Attachment 1 to the Enclosure contains Proprietary ... · Attachment 2 to the Enclosure should reference Invensys Operations Management Affidavit No. 993754-AFF-36T and be addressed

Attachment 1 to the Enclosure contains Proprietary Information - Withhold Under 10 CFR 2.390

Pacific Gas and Electric Company®

April 30, 2012

PG&E Letter DCL-12-039

James R. Becker Site Vice President

Diablo Canyon Power Plant Mail Code 104/6 P. O. Box 56 Avila Beach, CA 93424

805.545.3462 Internal: 691. 3462 Fax: 805.545.6445

10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Submittal of V1 0 Tricon Time Response Calculation for the License Amendment Request for Digital Process Protection System Replacement

References: 1. PG&E Letter DCL-11-104, "License Amendment Request 11-07, Process Protection System Replacement," dated October 26,2011.

2. NRC Letter "Diablo Canyon Power Plant, Unit Nos. 1 and 2 ~ Acceptance Review of License Amendment Request for Digital Process Protection System Replacement (TAC Nos. ME7522 and ME7523)," dated January 13, 2012.

3. PG&E Letter DCL-12-030, "Response to Items Contained in NRC Acceptance Review of License Amendment Request for Digital Process Protection System Replacement," dated April 2,2012.

Dear Commissioners and Staff:

In Reference 1, Pacific Gas and Electric (PG&E) submitted License Amendment Request 11-07 to request NRC approval to replace the Diablo Canyon Power Plant Eagle 21 digital process protection system (PPS) with a new digital PPS that is based on the Invensys Operations Management Tricon Programmable Logic Controller, Version 10, and the CS Innovations, LLC (a Westinghouse Electric Company), Advanced Logic System.

In Reference 2, the NRC staff documented its acceptance of Reference 1 for review and requested further clarification be provided for nine items. PG&E's response to the staff's request for further clarification was submitted in Reference 3. In the Reference 3 response for clarification Item 1, PG&E committed to submit the time response calculation for the Invensys Operations Management V1 0 Tricon PPS Replacement architecture. The V1 0 Tricon PPS Replacement architecture time response calculation is contained in Attachment 1 to the Enclosure.

Attachment 1 to the Enclosure contains Proprietary Information When separated from Attachment 1 to the Enclosure, this document is decontrolled .

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance

Callaway • Comanche Peak • Diablo Canyon • Palo Verde • San Onofre • South Texas Project • Wolf Creek


I I Document Control Desk I ~ April 30, 2012


Page 2

The Invensys Operations Management document 993754-1-817, Revision 1, "Maximum TSAP Scan Time", contained in Attachment 1 to the Enclosure contains information proprietary to Invensys Operations Management. Accordingly, Attachment 2 to the Enclosure includes Invensys Operations Management Affidavit No. 993754-AFF-36T. The affidavit is signed by Invensys Operations Management, the owner of the information. The affidavit sets forth the basis on which the I nvensys Operations Management proprietary information contained in I nvensys Operations Management document 993754-1-817, Revision 1, "Maximum TSAP Scan Time" may be withheld from public disclosure by the Commission, and it addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390 of the Commission's regulations. PG&E requests that the I nvensys Operations Management proprietary information be withheld from public disclosure in accordance with 10 CFR 2.390.

Correspondence with respect to the I nvensys Operations Management proprietary information or the Invensys Operations Management affidavit provided in Attachment 2 to the Enclosure should reference Invensys Operations Management Affidavit No. 993754-AFF-36T and be addressed to Roman Shaffer, Project Manager, Invensys Operations Management, 26561 Rancho Parkway South, Lake Forest, CA 92630.

If you have any questions, or require additional information, please contact Tom Baldwin at (805) 545-4720.

This information does not affect the results of the technical evaluation or the significant hazards consideration determination previously transmitted in Reference 1.

This communication does not contain any regulatory commitments (as defined by NEI99-04).

I state under penalty of perjury that the foregoing is true and .correct.

Executed on April 30, 2012.

