RS-25-040, Intent to Submit License Amendment to Install Numac Power Range Neturon Monitor (Prnm) System in Accordance with Interim Staff Guidance, Digital Instrumentation and Controls DI&C-ISG-06
| ML25066A103 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 03/07/2025 |
| From: | Wilson C Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML25066A102 | List: |
| References | |
| RS-25-040 | |
| Download: ML25066A103 (1) | |
Text
200 Energy Way Kennett Square, PA 19348 www.ConstellationEnergy.com contains proprietary information - Withhold from Public Disclosure under 10 CFR 2.390. When separated from Attachment 4, this document is decontrolled.
Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 RS-25-040 10 CFR 2.390 March 7, 2025 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374
Subject:
Intent to Submit License Amendment Request to Install NUMAC Power Range Neutron Monitor (PRNM) System in accordance with Interim Staff Guidance, Digital Instrumentation and Controls DI&C-ISG-06 In accordance with NRC Interim Staff Guidance, Digital Instrumentation and Controls DI&C-ISG-06, Revision 2, Constellation Energy Generation, LLC (CEG) is submitting a letter of intent to support the PRNM Pre-Application (ISG-06 Phase 0) meeting on March 18, 2025 (ADAMS ML25055A095), to discuss a planned license amendment for LaSalle to replace the existing analog PRNM system with a digital system.
This letter formally transmits presentation material to the NRC in advance of the meeting. provides the presentation material for the open (public) portion of the meeting. provides a non-proprietary redacted version of the presentation material for the closed portion of the meeting. provides an affidavit related to the proprietary material in Attachment 4. provides the proprietary presentation material for the closed portion of the meeting. contains proprietary information as defined by 10 CFR 2.390. GE-Hitachi, as the owner of the proprietary information, has executed the Attachment 3 affidavit identifying that the proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure. GE-Hitachi requests that the proprietary information in Attachment 4 be withheld from public disclosure, in accordance with the requirements of 10 CFR 2.390(a)(4), "Trade secrets and commercial or financial information obtained from a person and privileged or confidential."
Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 March 7, 2025 U.S. Nuclear Regulatory Commission Page 2 contains proprietary information - Withhold from Public Disclosure under 10 CFR 2.390. When separated from Attachment 4, this document is decontrolled.
There are no regulatory commitments contained within this letter. Should you have any questions regarding this letter, please contact Duane Avery, Regulatory Engineer, at (779) 231-6244.
Respectfully, Christopher D. Wilson Director - License Renewal Constellation Energy Generation, LLC cc:
Jack Giessner - NRC Regional Administrator - Region III (without attachments)
Jamie Benjamin - NRC Senior Resident Inspector (without attachments)
Robert Kuntz - NRC NRR Project Manager (without attachments) - CEG Pre-Application Meeting Presentation (Public, Non-Proprietary) - GE Pre-Application Meeting Presentation (Public, Non-Proprietary) - GE-Hitachi Affidavit (Public, Non-Proprietary) - GE Pre-Application Meeting Presentation (Proprietary)
Wilson, Christopher D Digitally signed by Wilson, Christopher D Date: 2025.03.07 09:34:54 -05'00'
Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 contains proprietary information - Withhold from Public Disclosure under 10 CFR 2.390. When separated from Attachment 4, this document is decontrolled.
