Letter Sequence Response to RAI |
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MONTHYEAR0CAN072004, Withdrawal of Request for Exemption from 10 CFR 50, Appendix B Requirements to Support Application of ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 22020-07-15015 July 2020 Withdrawal of Request for Exemption from 10 CFR 50, Appendix B Requirements to Support Application of ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 Project stage: Withdrawal ML20260H4852020-09-10010 September 2020 NRR E-mail Capture - ANO-1 and ANO-2 - Acceptance Review of Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of ECP Supply Piping (L-2020-LLR-0104) Project stage: Acceptance Review ML20293A1842020-11-0404 November 2020 Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance ML21022A0842021-01-22022 January 2021 Request for Additional Information - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond Supply Piping - Arkansas Nuclear One,Units 1 and 2 -Entergy Operations, Inc. NON-PROPRIETARY Redacted Project stage: RAI 0CAN022101, Response to Request for Additional Information - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond Supply Piping2021-02-22022 February 2021 Response to Request for Additional Information - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond Supply Piping Project stage: Response to RAI ML21116A1092021-04-26026 April 2021 NRR E-mail Capture - ANO-1 and ANO-2: Final Supplemental RAI Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of ECP Supply Piping Project stage: RAI ML21141A1822021-05-21021 May 2021 Closed Teleconference with Entergy Operations, Inc. Concerning Proposed Alternative to Allow Use of a Carbon Fiber Reinforced Polymer Composite System at Arkansas Nuclear One, Units 1 and 2 Project stage: Meeting 0CAN052103, Presentation Information for Pre-Submittal Meeting Regarding the Response to Request for Additional Information - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency .2021-05-25025 May 2021 Presentation Information for Pre-Submittal Meeting Regarding the Response to Request for Additional Information - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency . Project stage: Response to RAI 0CAN062101, Presentation Information for Pre-Submittal Meeting Regarding the Response to Request for Additional Information - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling2021-06-15015 June 2021 Presentation Information for Pre-Submittal Meeting Regarding the Response to Request for Additional Information - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Project stage: Response to RAI ML21145A0042021-06-28028 June 2021 Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance 0CAN072102, Response to Request for Additional Information (Follow-up) - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond Supply Piping2021-07-22022 July 2021 Response to Request for Additional Information (Follow-up) - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond Supply Piping Project stage: Response to RAI ML21225A3012021-08-25025 August 2021 Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance 0CAN092101, Unit 2 - Revised Proprietary Demarcation in Response to Request for Additional Information (Follow-up) - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond Supply Piping2021-09-14014 September 2021 Unit 2 - Revised Proprietary Demarcation in Response to Request for Additional Information (Follow-up) - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond Supply Piping Project stage: Response to RAI ML21225A5432021-09-23023 September 2021 Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance ML21188A0222021-09-30030 September 2021 Approval of Request for Alternative from Certain Requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (EPID L-2020-LLR-0104) (Redacted) Project stage: Other 2021-05-25
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Category:Legal-Affidavit
