Attachment 38

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)
Job Number:
BECHTEL POWER CORPORATION
25402
SUPPLIER DOCUMENT REVIEW STATUS
STATUS CODE:
1
El Work may proceed.
3
[]
Rejected. Revise and resubmit.
1C
El
4
fZ
Review not required. Work may
proceed.
Work may proceed. Editorial
comments need only be
Incorporated ifrevised for other
purposes.
PO 77469-77448
Revise and resubmit. Work may
proceed subject to incorporation of
changes indicated.
2
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
4
CS
VkA/A51
Elect
Mech
MET
PD
DATE
LEGIBILITY EVALUATED AND
ACCEPTED FOR ISSUE. ALL PAGES.
SI G NAT URE:
Rtsffw
yk5 ZDATE
:4
Startup
#41 AIR
AiA##/sA
Status By:
Constr
STE
111=
25402-011 -VIA-HARA-00224-001
General Atomics HARA
White Paper: Qualification of RM-1000 Processors Attachment I (Redacted)
PURCHASE ORDER
VENDOR ID
1215541 2
CON015
RECEIVER #
LINE #
WAREHOUSEJLOCATION/WBS
RECEIVED DATE
73693
2
MAIN/INSP
7/29/2008
PART #
INSP REQ'D
REV
50015790-001
Y
VENDOR NAME
PRODUCT CODE COMMODITY CODE
BUYER
ORDER DATE
REC'D BY
010-10
SHARONP
7/22/2008
HECTORJ
REQUESTOR
DELIVER TO
SHIP TO
RECEIVING INSPECTION:
INSPECTED BY
04-999
GA-ESI
UM
ORDER QTY
REC'D QTY
TRACE ID
EA
10.00
10.00
RM012111
FLTR,ACTIVE,COM & NORM MODE,120VAC,5A
QA NOTE CODES: 41
MFG NAME
MFG PART #
PusiessS-nsit-ive-1
STOCKROOM:
DATE
LOCATION ID
INSP
0-7 1Mý6
WORK ORDER SHORTAGE FOR:
WORK ORDER #
Date Printed: 7/29/2008 4:32:50 PM
PURCHASE PART RECEIVER
IBusiness Senitve
GELSCTrROHIC
ENERAL ATOMICS
SySTEMS
/2/554'
PIECE #
QTY SHORT
DUE DATE
WAREHOUSE
WBS CODE
STOCKED BY
DATE
-- 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
Sspecifications.
This product has been fully tested & inspected,
Class 11 and
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:
DATE:
(Xnccgdý
o7lno!b•
25402-011 -VI A-HARA-00224-001
BILL OF LADING
i i iii
ii
SHIP TO- --
I
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SHIP VIA
SOLD TO;
-E R' L
;
.
E92123
MICS
CONTACT NAME: ,ENER_
PO N
BIN
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EL
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LOCATION: 312
SALES ORDER NO.
..c'.
SCHEDULED SHIP:
2.4JLILC
LAUDE
-
.. 2
C USTOMER
PART I DESCRIPTION
/ES
NUMBER CODE
1 01.
UW;v!
NO: CCC
CAD=T-D
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.-.. L
PICK LIST DATE
FR
,
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PPD & ADD
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COORDINATOR: EMIL,
L
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1i-EGO
554
IFROM
[ORDERING SA: )2090
. I C.
UN
ELEC
UPS
" .R..C-
IBusiness Sensitive
EL E c S .
.
CUSTOMER
Iii~
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JUL 2 4 2008
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~sins
ensitive I
~~
p IC Z.,_)=I
DELIVE'
04UZ-U-1 -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:
CIRCLE: ACTION: ADD/(O
PARTIDRAWING NAME:
L.-T
DESCRIPTION:
MANUFACTURER:I
•/TIBusinesS Sensitive
PRODUCT.
