L-MT-15-065, Enclosure 8, Areva Report ANP-3424NP, Revision 1 to Areva Responses to RAI from Scvb on MNGP EFW LAR (Non-Proprietary) and Enclosure 9, Areva Affidavits
| ML15274A476 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 09/29/2015 |
| From: | AREVA |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML15274A484 | List: |
| References | |
| L-MT-15-065, TAC MF5002 ANP-3424NP, Rev. 1 | |
| Download: ML15274A476 (29) | |
Text
L-MT-1 5-065 Enclosure 8 ARE VA Report ANP-3424NP Non-Proprietary AREVA Responses to RAI from SCVB on MNGP EFW LAR Revision 1 August 2015 21 pages follow
Contro~led Document A
ARE VA AN P-3424N P Revision 1 AREVA Responses to RAI from SCVB on MNGP EFW LAR August 2015 (c) 2015 AREVA Inc.
Controlled Document AREVA Inc.
ANP-3424NP Revision 1 Copyright © 2015 AREVA Inc.
All Rights Reserved
Controdled Document ANP-3424NP AREVA Responses to RAI from Revision 1 SCVB on MNGP EFW LAR Pagei Nature of Changes Item Description and Justification Page
- 1. 2-3 Corrected a decay heat value in Table 3.
AREVA Inc.
Controlled Document ANP-3424NP AREVA Responses to RAI from Revision 1 SCVB on MNGP EFW [AR Page ii Contents 1.0 Introduction............................................................................................. 1-1 2.0 RAIs and Responses ........................................ :......................................... 2-1 3.0 References ............................................................................................. 3-1 Tables Table I ATWS Containment Heatup Key Results ............................................................. 2-I Table 2 Kinetics Parameters Comparison ...................................................................... 2-2 Table 3 Decay Heat Comparison................................................................................ 2-3 Table 4 Short Term Containment Results ...................................................................... 2-5 AREVA Inc.
Controlled Document ANP-3424NP AREVA Responses to PAl from Revision 1 SCVB on MNGP EFW LAR Page iii Nomenclature Acronym Definition
$ Dollar, relative unit for reactivity ANS American Nuclear Society ATWS Anticipated Transient Without Scram BOGC Begin nin g-of-Cycle DBA Design Basis Accident ECCS Emergency Core Cooling Systems EFW Extended Flow Window EOC End-of-Cycle EPU Extended Power Uprate GE General Electric GL Generic Letter HPCI High Pressure Coolant Injection LAR License Amendment Request LOCA Loss-Of-Coolant Accident LPCI Low Pressure Coolant Injection MCPR Minimum Critical Power Ratio MELLLA+ Maximum Extended Load Line Limit Analysis Plus MNGP Monticello Nuclear Generating Plant NPSH Net Positive Suction Head NRC Nuclear Regulatory Commission, U.S.
RAI Request for Additional Information RCIC Reactor Core Isolation Cooling RHR Residual Heat Removal SCVB Staff in Containment and Ventilation Branch SGTS Standby Gas Treatment System SRV Safety Relief Valve AREVA Inc.
Controlled Document ANP-3424NP AREVA Responses to RAI from Revision 1 SCVB on MNGP EFW LAR Page 1-1 1.0 Introduction In Reference 1, Northern States Power Company - a Minnesota corporation, doing business as XceI Energy, submitted a license amendment request for the Monticello Nuclear Generating Plant (MNGP).
The application was supplemented by Reference 2. The amendment would revise the Technical Specifications and approve certain AREVA analytical methods to support plant operation in the expanded power-flow domain described as the Extended Flow Window (EFW).
The U.S. Nuclear Regulatory Commission (NRC) staff in the Containment and Ventilation branch (SCVB) has reviewed the application and concluded that additional information is necessary to complete its review. Draft Requests for Additional Information (RAI) were provided as an attachment to Reference 3.
The RAI and the AREVA responses are attached.
These responses are provided so that XceI Energy can provide a complete set of responses to the NRC by combining the AREVA responses with the responses being prepared by XceI Energy.
AREVA Inc.
