ML14190A907

Proposed Tech Specs Deleting Requirements Re Maint of Highly Borated Water Inventory in Boron Injection Tank & Associated Heat Tracing Required to Maintain High Boron Concentration in Solution,Per Generic Ltr 85-16

ML14190A907
Person / Time
Site:	Robinson
Issue date:	11/13/1985
From:	CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML14190A906	List: L-85-016, Application to Amend License DPR-23,revising Tech Specs to Delete Requirement Re Maint of High Borated Water Inventory in Boron Injection Tank,Per Generic Ltr 85-16.Proprietary XN-NF-85-17(P) Encl.Rept Withheld (Ref 10CFR2.790).Fee Paid ML14190A907
References
GL-85-16, NUDOCS 8511190359
Download: ML14190A907 (28)

Text

ENCLOSURE BORON INJECTION TANK REVISED TS PAGES 8511190359 851113 PDR ADOCK 05000261 P PDR

g g(HBR-28)

b. Each accumulator is pressurized to at least 600 psig and contains at least 825 ft3 and no more than 841 ft 3 of water with a boron concentration of at least 1950 ppm. No accumulator may be isolated.

c. Three safety injections pumps are operable.

d. Two residual heat removal pumps are operable.

e. Two residual heat exchangers are operable.

f. All essential features including valves, interlocks, and piping associated with the above components are operable.

g. During conditions of operation with reactor coolant, pressure in excess of 1000 psig the A.C. control power shall be removed from the following motor operated valves with the valve in the specified position:

Valves Position MOV 862 A&B Open MOV 864 A&B Open MOV 865 A,B,&C Open MOV 878 A&B Open MOV 863 A&B Closed MOV 866 A&B Closed

h. During conditions of operation with reactor coolant pressure in excess of 1000 psig, the air supply to air operated valves 605 and 758 shall be shut off with valves in the closed position.

i. Power operation with less than three loops in service is prohibited.

3.3-2

(HBR-28) 3.3.1.2 During power operation, the requirements of 3.3.1.1 may be modified to allow any one of the following components to be inoperable. If the system is not restored to meet the requirements of 3.3.1.1 within the time period specified, the reactor shall be placed in the hot shutdown condition utilizing normal operating procedures. If the requirements of 3.3.1.1 are not satisfied within an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the reactor shall be placed in the cold shutdown condition utilizing normal operating procedures.

a. One accumulator may be isolated for a period not to exceed four hours.

b. If one safety injection pump becomes inoperable during normal reactor operation, the reactor may remain in operation for a period not to exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, provided the remaining two safety injection pumps are demonstrated to be operable prior to initiating repairs.

c. If one residual heat removal pump becomes inoperable during normal reactor operation, the reactor may remain in operation for a period not to exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, provided the other residual heat removal pump is demonstrated to be operable prior to initiating repairs.

d. If one residual heat exchanger becomes inoperable during normal reactor operation, the reactor may remain in operation for a period not to exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

e. If any one flow path including valves of the safety injection or residual heat removal system is found to be inoperable during normal reactor operation, the reactor may remain in operation for a period not to exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, provided the other flow path(s) are demonstrated to be operable prior to initiating repairs. The hot leg injection paths of the Safety Injection System, including 3.3-3

(HBR-28) valves, are not subject to the requirements of this specification.

f. Power or air supply may be restored to any valve referenced in 3.3.1.1.h. and 3.3.1.1.i. for the purpose of valve testing or maintenance providing no more than one valve has power restored and provided that testing and maintenance is completed and power removed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> except for accumulator isolation valves (MOV 865 A,B,&C) which will have this time period limited to four hours.

3.3-4

(HBR-28) floor. This depth of water is equivalent to the amount of water in the primary system plus 60% of the refueling water storage tank, approximately 215,000 gallons of water at 263oF.(1)

The post-accident containment venting system is designed with redundant air supply and vent paths. The valves in the system will be demonstrated to be operable prior to criticality. Testing of the air supply system is not required because of the long lead time between an accident and the required operation of the venting system. This period of time will permit maintenance effort, if required. The efficiency of the filters in each vent.path was not used in this safety analysis; therefore, testing of these filters is not required.(6 )

The Isolation Seal Water System provides a reliable means for injecting seal water between the seats and stem packing of the globe and double disc types of isolation valves and into the piping between closed diaphragm type isolation valves.(7)

The minimum 825 ft3 and maximum 841 ft3 of water in the accumulators correspond to an instrument reading of 61.5% and 80.4% of instrument span, respectively.