CEG Pre-Application Meeting Presentation
LaSalle County Station Power Range Neutron Monitor (PRNM)
Amendment Request Pre-Application (Phase 0) Meeting March 18, 2025
- Introductions
- Meeting Purpose
- PRNM Overview and Benefits
- NUMAC PRNM System
- Licensing Scope and Schedule
- Summary
- Feedback / Questions Agenda 1
LaSalle PRNM Pre-Application Meeting
Introductions
2 LaSalle PRNM Pre-Application Meeting
- Brief NRC on Constellation Energy Generation, LLC (CEG) plans for Power Range Neutron Monitor (PRNM) Nuclear Measurement Analysis and Control (NUMAC) digital upgrade at LaSalle County Station, Units 1 and 2 (LaSalle)
- Describe the scope, schedule, and approach for the licensing action required for PRNM
- Receive NRC feedback on planned approach in accordance with DI&C-ISG-06 (Rev. 2) Digital Instrumentation and Controls licensing process Meeting Purpose 3
LaSalle PRNM Pre-Application Meeting
- CEG is evaluating a digital upgrade PRNM System for each Unit
- Implementation during the LaSalle refueling outages
- Unit 2 - Spring 2029
- Unit 1 - Spring 2030
- The proposed PRNM digital upgrade is to a NUMAC platform-based system
- Replaces existing analog components
- Implementation of NUMAC PRNM will:
- Improve neutron monitoring system reliability
- Improve thermal stability options, fuel operating margins, and overall efficiency of the reactor operations
- Reduce total system hardware
- Reduce operating cost by simplifying calibration and surveillance activities
- Resolves obsolescence issues of the existing system PRNM Overview and Benefits 4
LaSalle PRNM Pre-Application Meeting
- The PRNM configuration will include upgraded components
- Local Power Range Monitor (LPRM) Chassis
- Average Power Range Monitor (APRM) / Oscillation Power Range Monitor (OPRM)
Chassis with DSS-CD functions
- Rod Block Monitor (RBM) Chassis
- Control Room Operator Display Assemblies (ODAs)
PRNM Overview and Benefits (continued) 5 LaSalle PRNM Pre-Application Meeting
- LaSalle PRNM will be similar in design to the NUMAC PRNM systems at the following plants:
- Nine Mile Point, Unit 2
- Susquehanna, Units 1 and 2
- Peach Bottom, Units 1 and 2
- Limerick, Units 1 and 2
- Browns Ferry, Units 1, 2, and 3
- Columbia
- Grand Gulf
- Hope Creek
NUMAC PRNM System 6
LaSalle PRNM Pre-Application Meeting PRNM Outputs Control Room Non-Safety Systems Safety Systems RCMS (No Change)
RPS (No Change)
Data Interface to PPC (Change)
Annuciators (Change)
ODAs (Change)
Plant Process Computer (PPC)
(No Hardware Change)
Inputs to PRNM Flow Inputs (No Change)
LPRM Inputs (No Change)
RPS A Bus Power Inputs (No Change)
RPS B Bus Power Inputs (No Change)
& Flow By-Pass (Change)
RBM By-Pass
- NUMAC PRNM Licensing Topical Reports (LTRs)
- NEDC-30851P-A, Technical Specification Improvement Analysis for BWR Reactor Protection System, March 1988
- NEDC-30851P-A, Supplement 1, Technical Specification Improvement Analysis for BWR Control Rod Block Instrumentation, October 1988
- NEDE-30908, Engineering Evaluation of Average Power Range Monitor, Rod Block Monitor, Technical Specifications (ARTS) Improvement Program, April 1983
- NEDO-31960-A, BWR Owners Group Long-Term Stability Solutions Licensing Methodology and Supplement 1, November 1995
- NEDC-32410P-A, Volumes 1 & 2, NUMAC PRNM Retrofit Plus Option III Stability Trip Function, October 1995
- NEDC-32410P-A, Supplement 1, NUMAC PRNM Retrofit Plus Option III Stability Trip Function, November 1997
- NEDO-32465-A, Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology for Reload Applications, August 1996