Controlled Document ANP-3424NP AREVA Responses to RAI from Revision 1 SCVB on MNGP EFW [AR Page 2-1 2.0 RAIs and Responses SCVB RAI-1 In Table 2. 1 Disposition of Events Summary of ANP-3295P, the licensee states that the fuel dependent characteristicsvoid coefficient and boron worth, important to containment response, were compared for events without scram (Anticipated Transients Without Scram (A TWS)) and the analysis of record remains applicable. The licensee references Section 7.2.2 for the comparison and states that((t
- 11. There is no quantifiable comparison between the fuel characteristicsfor GEl4 fuel at Maximum Extended Load Line Limit Analysis Plus (MELLLA +) conditions and ATRIUM TM IOXM* fuel at Extended Flow Window (EFW) conditions.
- a. Provide the comparison andjustify the use of the GEI4 MELLLA+ analysis as bounding.
- b. Provide a table of the containment response limits and the GEI4 and ATRIUM I OXM values.
ARE VA Response
- a. The licensing basis for MNGP MELLLA+ is summarized in Section 4.1 of Reference 11.
Additional information about the MNGP ATWS analyses is summarized in Reference 4. [
]
- b. The ATIWS containment results for GEl4 values (Reference 4) are provided in the following table together with the design limits. [
Table I ATW3S Containment Heatup Key Results GEl4 EPU GEl4 M+ Design Item Parameter Unit Value Value Limit 1 Peak °F [ J [ ] 281 Suppression Pool Temperature _____
2 Peak psig i[ ] [ ] 56 Containment Pressure
- ATRIUM is a trademark of AREVA Inc.
AREVA Inc.
Controlled Document ANP-3424NP AREVA Responses to RAl from Revision 1 SCVB on MNGP EFW LAR Page 2-2 SCVB RAI-2 In Table 2.1 Disposition of Events Summary of ANP-3295P, under the comment section for A TVVS, it is stated that the decay heat is used for the long-term cooling analysis and that containment heatup was dispositioned by comparing kinetics parameters forATRIUM IOXM fuel with those for the fuel in the analysis of record. The analysis of record is based on GEI4 fuel.
Provide the comparison of kinetics parameters, decay heat, and justify the use of the analysis of record for containment heatup.
AREVA Response The fuel in the analysis of record is GE14 while the fuel in the EFW analysis is ATRIUM 10OXM. [
]
Table 2 Kinetics Parameters Comparison Unit of Void Coefficient is (Ak/k)/(AVF), where Ak/k = (ki-kf)/ki and AVE = yE1 - VFf Unit of Boron Worth is Ak/k, where Ak/k = (ki-kf)lki Unit of Doppler Coefficient is (Ak)/(A°F), where Ak = (ki-kf) and A°F = 0F, -°F UO 2 is used in both the GEI4 and ATRIUM 10XM fuel designs. [
] Decay heat is the heat produced by the decay of fission products which depend on the power levels at which the reactor is operated, the amount of time spent at those power levels, and the time after shutdown; [
AREVA Inc.
ANP-3424NP AREVA Responses to RAl from Detocmeaisnt Revision 1 SCVB on MNGP EFW LAR Page 2-3 CoTrolle3Dea
[ ]
Table 3 Decay Heat Comparison E
]
AREVA Inc.
Controll~ed Document ANP-3424NP AREVA Responses to RAI from Revision 1 SCVB on MNGP EFW LAR Page 2-4 SCVB RAI-3 In supplement ANP-3376P, Section 4.4.1, the licensee stated:
"The short term containment pressure depends on the break energy which is derived from the break flow rate and enthalpy. Break flow and enthalpy from a design basis break in the recirculationsuction line depend on conditions inside the reactor vessel (pressure,power, feedwater temperature, etc.), but do not depend on the fuel design.
Thus, the analysis of recordfor short-term containmentpressure remains valid (bounding) for ARE VA ATRIUM IOXM fuel operating within EFW because: (1) the analysis results do not depend on fuel design, and (2) the methodology for MNGP containment analyses is not being changed by the EFW LAR."