References (1) FSAR Section 6.2 (2) FSAR Section 6.3 (3) FSAR Section 14.3.5 (4) FSAR Section 9.3 (5) FSAR Section 9.6.2 (6) FSAR Appendix 6B (7) FSAR Section 5.2.2 (8) CP&L report and supplemental letters of September 29, November 5,

December 8, 1971, and March 20, 1972.

3.3-14

(HBR-28)

TABLE 4.1-1 (Continued)

MINIMUM FREQUENCIES FOR CHECKS, CALIBRATIONS AND TEST OF INSTRUMENT CHANNELS Channel Description Check Calibrate Test Remarks

9. Analog Rod Position S (1,2) R M (1) With step counters (2) Following rod motion in excess of six inches when the computer is out of service

10. Rod Position Bank Counters S (1,2) N.A. N.A. (1) Following rod motion in excess of six inches when the computer is out of service

11. Steam Generator Level S R M

12. Charging Flow N.A. R N.A.

13. Residual Heat Removal Pump Flow N.A. R N.A.

14. Boric Acid Tank Level D (1) R N.A. (1) Bubbler tube rodded weekly

15. Refueling Water Storage W R N.A.

Tank Level

16. Deleted

17. Volume Control Tank Level N.A. R N.A.

19. Deleted by Amendment No. 85

20. Boric Acid Makeup Flow Channel N.A. R N.A.

(HBR-28)

TABLE 4.1.2 FREQUENCIES FOR SAMPLING TESTS Maximum Time Between Check Frequency Tests

1. Reactor Coolant Samples - Cross Activity (1) Minimum 1 Per 72 hrs. 3 dayg

- Radiochemical (2) Monthly 45 days

- Radiochemical for 1 per 6 mos. (6)(7) 6 months E Determination

- Isotopic Analysis 1 per 14 days (7) 14 days for Dose Equivalent 1-131 Concentration

- Isotopic Analysis a) Once per 4 for Iodine ##?Inlud- hours (8) ing 1-131, 1-133 b) One sample (9) and 1-135

- Tritium Activity Weekly 10 days

- Cl & 02 5 day/week 3 days

2. Reactor Coolant Boron concentration Twice/week 5 days Boron

3. Refueling Water Boron concentration Weekly. 10-days Storage Tank Water Sample

4. Boric Acid Tank Boron concentration Twice/week 5 days

5. Spray Additive NaOH concentration Monthly 45 days Tank

6. Accumulator Boron concentration Monthly 45 days

7. Spent Fuel Pit Boron concentration Prior to Refueling NA*

8. Secondary Coolant Gross activity Minimuml Per 72 hrs. 3 days Isotopic Analysis a) 1 per 31 days (10) for Dose Equivalent b) 1 per 6 months (11) 1-131 Concentration

9. Stack Gas Iodine 1-131 and particulate Weekly (3) 10 days

& Particulate radioactivity Samples releases

10. Steam Generator Primary to secondary 5 days/week 3 days Samples tube leakage 4.1-10

(HBR-28)

NOTES TO TABLE 4.1-2 (1) A gross activity analysis shall consist of the quantitative measurement of the total radioactivity of the primary coolant in units of PCi/gram.

(2) A radiochemical analysis shall consist of the quantitative measurement of each radionuclide with half life greater than 30 minutes making up at least 95% of the total activity of the primary coolant.

(3) When iodine or particulate radioactivity levels exceed 10% of the limit in Specification 3.9.2.1, the sampling frequency shall be increased to a minimum of once each day.

(5) Deleted.

(6) Sample to be taken after a minimum of 2EFPD and 20 days of power operation have elapsed since the reactor was last subcritical for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or longer.

(7) Samples are to be taken in the power operating condition.

(8) Sample taken at all operating conditions whenever the specific activity exceed 1.0 pCi/gram DOSE EQUIVALENT 1-131 or 100/E pCi/gram. These samples are to be taken until the specific activity of the reactor coolant system is restored within its limits.

