ML13091A040

Supplement to License Amendment Request to Relocate, the Pressure and Temperature Limit Curves to the Pressure and Temperature Limits Report

ML13091A040
Person / Time
Site:	Nine Mile Point
Issue date:	03/25/2013
From:	Costanzo C Constellation Energy Nuclear Group, EDF Group, Nine Mile Point
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MF0345, GEH Letter Number 315497-11
Download: ML13091A040 (20)

Text

Attachment 6 to the Enclosure transmitted herewith contains Proprietary Information.

Withhold from public disclosure in accordance with 10 CFR 2.390.

When separated from the Enclosure, this document is decontrolled.

Christopher R. Costanzo P.O. Box 63 Vice President-Nine Mile Point Lycorning, New York 13093 315.349.5200 315.349.1321 Fax CENOSM*

a joint venture of

©ConsteL-ation a NINE MILE POINT NUCLEAR STATION March 25, 2013 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION: Document Control Desk

SUBJECT:

Nine Mile Point Nuclear Station Unit No. 2, Docket No. 50-410 Supplement to Nine Mile Point Nuclear Station License Amendment Request to Relocate, the Pressure and Temperature Limit Curves to the Pressure and Temperature Limits Report

REFERENCE:

(a) Letter from K. Langdon (NMPNS) to Document Control Desk (NRC), dated November 21, 2012, License Amendment Request Pursuant to 10 CFR 50.90:

Relocation of Pressure and Temperature Limit Curves to the Pressure and Temperature Limits Report (TAC No. MF0345)

Nine Mile Point Nuclear Station (NMPNS) submitted the original License Amendment Request (LAR) described in Reference (a) with an Enclosure and six Attachments. Attachment 5 to the Enclosure of Reference (a) contained two affidavits to justify withholding proprietary information. The original affidavits and attachments were provided to NMPNS by General Electric Hitachi Nuclear Energy (GEH) in a letter from J. A. Hren (GEH) to G. Inch (NMPNS), dated November 6, 2011, Pressure Temperature Curve Request (RAI Responses), GEH Letter Number 315497-11.

The purpose of this supplemental letter is to replace the Electric Power Research Institute (EPRI) affidavit in Attachment 5 to the Enclosure of Reference (a) with a revised affidavit to clarify the reasons for

Document Control Desk March 25, 2013 Page 2 withholding the information and other administrative changes. The original GEH affidavit provided in to the Enclosure of Reference (a) remains unchanged. Additionally, Attachments 4 and 6 to the Enclosure of Reference (a) are being replaced with new Attachments 4 and 6 and are also enclosed in this letter. The only changes in Attachments 4 and 6 are updated headers to clarify their relationship to the original GEH letter submitting them to NMPNS. This letter also contains the Enclosure cover page, with the updated wording of the Attachment 4 and 6 headers. The GEH Letter Number 315497-11, Attachment A, Pressure Temperature Curve Request (RAI Responses) - Proprietary Version was converted to NMPNS Reference (a), Attachment 6 to the Enclosure and is the same document provided by GEH Letter Number 315497-11. The Non-Proprietary version of GEH Letter Number 315497-11, Attachment B, was converted to NMPNS Reference (a), Attachment 4 to the Enclosure. This clarification of the conversion of the proprietary and non-proprietary RAI responses from the GEH Letter Number 315497-11 to the NMPNS submittal in Reference (a) is necessary because the affidavits provided by GEH and EPRI reference the GEH Letter Number 315497-11 and not the original NMPNS submittal. to the Enclosure contains information considered to be proprietary as defined by 10 CFR 2.390. The EPRI and GEH, as the owners of the proprietary information, have executed the affidavits provided in Attachment 5 to the Enclosure detailing the reasons for withholding the proprietary information. On behalf of EPRI and GEH, NMPNS hereby requests that proprietary information in to the Enclosure be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390. A non-proprietary version of the information is provided in Attachment 4 to the Enclosure.