9*-2
DAE
J?: YES
IJ
M A I)
V/c , _5
Nc,(Lm Pto(C , Ian
SPECIAL TOOILSIPROCEDURE4 REQ'D?: YES ,N7
%IF,, CoM c4
EXTERNAL/MANUFACTURER'S PART NUMBER:
MpLwN-")
WHERE USED:
COMMENTS/JUSTIFICATION: (MO•iFy
'PA
gj=.L.i
PROJECT:
-- -
GJ
_aIJA1
-
SECTION 2
DATE:
TRANSCRIBER:
DESCRIPTION: ..-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
(40)
(2)
(18) UIM:
REMARKS:
-
(18)
REMARKS OVERFLOW:....-----------
MFRI:---------------
(10) PIN: -----------------------------------------------------
(35)
MFR2:-
(10) PIN: --- --------------------------------------------------
(35)
P/N:------------------------------(35)
MFR 3:----------(10)
(10) PIN:-------------------------------------------------------(15)
MFR4:--------------MATERIAL:
(15)
MATERIAL OVERFLOW:
FINISH:
CIRCLE PART CODE:
__-(12)
(12) OVERFLOW:
SCD SCE ALT OTHER
SECION 3E(-
DESIGN ENGINEERING: (NAME)
MA
-1.
BASIC
SRCGI
COMPONENT
(
IV41L'DATE:
SAFETY
RELATED
EQUIPMENT
RE-QUALIFICATION
REQUIRED
QUALIFICATION
DOCUMENTS
AFFECTED
YES
NO
(35)
NOTE:
Attach Any Critical
Characteristics if
SRCGI is
marked YES.
(Form SE01S9 OP-7.3.240)
_
_
_
__
DOCUMENT NUMBER:
SECTION 4
QUALITY ASSURANCE
Q.A. PURCHASE ORDER NOTES: 1.
APPROVALS
IND. ENGA..
Q.A. C,;ý?
•',
Z"U
•
6
2.
DATA ENTRY:
BY:
.ENTERED
DATE: '"
VERIFIED BY:.
DATE: -i•03-
L
.
3.
DATE:
DATE:
..o
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#: 7DESCRIPTION: FILTER, ACTIVE, COMMON & NORMAL MODE. 120 VAC, 5A
('T
n- Q7P.
A.
~7.
lio
4ZAkN fPI Q1
RECEIVER#:
________
NX iD I
[ ] SAMPLE LOT INSPECTION PER,
REQUIREMENTS
[X]
NP-7218 AND QCI -100 TABLE I
[ ]REDUCED
[
NORMAL
[ ] SPECIAL
[ I TIGHTENED
NOTE: APPEND ENGINEERING/
QUALITY JUSTIFICATION FOR ANY
SAMPLING OF ANY
CHARACTERISTIC WHICH IS NOT
PER NORMAL TABLE I OF QCI 100.
(CRITICAL CHARACTERISTICS)
I. MARKING AND VISUAL
__
__
__
P(PASS
__
__
__
__
2. DIMENSIONAL
_I._
_
[
SERIAL NOJ
SAMPLE LOT
PASS
_ _ _ _
CCN: \-2
[1ASS
[
1.
FAIL
•__
[ IFAIL
CCN:
4. MATERIAL
[]SERIALIZATION REQUIRED
__
[4(PASS
3. FUNCTIONAL
FAIL
[X] 100% INSPECTION AND TEST
[%y4ASS
[ I FAIL
FAIL
[]
CCN
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3.
[1
4.
[]
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5.
[1
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6.
[ I
[1
[I
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[
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CCN:
5. OTHER/SPECIAL
8._[
9.
INSPECTOR SIGNATURE:
-
DAT
_____________DATE:
W/o #:
'CHSERIALIZED
1
[]
RECORDED
CHARA4CTERISTICS
WHEN REQUIRED ABOVE:
S/O #:
TEST TECH. SIGNATURE: -flA
DATE:
I.
WORKORDER #:
3.
