0CAN072102, Response to Request for Additional Information (Follow-up) - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond Supply Piping

Response to Request for Additional Information (Follow-up) - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond Supply Piping

ML21203A198
Person / Time
Site:	Arkansas Nuclear
Issue date:	07/22/2021
From:	Gaston R Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML21203A197	List: 0CAN072102, Response to Request for Additional Information (Follow-up) - Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Emergency Cooling Pond Supply Piping
References
0CAN072102
Download: ML21203A198 (27)

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 601-368-5138 Ron Gaston Director, Nuclear Licensing 10 CFR 50.55a(z)(1) 0CAN072102 July 22, 2021 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Response to Request for Additional Information (Follow-up) - 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 By letter dated July 15, 2020 (Reference 1), Entergy Operations, Inc. (Entergy), requested NRC approval of a proposed alternative to American Society for Mechanical Engineers (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). During the course of the review, the NRC determined that additional information is needed to support completing the review process (Reference 2). Entergy provided responses to the Request for Additional Information (RAI) (Reference 3). To complete its review, the NRC staff requested additional supplemental information to NRC Mechanical Engineering and Inservice Testing Branch (EMIB)

EMIB-RAI-10 (Reference 4).

Entergy presented preliminary responses to the NRC's request in a closed meeting on May 26, 2021. See Reference 5 for the presentation material. Subsequent to the meeting, the NRC provided a set of additional requests (Reference 6).

The request for additional supplemental information (References 4 and 6) and associated Entergy responses are included in Enclosure 1.

The response to the additional supplemental information provided in Enclosure 1 is considered proprietary to Structural Group, Inc., and is to be withheld from public disclosure in accordance with 10 CFR 2.390 of the Commissions regulations. The non-proprietary version is provided in .

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.

0CAN072102 Page 2 of 3 This information is supported by affidavit, signed by Structural Group, Inc. the owner of the information. The affidavit 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 Structural Group, Inc. letter to the NRC entitled, "Application for Withholding Proprietary Information from Public Disclosure." The Structural Group, Inc. authorization letter is provided in Enclosure 3.

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.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on July 22, 2021.

Respectfully,

~1 Ron Gaston RWG/rwc

Enclosures:

1. Response to Final Supplemental Request for Additional Information related to Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of ECP Supply Piping in accordance with 10 CFR 50.55a(z)(1) (Proprietary)

2. Response to Final Supplemental Request for Additional Information related to Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of ECP Supply Piping in accordance with 10 CFR 50.55a(z)(1) (Non-Proprietary)

3. Structural Group Application for Withholding Proprietary Information from Public Disclosure 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.

0CAN072102 Page 3 of 3

References:

1. 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 (ML20218A672) (0CAN072001), dated July 15, 2020.

2. NRC email to Entergy, "Arkansas Nuclear One, Units 1 and 2 - Request for Additional Information RE: Proposed Alternative to ASME Code Requirements for the Repair of Emergency Cooling Pond Piping (EPID L-2020-LLR-0104)," (ML21022A084) (0CNA012105), dated January 22, 2021.

3. Entergy letter to NRC, "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, Units 1 and 2 (ML21063A243) (0CAN022101),

dated February 22, 2021.

4. NRC email to Entergy, "Arkansas Nuclear One, Units 1 and 2 - Final Supplemental Request for Additional Information RE: Proposed Alternative to ASME Section XI Requirements for the Repair/Replacement of Emergency Cooling Pond Supply Piping (EPID L-2020-LLR-0104)," (ML21116A109) (0CNA042102), dated April 26, 2021.

5. Entergy letter to NRC, "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, Units 1 and 2 (ML21167A279) (0CAN062101),

dated June 15, 2021.

6. NRC email to Entergy, "As discussed during the pre-submittal meeting related to the response to EMIB-2-RAI-1, Entergy is providing our understanding of the scope of the response for NRCs review and agreement," (0CNA062104), dated June 1, 2021.

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 0CAN072102 Response to Final Supplemental Request for Additional Information related to Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of ECP Supply Piping in accordance with 10 CFR 50.55a(z)(1)

(Non-Proprietary)

0CAN072102 Page 1 of 16 RESPONSE TO FINAL SUPPLEMENTAL REQUEST FOR ADDITIONAL INFORMATION RELATED TO PROPOSED ALTERNATIVE TO ASME SECTION XI REQUIREMENTS FOR REPAIR/REPLACEMENT OF ECP SUPPLY PIPING IN ACCORDANCE WITH 10 CFR 50.55A(Z)(1)

(NON-PROPRIETARY)

By letter dated July 15, 2020 (Reference 1), Entergy Operations, Inc. (Entergy), requested NRC approval of a proposed alternative to American Society for Mechanical Engineers (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). During the course of review, the NRC determined that additional information is needed to support completing the review process (Reference 2). Entergy provided responses to the Request for Additional Information (RAI) (Reference 3). To complete its review, the NRC staff requested additional supplement information to NRC Mechanical Engineering and Inservice Testing Branch (EMIB)

EMIB-RAI-10 (Reference 4). The request for additional supplemental information and associated Entergy response is included in the attached enclosure.

