GO2-13-111, Response to Request for Additional Information Related to License Amendment Request to Implement Prnm/Arts/Mellla

Response to Request for Additional Information Related to License Amendment Request to Implement Prnm/Arts/Mellla

ML13233A287
Person / Time
Site:	Columbia
Issue date:	08/06/2013
From:	Swank D Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-13-111, TAC ME7905
Download: ML13233A287 (19)

Text

David A.Swank Columbia Generating Station P.O. Box 968, PE04 Richland, WA 99352-0968 NORTHW EST Ph. 509.377.2309 1 F. 509.377.4150 daswank@energy-northwest.com Proprietary - Withhold under 10 CFR 2.390. Enclosure I contains PROPRIETARY information.

August 6, 2013 G02-13-1 11 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST TO IMPLEMENT PRNMIARTSIMELLLA

References:

1) Letter, G02-12-017, dated January 31, 2012, BJ Sawatzke (Energy Northwest) to NRC, "License Amendment Request to Change Technical Specifications in Support of PRNM /ARTS / MELLLA Implementation" (ADAMS Accession No. ML12040A072)

2) Letter dated July 10, 2013, NRC to ME Reddemann (Energy Northwest),

"Columbia Generating Station - Request for Additional Information Related to License Amendment Request to Implement PRNM/ARTS/MELLLA (TAC NO. ME7905)" (ADAMS Accession No. ML13179A128)

Dear Sir or Madam:

By Reference 1, Energy Northwest requested approval of a license amendment request to revise the Columbia Generating Station Technical Specifications to reflect improvements in the Average Power Range Monitor / Rod Block Monitor Technical Specifications (ARTS) and expand the facility operating domain to reflect operations using the Maximum Extended Load Line Limit Analysis (MELLLA). These improvements coincide with the installation of the digital General Electric-Hitachi (GEH)

Nuclear Measurement Analysis and Control (NUMAC) Power Range Neutron Monitoring (PRNM) System.

Via Reference 2, the Nuclear Regulatory Commission (NRC) requested additional information related to the Energy Northwest submittal. Transmitted herewith in Enclosure I is the response to the request for additional information (RAI).

When Enclosure 1 is removed from this letter, the letter and remaining Enclosures are NON-PROPRIETARY.

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO 'LICENSE AMENDMENT REQUEST TO IMPLEMENT PRNMWARTS/MELLLA Page 2 There are no new regulatory commitments identified with this response. Should you have any questions or require additional information regarding this matter, please contact Ms. L. L. Williams, Licensing Supervisor, at (509) 377-8148. contains proprietary information as defined by 10 CFR 2.390. GEH, as the owner of the proprietary information, has executed the affidavit, included in Enclosure 3, which identifies that the enclosed proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure. The proprietary information was provided to Energy Northwest in a GEH transmittal that is referenced by the affidavit. The proprietary information has been faithfully reproduced in the respective Enclosure such that the affidavit remains applicable. GEH hereby requests that the enclosed proprietary information be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390 and 9.17.

Information that is not considered proprietary is provided in Enclosure 2.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.

Respectfully, DA Swank Assistant Vice President, Engineering - Response to RAls, Enclosure 1 of GEH Letter GE-MS-CT-1 06244-JC25, "GEH Responses to NRC EICB RAIs 22-28," (Proprietary) - Response to RAIs, Enclosure 2 of GEH Letter GE-MS-CT-106244-JC25, "GEH Responses to NRC EICB RAls 22-28," (Non Proprietary) -Affidavit for Enclosure 1 cc:

NRC Region IV Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C AJ Rapacz - BPA/1 399 (email - Enclosure 2 & 3)

WA Horn - Winston & Strawn (email - Enclosure 2 & 3)

JO Luce - EFSEC (email - Enclosure 2 & 3)

RR Cowley - WDOH (email - Enclosure 2 & 3)

GE-MS-CT-106244-JC25 GEH Responses to NRC EICB RAls 22-28 Non-Proprietary Information-Class I (Public)

No*-Proprietary Notice This is a non-proprietary version of the Enclosure 1 of GE-MS-CT-106244-JC25 which has the proprietary information removed.

Portions of the document that have been removed are indicated by an open and closed bracket as shown here ((

fl.

