2CAN029707, Forwards non-proprietary Repts Re ANO-2 SG Cycle 12 Operational Assessment

Forwards non-proprietary Repts Re ANO-2 SG Cycle 12 Operational Assessment

ML20135D235
Person / Time
Site:	Arkansas Nuclear
Issue date:	02/26/1997
From:	Mims D ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20135D238	List: 2CAN029707, Forwards non-proprietary Repts Re ANO-2 SG Cycle 12 Operational Assessment ML20135D243 ML20135D248 ML20135D255 ML20135D259 ML20135D262
References
2CAN029707, 2CAN29707, TAC-M96481, NUDOCS 9703050143
Download: ML20135D235 (9)

Text

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February 26,1997 2CAN029707 U. S. Nuclear Regulatory Commission Document Control Desk Mail Stelion PI-137 Washington, DC 20555 l

Subject:

Arkansas Nuclear One - Unit 2 Docket No. 50-368 License No. NPF-6 Non-Proprietary' Reports Related to ANO-2 Steam Generator Cycle 12 Operational Assessment (TAC No. M96481)

Gentlemen:

On October 18,1996 (2CAN109605), Entergy Operations responded to a NRC Staff request for additional information (2CNA099602) related to an Arkansas Nuclear One, Unit 2 (ANO-2), steam generator operational assessment for cycle 12 operation. Four reports included as attachments to the October 18,1996, letter were considered to contain proprietary information (Attachments 3,4, 5, and 6). Subsequent to that submittal, the Staff requested that non-proprietary versions of these reporta be provided.

Non-proprietary versions of the four reports have been prepared and are attached to this letter utilizing the same attachment numbers as the October 18,1996, letter. TETRA report TR , 25 (included in Attachment 7 to the October 18, 1996, letter) is non-proprietary, but was marked as proprietary. This report is resubmitted with the proprietary designations remond.

An aflidavit is also enclosed for TETRA report TR-95-024 (Attachment 5 of the October 18, 1996, letter) because this report number was inadvertently omitted from the original aflidavit.

Additionally, Exhibit B of the aflidavit included with the October 18,1996, letter is attached.  !

This exhibit, which lists the reasons for public withholding of the proprietary versions of the v[/

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reports, w:a not transmitted with the originalletter. /

In November 1996, ANO-2 experienced a forced outage (2F96-1). During this outage, an pq extensive inspection of the steam generator tubes was performed, as documented in Entergy Operations' submittal dated December 30,1996 (2CAN129613). The completion of this inspection during the 12th cycle obviates the need for continued Staff review of the full cycle operational assessment contained in Entergy Operations' previous submittals.

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1 U. S. NRC February 26,1997 2CAN029707 Page 2 i-l If you have any questions concerning this submittal, please contact me.

Very truly yours, ko#

Dwight C. Mims N/A '

Director, Nuclear Safety i

i DCMSjd  ;

l attachments cc: Mr. Leonard J. Callan -

Regional Administrator ,

U. S. Nuclear Regulatory Commission l

! Region IV 1 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London, AR 72847 l

t Mr. George Kalman NRR Project Manager Region IV/ANO-1 & 2 i U. S. Nuclear Regulatory Comnussion  ;

NRR Mail Stop 13-H-3 l One White Flint North 11555 Rockville Pike Rockville, MD 20852 i

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. AFFIDAVIT OF DAVID S. MOELLING i

AFFIDAVIT OF DAVID S. MOELLING A. My name is David S. Moeiling. I am Treasurer for Tetra Engineering Group, Inc. (TETRA), and as such I am authorized to execute this Affidavit.

B. I am familiar with the criteria applied by TETRA to determine whether certain information of TETRA is proprietary and I am familiar with the procedures established within TETRA to unsure the proper application of these criteria.

C. In determining whether a TETRA document is to be classified as proprietary information, an initial determination is made by the Principal, who is responsible for originating the document, as to whether it falls within the criteria set forth in Paragraph D hereof. If the information falls within any one of these criteria, it is classified as proprietary by the originating Principal. This initial determination is reviewed by the Manager, Quality Assurance to assure that the regulatory requirements of 10 CFR j Section 2.790 are met.

D. The following information is provided to demonstrate that the provisions of 10 CFR Section 2.790 of the Commission's regulations have been considered:

(i) ne information has been held in confidence by TETRA. Copies of the document are clearly identified as proprietary, in addition, whenever TETRA transmits the information to a customer, customer's agent, potential customer or regulatory agency, the transmittal requests the recipient to hold the information as proprietary.

