RS-17-084, Response to Request for Additional Information for Byron Station and Braidwood Station Post Peening Relief Requests

Response to Request for Additional Information for Byron Station and Braidwood Station Post Peening Relief Requests

ML17200C952
Person / Time
Site:	Byron, Braidwood
Issue date:	07/14/2017
From:	Gullott D Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-17-084
Download: ML17200C952 (80)

Text

... 4300 Winfield Road Warrenville. IL 60555

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Exelon Generation 630 657 2000 Office Proprietary information contained in Attachment 1.

Withhold from public disclosure under 10 CFR 2.390 When separated, the cover letter and remaining attachments are Non-Proprietary 10 CFR 50.55a RS-17-084 July 14, 2017 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. 50-456 and 50-457 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455

Subject:

Response to Request for Additional Information for Byron Station and Braidwood Station Post Peening Relief Requests

References:

1. Letter from David M. Gullatt (Exelon Generation Company, LLC) to U.S.

NRC, "Request for Relief for Extension of Examination Interval for Reactor Pressure Vessel Head Penetration Nozzles with Mitigated Alloy 600/82/182 Peened Surfaces in Accordance with 10 CFR 50.55a(z)(1 ), " dated December 16, 2016(ML16356A019) [RS-16-249 for Byron Station Unit 2]

2. Letter from David M. Gullatt (Exelon Generation Company, LLC) to U.S.

NRC, "Supplement to Request for Relief for Extension of Examination Interval for Reactor Pressure Vessel Head Penetration Nozzles with Mitigated Alloy 600/82/182 Peened Surfaces (RS-16-049)," dated April 28, 2017(ML17128A031) [RS-17-054 for Byron Station Unit 2]

3. Letter from David M. Gullatt (Exelon Generation Company, LLC) to U.S.

NRC, "Request for Relief for Extension of Examination Interval for Reactor Pressure Vessel Head Penetration Nozzles with Mitigated Alloy 600/82/182 Peened Surfaces in Accordance with 10 CFR 50.55a(z)(1)," dated March 31, 2017(ML17095A268) [RS-17-039 for Braidwood Station Unit 1]

4. Letter from David M. Gullatt (Exelon Generation Company, LLC) to U.S.

NRC, "Request for Relief for Extension of Examination Interval for Reactor Pressure Vessel Head Penetration Nozzles with Mitigated Alloy 600/82/182 Peened Surfaces in Accordance with 10 CFR 50.55a(z)(1)," dated June 15, 2017 (ML17170A146) [RS-17-080 for Byron Station Unit 1] ~ \_\.

1

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Proprietary information contained in Attachment 1.

Withhold from public disclosure under 10 CFR 2.390 When separated, the cover letter and remaining attachments are Non-Proprietary U.S. Nuclear Regulatory Commission July 14, 2017 Page2

5. Electric Power Rese~rch Institute (EPRI), Materials Reliability Program:

Topical Report for Primary Water Stress Corrosion Cracking Mitigation by Surface Stress Improvement (MRP-335 Revision 3-A), EPRI Publication No.

3002009241, Final Report, dated November 2016

6. Letter from Kevin Hsueh, (U.S. NRC) to Matthew Sunseri, (EPRI), "Final Safety Evaluation of the Electric Power Research Institute MRP-335, Revision 3, 'Materials Reliability Program: Topical Report for Primary Water Stress Corrosion Cracking Mitigation by Surface Stress Improvement [Peening],"' dated August 24, 2016(ML16208A485)

7. Email from Joel Wiebe, (U.S. NRC) to Jessica Krejcie (EGC),

"Preliminary RAls for Braidwood and Byron Post Peening Relief Requests," dated June 14, 2017 In accordance with 10 CFR 50.55a, "Codes and standards," paragraph (a)(z)(1), Exelon Generation Company, LLC (EGC), submitted relief requests for Braidwood Station Unit 1 and Byron Station Units 1 and 2 (References 1 through 4) requesting inspection frequency relief for Reactor Pressure Vessel Head Penetration Nozzle (RPVHPN) examinations performed in accordance with 10 CFR 50.55a(g)(6)(ii)(D), which specifies the use of American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel Code,Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components," Code Case N-729-1. The basis of the request was the implementation of the Ultra High Pressure Cavitation Peening (UHPCP) process and that the proposed alternative would provide an acceptable level of quality and safety. Specifically, EGC requested a change to the examination interval of the follow-up inspections for peened RPVHPNs and associated welds in accordance with References 5 and 6; including relief from the Reference 6 Condition 5.4 (b) requirement for inspection in the first refueling outage after peening.

