1CAN031504, Arkansas Nuclear One, Unit 1 - Responses to Request for Additional Information on Update of the Reactor Coolant System Pressure and Temperature and the Low Temperature Overpressure Protection System Limits

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Arkansas Nuclear One, Unit 1 - Responses to Request for Additional Information on Update of the Reactor Coolant System Pressure and Temperature and the Low Temperature Overpressure Protection System Limits
ML15086A023
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 03/25/2015
From: Browning J G
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15086A019 List:
References
1CAN031504
Download: ML15086A023 (7)
v • d • e


Text

'% Entergy Entergy Operations, Inc.1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Jeremy G. Browning Vice President

-Operations Arkansas Nuclear One 1 CAN031504 March 25, 2015 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Responses to Request for Additional Information Update the Reactor Coolant System Pressure and Temperature and the Low Temperature Overpressure Protection System Limits Arkansas Nuclear One, Unit 1 Docket No. 50-313 License No. DPR-51

REFERENCES:

1. Entergy letter to NRC, "License Amendment Request Update the Reactor Coolant System Pressure and Temperature and the Low Temperature Overpressure Protection System Limits," dated November 21, 2014 (1CAN111401) (ML14330A249)
2. NRC email to Entergy dated March 20, 2015, "Arkansas Nuclear One, Unit No. 1, Request for Additional Information (2 nd Round) License Amendment Request (TAC No. MF5292)"

Dear Sir or Madam:

In accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR)Section 50.90, Entergy Operations, Inc. (Entergy) submitted a request for an amendment to the Arkansas Nuclear One, Unit 1 (ANO-1) Technical Specifications (TS) to revise the Reactor Coolant System Pressure and Temperature (P/T) Limits (TS 3.4.3); Pressurizer (TS 3.4.9);Pressurizer Safety Valves (TS 3.4.10); and Low Temperature Overpressure Protection (LTOP)System (TS 3.4.11) requirements (Reference 1). The proposed changes would extend the applicability of the limits from 31 Effective Full Power Years (EFPY) to 54 EFPY.In the course of its review, the NRC staff has determined that additional information is required to complete its evaluation of the request (Reference 2). Entergy's response to the NRC's request for additional information (RAI) is included in attachment to this letter.Attachments I and 3 to this letter contains proprietary information

-Attachments I and 3 are withheld from public disclosure per 10 CFR 2.390 A6b(

I CAN031504 Page 2 of 3 AREVA document ANP 3300Q3P, Revision 0, "Response to Request for Additional Information on Reactor Coolant System Pressure/Temperature and Low Temperature Overpressure Protection System Limits to 54 EFPY for Arkansas Nuclear One, Unit 1" has been prepared with the response to the request. The information contained in the AREVA document is considered proprietary to AREVA. Attachment 1 is the proprietary version of the document.A non-proprietary version of the AREVA document is included in Attachment 2.During a conference call on March 23, 2015, the NRC requested a copy of the AREVA LTOP calculation.

Attachment 3 is a copy of AREVA's proprietary calculation 32-9220706-002,"ANO-1 LTOP P-T Limits for 54 EFPY". A non-proprietary version of this calculation is not available.

AREVA requests that the proprietary information provided in Attachments 1 and 3 be withheld from public disclosure in accordance with 10 CFR 2.390. AREVA has provided Entergy with authorization to provide the proprietary information.

An affidavit by the information owner, AREVA, supporting the request for non-disclosure is provided in Attachment

4. Therefore, Entergy requests that Attachments 1 and 3 of this submittal be withheld from public disclosure in accordance with 10 CFR 2.390.With respect to the original Entergy request, the information contained in this submittal has been evaluated and Entergy has determined that the assessment of the no significant hazards consideration provided in Reference 1 is not invalidated by this additional information.

In accordance with 10 CFR 50.91 (b)(1), a copy of this application is being provided to the designated Arkansas state official.No new commitments have been identified in this letter.If you have any questions or require additional information, please contact Stephenie Pyle at 479-858-4704.

I declare under penalty of perjury that the foregoing is true and correct.Executed on March 25, 2015.Sincerely, JGB/rwc Attachments 1 and 3 to this letter contains proprietary information

-Attachments 1 and 3 are withheld from public disclosure per 10 CFR 2.390 1 CAN031504 Page 3 of 3 Attachments

1. AREVA document ANP 3300Q3P, Revision 0, "Response to Request for Additional Information on Reactor Coolant System Pressure/Temperature and Low Temperature Overpressure Protection System Limits to 54 EFPY for Arkansas Nuclear One, Unit 1" PROPRIETARY
2. AREVA document ANP 3300Q3NP, Revision 0, "Response to Request for Additional Information on Reactor Coolant System Pressure/Temperature and Low Temperature Overpressure Protection System Limits to 54 EFPY for Arkansas Nuclear One, Unit 1" NON-PROPRIETARY
3. AREVA Calculation 32-9220706-002, "ANO-1 LTOP P-T Limits for 54 EFPY" PROPRIETARY
4. Affidavit cc: Mr. Marc L. Dapas Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 NRC Senior Resident Inspector Arkansas Nuclear One P. 0. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Ms. Andrea E. George MS O-8B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Bernard R. Bevill Arkansas Department of Health Radiation Control Section 4815 West Markham Street Slot #30 Little Rock, AR 72205 Attachments I and 3 to this letter contains proprietary information

-Attachments I and 3 are withheld from public disclosure per 10 CFR 2.390 Attachment 4 to 1CAN031504 Affidavit For Information Only AFFIDAVIT COMMONWEALTH OF VIRGINIA )) ss.CITY OF LYNCHBURG

)1. My name is Gayle Elliott. I am Manager, Product Licensing, for AREVA Inc.(AREVA) and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.

I am familiar with the policies established by AREVA to ensure the proper application of these criteria.3. I am familiar with the AREVA information contained in the documents ANP-3300Q3P, Revision 0, entitled, "Response to Request for Additional Information on Reactor Coolant System Pressure/Temperature and Low Temperature Overpressure Protection System Limits to 54 EFPY for Arkansas Nuclear One, Unit 1," and 32-9220706-002, entitled, "ANO-1 LTOP P-T Limits for 54 EFPY," both dated March 2015 and referred to herein as "Documents." Information contained in these Documents has been classified by AREVA as proprietary in accordance with the policies established by AREVA Inc. for the control and protection of proprietary and confidential information.

4. These Documents contain information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in these Documents as proprietary and confidential.
5. These Documents have been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in these Documents be withheld from public disclosure.

The request for withholding of proprietary information is For Information Only made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information." 6. The following criteria are customarily applied by AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA's research and development plans and programs or their results.(b) Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.(c) The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for AREVA.(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability.(e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA.The information in these Documents is considered proprietary for the reasons set forth in paragraphs 6(c), 6(d) and 6(e) above.-7. Iniaccardanrce-ith-ARE policAies.gern

-_heprotecteion..ancl-cntrol of information, proprietary information contained in these Documents has been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. AREVA policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.j For Information Only 9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.'-, AL"Irb d-D SUBSCRIBED before me this day of VAXLrc , 2015.Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/18 Reg. # 7079129 m I SHERRY L MCFAVN Notay Publi convnm"U~m of virois 7071201 my0M~ ouINS"l horMs Oct 31. 2015 I J *
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