MONTHYEAR1CAN122301, Responses to Request for Additional Information for Request for Alternative for Implementation of Extended Reactor Vessel Inservice Inspection Interval (ANO1-ISl-037)2023-12-14014 December 2023 Responses to Request for Additional Information for Request for Alternative for Implementation of Extended Reactor Vessel Inservice Inspection Interval (ANO1-ISl-037) 1CAN062301, Request for Alternative for Implementation of Extended Reactor Vessel Inservice Inspection Interval (ANO1-ISI-037)2023-06-0808 June 2023 Request for Alternative for Implementation of Extended Reactor Vessel Inservice Inspection Interval (ANO1-ISI-037) ML23020A9442023-01-20020 January 2023 Enclosure 3: Affidavit 2CAN122103, Relief Request ANO2-RR-21-002, Half-Nozzle Repair of Reactor Vessel Closure Head Penetration 46 - Submittal of Analyses - Affidavits and Calculation Summary Sheet2021-11-19019 November 2021 Relief Request ANO2-RR-21-002, Half-Nozzle Repair of Reactor Vessel Closure Head Penetration 46 - Submittal of Analyses - Affidavits and Calculation Summary Sheet 2CAN102102, Relief Request ANO2-R&R-012: Support the Repair of the Reactor Vessel Closure Head Penetration 462021-10-10010 October 2021 Relief Request ANO2-R&R-012: Support the Repair of the Reactor Vessel Closure Head Penetration 46 0CAN092101, Unit 2 - Revised Proprietary Demarcation in Response to Request for Additional Information (Follow-up) - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond Supply Piping2021-09-14014 September 2021 Unit 2 - Revised Proprietary Demarcation in Response to Request for Additional Information (Follow-up) - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond Supply Piping 0CAN052103, Presentation Information for Pre-Submittal Meeting Regarding the Response to Request for Additional Information - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency .2021-05-25025 May 2021 Presentation Information for Pre-Submittal Meeting Regarding the Response to Request for Additional Information - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency . 0CAN022101, Response to Request for Additional Information - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond Supply Piping2021-02-22022 February 2021 Response to Request for Additional Information - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond Supply Piping 2CAN032001, Response to Request for Additional Information Related to License Amendment Request to Revise the Control Element Assembly Drop Times2020-03-11011 March 2020 Response to Request for Additional Information Related to License Amendment Request to Revise the Control Element Assembly Drop Times 1CAN121601, Arkansas Nuclear One Unit 1, Update to Evaluations Described Response to Request for Additional Information 14(a) Reactor Vessel Internals Aging Management Program Plan2016-12-21021 December 2016 Arkansas Nuclear One Unit 1, Update to Evaluations Described Response to Request for Additional Information 14(a) Reactor Vessel Internals Aging Management Program Plan 1CAN121601, Update to Evaluations Described Response to Request for Additional Information 14(a) Reactor Vessel Internals Aging Management Program Plan2016-12-21021 December 2016 Update to Evaluations Described Response to Request for Additional Information 14(a) Reactor Vessel Internals Aging Management Program Plan 1CAN121502, Evaluations Described Response to Requests for Additional Information 3, 5, 6(a), and 7, Reactor Vessel Internals Aging Management Program Plan2015-12-30030 December 2015 Evaluations Described Response to Requests for Additional Information 3, 5, 6(a), and 7, Reactor Vessel Internals Aging Management Program Plan ML15278A0242015-09-28028 September 2015 Attachment 2, Areva Document ANP-3417NP, Revision 0, MRP-227-A Applicant / Licensee Action Item No. 7 Analysis for Arkansas Nuclear One, Unit 1 (Non-Proprietary), Attachment 3, Affidavit, and Attachment 4, List of Commitments 2CAN051504, Revised Affidavit for Request for Relief ANO2-ISI-0162015-05-19019 May 2015 Revised Affidavit for Request for Relief ANO2-ISI-016 1CAN031504, Arkansas Nuclear One, Unit 1 - Responses to Request for Additional Information on Update of the Reactor Coolant System Pressure and Temperature and the Low Temperature Overpressure Protection System Limits2015-03-25025 March 2015 Arkansas Nuclear One, Unit 1 - Responses to Request for Additional Information on Update of the Reactor Coolant System Pressure and Temperature and the Low Temperature Overpressure Protection System Limits 1CAN031504, Responses