Letter Sequence Other |
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Initiation
- Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request
- Acceptance
- Supplement, Supplement, Supplement, Supplement, Supplement, Supplement
Results
Other: ML20318A339, ML21021A182, ML21253A001, ML21302A097, ML21302A103, ML21302A107, ML21316A033, ML21316A036, ML21316A037, ML21316A038, ML22067A246
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MONTHYEARML20318A3482020-11-10010 November 2020 Enclosure 4 - Proposed Revision of Affected Technical Specifications Project stage: Request ML20318A3492020-11-10010 November 2020 Enclosure 5 - Affidavit for Proprietary Information Project stage: Request ML20318A3392020-11-10010 November 2020 Afrri LAR for Digital I&C Upgrade Project stage: Other ML20318A3402020-11-10010 November 2020 Explanation of Enclosures Project stage: Request ML20318A3432020-11-10010 November 2020 Enclosure 1c - License Amendment Request for the Upgrade of the Instrumentation and Control System for the Armed Forces Radiobiology Research Institute Triga Reactor - Redacted Project stage: Request ML20318A3462020-11-10010 November 2020 Enclosure 2c - Revised FSAR Chapter 7 - Instrumentation and Control Systems Project stage: Request ML20318A3472020-11-10010 November 2020 Enclosure 3 - Proposed Technical Specifications Changes Project stage: Request ML21021A1822021-01-0808 January 2021 AFRRI-Digital Instrumentation and Control License Amendment Request Non-Acceptance with Opportunity to Supplement Project stage: Other ML21036A3012021-02-0404 February 2021 Enclosure 4: General Atomics - Affidavit Project stage: Request ML21036A3002021-02-0505 February 2021 Enclosure 3: Supplemental Information for the License Amendment Request for the Upgrade of the Instrumentation and Control System for the Armed Forces Radiobiology Research Institute Triga Reactor Project stage: Supplement ML21036A2972021-02-0505 February 2021 Response to NRC 01/08/2021 Letter Re License Amendment Request for Facility Operating License No. R-84 for the Afrri Triga Reactor Docket No. 50-170 Project stage: Request ML21042B8412021-02-11011 February 2021 Transmittal of Proposed Changes to the Technical Specifications in Support of the License Amendment Request for the Digital Instrumentation and Control Upgrade for the Afrri Triga Reactor Project stage: Request ML21042B8422021-02-11011 February 2021 Enclosuproposed Changes to the Technical Specifications in Support of the License Amendment Request for the Digital Instrumentation and Control Upgrade for the Afrri Triga Reactor Project stage: Request ML21053A2672021-02-25025 February 2021 Armed Forces Radiobiology Research Institute Acceptance of the Application for a Llicense Amendment Digital Instrumentation and Control Upgrade Project stage: Acceptance Review ML21316A0372021-04-27027 April 2021 Enclosure 4 - Affidavit for Proprietary Information Project stage: Other ML21253A0012021-09-13013 September 2021 Us Department of Defense Armed Forces Radiology Research Institute - Regulatory Audit Plan for Digital Instrumentation and Control System Upgrade Project stage: Other ML21302A1072021-10-15015 October 2021 Enclosure 4 - Affidavit for Proprietary Information Project stage: Other ML21302A0962021-10-15015 October 2021, 28 October 2021 Afrri LAR for the Digital Instrumentation and Control Upgrade Revision 1 Project stage: Request ML21302A0972021-10-28028 October 2021 Afrri LAR for the Digital Instrumentation and Control Upgrade Revision 1 Project stage: Other ML21302A1032021-10-28028 October 2021 Enclosure 2c - Revision 1 of the Revised FSAR Chapter 7 - Instrumentation and Control Systems - Redacted Project stage: Other ML21302A1062021-10-28028 October 2021 Enclosure 3c - Revision 1 of the Supplemental Information for the License Amendment Request for the Upgrade of the Instrumentation and Control System for the Armed Forces Radiobiology Research Institute Triga Reactor - Redacted Project stage: Supplement ML21302A1002021-10-28028 October 2021 Enclosure 1c - Revision 1 of the License Amendment Request for the Upgrade of the Instrumentation and Control System for the Armed Forces Radiobiology Research Institute Triga Reactor - Redacted Project stage: Request ML21316A0382021-11-0808 November 2021 Enclosure 5 - Errata for Usuhs/Afrri Triga Reactor Control System Functional Requirements Specification (Conceptual) - T3S990001-FRS Rev