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{{#Wiki_filter:Enclosure 1BSEP 14-0048Duke Energy Presentation  
{{#Wiki_filter:Enclosure 1 BSEP 14-0048 Duke Energy Presentation - Brunswick MELLLA+ Methods Applicability, Pre-Application Meeting, April 17, 2014
-Brunswick MELLLA+ Methods Applicability, Pre-Application Meeting,April 17, 2014 Brunswick MELLLA+Pre-Application MeetingAREVA MELLLA+ Methods Applicability April 17, 2014DUKE'~ENERGY.
 
Brnwc LA+ Mehd Appiablt* Duke Participants
Brunswick MELLLA+
* Roger Thomas" Bill Murray* Charles Stroupe(Presenter)
Pre-Application Meeting AREVA MELLLA+ Methods Applicability April 17, 2014 DUKE
                                    '~ENERGY.
 
Brnwc         LA+ Mehd   Appiablt
* Duke Participants
* AREVA Participants
* Roger Thomas
* Dan Tinkler
  " Bill Murray               .      Alan Meginnis
* Charles Stroupe (Presenter)
* Greg Westmoreland
* Greg Westmoreland
* John Siphers* AREVA Participants
* John Siphers mmK 2
* Dan Tinkler.Alan MeginnismmK2 Agenda" Schedule* Introduction and Objectives
 
* Fuel and plant licensing analysis strategy* AREVA MELLLA+ Methods Applicability SummaryDUKEENERY.3 Schedule* MELLLA+ LAR submittal (both Units)* B1C19 sample problem with ATRIUMTM 1OXM" B1C21 cycle specific application results to NRC* First planned MELLLA+ cycle" MELLLA+ requested approval (both Units)Fall 2014December 2015Spring 2016* MELLLA+ implementation
Agenda
* During B1C21 refueling outageSpring 2016DLUKEENERGY.4 On January 8, 2013 Duke energy presented a pre-application meeting with the NRC. (ML13007A373)
" Schedule
* Benefits of MELLLA+* Approach to fuel and licensing analysis strategies
* Introduction and Objectives
* Thermal hydraulic stability solution (AREVA's Enhanced Option Ill)* Containment Accident Pressure (CAP)* Anticipated Transient Without SCRAM analysis* MELLLA+ impacts* Several follow up pre-application meetings were proposed.
* Fuel and plant licensing analysis strategy
* The NRC requested "The licensee should justify the use andapplicability of the GEH generic MELLLA+ LTR to the AREVAapproaches and the use of AREVA fuel assemblies."
* AREVA MELLLA+ Methods Applicability Summary DUKE 3                                    ENERY.
 
Schedule
* MELLLA+ LAR submittal (both Units)               Fall 2014
* B1C19 sample problem with ATRIUMTM       1OXM
" B1C21 cycle specific application results to NRC   December 2015
* First planned MELLLA+ cycle
" MELLLA+ requested approval (both Units)           Spring 2016
* MELLLA+ implementation
* During B1C21 refueling outage                  Spring 2016
                                                            -* DLUKE 4                                                      ENERGY.
 
On January 8, 2013 Duke energy presented a pre-application meeting with the NRC. (ML13007A373)
* Benefits of MELLLA+
* Approach to fuel and licensing analysis strategies
* Thermal hydraulic stability solution (AREVA's Enhanced Option Ill)
* Containment Accident Pressure (CAP)
* Anticipated Transient Without SCRAM analysis
* MELLLA+ impacts
* Several follow up pre-application meetings were proposed.
* The NRC requested "The licensee should justify the use and applicability of the GEH generic MELLLA+ LTR to the AREVA approaches and the use of AREVA fuel assemblies."
(ML13016A014)
(ML13016A014)
DUKE5 ENERGY.
DUKE 5                                                        ENERGY.
* On 8/20/13 a pre-application meeting was conducted whichfocused primarily on GEH methods applicability to AREVAfuel (ML13327A037 and ML13327A038)
* On 8/20/13 a pre-application meeting was conducted which focused primarily on GEH methods applicability to AREVA fuel (ML13327A037 and ML13327A038)
GEH A10XM Core Modeling* GEH ATWS A1OXM Modeling* Overview of AREVA Methods Applicability Report* Today's meeting will provide more detail on AREVA'smethods applicability to BSEP MELLLA+ conditions DUKE6 " ENERGY.
GEH A10XM Core Modeling
Introduction and Objectives MELLLA+ overview...... .. ..I Brunswick MELLLA+ Power Flow Map120.0110.0100.090.080.070.060.050.040.030.020.010.00.0e-" i- M LL9 A_+ R g oMELLL Line\7 ,0.007.7 15.4 23.1 30.8 38.5 46.2 53.9 61.6 69.3 77.0 84.7 92.4 Mlbs/hr Core Flow10 20 30 40 50 60 70 80 90 100 110 120 % Core FlowDUKE7 ' ENERGY.
* GEH ATWS A1OXM Modeling
* All topical areas of the MELLLA+ LTR will beaddressed in the LAR* Duke Energy will address:" SAR Integration of GEH and AREVA input" APRM and Enhanced Option III setpoints andimplementation
* Overview of AREVA Methods Applicability Report
" Risk evaluation, procedure  
* Today's meeting will provide more detail on AREVA's methods applicability to BSEP MELLLA+ conditions DUKE 6    " ENERGY.
: updates, operator training" Plant changes to mitigate ATWS (SLC B-1 0enrichment increase)
 