In Reference 7, the NRC requested additional information related to their review of References 1 through 3. The response to the Reference 7 request is included in Attachment 1. Note, some of the responses to the NRC requested additional information in Reference 7 are also applicable to Reference 4 and a planned submittal for Braidwood Station Unit 2. For this reason, the Braidwood Unit 2 docket number is included as part of these RAI responses. As part of the responses in , EGC has identified which responses are applicable to which units. contains proprietary information as defined by 10 CFR 2.390, "Public inspection, exemption, requests for withholding." EGC has reproduced the information from the proprietary AREVA Licensing Report, ANP-3601 P, Revision 0, entitled "Response to Request for Additional Information for Byron Station Unit 2 and Braidwood Station Unit 1," dated July 2017. AREVA, Inc, (AREVA) as the owner of proprietary information has executed the enclosed affidavit, which identifies that the enclosed proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure. The proprietary information was provided to EGC by AREVA as referenced by the affidavit. The proprietary information has been faithfully reproduced in the attached information such that affidavits remain applicable. AREVA hereby requests that the attached proprietary information be withheld, in its

Proprietary information contained in Attachment 1.

Withhold from public disclosure under 10 CFR 2.390 When separated, the cover letter and remaining attachments are Non-Proprietary U.S. Nuclear Regulatory Commission July 14, 2017 Page 3 entirety, from public disclosure in accordance with the provisions of 10 CFR 2.390 and 10 CFR 9.17. The affidavit supporting the proprietary nature of the information is contained in .

There are no regulatory commitments contained in this letter.

If you have any questions regarding this matter, please contact Jessica Krejcie at (630) 657-2816.

Respectfully, David M. Gullett Manager - Licensing Exelon Generation Company, LLC : EGC responses to "Preliminary RAls for Braidwood and Byron Post Peening Relief Requests," dated June 14, 2017 (PROPRIETARY) : AREVA Licensing Report ANP-3601 NP Revision 0, "Response to Request for Additional Information for Byron Station Unit 2 and Braidwood Station Unit 1,"

dated July 2017 (Non-Proprietary)

(NOTE, Attachment 2 is the Non-Proprietary version of Attachment 1. Although titles vary slightly, technical content remains the same) : AREVA Inc., Affidavit for "Licensing Report ANP-3601 NP Revision 0, "Response to Request for Additional Information for Byron Station Unit 2 and Braidwood Station Unit 1," dated July 2017 cc: Regional Administrator-NRG Region Ill NRC Senior Resident Inspector-Braidwood Station NRC Senior Resident Inspector-Byron Station NRC Project Manager, NRR - Braidwood and Byron Station Illinois Emergency Management Agency - Division of Nuclear Safety

ATTACHMENT 2 AREVA Licensing Report ANP-3601 NP Revision 0, "Response to Request for Additional Information for Byron Station Unit 2 and Braidwood Station Unit 1," dated July 2017 (Non-Proprietary)

NOTE, Attachment 2 is the Non-Proprietary version of Attachment 1. Although titles vary slightly, technical content remains the same

A AREVA Response to Request for Additional ~~~~i~~o~NP Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report July 2017 AREVA Inc.

(c) 2017 AREVA Inc.

ANP- 3601NP Revision O Copyright © 2017 AREVA Inc.

All Rights Reserved

AREVA Inc. ANP- 3601NP Revision O Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page i Nature of Changes Section(s)

Item or Page(s) Description and Justification 1 All Initial Issue

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1.0 INTRODUCTION

AND

SUMMARY

................................................................... 1-1 2.0 REQUESTS RELATED TO ATTACHMENT 1 TO THE LICENSEE'S SUBMITTALS DATED DECEMBER 16, 2016, APRIL 28, 2017, AND MARCH 31, 2017 ...................................................................... 2-1 2.1 RAI 1-1 .................................................................................................... 2-1 2.1.1 StatementofRAI 1-1 ................................................................. 2-1 2.1.2 Response to RAI 1-1 ................................................................. 2-1 2.2 RAI 1-2 .................................................................................................... 2-2 2.2.1 Statement of RAI 1-2 ................................................................. 2-2 2.2.2 Response to RAI 1-2 ................................................................. 2-2 2.3 RAI 1-3 .................................................................................................... 2-7 2.3.1 Statement of RAI 1-3 ................................................................. 2-7 2.3.2 Response to RAI 1-3, Qualification Process .............................. 2-7 3.0 NRG REQUESTS RELATED TO PROPRIETARY ATTACHMENT 3 TO THE LICENSEE'S SUBMITTALS ---AREVA DOCUMENT#

150-8086004-001, "SPECIAL PROCESS QUALi Fl CATION RECORD (SPQR)" FOR BRAIDWOOD, UNIT 1 AND BYRON, UNIT 2............................................................................................................... 3-1 3.1 RAI 3-1 ............................................................. : ...................................... 3-1 3.1.1 Statement of RAI 3-1 .................................................................. 3-1 3.1.2 Response to RAI 3-1 ................................................................. 3-1 3.2 RAI 3-2 .................................................................................................... 3-4 3.2.1 Statement of RAI 3-2 ................................................................. 3-4 3.2.2 Response to RAI 3-2 ................................................................. 3-4 3.3 RAI 3-3 .................................................................................................... 3-6 3.3.1 Statement of RAI 3-3 ................................................................. 3-6 3.3.2 Response to RAI 3-3 ................................................................. 3-6 3.3.3 Summary for RAI 3-3 ............................................................... 3-25 3.4 RAI 3-4 ....................................'.............................................................. 3-27 3.4.1 Statement for RAI 3-4 .............................................................. 3-27 3.4.2 Response to RAI 3-4 ............................................................... 3-27 3.5 RAI 3-5 .................................................................................................. 3-28 3.5.1 Statement for RAI 3-5 .............................................................. 3-28 3.5.2 Response to RAI 3-5 ............................................................... 3-28

