ML11257A058

Attachment 25, General Atomics Electronic Systems 04508905-1SP, Revision B, Qualification Test Report Supplement, RM-1000 Upgrades.

ML11257A058
Person / Time
Site:	Watts Bar
Issue date:	02/10/2011
From:	General Atomic Co
To:	Office of Nuclear Reactor Regulation
References
25402-011-VIA-HARA-00191-001 04508905-1SP, Rev. B
Download: ML11257A058 (45)

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Attachment 25 General Atomics Electronic Systems 04508905-1 SP, Revision B, "Qualification Test Report Supplement, RM-1000 Upgrades" (Non-Proprietary)

REVISIONS REV DESCRIPTION J DATE APPROV--ED B INCORPORATED ECN 400000218 2-to-IL  ? & i.-*0 A.EVANS 2/10/2011 a-jo - at 2--' a K-25402-011-VIA-HARA-00191 -001 General Atomics HARA Redacted Qualification Test Report Supplement, RM-1000 Upgrades BECHTEL POWER CORPORATION I Job Number: 25402 SUPPLIER DOCUMENT REVIEW STATUS STATUS CODE:

1 [] Work may proceed. 3 [] Rejected. Revise end resubmit 1C E] Work may proceed. Editodal 4 j] Review not required. Work may comments need only be incorporated proceed if revised for otlher purposes.

2 I Revise andsubject resuhbmit ay to incorporation of P0 278595 proceed changes indicated.

Perniission to proceed does not constitute acceptance or epprovel of design details, calculations, analysis, ted methods, or materials developed or selected by the Supplier and does not relieve the Supplier from full compliance with co"tactual obligations.

Reviewed by I/,4 4A, Arch Civil CS 111A, I IVI,' I111A Elect Mech MET IP

,,NY41, ,,,VII V Consr IStartup STE Status By.. DAT5~!

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+ *GENERAL ELECTRONICATOMICS OATE SYSEIMS 4949 GREENCRAIG LANE SAN DIEGO, CA 92123-1675 A.E.BUTr --

1-06 MR A.E. Urr &-0 QUALIFICATION TEST REPORT D. DOY' SUPPLEMENT, RM-1000 UPGRADES PMOJ uWl SIZE FCM NO. DRAW1NG NO, REV P. NEWMAN (-2-06 O____ M.,,,LE,_6.2_W A 58307 04508905-1SP B REAS SHEE" V.DIXON 6-56 Lea 3

• NONE 1of 35

25402-011 -VI A-HARA-001 91-001 CHANGE RECORD Description Issue Date of Change Rev. A June 2006 Original Issue Rev. B February 2011 Incorporated Customer Comments 04508905-1SP (Rev. B)

25402-011 -VI A-HARA-001 91-001 CONTENTS

1. PURPOSE ................................................................................................................... 1-1

2. EQUIPMENT DESCRIPTION ..................................................................................... 2-1

3. QUALIFICATION REQUIREMENTS .......................................................................... 3-1 3.1 GENERAL QUALIFICATION REQUIREMENTS .............................................................. 3-1 3.2 ENVIRONMENTAL QUALIFICATION REQUIREMENTS ................................................ 3-1 3.3 SEISMIC QUALIFICATION REQUIREMENTS ................................................................ 3-1

4. QUALIFICATION PROGRAM ................................................................................. 4-1 4.1 GENERAL ATOMICS ELECTRONIC SYSTEMS INC'S GENERIC QUALIFICATION PROGRAM ................................................................................................................................... 4-1 4.2 QUALIFICATION PROGRA M FOR THIS SUPPLEMENT ............................................... 4-1

5. QUALIFICATION BASIS ............................................................................................. 5-1 5.1 RM-1 000 PROCESSOR MODULE (GA-ESI P/N 04501200-001) ................................... 5-1 5.1.1 Front PlateAssembly (GA-ESI P/N 04501260-001)..................................................................... 5-1 5.1.2 Display/KeyboardCableAssembly (GA-ES/ P/N 04502018-002)................................................ 5-6 5.1.3 CPU PWA (P/N 04503000-002).................................................................................................... 5-6 5.1.4 Output PWA (P/N 04503080-001)................................................................................................. 5-6 5.2 RM-1000 PROCESSOR MODULE (GA-ESI P/N 04501200-002) ................................... 5-9 5.2.1 Main Assembly (GA-ESI PIN 04501050-003)............................................................................. 5-10 5.3 ENGINEERING CHANGE ORDERS THAT AFFECT THE QUALIFICATION REPORTS-11 5.3.1 ECO 18101 ................................................................................................................................... 5-11 5.3.2 ECO 18108 ................................................................................................................................... 5-11 5.3.3 ECO 18289 .................................................................................................................................. 5-12 5.3.4 ECO 18705 .................................................................................................................................. 5-12 5.3.5 ECO 19171 ................................................................................................................................... 5-12 5.3.6 ECO 102724................................................................................................................................. 5-12 5.4 COMMERCIAL GRADE PARTS THAT AFFECT THE QUALIFICATION REPORT ...... 5-13 5.4.1 GA-ES1 P/N 50015835-001, 7/14/1999....................................................................................... 5-13 5.4.2 GA-ESI P/N 50015836-001, 7/14/1999....................................................................................... 5-13 5.4.3 GA-ES1 P/N 50015837-001, 7/13/1999....................................................................................... 5-13 5.4.4 GA-ESI P/N 50015841-001, 8/5/1999, 8/121999, 8/24/1999, and 8/31/1999 ........... 5-13 (Rev. B) 04508905-1SP

25402-011 -VI A-HARA-001 91-001 5.4.5 GA-ES/ P/N 50016004-001, 10/26/2000 ..................................................................................... 5-14 5.4.6 GA-ES) PIN 50016005-001, 11/1/2000 ....................................................................................... 5-14 5.4.7 GA-ESI PIN 50016021-001, 2/2/2001 ......................................................................................... 5-14 5.4.8 GA-ESl P/N 50016034-001, 2/13/2001 ....................................................................................... 5-14 5.4.9 GA-ESI P/N 50016042-001, 3/9/2001 ......................................................................................... 5-14 5.4.10 GA-ES) P/N 50016063-001, 4/24/2001 ..................................................................................... 5-14 5.4.11 GA-ES) P/N 50016214-001, 6/18/2002 ....................................................................................... 5-14

6. REPLACEM ENT SCHEDULE .................................................................................... 6-1

7. REFERENCE DO CUM ENTS ...................................................................................... 7-1 APPENDICES A. ANALYSIS OFN PRINTED WIRING ASSEMBLY ..................... A-2 A.1 INTRODUCTION .............................................................................................................. A-2 A.2 APPLICABLE DOCUMENTS ........................................................................................... A-2 A.3 EQUIPMENT DESCRIPTION .......................................................................................... A-2 A.4 METHODS ........................................................................................................................ A-2 A.5 ACCEPTANCE CRITERIA ............................................................................................... A-3 A.6 CONCLUSIONS ............................................................................................................... A-3 A.7 ANALYSES ....................................................................................................................... A-3 A. 7.1 NaturalFrequency of the PWA ........................................................................... A-3 A.7.2 Mounting Analysis of the