" Selected non-fuel impacts8DUKEENERGY.
Introduction and Objectives MELLLA+ overview I                         Brunswick MELLLA+ Power Flow Map 120.0 110.0 100.0 90.0 80.0                                      e-"                 i-LL9A_+ R g o M
* GEH MELLLA+ LTR process (NEDC-33006P-A) with GEH methodologies and analyses willaddress:" Non-fuel impacts" Long term ATWS and ATWS instability explicitly modeling ATRIUMTM 1OXM fuel9 DUKE9 '~ENERGY.
70.0 MELLL Line 60.0 50.0 40.0                              *" \7                                       ,
Fuel Iplan strteg* AREVA methodologies and analyses willaddress:* Fuel, core design, COLR fuel limits, LOCA, DBA* ATWS and ASME overpressure
30.0 20.0 10.0 0.0 0.0 7.7   15.4 23.1   30.8   38.5 46.2   53.9   61.6   69.3     77.0   84.7 92.4 Mlbs/hr Core Flow 0  10    20   30     40     50     60   70     80     90       100   110 120 % Core Flow DUKE 7                                                                                      '   ENERGY.
" Enhanced Option III (EO-Ill) stability solution10 10 ENERGY.
* All topical areas of the MELLLA+ LTR will be addressed in the LAR
* AREVA will present information on methods applicability to the BSEP" AREVA will provide a methods applicability report specific toBSEP MELLLA+ conditions
* Duke Energy will address:
" Enhanced Option III" AREVA application of fuel specific limitations and conditions fromthe generic MELLLA+ topical NEDO-33006A 1XDKE11 t~ ENERGY.
  " SAR Integration of GEH and AREVA input
* AREVA proprietary presentation will be given at this pointin the presentation 12DKE12 ENERGY.
  " APRM and Enhanced Option III setpoints and implementation
* AREVA methods are applicable to Brunswick MELLLA+conditions
  " Risk evaluation, procedure updates, operator training
* Methods applicability report will be submitted with LAR* Steady state and transient neutronic and thermal-hydraulic analytical methods and code systems supporting MELLLA+ will be appliedwithin NRC approved applicability ranges4 The assessment database and uncertainty of models used tosimulate the plant response at MELLLA+ conditions are equivalent tocore and assembly conditions for which the AREVA methodology wasbenchmarked
  " Plant changes to mitigate ATWS (SLC B-1 0 enrichment increase)
* AREVA analyses will comply with the fuel-specific limitations andconditions from the generic MELLLA+ SE to NEDO-33006A DiKE13 t ENERGY.
  " Selected non-fuel impacts 8DUKE                                          ENERGY.
Brnwc LA+ Mtos. Applcablit Questions?
* GEH MELLLA+ LTR process (NEDC-33006P-A) with GEH methodologies and analyses will address:
@ENERGY.14 Selected AcronymsASME -American Society of Mechanical Engineers ATWS -Anticipated Transient Without ScramBSEP -Brunswick Steam Electric PlantCAP -Containment Accident PressureCOLR -Core Operating Limits ReportDBA -Design Basis Accidents EO-Ill -Enhanced Option IIIGEH -General Electric HitachiLAR -License Amendment RequestLOCA -Loss of Coolant AnalysisLTR -License Topical ReportMELLLA- Maximum Extended Load Line LimitAnalysisMELLLA+ -Maximum Extended Load Line LimitAnalysis PlusSAR -Safety Analysis ReportSE -Safety Evaluation SLC -Standby Liquid Control~tENERGY.
  " Non-fuel impacts
15 Enclosure 3BSEP 14-0048AREVA Affidavit Regarding Withholding Presentation onAREVA MELLLA+ Methods Applicability AFFIDAVIT STATE OF WASHINGTON  
  " Long term ATWS and ATWS instability explicitly modeling ATRIUMTM 1OXM fuel 9 DUKE 9                                            '~ENERGY.
)) ss.COUNTY OF BENTON )1. My name is Alan B. Meginnis.
 