Pursuant to 10 CFR 50.91(b)(1), NMPNS has provided a copy of this supplemental letter, with the Enclosure absent Attachment 6, to the appropriate state representative.

There are no commitments in this submittal.

This supplemental letter does not change the initial determination of "no significant hazards consideration" justified in the original amendment request, Reference (a).

Should you have any questions regarding the information in this submittal, please contact John J. Dosa, Director Licensing, at (315) 349-5219.

I declare under penalty of perjury that the foregoing is true and correct. Executed on March 25, 2013.

Very truly yours, CRC/KJK

Enclosure:

Evaluation of the Proposed Change (cover page and updated Attachments 4, 5 and 6 referenced therein) cc: Regional Administrator, Region 1, NRC Project Manager, NRC Resident Inspector, NRC A. L. Peterson, NYSERDA (without Attachment 6 to the Enclosure)

.6 4 ENCLOSURE EVALUATION OF THE PROPOSED CHANGE TABLE OF CONTENTS 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 Description of the Proposed Change 2.2 Background

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

ATTACHMENTS

1. Nine Mile Point Unit 2 - Proposed Technical Specification Changes (Mark-up)

2. Nine Mile Point Unit 2 - Changes to Technical Specification Bases (Mark-up)

3. Nine Mile Point Unit 2 Pressure and Temperature Limits Report (PTLR) (Draft)

4. Responses to Requests for Additional Information - Non-Proprietary Version (GEH Letter Number 315497-11, Attachment B)

5. Affidavits Justifying Withholding of Proprietary Information

6. Responses to Requests for Additional Information - Proprietary Version (GEH Letter Number 315497-11, Attachment A)

Nine Mile Point Nuclear Station, LLC March 25, 2013

ATTACHMENT 4 RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION -

NON-PROPRIETARY VERSION (GEH Letter Number 315497-11, Attachment B)

Nine Mile Point Nuclear Station, LLC March 25, 2013

Attachment 4 Responses to Requests for Additional Information - Non-Proprietary Version (GEH Letter Number 315497-11, Attachment B)

The following Requests for Additional Information (RAI) were received by Grand Gulf Nuclear Station-.

(GGNS) in email correspondence dated January 31, 2011 (Accession Number MLl 10310390). The RAIs were in response to their submittal of a license amendment request (LAR) for an Extended Power Uprate (EPU). The original RAI included questions for vessel internals and the Pressure-Temperature.

Limits Report (PTLR) implementing the methodology of NEDC-33178P-A, "General Electric Methodology for Development of Reactor Pressure Vessel Pressure-Temperate Curves." This attachment only includes the GGNS RAI questions that apply to the PTLR. The NMP2 response was prepared by General Electric Hitachi (GEH) to address the applicability of the GGNS RAIs to Nine Mile Point Unit 2 (NMP2). The GGNS RAI question is in italics, followed by the response as it applies to' NMP2.

NON-PROPRIETARY INFORMATION NOTICE This is a non-proprietary'version of attachment 6 which has the proprietary information removed.

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

Page 1 of 12

Attachment 4 Responses to Requests for Additional Information - Non-Proprietary Version (GEH Letter Number 315497-11, Attachment B)

GGNS RAI-3 Confirm that the proposed PTLR will take effect prior to or concurrent with the proposed EPU, replacingthe P-T limits currently in the GGNS Technical Specifications (TS). If the previous statement is correct the staff will not review the P-T limits in the GGNS TS, as only the PTLR is applicable to the EPU.

NMP2 Response to GGNS RAI-3 This RAI is not applicable to NMP2. EPU has already been implemented at NMP2. The P-T limit curves currently contained in the NMP2 Technical Specifications are valid for the peak vessel fluence corresponding to 22 Effective Full Power Years (EFPY), based on a 3467 MWth rating.

Conservative projections for the 1st EPU cycle indicate that NMP2 will reach the peak vessel fluence corresponding to the current PT curves in December 2013.

