ML24254A360

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Pre-Submittal Slides for License Amendment Request, Criticality Safety Analysis, Technical Specification 4.3.1, Criticality and Technical Specification 5.5.14, Spent Fuel Storage Rack Neutron Absorber Monitoring Program
ML24254A360
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 09/10/2024
From: Hardy J
Entergy Operations
To:
Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML24254A359 List:
References
GNRO2024-00031
Download: ML24254A360 (1)
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Text

Proprietary Information - Withhold From Public Disclosure Under 1 O CFR 2.390 The Balance Of This Letter May Be Considered Non-Proprietary Upon Removal Of Enclosure 4

Jeffery A. Hardy

~ entergy Manager Regulatory Assurance Grand Gulf Nuclear Station Tel: 802-380-5124

GNRO2024-00031

September 10, 2024

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

Grand Gulf Nuclear Station, Unit 1, Pre-Submittal Slides for License Amendment Request, Criticality Safety Analysis, Technical Specification 4.3.1, Criticality and Technical Specification 5.5.14, Spent Fuel Storage Rack Neutron Absorber Monitoring Program

Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

Pursuant to the provisions Section 50.90 of Title 1 O Code of Federal Regulations (CFR),

Entergy Operations, lnc. (Entergy) is planning a license amendment to the Grand Gulf Nuclear Station, Unit 1 (GGNS ). The proposed amendment includes, 1) a revision to the criticality safety analysis for the spent fuel storage racks, 2) addition of requirements for the analysis for the fuel pool storage racks as contained in TS 4.3, Fuel Storage; Subpart 4.3.1, Criticality, and 3) addition of the requirements for monitoring of the neutron absorber material in the storage racks in TS 5.5, Programs and Manuals, New-Subpart 5.5.14, Spent Fuel Storage Rack Neutron Absorber Monitoring Program.

Entergy has requested a Pre-Submittal meeting the week of September 16, 2024. To support the meeting, Entergy is providing as enclosures to this letter its presentation for this meeting.

Enclosures 1 and 2 are non-proprietary. Enclosure 4 is proprietary and Entergy requests it to be withheld from public disclosure in accordance with 1 O CFR 2.390 of the Commission's regulations.

To support withholding the slides in Enclosure 4 from public disclosure, Enclosure 3 provides an affidavit, signed by Lisa K. Schichlein. The affidavit sets forth the basis by which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390 of the Commission's regulations.

GNRO2024-00031 Page 2 of 2

This letter contains no new regulatory commitments.

Should you have any questions or require additional information, please contact me at (802) 380-5124.

RZlilY2

JAH/ram

Enclosure:

1. Entergy Pre-Submittal Call Slides (Non-Proprietary)
2. GNF Pre-Submittal Call Slides (Non-Proprietary)
3. GNF Affidavit
4. GNF Pre-Submittal Call Slides (Proprietary)

cc : NRC Region IV Regional Administrator NRC Senior Resident Inspector - Grand Gulf Nuclear Station NRC Project Manager - Grand Gulf Nuclear Station State Health Officer, Mississippi Department of Health Enclosure 1 GNRO2024-00031

Entergy Pre-Submittal Call Slides (Non-Proprietary)

(19 pages below)

) entergy

GRAND GULF NUCLEAR STATION PRE-SUBMITTAL MEETING

Proposed License Amendment Request

Spent Fuel Pool and Upper Containment Pool Neutron Absorber Inserts And Criticality Safety Analysis

September 19, 2024 OPENING REMARKS/ AGENDA

Jeff Hardy Manager Regulatory Assurance Grand Gulf Nuclear Station

2 :) entergy Purpose

  • Discuss Grand Gulf Nuclear Station's plan to install NETCO SNAP-IN neutron absorber inserts into the spent fuel storage rack cells within the spent fuel pool and upper containment pool
  • Describe the methodology for a new spent fuel pool and upper containment pool criticality safety analysis, crediting the inserts and supporting the license amendment request
  • Review the proposed license changes to credit the inserts
  • Seek feedback from the NRC staff before making the submittal

3 :) entergy Agenda (Non-Proprietary Session)

