ML16004A178

Evaluations Described Response to Requests for Additional Information 3, 5, 6(a), and 7, Reactor Vessel Internals Aging Management Program Plan

ML16004A178
Person / Time
Site:	Arkansas Nuclear
Issue date:	12/30/2015
From:	Pyle S Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML16004A183	List: 1CAN121502, Attachment 2, ANP-3418NP, Revision 0, Arkansas Nuclear One Unit 1 Reactor Vessel Internals License Renewal Scope and MRP-189, Revision 1 Comparison (MRP-227-A Action Item 2) Licensing Report. (Non-Proprietary) ML16004A178
References
1CAN121502
Download: ML16004A178 (7)

Text

SEntergy Mantgergy Operuations, AsuInc.

1448sa S.R.

ear333 Stephenie L. Pyle Manager, Regulatory Assurance Arkansas Nuclear One 1CAN 121502 December 30, 2015 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

REFERENCES:

Evaluations Described Response to Requests for Additional Information 3, 5, 6(a), and 7 Reactor Vessel Internals Aging Management Program Plan Arkansas Nuclear One, Unit 1 Docket No. 50-313 License No. DPR-51 1Entergy letter to NRC, "Reactor Vessel Internals Aging Management Program Plan," dated May 20, 2014 (1CAN051403) (ML14141A554) 2 NRC email to Entergy, dated December 2, 2014, "Requests for Additional Information - Reactor Vessel Internals Aging Management Plan - ANO-1

-TAC No. MF4201"

3. Entergy letter to NRC, "Responses to Request for Additional Information

- Reactor Vessel Internals Aging Management Program Plan," dated February 10, 2015 (1CAN021503) (ML15043A102)

Dear Sir or Madam:

Entergy Operations, Inc. (Entergy) submitted the Arkansas Nuclear One, Unit 1 (ANO-1)

Reactor Vessel Internals Aging Management Program Plan (Reference 1) to fulfill a commitment made as part of the ANO-1 License Renewal Application. The plan identified the reactor vessel internals components that must be included for aging management review and identified the augmented inspection plan for those components.

The NRC Staff reviewed the submittal and developed requests for additional information (RAIs).

These requests were provided via Reference 2. Reference 3 provided the responses to the RAIs. As part of those responses, Entergy committed to provide additional information as it was developed.

Attachment I to this letter contains proprietary information - Attachment 1 s withheld/

from public disclosure per 10 CFR 2.390.

/P

1CAN 121502 Page 2 of 3 In Reference 3, Entergy committed to provide the requested information for RAIs 3, 5, 6(a),

and 7 by December 31, 2015. The purpose of this submittal is to provide the requested information.

RAIs 3, 5, 6(a), and 7 are related to the Applicant/ILicensee Action Item 2 of the NRC Staff Safety Evaluation (SE) for MRP-227-A. This action requires the licensee to identify which reactor vessel internal components are within the scope of license renewal for their facility and then review the information in the appropriate tables of MRP-1 89, Revision 1, and MRP-1 91, identifying whether these tables contain all of the reactor vessel internal components that are within the scope of license renewal for their facility. If the tables do not identify all the components, then the licensee is to identify these components and propose any necessary modifications to the site-specific aging management program.

AREVA document ANP-3418P, Revision 0, "Arkansas Nuclear O~ne Unit 1 Reactor Vessel Internals License Renewal Scope and MRP-1 89, Revision 1 Comparison (MRP-227-A Action Item 2) Licensing Report," has been prepared to summarize the analyses performed for the applicable component items at ANO-1 to complete applicant / licensee action Item 2 from MRP-227-A for ANO-I. The information contained in the ARE VA 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. AREVA requests that the proprietary information 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 3. Therefore, Entergy requests that Attachment 1 of this submittal be withheld from public disclosure in accordance with 10 CER 2.390.

No new regulatory commitments have been identified in this letter.

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

Sincerely, SLP/rwc Attachment I to this letter contains proprietary information - Attachment I is withheld from public disclosure per 10 CFR 2.390.

1CAN 121502 Page 3 of 3 Attachments

1. AREVA document ANP-341 8P, Revision 0, "Arkansas Nuclear One Unit 1 Reactor Vessel Internals License Renewal Scope and MRP-189, Revision 1 Comparison (MRP-227-A Action Item 2) Licensing Report," PROPRIETARY

2.

AREVA document ANP-3418NP, Revision 0, "Arkansas Nuclear One Unit 1 Reactor Vessel Internals License Renewal Scope and MRP-189, Revision 1 Comparison (MRP-227-A Action Item 2) Licensing Report," NON-PROPRIETARY

3.

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: 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 Attachment I to this letter contains proprietary information - Attachment I is withheld from public disclosure per 10 CFR 2.390.

to 1 CAN121502 Affidavit

AFFIDAVIT COMMONWEALTH OF VIRGINIA

)) SS.

CITY OF LYNCHBURG

)

1.

My name is Morris Byram. 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 topical report ANP-341 8P, Revision 0, "Arkansas Nuclear One Unit 1 Reactor Vessel Internals License Renewal Scope and MRP-1 89, Revision 1 Comparison (MRP-227-A Action Item 2)," dated December, 2015, and referred to herein as "Document." Information contained in this Document has been classified by ARE VA as proprietary in accordance with the policies established by AREVA Inc. 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 disciosure 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 ARE VA to determine whether information should be classified as proprietary:

(a)

The information reveals details of ARE VA'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 ARE VA.

