RS-13-050, Additional Information Supporting License Amendment Request to Revise Technical Specification 2.1.1.2 for Minimum Critical Power Ratio Safety Limit - Cycle 15
| ML130510727 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 02/20/2013 |
| From: | Gullott D Exelon Generation Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML130510729 | List: |
| References | |
| RS-13-050, TAC ME9769 | |
| Download: ML130510727 (10) | |
Text
1 4300 4300Winfield Winfield Road Road Warrenville, Warrenville, IL 60555 IL 60555 Exelon Generation Exeton Generation@, 630 630 657 657 2000 2000 Office Office Proprietary Information -- Withhold from Public Public Disclosure Under 10 10 CFR 2.390 RS-13-050 10 CFR 50.90 50.90 February 20, 2013 U. S.
S. Nuclear NuclearRegulatory Regulatory Commission Commission ATIN: Document Control ATTN: Control Desk Washington, DC Washington, 20555-001 DC 20555-001 LaSalle County Station, Unit Unit 22 Facility Operating License No. No. NPF-18 NPF-18 NRC Docket No. 50-374 50-374
Subject:
Additional InformationSupporting Additional Information SupportingLicense License Amendment Amendment Request Request to to Revise Revise Technical Specification 2.1.1.2 2.1.1.2 for for Minimum Critical Power Minimum Critical Power Ratio Safety Safety Limit Limit --
LaSalle County Station, Unit Unit 2, Cycle Cycle 15 15
References:
Letter from
- 1) Letter from D. D. M.
M. Gullott Gullott(Exelon (Exelon Generation Generation Company, LLC) LLC) to u. U. S. Nuclear Nuclear Regulatory Regulatory Commission, Commission, "Request "Request toto Revise Revise Technical Specification 2.1.1.2 2.1.1.2for for Minimum Critical Minimum CriticalPower PowerRatioRatio Safety Safety Limit Limit-- LaSalle County County Station, Station,Unit Unit2,2, 15," dated Cycle 15, II dated October October 11, 11, 2012
- 2) Letter Letter from from D. D. M.
M. Gullott Gullott(Exelon (Exelon Generation Generation Company, LLC) LLC) to u. U. S. Nuclear Regulatory Commission, "Response Regulatory "Responseto toRequest Requestfor forAdditional AdditionalInformation Information Supporting License Supporting License Amendment Amendment Request Request to Revise Revise Technical Technical Specification Specification 2.1.1.2 for 2.1.1.2 for Minimum Critical Power Minimum Critical Power Ratio Ratio Safety Safety Limit Limit -- LaSalle LaSalle CountyCounty Station, Station, Unit Unit 2, 2, Cycle Cycle 15,"
15," dated dated January January 17, 2013 2013 Email from
- 3) Email from N. N.J.J. DiFrancesco DiFrancesco (U. (U. S. Nuclear Regulatory Commission)
Commission) to to L. A.
L. A.Simpson Simpson (Exelon (Exelon Generation Generation Company, LLC), LLC), "February 14, 2013, Request for Request for Additional Information RE:
Additional Information RE: NRC NRC Review Review of of the the LaSalle LaSalleUnitUnit 22 SLMCPR Change SLMCPR Change (TAC(TAC NO.NO. ME9769),"
ME9769),"dateddated February 14, 2013 2013 In Reference In Reference 1, Exelon Exelon Generation Company, LLC, (EGC)submitted LLC, (EGC) submittedaa license license amendment amendment request proposing request proposing toto revise revisethe thesafety safetylimit limitminimum minimum critical critical power power ratio ratio (SLMCPR)
(SLMCPR) values values contained inin Technical Specifications (TS) (TS) 2.1.1, 2.1.1, "Reactor "Reactor Core CoreSLs,"
SLs, for II for LaSalle LaSalle CountyCountyStation Station (LSCS), Unit (LSCS), Unit2.2. The proposed changes changessupport supportupcoming upcomingCycleCycle15 15operation operationfor for LSCS, LSCS, Unit Unit 2.
2.
EGC supplemented EGC supplemented Reference 1 with with aa letter letter dated dated January January 17, 2013 (Reference 2). 2).
Attachment 22 contains Attachment contains Proprietary Information. Withhold Proprietary Information. Withholdfrom frompublic publicdisclosure disclosure under 10 CFR 10 CFR2.390.
2.390. When When separated separated fromfrom Attachment Attachment2,2,this this document document is decontrolled.
February 20, 2013 U. S. Nuclear Regulatory Commission U.
Page 2 Proprietary Information -- Withhold Withhold from from Public Public Disclosure Disclosure Under Under 10 10 CFR CFR 2.390 In Reference 3, the In the U.U. S.
S. Nuclear Nuclear Regulatory Regulatory Commission Commission(NRC) (NRC) requested requestedadditional additionalinformation information to complete its reviewreview of of References References 1 and 2. EGC met EGC met with with the NRC on on January 31 31 and February 11, 2013, 2013, viavia teleconference teleconference to to discuss aspects aspectsof of the the referenced referenced submittal.
submittal. The The attachments to attachments to this this submittal submittal provide provide the the requested requestedinformation.
information.
The information in in Attachment 2 contains proprietary proprietary information information as defineddefined by by 10 10 CFR CFR 2.390, 2.390, "Public inspections, IIpublic inspections, exemptions, requests requestsfor forwithholding."
withholding.1I Global Global Nuclear Nuclear Fuel Fuel (GNF),
(GNF), as as the the owner of the proprietary information, information, has has executed executedthe theenclosed enclosedaffidavit affidavit(Attachment (Attachment4), 4),which which identifies that identifies that the the proprietary proprietary information informationhas has been handled handled and andclassified classified as asproprietary, proprietary,isis customarily held customarily held in in confidence, confidence, and has has been beenwithheld withheldfrom from public public disclosure.
disclosure. The Theproprietary proprietary information was information was provided to Exelon Nuclear in a GNF GNF transmittal that is is referenced referencedby bythe the affidavit. The proprietary information information has been beenfaithfully faithfully reproduced reproduced in in the the attached attachedRAI RAI responses such responses such that that the the affidavit remains applicable.
affidavit remains applicable. GNF GNF hereby requests that the attached attached proprietary information be withheld from public disclosure disclosure in in accordance accordancewith withthe theprovisions provisionsofof 10 CFR 2.390 and 10 10 CFR CFR 9.17.
9.17.