SE01I59-2C. 05/99
F--
"NUCLEAR SAFETY RELATED"
F:\GROUPSXEVERYONE\BLANKCCP.00-2
Use additional sheets as required
]
25402-011 -VI A-HARA-00224-001
4
Page I of 1
9!4/02
SORRENTO ELECTRONICS
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
Critical Characteristic
General Config (Visual)
Physical:
Dimensions:L X W X H (inches)
spacing
Mtg Hole (dia.=
Mild: Yes
Seismic: Yes
Range
Acceptable Values
Per Mfg Catalog
Max
Nom
Business Sensitive
Functional:
Freq. Response & Surge Current
Capability and Rating
(Ref Mfr. Test Data)
Casing (Visual)
Material:
Current Audit of Mfr.
Testing and results.
Filled
Max
Weight
Other: marked with Mfr P/N
Test Lab report Ref Mil STD-220A
or equiv insertion loss test and
IEEE/ANSI-STD C62.41 surge test
Ref WDS Database
Engineer:
Independent Reviewer:
F
QA Review:
RucordCeiiler idd SRCGI to WL)SSE
5I2
SE0!54-213
25402-0-1 -1-V11A-NAKR-UUZZ4-UU
. 1W•
4
SORRENTO ELECTRONICS
Page I of I
COMMERCIAL GRADE ITEM ENGINEERING EVALUATION
Date:
Customer:
50015790-001
Salem Unit I & 2 [ýnssSensiti
SE Part #:
Plant:
September 4, 2002
Snsi
Item:
j Sales Order#:
Cust. P.O.4:
0010
QUALIFIED APPLICATION
Previously Verified?: Yes
Tag Numbers
Top Assembly
IRI 1/12
04230841-001
IRI 1/12
04230841-001
Qual Type
Environ
Seismic
Qual Report
04238925
04238926
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
0201300
Significant changes since last evaluation: *Ref. SO
Like-For-Like?: Yes
Part replacement type
Alternate: No
Technical Evaluation:
Functional Test changed to SE audit of supplier and test data.
Equivalency Evaluation:
Engineer A
,
independent Reviewer
•
1
QA Review
-•' i,,,••.,
el:&
ah Van Number
File %%
_
_,_..Date:
- J
Date:
X1,91-1 z
Date:
7,9/
•
/O-
A
.
25402-01 -VIA-HARA-00224-001
No.:. 5001 72tv 47-Of
COMMERCIAL GRADE WORKSHEET
1.
GE
•..N
$ C.W I(-A-L'Parent Equipment normal function: P-ietX •
..
.IO
M
U
1bu
.
function:
safety
Equipment
Parent
M.
item normal function: CUeW - S -•
Item credible failure modes:
[]
[ ] Blockage
[ Rupturefracture
[]
[ ] Seizure
[ ] Corrosion/Erosion
]
D9 Circuit failure
[ ] Loss of Properties
J
J
Failure and Support Parent Equipment Safety Functions:
IL Characteristics Needed to Lower the Probability of a Credible
ACCEPTANCE METHODS
I
EPRI NCIG-07 Method One:
CRITICAL DESIGN CHARACTERISTICS
Method Two:
L NCI,
cial Inspe tions nd Tests
TT T T C
RtIM1 I
EEEE
NE N
E
M S S S RI
SBM
S
C
EV P 8 PA T T T T I
S
I I BU ET
L
VS C R C E R P C 0 1
HF
IU T E T R
STICS
K
NA I M•IJ•IC
CI
GL O E OAI E T
P01
N N NL I
I(
V1
T
4ENT
RAI N S FI
R
I
EN N S TO1
E
N
Rf
T
CA
C
S
A
E L
E
P
IYB LAA
I
E
VS E A IlN
V
C
TNC
IIN
I
T
T E
NlSC
N
I
H 0E
aG
o
(Ref. EPRI - TERI Guide) .
I .:
I.