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page iii 3.6 RAI 3-6 .................................................................................................. 3-33 3.6.1 Statement of RAI 3-6 ............................................................... 3-33 3.6.2 Response to RAI 3-6 ............................................................... 3-33 3.7 RAI 3-7 .................................................................................................. 3-35

3. 7 .1 Statement of RAI 3-7 ............................................................... 3-35 3.7.2 Response to RAI 3-7 ............................................................... 3-35 4.0 REQUESTS RELATED TO PROPRIETARY ATTACHMENT 4 TO THE LICENSEE'S SUBMITTALS --- AREVA DOCUMENT #32-9241722-001, "BYRON AND BRAIDWOOD PEENING RESIDUAL PLUS OPERATING STRESS ANALYSIS" ........................................................ 4-1 4.1 RAI 4-1 .................................................................................................... 4-1 4.1.1 Statement of RAI 4-1 ................................................................. 4-1 4.1.2 Response to RAI 4-1 ................................................................. 4-1 4.2 RAI 4-2 .................................................................................................... 4-3 4.2.1 Statement of RAI 4-2 ................................................................. 4-3 4.2.2 Response to RAI 4-2 ................................................................. 4-3 4.3 RAI 4-3 .................................................................................................... 4-4 4.3.1 Statement of RAI 4-3 ................................................................. 4-4 4.3.2 Response to RAI 4-3 ................................................................. 4-4

5.0 REFERENCES

.................................................................................................. 5-1

Controlled Docurnent AREVA Inc. ANP- 3601NP Revision O Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page iv List of Tables Table RAI 1-2 RPVHPNs Requiring ID or OD Peening ................................................ 2-6 Table 5-1 [

] (References 2, 3 and 4 Attachment 2) .......................................................................... 3-8 Table RAI 3-3 'As Peened' vs 'Post Peened' Stress Ratios ...................................... 3-12 Table 10-4 (References 1, 3 and 4 Attachment 3) ......... 3-14 Table C-3

]

(References 1, 3 and 4 Attachment 3) ............................................... 3-14 Table C-5

] From SPQR Doc. No. 150-8086004-001 (References 1, 3 and 4 Attachment 3) ............................................... 3-16 Table 10-3 (References 1, 3 and 4 Attachment 3) ......... 3-19 Table C-1

] (References 1, 3 and 4 Attachment

3) ........................................................................................................ 3-20 Table C-1 [

] (References 1 , 3 and 4 Attachment

3) ........................................................................................................ 3-24 Table RAI 3-5 [ ] ............................ 3-30

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Pagev List of Figures Figure 4-1

](References 1, 3 and 4 Attachment 4) ....................................................................................... 3-7

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 1-1

1.0 INTRODUCTION

AND

SUMMARY

REQUEST FOR ADDITIONAL INFORMATION (RAI)

BYRON STATION, UNIT NOS. 1 AND 2, AND BRAIDWOOD STATION, UNITS 1AND2 DOCKET NOS. STN 50-454, STN 50-455, STN 50-456 AND STN 50-457 In reviewing the Exelon Generation Company, LLC (Exelon's) submittals dated December 16, 2016 (Agency-wide Documents Access and Management System (ADAMS) Accession No. ML16356A012), and April 28, 2017 (ADAMS Accession No. ML17128A021), related to proposed alternative 14R-14, Revision 1, for the Byron Station (Byron), Unit 2, and submittal dated March 31, 2017 (ADAMS Accession No. ML17095A333), related to proposed alternative 13R-22 for the Braidwood Station (Braidwood), Unit 1, the NRG staff has determined that the following information is needed in order to complete its review:

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 2-1 2.0 REQUESTS RELATED TO ATTACHMENT 1 TO THE LICENSEE'S SUBMITTALS DATED DECEMBER 16, 2016, APRIL 28, 2017, AND MARCH 31,2017 2.1 RAJ 1-1 2.1.1 Statement of RAI 1-1 In Section 5.1, Page 4, of Attachment 1, the licensee states that the ongoing visual examinations for evidence of leakage is performed at the same schedule as prior to peening. In Section 5. 1. 1 entitled Proposed Alternative, there is no formal request to deviate from Condition 5. 1 of NRC's safety evaluation for MRP-335R3A (ADAMS Accession No. ML16208A485). To clarify the visual examination schedule, confirm that Condition 5. 1 will be met by performing a bare metal visual examination on all peened RPVHPNs and J-groove welds each refueling outage.

