ML16019A101

MELLLA License Amendment Request - Supplement 8, Proprietary Labeling Corrections and Implementation Plan Change

ML16019A101
Person / Time
Site:	Peach Bottom
Issue date:	01/15/2016
From:	Borton K Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML16019A100	List: ML16019A101
References
TAC MF4401, TAC MF4402 GEH-PBAPS-MP-141, Rev. 1
Download: ML16019A101 (43)

Text

PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 10 CFR 50.4 10 CFR 2.390 January 15, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Unit 2 and Unit 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278

Subject:

MELLLA+ License Amendment Request - Supplement 8, Proprietary Labeling Corrections and Implementation Plan Change

References:

1. Exelon letter to the NRC, "License Amendment Request - Maximum Extended Load Line Limit Analysis Plus," dated September 4, 2014 (ADAMS Accession No. ML14247A503)

2. Exelon letter to the NRC, "MELLLA+ License Amendment Request -

Supplement 6 Response to Request for Additional Information," dated October 1, 2015 (ADAMS Accession No. ML15187A391)

3. Exelon letter to the NRC, "MELLLA+ License Amendment Request -

Supplement 4, Response to Request for Additional Information," dated July 6, 2015 (ADAMS Accession No. ML15187A391, ML15187A392)

4. NRC letter to Exelon, "Peach Bottom Atomic Power Station, Units 2 and 3

- Issuance of Amendments Re: Revise Facility Operating License and the Technical Specifications to Incorporate Administrative Changes (TAC Nos.

MF4401 and MF4402)," dated March 11, 2015 (ADAMS Accession No.

14363A227)

In accordance with 10 CFR 50.90, Exelon Generation Company, LLC (EGC) requested amendments to Facility Operating License Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS) Units 2 and 3, respectively (Reference 1). Specifically, the proposed changes would revise the Renewed Operating Licenses to allow operation in the expanded Maximum Extended Load Line Limit Analysis Plus (MELLLA+) operating domain and the use of the Detect and Suppress - Confirmation Density (DSS-CD) stability solution.

Attachment 1 contains Proprietary Information.

When separated from Attachment 1, this document is decontrolled.

U.S. Nuclear Regulatory Commission MELLLA+ License Amendment Request - Proprietary Labeling Corrections January 15, 2016 Page 2 This letter provides a correction to Supplement 6 (Reference 2). Specifically, portions of Supplement 6, Attachments 1 and 2 incorrectly identified GEH material as proprietary. As such, Attachment 1 and 2 of this letter supersede the Supplement 6 Attachments 1 and 2 in their entirety. No other changes were made to the documents.

Portions of the information provided in Attachment 1 are considered to be proprietary and are, therefore, exempt from public disclosure pursuant to 10 CFR 2.390. Attachment 2 provides a non-proprietary version. Attachment 3 contains an affidavit for withholding information executed by GE Hitachi Nuclear Energy Americas LLC (GEH). On behalf of GEH, EGC requests Attachment 1 be withheld from public disclosure in accordance with 10 CFR 2.390(b)(1 ).

In addition, this letter also modifies the PBAPS plans for implementation of the MELLLA+

amendments, and withdraws a proposed change to Technical Specifications (TS) 5.6.5 b.9. contained in Reference 1. In the cover letter of the Supplement 4 (Reference 3), EGC described plans for implementation of the MELLLA+ amendment. The following statement amends the implementation schedule: Once approved, the Unit 2 and Unit 3 amendments will be implemented within one year. The proposed change to TS 5.6.5 b.9. contained in Reference 1, that would replace the listed description of document NEDC-33075P-A with a description of NEDC-33075P-A is no longer needed since amendments 296 and 299 deleted TS 5.6.5 b.9. (Reference 4). The bases for the deletion was that the associated topical report is referenced within GESTAR II, which is included as TS 5.6.5 b, reference 1.

Since 5.6.5 b.9. has been deleted and NEDC-33075P-A is also referenced within GESTAR II, the proposed change to TS 5.6.5 b.9. is withdrawn.

There are no regulatory commitments contained in this letter.

Should you have any questions concerning this letter, please call me at (610) 765-5528.