(9) One sample between 2 and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following a thermal power change exceeding 15 percent of the rated thermal power within a one-hour period. Samples are required when in the hot shutdown or power operating modes.

(10) Sample whenever that gross activity determination indicates iodine concentrations are greater than 10% of the allowable limit.

(11) Sample whenever the gross activity determination indicates iodine concentrations are below 10 percent of the allowable limit.

NA* - Not applicable.

4L1-11

Evaluation of Electrical Equipment at H. B. Robinson Unit 2 Following a Main Steam Line Break Inside Containment Prepared by: -- /0a/'6 M. A. opd datd Senior Engineer-Transient Analysis Concurred by: __<

T. B. Clements Date Project Engineer-Transient Analysis Concurred by: '_/__ _ _ _ _ /o K. E. Karcher Date Principal Engineer-In-Core Analysis Approved by:

L. H. Martin ate Manager-Nuclear Fuel

Introduction In support of H. B. Robinson Cycle 10 operation, CP&L contracted with Exxon Nuclear Company to analyze the consequences of a main steam line break (MSLB) with the boron injection tank (BIT) either removed or filled with unborated water. In addition to analyzing this event from an MDNBR standpoint, the containment temperature response was also evaluated to determine the effects of the MSLB mass and energy release on containment equipment.

It became obvious from preliminary calculations that the peak containment atmosphere temperature would exceed the 286 0 F equipment qualification (EQ) limit established by the LOCA containment analysis.

The fact that this event results in temperatures higher than those experienced during a LOCA is not due to the BIT modifications, but to changes in the assumptions made concerning mass and energy release rates from MSLB's as documented in WCAP-8822 and other vendor reports generated in the mid-70's. The NRC staff recognized, however, that although containment atmosphere temperatures following MSLB's tended to exceed LOCA temperatures, the short duration of the MSLB temperature peak and the lower equilibrium temperatures meant that the LOCA analysis often remained the limiting event for equipment qualification. This position was documented in Generic Task A-21, Main Steam Line Break Inside Containment, of NUREG-0510:

Although preliminary calculations indicated that the temperature within the containment following a steam line break could be significantly higher than following a loss-of-coolant accident, the duration of the high temperature was calculated to be short.

-2 Because of the relatively low heat transfer rate in superheated steam and the heat capacity of the affected safety-related equipment, the equipment itself would not be expected to exceed the temperature for which it was qualified as a result of this short duration peak in the temperature of the containment atmosphere.

The NRC outlined the process whereby EQ curves defined by the LOCA analysis can be used to qualify equipment inside containment following an MSLB in NUREG-0588.

-3

.. Solution Technique The technique for qualifying equipment for an MSLB using LOCA EQ curves is identified in NUREG-0588, paragraph 1.2(5)b. This method defines the peak surface temperature of the equipment component as the limiting temperature for EQ purposes. Temperatures were calculated by the CONTEMPT/LT28 computer code using NUREG-0588, Appendix B.1, as a guide-forcode input- options..-The analysis was performed in two stages. The first stage involved running sensitivity studies on the initial relative humidity and on the different mitigating system failure options to determine the set of code inputs which would result in the highest heat slab surface temperatures. In the second phase of the analysis, studies were made using the limiting deck from phase one to determine the most conservative approach to modeling safety-related equipment using additional heat conducting slabs. It is the intent of this analysis to show that for the duration of the mass and energy release, the surface temperature of a conservatively modeled component will sufficiently lag the containment atmosphere temperature such that it will remain below the EQ limit of 286 0F.

-14 III CONTEMPT Input Deck Exxon Nuclear Company provided three basic CONTEMPT decks depicting separate single failure possibilities:

(1) Loss of one containment spray system (ENC1,ENC1L)

(2) Loss of two fan coolers (ENC2)

(3) MSIV failure (ENC3,ENC3L)

Both decks (1) and (3) included a "short term" case with two fan coolers operating at time zero, and a "long term" case with four fan coolers starting 45.6 sec. into the event. One modification made to these base decks by CP&L involved the variable on Card 11001 which determines the fraction of the condensate that is transferred from the superheated compartment to the pool. This value was conservatively increased from 0.8 to 0.92 to comply with Appendix B.1.b of NUREG-0588.

