0CAN062101, Presentation Information for Pre-Submittal Meeting Regarding the Response to Request for Additional Information - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling

Presentation Information for Pre-Submittal Meeting Regarding the Response to Request for Additional Information - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling

ML21167A279
Person / Time
Site:	Arkansas Nuclear
Issue date:	06/15/2021
From:	Couture P Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML21167A278	List: 0CAN062101, Presentation Information for Pre-Submittal Meeting Regarding the Response to Request for Additional Information - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling
References
0CAN062101
Download: ML21167A279 (37)

Text

This letter contains proprietary information.

Withhold Enclosure 1 from public disclosure in accordance with 10 CFR 2.390.

Entergy Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5102 Phil Couture Sr. Manager, Fleet Regulatory Assurance 10 CFR 2.390 0CAN062101 June 15, 2021 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Presentation Information for Pre-Submittal Meeting Regarding the Response to Request for Additional Information - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond Supply Piping Arkansas Nuclear One, Unit 1 and Unit 2 NRC Docket Nos. 50-313 and 50-368 Renewed Facility Operating License Nos. DPR-51 and NPF-6

Reference:

Entergy Operations, Inc. (Entergy) letter to U. S. Nuclear Regulatory Commission (NRC), "Presentation Information for Pre-Submittal Meeting Regarding the Response to Request for Additional Information - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond Supply Piping," Arkansas Nuclear One, Units 1 and 2 (0CAN052103) (ML21144A087), May 25, 2021.

A meeting between Entergy Operations, Inc. (Entergy), Structural Group, Inc. (SGI), Simpson Gumpertz & Heger, Inc. and the U. S. Nuclear Regulatory Commission (NRC) was held on May 26, 2021, in order to discuss an NRC Request for Additional Information (RAI). The RAI is concerning the proposed alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond piping at Arkansas Nuclear One (ANO).

From preparation of the presentation material to be used in the meeting, it was determined that the material is proprietary to SGI. On that basis, the meeting on May 26, 2021, was closed to the public. The proprietary presentation was provided to the NRC via the referenced submittal.

This letter contains proprietary information.

Withhold Enclosure 1 from public disclosure in accordance with 10 CFR 2.390.

This letter contains proprietary information.

Withhold Enclosure 1 from public disclosure in accordance with 10 CFR 2.390.

0CAN062101 Page 2 of 2 In performing the proprietary review of the meeting slides, the NRC staff has determined that Entergy must submit a non-proprietary version of the slides in accordance with the requirements of 10 CFR 2.390 and the NRC staff guidance in LIC-204 Revision 1.

For completeness, the proprietary version of the presentation material used in the meeting is provided in Enclosure 1. These slides are considered proprietary to SGI and are to be withheld from public disclosure in accordance with 10 CFR 2.390 of the Commissions regulations. provides the non-proprietary version of the presentation material in accordance with the NRC's request.

This information is supported by affidavit, signed by Scott Greenhaus, Executive Vice President of SGI, the owners of the information. The affidavits set forth the bases by which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390 of the Commission's regulations. The affidavit is included in the SGI letter to the NRC entitled, "Application for Withholding Proprietary Information from Public EMIB-2-RAI-1 Pre-submittal Meeting". The SGI authorization letter is provided in Enclosure 3.

No new regulatory commitments are included in this submittal.

If there are any questions or if additional information is needed, please contact Riley Keele, Jr.,

Manager, Regulatory Assurance, Arkansas Nuclear One, at 479-858-7826.

Respectfully, ORIGINAL SIGNED BY PHIL COUTURE PC/rwc

Enclosures:

1. Presentation Material for May 26, 2021, Meeting (Proprietary)

2. Presentation Material for May 26, 2021, Meeting (Non-Proprietary)

3. SGI Application for Withholding Proprietary Information from Public cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector - Arkansas Nuclear One NRC Project Manager - Arkansas Nuclear One This letter contains proprietary information.

Withhold Enclosure 1 from public disclosure in accordance with 10 CFR 2.390.