A Non-Proprietary version of A of the the information information contained contained in in Attachment Attachment22isisprovided providedinin . The Theaffidavit affidavit isis provided provided in in Attachment Attachment4. 4.
EGC hashas reviewed reviewed the the information information supporting supporting aafindingfinding of of no no significant significant hazards hazardsconsideration consideration and the the environmental environmental consideration consideration that thatwerewerepreviously previouslyprovidedprovided to to the the NRC NRC inin Attachment Attachment 11 of of Reference 1. 1. The Theadditional additional information information provided in this this submittal submittal does does not affect affect the the bases bases for for concluding that concluding that the proposed license license amendment amendmentdoes doesnot notinvolve involveaasignificant significant hazards hazards consideration. In Inaddition, addition, thetheadditional additional information information provided in this submittal does not not affect affect the bases for bases for concluding concluding that neither an environmentalenvironmental impact impact statement statement nor nor anan environmental environmental assessment needs assessment needstotobe beprepared preparedininconnection connectionwith with thethe proposed proposed amendment.
amendment.
In accordance In accordance with with 1010 CFR CFR 50.91, 50.91, "Notice IINotice for for public public comment; State State consultation,"
consultation,1I paragraph paragraph(b), (b),
a copy of this this letter letter and and its attachments are are being being provided provided to to the the designated designatedState StateofofIllinois Illinois official.
There are are nono regulatory regulatory commitments commitments contained in submittal. Should you have any questions in this submittal.
concerning this concerning this letter, letter, please please contact Ms. Lisa A. A. Simpson at (630) 657-2815.
II declare declare under penalty of perjury perjury that that the the foregoing foregoing isistrue true and and correct.
correct. Executed Executed on on the the 20th 20th day day of February 2013.
of Respectfully, David M. Gullott Manager - Licensing Licensing Exelon Generation Company, LLC LLC Attachment 2 contains Attachment contains Proprietary Information. Withhold Proprietary Information. Withhold from frompublic publicdisclosure disclosure under CFR2.390.
10 CFR 2.390. When When separated from Attachment 2, from Attachment 2, this this document document is decontrolled.
February 20, 2013 U. S.
U. S. Nuclear Regulatory Commission Page 3 Proprietary Proprietary Information Information- - Withhold Withholdfrom fromPublic Public Disclosure Under 10 Disclosure Under 10 CFR CFR 2.390 2.390 Attachments:
- 1) Additional
- 1) AdditionalInformation InformationSupporting SupportingLicense LicenseAmendment Amendment Request Request to Revise Revise Technical Technical Specification Specification 2.1.1.2 for Minimum Minimum Critical CriticalPower Power Ratio Ratio Safety Safety Limit Limit-- LaSalle County Station, Unit 2, Cycle 15 15
- 2) Response Response to to NRC NRC Supplemental SupplementalRAlsRAts for for LaSalle LaSalle County County Station, Station, Unit Unit 2, Cycle Cycle 15 SLMCPR Submittal (PROPRIETARY)
(PROPRIETARY)
- 3) Response
- 3) Response to to NRC NRC Supplemental RAls for LaSalle County Station, Unit Unit 2, 2, Cycle Cycle 15 15 SLMCPR Submittal (NON-PROPRIETARY)
(NON-PROPRIETARY)
- 4) Global Nuclear Fuel Fuel Affidavit Supporting Proprietary Nature Affidavit Supporting Nature of of Information Information in in Attachment Attachment 22 cc: IllinoisEmergency Illinois Emergency Management Management Agency -- Division Division of Nuclear Safety Attachment 2 contains contains Proprietary Information. Withhold Proprietary Information. from public Withhold from public disclosure disclosure under under 10 CFR 2.390. When separated from CFR 2.390. Attachment 2, from Attachment 2, this this document is is decontrolled.
decontrolled.
ATTACHMENT ATTACHMENT 11 Additional InformationSupporting Additional Information SupportingLicenseLicense Amendment Amendment Request Request to Revise Revise Technical Specification Specification2.1.1.2 2.1.1.2forforMinimum MinimumCritical Critical Power Power RatioRatio Safety SafetyLimitLimit --
LaSalle LaSalle County Station, Unit Unit 2, 2, Cycle 15 By letters By letters to to the the U.
U. S.S. Nuclear Regulatory Commission (NRC) (NRC) dateddated October 11, 2012, and and January January 17,17, 2013, 2013, Exelon Exelon Generation Generation Company, Company, LLC, LLC, (EGC)
(EGC) submitted submitted a license amendment amendment request proposing request proposingto torevise revisethe thesafety safetylimit limitminimum minimumcriticalcritical power powerratio ratio (SLMCPR)
(SLMCPR) values values contained in in Technical Specifications Specifications (TS)(TS) 2.1.1, 2.1.1, "Reactor IIReactorCore CoreSLs,"
SLs,"forfor LaSalle LaSalle County CountyStation Station (LSCS), Unit (LSCS), Unit2.2. The proposed proposed changes changessupport supportupcoming upcomingCycle Cycle15 15operation operationfor for LSCS, LSCS, Unit Unit 2.
In In an an email email dated February February 14, 14, 2013, 2013, the theNRCNRCrequested requestedadditional additionalinformation information to to complete completethe the review.
RAI-01
Regarding the Regarding the second second question under under RAI-02. Please provide technical Please provide technicaljustification justification forfor the magnitude of magnitude of the the increase of the SLMCPR values by by 0.03 0.03andand0.05 0.05forfortwo tworecirculation recirculation looploop operation and single loop operation loop operation, operation, respectively.
respectively. What What factors factors contribute contributeto tothe the change?
change?
Response to RAI-01:RAI-01: of this this submittal submittal discusses discusses the thecontribution contribution of of the change change to to GNF2 GNF2 fuel fuel on on SLMCPR values.
SLMCPR values. In In addition addition to to the the fuel fuel related related factors, factors, another anothercontributor contributor is is the the fact fact that that the the existing Cycle existing Cycle 14 SLMCPR SLMCPR values values were developed developed by by Areva Areva using using their NRC approved methodology. The methodology. The proposed proposedSLMCPR SLMCPR valuesvaluesfor for Cycle Cycle 15 15 were were developed developed by by GNF GNF using using their their NRC NRC approved methodology. Both Bothvendors' vendors'methodologies methodologiesfor forcalculating calculating SLMCPR SLMCPR values values areare approved by by the the NRC NRC and and can canyield yield different different results.
