ML13092A457
| ML13092A457 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon, PROJ0709  |
| Issue date: | 02/11/2013 |
| From: | Shaffer R Invensys Operations Management |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 993754-53T | |
| Download: ML13092A457 (8) | |
Text
n V'e. n s".ý s Operations Management Invensys Operations Management 26561 Rancho Parkway South Lake Forest, CA 92630 USA iom.invensys.com February 11, 2013 U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, Maryland 20852 Transmittal No. 993754-53T Project:
PPS Replacement Project PG&E PO# 3500897372 Invensys SO# 993754
Reference:
Subject:
- 1) PG&E Letter DCL-1 1-104, from James R. Becker (PG&E) to the Commissioners and Staff of the NRC, dated October 26, 2011 (MLl 1307A331)
- 2) Invensys Operations Management Project Letter 993754-49T, from Roman Shaffer to Mr. Scott Patterson, Pacific Gas & Electric, dated 12/07/2012 Invensys Operations Management Submittal to Support License Amendment Request from PG&E for Replacement of the Eagle 21 Process Protection System at Diablo Canyon Power Plant, Submittal to Support November 2012 NRC Audit
Dear Sir or Madam:
As one of the selected platformn vendors for the Diablo Canyon Power Plant (DCPP) Process Protection System (PPS) Replacement, Invensys Operations Management is pleased to submit the documents listed in the table in Attachment 1 in accordance with DI&C-ISG-06 to support the DCPP License Amendment Request (LAR). The documents were requested by the U.S. Nuclear Regulatory Commission (NRC) during the November 2012 audit of Invensys Operations Management at its facility in Lake Forest, California.
Previously Invensys Operations Management provided proprietary documents to the staff directly through its SharePoint site to assist with the review and close-out of its report for the November 2012 audit (Reference 2). However, as with previous transmittals of project documentation (i.e.,
documents numbered with 993754-xx-xxx), Invensys Operations Management has provided hard copies to Pacific Gas & Electric for subsequent submittal to the staff for placement on the docket for the DCPP LAR review. The staff should have already received those project documents in a separate submittal from Pacific Gas & Electric.
Documents listed in the table in Attachment 1 may be designated with a "P" and/or "NP" suffix.
- A document with the "P" suffix contains proprietary information regarding the V10 Tricon Programmable Logic Controller as well as the processes and procedures utilized by Invensys Operations Management in the development of nuclear safety-related systems. The
--. 1?
Avantis Foxboro SimSci-Esscor Triconex P Lg) 1 Page I of*-;ý
i nV.n sv.'ei so TM Operations Management Transmittal No. 993754-53T corresponding document with a "NP" suffix is the redacted version of the proprietary ("P")
document.
If a document is designated with only a "P" suffix then it contains predominately proprietary information, and therefore Invensys Operations Management does not plan to submit a non-proprietary version because of its limited value to the public.
Because this submittal contains proprietary information from 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 993754-53T and be sent to the Lake Forest, California, address shown above in the letterhead with attention to Mr. Roman Shaffer.
Sincerely, 2Roma~nShaf1Er Project Manager Invensys Operations Management cc:
Mr. Joseph Sebrosky - NRC Project Manager (CDs)
Mr. Kenneth J. Schrader - Pacific Gas & Electric (Letter Only)
Mr. Scott Patterson - Pacific Gas & Electric (Letter Only)
Mr. Mark Herschthal - Invensys - (Letter Only)
Enclosures:
As stated Avantis Foxboro SimSci-Esscor Triconex Page 2 of-3.
