ML073440115

NEDC-33383, Revision 0, GEXL97 Correlation Applicable to ATRIUM-10 Fuel, (Non-Proprietary), Attachment 2

ML073440115
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Site:	Grand Gulf
Issue date:	09/30/2007
From:	Global Nuclear Fuel - Americas
To:	Office of Nuclear Reactor Regulation
References
GNRO-2007/00071 NEDC-33383, Rev 0
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Attachment 5 GNRO-2007100071 NEDC-33383P, "GEXL97 Correlation Applicable to ATRIUM-10 Fuel,"

Non-Proprietary Version

GNFr Global Nuclear Fuel A Joint Venture of GE, Toshiba, &Hitachi NEDO-33383 Revision 0 Class I September 2007 NON-PROPRIETARY INFORMATION GEXL97 Correlation Applicable To ATRIUM-10 Fuel COPYRIGHT 2007 GLOBAL NUCLEAR FUELS-AMERICAS, LLC ALL RIGHTS RESERVED

Non-Proprietary Information NEDO-33383 Revision 0 Disclaimer of Responsibility This document was prepared by or for Global Nuclear Fuel. Neither Global Nuclear Fuel nor any of the contributors to this document:

A. Make any warranty or representation, expressed or implied, with respect to the accuracy, completeness, or usefulness of the information contained in this document, or that the use of any information disclosed in this document may not infringe privately owned rights; or B. Assumes any responsibility for liability or damage of any kind, which may result from the use of any information disclosed in this document.

INFORMATION NOTICE This document is a non-proprietary version of NEDC-33383P, which has the proprietary information removed. Portions of the document that have been removed are indicated by double open and closed brackets as shown here (( fl.

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Non-Proprietary Information NEDO-33383 Revision 0 Document

Title:

GEXL97 Correlation for ATRIUM-10 Fuel August 2007 ABSTRACT The GEXL97 correlation for determining the minimum critical power ratio (MCPR) during normal and transient operation for the boiling water reactor (BWR) and its development is presented for application to the AREVA ATRIUM-10 fuel design. The basic GEXL correlation is a critical quality and boiling length correlation used to predict the occurrence of boiling transition in BWR fuel designs. The database used to support the development of the GEXL97 correlation consisted of calculated critical power data generated with the NRC approved SPCB critical power correlation as encoded in AREVA's thermal-hydraulic model XCOBRA. The specific ATRIUM-10 GEXL97 correlation developed for use in the core design and safety analysis process is intended to accurately predict the expected critical power performance of the fuel assembly design. In the core design process the GEXL97 correlation is used to determine the expected thermal margin for the ATRIUM- 10 fuel in the operating cycle. Thermal margins for the Global Nuclear Fuel (GNF) bundles in the operating cycle will be determined based on the appropriate GEXL correlation for those fuel designs. In the safety analysis process the GEXL97 correlation is to be applied to the ATRIUM-10 fuel in the mixed core while the appropriate GNF GEXL correlation will be applied to the GNF fuel (including the determination of an acceptable MCPR safety limit for the mixed core). Based on the supporting NRC approved SPCB correlation generated database, it is concluded that the safety related conditions have been satisfied with respect to the development of an acceptable critical power correlation.

The overall uncertainty of the GEXL97 correlation in prediction of the critical power for ATRIUM-10 fuel is ((

iii

Non-Proprietary Information NEDO-33383 Revision 0 Revision Status Revision Description of Change 0 Initial Issue September 2007 4

i iv

Non-Proprietary Information NEDO-33383 Revision 0 TABLE OF CONTENTS Page

1. INTRODUCTION AND

SUMMARY

.......................................................................... 1-1

2. CRITICAL POWER DATABASE FOR GEXL97 ..................................................... 2-1

3. DATA COLLECTION MATRIX AND CORRELATION PROCEDURES ........... 3-1 3.1 THE ATRIUM- 10 DATA COLLECTION MATRIX ..................................................... 3-1 3.2 CORRELATION PROCEDURE FOR GEXL97 ............................................................ 3-1 3.3 G EX L97 C ORRELATION ....................................................................................... 3-3

4. CRITICAL POWER CORRELATION ...................................................................... 4-1 4.1 FORM OF THE GEXL CORRELATION ..................................................................... 4-1 4.2 GEXL97 APPLICATION RANGE ............................................................................ 4-3 4.3 CALCULATION OF CRITICAL POWER BY GEXL ..................................................... 4-4 4.4 G EX L INPUT PARAM ETERS .................................................................................. 4-5 4.4.1. B oilingL ength ..................................................................................... 4-5 4.4.2. Thermal D iameter ............................................................................... 4-5 4.4.3. Mass F lux ............................................................................................ 4-6 4 .4 .4. P ressure.............................................................................................. 4-6 4.4.5. R -Factor.............................................................................................. 4 -6 4.4.6. A nnularF low Length .......................................................................... 4-6

5. ATRIUM-10 GEXL97 CRITICAL POWER EVALUATION .................................. 5-1

6. NOMENCLATURE ....................................................................................................... 6-1

7. REFERE N CES ............................................................................................................... 7-1 APPENDIX A. R-FACTOR CALCULATION METHOD ....................................... A-1 A. 1 IN TROD U CTION .................................................................................................... A -1 A.2 R-FACTOR CALCULATION PROCESS .................................................................. A-1 A.3 BUNDLE AVERAGE AXIAL DISTRIBUTIONS ....................................................... A-I A.4 R -FACTOR D ISTRIBUTION ..................................................................................... A -3 A.5 R-FACTOR CALCULATION EXAMPLES .................................................................. A-3 A .6 FUEL ASSEMBLY R-FACTOR ................................................................................. A -4 v

Non-Proprietary Information NEDO-33383 Revision 0 LIST OF TABLES Table Title Page TABLE 2-1. GEXL97 DATABASE FOR ATRIUM-10 FUEL .................................................. 2-2 TABLE 2-2. G EX L97 DATABASE D ETAILS .......................................................................... 2-3 TABLE 2-3. ATRIUM- 10 MODELING DIMENSIONS ............................................................. 2-5 TABLE 3-1. ATRIUM-10 CRITICAL POWER DATA MINIMUM COLLECTION MATRIX (STEADY-ST A TE) .......................................................................................................... 3 -2 TABLE 3-2. STATISTICAL

