ML11307A267
| ML11307A267 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/28/2011 |
| From: | Shaffer R Invensys Operations Management |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PG&E PO# 3500897372, SO# 993754 | |
| Download: ML11307A267 (7) | |
Text
n V'e. n s'.. s-o TM Operations Management Transmittal No. 993754-27T Invensys Operations Management 26561 Rancho Parkway South Lake Forest, CA 92630 USA iom.invensys.com October 28, 2011 U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, Maryland 20852 Project:
PPS Replacement Project PG&E PO# 3500897372 Invensys SO# 993754
Reference:
- 1) PG&E Letter DCL-10-030, From James R. Becker (PG&E) to the Chief Financial Officer of the NRC, dated April 9, 2010 (ML101100646)
- 2) Invensys Operations Management Project Letter 993754-26T, From Roman Shaffer to the NRC Document Control Desk, dated October 26, 2011
Subject:
Invensys Operations Management Submittal to Support License Amendment Request fi'om PG&E for Replacement of the Eagle 21 Process Protection System at Diablo Canyon Power Plant
Dear Sir or Madam:
As discussed in referenced letter 1), PG&E intends to submit a License Amendment Request (LAR) to upgrade the existing Eagle 21 Process Protection System (PPS) at Diablo Canyon Power Plant (DCPP) with a digital system based, in part, on the V10 Tricon Triple-Modular-Redundant Programmable Logic Controller (MLl 10140443). Furthermore, the letter indicates that DCPP is the pilot plant for DI&C-ISG-06, the interim staff guidance on performing licensing reviews of LARs involving digital systems and the supporting technical documentation necessary to support the staff's reviews. As one of the selected platform vendors for the PPS upgrade, Invensys Operations Management is pleased to submit the documents listed in the table in Attachment I in accordance with DI&C-ISG-06 to support the DCPP LAR. The enclosed documents will be incorporated by reference in the DCPP LAR from PG&E. Please note that Invensys Operations Management previously submitted documentation to support the DCPP LAR in referenced letter 2).
Any Requests for Additional Information associated with the staff's review of the enclosed documents should be sent to Mr. Tom Baldwin of PG&E. PG&E is responsible for the payment of any NRC review fees associated with the DCPP LAR review. Therefore, Mr. Baldwin is the point of contact for any questions or requests from the staff regarding the enclosed documents.
The documents listed in the table in Attachment 1 are designated with a "P" indicating that they contain proprietary information regarding the V 10 Tricon Programmable Logic Controller as well as Avantis Foxboro SimSci-Esscor Triconex Page 1 of 3
in vle. n s*., so 0
T'M Operations Management Transmittal No. 993754-27T the processes and procedures utilized by Invensys Operations Management in the development of nuclear safety-related systems, the DCPP PPS Replacement in particular. The documents contain predominately proprietary information, and therefore Invensys Operations Management does not plan to submit non-proprietary versions because of their limited value to the public.
Because this submittal contains proprietary information firom Invensys Operations Management, an Application for Withholding Proprietary Information from Public Disclosure is enclosed in compliance with the requirements of 10 CFR Part 2.390, as amended. Also enclosed is an affidavit that sets forth the basis on which the information identified as proprietary may be withheld from public disclosure.
Correspondence with respect to the proprietary aspects of the application for withholding or the Invensys Operations Management affidavit should reference 993754-27T and sent to the Lake Forest, California, address shown above with attention to Mr. Roman Shaffer.
2Sincerel,
/)
Project Manager Invensys Operations Management cc:
Mr. Scott Patterson - Pacific Gas & Electric Mr. Clayton Scott - Invensys - Letter Only Mr. Christopher Wiegand - Invensys - Letter Only Mr. Richard Lilleston - hivensys - Letter Only Mr. Brian Haynes - hivensys - Letter Only
Enclosures:
As stated Avantis Foxboro SimSci-Esscor Triconex Page 2 of 3
I I
Transmittal No. 993754-27T ATTACHMENT 1 Enclosure Listing - CD 3 & 4 Content Enclosure Description CD3
- CD4
[filenatme] [size AB] : - Affidavit #993754-AFF-27T X
X
[DCO25_Affidavit_27Tpdf [1.3] : Invensys DI&C-ISG-06 Documents Software Requirements Specification, PS 1, Rev 0, 903754-11-809 (-P)*
X
[DC026 809 SRSI P.pdffl [1.3]
Software Requirements Specification, PS 2, Rev 0, 903754-12-809 (-P)*
X
[DC027 809 SRS2_P.pdf7 [1.3]
Software Requirements Specification, PS 3, Rev 0, 903754-13-809 (-P)*
X
[DC028 809 SRS3 P.pdqf [1.2]
Software Requirements Specification, PS 4, Rev 0, 903754-14-809 (-P)*
x
[DC029 809 SRS4P.pdfl [1.3]
- )
Document contains Invensys Proprietary material
- ) Non-proprietary version of Proprietary document Document with no asterisk or P/NP notation is fully public (no proprietary information)
Notes:
(a) CD#I contains Proprietary Documents (among all files). CD#2 contains only Non-Proprietary Documents (Publicly Available).
