0CAN092101, Unit 2 - Revised Proprietary Demarcation in Response to Request for Additional Information (Follow-up) - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond Supply Piping

Unit 2 - Revised Proprietary Demarcation in Response to Request for Additional Information (Follow-up) - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond Supply Piping

ML21257A455
Person / Time
Site:	Arkansas Nuclear
Issue date:	09/14/2021
From:	Gaston R Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML21257A454	List: 0CAN092101, Unit 2 - Revised Proprietary Demarcation in Response to Request for Additional Information (Follow-up) - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond Supply Piping
References
0CAN092101
Download: ML21257A455 (27)

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 601-368-5138 Ron Gaston Director, Nuclear Licensing 10 CFR 50.55a(z)(1) 0CAN092101 September 14, 2021 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Revised Proprietary Demarcation in Response to Request for Additional Information (Follow-up) - 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), "Response to Request for Additional Information (Follow-up) - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond (ECP) Supply Piping,"

Arkansas Nuclear One, Units 1 and 2 (ML21203A198) (0CAN072102), dated July 22, 2021.

By the referenced submittal, Entergy Operations, Inc. (Entergy), provided the follow-up responses to the Request for Additional Information associated with the proposed alternative to American Society for Mechanical Engineers 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). Subsequent to the submittal, Entergy was asked to review the proprietary demarcations in the submittal to determine if they were too conservative.

As a result of this review, the proprietary markings were revised. The complete responses are provided in Enclosure 1. It should be noted that the only change between Enclosure 1 and the reference responses is where the brackets denoting proprietary material are located.

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.

0CAN092101 Page 2 of 3 The response to the additional supplemental information provided in Enclosure 1 is considered proprietary to Structural Group, Inc., and is to be withheld from public disclosure in accordance with 10 CFR 2.390 of the Commissions regulations. The non-proprietary version is provided in .

This information is supported by affidavit, signed by Structural Group, Inc. the owner of the information. The affidavit 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 Structural Group, Inc. letter to the NRC entitled, "Application for Withholding Proprietary Information from Public Disclosure." The Structural Group, Inc. 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.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on September 14, 2021.

Respectfully, Digitally signed by Ronald W.

Ronald W. Gaston Gaston Date: 2021.09.14 14:03:42 -05'00' Ron Gaston RWG/rwc

Enclosures:

1. Response to Final Supplemental Request for Additional Information related to Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of ECP Supply Piping in accordance with 10 CFR 50.55a(z)(1) (Proprietary)

2. Response to Final Supplemental Request for Additional Information related to Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of ECP Supply Piping in accordance with 10 CFR 50.55a(z)(1) (Non-Proprietary)

3. Structural Group Application for Withholding Proprietary Information from Public Disclosure 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.

0CAN092101 Page 3 of 3 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 0CAN092101 Response to Final Supplemental Request for Additional Information related to Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of ECP Supply Piping in accordance with 10 CFR 50.55a(z)(1)

(Non-Proprietary)

0CAN092101 Page 1 of 16 RESPONSE TO FINAL SUPPLEMENTAL REQUEST FOR ADDITIONAL INFORMATION RELATED TO PROPOSED ALTERNATIVE TO ASME SECTION XI REQUIREMENTS FOR REPAIR/REPLACEMENT OF ECP SUPPLY PIPING IN ACCORDANCE WITH 10 CFR 50.55A(Z)(1)

(NON-PROPRIETARY)

By letter dated July 15, 2020 (Reference 1), Entergy Operations, Inc. (Entergy), requested NRC approval of a proposed alternative to American Society for Mechanical Engineers (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). During the course of review, the NRC determined that additional information is needed to support completing the review process (Reference 2). Entergy provided responses to the Request for Additional Information (RAI) (Reference 3). To complete its review, the NRC staff requested additional supplement information to NRC Mechanical Engineering and Inservice Testing Branch (EMIB)

EMIB-RAI-10 (Reference 4). The request for additional supplemental information and associated Entergy response is included in the attached enclosure.

Proprietary information is identified by text enclosed within double brackets ((Example)).