a Project stage: Other ML21316A0362021-11-0808 November 2021 Enclosure 3 - Usuhs/Afrri Triga Reactor Control System Functional Requirements Specification (Conceptual) - T3S990001-FRS Rev a, Redacted Project stage: Other ML21316A0332021-11-0808 November 2021 Afrri - LAR - Digital IC - Functional Requirement Specification Project stage: Other ML22007A2642022-01-0707 January 2022 Us Dept. of Defense, Uniformed Services Univ. of the Health Sciences - the Armed Forces Radiobiology Research Institute (Afrri) Is Submitting a Supplement to the License Amendment Request for the Digital Instrumentation and Control Upgrade Project stage: Supplement ML22007A2652022-01-0707 January 2022 Armed Forces Radiobiology Research Institute, Responses to Open Items Related to the License Amendment Request for the Upgrade of the Instrumentation and Control System Project stage: Request ML22007A2632022-01-0707 January 2022 Us Dept. of Defense, Uniformed Services Univ. of the Health Sciences - the Armed Forces Radiobiology Research Institute (Afrri) Is Submitting a Supplement to the License Amendment Request for the Digital Instrumentation and Control Upgrade Project stage: Request ML22007A2662022-01-0707 January 2022 Armed Forces Radiobiology Research Institute, Proposed Changes to the Technical Specifications Related to the License Amendment Request for the Upgrade of the Instrumentation and Control System Project stage: Request ML22067A2462022-03-29029 March 2022 Armed Forces Radiobiology Research Institute (Afrri) Digital Instrumentation and Control (I&C) Audit Report Project stage: Other ML22096A2812022-04-0404 April 2022 Uniformed Services Univ. of the Health Sciences, Armed Forces Radiobiology Research Institute (Afrri), Proposed Changes to the Technical Specifications Related to the License Amendment Request for the Upgrade of the Instrumentation and Cont Project stage: Request ML22096A2792022-04-0404 April 2022 Uniformed Services Univ. of the Health Sciences, Armed Forces Radiobiology Research Institute (Afrri), Submittal of Supplement to License Amendment Request for the Digital Instrumentation and Control Upgrade Project stage: Request ML22096A2802022-04-0404 April 2022 Uniformed Services Univ. of the Health Sciences, Armed Forces Radiobiology Research Institute (Afrri), Submittal of Supplement to License Amendment Request for the Digital Instrumentation and Control Upgrade Project stage: Supplement ML22118A8682022-04-28028 April 2022 Armed Forces Radiobiology Research Institute (Afrri) - Supplement to the License Amendment Request for the Digital Instrumentation and Control Upgrade Project stage: Supplement ML22118A8672022-04-28028 April 2022 Armed Forces Radiobiology Research Institute (Afrri) - Supplement to the License Amendment Request for the Digital Instrumentation and Control Upgrade Project stage: Request ML22118A8692022-04-28028 April 2022 Supplemental Information to the License Amendment Request for the Upgrade of the Instrumentation and Control System for the Armed Forces Radiobiology Research Institute Triga Reactor Project stage: Supplement ML22131A3712022-06-27027 June 2022 Armed Forces Radiobiology Research Institute - Issuance of Amendment No. 26 to Renewed Facility Operating License No. R-84 Project stage: Approval 2021-02-04
[Table View] |
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Category:Legal-Affidavit
MONTHYEARML21302A1072021-10-15015 October 2021 Enclosure 4 - Affidavit for Proprietary Information ML21316A0372021-04-27027 April 2021 Enclosure 4 - Affidavit for Proprietary Information ML21036A3012021-02-0404 February 2021 Enclosure 4: General Atomics - Affidavit ML20318A3492020-11-10010 November 2020 Enclosure 5 - Affidavit for Proprietary Information 2021-04-27
[Table view] Category:Letter
