NRC-15-0022, Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 12 Questions 4.2.2-1 and 4.2.2-2 and Set 15 Question 4.2.6-1

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Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 12 Questions 4.2.2-1 and 4.2.2-2 and Set 15 Question 4.2.6-1
ML15030A350
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 01/30/2015
From: Kaminskas V
Detroit Edison, Co, DTE Energy
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-15-0022
Download: ML15030A350 (20)
v • d • e


Text

{{#Wiki_filter:Vito A. Kaminskas Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.6515 Fax: 734.586.4172 Email: kaminskasvitdteenergy.com Proprietary Information - Withhold Under 10 CFR 2.390 10 CFR 54 January 30, 2015 NRC-15-0022 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington D C 20555-0001

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
2) DTE Electric Company Letter to NRC, "Fermi 2 License Renewal Application," NRC-14-0028, dated April 24, 2014 (ML14121A554)
3) NRC Letter, "Requests for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 12 (TAC No. MF4222),"

dated December 19, 2014 (ML14342A986)

4) NRC Letter, "Requests for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 15 (TAC No. MF4222),"

dated December 17, 2014 (ML14342A652)

5) DTE Electric Company Letter to NRC, "Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 12," NRC-15-0007, dated January 28, 2015
6) DTE Electric Company Letter to NRC, "Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 15," NRC-15-0009, dated January 15, 2015

Subject:

Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 12 Questions 4.2.2-1 and 4.2.2-2 and Set 15 Question 4.2.6-1 Enclosure 2 contains Proprietary Information - Withhold Under 10 CFR 2.390. When separated from Enclosure 2, this document is decontrolled.

USNRC NRC-15-0022 Page 2 In Reference 2, DTE Electric Company (DTE) submitted the License Renewal Application (LRA) for Fermi 2. In References 3 and 4, NRC staff requested additional information regarding the Fermi 2 LRA. The DTE responses to the requests for additional information (RAIs) except for RAIs 4.2.2-1, 4.2.2-2, and 4.2.6-1were provided in References 5 and 6. Enclosure 1 to this letter provides the DTE responses to RAIs 4.2.2-1 and 4.2.6-1. Enclosure 2 to this letter provides the DTE response to RAI 4.2.2-2. contains proprietary information as defined by 10 CFR 2.390. General Electric - Hitachi (GEH), as the owner of the proprietary information, has executed the affidavit in Enclosure 4, which identifies that the enclosed proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure. The proprietary information was provided to DTE in a GEH transmittal that is referenced by the affidavit. The proprietary information has been faithfully reproduced in the enclosed documentation such that the affidavit remains applicable. GEH herein requests as set forth in the enclosed Affidavit of Lisa K. Schichlein that the enclosed proprietary information be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390. A non-proprietary version of the documentation in Enclosure 2 is provided in Enclosure 3. No new commitments are being made in this submittal. Should you have any questions or require additional information, please contact Lynne Goodman at 734-586-1205. I declare under penalty of perjury that the foregoing is true and correct. Executed on January30, 2015 Vito A. Kaminskas Site Vice President Nuclear Generation

USNRC NRC-15-0022 Page 3

Enclosures:

1) DTE Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application - Set 12 Question 4.2.2-1 and Set 15 Question 4.2.6-1
2) Enclosure 1 to GEH Letter 318178-5, "Response to RAI 4.2.2-2" -

PROPRIETARY

3) Enclosure 2 to GEH Letter 318178-5, "Response to RAI 4.2.2-2" -

NON-PROPRIETARY

4) GE-Hitachi Nuclear Energy Americas LLC Affidavit for Enclosure 1 of 318178-5 cc w/ all

Enclosures:

NRC Project Manager NRC License Renewal Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III cc w/o Enclosure 2: Michigan Public Service Commission, Regulated Energy Division (kindschl@michigan.gov)

Enclosure 1 to NRC-15-0022 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 DTE Response to NRC Request for Additional Information for the Review of the Fermi 2 License Renewal Application 