• PWA ............................................................................. A-3 FIGURES FIGURE 3-1 RRS FOR RM-1000 SEISMIC TESTS (W YLE SHAKE TABLE LIMITS) .................................................. 3-2 FIGURE 5-1 HORIZONTAL SSE RESPONSE SPECTRA FOR THE RM-2000 UUT#1 ............................................... 5-4 FIGURE 5-2 VERTICAL SSE RESPONSE SPECTRA FOR THE RM-2000 UUT#1 .................................................... 5-5 FIGURE 5-3 MAIN ASSEMBLY SECTION SHOWINGý. ...................................................................... 5-10 FIGURE A-1 PW A FREE BODY DIAGRAM .............................................................................. A-4 iii 04508905-1 SP (Rev. B)

25402-011 -VIA-HARA-00191-001 TABLES TABLE 2-1 SIGNIFICANT DIFFERENCES BETWEEN THE NEW RM-1000 &THE ORIGINAL RM-1000 ...................... 2-2 TABLE 5-1 *CHARACTERISTICS ............................................................................................. 5-2 TABLE 5-2 COMPARISON .................................................................................. 5-8 TABLE 5-3 COMPARISON .................................................................................. 5-9 TABLE 6-1 RM-1 000 LIMITED LIFE COMPONENTS .............................................................................................. 6-1 iv 04508905-1SP (Rev. B)

25402-011-VIA-HARA-00191-001

1. PURPOSE This supplement report establishes the basis for the qualification of the RM-1000 Radiation Monitoring Processor Modules, GA-ESI P/N 04501200-001 and -002, that are a replacement for the originally qualified RM-1000 Processor Module, GA-ESI P/N 04501000-001. These replacements are necessitated by the obsolescence of the originally qualified front panel display and the addition of a panel for the -

002 assembly. The replacement Front Panel Display Module, GA-ESI P/N 50016021-001, required creation of a replacement Front Plate Assembly (GA-ESI P/N 04501260-001), a replacement Output Printed Wiring Assembly (PWA) (GA-ESI P/N 04503080-001) and a new configuration of the CPU PWA (GA-ESI P/N 04503000-002). In addition to the replacement front panel display, a number of Engineering Change Orders (ECOs) have been incorporated in the RM-1000. A number of Commercial Grade Parts were also added to new assemblies and ECOs. These are also qualified by this supplement report.

The RM-1000 Processor Module is safety-related and is generically qualified as Class 1E and Seismic Category I in GA-ESI document 04508905-QR, in accordance with IEEE-323-1974 and -1983 and IEEE-344-1975 and -1987. This supplement report demonstrates that the replacement RM-1000 Processor Modules and their new assemblies are qualified to the same qualification requirements as the RM-1000 test article.

This report consists of the following sections.

Section 1. PURPOSE. This section describes the reason for the report, its safety category, the applicable qualification standards, a statement of qualification, and a description of the contents of each section.

Section 2. EQUIPMENT DESCRIPTION. This section describes the equipment modifications being qualified.

Section 3. QUALIFICATION REQUIREMENTS. This section describes the general, environmental and seismic requirements for the RM-1000 Processor Module.

Section 4. QUALIFICATION PROGRAM. This section delineates the generic qualification program established by GA-ESI and the application of that program to the components supplied.

Section 5. QUALIFICATION BASIS. This section demonstrates the qualification of the equipment modifications by similarity to equipment and components successfully tested to requirements equal to or greater than the requirements of the RM-1000 Processor Module.

Section 6. REPLACEMENT SCHEDULE. This section provides the replacement schedule for components whose life is less than 40 years.

Section 7. REFERENCE DOCUMENTS. This section lists the GA-ESI supplied documents and drawings referenced in the body of the supplement report.

04508905-1 SP (Rev. B) 1-1

25402-011 -VIA-HARA-00191-001

2. EQUIPMENT DESCRIPTION The RM-1000s (GA-ESI P/N 04501200-001 and -002) replace the original RM-1000 (GA-ESI P/N 04501000-001). The new assemblies incorporate a number of new subassemblies that replace those in the original RM-1000. The major changes are:

• A New Front Plate Assembly (GA-ESI P/N 04501260-001) replaces the original Front Plate Assembly (GA-ESI P/N 04501060-001). The new assembly incorporates a replacing the original that is no longer manufactured. The front panel has been modified to accommodate the new display.

• A modified cable assembly to accommodate the new front panel.

• A modified Assembly (PWA) (GA-ESI P/N 04503000-002) to incorporate changes necessary for the new display and enhancements.

• A new * (GA-ESI P/N 04503080-001) to incorporate enhancements such as two additionalýfor programming jumpers as well as new DC to DC converters.

• A new Panel (GA-ESI P/N 04503060-001) for RM-1 000 with relay panel (GA-ESI P/N 04501200-002) is provided for ýto the relay contacts.

The new RM-1000 assembly incorporates the following Engineering Change Orders (ECOs): 17827, 18067, 18101, 18108, 18147, 18289, 18705, 18706, 19127, 22130, 22355, and 102724. Those ECOs that affect qualification are evaluated in this supplement.

In addition to ECOs enhancements, a number of changes to commercial grade items and new commercial grade items have been made. The Data Base Change Requests (DBCRs), that are applicable, are:

50015835-001, 50015836-001, 50015837-001, 50015841-001, 50016004-001, 50016005-001, 50016021-001, 50016034-001, 50016042-001, 50016063-001, and 50016214-001.

The significant differences between the original RM-1000 and the new RM-1000s are shown in Table 2-1.

The column for the original assembly shows the components that are present in the original assembly but not in the new assemblies. Likewise, the components listed in the new assembly columns are those that are not present in the original assembly.

04508905-1$P (Rev. B) 2-1

25402-011-VIA-HARA-00191-001 Table 2-1 Significant Differences Between the New RM-1000s & the Original RM-1000 u'ovuvo-ior kriev.

25402-011 -VI A-HARA-001 91-001 25402-011 -VI A-HARA-001 91-001 04508905-1SP (Rev. B) 2-4

25402-011-VIA-HARA-00191-001

3. QUALIFICATION REQUIREMENTS The qualification requirements for the replacement RM-1000 Processor Module are the same as the GA-ESI's generic qualification requirements for the original RM-1000 Processor Module. This section is divided into three subsections: 1) General Qualification Requirements, 2) Environmental Qualification Requirements, and 3) Seismic Qualification Requirements.

3.1 GENERAL QUALIFICATION REQUIREMENTS RM-1000s, GA-ESI P/Ns 04501200-001 and -002, are Safety Related and Seismic Category I for mild environment applications. The requirements of IEEE-323-1983 and 323-1974 as well as IEEE-344-1975 and 344-1987 apply to the qualification.

Functional Requirements are in accordance with GA-ESI documents 04507000 and 04508905-QR (Section 3.2).

3.2 ENVIRONMENTAL QUALIFICATION REQUIREMENTS The environmental conditions listed below are those found in the GA-ESI document 04507000. They reflect the mild environment to be considered for the determination of replacement schedule of limited life components years is used), as well as operating environment.