Non-Proprietary Information - Class I (Public)

GE-MS-CT-106244-JC25 Page 2 of 13 With regard to Staff Position 20 of Digital Instrumentation and Controls DI&C-ISG-04, Revision 1, "Task Working Group #4: Highly-Integrated Control Rooms--Communications Issues (HICRc), Interim Staff Guidance," dated March 6, 2009 (ADAMS Accession No. ML083310185), the licensee has stated that ((

)). If this test data is available by middle of August 2013, please provide a summary of the test results. If such data is not likely to be available by August 31, 2013, please provide the date by which the data will be available for CGS.

Data error rate testing was completed in October of 2011 and the test data is available.

))The table below summarizes the test results.

((

The test results validate that the observed data error rates are less than or equal to the established design basis error rates.

Non-Proprietary Information - Class I (Public)

GE-MS-CT-106244-JC25 Page 3 of 13 Recirculation flow signal processing electronics are being replaced by integrated digital NUMAC chassis based APRM electronics. The APRM is to be designed such that any single short or open of any one of the flow inputs will not affect the other flow inputs. Energy Northwest has stated that ((

f]. Please confirm how the flow transmitter signal to local power range monitor (LPRM) system will be isolated such that there is no adverse effect on the safety system due to an open circuit, a short circuit, or a ground fault. Since the eight flow transmitters are not safety related, Energy Northwest is requested to clarify how the safety to non-safety interface and signal isolation is achievedfor the flow transmitters.

The flow transmitter signals and local power range monitor (LPRM) detectors enter the LPRM Input Modules within the average power range monitor (APRM) instruments. ((

)) These devices provide the isolation to prevent adverse effects on the safety system due to an open circuit, a short circuit or ground fault in the LPRM detectors or flow transmitter signals.

Non-Proprietary Information - Class I (Public)

GE-MS-CT-106244-JC25 Page 4 of 13 In order to determine that Rod Manual Control System (RMCS) to Rod Block Monitor (RBk) communication link will not be subject to a broadcast storm, the licensee is requested to confirm whether the data communicated over the serial link from the RMCS to the RBM is fixed and validated prior to use.

If not, please explain how data broadcast storm is avoided such that adverse effects on the functioning of RBM are prevented GEH JUmans The design and implementation of the Columbia Generating Station (CGS) RBM ensures that a broadcast data storm from the RMCS to the RBM does not have an adverse effect on the functioning of the RBM.

))

Therefore, there are no adverse effects on the functioning of the RBM in the event of a data broadcast storm.

Non-Proprietary Information - Class I (Public)

GE-MS-CT-106244-JC25 Page 5 of 13 NRC RAI 25 Table 1, Columbia NUMAC PRNM Licensing Topical Report (LTR) Deviations in 0000-0101-7647-R3 (ADAMS Accession No.

MT12040A073) lists three exceptions.

Exception (a) states that Oscillation Power Range Monitor (OPRM) Upscale function is voted with APRM INOP [inoperable] Function with the justifcation that it improves operating flexibility.

The PRNM licensing basis, as described in the in the document cited above, is that "OPRM Upscale function is voted separately from the APRM INOP function. " The justification for this deviation is to improve operational flexibility. As the licensee states, This deviation allows using the APRM chassis keylock switch to place APRM and OPRM outputs from a second channel in the tripped condition when another APRM/OPRM channel is already bypassed (and cannot be returned to service within the allowed out of service time) without having to resort to other actions such as disconnecting a fiber-optic cable to the 2-out-of-4 voters or removing power from the APRM chassis.

Section 8.4.1.3 of NEDC-32410P', Supplement 12 states, in part, that combining the OPRM upscale with the APRMINOPfunction could result in unnecessary trips. Unnecessary trips are considered nuisances and challenges to the safety system. Based on the rationale provided in Section 8.4.1.3 of NEDC-32410P, Supplement 1, please furtherjust6fy this change with the regard to spurious trips.

G-HUnse The concern about unnecessary trips was because of the limited operational experience with OPRMs at the time LTR Supplement 1 was written. Note that Section 8.4.1.3 of Reference 25-1 states ((

)) With over 200 plant-years of operational experience with installed OPRMs, those uncertainties no longer remain.

This LTR deviation has been part of other approved NUMAC PRNM license amendment requests, including Grand Gulf Nuclear Station (Reference 25-2) and Monticello Nuclear Generating Plant (Reference 25-3). No unnecessary trips due to this design feature have been reported.

Reference 25-1.

GE Nuclear Energy, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," NEDC-32410P-A, Supplement 1, November 1997.

NEDC-32410P-A, "'Nuclear Measurment Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function, Volumes I and 2, " October 1995 (ADAMS Legacy Accession No. 9605290009).

2 NEDC-3241OP-A, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function, Supplement I '" November 1997 (ADAMS Legacy Accession No. 9806120242).