  - Set 12 Question 4.2.2-1 and Set 15 Question 4.2.6-1

Enclosure 1 to NRC-15-0022 Page 1 RAI 4.2.2-1

Background

LRA Section 4.2.2 addresses the applicant'stime-limited aging analyses (TLAA) of its adjusted reference temperatures (ARTs). LRA Table 4.2-2 describes the ART values of the reactor vessel beltline materialsand other data relatedto the beltline materialsandARTs (e.g., material chemistry, chemistryfactor, 52-EFPY (effective full-power years)fluence, initialreference temperaturefor nil-ductility transition(RTNDT), and RTNDT shift). The LRA states that the ART values in LRA Table 4.2-2 are calculatedin accordancewith RG 1.99 Position 1.1 (i.e., by using the chemistryfactor tables andfluence factor describedin RG 1.99). In comparison,LRA Table 4.2-3 describes the ART values of the surveillanceplate and weld for the applicant'sreactor vessel materialsbased on the surveillance data of the Boiling Water Reactor Vessel and Internals Project(BWRVIP) IntegratedSurveillance Program(ISP). LRA Section 4.2.2 states that the representative surveillanceplate and weld materialswere evaluated for 52 EFPY in accordancewith RG 1.99 Position2.1 (surveillance data available)to generate the ART values in LRA Table 4.2-3. The LRA and onsite documentation also indicate that the reactor vessel surveillance data are described in BWRVIP-135, Revision 2, "Integrated Surveillance Program(ISP)Data Source Book and PlantEvaluations." Issue LRA Table 4.2-3 describesART values and associatedfluencesof the surveillanceplate and weld materials. However,LRA Table 4.2-3 is inconsistentwith LRA Table 4.2-2 because it does not address other relateddata (e.g., materialchemistry, chemistryfactor, initialRTNDT and RTNDT shift). The staff cannot determine the adequacy of the ARTs with insufficient datafor the surveillance materials. In addition,the LRA does not clearly address whether the ART values of the surveillance materialsare used in the other neutron embrittlement TLAAs (e.g., LRA Section 4.2.3 for pressure-temperaturelimits; Section 4.2.5for circumferentialweld inspection relief; and Section 4.2.6for axialweld failureprobability),or are providedfor information only. Re quest

1. Provide the materialchemistry, chemistryfactor, initialRTNDT, RTNDT shift and other related data for the surveillance materials in a consistentformat with LRA Table 4.2-2, orjustfy why LRA Table 4.2-3 for the surveillance materials does not contain this data.
2. As part of the response, identify the specific heat of the surveillance materialwhich was used to generate credible surveillance data, and the applicant'sreactorvessel material which is represented by the credible surveillance material.

to NRC-15-0022 Page 2

3. Clarfy whether ART values based on credible surveillance data,per RG 1.99 Position 2.1, are used as the data of limiting materialsin the other neutron embrittlement TLAAs (e.g.,

LRA Sections 4.2.3, 4.2.5 and 4.2.6). If credible surveillance data are not used, confirm whether the conclusions of these TLAAs are not affected by the use of credible ART values.

Response

1. The requested surveillance material data are provided in Table 4.2.2-la on the following page. The data are presented in a format consistent with License Renewal Application (LRA)

Table 4.2-2.

2. The specific heat and reactor vessel material information is provided in Table 4.2.2-la (and associated footnotes) on the following page.
3. ART values based on credible surveillance data per RG 1.99 Position 2.1 were used in the TLAA evaluated in LRA Section 4.2.3, "Pressure-Temperature Limits." As stated in that section, the limits are calculated using materials and fluence data, including data obtained through the Reactor Vessel Surveillance Program.

Credible surveillance data are not used in support of LRA Section 4.2.5, "Reactor Vessel Circumferential Weld Inspection Relief." The surveillance weld materials from the host reactors representing Fermi 2 in the ISP are not a match to the weld heat for RPV lower shell-to lower intermediate shell circumferential weld 1-313. Weld surveillance data were not used in the TLAA for RPV circumferential weld 1-31.3 inspection relief, as the circumferential weld is not the limiting beltline material. RPV axial welds 2-307A, B, & C are considered the limiting beltline weld material and surveillance weld materials from host reactors representing Fermi 2 in the BWRVIP ISP are a match to these welds. Credible surveillance data are available but were not used in support of LRA Section 4.2.6, "Reactor Vessel Axial Weld Failure Probability." The surveillance weld materials from the host reactors representing Fermi 2 in the ISP are a match to the weld heat for Fermi 2 RPV lower shell axial welds 2-307A, B, and C. LRA Table 4.2-7, Effects of Irradiation on Fermi 2 Reactor Vessel Axial Weld Properties, will be revised to reflect ISP weld data. The material chemistry, adjusted chemistry factor, and initial RTNDT in Table 4.2.2-lb of this response were obtained from the adjusted reference temperature (ART) data presented in the LRA. The fluence in Table 4.2.2-lb is different than the fluence in the original LRA Table 4.2-7 because it was revised to be the applicable neutron fluence at these axial welds. The adjusted reference temperature using Fermi 2 weld data is 49°F. However, when using the ISP data, the adjusted reference temperature is 102°F. Both are less than the bounding 114°F shown in the NRC SER for BWRVIP-74 (based on a calculation performed to identify the mean RTNDT value required to provide a result which closely matches the RPV failure frequency of 5E-6 per reactor-year). The LRA will be revised to reflect this response as indicated on subsequent pages. to NRC-15-0022 Page 3 Table 4.2.2-1a Fermi 2 Beltline ART Values for 52 EFPY - ISP Chemistry Initial %T 52 52 52 Component Heat or Heat/Lot %C o~u %Ni 