Background / Objective Jeff Hardy

SNAP-IN Inserts Overview Brian Rickard

Criticality Safety Analysis Overview Christopher Kmiec

Proposed License Changes Jeff Hardy

Questions

4 E) entergy BACKGROUND/ OBJECTIVE

Jeff Hardy Manager Regulatory Assurance Grand Gulf Nuclear Station

5 :) entergy Background / Objective

  • Current GGNS spent fuel criticality safety analysis credits Boraflex neutron absorber material within the spent fuel pool and upper containment pool
  • Contracted with Curtiss-Wright Nuclear Division to design, manufacture, and install neutron absorber inserts
  • Contracted with Global Nuclear Fuel-Americas to prepare new criticality safety analysis which removes credit for Boraflex and credits inserts
  • The license renewal application commitment to Boraflex monitoring will be replaced with a Neutron Absorbing Material Monitoring Program, consistent with NEI 16-03-A

6 :) entergy SNAP-IN INSERTS OVERVIEW

Brian Rickard Engineering Supervisor Curtiss-Wright Nuclear Division (CWND)

7 :) entergy NETCO-SNAP-IN Inserts

I D D D

Ebl© I I

8 :) entergy NETCO-SNAP-IN Inserts

  • Simple design, L-shaped (chevron), full length inserts
  • Top of bent edges are "coped" to provide clearance for fuel channel spacers
  • Robust material, Rio Tinto Alcan's Boralcan TM; a metal matrix of aluminum alloy with nuclear grade B4 C
  • Similar inserts installed in BWR racks for LaSalle, Peach Bottom, Quad Cities, Fermi, and River Bend
  • Ample neutron absorption
  • Nominal 8 4 C content = 23 vol%
  • Minimum certified 8 10 areal density = 0.0141 g B 10/cm 2

9 ~ entergy NETCO-SNAP-IN Inserts

  • Monitoring program will be implemented:
  • Complies with NEI 16-03-A, Rev. 0, "Guidance for Monitoring of Fixed Neutron Absorbers in Spent Fuel Pools"
  • Includes 3 different types of test coupons installed in the spent fuel pool (general, bend, and galvanic) and examined periodically
  • Inspections may include visual, dimensional, neutron attenuation, corrosion, dependent on coupon type
  • Includes full insert in-situ and removal inspections
  • Visual for physical deformities (in-situ and removal)
  • Thickness

10 :) entergy CRITICALITY SAFETY ANALYSIS OVERVIEW

Christopher Kmiec Engineering Technical Leader GE Hitachi Nuclear Energy

11 :} entergy Criticality Safety Analysis Overview

  • Consistent with most current N RC and industry guidance
  • NEI 12-16, Rev. 4, "Guidance for Performing Criticality Analyses of Fuel Storage at Light-Water Reactor Power Plants"
  • No credit for Boraflex neutron absorber; only credit for inserts
  • Analysis performed with TGBLA06 and MCNP-0SP
  • Peak Standard Cold Core Geometry (SCCG) in-core eigenvalue (koo) criterion,
  • Established maximum cold, uncontrolled peak in-core koo of 1.29, so that kmax < 0.95 for all credible abnormal conditions, manufacturing tolerance implications, and computational uncertainties

12 :) entergy Criticality Safety Analysis Overview

  • Assessed current fuel types and all legacy fuel
  • Uniform pool loading - all fuel storage locations loaded with an insert and the bundle with the highest rack efficiency
  • Misload of fuel outside the rack was evaluated
  • Missing insert evaluated to address removal during fuel movement and during periodic removal for inspection

13 ~ entergy PROPOSED LICENSE CHANGES

Jeff Hardy Manager Regulatory Assurance Grand Gulf Nuclear Station

14 :} entergy Proposed License Changes

  • Proposed Submittal Schedule
  • Submittal of License Amendment Request in the fourth quarter 2024
  • Requested approval in the second quarter of 2026
  • Implementation time of 120 days from approval of the License Amendment or after the completion of insert installation
  • Add statement to address that neutron absorbing inserts are installed
  • Revise maximum k"° in the normal reactor core configuration at cold conditions
  • Deletion of 4.3.1.1.e and all of its sub-steps, removal of Region II spent fuel rack classification within the spent fuel pool
  • Add new section to describe the Spent Fuel Storage Rack Neutron Absorber Monitoring Program that will be implemented in accordance with NEl-16-03-A, "Guidance for Monitoring of Fixed Neutron Absorbers in Spent Fuel Pools"