Enclosure 2 0CAN062101 Presentation Material for May 26, 2021, Meeting (Non-Proprietary)

Entergy Nuclear Arkansas Nuclear One ASME B&PV Code Section XI Material Relief Request EMIB2RAI1 Response PUBLIC VERSION 1

Introductions

• Licensee Attendees

- Entergy/Arkansas Nuclear One - Licensee

• Bob Clark, Mark Reid (Regulatory Assurance)

• Terry Freeman, Mike Hedgecock (Projects)

• Vince Bond, Bob Thweatt, Dan Sojka, Ryan Brumwell (Engineering)

- Structural Technologies, LLC - CFRP Composite System

• Anna Pridmore, Emily Cernic, Leo Nadeau, Chris Burton

- Simpson Gumpertz & Heger (SGH) - CFRP Designer

• Rasko Ojdrovic PUBLIC VERSION 2

Agenda Topic Speaker Introductions NRC/ENTERGY Licensee Presentation Reason for Relief Request Definitions/Acceptance Criteria Mechanical Behavior ENTERGY

(( )) Test Results Cure Temperature Material Properties Summary Open Discussion NRC Meeting Adjournment PUBLIC VERSION 3

Reason for the Relief Request

• Piping systems constructed of similar materials and transporting similar water have experienced degradation.

• ASME B&PVC Section XI, Rules for InService Inspection of Nuclear Power Plant Components, Article IWA4000, subparagraph IWA4221(b)(1) states:

An item to be used for repair/replacement activitiesshall meet the Construction Code to which the original item was constructed.

• Entergy/ANO is submitting a relief request in accordance with 10 CFR 50.55a(z)(1) requesting approval to use a CFRP Composite System because CFRP was not a material available for use in the original construction codes (Entergy Letter No.

0CAN072001, dated July 15, 2020, ADAMS ML20218A672).

PUBLIC VERSION 4

Definitions NRC RAI: Explain why the minimum cure temperatures of 90 °F and 121 °F and the resultant Tg values are acceptable, even though the licensees Tg criteria (Tg Tmax + 40 °F) may not be met?

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PUBLIC VERSION 5

Acceptance Criteria for ANO

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PUBLIC VERSION 6

Material Behavior

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PUBLIC VERSION 7

(( )) Test Results

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PUBLIC VERSION 8

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PUBLIC VERSION 9

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PUBLIC VERSION 10

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PUBLIC VERSION 11

Cure Temperatures NRC RAI: Explain why the minimum cure temperatures of 90 °F and 121 °F and the resultant Tg values are acceptable, even though the licensees Tg criteria (Tg Tmax + 40 °F) may not be met?

((

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PUBLIC VERSION 12

Material Properties NRC RAI: Clarify whether the mechanical properties of the composite materials cured at 90 °F and 121 °F can meet the design criteria specified in Enclosure 4, Attachment B, Table 1, of the license amendment request (such as tensile, flexure and overlap shear strengths) at the maximum temperature (121 °F). If not, discuss why the material properties are acceptable.

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PUBLIC VERSION 13

Design Verification

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PUBLIC VERSION 14

Summary - Cure Temperature Effect

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PUBLIC VERSION 15

Cure Temperature Test Program Objective

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PUBLIC VERSION 16

Test Program

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PUBLIC VERSION 17

Test Sample in the (( ))

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PUBLIC VERSION 18

Conclusions from Test Program

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PUBLIC VERSION 19

Conclusions from Test Program

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PUBLIC VERSION 20

Test Program

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PUBLIC VERSION 21

Test Program

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PUBLIC VERSION 22

Conclusions from Test Program -((

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PUBLIC VERSION 23

Conclusions from Test Program -((

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PUBLIC VERSION 24

Summary

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PUBLIC VERSION 25

Summary

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PUBLIC VERSION 26

Open Discussion PUBLIC VERSION 27

Enclosure 3 0CAN062101 SGI Application for Withholding Proprietary Information from Public (6 pages)

struc*tura1 group May 21 , 2021 U .S. Nuclear Regulatory Commiss ion Document Control Desk 11555 Rockville Pike Rockville, MD20852

Subject:

Application for Withholding Proprietary Information from Public EMIB-2-RAl-1 Pre-submittal Meeting References :

1. Entergy Operations, Inc. (Entergy) letter to U. S. Nuclear Regu latory Commission (NRC) , "Response to Request for Additional Information - Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Emergency Cooling Pond (ECP) Supply Piping in accordance with 10 CFR 50.55a(z)(1) ," Arkansas Nuclear One, Units 1 and 2, NRC Docket Nos. 50-313 and 50-368 , Entergy letter no. 0CAN02201.

