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Submits First of Several Responses to NRC Questions from 960814 Meeting Re Updated Reactor Vessel Fluence
	ML18065A886
Person / Time
Site:	Palisades
Issue date:	08/27/1996
From:	Bordine T; CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
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ML18065A888	List: ML18065A886;
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	NUDOCS 9609040317
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l'OWERlll&

llllUllliAll"S l'IUllillUS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 August27, 1996 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT Thomas C. Bordlne Manager, Licensing UPDATED REACTOR VESSEL FLUENCE SUBMITTAL - PARTIAL RESPONSE TO ADDITIONAL QUESTIONS On April 4, 1996, Consumers Power Company (CPCo) submitted a reevaluation of the Palisades fluence data. The reevaluation contained a new estimate of when the limiting reactor vessel material will reach the Pressurized Thermal Shock (PTS)

screening criteria. On May 15, 19,96, CPCo met with the NRC staff to discuss the updated reactor vessel fluence values. On June 12 and 21, 1996, CPCo responded to the NRC questions from the May 15, 1996 meeting. On August 14, 1996, the NRC staff and CPCo met to further discuss the updated reactor vessel fluence submittal. At that meeting, the NRC staff asked additional questions. This submittal is the first of several submittals planned to respond to the NRC questions from the August 14, 1996 meeting. provides the CPCo response to the NRC question on the nominal reactor

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Proprietary Attachment 3 provides the proprietary drawings showing in-vessel capsule locations and dimensions in response to the NRC request. As these drawings provide information proprietary to Combustion Engineering, Incorporated (CE), this attachment is supported by an affidavit signed by CE, the owner of the information. Therefore, in accordance with 1 OCFR 2. 790 (b ), it is requested that the information which is proprietary to CE be withheld from public disclosure. Non-Proprietary Attachment 3 contains only the Attachment 3 Title Page since the drawings are proprietary. provides the CE affidavit identifying these drawings as proprietary.

The ex-vessel dosimetry is located the same as shown in the original submittal, dated April 4, 1996, with the dosimetry shifted in both the azimuthal and radial locations as described in Section 2. 1.1 of WCAP-144557 Revision 1. The basis for these values will be provided in a later submittal.

SUMMARY

OF COMMITMENTS.

This letter contains no new commitments and no revisions to existing commitments.-

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(f"l Thomas C. Berdine Manager, Licensing CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Attachments

I ATTACHMENT 1 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255.

CPCO RESPONSE TO NRC QUESTION ON NOMINAL REACTORVESSEL INNER RADIUS FROM AUGUST 14, 1996 MEETING 1 Page

Updated Fluence Submittal Request for Additional Information CPC Response to RAl-1 (CPCo June 12. 1996 Response)

In Response-1. 1 (Item 4.3), it is stated that the nominal vessel IR was determined by an average of the maximum and minimum measurements. What is the average of all the measurements?

CPCo Response The following measurement data for the vessel inside diameter (ID) is available from CE shop travelers (Attachment 2) associated with the manufacturing of the Palisades reactor pressure vessel. These ten values represent all the known as-built inner diameter data available to the plant for the middle and lower shell courses, which are the two shells that are adjacent to the core. (Dimensions are in inches.)

173 1/32 1727/16 172 %

172 %

172 9/16 172 3/8 172 13/16 (MA)_()

172 15/16 172 3/8 172 17/32 A straight average of the measured data yields an inner radius (IR) of 86.30 inches with a standard deviation of 0. 12 inches.

The height of the shell courses is approximately 16 feet. The limited data over this height and the fact that the lower shell ID values were recorded in a different manner than the middle shell ID values lead us to believe that.a *straight average of the measured data does not necessarily represent the true average value of the two shell courses. The data does show'that fluence calculated for the maximum vessel ID of 173 1/32 inches (IR 86.52 inches) or the minimum 172 3/8 inches (IR 86.19 inches) would be correct for at least some portion of the vessel. The use of the average of these two values, 86.35 inches, (86.37 inches was input into calculations, see CPCo's June 12, 1996 response) is justified when the deviation from this average is covered by the uncertainty associated with the maximum reG_orded deviation 0.16 inche_s,.or 2.6%

uncertainty on fluence.

The fabrication and welding specifications for the Palisades Reactor Pressure Vessel required the vessel to have a diameter of 172 % inches +3/4, -3/f3. This provides a range between 172 1 /8 and 173 1 /4 inches. If the vessel ID were to vary over this entire range the median would be 172 11/16. In terms of vessel radius, this provides a value of 86.344 +/- 0.281 inches, where +/- 0.281 is the absolute limit on the uncertainty of the IR. This information supports the use of the nominal value provided above.

