GO2-24-036, Presentation Information for Pre-Application Meeting Regarding Columbia’S Replacement Steam Dryer Evaluation Approach for Extended Power Uprate
| ML24071A206 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 03/11/2024 |
| From: | Dunham Z Energy Northwest |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML24071A205 | List: |
| References | |
| GO2-24-036 | |
| Download: ML24071A206 (1) | |
Text
Withhold under 10 CFR 2.390 - Attachment Contains Proprietary Information When Attachment 1 is Removed From This Letter, the Letter is Uncontrolled.
Zachary K. Dunham Columbia Generating Station P.O. Box 968, PE20 Richland, WA 99352-0968 Ph. 509.377.4735 zkdunham@energy-northwest.com GO2-24-036 10 CFR 2.390 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 PRESENTATION INFORMATION FOR PRE-APPLICATION MEETING REGARDING COLUMBIAS REPLACEMENT STEAM DRYER EVALUATION APPROACH FOR EXTENDED POWER UPRATE
Dear Sir or Madam:
A meeting between Energy Northwest (EN) and the U.S. Nuclear Regulatory Commission (NRC) is scheduled for April 17, 2024, to discuss Columbias replacement steam dryer evaluation approach for extended power uprate.
This letter formally transmits ENs presentation to the NRC staff in advance of the meeting.
No new commitments are being made by this letter or its attachments.
Executed this ______ day of ___________, 2024.
Respectfully, Zachary K. Dunham Manager, Regulatory Affairs :
EN Pre-Application Meeting Presentation (Proprietary Version) :
EN Pre-Application Meeting Presentation (Public Version) :
Affidavit cc:
NRC RIV Regional Administrator (w/o attachments)
NRC Senior Resident Inspector (w/o attachments)
NRC NRR Project Manager (w/o attachments)
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March 11, 2024 ENERGY NORTHWEST r-:: DocuSigned by:
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GO2-24-036 PRESENTATION INFORMATION FOR PRE-APPLICATION MEETING REGARDING COLUMBIAS REPLACEMENT STEAM DRYER EVALUATION APPROACH FOR EXTENDED POWER UPRATE NON-PROPRIETARY VERSION
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008N3729 R0 - CGS RSD 1 Non-Proprietary Information GE HITACHI 008N3729 Rev. 0 March 4, 2024 GEH Non-Proprietary Information - Public Copyright 2024 GE-Hitachi Nuclear Energy Americas LLC All Rights Reserved Columbia Replacement Steam Dryer Evaluation Approach for EPU Program USNRC - CGS - GEH Technical Discussion Presentation Slides Columbia Generating Station - Energy Northwest Co 1m ia Ge eratiing Stat o - E ergy ort west Col umb 1 a e1 I ac -
ea1 I
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-Va u tio p o c o EP Pro a S
C - CGS - G -
echn ca sc ss o e e1ntat o S 1ides ENERGY NORTHWEST
- GE VERNOVA
008N3729 R0 - CGS RSD 2 Non-Proprietary Information GE HITACHI Columbia Replacement Steam Dryer Information Notice INFORMATION NOTICE This is a non-proprietary version of the document 008N3729 Revision 0, 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 (( )).
IMPORTANT NOTICE REGARDING CONTENTS OF THIS REPORT Please Read Carefully The design contained in the contract between CGS and GE, engineering, and other information contained in this document are furnished for the purpose of supporting Energy Northwest Columbia Generating Station (CGS)
Nuclear Plant EPU project in proceedings before the U.S. Nuclear Regulatory Commission. The only undertakings of GEH with respect to the information in this document are H, and nothing contained in this document shall be construed as changing the contract. The use of this information by anyone other than CGS, or for any purpose other than that for which it is furnished by GEH is not authorized; and with respect to any unauthorized use, GEH makes no representation or warranty, express or implied, and assumes no liability as to the completeness, accuracy, or usefulness of the information contained in this document, or that its use may not infringe privately owned rights.
