DCL-12-121, Submittal of Revised Phase 1 and 2 Documents for the License Amendment Request for Digital Process Protection System Replacement

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Submittal of Revised Phase 1 and 2 Documents for the License Amendment Request for Digital Process Protection System Replacement
ML12342A149
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 12/05/2012
From: Allen B
Pacific Gas & Electric Co
To:
Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML123420258 List:
References
DCL-12-121
Download: ML12342A149 (17)
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Text

Attachments 2-6 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 Pacific Gas and Electric Company Barry S. Allen Diablo Canyon Power Plant Site Vice President Mail Code 104/6 P. O. Box 56 Avila Beach, CA 93424 805.545.4888 December 5,2012 Internal: 691.4888 Fax: 805.545 .6445 PG&E Letter DCL-12-121 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 Revised Phase 1 and Phase 2 Documents 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 (ADAMS Accession No. ML11307A331).
2. Digital Instrumentation and Controls Digitall&C-ISG-06, "Task Working Group #6: Licensing Process, Interim Staff Guidance,"

Revision 1, January 19, 2011 (ADAMS Accession No. ML110140103).

3. 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.

4. NRC Letter "Diablo Canyon Power Plant, Unit Nos. 1 and 2 - Request For Additional Information Regarding Digital Replacement of the Process Protection System Portion of the Reactor Trip System and Engineered Safety Features Actuation System (TAC NOS. ME7522 AND ME7523)," dated August 7,2012 (ADAMS Accession No. ML12208A364).
5. Westinghouse Letter Number LTR-NRC-11-50, "Submittal of WNA-DS-02442-PGE, Rev. 2, 'Diablo Canyon Units 1 & 2 Process Protection System Replacement Project, Advanced Logic System (ALS) System - Requirements Specification (Proprietary),'" dated September 27, 2011 (ADAMS Accession No. ML11279A160).
6. PG&E Letter DCL-12-050, "Submittal of Phase 2 Documents for the License Amendment Request for Digital Process Protection System Replacement," dated June 6, 2012 (ADAMS Accession No. ML12170A837).

Attachments 2-6 to the Enclosure contain Proprietary Information When separated from Attachments 2-6 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
  • Wolf Cr eek

Attachments 2-6 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 m Document Control Desk PG&E Letter DCL-12-121

~&~ December 5,2012 Page 2

7. PG&E Letter DCL-12-083, "Response to Request for Additional Information on License Amendment Request for Digital Process Protection System Replacement," dated September 11, 2012 (ADAMS Accession No. ML12256A308).

Dear Commissioners and Staff:

In Reference 1, Pacific Gas and Electric (PG&E) submitted License Amendment Request (LAR) 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 (CS Innovations) (a Westinghouse Electric Company), Advanced Logic System (ALS). The LAR format and contents in Reference 1 are consistent with the guidance provided in Enclosure E and Section C.3, respectively, of Digital Instrumentation and Controls (I&C) Revision 1 of Interim Staff Guidance Digital I&C-ISG-06, "Licensing Process," (ISG-06)

(Reference 2). In Reference 3, the NRC staff documented its acceptance of Reference 1 for review and requested further clarification be provided for nine items.

In Reference 3, the staff identified ISG-06 Phase 2 documents in support of LAR 11-07 that need to be submitted, including the CS Innovations ALS seismic qualification test methodology. CS Innovations document "EQ-TP-252-PGE, Revision 0, Seismic Test Procedure for the Line Sense Module (LSM) and Dataforth Isolation Amplifier for Use in Diablo Canyon (Proprietary), dated September 2012," is an ALS seismic qualification test methodology document and is contained in Attachment 2 to the Enclosure.

In Reference 4, Request for Additional Information Number 4, the staff requested an ISG-04 compliance matrix for the ALS platform be submitted. CS Innovations document "6116-00054, Revision 0, Diablo Canyon Process Protection System ISG-04 Matrix," is contained in Attachment 3 to the Enclosure.