I am Manager, Product Licensing, for AREVAInc. and as such I am authorized to execute this Affidavit.
Fuel *and* Iplan licensing* an*alysi  strteg
: 2. I am familiar with the criteria applied by AREVA to determine whether certainAREVA information is proprietary.
* AREVA methodologies and analyses will address:
I am familiar with the policies established byAREVA to ensure the proper application of these criteria.
* Fuel, core design, COLR fuel limits, LOCA, DBA
: 3. I am familiar with the AREVA information contained in the presentation
* ATWS and ASME overpressure
: entitled, "AREVA MELLLA+ Methods Applicability,"
  " Enhanced Option III (EO-Ill) stability solution 10                                         *DUKE ENERGY.
dated April 17, 2014 and referred to hereinas "Document."
10
Information contained in this Document has been classified by AREVA asproprietary in accordance with the policies established by AREVA for the control and protection of proprietary and confidential information.
* AREVA will present information on methods applicability to the BSEP
: 4. This Document contains information of a proprietary and confidential natureand is of the type customarily held in confidence by AREVA and not made available to thepublic. Based on my experience, I am aware that other companies regard information of thekind contained in this Document as proprietary and confidential.
  " AREVA will provide a methods applicability report specific to BSEP MELLLA+ conditions
: 5. This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document bewithheld from public disclosure.
  " Enhanced Option III
The request for withholding of proprietary information is madein accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4)  
  " AREVA application of fuel specific limitations and conditions from the generic MELLLA+ topical NEDO-33006A 1XDKE 11                                                      t~ ENERGY.
"Trade secrets and commercial or financial information."
* AREVA proprietary presentation will be given at this point in the presentation 12DKE                                          ENERGY.
: 6. The following criteria are customarily applied by AREVA to determine whetherinformation should be classified as proprietary:
12
(a) The information reveals details of AREVA's research and development plansand programs or their results.(b) Use of the information by a competitor would permit the competitor tosignificantly reduce its expenditures, in time or resources, to design, produce,or market a similar product or service.(c) The information includes test data or analytical techniques concerning  
* AREVA methods are applicable to Brunswick MELLLA+
: aprocess, methodology, or component, the application of which results in acompetitive advantage for AREVA.(d) The information reveals certain distinguishing aspects of a process,methodology, or component, the exclusive use of which provides acompetitive advantage for AREVA in product optimization or marketability.
conditions
(e) The information is vital to a competitive advantage held by AREVA, would behelpful to competitors to AREVA, and would likely cause substantial harm tothe competitive position of AREVA.The information in the Document is considered proprietary for the reasons set forth inparagraphs 6(b), 6(d) and 6(e) above.7. In accordance with AREVA's policies governing the protection and control ofinformation, proprietary information contained in this Document have been made available, on alimited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
* Methods applicability report will be submitted with LAR
: 8. AREVA policy requires that proprietary information be kept in a secured file orarea and distributed on a need-to-know basis.  
* Steady state and transient neutronic and thermal-hydraulic analytical methods and code systems supporting MELLLA+ will be applied within NRC approved applicability ranges 4 The assessment database and uncertainty of models used to simulate the plant response at MELLLA+ conditions are equivalent to core and assembly conditions for which the AREVA methodology was benchmarked
: 9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.SUBSCRIBED before me this / 0 14-day of -,2014..: U-O r,,Susan K. McCoy " 2NGTONNOTARY PUBLIC, STATE OF WAS-TGTON MY COMMISSION EXPIRES:
* AREVA analyses will comply with the fuel-specific limitations and conditions from the generic MELLLA+ SE to NEDO-33006A DiKE 13                                                    t ENERGY.
1/14/2016}}
 
Brnwc LA+ Mtos. Applcablit Questions?
14
                              @ENERGY.
 
