ML14066A174

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Supplement to Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specification 3.7.3, Ultimate Heat Sink (UHS)
ML14066A174
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 02/20/2014
From: Gullott D M
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML14066A250 List:
References
RS-14-042
Download: ML14066A174 (43)
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{{#Wiki_filter:Ad M 4300 Winfield Ro3d Warrenville. IL 60555~ E~ L Ge eatDo 630 657 2000 Office E [.\\toa Generation., oo, c Proprietary Information -Withhold from Public Disclosure Under 10 CFR 2.390 RS-14-042 10 CFR 50.90 February 20, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-1 1 and NPF-1 8 NRC Docket Nos. 50-373 and 50-374

Subject:

Supplement to Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specification 3.7.3,"Ultimate Heat Sink (UHS)"

References:

1) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Request for a License Amendment to LaSalle County Station, Units 1 and 2, Technical Specification 3.7.3, 'Ultimate Heat Sink,"'dated July 12, 2012 2) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Supplemental Information Related to License Amendment Request to LaSalle County Station, Units 1 and 2 Technical Specification 3.7.3, 'Ultimate Heat Sink,"' dated September 17, 2012 3) Letter from P. R. Simpson (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Response to Request for Additional Information Related to License Amendment Request to Technical Specification 3.7.3,'Ultimate Heat Sink,"' dated January 18, 2013 4) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Additional Information Supporting License Amendment Request to Revise Technical Specification 3.7.3, 'Ultimate Heat Sink,"' dated February 11, 2013 5) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Response to Request for Additional Information Related to License Amendment Request to Technical Specification 3.7.3,'Ultimate Heat Sink (UHS),'" dated October 4, 2013 Attachments 1, 4, and 6 contain Proprietary Information.

Withhold from public disclosure under A 10 CFR 2.390. When separated from Attachments 1, 4, and 6, this document is decontrolled. ADO/eý February 20, 2014 U. S. Nuclear Regulatory Commission Page 2 Proprietary Information -Withhold from Public Disclosure Under 10 CFR 2.390 In Reference 1, Exelon Generation Company, LLC, (EGC) requested an amendment to the Technical Specifications (TS) of Facility Operating License Nos. NPF-1 1 and NPF-18 for LaSalle County Station, Units 1 and 2 (LSCS). The license amendment would allow the TS temperature limit of the cooling water supplied to the plant from the Ultimate Heat Sink (UHS) to vary with the observed diurnal cycle. EGC supplemented Reference 1 with letters dated September 17, 2012, January 18, 2013, February 11, 2013, and October 4, 2013 (References 2, 3, 4, and 5).It has been identified that proprietary information was inadvertently provided in the following two attachments of Reference 5 submitted October 4, 2013: Attachment 3: UHS Calculation (Design Analysis L-002457, Revision 8)Attachment 5: UHS Heat Load Calculation (Design Analysis L-002453, Revision 4)EGC requests that Attachment 3 and Attachment 5 provided in Reference 5 be withdrawn and not made available to the public. Attachment 3 and Attachment 5 provided in Reference 5 are superseded by the attachments in this submittal. Attachment 1 to this submittal provides the proprietary General Electric Hitachi (GEH) references that support the LSCS UHS Heat Load Calculation and UHS Calculation. Attachments 1, 4, and 6 contain proprietary information as defined by 10 CFR 2.390, "Public inspections, exemptions, requests for withholding." GEH, as the owner of the proprietary information, has executed the enclosed affidavit, which identifies that the enclosed proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure. The proprietary information was provided to EGC in a GEH transmittal that is referenced by the affidavit. The proprietary information has been faithfully reproduced in the attached information such that the affidavit remains applicable. GEH hereby requests that the attached proprietary information be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390 and 10 CFR 9.17.A non-proprietary version of the information contained in Attachment 1 is provided in Attachment

2. The affidavit supporting the proprietary nature of the information in Attachment 1 is provided in Attachment 3.Attachment 4 provides the UHS heat load calculation (LSCS Design Analysis L-002453, Revision 4). The Attachment 4 UHS heat load calculation incorporates the proprietary GEH references of Attachment
1. A non-proprietary version of the information contained in Attachment 4 is provided in Attachment 5.Attachment 6 provides the UHS calculation (Design Analysis L-002457, Revision 8). The Attachment 6 UHS Calculation incorporates the proprietary GEH references of Attachment 1.For example, the heat loads from Attachment 4 are input to the LSCS UHS calculation (Attachment
6) to determine the peak plant cooling water inlet temperature.