Non-Proprietary Information - Class I (Public)

GE-MS-CT-106244-JC25 Page 6 of 13 25-2. NRC Letter, "Grand Gulf Nuclear Station, Unit 1 - Issuance of Amendment RE: Power Range Neutron Monitoring System Replacement (TAC NO. ME253 1)," dated March 28, 2012 (ADAMS Accession No. ML120400319).

25-3. NRC Letter, "Monticello Nuclear Generating Plant (MNGP)-Issuance of Amendment Regarding the Power Range Neutron Monitoring System (TAC NO. MD8064)," dated January 30, 2009 (ADAMS Accession No. ML083440681).

Non-Proprietary Information - Class I (Public)

GE-MS-CT-106244-JC25 Page 7 of 13 NRK RAI 26 Table I, Columbia NUMAC PRNMLTR Deviations in 0000-0101-7647-R3 (ADAMS Accession Nos. MI1204OA081 (non-public) and ML1204OA073 (public)) lists three exceptions and the second exception (Exception b) states that time to calculate the Flow-biased Trip Setpoint takes more than the allocated time in LTR NEDC-32410P-A, Volume 14, Section 3.3.2, with the explanation that ([

1]

Section 3.3.2 of NEDC-3241OP-A, in part states that:

[1 1]

)) The NRC staff is concerned that the intent of the trip may not be met for fast transients due to the excessive response time. Pleasefurt her justify this deviation for back up protection against all transients. In addition, please cite any precedence with regard to this deviation, *f available.

Columbia has Rosemount recirculation flow transmitters that are typical and widely used in the industry. They are unaffected by a PRNM retrofit. The time constant of these transmitters

((I

)) This deviation was discovered during the Columbia project. [C

)) Because the topic is not unique to Columbia, GEH notified other customers with installed PRNM systems.

The processing time is not a concern during fast transients because the STP trip does not protect against them. The APRM neutron flux high trip is intended to address fast transients. By contrast, the STP trip is intended to provide protection against a slow positive reactivity addition scenario such as Loss of Feedwater Heating, where thermal power increases slowly. While the sequence of events may produce sufficiently high flux levels to initiate an APRM reactor protection system trip, no credit is taken for a reactor trip on STP in the safety analysis of the event.

Non-Proprietary Information - Class I (Public)

GE-MS-CT-106244-JC25 Page 8 of 13 Reference 26-1.

GE Nuclear Energy, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," NEDC-3241OP-A Volume 1, October 1995.

Non-Proprietary Information - Class I (Public)

GE-MS-CT-106244-JC25 Page 9 of 13 NRC RAI127 Table 1, Columbia NUMAC PRNMLTR Deviations in 0000-0101-7647-R3 lists three exceptions and the third exception (Exception c) states that any missing module in a chassis causes an alarm but not necessarily a trip whereas the PRNM licensing basis states that ((

)) Energy Northwest justifies this exception by referring to the purpose of the APRMINOP trip described in NEDC-32410P-A, Section 3.2.10.1, and stating that ((

1] is beyond the intent.

The NRC staff has not found any statement in NEDC-32410P-A, Section 5.3.8.2 or Section 3.2.10.1, which states this rationale. Therefore, please clarify and further justify this exception.

Section 3.2.10.1 of Reference 27-1 specifies ((

)) and it is not desirable to cause an Inop trip if such a module were determined to be missing from the instrument. The system is designed to provide an alarm when a module is missing and to provide a trip only when performance of the safety function is affected. Detailed discussion of self-test faults was provided in Reference 27-2.

Referen=e 27-1.

GE Nuclear Energy, "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," NEDC-32410P-A, Volume 1, October 1995.

27-2. GE Nuclear Energy, "Columbia Generating Station Power Range Neutron Monitoring System Design Report on Computer Integrity, Test and Calibration, and Fault Detection,"

NEDC-33698P, Revision 2, December 2012.

Non-Proprietary Information - Class I (Public)

GE-MS-CT-106244-JC25 Page 10 of 13 NRK RAI 28 As mentioned earlier, the setpoint calculation audit was conducted by NRC on April 3, 2013.

Subsequent to the meeting, the staff observed that there are minor discrepancies between the previously provided Figure 9.3.8.1 in GEH setpoint methodology in NEDC-33685P (ADAMS Accession Nos. ML,1204OA082 and ML12040A074) and the response to RAI 18 provided by Energy Northwest's letter dated October 5, 2012. Figure 9.3.8.1 shows the required limit ((

1] whereas Figure RAI 18-1 shows the ((

]I Energy Northwest is requested to explain the noted discrepancy.