ENERGY NORTHWEST
- GE VERNOVA
008N3729 R0 - CGS RSD 3 Non-Proprietary Information GE HITACHI Columbia Replacement Steam Dryer Content
- 1. Introduction 1.1 Introduction / Objective 1.2 Acronym List 1.3 Overview
- 2. GEH Steam Dryers and Columbia OEM/RSD 2.1 OEM Steam Dryers EPU History 2.2 BWR/3 QC/D Steam Dryer EPU History 2.3 Steam Dryer EPU Impact and RG 1.20 CVAP 2.4 Replacement Steam Dryer Design Improvements 2.5 Columbia Steam Dryer: OEM vs. Production RSD Design 2.6 Columbia Plant vs. Prototype RSD Plants: Plant Operating Conditions 2.7 Steam Dryer FIV Loads Discussion 2.8 Columbia RSD Evaluation Approach vs. NRC RG 1.20 CVAP Discussion 2.9 ASME Stress Qualification 2.10 Risks and Mitigations 2.11 Steam Dryer Inspections 2.12 Summary
- 3. EPU License Amendment Documentation
- 4. Backup Slides
- Replacement Steam Dryer Design Improvements
- Steam Dryer FIV Loads Discussion ENERGY NORTHWEST
- GE VERNOVA
008N3729 R0 - CGS RSD 4 Non-Proprietary Information GE HITACHI Columbia Replacement Steam Dryer 1.1 Introduction / Objective
Background:
General Electric Boiling Water Reactor (BWR)/5 Mark II Containment Licensed Thermal Power History:
Original Licensed Thermal Power (OLTP):
3323 MWt (1983)
3486 MWt (1995)
Current Licensed Thermal Power (CLTP) MUR: 3544 MWt (2017)
Meeting Objective:
Present Columbia Replacement Steam Dryer EPU Evaluation Approach Overall Project Objective:
Implement Extended Power Uprate (EPU) Program
- Includes installation of a Replacement Steam Dryer (RSD)
Proposed EPU: 3988 MWt (120% OLTP, 112.5% CLTP)
Columbia Generating Station Nuclear Plant:
Steam Dryer within RPV Replacement Seam Dryer Columbia Generating Station The steam dryer is a nonsafety-related component and performs no active safety function; however, the steam dryer must maintain structural integrity during normal, transient and accident conditions and not generate loose parts that may interfere with the operation of safety systems.
ENERGY NORTHWEST
- GE VERNOVA
008N3729 R0 - CGS RSD 5 Non-Proprietary Information GE HITACHI Columbia Replacement Steam Dryer 1.2 Acronym List ASME American Society of Mechanical Engineers BWR Boiling Water Reactor CGS Columbia Generating Station CLTP Current Licensed Thermal Power CVAP Comprehensive Vibration Assessment Program EPU Extended Power Uprate FE Finite Element FEM Finite Element Model FIV Flow Induced Vibration GEH General Electric - Hitachi LAR License Amendment Request MSL Main Steam Line MUR Measurement Uncertainty Recovery MWt Megawatts Thermal NRC Nuclear Regulatory Commission OEM Original Equipment Manufacturer OLTP Original Licensed Thermal Power PLTP Previous Licensed Thermal Power PSD Power Spectral Density RG Regulatory Guide RSD Replacement Steam Dryer SD Steam Dryer SG Strain Gage SRV Safety Relief Valve VPF Vane Passing Frequency ENERGY NORTHWEST
- GE VERNOVA
008N3729 R0 - CGS RSD 6 Non-Proprietary Information GE HITACHI Columbia Replacement Steam Dryer 1.3 Overview Energy Northwest will be implementing EPU at Columbia Generating Station (CGS) in the near future, which will require a Replacement Steam Dryer.
CGS will install a GEH RSD when implementing EPU.
((
))
((
))
ENERGY NORTHWEST
- GE VERNOVA
008N3729 R0 - CGS RSD 7 Non-Proprietary Information GE HITACHI Columbia Replacement Steam Dryer 2.1 OEM Steam Dryer EPU History Overview of Fleet OEM Steam Dryers Operating at EPU (without RSD):
BWR Type RPV Size SD Hood Design EPU Approval Year EPU: % OLTP BWR/3 205
((
1998
- 106% OLTP BWR/4 218 1998 EPU / 2003 MUR 113.4 / 115% OLTP BWR/4 183 2001 (shut down 2020) 120% OLTP BWR/4 218 2002 120% OLTP BWR/6 218 2002 112% OLTP BWR/6 218 2002 120% OLTP BWR/6 238 2002 120% OLTP BWR/4 205 2006 (shut down 2014) 120% OLTP BWR/5 201 2007 120% OLTP BWR/4 251 2008 118.5% OLTP BWR/5 251
))
2011 120% OLTP
((
))
- 2013: 120% OLTP with RSD ENERGY NORTHWEST
- GE VERNOVA
008N3729 R0 - CGS RSD 8 Non-Proprietary Information GE HITACHI Columbia Replacement Steam Dryer 2.2 BWR/3 Quad Cities/Dresden Steam Dryer History Overview of BWR/3 QC 1/2 & Dresden 2/3 OEM Steam Dryer EPU Experience:
BWR/3 QC/Dresden OEM steam dryers operated at OLTP for ~30 years with no structural issues.