All of the input decks provided by Exxon contain 16 heat absorbing structures of various thicknesses and materials. Whil.e these structures are included to reduce the peak atmosphere temperature by removing heat from the containment, they also provide useful information in the form of temperature gradients through materials. Figure 1 shows a typical profile of atmosphere temperature and surface temperature of several heat slabs with different thicknesses. This figure illustrates the thermal lag between the atmosphere and slab temperatures during the early part of the blowdown. This is caused by the immediate response of the atmosphere temperature to changes in the containment mixture, while the heat

H.B. ROBINSON MSLB HEAT SLAB TEMPERATURES vs TIME 360 340 320 300 280 260 240 aL 220 Lii 200 180 160 140 120 0 200 400 600 TIME (sec.)

ATMCS. + #15 #9

1. A #11 x #12 THICKNESS SLAB "I (INCHES) 9 0.25 11 0.625 12 1 50 13 2.75 15 0.108 T-7 I

-5 structures respond'at a slower rate as they absorb energy from the atmosphere. This explains why the most limiting set of code inputs for peak containment temperature may not be limiting for maximum surface temperatures.

Sensitivity studies were performed on each of the Exxon decks to determine the effects of initial relative humidity on the containment temperature response. Results of these studies indicated that both peak atmosphere and slab temperatures increased with increasing relative humidity. Although a lower value for the Uchida heat transfer coefficient would be calculated due to the greater air-to-steam ratio associated with a lower initial relative humidity, this effect is offset by the lower initial quantity of air at higher relative humidities. The temperature of the containment atmosphere at any given time is determined by the equilibrium quantities of air and steam, because in an equilibrium mixture of non-reactive gases, the properties of each component are calculated from the partial pressures of the components.

Since no air is added to the containment during this event, the mass of air in the containment is fixed at time zero from the initial relative humidity at 14.7 psia. Therefore, as the initial relative humidity is increased, the initial mass of air decreases, resulting in a lower partial pressure for air and a higher partial pressure for steam. From the equations of state, the temperature of steam increases with increasing pressure, and the temperature of the mixture is equal to the component temperatures.

It should be noted here that throughout these studies, the Uchida condensing heat transfer coefficient was used. This form of the heat

transfer normally results in lower atmosphere temperatures than achieved with the Tagami heat transfer correlation often used for LOCA calculations. Generally, however, both forms of condensing heat transfer have been found to be conservative relative to measured data, and the Uchida form found in the ENC base decks complies with NUREG-0588 Appendix B.1.a. The results of these studies are shown in Table 1.

-7 TABLE 1 INITIAL PEAK LONG TERM HEAT SLAB RELATIVE ATMOSPHERE ATMOSPHERE SURFACE HUMIDITY TEMPERATURE TEMPERATURE TEMPERATURE*

CASE or MODEL OF OF OF 1 0 ENC1 330 ... 227.3 2 100 ENC1 357.9 --- 236.3 3 100 ENC3 360.1 237.3 4 100 ENC2(L) 344.5 277 236.4 5 0 ENC2(L) 329.4 276 227.7 6 100 ENC1L 344.6 279 236.3 7 0 ENC1L 329.4 280 227.6 8 100 ENC3L 346.4 275 237.4 9 0 ENC3L 331.5 273 228.8

• Heat slab #15 at 62 seconds.

-.8 For purposes of comparison, the slab temperatures reported on Table 1 were taken from a single heat slab at the time step just prior to initiation of containment sprays. Although these are not the maximum heat slab temperatures which occur at the end of the event, they are characteristic for any non-insulated heat structure at any time step before the start of containment sprays. After this time, the atmosphere temperature rapidly drops to an equilibrium value with the heat structures, and the slab temperatures can be conservatively assumed to

.equal the-atmosphere temperature. The results. of the sensitivity studies indicate that the "long term" MSIV failure (ENC3L) case with 100% initial relative humidity generates the highest heat slab temperatures. It is interesting to note that the highest equilibrium atmosphere temperature calculated in any of the studies is 2800F, indicating that the maximum possible component temperature following the atmosphere temperature peak is below the EQ limit.