Page 2 of 12

Attachment 4 Responses to Requests for Additional Information - Non-Proprietary Version (GEH Letter Number 315497-1I, Attachment B)

GGNS RAI-4 Do the P-T limit curves provided include a hydrostaticpressure adjustmentfor the column of water in a fidl RP V? If so, provide the pressure head used in the P-T limit curve analysis..

NMP2 Response to GGNS RAI-4 Yes, the PT limit curves include a hydrostatic pressure adjustment for the column of water in a full RPV.

The pressure head for the beltline hydrostatic test curve (Curve A) for NMP2 is 23.6 psig. This is determined using the height of the vessel and the elevation of bottom of active fuel.

The full vessel pressure head is 31.4 psig. This pressure is indirectly used in the PT curve analysis. It is considered in the determination of K, for the bottom head curve as discussed in the PT curve licensing topical report, "GE Hitachi Nuclear Energy Methodology for Development of Reactor Pressure Vessel Pressure-Temperature Curves," NEDC-33178P-A, Revision 1. Sections 4.3.2.1.1 and 4.3.2.2.2 of NEDC-33178P-A, Revision 1, include additional discussion regarding the use of the pressure head.

Page 3 of 12

Attachment 4 Responses to Requests for Additional Information - Non-Proprietary Version (GEH Letter Number 315497-11, Attachment B)

GGNS RAI-5 Address inconsistenciesbetween the statement that "the P-T curves are beltline (A1224-1 plate) limited above 1330 psig for Curve A for 35 EFPY... " and the staff determination that the P-T curves are beltline (A 1224-1 plate) limited above -1360 psig from data in Table I of GNRO-2010/00056.

NMP2 Response to GGNS RAI-5 This RAI is not applicable to NMP2 as it addresses a plant-specific GGNS statement.

Page 4 of 12

Attachment 4 Responses to Requests for Additional Information - Non-Proprietary Version (GEH Letter Number 315497-11, Attachment B)

GGNS RAI-6 Provide the surveillance data and the analysis of the surveillance data used to determine ART from reference 6.3 (BWRVIP-135, Revision I "BWR Vessel and Internals Project Integrated Surveillance Program(ISP) Data Source Book and Plant Evaluations"), as requiredby NEDC-331 78P-A.

NMP2 Response to GGNS RAI-6 BWRVIP- 135, Revision 2 provides the surveillance data considered in determining the chemistry and any adjusted Chemistry Factors (CF) for the beltline materials.

Excerpt from BWRVIP-135, Revision 2'

((]

For NMP2, the Integrated Surveillance Program (ISP) representative weld, heat (( )), is not the target vessel material. However, the ISP weld heat is the same heat as another beltline weld. Therefore, the surveillance data is considered and the CF is adjusted as defined in Regulatory Guide 1.99 (RG1.99),

Position 2.1.

Plate Material The ISP representative plate material, heat (( )), is not the target vessel material and is therefore provided for information only. The NMP2 plant-specific plate heat C3 147-1 is the limiting material for the vessel, and is used in development of the PT curves.

Note that the Adjusted Reference Temperature (ART) table provided in the PTLR includes chemistries based on both the plant-specific information and Using the BWRVIP-135 best estimates.

For the plate material, heat (( was contained in one (1) of the [

capsules that has been tested and analyzed. The resultant chemistry is (( )) Cu and ((

)) Ni. The CF from Regulatory Guide 1.99, Revision 2 (RG1.99) is (( ))* a fitted CF will be determined once a second capsule is tested. Therefore, the CF used for the ISP evaluation for the plate material is (( )).

Page 5 of 12

.1.