- NEDC-33075P-A, Revision 8, GE Hitachi Boiling Water Reactor Detect and Suppress Solution - Confirmation Density, November 2013 Licensing Scope and Schedule 7
LaSalle PRNM Pre-Application Meeting
- PRNM digital upgrade LAR will conform to current guidance
- NRC guidance, Digital Instrumentation and Controls DI&C-ISG-06, Rev 2, Dec. 2018
- Tier 2 documents - accepted for use LTRs with deviations
- Deviation details to be provided during future meeting
- DI&C-ISG-06 LAR Review Process considers applications to be within one of the following three tiers of review:
- Tier 1
- Reference previously accepted Topical Report - NO
- Rely on Previous Reviews - NO
- Tier 2
- Referenced previously accepted Topical Report with exceptions - YES
- Similarities to other Plants previous approval - YES
- Tier 3
- New digital I&C platforms - NO Licensing Scope and Schedule (continued) 8 LaSalle PRNM Pre-Application Meeting
- Submittal timing
- Phase 0 Meeting March 18, 2025
- LAR and Phase 1 Submittal 2Q 2026
- Phase 2 Submittal 1Q 2028
- NRC approval will be requested for June 2028 to support the implementation schedule:
- Unit 2 Implementation 1Q 2029, Refueling Outage
- Unit 1 Implementation 1Q 2030, Refueling Outage Licensing Scope and Schedule (continued) 9 LaSalle PRNM Pre-Application Meeting
- Digital upgrade PRNM LAR for LaSalle to be submitted tentatively in 2Q2026 with approval requested in advance of the implementation schedule:
- Supports implementing in LaSalles Unit 2 - 2029 and Unit 1 - 2030 refueling outages
- Communications with NRC on LAR development status to be maintained throughout pre-submittal process
- NUMAC PRNM System is a digital upgrade, replacing existing analog components
- The upgraded NUMAC PRNM System improves the neutron monitoring system reliability Summary 10 LaSalle PRNM Pre-Application Meeting
Feedback / Questions 11 LaSalle PRNM Pre-Application Meeting
12 LaSalle PRNM Pre-Application Meeting Supplementary Information
- APRM - Average Power Range Monitor
- DI&C - Digital Instrumentation and Controls
- DSS-CD - Detect and Suppress Solution - Confirmation Density
- GE/GEH - General Electric / General Electric-Hitachi
- I&C - Instrumentation and Controls
- ISG - Interim Staff Guidance
- LAR - License Amendment Request
- LPRM - Local Power Range Monitor
- LTR - Licensing Topical Report
- NRC - U.S. Nuclear Regulatory Commission
- NUMAC - Nuclear Measurement Analysis and Control Acronym List 13 LaSalle PRNM Pre-Application Meeting
- ODA - Operator Display Assemblies
- OPRM - Oscillation Power Range Monitor
- PPC - Plant Process Computer
- PRNM - Power Range Neutron Monitor
- PS - Power Supply
- RBM - Rod Block Monitor
- RCMS - Rod Control Management System
- RPS - Reactor Protection system Acronym List (continued) 14 LaSalle PRNM Pre-Application Meeting
Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 contains proprietary information - Withhold from Public Disclosure under 10 CFR 2.390. When separated from Attachment 4, this document is decontrolled.
GE Pre-Application Meeting Presentation (Public, Non-Proprietary)
LaSalle Units 1 & 2 NUMAC PRNM System NRC Phase Zero Pre-submittal Meeting License Amendment Request for PRNM PLM Specification 009N7610 Revision 0 Non-Proprietary Information IMPORTANT NOTICE This is a non-proprietary version of Attachment 4, from which the proprietary information has been removed. Portions of the attachment that have been removed are indicated by an open and closed bracket as shown here (( )).