EMIB-2-RAI-1

((

))

0CAN092101 Page 2 of 16 Entergy Response:

For the purposes of this response the following definitions are provided:

((

))

Tmax is defined as the faulted maximum achievable ECP Supply system piping water temperature of 121 °F. Typical operating temperature range is 32 °F to 101 °F. The maximum faulted temperature of 121 °F peaks above 120 °F for a short duration of less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The acceptance criteria for ((

))

As shown on Figures 2, 3, and 4, and as discussed below, a (( )) margin above Tmax (121

°F) will keep V-Wrap' 770 epoxy in the glassy phase.

General Design Criteria - Material Properties

(( )) is a general design criterion for the initial selection of an epoxy material for use at ANO. (( )) for an epoxy and depends on the American Society for Testing and Materials (ASTM) test method, specified ((

)). Using ASTM E1640 test methods (( )) for V-Wrap' 770 epoxy is (( )) °F. Based on ASTM E1640 test results for the initial selection of the epoxy material V-Wrap' 770 epoxy meets the general design criterion for ANO:

(( )) °F) > Tmax (121 °F) + (( )) °F = (( )) °F

0CAN092101 Page 3 of 16 Material Behavior Figure 1 below shows the theoretical behavior of an amorphous thermoplastic epoxy based on an ASTM E1640, Dynamic Mechanical Analysis (DMA) testing protocol. At lower temperatures, the epoxy remains in a glassy state. At the glass transition temperature, the epoxy becomes leathery and at a higher temperature it behaves like a soft elastic rubber.

Figure 1 (Reference 5)

0CAN092101 Page 4 of 16 V-Wrap' 770 (( ))

Figures 2, 3 and 4 provide (( )) test results for V-Wrap' 770 epoxy (( )). Results from these (( ))

laboratory tests demonstrate that V-Wrap' 770 epoxy ((

)) for the maximum achievable system temperature of 121 °F (Tmax) at ANO. These test temperatures ((( )) °F, (( )) °F and

(( )) °F) bound the design basis, normal operating, and maximum achievable temperatures for this system at ANO which has a typical operating temperature range of 32 °F to 101 °F. The installed CFRP composite system will be cured as determined by ANO specific ((

)). The maximum faulted temperature used for the ANO CFRP composite system design is 121 °F. ANO design basis calculations indicate the system temperature peaks at 120 °F for a short duration of less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The ((

)) °F (Minimum). This approach ensures V-Wrap' 770 epoxy ((

)) at ANO using the criterion (( )) °F.

Figure 2 - V-Wrap' 770 epoxy cured at (( )) °F

((

))

0CAN092101 Page 5 of 16 Figure 3 - V-Wrap' 770 epoxy (( )) °F

((

))

0CAN092101 Page 6 of 16 Figure 4 - V-Wrap' 770 epoxy (( )) °F

((

))

Glass Transition Temperature Summary

(( )) are acceptable for ANO.

(( )) for V-Wrap' 770 epoxy (( )) in the initial design process (( )):

(( )) °F.

As demonstrated by (( )) previously performed V-Wrap' 770 epoxy cured at a (( )) and will not behave (( )) at the maximum achievable system temperature of 121°F (Tmax) and satisfies the acceptance criterion:

(( ))

((

0CAN092101 Page 7 of 16

))

Entergy Response Material properties are initially determined to support the (( )) and are included in Enclosure 4, Attachment B of Reference 1, "Material Qualification and Testing",

Tables 1, 2, and 3. These test results represent the ((

)). These tests are performed at ((

)), or at other conditions as specified in the relevant standards.

As presented in Figure 5, below the (( )) requires these ((

)) of (( )) and (( )) to be controlled as ((

)).

Figure 5 (( ))

((

))

(( )) for (( )) are ((

)) as the V-Wrap' CFRP composite system installed in the pipeline. (( )) have demonstrated that ((

0CAN092101 Page 8 of 16

)) the maximum achievable temperature (Tmax = 121 °F) for ANO.

((

))

Entergy Response

(( )) will be performed on the witness panels cured at the ((

)) at those temperatures.