SUMMARY

FOR ATRIUM-10 GEXL97 ....................................... 3-3 TABLE 3-3. STATISTICAL

SUMMARY

FOR EACH AXIAL POWER SHAPE FOR ATRIUM- 10 G E XL 9 7 ....................................................................................................... 3-3 TABLE 4-1. GEXL97 CORRELATION COEFFICIENTS ............................................................ 4-2 TABLE 4-2. GEXL97 ADDITIVE CONSTANTS FOR ATRIUM-10 FUEL ................................ 4-6 TABLE 5-1. STATISTICAL

SUMMARY

FOR COMBINED GEXL97 AND SPCB UNCERTAINTY. 5-4 TABLE 6-1. N OM EN CLATURE ............................................................................................... 6-1 TABLE 6-2. A CR O N Y M S ....................................................................................................... 6-3 TABLE A- 1. R-FACTOR CALCULATION BY LATTICE POSITION ............................................ A-6 TABLE A-2. ATRIUM-10 AXIAL SHAPES FOR ROD POWER INTEGRATION ........................ A-8 LIST OF ILLUSTRATIONS Figure Title Page FIGURE 2-1. ATRIUM- 10 ASSEMBLY ROD NUMBERING SYSTEM ....................................... 2-4 FIGURE 2-2. BUNDLE AXIAL POWER SHAPES - AREVA CRITICAL POWER DATA COLLECTION

...................................................................................................................... 2 -6 FIGURE 3-1. SPCB CALCULATED VS. GEXL97 CALCULATED CRITICAL POWER ................ 3-4 FIGURE 3-2. GEXL97 M ASS FLUX TRENDS ........................................................................ 3-4 FIGURE 3-3. GEXL97 PRESSURE TRENDS ........................................................................... 3-5 FIGURE 3-4. GEXL97 INLET SUB-COOLING TRENDS ........................................................... 3-5 FIGURE 4-1. GEXL97 R-FACTOR TRENDS ........................................................................... 4-3 FIGURE 4-2. CRITICAL POWER ITERATION SCHEME ............................................................. 4-5 FIGURE 4-3. REGIMES OF TwO-PHASE FLOW ....................................................................... 4-8 FIGURE 5-1. FREQUENCY VERSUS ECPR HISTOGRAM FOR ATRIUM-10 GEXL97 ............. 5-4 FIGURE A-1. ATRIUM- 10 AXIAL SHAPES FOR ROD POWER INTEGRATION (NORMALIZED)A-2 FIGURE A-2. IDENTIFICATION OF RODS IN POSITIONS ADJACENT TO ROD I ..................... A-5 vi

Non-Proprietary Information NEDO-33383 Revision 0

1. INTRODUCTION AND

SUMMARY

This report summarizes the development of the ATRIUM-10 GEXL97 correlation. The ATRIUM-10 GEXL97 correlation will be used to determine the critical power performance of the AREVA ATRIUM-10 fuel in a mixed core of AREVA and GNF fuel. This document describes the process used in the development of the GEXL97 correlation for prediction of critical power for ATRIUM-10 fuel and the determination of the overall uncertainty of that correlation in prediction of the ATRIUM 10 critical power performance.

ATRIUM- 10 calculated bundle critical power data was obtained from AREVA based on the NRC approved SPCB correlation (Reference 2) as encoded in the AREVA thermal hydraulic model XCOBRA. The objective of this data collection was to obtain quality data appropriate for GEXL analysis. The span of the data collection encompasses cosine, top peaked, bottom peaked, and double humped axial power shapes in order to cover the complete range of expected operation of the ATRIUM-10 fuel in a BWR core. The data was used to develop a new GEXL correlation for the ATRIUM-10 design. This new GEXL correlation for ATRIUM 10 fuel is designated as GEXL97. The new GEXL97 correlation uses the same functional form as previous GEXL correlations with different constants for the GEXL correlation coefficient parameters. This report provides the results of the GEXL97 correlation development, including the overall uncertainty relative to measurement results.

The GE critical quality - boiling length correlation (GEXL) was developed to accurately predict the onset of boiling transition in boiling water reactor (BWR) fuel assemblies during both steady-state and reactor transient conditions. The GEXL correlation is necessary for determining the MCPR operating limits resulting from transient analysis, the MCPR safety limit analysis, and the core operating performance and design. The GEXL correlation is an integral part of the transient analysis methodology. It is used to confirm the adequacy of the minimum critical power ratio (MCPR) operating limit, and it can be used to determine the time of onset of boiling transition in the analysis of other events.

The GEXL correlation has been used in the safety analysis process for GE fueled BWRs since 1974. The GEXL correlation was developed to provide a best estimate prediction of the onset of boiling transition in BWR fuel assemblies. The GEXL correlation is based on the relationships of critical quality with boiling length. It expresses bundle average critical quality as a function of boiling length, thermal diameter, system pressure, lattice geometry, local peaking pattern (R-factor), mass flux and annular flow length.

The GEXL correlation was originally developed based on test data typical of 7x7 and 8x8 fuel assemblies. Over 14,000 data points having various numbers of rods, heated lengths, axial heat flux profiles, and rod to rod power distributions were used in the development of the original GEXL (GEXL01) correlation. The boiling transition test data available at the time of the development of the GEXLO 1 correlation are provided in the original licensing topical report (Reference 1). Further background on the development of the GEXL97 correlation is provided in Section 2.

The GEXL correlation requires the development of coefficients for the specific mechanical geometry of the fuel assembly design. The database supporting the development of the GEXL97 correlation is described in Sections 2 and 3.

1-1

Non-Proprietary Information NEDO-33383 Revision 0 As described above, the GEXL correlation is a critical quality-boiling length correlation.