MONTHYEARML24185A2502024-07-0202 July 2024 Us Dept. of Defense, Armed Forces Radiobiology Research Institute (Afrri) - Reactor Facility Director Change Appointed Update ML24095A2482024-06-0404 June 2024 Examination Result Letter No. 50-170/OL-24-01, Armed Forces Radiobiological Research Institute ML24095A2472024-05-23023 May 2024 Examination Report Letter No. 50-170/OL-24-01, Armed Forces Radiobiological Research Institute IR 05000170/20232012023-09-26026 September 2023 Armed Forces Radiobiology Research Institute - U.S. Nuclear Regulatory Commission Safety Inspection Report No. 05000170/2023201 ML23163A2262023-08-10010 August 2023 Examination Result Letter No. 50-170/OL-23-01, Armed Forces Radiobiology Research Institute ML23214A1552023-07-13013 July 2023 Uniformed Services University of the Health Sciences - Change of Director at the Uniformed Services University of the Health Sciences (Usuhs), Armed Forces Radiobiology Research Institute (Afrri) in Bethesda, Maryland ML23163A2252023-06-13013 June 2023 Examination Report Letter No. 50-170/OL-23-01, Armed Forces Radiobiology Research Institute ML23040A4612023-05-0404 May 2023 Examination Confirmation Letter No. 50-170-OL-23-01, Armed Forces Radiobiology Research Institute ML23080A0162023-03-10010 March 2023 2022 Annual Operating Report for the Armed Forces Radiobiology Research Institute (Afrri) ML22263A2382022-09-12012 September 2022 Uniformed Services Univ. of the Health Sciences - Letter of Reply to the Event Report No. 54349 IR 05000170/20222012022-08-24024 August 2022 Armed Forces Radiobiology Research Institute - U.S. Nuclear Regulatory Commission Safety Inspection Report No. 05000170/2022201 ML22131A3712022-06-27027 June 2022 Armed Forces Radiobiology Research Institute - Issuance of Amendment No. 26 to Renewed Facility Operating License No. R-84 ML22118A8682022-04-28028 April 2022 Armed Forces Radiobiology Research Institute (Afrri) - Supplement to the License Amendment Request for the Digital Instrumentation and Control Upgrade ML22096A2802022-04-0404 April 2022 Uniformed Services Univ. of the Health Sciences, Armed Forces Radiobiology Research Institute (Afrri), Submittal of Supplement to License Amendment Request for the Digital Instrumentation and Control Upgrade ML22090A1762022-03-31031 March 2022 Submittal of 2021 Annual Operating Report Required by the Technical Specifications for the Armed Forces Radiobiology Research Institute (Afrri) Facility Operating License No. R-84, Docket 50-170 ML22067A2462022-03-29029 March 2022 Armed Forces Radiobiology Research Institute (Afrri) Digital Instrumentation and Control (I&C) Audit Report ML21362A7662022-01-14014 January 2022 Armed Forces Radiobiology Research Institute Routine Inspection Report No. 05000170_2021203 ML22007A2642022-01-0707 January 2022 Us Dept. of Defense, Uniformed Services Univ. of the Health Sciences - the Armed Forces Radiobiology Research Institute (Afrri) Is Submitting a Supplement to the License Amendment Request for the Digital Instrumentation and Control Upgrade ML21327A3812021-12-30030 December 2021 Examination Confirmation Letter No. 50-170/OL-22-01, Armed Forces Radiobiology Research Institute ML21316A0332021-11-0808 November 2021 Afrri - LAR - Digital IC - Functional Requirement Specification ML21302A0972021-10-28028 October 2021 Afrri LAR for the Digital Instrumentation and Control Upgrade Revision 1 ML21270A0672021-10-22022 October 2021 Letter - Armed Forces Radiobiology Research Institute - Exemption from 10 CFR 55.31(a)(5) and 55.45(b) ML21302A1072021-10-15015 October 2021 Enclosure 4 - Affidavit for Proprietary Information ML21285A0252021-10-0707 October 2021 Afrri - RO Licensing Exemption Request Supplemental Information ML21260A1842021-09-17017 September 2021 Us Dept of Defense, Uniformed Services Univ. of the Health - Afrri Exemption Request for Licensing of Reactor Operators ML21253A0012021-09-13013 September 2021 Us Department of Defense Armed Forces Radiology Research Institute - Regulatory Audit Plan for Digital Instrumentation and Control System Upgrade IR 05000170/20212012021-08-24024 August 2021 Armed Forces Radiobiology Research Institute - Nuclear Regulatory Commission Security Inspection Report No. 05000170/2021201 (Public) IR 05000170/20212022021-08-24024 August 2021 Armed Forces Radiobiology Research Institute - U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000170/2021202 ML21138A9092021-05-14014 May 2021 Uniformed Services Univ. of the Health Sciences, Interim Reactor Facility Director Change Update ML21316A0372021-04-27027 April 2021 Enclosure 4 - Affidavit for Proprietary Information ML21089A1212021-03-29029 March 2021 Uniformed Services Univ. of the Health Sciences - 2020 Annual Operating Report ML21053A2672021-02-25025 February 2021 Armed Forces Radiobiology Research Institute Acceptance of the Application for a Llicense Amendment Digital Instrumentation and Control Upgrade ML21042B8412021-02-11011 February 2021 Transmittal of Proposed Changes to the Technical Specifications in Support of the License Amendment