Respectfully, Kevin F. Borton Manager, Power Uprate Licensing Exelon Generation Company, LLC Attachments:

1. Enclosure 1 - GEH-PBAPS-MP-141, Revision 1, "Response to SRXB-RAl-18 in Support of PBAPS MELLLA+ LAR" - Proprietary

2. Enclosure 1 - GEH-PBAPS-MP-141, Revision 1 "Response to SRXB-RAl-18 in Support of PBAPS MELLLA+ LAR" - Non-Proprietary

3. Affidavit cc: USNRC Region I, Regional Administrator w/attachments USNRC Senior Resident Inspector, PBAPS w/attachments USNRC Project Manager, PBAPS w/attachments R. R. Janati, Commonwealth of Pennsylvania w/o proprietary attachment S. T. Gray, State of Maryland w/o proprietary attachment

Attachment 2 Peach Bottom Atomic Power Station Unit 2 and Unit 3 NRC Docket Nos. 50-277 and 50-278 GEH-PBAPS-MP-141, Revision 1, "Response to SRXB-RAl-18 in Support of PBAPS MELLLA+ LAR"- Non-Proprietary

ENCLOSURE 2 GEH-PBAPS-MP-141 Revision 1 Response to SRXB-RAI-18 in Support of PBAPS MELLLA+ LAR Non-Proprietary Information - Class I (Public)

NON-PROPRIETARY NOTICE This is a non-proprietary version of Enclosure 1 of GEH-PBAPS-MP-141 Revision 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 (( )).

Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 1 of 34 SRXB-RAI-18 The NRC staff needs to better understand the performance of TRACG beyond Nucleate Boiling (i.e., in Transition Boiling and Film Boiling). The staff has questions regarding the use of a Minimum Film Boiling Temperature (Tmin) model in TRACG as a means of predicting the transition to film boiling and determining the Transition and Film Boiling Heat Transfer Coefficient.

1) Provide TRACG turbine trip with bypass (TTWBP) and dual recirculation pump trip (2RPT) sensitivity calculations for PBAPS in which the Homogeneous Nucleation Temperature is used for Tmin; include relevant plots of results.

2) Additionally, provide TRACG sensitivity calculations with more realistic assumptions in which both the Homogenous Nucleation Temperature and the Shumway correlation (as currently implemented in TRACG) is used. Include relevant sensitivity parameters (such as, but not necessarily limited to: operator response time, Tmin model, peak cladding temperature (PCT) and/or number of assemblies that exceed 2200 °F, peaking factor and feedwater assumptions); also include relevant plots of results.

GEH Response TRACG sensitivity analyses are performed and results are provided.

The first row of Table 1 (Case RG) shows the results for the licensing case for the TTWBP anticipated transient without scram instability (ATWSI) event. ((

))

a conservative feedwater temperature reduction that decreases from the initial feedwater temperature to the condenser temperature over a 60 second time constant, a 120-second operator action time to reduce reactor water level,

((

)) and a limiting rod peaking factors where the initial condition for the limiting rod is set at 95%

of the linear heat generation rate (LHGR) limit.

Sensitivity calculations are performed with changes to these parameters, and results are shown in Table 1 and in Figures 2 through 8.

The first row of Table 2 (Case RG) shows the results for the licensing case for the recirculation pump trip (RPT) ATWSI event. ((

))

a 60-second operator action time to initiate manual scram (and recognize failure to scram),

a 120-second operator action time to reduce reactor water level, Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 2 of 34

(( )) and a limiting rod peaking factors where the initial condition for the limiting rod is set at 95%

of the LHGR limit.

Sensitivity calculations are performed with changes to these parameters, and results are shown in Table 2 and in Figures 9 through 15.

For the TTWBP analysis, an expected feedwater temperature response is used in the sensitivity analysis. This nominal response is based on Peach Bottom Atomic Power Station (PBAPS) simulator data and decreases at a much slower rate. It also includes some added conservatism by assuming a constant feedwater temperature for 20 seconds, then a linear decrease of 1.5°F/sec to the condenser temperature. Both feedwater temperature profiles used in the analysis are shown in Figure 1.

The homogeneous nucleation Tmin model is estimated to result in Tmin values that are conservatively low compared to the modified Shumway Tmin correlation. This Tmin correlation is used in the sensitivity analysis. This correlation, as applied in TRACG, is defined in Section 6.6.7 of the TRACG Model Description (Reference 1). The equation is:

where Tc is the critical temperature for water (647 K). ((

))

For the TTWBP event, the operator action time to reduce water level is assumed to be either 90, 120 (licensing value), or 200 seconds.

For the RPT event, the operator action time to manually scram the reactor is assumed to be either 30 or 60 seconds (licensing value). The operator action time to reduce water level is either 120 (licensing value) or 200 seconds. Table 2 only shows the summation of these operator action times since it is only the combination of the two that is important in the TRACG analysis.

The rod-to-rod peaking factors are increased in all analyses. For the licensing case, the initial LHGR peaking is increased to 95% of the limit (( )). This is the only value assumed in the TTWBP sensitivity analysis. In some RPT analyses, the initial LHGR peaking is increased to the maximum core value corresponding to the peak hot excess exposure and peaked power shape associated with the event (( )).