The U.S. Nuclear Regulatory Commission (NRC) staff disagrees that the short-term analysis does not depend on fuel design. The staff notes that even though for the proposed fuel the decay heat is based on the same standardAmerican Nuclear Society (ANS) 5.1-1971 as currently used, the normalized decay heat values versus time will be different and should be considered.
The short-term analysis for mass and energy (M&E) release is during the blowdown, refill, and reflood phases of loss-of-coolant accident (LO CA) which are described below:
BLOWDOWN The period from accident initiation (when the reactoris at steady-state operation) to the time that the reactorvessel reaches initial pressure equilibrium with containment.
REFILL The period of time when the Core Spray (CS) pumps are delivering spray water above the core and the Residual Heat Removal (RHR) pumps in the Low PressureCoolant Injection (LPCI) mode are delivering water to the lower plenum.
REFLOOD As the two-phase level in the core recovers and is reflooded, continued core cooling is provided by the CS pumps and RHR pumps in the LPCI mode.
The current (Extended Power Uprate (EPU) in MELLLA operating domain) short term containment analysis was performed using LAMB code for M&E release calculation and M3CPT code for containment response. During the above phases of LOCA, a significant portion of M&E release is based on the fuel related parameterswhich are (a) initial stored energy in the fuel, (b) the energy transferredfrom the fuel to the reactorcoolant, and (c) the decay heat. The core stored energy should be determined consistent with the initial conditions and time in the fuel cycle life and for conservatism should be biased high by using a low value of gap (between the U02 and the cladding) conductance. For the energy transferredto the reactorcoolant, for conservatism, an upperbound gap conductance should be used during the transient to maximize the stored energy transferredto the coolant (reference 10 CFR 50 Appendix K Sections l.A. I through I.A.3). The decay heat should be based on ANS 5. 1-1971 plus 20-percent for uncertainty.
The NRC staff proposes the following options for responding to this RAI:
Option A
- a. Perform a revised licensing basis analysis for the short term pressure containment response using the currently used codes LAMB and M3CPT for the proposed fuel change and provide key inputs, assumption, description of analysis, and results (peak values and graphs).
- b. Providejustification if conservatism in any of the inputs and assumptions is reduced.
AREVA Inc.
Controlled Document ANP-3424NP AREVA Responses to RAI from Revision I SCVB on MNGP EFW LAR Page 2-5 Option B
- a. Considering the differences in the proposedATRIUM IOXM fuel and the current GEI4 fuel (e.g.,
mass, materialproperties, core flow, decay heat, heat transfercoefficients and any other variations),justify the initial core stored energy, energy transferredto the reactorcoolant, and the decay heat during the transient is bounded by the same in the current licensing basis analysis.
Forthis purpose, provide a comparison of all parametersused in the analysis with qualitative reasonsjustifying that the value of each parameterin the current analysis leads to a transient that will bound the same transientin the analysis for the proposed fuel.
ARE VA Response Option B will be used to respond. The following table compares the results for the MNGP short term containment analysis to the design limits. This analysis was performed by GE for MNGP based on a core of GEI4 fuel and these results are reported in Reference 5 (Section 3.3.1).
Table 4 Short Term Containment Results GEI4 EPU GEl4 M+
Parameter* Unit Value Value Design Limit Drywell Peak Pressure psig [ ] [ ] 56 Drywell Peak Temperature 0F [ ] [ ] 340**
DW-WW Peak Differential psid [ ] [ ] N/A Pressure
[
]
10 CER 50 Appendix K Section l.A describes the sources of heat during the LOCA. [
]
AREVA Inc.
Controlled Document AN P-3424N P AREVA Responses to RAI from Revision 1 SCVB on MNGP EFW LAR Page 2-6 I
AREVA Inc.
Controlled Document AN P-3424N P AREVA Responses to RAI from Revision 1 SCVB on MNGP EFW LAR Page 2-7 1
Decay heat is principally a function of the reactor power level, the irradiation time and the time after shutdown. [
]
AREVA Inc.