In the GEXL correlation critical quality is expressed as a function of boiling length, thermal diameter, mass flux, pressure, R-factor, and annular flow length. The axial power profile is not explicitly included in the GEXL correlation, however, the axial power shape is used to calculate boiling length, annular flow length, and axial variation of quality, and thus, is inherently included in the critical power correlation. The exact form of the GEXL correlation and the coefficients for ATRIUM-10 fuel are provided in Section 4.

The measure of the capability of a boiling transition prediction correlation is its ability to predict the collected data. The GEXL correlation has been demonstrated to be an accurate predictor of the data generated from the NRC approved SPCB ATRIUM-10 critical power correlation. Its capability for predicting ATRIUM-10 fuel is provided in Sections 3 and 5.

The nomenclature and references used in this report are demonstrated in Sections 6 and 7, respectively.

The overall uncertainty of the GEXL97 correlation in prediction of the critical power for ATRIUM-10 fuel is ((

))

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Non-Proprietary Information NEDO-33383 Revision 0

2. CRITICAL POWER DATABASE FOR GEXL97 The current form of the GE critical quality-boiling length correlation (GEXL) was developed to provide an accurate means of predicting the occurrence of boiling transition in BWR fuel. The primary source of boiling transition data used in the development and verification of the GEXL correlation are dryout tests at the GE ATLAS facility in San Jose, California. The ATLAS test loop generates pressure, flow and temperature conditions that accurately simulate the actual operating reactor environment.

The data for the GEXL97 development specific to ATRIUM- 10 fuel was generated using the NRC approved SPCB correlation. Specified rod-to-rod peakings, axial power shapes, pressure, mass flux and sub-cooling were used in the AREVA thermal hydraulic model XCOBRA with the SPCB correlation to determine critical power at dryout. No GEXL97 development data was generated outside the SPCB correlation range of applicability.

ATRIUM-10 fuel is a 1Oxl0 fuel bundle with a water channel design that displaces 9 fuel rods. It contains a total of 83 full-length fuel rods and 8 part length rods. It has 27 unique fuel rod locations (Figure 2-1) within the 10xl0 lattice for which dryout data was collected.

In Section 4, the final GEXL97 correlation for ATRIUM-10 fuel is given, including additive constants. The database used in the development of the GEXL97 correlation for ATRIUM-10 fuel is summarized in Table 2-1. This table shows the number of calculated critical power data points obtained using the SPCB critical power correlation for cosine, inlet, outlet, and double humped axial power distributions. It also shows the fuel pin dryout location that formed the basis of the 28 different sets of AREVA calculated critical power data. Table 2-2 shows the same information but further divides the data collected into subgroups of pressure, mass flux, and inlet sub-cooling.

The ATRIUM-10 modeling dimensions used in the AREVA generation of the SPCB dryout data as well as in the development of the GEXL97 correlation are provided in Table 2-3. The generated data was based on chopped cosine, top and bottom, and a double humped peaked axial power profile. The axial power profiles are shown in Figure 2-2.

2-1

Non-Proprietary Information NEDO-33383 Revision 0 Table 2-1. GEXL97 Database for ATRIUM-10 Fuel Number of Critical Power Data Points Fuel Pin Data Set rT Dryout

(( ]1] Position

.4 4- 4 .4

-4 4- .4 .

-4 4- i 4 .

1 1 1

.1]

2-2

Non-Proprietary Information NEDO-33383 Revision 0 Table 2-2. GEXL97 Database Details Collection Axial Nominal Thermal Hydraulic Conditions Type Shape 1I _

Pressure (psia)

Iessure[I I I Mass Flux (Mlbm/hr-ft2)

_ _ _ _ _ _ _ In I 1I Inlet Subcooiing (Btu/lbm) t__I I I _

44-~ -4 ~~ -4 -4 4 - 4 -4 -4 ~4- I 4- -

44 4- + + + 44 H4 4 4 4 4- 4 4 4 44i ii 14-~~ 4- 4- 44 4 4 4- ~4 4-H- 4 4 4 ii- - + 4- + + ii 4 4 4 - 4- i 4 4 H4 i 4 4 4 +

44 + + + + 44 ii 4 4 4- 4- 4- 4 4 H4i D4 - 4- - + + ii 4 4- - 4- 4- 4- 4 44 H 4i 4 4 44- 4- + + + + 44 4- 4- 4- 4- 4- 4- 4 4 44- 4 4 4 4 +/-

4 44--I -4-4--* 44444444444-44144

________ ________ S _____ r S _____ r ,r C C C C _____ _____ Z _____ C  : _____ ~ S S 2-3

Non-Proprietary Information NEDO-33383 Revision 0 2 3) 4) 1;I 5, 6 710 r2,2*N 2,3ý (2,4 (D /2,6 27 0

\12J \\13 14 15 J 702 3,3 (3,4 35 /"3,6 37 0O@@@

23 24 25 2 27j 30 000 04 48 0@0 5,8 Water Box 6,8 0(

1000 0 Line of Symmetry Figure 2-1. ATRIUM-10 Assembly Rod Numbering System 2-4

Non-Proprietary Information NEDO-33383 Revision 0 Table 2-3. ATRIUM-10 Modeling Dimensions Characteristic Assembly Data sets 1 through 28 Lattice 10 x 10 Nominal Inside Width of Channel 1]

Inside Comer Radius of Channel Rod Pitch [1 Diameter of All Heated Rods Axial Heat Flux Profiles (4) of Full Length Rods 1.4 Peak-to-Average Cosine 1.6 Peak-to-Average Bottom and Top Peaked, 1.2 Peaked Double Humped Number of Full Length Heated Rods 83 Heated Length of Full Length Rods 150 in. (381 cm)

Number of Part Length Heated Rods 8 End of Heated Length of Part Length Rods Er 1]

Spacers 8 Water Box Off-set Central, Displacing 9 Fuel Rods Water Box Area Water Box Outer Width Water Box Outside Comer Radius R[ 1]

Hydraulic Parameters Used in GEXL Correlation:

Active Channel Flow Area True Hydraulic Diameter Er ))J True Thermal Diameter Er GEXL Hydraulic Diameter*

))

GEXL Thermal Diameter*

2-5

Non-Proprietary Information NEDO-33383 Revision 0 Figure 2-2. Bundle Axial Power Shapes - AREVA Critical Power Data Collection 2-6

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3. DATA COLLECTION MATRIX AND CORRELATION PROCEDURES 3.1 THE ATRIUM-10 DATA COLLECTION MATRIX The ATRIUM-10 data collection matrix is outlined in detail in Table 3-1. This matrix shows the minimum range of data required for the GEXL97 correlation development. The data was generated by AREVA using the NRC approved SPCB correlation (Reference 2) as encoded in the AREVA thermal hydraulic model XCOBRA. ((

rE]

3.2 CORRELATION PROCEDURE FOR GEXL97 The procedure used for development of the ATRIUM-10 GEXL97 correlation can be summarized as follows:

" A range of generated data covering all parameter variations was selected to form a development database. This is the majority of the data. A separate set of data was used as the verification database.