Proprietary information is identified by text enclosed within double brackets ((Example)).

EMIB-2-RAI-1

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The NRC provided additional requests for information via Reference 7. These additional requests and Entergy's responses are provided below.

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REFERENCES

1. 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 (ML20218A672)

(0CAN072001), dated July 15, 2020.

2. NRC email to Entergy, "Arkansas Nuclear One, Units 1 and 2 - Request for Additional Information RE: Proposed Alternative to ASME Code Requirements for the Repair of Emergency Cooling Pond Piping (EPID L-2020-LLR-0104)," (ML21022A084)

(0CNA012105), dated January 22, 2021.

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3. Entergy letter to NRC, "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, Units 1 and 2 (ML21063A243)

(0CAN022101), dated February 22, 2021.

4. NRC email to Entergy, "Arkansas Nuclear One, Units 1 and 2 - Final Supplemental Request for Additional Information RE: Proposed Alternative to ASME Section XI Requirements for the Repair/Replacement of Emergency Cooling Pond Supply Piping (EPID L-2020-LLR-0104)," (ML21116A109) (0CNA042102), dated April 26, 2021.

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7. NRC email to Entergy, "As discussed during the pre-submittal meeting related to the response to EMIB-2-RAI-1, Entergy is providing our understanding of the scope of the response for NRCs review and agreement," (0CNA062104), dated June 1, 2021.

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Enclosure 3 0CAN072102 Structural Group Application for Withholding Proprietary Information from Public Disclosure (6 pages)

0CAN072102 Page 1 of 6 STRUCTURAL GROUP APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE struc*tura1 group June 29, 2021 U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD20852

Subject:

Application for Withholding Proprietary Information from Public

References:

1. Entergy Operations, Inc. (Entergy) letter to U. S. Nuclear Regulatory Commission (NRC), "Response to Request for Additional Information - Proposed A lternative to ASME Boiler & Pressure Vessel Code Section X I 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 - Final Supplemental Request for Additional Information RE: Proposed Alternative to ASME Section XI Requirements for the Repair/Replacement of Emergency Cooling Pond Supply Piping (EPID L-2020-LLR-0104)," (ML21116A109) (0CNA042102), dated April 26, 2021.

4. NRG email to Entergy, "As discussed during the pre-submittal meeting related to the response to EMIB-2-RAl-1, Entergy is providing our understanding of the scope of the response for NRC's review and agreement," dated June 1, 2021.

Ladies and Gentlemen:

Structural Group, lnc.,(SGI) has provided certain proprietary information to Entergy Operations, Inc. (Entergy), in connection with a supplemental response by Entergy to EMIB-2-RAl-1 from the U.S. Nuclear Regulatory Commission (NRC) which was provided in reference 4. This application requests that proprietary information of SGI provided in the response to EM IB-2-RA l-1 be protected from public disclosure.

The proprietary information for which withholding is being requested identified 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 reg ulations.

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0CAN072102 Page 2 of 6 struc'turat group Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Entergy.

zly; 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 President, Structural Group, Inc., 10150 Old Columbia Road, Columbia, MD21046.

Scott Greenhaus Executive Vice President 0 (410) 859-6458, M (410) 340-3205 SGreenhaus@structuralgroup.com Page 2 of 6

0CAN072102 Page 3 of 6 struc'tura1 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 conjunction 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 Regulatory Commission (NRG) 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 commercia l 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 NRG 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 response provided in Entergy's letter (Docket Nos. 50-313 and 50-368) to the NRC's "Request for Additional Information" in Reference 4 (EMIB RAl-1) includes SGI proprietary information.

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 ofthat system provides a rational basis for maintaining confidentiality and justifies the NRG 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.

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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 advantage over competitors. It is, therefore, withheld from disclosure to protect SGl's 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 response to the NRC RAJ (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 ASME Section XI Requirements 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 A NO 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.

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2) That SGI can sell support and defense of the technology to their customers in t he licensing process.

3) The information requested to be withheld reveals the distinguishi ng aspects of a methodology which was developed by SGI.

4) Public disclosure of this proprietary information is likely to cause substantial harm to the 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 developme nt 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.

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0CAN072102 Page 6 of 6 struc'tural group strucl ural 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 th;sr ; ; ; ~ [ o r r e c t to the best of h;s knowledge, ;nformaHon, and beHef WoJ Greenhaus Executive Vice President Sworn to and subscribed before me thisA1ay of June 2021 Public 1 1-f "",....h-,.-J &P,7 lf/dJ

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