((

))

Entergy Response The information presented at the ASME Code Committee meeting was ((

)) to the V-Wrap' CFRP Composite System proposed at ANO. As discussed in the response to EMIB-2-RAI-1(A) the initial design criterion that uses a margin of (( )) °F is (( )) °F. (( ))

is used to evaluate if V-Wrap' 770 epoxy is suitable for the ANO application by comparing

0CAN092101 Page 9 of 16

(( )) with the ((

)).

(( )) will be used to determine the ((

`

)). V-Wrap' 770 epoxy ((test samples prepared in the field will be cured at a minimum of 90 °F throughout the pipe, and a minimum of 121 °F at the terminal ends)).

V-Wrap 770 epoxy will be verified ((

)) by ((

)). Preliminary data and the (( )) testing methods presented in the ASME Code Committee meeting are representative of the (( )) that will be used for the ANO CFRP composite system.

((

))

Entergy Response When the system is placed in-service, the epoxy will ((

)). See response to EMIB-2-RAI-1(A) which demonstrates based on Tg_Field previous test results V-Wrap' 770 epoxy ((will not transition out of the glassy phase and will not behave in a viscous manner)). The installed CFRP composite system will be cured as determined by ANO ((

` `` )) °F. At the (( )), the installed CFRP composite system will be (( )) °F.

Tests results can be made available.

Tmax of 121 °F at ANO conservatively bounds all of the design basis and severe accident conditions. Typical operating temperature range is 32 °F to 101 °F. Tmax (121 °F) is defined as the faulted maximum achievable ECP Supply system piping water temperature. The maximum faulted achievable temperature of 121 °F is based on calculations that show a temperature peak above 120 °F for a short duration of less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

((

0CAN092101 Page 10 of 16

))

Entergy Response

((

)) defined by the ANO design basis conditions to ensure V-Wrap' 770 epoxy remains (( )) the performance criterion

(( )) °F.

((

))

Entergy Response The ((

)). The installed CFRP composite system ((

)) °F. At the

(( )), the installed CFRP composite system ((

)) °F. The cure temperature and durations used in the field will achieve the required minimum 85% degree of cure which will be verified using (( )) testing. Tests results will be available.

((

))

Entergy Response

((

)).

Witness panels will be ((

)). The witness panels ((

))

0CAN092101 Page 11 of 16

((

))

Entergy Response

(( ))

will be tested per the ((

))

((

))

Entergy Response As previously stated in response to EMIB RAI-9 (Reference 4), the ((

)). The (( )) will not be required since the terminal end zones will be (( )).

The design calculations previously submitted in Enclosure 5 of Reference 1 ((

)). See response to EMIB-2-RAI-1(A).

The CFRP repair is acceptable for (( )). This is demonstrated through ((

))

The NRC provided additional requests for information via Reference 7. These additional requests and Entergy's responses are provided below.

((

0CAN092101 Page 12 of 16

))

Entergy Response

(( )):

(( )) in the design process since the design calculations provided in Enclosure 5, Attachment C of Reference 1, "Sample Calculations" (( )) of the CFRP composite.

Overlap Shear Strength:

There are currently ((

)) testing performed for V-Wrap' 770 epoxy indicates that (( )). As described in , Attachment D of Reference 1, "Design Illustrations", ((

)).

Shear Bond Strength (CFRP to Metal)

(( )) at the terminal ends. At the terminal ends the installed CFRP composite system ((

))

((

))

Entergy Response As stated in the response to EMIB-2-RAI-1, at ANO the ((

)) °F. Results of the design basis analysis at ANO calculated Tmax to be 121 °F. ((

)) °F. As shown on Figures 2, 3, and 4, and discussed in the response to EMIB-2-RAI-1, (( )) V-Wrap' 770 epoxy in the

(( )).

0CAN092101 Page 13 of 16 The (( )) specimens will be considered in the ((

)).

The determination of ((

)). There is ((

)).

As shown in the figure below, V-Wrap' 770 epoxy has ((

)). At ANO ((

)). Use of the (( )) Tg from V-Wrap' 770 epoxy ((

))

0CAN092101 Page 14 of 16

((

))

Entergy Response

((

[ `

))

((

))

Entergy Response

((

))

((

))

Entergy Response As necessary to meet ((

)). Structural Technologies has reviewed the ((

)) are provided below. ((

0CAN092101 Page 15 of 16

)).