Temperature Relative humidity Line voltage 3.3 SEISMIC QUALIFICATION REQUIREMENTS The generic seismic qualification requirements for the RM-1000 Module for the Operating Basis Earthquake (OBE) and the Safe Shutdown Earthquake (SSE) shown in GA-ESI document 04508905-OR, Figures 3-2 and 3-3 were not attainable for the shake table on which the seismic tests were performed. The Required Response Spectra (RRS) are provided in Seismic Qualification Test Results, GA-ESI Test Report 04508903-1TR are used for this qualification. The SSE RRS used for seismic tests are shown in Figures 3-1.

04508905-1SP (Rev. B) 3-1

25402-011 -VI A-HARA-001 91-001 100 CM

i0 C

0 c 10 0

10 100 Frequency (Hz)

Figure 3-1 RRS for RM-1 000 Seismic Tests (Wyle Shake Table Limits) 04508905-1SP (Rev. B) 3-2

25402-011 -VI A-HARA-001 91-001

4. QUALIFICATION PROGRAM 4.1 GENERAL ATOMICS ELECTRONIC SYSTEMS INC'S GENERIC QUALIFICATION PROGRAM General Atomics Electronic Systems Inc.'s qualification program for radiation monitors was initiated in 1978.

The basis and justification for GA-ESI's qualification program is provided in GA-ESI document E-115-699, Qualification and Aging Plan for Class 1E Equipment. The qualification program delineates GA-ESI's philosophy regarding aging as well as an overall test plan for the qualification of GA-ESI's Class 1E radiation monitor components and assemblies.

The document further identifies those components that have and the for each component type. This is used as the basis for the qualification tests performed on representative radiation monitors and components. The process and methods used internally at GA-ESI for qualification are governed by GA-ESI Operating Procedure OP-7.3-1 10, "Safety-Related Equipment Qualification". This GA-ESI internal procedure will be used for both environmental and seismic qualification as appropriate for the equipment items listed in Section 2 of this document.

4.2 QUALIFICATION PROGRAM FOR THIS SUPPLEMENT The qualification program for the RM-1000 Processor Module is described in this subsection. It follows the requirements of the parent document, GA-ESI document 04508905-QR, IEEE-323-1974 & -1983, IEEE-344-1975 & -1987, and GA-ESI operating procedure OP-7.3-1 10.

The RM-1000 Processor Module is located in a mild environment. A similarity analysis is performed to identify the changes made between the tested RM-1000 and the design being qualified by this supplement.

The changes are reviewed for differences of that can affect qualification and performance of its safety function. Equipment is required to be suitable for the application and included in an appropriate surveillance and maintenance program. Failures will still occur randomly, however, if the limited life components are replaced at the interval identified in Section 6, common mode failures will not occur and qualification will be maintained.

04508905-1SP (Rev. B) 4-1

25402-011-VIA-HARA-00191 -001

5. QUALIFICATION BASIS The qualification for the replacement RM-1000 Processor Modules is based on original RM-1000 Processor Module qualification tests, This section is organized for ease of review by customers and reviewers of GA-ESI's procedures. The subsections are:

a 5.1 GA-ESI P/N 04501200-001 RM-1000 Processor Module

• 5.2 GA-ESI P/N 04501200-002 RM-1000 Processor Module with Relay PWA

• 5.3 Engineering Change Orders that affect qualification 0 5.4 Commercial Grade Parts that affect qualification The following subsections describe the seismic and environmental qualification basis in accordance with the Section 3 Qualification Requirements. The replacement RM-1000 Processor Module must be capable of performing the same safety functions as the original RM-1000 Processor Module. The functional test procedure, 04508904, is the same for the two RM-1 000 Modules.

5.1 RM-1000 Processor Module (GA-ESI PIN 04501200-001)

The RM-1000 Processor Module (GA-ESI P/N 04501200-001) is a modification of the tested RM-1000 Processor Module (GA-ESI P/N 04501000-001). The top assembly part number was changed so that new printed circuit assemblies and a new display module could be incorporated. The differences between the tested RM-1000 and the new RM-1000 are provided in Table 2-1. The Qualification Basis reflects the configuration of GA-ESI P/N 04501200-001 on January 31, 2006. This section demonstrates that the new RM-1 000 is qualified by RM-1000 in accordance with the Qualification Requirements in Section 3. The Qualification Basis includes of the ECOs and Commercial Grade Parts listed in Sections 5.3 and 5.4.

mounting attachments to the NIM Bin, and electrical connections of GA-ESI P/N 04501200-001 are the same as the tested RM-1000, GA-ESI P/N 04501000-001. At the module level, GA-ESI P/N 04501200-001M Changes to the internal components are evaluated in the following subsections.

5.1.1 Front Plate Assembly (GA-ESI P/N 04501260-001)

The new and original front plate assemblies use the same front plate,

• panel retainer and 4-40 mounting hardware. The differences are display module and the keypad/display Printed Wiring Assembly (PWA).

04508905-1SP (Rev. B) 5-1

25402-011 -VI A-HARA-001 91-001 Keypad/Displav PWA (P/N 04503070-001)

A new Keyboard/Display PWA is provided to support the change to the The schematic for the PWA has changed to reflect the circuitry changes necessary for the display to operate.

The is the same as the tested PWA. The replacement keypad/display assembly is the same as the original keypad/display assembly except for one connector and the PWB. The mounting studs, network are the identical. A connector replaced the

• connector.

The connectors use the same body material and The replacement PWB has only minor layout and component changes to accommodate the connector change compared the original PWB. None of the changes have significant aging failure mechanisms. These changes maintain qualification.

Display Module (P/N 50016021-001)

The RM-1000 is based on qualification of a similar display for the RM-2000 Unit Under Test (UUT) 1 display module, GA-ESI Report 04619010, QualificationReport for the Class 1E Generic RM-2000 Radiation Monitoring System. The new display module is the same manufacturer and model series as the display tested and reported in the above report. The difference in the two displays is= The new display for the RM-1000 is for the RM-2000. Other than the displays are the same.

Table 5-1 Display Module Characteristics installed in the RM-2000 and given a functional test. The RM-2000 passed the functional test.

04508905-1SP (Rev. B) 5-2

25402-011 -VI A-HARA-00191-001 The RM-2000 assembly was given an age conditioning margin test by from

• while maintaining the relative humidity between The RM-2000 had power applied with voltage adjusted to ach. The RM-2000 functioned properly through this conditioning.

At the conclusion of the age conditioning margin test the RM-2000 assembly was subjected to low temperature extremes test of A remote functional test was performed at the low temperature and high temperature at the end of the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> period.

The RM-2000 passed these tests. A post environmental functional test was performed. The ELD performed satisfactorily.

Next, the RM-2000 UUT 1 was given a seismic test. The seismic test consisted of The UUT was rotated and given a second set of reported in GA-ESI Document 04619010, the ELD in UUT 1 did perform acceptably. Figures 5-1 and 5-2 show the Test Response Spectrum (TRS) versus the Required Response Spectrum (RRS). The M is considered qualified.

