ML11341A036

Attachments 38 Through 39, General Atomics-Electronics Systems Inc. Document 04038800, Attachment I White Paper: Qualification of RM-1000 Processors Processors, Revision a (Letter Item 14)

ML11341A036
Person / Time
Site:	Watts Bar
Issue date:	11/30/2011
From:	Tennessee Valley Authority
To:	Office of Nuclear Reactor Regulation
References
04038800, Rev A
Download: ML11341A036 (25)

Text

Attachment 38 Redacted non- proprietary General Atomics-Electronics Systems Inc. document 04038800, Attachment I "White Paper: Qualification of RM-1000 Processors," Revision A (Letter Item 14)

25402-011 -VIA-HARA-00224-001 General Atomics HARA White Paper: Qualification of RM-1000 Processors Attachment I (Redacted)

BECHTEL POWER CORPORATION Job Number:

25402 SUPPLIER DOCUMENT REVIEW STATUS STATUS CODE:

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

1C El Work may proceed. Editorial 4 fZ Review not required. Work may comments need only be proceed.

Incorporated ifrevised for other purposes.

2 Revise and resubmit. Work may PO 77469-77448 proceed subject to incorporation of 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

__ 4 VkA/A51 AiA##/sA #41 AIR Status By: DATE LEGIBILITY EVALUATED AND ACCEPTED FOR ISSUE. ALL PAGES.

SI G NAT URE: Rtsffw yk5 ZDATE :4

111=

25402-011 -VIA-HARA-00224-001 General Atomics HARA White Paper: Qualification of RM-1000 Processors Attachment I (Redacted)

/2/554' PURCHASE PART RECEIVER Date Printed: 7/29/2008 4:32:50 PM GELSCTrROHIC ENERAL ATOMICS SySTEMS IBusiness Senitve PURCHASE ORDER VENDOR ID VENDOR NAME PRODUCT CODE COMMODITY CODE BUYER ORDER DATE REC'D BY 1215541 2 CON015 010-10 04-999 SHARONP 7/22/2008 HECTORJ RECEIVER # LINE # WAREHOUSEJLOCATION/WBS RECEIVED DATE REQUESTOR DELIVER TO SHIP TO 73693 2 MAIN/INSP 7/29/2008 GA-ESI PART # INSP REQ'D REV UM ORDER QTY REC'D QTY TRACE ID MFG NAME MFG PART #

50015790-001 Y EA 10.00 10.00 RM012111 FLTR,ACTIVE,COM & NORM MODE,120VAC,5A QA NOTE CODES: 41 PusiessS-nsit-ive-1 RECEIVING INSPECTION: STOCKROOM:

INSPECTED BY DATE LOCATION ID STOCKED BY DATE INSP 0-7 1Mý6 WORK ORDER SHORTAGE FOR:

WORK ORDER # PIECE # QTY SHORT DUE DATE WAREHOUSE WBS CODE

-- M 25402-011 -V1 A-HARA-00224-001

_ _ __ usines ensitiveJ CERTIFICATE OF CONFORMANCE IBussSensiti certifies that the following products have been manufactured to IPC 610 Class 11 and Sspecifications. This product has been fully tested & inspected, and found to comply with all applic, requirements.

Model:

Date: 07/24/08 Quantity: 10 PIECES Customer Order #: J65719 Isabel Duran Quality Manager GA-ESI The certfcations received have been chocked for accuracy aid completeness INSPECTED BY: (Xnccgdý DATE: o7lno!b*

25402-011 -VI A-HARA-00224-001 BILL OF LADING ii i i iii I Ii I III Iii~ IBusiness Sensitive SHIP TO- SOLD TO;

- -- - -C " EL E c S . -E R' L  ; o ': Ss EL =-

' , z:

. E92123 UN 1i-EGO .,;2. 3 CONTACT NAME: ,ENER_ MICS ELEC -,'S CUSTOMER PO N . 554 SALES ORDER NO. ..c'. - .. 2 PICK LIST DATE .-.. L SHIP VIA UPS IFROM LOCATION: 312 SCHEDULED SHIP: 2.4JLILC PPD & ADD COLLECT

[ORDERING SA: )2090 COORDINATOR: EMIL, LAUDE C USTOMER NO: CCC FR CHG

,-li ANr..! , -i .# -

L r:U.ANTIT'-

. I C. BIN PART I DESCRIPTION NUMBER CODE UW;v! CAD=T-D SC',NED

" .R..C- 1 01. ER, 1: 2-

-1 5-AIrP .1242lk.C /ES

-F ORML.N ID TESTING RE3,IUIFzED

. . E,! OF PICKLIST JUL 2 4 2008 TzUi(., E-, TI:' CALL: HI:IuRS 6EPI:IRE DELIVE' l ~sins ensitive I ~~ p IC Z.,_)=I