Steam dryer structural integrity and fatigue failure concerns for EPU projects are a result of the QC/Dresden steam dryer failures that occurred at EPU.
The QC/Dresden EPU steam dryer failures ((( )))
had three causal factors:
((
))
The BWR/4-6 OEM designs are structurally more robust.
(( ))
(( ))
(( )) SD PLTP and EPU Measured PSD Loads (Outer Hood Location)
ENERGY NORTHWEST
- GE VERNOVA
008N3729 R0 - CGS RSD 9 Non-Proprietary Information GE HITACHI Columbia Replacement Steam Dryer 2.3 Steam Dryer EPU Impact and RG 1.20 CVAP After the Quad Cities/Dresden steam dryer failures, the EPU projects for the rest of the fleet have been ((
))
The NRC has recommended that the EPU fatigue analysis results show a factor of 2.0 margin to the ASME fatigue limit. The factor of 2.0 margin was included primarily to address lack of benchmarking in indirect acoustic load measurement techniques.
((
))
As the steam dryer analysis methodologies have matured and have been benchmarked against on-dryer measurements, ((
))
The previous GEH RSDs (((
))) were ((
)) with Full CVAP performed.
ENERGY NORTHWEST
- GE VERNOVA U.S. NUCLEAR REGULATORY COMMISSION OFFK:E OF NUCLEAR REGULATORY RESEARCH REGULATORY GUIDE REGULATORY GUIDE 1.20
{Dlall-uwd*OO.I.UJ.~Ju/f10!5J FeoNal\\'2017 *-*
COMPREHENSIVE VIBRATION ASSESSMENT PROGRAM FOR REACTOR INTERNALS DURING PREOPERATIONAL AND STARTUP TESTING
008N3729 R0 - CGS RSD 10 Non-Proprietary Information GE HITACHI Columbia Replacement Steam Dryer 2.4 Replacement Steam Dryer Design Improvements In order to maintain the structural integrity at the EPU loading conditions, GEH RSD design uses:
((
))
Refer to backup slides for more details on steam dryer design improvements.
(( )) RSD As a result, the (( )) RSD design is significantly more robust than the original Columbia steam dryer.
Design improvements address all locations experiencing fatigue cracking in fleet OEM steam dryers
(( )) RSD ENERGY NORTHWEST
- GE VERNOVA
008N3729 R0 - CGS RSD 11 Non-Proprietary Information GE HITACHI Columbia Replacement Steam Dryer 2.4 Replacement Steam Dryer Design Improvements (continued)
The GEH RSD design has been refined over multiple design iterations and has been demonstrated to have adequate fatigue margin under a variety of acoustic loading conditions:
All RSDs qualified through vibration design/test/inspection program for prototype steam dryers as laid out in RG 1.20 R4 Appendix A (Rev. 4 captures the experience and lessons learned from these prototype programs).
((
))
Lessons learned from operating experience of each prototype RSD were factored into subsequent RSD designs.
((
))
((
))
((
))
((
))
((
))
ENERGY NORTHWEST
- GE VERNOVA
008N3729 R0 - CGS RSD 12 Non-Proprietary Information GE HITACHI Columbia Replacement Steam Dryer 2.5 Columbia Steam Dryer: OEM vs. Production RSD Design: Geometric Comparison
(( )) RSD Component Columbia OEM SD
(( ))
RSD RPV SD Support Brackets Number
((
RPV SD Support Brackets Locations Support Ring - Inner / Outer Diameter Bottom of Skirt Ring to Top of Support Ring Bank Height Bank to Bank Spacing Center Bank to Center Bank Spacing Base Plate Width - Mid, Outer / Center Hood Entrance (Opening)
Skirt - Inner / Outer Diameter Skirt Ring - Inner / Outer Diameter Hoods - Outer Hoods - Inner & Mid Cover Plates Base Plate Bank Top Caps Inlet End Plates - Outer / Inner Bank End Plates - Outer / Inner Outlet End Plates - Outer / Inner / Middle Hood Supports Trough Thin / Thick Sections Skirt / Drain Channel Panels Lifting Rods Diameter / Collars Thickness Support Ring - Height x Width Skirt Ring - Height x Width Dryer Approximative Weight
))
Columbia production RSD will be based on the ((
))
Columbia RSD would be the same in overall dimensions / shape to
(( ))
The RSD (( )) than Columbia OEM SD.