Selected Acronyms ASME -American Society of Mechanical Engineers LOCA - Loss of Coolant Analysis ATWS -Anticipated Transient Without Scram      LTR - License Topical Report BSEP - Brunswick Steam Electric Plant          MELLLA- Maximum Extended Load Line Limit CAP - Containment Accident Pressure            Analysis COLR - Core Operating Limits Report            MELLLA+ - Maximum Extended Load Line Limit Analysis Plus DBA - Design Basis Accidents SAR - Safety Analysis Report EO-Ill - Enhanced Option III SE - Safety Evaluation GEH - General Electric Hitachi SLC - Standby Liquid Control LAR - License Amendment Request
                                                                              ~tENERGY.
15
 
Enclosure 3 BSEP 14-0048 AREVA Affidavit Regarding Withholding Presentation on AREVA MELLLA+ Methods Applicability
 
AFFIDAVIT STATE OF WASHINGTON             )
                                ) ss.
COUNTY OF BENTON               )
: 1. My name is Alan B. Meginnis. I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
: 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary. I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
: 3. I am familiar with the AREVA information contained in the presentation entitled, "AREVA MELLLA+ Methods Applicability," dated April 17, 2014 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA for the control and protection of proprietary and confidential information.
: 4. This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.
: 5. This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is
 
requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information."
: 6.     The following criteria are customarily applied by AREVA to determine whether information should be classified as proprietary:
(a)     The information reveals details of AREVA's research and development plans and programs or their results.
(b)     Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.
(c)     The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for AREVA.
(d)     The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability.
(e)     The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA.
The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above.
: 7.       In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
: 8.     AREVA policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
: 9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.
SUBSCRIBED before me this         / 0 1 4-day of         -         ,2014.
                                                                    .:       U
                                                                      -O   r,,
Susan K. McCoy           "         2 NGTON NOTARY PUBLIC, STATE OF WAS-TGTON MY COMMISSION EXPIRES: 1/14/2016}}

Latest revision as of 21:06, 5 February 2020

Enclosure 1 to BSEP 14-0048, Duke Energy Presentation - Brunswick Mellla+ Methods Applicability, Pre-Application Meeting
ML14135A509
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 04/17/2014
From:
Duke Energy Carolinas
To:
Office of Nuclear Reactor Regulation
Shared Package
ML14136A059 List:
References
BSEP 14-0048
Download: ML14135A509 (20)


Text

Enclosure 1 BSEP 14-0048 Duke Energy Presentation - Brunswick MELLLA+ Methods Applicability, Pre-Application Meeting, April 17, 2014

Brunswick MELLLA+

Pre-Application Meeting AREVA MELLLA+ Methods Applicability April 17, 2014 DUKE

'~ENERGY.

Brnwc LA+ Mehd Appiablt

  • Duke Participants
  • AREVA Participants
  • Roger Thomas
  • Dan Tinkler

" Bill Murray . Alan Meginnis

  • Charles Stroupe (Presenter)
  • Greg Westmoreland
  • John Siphers mmK 2

Agenda

" Schedule

  • Introduction and Objectives
  • Fuel and plant licensing analysis strategy
  • AREVA MELLLA+ Methods Applicability Summary DUKE 3 ENERY.

Schedule

  • MELLLA+ LAR submittal (both Units) Fall 2014
  • B1C19 sample problem with ATRIUMTM 1OXM

" B1C21 cycle specific application results to NRC December 2015

  • First planned MELLLA+ cycle

" MELLLA+ requested approval (both Units) Spring 2016

  • MELLLA+ implementation
  • During B1C21 refueling outage Spring 2016

-* DLUKE 4 ENERGY.

On January 8, 2013 Duke energy presented a pre-application meeting with the NRC. (ML13007A373)

  • Benefits of MELLLA+
  • Approach to fuel and licensing analysis strategies
  • Thermal hydraulic stability solution (AREVA's Enhanced Option Ill)
  • Containment Accident Pressure (CAP)
  • MELLLA+ impacts
  • Several follow up pre-application meetings were proposed.
  • The NRC requested "The licensee should justify the use and applicability of the GEH generic MELLLA+ LTR to the AREVA approaches and the use of AREVA fuel assemblies."

(ML13016A014)

DUKE 5 ENERGY.