2.1.2 Response to RAI 1-1 For Byron Station Units 1 and 2 and Braidwood Station Unit 1, EGG will continue to perform bare-metal visual examination of all reactor vessel closure head penetrations per the requirements of Code Case N-729-1 (or later NRG approved version) during each refueling outage. This frequency complies with NRG Condition 5.1 of MRP-335, R3-A.

Controlled Docun1ent AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 2-2 2.2 RA/ 1-2 2.2.1 Statement of RAI 1-2 Several nozzles have been identified as receiving peening that deviated from the planned process, e.g., some aspect of the process was outside of the established acceptance criteria. In some cases the submittal proposes that the nozzles are acceptable and in others it questions the acceptability of the peening process.

(a) Confirm that all nozzles that received peening that deviated from the planned process are identified in the submittals; (b) In the population of nozzles that received peening that deviated from the planned

• process, identify the nozzles that will be included in and those that will be excluded from the relief request. If included in this relief request, provide the basis for acceptability in accordance with MRP-335-3-A and/or the actions and timing of actions that will be undertaken to demonstrate acceptability.

2.2.2 Response to RAI 1-2 The following Table provides a list of Byron Station Unit 2 and Braidwood Station Unit 1 RPVHPNs that have not been peened in accordance with MRP-335, R3-A and identifies the surfaces of those nozzles that will require peening in the future.

EGG intends to re-peen the nozzles that did not receive peening coverage to meet the MRP-335, R3-A requirements during subsequent refueling outages.

Table RAI 1-2 RPVHPN s R equmng ID or OD Peenmg Requires Requires Station Unit Penetration Peening Outage ID OD Peening Peening Byron 2 67 B2R19 (April 2016) x Byron 2 68 B2R19 (April 2016) x Bvron 2 69 B2R19 (April 2016) x x Byron 2 71 B2R19 (April 2016) x Byron 2 73 B2R19 (April 2016) x Byron 2 74 B2R19 (April 2016) x Bvron 2 75 B2R19 (April 2016) x Bvron 2 77 B2R19 (April 2016) x Byron 2 Vent Line B2R 19 (April 2016) x Braidwood 1 67 A1R19 (Sept 2016) x Braidwood 1 71 A1R19 (Sept2016) x Braidwood 1 73 A1R19 (Sept 2016) x Braidwood 1 Vent Line A1R19 (Sept 2016) x

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 2-3 The response to NRG RAI 1-2 part a is unit specific and provided on a unit bases as follows:

EGG Response to NRG RAI 1-2a, Byron Station Unit 2:

EGG confirms that all peened nozzles where peening had deviated from the procedural process were identified in the Byron Station Unit 2 relief request submittals (References 1 and 2, Attachment 1) i.e.,

nozzles that received peening but were not in accordance with the AREVA Special Process Qualification Record (SPQR) Document No.

150-8086004-001 (References 1, 3 and 4, Attachment 3), thus not meeting the requirements of MRP-335, R3-A. Refer to Page 3 of Reference 2:

"No credit will be taken for extension of examination interval for nozzles not peened in accordance with Reference 2 (i.e., 67, 68, 69, 71, 73, 74, 75, 77 and the vent line as described above). These nozzles are planned to be re-peened during a future outage Reactor Head Peening campaign and will be re-evaluated for compliance with Reference 2 once complete."

During the Byron Station Spring 2016 Refueling Outage (B2R19) ID peening tooling could not be sealed adequately to maintain the backpressure necessary to peen the ID surfaces of two CROM penetrations (68 and 69) and three CETC penetrations (74, 75 and 77). Leakage issues persisted and the causes were varied such that they could not be resolved during the outage window. Therefore, it was decided to not complete the ID peening on these penetrations during B2R19 and to re-visit these penetrations in a subsequent outage. The other 73 Reactor Pressure Vessel Head Penetration Nozzles (RPVHPNs) and the vent, at the time of the issuance of the Revision 0 relief request (Reference 1), were considered effectively peened meeting the requirements of MRP-335, R3-A. However, additional peening application legacy issues were discovered during the Byron Station Unit 1 Spring 2017 Refueling Outage (B1R21) that were determined to also apply to the Byron Station Unit 2 peened head. Thus, the Byron Station Unit 2 Summary Report Document No.

51-8092600-001 (Reference 2 Attachment 2,) was updated to document the impact based on the legacy issue identified during B1 R21 and the associated relief request (Reference 2 Attachment 1,)

was revised to document the additional impact. The revised Summary Report and relief request were sent to the NRG in Reference 2.

[

]

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 2-4

[

1 Note, the Byron Station Unit 2 AREVA Summary Report Document No.

51-8092600-001 (Reference 2 Attachment 2,) confirms the current status of the peening coverage for RPVHPNs under Table 2-1. As documented in Table 2-1, nozzle penetrations including the OD and ID surfaces were peened to meet the specifications of MRP-335, R3-A; with exception to the deviated nozzle penetrations listed above and as summarized in Table RAI 1-2.