RAI-02
Please provide Please provide evaluation evaluation or or design design documents documentswhich which demonstrate demonstratethat thatthe theconclusion conclusioninin
'GNF
'GNF Response Response to toRAI-03' RAI-03' are are applicable applicableto tothe theLaSalle LaSalleUnit Unit2,2,GNF2 GNF2fuel fuel design designwith with Areva Areva Atrium-10 fuel for the following following items:
Item 1) TGBLA fuel rod power power calculation calculation uncertainty uncertainty for ATRIUM-10, R-factor uncertainty Item 2) the R-factor uncertainty for ATRIUM-ATRIUM-10, 10, and the bundle Item 4) the bundle power poweruncertainty uncertaintyassociated associatedthe thecore coremonitoring monitoring system systemapplied appliedto to ATRIUM-10.
Response to RAI-02, Items Items 11 andand 2:
2:
The response responsetotoRAI-02, RAI-02, ItemsItems 11andand2,2,areareprovided providedininAttachment Attachment22to tothis thissubmittal.
submittal.
Response
ResponsetotoRAI-02,RAI-02,Item Item 4: 4:
The bundle bundle power power uncertainty uncertainty reflects reflects the the core core monitoring monitoring system's system's ability ability to predict the bundle power.
power. This This uncertainty uncertainty is is associated associatedwith with the thespecific specific core core monitoring monitoring system and and in-core in-core nuclear instrumentation that is in use at at the the plant.
plant. GNF GNFprovided provided EGC EGC withwith the bundle power power uncertainty value as as originally originally documented in in NEDO-10958-A NEDO-10958-A (Reference (Reference 1). 1). The The GNF GNF bundle bundle uncertainty value power uncertainty value isis identified identified asasthe the"overall "overallLPRM-extrapolated LPRM-extrapolatedTIP TIPuncertainty uncertaintyof 4.3% 11 of4.3%"
in NEDO-10958-A, NEDO-10958-A, Appendix Appendix VII, VII,page page VII-40.
VII-40. GNF requested requested that thatEGC EGCconfirm confirm the the applicability of applicability of this this uncertainty uncertainty sincesince the core monitoring monitoring system in in use useat atLSCS LSCSisisAREVA's AREV A's Page 11 of of 44
ATTACHMENT 11 ATTACHMENT Additional Information Additional InformationSupporting SupportingLicenseLicense Amendment Amendment Request to Revise Revise Technical Specification 2.1.1.2 for Minimum Critical Power Ratio Limit --
Safety Limit Ratio Safety LaSalle County Station, Unit Unit 2, Cycle 15 POWERPLEX-Ill,and POWERPLEX-III, and GNF GNF is is not not knowledgeable of of the the associated associatedPOWERPLEX-III POWERPLEX-III uncertainties.
EGC contacted AREVA,AREVA, and and AREVA AREVAprovided providedthe thebundle bundle power power uncertainty that associated that is associated with POWERPLEX-1I1.
with POWERPLEX-III. In In Topical Topical Report Report EMF-2158(P)(A)
EMF-2158(P)(A)(Reference (Reference 2), the total bundle bundle certainty is power certainty is provided provided in in Table Table 2.3, 2.3, "SPC "SPC BWR BWR Core Core Simulator Simulator Code Code Measured Power Power Distribution Uncertainty Distribution Uncertainty Verification,"
Verification,"for forRadial RadialBundle Bundle Power Power uncertainty as as applied appliedtotoC-Lattice C-Lattice plants (e.g., LaSalle).
LaSalle). By By letter letter dated dated October October 18, 18, 1999, 1999, the theNRC NRC approved approvedEMF-2158(P)
EMF-2158(P)
(Reference 3).
(Reference 3).
EGC compared the the GNF GNF and and AREVA AREVA bundle power uncertainties, uncertainties, which which involved involved aa comparison comparison of of the uncertainty value provided the one uncertainty provided by by GNF GNF to thethe one oneuncertainty uncertaintyvalue valueprovided providedby byAREVA.
AREVA.
EGC determined that the GNF bundle power uncertainty bounded EGC bounded the theAREVA AREVA bundle power uncertainty. Therefore, Therefore, for for the thedetermination determinationof ofthe theLSCS, LSCS,UnitUnit2, 2,Cycle Cycle15 15SLMCPR, SLMCPR,EGC EGC notified GNF notified GNFthat thatthe the use use ofof the the GNF GNF bundle bundle power uncertainty is appropriate and and conservative.
conservative.
References:
NEDO-10958-A, "General (1) NEDO-10958-A, "General Electric Electric BWRBWRThermal Thermal Analysis Analysis Basis Basis (GETAB):
(GETAB): Data,Data, Correlation and Design Application,"
Correlation Application," dated dated January January 31,31, 1977, 1977,ADAMS ADAMS Accession Accession Number ML102290144 ML102290144 Topical Report EMF-2158(P)A),
(2) Topical EMF-2158(P)A), Revision Revision 0, 0, "Siemens "Siemens Power Power Corporation Corporation Methodology Methodology for Boiling for Boiling Water Water Reactors:
Reactors: Evaluation Evaluationand andValidation ValidationofofCASMO-4/MICROBURN-B2,1' CASMO-4/MICROBURN-B2,1I TOPICAL TOPICALREPORT REPORT EMF-2158(P),
EMF-2158(P),dated dated October 1999 (3) Letter Letter from from S. S. Dembek Dembek (NRC) (NRC) to to J.
J. F.
F. Mallay Mallay (Siemens Power Corporation),
(Siemens Power Corporation), "Acceptance "Acceptance for for Referencing of LicensingLicensing Topical Topical Report Report EMF-2158(P),
EMF-2158(P), Revision Revision 0, 'Siemens
'Siemens Power Power Corporation Corporation Methodology Methodology for for Boiling BoilingWaterWaterReactors: Evaluation and Reactors: Evaluation and Validation Validation of of CASMO-4/Microburn-B2' (T CASMO-4/Microburn-B2' (TAC No. MA4592),
AC No. MA4592),"II dated October 18, 1999
RAI-03
In follow-up In follow-upto, to,"GNF "GNFResponse Response to to RAI-04-2,1I RAI-04-2,"pleaseplease provide provide analysis analysis which demonstrate that which demonstrate that items 1, 2, 3, and 1,2,3, and 4,4, for for ATRIUM-10 ATRIUM-10 nuclear fuel are applicable applicable and andwill will remain remain applicable applicabletoto future future cycles. Although, the cycles. Although, the licensee evaluated the expand expand application application range range change changethrough through aa evaluation based 50.59 evaluation based on a Columbia Columbia licenselicense amendment amendment approval.
approval. Please Pleaseprovide provide technical technical justification and justification and analysis analysis which whichdemonstrates demonstrates the expanded expanded application range isis appropriate application range appropriateforfor the Atrium-10 fuel for LaSalle Unit 2.