to Request for Additional Information on Update of the Reactor Coolant System Pressure and Temperature and the Low Temperature Overpressure Protection System Limits2015-03-25025 March 2015 Responses to Request for Additional Information on Update of the Reactor Coolant System Pressure and Temperature and the Low Temperature Overpressure Protection System Limits ML15041A0742015-02-0606 February 2015 ANP-3300Q1NP, Rev. 0, Response to Request for Additional Information on Reactor Coolant System Pressure/Temperature and Low Temperature Overpressure Protection System Limits to 54 EFPY for Arkansas Nuclear One, Unit 1, Attachment 2 to 1CAN0 2CAN111402, Unit 2, Revised Affidavit for Request for Relief ANO2-ISI-0162014-11-11011 November 2014 Unit 2, Revised Affidavit for Request for Relief ANO2-ISI-016 2CAN041402, Successive Examination Plans, Request for Relief ANO2-ISI-016. Weld Scan Plans & Preliminary Coverage Estimates, Pdqs Number 783 & Affidavit Enclosed2014-04-15015 April 2014 Successive Examination Plans, Request for Relief ANO2-ISI-016. Weld Scan Plans & Preliminary Coverage Estimates, Pdqs Number 783 & Affidavit Enclosed 0CAN041401, NRC Augmented Inspection Team Follow-up Inspection Report 05000313/2013012 and 05000368/2013012; Preliminary Red and Yellow Findings2014-04-0101 April 2014 NRC Augmented Inspection Team Follow-up Inspection Report 05000313/2013012 and 05000368/2013012; Preliminary Red and Yellow Findings 0CAN071303, Units 1 and 2, Augmented Inspection Team Information Request2013-07-31031 July 2013 Units 1 and 2, Augmented Inspection Team Information Request ML12038A1772012-02-0303 February 2012 Units 1 and 2, HI-STORM 100 Cask System, Thermal Validation Test Using Air Mass Flow Rate ML0935005322009-12-11011 December 2009 Affidavit from Gayle F. Elliot, Manager of Product Licensing for Areva, Np Inc ML0828300342008-08-20020 August 2008 Affidavit of Gayle F. Elliott, for Areva Np Inc., Regarding NRC Presentation of August 2008 ML0627703182006-09-28028 September 2006 Transmittal of Draft Slide Presentation for Nrc/Entergy/Westinghouse Pre-Submittal Meeting (Proprietary/Non-Proprietary) ML0514603882005-05-10010 May 2005 Units 1 and 2, Request for Additional Information Concerning Request for Exemption from Holtec International Certificate of Compliance 2CAN010402, Revisions to Wesdyne Proprietary Reports in Support of Relaxation from Performing a Bare Metal Visual Inspection2004-01-16016 January 2004 Revisions to Wesdyne Proprietary Reports in Support of Relaxation from Performing a Bare Metal Visual Inspection ML15350A2151985-09-0505 September 1985 Overview Description of Core Operating Limit Supervisory System (Colss)(Rev 00-NP to CEN-312-NP) 2023-06-08
[Table view] Category:Letter type:
MONTHYEAR1CAN082401, Inservice Inspection Summary Report for the Arkansas Nuclear One, Unit 1 Thirty-First Refueling Outage (1R312024-08-13013 August 2024 Inservice Inspection Summary Report for the Arkansas Nuclear One, Unit 1 Thirty-First Refueling Outage (1R31 2CAN072401, Proposed Alternative for Implementation of Extended Reactor Vessel In-Service Inspection Interval (ANO2-ISI-24-02)2024-07-19019 July 2024 Proposed Alternative for Implementation of Extended Reactor Vessel In-Service Inspection Interval (ANO2-ISI-24-02) 0CAN072401, Annual 10 CFR 50.46 Report for Calendar Year 2023 Emergency Core Cooling System Evaluation Changes2024-07-0808 July 2024 Annual 10 CFR 50.46 Report for Calendar Year 2023 Emergency Core Cooling System Evaluation Changes 1CAN072401, Request for Review and Approval of Changes to the Safety Analysis Report and to a Confirmatory Order Clarifying an Alternate Means of Compliance for Pressurizer Heaters Emergency Power Supply2024-07-0202 July 2024 Request for Review and Approval of Changes to the Safety Analysis Report and to a Confirmatory Order Clarifying an Alternate Means of Compliance for Pressurizer Heaters Emergency Power Supply 1CAN072402, Source Range Nuclear Instrument Failure Resulting in Condition Prohibited by Technical Specifications2024-07-0101 July 2024 Source Range Nuclear Instrument Failure Resulting in Condition Prohibited by Technical Specifications 0CAN062403, Groundwater Protection Initiative - Voluntary Special