EGG Response to NRG RAI 1-2a, Braidwood Station Unit 1:

EGC confirms that all peened nozzles where peening had deviated from the procedural process were identified in the Braidwood Station Unit 1 relief request submittal (Reference 3 Attachment 1,) i.e., nozzles that received peening but were not in accordance with the SPQR Document No. 150-8086004-001 (References 1, 3 and 4 Attachment 3), thus not meeting the requirements of MRP-335, R3-A. Refer to Page 2 of Reference 3:

"The Attachment 2 "Summary Report, RVCH Peening Implementation, Braidwood Unit 1" section 2.5 identifies Condition Report (CR) CR-2017-1767 and CR-2017-1944 which discuss two peening process legacy issues identified during the Spring 2017 Byron Station Unit 1 outage (B1R21). These legacy issues resulted in the identification that certain Braidwood Station Unit 1 nozzles may not meet the essential variables/critical parameters in section

4. 3. 8 of MRP-335, R3-A. This will result in additional testing to verify if these nozzles met the MRP-335 requirements. If not, these nozzles will be re peened during the next outage to meet the MRP-335 requirements. Once the requirements of MRP-335 are confirmed to be met through additional testing or re peening, these nozzles will be part of the Attachment 1 Relief Request ASME Code Component scope (see Attachment 1section1 "Identification" and associated note)."

At the completion of the Braidwood Station Unit 1 A 1R19 peening campaign, the 78 RVHPNS and the vent penetration were considered effectively peened. However, additional legacy issues were discovered during the Byron Station Unit 1 Spring 2017 Refueling

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 2-5 Outage (B1 R21) that were determined to also apply to the Braidwood Station Unit 1 peened head. Thus, the Braidwood Station Unit 1 Summary Report Document No. 51-8093944-001 (Reference 3 Attachment 2) was updated to document the impact based on the Byron Station Unit 1 condition reports and issued with the Revision 0 relief request (Reference 3 Attachment 1) documenting the additional impact. Both Byron Station Unit 1 legacy issues described above for Byron Station Unit 2 also affected Braidwood Station Unit 1 which included the peened Braidwood Station Unit 1 14B nozzles (i.e., 67, 71, and 73) (CR-2017-1767) and vent line (CR-2017-1944) where the results of the cavitation peening will not meet MRP-335, R3-A requirements. The Braidwood Station Unit 1 14B nozzle 69 was not included since the penetration was peened as a repaired nozzle requiring a different motion profile program and, thus, not affected.

Note, the Braidwood Station Unit 1 AREVA Summary Report 51-8093944-001 (Reference 3 Attachment 2) confirms the current status of the peening coverage for RPVHPNs under Table 2-1. The Summary Report and relief request that includes a summary of these issues and the current status of peening application were sent to the NRC in Reference 3. As documented in Table 2-1, nozzle penetrations including the OD and ID surfaces were peened to meet the specifications of MRP-335, R3-A; with exception to the deviated nozzle penetrations listed above and as summarized in the below Table RAI 1-2.

EGC Response to NRC RAI 1-2a, Byron Station Unit 1:

Byron Station Unit 1 peening application was completed during Spring 2017. A relief request and associated Summary Report was sent to the NRC in Reference 4. EGC confirms that none of the 78 peened nozzles or vent line penetration identified in the Byron Station Unit 1 relief request submittal (Reference 4 Attachment 1) had deviated from the procedural process and were fully peened in accordance with the AREVA SPQR Document No. 150-8086004-001 (Reference 4 Attachment 3), and met the requirements of MRP-335, R3-A. Refer to EGC Letter RS-17-080 (Reference 4).

The following response to NRC RAI 1-2 part b is applicable to Byron Station Unit 1 and Unit 2 and Braidwood Station Unit 1:

AREVA Inc. ANP- 3601NP Revision O Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 2-6 EGC Response to NRC RAI 1-2b:

For Braidwood Station Unit 1 and Byron Station Units 1 and 2 peened units, the applicable Relief Requests (References 2, 3 and 4) Section 1.0 notes that RPVHPNs 1 through 78 and the vent are included in this relief when, as noted, the nozzles have been mitigated in accordance with section 4.3.8 of MRP-335, R3-A. The peening process is performed in accordance with the Exelon design control process.

When peening is performed, the results are documented into the Engineering design control process by an Engineering Change (EC).

In addition to the results of peening application, the requirements for inspections are updated as part of the design control process. Upon NRC approval of References 2, 3 and 4, the relief requests will be incorporated into the Station lnservice Inspection Program.