Atrium-1 0 fuel for LaSalle Unit 2. Please discuss Please discuss whether the expanded range of application expanded range of application is being being utilized utilizedforforthetheproposed proposed LaSalleLaSalle Cycle Cycle15 15core core design. Lastly, please design. Lastly, please confirm confirm that the NRC Part 21 21 Log Log No.
No. 2007-29-00 2007-29-00(ADAMS (ADAMS No. No. ML072830334)
ML072830334)regarding regardingATRIUM-10 ATRIUM-10MCPR MCPR remains dispositioned dispositioned for for LaSalle LaSalle Unit Unit 2,2, Cycle Cycle 15.
15.
Response to RAI-03:RAI-03:
The data data for GEXL97 development was generated for the GEXL97 generated by AREVA. The database consisted of of ATRIUM-10 ATRIUM- 10 sub-bundle and full full bundle bundle critical criticalpower powerdatadatagenerated generated bybythethe sub-channel sub-channel codecode XCOBRA, as as incorporated incorporated in in the NRC -approved SPCB correlation. This NRC-approved This database contains contains Page 2 of 4
ATTACHMENT 11 Additional InformationSupporting Additional Information Supporting License License Amendment Amendment Request to Revise Revise Technical Specification Specification2.1.1.2 2.1.1.2for forMinimum Minimum Critical Critical Power Ratio Safety Limit Limit --
LaSalle County Station, Unit Unit 2, Cycle 15 ATRIUM-10 ATRIUM-10fuel fuelperformance performancedata data thatthat is is dependent dependent on physical boundary conditions conditions (e.g., flow, power, pressure),
flow, power, pressure), but is independent independent of of any specific plant or core core design. The The database for database forthethedevelopment developmentofofthe theGEXL97 GEXL97correlation correlation used usedfor for LSCS, LSCS, Unit Unit 2, 2, Cycle Cycle 15 15 includes ATRIUM-10 ATRIUM-10 fuel fuel performance performance data data provided provided by by AREVA AREVA to to address address NRC NRC PartPart21 21 Log No. 2007-29-00 Log 2007-29-00 (ADAMS (ADAMS No. ML072830334)
ML072830334) regarding regardingATRIUM-10 ATRIUM-10 MCPR. MCPR.
The data collection encompasses cosine, collection encompasses cosine, top-peaked, top-peaked, bottom-peaked, bottom-peaked, and and double-humped double-humped axial power axial power shapes.
shapes. TheseThesedatadatawere weregenerated generatedtotocover coverthe the complete complete range range of of expected expected operation of the ATRIUM-1 of the ATRIUM-10 fuel.These 0 fuel. Thesedata data were were usedused to to generate generate a database databaseof ofpredicted predicted critical power critical power values for aa range rangeof of operating operatingconditions conditionscorresponding correspondingtotothe theATRIUM-10 ATRIUM-10fuel fuel performance. The TheGEXL97 GEXL97 correlation correlation used usedfor forLSCS, LSCS, Unit Unit 2,2, Cycle Cycle 15 15 uses the same functional formform as previous previous GEXL GEXL correlations correlations with with different constants constants for for the the GEXL GEXL correlation correlation coefficient parameters.
coefficient parameters. The Therange rangeofofapplication applicationofofthe theGEXL97 GEXL97 correlation correlation was was determined determinedby by the range rangeof of data datafor forATRIUM-10 ATRIUM-10 fuel provided by AREVA AREVA and and in in accordance accordance with with the the NRC-NRC-approved methodology methodology used usedby byGNFGNFfor forthe thedevelopment developmentofofaatransition transitionboilingboilingcorrelation.
correlation.
Therefore, because becausethe therange rangeofofapplicability applicability of the correlation correlation is is based on on the the range range of of data datain in the database databaseused usedto todevelop developthe thecorrelation correlation and and thethe data datain in the the database databaseisisindependent independentof of plant or core design, design, thetherange rangeofofapplicability applicability isis appropriate appropriatefor for anyanyapplication applicationwith with GNF GNF methods modeling methods modelingATRIUM-10 ATRIUM-10 fuel, including including LSCS, LSCS, Unit Unit 2.
As described described above,above, thetherevised revisedGEXL97GEXL97 correlation correlation used usedto tocalculate calculatethe theLSCS, LSCS,Unit Unit2, 2, Cycle 15 Safety SafetyLimit Limit included the the ATRIUM-10 ATRIUM-10 fuel fuel performance performance data dataprovided providedby byAREVA AREVA to to address NRC address NRC Part Part 21 21 LogLog No.No. 2007-29-00.
2007-29-00. This Thisdid did not notchange changethe theGEXL97 GEXL97 correlation correlation coefficients or additive constants, constants,but butititdid didresult resultininaaslightly slightly higher higheroveralloverall correlation correlation uncertainty relative uncertainty relative to to NEDC-33106P, NEDC-33106P,"GEXL97 "GEXL97Correlation Correlationfor forATRIUM-10 ATRIUM-10 Fuel," Fuel," Revision Revision22 (GEXL97Rev.
(GEXL97 Rev.2). 2). The pressure pressure and andR-Factor R-Factorparameters parametersused usedininthe thecalculation calculationofofthe theLSCS, LSCS, Unit 2, Unit 2, Cycle Cycle 15 SLMCPR were determined determined to to be bewithin within thetherange rangeofofapplicability applicability of of GEXL97 GEXL97 Rev.