GEH Respps:

Overview of the Differences in Information Ia the Figures:

Both Figure 9.3.8-1 in NEDC-33685P (Reference 28-1) and Figure RAI 18-1 (Reference 28-2) indicate the errors considered in the margin between the Technical Specifications Allowable Value (TS AV) and the final adjusted Nominal Trip Setpoint, called "NTSP(ADJ)" and, more recently, "NTSP Final (NTSPF)." However, the figure provided in the RAI 18 response is a simplified pictorial representation of the GEH setpoint methodology to discuss the pertinent features described in that RAI response. Both figures indicate the same method and procedure for calculating the Licensee Event Report (LER) Avoidance Margin, but because the calculation process is complicated, the figures provided slightly different ways of displaying the process in a simple way. The more detailed Figure 9.3.8-1 displays an intermediate LER Avoidance Margin, corresponding to an intermediate NTSP calculation.

As explained in the description in NEDC-33685P (Reference 28-1) that accompanies Figure 9.3.8-1, the initial instrument setting, NTSP1 3, might be too close to the AV. If the AV/NTSPI margin is not sufficient for the LER avoidance test, the NTSP is conservatively adjusted to provide added margin from the AV. The GEH Setpoint Methodology includes a multiple-step process to determine the final NTSP with sufficient margin from the AV for LER avoidance.

The first step is changing NTSPI to NTSP2, an intermediate NTSP, which involves the [f

))

The GEH setpoint methodology performs a Leave Alone Tolerance 4 (LAT) test to determine if the NTSP needs to be adjusted further in the conservative direction, as was described in NEDC-33685P (Reference 28-1). This second step in changing to the final adjusted NTSP(ADJ) 3 Note that NTSPI is the Limiting Trip Setpoint (LTSP), as the instrument setting nay be no closer to the Analytical Limit (AL) than NTSPI.

4 Note per the guidance provided in RIS 2006-17 (Reference 28-3) and TSTF-493 (Reference 28-4), the instrument setting must be set equal to the Limiting Trip Setpoint after periodic testing. In practice, the instrument setting is reset to the Final NTSP +/-ALT after each calibration. Thus, the LAT is set equal to the ALT in the GEH setpoint calculations.

Non-Proprietary Information - Class I (Public)

GE-MS-CT-106244-JC25 Page 11 of 13 (i.e., NTSPF) also involves determining the ((

)) and may result in an adjustment to the setpoint in the conservative direction to the final adjusted NTSPF.

This two-step methodology was simplified in Figure RAI 18-1 provided in the RAI 18 response (Reference 28-2), as was explained in that RAI response. The methodology for calculating the setpoints in Figure RAI 18-1 is exactly the same as what was previously described in Figure 9.3.8-1 in NEDC-33685P (Reference 28-1).

However, for simplification, Figure RAI 18-1 leaves out the pictorial representation of NTSP2, the intermediate NTSP.

Hence, the change from NTSPI to the final adjusted NTSPF shown in that figure includes the interim steps of [C

)) However, because it is a simplified figure, it does not show the interim steps.

For convenience, see Figure RAI 28-1.

Hence, the differences in the two figures are simply differences in notation and there is no discrepancy in the setpoint methodology used for the Columbia PRNM!ARTS/MELLLA setpoint calculations.

Non-Proprietary Information - Class I (Public)

GE-MS-CT-106244-JC25 Page 12 of 13

((

11 Figure RAI 28-1 GEH Simplifled Setpoint Methodology Note that for clarity, the figure provided in the response to RAI 7 (Reference 28-2),

Figure RAI 7-1, should have been made to be the same as Figure RAI 18-1, so that it would indicate that the errors considered in the ((

I]

Summary:

Thus, the final NTSPF includes [

Non-Proprietary Information - Class I (Public)

GE-MS-CT-106244-JC25 Page 13 of 13 11 Also, the final NTSPF includes sufficient margin from the AL as the margin between the AL and the final NTSP is at least equal to, and generally greater than that needed to meet the 95%

probability requirement of Regulatory Guide 1.105. That is, the final adjusted NTSP(ADJ) is generally more conservative than NTSP 1, the Limiting Trip Setpoint.

Refren 28-1.

GE Hitachi Nuclear Energy, "Digital I&C-ISG-06 Compliance for Columbia Generating Station NUMAC Power Range Neutron Monitoring Retrofit Plus Option III Stability Trip Function," NEDC-33685P, Revision 2, dated December 2012.