However, since the response to NRC RAI 1-2 part a identifies certain nozzles that did not receive adequate peening coverage, those nozzles will not yet be able to credit the reduced inspection frequency relief as requested. Only once the penetrations have been mitigated in accordance with section 4.3.8 of MRP-335, R3-A and documented to meet the requirements as part of the EGC design control process will the peened penetrations be able to utilize the requested reduced inspection frequency inspection schedule as requested in References 2, 3 and 4. It is EGC's intention to peen the remaining penetrations to the MRP-335, R3-A parameters during subsequent refueling outages and incorporate the penetrations into the Engineering Change and Station lnservice Inspection Program.

AREVA Inc. ANP- 3601NP Revision O Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 2-7 2.3 RA/ 1-3 2.3.1 Statement of RAI 1-3 In addition to the nozzles discussed above, the documentation of the qualification process describes instances where the peening process deviated from the planned process.

(a) For each nozzle and mockup where the peening process deviated from the planned process provide a brief explanation for the deviation.

(b) Given that these deviations should not have occurred for the nozzleslmockups for which the deviation was identified, provide your basis for having confidence that these deviations did not occur in other nozzles for which deviations have not currently been identified.

2.3.2 Response to RAI 1-3, Qualification Process EGG agrees that the documentation of the qualification process as included in the SPQR (References 1, 3, 4 Attachment 3) identified instances where the peening process deviated from the planned process. In addition to the qualification process, as described in the response to NRG RAI 1-2, some implementation process deviations occurred.

a. The following peening qualification process deviations occurred during the Special Process Qualification as described below:

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AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 2-10 (References 1, 3 and 4 Attachment 3); the AREVA Special Process Qualification for Ultra High Pressure Cavitation Peening has been completed successfully in accordance with MRP-335, R3-A.

EGG Response to NRG RAI 1-3a, Site Implementation:

In addition to deviations that occurred during the qualification program, issues also occurred during Site implementation or peening application. The details on a station and unit specific basis are below.

In general, peening deviations resulted in nozzles in one of the following three categories:

Category 1: The essential variables/critical parameters were either determined to be acceptable or within tolerance, or outside of tolerance for an acceptable period of time per the SPQR, or the nozzle surface was successfully re-peened Category 2: The essential variables/critical parameters were outside of tolerance and the nozzle was not re-peened (but planned to be re-peened during a subsequent outage)

Category 3: The essential variables/critical parameters were outside of tolerance and were evaluated to confirm the acceptability of the overall peening application for the specific nozzle

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c AREVA Inc. ANP- 3601NP Revision O Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 2-17

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 2-18

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 2-19 Braidwood Station Unit 1 RPVHPNs as defined in Table 2-1 of 51-8093944-001 (Reference 3 Attachment 2) have been effectively

[

]

EGG Response to NRG RAI 1-3a, Site Implementation, Byron Station Unit 1:

Site implementation issues were not provided in the Byron Station Unit 1 relief request submittal (Reference 4 Attachment 1) since there were no issues reported to impact cavitation peening results where essential variables/critical parameters were outside of tolerance and the nozzle was not re-peened (category 2) or were outside of tolerance and were evaluated to confirm the acceptability of the overall peening application (category 3). Category 1 nozzles are additional issues provided below that had potential to impact cavitation peening performance but were either found to be acceptable or the surfaces in question were re-peened and therefore satisfactorily addressed. [

]

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 2-20

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 2-21

Ii AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-1 3.0 NRC REQUESTS RELATED TO PROPRIETARY ATTACHMENT 3 TO THE LICENSEE'S SUBMITTALS ---AREVA DOCUMENT# 150-8086004-001, "SPECIAL PROCESS QUALIFICATION RECORD (SPQR)" FOR BRAIDWOOD, UNIT 1 AND BYRON, UNIT 2.

(NOTE: Responses are applicable to Braidwood Station Units 1 and 2 and Byron Station Units 1 and 2) 3.1 RA/ 3-1 3.1.1 Statement of RAI 3-1 In reviewing Sections 10.1and10.2 of SPQR, the NRG staff notes that [

]

3.1.2 Response to RAI 3-1

led AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-2

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-3

[

]

Testing demonstrated successful results with [

]

AREVA Inc. ANP- 3601NP Revision O Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-4 3.2 RA/ 3-2 3.2.1 Statement of RAI 3-2 Section 10. 4. 1 of SPQR states that [

]

3.2.2 Response to RAI 3-2

AREVA Inc. ANP- 3601NP Revision O Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-5

[

]

and is documented in 51-8088838-000 (Reference 8). The final approach was to

[

] as described in the SPQR, Appendix F (References 1, 3 and 4 Attachment 3).