15 E) entergy Proposed License Changes (Draft) 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

a. keff 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.1.2 of the UFSAR;
b. A nominal fuel assembly center to center storage spacing of 6.26 inches, with a neutron absorber insert within the storage cells, in the spent fuel storage pool and in the upper containment pool.
c. Fuel assemblies having a maximum K-infinity of 1.29 in the normal reactor core configuration at cold conditions;

16 :) entergy Proposed License Changes (Draft)

Deslgn Feacures 4.o

4.0 DESIGN FEATURES

4. 3. 1.1 (cont.inued) -H<j~

"eq-J.-e K4-S-ter--aqo-Gon -f1/4<j'u-l'i>-t--1/4<>ft

d. Fuel assemblies having a maximum nominal U-235 enrichment of 4.9 weight percent:

~,-fi.e<J h>~~aeen-t~-&1-1-<>d---a~we+ t PRJf~l

l *t.G.Fdil -Y,-,H~~

r s e t. ~., d a qa,,....a d:,:, e.11 exee_:, of 2.3:18 r"d :, o.

which ~ae a 8GF8R 10 areal deASlt:f leas nnaA J, bl~&,

  • lnala are Eie,.J.gRate,i,at:la1R Elae S13eRt: Fuel Peel Rael, EEEB Ile., a r 1 e" lier, 1 c~~ H

~ ~ I Fuel A55embly

( L Storage Location

~- Sterage ee:ls faee aa3aeeRt: t:o Reg10R II ~aRels are e1tlaer res-t e a ffGI!\\ fuel et~l+l 7 Locat.ion Phy.,,ically Blocked to Prevent

~~\\J r.he isa1 a te8 sel:.tt er a 1: e eo r. f.1(:tmreJ... t:1 Rleut, Storage a&-a-ll\\l.ft1/4ff\\Ull',--f-h-C.. ~ 1/4&--fflay---be---bl<>e-<!Gh ~.>-......>.~

£.J-,e-R"'l +/-81' I: tuel.---:t-t-0...ag-~ a ~u.r~m t., t'J ill ~' l\\jlffP 1 J i.

(continued )

3, W1e" a 4!t l ar~a ~ ef c, !:ls +/-s el a991 f. e d " " ne g1e11 II

~-£.-;>-,.,Rathe.- Re<Ji<>A Il 4u~ s::or a gi, arEa), tht ne w r\\egieR II 1u ~ arra y i s reeJdired te 1:1e b-1-00!t-cd tA t:ha sal!\\e-~-,H~at;teEB an<l-.l-l.-'--Ae-io.lffte-011.e n cat:i:Ofl us :.Ar ad3aee1H;. t'iOiJi.Gfl II 4u 4 ~teEaffP eoR-H<j-Ufi>-t:.r<>&-r GRAND GUL: 4.0 - 2 Amendment No. 4 - 0, 195

17 :} entergy Proposed License Changes (Draft) 5.5.14 Spent Fuel Storage Rack Neutron Absorber Monitoring Program This program provides controls for monitoring the condition of the neutron absorber inserts used in the high density spent fuel storage racks to verify the Boron-10 areal density is consistent with the assumptions in the spent fuel pool criticality analysis. The program shall be in accordance with NEI 16-03-A, "Guidance for Monitoring of Fixed Neutron Absorbers in Spent Fuel Pools," Revision 0, May 2017.

18 :} entergy QUESTIONS

19 :) entergy Enclosure 2 GNRO2024-00031

GNF Pre-Submittal Call Slides (Non-Proprietary)

(12 pages below)

Non-Proprietary Information

Grand Gulf Nuclear Station Spent Fuel Pool Criticality Analysis of Boraflex Storage Racks with NETCO-SNAP-IN Rack Inserts

GNi=

Global Nuclear Fuel Non-Proprietary Information Regulatory Requirements 10 CFR 50.68(b)(4)

"If credit is taken for soluble boron, the k-effective of the spent fuel storage racks loaded with fuel of the maximum fuel assembly reactivity must not exceed 0. 95, at a 95 percent probability, 95 percent confidence level, if flooded with borated water, and the k effective must remain below 1.0 (subcritical), at a 95 percent probability, 95 percent confidence level, if flooded with unborated water."