The next phase of the analysis involved including additional heat structures in the ENC3L deck to evaluate the best method of conservatively modeling the safety-related electrical components in containment. Studies were performed with variations made to the slab area, thickness, geometry, insulation, and heat transfer correlation.

The following observations were made:

(1) Heat slab surface temperature is not related to slab surface .area.

(2) Condensation heat transfer on both sides of an uninsulated heat slab is equivalent to condensation heat transfer on a single side of a slab with half the thickness. Actually, the two-sided surface is slightly more conservative because the non-condensing, insulated surface does conduct away a small amount of heat.

(3) No significant differences were observed between the surface temperatures of rectangular and cylindrical slabs.

(4) The use of the Tagami heat transfer correlation on the component heat slab resulted in significantly lower surface temperatures.

(5) The temperature of exposed insulated surfaces (i.e.,

cables) increases more rapidly at first than non-insulated surfaces due to the lower volumetric heat capacity of the insulation.

However, the temperature of the component surface beneath the insulation was lower than the surface of identical components without insulation.

Based on these findings, the test slab added to the ENC3L deck for the final analysis consisted of a two-sided, non-insulated, rectangular slab of carbon steel with a thickness of 0.1 inches, which is equivalent to a component with a 0.05-inch thick steel casing.

IV. Results and Conclusions When qualifying equipment temperatures for a main steam line break to a qualification limit established by a LOCA analysis, Appendix B.2 of NUREG-0588 calls for the condensing heat transfer coefficient on the component of interest to be equal to four times Uchida during condensing heat transfer. A forced convection heat transfer mechanism is to be applied when condensation is not taking place.

The switch to this mode of heat transfer is done automatically by the CONTEMPT code when the Uchida condensing heat transfer coefficient is specified.

Unfortunately, the code does not have a built-in multiplier on the condensing heat transfer coefficient; and a constant heat transfer coefficient input by the user would not reflect the switch from condensation to convection.

-10 Variations were made to the heat transfer coefficient of the test slab described above to show that a user-defined heat transfer coefficient would satisfy the 4 x Uchida requirement when conservatively modeling safety-related equipment. The first case employed a straight Uchida condensing heat transfer coefficient with automatic switch to convection heat transfer. Case #2 used a fixed heat transfer coefficient equal to 91 Btu/hr-ft2 OF (determined by the value of the Uchida coefficient at the time in which the surface temperature of the test slab in case #1 became equal the temperature of the..atmosphere (102 sec.)).

The surface temperature of the test slab in case #2 exceeded the surface temperature from case #1 at each time step. This means that the fixed value of 91 Btu/hr-ft2-OF is more conservative than the Uchida/convection heat transfer mechanism. Finally, a heat transfer coefficient of 364 Btu/hr ft2-oF (4 x91) was applied in case #3, representing a heat transfer rate more conservative than 4 x Uchida as required by NUREG-0588.

Each of the cases are illustrated in Figure 2.

Appendix B.1.f of NUREG-0588 requires the identification of the most severe environment by considering the spectrum of break sizes and single failures. This criterion is covered in part by the sensitivity studies performed and the variety of input decks provided by Exxon.

The mass and energy release rate supplied by Exxon represents a full, double-ended break at hot zero power with no entrainment. The reasonableness of this break for worst case conditions was evaluated against the spectrum of breaks analyzed in the Shearon Harris FSAR. This review indicated that:

H.B. ROBINSON MSLB CONSERVATIVE COMPONENT TEMP. vs TIME 360 340 320 300 280 260 240 Lii 220 1- 200 180 160 140 120 0 200 400 600 ATMOS. I-=1UCHIDA ( H=91 x H=364

(1) Breaks with no entrainment resulted in significantly higher peak containment temperatures than cases with entrainment.

(2) Peak containment temperatures generally increased with break sizes for double ended ruptures.

(3) Pipe splits resulted in higher peak containment temperatures than small double-ended breaks, but were still bounded by full, double ended breaks without entrainment.

(4) Peak containment temperatures were slightly higher for full double ended breaks at 30%, 70%,'and 102% power than at hot zero power, but the magnitude of this difference was less than 120F.