RECOMMENDED CGI SURVEY ELEMENTS:
[ I Performance Test Control
-[Y. Survey N/A
[
] Product Identification
[ ] Attributes Control
Material Source Control
SE-0218 (11198)
[
[
] Instrument Calibration Control
Document Control
[
]
II
1)
[I
I I
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
-7----
l
~sines
enitiveI
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
STATUS: 0
FLTR,ACTIVECOM & NORM MODE,120VAC,5A
Description:
CAGE
PROD GP: C
P/M: P
U/M: EA
Priority-
Mfg Part No.
Mfg Company
01
IBusiness SensitiveI
REMARK1
REMARK2
Spare:
Repairable:
Wrk Lead Time:
S
N
14
Catalog Update
Catalog Price:
919/02
Min Buy Oty
Shelf Life:
IBusiness
sitive
1
OC PO Note Codes
41
64
CCAPREV A
Entered:
9/9/02 Updated By CAVE1TM
3/8/99 Updated:
Part Codes:
NPP
SCE
ASL
SCD
ALT
Basic Component N
Safety Related: Y
QC Doc Affect N
Document No.
SRCG Y
DATE
3/12/02
Re-Oual Req'd N
FINISH
MATERIAL:
MilitarySpec
-jI
-___-
25402-011-VIA-HARA-00224-001
-
EA
UE
EXTERNAL SUPPLIER AUDIT CORRESPONDENCESTO:
FRANCES McCORD
FROM:
C.
R
-/DT
DATE: 6/4/03
IN REPLY REFER TO
CMM:03:39:QA
M. MILLER
SUBJECT:-
sBusiness Se
AUDIT REPORT NUMBER:
02:5021
(FINAL REPORT)
IBusiness Sensitive I
PURPOSE
The audit was conducted
effectively
implementing
requirements of ISO 9001,
Level approved by ESI.
to verify that
a
Quality
Progr•
as specified by the
is
tat
meets
the
assigned Quality
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.
2.
I~O 9001:1994.
I~snessSensitive
SUMMARY
A
surve
performed September 4,
2002 determined that
was
properly
implementing
a
Quality
Program
t at
the requirements of ISO 9001 as specified in
their
Quality Manual,
with three
exceptions.
One finding and two
observations were evident during performance of the audit.
sat ses
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,
"Approved" status on the ESI Approve
can now be given
List (ASL).
Spp is
A TBusiness Sensitive
AUDITOR
D
DATE
6/4/03
C. M. Miller, Lead Auditor
PERSONNEL CONTACTED
Gary Pasquale,
Manager of Quality
IBusiness Sensitive I
CONDUCT
1.
Verified that I
their suppliero-T
closed on 6/4/03.
FINDING
1.
-
had
urviej
andCARevaluated
913 was
IBusiness Sensitive I
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
IBusinessSenitive
OBSERVATIONS
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.
This audit is considered
OS.
xc:
No further follow-up
Audit File Number: 02:5021
Purchasing
3 of 3
is
required.
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
Job Number'.
BECHTEL POWER CORPORATION
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
proceed.
comments need only be
Incorporated ifrevised for other
purposes.
2
PO 77469-77448
Revise and resubmit. Work may
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
_tatus
Arch
Civil
CS
Elect
Mech
PD
# &*D
A14
NIA
Status By:
___2C__
MET
Constr
AT
DATE
-rek7,k4
I
1/Z
- 10,
II&
z
f
Startup
STE
A04
G
+GENERAL
25402-011 -VIA-HARA-00225-001
General Atomics HARA
Affidavit to Withhold Certain Information from Public Disclosure
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
Page 1 of 4
Enclosure to GA/GA-ESI Letter No. GA-ESI 4500
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 1OCFR 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.
Enclosure to GANGA-ESI Letter No. GA-ESI 4500
25402-011 -VI A-HARA-00225-001
General Atomics HARA
Affidavit to Withhold Certain Information from Pyblic Disclosure
Page 4 0r
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
V •
Comnilsslon # 191)792
Notary Public - California
(Signature of Notary)
-Mv
Son Diego County
Comm. Expires Jan 1,2015
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