((
))
The ((
)) RSD design is significantly more robust than the OEM SD it replaces.
Columbia OEM SD ENERGY NORTHWEST
- GE VERNOVA
008N3729 R0 - CGS RSD 13 Non-Proprietary Information GE HITACHI Columbia Replacement Steam Dryer 2.6 Columbia Plant vs. Prototype RSD Plants: Plant Operating Conditions Compared Item
(( )) EPU
(( ))
(( ))
(( )) EPU Columbia EPU Rated Core Thermal Power [MWt]
2957 3952 3952 4408 3988 Thermal Power: % of OLTP 118%
120%
120%
115%
120%
EPU Approval Year 2001 2008 2017 2012
((
))
Comparison of Plant Operating Conditions: Prototype RSD Plants vs. Columbia Plant The above comparisons support the design basis discussion of ((
))
FIV and acoustic loads are ((
))
ENERGY NORTHWEST
- GE VERNOVA
008N3729 R0 - CGS RSD 14 Non-Proprietary Information GE HITACHI Columbia Replacement Steam Dryer 2.7 Steam Dryer FIV Loads Discussion GEH RSDs were designed to support different types of loading, including:
((
))
Refer to backup slides on how the ((
))
((
))
RSD EPU Projected PSD Loads Comparison:((
))
ENERGY NORTHWEST
- GE VERNOVA
008N3729 R0 - CGS RSD 15 Non-Proprietary Information GE HITACHI Columbia Replacement Steam Dryer 2.7 Steam Dryer FIV Loads Discussion (continued)
Columbia Expected FIV Loads -versus-Prototype RSD Loads Overall similarity ((
))
The range of acoustic and FIV load ((
))
Columbia (( )) RSD will have (( ))
ENERGY NORTHWEST
- GE VERNOVA
008N3729 R0 - CGS RSD 16 Non-Proprietary Information GE HITACHI Columbia Replacement Steam Dryer 2.8 Columbia RSD Evaluation Approach vs. NRC RG 1.20 CVAP Discussion RG 1.20 CVAP Appendix A - Steam Dryer Prototype:
(1) a comprehensive vibration and stress analysis program, (2) an extensive vibration measurement program, and (3) a full inspection program.
Previous GEH Replacement Steam Dryers (( ))
o Although the Steam Dryers are non-safety-related components, the structural integrity qualifications of GEH Replacement Steam Dryers (RSD) in the previous EPU programs followed RG 1.20 guidelines (( )) and implemented the above full CVAP.
o On previous GEH EPU RSD projects, the NRC has been recommending analysis, instrumentation, and inspections.
o The (( )) RSDs were retrofit after the EPUs were licensed and implemented for these plants and the original dryers ((
))
o The ((
)) RSDs performed predictive structural analyses based on plant-specific measurements (RG 1.20) as part of the EPU license submittal.
o The previous GEH RSDs have met the key RG 1.20 standards:
o Successful CVAP including analysis, extensive measurement, full inspection, and no adverse vibration effects.
o No evidence of loose parts, cracking, unacceptable motion, or significant wear following the inspection program.
o Therefore, the previous GEH RSDs are now ((
))
Columbia GEH Replacement Steam Dryer ((
))
o Given:
o The significant structural margin improvements achieved with the prototype RSD design and testing iterations.
o The variety of EPU plant loads included in the prototype RSD development basis.
o The successful validation of GEH acoustic and stress analysis methodologies used to develop the RSDs.