Non-Proprietary Information LASALLE UNITS 1 & 2 NUMAC PRNM SYSTEM NRC Phase Zero Pre-submittal Meeting License Amendment Request for PRNM PLM Specification 009N7610 Revision 0 March 18, 2025
Non-Proprietary Information 9
PRNM System Configuration (Constellation) 9 PRNM System Overview and PRNM LTR Applicability System Description & Diagrams (Constellation)
DSS-CD Stability Protection (GEH)
GEH Programmatic Enhancements NUMAC 2.0 Technology Changes 9
PRNM LAR Development per ISG-06 Compliance to Phase 1, 2 (Constellation)
Phase 1 Deliverables Phase 2 Deliverables Diversity and Defense-in-Depth (GEH)
Cyber Security (CEG) 9 Questions and Feedback Agenda
Non-Proprietary Information
- Local Power Range Monitor (LPRM)
Subsystem LPRM Detectors monitor power at specific core locations Provides local power signals used by APRM, OPRM,
& RBM
- Flow Monitor Subsystem Monitors the Drive Flow of each recirculation loop Used to adjust flow-biased setpoints Used to enable OPRM trip function
- Average Power Range Monitor (APRM) Subsystem Determines average neutron flux and thermal power based on assigned LPRMs Used to enable the OPRM trip function Provides rod withdrawal block and reactor trip
- Oscillation Power Range Monitor (OPRM) Subsystem Monitors local power levels to detect thermal-hydraulic instability (THI)
Provides reactor trip output when THI detected
- Rod Block Monitor (RBM) Subsystem Determines average local power around selected control rod Provides rod withdrawal block based on local power level PRNM Subsystems
Non-Proprietary Information Simplified Block Diagram - Existing PRM System LaSalle PRNM - Existing System Block Diagram
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Non-Proprietary Information LaSalle Planned PRNM System Configuration LaSalle PRNM - Block Diagram
((
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Non-Proprietary Information 9 Control Room Human-Machine Interface Changes APRM Operator Display Assembly (ODA) - Replaces Analog APRM Display RBM ODA - Replaces Analog LPRM Display APRM/Flow Fiber Optic Bypass Switch - Replaces Analog APRM & Flow Bypass Maintain Current Control Room Annunciation, with specific annunciator windows being re-assigned Maintain current APRM & RBM Control Panel Recorders LaSalle Planned PRNM System Configuration
Non-Proprietary Information PRNMS Subsystem Comparison Subsystem Existing PRNM System NUMAC PRNM System LPRM
- 43 LPRM strings, 172 LPRM Signals
- 43 LPRM strings, 172 LPRM Signals (No change to detector locations)
Flow
- Four flow channels, 8 Flow Transmitters
- Flow Channels A&C provide input to APRM A, C, E. Each APRM selects the low input.
- Flow Channels B&D provide input to APRM B, D, F. Each APRM selects the low input.
- Four flow channels, two loops, => 8 Flow Transmitters
- Each flow channel provides input to 1 APRM channel APRM
- 6 APRM Channels
- 21 or 22 LPRM Input Signals to each APRM channel
- LPRM Groups A, B - not used by APRM
- Eight Outputs to RPS APRM A - RPS Channel A1 APRM B - RPS Channel B1 APRM C - RPS Channel A2 APRM D - RPS Channel B2 APRM E - RPS Channel A1, A2 APRM F - RPS Channel B2, B2
- 2 Bypass switches
- 4 APRM Channels
- 43 LPRM Input Signals to each APRM channel
- All LPRM detectors used by APRM
- Eight Outputs to RPS Voter 1 - RPS Channel A1 Voter 2 - RPS Channel B1 Voter 3 - RPS Channel A2 Voter 4 - RPS Channel B2
- Each 2oo4 Voter provides outputs to RTS
- Single four-way Bypass switch OPRM
- ABB Option III
- Stability Protection: GEH DSS-CD RBM
- 2 RBM Channels
- ARTS approved but not fully implemented
- 2 RBM Channels
- ARTS fully Implemented
Non-Proprietary Information Long Term Stability Solution
- Implemented in NUMAC PRNM System
- OPRM is wholly contained in the APRM Hardware
- Many years of operational experience with both Option III and DSS-CD
- Detect and Suppress Solution - Confirmation Density (DSS-CD)
- Option III stability solution retained as defense-in-depth function
Non-Proprietary Information NUMAC System Installation Base
((
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Non-Proprietary Information PRNM Topical Report Plant Specific Action Items NEDC-32410P-A: Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC-PRNM) Retrofit Plus Option III Stability Plant Specific Action Items
- 1) ((
))
Non-Proprietary Information Deviations from the NUMAC PRNM LTR (Previously accepted for use by NRC)
LaSalle PRNM System Basis GEH Licensing Topical Report NEDC-32410P-A NUMAC-PRNM Retrofit Plus Option III Stability Trip Function GEH Option III with Detect and Suppress Solution - Confirmation Density (DSS-CD ) Stability
((
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Non-Proprietary Information Enhancements to the NUMAC PRNM LTR (Not previously evaluated by the NRC) 9 NUMAC Platform 2.0
((
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Non-Proprietary Information NUMAC PRNM Power Distribution
((
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Non-Proprietary Information NUMAC PRNM General Block Diagram
((
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Non-Proprietary Information Compliance with current guidance 9
ISG-06 Enclosure B, Phase 1, Documentation Review Constellation will provide documents listed in ISG-06 Enclosure B 9
ISG-06 Enclosure B, Phase 2, Documentation Review Constellation will provide documents listed in ISG-06 Enclosure B 9
Audit Support Additional documents will be made available for NRC audit upon request.