28-2. Energy Northwest Letter, "Columbia Generating Station, Docket No. 50-397 Response to Request for Additional Information Regarding Licensing Amendment Request to Implement PRNMIARTS/MELLLA," G02-12-135, dated October 5, 2012 (ADAMS Accession No. ML122920735).

28-3. NRC Regulatory Issue Summary (RIS) 2006-17, "NRC Staff Position on the Requirements of 10 CFR 50.36, 'Technical Specifications,' regarding Limiting Safety System Settings during Periodic Testing and Calibration of Instrument Channels,"

August 24,2006 (ADAMS Accession No. ML051810077).

28-4. Letter, TSTF to NRC, "Transmittal of TSTF-493 Revision 4, Errata," TSTF-10-07, dated April 23, 2010 (ADAMS Accession No. MLI01 160026).

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING UCENSE AMENDMENT REQUEST TO IMPLEMENT PRNIWARTS/MELLLA Affidavit for Enclosure 1

GE-Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, Linda C. Dolan, state as follows:

(1) I am the Manager of Regulatory Compliance, Regulatory Affairs, of GE-Hitachi Nuclear Energy Americas LLC ("GEH"), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in Enclosure I of GEH letter, GE-MS-CT-106244-JC25, "ENW-CGS PRNM/ARTS/MELLLA Round 4 RAI Responses," dated July 25, 2013. The GEH proprietary information in Enclosure 1, which is entitled "GEH Responses to NRC EICB RAls 22-28," is identified by a dotted underline inside double square brackets. ((,

q ý ie '

11 In each case, the superscript notation I refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GEH relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA'), 5 U.S.C. Sec. 552(b)(4), and the Trade Secrets Act, 18 U.S.C.

Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for trade secrets (Exemption 4). The material for which exemption from disclosure is here sought also qualifies under the narrower definition of trade secret, within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Proiect v. Nuclear Regulatoy Commission. 975 F.2d 871 (D.C. Cir. 1992), and Publki Citizen Health Research Group v. FDA. 704 F.2d 1280 (D.C. Cir. 1983).

(4) The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. Some examples of categories of information that fit into the definition of proprietary information are:

a.

Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GEH's competitors without license from GEH constitutes a competitive economic advantage over other companies;

b.

Information that, if used 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 of a similar product;

c.

Information that reveals aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential products to GEH;

d.

Information that discloses trade secret or potentially patentable subject matter, or both, for which it may be desirable to obtain patent protection.

(5) To address 10 CFR 2.390(b)(4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GEH, Affidavit for Enclosure I of GE-MS-CT-106244-JC25 Page 1 of 3

GE-Hitachi Nuclear Energy Americas LLC and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GEH, not been disclosed publicly, and not been made available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions, or to proprietary or confidentiality agreements that provide for maintaining the information in confidence. The initial designation of this information as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in the following paragraphs (6) and (7).

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, who is the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or who is the person most likely to be subject to the terms under which it was licensed to GEH. Access to such documents within GEH is limited to a "need to know" basis.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist, or other equivalent authority for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GEH are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary or confidentiality agreements, or both.

(8) The information identified in paragraph (2), above, is classified as proprietary because it contains the detailed setpoint methodology and design information for the instrumentation and control equipment that is used in the design and analysis of the power range neutron monitoring system for the GEH Boiling Water Reactor (BWR). These methods, techniques, and data along with their application to the design, modification, and analyses associated with the power range neutron monitoring system was achieved at a significant cost to GEH.

The development of the evaluation process, as well as the interpretation and application of the analytical results, constitutes a major GEH asset that is derived from the extensive lie cycle experience that is recorded in databases for this equipment. Moreover, the procedure documentation is generally held as company proprietary throughout the General Electric Company. The procedure document discussed with reference to the verification process used by GEH is a part of the overall General Electric Company library of procedures that has been developed over the company's long history.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GEH's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost.

The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

Affidavit for Enclosure I of GE-MS-CT-106244-JC25 Page 2 of 3

GE-Hitachi Nuclear Energy Americas LLC The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GEH. The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial. GEH's competitive advantage will be lost if its competitors are able to use the results of the GEH experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to GEH would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.

I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.

Executed on this 2 5 h of July 2013.

Linda C. Dolan Manager, Regulatory Compliance Regulatory Affairs GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Rd.

Wilmington, NC 28401 Affidavit for Enclosure 1 of GE-MS-CT-106244-JC25 Page 3 of 3