GNRO-2012/00023, Response to Request for Additional Information Regarding Extended Power Uprate
| ML12097A055 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 04/05/2012 |
| From: | Krupa M A Entergy Operations |
| To: | Document Control Desk |
| Shared Package | |
| ML120970056 | List: |
| References | |
| GNRO-2012/00023 | |
| Download: ML12097A055 (24) | |
Text
When Attachment 1 is removed, the entire letter is non-proprietary.
Attachment 1 contain s proprietary information.
GNRO-201 2/00 0 23 April 5 , 201 2 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Response to Request for Additional Information Regarding Extended Power Uprate Grand Gulf Nuclear Station, Unit 1 Docket No. 50
-416 License No.
REFERENCES:
- 1. Entergy Operations, Inc. letter to the NRC (GNRO
-2010/00056), License Amendment Request
- Extended Power Uprate , September 8, 2010 (ADAMS Accession No. ML102660403)
Dear Sir or Madam:
The Nuclear Regulatory Commission (NRC) has requested additional information regarding the steam dryer discussed in the Grand Gulf Nuclear Station, Unit 1 (GGNS) Extended Power Uprate (EPU) License Amendment Request (LAR) (Reference 1).
GE-Hitachi Nuclear Energy Americas, LLC (GEH) considers portions of the information provided in support of the responses to the request for additional information (RAI) in Attachment 1 to be proprietary and therefore exempt from public disclosure pursuant to 10 CFR 2.390.
An affidavit for withholding information, executed by GEH, is provided in Attachment 3. The proprietary information was provided to Entergy in a GEH transmittal that is referenced in the affidavit. Therefore, on behalf of GEH, Entergy requests Attachment 1 be withheld from public disclosure in accordance with 10 CFR 2.390(b)(1). A non
-proprietary version of the RAI responses is provided in Attachment 2.
No change is needed to the no significant hazards consideration included in the initial LAR (Reference 1) as a result of the additional information provided. There are no new commitment s in this letter
. If you have any questions or require additional information, please contact Jerry Burford at 601-368-5755. Entergy Operations, Inc.
P. O. Box 756 Port Gibson, MS 39150 Michael A. Krupa Director, Extended Power Uprate Grand Gulf Nuclear Station Tel. (601) 437
-6684 GNRO-201 2/0 0 023 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on April 5 , 201 2. Sincerely, MAK/FGB Attachments:
- 1. Response to Request for Additional Information, Mechanical and Civil Engineering Branch, Steam Dryer (Proprietary)
- 2. Response to Request for Additional Information, Mechanical and Civil Engineering Branch, Steam Dryer (Non
-Proprietary)
Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 612 East Lamar Blvd., Suite 400 Arlington, TX 76011
-4 12 5 NRC Senior Resident Inspector Grand Gulf Nuclear Station
Port Gibson, MS 39150 U. S. Nuclear Regulatory Commission ATTN: Mr. A. B. Wang, NRR/DORL (w/2) ATTN: ADDRESSEE ONLY ATTN: Courier Delivery Only Mail Stop OWFN/8 B1 11555 Rockville Pike Rockville, MD 20852
-2378 State Health Officer Mississippi Department of Health P. O. Box 1700
Jackson, MS 39215
-1700 Attachment 2 GNRO-201 2/00 0 23 Grand Gulf Nuclear Station Extended Power Uprate Response to Request for Additional Information Mechanical and Civil Engineering Branch, Steam Dryer (Non
-Proprietary)
This is a non
-proprietary version of Attachment 1 from which the proprietary information has been removed. The proprietary portions that have been removed are indicated by double square brackets as shown here: [[ ]].