                                   /o1       Ctr (F)o      AdjustedRNT Aduse      RTNDT       F Fluence   EFPY       c3;   G    0Margin F    EFPY Shf      EFPY AR Heat/Lot{(CF)                                CF [1]     (°F)      (n/cm 2) ARTNDT                    ((F)    Shift     ART (OF)                            ( F)      ( F)

Integrated Surveillance Program (ISP) [2] BWRVIP-135 R2 Plate [3] C4114-2 0.12 0.7 84.5 -- -12 9.90E+17 35 0 17 34 69 57 CE-2 Weld [4] (1325, 0.21 0.86 207 351 -44 6.51E+17 118 0 28 28 146 102 12008) [1] Adjusted Chemistry Factor (CF) calculated per RG 1.99 Position 2.1. [2] Procedures defined in RG 1.99 are applied to determine the ART considering the Integrated Surveillance Program. [3] The ISP plate is not the identical heat and is presented using the ISP chemistry and CF applied to the limiting Fermi 2 plate, which is (Heat C4568-2) fluence and initial RTNDT. ISP indicates that C4554-1 is also a limiting plate; however due to the reduced fluence at the lower shell, this material is no longer limiting. [4] The ISP weld is the identical heat and is presented using the ISP chemistry and adjusted CF with the vessel weld Initial RTNDT and fluence. 6a is presented as calculated, but is multiplied by 0.5 for the margin calculation as defined in RG 1.99, Position 2.1. to NRC-15-0022 Page 4 Table 4.2.2-1b Effects of Irradiation on Fermi 2 Reactor Vessel Axial Weld Properties Fermi 2 Data for Weld Data for ISP Weld CE-2 Parameter Description Tandem 13253, 12008, 1092 Lot 3833 (WM) (13253, 12008) Neutron Fluence, 1E+19 n/cm 2 Weld copper content, % 0.26 0.21 Weld nickel content, % 0.87 0.86 Weld chemistry factor (CF) 224 207 Adjusted chemistry factor -- 351 Initial (unirradiated) reference temperature -44 -44 (RTNDT), °F Increase in reference 93 146 temperature (ARTNDT), °F Mean adjusted reference temperature (ART), °F 49 102 (RTNDT + ARTNDT) LRA Revisions: LRA Table 4.2-7 and Section 4.2.6 are revised to reflect ART based on ISP data (102°F) for the lower shell axial weld. LRA Appendix C Applicant Action Item 12 regarding BWRVIP-74-A is revised to reflect a corrected ART based on Fermi 2 data (49°F) and ART based on ISP data (102°F) for the lower shell axial weld. These revisions are shown on the following pages. Additions are shown in underline and deletions are shown in strike-through. to NRC-15-0022 Page 5 4.2.6 Reactor Vessel Axial Weld Failure Probability The NRC SER for BWRVIP-74-A evaluated the failure frequency of axially oriented welds in BWR reactor vessels. Applicants for license renewal must evaluate axially oriented RPV welds to show that their failure frequency remains below the value calculated in the BWRVIP-74 SER. The SER states that an acceptable way to do this is to show that the mean RTNDT of the limiting axial beltline weld at the end of the period of extended operation is less than the values specified in the SER. Table 4.2-7 compares the Fermi 2 reactor vessel limiting axial weld parameters to those used in the NRC analysis documented in BWRVIP-74. This table uses surface (OT) fluence rather than %T fluence and no margin for RTNDT. Table 4.2-7 Effects of Irradiation on Fermi 2 Reactor Vessel Axial Weld Properties Fermi 2 Data for Weld Daa ol P "et Parameter Description Tandem 13253, 12008 ._2...,325-1092 Lot 3833 12A Neutron fluence, (0) 1E+19 n/cm 2 q-24 0_1 1 1 Weld copper content, % 0.26 01 Weld nickel content, % 0.87 .06 Weld chemistry factor (CF) 224 20 Initial (unirradiated) reference temperature 44 (RTNDT), "F Increase in reference temperature (ARTNDT), 