• The correlation coefficients were chosen to minimize the bias and standard deviation in correlating the data and to minimize any trend errors in reference to flow, pressure, sub-cooling, and R-factor.

• Once the optimum coefficients were determined, the apparent R-factors were calculated for each assembly. The apparent R-factor is defined as that R-factor which yields an overall ECPR of 1.0 for a given assembly. In this document, ECPR is defined as the ratio of the GEXL97 calculated critical power to the SPCB calculated critical power.

1]

These steps were taken to optimize GEXL97 for the ATRIUM-10 fuel design and to minimize the prediction uncertainty. This identical process is used when developing GEXL correlation coefficients for GNF/GE fuel designs using test data.

3-1

Non-Proprietary Information NEDO-33383 Revision 0 Table 3-1. ATRIUM-10 Critical Power Data Minimum Collection Matrix (Steady-state)

Collection Type:

Number of peaking patterns:

Axial Heat Flux Shape:

R-factor:

Pressure:

Mass flux:

Inlet sub-cooling:

Collection Type:

Number of peaking patterns:

Axial Heat Flux Shape:

R-factor:

Pressure:

Mass flux:

Inlet sub-cooling:

Collection Type:

Number of peaking patterns:

Axial Heat Flux Shape:

R-factor:

Pressure:

Mass flux:

Inlet sub-cooling:

Collection Type:

Number of peaking patterns:

Axial Heat Flux Shape:

R-factor:

Pressure:

Mass flux:

Inlet sub-cooling:

Collection Type:

Number of peaking patterns:

Axial Heat Flux Shape:

R-factor:

Pressure:

Mass flux:

Inlet sub-cooling:

Collection Type:

Number of peaking patterns:

Axial Heat Flux Shape:

R-factor:

Pressure:

Mass flux:

Inlet sub-cooling: ]

3-2

Non-Proprietary Information NEDO-33383 Revision 0 3.3 GEXL97 CORRELATION Figure 3-1 shows the ATRIUM-10 SPCB calculated critical power data versus the calculated critical power for ATRIUM-10 fuel using the GEXL97 correlation developed herein. The final ATRIUM-10 GEXL97 correlation coefficients and additive constants are shown in Section 4. The GEXL97 correlation is developed from the majority of the data that consists of (( )) points for 24 different local peaking patterns and 4 axial power shapes with R-factors ranging up to (( )). The overall statistics for the GEXL97 correlation are shown in Table 3-2 and Table 3-3. Figures 3-2 through 3-4 show the ECPR mean and standard deviation for mass flux, pressure, and inlet sub-cooling for the correlation database which included all collection types except high R-factor (discussed below), all axial heat flux shapes, and pin peaking patterns which were used explicitly in the GEXL97 uncertainty calculation ((( )) data points). The low mass flux data ((( )) Mlb/hr-ft2), which had a

)) mean ECPR ((( ))) and small uncertainty ((( ))), were also not included as part of the correlation development database. Figure 3-2 includes data for mass fluxes in the range of

(( )) Mlb/hr-ft2, Figure 3-3 includes data for pressures in the range of (( )) psia, and Figure 3-4 includes data for inlet sub-cooling in the range of (( )) Btu/lb. These figures demonstrate that there are no substantial trend errors in the GEXL97 correlation and that the GEXL97 correlation closely replicates the SPCB correlation over the given ranges.

The GEXL97 correlation was separately assessed against high R-factor data with R-factor values up to (( )), and a mean ECPR of (( )) and a standard deviation of (( ))

were obtained. (( )) High R-factors in this range are generally obtained for controlled bundles, which are non-limiting bundles, and therefore these data are not included in the correlation statistics.

Table 3-2. Statistical Summary for ATRIUM-10 GEXL97 Total Correlation Development Verification Database Database Database Number of data points ((

Mean ECPR Standard deviation, a (%) ))

Table 3-3. Statistical Summary for Each Axial Power Shape for ATRIUM-10 GEXL97 Axial Power Shape Number of data points Mean ECPR Standard deviation,_a_(%) ))

3-3

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Figure 3-1. SPCB Calculated vs. GEXL97 Calculated Critical Power 1]

Figure 3-2. GEXL97 Mass Flux Trends 3-4

Non-Proprietary Information NEDO-33383 Revision 0 11 11 Figure 3-3. GEXL97 Pressure Trends

[I Figure 3-4. GEXL97 Inlet Sub-cooling Trends 3-5

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4. CRITICAL POWER CORRELATION 4.1 FORM OF THE GEXL CORRELATION As discussed in Section 2, the critical quality versus boiling length plane was chosen by GE as the coordinate system for correlating the boiling transition data described in Section 3.

This approach was chosen because (1) it yields good precision, (2) is conceptually simple to apply, and (3) will account for variations in the axial heat flux profile. The critical quality -

boiling length correlation developed to predict the critical power in BWR fuel assemblies is called GEXL.

The GEXL correlation, expressed in the most general terms, is:

XC = f(LB, DQ, G, P, R, LA) (4-1) where:

Xc = Critical quality (dimensionless)

LB = Boiling length (in.)

DQ = Thermal diameter (in.)

G = Mass flux (106 lb/hr-ft2)

P = Pressure (psia)

R = Bundle R-factor (dimensionless)

LA = Annular flow length (in.)