04508905-1SP (Rev. B) 5-3

25402-011-VIA-HARA-00191-001 REPORT 110 546(3 PAGE NO. 2-U uSm"'. GROW CUSTOMER SORRENTO ELECTRONIICS 506 No. 54643 -DATE 12-16-92 SPECI)4EU 2042000 RADIATION MNOITOR Sim U~UT-1 AXIS OF TEST Z-Y ACCELNO. 3______ AXIS Z C00TEj. ( ) RESP USE (X ) WE5 ) SSE (X ) anE FULL $CAE 1000 9 DAMPING .5-1-2-3-CS)  % RUN0. /5 S-f6--

OKKA7R I - VALFRE ENGINEER K. SCIFULLIN RESVOYSE 5PECTR UK 10o0 I Il 4 a M0 r M9 1114 I aI6 a 9 to I a 4 a 6 7 a SIG.-

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4 I

TRS (5% DAMPING) 4 S1

.S 10 Etli 4

RRS (5% DAMPING) t -1 I I I I Figure 5-1 Horizontal SSE Response Spectra for the RM-2000 UUT#1 04508905-1SP (Rev. B) 5-4

25402-011-VIA-HARA-00191 -001 REPORT N4. 54643 WyLE VE u SUC 4, sYsIws PAGE NO. 2-185 LumAT01 GMItw CUSTOMER SORRENTO ELECTRONICS Joe nO. 546 3 ATE 12-16-92 O..

SPECIMEN AM-20OO RADIATION MONITOR S/N UUT-1 AXIS OF TEST Z-Y ACCEL MO. _ AXIS f CONTROL. RESPONSE (X ) OE ) SSE (X ORE FULLSCALE 1000 9 DMI CIG .5-1-z-3-CS) %.mm--o.

x RUN M.

OPERATOR 1. VALFRE ENGINEER K. SEIFULLIN RESPONSE SPECTRUM 1 oop 4 Yalta~ 7 1 9I1 2 a 4 I 6 1 6 f I 4 I S 5 4 l 4 I

a T

'£ iI 4 100 TRS (5%l DAMPING)

S

-I 10 to

.TRS (5% DAMPING) 2 I ,I... 2 t I

]WO Mo I I Figure 5-2 Vertical SSE Response Spectra for the RM-2000 UUT#1 04508905-1SP (Rev. B) 5-5

25402-011-VIA-HARA-00191-001 5.1.2 Display/Keyboard Cable Assembly (GA-ESI P/N 04502018-002)

The Display/Keyboard Cable Assembly (GA-ESI P/N 04502018-002) is slightly different than the cable assembly (GA-ESI P/N 04502018-001) used in the tested RM-1000. The new cable assembly is the same as the tested cable assembly except the has been eliminated. The is an that is not necessary for the new The elimination of the ~ does not affect environmental or seismic qualification.

5.1.3 CPU PWA (P/N 04503000-002)

The CPU PWA for the new RM-1000 is similar to the CPU PWA tested and qualified as part of the RM-1000 test article. The printed circuit board is the same for both CPU PWAs. The -002 PWA components have been changed to accommodate the new This required the replacement of the

• with a newfthat has the A number of discrete components (resistors, capacitors, and transistors) and one ICare not included on the -002 board since they are no longer needed to support the A has been added, however, the n unctions have not been implemented in the RM-1 000 software for this version of the RM-1 000. The circuit has also been modified by the use of several on board jumper wires, the same size and method of attachment as jumper wires used on test articles. The added components do not have significant age related failure mechanisms and are similar to other ICs qualified as part of the RM-1000 test article. The changes in the components on the board do not affect seismic or environmental qualification. The functional changes are tested as part of the Acceptance Test Procedure and do not change any safety functions.

5.1.4 Output PWA (P/N 04503080-001)

Many components on the replacement Output PWA are identical to those on the original Output PWA (P/N 04503010-001 per Table 2-1 and 04508905-QR). Some parts are new and are qualified by The replacement Output PWA does not have parts with significant aging mechanisms. Therefore, the replacement Output PWA has a qualified life of Mat an average ambient temperature of*

M. Individual components that differ from those used on the original Output PWA are qualified in the subsections that follow.

The original display required ý while the replacement Planar display requires ý The main change to the Output PWA was deletion of the components associated with providing

• and replacing them with components to provideý Deleted were Added were 04508905-1SP (Rev. B) 5-6

25402-011-VIA-HARA-00191-001 These changes required the creation of a replacement printed circuit board. The new printed circuit board is the same size, component density, mounting configuration, and approximately the same weight as the tested Output PWA. The connector is the same manufacturer's part number as used on the CPU PWA in the original RM-1 000 qualification. Most of the components on the replacement PWA are identical to those used on the original PWA. The printed circuit board and added components are similar to those used on the original PWA. The following subsections describe the qualification of components and parts not identical to those on the original Output PWA.

Printed Wiring Board (GA-ESI P/N 04503082-001)

The = printed wiring board (PWB) is the same as the original printed PWB (GA-ESI P/N 04503012-001) with the exception of the arrangement of several components as described above and some trace re-arrangement. The layout changes do not impact qualification because the same design rules for trace routing were used for the outputs as for the original layout. The added trace sizes are the same as original trace sizes for like signals. of the replacement PWA is considered to be equivalent to that of the original PWA. The replacement PWB is considered environmentally and seismically qualified.

-(GA-ESI P/N 50015841-001)

Appendix A of the main body of Report 04508905-QR addresses the replacement of the original and its alternate -

. Since then, The additional ý can be evaluated on the basis of performance characteristics shown in Table 5-2.

The replacement

• all use integrated circuits, diodes, transistors, resistors, There are no digital circuits and no The replacement are encapsulated. The functional mode of the is passive.

04508905-1SP (Rev. B) 5-7

25402-011 -VI A-HARA-001 91-001 The functional characteristics of are as good as or better than those of the The key environmental characteristic of maximum operating temperature is the same. This maintains the seismic and environmental qualification.

The qualification basis of the provided in Appendix D of 04508905-QR is used as the basis for the The additional

• can be evaluated on the basis of performance characteristics shown in Table 5-3.

04508905-1SP (Rev. B) 5-8

25402-011 -VI A-HARA-001 91-001 The functional characteristics of range of the are as good as or better than those of the The key environmental characteristic of maximum operating temperature is the same. This establishes the seismic and environmental qualification.

5.2 RM-1000 Processor Module (GA-ESI P/N 04501200-002)

The RM-1000 Processor Module (GA-ESI P/N 04501200-002) is a modification of the tested RM-1000 Processor Module (GA-ESI P/N 04501000-001) and similar to the RM-1000 Processor Module (GA-ESI P/N 04501200-001) qualified in Section 5.1. The top assembly part number was changed so that new printed circuit assemblies and a new display module could be incorporated. The dash -002 assembly has been modified further to allow the use of a

• The differences between the tested RM-1 000, the dash -

001 RM-1000, and the dash -002 RM-1000 are provided in Table 2-1. The Qualification Basis reflects the configuration of GA-ESI P/N 04501200-001 on January 31, 2006, the Engineering Change Orders in section 5.3, and the Commercial Grade Parts in Section 5.4. This section demonstrates that RM-1000 GA-ESI P/N 04501200-002 is qualified by similarity to the tested RM-1000 in accordance with the Qualification Requirements in Section 3.