The CS Innovations document, "WNA-DS-02442-PGE, Diablo Canyon Units 1 and 2 Process Protection System Replacement Project, Advanced Logic System (ALS)

System Requirements Specification," has been revised from Revision 2 to Revision 3 to incorporate revised seismic requirements. CS Innovations document, "WNA-DS-02442-PGE, Revision 3, Diablo Canyon Units 1 and 2 Process Protection System Replacement Project, Advanced Logic System (ALS) System Requirements Specification, dated July 2012," is contained in Attachment 4 to the Enclosure and supersedes CS Innovations document, "WNA-DS-02442-PGE, Revision 2, Diablo Canyon Units 1 and 2 Process Protection System Replacement Project, Advanced Logic System (ALS) System Requirements Specification, dated September 2011 ,"

which was submitted in Reference 5.

Attachments 2-6 to the Enclosure contain Proprietary Information When separated from Attachments 2-6 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
  • Wolf Creek

Attachments 2-6 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 III Document Control Desk PG&E Letter DCL-12-121

~&~ December 5,2012 Page 3 The CS Innovations document, "6116-00000, Revision 2, Diablo Canyon PPS Management Plan," has been revised to Revision 3 and the document "6116-00003, Revision 0, Diablo Canyon PPS V&V Plan," has been revised to Revision 1 to address staff comments. CS Innovations documents "6116-00000, Revision 3, Diablo Canyon PPS Management Plan," and "6116-00003, Revision 1, Diablo Canyon PPS V&V Plan," are contained in Attachments 5 and 6 to the Enclosure, respectively, and supersede 6116-00000, Revision 2, and 6116-00003, Revision 0, which were submitted in Attachments 13 and 7 of the Enclosure of Reference 6, respectively.

This letter contains CS Innovations documents in Attachments 2 through 6 to the Enclosure with information proprietary to CS Innovations. Accordingly, Attachment 1 to the Enclosure includes a CS Innovations authorization letter, Affidavit AFF6116-00053-4, an accompanying affidavit, a Proprietary Information Notice, and a Copyright Notice. The affidavit is signed by CS Innovations, the owner of the information. The affidavit sets forth the basis on which the CS Innovations proprietary information contained in Attachments 2 through 6 to the Enclosure may be withheld from public disclosure by the NRC, and it addresses with specificity the considerations listed in paragraph (b )(4) of 10 CFR 2.390 of the NRC's regulations.

PG&E requests that the CS Innovations proprietary information be withheld from public disclosure in accordance with 10 CFR 2.390. Correspondence with respect to the copyright or proprietary aspects of the application for withholding related to the CS Innovations proprietary information or the CS Innovations affidavit provided in Attachments 2 through 6 of the Enclosure should reference CS Innovations Affidavit AFF6116-00053-4 and be addressed to Scott Roberts, Director, CS Innovations, LLC, 7400 E Tierra Buena Lane, Suite 101, Scottsdale, AZ 85260-1795.

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 letter satisfies commitment Number 5 of Attachment 1 to the Enclosure of Reference 7.

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

Attachments 2-6 to the Enclosure contain Proprietary Information When separated from Attachments 2-6 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
  • Wolf Creek

Attachments 2-6 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 Docu ment Control Desk PG&E Letter DCL-12-121 December 5,2012 Page 4 I state under penalty of perjury that the foregoing is true and correct.

Executed on December 5,2012.

Sincerely, V5dj s. 4tt--

Barry S. Allen Site Vice President kjse/4328 SAPN 50271918 Enclosure cc: Diablo Distribution cc/enc: Gonzalo L. Perez, Branch Chief, California Department of Public Health Elmo E. Collins, NRC Region IV Thomas R. Hipschman, NRC Senior Resident Inspector Joseph M. Sebrosky, NRR Project Manager Attachments 2-6 to the Enclosure contain Proprietary Information When separated from Attachments 2-6 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
  • Wolf Creek

Attachments 2-6 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 Enclosure PG&E Letter DCL-12-121 Submittal of Revised Phase 1 and Phase 2 Documents for the License Amendment Request for Digital Process Protection System Replacement In Pacific Gas and Electric (PG&E) Letter DCL-11-104, "License Amendment Request 11-07, Process Protection System Replacement," dated October 26,2011, PG&E submitted License Amendment Request (LAR) 11-07 to request NRC approval to replace the Diablo Canyon Power Plant (DCPP) 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 (CS Innovations) (a Westinghouse Electric Company),

Field Programmable Gate Array based Advanced Logic System (ALS). The LAR 11-07 format and contents are consistent with the guidance provided in Enclosure E and Section C.3, respectively, of Digital Instrumentation and Controls (I&C) Revision 1 of Interim Staff Guidance Digital I&C-ISG-06, "Licensing Process" (ISG-06).