Request for the Digital Instrumentation and Control Upgrade for the Afrri Triga Reactor ML21041A1652021-02-10010 February 2021 EA-2020-056, Armed Forces Radiobiology Research Institute, Relaxation Letter ML21036A2972021-02-0505 February 2021 Response to NRC 01/08/2021 Letter Re License Amendment Request for Facility Operating License No. R-84 for the Afrri Triga Reactor Docket No. 50-170 ML24219A1102021-01-28028 January 2021 Afrri Letter to Mr. Wilson NRC Feb 2021 IR 05000170/20202012021-01-14014 January 2021 Armed Forces Radiobiology Research Institute - Nuclear Regulatory Commission Routine and Follow-up Inspection Report No. 05000170/2020201 ML20303A2062020-11-19019 November 2020 Cover Letter to Confirmatory Order and NRC Investigation Report 1-2019-003 to Armed Forces Radiobiology Research Institute (EA-20-056) ML20318A3392020-11-10010 November 2020 Afrri LAR for Digital I&C Upgrade ML20322A0372020-11-0909 November 2020 Signed Consent and Hearing Waiver from Armed Forces Radiobiology Research Institute (EA-20-056) ML20108F5342020-03-30030 March 2020 2019 Annual Operating Report Required by the Technical Specifications for the Armed Forces Radiobiology Research Institute Reactor (License R-84, Docket 50-170) ML20023C3412020-03-0303 March 2020 Armed Forces Radiobiology Research Institute - U.S. Nuclear Regulatory Commission Notice of Violation IR 05000170/20192032019-12-30030 December 2019 Armed Forces Radiobiology Research Institute - U.S. Nuclear Regulatory Commission Reactive Inspection Report 05000170/2019203 ML19357A0622019-12-13013 December 2019 Armed Forces Radiobiology Research Institute (Afrri) - Change in Afrri Licensee (Level I Management), Docket No. 50-170, License R-84 ML19281C3322019-09-0505 September 2019 Appointment of Walter (Dale) Tomlinson as the Reactor Facility Director for the Armed Forces Radiobiology Research Institute (Afrri) Training; Docket 50-170, License R-84 ML19058A3272019-08-14014 August 2019 Armed Forces Radiobiology Research Institute - Issuance of Amendment No. 25 Regarding Changing the Required Qualifications of Reactor Facility Director Per Technical Specification 6.1.3.1.B. and 6.2.5 Audit Frequencies IR 05000170/20192022019-07-17017 July 2019 Armed Forces Radiobiology Research Institute - Nuclear Regulatory Commission Reactive Safety Conscious Work Environment Issue of Concern Follow-Up Interim Inspection Report No. 05000170/2019-202-0004 ML19170A1052019-06-0606 June 2019 Us Dept. of Defense, Armed Forces Radiobiology Research Institute - Reply to Notice of Violation Dated May 10, 2019 ML19087A1272019-03-18018 March 2019 Us Dept. of Defense, Uniformed Services Univ. of the Health Sciences - Submittal of 2018 Annual Operating Report IR 05000170/20192012019-03-14014 March 2019 Armed Forces Radiobiology Research Institute - U.S. Nuclear Regulatory Commission Routine Inspection Report No. 05000170/2019201 2024-07-02
[Table view] |
Text
Enclosure 4 - Available to the Public Affidavit for Proprietary Information
+ GENEIIIIL ATOMll:S' GA/EMS-5084 October 15, 2021 USUHS/AFRRI Attn: Andrew Cook 4301 Jones Bridge Rd, Bldg 42 Bethesda, MD 20814
Subject:
Request by General Atomics to Withhold Certain Information from Public Disclosure under 10CFR2.390
Reference:
Licensing Request for the Armed Forces Radiobiology Research Institute (AFRRI)
TRIGA Reactor Mr. Cook, General Atomics (GA) hereby submits the following documents related to its Instrumentation and Control System in support of licensing requests, planned or pending, with the U.S. Nuclear Regulatory Commission initiated by AFRRI:
License Amendment Request for the Upgrade of the Instrumentation and Control System for the Armed Forces Radiobiology Research Institute TRIGA Reactor- Marked for Redaction License Amendment Request for the Upgrade of the Instrumentation and Control System for the Armed Forces Radiobiology Research Institute TRIGA Reactor -
Redacted Supplemental Information for the License Amendment Request for the Upgrade of the Instrumentation and Control System for the Armed Forces Radiobiology Research Institute TRIGA Reactor- Marked for Redaction Supplemental Information for the License Amendment Request for the Upgrade of the Instrumentation and Control System for the Armed Forces Radiobiology Research Institute TRIGA Reactor - Redacted Proposed Safety Analysis Report Chapter 7 - INSTRUMENTATION AND CONTROL SYSTEMS - Marked for Redaction .