Kmax(95/95) ~ 0. 9 5 General Design Criterion 62, Appendix A to 10 CFR 50 "Criticality in the fuel storage and handling system shall be prevented by physical systems or processes, preferably by use of geometrically safe configurations."

2 GNi=

Global Nuclear Fuel Non-Proprietary Information Methodology Overview

  • Follows the process outlined in NEI 12-16 Revision 4, "Guidance for Performing Criticality Analyses of Fuel Storage at Light-Water Reactor Power Plants."
  • Peak reactivity analysis with most limiting (bounding) lattice in every usable rack cell location.
  • No credit for the 8oraflex neutron absorber (modeled as water).
  • 8-10 areal density used for rack insert analysis (0.0139 g 8-1 0/cm 2 ) is less than the certified minimum areal density.
  • Quantification of credible normal and abnormal conditions with consideration of biases, rack/fuel tolerances and computational uncertainties.
  • Covers current and legacy fuel product lines at Grand Gulf Nuclear Station.

3 GNr Global Nuclear Fuel Non-Proprietary Information Analysis Uncertainty Quantification

Derived from NEI 12-16 Equation 1.

kmax(95/95) = LikNormal + Liksias + Likuncertainty

The contribution from the biases are:

n

.1kBias = I.1kBi i=l

The contribution from the uncertainties are:

n n

.1kuncertainty = / I.1kf i + I.1ktJi i=l i=l

4 GNr Global Nuclear Fuel Non-Proprietary Information C omputer Code Calculations TG BLA06 a MCNP-05P b

  • NRG-approved lattice physics code
  • Monte Carlo N-Particle code used for in

( NEDE-30130-P-A). rack reactivity (keff) calculations.

  • TGBLA solves Two-Dimensional
  • Uses point-wise (i.e., continuous)

(2D) diffusion equations with ENDF/8-VII cross-section library, and all diffusion parameters corrected by reactions in a given cross-section transport theory to provide system evaluation are considered.

multiplication factors and perform

  • GNF has benchmarked MCNP5 with burnu p (depletion) calculations. ((
  • Uses ENDF/8-V cross-section data. )) for validation purposes
  • Performs coarse-mesh, broad using the ENDF/8-VII cross-section group, diffusion theory calculations; library.

including thermal neutron scattering

  • The critical experiment modeling results, with hy drogen using an S(a,B) light along with the calculation demonstrate water thermal scattering kernel. the associated bias and bias uncertainty a) A 95/95 bias u ncertainty is added to the fuel rack studies terms at the 95/95 confidence level using related to eigenvalue calculations performed using the NUREG/CR-6698 guidance.

TG BLA06 w hich is based on (( b) MCNP-05P is the GNF controlled production version of the Los

)) Alamos National Laboratory code MCNP5.

5 GNii=

Global Nuclear Fuel Non-Proprietary Information Usable Rack Cell Model with Inserts

((

  • No credit taken for Boraflex neutron absorber.

. ((

))

  • Stainless steel rack modeled.
  • B-10 areal density used in the rack insert model is lower than the certified minimum (95/95).

)). (( )) 6 GNi=

Global Nuclear Fuel Non-Proprietary Information Design Basis Bundle

((. ((

)) bounds current and legacy fuel types at Grand Gulf Nuclear Station.

  • Design basis bundle is selected to be the bundle with the worst rack reactivity suppression capability (i.e., highest rack efficiency) ((

))

  • The design basis bundle is used to:

Define the nominal in rack keff result.

Used for performing all biases, manufacturing tolerances, computational uncertainty calculations, and all credible abnormal/accident

)) condition calculations.

7 GNi=

Global Nuclear Fuel Non-Proprietary Information Fuel Storage Conditions Analyzed

Credible Normal Conditions Credible Abnormal Conditions

  • Storage of non-channeled
  • Dropped/Damaged assembly assemblies
  • Abnormal position of a fuel
  • Eccentric Loading assembly outside the fuel storage

. (( )) rack

  • Pool moderation temperature
  • Misplacement of fuel bundles in variation unpoisoned equipment racks next to the fuel racks
  • Dropped bundle on rack
  • Rack sliding due to seismic event
  • Loss of fuel pool cooling

8 GNii=

Global Nuclear Fuel Non-Proprietary Information Bias Cases Analyzed

Fuel Depletion Bias Normal Bias

. ((

  • No inserts on rack periphery
  • Missing rack insert
  • Fuel out of rack during normal fuel handling/inspections