Report for Tritium Levels2024-06-25025 June 2024 Groundwater Protection Initiative - Voluntary Special Report for Tritium Levels 0CAN062402, Proposed Alternatives ANO1-ISI-24-01 and ANO2-ISI-24-01 for Examinations of Steam Generator Pressure-Retaining Welds and Full Penetration Welded Nozzles2024-06-0606 June 2024 Proposed Alternatives ANO1-ISI-24-01 and ANO2-ISI-24-01 for Examinations of Steam Generator Pressure-Retaining Welds and Full Penetration Welded Nozzles 0CAN052401, – Units 1 and 2, Submittal of Annual Radiological Environmental Operating Report for 20232024-05-13013 May 2024 – Units 1 and 2, Submittal of Annual Radiological Environmental Operating Report for 2023 1CAN052401, Cycle 32 Core Operating Limits Report2024-05-0404 May 2024 Cycle 32 Core Operating Limits Report 2CAN042403, Response to the Request for Additional Information Regarding ANO-2 License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended C2024-04-24024 April 2024 Response to the Request for Additional Information Regarding ANO-2 License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended C 0CAN042402, Annual Occupational Radiation Exposure Report for 20232024-04-23023 April 2024 Annual Occupational Radiation Exposure Report for 2023 0CAN042401, Radioactive Effluent Release Report for the 2023 Calendar Year2024-04-15015 April 2024 Radioactive Effluent Release Report for the 2023 Calendar Year 2CAN042402, Special Report of Non-functional Main Steam Line Radiation Monitor2024-04-11011 April 2024 Special Report of Non-functional Main Steam Line Radiation Monitor 2CAN042401, Request to Revise Typographical Errors in Arkansas Nuclear One, Unit 2 Technical Specifications2024-04-0404 April 2024 Request to Revise Typographical Errors in Arkansas Nuclear One, Unit 2 Technical Specifications 2CAN012401, U.S. Additional Protocol2024-01-17017 January 2024 U.S. Additional Protocol 2CAN012403, Supplemental Information - Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 42024-01-11011 January 2024 Supplemental Information - Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4 0CAN012401, Registration of Cask Use2024-01-10010 January 2024 Registration of Cask Use 1CAN122301, Responses to Request for Additional Information for Request for Alternative for Implementation of Extended Reactor Vessel Inservice Inspection Interval (ANO1-ISl-037)2023-12-14014 December 2023 Responses to Request for Additional Information for Request for Alternative for Implementation of Extended Reactor Vessel Inservice Inspection Interval (ANO1-ISl-037) 2CAN112302, Submittal of Amendment 31 to Safety Analysis Report2023-11-16016 November 2023 Submittal of Amendment 31 to Safety Analysis Report 0CAN102303, Registration of Cask Use2023-10-24024 October 2023 Registration of Cask Use 0CAN102302, (ANO) Emergency Plan Revision 49 and Emergency Plan On-Shift Staffing Analysis Revision 32023-10-11011 October 2023 (ANO) Emergency Plan Revision 49 and Emergency Plan On-Shift Staffing Analysis Revision 3 0CAN102301, Evacuation Time Estimate (ETE) Study2023-10-0404 October 2023 Evacuation Time Estimate (ETE) Study 1CAN092301, Supplemental Information - Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 42023-09-21021 September 2023 Supplemental Information - Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4 0CAN092302, Supplement to Request for Alternative Frequency to Containment Unbonded Post-Tensioning System Inservice Inspection (ANO-CISI-002)2023-09-14014 September 2023 Supplement to Request for Alternative Frequency to Containment Unbonded Post-Tensioning System Inservice Inspection (ANO-CISI-002) 2CAN092301, Reply to a Notice of Violation2023-09-0808 September 2023 Reply to a Notice of Violation 0CAN092301, Emergency Plan Implementing Procedure Revision2023-09-0505 September 2023 Emergency Plan Implementing Procedure Revision 0CAN082301, Units 1 and 2 - Changes to the Quality Assurance Program Approval Form for Radioactive Material Package No. 03412023-08-17017 August 2023 Units 1 and 2 - Changes to the Quality Assurance Program Approval Form for Radioactive Material Package No. 0341 2CAN082301, Inservice Inspection Summary Report for the Arkansas Nuclear One, Unit 2, Twenty-Ninth Refueling Outage (2R29)2023-08-10010 