Externally, the appearance, mounting attachments to the NIM Bin, and electrical connections of GA-ESI P/N 04501200-002 are the same 04508905-ISP (Rev. B) 5-9

25402-011 -VI A-HARA-00191-001 as the tested RM-1000, GA-ESI P/N 04501000-001. At the module level, GA-ESI P/N 04501200-002 is considered similar to the tested RM-1000 and is qualified without further evaluation.

The only difference between GA-ESI P/N 04501200-001 and GA-ESI P/N 04501200-002 is the Main Assembly GA-ESI P/N 04501050-003. The tested RM-1000 and GA-ESI P/N 04501200-001 use Main Assembly GA-ESI P/N 04501050-001. All other parts in the dash -002 RM-1000 are the same as the dash -

001 RM-1000 and their qualification basis is provided in Section 5.1. The qualification bases for GA-ESI P/N 04501050-003 are evaluated in the following subsection.

5.2.1 Main Assembly (GA-ESI P/N 04501050-003)

The differences in the main assembly of the GA-ESI P/N 04501200-002 RM-1000 Processor Module and the tested RM-1000 main assembly is the addition of a

• GA-ESI P/N 04503060-001 and a modification to the harness assembly GA-ESI P/N 04502013-002. Figure 5-3 shows the location of the panel and its standoffs.

Figure 5-3 Main Assembly Section Showinn The printed circuit board material and Iare the same as those used on the Output PWA of the tested RM-1 000 reported in GA-ESI document 04508905-QR and are considered qualified without further evaluation. The harness assembly, GA-ESI P/N 04502013-002, is the same as the hamess assembly as that tested in the RM-1000 reported in GA-ESI document 04508905-QR except the routing of the wires has been changed to include the ý The addition of the 04508905-1SP (Rev. B) 5-10

25402-011-VIA-HARA-00191 -001 does not change the qualification of the Output PWA because the~that the~replaces have been left on the Output PWA. The P PWA and the wiring harness are functionally verified during the performance of the Acceptance Test Procedure.

The are metal and are rigid. They are similar to standoff used in many GA-ESI assemblies. The PWA mounting attachment provided in Appendix A demonstrates that the attachment is adequate. The P PWA is considered qualified.

5.3 Engineering Change Orders that Affect the Qualification Report The following subsections evaluate the Engineering Change Order (ECO) changes that affect the qualification report. They are evaluated in numerical order. Some ECOs were evaluated in the original qualification report. Both the original report and this report supplement should be used when reviewing the ECOs that affect the qualification report.

5.3.1 ECO 18101 This ECO, released on 5/23/2001, made the following changes to GA-ESI P/Ns 04501200-001 and -002:

1. IC connector for P502 on the Keyboard / Display PWA was changed from an connector. A The connectors use the same body material

• and The change does not add significantly to the weight of the nor change the PWA's center of mass. The connector does not have any age related failure mechanisms. It is considered qualified by similarity to the tested connector.

2. was added to TB1. The the same as one tested as part of the Counter Board PWA but a different value. The addition of the =does not significantly affect the weight or center of mass of the PWA. The added is functionally tested during the Acceptance Test Procedure. The change is considered qualified.

3. Other changes by the ECO are to artwork and PWA board layout to accommodate the above changes and they do not affect qualification.

5.3.2 ECO 18108 This ECO, released on 3/23/2001, made the following changes to GA-ESI P/Ns 04501200-001 and -002:

1. Replaced the CPU PWA and the Display/ Keyboard Cable Assembly with a different version.

These changes have been evaluated in Section 5.1.2 and 5.1.3 and are considered qualified.

04508905-1SP (Rev. B) 5-11

25402-011 -VI A-HARA-001 91-001 5.3.3 ECO 18289 This ECO, released on 10/23/2001, made the following changes to GA-ESI P/Ns 04501200-001 and -002:

1. Hex nuts and spacers were replaced as a product improvement. The spacer length has been increase by 1/16 inch and the hex nuts are the same thread size. These are insignificant hardware changes that do not impact seismic or environmental qualification.

2. A ribbon cable has been added between PWA. This is aý PVC ribbon cable similar to the ribbon cable tested as part of the RM-1000 test article. The ribbon cable tested was acable made of PVC. The tested cable was aged to an equivalent of

• years and then assembled in the test RM-1000. The cable functioned satisfactorily during and after the environmental and seismic test. It is a limited life component and must be replaced afterE years in order to maintain qualification.

5.3.4 ECO 18705 This ECO, released on 6/18/2002, made the following changes to GA-ESI P/Ns 04501200-001 and -002:

1. Addedýfor circuit protection to the CPU PWA. Theý are the same as otherýtested as part of the RM-1000 test article and are consider qualified seismically and environmentally. Functionally their performance is verified during the Acceptance Test Procedure.

2. Added a Seismically, the addition of theioes not change the weight or center of mass significantly. Thelis similar to other Mtested as part of the RM-1000 test article. TheE does not have any significant age related failure mechanisms. Environmentally, the operating temperature range for the ICis * . Functionally, the functions of the were not implemented in the RM-1000 software. Itis considered qualified seismically and environmentally.

5.3.5 ECO 19171 This ECO, released on 1/8/2003, made changes to GA-ESI document 04507000 (Rev. D to E), RM-1000 System Requirements Specification. The change added features to the RM-1000 function (per para. 3.15.4), channel ý (para. 5.8), (para. 7.10), and additional These changes have not been implemented in the software as of yet, but may be in the future. The present RM-1 000 software is Version 1.1 (V1.1), as the effective version applicable to this report.

Version 1.1 is the original software that has been thoroughly tested, validated and verified, which conforms to GA-ESI document 04507000, Rev. D.

5.3.6 ECO 102724 This ECO, released on 4/18/2006, made the following changes to GA-ESI P/Ns 04501200-001 and -002:

1. Added a cover on the rear of the display for protection from ýin the RM-1000 main assembly. This insulator cover, P/N 04612047-007 is nearly identical to the -006 insulator in the original RM-1000 module. The insulator isn nd will not add to the weight of the RM-1000. It doesn't have a safety related function. It is a device to prevent contact with the display and 04508905-1SP (Rev. B) 5-12

25402-011 -VI A-HARA-001 91-001 in the RM-1000. It has no operational function. It has an Underwriters Laboratory continuous rating of M It does not have any significant age related failure mechanisms. It is considered qualified environmentally and seismically.

5.4 Commercial Grade Parts that Affect the Qualification Report The following subsections evaluate the Commercial Grade Parts changes that affect the qualification report.

They are evaluated in numerical order. Some parts were evaluated as part of ECOs in the original qualification report.

