CNRO-2004-00017, Arkansas, Unit 1 - Request for Alternative ANO1-R&R-005, Proposed Alternative to ASME Weld Examination Requirements for Repairs Performed on Reactor Vessel Head Penetrations

Arkansas, Unit 1 - Request for Alternative ANO1-R&R-005, Proposed Alternative to ASME Weld Examination Requirements for Repairs Performed on Reactor Vessel Head Penetrations

ML040760883
Person / Time
Site:	Arkansas Nuclear
Issue date:	03/10/2004
From:	Burford F Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ANO1-R&R-005, CNRO-2004-00017
Download: ML040760883 (6)

Text

Entergy Operations, Inc.

- Entergy 1340 Echelon Parkway Jackson. Mississippi 39213-8298 Tel 601-368-5758 F. G. Burford Acting Director Nuclear Safety & Licensing CNRO-2004-00017 March 10, 2004 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Request for Alternative ANO1-R&R-005 -

Proposed Alternative to ASME Weld Examination Requirements for Repairs Performed on Reactor Vessel Head Penetrations Arkansas Nuclear One, Unit 1 Docket No. 50-313 License No. DPR-51

REFERENCE:

Entergy Operations, Inc. Letter No. CNRO-2004-00006 to the NRC dated March 4, 2004

Dear Sir or Madam:

In the referenced letter, Entergy Operations, Inc. (Entergy) submitted to the NRC staff a revision to Request for Alternative ANO1-R&R-005, Rev. 0 for use at Arkansas Nuclear One, Unit 1 (ANO-1). In a telephone call conducted on March 1, 2004, to discuss this revised submittal, the NRC staff requested that Entergy provide a copy of Framatome Document 51-5021608, Corrosion Evaluation of AN01 CRDM IDTB Weld Repair, which supports the request. This calculation is contained in Enclosure 1.

Framatome-ANP, the owner of the calculation, considers information contained in Framatome Document 51-5021608 to be proprietary and confidential pursuant to 10 CFR 2.390(a)(4) and 10 CFR 9.17(a)(4). As such, Framatome has requested that this document be withheld from public disclosure. The affidavit supporting this request is provided in Enclosure 2.

Framatome has also informed Entergy that they consider the vast majority of information contained in the document to be proprietary; therefore, a nonproprietary version was not provided.

CNRO-2004-00017 Page 2 of 2 Should you have any questions regarding this letter, please contact Guy Davant at (601) 368-5756.

This letter contains no commitments.

Very truly yours, xe 5 f/1 FGB/GHD/ghd

Enclosures:

1. Framatome Document 51-5021608 (Proprietary Information)

2. Affidavit for Withholding Information from Public Disclosure cc: Mr. W. A. Eaton (ECH)

Mr. J. S. Forbes (ANO)

Dr. Bruce S. Mallett, Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Arkansas Nuclear One P. 0. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. T. W. Alexion MS 0-7 D1 Washington, DC 20555-0001

ENCLOSURE 2 CN RO-2004-0001 7 AFFIDAVIT FOR WITHHOLDING INFORMATION FROM PUBLIC DISCLOSURE

AFFIDAVIT COMMONWEALTH OF VIRGINA )

) ss.

CITY OF LYNCHBURG )

1. My name is James F. Mallay. I am Director, Regulatory Affairs, for Framatome ANP ("FANP"), and as such I am authorized to execute this Affidavit.

2. i am familiar with the criteria applied by FANP to determine whether cert in FANP information is proprietary. I am familiar with the policies established by FANP to ensure the proper application of these criteria.

3. 1am familiar with the information contained in the document 'Corrosion Evalaution of ANO1 CRDM IDTB Weld Repair," 51-5021608-02, which is being sent to the I RC by Entergy Operations as an enclosure to its letter, CNRO-2004-00017. This report is referred to herin as"Document." Information contained in this Document has been classified by FA NP as proprietary in accordance with the policies established by FANP for the control and protection of proprietary and confidential information.

4. This Document contains information of a proprietary and confidential nat re and is of the type customarily held in confidence by FANP and not made available to the p blic.

Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.

5. This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure.

6. The following criteria are customarily applied by FANP to determine whether information should be classified as proprietary:

(a) The information reveals details of FANP'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 FANP.

(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for FANP in product optimization or marketability.

(e) The information is vital to a competitive advantage held by FANP, would be helpful to competitors to FANP, and would likely cause substantial harm to the competitive position of FANP.

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

8. FANP policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.

9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.

SUBSCRIBED before me this__

day of Aj 2 2004.

Ella F. Carr-Payne NOTARY PUBLIC, STATE OF VIRGINIA MY COMMISSION EXPIRES: 8/31/05 ELLA F.CARR-PAYNE Notary Public Commonwealth of Virginia My Comimssin Exps. Aug. 31,20