ATTACHMENT 2 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 COMBUSTION ENGINEERING SHOP TRAVELERS WHICH SUPPORT ATTACHMENT 1 4 Pages

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ATTACHMENT 3 NON-PROPRIETARY CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 COMBUSTION ENGINEERING DRAWINGS SHOWING IN-VESSEL CAPSULE LOCATIONS AND DIMENSIONS Combustion Engineering Drawings Nos.

2996 - D - 30728 2966 - E - 2949, Rev 2 2966-E -2871, Rev 1 2966 - SJ - 1571 (Drawings Not Enclosed In This Non-Proprietary Version of Attachment 3) 4 Sheets

ATTACHMENT 4 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 COMBUSTION ENGINEERING AFFIDAVIT PURSUANT TO 10 CFR 2.790 FOR ATTACHMENT 3 DRAWINGS 4 Pages

'/7' u-r Combustion Engineering, Inc.*

State of Connecticut County of ~artford.

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AFF1DA VIT PURSUANT TO 10...CFR 2.790 I, Ian C. Rickard, depose and say that I am the Director of Operations Licensing, of Combustion I?ngineering, 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

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the paragraph immoo~tely _below. '1 am submitting this affidavit in confonnanee with the '

provisio~sof 10 CFR_2.790 of the Commission's regulations in oonjunction with Consumers Power Company for withholding this information..

The information for which proprietary treatment is sought is contained ~r referenced in _

the following documents:

CE Drawing ?l{umber

. Title

Purpose 2966-D-3072B Caps~le Holder Assys.

Shows. capsule holders and dimensions.

2_966:&29~9, Rev~ 2 Temp, Flux & Tensile Show positioning of Capsule Compartment Assy_ -

monitors.

Surveillance 2966-E-2871. Rev. 1 Capsule Detail Surveillance Shows capsule dimensions.

2966-SJ-1571-Surveillance Holder Assy. :

Shows-capsule positions and dimensions.

The above docdments have been appropriately *designated as proprietary. **

I have personal knowledge of the criteria and procedure5 utilized by Combustion.

Engineering in designating infonnation as a trade secret, privileged or as confidential.

commercial or financial infonnation.

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*Pursuant to the provisions of paragraph (b) (4)of Section 2:190 of the. Commission's regulations, the following is fumi.shed for consideration by the Commission. in d.etermining whether the information sought to be ~thheld from public disclosure, included in the above

. ~ferenced documents, should be withheld.

1.

. The infonnation sought.to be withheld from public disclosure, which is owned and has been held in confidence by Combustion Engineering, is the dimensionai and design.

configuration i~format:ion concerning surveiii'ance capsules and capsule holders~..

2.

The inf<;mnation consists of test data or other' similar data ~nceming a pr0cess, 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 confidenee by Combustion

4.

5.

Engineering and not customarily disclosed to the public. Combustion Engjneering has a rational basis for determining the types.of ~formation customarily held in confidence

. by it and, in that connection utilizes a system to determine when and whether io hold certain. types of information in confidence. The details of the aforeq\\entioned system *

. were provided to the Nuclear Regulatory Commission via.letter DP-537 from F.M~

Stern to Frank Schroeder dated December 2, 1974. This-system was applied in

determining that the subject document herein is proprietary.

. The information is being transmitted to the Commission fo confidence under the

provisi~ns of lO*CFR 2.790 with the understanding that it is to be received in.

eonfide.nce by the Commission.

The information, to the best of my lmowledge and belief, is. not.avai4ble in public sources, and any disclosure* to third parties has.been made pursuant to regulatory provisions or proprietary agreeme~ts which provide for maintenance of the information in confidence.

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. Public disclosure of the information is likely to cause substantial harm to the competitive position of Combustion Engineering because:

a)

. Servicing of _the capsules and holders _could be provided by nuclear services competitors of Combustion Engineering.

b) *

. In order to acquire *such information, a competitor would require considerable c).*.

time and Inconvenience to determine the design configuration and location of.

surveillance capsules and capsule holders so as to perform accurate* fluenc~

calculations or service the holders.

In pricing Combustion Engineerin~*s products and_ services, significani

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research, _development, engineering, analytical, manufact~ring, licensing, quality assurance and other oosts and expenses must be i.Ilclud~-~ The ability of Combustion Engineering's competitors to utilize such information without si~il~ expenditure of resources may enable them ~o sell at prices reflecting significantly lower* costs:

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1 r;;. Further the deponent" sayeth not.

Director of

Operations Licensing Sworn to before me

.this.r2.-GZk day of~,

19,96:

t! ilZ!Yf4.?'-k ()). /lli ca47 *

. Notary Public My commission eXpires: 1,/ 31 /1r

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ML18065A886

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