A non-proprietary version of the information contained in Attachment 6 is provided in Attachment 7.Attachments 1, 4, and 6 contain Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachments 1, 4, and 6, this document is decontrolled. February 20, 2014 U. S. Nuclear Regulatory Commission Page 3 Proprietary Information -Withhold from Public Disclosure Under 10 CFR 2.390 EGC has reviewed the information supporting a finding of no significant hazards consideration that was previously provided to the NRC in Attachment 2 of Reference

5. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendments do not involve a significant hazards consideration.

There are no regulatory commitments contained in this submittal. Should you have any questions concerning this letter, please contact Ms. Lisa A. Simpson at (630) 657-2815.I declare under penalty of perjury that the foregoing is true and correct. Executed on the 20th day of February 2014.Respectfully, David M. Gullott Manager -Licensing Exelon Generation Company, LLC Attachments:

1) General Electric Hitachi (GEH) References (PROPRIETARY)
2) General Electric Hitachi (GEH) References (NON-PROPRIETARY)
3) GEH Affidavit Supporting Proprietary Nature of Information in Attachment 1 4) UHS Heat Load Calculation/LSCS Design Analysis L-002453, Revision 4 (PROPRIETARY)
5) UHS Heat Load Calculation/LSCS Design Analysis L-002453, Revision 4 (NON- PROPRIETARY)
6) UHS Calculation/LSCS Design Analysis L-002457, Revision 8 (PROPRIETARY)
7) UHS Calculation/LSCS Design Analysis L-002457, Revision 8 (NON-PROPRIETARY) cc: NRC Regional Administrator, Region III NRC Senior Resident Inspector, LaSalle County Station Attachments 1, 4, and 6 contain Proprietary Information.

Withhold from public disclosure under 10 CFR 2.390. When separated from Attachments 1, 4, and 6, this document is decontrolled. ATTACHMENT 2 General Electric Hitachi (GEH) References

1) GE Nuclear Energy, "Response to DIR for T0608," GEH-LCGS-EPU-262, dated April 18, 2012 2) GE Nuclear Energy, "LaSalle 1 and 2 Heat Balance at 105% Uprated Power," GE-LPUP-024, dated February 18,1999 3) GE Nuclear Energy, "Response to Request for Sensible Energy Data," GE-LPUP-204, dated June 22,1999 4) GE Nuclear Energy, "Decay Heat Table for LaSalle County Station Power Uprate (Including Contribution from Additional Actinides and Activation Products and a Custom G-factor)," NSA-01-404, Revision 1, dated September 4, 2001 (NON-PROPRIETARY) 34 pages follow ENCLOSURE 2 7491-318563-HAO-1 RI LaSalle Requested Documents Non-proprietary Information-Class I (Public)NON-PROPRIETARY NOTICE This is a non-proprietary version of Enclosure 1 of 7491-318563-HAO-1 which has the proprietary information removed. Portions of the document that have been removed are indicated by an open and closed bracket as shown here [[

Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)* HITACHI GE Hitachi Nuclear Energy Kevin E. Baucom Project Manager Asset Enhancement Services 3901 Castle Hayne Road Wilmington, NC 28401 USA T 910-819-4789 M910-547-8158 kevin.boucom@ge.com GEH-LCGS-EPU-262 April 18, 2012 eDRF 0000-0113-9242 To: From: Subject-

Reference:

Dear Dole,

Dale Spencer (Exelon Nuclear)Kevin Baucom Response to DIR for T0608 1. Exelon Generation Co. LLC, Contract Agreement No. 00451634, Release No. 00002 (NSSS ENG SERVICES FOR EPU -LS UNITS 1 & 2), Executed June 21, 2010.In accordance with Reference 1, this letter provides the input requested to support the T0608 UHS evaluation. Three items were requested of GEH.9 Provide confirmation that the Decay Heat Table from Table 7.1 (Design Input 4.1) of L-002453 is still acceptable for EPU." Provide confirmation that the Fuel Pool Heat Load from Design Input 4.6 of L-002453 is still acceptable for EPU.* Provide confirmation that the Sensible Energy Data from Table 7.4 (Design Input 4.7)of L-002453 is still acceptable for EPU.The first two items are addressed by the attached document which provides updated data for the decay heat and fuel pool heat This document has been verified in accordance with GEH requirements and evidence of the verification is contained in GEH DRF section 0000-0146-7978. For the third item, GEH has qualitatively reviewed L-002453, as well as the supporting GEH documentation. EPU does not affect the component mass of steel and water utilized in the referenced document However, the OPL-4A data provided by Exelon is marginally different than the configuration described in L-002453. The OPL does include items, such as RCIC and HPCS piping, which were not considered in L-002453. Additionally, there is a difference in the mass of the RPV. This difference is due to the RPV and fuel reported as a combined value in L-002453, whereas these were separated in the EPU version of the OPL-4A. It is the opinion of GEH that these items, for the purpose of evaluating the UHS, are representative. Accordingly, GEH considers it reasonable to conclude that L-002453 remains valid for EPU to evaluate the UHS. On balance, L-002453 would be expected to present a bounding sensible heat summary for EPU operation. Please note this GEH conclusion IS NOT based on a VERIFIED evaluation. Enclosure 2 of 7491-318563-HAO-1 R1 GEH-LCGS-EPU-262 April 18, 2012 Non-proprietary Information-Class I (Public)Regards Kevin Baucom Attachment Decay Heat Data Decay Heat Data 0000-0146-7979-RO.1 cc Faromarz Poumio (Exelon)John Morrison (Exelon)Vikrom Shah lExleon)Mike Peters (Exelon)Bruce Hagemeier (GEH)Don Hartsock (GEH)William McDonald (Exelon) Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)1] Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)1] Enclosure 2 of 7491-318563-HAO-1 RI Non-proprietary Information-Class I (Public)1] Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)1] Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)1] Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)1] Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)1] Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)11 Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)1] Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)1] Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)1] Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)]] Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)[I: 1] Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)11 Enclosure 2 of 7491%318563-HAO-1 R1 Non-proprietary Information-Class I (Public)g GE Nuclear Energy GW~fWEMWCO-~ 175 Q~xm Abmeni* San Jaw CA.95125 February 18, 1999 GE-LPUP-024 DRF A 13-00384-00 Action Requested by: N/A Response to: Project Deliverable: N/A Yes cc: C. Mowry-(GE) M. Shepherd (GE)C. Dinh (GE)J. Lesiuk (GE)To: From: Author:.

Subject:

References:

Mr. Dave Rogowski LaSalle County Station 2601 N. 21 Road Marseilles, IL 61341 E.G. Thacker (GE)F.T. Bolger (GE)LaSalle I and 2 Heal Balances at 105% Uprated Power Draft Report "105% Core Thermal Power Uprate Turbine -Generator Engineering Study LaSalle Station Unit No. 2 -S/N 170X579, August 1998 Per the reference, the heat balance calculations were re-run to incorporate the FW temperatures for 105% uprated power. The table below summarizes the results. The reactor heat balance diagram for the 105% uprate is also attached (Figure 1.). Per the reference letter, notice that this is the final FW temperatures for the uprated conditions. 1] Enclosure 2 of* 749.1-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)LaSa le I and 2 Heat Balances at ! 05% UprmId Power GE-LPUP-024 DRF A 13-00384-00 February 18, 1999 Page 2 1] Enclosure 2 of 7491-318563-HAO'-I RI Non-proprietary Information-Class I (Public)LaSalle I and 2 Heat Balances at 105% Uprated Power GE-LPUP-024 DRF A 13-00384-00 February 18, 1999 Page 3 CornEd and GEPGS need to confirm by 2/26/99 that the result for the 105% uprate case is acceptable-A signed copy of this letter is included in DRF A]13-00384-00. Supporting technical information and evidence of verification for this information are contained in DRF A13-00384-01. E. G. Thacker 11 Project Manager .., ,s .Enclosure 2 of 7491-318563-HAO-1 R1/N//oy- / s I (Lc Non-proprietary Inform ti -Clss I (Public)Generd EaecW, COnPWy 175 CUftnerAvenue. Son Jose CA 95125 June 22, 1999 GE-LP.UP-204 Action Requested by: Response to: Project Deliverable: N/A Request N/A DRF A) 3-00384-00 cc: C. Shaw (GE)M. Peters (CornEd)D. Pankratz (GE)P. Doverspike (GE)To: From: Mr. Dale Spencer LaSalle County Station 2601 N. 21 VRoad Marseilles, IL 61341 E.G. Thacker (GE)

Subject:

Response to Request for Sensible Energy Data

Dear Dale:

Attached is a table of verified sensible energy information which was requested to support tasks associated with the CornEd scope of the power uprate for LaSalle.A signed copy of this letter is included in DRF Al 3-00384-00. Supporting technical information and evidence of verification for the attached data are contained in DRF A 13-00384-02. E. G. Thacker If Project Manager, LaSalle Power Uprate Aut. Enclosure 2 of-q, 7491-318563-HAO-1 R1 Table UFSAR Table Item No.Non-proprietary Information-Class I (Public)I .Summary of Task 400 Requested Information by S&L Requested Input Value]] Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)GE Nuclear Energy Gea)e EtLwi Cwmpan 175 Cumew Awe. Son Jase. CA 95125 NSA-01 -404, Revision I September 4, 2001 Mr. Michael Doromal

SUBJECT:

Decay Neat Table 6or LaSalle County Station Power Uprate fincluding Contributions from Additional A ctinides and Activation Products and a Custom G-factor)Design Record File: E12-00141-02 Section 17

References:

1. "American National Standard for Decay Heal Power in Light Water Reactors", ANSI/ANS-5.1-1979.2. GE Nuclear Energy Services Information Letter (SIL) Number 636, Revision 1, June 6, 2001.3. Pallonta, A. S., "LaSalle Generic 24 Month Parameters for Containment Analysis Decay Heat Generation", Nuclear Design Information Transmittal, NFM9900058, March 26, 1999.4. Martin, C. L., "Decay Heat Table for LaSalle County Station", letter to ]. Rhee, March 29, 1999.5. Martin, C. L., "Parameters for Decay Heal Evaluations", GE-NE-E1200141-0l R2, Class a]1, May 2000.6. Croff, A. G., "A User's Manual for the OR1GEN2 Computer Code," ORNLJTM-7175, July 1980.A new decay heat table has been generated for LaSalle County Station based upon the ANSI/ANS-5.1-1979 standard (Reference
1) with an added conservatism corresponding to two sigma uncertainty.

This new table was prepared with an allowance for miscellaneous Actinides and Activation Products consistent with the recommendations of SIL 636 (Reference 2). It also includes a custom G-factor evaluation (adjustment for the neutron capture effect). The fuel cycle assumptions which were obtained from Reference 3 are as follows: 1](These are the same parameters previously used in Reference 4.)I Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)According to Reference 3, the enrichment for future reload batches is expected to be within the range of[[ ]]enrichment. However, in the near term, the core average enrichment will be lower[[ ]lfor LaSalle 2 and 3.63% for LaSalle 1). Therefore, the enrichment was chosen reasonably to be[[ ]]the average of these two figures. In general, lower enrichment is more conservative than higher enrichment. However, differences of one quarter of one percent are not significant. The new decay heat table is also applicable to other fuel product lines, including those of other fuel manufacturers, which have the same general configuration. Using the information in the table above, the inputs for the decay heat standard were obtained from Reference

5. The procedure used in Reference 5 was to perform a lattice evaluation with the production lattice physics code, TGBLA04. The lattice chosen Was a typical GEI2 design with an average enrichment of[[ ]]According to the recommended procedure in Reference 5, linear interpolation of the constants was performed between the two closest exposure points]]The following is the list of the parameters determined in this manner: Fissions in materials other than Pu239 and U 2 3 8 are included with U23 5 as required by the standard.The decay heat tables of Reference I represent the heat produced from an ideal situation in which the fission products are allowed to decay in the absence of any competing

