2CAN121201, Revised Request for Alternative ANO2-ISI-007 Code Case N-770-1 Baseline Examination Arkansas Nuclear One, Unit 2

Revised Request for Alternative ANO2-ISI-007 Code Case N-770-1 Baseline Examination Arkansas Nuclear One, Unit 2

ML12340A449
Person / Time
Site:	Arkansas Nuclear
Issue date:	12/04/2012
From:	Pyle S Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2CAN121201, ANO2-ISI-007
Download: ML12340A449 (12)

Text

'0 Entergy0 Entergy Operations, Inc.1448 StR. 333 Russellville, AR 72802 Tel 479-858-4704 Stephenie L. Pyle Manager, Licensing Arkansas Nuclear One 2CAN 121201 December 4, 2012 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

REFERENCES:

Revised Request for Alternative ANO2-ISI-007 Code Case N-770-1 Baseline Examination Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6 1. Entergy letter dated November 30, 2011, "Use of Alternate ASME Code Case N-770-1 Baseline Examination Request for Alternative ANO2-1SI-007" (2CAN 111101) (ML113340158)2. Entergy letter dated April 13, 2012, "Response to the Request for Additional Information Regarding Request for Alternative ANO2-ISI-007 Code Case N-770-1 Baseline Examination" (2CAN041202)(ML12104A066)3. Entergy letter dated May 21, 2012, "Additional Information Related to Request for Alternative ANO2-ISI-007 Code Case N-770-1 Baseline Examination" (2CAN051202) (ML12142A319)

4. Entergy letter dated September 10, 2012, "Response to Second Request for Additional Information Request for Alternative ANO2-ISI-007 Code Case N-770-1 Baseline Examination" (2CAN091205) (ML12255A388)

5. NRC letter dated November 27, 2012, "Arkansas Nuclear One, Unit 2 -Request for Alternative ANO2-ISI-007, Use of Alternate ASME Code Case N-770-1 Baseline Examination" (TAC NO. ME7646)(ML12319A367)

Attachment 1 to this letter contains proprietary information

-Attachment 1 is withheld from public disclosure per 10 CFR 2.390.

2CAN 121201 Page 2 of 3

Dear Sir or Madam:

Section 50.55a(g)(6)(ii)(F)(3) of 10 CFR states that baseline examinations for welds in American Society of Mechanical Engineers (ASME) Code Case N-770-1, Table 1, Inspection Items A-i, A-2, and B, shall be completed by the end of the next refueling outage after January 20, 2012. Previous examination of these welds may be credited for baseline examinations if they were performed within the re-inspection period for the weld item in ASME Code Case N-770-1, Table 1 using Section Xl, Appendix VIII requirements and met the Code required examination volume of essentially 100 percent. Other previous examinations that do not meet these requirements may be used to meet the baseline examination requirement, provided NRC approval of alternative inspection requirements in accordance with paragraphs (a)(3)(i) or (a)(3)(ii) of this section is granted prior to the end of the next refueling outage after January 20, 2012.By Reference 1, as supplemented by References 2, 3, and 4 Entergy Operations, Inc.(Entergy) submitted Request for Alternative ANO2-1SI-007 for Arkansas Nuclear One, Unit 2 (ANO-2) to the NRC for relief from certain requirements of ASME Boiler and Pressure Vessel Code, Code Case N-770-1, as conditioned in the Final Rule 10 CFR 50.55a(g)(6)(ii)(F)(3), dated June 21, 2011.Specifically, pursuant to 10 CFR 50.55a(a)(3)(ii)

Entergy requested relief from achieving the Code-required coverage when performing volumetric examinations of nickel-based Alloy 82/182 dissimilar metal butt welds for the baseline examinations required by Code Case N-770-1.The NRC provided their verbal approval in Reference

5. It was noted that as part of the approval that it was limited until January 1, 2013 (approximately 40 months from the last inspection).

At that time, these welds would have to be re-inspected unless additional information was provided and this information was approved by the NRC. The purpose of this submittal is to provide the additional information that was discussed with the NRC.The analyses that were previously performed and transmitted to the NRC have been revised to include the effects of the stainless steel weld and an inner diameter weld repair of 50% wall thickness without post-repair heat treatment.

The conclusions of the analyses are that a postulated initial flaw that is 16.7% through wall would grow to the ASME Code allowable flaw size of 75% through wall in approximately 54 months from the inspection.

The largest undetected flaw that could exist due to the examination limitations is 10% through wall, providing a margin of 6.7%. This crack growth analysis supports operation of ANO-2 until the next scheduled refueling outage in which the welds will be inspected.

The details of the calculations are provided in Attachment 1 of this submittal.

To prevent an unplanned outage at the first of the year, Entergy requests approval of this alternative by December 20, 2012.The information contained in Attachment 1 is considered proprietary to Westinghouse in its entirety, and therefore, nonproprietary versions are not being provided.