Because GEXL is a dimensional correlation, the above units must be used in specific analyses.

The explicit form of the GEXL correlation is:

(( )) (4-2) where the correlation parameters, V(I), and the coefficients, A(I), are shown in Table 4-1.

The additive constants are shown in Table 4-2.

4-1

Non-Proprietary Information NEDO-33383 Revision 0 Table 4-1. GEXL97 Correlation Coefficients 11

_ I_______ I. _______

+ I.

4-2

Non-Proprietary Information NEDO-33383 Revision 0 4.2 GEXL97 APPLICATION RANGE The GEXL97 correlation for ATRIUM-10 fuel is valid over the range stated below:

Pressure: ((

Mass'Flux:

Inlet Sub-cooling:

R-factor: 1]

The correlation database spanned all application ranges except those for low inlet sub-cooling and low R-factor. Subsequent to the GEXL97 correlation development, additional data was collected to (( )) Btu/lbm and (( )) R-factor to confirm the low end of the inlet sub-cooling and R-factor application ranges. The combination of this additional data with the correlation database had a negligible effect (less than 0.005) on the overall mean and standard deviation of the GEXL97 correlation statistics.

A study of the GEXL97 trends shows that the R-factor trend is (( )) over the entire range of expected operation (see Figure 4-1).

((

1]

Figure 4-1. GEXL97 R-factor Trends 4-3

Non-Proprietary Information NEDO-33383 Revision 0

)) Based on these arguments, the GEXL97 correlation can be used to perforn critical power calculations for these non-limiting fuel assemblies even though their mass flux values may be greater than the upper mass flux limit specified herein.

As described in Section 3.3, a separate evaluation was completed using the high R-factor data to show that the correlation is well behaved at high R-factor conditions. The general trend of the GEXL97 correlation critical power calculations for high R-factor conditions follows the general trend of the AREVA predicted critical power performance for these highly peaked pin power profiles.

4.3 CALCULATION OF CRITICAL POWER BY GEXL For steady-state conditions, critical power is predicted by an iterative procedure. Given the pressure, flow rate, inlet sub-cooling, axial power shape and fuel lattice design, a value for the critical power is assumed and the local quality and boiling length are computed for each axial node (24 nodes are assumed) using energy and mass balance relationships. The critical quality is also computed for each node using Equation 4-2. If, at any of the nodes, the local quality is greater than the critical quality, a lesser value for the critical power is assumed. If the local quality is less than the critical quality at all of the nodes, a greater value for the critical power is assumed. The iteration continues until the local quality is just equal to the critical quality at one of the nodes and is less at all other nodes. The power for this last iteration is the predicted critical power.

This process is illustrated in Figure 4-2 where the dashed/solid lines show the critical and equilibrium quality profiles for the first and last iterations. The equilibrium quality X is a function of bundle elevation z and is calculated from:

X(z) = [Q(z)/W -(hf - hi,))]/(hg - hf) (4-3)

In Equation 4-3, X = local quality; z = axial coordinate for elevation in the bundle; Q =

integrated power input to the coolant up to location z; W = bundle coolant flow rate; hf=

saturated liquid enthalpy; hi, = inlet liquid coolant enthalpy; and hg = saturated vapor enthalpy.

For design application the correlation is intended to iteratively determine the bundle power which satisfies the requirement that for some z, X = Xc and X < Xc for all other z. It also should be noted that the values of Xc, X and z at which (Xc - X) is a minimum, change with each iteration on bundle power.

4-4

Non-Proprietary Information NEDO-33383 Revision 0 0.40 0.35 0.30

>- 0.25

< 0.20 a

0.15 0.05 0.10 0

-0.05 0 50 100 150 200 250 300 350 BUNDLE ELEVATION (cm)

Figure 4-2. Critical Power Iteration Scheme The critical power ratio (CPR) is the ratio of the predicted critical power to the actual power of the particular fuel assembly, both evaluated at the same pressure, mass flux and inlet sub-cooling. The minimum critical power ratio (MCPR) is defined as the minimum CPR for any fuel assembly within a core and is the figure of merit to represent the reactor thermal performance or margin.

4.4 GEXL INPUT PARAMETERS This section describes the necessary inputs to the GEXL correlation for the bundle critical power calculation. Based on Equation 4-1, there are six input parameters required for the calculation of critical power. These parameters are: (1) boiling length, LB; (2) thermal diameter, DQ; (3) mass flux, G; (4) pressure, P; (5) bundle R-factor, R; and (6) annular flow length, LA. These parameters are discussed in more detail below.

4.4.1. Boiling Length Boiling length, LB, is the distance from the onset of thermodynamic average bulk boiling to the point of boiling transition. Boiling length is not a direct input to GEXL, but it is calculated through the energy balance during the calculation of critical power described in Section 4.3. The boiling length is dependent on the core pressure, enthalpy at the fuel assembly inlet, normalized axial power shape, mass flux and bundle power level.

4.4.2. Thermal Diameter The thermal diameter, DQ, is a characteristic diameter defined in the heated length region as four times the bundle active coolant flow area divided by the total rodded perimeter, i.e.

the perimeter of the fuel rods and the water box. The rodded perimeter does not include the 4-5

Non-Proprietary Information NEDO-33383 Revision 0 channel. The thermal diameter used in the GEXL97 correlation for ATRIUM- 10 fuel is ((

)), and the active flow area is (( )).

Both parameters are assumed constant over the length of the fuel assembly. This thermal diameter is specific to the GEXL97 correlation and is calculated to be consistent with GNF-A engineering computer program (ECP) calculations. ((

4.4.3. Mass Flux The mass flux, G, is defined as the (( )) coolant flow per unit flow area in the heated region.

4.4.4. Pressure The pressure, P, is defined as the system pressure, taken as the core pressure ((

]I 4.4.5. R-Factor The R-factor is a parameter that accounts for the effects of the fuel rod power distributions and the fuel assembly local spacer and lattice critical power characteristics. Its formulation for a given fuel rod location depends on ((

)) A detailed description of the R-factor calculation method is provided in Appendix A. In addition, there is an additive constant applied to each fuel rod location ((

)) For ATRIUM-10 the additive constants are provided in Table 4-2. The bolded positions represent unique rod locations for which data were generated in order to cover all symmetric locations.