August 2023 Inservice Inspection Summary Report for the Arkansas Nuclear One, Unit 2, Twenty-Ninth Refueling Outage (2R29) 0CAN072301, Registration of Cask Use2023-07-18018 July 2023 Registration of Cask Use 1CAN062304, Supplement Related to License Amendment Request to Remove Technical Specification Condition Allowing Two Reactor Coolant Pump Operation2023-06-29029 June 2023 Supplement Related to License Amendment Request to Remove Technical Specification Condition Allowing Two Reactor Coolant Pump Operation 0CAN062301, Status of Actions to Return to Compliance2023-06-26026 June 2023 Status of Actions to Return to Compliance 0CAN062302, Submittal of Revision 22 of the ANO Fire Hazards Analysis2023-06-20020 June 2023 Submittal of Revision 22 of the ANO Fire Hazards Analysis 1CAN062301, Request for Alternative for Implementation of Extended Reactor Vessel Inservice Inspection Interval (ANO1-ISI-037)2023-06-0808 June 2023 Request for Alternative for Implementation of Extended Reactor Vessel Inservice Inspection Interval (ANO1-ISI-037) 0CAN052303, Annual 10 CFR 50.46 Report for Calendar Year 20222023-05-24024 May 2023 Annual 10 CFR 50.46 Report for Calendar Year 2022 0CAN052302, Emergency Plan Rev. 482023-05-11011 May 2023 Emergency Plan Rev. 48 0CAN052301, Units 1 and 2 - Annual Radiological Environmental Operating Report for 20222023-05-0909 May 2023 Units 1 and 2 - Annual Radiological Environmental Operating Report for 2022 2CAN052301, Cycle 30 Core Operating Limits Report (COLR)2023-05-0303 May 2023 Cycle 30 Core Operating Limits Report (COLR) 0CAN042302, Annual Occupational Radiation Exposure Report for 20222023-04-27027 April 2023 Annual Occupational Radiation Exposure Report for 2022 0CAN042301, Radioactive Effluent Release Report for 20222023-04-14014 April 2023 Radioactive Effluent Release Report for 2022 2CAN042301, License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 42023-04-0505 April 2023 License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4 1CAN032301, License Amendment Request to Modify the Arkansas Nuclear One, Unit 1, Technical Specification 3.3.1, Reactor Protection System Instrumentation, Turbine Trip Function on Low Control Oil Pressure2023-03-30030 March 2023 License Amendment Request to Modify the Arkansas Nuclear One, Unit 1, Technical Specification 3.3.1, Reactor Protection System Instrumentation, Turbine Trip Function on Low Control Oil Pressure 2CAN032304, Supplement to the Request for Alternative Regarding the Half-Nozzle Repair of Reactor Vessel Closure Head Penetration 462023-03-29029 March 2023 Supplement to the Request for Alternative Regarding the Half-Nozzle Repair of Reactor Vessel Closure Head Penetration 46 2CAN032303, Responses to Request for Additional Information Concerning the Request for Alternative Regarding the Half-Nozzle Repair of Reactor Vessel Closure Head Penetration 462023-03-29029 March 2023 Responses to Request for Additional Information Concerning the Request for Alternative Regarding the Half-Nozzle Repair of Reactor Vessel Closure Head Penetration 46 2CAN032305, 03 Post Examination Analysis2023-03-23023 March 2023 03 Post Examination Analysis 1CAN032302, Inspection Summary Report for the Thirtieth Refueling Outage (1R30)2023-03-20020 March 2023 Inspection Summary Report for the Thirtieth Refueling Outage (1R30) 1CAN012301, Responses to Request for Additional Information for Request for Relief ANO1-ISI-0352023-01-30030 January 2023 Responses to Request for Additional Information for Request for Relief ANO1-ISI-035 2CAN012303, U.S. Additional Protocol2023-01-23023 January 2023 U.S. Additional Protocol 2CAN012302, Relief Request ANO2-RR-23-001, Half-Nozzle Repair of Reactor Vessel Closure Head Penetration 462023-01-20020 January 2023 Relief Request ANO2-RR-23-001, Half-Nozzle Repair of Reactor Vessel Closure Head Penetration 46 1CAN122201, License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 42022-12-22022 December 2022 License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4 0CAN122202, Registration of Cask Use2022-12-21021 December 2022 Registration of Cask Use 2024-08-13
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Text
This letter contains proprietary information.