Attachment 4 Responses to Requests for Additional Information - Non-Proprietary Version (GEH Letter Number 315497-11, Attachment B)

Excerpt from BWRVIP-135, Revision 2 1]

Weld Material For the weld material, heat (( was included in [

capsules and (( )) capsule that have been tested and analyzed. The resultant chemistry is provided as (( )) Cu and [ ))] Ni for the (( )) capsule material, and as (( )) Cu and (( 1] Ni for the (( ] capsule materials; the CF for this chemistry is (( )). The mean surveillance chemistry is defined as (( )) Cu and (( )) Ni. The resulting RG1.99 CF for the mean chemistry is (( )), and the fitted CF is (( )). The maximum scatter in the fitted data is within the 1-sigma value of 287F from RGI.99. BWRVIP-135 also provides best estimate chemistries that are used in the ART evaluation. Best estimate weld heat (( )) information is provided, defining the chemistry as (( )) Cu and (( )) Ni. The CF from RGI.99 for the best estimate chemistry of (( )) Cu and (( )) Ni is (( )). The chemistry for this weld heat that occurs in the NMP2 vessel beltline is (( )) Cu and (( )) Ni; the resulting CF is

[]. For the weld material, the CF is determined using the equation:

Adute~urC Table T CFý AdusI SiiCv.iCF-TAbl:ýCf~~

Therefore, the adjusted CF (( )), which is used for the ISP weld material evaluation. It is noted that the (( )) weld material from the ISP has a CF of (( )) and the (( )) weld material from the ISP has a CF of(( )). For the equation above, use of the

(( )) CF has been conservatively considered.

Page 6 of 12

Attachment 4 Responses to Requests for Additional Information - Non-Proprietary Version (GEH Letter Number 315497-11, Attachment B)

Excerpts from BWRVIP-135, Revision 2 I]

Page 7 of 12

Attachment 4 Responses to Requests for Additional Information - Non-Proprietary Version (GEH Letter Number 315497-11, Attachment B)

Page 8 of 12

Attachment 4 Responses to Requests for Additional Information - Non-Proprietary Version (GEH Letter Number 315497-11, Attachment B)

GGNS RAI-7 Provideadditionaldetailfor the non-beltline analysisconducted in the following areas in orderfor the staff to complete independent verification of the proposed P-T limits:

1. Identify limiting materialsfor the Reference Temperature for Nil Ductility Transition (RTNDT) values used to shift the generic Bottom Head and Upper Vessel P-T curves when applying NEDC-33178P-A.

2. The staff identified a limiting RTNDT of 10OF for the Bottom Head Torus Plates, while GGNS assumed a RTNDT of 24.6°Ffor Bottom Head Curve B. Support all RTNDT values reported by providing details of any plant-specific analysis conducted.

3. Explain minor differences in assumed RTNDT valuesfor the Bottom Head. Specifically Curves A and C assume a limiting RTNDT of 19 OF, while Curve B assumes a limiting RTNDT of 24.6 0F.

4. Which region of the RP V is limitingfor Curve C < 312 psig?

NMP2 Response to GGNS RAI-7 In order to determine how much to shift the Pressure-Temperature (PT) curves, an evaluation is performed using Tables 4-4b and 4-5b from NEDC-33178P-A. These tables define the required Temperature minus Reference Temperature of Nil Ductility Transition (T-RTNDT) that is used to develop the non-shifted curves. Each component listed in these tables is evaluated using the plant-specific initial RTNDT for each component. The required temperature is then determined by adding the T-RTNDT to the plant-specific RTNDT, thereby resulting in the required T for the curve. As the upper vessel curve is initially based on the non-shifted feedwater (FW) nozzle T-RTNDT, all resulting T values are compared to the FW nozzle T. The difference between the maximum T and the FW nozzle T-RTNDT is used to shift the upper vessel curve. The same method is applied for the Control Rod Drive (CRD) curve. In this manner, it is assured that each curve bounds the maximum discontinuity that is represented.

For the NMP2 upper vessel curve, the maximum T value from the method described above is ((

)). The initial required T-RTNDT for the (( )); this is then adjusted by the NMP2-specific maximum (( )), resulting in (( )). Comparing this to the FW nozzle values, the required T-RTNDT is (( )), which is added to the ((

)). It is seen that the resulting T required for the FW nozzle is E[ )). As (( )) is ((

)) the baseline non-shifted FW nozzle curve (( )), which is based on the NMP2 upper vessel curve is based on an RTNDT of (( )). As noted above, this calculation was performed for each component shown in Table 4-4a; only the limiting case is presented here.