ýeffect, such as neutron capture. However, in a reactor, the fission products are exposed to a substantial neutron flux, which results in many captures and transmutations of the fission products. The net effect is to produce more decay heat after shutdown. This is known as the Neutron Capture Effect (NCE).The NCE is formally defined as the additional decay heat which results from the decay of the isotopes produced by neutron capture in fission products, which are exposed to a neutron flux for a finite irradiation period.The NCE is incorporated into the decay heat standard through a parameter called the G-factor, which is the ratio of the decay heat from fission products exposed to a finite neutron flux to the decay heat from fission products in a zero flux environment. Note that the G-factor does not apply to the decay heat contributions from actinides, structural materials or delayed neutron fission.The G-factor depends on the reactor type, the irradiation history and the neutron flux level and spectrum. For the purpose of the standard, Reference 1, a G-factor lable was calculated which was intended to represent in a conservative way, all Light Water Reactors (LWRs). Since this 2 Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)may be overly conservative in some cases, the User of the standard is given the option of calculating and justifying the G-factor.The G-factor in the standard was calculated for the following specific conditions: a) Cross section data in ENDF/B-IV averaged in a typical LWR spectrum;b) Constant power for[[ ]kprior to shutdown;c) Thermal neutron flux 4=[[ ]]n/cm2-sec (equivalent to a flux of 1014 applied to effective cross sections at 0.0253 eV); epitherral neutron flux 4s,, =[[ ]]n/cm2-sec (where ,pi is the total resonance region flux in the range of 0.625 eV to 5.53 x 1 03 eV);d) U 2 3 5 thermal fission.The neutron fluxes in item c significantly exceed those normally found in BWRs. Therefore, a separate evaluation of the G-factor was made with the well-known computer program ORIGEN2 (Reference 6). The results are shown in Figure 3.The ORIGEN2 G-factor is smaller than the standard for all cooling times less than[[ 11 seconds. Beyond that point, it is approximately I% larger. In the range of greatest interest, between 104 and 105 seconds, the ORIGEN2 G-factor is smaller by[[ ]]rhe differenoes are attr'buted mainly to the neutron fluxes, which were approximately a factor of five lower than assumed in the standard.It should be remarked that the G-factor shown in Figure 3 is specific to the fuel product line, enrichment, exposure, irradiation time and power level for the LaSalle County Station Power Uprate, as specified in Reference 3.The decay heat table based on the parameters above and the custom G-factor is shown in Table 1.The first column in the table is the shutdown or cooling time. The second column shows the unadjusted decay heat for the given cooling time and the third column the uncertainty. In the fourth column, the decay heat is shown with two sigma of uncertainty added. The final column is the integral of the decay heal (including the two sigma uncertainty) from time-zero up to the cooling time. The trapezoidal rule of integration was used, thus producing a conservative, upper botnd on the integral.Table 2 is a comparison between the shutdown power (plus two sigma) for the Power Uprate case and the previous case, which did not have an allowance for miscellaneous Actinides and Activation Products or a custom G-factor. Figure I is a plot of the two curves and Figure 2 shows the difference in percent.The new table shows more decay heat than the old one for most cooling times, but the difference is less than 1% for cooling times up to 3 days. This is regarded as an insignificant difference when compared with one sigma uncertainty. 3 Enclosure 2 of , 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)Applicabilitv of Table I to Transition Cycles The general practice is to generate a decay beat table for an equilibrium cycle consisting entirely of a single fuel product line. The table is expected to be conservative not only for the equilibrium cycle, but also for the transition cycles which lead up to equilibrium. The two most significant parameters affecting decay heat are the average irradiation time of the fuel and the average initial enrichment of the fuel. As a rule, longer irradiation times always result in higher decay heat. Higher enrichments in general result in a reduction in decay heat, due principally to the reduced production of Actinides. Fuel product line on the other hand, is not a significant factor in decay heat.Recognizing these sensitivities, it is the general practice to add a margin to the calculated irradiation time for the equilibrium cycle to ensure that the decay heat calculations are conservative. Also, if a range of enrichments are projected for the equilibrium cycle, a value near the low end of the range is generally chosen, also for the sake of conservatism. Several additional conservatisms are also used, including: ignoring refueling outages, assuming that the capacity factor is 1.0 and performing the calculation at the end of the cycle. Finally, an additional allowance corresponding to two sigma of uncertainty is also applied. Taken altogether, these assumptions and conservatisms are expected to result in a decay heat curve which is conservative for the equilibrium cycle.Transition cycles, in general, have a lower average enrichment than the equilibrium cycle they are transitioning toward. As a direct result of the lower enrichment, the transition core has either a smaller energy capability or a large proportion of fresh fuel. In either case, the average irradiation time is reduced (relative to the equilibrium cycle) and the net effect is a reduction in decay heat. For these reasons, as well as the other conservaiisms mentioned above, it is expected that the decay heat table for the equilibrium cycle is also conservative for transition cycles.Cautions with Regard to Use of Table I I. The table represents the decay heat for a full core at End-Of-Cycle. It is not applicable to a discharged batch of fuel.2. The fission power included in the table is directly applicable to Large-Break LOCAs, which have large, immediate negative void feedback. Application to other events requires justification.