Attachment 2 to GNRO-201 2/ 00 023 Page 1 of 17 N on-Proprietary Non-Proprietary Response to Request for Additional Information Mechanical and Civil Engineering Branch By letter dated September 8, 2010, Entergy Operations, Inc. (Entergy) submitted a license amendment request (LAR) for an Extended Power Uprate (EPU) for Grand Gulf Nuclear Station , Unit 1 (GGNS). The NRC has requested additional information regarding the steam dryer to support the review of the steam dryer analysis report. The responses are provided below
. RAI 0 1 During the audit conducted by the NRC staff on Marc h 21-23, 2012, General Electric Hitachi (GEH) displayed an EXCEL table that contained stresses for GGNS replacement Steam dryer (RSD) in various dryer components.
For dryer
[[
]], three different stress values, namely
[[
]]. The staff noted that
[[
]] stress. The staff requests justification for how the stress of
[[
]] is reduced to [[
]] in the dryer
[[
]]. Response As stated in Reference 1, in performing the Flow Induced Vibration (FIV) fatigue loading evaluation for the GGNS replacement dryer, the maximum stress intensity in each drye r component is determined based on both the [[ ]] of the FIV stress analysis results.
Each dryer component has [[ ]] after scoping, the maximum stress intensity from the [[ ]]. Several dryer components included more refined stress processing [[ ]] to more accurately reflect the stress in these locations including the [[ ]]. The stresses from the further post
-processing were used to represent the maximum stress intensity for this dryer component.
In the GGNS replacement steam dryer global finite element (FE) model, to help manage the model size and complexity, the tie bar assembly was modeled [[
]] as shown in Figure 1.
The tie bars' [[ ]] was also not explicitly modeled in the dryer global FE model.
These model simplifications lead to the [[
]] locations. As shown in Figure 2, the maximum stress intensity for the top cap component was [[
]]. Refined stress processing was performed to determine more accurate stress prediction for the top cap component.
Attachment 2 to GNRO-201 2/ 00 023 Page 2 of 17 N on-Proprietary Non-Proprietary In the Excel workbook generated for creating the final stress table, four rows are related to the top cap - inner component as summarized in Table 1.
In the GGNS replacement dryer analysis, the PBLE acoustic loads developed from the [[
]] This load definition was then used in the finite element structural evaluation for the replacement dryer.
There are [[
]] for each dryer component as shown in Table 1.
[[ ]] The first row in Table 1 is maximum stress intensity on the bank top cap
- inner from [[
]]; The second row in Table 1 is the maximum stress intensity on the bank top cap
- inner from
[[ ]]; The third row in Table 1 is the maximum stress intensity on the bank top cap - inner [[ ]] connection.
This stress intensity was determined by scoping the top cap component, [[
]], for the maximum stress and combining it with the calculated stress intensity [[
]] The stress intensity in this weld was calculated by
[[ ]] from the ANSYS FIV analysis results.
The combination of these two stress intensities determines [[
]] The combined stress for the top cap component was then multiplied by a [[
]] The results and calculation approach were provided in response to Round 4 RAI 6 (Reference 2)
. The fourth row in Table 1 is the primary plus secondary stress intensity on the bank top cap
- inner. The nominal primary plus secondary stress [[
]] A weld factor of [[ ]] was then applied to this nominal primary plus secondary stress to be consistent with American Society of Mechanical Engineering Attachment 2 to GNRO-201 2/ 00 023 Page 3 of 17 N on-Proprietary Non-Proprietary (ASME) Boiler and Pressure Vessel Code (BPVC) NG
-3352 methodologies. The results and calculation approach were provided in the response to Round 4 RAI 6 (Reference 2)
. The maximum stress intensity [[ ]] from the refined processing (rows 3 and 4) was selected as the more accurate prediction of the stresses compared to the results in rows 1 and 2. Rows 1 and 2 are not accurate stress predictions for the reasons stated above.