04UZ-U-1 V-1A-flAIA-UUZZ4-001

+ OREIT ELECTRONIICS DATA BASE CHANGE REQUEST (DBCR)

SE Part/Drawing Number: _ Q*.1 2_ 00-9 (12 characters)

SECTIONI ,D, ORIGINATOR: DAE 9*-2 CIRCLE: ACTION: ADD/(O PRODUCT. */TIBusinesS Sensitive J?: YES M A I)

IJ PARTIDRAWING NAME:

DESCRIPTION: L.-T %IF,, CoM c4 Nc,(Lm Pto(C , Ian V/c , _5 MANUFACTURER:I SPECIAL TOOILSIPROCEDURE4 REQ'D?: YES ,N7 EXTERNAL/MANUFACTURER'S PART NUMBER:

WHERE USED: MpLwN-") PROJECT: 'PA COMMENTS/JUSTIFICATION: (MO*iFy GJ

_aIJA1 -- - gj=.L.i SECTION 2 TRANSCRIBER: DATE:

DESCRIPTION: ..- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - (40)

REMARKS: (18) UIM: (2)

REMARKS OVERFLOW:....----------- (18)

MFRI:--------------- (10) PIN: ----------------------------------------------------- (35)

MFR2:- (10) PIN: --- -------------------------------------------------- (35)

MFR 3:----------(10) P/N:------------------------------(35)

MFR4:--------------- (10) PIN:-------------------------------------------------------- (35)

MATERIAL: (15)

MATERIAL OVERFLOW: (15)

FINISH: (12) OVERFLOW: __-(12)

CIRCLE PART CODE: SCD SCE ALT OTHER SECION 3E(-

DESIGN ENGINEERING: (NAME) MA ( IV41L'DATE:

-1.

SRCGI BASIC SAFETY RE-QUALIFICATION QUALIFICATION NOTE:

COMPONENT RELATED REQUIRED DOCUMENTS Attach Any Critical EQUIPMENT AFFECTED Characteristics if SRCGI is YES marked YES.

(Form SE01S9 OP-7.3.240)

NO _ __ _ _

DOCUMENT NUMBER:

SECTION 4 QUALITY ASSURANCE Q.A. PURCHASE ORDER NOTES: 1.

• 6 2. L . 3.

APPROVALS DATA ENTRY:

IND. ENGA.. *', DATE: '" .ENTERED BY: DATE: ..o Q.A. C,;ý? Z"U DATE: -i*03- VERIFIED BY:. DATE: T..E'2--

SE0079 (05100)

w 25402-011 -VI A-HARA-U0224-001 PAGE 1OF2 SEE AITACHED FORM SE0159-2B (PAGE 2 OF 2)

REVISION IAl QUALITY CONTROL CRITICAL CHARACTERISTIC ACCEPTANCE PLAN "DBCR & QCI-146" (APPLICABLE DOCUMENTATION REQUIRED)

PART NUMBER: 50015790-001 P.O. #: I -J5.4 ITEM#: 7- RECEIVER#: ________

DESCRIPTION: FILTER, ACTIVE, COMMON & NORMAL MODE. 120 VAC, 5A

('T n- Q7P. lio ~7.

4ZAkN fPI Q1 A. NX iD I

[ ] SAMPLE LOT INSPECTION PER, REQUIREMENTS [X] NP-7218 AND QCI -100 TABLE I [X] 100% INSPECTION AND TEST

[ ]REDUCED [ NORMAL (CRITICAL CHARACTERISTICS) [ I TIGHTENED [ ] SPECIAL NOTE: APPEND ENGINEERING/

QUALITY JUSTIFICATION FOR ANY SAMPLING OF ANY []SERIALIZATION REQUIRED CHARACTERISTIC WHICH IS NOT PER NORMAL TABLE I OF QCI 100.

I. MARKING AND VISUAL P(PASS [ FAIL SERIAL NOJ PASS FAIL CCN SAMPLE LOT

__ _I._

_ __ _ _ _ _ [] [I

2. DIMENSIONAL [4(PASS [ FAIL 2. []

H CCN: \-2 1. *__ 3. [1

3. FUNCTIONAL [1ASS [ IFAIL 4. [] [I CCN: 5. [1 t[

4. MATERIAL [%y4ASS [ I FAIL 6. [ I [I

[1 [1 CCN:

5. OTHER/SPECIAL 8._[ ] [

9. [] ]

INSPECTOR SIGNATURE: - DAT 'CHSERIALIZED RECORDED

_____________DATE: 1 CHARA4CTERISTICS WHEN REQUIRED ABOVE:

W/o #: S/O #:

TEST TECH. SIGNATURE: -flA DATE: I.