o The years of successful operating history at EPU for both the OEM and replacement steam dryers o
((
))
o Using the categorization defined in Reg Guide 1.20:
o Previous curved hood RSDs (( ))
o Columbia GEH Replacement Steam Dryer design ((
))
008N3729 R0 - CGS RSD 17 Non-Proprietary Information GE HITACHI Columbia Replacement Steam Dryer 2.9 ASME Stress Qualification The (( )) RSD is significantly stronger than the OEM SD and ((
))
Columbia plant-specific RSD ((
))
ENERGY NORTHWEST
- GE VERNOVA
008N3729 R0 - CGS RSD 18 Non-Proprietary Information GE HITACHI Columbia Replacement Steam Dryer 2.10 Risks and Mitigations Risks:
((
))
Risks Mitigation:
The previous RSD were designed ((
))
RSD design analysis methodology included ((
))
((
))
ENERGY NORTHWEST
- GE VERNOVA
008N3729 R0 - CGS RSD 19 Non-Proprietary Information GE HITACHI Columbia Replacement Steam Dryer 2.11 Steam Dryer Inspections The steam dryer inspection plan for Columbia RSD will be:
((
))
While fatigue cracking ((
))
ENERGY NORTHWEST
- GE VERNOVA
008N3729 R0 - CGS RSD 20 Non-Proprietary Information GE HITACHI Columbia Replacement Steam Dryer 2.12 Summary FIV/acoustic loading ((
))
The (( )) OEM dryer ((
))
The OEM dryer experience at EPU for the rest of the fleet has been satisfactory.
The prototype RSD design has gone through (( ))
Lessons learned/design improvements have been incorporated in each design iteration.
The prototype RSDs have been ((
))
The prototype RSDs have been ((
))
GEH Production RSD ((
))
ENERGY NORTHWEST
- GE VERNOVA
008N3729 R0 - CGS RSD 21 Non-Proprietary Information GE HITACHI Columbia Replacement Steam Dryer 3.1 EPU License Amendment Documentation Documentation:
EPU Licensing Documentation for Prototype RSD Plants Prototype RSD licensing documentation submitted for NRC review/approval consisted of:
((
))
EPU Licensing Documentation for Columbia
(( )) RSD licensing documentation will be included ((
))
ENERGY NORTHWEST
- GE VERNOVA
008N3729 R0 - CGS RSD 22 Non-Proprietary Information GE HITACHI Columbia Replacement Steam Dryer USNRC - CGS - GEH Technical Discussion Thank You !
Columbia Generating Station - Energy Northwest Replacement Steam Dryer Evaluation Approach EPU Program USNRC - CGS - GEH Technical Discussion Presentation Slides Columbia Generating Station - Energy Northwest Rep aceme Ste,am Dryer va at* on Ap1p,roac IEP
!Program USNRC - CGS - GEH Technical Discussion Presentation Slides ENERGY NORTHWEST
- GE VERNOVA
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GE-Hitachi Nuclear Energy Americas, LLC 008N3729 Revision 0 Affidavit Page 1 of 3 AFFIDAVIT I, Lisa K. Schichlein, state as follows:
(1) I am a Senior Licensing Engineer, 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 GEH proprietary presentation 008N3729 Revision 0, Columbia Replacement Steam Dryer Evaluation Approach for EPU Program, dated March 4, 2024. GEH proprietary information in 008N3729 Revision 0 is identified by a dotted underline inside double square brackets. ((This sentence is an example{3})). All images and figures are GEH proprietary information in their entirety and have no proprietary markings. 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. §552(b)(4), and the Trade Secrets Act, 18 U.S.C.
§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 a license from GEHA constitutes a competitive economic advantage over other companies;
- b.
Information that, if used by a competitor, would reduce its expenditure of resources or improve its 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.
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GE-Hitachi Nuclear Energy Americas, LLC 008N3729 Revision 0 Affidavit Page 2 of 3 (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 for proprietary or confidentiality agreements or both 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 and/or confidentiality agreements.
(8) The information identified in paragraph (2) is classified as proprietary because it contains the detailed GEH methodology for analyses of the GEH Boiling Water Reactor (BWR) steam dryer. These methods, techniques, and data along with their application to the design, modification, and analyses 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.
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GE-Hitachi Nuclear Energy Americas, LLC 008N3729 Revision 0 Affidavit Page 3 of 3 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 there 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 5th day of March 2024.
Lisa K. Schichlein Senior Licensing Engineer GE-Hitachi Nuclear Energy Americas, LLC 3901 Castle Hayne Road Wilmington, NC 28401 lisa.schichlein@ge.com
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