1CAN071406, Unit 1, Revised Affidavit for the Time-Limited Aging Analysis Regarding Reactor Vessel Internals Loss of Ductility

Unit 1, Revised Affidavit for the Time-Limited Aging Analysis Regarding Reactor Vessel Internals Loss of Ductility

ML14216A510
Person / Time
Site:	Arkansas Nuclear
Issue date:	07/30/2014
From:	Pyle S Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
1CAN071406
Download: ML14216A510 (6)

Text

Entergy Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-4704 Stephenie L. Pyle Manager, Regulatory Assurance Arkansas Nuclear One 1CAN071406 July 30, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Revised Affidavit for the Time-Limited Aging Analysis Regarding Reactor Vessel Internals Loss of Ductility Arkansas Nuclear One - Unit 1 Docket No. 50-313 License No. DPR-51

REFERENCE:

Entergy letter dated May 6, 2014, "Time-Limited Aging Analysis Regarding Reactor Vessel Internals Loss of Ductility for Arkansas Nuclear One, Unit 1 at 60 Years," (1CAN051401) (ML14126A816)

Dear Sir or Madam:

By the referenced letter, Entergy Operations, Inc. (Entergy) submitted the Arkansas Nuclear One, Unit 1 specific time-limited aging analysis for the loss of ductility of the reactor vessel internals. This analysis demonstrates that the internals will meet the deformation limits at the expiration of the renewed license.

The submitted analysis is considered to be proprietary to AREVA, Inc. AREVA, Inc. requests that the proprietary information be withheld from public disclosure in accordance with 10 CFR 2.390. AREVA, Inc. provided Entergy with authorization to provide the proprietary information. An affidavit by the information owner, AREVA, Inc., supporting the request for non-disclosure was attached to the reference submittal. Entergy requested the submitted analysis be withheld from public disclosure in accordance with 10 CFR 2.390. Proprietary and non-proprietary versions of the analysis were included in the submittal.

During the review of the submittal, the NRC had questions concerning the affidavit. This resulted in the need to provide a revised affidavit. The revised affidavit from AREVA, Inc. is attached.

This does not affect the proprietary or non-proprietary versions of the previous submitted analysis.

1CAN071406 Page 2 of 2 This letter contains no new regulatory commitments.

If you have any questions or require additional information, please contact me.

Sincerely, ORIGINAL SIGNED BY STEPHENIE PYLE SLP/rwc

Attachment:

Revised 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.O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Peter Bamford MS O-8B3 One White Flint North 11555 Rockville Pike Rockville, MD 20852

Attachment to I CAN071406 Revised Affidavit

AFFIDAVIT COMMONWEALTH OF VIRGINIA )

) ss.

CITY OF LYNCHBURG )

1. My name is Gayle F. 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 licensing document ANP-3281 P, Revision 1, entitled, "Time-Limited Aging Analysis Regarding Reactor Vessel Internals Loss of Ductility for Arkansas Nuclear One Unit I at 60 Years," dated March 2014 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA for the control and protection of proprietary and confidential information.

4. This Document contains 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 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. The request for withholding of proprietary information is 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 this Document is considered proprietary for the reasons set forth in paragraphs 6(c), 6(d) and 6(e) above.

7. In accordance with AREVA'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 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.

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

SUBSCRIBED before me this day of 0 2014.

Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/14 Reg. # 7079129 SHERRY L. MACFADEN Notary Public Commonwealth of Virginia 7079129 My Commission Expires Oct31 2014

' -vp Oc 31. 2014