Table 4-2. GEXL97 Additive Constants for ATRIUM-10 Fuel fE ______________ ______________

4.4.6. Annular Flow Length 4-6

Non-Proprietary Information NEDO-33383 Revision 0 4-7

Non-Proprietary Information NEDO-33383 Revision 0 I]

Figure 4-3. Regimes of Two-Phase Flow FLOW HEAT STEAM REGIONS TRANSFER REGIONS TSAT I CONVECTIVE SINGLE HEAT TRANSFER TO STEAM SUPERHEATED 100 PHASE STEAM WALL TEMP I I LIQUID DEFICIENT R EGION

.T..

• FORCED ANNULAR CONVECTIVE HEAT TRANSFER

0. FLOW ITHROUGH LIQUID FILM z .

. SLUG FLOW

• _ NUCLEATE BOILING z I 0 -BUBBLE SUBCOOLED FLOW BOILING TSAT 100% 0 SINGLE

{

CONVECTIVE I-.l PHASE HEAT TRANSFER TEMP QUALITY WATER WATER TO WATER 4-8

Non-Proprietary Information NEDO-33383 Revision 0

5. ATRIUM-10 GEXL97 CRITICAL POWER EVALUATION The GE critical quality-boiling length correlation (GEXL) was developed to be an accurate, best estimate predictor of boiling transition in BWR fuel. A large critical power test database was obtained as part of the development of the form of the GEXL correlation.

The data covered the full range of BWR steady-state operating conditions for which an accurate prediction of critical power is an important element of the safety analysis process.

The GEXL97 correlation was developed from data generated using the NRC approved SPCB critical power correlation encoded in the AREVA XCOBRA thermal hydraulic model.

This section provides the results of statistical analyses performed to demonstrate the application of the final GEXL97 correlation to predict the ATRIUM-10 simulated critical power data.

A statistical analysis was performed for the ATRIUM- 10 correlation database consisting of (( )) data points for ((

)). The data and analyses cover the range for which the ATRIUM-10 GEXL97 correlation is considered valid, as identified in Section 4. To facilitate the statistical evaluation of the predictive capability of the ATRIUM-10 GEXL97 correlation, ((

(5-1) 1]

Figure 5-1 shows the frequency distribution of the calculated ECPR results for ATRIUM-10 and is a graphical representation of the ECPR results that were used to calculate the statistics shown in Tables 3-2 and 3-3. ((

)). The large total correlation uncertainty of (( )) used in the safety limit calculation provides additional conservatism.

5-1

Non-Proprietary Information NEDO-33383 Revision 0 5-2

Non-Proprietary Information NEDO-33383 Revision 0 In 5-3

Non-Proprietary Information NEDO-33383 Revision 0 Table 5-1. Statistical Summary for Combined GEXL97 and SPCB Uncertainty Mean ECPR Standard Deviation, a (%)

GEXL97 Correlation Bounding Value for SPCB Correlation Combined Value (Using p = 1) ))

11 Figure 5-1. Frequency versus ECPR Histogram for ATRIUM-10 GEXL97 Small ECPR errors exist for the individual power shapes as shown in Table 3-3. These errors are not atypical compared to past experience and these ECPR errors are accounted for in the larger GEXL97 correlation uncertainty for the total database. The relatively small

)) of the outlet and double humped axial power shapes and somewhat larger, but

)) of the cosine and inlet peaked data is what leads to the non-normality of the ECPR histogram for the total database.

5-4

Non-Proprietary Information NEDO-33383 Revision 0 The safety limit is determined by summing the probability that each rod is in boiling transition and determining the point where the sum over all the rods of the probability the rod is in boiling transition equals 0.1% of the total number of rods.

NRSBT = ppi = 0.001NR, Allrods where: NR is the total number of rods pi is the probability rod "i" is in boiling transition NRSBT is the number of rods subject to boiling transition For a rod "i" with a given critical power ratio, "CPRi", the likelihood of that rod being in boiling transition is given by the probability that the ECPR is greater than the CPR value:

pi f f(x)dx, CPRi where: f is the ECPR probability density function.

The impact of the non-normality can therefore be evaluated by comparing the integrated probability of boiling transition as a function of CPR value for the actual ECPR histogram and the assumed normal distribution. This comparison is shown in Figure 5-2.

((

Figure 5-2. Comparison of Integrated Probability of Boiling Transition 5-5

Non-Proprietary Information NEDO-33383 Revision 0 For the nominal conditions the limiting rod will be at the safety limit, which is typically around 1.10. All other rods will have higher CPR values. From the above figure it is clearly seen that the probability of the rods being in boiling transition is conservatively calculated when using the normal distribution.

When the uncertainties in plant operating parameters and power distribution are accounted for in the safety limit methodology, the leading bundles that contribute to the safety limit will have a CPR distribution around the safety limit. From the above figure it is seen that the probability of boiling transition is (( )) predicted for CPR values greater than (( )) and non-conservatively for CPR values between ((

)). Since most of the rods that contribute to the safety limit will be in the range close to the safety limit, the overall impact of using the normal distribution will be conservative.

5-6

Non-Proprietary Information NEDO-33383 Revision 0

6. NOMENCLATURE The nomenclature and acronyms used in this report are provided below. The units shown here are general dimensions of the variables. Actual units required for dimensional calculations V (I) terms in Equation 4-2 are described in Section 4.

Table 6-1. Nomenclature Svmbol Definition Units A Bundle flow area in2 (Mi)

A (I) Fuel type specific GEXL coefficients Values in Section 4 consistent with specific English units DH Hydraulic diameter in (in)

DQ Thermal diameter in (in)

F Number of active fuel rods dimensionless G Mass flux lb/ft2-sec (kg/m2-sec) lb/ft2-sec (kg/m2-sec)

Gf Mass flux of the liquid phase alone lb/ft2-sec (kg/m 2-sec)

Gg Mass flux of the gaseous phase alone g Gravitational constant ft/sec2 (m/sec2) hf Saturated liquid enthalpy Btu/lb (kJ/kg) hg Saturated vapor enthalpy Btu/lb (kJ/kg) hi.