Rev. 2. Therefore, Therefore, the theLSCS, LSCS,Unit Unit2, 2,Cycle Cycle 15 15SLMCPR SLMCPR calculation calculation did did not utilize utilize the the expanded range of of applicability identified ininIIGNF applicability identified "GNFResponse Response to RAI-04-2,"
RAI-04-2,"items items 11 and and 2. 2. Item Item 33 of of IIGNF "GNF Response Response to toRAI-04-2,"
RAI-04-2," is is aa minimum minimum allowable allowable annular annularflow flow length, length, not not implemented implemented previously in in GEXL97 GEXL97 Rev. Rev. 2.2. The The annular annularflow flow lengths lengths usedusedininthe thecritical critical power power calculations calculations for ATRIUM-10 ATRIUM-10fuel fuelassemblies assemblies in in Cycle Cycle 15 15 were were shown to be greater greater than thanthe theminimum minimum value value allowed in in GEXL97 GEXL97 Rev Rev 4. The increased
- 4. The increasedoverall overallcorrelation correlationuncertainty uncertaintyidentified identified in in item item 44 ofof "GNF Response "GNF Response to to RAI-04-2" corresponds to RAI-04-2" corresponds to the theGEXL97 GEXL97 uncertainty uncertainty including including the Part Part 21 21 ATRIUM-10 data.
ATRIUM-10 data. Therefore, the the expanded expandedrange rangeofofapplicability applicabilityidentified identified in in items items 11and and2,2, and the the restriction restriction on on annular annularflowflow length length described describedin in item item 33 of of "GNF IIGNF Response ResponsetotoRAI-04-2"RAI-04-211 were notnot utilized utilized in in the calculation of the LaSalle Unit 2 Cycle Cycle 15 SLMCPR, SLMCPR, and the uncertainty uncertainty identified in identified in item item 44 ofof "GNF "GNF Response Response to to RAI-04-2" RAI-04-2" incorporates the the NRC NRC Part Part21 21 Log Log No. No.
2007-29-00 2007 00 issue.
In letter In letter IIColumbia "Columbia Generating Generating Station - Issuance IssuanceofofAmendment AmendmentRe: Re:CoreCoreOperating OperatingLimits Limits Report and Scram Scram TimeTime Testing Testing (TAC (TAC No. No. MD9247)"
MD9247)" issued May May 5, 2009, the 5,2009, the NRC NRC reviewed reviewed NEDC-33419-P, "GEXL97 IIGEXL97 Correlation Applicable to ATRIUM-10 ATRIUM-10 Fuel," Fuel,"which which contains contains the GEXL97 correlation developed GEXL97 developed by byGNF GNFusingusingATRIUM-10 ATRIUM-10 data datacorrected correctedfor forthe theAREVA AREVAPart Part21 21 error. The NRC NRC determined determined that that the the GNF GNF method method was was aa reasonable engineering approach to to dealing with mixed core fuel fuel and and thatthatthetheuseuseofofthetheGEXL97 GEXL97correlation correlationwithin within the thelimits limits ofof the the analytical analytical database, database, as asbounded boundedby byexperimental experimentallimits limits derived derived from from actual test data data forfor the ATRIUM-10database, ATRIUM-10 database, is acceptable.
acceptable.
Page Page 33of4 of 4
ATTACHMENT 11 Additional Additional Information InformationSupporting SupportingLicense License Amendment Amendment Request to Revise Revise Technical Specification Specification2.1.1.2 2.1.1.2forforMinimum Minimum Critical Critical Power Ratio Safety Limit Limit --
LaSalle County Station, Unit Unit 2, Cycle 15 15 The same same GEXL97 GEXL97 correlation correlation documented in in NEDC-33419-P is being applied applied in in total at LaSalle for LaSalle forthe the same same intended intended use and withwith the same terms, terms, limitations conditions. The limitations and conditions. The GEXL97 correlation GEXL97 correlation used used to determine determine transition transition boiling boiling for for LSCS, LSCS, Unit Unit 2, 2, is is mathematically mathematically exactly the exactly the same GEXL97 correlation based GEXL97 correlation based on the same same AREVA AREVA data that was reviewed reviewed by the NRC NRC for for use use atat Columbia. analysis to Columbia. The analysis to demonstrate demonstratethe theapplicability applicability of of items 1, 1, 2, 3, 3, and and 44 RAI-04-2 to of RAI-04-2 to ATRIUM-10 ATRIUM-10fuel fuelare are included included in NEDC-33419-P, NEDC-33419-P, "GEXL97"GEXL97 Correlation Correlation Applicable Applicable ATRIUM-10FueLI!
to ATRIUM-10 Fuel."EGC EGCunderstands understands that that at at this this time time the the NRC NRC does does not intend to approve the use use of of the the expanded expandedranges rangesofofapplicability applicabilitydocumented documentedininNEDC-33106P, NEDC-331 06P,"GEXL97"GEXL97 Correlation for ATRIUM-10 ATRIUM-10Fuel,ll Fuel,"Revision Revision 44 for forSafety Safety Limit LimitMCPR MCPRcalculations calculations at LaSalle Station. As discussed discussed above, above,the theUnit Unit22Cycle Cycle 1515Safety SafetyLimit Limit did not utilize these expanded utilize these expanded ranges andfuture ranges and future LSCS LSCSSafety SafetyLimit Limit calculations willwill be be in compliance withwith the terms terms and and licensing conditions applicable to the correlation used.
licensing used.
Page 4 of 4
ATTACHMENT 3 Response toNRC Response to NRC Supplemental SupplementalRAIs RAlsfor forLaSalle LaSalleCounty CountyStation, Station,Unit Unit2, 2,Cycle Cycle15 15 SLMCPR Submittal (NON-PROPRIETARY) 6 pages pagesfollow follow
ENCLOSURE 2 ENCL©SURE2 CFL -EXN-HA2-13-022 CFL-EXN-HA2-13-022 Response to NRC Supplemental Supplemental RAls RAts for for LaSalle LaSalle Unit Unit22Cycle Cycle15 15 SLMCPR Submittal Information -- Class Non-Proprietary Information Class II (Public)
(Public)
INFORMATION NOTICE NOTICE This This is is aanon-proprietary non-proprietary version version ofofCFL-EXN-HA2-13-022 Enclosure1,1, which CFL-EXN-HA2-13-022 Enclosure which hashas the the proprietary removed. Portions information removed.
proprietary information of the Portions of the document that have document that have been been removed removed are are indicated indicated by by white whitespace space inside inside an an open and closed bracket as as shown shown here here ((
(( n.
)).
Non-Proprietary Information Non-Proprietary Information-- Class Class II (Public)
Enclosure to CFL -EXN-HA2-13-022 CFL-EXN-HA2-13-022
RAI-01
Regarding the second Regarding second question questionunderunderRAI-02.