LAR Development ISG-06 Revision 2
Non-Proprietary Information ISG-06 Enclosure B Licensing Process - ISG-06 Guidance
Non-Proprietary Information 9 Defense-in-Depth Summary LAR Development ISG-06 (continued)
Note: Information is based on preliminary assessment Echelon LaSalle Impact PRNM System Specific Control System No new operator actions required.
Routine and just-in-time training for operators will be performed.
((
LaSalle RPS remains unchanged with this modification.
LaSallle ECCS systems remain unchanged with this modification.
Monitoring and Indication Control room indications remain available on operator display assemblies.
Non-Proprietary Information 9 Defense-in-Depth Actuation Systems LAR Development ISG-06 (continued)
Note: Information is based on preliminary assessment Actuation System LaSalle Impact PRNM System Specific RPS (Reactor Protection System)
RPS Scram on APRM trip functions Other diverse scrams inputs such as Reactor pressure, Reactor water level, IRM.
Manual Scram on loss of APRM functions
((
ARI (Alternate Rod Insertion)
ARI initiation on Reactor level and reactor pressure are not dependent on APRM, Containment Isolation Initiation on Reactor level, Reactor pressure, Drywell pressure is not dependent on APRM.
RCMS (Rod Control Management System)
APRM / RBM provide Rod Blocks to RCMS.
))
Non-Proprietary Information 9 Diversity - Applicable Events LAR Development ISG-06 (continued)
Note: Information is based on preliminary assessment Transient Condition LaSalle Current Design NUMAC PRNM Design Loss of Feedwater Heater APRM is Credited
((
Rod Withdrawal Error (RWE)
Low Power - IRM Scram with APRM Scram as backup.
(At Power) No credit for RBM in Cycle Specific analysis of RWE event(RWE delta-MCPR within acceptable limits)
Recirc Flow Control Failure with increasing Flow.
APRM High Flux Scram initiated on increasing power level.
Control Rod Drop Accident Rod Worth Monitor (RWM) enforces Banked Rod Withdrawal Sequence.
APRM is credited, IRM is not credited.
Thermal Hydraulic Instability OPRM initiated scram on increasing flux oscillations.
Turbine Trip APRM is the backup protection.
MSIV Closure APRM and Reactor pressure are credited.
))
Non-Proprietary Information LAR Development ISG-06 (continued)
((
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Non-Proprietary Information Modified PRNM P608 Arrangement
((
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Non-Proprietary Information Conceptual NUMAC 2.0 PRNM System Equipment Arrangement
((
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Non-Proprietary Information Generic Block Diagram - NUMAC APRM Channel
((
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Non-Proprietary Information Generic Block Diagram - NUMAC RBM Channel
((
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Non-Proprietary Information Reference Documents NEDE-30908P: Engineering Evaluation of Average Power Range Monitor, Rod Block Monitor, Technical Specifications (ARTS) Improvement Program NEDC-30851P-A: Technical Specification Improvement Analysis for BWR Control Rod Block Instrumentation NEDO-31960-A: BWR Owners Group Long-Term Stability Solutions Licensing Methodology, Licensing Topical Report and Supplement 1 NEDC-32410P-A: Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC-PRNM) Retrofit Plus Option III Stability Trip Function, Licensing Topical Report Volumes 1&2.
