DCL-10-030, Diablo Canyon, Units 1 & 2, Review of Topical Report, Process Protection System Replacement Diversity & Defense-in-Depth Assessment

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Diablo Canyon, Units 1 & 2, Review of Topical Report, Process Protection System Replacement Diversity & Defense-in-Depth Assessment
ML101100646
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 04/09/2010
From: Becker J R
Pacific Gas & Electric Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
DCL-10-030
Download: ML101100646 (6)
v • d • e


Text

Enclosure 1 Contains Proprietary Information Pacific Gas and Withhold From Public Disclosure Under 10 CFR 2.390 Electric Company' James R. Becker Site Vice President Diablo Canyon Power Plant Mail Code 104/5/601 P. O. Box 56 Avila Beach, CA 93424 805.545.3462 Internal:

691.3462 Fax: 805.545.6445 April 9, 2010 PG&E Letter DCL-10-030 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Diablo Canyon Units 1 and 2 Docket No. 50-275,.OL-DPR-80 Docket No. 50-323, OL-DPR-82 Review of Diablo Canyon Power Plant Topical Report, Process Protection System Replacement Diversity

& Defense-in-Depth Assessment

References:

1. Letter No. NRC-V10-09-001, J. Polcyn (Invensys) to NRC, "Nuclear Safety-Related Qualification of the Tricon TMR Programmable Logic Controller (PLC) -Update to Qualification Summary Report Submittal and 'Application for Withholding Proprietary Information from Public Disclosure,"'

dated September 9, 2009..2. NRC Standard Review Plan Branch Technical Position 7-19,"Guidance for Evaluation of Diversity and Defense-in-Depth In Digital Computer-Based Instrumentation and Control System,,'Revision 5, dated March 2007.3. PG&E Letter DCL-09-051, "Request to be Considered Pilot Plant for Digital Instrumentation and Controls Interim Staff Guidance, DI&C-ISG-06, 'Task Working Group #6: Licensing Process,"'

dated July 27, 2009.4. NRC Letter from J. E. Dyer, Chief Financial Officer, to James R.Becker, Site Vice President, Diablo Canyon Power Plant, dated October 14, 2009.Dear Commissioners and Staff: Pursuant to Reference 2, Pacific Gas and Electric Company (PG&E) hereby requests approval of the enclosed Diablo Canyon Power Plant (DCPP) Topical Report,,"Process Protection System Replacement Diversity

& Defense-in-Depth Assessment," Revision 0.A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway -Comanche Peak

  • Diablo Canyon
  • Palo Verde. San Onofre
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Document Control Desk PG&E Letter DCL-10-030 April 9, 2010 Page 2 PG&E is currently planning the replacement of the DCPP Eagle 21TM reactor trip system (RTS) and engineered safety features actuation system (ESFAS) in 2014 for Units 1 and 2. PG&E plans to use the Invensys Tricon PLC Version 10 described in Reference 1 and the CS Innovations, LLC, Advanced Logic System for the Eagle 21TM RTS and ESFAS digital based instrumentation and control (I&C)replacement.

As stated in NRC Standard Review Plan Branch Technical Position 7-19 (Reference 2), the Staff requires that the licensee perform a diversity and defense-in-depth assessment of the proposed digital I&C system to demonstrate that vulnerabilities to common-cause failures have been adequately addressed.

In this assessment, the licensee should analyze design basis events (as identified in the Final Safety Analysis Report). The enclosed PG&E Topical Report contains the diversity and defense-in-depth assessment of the proposed Eagle 21TM RTS and ESFAS replacement.

The Topical Report, "Process Protection System Replacement Diversity

&Defense-in-Depth Assessment," Revision 0, contained in Enclosure 1, contains information proprietary to PG&E. Accordingly, Enclosure 2 includes an affidavit signed by PG&E, the owner of the proprietary information.

The affidavit sets forth the basis on which the information 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 PG&E proprietary information be withheld from public disclosure in accordance with 10 CFR 2.390. A nonproprietary version of the Topical Report,"Process Protection System Replacement Diversity

& Defense-in-Depth Assessment," Revision 0, is contained in Enclosure 3.Correspondence with respect to the proprietary aspects of the application for withholding related to the PG&E proprietary information or the PG&E affidavit provided in Enclosure 2 should reference PG&E Letter DCL-10-030 and be addressed to James R. Becker, Vice President, Pacific Gas and Electric Company, Diablo Canyon Power Plant, P. 0. Box 56, Avila Beach, California 93424.In Reference 3, PG&E identified that it intended to submit a License Amendment Request (LAR) for a digital upgrade of the DCPP Eagle 21TM RTS and ESFAS system and requested NRC, consideration of DCPP as a pilot plant for the use of interim staff guidance (ISG) on the licensing of digital instrumentation and control (DI&C) safety systems for operating nuclear plants contained in Digital Instrumentation and Controls Interim Staff Guidance, DI&C-ISG-06, "Task Working Group #6: Licensing Process." The NRC granted PG&E a fee waiver for the LAR in accordance with 10 CFR 170.11 (b) in Reference 4 based on PG&E's commitment that DCPP is the pilot plant for DI&C-ISG-06.

In Reference 3, PG&E identified that it A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

  • Comanche Peak
  • Diablo Canyon
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  • Wolf Creek Document Control Desk PG&E Letter DCL-10-030 April 9, 2010 Page 3 intended to submit the LAR by April 30, 2010, based on the assumed NRC issuance of the initial version of DI&C-ISG-06 in the fall of 2009. The NRC and the Nuclear Energy Institute (NEI) are continuing the development of the initial version of DI&C-ISG-06.