For the NMP2 bottom head or CRD ER respectively), the maximum T values from the method described above is E]

The required T-RTNDT for the (( ]; this is adjusted by the NMP2-specific maximum (( )), resulting in (( )). Comparing this to the CRD values, the required T-RTNDT is 161°F, which is added to the []

It is seen that the resulting T required for the bottom head is (( )). As (( )) is Page 9 of 12

Attachment 4 Responses to Requests for Additional Information - Non-Proprietary Version (GEH Letter Number 315497-11, Attachment B)

)) the baseline non-shifted CRD curve (( )), the NMP2 bottom head (CRD) curve is based on an (( )). As noted above, this calculation was performed for each component shown in Table 4-5a; only the limiting case is presented here.

Appendix H ofNEDC-33178P-A contains the details of an analysis performed to determine the baseline requirement (non-shifted) for the ((

It can be seen in Section H.5 of Appendix H that the stresses developed in this finite element analysis demonstrated that the (( )),

resulting in a baseline non-shifted required T-RTNDT of E[ )). Therefore, considering the determination of the required shift from the paragraph above for EE calculations for all components listed in Table 4-5a were compared to the CRD T, which is ((

)) (where (( )) materials). Therefore, the shift for the bottom head E[ )).

For Curve C, the upper vessel is bounding at pressures between 110 and 312.5 psig. For pressures above 1250 psig, the beltline is bounding. For the remaining pressure ranges from 0 to 110 psig and between 312.5 and 1250 psig, the 10CFR50 Appendix G requirement are bounding.

Page 10 of 12

Attachment 4 Responses to Requests for Additional Information - Non-Proprietary Version (GEH Letter Number 315497-11, Attachment B)

GGNS RAI-8 identifies nozzle N12 as a beltline water level instrument nozzle and notes that an evaluation was conducted using the limiting material propertiesfor the adjoining shell ring, which appears to be appropriate as nozzle N12 is identified as austenitic. Provide details of this evaluation which demonstrates that the drill holefor the beltline water level instrument nozzle is not limiting.

NMP2 Response to GGNS RAI-8 Appendix J of NEDC-33178P-A provides detailed results of an analysis performed for the water level instrumentation nozzle that provides the required stresses for the drill hole in the shell plate. These stresses were used to generate a specific curve applicable for the water level instrumentation nozzle to assure that this location is bounded in the PT curves. For NMP2, the water level instrumentation nozzle is (( A.

The LPCI. (N6) nozzle is included in the extended beltline region in accordance with 10 CFR 50 Appendix G. For the N6 nozzle, CMTRs were located that contained Cu (0.07%) and Ni (0.86%)

values. An assessment of the N6 nozzle is contained in Appendix B of the PTLR.

The Water Level Instrumentation (N 12) nozzle is included in the extended beltline region in accordance with 10 CFR 50 Appendix G. For this nozzle, the CMTRs do not contain the Cu and Ni content. Since plant-specific information regarding the Cu and Ni content for this-material is not available, the evaluation was performed based on a (( )) fabricated from SA508 Class 1 material. This was defined based on a search of ((

for SA508 Class I materials. The Cu and Ni values ((

respectively. The weld connecting the forging to the vessel shell is fabricated from Inconel, and does not require a fracture toughness evaluation.

Page 11 of 12

Attachment 4 Responses to Requests for Additional Information - Non-Proprietary Version (GEH Letter Number 315497-11, Attachment B)

GGNS RAI-9 Provide details on any plant-specificfeedivaternozzle evaluation conducted in support of the proposed P-T limits or explain why plant-specific evaluation was not required.

NMP2 Response to GGNS RAI-9 An evaluation was performed for the feedwater nozzle as described in Section 4.3.2.1.3 of NEDC-333178P-A. This evaluation confirmed that the feedwater discontinuity bounds the other discontinuities defined in Table 4-4a of NEDC-33178P-A. The first part of the evaluation is as described in the response to RAI 7, where it is assured that the limiting component that is represented by the upper vessel nozzle curve is bounded. A second evaluation was performed using the NMP2-specific feedwater nozzle dimensions; this evaluation is shown below to demonstrate that the ((

curve is applicable to NMP2.