((

))

REFERENCES

1. Entergy Operations, Inc. (Entergy) letter to U. S. Nuclear Regulatory Commission (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 (ML20218A672)

(0CAN072001), dated July 15, 2020.

2. 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)," (ML21022A084)

(0CNA012105), dated January 22, 2021.

0CAN092101 Page 16 of 16

3. Entergy letter to NRC, "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 (ML21063A243)

(0CAN022101), dated February 22, 2021.

4. NRC email to Entergy, "Arkansas Nuclear One, Units 1 and 2 - Final Supplemental Request for Additional Information RE: Proposed Alternative to ASME Section XI Requirements for the Repair/Replacement of Emergency Cooling Pond Supply Piping (EPID L-2020-LLR-0104)," (ML21116A109) (0CNA042102), dated April 26, 2021.

5. ((

6.

))

7. NRC email to Entergy, "As discussed during the pre-submittal meeting related to the response to EMIB-2-RAI-1, Entergy is providing our understanding of the scope of the response for NRCs review and agreement," (0CNA062104), dated June 1, 2021.

8. ((

9.

))

Enclosure 3 0CAN092101 Structural Group Application for Withholding Proprietary Information from Public Disclosure (6 pages)

STRUCTURAL GROUP APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE August 26, 2021 U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD20852

Subject:

Application for Withholding Proprietary Information from Public

References:

1 Entergy Operations, Inc. (Entergy) letter to U. S. Nuclear Regulatory Commission (NRC), "Response to Request for Additional Information - Proposed Alternative to ASME Boiler & Pressure Vessel Code Section Xl 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 Commission (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 Final Supplemental Request for Additional Information RE: Proposed Alternative to ASME Section XI Requirements for the Repair/Replacement of Emergency Cooling Pond Supply Piping (EPID L-2020-LLR-0104)," (ML21116A109) (0CNA042102), dated April 26, 2021.

4. NRC email (Thomas Wengert) to Entergy (Robert Clark), dated August 17, 2021 @

6:44 AM, Subject "Proprietary Review of 7/22/21 RAI Response RE: CFRP Alternative Request."

Ladies and Gentlemen:

Structural Group, Inc.,(SGl) has provided certain proprietary information to Entergy Operations, Inc. (Entergy), in connection with a supplemental response by Entergy to EMIB-2-RAI-1 from the U.S. Nuclear Regulatory Commission (NRC). This application requests that the information provided to Entergy related to the NRC's request in Reference 4 for Entergy to review the proprietary portions of the response to EMIB-2-RAI-1 and resubmit with appropriate bracketed redactions in accordance with 10 CFR 2.390 be withheld as SGI proprietary information.

The proprietary information for which withholding is being requested 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 Page 1 of 6

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.

Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Entergy.

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, Structural Group, Inc., 10150 Old Columbia Road, Columbia, MD 21046.

Scott Greenhaus Executive Vice President O (410) 859-6458, M (410) 340-3205 SGreenhaus@structuralqroup.com Page 2 of 6

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 SGI'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 response provided by Entergy (Docket Nos. 50-313 and 50-368) to the NRC's request in Reference 4 to review the proprietary portions of the response to EMIB-2-RAl-1 and resubmit with appropriate bracketed redactions in accordance with 10 CFR 2.390 includes SGI proprietary information.

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 SGI'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, as follows:

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.

Page 3 of 6

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 competitors.

It is, therefore, withheld from disclosure to protect SGI's competitive position.

2) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes SGI's ability to sell products and services involving the use ofthe 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) SGI'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 public 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 response to the NRC RAI (EMIB-2-RAI-1) being transmitted by Entergy letter (Docket Nos. 50-313/368) and reflected in SGI'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 Xl 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 provide 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 SGI'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.

Page 4 of 6

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

4) Public disclosure of this proprietary information is likely to cause substantial harm to the 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.

Page 5 of 6

AFFIDAVIT 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 are true and correct to the best of his knowledge, information, and belief.

Scott Greenhaus Executive Vice President Sworn to and subscribed before me this 26th day of August 2021 Page 6 of 6