5.4.1 GA-ESI P/N 50015835-001, 7/14/1999 This part is a hex standoff, Y2 inch long with 4-40 threads for attachment. It was added by ECO 17656A to the back plate assembly, GA-ESI P/N 04501070-001 as an extension of the ground terminal for the backplate connector. The standoff does not add significantly to the weight or the center of mass of the backplate. It is made of plated steel or stainless steel and has no impact on the environmental qualification. Functionally, it is a passive part that extends the ground terminal 1/2/2 inch. It is considered qualified.

5.4.2 GA-ESI P/N 50015836-001, 7/14/1999 This part is a 4-40 0.35 inch long jackscrew that terminates the ground wire to connector P401 shell. It was added by ECO 17656A to the connector assembly, GA-ESI P/N 04502013-001. The jackscrew provides ground connection from P2 at the shell of P401. It is made of plated steel and has no impact on the environmental qualification. The weight added by the addition of the jackscrew is not significant. It is a passive device that functionally provides a ground connection at the P401 shell. It is considered qualified.

5.4.3 GA-ESl P/N 50015837-001, 7/13/1999 This part is a

• wire terminal ring that is used to terminate the ground wire to GA-ESI P/N 50015836-001, describe in the previous section. It was added by ECO 17656A to the connector assembly, GA-ESI P/N 04502013-001. It is the same manufacturer and model series as GA-ESI P/N 50012469-001 tested as part of the RM-1000 test article reported in GA-ESI document 04508905-QR. It is not significantly larger than the tested part and is considered qualified.

5.4.4 GA-ESI P/N 50015841-001, 8/5/1999, 8/12/1999, 8/24/1999, and 8/31/1999 This part is a ýthat was added to the new Output PWA GA-ESI P/N 04503080-001 used on both RM-1000s, GA-ESI P/Ns 04501200-001 and -002. The part Data Base Change Request (DBCR) was changed several times on the dates shown in this subsection title as the design of the Output PWA progressed. The qualification of the final configuration of the converter is demonstrated in Section 5.1.4. It is considered qualified.

04508905-1SP (Rev. B) 5-13

25402-011 -VI A-HARA-001 91-001 5.4.5 GA-ESI P/N 50016004-001, 10/26/2000 This part is a that was added to the new Output PWA GA-ESI P/N 04503080-001 used on both RM-1000s, GA-ESI P/N 04501200-001 and -002. The qualification of this part is provided in Section 5.1.4. Itis considered qualified.

5.4.6 GA-ESI P/N 50016005-001, 11/1/2000 This part is a discrete It is used on the= PWA. It is similar to other discrete molded body tested as part of the RM-1000 test article. The resistor does not have significant age related failure mechanisms, it is attached to the PWA in the same manner as all other discrete parts, and it is a solid passive device with no moving parts. Itis considered qualified.

5.4.7 GA-ESI P/N 50016021-001, 2/2/2001 This part is ao replace the obsolete display in the RM-1 000 test article on the Front Panel. It is used on GA-ESI P/Ns 04501200-001 and -002. Its qualification is described in Section 5.1.1. It is considered qualified.

5.4.8 GA-ESI P/N 50016034-001, 2/13/2001 This part is a Except for the value, it is similar to otherteested as part of the RM-1000 test article described in GA-ESI document 04508905-OR. It is considered qualified.

5.4.9 GA-ESI P/N 50016042-001, 3/9/2001 This part is a rribbon cable assembly with M connectors at each end. It was added by ECO 18289 to the Front Panel Assembly GA-ESI P/N 04501260-001. Its qualification is provided in Section 5.3.3. It is considered qualified.

5.4.10 GA-ESI P/N 50016063-001,4/24/2001 This part is a connector for PWA mounting that mates with ribbon cable assembly connector, GA-ESI P/N 50016042-001. Itwas added by ECO 18101 to the GA-ESI P/N 04503070-001. Its qualification is described in Section 5.3.1. Itis considered qualified.

5.4.11 GA-ESI P/N 50016214-001, 6/18/2002 This part is a added to the= PWA, GA-ESI P/N 04503000-002. Itwas added by ECO 18705. Its qualification is described in Section 5.3.4. Itis considered qualified.

04508905-1SP (Rev. B) 5-14

25402-011-VIA-HARA-00191 -001

6. REPLACEMENT SCHEDULE The replacement schedule for parts with significant aging mechanisms is provided in this section. The replacement schedule provided is based on an ýaverage ambient temperature. Lifetimes for components in enclosures include an The individual assemblies listed in Table 6-1 are considered to be replaceable assemblies. Lower level components with age related failure mechanisms are replaced as part of the higher level assembly. A dash entry indicates an upper level assembly with subassemblies listed below the entry. These subassemblies are the replaceable items with qualified lifetimes.

Other subassemblies and components (not listed) and the upper level (dashed) assemblies have a life exceeding 40 years.

Table 6-1 RM-1000 Limited Life Components Component GA-ESI Part Number Life, years @ 869F (302C)

RM-1000 Processor Module 04501200-001 & -002 Display/Keypad Cable Assy 04502018-002 Front Panel Assembly 04501260-001 04503070-001 Cable Strip with Connector 50016042-001 50016021-001 04508905-1SP (Rev. B) 6-1

25402-011-VIA-HARA-00191-001

7. REFERENCE DOCUMENTS GA-ESI DRAWINGS 04501200 RM-1000 PROCESSOR MODULE GA-ESI DOCUMENTS 04507000 RM-1000 SYSTEM REQUIREMENTS SPECIFICATION 04508903-1TR SEISMIC QUALIFICATION TEST RESULTS 04508904 TEST PROCEDURE, RM-1000 04619010 QUALIFICATION REPORT FOR THE CLASS 1E GENERIC RM-2000 RADIATION MONITORING SYSTEM E-1 15-699 CLASS 1E EQUIPMENT QUALIFICATION AND AGING PLAN (Revision 3) 04508905-1 SP (Rev. B) 7-1

25402-011 -VI A-HARA-001 91-001 APPENDIX A NTED WIRING ASSEMBLY 04508905-1SP (Rev. B) A-1

25402-011 -V1 A-HARA-001 91-001 A. ANALYSIS OF A.1 Introduction This appendix provides the mounting analysis of the GA-ESI P/N 04503060-001. The analysis demonstrates the adequacy of the attachment and mounting of the PWA to withstand the seismic accelerations that could be expected in the RM-1000 Processor Module, GA-ESI P/N 04501200-002.

A.2 Applicable Documents A.3 Equipment Description Th ePWA, GA-ESI P/N 04503060-001, consists of three printed circuit board discrete components, a connector, an insulator, and wiring from the Wiring Harness, GA-ESI P/N 04502013-002, mounted to the backplate with three 1-1/4 inch long hex metal standoffs. The hardware attaching the PWA to the standoffs and the standoffs to the backplate are 4-40 pan head screws. The backplate is the same as the backplate in the test RM-1000, GA-ESI P/N 04501000-001. The backplate is rigid as demonstrated by resonance searches made during the seismic qualification testing and reported in GA-ESI document 04508905-QR.

A.4 Methods GA-ESI's seismic analysis uses the following conservative approach. If the natural frequency of the component being analyzed can be determined, it is determined Components in the rigid range (natural frequency greater than 33 Hertz) use the Zero Period Acceleration (ZPA)ýto provide margin. If the natural frequency of the component being analyzed cannot be determined or beyond available formula, the peak acceleration found for the appropriate damping level on the Required Response Spectra (RRS) multiplied by~is used. The result of the method used is the acceleration of the mass concentrated at its center of gravity.