In order for PG&E to prepare the LAR in accordance with the guidance provided in the initial version of DI&C-ISG-06, PG&E currently plans to submit the LAR by May, 2011.The enclosed Topical Report is associated with the future LAR for the digital upgrade of the DCPP Eagle 21TM RTS and ESFAS system and presents advanced technologies that enhance safety.PG&E requests approval of the enclosed Topical Report no later than September 1,2010.PG&E makes no regulatory commitments (as defined by NEI 99-04), in this letter.This letter includes no revisions to existing regulatory commitments.

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

I state under penalty of perjury that the foregoing is true and correct.Executed on April 9, 2010.Sin erely, James R. ecker Site Vice President kjse/4328 SAPN 50271918

Enclosures:

cc: Gary W. Butner, Acting Branch Chief, California Department of Public Health Gordon Clefton, Senior Project Manager, Nuclear Energy Institute Elmo E. Collins, NRC Region IV Bill Kemper, NRC, Chief, Instrumentation and Controls Engineering Branch.Michael S. Peck, NRC, Senior Resident Inspector Diablo Distribution cc/enc: Alan B. Wang, Project Manager, Office of Nuclear Reactor Regulation A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

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  • Wolf Creek Enclosure 2 PG&E Letter DCL-10-030 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION) Docket No. 50-275 In the Matter of ) Facility Operating License PACIFIC GAS AND ELECTRIC COMPANY) No. DPR-80)Diablo Canyon Power Plant ) Docket No. 50-323 Units 1 and 2 ) Facility Operating License_) No. DPR-82 AFFIDAVIT James R. Becker, of lawful age, first being duly sworn upon oath states as follows: (1) I am Site Vice President, of Pacific Gas and Electric Company (PG&E), and as such, I have been specifically delegated the function of reviewing the confidential information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rulemaking proceedings, and am authorized to apply for its withholding on behalf of PG&E.(2) I am making this affidavit in conformance with the provisions of 10 CFR 2.390 of the Commission's regulations and in conjunction with the PG&E application for withholding accompanying this affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by PG&E in designating information as confidential.

(4) Pursuant to the provisions of paragraph (b)(4) of 10 CFR 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.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the nonproprietary versions, only the brackets remain. The information so designated as proprietary is indicated in both versions by means of a lower case letter "a" located as a superscript immediately following the brackets.

This lower case letter refers to the types of information PG&E customarily holds in confidence identified in this affidavit pursuant to 10 CFR 2.390(b)(1).

1 Enclosure 2 PG&E Letter DCL-10-030 (i) The information sought to be withheld from public disclosure is owned and has been held in confidence by PG&E.(ii) The information is of a type customarily held in confidence by PG&E and not customarily disclosed to the public. PG&E has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence.

The application of that system and the substance of that system constitutes PG&E policy and provides the rational basis required.Under that system, information is held in confidence if the unauthorized disclosure, modification, or destruction of this information would adversely impact PG&E or could subject it to legal action and penalties.

Generally, this information is intended for use only within PG&E and access to it is restricted to authorized individuals and entities.

This information is considered confidential because it falls into one the following types: (a) Proprietary information is information in which PG&E has property rights which can be protected via a patent, a copyright, or other legal action as in the case of trade secrets.(b) A trade secret is information that: (1) derives independent economic value, whether actual or potential, from being unknown to the public in general or to persons who can obtain economic value from its disclosure or use, and (2) is the subject of efforts to maintain its secrecy that are reasonable under the circumstances.

Examples include formulas and processes, designs, plans, and strategies, computer software and databases, methods and expertise that produce a desired result in a manner unknown to others in the trade ("know-how"), operational information, customer lists, and market information.(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR 2.390, it is to be received in confidence by the Commission.(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.(v) The confidential information sought to be withheld in this submittal is that which is marked by lower case letter "a" in Topical Report, "Process Protection System Replacement Diversity

& Defense-in-Depth Assessment," Revision' 0, March, 2010.2 Enclosure 2 PG&E Letter DCL-10-030 This information addresses matters which will enable PG&E to license a digital upgrade of the reactor trip system and engineered safety features actuation system.Further, this information has substantial commercial value. It consists of technical design details that support a robust design for a digital upgrade of the reactor trip system and engineered safety features actuation system. Use of the technical design details by a competitor would reduce their expenditure of resources in licensing a similar digital upgrade to the reactor trip system and engineered safety features actuation system.Public disclosure of this confidential information is likely to cause substantial harm to the competitive position of PG&E because it would enable others to use the information to meet NRC requirements for licensing documentation for digital upgrades without purchasing the right to use the information.

The development of the design details for the digital upgrade of the reactor trip system and engineered safety features actuation system is the result of applying the results of many years of experience in an intensive PG&E effort and the expenditure of a considerable sum of money.In order for competitors of PG&E to duplicate this information, similar technical design details would have to be developed and a significant manpower effort, having the requisite talent and experience, would have to be expended.I state under penalty of perjury that the foregoing is true and correct.Executed on April 9, 2010.Sin erely, James .Becker Site Vice President Affidavit on behalf of Pacific Gas and Electric Company.'Affidavit consists of 3 pages total.3

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