RAI-02. Please Pleaseprovide providetechnical technicaljustification justificationfor for the magnitude magnitudeof of the the increase increase of SLMCPR values of the SLMCPR values by by 0.03 0.03 and and 0.05 0.05 for for two two recirculationloop recirculation loop operation operation and and single single looploop operation, operation, respectively.
respectively. What factors What factors contribute to the contribute to the change?change?.
GNF Response GNF Response to toRAI-01
RAI-01
The most significant The factors contributing significant factors contributing to to the the high SLMCPR SLMCPR for LaSalleLaSalle 22 Cycle Cycle 15 15 are are the the switch to GNF2 fuel and a flat core core power power distribution.
distribution.
Prior to Prior to Cycle Cycle 15, 15, GNF GNF last last performed performed the the safety limit analysis for limit analysis for LaSalle LaSalle 22 Cycle Cycle 11. 11. This This analysis supported analysis supported the current current Technical Technical Specification SLMCPRvalues Specification SLMCPR values of of 1.11 1.11 andand 1.12 1.12 for for TLO and TLO and SLO, SLO, respectively1.
respectively'. The The increase increaseofofthe theTechnical TechnicalSpecification Specification valuesvaluesby by0.03 0.03TLO TLO and 0.05 SLO SLO can be be understood understood by bycomparing comparing Cycles Cycles 1111 and and15, 15,since sinceboth bothutilized utilizedthetheGNF GNF approved SLMCPR methodology. Figure SLMCPR methodology. Figure 1 shows several data data points:
points: the (( ((
)); the LaSalle 2 Cycle 11 SLMCPR results; results; and the LaSalle 2 Cycle 15 SLMCPR SLMCPR results.
((
)) The calculated calculated limiting limiting TLO TLO SLMCPR (1.14) for for LaSalle LaSalle 22 Cycle Cycle15 15isiswithin within expectations expectations and andconsistent consistentwith withobserved observedtrends trendsfor forGNF2 GNF2fuelfuelwith withGETAB GETABuncertainties.
uncertainties.
The current SLMCPR difference between TLO and and SLO SLO ofof 0.02 0.02 isis consistent consistent with with ((((
)) Therefore, the calculated calculated limiting limiting SLO SLO SLMCPR SLMCPR (1.17) (1.17) for for LaSalle 2 Cycle Cycle 15 15 isiswithin within expectations expectationsand and consistent with consistent with observed observedtrends trendsforforGNF2 GNF2fuel fuelwith withGETAB GETAB uncertainties.
uncertainties.
In conclusion, In conclusion, there are two major factors that contribute contribute to the increased increased corecoreSLMCPR SLMCPR values values for both TLOTLO and SLO: SLO: 1) a flat flat core power power distribution distribution in Cycle 15 and and 2)2) the theswitch switch to toGNF2, GNF2, and both both ofof these these are arewithin within expectations.
expectations.
1 (( ))
11 of of 55
))
Non-Proprietary Information - Class I (Public)
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Non-Proprietary Information Non-Proprietary Information -- Class I (Public) to CFL-EXN-HA2-13-022
RAI-02
RAI ..02 Please provide provide evaluation evaluation or design documents documents which which demonstrate demonstrate that thatthetheconclusion conclusion in 'GNF in `GNF Response Response to RAl-03' RAI-03' are applicable applicable to the the LaSalle LaSalle Unit Unit 2, 2, GNF2 GNF2 fuel fuel design design with Areva with Areva Atrium-1 Atrium-10 fuel for the following items:
0 fuel Item 1) TGBLA Item TGBLAfuel fuel rod rod power power calculation uncertainty uncertaintyfor for ATRIUM-10, ATRIUM-1 0, Item 2)
Item 2) the R-factor uncertainty uncertainty for for ATRIUM-10, ATRIUM-10, and Item 4)
Item 4) the bundle bundle power power uncertainty uncertainty associated associated the the core coremonitoring monitoring system system applied to applied to ATRIUM-10.
ATRIUM-10.
GNF Response to RAI-02, RAI . .02, Item 1: 1:
This item This item is inin the context of the first first of the four actions in in the the safety safety evaluation evaluation for for the the approved NEDC-32601 NEDC-32601 P-A P-Aand and NEDC-32694P-A.
NEDC-32694P-A. It is stated stated as: as:
The TGBLA The TGBLA fuel fuelrod rodpower power calculational calculational uncertainty should should be beverified verified when applied to applied to fuel fuel designs designs not not included included in in the the benchmark benchmark comparisons comparisons of of Table 3.
Table 3.1 1 ofof NEDC-32601 NEDC-32601 P-A, P A, since changes in in fuel design can fuel design can have have a significant effect on calculation accuracy.accuracy.
Table 3.1 Table 3.1 inin NEDC-32601 NEDC-32601 P-A P-A summarizes summarizes the RMS RMS differences differences between between the theMCNP MCNP and TGBLA TGBLA pin pin power power comparisons comparisons for for different different configurations that that cover covereighteightdifferent different 8x8, 9x9 8x8, 9x9 and and 10x10 lattice designs.
1Ox1 0 lattice designs. The The weighted weighted average averagedifference difference is is ((
(( )).
In a similar similar manner, manner, the thepinpinpower powercomparisons comparisonsforforfive fiverepresentative representative ATRIUM-10 ATRIUM-10 lattice designs were lattice were performed performed usingusing results resultsfrom fromMCNPMCNP and andTGBLA.
TGBLA. Table TableRAI-02-01 RAI-02-01 below summarizes below summarizes the standard standard deviations deviations for for the lattices lattices ((((
)), consistent consistent with Table 3.1 with Table 3.1 in NEDC-32601 P-A. The in NEDC-32601P-A. The weighted av~rage weighted average value value for the ATRIUM-10 ATRIUM-10 lattice lattice designs designs is is (((( which is
)), which is smaller compared to smaller compared to the the (((( )) for the lattice lattice designs designs listed listed in in Table Table 3.13.1 ofof NEDC-32601 P-A.
NEDC-32601 P-A.
Therefore, Therefore, this this evaluation confirms that evaluation confirms that the the TGBLA TGBLA design design basis fuel fuel rodrod power power calculational uncertainty uncertainty of of ((
(( ))
)) is conservative conservative when whenapplied appliedtotothe theATRIUM-10 ATRIUM-10 fuel. This completes the requirements requirements for for the the first first of the four four actions actions stated in in the safety evaluation for the approved approvedNEDC-32601 NEDC-32601 P-A P-A and and NEDC-32694P-A.