Sincerely,

~"---"1 James R. Becker Site Vice President





Document Control Desk April 30, 2012 Page 3

kjse/4328 SAPN 50271918 Enclosure cc: Diablo Distribution


cc/enc: Gary W. Butner, Branch Chief, California Department of Public Health Elmo E. Collins, NRC Region IV Michael S. Peck, NRC, Senior Resident Inspector Joseph M. Sebrosky, NRR Project Manager Alan B. Wang, NRR Project Manager





Enclosure PG&E Letter DCL-12-039

PG&E Response to Items Contained in NRC Acceptance Review of License Amendment Request for Digital Process Protection System Replacement

Invensys Operations Management provided detailed information on the deterministic operation of the V1 0 Tricon to address NRC Interim Staff Guidance 06 Enclosure B, Item 1.3, in Invensys Operations Management Letter No. NRC-V1 0-11-001, dated January 5, 2011. In support of the V1 0 Tricon safety evaluation, Invensys Operations Management submitted document 9600164-731, "Maximum Response Time Calculations," describing the worst-case response time for the V1 0 Tricon Qualification System. Included in document 9600164-731 are the standard equations for calculating worst-case response time of a given V10 Tricon configuration.

The time response calculation for the V1 0 Tricon for the Diablo Canyon Power Plant Process Protection System Replacement architecture is contained in Invensys Operations Management document 993754-1-817, Revision 1, "Maximum TSAP Scan Time," contained in Attachment 1 to this Enclosure. As previously stated in PG&E Letter DCL-12-030, "Response to Items Contained in NRC Acceptance Review of License Amendment Request for Digital Process Protection System Replacement," dated April 2, 2012, the Tricon response time will be verified as part of the factory acceptance test (FAT) and the results will be documented in the System Response Time Confirmation Report, 993754-1-818, that will be submitted to the staff as part of the ISG-06 Phase 2 submittals at the completion of FAT for the V10 Tricon PPS Replacement architecture.

1 Attachment 1 to the Enclosure contains Proprietary Information

When separated from Attachment 1 to the Enclosure, this document is decontrolled.


Enclosure Attachment 2


Invensys Operations Management Affidavit No. 993754-AFF-36T for

Invensys Operations Management document 993754-1-817, Revision 1, "Maximum TSAP Scan Time"

Attachment 1 to the Enclosure contains Proprietary Information When separated from Attachment 1 to the Enclosure, this document is decontrolled.

993754-AFF-36T

AFFIDAVIT No. 993754-AFF-36T Re: Request for Withholding from Public Disclosure per 10CFR2.390

STATE OF CALIFORNIA ss

COUNTY OF ORANGE

I, Roman Shaffer, being duly sworn, hereby say and depose:

1. I am the Diablo Canyon PPS Replacement Project Manager for Invensys Operations Management, and as such I have been specifically delegated the function of reviewing company proprietary information sought to be withheld from public disclosure in connection with nuclear IE qualification and application of the TRICON Programmable Logic Controller (PLC) and am authorized to apply for its withholding on behalf of the Nuclear Delivery Unit of Invensys Operations Management.

2. The information sought to be withheld is contained in the document(s) described below:

(1) Maximum TSAP Scan Time, 993754-1-817, Rev 1

The indicated document contains information considered to be proprietary. Proprietary material in the enclosed document is indicated by brackets [ ] or other similar markings as required by IOCFR2.390(b)(1)(i)(B). A Non-proprietary version of the document is not being provided, due to the predominantly proprietary content.

This information is associated with the Diablo Canyon Power Plant (DCPP) Process Protection System Replacement Project, which incorporates Invensys Operations Management TRICON systems and delegated digital application project integration services. This will allow the NRC to verify compliance with current regulatory requirements for certain Invensys Operations Management activities in support of the DCPP PPS Replacement Project.

3. I am making this affidavit in confonnance with the provisions of I OCFR Part 2.390 of the Commission's regulations and in conjunction with the Invensys Operations Management application for withholding accompanying this affidavit.