The effect of the sensitivity cases on the output parameters of interest is consistent with the expected effect of the changes. ((

Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 3 of 34

))

Reference

1. GE Hitachi Nuclear Energy, TRACG Model Description, NEDE-32176P, Revision 4, January 2008.

Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 4 of 34 Figure 1 - Turbine Trip Feedwater Temperature Reduction

Enclosure 2 Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 5 of 34 Table 1. TTWBP-ATWSI PCT Results Operator Transient FW Action Time Case Limiting Rod Temperature to Reduce Tmin Model PCT (K)

Figure # Peaking (kW/ft)

Response Water Level (sec)

RG. Modified 95% limit =

Licensing 120 ((

Figure 2 Shumway (( ))

RG4. Modified 95% limit =

Nominal 120 Figure 3 Shumway (( ))

RG6. Homogeneous 95% limit =

Nominal 120 Figure 4 Nucleation (( ))

RG2. Modified 95% limit =

Licensing 90 Figure 5 Shumway (( ))

RG7. Homogeneous 95% limit =

Licensing 90 Figure 6 Nucleation (( ))

RG3. Modified 95% limit =

Licensing 200 Figure 7 Shumway (( ))

RG5. Modified 95% limit =

Nominal 200 ))

Figure 8 Shumway (( ))

Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 6 of 34 Table 2. RPT-ATWSI PCT Results Operator Action Time to Reduce Water Limiting Rod Case.

Level (sec) Tmin Model Peaking PCT (K)

Figure #

(Includes time (kW/ft) for manual scram)

RG1a. Modified 95% limit =

180 ((

Figure 9 Shumway (( ))

RG4a. Homogeneous 95% limit =

180 Figure 10 Nucleation (( ))

RG2a. Modified 95% limit =

150 Figure 11 Shumway (( ))

RG5a. Homogeneous 95% limit =

150 Figure 12 Nucleation (( ))

RG8. Modified Max core value =

150 Figure 13 Shumway (( ))

RG9. Homogeneous Max core value =

150 Figure 14 Nucleation (( ))

RG3a. Modified 95% limit =

260 ))

Figure 15 Shumway (( ))

Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 7 of 34

((

))

Figure 2a - ATWSI-TTWBP Licensing FW Temperature, 120-second Operator Action to Reduce Water Level, Modified Shumway Tmin Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 8 of 34

((

))

Figure 2b - ATWSI-TTWBP Licensing FW Temperature, 120-second Operator Action to Reduce Water Level, Modified Shumway Tmin Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 9 of 34

((

))

Figure 3a - ATWSI-TTWBP Best-Estimate FW Temperature, 120-second Operator Action to Reduce Water Level, Modified Shumway Tmin Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 10 of 34

((

))

Figure 3b - ATWSI-TTWBP Best-Estimate FW Temperature, 120-second Operator Action to Reduce Water Level, Modified Shumway Tmin Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 11 of 34

((

))

Figure 4a - ATWSI-TTWBP Best-Estimate FW Temperature, 120-second Operator Action to Reduce Water Level, Homogeneous Nucleation Tmin Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 12 of 34

((

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Figure 4b - ATWSI-TTWBP Best-Estimate FW Temperature, 120-second Operator Action to Reduce Water Level, Homogeneous Nucleation Tmin Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 13 of 34

((

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Figure 5a - ATWSI-TTWBP Licensing FW Temperature, 90-second Operator Action to Reduce Water Level, Modified Shumway Tmin Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 14 of 34

((

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Figure 5b - ATWSI-TTWBP Licensing FW Temperature, 90-second Operator Action to Reduce Water Level, Modified Shumway Tmin Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 15 of 34

((

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Figure 6a - ATWSI-TTWBP Licensing FW Temperature, 90-second Operator Action to Reduce Water Level, Homogeneous Nucleation Tmin Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 16 of 34

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Figure 6b - ATWSI-TTWBP Licensing FW Temperature, 90-second Operator Action to Reduce Water Level, Homogeneous Nucleation Tmin Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 17 of 34

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Figure 7a - ATWSI-TTWBP Licensing FW Temperature, 200-second Operator Action to Reduce Water Level, Modified Shumway Tmin Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 18 of 34

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Figure 7b - ATWSI-TTWBP Licensing FW Temperature, 200-second Operator Action to Reduce Water Level, Modified Shumway Tmin Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 19 of 34

((

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Figure 8a - ATWSI-TTWBP Best-Estimate FW Temperature, 200-second Operator Action to Reduce Water Level, Modified Shumway Tmin Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 20 of 34

((

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Figure 8b - ATWSI-TTWBP Best-Estimate FW Temperature, 200-second Operator Action to Reduce Water Level, Modified Shumway Tmin Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 21 of 34

((

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Figure 9a - ATWSI-RPT 180-second Operator Action to Reduce Water Level, Modified Shumway Tmin Initial LHGR at 95% of Limit Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 22 of 34