The NRC Staff (Staff) documented its acceptance of LAR 11-07 for review in the 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, and requested further clarification be provided for nine items. PG&E's response to the Staff's request for further clarification was submitted 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.

In the NRC letter dated January 13, 2012, the Staff identified ISG 06 Phase 2 documents in support of LAR 11-07 that need to be submitted, including the CS Innovations ALS seismic qualification test methodology. CS Innovations document "EQ TP-252-PGE, Revision 0, Seismic Test Procedure for the Line Sense Module (LSM) and Dataforth Isolation Amplifier for Use in Diablo Canyon (Proprietary),

dated September 2012," is an ALS seismic qualification test methodology document and is contained in Attachment 2 to the Enclosure.

In the NRC Letter "Diablo Canyon Power Plant, Unit Nos. 1 and 2 - Request For Additional Information Regarding Digital Replacement of the Process Protection System Portion of the Reactor Trip System and Engineered Safety Features Actuation System (TAC NOS. ME7522 AND ME7523)," dated August 7,2012, in Request for Additional Information Number 4, the Staff requested an ISG-04 compliance matrix for the ALS platform be submitted. CS Innovations document "6116-00054, Revision 0, Diablo Canyon Process Protection System ISG-04 Matrix,"

is contained in Attachment 3 to the Enclosure.

The CS Innovations document, "WNA-DS-02442-PGE, Diablo Canyon Units 1 and 2 Process Protection System Replacement Project, Advanced Logic System (ALS) 1 Attachments 2-6 to the Enclosure contain Proprietary Information When separated from Attachments 2-6 to the Enclosure, this document is decontrolled .

Attachments 2-6 to the Enclosure con tain Proprieta ry Information - With hold Under 10 CFR 2.390 Enclosure PG&E Letter DCL-12-121 System Requirements Specification," has been revised from Revision 2 to Revision 3 to incorporate revised seismic requirements in Section 2.3.3. The seismic requirements in Section 2.3.3 of WNA-DS-02442-PGE, Revision 2, contained an overly conservative application of a 10 percent margin to values that already included 10 percent margin. CS Innovations document, "WNA-DS-02442-PGE, Revision 3, Diablo Canyon Units 1 and 2 Process Protection System Replacement Project, Advanced Logic System (ALS) System Requirements Specification, dated July 2012," is contained in Attachment 4 to the Enclosure and supersedes CS Innovations document, "WNA-DS-02442-PGE, Revision 2, Diablo Canyon Units 1 and 2 Process Protection System Replacement Project, Advanced Logic System (ALS) System Requirements Specification, dated September 2011,"

which was previously submitted in Westinghouse Letter Number LTR-NRC-11-50, "Submittal of WNA-DS-02442-PGE, Rev. 2, 'Diablo Canyon Units 1 & 2 Process Protection System Replacement Project, Advanced Logic System (ALS) System -

Requirements Specification (Proprietary),'" dated September 27, 2011.

The CS Innovations document, "6116-00000, Revision 2, Diablo Canyon PPS Management Plan," has been revised to Revision 3 and the document "6116-00003, Revision 0, Diablo Canyon PPS V&V Plan," has been revised to Revision 1. The DCPP PPS Management Plan changes include a revision of the description of the project organization to align with the structure contained in the organization structure figure of the Management Plan, additional information on the interface between the independent Verification and Validation (V&V) team and the PPS replacement project, additional information on the role of the Westinghouse Electric Company customer project manager, and additional description of the role and responsibility of the quality assurance manager and the managerial review board. The DCPP PPS V&V Plan changes include identification of the V&V tools used and inclusion of the five activities in IEEE Standard 1012-1998, Annex G, "Optional V&V Tasks" that are considered necessary by Regulatory Guide 1.168. CS Innovations documents "6116-00000, Revision 3, Diablo Canyon PPS Management Plan," and "6116-00003, Revision 1, Diablo Canyon PPS V&V Plan," are contained in Attachments 5 and 6 to the Enclosure, respectively, and supersede 6116-00000, Revision 2, and 6116-00003, Revision 0, which were submitted in Attachments 13 and 7 of the Enclosure of PG&E Letter DCL-12-050, "Submittal of Phase 2 Documents for the License Amendment Request for Digital Process Protection System Replacement,"

dated June 6, 2012, respectively.

