ML17202U971

Forwards Proprietary & non-proprietary Fracture Toughness Evaluation of Shell Side of Lpcis Heat Exchanger for Dresden Station - Unit 2, Per NRC Re SEP Topic III-1. Proprietary Rept Withheld (Ref 10CFR2.790)

ML17202U971
Person / Time
Site:	Dresden
Issue date:	02/04/1991
From:	Richter M COMMONWEALTH EDISON CO.
To:	Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
Shared Package
ML17202U972	List: ML17202U971 ML20067B492
References
TASK-03-01, TASK-3-1, TASK-RR NUDOCS 9102080237
Download: ML17202U971 (6)

Text

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Commonw. Edison 1400 Opus Place.

Downers Grove, Illinois 60515' I

February 4, 1991 Dr. Thomas E. Murley, D1rector Off1ce of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn:

Document Control Desk

Subject:

Dresden Nuclear Power Station Unit 2 Fracture Toughness Evaluation of the LPCI Heat Exchanger <shell-side)

NR9 Docket No. 50-237

References:

<a>

J. Craig <NRC> letter to T. Kovach <CECo), dated November 29, 1989, transmitting IPSAR Final Report (NUREG 0823 Supplement No. 1).

(b)

(c)

( d)

D. Muller <NRC) letter to T. Kovach <CECo), dated May l, 1989.

J. Silady <CECo) letter to T. Murley <NRC), dated March 30, 1990.

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NRC <B. Siegel) and CECo <M. Rtchter) teletonference on October 23, 1990.

Dr. Murley:

References <a> and (b) indicated that an open item existed from the NRC's review of Systematic Evaluation Program <SEP) Topic III-1 for Dresden Unit 2.

For closure of this item~ the NRC requested additional justification of the fracture toughne5s of the Low Pressur~ Coolant Injection <LPCI) heat exchangers <shell side) with respect to expected minimum service temperature.

Reference (c) submitted the results of an analysis, performed by SMC O'Donnell Inc., which demonstrated adequate fracture toughness of the heat exchangers.

As requested in the R~ference (d) teleconference, this letter transmits the fracture toughness evaluation report and provides information on those actions performed at Dresden Station which would provide the opportunity to identify heat exchanger shell side leakage.

Attachment 'A' presents the SMC O'Donnell fracture toughness evaluation report for the LPCI heat exchangers for Dresden Unit 2.

The information in Attachment 'A' is considered to be proprietary information to SMC O'Donnell Inc., and is supported by an aff1davit s1gned by SMC O'Donnell Inc. 1 the owner of the 1nformat1on.

Attachment 'B' contains the affidavit that sets forth the basis on which the information may be withheld from public disclosure by the NRC and addresses the considerations listed in paragraph (b)

(4) of 10 CFR 2.790-of the NRC's regulations. Accordingly, Commonwealth Edison Company <CECo) requests that the information contained in Attachment

'A' be withheld from public disclosure in accordance with 10 CFR 2.790.

It should also be noted that Attachment 'C' provides a non-proprietary version of the SMC O'Donnell fracture toughness evaluation report.

ZULD703/12 9102080237 910204

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PDR ADOCK --050002:37

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Dr. T. February 4, 1991 Currently, there *are activities being performed at Dresden Station which would provide *the opportunity to identify shell side leakage from the LPCI heat exchangers.

Dur1ng normal unit operatinn, when the shell side of the heat exchangers are pressurized to approximately 80 psig by the ECCS

'keep-fill' pump, Operating Department personnel enter each heat exchanger room on a daily basis to verify the status of the equipment and to identify any abnormal condition. Operating Department personnel are also in the heat exchanger rooms during the performance of the monthly operability surveillance test for the LPCI pumps <which pressurize the shell side of the heat exchangers to approximately 150 psig). Additionally, the LPCI heat exchangers are included in Dresden Station's Inservice Inspection CISI> Program.