Proposed Safety Analysis Report Chapter 7 - INSTRUMENTATION AND CONTROL SYSTEMS - Redacted The enclosed documents include GA proprietary commercially strategic information which GA has held in confidence, and which is not available through public sources. Accordingly, GA is submitting this document in confidence and, as set forth in the enclosed affidavit of Dr. Jerome Gormley, GA 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.
3550 GENERAL ATOMICS COURT, SAN DIEGO. CA 92121-1122 PO BOX 85608, SAN DIEGO, CA 92186-5608 (858) 455-3000
If you have questions regarding this submittal, please do not hesitate to contact Dr. Gormley at (858) 964-6957 or jerome.gormley@ga.com, or me at (858) 455-2809 or michael.gr an@ga.com.
ael J. Grogan, r. Director Li ensing, Safety and Nuclear Compliance
Enclosures:
- 1) Affidavit of Dr. Gormley
- 2) Copies of documents listed in text 3550 GENERAL ATOMICS COURT, SAN DIEGO, CA 92121-1122 PO BOX 85608, SAN DIEGO, CA 92186-5608 (858) 455-3000
STATE OF CALIFORNIA )
) ss COUNTY OF SAN DIEGO )
AFFIDAVIT OF Jerome Gormley I, Jerome Gormley, Director of Strategic Development, Nuclear Programs of General Atomics, do hereby affirm and state:
(1) I have been delegated the function of reviewing the information sought to be withheld by General Atomics and I am authorized to execute this affidavit on behalf of General Atomics.
(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 from public disclosure orpublication.
(3) The information sought to be withheld is related to General Atomics' Instrumentation and Control System and is contained in the documents designated as:
License Amendment Request for the Upgrade of the Instrumentation and Control System for the Armed Forces Radiobiology Research Institute TAIGA Reactor - Marked for Redaction License Amendment Request for the* Upgrade of the Instrumentation and Control System for the Armed Forces Radiobiology Research Institute TAIGA Reactor - Redacted Supplemental Information for the License Amendment Request for the Upgrade of the Instrumentation and Control System for the Armed Forces Radiobiology Research Institute TAIGA Reactor - Marked for Redaction Supplemental Information for the License Amendment Request for the Upgrade of the Instrumentation and Control System for the Armed Forces Radiobiology Research Institute TAIGA Reactor - Redacted Proposed Safety Analysis Report Chapter 7 - INSTRUMENTATION
- AND CONTROL SYSTEMS - Marked for Redaction Proposed Safety Analysis Report Chapter 7 - INSTRUMENTATION AND CONTROL SYSTEMS - Redacted (4) In making this application for withholding of proprietary information of which it is the owner, General Atomics 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 NRG 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 purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy 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' competitors without license from General Atomics 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 NRG in confidence.
The information is of a sort customarily held in confidence, is of a sort customarily held in confidence by General Atomics, 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. 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 NRG, 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 is controlled to protect it from unauthorized disclosure.
(8) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his designee), and by the Legal Department, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside General Atomics are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements for protecting the information from further disclosure.
(9) The information classified as proprietary was developed and compiled by General Atomics at a significant cost to General Atomics. This information is classified as proprietary because it contains detailed historical data and analytical results not available elsewhere. This information would provide other parties, including competitors, with information from General Atomics technical database and the results of evaluations performed using codes developed by General Atomics. Release of this information would improve a competitor's position without the competitor having to expend similar resources for the development of the database. A substantial effort has been expended by General Atomics to develop this information.
(10) Public disclosure of the information sought to be withheld is likely to cause substantial harm to General Atomics' competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of General Atomics comprehensive research and test reactor nuclear instrumentation technology base, and its commercial value extends beyond the original de,vel- opm.e~t.cost. , . ,. ~ .....
~
t - . ,.
f . ., ;, -
The value of the technology base goes beyond the extensive physical da,tqbq.se *and analytical methodology, and includes development of ,}he *expertise to determine Jnd
- o j,~, *. ('1 >°lft,~' ~!,.).I'~ .'-** * .,.~,~ ~;. * ..,.. ,,\
apply the appropriate evaluation process.
- The research, development, engineering, and analytical costs comprise a substantial investment of time and money by General Atomics.
The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it is clearly substantial.
General Atomics competitive advantage will be lost if its competitors are able to use the results of the General Atomics' exp~rience 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 ormley of Strategic Development, Nuclear A Notary public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accurac , or validit of that document.
Subscribed and sworn to before me on this
\4 day of OC'+/-n be.c '2021, by Jerome Gormley,