33 of of 5
Non-Proprietary Information Non-Proprietary Information-- Class Class II (Public)
(Public)
Enclosure 2 to Enclosure CFL-EXN-HA2-13-022 CFL-EXN-HA2-13-022
((
((
))
]1 GNF Response GNF Response to toRAI -02, Item RAI-02, Item 2:
2:
Per Section Section 33ofofNEDC-32601P-A, NEDC-32601 P-A, GNF's GNF'sSLMCPR SLMCPR methodology methodology Licensing Licensing Topical Topical Report, Report,
((
IT ))
11 The overall overall R-factor R-factor uncertainty uncertainty calculation calculation process processisisoutlined outlinedininAppendix AppendixCCofofNNEDC-32601 EDC-32601 P-P-A.
A. ((((
4 of 5 4of5
Non-Proprietary Information -- Class Class II (Public)
(Public) to CFL-EXN-HA2-13-022
)) Therefore the the R-factor R-factor uncertainty uncertaintystill still applies and and isisapplicable applicabletotoATRIUM-10 ATRIUM-1 0 fuel fuel in in LaSalle LaSalle Unit Unit 2.
55of5 of 5
ATTACHMENT 4 Global Nuclear Fuel Fuel Affidavit Supporting Proprietary Nature Affidavit Supporting Nature of of Information Information in in Attachment Attachment 22 4 pages pagesfollow follow
ENCLOSURE 3 ENCLOSURE3 CFL-EXN-HA2-13-022 CFL-EXN-HA2-13-022 Affidavit
Global Nuclear Fuel- Americas Fuel - Americas AFFIDAVIT I, Lukas Trosman, state as follows:
(1) I am Engineering Engineering Manager, Manager, ReloadReload Design Design andand Analysis, Analysis, Global Global Nuclear Fuel --
Americas, Americas, LLC LLC (GNF-A),
(GNF-A), and have been been delegated delegated the function function of of reviewing reviewing the the information described in information described in paragraph paragraph (2) (2) which which is is sought sought to be be withheld, withheld, and and have have authorized to been authorized to apply apply for for its its withholding.
withholding.
infonnation sought to (2) The information to be withheld is contained in Enclosure I1 of ofGNF's GNF' sletter, letter, CFL-EXN-HA2-13-022, CFL-EXN-HA2-13-022, C. C. Latnb Lamb (GNF-A)
(GNF-A) to to J.J. Fisher Fisher (Exelon),
(Exelon), entitled entitled "GNF "GNF
Response
Response to to NRC NRC Supplemental Supplelnental RAIs RAIs forfor LaSalle LaSalle Unit Unit 2 CycleCycle 15 15 SLMCPR SLMCPR Submittal," February 16, 16,2013.
2013. The TheGNF-A GNF-Aproprietary proprietaryinformation informationin Enclosure1,1, inEnclosure which is entitled "Response to to NRC Supplemental Supplemental RAIs RAIs forfor LaSalle LaSalle Unit Unit 22 Cycle Cycle 1515 SLMCPR Submittal," identified by a dotted underline inside inside double double square square brackets.
brackets.
((This setecy_isLya aex1)) LargeLarge figures and and figures tablestablescontaining containingGEH GEH proprietary proprietary information information are are identified identified with double square brackets before and after after object. InIneach the object. eachcase, case,thethenotation notation13; refers refers toto Paragraph Paragraph (3) of this (3) of this affidavit, affidavit, which provides the basis for for the the proprietary proprietary determination.
determination.
(3) In making Inaking this application application for withholding withholding of of proprietary proprietary information infonnation of of which which itit isis the owner or licensee, GNF-A relies upon the the exemption exeInption from frOln disclosure disclosure set setforth forth in in the Freedom of Information the Freedom Information Act Act ("FOrA"),
("FOIA"), 5 USC USC Sec. Sec. 552(b)(4),
552(b)(4), and the the Trade Trade Act, 18 Secrets Act, 18 USC USC Sec.
Sec. 1905, 1905, and and NRC NRC regulations regulations 10 10 CFR CFR 9.17(a)(4),
- 9. 17(a)(4), andand 2.390(a)(4) secrets" (Exemption 2.390(a)(4) for "trade secrets" (Exemption 4). 4). The material for which which exemption exemption from disclosure from disclosure is here sought sought alsoalso qualify qualify under under thethe narrower narrower definition definition of of"trade "trade secret", within within the Ineanings assigned the meanings assignedtoto those those tenns terns forfor purposes purposes of of FOIA FOIA Exemption 4 in, respectively, Exemption respectively, Critical Critical Mass Energy Project v. v. Nuclear Nuclear Regulatory Regulatory Commission, 975 COlnInission, 975 F2d F2d 871 871 (DC (DC Cir.
Cir. 1992),
1992), and and Public Public Citizen CitizenHealth HealthResearch Research Group v. FDA, 704 F2d 1280 1280 (DC(DC Cir.
Cir. 1983).
1983).
Some examples (4) SOlne examples of of categories categories of of information information which which fit fit into into the the definition definition of of proprietary information information are:
are:
a.
- a. Infonnation Information that discloses aa process, that discloses method, or process, method, or apparatus, apparatus, including including supportingdata supporting data and and analyses, analyses, where where prevention preventionof of its its use by by GNF-A's GNF -A's competitors without license competitors without license from from GNF-A constitutes a competitive economic competitive economic advantage over other companies;
- b. Information which, Information which, if if used used byby a competitor, competitor, would would reduce reduce his expenditure expenditure of resources or resources or improve improve his competitive cOInpetitive position position in in the the design, design,manufacture, manufacture, shipment, installation, assurance of of quality, oror licensing licensing of ofaa similar similarproduct; product; c.
- c. Information which Information which reveals reveals aspects aspects of past, present, or future GNF-A customer- customer-funded funded development development plans plans and and programs, programs, resulting resulting in potential products in potential products to to GNF-A; CFL-EXN-HA2-I3-022 CFL-EXN-HA2-13-022 Affidavit PagePage 1 ofof 3
- d. Information Information which which discloses discloses patentable patentable subject subject matter matter forfor which which it may may be be desirable to obtain patent protection.