 *F  [ARTNDT =   CF x f(o.28-0.10lo09              _     _>_

Mean adjusted reference temperature (ART), f6 49 102 

 *F (RTNDT + ARTNDT                                                   _

The projected 52 EFPY Fermi 2 mean ART (6C 49*F) anjo ivd mwec!A ( 0 2 *E)_ae less than the bounding 114*F shown in the NRC SER for BWRVIP-74 (based on a calculation performed to identify the mean RTNDT value required to provide a result which closely matches the RPV failure frequency of 5E-6 per reactor-year). The reactor vessel axial weld TLAA has been projected to the end of the period of extended operation in accordance with 10 CFR 54.21(c)(1)(ii). to NRC-15-0022 Page 6 Appendix C Response to BWRVIP Applicant Action Items Action Item Description Response BWRVIP-74-A (12) As indicated inthe staff's March 7, The projected 52 EFPY Fermi 2 mean 2000, letter to Carl Terry, an LR ART (6 19*F) angj eL mean applicant shall monitor axial beltline / ILji *F);reis-ess than the weld embrittlement. One acceptable bounding 1144F shown inthe NRC method is to determine that the mean SER for BWRVIP-74 (based on a RTNDT of the limiting axial beltline weld calculation performed to identify the at the end of the period of extended mean RTNDT value required to provide operation is less than the values a result which closely matches the specified in Table 1 of this FSER. RPV failure frequency of 5E-6 per reactor-year). This analysis has been projected through the period of extended operation in accordance with 10 CFR 54.21(c)(1)(ii) as discussed in LRA Section 4.2.6.

Enclosure 1 to NRC-15-0022 Page 7 RAI 4.2.6-1

Background:

LRA Section 4.2.6 andLRA Table 4.2-7 provide the applicant'sTLAA on mean RTvDT for nil-ductility transition)for the limiting axial welds in the beltline of the RP V, as projected to the end of the periodof extended operation (i.e., 52 EFPY). LRA Section B.1.38 provides the applicant'sReactor Vessel Surveillance Program. The LRA indicatesthat the AMP is based on implementation of the ISP that has been approvedby the staff in EPRI BWRVIP TR No. BWRVIP-86-A, Revision 1. The applicant'sAMP relies on the surveillance data obtainedfrom specific RPV surveillance materials in other reactors (i.e., ISP host reactors)that are representativeof the base metal and weld materials in the Fermi 2 RPV Issue: LRA Table 4.2-7 does not include a mean RTNDT analysisfor RPV lower shell axial welds 2-307A, B, an[d] C (Tandem HeatNo. 13253/12008) that is based on the ISP surveillance data for these weld components and is calculated,in part,using Section 5.2 of TR No. BWRVIP-86-A, Revision 1, for the CF andA RTNDT values used in the mean RTNDT analysis. Request: Clarify whether the surveillance weld materialsfrom the host reactorsrepresentingFermi 2 in the BWR VIP ISP match the weld heatfor RPV lower shell axialwelds 2-307A, B, and C (Tandem HeatNo. 13253/12008). If so, provide the CF value for these welds using applicable surveillance datafrom the integratedreactor vessel surveillanceprogramand mean RTNDT value for these welds using this CF value. If the surveillance weld materialsfrom the host reactorsdo not match the heatfor RPV axial welds 2-307A, B, and C, clarify how the ISP surveillance weld datafrom the host reactorssupportsthe adequacy of the predictedARTNDT value used in the mean RTNDT calculationfor RPV axial welds 2-307A, B, and C.

Response

The surveillance weld materials from the host reactors representing Fermi 2 in the ISP are a match to the weld heat for Fermi 2 RPV lower shell axial welds 2-307A, B, and C. License Renewal Application (LRA) Table 4.2-7, Effects of Irradiation on Fermi 2 Reactor Vessel Axial Weld Properties, will be revised to reflect ISP weld data. The material chemistry, adjusted chemistry factor, and initial RTNDT in Table 4.2.2-lb of the response to RAI 4.2.2-1 (included in this letter) were obtained from the adjusted reference temperature (ART) data presented in the LRA. When using the ISP data, the adjusted reference temperature is 102°F. However, this remains less than the bounding 11 4°F shown in the NRC SER for BWRVIP-74 (based on a calculation performed to identify the mean RTNDT value required to provide a result which closely matches the RPV failure frequency of 5E-6 per reactor-year). LRA Section 4.2.6 and to NRC-15-0022 Page 8 LRA Table 4.2-7 are revised as shown in the response to RAI 4.2.2-1 (included in this letter) to reflect ISP data for the lower shell axial weld. LRA Revisions: LRA Section 4.2.6 and LRA Table 4.2-7 are revised as shown in the response to RAI 4.2.2-1.