Control~ed Document ANP-3424NP AREVA Responses to RAl from Revision 1 SCVB on MNGP EFW LAR Page 2-8 SCVB RAI-4 Section 4.4.7 of ARE VA document ANP-3376P Revision 0, "Supplement to Xcel Energy License Amendment Request for ARE VA Extended Flow Window" (ADAMS accession number ML15022A162),
states:
"Since the methodology for MNGP containment analyses is not being changed by the EFW LAR, the only way the change from GEl4 to ATRIUM IOXM fuel could potentially impact the containment dynamic loads would be due to differences in sensible heat (short-term) and decay heat (long term)."
The staff agrees, however as stated in RAIs 3 and 7, there are differences in the short term energy release and the long term decay heat. Consideringthe differences, provide an evaluation of the impact on the containmentdynamic loads including subcompartment pressurizationloads, LOCA loads, and SRV loads and justify that the currentloads bound the same in the EFW operating domain.
ARE VA Response The licensing basis for MNGP containment dynamic loads including subcompartment pressurization loads, LOCA loads, and SRV loads at MELLLA+ conditions is summarized in Sections 4.1.3 and 4.1.4 of Reference 11, which was transmitted to the NRC as Attachment 3 of Reference 12. Additional information about these MNGP containment analyses are summarized in Reference 5.
] The impact of changing from GEl4 fuel to ATRIUM 10XM fuel was evaluated in response to RAI-1, RAI-2, and RAI-3.
AREVA Inc.
Controlled Document AREVA Responses to RAI from ANP-3424NP Revision 1 SCVB on MNGP EFW LAR Page 2-9 SCVB RAI-5 The current (EPU in MELLLA operating domain) long term analysis was performed using Super HEX (SHEX) code in which the M&E release included the stored energy in the fuel, energy transfer from the fuel to reactorcoolant, and decay heat besides the sensible heat in reactormaterials. Therefore, differences between these parametersfor the proposed and the current fuel should be considered for the following analyses:
- a. Suppression pool temperature response
- b. Drywell gas temperature response
- c. Net positive suction head (NPSH) analysis The NRC staff proposes the following options for responding to this RAI:
Option A
- a. Revise the above (a), (b), and (c) licensing basis analyses using the currently used SHEX code for the proposed fuel change and provide key inputs, assumption, description of analysis, and results (peak values and graphs).
- b. Providejustification if conservatism in any of the inputs and assumptions is reduced.
Option B
- a. Consideringthe differences in the fuel, justify the above (a), (b), and (c) current licensing basis analyses are bounding.
- b. For this purpose, provide a comparison of all parameters used in the analysis with qualitative reasonsjustifying that the value of each parameterin the current analysis leads to a transient that will bound the same transientin the analysis for the proposed fuel.
AREVA Response Option B will be used to respond this RAI. The licensing basis for MNGP containment system performance at MELLLA+ conditions is summarized in Section 4.1 of Reference 11. The licensing basis for MNGP containment system performance at EPU/MELLLA conditions is summarized in Section 2.6 of Reference 13, which was transmitted to the NRC as Enclosure 5 of Reference 14. Additional information about the MNGP containment analyses are summarized in Reference 15 for EPU/MELLLA and in Reference 5 for MELLLA+.
- Suppression pool temperature response. The long-term suppression pool temperature response for MNGP at MELLLA+ conditions is summarized in Section 4.1.2 of Reference 11.
[
] The impact of changing from GEI4 fuel to ATRIUM 10XM fuel was evaluated in response to RAI-1, RAI-2 and RAI-3.
- Drywell gas temperature response. The drywell gas temperature response for MNGP at MELLLA+ conditions is summarized in Section 4.1.1 of Reference 11.[
]
AREVA Inc.
Controlled Document ANP-3424NP AREVA Responses to RA! from Revision 1 SCVB on MNGP EFW LAR Page 2-10
[ ] The impact of changing from GEI4 fuel to ATRIUM 10XM fuel was evaluated in response to RAI-1, RAI-2, and RAI-3.
- NPSH analyses. NPSH analyses for MNGP at MELLLA+ conditions are summarized in Section 3.6.2 (recirculation pumps and jet pumps), Section 3.9.3 (RClC) and 4.2.1 (HPCI) of Reference 11. [:
] The impact of changing from GEI4 fuel to ATRIUM I10XM fuel was evaluated in response to RAI-1, RAI-2, and RAI-3.