Withhold Enclosure 1 from public disclosure in accordance with 10 CFR 2.390.
Entergy Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5102 Phil Couture Sr. Manager, Fleet Regulatory Assurance 10 CFR 2.390 0CAN052103 May 25, 2021 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Presentation Information for Pre-Submittal Meeting Regarding the Response to Request for Additional Information - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond Supply Piping Arkansas Nuclear One, Unit 1 and Unit 2 NRC Docket Nos. 50-313 and 50-368 Renewed Facility Operating License Nos. DPR-51 and NPF-6 A meeting (phone conference) between Entergy Operations, Inc. (Entergy), Structural Group, Inc. (SGI), Simpson Gumpertz & Heger, Inc. and the U. S. Nuclear Regulatory Commission (NRC) is scheduled for May 26, 2021, in order to discuss an NRC Request for Additional Information (RAI). The RAI is concerning the proposed alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond piping at Arkansas Nuclear One (ANO).
From preparation of the presentation material to be used in the meeting, it was determined that the material is proprietary to SGI. On that basis, the meeting is planned to be closed to the public.
The presentation material to be used for the meeting is in the form of PowerPoint "slides" prepared by SGI personnel and reviewed by Entergy. The purpose of this letter is to transmit the slides to the NRC staff prior to the meeting.
Slides for the meeting are provided in Enclosure 1. These slides are considered proprietary to SGI and are to be withheld from public disclosure in accordance with 10 CFR 2.390 of the Commissions regulations.
This letter contains proprietary information.
Withhold Enclosure 1 from public disclosure in accordance with 10 CFR 2.390.
This letter contains proprietary information.
Withhold Enclosure 1 from public disclosure in accordance with 10 CFR 2.390.
0CAN052103 Page 2 of 2 This information is supported by affidavit, signed by Scott Greenhaus, Executive Vice President of SGI, the owners of the information. The affidavits set forth the bases by which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390 of the Commission's regulations. The affidavit is included in the SGI letter to the NRC entitled, "Application for Withholding Proprietary Information from Public EMIB-2-RAI-1 Pre-submittal Meeting". The SGI authorization letter is provided in Enclosure 2.
No new regulatory commitments are included in this submittal.
If there are any questions or if additional information is needed, please contact Riley Keele, Jr.,
Manager, Regulatory Assurance, Arkansas Nuclear One, at 479-858-7826.
Respectfully, Phil Couture PC/rwc
Enclosures:
- 1. Presentation Material for May 26, 2021, Meeting (Proprietary)
- 2. SGI Application for Withholding Proprietary Information from Public cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector - Arkansas Nuclear One NRC Project Manager - Arkansas Nuclear One This letter contains proprietary information.
Withhold Enclosure 1 from public disclosure in accordance with 10 CFR 2.390.
Enclosure 2 0CAN052103 SGI Application for Withholding Proprietary Information from Public (6 pages)
This letter contains proprietary information.