The results and calculation approach were provided in Table 1 of Final Stress Intensity Table with Bias and Uncertainty in the response to Round 6 RAI 6 (Reference 3). The MASR for this component is [[ ]]. Reference s 1. GE Hitachi Nuclear Energy, Grand Gulf Replacement Steam Dryer Fatigue Stress Analysis Using PBLE Methodolog y , NEDC-33601P. 2. Entergy letter to the NRC dated November 25, 2011, Response to Request for Additional Information Regarding Extended Power Uprate (ML113290137)
- 3. Entergy letter to the NRC dated March 21, 2012, Response to Request for Additional Information Regarding Extended Power Uprate (ML12082A025
)
Attachment 2 to GNRO-201 2/ 00 023 Page 4 of 17 N on-Proprietary Non-Proprietary Table 1: Bank Top Cap
- Inner Stresses with Bias and Uncertainty
[[ ]]
Attachment 2 to GNRO-201 2/ 00 023 Page 5 of 17 N on-Proprietary Non-Proprietary
[[
]] Figure 1 Tie Bar Assembly in GGNS Global FE Model
Attachment 2 to GNRO-201 2/ 00 023 Page 6 of 17 N on-Proprietary Non-Proprietary
[[
]] Figure 2 Stress Contour for Top Cap Component at Maximum Stress Load Step
Attachment 2 to GNRO-201 2/ 00 023 Page 7 of 17 N on-Proprietary Non-Proprietary RAI 02 During the audit conducted by the NRC staff on March 21
-23, 2012, the staff requested General Electric Hitachi (GEH) to provide Corrective Action Reports (CARs) written in 2012.
The staff reviewed CAR# 57911, which pertains to a submodel that contained two unconnected nodes.
The staff noted that the justification for the unconnected nodes was based on a study using static
analysis with reconnecting the nodes and applying static accelerations.
The staff requests justification based on applying the applicable dynamic flow induced vibration (FIV) loading, and the appropriate cut boundary conditions to the submodel mentioned in CAR# 57911. Response The model connectivity of Grand Gulf Nuclear Station (GGNS) global model and submodels was checked in the response to Round 5 Request for Additional Information (RAI)
-08. Disconnected nodes were identified in the [[ ]] in two locations as shown in Figure 1. One set of disconnected nodes is located across the [[ ]] edge length; the other set is along the [[ ]]. In the response to Round 5 RAI 8, a static analysis has been performed on the revised submodel (with merged nodes) to provide justification that the original submodel results are conservative as assumed.
This static analysis study was performed by [[ ]] on both the model with the unconnected nodes and the corrected model. The static analysis
stress results were [[
]]. The static analysis demonstrated that the difference is insignificant between the localized stress intensity between the submodels with disconnected nodes and with the all appropriate nodes connected. Further validation of that assumption was performed using a confirmatory Flow Induced Vibration (FIV) dynamic analysis, and is presented in response to this RAI. To track the assumption that the stress prediction in the submodel with the unconnected nodes provides a conservative result as supported by the static analysis, Corrective Action Request (CAR) #57911 was issued. To confirm that assumption, FIV dynamic analyses were performed on a corrected submodel (all proper nodes connected) for [[
]] These are the same load cases used in the original submodel FIV analysis.
Although all of the weld elements were scoped for the maximum stress, the location of interest is
[[ ]]; the original submodel work identified that this weld sustains the most stress when compared to the rest of the welds in the submodel. This location is depicted in Figure 2 (weld elements are shown in the yellowish color). All of the time steps from the FIV analysis were scoped for maximum stress intensity in the weld elements. The scoping results demonstrate that the maximum stress intensity is observed for the [[ ]] case and occurs at [[
]]. The original submodel maximum stress is in the same load case;
Attachment 2 to GNRO-201 2/ 00 023 Page 8 of 17 N on-Proprietary Non-Proprietary however, the high
-stress weld was located on the [[ ]]. The maximum stress occurs for a different load step as well, [[ ]] for the original submodel runs. Submodel benchmarking was performed to address these differences.