ATTACHMENTS

1. CS Innovations Authorization Letter, Affidavit AFF6616-00053-04
2. CS Innovations document "EO TP-252-PGE, Revision 0, Seismic Test Procedure for the Line Sense Module (LSM) and Dataforth Isolation Amplifier for Use in Diablo Canyon" (Proprietary) 2 Attachm ents 2-6 to the Enclosure contain Proprietary Information When separated from Attachments 2-6 to the Enclosure, this document is decontrolled.

Attachm ents 2-6 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 Enclosure PG&E Letter DCL-12-121

3. CS Innovations document "6116-00054, Revision 0, Diablo Canyon Process Protection System ISG-04 Matrix" (Proprietary)
4. CS Innovations document "WNA-DS-02442-PGE, Revision 3, Diablo Canyon Units 1 and 2 Process Protection System Replacement Project, Advanced Logic System (ALS) System Requirements Specification" (Proprietary)
5. CS Innovations document "6116-00000, Revision 3, Diablo Canyon PPS Management Plan" (Proprietary)
6. CS Innovations document "6116-00003, Revision 1, Diablo Canyon PPS V&V Plan" (Proprietary) 3 Attachments 2-6 to the Enclosure contain Proprietary Information When separated from Attachments 2-6 to the Enclosure, this document is decontrolled .

Attachments 2-6 to the Enclos ure con tain Proprietary Information - Withhold Under 10 CFR 2.390 Enclosure Attachment 1 PG&E Letter DCL-12-121 CS Innovations Authorization Letter, Affidavit AFF6616-00053-4 Attachments 2-6 to the Enclosure contain Proprietary Information When separated from Attachments 2-6 to the Enclosure, this document is decontrolled .

+CS Innovations A Westinghouse Electric Company CS Innovations, LLC 7400 E. Tierra Buena Lane, Suite 101 Scottsdale, AZ 85260 November 26, 2012 Phone: 480-567-1100 Affidavit #AFF6116-00053-4 Fax: 480-315-9359 Pacific Gas & Electric Company Ken Schrader Diablo Canyon Power Plant, Bid 104/5/21 A 9 Miles NW of Avila Beach Avila Beach , CA 93424 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE Sub*IJec:t Diablo Canyon Units 1 and 2 Process Protection System Replacement Project Advanced Logic System (ALS) - System WNA-DS-02442-PGE, Rev 3 Requirements Specification Seismic Qualification Test Procedure for the Line Sense Module EQ-TP-252-PGE, Rev 0 (LSM) and Dataforth Isolation Amplifier for Diablo Canyon 6116-00054, Rev 0 Diablo Canyon PPS ISG04 Matrix 6116-00000, Rev 3 Diablo Canyon PPS Management Plan 6116-00003, Rev 1 Diablo Canyon PPS VV Plan

Reference:

Letter from Scott Roberts to PG&E, 6116-00053, dated November 26,2012 The Application for \tVithholding Proprietary Information from Public Disclosure is submitted by CS Innovations, LLC, a wholly-owned subsidiary of Westinghouse Electric Company LLC (Westinghouse),

pursuant to the provisions of paragraph (b)(1) of Section 2.390 of the Commission's regulations. It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.

The proprietary information for which withholding is being requested is contained in the documents identified in the Reference. In conformance with 10 CFR Section 2.390, Affidavit AFF6116-00053-4 accompanies this application for withholding, setting forth the basis on which the identified proprietary information may be withheld from public disclosure.

The documents identified in the Reference were prepared as Proprietary, and CS Innovations requests that they be considered proprietary in their entirety. CS Innovations does not plan to submit non-proprietary versions of these documents due to their extensive proprietary content. Non-proprietary versions would be of no value to the public.