AREVA Inc.
Controlled Document AN P-3424N P AREVA Responses to RAI from Revision 1 SCVB on MNGP EFW LAR Page 2-11 SCVB RAI-6 Justify the statement that no further analysis is requiredfor the Standby Gas Treatment System for EFW, beca use EFW has the same operating domain as MELLLA+. Explain all applicable assumptions.
ARE VA Response The licensing basis for MNGP MELLLA+ is summarized in Section 4.5 of Reference 11. Additional information about the MNGP analyses is summarized in Reference 16. The Standby Gas Treatment System (SGTS) is designed to maintain secondary containment at a negative pressure and to filter the exhaust air for removal of fission products potentially present during abnormal conditions. The impact of changing from GEI4 fuel to ATRIUM 10XM fuel is evaluated as follows.
]
Therefore; under the postulated accident conditions,
[
]
AREVA Inc.
Controlled Document AREVA Responses to RAl from ANP-3424NP Revision 1 SCVB on MNGP EFW LAR Page 2-12 SCVB RAI-7 Provide an evaluation of the impact on containment isolation function based on the changes in the short term pressure and temperature response due to differences in short term energy release and decay heat between the GEI4 and the ATRIUM IOXM as stated in RAI-3.
AREVA Response The licensing basis for MNGP containment isolation at MELLLA+ conditions is summarized in Section 4.1.5 of Reference 11. The impact of changing from GEl4 fuel to ATRIUM 10XM fuel was evaluated in response to RAI-1, RAI-2 and RAI-3. [
AREVA Inc.
Controlled Document ANP-3424NP AREVA Responses to RAI from Revision 1 SCVB on MNGP EFW LAR Page 2-13 SCVB RAI-8 Provide an evaluation of the impact on responses to NRC Generic Letters 89-10, 89-16, 95-07, and 96-06 based on the changes in the short term pressure and temperature response due to differences in the short term energy and decay heat between the GEl4 and the ATRIUM IOXM as stated in RAI-3.
ARE VA Response In the response to RAI-3 above, the differences in short-term energy and decay heat were evaluated for the two fuel designs, r
]
AREVA Inc.
ControdDed Document AREVA Responses to RAI from ANP-3424NP Revision 1 SCVB onl MNGP EFW LAR Page 2-14 SCVB RAI-9 In Section 4.5.6 of your January 9, 2015, it states that various pressures and temperaturesfor MELLLA+
are bounded by MELLLA.
What is the impact on the peak drywell-to-wetwell differential pressure for the EFW operating domain?
ARE VA Response Section 4.5.6 in Reference 2 addresses GL 96-06. The licensing basis for equipment operability and containment integrity during design basis accidents initiated from the MELLLA+ domain is summarized in Section 4.1.9 of Reference 11 and is based on the evaluation provided in Section 4.1.1 of Reference 11 (short term pressure and temperature response). The impact of the MELLLA+ operating domain expansion on the peak drywell-to-wetwell differential pressure for GEI4 fuel was summarized in response to RAI-3. [:
] The impact of changing from GEl4 fuel to ATRIUM 10XM fuel was evaluated in response to RAI-1, RAI-2, and RAI-3.
AREVA Inc.
ControD~ed Document AREVA Responses to RAI from ANP-3424NP Revision 1 SCVB on MNGP EFW LAR Page 3-1 3.0 References
- 1. License Amendment Request for ARE VA Extended Flow Window, October 3, 2014, MNGP L-MT-14-044, (ADAMS Accession No. ML 14283Al19).
- 2. License Amendment Request for AREVA Extended Flow Window Supplement to Respond to NRC Staff Questions (TAO No. MF5002), January 9, 2015, MNGP L-MT-14-1 03, (ADAMS Accession No. ML15022A165 and ML15022A167).
- 3. Monticello Nuclear Generating Plant - Draft Requests for Additional Information (SCVB) re:
AREVA Extended Flow Window License Amendment Request (TAO No. MF5002), email from Terry Beltz (NRC) to Glenn Adams (Xcel Energy), June 17, 2015.