Inlet liquid enthalpy Btu/lb (kJ/kg)

Average liquid velocity = Wf/pfA = Gf /pf ft/sec (m/sec) if Average vapor velocity = Wg /pgA Gg /Pg ft/sec (m/sec) ig JIf Dimensionless liquid velocity dimensionless ig Dimensionless vapor velocity dimensionless LA Annular flow length in (in)

LB Boiling length in (in) li Additive constant dimensionless nj Number of rods in position j dimensionless nk Number of rods in position k dimensionless P Pressure psi (Pa) q Correction for adjacent low power rods dimensionless 6-1

Non-Proprietary Information NEDO-33383 Revision 0 Symbol IDefinition Units Q(z) Integrated power input to the coolant up to BTU/sec (Watts) location (z)

R Bundle R-factor dimensionless Ri R-factor for an individual rod dimensionless RFC R-factor at fully controlled dimensionless ri Local peaking factor for rod i dimensionless Local peaking factor for rod j dimensionless rk Local peaking factor for rod k dimensionless T Total number of lattice positions dimensionless V(I) GEXL correlation parameters Values in Section 4 consistent with specific English units.

W Bundle coolant flow rate lb/hr (kg/sec)

Wf Liquid mass flow lb/hr (kg/sec)

Wg Vapor mass flow lb/hr (kg/sec)

Wi Weighting factor for rods in position i dimensionless Wi Weighting factor for rods in position j dimensionless Wk Weighting factor for rods in position k dimensionless X Local quality dimensionless Xc Critical quality dimensionless XTR Annular flow transition quality dimensionless zc Axial coordinate for the point of critical ft (in) quality ZTR Axial coordinate for the point of transition to ft (in) annular flow z Axial coordinate for elevation in bundle ft (in)

Pf Liquid density lb/ft3 (kg/m3 )

Pg Vapor density lb/ft3 (kg/m3 )

6-2

Non-Proprietary Information NEDO-33383 Revision 0 Table 6-2. Acronyms BWR Boiling Water Reactor CPR Critical Power Ratio defined as the predicted critical power to the actual power of the particular fuel assembly, both evaluated at the same pressure, mass flux and inlet sub-cooling ECPR ECP Engineering Computer Program GETAB General Electric BWR Thermal Analysis Basis GEXL GE critical quality-boiling length correlation GNF Global Nuclear Fuels GNF-A Global Nuclear Fuels - Americas MCPR Minimum Critical Power Ratio defined as the minimum CPR for any fuel assembly within a core and is the figure of merit to represent the reactor thermal performance or margin NRC Nuclear Regulatory Commission SPCB NRC approved AREVA (formerly Framatome Advanced Nuclear Power) critical power correlation for ATRIUM-10 fuel XCOBRA AREVA thermal-hydraulic model SPC Siemens Power Corporation 6-3

Non-Proprietary Information NEDO-33383 Revision 0

7. REFERENCES

1. NEDE-10958P-A, General Electric BWR Thermal Analysis Basis (GETAB): Data, Correlation and Design Basis, GE Proprietary Report, January 1977.

2. EMF-2209(P)(A), "SPCB Critical Power Correlation", Rev. 2, September 2003.

3. NEDC-32505P-A, R-Factor Calculation Method for GEl 1, GE12, and GEl3 Fuel, Revision 1, GE Proprietary Report, July 1999.

7-1

Non-Proprietary Information NEDO-33383 Revision 0 APPENDIX A. R-Factor Calculation Method A.1 Introduction The R-factor is an input to the GEXL correlation that accounts for the effects of the fuel rod power distributions and the fuel assembly and channel geometry on the fuel assembly critical power. Its formulation for a given fuel rod location depends on the power of that fuel rod, as well as the power of the surrounding fuel rods. In addition, there is an additive constant applied to each fuel rod location that is dependent on the fuel assembly and channel geometry. The complete R-factor methodology is documented in Reference 3.

A.2 R-factor Calculation Process Local two-dimensional fuel rod power distributions vary axially in BWR fuel assemblies due to axial variations in nuclear design, exposure, void fraction and control state. These factors are considered when calculating the axially integrated powers for individual rods. The two-dimensional distribution of integrated rod powers for a bundle is then used to calculate individual rod R-factors. The bundle R-factor for a particular bundle average exposure and control fraction is the maximum of all of the individual fuel rod R-factors. The steps used in the R-factor calculation process are as follows:

1. Obtain relative 2D rod-by-rod power distributions from TGBLA, which are a function of lattice nuclear design, average exposure, void fraction, and control state.

2. ((

1]

3. Calculate an R-factor for each individual fuel rod. ((

4. The bundle R-factor is the maximum value of all individual rod R-factors.

5. Repeat these calculations for each desired bundle average exposure, control fraction and channel bow.

A.3 Bundle Average Axial Distributions A 25-node axial shape is used to define a bundle axial relative power shape for the purposes of calculating R-factors. This shape is a function of control fraction. Bundle axial void fraction and bundle axial relative exposure shapes are used to determine two-dimensional radial distributions as a function of axial height.

A-I

Non-Proprietary Information NEDO-33383 Revision 0

((

1]

• 1i 1]

• The bundle axial relative exposure shape is defined as that shape which is consistent with the uncontrolled axial relative power shape assuming uniform fuel density; and

" The bundle axial void fraction shape is defined as a shape that is consistent with the uncontrolled axial relative power shape and gives a prototypical bundle average void fraction.

Figure A-1 provides a summary of these normalized axial shapes for ATRIUM-10 fuel. The corresponding numbers are listed in Table A-2.

Figure A-1. ATRIUM-10 Axial Shapes for Rod Power Integration (Normalized)

A-2

Non-Proprietary Information NEDO-33383 Revision 0 A.4 R-factor Distribution 1] (A-1) 1]

A.5 R-factor Calculation Examples Using the procedures defined in the previous sections, R-factors are calculated for different lattice locations in a bundle as a function of fuel assembly exposure, control state and channel bow using Equation A-1. The following example is for a 10xlO lattice (ATRIUM- 10).

