V", SwRI Project No. 17-2106 (Revised), March 1990, p. IV-26.

Attachment 3 Page 7 of 8 Table I.I (Con)

Weld Wire Heat W5214 + Ni 200 Identification Tandem Arc IP3 surveillance weld 0.15 1.02 0.166 1.21 9

~M::1:1 :1]::1:?

IP3 nozzle cutout 0.16 1.06 0.15 1.11 0.15 1.09 1~~:1:1 :1::~:11 HBR2 surveillance weld 0.32 0.66 0.34 0.33 *0.63 0.35 1:~::11 OCI surveillance weld 0.282 0.290 0.282 11 9

Yanichko, Anderson and Kaiser, "Analysis of Capsule Y from the Power Authority of the State of New York Indian Point Unit 3 Reactor Vessel Radiation" Surveillance Program", WCAP-10300, March 1983, p. 4-3.

10 Yanichko, Williams and Kunka, "Evaluation of H.B. Robinson Unit 2 Reactor Vessel Beltline Region Weld Material Chemistry", May 1983, Table I.

11 Chen(GPUN) to Kneeland(CPCo), November 4, 1992, p.5.

Attachment 3 Page 8 of 8 CALCULATION OF THE MEAN COPPER AND NICKEL CONTENT OF WELDS FABRICATED USING WELD WIRE FROM HEAT No. W5214

1. COPPER CONTENT Sample Identification Weight % Copper 0.20 0.20 HBR2 - Torus Flange 0.159 II II II 0.159 IP2 Surveillance *0.20 IP3 - Surveillance 0 .-16 0.16 IP3 - Nozzle Cutout 0.15 HBR2 - Surveillance 0.34 OCl --Surveillance 0.285 Total 2.013 2.013/10 = 0.201 Mean Copper content .
l. NICKEL CONTENT Sample Identification Nickel Content 0.94 1.20 1.00 1.05 1.12 0.97 0.92 0.99 1.13 HBR2 - Torus Flange .0.99 IP2 - Surveillance 1.03 IP3 - Surveillance 1.12 IP3 - Nozzle Cutout 1.09 HBR2 - Surveillance 0.66 Total
  • 14.21 14.21/14 = 1.015 =Mean Nickel Content

j- .

-.* ATTACHMENT 4 Consumers Power Company Palisades Plant Docket 50-255 COMBUSTION ENGINEERING, INC AFFIDAVIT PURSUANT TO 10CFR2.790 February 23, 1994 5 Pages

~.. .

AFFIDAVIT PURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc. )

State of Connecticut )

County o~ Hartford ) ss.:

I, S. A. Toelle, depose and say that I am th~ Manager, Nuclear Licensing, of Combustion Engineering, Inc., *duly authorized to make this affidavit, and have reviewed or caused to 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 for withholding this information.

The information for which proprietary ..treatment is sought is contained in the following document:

Attachment 1, . "Revised RTprs for *the Palisades Reactor Vessel Axial Welds Containing Heat No. W5214," February 1994.

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 oi: financial information.

Pursuant to the provisions of paragraph (b) (4) of Section 2.790 of the Commission's regulations, the following is furnished for

J consideration by the Commission in determining whether the information sought to be withheld from public disclosure, included in the above referenced document, 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, ~s reactor vessel weld material and mechanical and chemical data used to calculate RTprs values.
2. The information consists. of test data or other similar data concerning a process, method or compone~t, the application of which results in substantial competitive advantage to Combustion Engineering.
3. The information :i,s_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 information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in co~f idence. The details of the aforementioned system were provided to the Nuclear Regulatory Commission via letter DP-537 from F. M*. Stern to Frank Schroeder dated December 2, 197'4.

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 of my knowledge and belief, is not available in public sources, and any disclosure to third parties has been made pursuant to regulatory provisions or proprietary agreements which provide 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
  • Engineering because:
a. A similar product is manufactured and sold by major pressurized water reactor competitors of Combustion Engineering.
b. Development of this information by *c-E required hundreds 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.
c. In order to acquire such information, a competitor would also require considerable time and inconvenience to ascertain the reactor vessel weld material and mechanical and chemical data used to calculate RTPTs values.

. l

,,1

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 reactor vessel we.ld material and mechanical and chemical data used to calculate RT~s values, the application of which provides a competitive economic advantage. The availability of such information to competitors would enable them to modify their product to better compete with Combustion Engineering, take marketing or other actions to improve th~ir 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, licensing, quality assurance and other costs and expenses must be included. The ability of Combustion Engineering's competitors. to utilize such information without similar expenditure of resources 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.

S. fl .111!._

S. A. Toelle Manager Nuclear Licensing sworn to before me this I 7 +t, t 1994 My commission expires: 3 CJ../

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