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-6 3.3 RA/3-3 3.3.1 Statement of RAI 3-3 Section 10. 9 of SPQR addresses the concept of [

]

3.3.2 Response to RAI 3-3 The OD-weld and OD and ID nozzle residual plus operating stress values are shown in Table 5-1 of the post peening Summary Report for: Byron Station Unit 2 Document No. 51-8092600-001 (Reference 2 Attachment 2), Braidwood Station Unit 1 Document No: 51- 8093944-001 (Reference 3 Attachment 2) and Byron Station Unit 1 Document No. 51-8094406-000 (Reference 4 Attachment 2) based on locations defined in Figure 4-1 of the peening residual plus operating stress analysis Document No. 32-9241722-001 (References 1, 3 and 4 Attachment 4).

rn AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-7 Figure 4-1

[

](References 1, 3 and 4 Attachment 4)

Controlled Docurnent AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-8 Table 5-1

[

] (References 2, 3 and 4 Attachment 2)

AREVA Inc. ANP- 3601NP Revision O Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-9 Table 5-1 (Continued)

[

] (References 2, 3 and 4 Attachment 2)

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 In this section, 'As Peened' refers to the stress state of the surface directly after peening is performed. 'Post Peened' is the final stress state after thermal relaxation, shakedown and operating loads have been applied. [

]

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-11

Controlled Docurnent AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensin Re ort Pa e 3-1 Table RAI 3-3

'As Peened' vs 'Post Peened' Stress Ratios Table notes: *'As Peened' refers to the stress state of the surface directly after peening is performed.

'Post Peened' is the final stress state after thermal relaxation, shakedown and operating loads have been applied.

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensin Re ort

Controlled Docun1ent AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-14 Table 10-4

[

] (References 1, 3 and 4 Attachment 3)

Table C-3

[

]

(References 1, 3 and 4 Attachment 3)

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Pa e 3-15

Controlled Docurnent AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-16 Table C-5

[

] From SPQR Doc. No. 150-8086004-001 (References 1, 3 and 4 Attachment 3)

rnent AREVA Inc. ANP- 3601NP Revision O Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-17

AREVA Inc. ANP- 3601NP Revision O Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-18

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Table 10-3

[

] (References 1, 3 and 4 Attachment 3)

Controlled Docurnent AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-20 Table C-1

[

] (References 1, 3 and 4 Attachment 3)

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-21 Table C-1 (Continued)

[

] (References 1, 3 and 4 Attachment 3)

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-22 Table C-1 (Continued)

[

] (References 1, 3 and 4 Attachment 3)

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-23

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-24 Table C-1

[

] (References 1, 3 and 4 Attachment 3)

Controlled Document AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-25 3.3.3 Summary for RAI 3-3

[

] All performance criteria for the residual plus operating stress analysis Document No. 32-9241722-001 (References 1, 3 and 4 Attachment 4) have been met in accordance with MRP-335, R3-A.

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-26

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-27 3.4 RA/3-4 3.4.1 Statement for RAI 3-4 RA/ 3-4 Appendix G of SPQR utilizes the terms repeatability, [

]

3.4.2 Response to RAI 3-4

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-28 3.5 RA/ 3-5 3.5.1 Statement for RAI 3-5 Appendix G.5 of SPQR states that [

] Clarify this apparent inconsistency.

3.5.2 Response to RAI 3-5

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-29

AREVA Inc. ANP- 3601NP Revision O Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-30 Table RAI 3-5

[ ]

AREVA Inc. ANP- 3601NP Revision O Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-31

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-32

[

] The results of the Special Process Qualification Document No.

150- 8086004-001 (References 2, 3 and 4 Attachment 3) meets or exceeds the performance criteria defined in MRP-335, R3-A.

Also see response to RAI 3-3.

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-33 3.6 RAJ 3-6 3.6.1 Statement of RAI 3-6 The final sentence of the first paragraph of section G.5 states [

]

The NRG staff is unclear as to the meaning and significance of this statement. Provide additional information to explain this statement.

3.6.2 Response to RAI 3-6

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-34

Controlled Docurnent AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-35 3.7 RAJ 3-7 3.7.1 Statement of RAI 3-7 Section 10 provides summaries of essential variables for the qualification testing of peening on mockups. [

]

3.7.2 Response to RAI 3-7 Essential variables are the important variables that could change during process implementation and need to be monitored. Process controls are in place that stop the peening if the essential variables fall outside of qualified boundaries.

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-36

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-37 For a random example, the nozzle 72 XML file defines the shell segment start speed [

]

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 3-38

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 4-1 4.0 REQUESTS RELATED TO PROPRIETARY ATTACHMENT 4 TO THE LICENSEE'S SUBMITTALS ---AREVA DOCUMENT #32-9241722-001, "BYRON AND BRAIDWOOD PEEf\i!ING RESIDUAL PLUS OPERATING STRESS ANALYSIS" (NOTE: Responses are applicable to Braidwood Station Units 1 and 2 and Byron Station Units 1 and 2)

• 4.1 RA/4-1 4.1.1 Statement of RAI 4-1 Paragraph 1 of section 4.3 of the stress analysis document [ uses

] The distinction between these terms in this context is not apparent to the NRC staff. Provide clarification.