Withhold Enclosure 1 from public disclosure in accordance with 10 CFR 2.390.
struc'tura1 group May 21, 2021 U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD20852
Subject:
Application for Withholding Proprietary Information from Public EMIIB-2-RAl-1 Pre-submittal Meeting
References:
- 1. Entergy Operations, Inc. (Entergy) letter to U. S. Nuclear Regulatory Commission (NRC), "Response to Request for Additional Information - Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Emergency Cooling Pond (ECP) Supply Piping in accordance with 10 CFR 50 .55a(z)(1)," Arkansas Nuclear One, Units 1 and 2, NRC Docket Nos. 50-313 and 50-368, Entergy letter no. 0CAN02201.
- 2. Entergy Operations, Inc. (Entergy) letter to U. S. Nuclear Regulatory Commission (NRC), "Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Emergency Cooling Pond (ECP) Supply Piping in accordance with 10 CFR 50.55a(z)(1)," Arkansas Nuclear One, Units 1 and 2 (0CAN072001) (ML20218A672).
- 3. NRC email to Entergy, "Arkansas Nuclear One, Units 1 and 2 - Request for Additional Information HE: Proposed Alternative to ASME Code Requirements for the Repair of Emergency Cooling Pond Piping (EPID L-2020-LLR-0104)," (0CNA012105).
- 4. NRC (Thomas Wengert) email to Entergy (Riley Keele), April 26, 2021 at 6:54 AM, "ANO-1 and ANO-2: Final Supplemental RAI RE: Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of ECP Supply Piping (EPID L-2020-LLR-0104)."
Ladies and Gentlemen:
Structural Group, lnc.,(SGI) has provided certain proprietary information to Entergy Operations, Inc. (Entergy) in connection with a pre-submittal meeting to review the response to EMll3-2-RAl-1 provided by the U.S. Nuclear Regulatory Commission (USN RC) in Reference 4. This application requests that SGI proprietary information provided in the pre-submittal meeting documents related to EMIB-2-RAl-1 be protected from public disclosure.
The proprietary information for which withholding is being requested is iidentified in the attached affidavit signed by the owner of the proprietary information, SGI, on behalf of itself and any wholly-owned subsidiaries or affiliated companies . An affidavit accompanies this letter, setting forth the basis on which the information may be withheld from public disclosure by the NRC and addressing with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390 of the NRC's regulations .
struclura1 group Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Entergy.
Correspondence with respect to the proprietary aspects of the Application or the Affidavit should reference this letter and be addressed to Scott Greenhaus, Executive Vice
~h____
President, St ctural Group, Inc., 10150 Old Columbia Road, Columbia, MD 21046.
acerely; Scott Green aus Executive Vice Rresident 0 (410) 859-645B, M (410) 340-3205 SGreenhaus@structuralgroup.com
struclurc11 group AFFIDAVIT I, Scott Greenhaus, am Executive Vice President of Structural Group, Inc. (SGI).
In my capacity as Executive Vice President I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in conj unction with nuclear plant licensing and rulemaking proceedings and am authorized to apply for its withholding on behalf of SGI and its affiliates.
I am making this .Affidavit in conformance with the provisions of 10 CFR 2.390 of the U.S. Nuclear Rei~ulatory Commission (NRC) regulations and in conjunction with SGl's Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.
I have personal knowledge of the criteria and procedures utilized by SGI in designating information as a trade secret, privileged or as confidential commercial or financial information.
Pursuant to the provisions of paragraph (b) (4) of 10 CFR 2.390 of the NRC's regulations, the following is furnished for consideration by the NRC in determining whether the information sought to be withheld from public disclosure should be withheld.
The information sought to be withheld from public disclosure is owned by and has been held in confidence by SGI. The documents provided in the Entergy pre-submittal meeting with the USNRC in response to Reference 4 (EMIB-2-RAl-1) include SGI proprietary information and are requested to be protected from public disclosure.