(ii) ne following criteria are customarily applied by TETRA in a rational decision process to determine whether the information should be classified as proprietary. Information may be classified as proprietary if one or more of the following criteria are met:

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a. Information reveals cost or price information, commercial strategies, production capabilities, or i budget levels of TETRA, its customers or suppliers.

b. The information reveals data or material concerning TETRA research or development plans or programs of present or potential competitive advantage to TETRA.

c. The use of the information by a competitor would decrease his expenditures, in time or resources, in designing, producing or marketing a similar product.

d. The information consists of test data or other similar data concerning a process, method or ,

component, the application of which results in a competitive advantage to TETRA.

e. He infonnation reveals special aspects of a process, method, component or the like, the exclusive use of which results in a competitive advantage to TETRA.

f. The information contains ideas for which patent protection may be sought.  !

The document (s) listed on Exhibit "A", which is attached hereto and made a part hereof, has been  !

evaluated in accordance with normal TETRA procedures with respect to classification and has I been found to contain information which falls within one or more of the criteria enumerated )

above. Exhibit "B", which is attached hereto and made a part hereof, specifically identifies the criteria applicable to the documents (s) listed in Exhibit "A" (iii) The document (s) listed in Exhibit "A", which has been made available to the United States Nuclear Regulatory Commission was made available in confidence with a request that the document (s) and the information contained therein be withheld from public disclosure.

(iv) ne information is not available in the open literature and to the best of our knowledge is not ,

known by ABB Combustion Engineering Nuclear Power, B&W/Framatome Technologies, Inc.,

i Westinghouse Nuclear Service Division, Aptech Engineering Services, Dominion Engineering or the Electric Power Research Institute or other current or potential domestic or foreign competitors of TETRA .

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AFFIDAVIT OF DAVID S. MOELLING l

(v) Specific information with regard to whether public disclosure of the information is likely to cause .

harm to the competitive position of TETRA, taking into account the value of the information to TETRA; the amount of effort or money expended by TETRA developing the information; and the .

case or difriculty with which the information could be properly duplicated by others is given in j 4

Exhibit "B".

f E. I have personally reviewed the document (s) listed on Exhibit "A" and have found that is considered I q proprietary by TETRA because it contains information which falls within one or more of the criteria

. enumerated in Paragraph D, and it is information which is customarily held in confidence and ,

protected as proprietary information by TETRA. This report comprises information utilized by  !

TETRA in its business which afford TETRA an opportunity to obtain a competitive advantage over those who may wish to know or use the information contained in the document (s),

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1 DAVID S. MOELLING l

David S. Moelling, being duly sworn, on his oath deposes and says that he is the person 1 who subscribed his name to the foregoing statement, and that the matters and facts set forth in the statement are true.

DAVID S. MOELLING Subscribed and sworn before me g .

i this 21st day of January,1997. -

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Notary Public M t.A y p kLYflool

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AFFIDAVIT OF DAVID S. MOELLING l l

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Exhibit A  !

l. "ANO Unit 2 Stem Generator Tubes Evaluation of Burst Pressures with 4

Circumferential Flaws Present", TR-95-024, April 11,1996. i

,. r Exhibit B -

I Tiu bases for classifying this report as proprietary are:  !

ii.  ;

b. 'Ihe information reveals data or material concerning TETRA research or development plans or programs l of present or potential competitive advantage to TETRA. l

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c. The use of the infonnation by a competitor would dec.ee his expenditures, in time or resources, in designing, producing or marketing a similar product. )

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d. The information consists of test data or other similar data concerning a process, method or component, l the application of which results in a competitive advantage to TETRA.

e. The information reveals special aspects of a process, method, component or the like, the exclusive use of which results in a competitive advantage to TETRA.

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EXHIBIT "B" TO AFFIDAVIT INCLUDED IN OCTOBER 18,1996 LETTER (2CAN109605) FOR PROPRIETARY REPORTS TR-96-007, REV.1 TR-96-005, REV.1

, TR-96-021, REV. O  ;

The documents listed in Exhibit "A" contain information of a proprietary nature which, if disclosed to competitors, could result in irreoarable harm to the financial interest of l TETRA ENGINEERING GROUP.

i The documents listed in Exhibit "A" contain trade secrets and information developed by TETRA ENGINEERING GROUP to justify operating cycles for nuclear power plants with CE-design steam generator tubes with stress corrosion cracking.

These trade secrets and information have been held in confidence by TETRA ENGINEERING GROUP and is not available in public sources. Public disclosure of the information in the documents in Exhibit "A" is likely to cause substantial harm to the  !

competitive position of TETRA ENDPMERING GROUP.  !

These information and trade secrets have been under development by TETRA ENGINEERING GROUP since 1990. Over 50.5 million dollars has been spent by TETRA ENGINEERING to develop these trade secrets.

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ATTACHMENT 1 l 1

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ATTACIIMENT 2 BLANK 4

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ATTACHMENT 3 TR-96-007, REV.1 NON-PROPRIETARY l

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