The benchmarking process included [[
]] Results show that [[ ]] This indicates that no significant change in stiffness is introduced in the submodel by merging the additional nodes. By merging the disconnected row of nodes, the weld elements become fully connected to the adjoining components. This change in the local load path caused enough difference in the stress distribution to cause the maximum stress load step to shift slightly. In addition, the unconnected nodes effectively acted as a crack in the weld and provided a location of higher stress concentration.
As mentioned above, all load steps were scoped for the maximum stress in the weld elements. Table 1 provides a comparison between the maximum stress intensity in the original submodel welds and the maximum stress intensity in the corrected submodel weld material. The results show that [[
]]. It is important to note that the stress distribution in the weld has changed for the revised submodel as well. The element stress intensity contour plots for both the original and revised submodel are depicted in Figure 3. As is evident in the contour plots, [[
]]. Upon closer inspection of nodal stress distribution, the results indicate that [[
]]. The peak stress observed for the original submodel was [[ ]], as seen in Figure 3.
Table 1: Maximum stress comparison between the original and corrected submodels.
Percent Difference is calculated as the percent reduction in stress from the original (Unconnected) submodel.
[[ ]]
The dynamic FIV analysis results indicate that by merging the nodes, the maximum stress intensity encountered in the weld of interest decreases, as compared to the stress intensity in the Attachment 2 to GNRO-201 2/ 00 023 Page 9 of 17 N on-Proprietary Non-Proprietary original submodel analysis with the disconnected nodes. This result validates the assumption that the stress results provided by the original submodel analysis with the unconnected nodes are conservative.
[[
]] Figure 1: The Two Regions of Nodes to be merged for the Submodel Revision.
Attachment 2 to GNRO-201 2/ 00 023 Page 10 of 17 N on-Proprietary Non-Proprietary
[[ ]] Figure 2:
[[
]] and weld of interest geometry for the submodel analysis.
Attachment 2 to GNRO-201 2/ 00 023 Page 11 of 17 N on-Proprietary Non-Proprietary
[[ ]] Figure 3: Element Stress Intensity Distribution for the weld of interest. The stress distribution for the revised submodel is seen on the left (merged nodes), while the original submodel is shown on the right (disconnected nodes).
Attachment 2 to GNRO-201 2/ 00 023 Page 12 of 17 N on-Proprietary Non-Proprietary R AI 03 The licensee summarized the maximum stress intensities for the overlay and MPC approaches in Table 1 of response to the previous RAI 04 (Attachment 1 to GNRO
-2012/00009).
The MPC approach resulted in higher stress with a difference
[[
]] for the following dryer components:
[[
]] The licensee justified by performing a submodel analysis for the
[[
]] showing that the submodel results are lower than the overlay and MPC approaches.
However, that location is not the higher stress location in terms of magnitude (dryer base plate) or the higher percentage difference location
[[
]]. The licensee is requested to provide additional justification for the other significant locations noted above for the applicability of the submodel analysis conclusion, or validate the conclusion based on additional submodels.
Response Table 1 in the response to Round 5 RAI
-04 (Reference 1) provided a comparison of the calculated maximum stress intensities for all steam dryer components using the embedded /
overlay approach for the shell
-to-solid transition versus the Multi
-Point Constraint (MPC) algorithm. The most significant differences in the stress results for the two approaches were seen for the [[
]] components.