  • On 8/20/13 a pre-application meeting was conducted which focused primarily on GEH methods applicability to AREVA fuel (ML13327A037 and ML13327A038)

GEH A10XM Core Modeling

  • Overview of AREVA Methods Applicability Report
  • Today's meeting will provide more detail on AREVA's methods applicability to BSEP MELLLA+ conditions DUKE 6 " ENERGY.

Introduction and Objectives MELLLA+ overview I Brunswick MELLLA+ Power Flow Map 120.0 110.0 100.0 90.0 80.0 e-" i-LL9A_+ R g o M

70.0 MELLL Line 60.0 50.0 40.0 *" \7 ,

30.0 20.0 10.0 0.0 0.0 7.7 15.4 23.1 30.8 38.5 46.2 53.9 61.6 69.3 77.0 84.7 92.4 Mlbs/hr Core Flow 0 10 20 30 40 50 60 70 80 90 100 110 120 % Core Flow DUKE 7 ' ENERGY.

  • All topical areas of the MELLLA+ LTR will be addressed in the LAR
  • Duke Energy will address:

" SAR Integration of GEH and AREVA input

" APRM and Enhanced Option III setpoints and implementation

" Risk evaluation, procedure updates, operator training

" Plant changes to mitigate ATWS (SLC B-1 0 enrichment increase)

" Selected non-fuel impacts 8DUKE ENERGY.

" Non-fuel impacts

" Long term ATWS and ATWS instability explicitly modeling ATRIUMTM 1OXM fuel 9 DUKE 9 '~ENERGY.

Fuel *and* Iplan licensing* an*alysi strteg

  • AREVA methodologies and analyses will address:

" Enhanced Option III (EO-Ill) stability solution 10 *DUKE ENERGY.

10

  • AREVA will present information on methods applicability to the BSEP

" AREVA will provide a methods applicability report specific to BSEP MELLLA+ conditions

" Enhanced Option III

" AREVA application of fuel specific limitations and conditions from the generic MELLLA+ topical NEDO-33006A 1XDKE 11 t~ ENERGY.

  • AREVA proprietary presentation will be given at this point in the presentation 12DKE ENERGY.

12

  • AREVA methods are applicable to Brunswick MELLLA+

conditions

  • Methods applicability report will be submitted with LAR
  • Steady state and transient neutronic and thermal-hydraulic analytical methods and code systems supporting MELLLA+ will be applied within NRC approved applicability ranges 4 The assessment database and uncertainty of models used to simulate the plant response at MELLLA+ conditions are equivalent to core and assembly conditions for which the AREVA methodology was benchmarked
  • AREVA analyses will comply with the fuel-specific limitations and conditions from the generic MELLLA+ SE to NEDO-33006A DiKE 13 t ENERGY.

Brnwc LA+ Mtos. Applcablit Questions?

14

@ENERGY.

Selected Acronyms ASME -American Society of Mechanical Engineers LOCA - Loss of Coolant Analysis ATWS -Anticipated Transient Without Scram LTR - License Topical Report BSEP - Brunswick Steam Electric Plant MELLLA- Maximum Extended Load Line Limit CAP - Containment Accident Pressure Analysis COLR - Core Operating Limits Report MELLLA+ - Maximum Extended Load Line Limit Analysis Plus DBA - Design Basis Accidents SAR - Safety Analysis Report EO-Ill - Enhanced Option III SE - Safety Evaluation GEH - General Electric Hitachi SLC - Standby Liquid Control LAR - License Amendment Request

~tENERGY.

15

Enclosure 3 BSEP 14-0048 AREVA Affidavit Regarding Withholding Presentation on AREVA MELLLA+ Methods Applicability

AFFIDAVIT STATE OF WASHINGTON )

) ss.

COUNTY OF BENTON )

1. My name is Alan B. Meginnis. I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary. I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
3. I am familiar with the AREVA information contained in the presentation entitled, "AREVA MELLLA+ Methods Applicability," dated April 17, 2014 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA for the control and protection of proprietary and confidential information.
4. This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.
5. This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is

requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information."

6. The following criteria are customarily applied by AREVA to determine whether information should be classified as proprietary:

(a) The information reveals details of AREVA's research and development plans and programs or their results.

(b) Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.

(c) The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for AREVA.

(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability.

(e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA.

The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above.

7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
8. AREVA policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.

SUBSCRIBED before me this / 0 1 4-day of - ,2014.

.: U

-O r,,

Susan K. McCoy " 2 NGTON NOTARY PUBLIC, STATE OF WAS-TGTON MY COMMISSION EXPIRES: 1/14/2016