(b) Non-Proprietary versions of the four Software Requirements Specifications not provided due to the predominantly proprietary content.
! TRICONEX PRODUCTS PROJECT DOCUMENT TRANSMITTAL TO:
Date: 10/28/11 U.S. Nuclear Regulatory Commission Transmittal No.: 993754-27T 11555 Rockville Pike Customer: P G & E Rockville, Maryland 20852 Sales Order: 993754 Project Name: PPS Replacement Project ATTN: Document Control Desk ITEMS TRANSMITTED:
Ket S~iie o6T WC-sti%
Hard 3
N/A N/A Affidavit No. 993754-AFF-27T Copy/
CD Hard 161 993754-11-809 0
Software Requirements Specification Protection Copy/
(-P)
Set I CD Hard 158 993754-12-809 0
Software Requirements Specification Protection Copy/
(-P)
Set II CD Hard 138 993754-13-809 0
Software Requirements Specification Protection Copy/
(-P)
Set III CD Hard 143 993754-13-809 0
Software Requirements Specification Protection Copy/
(-P)
Set IV CD I
I I
_III
- R= Review A= Approval CR = Comment Resolution I
Information NOTE: RETURN ON OR BEFORE:
I J/ U Comments:
ACKNOWLEDGEMENT REQUe t(Y/N)
Y Project Engineer:
Date:
Please sign below and fax return to:
Triconex Products Fax No.: (949) 638-8875 ATTENTION: Roman Shaffer Received By:
Date:
PPM Form 4-2,. Rev. 0
993754-AFF-27T AFFIDAVIT No. 993754-AFF-27T Re: Request for Withholding from Public Disclosure per 1 OCFR2.390 STATE OF CALIFORNIA
) ss COUNTY OF ORANGE 1, 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 I E 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) Software Requirements Specification, PS 1, Rev 0, 903 754-11-809 (2) Software Requirements Specification, PS 2, Rev 0, 903 754-12-809 (3) Software Requirements Specification, PS 3, Rev 0, 903 754-13-809 (4) Software Requirements Specification, PS 4, Rev 0, 903 754-14-809 Each of the indicated documents contains information considered to be proprietary. Proprietary material in the enclosed documents are indicated by brackets [ ] or other similar markings as required by 10CFR2.390(b)(I)(i)(B). As indicated in the associated transmittal letter, non-proprietary versions of the documents are 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.
1 am making this affidavit in conformance 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.
1 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 information 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.
Page ] of3
993754-AFF-27T 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.
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.
f)
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 IOCFR2.390(a)(4), with consideration of the reasons set forth above.
- 5.
These documents describe the details of a program to qualify Invensys Triconex equipment for I E application, product design details, and/or customer application approaches. Invensys Triconex is the first manufacturer of a PLC to fully implement the requirements set forth in the EPRI TR-107330, 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 IE 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 determine 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 IOCFR Part 2.390, it is to be received in confidence by the Commission.
(iv)
This information is not readily available in public sources.
Page 2 of 3
993754-AFF-27T (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 of PLC 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.
- 7.
The foregoing statements are true and correct to the best of my knowledge, information, and belief.
Project Manager; DCPP PPS Replacement Project Jnvensys Operations Management Sworn to and subscribed before me thisdayof
.4.
,.2011 UZZIELJ. GUZMAN R ORIGUEZ~
COMMISSION1 1904502 Z
Notary Public - California 2 ORANGE COUNTY T
M'y Comm Expires Sept. 18, 2014 Page 3 of 3