Seismic forces (plus weight) are independently applied to the center of mass in the three orthogonal axes that produce the highest stress in the component. The Wstresses are calculated for each reaction. Stresses of the same type are combined using The maximum ýstresses are then calculated and compared to the material allowable stresses.

04508905-1SP (Rev. B) A-2

25402-011 -VI A-HARA-001 91-001 The analyses are performed using MathCAD 12.

A.5 Acceptance Criteria The acceptance criteria for the seismic analysis is based on the acceleration used to calculate the seismic forces and the allowable stresses for the material of which the part is made. The acceleration used is taken from Figure 3-1 of this document aticritical damping. The accelerations used in the analysis are shown below.

Parameter RRS Acceleration, q's Analysis Acceleration, q's Vertical, Peak Vertical, ZPA Horizontal, Peak Horizontal, ZPA GA-ESI uses the following conservative allowable stress relationships.

• Total maximum allowable principal tensile stress is~ the yield strength of the material.

• Total maximum allowable principal shear stress is~ the yield strength of the material.

A.6 Conclusions The analysis of the mounting of the PWA demonstrates that the design is adequate and meets the acceptance criteria.

A.7 Analyses A.7.1 Natural Frequency of the PWA The PWA is supported on three comers. This configuration is not represented in a search of available text material and web sites. The analysis is performed using the peak acceleration times 1.5.

A.7.2 Mounting Analysis of the PPWA The highest stress is present at the backplate attachment screws to the standoffs for the PWA. Afree body diagram of theWPWA with the mounting standoffs is shown in Figure A-1.

04508905-1SP (Rev. B) A-3

25402-011-VIA-HARA-00191 -001 A classical analysis of the PWA would be td determine the centroid of the bolt group at the backplate as the reaction force and moments. This presents a degree of complication that is not necessary in this case. Assume that the third standoff attachment is not there and the full load is taken by the two standoff attachments along the long side of the PWA. This is conservative since the two screws take the entire load rather than three screws. See the free body diagram.

04508905-1SP (Rev. B) A-4

25402-011 -VI A-HARA-001 91-001 04508905-1SP (Rev. B) A-5

25402-011-VIA-HARA-00191 -001 M.:= (Fy + w) z~g M, = 2.61in.lbf MY=Fz~xcg + Fizcg My= 6.81 in - bf Mz:= 4Fy + w)-xcg Mz = -4.5in.lbf Reaction at screw A due to the seismic forces Rshear := + + Rshear = 3.271bf PRx Mz Rtensile := - + - Rtensile = -Olbf 2 y Stresses on screw A aTTAL enile Mycscrew 2

oTOTAL = 24699.8 psi

( Ascrew "screw Rehear cTOTAL:= raTOTAL = 544.3 psi Ascrew Maximum principal stresses amax := I

+TOTAL

+ ,aTOTALT I 2 + tTOTAL2 2 amax 0

= 24711.8psi aliow = 25500psi 2 k2

,cmax := TO2) rTOTAI? T

+ Tmax = 12361.9 psi a.low = 15000 psi The maximum principal stresses are less than the allowable stresses. The attachment is acceptable for seismic forces inthe three orthogonal directions.

04508905-11SP (Rev. B) A-6

Attachment 26 General Atomics Electronic Systems GA/ESI-4482, "Request by General Atomics Electronic Systems, Inc. to Withhold Certain Information from Public Disclosure under IOCFR2.390"

25402-011 -V1 A-HARA-00193-001 General Atomics HARA Request by General Atomics Electronic Systems, Inc. to Withhold Certain Information from Public Disclosure Under 10FCR2.390 BECHTEL POWER CORPORATION Job Number:

25402 SUPPLIER DOCUMENT REVIEW STATUS STATUS CODE:

I E] Work may proceed. 3 [] Rejected. Revise and resubmit.

IC E] Work may proceed. Editorial 4 29 Review not required. Work may comments need only be proceed.

incorporated ifrevised for other purposes.

2 Revise and resubmit. Work may proceed subject to incorporation of PO 278595 changes indicated.

Permission to proceed does not constitute acceptance or approval of design details, calculations, analysis, test methods, or materials developed or selected by the Supplier and does not relieve the Supplier from full compliance with contractual obligations.

Reviewed by Arch Civil CS Elect Mech MET PD -Constr Startup STE Ai1141,V#NA/JA At/A A/R~ fl/IA 0AIVA Status B3y: /7/DATE tX~~~~eZ t* 4/r/ 7 I "

25402-011 -VI A-HARA-001 93-001 General Atomics HARA GENERAL ATOMICS Request by General Atomics Electronic Systems, Inc. to Withhold

+ NR Certain Information from Public Disclosure Under 10FCR2.390 August 15, 2011 GA/ESI-4482 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 2055

Subject:

Request by General Atomics Electronic Systems, Inc. to Withhold Certain Information from Public Disclosure under IOCFR2.390

Reference:

Tennessee Valley Authority /Watts Bar 2 Completion Project To Whom It May Concern:

General Atomics Electronic Systems Inc., (GA-ESI) hereby submits the following documents related to its Radiation Monitoring System pursuant to the specific request of Bechtel Power Corp. Control Systems in support of the Tennessee Valley Authority's Watts Bar 2 Completion Project:

04038903-7SP Qualification Basis for 04034101-001 04508905-1SP Qualification Report Supplement Certain portions of the enclosed documents include GA-ESI proprietary commercially strategic information which GA-ESI has held in confidence, and which is not available through public sources. Accordingly, GA-ESI is submitting these documents in confidence and, as set forth in the enclosed affidavit of Mr. Paul G. Berner, GA-ESI requests that this information be treated as proprietary information under the provisions of 10CFR2.390 and be withheld from public disclosure. The enclosed affidavit addresses specifically the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the of the NRC's regulations.

GA-ESI is submitting both a proprietary version of the documents plus a nonproprietary version of the same. In the proprietary versions of the documents, the proprietary material is delineated by "business sensitive" or "trade secret" designation on specific paragraphs and highlighted text, sentence, figure or drawing to which the designation applies. In the nonproprietary versions, the proprietary information has been obscured/blacked-out.

If you have questions regarding this submittal, please do not hesitate to contact Mr. Paul Berner at (858) 522-8246 or paul.berner(ciqa-esi.com, or me at (858) 455-2823 or keith.asmussen(&.qa.com.

Very truly yours, Keith E. Asmussen, Ph.D., Director Licensing, Safety and Nuclear Compliance

Enclosures:

1) Documents as listed in text

2) Affidavit of Mr. Paul G. Berner 3550 GENERAL ATOMICS COURT. SAN DIEGO, CA 92121-1122 PO BOX 85608, SAN DIEGO, CA 92186-5608 (8581455-3000

Attachment 27 General Atomics Electronic Systems GA/ESI-4482, Enclosure "Affidavit for Withholding"

25402-011 -VI A-HARA-001 92-001 General Atomics HARA Affidavit of Paul G. Berner BECHTEL POWER CORPORATION Job Number:

25402 SUPPLIER DOCUMENT REVIEW STATUS STATUS CODE:

1 [1 Work may proceed. 3 [] Rejected. Revise and resubmit.