WORKORDER #:

3.

"NUCLEAR SAFETY RELATED" Use additional sheets as required SE01I59-2C. 05/99 F:\GROUPSXEVERYONE\BLANKCCP.00-2 F--

25402-011 -VI A-HARA-00224-001 Page I of 1 4 SORRENTO ELECTRONICS 9!4/02 COMMERCIAL GRADE ITEM ENGINEERING EVALUATION SE Part Number: 50015790-001 Technical Evaluation:

This FLTR. ACTIVE.COM & NORM MODE. 120VAC.5A is an active electronic part whose normal function is to suppress noise/transients on AC lines The part is essential to RMS equipment safety function: to limit radiation exposure to the public per IOCFR! 00. and to maintain part form, fit. function & prevent or mitigate the consequences of part failure. Credible failure mode(s): Circuit Failure, and Failure to Actuate has been selected. Critical design &

verification attribute selection. based on the foregoing is given in the CGI Worksheet Equivalency Evaluation:

DETERMINATION OF CRITICAL CHARACTERISTICS Environment Harsh: No Mild: Yes Seismic: Yes Critical Characteristic Acceptable Values Range Physical: General Config (Visual) Per Mfg Catalog Dimensions:L X W X H (inches) Max Mtg Hole (dia.= spacing Nom Business Sensitive Functional:

Freq. Response & Surge Current Current Audit of Mfr.

Capability and Rating Testing and results.

(Ref Mfr. Test Data)

Material: Casing (Visual)

Filled Weight Max Other: marked with Mfr P/N Ref WDS Database Test Lab report Ref Mil STD-220A or equiv insertion loss test and IEEE/ANSI-STD C62.41 surge test Engineer:

Independent Reviewer:

F QA Review:

RucordCeiiler idd SRCGI to WL)SSE 5I2 SE0!54-213

. 1W* 25402-0-1 V11A-NAKR-UUZZ4-UU 4 SORRENTO ELECTRONICS Page I of I COMMERCIAL GRADE ITEM ENGINEERING EVALUATION Date: September 4, 2002 SE Part #: 50015790-001 Customer: Snsi Plant: Salem Unit I & 2 [ýnssSensiti Cust. P.O.4: j Sales Order#: Item: 0010 QUALIFIED APPLICATION Previously Verified?: Yes Top Assembly Tag Numbers Qual Report Qual Type 04230841-001 IRI 1/12 04238925 Environ 04230841-001 IRI 1/12 04238926 Seismic Notes:

Ref. S/O: 0201300 04230841-001 is Control Room Equipment associated with monitor assy. 04231201-001 and qual.

reports qualify both assemblies.

COMMERCIAL GRADE EVALUATION Supplier:

Notes: [B3usinessSestv TECHNICAL EVALUATION Has part been evaluated before?: Yes Significant changes since last evaluation: *Ref. SO 0201300 Part replacement type Like-For-Like?: Yes Alternate: No Technical Evaluation:

Functional Test changed to SE audit of supplier and test data.

Equivalency Evaluation:

Engineer A , Date: X1,91-1 z independent Reviewer

• 1 _ _,_..Date: 7,9/ A .

QA Review -*' i,,,**., - J Date: * /O-el:&

File %% ah Van Number

25402-01 -VIA-HARA-00224-001 COMMERCIAL GRADE WORKSHEET No.:. 5001 72tv 47-Of

1. GE

'Parent Equipment normal function: P-ietX * $ C.W I(-A-L- *..N safety function:. 1bu U M .IO ..

Parent Equipment M.

item normal function: CUeW - S -*

Item credible failure modes: []

J

[ Rupturefracture [ ] Blockage

[ ] Seizure []

[ ] Corrosion/Erosion J

]

[ ] Loss of Properties D9 Circuit failure Failure and Support Parent Equipment Safety Functions:

IL Characteristics Needed to Lower the Probability of a Credible ACCEPTANCE METHODS I CRITICAL DESIGN CHARACTERISTICS EPRI NCIG-07 Method One: Method Two:

(Ref. EPRI - TERI Guide) . cial Inspe tions nd Tests L NCI, RtIM1 I TT T T C E NE N EEEE C S M S S S RI SBM EV P 8 PA T T T T I L I I BU ET S VS C R C E R P C 0 1 STICS IU T E T R HF NA I M*IJ*IC K GL O E OAI E T CI N N NL I P01 4ENT T V1 I(