Consider Equation A-I for the various cases as shown in Figure A-2:

Corner Rod:

Applying Equation A-I to a comer rod (as in Figure A-2a),

))(A-2) 1 Subscripts i, j, and k refer to relative rod positions; i-position for which R-factor is calculated; j- position face adjacent to i; and k - position diagonally adjacent to i.

A-3

Non-Proprietary Information NEDO-33383 Revision 0 Side Rod:

Applying Equation A-I to a side rod (as in Figure A-2b),

(( )) (A-3)

Interior Rod:

Applying Equation A-1 to an interior rod (as in Figure A-2c),

)) (A-4)

If there is one unheated lattice position (as in Figure A-2d),

)) (A-5)

If there are two unheated lattice positions (as in Figure A-2e),

(( )) (A-6)

If there are three unheated lattice positions (as in Figure A-2f),

)) (A-7)

A summary of the R-factor calculation method for each ATRIUM-10 lattice position (as identified in Figure A-3) is given in Table A-1.

A.6 Fuel Assembly R-factor The fuel assembly R-factor is determined in accordance with Equation A-8 for any specified fuel assembly exposure, control state and channel bow.

R =- Max [Ri ] taken over all i (A-8)

A-4

Non-Proprietary Information NEDO-33383 Revision 0 Water Box Figure A-2a Figure A-2d

, Water Box Ci Figure A-2b Figure A-2e r ZWater Box Figure A-2c Figure A-2f Figure A-2. Identification of Rods in Positions Adjacent to Rod i A-5

Non-Proprietary Information NEDO-33383 Revision 0 Table A-1. R-factor Calculation by Lattice Position Lattice Apply Use Position Figure Equation (1,1) A-2a A-2 (1,2) A-2b A-3 (1,3) A-2b A-3 (1,4) A-2b A-3 (1,5) A-2b A-3 (1,6) A-2b A-3 (1,7) A-2b A-3 (2,2) A-2c A-4 (2,3) A-2c A-4 (2,4) A-2c A-4 (2,5) A-2c A-4 (2,6) A-2c A-4 (2,7) A-2c A-4 (3,3) A-2c A-4 (3,4) A-2c A-4 (3,5) A-2c A-4 (3,6) A-2c A-4 (3,7) A-2c A-4 (4,4) A-2d A-5 (4,5) A-2e A-6 (4,6) A-2f A-7 (4,7) A-2e A-6 (4,8) A-2d A-5 (5,8) A-2e A-6 (6,8) A-2f A-7 (7,8) A-2e A-6 (8,8) A-2d A-5 A-6

Non-Proprietary Information NEDO-33383 Revision 0 Line of Symmetry 12 2,2 2:,3 (,42 02,06 C

,~ 2,3 1, 1,3 2,3 3,3 3ý,4 A 1, ,7) 33 2, ,

1424 34 4,4 "4ý,55 4,06 4:,7 48) 2, 1, 1, 27 1,6 2,6

,7 4,7 3,6 4,6Water Box (3 1,8 1,3( 2, 3, 48 , 68 , 8,8 2 s,3 ,

Q Part Length Rod x,x - Additive Constants Label Figure A-3. ATRIUM-10 Lattice A-7

Non-Proprietary Information NEDO-33383 Revision 0 Table A-2. ATRIUM-10 Axial Shapes for Rod Power Integration i

A-8

Attachment 6 GNRO-2007/00071 Affidavit for Request to Withhold Information

Global Nuclear Fuel - Americas AFFIDAVIT 1, Andrew A. Lingenfelter, state as follows:

(1) 1 am Vice President, Fuel Engineering, Global Nuclear Fuel-Americas, L.L.C.

("GNF-A"), and have been delegated the ftinrtion of reviewing the inmfrmation 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 GNF Licensing Topical Report, NEDC-33383P, Revision 0, GEXL97 CorrelationApplicable To ATRIUM-10 Fuel, September 2007. The proprietary information in GNF Licensing Topical Report, NEDC-33383P, Revision 0, GEXL97 CorrelationApplicable To ATRIUM-10 Fuel, September 2007, is identified by a single ((dottedunderline inside double qu..are.b~ra~ck~e~ts]l. Figures and other large objects are identified with double square brackets before and after the object. In each case, the superscript notation 0) refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application forwithholding of proprietary information of which it is the owner or licensee, GNF-A relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC 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 qualify 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 Project v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group

v. FDA, 704F2d1280 (DC Cir. 1983).

(4) Some examples of categories of information which 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 GNF-A's competitors without license from GNF-A constitutes a competitive economic advantage over other companies;

b. information which, if used 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 of a similar product;

c. Information which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, resulting in potential products to GNF-A; NEDC-33383P- GEXL97 Correlation AffidaviL Page I of 3

d. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. above.

(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 GNF-A, 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 GNF-A, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made'by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge; or subject to the terms under which it was licensed to GNF-A. Access to such documents within GNF-A is limited on 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, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GNF-A 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 agreements.

(8) The information identified in paragraph (2) is classified as proprietary because it contains details of GNF-A's fuel design and licensing methodology.

The development of the methods used in these analyses, along with the testing, development and approval of the supporting methodology was achieved at a significant cost, on the order of several million dollars, to GNF-A or its licensor.

NEDC-33383P- GEXL97 Correlation Affidavit Page 2 of 3

(9) Public disclosure of the information sought to be withheld is likely to cause substantial, harm to GNF-A's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GNF-A'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 fi-om providing analyses done with NRC-approved methods.

The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GNF-A.

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.

GNF-A's competitive advantage will be lost if its competitors are able to use the results of the GNF-A 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 GNF-A 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 GNF-A 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 7th day of September 2007.

Andrew A. Lingenfelter Vice President, Fuel Engineering Global Nuclear Fuel - Americas. L.L.C.

NEDC-33383P- GEXL97 Correlation Affidavit Page 3)of 3