CS Innovations A Westinghouse Electric Company CS Innovations, LLC 7400 E. Tierra Buena Lane, Suite 101 Scottsdale, AZ 85260 November 26, 2012 Phone: 480-567-1100 Affidavit #AFF6116-00053-4 Fax: 480-315-9359 It is respectfully requested that the subject information which is proprietary to CS Innovations be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Correspondence with respect to the proprietary aspects of the application for withholding or the accompanying affidavit should reference AFF6116-00053-4 and should be addressed to Scott Roberts, President, CS Innovations, LLC, 7400 E Tierra Buena Lane, Suite 101, Scottsdale, AZ 85260-1795.

Very truly yours, Scott Roberts, President CS Innovations Enclosures

AFF6116-00053-4 AFFIDAVIT STATE OF ARIZONA:

COUNTY OF MARICOPA:

Before me, the undersigned authority, personally appeared Scott Roberts, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of CS Innovations, LLC, a wholly-owned subsidiary of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

Scott Roberts, President CS Innovations Sworn to and subscribed before me this 26th day of November 2012.

CHRISTM I. 1'HRONDERRY

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2 AFF6116-00053-4 (1) I am President, CS Innovations, LLC, and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of CS Innovations.

(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the CS Innovations Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by CS Innovations in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) 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 CS Innovations.

(ii) The information is of a type customarily held in confidence by CS Innovations and not customarily disclosed to the public. CS Innovations 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 CS Innovations policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

3 AFF6116-00053-4 CS Innovations' competitors without license from CS Innovations constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c ) Its use 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 a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of CS Innovations, its customers or suppliers.

(e) It reveals aspects of past, present, or future CS Innovations or customer funded development plans and programs of potential commercial value to CS Innovations.

(f) It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the CS Innovations system which include the following:

(a) The use of such information by CS Innovations gives CS Innovations a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the CS Innovations competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the CS Innovations ability to sell products and services involving the use of the information.

(c) Use by our competitor would put CS Innovations at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 AFF6116-00053-4 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, anyone component may be the key to the entire puzzle, thereby depriving CS Innovations of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of CS Innovations in the world market, and thereby give a market advantage to the competition of those countries.

(f) The CS Innovations capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 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 proprietary information sought to be withheld in this submittal is that which is contained in the following documents being submitted to the Commission.

1) WNA-DS-02442-PGE, Rev 3, Diablo Canyon Units 1 and 2 Process Protection System Replacement Project Advanced Logic System (ALS) - System Requirements Specification (Proprietary)
2) EQ-TP-252-PGE, Rev 0, Seismic Qualification Test Procedure for the Line Sense Module (LSM) and Dataforth Isolation Amplifier for Diablo Canyon (Proprietary)
3) 6116-00054, Rev 0, Diablo Canyon PPS ISG04 Matrix (Proprietary)
4) 6116-00000, Rev 3, Diablo Canyon PPS Management Plan (Proprietary)
5) 6116-00003, Rev 1, Diablo Canyon PPS VV Plan (Proprietary)

5 AFF6116-00053-4 These documents are being transmitted by CS Innovations letter, 6116-00053, and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by CS Innovations is submitted in support of Pacific Gas & Electric Company's intention to submit a license amendment request for a digital upgrade of the Diablo Canyon Power Plant Reactor Trip System and Engineered Safety Features Actuation System, and may be used only for that purpose.

This information is part of that which will enable CS Innovations to:

(a) Obtain NRC approval of its Advanced Logic System for use in Reactor Trip and Engineered Safety Features Actuation Systems.

Further this information has substantial commercial value as follows:

(a) CS Innovations plans to sell the use of this information to its customers for purposes of obtaining NRC approval of its Advanced Logic System for use in Reactor Trip and Engineered Safety Features Actuation Systems.

(b) CS Innovations can sell support and defense of the use of its Advanced Logic System in safety related applications.

( c) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by CS Innovations.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of CS Innovations because it would enhance the ability of competitors to provide similar engineering services and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

6 AFF6116-00053-4 The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive CS Innovations effort and the expenditure of a considerable sum of money.

In order for competitors of CS Innovations to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith is the proprietary version of documents furnished to the NRC in cOlliiection with requests for generic and/or plant-specific review and approval. The documents are to be considered proprietary in their entirety.

COPYRIGHT NOTICE The documents transmitted herewith bear a CS Innovations copyright notice. CS Innovations is a wholly-owned subsidiary of Westinghouse. The NRC is permitted to make the number of copies of the information contained in these documents which is necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding.

Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

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