Based upon these observations, the mass and energy release provided by Exxon is very reasonable for worst case conditions. The resulting component surface temperatures may be non-conservative by a few degrees F

due to the larger amount of energy available at the higher power levels; however, the long-term equilibrium temperature is very conservative as a result of increasing the auxiliary feedwater temperature to the initial

.primary side temperature, and continuing this mass and energy addition until operator action is assumed at 10 minutes.

From the data presented in Figure 2, the surface temperature of the test slab in case #3 at the atmosphere temperature peak (102 sec.) is equal to 253.4 OF. If it is conservatively assumed that a 120 F

• -12 adjustment to.the atmosphere temperature peak results in a 120 F rise in the heat slab surface temperature, then the adjusted surface temperature of a conservatively modeled component becomes 253.4 + 12 = 265.40F. This value is below the equipment qualification temperature of 286 0 F. The mass and energy release rate during the long-term blowdown is conservative due to the assumed enthalpy of the auxiliary feedwater. The maximum atmosphere temperature during this time determines the maximum component temperature and does not exceed 2800F. Based upon this discussion, we can conclude that the maximum temperatures of the safety related equipment in containment following an MSLB are bounded by the EQ limit established in the LOCA analysis.

MSLB-ICA

A F F I DA V IT STATE OF WASHINGTON )

) 'ss.

COUNTY OF BENTON )

I, Richard B. Stout, being duly sworn, hereby say and depose:

1. I am Manager, Licensing and Safety Engineering, for Exxon Nuclear Company, Inc. ("ENC"), and as such I am authorized to execute this Affidavit.

2. I am familiar with ENC's detailed document control system and policies which govern the protection and control of information.

3. I am familiar with the document XN-NF-85 17(P) entitled "Analysis of the Steamline Break Event with Boron Injection Tank Removal or Dilution to Zero Concentration Boric Acid for H. B. Robinson Unit 2" referred to as "Document." Information contained in this Document has been classified by ENC as proprietary in accordance with the .control 'system and policies established by ENC for the control and protection of information.

4. The document contains information of a proprietary and confidential nature and is of the type customarily held.in confidence by ENC and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in the Document as proprietary and confidential

0 2

5.. The Document has been made available to the U.S. Nuclear Regulatory Commission in confidence, with the request that the information contained in the Document will not be disclosed or divulged.

6. The Document contains information which is vital to a competitive advantage of ENC and would be helpful to competitors of ENC when competing with ENC.

7. The information contained in the Document is considered to be proprietary by ENC because it reveals certain distinguishing aspects of the Exxon Nuclear steamline break methodology which secure competitive advantage to ENC for fuel design optimization and marketability, and includes information utilized by ENC in its business which affords ENC an opportunity to obtain a competitive advantage over its competitors who do not or may not know or use the information contained in the Document.

8. The disclosure of the proprietary information contained in the Document to a competitor would permit the competitor to reduce its expenditure of money and manpower and to improve its competitive position by giving it extremely valuable insights into the Exxon Nuclear steamline break methodology and would result in substantial harm to the competitive position of ENC.

9. The Document contains proprietary information which is held in confidence by ENC and is not available in public sources.

3

10. In accordance with ENC's policies governing the protection and control of information, proprietary information contained in the Document has been made available, on a limited basis, to others outside ENC only as required and under suitable agreement providing for non-disclosure and limited use of the information.

11. ENC policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-knoW basis.

12. This Document provides information which reveals the Exxon Nuclear steamline break methodology developed by ENC over the past several years. ENC has invested millions of dollars and many man-years of effort in developing the the Exxon Nuclear steamline break methodology revealed in the Document. Assuming a competitor had available the same background data and incentives as ENC, the competitor might, at a minimum, develop the information for the same expenditure of manpower and money as ENC.

13. Based on my experience in the industry, I do not believe that the background data and incentives of ENC's competitors are sufficiently similar to the corresponding background data and incentives of ENC to reasonably expect such competitors would be in a position to duplicate ENC's proprietary information contained in the Document.

4 THAT the statements made hereinabove are, to the best of my knowledge, information, and belief, truthful and complete.

FURTHER AFFIANT SAYETH NOT.

SWORN TO AND SUBSCRIBED before me this j day of 19 6OTARY. PUBLIC