The information sought to be withheld withheld is is considered considered to to be be proprietary proprietary for for the the reasons reasons set forth in paragraphs (4)a. and and (4)b.
(4)b. above.
above.
(5) To address address 10 CFR 2.390 2.390 (b)
(b) (4),
(4), the the information information soughtsought to to bebe withheld withheld isis being being submitted submitted to to NRC NRC in confidence. The in confidence. The information information is is of ofaasort sortcustomarily customarily held held inin GNF-A, and is in fact so held. The confidence by GNF-A, Theinformation informationsought sought to to bebe withheld withheld has, to the best of of my lny knowledge and belief, consistently been held in confidence confidence by GNF GNF-A,-A, no public disclosure no public disclosure has has been been made, made, and and it isis notnotavailable available ininpublicpublic sources.
sources. All disclosures to third third parties parties including including any anyrequired requiredtransmittals transmittalstotoNRC, NRC, have been made, or or must must bebe made, made, pursuant pursuanttotoregulatory regulatoryprovisions provisionsororproprietary proprietary agreements which agreelnents which provide provide forfor maintenance maintenance of of the the information information in in confidence.
confidence. Its Its initial designation designation as proprietary information, as proprietary information, and and the subsequent steps the subsequent steps taken to to prevent its unauthorized prevent its disclosure,are unauthorized disclosure, are asas set set forth forth in in paragraphs paragraphs (6) (6) and and (7)(7) following.
Initial approval (6) Initial approval of proprietary proprietary treatment treatment of of aa document document is is made made by the manager of of the originating component, originating cOlnponent, the the person most likely to be acquainted with to be acquainted with the value the value and sensitivity of of the information infol1nation in in relation relation toto industry industry knowledge, knowledge, or orsubject subjectto to the the terms terms under under which which it was licensed licensed to GNF-A.
GNF-A. Access Access totosuch suchdocuments documents within within limited on a "need to know" basis.
GNF-A is lhnited basis.
(7) The procedure for approval of of external extelnal release of of such such aa document doculnent typically typically requires requires review by the staffstaff manager, project project manager, manager, principal principal scientist scientist or or other other equivalent equivalent authority, by the manager of authority, of the the cognizant cognizant marketing marketing function function (or (or his his delegate),
delegate), and and by the Legal Operation, Operation, for for technical technical content, content, competitive competitive effect, effect, andanddetermination determination of the the accuracy accuracy of ofthetheproprietary proprietary designation.
designation. Disclosures Disclosures outside outside GNF-A GNF -A are are limited to regulatory regulatory bodies, bodies, customers, custOlners, and and potential potential customers, customers, and andtheir theiragents, agents, suppliers, suppliers, and and licensees, licensees, and others with a legitimate legitimate need for for the the information, information, and and then only in then only in accordance accordance with withappropriate appropriate regulatory regulatory provisions provisions or orproprietary proprietary agreements.
agreelnents.
The information (8) The information identified identified in paragraph (2) is is classified classified as as proprietary proprietary becausebecause itit contains details of GNF-A's GNF-A's fuel fuel design designand andlicensing licensingmethodology.
methodology. The development of of this methodology, along along with with the the testing, testing,development developmentand andapproval approval was achieved at a significant significant cost cost toto GNF-A.
GNF -A.
The development of The development fuel design of the fuel design and and licensing licensing methodology methodology along along withwith thethe interpretation and interpretation and application application of the analytical results is derived derived fromfrom an an extensive extensive experience database that constitutes aa major major GNF-A GNF-A asset.asset.
(9) Public disclosure (9) Public disclosure of of the the information infol1nation sought sought to to be withheld withheld is is likely likely totocausecause substantial harm substantial harm to to GNF-A's GNF -A's competitive cOlnpetitive position position and foreclose foreclose or or reduce reduce the the availability of availability of profit-making profit-making opportunities.
opportunities. The information is The information part of is part of GNF-A's GNF-A's comprehensive BWR safety and technology base, cOlnprehensive base, and and itsits commercial commercial value value extends extends beyond beyond the original original development developlnent cost. cost. The value of The value of thethe technology technology base base goes goes beyond beyond the extensive extensive physical physical database database and and analytical analytical methodology Inethodology and and includes includes CFL-EXN-HA2-13-022 Affidavit Page 22 of of33
development development of the expertise of the expertise toto determine detennine and and apply apply thetheappropriate appropriate evaluation evaluation process. In process. In addition, addition, thethe technology technology base base includes includes thethe value value derived derived from from providing providing analyses done with with NRC-approved NRC-approved methods.
methods.
research, development, engineering, analytical, and NRC review costs comprise The research, substantial investment a substantial investment of of time and money by GNF-A.
The precise The precise value value of the the expertise expertise to devise devise an an evaluation evaluation process process and and apply apply the the correct analytical correct analytical methodology methodology is difficult difficult to to quantify, quantify, butbut itit clearly clearlyisissubstantial.
substantial.
GNF-A's competitive GNF-A's competitive advantage advantagewill will be be lost lost if its its competitors competitors are are able able to use use the the results of the GNF-A results GNF -A experience experience to normalize nonnalize or or verify their their own process process or or ififthey they are able are able to claim claim an an equivalent equivalent understanding understanding by by demonstrating demonstrating that that they they can can arrive arrive at the at the Salne same or similar conclusions.
The value The value ofofthisthisinformation GNF-A would be infonnation to GNF-A lost ififthe be lost theinformation infonnation werewere disclosed to the the public.
public. Making such information infonnation available competitors without available to competitors their their having undertake a similar required to undertake having been required similar expenditure expenditure of ofresources resources would would unfairly provide unfairly provide competitors with a windfall, and and deprive GNF-AGNF-A of the opportunity to exercise its to exercise its competitive advantage to cOlnpetitive advantage to seek an an adequate adequate return return on large on its large investment in developing and obtaining these very velY valuable analytical tools.
I declare declare under penalty of perjury under penalty perjury that that the foregoing affidavit the foregoing affidavit and and the the matters matters stated stated are true therein are trueand andcorrect correcttotothe thebest bestofofIny my knowledge, knowledge, information, infonnation, and belief.
th Executed on this 16 16`h dayof day of February February 2013.
Lukas Trosman Engineering Manager, Manager, Reload Reload Design and Analysis Analysis Global Nuclear Fuel-Americas, LLC LLC CFL-EXN-HA2-13-022 Affidavit Page Affidavit Page 33 of of33