))

  • Depleted with clad creep

9 GNi=

Global Nuclear Fuel Non-Proprietary Information T olerance Cases Analyzed

  • Fuel enrichment increase
  • Fuel pellet density increase
  • Gadolinia wt.% decrease
  • Rod cladding thickness increase/decrease
  • Channel thickness increase/decrease
  • Fuel pellet outer diameter increase/decrease
  • Fuel rod pin pitch increase/decrease
  • Rack wall thickness increase/decrease
  • Rack pitch increase/decrease
  • Rack insert thickness increase/decrease
  • Rack insert length decrease

10 GNii=

Global Nuclear Fuel Non-Proprietary Information Analysis Uncertainties

  • MCNP-05P critical benchmarking uncertainty with ENDF/B-VII continuous energy cross-section library
  • TGBLA06 eigenvalue uncertainty
  • MCNP-05P code statistical uncertainty for kNormal (2a)
  • Uncertainty of bias contributors
  • Uncertainty of tolerance contributors
  • Fuel depletion uncertainty

11 GNii=

Global Nuclear Fuel Non-Proprietary Information Summary

  • Consideration given to all credible abnormal conditions, manufacturing tolerance implications, and computational uncertainties in determining maximum in-rack eigenvalue.
  • The analysis resulted in a storage rack maximum keff less than the 0.95 limit from 10 CFR 50.68(b)(4) for normal and credible abnormal operation with tolerances and computational uncertainties considered.

12 GNi=

Global Nuclear Fuel Enclosure 3 GNRO2024-00031

GNF Affidavit (3 pages below)

Global Nuclear Fuel -Americas, LLC AFFIDAVIT

I, Lisa K. Schichlein, state as follows:

(I) I am a Senior Licensing Engineer, Regulatory Affairs, Global Nuclear Fuel -

Americas, LLC ("GNF"), 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 I of GNF's letter,

KGO-ENO-JB 1-24-064, Kimberly O'Connor to Jedidiah Romo (Entergy Operations, Inc.), entitled "Grand Gulf Nuclear Station Criticality Safety Analysis of Fuel Storage Racks with Inserts Presentation Slides," September 06, 2024. GNF proprietary information in Enclosure I, which is entitled "Grand Gulf Nuclear Station Spent Fuel Pool Criticality Analysis of Boratlex Storage Racks with NETCO-SNAP-IN Rack Inserts," is identified by a dotted underline inside double square brackets. (( Thi... sentence.. i... an _ exam pie. 13 1 )) Figures and large objects containing GNF proprietary information 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, GNF relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations IO CFR 9. I 7(a)(4), and 2.390(a)(4) for "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought also qualify 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 F2d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2d 1280 (DC Cir. 1983).

(4) Some examples of categories of information which 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 GNF's competitors without license from GNF constitutes a competitive economic advantage over other companies;
b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;

KGO-ENO-JB 1-24-064 Enclosure I Affidavit Page I of 3

c. Information which reveals aspects of past, present, or future GNF customer funded development plans and programs, resulting in potential products to GNF;
d. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. above.

(5) To address IO 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 GNF, 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 GNF, no public disclosure has been made, and it is not available in public sources.

All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or subject to the terms under which it was licensed to GNF.

(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, by the manager of the cognizant marketing function ( or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GNF 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 agreements.

(8) The information identified in paragraph (2), above, is classified as proprietary because it contains details of GNF's fuel design and licensing methodology. The development of this methodology, along with the testing, development and approval was achieved at a significant cost to GNF or its licensor.

The development of the fuel design and licensing methodology along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GNF asset.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNF's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GNF's comprehensive BWR safety and technology base, and its commercial value extends

KGO-ENO-JB 1-24-064 Enclosure I Affidavit Page 2 of 3 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 GNF.

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.

GNF's competitive advantage will be lost if its competitors are able to use the results of the GNF 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 GNF 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 GNF 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 September 2024.

Lisa K. Schichlein Senior Licensing Engineer Regulatory Affairs Global Nuclear Fuel - Americas, LLC 390 l Castle Hayne Road Wilmington, NC 28401 Lisa.Schichlein @ ge.com

KGO-ENO-JB 1-24-064 Enclosure l Affidavit Page 3 of 3

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