1CAN121601, Update to Evaluations Described Response to Request for Additional Information 14(a) Reactor Vessel Internals Aging Management Program Plan

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Update to Evaluations Described Response to Request for Additional Information 14(a) Reactor Vessel Internals Aging Management Program Plan
ML16365A026
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 12/21/2016
From: Pyle S
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML16364A016 List:
References
1CAN121601
Download: ML16365A026 (7)
v • d • e


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 1CAN121601 December 21, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Update to Evaluations Described Response to Request for Additional Information 14(a)

Reactor Vessel Internals Aging Management Program Plan Arkansas Nuclear One, Unit 1 Docket No. 50-313 License No. DPR-51

Dear Sir or Madam:

Entergy Operations, Inc. (Entergy) submitted the Arkansas Nuclear One, Unit 1 (AN0-1)

Reactor Vessel Internals Aging Management Program Plan (Reference 1) to fulfill a commitment made as part of the AN0-1 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 NRG issued a Request for Additional Information (RAI) via Reference 2. Reference 3 provided the Entergy responses to the RAI, with a commitment to provide the requested evaluations associated with RAI 14(a) by December 31, 2016. RAI 14 is related to the Applicant I Licensee Action Item 6 of the NRG Staff Safety Evaluation' (SE) for MRP-227-A. RAI 14 requests justification for the continued operability of each of the inaccessible reactor vessel internals components through the period of extended operation or, if necessary, a plan for the replacement of the components. This submittal contains the RAI 14(a) response.

Attachment 1 is the proprietary version of AREVA Document ANP-3486P. The respective non-proprietary version of the AREVA document, ANP-3486NP, 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 CFR 2.390.

Attachment 1 to this letter contains proprietary information Attachment 1 is withheld from public disclosure per 10 CFR 2.390.

1CAN121601 Page 2 of 3 The evaluations presented in this submittal were developed by AREVA for both AN0-1 and Oconee 1, 2 and 3 (Reference 3).

This submittal contains no new regulatory commitments.

In accordance with 10 CFR 50.91 (b)(1 ), a copy of this application is being provided to the designated Arkansas state official.

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

Sincerely, SLP/rwc Attachments:

1. AREVA Document ANP-3486P, Revision 0, MRP-227-A Applicant I Licensee Action Item 6 Analysis for Arkansas Nuclear One Unit 1, PROPRIETARY
2. AREVA Document ANP-3486NP, Revision 0, MRP-227-A Applicant I Licensee Action*

Item 6 Analysis for Arkansas Nuclear One Unit 1, NON-PROP RI ETARY

3. Affidavit

REFERENCES:

1. Entergy letter to NRG, Reactor Vessel Internals Aging Management Program Plan, dated May 20, 2014 (1CAN051403) (ML14141A554)
2. NRG email to Entergy, dated December 12, 2014, Requests for Additional Information -

Reactor Vessel Internals Aging Management Plan (TAC No. MF4201) (1CNA121403)

(ML14349A787)

3. Duke Energy letter to NRG, Pressurized Water Reactor Internals and Evaluation Guidelines (MRP-227-A); Submittal of Information to Resolve Licensee Action Item 6,

.. dated May 26, 2016 (ML16152A051 and ML16152A052)

Attachment 1 to this letter contains proprietary information Attachment 1 is withheld from public disclosure per 10 CFR 2.390.

1CAN121601 Page 3 of 3 cc: Mr. Kriss Kennedy 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: Mr. Thomas J. Wengert MS 0-8B1A 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 1 to this letter contains proprietary information Attachment 1 is withheld from public disclosure per 10 CFR 2.390.

to 1CAN121601 Affidavit

AFFIDAVIT COMMONWEALTH OF VIRGINIA SS.

CITY OF LYNCHBURG

1. My name is Gayle Elliott. I am Deputy Director, Licensing & Regulatory Affairs, 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 Report ANP-3486P, Revision 0, entitled, "MRP-227-A Applicant/Licensee Action Item 6 Analysis for Arkansas Nuclear One Unit 1 (AN0-1)," dated October 2016 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 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 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 fo 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 tha_t 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 dayof O~y- I 2016.

Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/18 Reg. # 7079129 SHERRV L. MCFADEN Notiry-P1,1bllc commonwealttl of Virginia

. . 7079129 My commlsslo!I ~~plres-Oct31, 2018

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