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Figure 9b - ATWSI-RPT 180-second Operator Action to Reduce Water Level, Modified Shumway Tmin Initial LHGR at 95% of Limit Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 23 of 34

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Figure 10a - ATWSI-RPT 180-second Operator Action to Reduce Water Level, Homogeneous Nucleation Tmin Initial LHGR at 95% of Limit Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 24 of 34

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Figure 10b - ATWSI-RPT 180-second Operator Action to Reduce Water Level, Homogeneous Nucleation Tmin Initial LHGR at 95% of Limit Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 25 of 34

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Figure 11a - ATWSI-RPT 150-second Operator Action to Reduce Water Level, Modified Shumway Tmin Initial LHGR at 95% of Limit Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 26 of 34

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Figure 11b - ATWSI-RPT 150-second Operator Action to Reduce Water Level, Modified Shumway Tmin Initial LHGR at 95% of Limit Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 27 of 34

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Figure 12a - ATWSI-RPT 150-second Operator Action to Reduce Water Level, Homogeneous Nucleation Tmin Initial LHGR at 95% of Limit Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 28 of 34

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Figure 12b - ATWSI-RPT 150-second Operator Action to Reduce Water Level, Homogeneous Nucleation Tmin Initial LHGR at 95% of Limit Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 29 of 34

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Figure 13a - ATWSI-RPT 150-second Operator Action to Reduce Water Level, Modified Shumway Tmin Initial LHGR at Core Maximum Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 30 of 34

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Figure 13b - ATWSI-RPT 150-second Operator Action to Reduce Water Level, Modified Shumway Tmin Initial LHGR at Core Maximum Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 31 of 34

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Figure 14a - ATWSI-RPT 150-second Operator Action to Reduce Water Level, Homogeneous Nucleation Tmin Initial LHGR at Core Maximum Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 32 of 34

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Figure 14b - ATWSI-RPT 150-second Operator Action to Reduce Water Level, Homogeneous Nucleation Tmin Initial LHGR at Core Maximum Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 33 of 34

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Figure 15a - ATWSI-RPT 260-second Operator Action to Reduce Water Level, Modified Shumway Tmin Initial LHGR at 95% of Limit Non-Proprietary Information - Class I (Public)

GEH-PBAPS-MP-141 Revision 1 Page 34 of 34

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Figure 15b - ATWSI-RPT 260-second Operator Action to Reduce Water Level, Modified Shumway Tmin Initial LHGR at 95% of Limit

Attachment 3 Peach Bottom Atomic Power Station Unit 2 and Unit 3 NRC Docket Nos. 50-277 and 50-278 AFFIDAVIT Note contains proprietary information as defined by 10 CFR 2.390.

GEH, as the owner of the proprietary information, has executed the enclosed affidavit, which identifies that the proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure. The proprietary information has been faithfully reproduced in the attachment such that the affidavit remains applicable.

ENCLOSURE 3 GEH-PBAPS-MP-141 Revision 1 GEH Affidavit for Enclosure 1

GE-Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, Lisa K. Schichlein, state as follows:

(1) I am a Senior Project Manager, NPP/Services Licensing, Regulatory Affairs, 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, GEH-PBAPS-MP-141 Revision 1, GEH Response to PBAPS MELLLA+ RAI SRXB-RAI-18 with Revised Proprietary Markings, dated November 16, 2015. The GEH proprietary information in Enclosure 1, which is entitled Response to SRXB-RAI-18 in Support of PBAPS MELLLA+ LAR, is identified by a dotted underline inside double square brackets. ((This sentence is an example.{3})) Figures and large objects are identified with double square brackets before and after the object. In each case, the superscript notation {3} 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 Information 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 GEH-PBAPS-MP-141 Revision 1 Page 1 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.

(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 detailed results and conclusions regarding supporting evaluations of the safety-significant changes necessary to demonstrate the regulatory acceptability of the Maximum Extended Load Line Limit Analysis Plus analysis for a GEH Boiling Water Reactor (BWR). The analysis utilized analytical models and methods, including computer codes, which GEH has developed, obtained NRC approval of, and applied to perform evaluations of Maximum Extended Load Line Limit Analysis Plus for a GEH BWR.

The development of the evaluation processes along with the interpretation and application of the analytical results is derived from the extensive experience and information 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.

Affidavit for GEH-PBAPS-MP-141 Revision 1 Page 2 of 3

GE-Hitachi Nuclear Energy Americas LLC 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 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 normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to 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 is true and correct.

Executed on this 16th day of November 2015.

Lisa K. Schichlein Senior Project Manager, NPP/Services Licensing Regulatory Affairs GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Road Wilmington, NC 28401 Lisa.Schichlein@ge.com Affidavit for GEH-PBAPS-MP-141 Revision 1 Page 3 of 3