It should also be noted that control room alarms are available which would provide notification to Operating Department personnel of low LPCI System header pressure or high sump level (for the sump in each heat exchanger room).

Please contact this offite should further information be required.

Respectfully, M. H. Richter Nuclear Licensing Administrator Attachments:

A - Fracture Toughness Evaluation of the Shell Side of the LPCI Heat Exchanger for Dresden Station Unit 2

<Propietary Report - Report No. 2042.04-400-001-00)

B - SMC O'Donnell Inc. Affidavit C - Fracture Toughness Evaluation of the Shell Side of the LPCI Heat Exchanger for Dresden Station Unit 2 CNon-Propietary Report - Report No. 2042.04-400-002-00) cc:. A.B. Davis - Regional Administrator, Region III B.L. Siegel - NRR Project Manager D.E. Hills - Senior Resident Inspector, Dresden ZNLD703/13

Attachment B SMC O;Donnell Inc. Affidavit ZNLD703/15

COMMONWEALTH OF PENNSYLVANIA

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COUNTY OF ALLEGHENY

) S.S.

AFFIDAVIT I, Edward John Hampton being duly sworn, hereby say and depose~

1.

I am the Senior Vice President, Engineering, of SMC O'Donnell Inc., and as such I am authorized to execute this Affidavit.

2.

I am familiar with O'Donnell's detailed document control system and policies which govern the protection and control of information.

3.

I am familiar with the Report 2042.04-400-001-00, Fracture Toughness Evaluation of the Shell Side of the Low Pressure Coolant Injection System (LPCI) Heat Exchanger for Dresden Statton - Unit 2, referred to as "Document."

Information contained in this Document has been classified by O'Donnell as proprietary in accordance with the control system and policies established by O'Donnell for the control and protection of information.

4.

The Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by O'Donnell and not made av~ilable*to the publi.c.

Bas*ed on my experience, I am aware that other companies 'regard informatiOn of the k'ind contain~d._in. the Document as proprietary and confidential.

5.

The Docu~ent has been m~de available to the*U. S. Nuclear Regulatory Commission in confidence, with the request that the information contained in the Document will not be disclosed or divulged.

AFFIDAVIT Page 2

6.

The Document contains information which is vital to a competitive advantage of O'Donnell and would be helpful to competitors of O'Donnell when competing with O'Donnell.

7.

The information contained in the Document is considered to be proprietary by O'Donnell because it reveals certain distinguishing aspects of O'Donnell's fracture mechanics methodology which secure competitive advantage to O'Donnell for engineering design and analysis, and includes information utilized by O'Donnell in its business which affords O'Donnell an opportunity to obtain a competitive advantage over its competitors who do not or may not know or use the information contained in the Document.

8.

The disclosure of the proprietary information contained in the Document to a competitor would permit the competitor to reduce its expenditure of money and manpower and to improve its competitive position by giving it valuable insights into O'Donnell's fracture mechanics methodology and would result in substantial harm to the competitive position of O'Donnell.

9.

The Document contains proprietary information which is held in confidence by O'Donnell and is not available in public sources.

10. In accordance with O'Donnell policies governing the protection and control of information, proprietary information contained in the Document has been made available, on a limited basis, to others outside O'Donnell only as required and under suitable agreement providing for nondisclosure and limited use of the information.

11. O'Donnell policy requires that proprietary information be kept in a secured floor area and distributed on a need-to-know basis.

12. Information in this Document provides insight into O'Donnell's fracture mechanics methodology as well as the strategy for this application.

f. -e AFFIDAVIT Page 3 Assuming a competitor had available the same background data and incentives as O'Donnell the competitor might, at a minimum, develop the information for the same expenditure of manpower and money as O'Donnell, THAT the statements made hereinabove are, to the best of my knowledge, information and belief, truthful and complete.

FURTHER AFFIANT SAYETH NOT.

Sworn to and subscribed before me this 26 day of October, 1990

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