Vessel radius to base metal, Rv ((

Vessel thickness, tv Vessel pressure, Pv Pressure stress = PR/t A))=

Dead Weight + Thermal Restricted Free End stress Total Stress = [)) ]

The factor F (a/r,) from Figure A5-1 of "PVRC Recommendations on Toughness Requirements for Ferritic Materials", Welding Research Council Bulletin 175, August 1972 (WRC-175) is determined where:

a = / (tn2 + tv2) -. ((

tn = thickness of nozzle "

tv = thickness of vessel rn = apparent radius of nozzle = n + 0.29*rc n= actual inner radius of nozzle rc =nozzle radius (nozzle corner radius) ))

Therefore, a/r, = )). The value F (a/rn), taken from Figure A5-1 of WRC-175 for an112 a/rn

)). Including the safety factor of 1.5, the stress intensity factor, K,, is 1.5 c (71a)

• of [f F(air,,):.

Nominal K, - 1.5* ((

A detailed upper vessel example calculation for core not critical conditions is provided in Section 4.3.2.1.4 ofNEDC-33178P-A. Section 4.3.2.1.3 ofNEDC-33178P-A, presents the (( ))

FW nozzle evaluation upon which the baseline non-shifted upper vessel PT curve is based. It can be seen that the nominal K, from this evaluation is E[ )). Therefore, it has been shown that the nominal K, for the NMP2-specific FW nozzle is bounded by the (( )) K,, demonstrating applicability of the FW nozzle curve for NMP2.

Page 12 of 12

ATTACHMENT 5 AFFIDAVITS JUSTIFYING WITHHOLDING OF PROPRIETARY INFORMATION Updated EPRI Affidavit only. The GEH Affidavit submitted by NMPNS letter dated November 21, 2012 remains unchanged.

Nine Mile Point Nuclear Station, LLC March 25, 2013

,ELECTRICPOWER RESEARCH INSTITUTE NEIL WILMSHURST Vice President and Chief Nuclear Officer February 8, 2013 Document Control Desk Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Request for Withholding of the Proprietary Information included in the following Document:

Attachment A- Pressure Temperature Curve Request (RAI Responses) - Proprietary Version of GEH letter, 315497-11, "Pressure Temperature Curve Request (RAI Responses)," dated November 6, 2012 To Whom It May Concern:

This is a request under 10 C.F.R. §2.390(a)(4) that the U.S. Nuclear Regulatory Commission ("NRC")

withhold from public disclosure the information identified in the enclosed Affidavit consisting of the proprietary information owned by Electric Power Research Institute, Inc. ("EPRr') identified above (the "Report"). Proprietary and non-proprietary versions of the Report and the Affidavit in support of this request are enclosed.

EPRI desires to disclose the Report in confidence to assist the NRC review of the enclosed submittal to the NRC by Constellation Energy. The Proprietary Information is not to be divulged to anyone outside of the NRC or to any of its contractors, nor shall any copies be made of the Proprietary information provided herein. EPRI welcomes any discussions and/or questions relating to the information enclosed.

Ifyou have any questions about the legal aspects of this request for withholding, please do not hesitate to contact me at (704) 704-595-2732. Questions on the content of the Report should be directed to Andrew McGehee of EPRI at (704) 502-6440.

Sincerely, Together . . . Shaping the Future of Electricity 1300 West W.T. Harris Boulevard, Charlotte, NC 28262-8550 USA 9 704.595.2732 e Mobile 704.490.2653

• nwilmshurst@epri.com

f ELECTRIC POWER RESEARCH INSTITUTE AFFIDAVIT RE: Request for Withholding of the Proprietary Information included in the following Document:

Attachment A- Pressure Temperature Curve Request (RAI Responses) - Proprietary Version of GEH letter, 315497-11, "Pressure Temperature Curve Request (RAI Responses)," dated November 6, 2012 I, Neil Wilmshurst, being duly sworn, depose and state as follows:

I am the Vice President and Chief Nuclear Officer at Electric Power Research Institute, Inc. whose principal office is located at 1300 W WT Harris Blvd, Charlotte North Carolina ("EPRI") and I have been specifically delegated responsibility for the above-listed Response that is sought under this Affidavit to be withheld (the "Report). I am authorized to apply to the U.S. Nuclear Regulatory Commission ("NRC") for the withholding of the Report on behalf of EPRI.