Enclosure 3 to NRC-15-0022 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 to GEH Letter 318178-5, "Response to RAI 4.2.2-2" - NON-PROPRIETARY

ENCLOSURE 2 318178-5 Response to RAI 4.2.2-2 Non-Proprietary Information - Class I (Public) INFORMATION NOTICE This is a non-proprietary version of Enclosure 1 of 318178-5, which has the proprietary information removed. Portions of the document that have been removed are indicated by white space inside open and closed bracket as shown here [[ ]

Enclosure 2 Non-Proprietary Information - Class I (Public) 318178-5 Page 1 of 1 RAI 4.2.2-2

Background:

LRA Table 4.2-2 describes the ARTs of the reactor vessel beltline components and other data related to the ARTs (e.g., material chemistry, chemistry factor, 52-EFPY fluence, RTNDT, and RTNDT shift). LRA Section 4.2.1 indicates that N16 water level instrumentation nozzles are reactor vessel beltline components because the peak fluence for these nozzles is 3.77x1017 n/cm2 (E > 1 MeV) at 52 EFPY, exceeding the threshold fluence of 10' n/cm2 for beltline components. Issue: LRA Table 4.2-2 does not describe the ART and other related data of the N16 nozzles which are reactor beltline components. The staff cannot determine the adequacy of the ART calculations due to the omission of ART data on the N16 instrumentation nozzles. Request: Provide the ART and other related data of N16 nozzles in a format consistent with the other beltline components described in LRA Table 4.2-2. GEH Response The following table contains GEH proprietary information: Table 4.2-2 Fermi 2 Beltline ART Values for 52 EFPY-Plant Specific Chemistries 52 EFPY 52 EFPY 53 EFPY IF HEATOR INITIAL 1/4T COMPONENT HEATO %CU %Ni CF RTNDT FLUENCE a1 6a MARGIN *F SHIFT ART [HEAT/LOT n/cm2 ARTNDT *F _F *F NOZZLES N16 (Water Level Instrumentation) [[ 136 30 2.47E+17 27 0 13 27 53 83 [2] N16 (Water Level Instrumentation) ]] 136 30 2.47E+17 27 0 13 27 53 83 [2] N16 Weld Inconel[1] [1] Non-ferritic materials such as Inconel do not require fracture toughness evaluation. [2] Insufficient information is available to determine the copper and nickel content for this nozzle; [[ 1

Enclosure 4 to NRC-15-0022 Fermi 2 NRC Docket No. 50-341 Operating License No. NPF-43 GE-Hitachi Nuclear Energy Americas LLC Affidavit for Enclosure 1 of 318178-5

ENCLOSURE 3 318178-5 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 I of GEH letter 318178-5, "Proprietary Review of Fermi 2 License Renewal Application RAI 4.2.2-2," dated January 9, 2015. The GEH proprietary information in Enclosure 1, which is entitled "Response to RAI 4.2.2-2," is identified by a dotted underline inside double square brackets. [[This sentence is an example.{)]] In each case, the superscript notation f 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.

(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 Affidavit for 318178-5 Page 1 of 3

GE-Hitachi Nuclear Energy Americas LLC 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 details on the GEH methodology for determining beltline adjusted reference temperatures for plant-specific chemistries for boiling water reactors (BWRs). Development of these methods, techniques, and information and their application for the design, modification, and analyses methodologies and processes was achieved at a significant cost to GEH. The development of the evaluation processes along with the interpretation and application of the analytical results is derived from the extensive experience databases that constitute a major GEH asset. (9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GEH's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods. The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GEH. The precise value of the expertise to 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 Affidavit for 318178-5 Page 2 of 3

GE-Hitachi Nuclear Energy Americas LLC own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions. The value of this information to GEH would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools. I declare under penalty of perjury that the foregoing affidavit it true and correct. Executed on this 9th day of January 2015. Lisa K. Schichlein Senior Project Manager, NPP/Services Licensing Regulatory Affairs GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Road, M/C A-65 Wilmington, NC 28401 Lisa.Schichlein@ge.com Affidavit for 318178-5 Page 3 of 3}}

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