2. Entergy Operations, Inc. (Entergy) letter to U. S. Nuclear Regulatory Comm ission (NRC) , "Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Emergency Cooling Pond (ECP) Supply Piping in accordance with 10 CFR 50.55a(z)(1) ," Arkansas Nuclear One, Units 1 and 2 (0CAN072001 ) (ML20218A672).

3. NRC email to Entergy, "Arkansas Nuclear One, Units 1 and 2 - Request for Additional Information RE : Proposed Alternative to ASME Code Requirements for the Repair of Emergency Cooling Pond Piping (EPID L-2020-LLR-0104) ," (0CNA012105) .

4. NRC (Thomas Wengert) email to Entergy (Riley Keele) , April 26, 2021 at 6:54 AM ,

"ANO-1 and ANO-2 : Final Supplemental RAI RE : Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of ECP Supply Piping (EPID L-2020-LLR-0104)."

Ladies and Gentlemen:

Structural Group, lnc.,(SGI) has provided certain proprietary information to Entergy Operations, Inc. (Entergy) in connection with a pre-submittal meeting to review the response to EMIB-2-RAl-1 provided by the U.S . Nuclear Regulatory Comm ission (USN RC) in Reference 4. This application requests that SGI proprietary information provided in the pre-submittal meeting documents related to EMI B-2-RAl-1 be protected from public disclosure.

The proprietary information for which withholding is being requested is identified in the attached affidavit signed by the owner of the proprietary information, SGI , on behalf of itself and any wholly-owned subsidiaries or affiliated companies . An affidavit accompanies this letter, setting forth the basis on which the information may be withheld from public disclosure by the NRC and addressing with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390 of the NRC's regulations .

struc*tura1 group Accordingly , this letter authorizes the utilization of the accompanying Affidavit by Entergy.

l__

Correspondence with respect to the proprietary aspects of the Application or the Affidavit should reference this letter and be addressed to Scott Greenhaus, Executive Vice President, St ctural Group, Inc., 10150 Old Columbia Road , Columbia, MD 21046.

~cerely; Scott Green aus Executive Vice President 0 (410) 859-6458, M (410) 340-3205 SGreenhaus@structuralqroup.com

struc'turc11 group AFFIDAVIT I, Scott Greenhaus, am Executive Vice President of Structural Group, Inc. (SGI).

In my capacity as Executive Vice President I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in conjunction with nuclear plant licensing and rulemaking proceedings and am authorized to apply for its withholding on behalf of SGI and its affiliates.

I am making this Affidavit in conformance with the provisions of 10 CFR 2.390 of the U.S. Nuclear Regulatory Commission (NRC) regulations and in conjunction with SGl's Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

I have personal knowledge of the criteria and procedures utilized by SGI in designating information as a trade secret, privileged or as confidential commercial or financial information.

Pursuant to the provisions of paragraph (b) (4) of 10 CFR 2.390 of the NRC's regulations , the following is furnished for consideration by the NRC in determining whether the information sought to be withheld from public disclosure should be withheld .

The information sought to be withheld from public disclosure is owned by and has been held in confidence by SGI. The documents provided in the Entergy pre-submittal meeting with the USN RC in response to Reference 4 (EM IB-2-RAl-1) include SGI proprietary information and are requested to be protected from public disclosure.

The information is of a type customarily held in confidence by SGI and not disclosed to the public. SGI has a rational basis for determining the types of information customarily held in confidence by it and utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system provides a rational basis for maintaining confidentiality and justifies the NRC withholding the information from public disclosure.