The term "Report" is used to identify the EPRI proprietary information contained in attachment Ato be withheld. EPRI Proprietary information is identified by a solid underline inside double square brackets ((This sentence is an example)) Tables containing EPRI Proprietary information are identified with double square brackets before and after the object.

EPRI requests that the Report be withheld from the public on the following bases:

Withholdinq Based Upon Privileged And Confidential Trade Secrets Or Commercial Or Financial Information:

a. The Report is owned by EPRI and has been held in confidence by EPRI. All entities accepting copies of the Report do so subject to written agreements imposing an obligation upon the recipient to maintain the confidentiality of the Report. The Report is disclosed only to parties who agree, in writing, to preserve the confidentiality thereof.

b. EPRI considers the Report and the proprietary information contained therein (the "Proprietary Information") to constitute trade secrets of EPRI. As such, EPRI holds the Report in confidence and disclosure thereof is strictly limited to individuals and entities who have agreed, inwriting, to maintain the confidentiality of the Report.

c. The information sought to be withheld is considered to be proprietary for the following reasons. EPRI made a substantial economic investment to develop the Report, and, by prohibiting public disclosure, EPRI derives an economic benefit in the form of licensing royalties and other additional fees from the confidential nature of the Report. Ifthe Report and the Proprietary Information were publicly available to consultants and/or other businesses providing services in the electric and/or nuclear power industry, they would be able to use the Report for their own commercial benefit and profit and without expending the substantial economic resources required of EPRI to develop the Report.

d. EPRI's classification of the Report and the Proprietary Information as trade secrets is justified by the Uniform Trade Secrets Act which California adopted in 1984 and a version of which has been adopted by over forty states. The California Uniform Trade Secrets Act, California Civil Code §§3426 - 3426.11, defines a "trade secret" as follows:

'Trade secret' means information, including a formula, pattern, compilation, program device, method, technique, or process, that:

(1) Derives independent economic value, actual or potential, from not being generally known to the public or to other persons who can obtain economic value from its disclosure or use; and (2) Is the subject of efforts that are reasonable under the circumstances to maintain its secrecy."

e. The Report and the Proprietary Information contained therein are not generally known or available to the public. EPRI developed the Report only after making a determination that the Proprietary Information was not available from public sources. EPRI made a substantial investment of both money and employee hours in the development of the Report. EPRI was required to devote these resources and effort to derive the Proprietary Information and the Report. As a result of such effort and cost, both in terms of dollars spent and dedicated employee time, the Report is highly valuable to EPRI.

f. A public disclosure of the Proprietary Information would be highly likely to cause substantial harm to EPRI's competitive position and the ability of EPRI to license the Proprietary Information both domestically and internationally. The Proprietary Information and Report can only be acquired and/or duplicated by others using an equivalent investment of time and effort.

I have read the foregoing and the matters stated herein are true and correct to the best of my knowledge, information and belief. I make this affidavit under penalty of perjury under the laws of the United States of America and under the laws of the State of California.

Executed at 1300 W WT Harris Blvd being the premises and place of business of Electric Power Research Institute, Inc.

Neil Wilmshurst (State of North Carolina)

(County of Mecklenburg)

Subscribed and sworn to (or affirmed) before me on this F'*day of , 20__ by

____ _AWA_ _A4__ , proved to me on the basis of satisfactory6idence to be the person(s) who appeared before me.

uSig re ".60JA 4 . ,AI (Seal)

My (ommission Expires ay ofy 20_.

, , - o