NEDC-32410P-A, Supplement 1: NUMAC PRNM Retrofit Plus Option III Stability Trip Function NEDO-32465-A: Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology for Reload Applications, Licensing Topical Report NEDO-32465-A NEDC-33075P-A: Detect and Suppress Solution - Confirmation Density (DSS-CD),
Licensing Topical Report, Rev. 8
Non-Proprietary Information
Non-Proprietary Information LASALLE UNITS 1 & 2 NUMAC PRNM SYSTEM Backup Slides to follow March 18, 2025
Non-Proprietary Information Enhancements to the NUMAC PRNM (Previously accepted for use by the NRC) 9 GEH NUMAC Programmatic Enhancements
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Non-Proprietary Information Conceptual NUMAC 2.0 PRNM System Equipment Arrangement
((
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Non-Proprietary Information Hardware Enforced Unidirectional Communications Interface
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Non-Proprietary Information APRM RBM Technical Specification Improvements Program
((
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Non-Proprietary Information
Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 contains proprietary information - Withhold from Public Disclosure under 10 CFR 2.390. When separated from Attachment 4, this document is decontrolled.
GE-Hitachi Affidavit
GE-Hitachi Nuclear Energy Americas, LLC 009N7610 Revision 0 Affidavit Page 1 of 3 AFFIDAVIT I, Lisa Schichlein, state as follows:
(1) I am a Senior Licensing Engineer, GE-Hitachi Nuclear Energy Americas, LLC (GEH), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.
(2) The information sought to be withheld is contained in GEH presentation 009N7610 Revision 0, LaSalle Units 1 & 2 NUMAC PRNM System NRC Phase Zero Pre-submittal Meeting, March 18, 2025. GEH proprietary information within the text and tables is identified by a dotted underline placed within double square brackets. ((This sentence is an example.{3})) Figures and large objects containing GEH proprietary information are identified with double square brackets before and after the object. In all cases, the superscript notation
{3} refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.
(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GEH relies upon the exemption from disclosure set forth in the Freedom of Information Act (FOIA), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC 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 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 F2.d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2.d 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 GEHs competitors without license from GEH 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;
- c. Information which reveals aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential products to GEH;
- 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 the 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to the NRC in confidence. The information is of a sort customarily held in confidence by
GE-Hitachi Nuclear Energy Americas, LLC 009N7610 Revision 0 Affidavit Page 2 of 3 GEH, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GEH, no public disclosure has been made, and it is not 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 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 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, 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 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 agreements.
(8) The information identified in paragraph (2) above, is classified as proprietary because it contains detailed GEH design specifications used in the design, analysis, and testing of PRNM systems for the GEH Boiling Water Reactor (BWR). Development of this information and its application for the design, modification, testing, and analyses methodologies and processes was achieved at a significant cost to GEH.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEHs competitive position and foreclose or reduce the availability of profit-making opportunities. The fuel design and licensing methodology is part of GEHs 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.
GEHs competitive advantage will be lost if its competitors are able to use the results of the GEH experience to normalize or verify their own process or if they are able to claim an
GE-Hitachi Nuclear Energy Americas, LLC 009N7610 Revision 0 Affidavit Page 3 of 3 equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.
The value of this information to GEH would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on this 5th day of March 2025.
Lisa Schichlein Senior Licensing Engineer GE-Hitachi Nuclear Energy Americas, LLC 3901 Castle Hayne Road Wilmington, NC 28401 lisa.schichlein@ge.com