- 6. ANP-3092(P) Revision 0, Monticello Thermal-Hydraulic Design Report for ATRIUMTM 10XM Fuel Assemblies, AREVA NP, July 2012.
- 7. License Amendment Request for Transition to ARE VA ATRIUM 10XM Fuel and AREVA Safety Analysis Methodology, July 15, 2013, MNGP L-MT-13-055, (ADAMS Accession No. ML13200A187).
- 8. ANP-3211(P) Revision 1, Monticello EPU LOCA Break Spectrum Analysis for ATRIUMTM 10XM Fuel, AREVA NP, July 2013.
- 9. ANP-3295P Revision 2, Monticello Licensing Analysis For EFW (EPU/MELLLA+), AREVA Inc, September 2014.
- 10. GE Report GE-NE-0000-0060-9174-R1, Containment Analysis Input Parameters (Form OPL-4A),
April 19, 2007.
- 11. GEH Report, "Safety Analysis Report for Monticello Regarding Maximum Extended Load Line Limit Analysis Plus", NEDC-33435P Revision 1, December 2009.
- 12. Letter from Xcel Energy to NRC, "License Amendment Request: Maximum Extended Load Line Limit Analysis Plus", MNGP L-MT-10-003, January 21, 2010 (ADAMS Accession No. ML100280558).
- 13. G EH Report, "Safety Analysis Report for Monticello Constant Pressure Power Uprate",
NEDC-33322P Revision 3, October 2008.
- 14. Letter from Xcel Energy to NRC, "License Amendment Request: Extended Power Uprate (TAC MD9990), MNGP L-MT-08-052, November 5, 2008 (ADAMS Accession No. ML083230111).
- 15. Task Report T0400 Revision 3, MNGP Extended Power Uprate: Containment System Response, February 2011.
- 16. Task Report T0409 Revision 0, MNGP Extended Power Uprate: Standby Gas Treatment System, January 2008.
AREVA Inc.
L-MT-1 5-065 Enclosure 9 ARE VA Affidavits 6 pages follow
AFFIDAVIT STATE OF WASHINGTON
)) SS.
COUNTY OF BENTON )
- 1. My name is Alan B. Meginnis. I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain ARE VA information is proprietary. I am familiar with the policies established by ARE VA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3435P, Revision 0, "AREVA Responses to RAI-8 and RAI-32 from SRXB and SNPB on MNGP EFW LAR," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by ARE VA as proprietary in accordance with the policies established by AREVA for the control and protection of proprietary and confidential information.
- 4. This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.
- 5. This Document has been made available to the' U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withhelcd from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is
requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information."
- 6. The following criteria are customarily applied by AREVA to determine whether information should be classified as proprietary:
(a) The information reveals details of ARE VA's research and development plans and programs or their results.
(b) Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.
(c) The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for ARE VA.
(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability.
(e) The information is vital to a competitive advantage held by ARE VA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of ARE VA.
The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above.
- 7. In accordance with ARE VA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
- 9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.
? J~
SUBSCRIBED before me this "3 /
day of 1(- .,7'L",2 015.
I*\*
- Susan K. McCoy NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/14/2016
AFFIDAVIT STATE OF WASHINGTON )
) ss.
COUNTY OF BENTON )
- 1. My name is Alan B. Meginnis. I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary. I am familiar with the policies established by ARE VA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3424P, Revision 1, "AREVA Responses to RAI from SCVB on MNGP EFW LAR," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA for the control and protection of proprietary and confidential information.
- 4. This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by ARE VA and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.
- 5. This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is
requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information."
- 6. The following criteria are customarily applied by AREVA to determine whether information should be classified as proprietary:
(a) The information reveals details of AREVA's research and development plans and programs or their results.
(b) Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.
(c) The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for ARE VA.
(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability.
(e) The information is vital to a competitive advantage held by ARE VA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of ARE VA.
The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above.
- 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside ARE VA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
- 9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.
SUBSCRIBED before me this____@
day of.-, 2015. *,.'
Susan K. McCoy
- NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/14/2016