The information is of a type customarily held in confidence by SGI and not disclosed to the public. SGI has a rational basis for determining the types of information customarily held in confidence by it and utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system provides a rational basis for maintaining confidentiality and justifies the NRC withholding the information from public disclosure.
Under SGl's system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, asfollows:
- 1) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by a competitor of SGI without license constitutes a competitive advantage over other companies.
- 2) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.
- 3) Its use by a competitor would reduce their expenditure of resources or improve their competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.
- 4) It reveals cost or price information, production capacities, budget levels, or commercial strategies of SGI, their customers or suppliers.
- 5) It reveals aspects of past, present, or future development plans funded by SGI or its customer, and programs of potential commercial value to SGI.
- 6) It contains patentable ideas, for which patent protection may be desirable.
There are sound policy reasons behind the SGI system which include the following;
- 1) The use of such information by SGI gives it a competitive advanta~~e over
struc'tura1 group competitors. It is, therefore, withheld from disclosure to protect SGls competitive position.
- 2) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes SGl's ability to sell products and services involving the use of the information.
- 3) Use by a competitor would put SGI at a competitive disadvantage by reducing the competitor's expenditure of resources and capital.
- 4) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage.
If competitors acquire components of proprietary information, any one component may be the key to the entire process, thereby depriving SGI of its competitive advantage.
- 5) Unrestricted disclosure would jeopardize the position of prominence of SGI in the world marketplace, and thereby give a market advantage to competitor in those countries in which SGI operates.
- 6) SGl's capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
The information is being transmitted to the NRC in confidence and, under the provisions of 10 CFR 2.390, it is to be received in confidence by the NRC. The information sought to be protected is not available in public sources and, to the best of our knowledge and belief, available information has not been previously employed in the same original manner or method.
The proprietary information sought to be withheld in this submittal is that which is appropriately marked in Entergy's responses to the NRC RAI (EMIB-2--RAl-1) being transmitted by Entergy letter (Docket Nos. 50-313/368) and reflected in SGl's Application for Withholding Proprietary Information from Public Disclosure addressed to the NRC Document Control Desk. The proprietary information as submitted by SGI is that associated with the "Proposed Alternative to ASM E Section XI Hequirements for Repair/Replacement of Emergency Cooling Pond (ECP) Supply Piping for Entergy Arkansas Nuclear One (ANO) Units 1 and 2" (Reference 2) and may be used only for that purpose.
This information is part of that which will enable SGI to:
- 1) Provide input to Entergy to provide to the NRC for the ANO Units 1 and 2, RAI response; and
- 2) Provide licensing support for the Entergy response.
SGI owns or is permitted to use the proprietary information referenced in this Affidavit under agreements that include SGl's maintaining the confidentiality of such information, as contemplated in this Affidavit.
Further this information has substantial commercial value as follows;
- 1) The SGI plan to sell the use of this information to their customers for the purpose of installing Carbon Fiber Reinforced Polymer (CFRP) in safety related piping.
- 2) That SGI can sell support and defense of the technology to their customers in the licensing process.
- 3) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by SGI.
- 4) Public disclosure of this proprietary information is likely to cause substantial harm to the
struc'tural group competitive position of SGI because it would enhance the ability of competitors to provide similar licensing services for commercial power reactors without commensurate expenses.
- 5) Public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.
- 6) The development of the technology described in part by the proprietary information is the result of applying the results of many years of experience in an intensive effort by SGI and the expenditure of a considerable sum of money and resources. In order for competitors to duplicate this information, similar technical programs would have to be performed including a significant expenditure money and resources.
Further the deponent sayeth not.
strucrtural group strucrtural group AFFIDAVIT State of Maryland )
County of Howard )
Before me, the undersigned authority, personally appeared Scott Greenhaus, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Structural Group, Inc. and that the averments of fact set forth in this Affidavit re true and correct to the best of his knowledge, information, and belief.
Scott Greenhaus Executive Vice President Sworn to and subscribed before me this 17th day of May 2021 N~~
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