This sensitivity study was performed for a full transient dynamic analysis using the Flow Induced Vibration (FIV) loading for the low frequency nominal load case. The stresses presented in Table 1 of that response were from the primary results scoping, i.e., there were no adjustment factors (weld factor, bias and uncertainty (B&U), etc.) applied. In the GGNS replacement dryer fatigue evaluation, in order to address the uncertainties in the steam dryer structural frequency response, [[
]] The latest final stress table was provided in the response to Round 6 RAI
-06 (Reference 2)
. For the four components that have the highest percentage differences from the overlay versus MPC comparison, Table 1 of this response provides the raw stresses from the ANSYS primary results scoping, the weld factor, the maximum final stresses under EPU conditions, and the Attachment 2 to GNRO-201 2/ 00 023 Page 13 of 17 N on-Proprietary Non-Proprietary MASR. [[
]] An estimated "B&U Factor"
[[
]] [[
]] There are two basic dryer design configurations where the shell
-to-solid transitions were used in the global model. The first configuration is where a [[
]] Examples of these are the [[
]] The other configuration is where a [[
]] Examples of these components are [[
]] Components with the first configuration are addressed by the solid element submodel analysis described in the response to Round 5 RAI
-04 (Reference 1). This solid element submodel analysis investigated the
[[
]] The submodel results are representative of this configuration and show
Attachment 2 to GNRO-201 2/ 00 023 Page 14 of 17 N on-Proprietary Non-Proprietary that the use of the shell overlay method in the global model to transfer the shell node moments into the solid nodes is acceptable.
For the second configuration, the analysis in the response to Round 5 RAI
-04 (Reference 1) showed that [[
]] These results show that the use of the shel l overlay method in the global model to transfer the shell node moments into the solid nodes is acceptable for this configuration.
It should be noted that if the global model stress results in these locations did not meet the minimum MASR of 2.0, the region would be analyzed with a refined submodel which replaces the shell-to-solid transitions in the high stress locations, using either overlay or MPC, with solid elements. With this approach, it is only necessary that the shell
-to-solid transition methodology used in the global model produce conservative results. It is not necessary to seek out which methodology maximizes the additional conservatism introduced in the global model results. In general, the submodeling technique or approach is a widely accepted method for treating stress risers (i.e., resolving local geometry features where the mesh is too coarse to produce accurate results) without revising and reanalyzing an entire global Finite Element (FE) model. In essence, the method can be thought of as (strictly) local mesh refinement; submodel analysis will produce accurate results as long as the cut boundaries are treated properly, standard FE modeling good practices for producing the refined mesh are followed, and the results by comparing boundary results to the original model are confirmed (Reference 3). Reference s 1. Entergy letter to the NRC dated February 14, 2012, Response to Request for Additional Information Regarding Extended Power Uprate (ML120400216
) 2. Entergy letter to the NRC dated March 21, 2012, Response to Request for Additional Information Regarding Extended Power Uprate (ML12082A025
) 3. Robert D. Cook, Finite Element Modeling for Stress Analysis, John Wiley & Sons, New York, 1995.
Attachment 2 to GNRO-201 2/ 00 023 Page 15 of 17 N on-Proprietary Non-Proprietary Table 1 Raw Stresses and Final Stresses for the Three Components that Have Highest Percentage Difference between Overlay vs. MPC
[[
]]
Attachment 2 to GNRO-201 2/ 00 023 Page 16 of 17 N on-Proprietary Non-Proprietary RAI 04 During the audit conducted by the NRC staff on March 21
-23, 2012, the staff noted that some overlay elements were used on some
[[
]] in SSES steam dryer structural finite element model (FEM) in regions
[[
]]. Since the SSES steam dryer is a prototype for Grand Gulf, and the FEMs are similar, the licensee is requested to provide the purpose for utilizing any fictitious overlay elements in regions
[[
]], and their impact on the Grand Gulf RSD stresses.
Response In the Susquehanna Steam Electric Station (SSES) replacement dryer global Finite Element Model (FEM), [[
]] The skin shell elements are not included in the solution of the structural analysis.
Therefore, these skin shell elements have no impact on the SSES dryer stress calculations.
[[
]] Figure 1: Skin Shell Overlay Elements in SSES Finite Element Model
Attachment 2 to GNRO-201 2/ 00 023 Page 17 of 17 N on-Proprietary Non-Proprietary In the GGNS FEM, [[
]] (see Figure 2). They are not used in the structural solution. There are no overlay elements used in the GGNS FEM other than those used for the [[
]] as described in previous RAI responses.