3. The shutdown power fraction including iwo sigma uncertainty (column 4of Table 1) does not include the uncertainty in the reactor power level. In most cases, this means that a factor of 1.02 must be applied to the reactor power level, consistent with NRC Regulatory Guide 1.49. In some cases, such as when Thermal Power Optimization (TPO) is in place, a smaller factor may be justified.
4. Heat from Metal-Water reactions during severe accidents, if any, must be included by the User.5. Sensible heat stored in the fuel and structure must be included by the User, if appropriate.

4 Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)Sincerely, Charles L. Martin Nuclear & Safety Analysis Tel: (408)925-6892 Fax: (408)925-1674 E-Mail: cbarles.mariin@gene.ge.com 5 Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)1]6 Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)]]7 Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)1]8 Enclosure 2 of 7491-318563-HAO-1 RI Non-proprietary Information-Class I (Public)9 Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)IM Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)46II Enclosure 2 of 7491-318563-HAO-1 R1 Non-proprietary Information-Class I (Public)12 ATTACHMENT 3 GEH Affidavit Supporting Proprietary Nature of Information in Attachment 1 4 pages follow Enclosure 3 7491-318563-HAO-1 RI Affidavit for Enclosure 1 GE-Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, Peter M. Yandow, state as follows: (1) I am the Vice President, Nuclear Plant Projects/Services Licensing, Regulatory Affairs, of GE-Hitachi Nuclear Energy Americas LLC ("GEH"), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding. (2) The information sought to be withheld is contained in Enclosure 1 of GEH letter, 7491-318563-HAO-1 RI, "LSCS Requested Documents," dated February 14, 2014. The GEH proprietary informration in Enclosure 1, which is entitled "LaSalle Requested Documents," is identified by a dotted underline inside double square brackets. This ...sen.tence is_.s a..an..ex.ample.... Figures and large equation objects containing GEH proprietary information are identified with double square brackets before and after the object. In each case, the superscript notation (31 refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination. (3) In making this application for withholding of proprietary information of which it is the owner or licensee, GEH relies upon the exemption from disclosure set forth in the Freedom of Ihformation Act ("FOIA"), 5 U.S.C. Sec. 552(b)(4), and the Trade Secrets Act, 18 U.S.C.Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for trade secrets (Exemption 4). The material for which exemption from disclosure is here sought also qualifies under the narrower definition of trade secret, within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975 F.2d 871 (D.C. Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F.2d 1280 (D.C. Cir. 1983).(4) The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. Some examples of categories of information that fit into the definition of proprietary information are: a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GEH's competitors without license from GEH constitutes a competitive economic advantage over other companies;

b. Information that, if used by a competitor, would reduce their expenditure of resources or improve their competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;c. Information that reveals aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential products to GEH;d. Information that discloses trade secret or potentially patentable subject matter for which it may be desirable to obtain patent protection.

Affidavit for 7491-318563-HAO-1 RI Page l of 3 GE-Hitachi Nuclear Energy Americas LLC (5) To address 10 CFR 2.390(b)(4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GEH, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GEH, not been disclosed publicly, and not been made available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary or confidentiality agreements that provide for maintaining the information in confidence. The initial designation of this information as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in the following paragraphs (6) and (7).(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, who is the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or who is the person most likely to be subject to the terms under which it was licensed to GEH. Access to such documents within GEH is limited to a "need to know" basis.(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist, or other equivalent authority for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GEH are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary or confidentiality agreements. (8) The information identified in paragraph (2), above, is classified as proprietary because it contains the detailed GEH methodology for decay heat, uprate, and energy data for the GEH Boiling Water Reactor (BWR). These methods, techniques, and data along with their application to the design, modification, and analyses associated with the pressure-temperature curves were achieved at a significant cost to GEH.The development of the evaluation processes along with the interpretation and application of the analytical results is derived from the extensive experience databases that constitute a major GEH asset.(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GEH's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost.The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GEH. The precise value of the expertise to Affidavit for 7491-318563-HAO-I RI Page 2 of 3 GE-Hitachi Nuclear Energy Americas LLC devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial. GEH's competitive advantage will be lost if its competitors are able to use the results of the GEH experience to nonnalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions. The value of this information to GEH would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief Executed on this 1 4 th day of February 2014.Peter M. Yandow Vice President, Nuclear Plant Projects/Services Licensing, Regulatory Affairs GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Rd.Wilmington, NC 28401 Peter.Yandow@ge.com Affidavit for 7491-318563-HAO-1 RI Page 3 of 3}}

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