IC E5 Work may proceed. Editorial 4 ig Review not required. Work may comments need only be proceed.

incorporated ifrevised for other purposes.

2 EL Revise and resubmit. Work may PO 278595 proceed subject to Incorporation of changes indicated.

Permission to proceed does not cbnstitute acceptance or approval of design details, calculations, analysis, test methods, or materials developed or selected by the Supplier and does not relieve the Supplier from full compliance with contractual obligations.

Reviewed by Arch Civil CS Eledt' Mech MET PD Constr Startup STE At11:4 AIA /a lv )v# X.

Dl/AT /A .4/ /A Status By: DATE

- a~e Tre"~(e tKliJ~ f17h/l I ,,,

LEGIBILITY EVALUATED AND ACCEPTED FOR ISSUE. ALL PAGES.

SIGNATURE-. 7^ne iarngs 7ýr./t DATE: /n!]

25402-011 -VI A-HARA-00192-001 General Atomics HARA Affidavit of Paul G. Berner Enclosure to GAIGA-ESI Letter No. GA-ESI 4482 Pag STATE OF CALIFORNIA

) ss COUNTY OF SAN DIEGO )

AFFIDAVIT OF PAUL G. BERNER I, Paul G. Berner, Radiation Monitoring Systems Program Director of General Atomics Electronic Systems, Inc., do hereby affirm and state:

(1) I have been delegated the function of reviewing the information sought to be withheld by General Atomics Electronic Systems, Inc. and I am authorized to execute this affidavit on behalf of General Atomics Electronic Systems, Inc.

(2) The affidavit is submitted under the provisions of 10CFR Part 2.390 in order to withhold the enclosed confidential commercial information (as set forth in paragraph 3 following) of General Atomics Electronic Systems, Inc. from public disclosure or publication.

(3) The information sought to be withheld is related to General Atomics Electronic Systems' Radiation Monitoring System (i.e., RM-1000) and is contained in the documents designated as:

04038903-7SP Qualification Basis for 04034101-001 04508905-1SP Qualification Report Supplement The proprietary material in these documents is delineated by "business sensitive" or "trade secret" designation on specific paragraphs and highlighted text, sentence, figure or drawing to which the designation applies.

(4) In making this application for withholding of proprietary information of which it is the owner, General Atomics Electronic Systems, Inc. relies upon the exemption from disclosure set forth is the Freedom of Information Act ("FOIA"), 5 USC Sec. 552.(b)(4) and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10CFR Part 9.17(a)(4) and 2.390(a)(4) for "trade secrets and commercial or financial information obtained from a person and privileged or confidential." The material for which exemption from disclosure is hereby sought is all "confidential commercial information," and some portions also qualify under the narrower definition of "trade secret," within the meanings assigned to those terms for

25402-011 -VI A-HARA-001 92-001 General Atomics HARA Affidavit of Paul G. Berner Enclosure to GAIGA-ESI Letter No. GA-ESI 4482 Pag purposes of FOIA Exemption 4 in, respectively, Critical Mass Eneray Project v.

Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2d1280 (DC Cir. 1983).

(5) Some examples of categories of information which fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by General Atomics Electronic Systems, Inc.'s competitors without license from General Atomics Electronic Systems, Inc. constitutes a competitive economic advantage over other companies;

b. Information which, if used by a competitor, would reduce his or her expenditure of resources or improve his or her competitive position in the design, manufacture, shipment, installation, assurance or quality, or licensing of a similar product.

c. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

(6) The information sought to be withheld is being submitted to the NRC in confidence. The information is of a sort customarily held in confidence, is of a sort customarily held in confidence by General Atomics Electronic Systems, Inc.,

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 General Atomics Electronic Systems, Inc. No public disclosure has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (7) and (8) following.

(7) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within General Atomics Electronic Systems, Inc. is controlled to protect it from unauthorized disclosure.

25402-011-VIA-HARA-00192-001 General Atomics HARA Affidavit of Paul G. Berner Enclosure to GAIGA-ESI Letter No. GA-ESI 4482 Pagp General Atomics Electronic Systems, Inc. competitive advantage will be lost if its competitors are able to use the results of the General Atomics Electronic Systems, Inc.'s experience to normalize or verity 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.

GENERAL ATOMICS ELECTRONIC SYSTEMS, INC.

Paul G. Berner, Radiation Monitoring Systems Program Director Subscribed and sworn to before me on this

/f day of g --j5... ,2011, by Paul G. Berner Proved to me on the basiisatisfactory evidence to be the person o peared before me.

Signature 4-0,4 AA4j,-c_( -

25402-011 -VI A-HARA-001 92-001 General Atomics HARA Affidavit of Paul G. Berner CALIFORNIA ALL-PURPOSE ACKNOWLEDGMENT CIVIL CODE § 1189 50_0ký I

State of California County of SOLO On _t__*0______ before me,L nne-rYviýe_ --

VJeA4t-r-s I Date J -

Here Insert Name and Title of the Officer of Signer(s) personally appeared Pow,ý w Name(s)

Name(s) of Signer(s) who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s)Qaie-subscribed to the within instrument and acknowledged to me that &/she4he- executed the same in mie.'4lei*- authorized capacity(jes), and that by

/herft~eir signature(s) on the instrument the person(*- or the entity upon behalf of which the ILYNNE-M1ARIE VETTERS person(,e acted, executed the instrument.

9-m t COnwnlgsion 0 1919792 DiSoCounty I certify under PENALTY OF PERJURY under the 1$ IRV IjCO:fALBIwjn1.2011 laws of the State of California that the foregoing paragraph is true and correct.

I Place Notary Seat Above OPTIONAL WITNESS my hand and official seal.

Signatureae Signature of Notary Public Though the information below is not requiredby law, it may prove valuable to persons relying on the document and could prevent fraudulent removal and reattachmentof this form to anotherdocument Description of Attached Document Title or Type of Document: -__,(_![j___ _,.

Document Date: " 15-, .16.1 Number of Pages: 3 Signer(s) Other Than Named Above: . A-Capacity(ies) C aimed by Signer(s)

Signer's Name: tX4A G & r- Signer's Name:

Li Corporate Officer - Title(s): Li Corporate Officer - Title(s):

0i Individual RIGHT THUMBPRINT L] Individual R 0ITTU1PI OF SIGNER Li Partner - E] Limited Li General Top of thumb here ELPartner - 0i Limited [] General I Top of thumb here Li Attorney in Fact Li Attorney in Fact Li Trustee Li Trustee Li Guardian or Conservator Li Guardian or Conservator L- Other: Li Other:

Signer Is Representing: Signer Is Representing:

©01Ntnloa AsoaiA- aoaoayr--0SN 7 TEt. IXtem#507 C 2010 National Notary Association - NationalNolary.org 800-US NOTARY (1-WO-876-6827) Item #5907