Under SGl's system , information is held in confidence if it falls in one or more of several types , the release of which might result in the loss of an existing or potential competitive advantage , asfollows:

1) The information reveals the distinguishing aspects of a process (or component ,

structure, tool , method , etc.) where prevention of its use by a competitor of SGI without license constitutes a competitive advantage over other companies .

2) It consists of supporting data, including test data, relative to a process (or component, structure, tool , method , etc.), the application of which data secures a competitive economic advantage , e.g ., by optimization or improved marketability.

3) Its use by a competitor would reduce their expenditure of resources or improve their competitive position in the design , manufacture, shipment, installation, assurance of quality, or licensing a similar product.

4) It reveals cost or price information, production capacities , budget levels, or commercial strategies of SGI , their customers or suppliers.

5) It reveals aspects of past, present, or future development plans funded by SGI or its customer, and programs of potential commercial value to SGI.

6) It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the SGI system which include the following ;

1) The use of such information by SGI gives it a competitive advantage over

struc'tura1 group competitors. It is, therefore , withheld from disclosure to protect SGl 's competitive position.

2) It is information that is marketable in many ways . The extent to which such information is available to competitors diminishes SGl's ability to sell products and services involving the use of the information.

3) Use by a competitor would put SGI at a competitive disadvantage by reducing the competitor's expenditure of resources and capital.

4) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage.

If competitors acquire components of proprietary information , any one component may be the key to the entire process , thereby depriving SGI of its competitive advantage.

5) Unrestricted disclosure would jeopardize the position of prominence of SGI in the world marketplace , and thereby give a market advantage to competitor in those countries in which SGI operates.

6) SGl's capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

The information is being transmitted to the NRC in confidence and , under the provisions of 10 CFR 2.390, it is to be received in confidence by the NRC. The information sought to be protected is not available in publ ic sources and , to the best of our knowledge and belief, available information has not been previously employed in the same original manner or method.

The proprietary information sought to be withheld in this submittal is that which is appropriately marked in Entergy's responses to the NRC RAI (EMIB-2-RAl-1) being transmitted by Entergy letter (Docket Nos. 50-313/368) and reflected in SGl 's Application for Withholding Proprietary Information from Public Disclosure addressed to the NRC Document Control Desk. The proprietary information as submitted by SGI is that associated with the "Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond (ECP) Supply Piping for Entergy Arkansas Nuclear One (ANO) Units 1 and 2" (Reference 2) and may be used only for that purpose.

This information is part of that which will enable SGI to :

1) Provide input to Entergy to prov ide to the NRC for the ANO Units 1 and 2, RAI response ; and

2) Provide licensing support for the Entergy response.

SGI owns or is permitted to use the proprietary information referenced in this Affidavit under agreements that include SGl 's maintaining the confidentiality of such information , as contemplated in this Affidavit.

Further this information has substantial commercial value as follows ;

1) The SGI plan to sell the use of this information to their customers for the purpose of installing Carbon Fiber Reinforced Polymer (CFRP) in safety related piping.

2) That SGI can sell support and defense of the technology to their customers in the licensing process.

3) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by SGI.

4) Pub lic disclosure of th is proprietary information is likely to cause substantial harm to the

struclural group competitive position of SGI because it would enhance the ability of competitors to provide similar licensing services for commercial power reactors without commensurate expenses.

5) Public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

6) The development of the technology described in part by the proprietary information is the result of applying the results of many years of experience in an intensive effort by SGI and the expenditure of a considerable sum of money and resources. In order for competitors to duplicate this information , similar technical programs would have to be performed including a significant expenditure money and resources .

Further the deponent sayeth not.

struclural group struc'tural group AFF IDAVIT State of Maryland )

County of Howard )

Before me, the undersigned authority, personally appeared Scott Greenhaus, who , being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Structural Group, Inc. and that the averments of fact set forth in this Affidavit re true and correct to the best of his knowledge , information , and belief.

Scott Greenhaus Executive Vice President Sworn to and subscribed before me this 17th day of May 2021 N~~

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