4. I have personal knowledge of the criteria and procedures utilized by the Nuclear Delivery Unit of Invensys Operations Management in designating information as a trade secret, privileged, or as confidential commercial or financial information. Some examples of categories of information which fit into the definition of proprietary infonnation are:

a) Information which discloses process, method, or apparatus, including supporting data and analyses, where prevention of its use by Invensys Operations Management's competitors without license or contract from Invensys constitutes a competitive economic advantage over other companies in the industry.

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

c) Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of Invensys Operations Management, its customers, its partners, or its suppliers.

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993754-AFF-36T

d) Information which reveals aspects of past, present, or future Invensys Operation Management customer-funded development plans or programs, of potential commercial value to Invensys.

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

t) Information obtained through Invensys Operation Management actions which could reveal additional insights into nuclear equipment qualification processes, customer applications, and regulatory proceedings, and which are not otherwise readily obtainable by a competitor.

Information to be withheld is considered to be proprietary based on 10CFR2.390(a)(4), with consideration of the reasons set forth above.

5. This document describes the details ofa program to qualify Invensys Triconex equipment for IE application, product design details, and/or customer application approaches. Invensys Triconex is the first manufacturer ofa PLC to fully implement the requirements set forth in the EPRI TR-I07330, which has been endorsed by the Commission in an SER. Invensys Triconex has expended a significant amount of money and effort involving numerous contractors over a 10 year time period to develop and implement an ongoing successful approach to its test programs and nuclear applications. Information developed relating to test plans, approaches, equipment, specific problems encountered, licensing perspectives, application approaches, and lessons learned has significant value because of the resources expended to successfully accomplish this process and the usefulness of this knowledge to potential competitors.

Specific data showing compliance with requirements and demonstrating technical capability of the equipment has substantial commercial value because it provides the basis for qualifying Invensys Triconex equipment and implementing safety-related digital upgrades to nuclear plants. Existing options for digital upgrades in the nuclear industry are limited. We believe that ongoing successful 1 E qualification upgrades of the TRICON PLC products and implementation of plant application projects will continue to give Invensys Operations Management a competitive advantage in this field.

Disclosure of information in these documents would cause substantial harm to the competitive position of the Invensys Operations Management, as there are other competing companies who wish to qualify digital PLC controllers and apply them in safety related applications in nuclear power plants. Competing firms could use our experience, successful approaches, and technical information to facilitate their own equipment qualification efforts, application approaches, and/or product design without compensating Invensys Operations Management.

6. Pursuant to the provisions of paragraph (b)( 4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld. (i) The information sought to be withheld from public disclosure is owned and has been held in

confidence by Invensys Operations Management. (ii) The information is of a type customarily held in confidence by Invensys Operations Management

and not customarily disclosed to the public. Invensys Operations Management has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to detennine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitute Invensys Operations Management policy and provide the rational basis required.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10CFR Part 2.390, it is to be received in confidence by the Commission.

(iv) This information is not readily available in public sources. (v) Public disclosure of this proprietary information is likely to cause substantial harm to the

competitive position of Invensys Operations Management because it would enhance the ability of competitors to provide similar design and qualification ofPLC systems and associated applications using similar project methods, equipment, testing approach, contractors, or licensing approaches. As described in section 5, this information is the result of considerable expense to Invensys and has great value in that it will assist Invensys in providing Invensys Triconex digital upgrade equipment and services to a new, expanding markets not currently served by the company.

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993754-AFF-36T

7. The foregoing statements are true and correct to the best of my knowledge, information, and belief.

S worn to and subscribed before me

this I() dayof Apr~ I

,2012

L-MiL~~ }clary Public

Project Manager, DCPP PPS Replacement Project Invensys Operations Management

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State of Cali!O~a r ...... . ~ t >a County of'-:;'~"!""~:-';;.J..~~~--Subscribed and sworn tQ (or affirmed) before n ~~~d§~~ ,20. ' proved to me on the basis of ~tisfactory eVidence to be the py~nw00~r:~ me. S ignature~~ (Seal)

Documents

Attachment 1 to the Enclosure contains Proprietary ... · Attachment 2 to the Enclosure should reference Invensys Operations Management Affidavit No. 993754-AFF-36T and be addressed