NL-15-169, Browns Ferry, Units 1, 2, and 3, General Electric Hitachi Affidavits

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Browns Ferry, Units 1, 2, and 3, General Electric Hitachi Affidavits
ML15282A258
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 09/17/2015
From: Harrison J F, Yandow P M
GE-Hitachi Nuclear Energy Americas
To:
Office of Nuclear Reactor Regulation
Shared Package
ML15282A154 List: ... further results
References
CNL-15-169 NEDC-33824P, Rev 0, NEDC-33860P, Rev 0
Download: ML15282A258 (7)


Text

{{#Wiki_filter:ATTACHMENT 50 General Electric Hitachi Affidavits NEDC-33860P Revision 0 GE-Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, James F. Harrison, state as follows: (1) 1 am Vice President, Fuel Licensing, Regulatory Affairs, GE-Hitachi Nuclear Energy Americas LLC ("GEH"U), 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 GEH proprietary report, NEDC-33860P, Safety Analysis Report for Browns Perry Nuclear Plant Units 1, 2, and 3 Extended Power Uprate, Revision 0, dated September 2015. GEH proprietary information within text is identified by a dotted underline within double square brackets. [[Th.)i~s-..~..t~e~n.c.e..is..a.n.eim.n~p.L.ePJ).] Figures and Large objects containing GEH proprietary information are identified with double square brackets before and after the object. In all cases, 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, iS 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 qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of ECIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission. 975 F2.d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2.d 1280 (DC Cir. 1983).(4) 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 GEH's competitors without license from GEH constitutes a competitive economic advantage over other companies;

b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;c. Information which reveals aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential products to GEH;d. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

NEDC-33860P Revision 0 Affidavit Page 1 of 3 The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. above.(5) To address 10 CER 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 GER, 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 GEl-, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to 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 (6) and (7) following. (6) 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, or subject to the terms under which it was licensed to GEH.(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 agreemen~ts. (8) The information identified in paragraph (2), above, is classified as proprietary because it contains detailed results and conclusions regarding supporting evaluations of the safety-significant changes necessary to demonstrate the regulatory acceptability of the analysis for a GEH Boiling Water Reactor (BWli)y: 'The analysis utilized analytical models and methods, including computer codes, which GEH- has developed, obtained NRC approval of, and applied to perform evaluations of Power Uprates for a GEH BWR. The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GEH asset.The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GEH asset.(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 GElH'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 NEDC-33860P Revision 0 AffidavitPae2o3 Page 2 of 3 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.

GEl-Is competitive advantage will be lost if its competitors are able to use the results of the GEH experience to nongialize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can ah'rive 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 GEl- of the opportunity to. exercise its competitive advantage to seek an adequate return on its large investment in developing and ob~taining these very valuable analytical tools.I declare under penalty of perjury that the foregoing is true and correct.Executed on this 1 7 Ih day of September 2015.James F. Harrison Vice President, Fuel Licensing Regulatory Affairs GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Road Wilmington, NC 28401 James.H Iarrison@ge.eom NEDC-33860P Revision 0 AffidavitPae3o3 Page 3 of 3 GE-Hitachi Nuclear Energy Americas LLC NEDC-33824P Revision 0 Affidavit Page 1 of 3 AFFIDAVIT I, Peter M. Yandow, state as follows:

(1) I am the Vice President, NPP/Services Li censing, Regulatory Affairs, 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 GEH proprietary report NEDC-33824P, "Browns Ferry Replacement Steam Dryer Stress Analysis," Revision 0, dated August 2015. GEH proprietary information in NEDC-33824P is identified by a dotted underline placed within double square brackets. [[This sentence is an example. {3}]]. GEH proprietary information in figures and large objects is identified by double square brackets before and after the object. In all cases, the superscript notation {3} refers to Paragraph (3) of this affidavit, which provide s 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 U.S.C. §552(b)(4), and the Trade Secrets Act, 18 U.S.C. §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 F.2d 871 (D.C. Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F.2d 1280 (D.C. 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 a license from GEH constitutes a competitive economic advantage over other companies; b. Information that, if used by a competitor, would reduce its expenditure of resources or improve its 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; d. Information that discloses trade secret or potentially patentable subject matter for which it may be desirable to obtain patent protection.

GE-Hitachi Nuclear Energy Americas LLC NEDC-33824P Revision 0 Affidavit Page 2 of 3 (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 for proprietary or confidentiality agreements or both 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 unde r which it was licensed to GEH.

(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) 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 an d their application for the design, modification, and analyses methodologies and processes was achieve d 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 ex tensive experience database that constitutes a major GEH asset.