Westinghouse requests that the proprietary information be withheld from public disclosure in accordance with 10 CFR 2.390. Westinghouse has provided Entergy with authorization to provide the proprietary information.

An affidavit by the information owner, Westinghouse, supporting the request for non-disclosure is provided in Attachment

2. Therefore, Entergy requests that Attachment 1 to this letter contains proprietary information

-Attachment 1 is withheld from public disclosure per 10 CFR 2.390.

2CAN 121201 Page 3 of 3 Attachment 1 of this submittal be withheld from public disclosure in accordance with 10 CFR 2.390.This submittal contains no regulatory commitments.

Should you have any questions, please contact me.Sincerely, SLP/rwc Attachments:

1. Westinghouse Calculation Note Number CN-MRCDA-1 2-27, Revision 1 entitled, "ANO-2 PWSCC Analysis for RCP Dissimilar Metal Welds" (Proprietary)

2. Westinghouse Letter CAW-12-3564, Revision 0, "Application for Withholding Proprietary Information From Public Disclosure" October 31, 2012 cc: Mr. Elmo E. Collins 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. Kaly Kalyanam MS 0-8 B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Attachment 1 to this letter contains proprietary information

-Attachment 1 is withheld from public disclosure per 10 CFR 2.390.

Attachment 2 to 2CAN121201 Westinghouse Letter CAW-12-3564, Revision 0,"Application for Withholding Proprietary Information From Public Disclosure" October 31, 2012 Westinghouse Electric Company W- 9u Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 720-0754 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 CAW-12-3564 October 31, 2012 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

Calculation Note CN-MRCDA-12-27, Revision 1, "ANO-2 PWSCC Analysis for RCP Dissimilar Metal Welds" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-12-3564 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on 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 Section 2.390 of the Commission's regulations.

The subject document was prepared and classified as Westinghouse Proprietary Class 2. Westinghouse requests that the document be considered proprietary in its entirety.

As such, a non-proprietary version will not be issued.Accordingly, this letter authorizes the utilization of the accompanying affidavit by Entergy Nuclear Operations, Inc.Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference CAW-12-3564, and should be addressed to J. A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours, iJames A. Gresham, Manager Regulatory Compliance Enclosures CAW-12-3564 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared James A. Gresham, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:&James A. Gresham, Manager Regulatory Compliance Sworn to and subscribed before me this day" day of 2012 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Anne M. Stegman, Notary Public Unity Twp., Westmoreland County My Commission Explres Aug. 7, 2016 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES 2 CAW-12-3564 (1) I am Manager, Regulatory Compliance, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) 1 have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, 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 constitutes Westinghouse policy and provides the rational basis required.Under that 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, as follows: (a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of 3 CAW-12-3564 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.(b) 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.(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.(f) It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following: (a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors.

It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW-12-3564 (d) 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 puzzle, thereby depriving Westinghouse of a competitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.(v) The proprietary information sought to be withheld in this submittal is that which is contained in Calculation Note CN-MRCDA-12-27, Revision 1, "ANO-2 PWSCC Analysis for RCP Dissimilar Metal Welds" (Proprietary), for submittal to the Commission, being transmitted by Entergy Nuclear Operations, Inc. letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with reactor coolant pump dissimilar metal welds to support the regulatory activities of Entergy Nuclear Operations, Inc. with respect to these welds in Arkansas Nuclear One, Unit 2, and may be used only for that purpose.

5 CAW-12-3564 This information is part of that which will enable Westinghouse to: (a) Support Entergy Nuclear Operations, Inc. in regulatory activities involving pressurized water stress corrosion cracking of reactor coolant pump dissimilar metal welds.Further this information has substantial commercial value as follows: (a) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses.

Also, 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.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith is the proprietary version of a document furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.

The document is to be considered proprietary in its entirety.COPYRIGHT NOTICE The report transmitted herewith bears a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in this report which is necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding.

Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Entergy Nuclear Operations, Inc.Letter for Transmittal to the NRC The following paragraphs are suggested for inclusion in your letter to the NRC Document Control Desk: Enclosed are: 1. 1 copy of Calculation Note CN-MRCDA-12-27, Revision 1, "ANO-2 PWSCC Analysis for RCP Dissimilar Metal Welds" (Proprietary)

Also enclosed is the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-12-3564, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.The subject document was prepared and classified as Westinghouse Proprietary Class 2. Westinghouse requests that the document be considered proprietary in its entirety.

As such, a non-proprietary version will not be issued.As Item I contains information proprietary to Westinghouse Electric Company LLC, it is supported by an affidavit signed by Westinghouse, the owner of the information.

The affidavit sets forth the, basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.

Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-12-3564 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.