[[
]] Figure 2: Skin Shell Overlay Elements in GGNS Finite Element Model In summary, [[ ]] The skin shell overlay elements are not used in the structural solution and do not have any impact on the stresses determined for either SSES or GGNS.
Attachment 3 GNRO-201 2/00 0 23 Grand Gulf Nuclear Station Extended Power Uprate Response to Request for Additional Information Mechanical and Civil Engineering Branch, Steam Dryer GEH Affidavit for Withholding Information from Public Disclosure
GE-Hitachi Nuclear Energy Americas LLC Affidavit for 173280-JB-063 Affidavit Page 1 of 3 AFFIDAVIT I, Edward D. Schrull, PE state as follows:
(1) I am the Vice President, Regulatory Affairs, Services Licensing, GE-Hitachi Nuclear Energy Americas LLC ("GEH"), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.
(2) The information sought to be withheld is contained in Enclosure 1 of GEH letter, 173280-JB-063, "Grand Gulf Steam Dryer: Transmittal of Steam Dryer Responses to Requests for Additional Information Round 7-1, 2, 3, and 4," dated April 5, 2012. The GEH proprietary information in Enclosure 1, which is entitled "GEH Responses to GGNS Steam Dryer Requests for Additional Information 1, 2, 3, and 4, GEH Proprietary Information -
Class III (Confidential)" is identified by a dotted underline inside double square brackets.
[[This sentence is an example.
{3}]] Figures and some tables containing GEH proprietary information are identified with double square brackets before and after the object. In each case, 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 qualifies under the narrower definition of trade secret, within the meanings assigned to those terms for purposes of FOIA Exempti on 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975 F2d 871 (DC Cir. 1992), and Public Citizen Health Research Group
- v. FDA, 704 F2d 1280 (DC Cir. 1983).
(4) The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. Some examples of categories of information that fit into the definition of proprietary information are:
- a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GEH's competitors without license from GEH constitutes a competitive economic advantage over other companies; b. Information that, if used by a competitor, would reduce their expenditure of resources or improve their competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product; c. Information that reveals aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential pr oducts to GEH; GE-Hitachi Nuclear Energy Americas LLC Affidavit for 173280-JB-063 Affidavit Page 2 of 3
- d. Information that discloses trade secret and/or potentially patentable subject matter for which it may be desirable to obtain patent protection.
(5) To address 10 CFR 2.390(b)(4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GEH, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GEH, not been disclosed publicly, and not been made available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary and/or confidentiality agreements that provide for maintaining the information in confidence. The initial designation of this information as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in the following paragraphs (6) and (7).
(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, who is the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or who is the person most likely to be subject to the terms under which it was licensed to GEH. Access to such documents within GEH is limited to a "need to know" basis.
(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist, or other equivalent authority for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GEH are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory
provisions or proprietary and/or confidentiality agreements.
(8) The information identified in paragraph (2), above, is classified as proprietary because it contains detailed GEH design information of the methodology used in the design and analysis of the steam dryers for the GEH Boiling Water Reactor (BWR). Development of these methods, techniques, and information and their application for the design, modification, and analyses methodologies and processes was achieved at a significant cost to GEH.
The development of the evaluation processes along with the interpretation and application of the analytical results is derived from the extensive experience databases that constitute major GEH asset.
GE-Hitachi Nuclear Energy Americas LLC Affidavit for 173280-JB-063 Affidavit Page 3 of 3 (9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GEH's comprehensive BWR safety and
technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.
The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GEH. The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial. GEH's competitive advantage will be lost if its competitors are able to use the results of the GEH experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.
The value of this information to GEH would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing a nd obtaining these very valuable analytical tools.
I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.
Executed on this 5 th day of April 2012.
Edward D. Schrull, PE Vice President, Regulatory Affairs Services Licensing GE-Hitachi Nuclear Energy Americas LLC
3901 Castle Hayne Rd.
Wilmington, NC 28401
Edward.Schrull@ge.com