4.1.2 Response to RAI 4-1 These statements are based on the data provided in Tables 10-3 and 10-4 of the SPQR Document No. 150-8086004-001 (References 1, 3 and 4 Attachment 3), which provides the input values to be used in the analysis. [. *

]

AREVA Inc. ANP- 3601NP Revision O Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 4-2

rn AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 4-3 4.2 RA/4-2 4.2.1 Statement of RAI 4-2 The final sentence of the second paragraph of section 4. 3 of the stress analysis document states" ... [

] Provide clarification of this statement.

4.2.2 Response to RAI 4-2 Reference Section 4.3:

"Note that Reference [1] also permits rotary peening application on ID surfaces.

Reference [12] concluded that [

]

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 4-4 4.3 RA/4-3 4.3.1 Statement of RAI 4-3 Section G.4 of SPQR addresses x-ray diffraction uncertainty by inspection, i.e., [

] Please provide additional clarity.

4.3.2 Response to RAI 4-3

[

] Details of the uncertainty applicable to various locations are provided in response to RAI 3-5.

AREVA Inc. ANP- 3601NP Revision 0 Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1 Licensing Report Page 5-1

5.0 REFERENCES

1. Letter from David M. Gullatt (Exelon Generation Company, LLC) to U.S. NRC, "Request for Relief for Extension of Examination Interval for Reactor Pressure Vessel Head Penetration Nozzles with Mitigated Alloy 600/82/182 Peened Surfaces in Accordance with 10 CFR 50.55a(z)(1)," dated December 16, 2016 (ML16356A019) [RS-16-249 for Byron Station Unit 2]

2. Letter from David M. Gullatt (Exelon Generation Company, LLC) to U.S. NRC, "Supplement to Request for Relief for Extension of Examination Interval for Reactor Pressure Vessel Head Penetration Nozzles with Mitigated Alloy 600/82/182 Peened Surfaces (RS-16-049)," dated April 28, 2017 (ML17095A268) [RS-17-054 for Byron Station Unit 2]

3. Letter from David M. Gullatt (Exelon Generation Company, LLC) to U.S. NRC, "Request for Relief for Extension of Examination Interval for Reactor Pressure Vessel Head Penetration Nozzles with Mitigated Alloy 600/82/182 Peened Surfaces in Accordance with 10 CFR 50.55a(z)(1)," dated March 31, 2017 (ML17095A333) [RS-17-039 for Braidwood Station Unit 1]

4. Letter from David M. Gullatt (Exelon Generation Company, LLC) to U.S. NRC, "Request for Relief for Extension of Examination Interval for Reactor Pressure

.Vessel Head Penetration Nozzles with Mitigated Alloy 600/82/182 Peened Surfaces in Accordance with 10 CFR 50.55a(z)(1 ), " dated June 15, 2017 (ML17095A268) [RS-17-080 for Byron Station Unit 1]

5. Electric Power Research Institute (EPRI), Materials Reliability Program: Topical Report for Primary Water Stress Corrosion Cracking Mitigation by Surface Stress Improvement (MRP-335 Revision 3-A), EPRI Publication No. 3002009241, Final Report, dated November 2016

6. Letter from Kevin Hsueh, (U.S. NRC) to Matthew Sunseri, (EPRI), "Final Safety Evaluation of the Electric Power Research Institute MRP-335, Revision 3,

'Materials Reliability Program: Topical Report for Primary Water Stress Corrosion Cracking Mitigation by Surface Stress Improvement [Peening],"' dated August 24, 2016(ML16208A485)

7. Email from Joel Wiebe, (U.S. NRC) to Jessica Krejcie (EGC), "Preliminary Request for Additional Information (RAI) Regarding Relief Request 14R-10 Preliminary RAls for Braidwood and Byron Post Peening Relief Requests," dated June 14, 2017(ML16343A252)

8. AREVA Document No. 51-8088838-000, Engineering Information Record, "AREVA UHP Cavitation Peening Testing with CETC Funnels"

9. AREVA Document No. 51-8088111-001, Engineering Information Record, "Data Summary, Qualification of the Cavitation Peening Process for RVCH Nozzles"

ATTACHMENT 3 AREVA Inc., Affidavit for "Licensing Report ANP-3601 NP Revision O, "Response to Request for Additional Information for Byron Station Unit 2 and Braidwood Station Unit 1," dated July

. 2017

AFFIDAVIT COMMONWEALTH OF VIRGINIA )

) SS.

CITY OF LYNCHBURG )

1. My name is Gayle Elliott. I am Deputy Director, Licensing & Regulatory Affairs, for AREVA Inc. (AREVA) 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 Licensing Report ANP-3601 P, Revision 0, entitled, "Response to Request for Additional Information for Byron Station Unit No. 2 and Braidwood Station Unit No. 1," dated July 2017 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 corifidential 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 this Document is considered proprietary for the reasons set forth in paragraphs 6(c), 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 has 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 ---'l:.....~=-~-

day of JiJ1v)f , 2017.

Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/18 Reg.# 7079129 SHERRY L." MCFADEN Notarv Pullll.c Commonwtalth of VlfOllll*

7079129 Mw Ccmm111lon E* fru Oct 31, 2011