I R RAI N S FI N E EN N S TO1 S C CA T Rf P E E L A E I IYB LAA C V VS E A IlN T I IIN TNC I N NlSC T E o aG H 0E I .:

I. RECOMMENDED CGI SURVEY ELEMENTS:

-[Y. Survey N/A [ I Performance Test Control II 1)

[ ] Product Identification [ ] Instrument Calibration Control [I

[ ] Attributes Control [ Document Control I I Material Source Control [ ]

SE-0218 (11198)

Business Sensitive I 25402-011 -VI A-HARA-00224-001

lbuinss bes"'ive 25402-011 -VI A-HARA-00224-001

. f, lBusiness SensitiveI OOC8)OL

l enitiveI

~sines 25402-011 -VI A-HARA-00224-001

25402-011 -V1lA-HARA-00224-U00l ENG 15 - Part Database Change Report Status Codes: 0 = Released; 1=OBS; 2=Pre-Released PART: 50015790-001 U/M: EA P/M: P PROD GP: C STATUS: 0

Description:

FLTR,ACTIVECOM & NORM MODE,120VAC,5A CAGE Priority- Mfg Part No. Mfg Company 01 IBusiness SensitiveI REMARK1 REMARK2 Spare: Repairable: Wrk Lead Time: Shelf Life:

S N 14 Catalog Update Catalog Price: Min Buy Oty IBusiness sitive 919/02 1 OC PO Note Codes 64 41 CCAPREV A Entered: 3/8/99 Updated: 9/9/02 Updated By CAVE1TM Part Codes:

NPP SCE ASL SCD ALT SRCG Y DATE 3/12/02 Basic Component N Safety Related: Y Re-Oual Req'd N QC Doc Affect N Document No.

FINISH

-jI MATERIAL: MilitarySpec

-___- - 25402-011-VIA-HARA-00224-001 EXTERNAL SUPPLIER AUDIT CORRESPONDENCES-EA UE R -/DT TO: FRANCES McCORD DATE: 6/4/03 IN REPLY REFER TO FROM: C. M. MILLER CMM:03:39:QA

SUBJECT:

sBusiness Se AUDIT REPORT NUMBER: 02:5021 (FINAL REPORT)

PURPOSE IBusiness Sensitive I The audit was conducted to verify that is effectively implementing a Quality Progr* tat meets the requirements of ISO 9001, as specified by the assigned Quality Level approved by ESI.

SCOPE This was a full scope audit to provide an assessment of the Quality Program adequacy and implementation for manufacturing AC Line Filters to ESI Purchase Orders.

APPLICABLE DOCUMENTS

1. I~O 9001:1994.

2.

I~snessSensitive

SUMMARY

A surve performed September 4, 2002 determined that sat ses was properly implementing a Quality the requirements of ISO 9001 as specified in Program t at their Quality Manual, with three exceptions. One finding and two observations were evident during performance of the audit.

1 of 3 M

25402-011 -VI A-HARA-00224-001 The finding was in the area of Purchasing for failure to evaluate subcontractors on the basis of their ability to meet subcontract requirements. The finding is documented on Corrective Action Request (CAR) 913. See FINDINGS below for details.IBusiness Sensite CAR 913 was closed on 6 4/03 after receiving confirmation that the calibration supplie was evaluated by .

Two observations were also noted during the survey for failure to evaluate previous results using M&TE found out-of-tolerance during the scheduled calibration service and failure to perform the annually scheduled internal audit of the quality system. However, both were previously noted by the recent DNV ISO audit, and will be addressed by ISO audit follow-up. See OBSERVATIONS below for details.

With the closure of CAR 913, can now be given "Approved" status on the ESI Approve Spp is List (ASL).

A TBusiness Sensitive AUDITOR D DATE 6/4/03 C. M. Miller, Lead Auditor PERSONNEL CONTACTED Gary Pasquale, Manager of Quality CONDUCT IBusiness Sensitive I

1. Verified that I their suppliero-T

- had urviej andCARevaluated 913 was closed on 6/4/03.

FINDING IBusiness Sensitive I

1. The finding is documented in CAR 913 for failure to evaluate subcontractors on the basis of their ability to meet subcontract re remnts as s ecified in Section 6 of ISO 9001 and the Para. 3.3, Section 6 of the Quality Manua.requires records of acceptable suppliers and subcontractors to be established and maintained. An evaluation of a supplier of calibration services, has not been per orme 2 of 3

25402-011 -VIA-HARA-00224-001 OBSERVATIONS IBusinessSenitive

1. ISO 9001, Section 11 and j" "

Para. 8.0 require that previous inspection test results be evaluated when M&TE is found to be out-of-calibration.

has failed to perform such evaluations, as note yte recent ISO Audit team as a "Risk Warning" that would be followed up at the next ISO Audit.