(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. GE-Hitachi Nuclear Energy Americas LLC The research , de ve lopment , engineering, analytical and NRC review costs comprise a substantial investment of time and money by GEH. The precise va lue 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 co mpetiti ve advantage to seek an adequate return on its large investment in developin g and obtaining these very valuable analytical tools. I declare under penalty of perjury that the foregoing is true a nd correct. E xecuted on this 26 1 h day of August 2015. N E D C-3382 4P R evis ion 0 Peter M. Yandow Vice President , NPP/Services Licensing R e gulatory Affairs GE-Hitachi Nuclear E nerg y Americas LLC 3901 Castle Hayne Road , M I C A-75 Wilmington , NC 28401 Peter. Yandow@ge.com Affida v it P age 3 of 3 ATTACHMENT 50 General Electric Hitachi Affidavits NEDC-33860P Revision 0 GE-Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, James F. Harrison, state as follows: (1) 1 am Vice President, Fuel Licensing, Regulatory Affairs, GE-Hitachi Nuclear Energy Americas LLC ("GEH"U), 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 GEH proprietary report, NEDC-33860P, Safety Analysis Report for Browns Perry Nuclear Plant Units 1, 2, and 3 Extended Power Uprate, Revision 0, dated September 2015. GEH proprietary information within text is identified by a dotted underline within double square brackets. [[Th.)i~s-..~..t~e~n.c.e..is..a.n.eim.n~p.L.ePJ).] Figures and Large objects containing GEH proprietary information are identified with double square brackets before and after the object. In all cases, 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, iS 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 qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of ECIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission. 975 F2.d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2.d 1280 (DC Cir. 1983).(4) 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 GEH's competitors without license from GEH constitutes a competitive economic advantage over other companies;

b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;c. Information which reveals aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential products to GEH;d. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

NEDC-33860P Revision 0 Affidavit Page 1 of 3 The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. above.(5) To address 10 CER 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 GER, 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 GEl-, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to 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 (6) and (7) following. (6) 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, or subject to the terms under which it was licensed to GEH.(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 agreemen~ts. (8) The information identified in paragraph (2), above, is classified as proprietary because it contains detailed results and conclusions regarding supporting evaluations of the safety-significant changes necessary to demonstrate the regulatory acceptability of the analysis for a GEH Boiling Water Reactor (BWli)y: 'The analysis utilized analytical models and methods, including computer codes, which GEH- has developed, obtained NRC approval of, and applied to perform evaluations of Power Uprates for a GEH BWR. The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GEH asset.The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GEH asset.(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 GElH'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 NEDC-33860P Revision 0 AffidavitPae2o3 Page 2 of 3 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.

GEl-Is competitive advantage will be lost if its competitors are able to use the results of the GEH experience to nongialize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can ah'rive 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 GEl- of the opportunity to. exercise its competitive advantage to seek an adequate return on its large investment in developing and ob~taining these very valuable analytical tools.I declare under penalty of perjury that the foregoing is true and correct.Executed on this 1 7 Ih day of September 2015.James F. Harrison Vice President, Fuel Licensing Regulatory Affairs GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Road Wilmington, NC 28401 James.H Iarrison@ge.eom NEDC-33860P Revision 0 AffidavitPae3o3 Page 3 of 3 GE-Hitachi Nuclear Energy Americas LLC NEDC-33824P Revision 0 Affidavit Page 1 of 3 AFFIDAVIT I, Peter M. Yandow, state as follows:

(1) I am the Vice President, NPP/Services Li censing, Regulatory Affairs, 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 GEH proprietary report NEDC-33824P, "Browns Ferry Replacement Steam Dryer Stress Analysis," Revision 0, dated August 2015. GEH proprietary information in NEDC-33824P is identified by a dotted underline placed within double square brackets. [[This sentence is an example. {3}]]. GEH proprietary information in figures and large objects is identified by double square brackets before and after the object. In all cases, the superscript notation {3} refers to Paragraph (3) of this affidavit, which provide s 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 U.S.C. §552(b)(4), and the Trade Secrets Act, 18 U.S.C. §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 F.2d 871 (D.C. Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F.2d 1280 (D.C. 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 a license from GEH constitutes a competitive economic advantage over other companies; b. Information that, if used by a competitor, would reduce its expenditure of resources or improve its 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; d. Information that discloses trade secret or potentially patentable subject matter for which it may be desirable to obtain patent protection.

GE-Hitachi Nuclear Energy Americas LLC NEDC-33824P Revision 0 Affidavit Page 2 of 3 (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 for proprietary or confidentiality agreements or both 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 unde r which it was licensed to GEH.

(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) 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 an d their application for the design, modification, and analyses methodologies and processes was achieve d 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 ex tensive experience database that constitutes a major GEH asset.

(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. GE-Hitachi Nuclear Energy Americas LLC The research , de ve lopment , engineering, analytical and NRC review costs comprise a substantial investment of time and money by GEH. The precise va lue 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 co mpetiti ve advantage to seek an adequate return on its large investment in developin g and obtaining these very valuable analytical tools. I declare under penalty of perjury that the foregoing is true a nd correct. E xecuted on this 26 1 h day of August 2015. N E D C-3382 4P R evis ion 0 Peter M. Yandow Vice President , NPP/Services Licensing R e gulatory Affairs GE-Hitachi Nuclear E nerg y Americas LLC 3901 Castle Hayne Road , M I C A-75 Wilmington , NC 28401 Peter. Yandow@ge.com Affida v it P age 3 of 3}}