-(d)

'The information reveals certain distinguishing aspects of a process,

........ methodology, or component, the exciusive 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 ARE VA.

The information in this Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(c), and 6(d) 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 ______________

_,2015.

Sherry L. McFaden....

NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/18 Reg. # 7079129

SEntergy Mantgergy Operuations, AsuInc.

1448sa S.R.

ear333 Stephenie L. Pyle Manager, Regulatory Assurance Arkansas Nuclear One 1CAN 121502 December 30, 2015 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

REFERENCES:

Evaluations Described Response to Requests for Additional Information 3, 5, 6(a), and 7 Reactor Vessel Internals Aging Management Program Plan Arkansas Nuclear One, Unit 1 Docket No. 50-313 License No. DPR-51 1Entergy letter to NRC, "Reactor Vessel Internals Aging Management Program Plan," dated May 20, 2014 (1CAN051403) (ML14141A554) 2 NRC email to Entergy, dated December 2, 2014, "Requests for Additional Information - Reactor Vessel Internals Aging Management Plan - ANO-1

-TAC No. MF4201"

3. Entergy letter to NRC, "Responses to Request for Additional Information

- Reactor Vessel Internals Aging Management Program Plan," dated February 10, 2015 (1CAN021503) (ML15043A102)

Dear Sir or Madam:

Entergy Operations, Inc. (Entergy) submitted the Arkansas Nuclear One, Unit 1 (ANO-1)

Reactor Vessel Internals Aging Management Program Plan (Reference 1) to fulfill a commitment made as part of the ANO-1 License Renewal Application. The plan identified the reactor vessel internals components that must be included for aging management review and identified the augmented inspection plan for those components.

The NRC Staff reviewed the submittal and developed requests for additional information (RAIs).

These requests were provided via Reference 2. Reference 3 provided the responses to the RAIs. As part of those responses, Entergy committed to provide additional information as it was developed.

Attachment I to this letter contains proprietary information - Attachment 1 s withheld/

from public disclosure per 10 CFR 2.390.

/P

1CAN 121502 Page 2 of 3 In Reference 3, Entergy committed to provide the requested information for RAIs 3, 5, 6(a),

and 7 by December 31, 2015. The purpose of this submittal is to provide the requested information.

RAIs 3, 5, 6(a), and 7 are related to the Applicant/ILicensee Action Item 2 of the NRC Staff Safety Evaluation (SE) for MRP-227-A. This action requires the licensee to identify which reactor vessel internal components are within the scope of license renewal for their facility and then review the information in the appropriate tables of MRP-1 89, Revision 1, and MRP-1 91, identifying whether these tables contain all of the reactor vessel internal components that are within the scope of license renewal for their facility. If the tables do not identify all the components, then the licensee is to identify these components and propose any necessary modifications to the site-specific aging management program.

AREVA document ANP-3418P, Revision 0, "Arkansas Nuclear O~ne Unit 1 Reactor Vessel Internals License Renewal Scope and MRP-1 89, Revision 1 Comparison (MRP-227-A Action Item 2) Licensing Report," has been prepared to summarize the analyses performed for the applicable component items at ANO-1 to complete applicant / licensee action Item 2 from MRP-227-A for ANO-I. The information contained in the ARE VA 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. AREVA requests that the proprietary information 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 3. Therefore, Entergy requests that Attachment 1 of this submittal be withheld from public disclosure in accordance with 10 CER 2.390.

No new regulatory commitments have been identified in this letter.

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

Sincerely, SLP/rwc Attachment I to this letter contains proprietary information - Attachment I is withheld from public disclosure per 10 CFR 2.390.

1CAN 121502 Page 3 of 3 Attachments

1. AREVA document ANP-341 8P, Revision 0, "Arkansas Nuclear One Unit 1 Reactor Vessel Internals License Renewal Scope and MRP-189, Revision 1 Comparison (MRP-227-A Action Item 2) Licensing Report," PROPRIETARY

2.

AREVA document ANP-3418NP, Revision 0, "Arkansas Nuclear One Unit 1 Reactor Vessel Internals License Renewal Scope and MRP-189, Revision 1 Comparison (MRP-227-A Action Item 2) Licensing Report," NON-PROPRIETARY

3.

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: 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 Attachment I to this letter contains proprietary information - Attachment I is withheld from public disclosure per 10 CFR 2.390.

to 1 CAN121502 Affidavit

AFFIDAVIT COMMONWEALTH OF VIRGINIA

)) SS.

CITY OF LYNCHBURG

)

1.

My name is Morris Byram. 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 topical report ANP-341 8P, Revision 0, "Arkansas Nuclear One Unit 1 Reactor Vessel Internals License Renewal Scope and MRP-1 89, Revision 1 Comparison (MRP-227-A Action Item 2)," dated December, 2015, and referred to herein as "Document." Information contained in this Document has been classified by ARE VA as proprietary in accordance with the policies established by AREVA Inc. 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 disciosure 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 ARE VA to determine whether information should be classified as proprietary:

(a)

The information reveals details of ARE VA'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 ARE VA.

-(d)

'The information reveals certain distinguishing aspects of a process,

........ methodology, or component, the exciusive 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 ARE VA.

The information in this Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(c), and 6(d) 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 ______________

_,2015.

Sherry L. McFaden....

NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/18 Reg. # 7079129