2. Section 17 of the Quality Manual requires an internal audit of the overall alit system to be performed twice each year.

• failed to perform the scheduled intern uIt.in Apri 2002, as noted by the recent ISO Audit Team as a "Risk Warning".

m~uiness sensitive FOLLOW-UP CAR 913 was closed on 6/4/03. No further follow-up is required.

This audit is considered OS.

xc: Audit File Number: 02:5021 Purchasing 3 of 3

Attachment 39 General Atomics-Electronics Systems Inc. letter GA-ESI 4500, Request by General Atomics Electronic Systems, Inc. to Withhold Certain Information from Public Disclosure under IOCFR2.390 dated November 18, 2011 (Letter Item 14)

25402-011 -V1 A-HARA-00225-001 General Atomics HARA Affidavit to Withhold Certain Information from Public Disclosure BECHTEL POWER CORPORATION Job Number'.

25402 SUPPLIER DOCUMENT REVIEW STATUS STATUS CODE:

1 F1 Work may proceed. 3 [] Rejected. Revise and resubmit.

1C El Work may proceed. Editorial 4 S] Review not required. Work may comments need only be proceed.

Incorporated ifrevised for other purposes.

2 Revise and resubmit. Work may PO 77469-77448 proceed subject to incorporation of 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

_tatus NIA # &*D A14 AT A04 Status By: DATE

___2C__ -rek7,k4 I - 10, II&

1/Z f z

25402-011 -VIA-HARA-00225-001 General Atomics HARA G Affidavit to Withhold Certain Information from Public Disclosure

+GENERAL ATOMIC'S November 18, 2011 GA/ESI-4500 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 10CFR2.390

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:

04038800 White Paper: Qualification of RM-1000 Processors 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.berneraqa-esi.com, or me at (858) 455-2823 or keith. asmussengcla.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 (858) 455-3000

25402-011 -VI A-HARA-00225-001 General Atomics HARA Affidavit to Withhold Certain Information from Public Disclosure Enclosure to GA/GA-ESI Letter No. GA-ESI 4500 Page 1 of 4 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:

04038800 White paper: Qualification of RM-1000 Processors 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 purposes of FOIA Exemption 4 in, respectively, Critical Mass Enerqy Project v.

25402-011General

-VIA-HARA-00225-001 Atomics HARA Affidavit to Withhold Certain Information from Public Disclosure Enclosure to GA/GA-ESI Letter No. GA-ES1 4500 Page 2 of 4 Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2d 1280 (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.

25402-011General

-VIA-HARA-00225.001 Atomics HARA Affidavit to Withhold Certain Information from Public Disclosure Enclosure to GA/GA-ESI Letter No. GA-ESI 4500 Page 3 of 4 (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 Electronic Systems, Inc. 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 Electronic Systems, Inc. at a significant cost to General Atomics Electronic Systems, Inc. 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 Electronic Systems, Inc. technical database and the results of evaluations performed using codes developed by General Atomics Electronic Systems, Inc. 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 Electronic Systems, Inc. to develop this information.

(10) Public disclosure of the information sought to be withheld is likely to cause substantial harm to General Atomics Electronic Systems, Inc.'s competitive position and foreclose or reduce the availability of profit-making opportunities.

The information is part of General Atomics Electronic Systems, Inc.'s comprehensive radiation monitoring system 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.

The research, development, engineering, and analytical costs comprise a substantial investment of time and money by General Atomics Electronic Systems, Inc.

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.

25402-011 -VI A-HARA-00225-001 General Atomics HARA Affidavit to Withhold Certain Information from Pyblic Disclosure Page 4 0r Enclosure to GANGA-ESI Letter No. GA-ESI 4500 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 State of California County of San Diego On November 18, 2011 before me, Lynne-Marie Vetters, Notary Public personally appeared Paul G.

Berner, who proved to me on the basis of satisfactory evidence to be the person whose name is subscribed to the within instrument and who acknowledged to me that he executed the same in his authorized capacity, and by his signature on the instrument the person, or entity upon behalf of which the person acted, executed the instrument.

I certify under PENALTY of PERJURY under the laws of the state of California that the foregoing paragraph is true and correct.

WITNESS my hand and official seal.

] ,4Z~b* LYNNE-MARIE V;TTERS I V

• Comnilsslon # 191)792 Notary Public - California I (Signature of Notary) Son Diego County

-Mv Comm. Expires Jan 1,2015