Transmittal No. 993754-53T ATTACHMENT 1 Enclosure Listing Enclosure Description CD5*
CD6
[Ref Project flenaine] [size MB] : Affidavit #993754-AFF-53T (for proprietary documents)
X X
[DC049 Affidavit 53Tpdf [1.2] : Invensys DI&C-ISG-06 Documents (Nov 2012 Audit Rept)
Product Discrepancy Report (PDR), IRTX 21105*
X
[DCO5O PDR21105 P.pd] [6.4]
Technical Advisory Bulletin (TAB) 183 X
X
[DCO51TAB183.pdJ] [1.0]
Engineering Project Plan (EPP), V 10.5.2, 9100346-001
- X
[DC052 EPP1052 P.pdqf [0.6]
VI 0.5.2 V&V Test Report, 1/14/2011
- X
[DC053 VVTRIO52 P.pdf] [0. 7]
Software Release Definition (SRD), V 10.5.2, 6200003-226*
X
[DC054 SRDIO52 P.pdj] [0.5]
Product Discrepancy Report (PDR), IRTX 22481*
X
[DC055 PDR22481 P.pd/] [5.2]
Product Alert Notice (PAN) 25 X
X
[DC056 PAN25.pdJ] [1.1]
ARR 932 NSC Evaluation X
[DC057 ARR932 NSCE P.pdf] [1. 0]
Engineering Project Plan (EPP), V 10.5.3, 9100428-001
- X
[DC058 EPPI053 P.pdf] [0. 4]
Tricon PAN 25 Master Test Report, 10/l 2/2011
- X
[DC059 TRPAN25 P.pdl7 [0.5]
Software Release Definition (SRD), V 10.5.3, 6200003-230*
X
[DCO60 SRD1053 P.pd/] [0.5]
Product Alert Notice (PAN) 22 X
X
[DC061 PAN22.pdj] [1.77]
Product Alert Notice (PAN) 24 X
X
[DC062 PAN24.pdf] [1.4]
Technical Advisory Bulletin (TAB) 147 X
X
[DC063_TABI47.pdfl [0.7]
Engineering Project Plan (EPP), TriStation V4.9, 9100359-001
- X
[DC064 EPP490 P.pdf] [0.6]
TriStation V4.9.0 Test Report, 5/16/2011
- X
[DCO65 TS490TR P.pdjl [1.1]
Software Release Definition (SRD), TriStation V4.9.0, 6200097-038*
X
[DC066 SRD490 P.pdj] [0.6]
I.
_ 1
+
I
+
- )
Document contains Invensys proprietary information.
- )
Non-proprietary version of proprietary document.
Document with no asterisk or P/NP notation is fully public (no proprietary infornnation)
Notes:
(a) CD#5 contains Proprietary Documents (among all files). CD#6 contains only Non-Proprietary Documents (publicly available).
(b) Non-proprietary versions of proprietary documents not provided due to predominantly proprietary content.
TRICONEX PRODUCTS PROJECT DOCUMENT TRANSMITTAL TO:
Date: 02/11/2013 Transmittal No.: 993754-53T U.S. Nuclear Regulatory Commission Customer: P G & E 11555 Rockville Pike Sales Order: 993754 Rockville, Maryland 20852 Project Name: PPS Replacement Project ATTN: Document Control Desk ITEMS TRANSMITTED:
Hard Copy /
3 N/A N/A Affidavit #993754-AFF-53T (for proprietary CDs documents)
Hard Copy /
14 N/A N/A Completed Defect CR ID: IRTX#21105 I
CDs Hard Copy /
3 9791006-183 1
Technical Advisory Bulletin # 183 1
CDs Hard Copy /
38 9100346-001 1.4 Tricon V 10.5.2 Engineering Project Plan I
CDs Hard Copy /
23 N/A 1.1 Tricon V I0.5.2 V&V Test Report I
CDs Hard Copy /
26 6200003-226 1.0 Tricon V10.5.2 Release I
CDs Software Release Definition Hard Copy /
I 1 N/A N/A Completed Defect CR ID: IRTX#22481 I
CDs Hard Copy /
3 9791010-025 2
Product Alert Notice #25 - Potential Safety Issue I
CDs Hard Copy /
2 N/A N/A Nuclear Safety Committee Evaluation Form I
CDs ARR 932 / PDR# 22481 Hard Copy /
25 9100428-001 1.2 Tricon PAN 25 Fix Engineering Project Plan I
CDs Hard Copy /
24 N/A 1.0 Tricon PAN25 Master Test Report I
CDs Hard Copy /
17 6200003-230 1.0 Tricon V10.5.3 Software Release Definition I
CDs Hard Copy /
5 9791010-022 3
Product Alert Notice #22 - Potential Safety Issue I
CDs Hard Copy /
4 9791010-024 0
Product Alert Notice #24 - Potential Safety Issue I
CDs Hard Copy/
2 9791006-147 1
Technical Advisory Bulletin #147 I
CDs Hard Copy /
32 9100359-001 1.3 TriStation v4.9.0 and Safety Suite Apps I
CDs Engineering Project Plan Hard Copy /
31 N/A 0.4 TriStation 1131 V4.9.0 Test Report I
CDs Hard Copy /
23 6200097-038 1.2 TriStation 1131 v4.9.0.117 SRD Software I
CDs Release Definition
- R= Review A= Approval CR = Comment Resolution I = Information PPM Form 4-2, Rev. 0
TRICONEX PRODUCTS PROJECT DOCUMENT TRANSMITTAL NOTE: RETURN ON OR BEFORE:
Comments:
ACKNOWLEDGEMENT REQUIRED ()(YN)
N I Project Engineer:
e__
()J*
j/
Date:
/
Please sign below and fax return to:
Triconex Products Fax No.: (949) 638-8875 ATTENTION: Roman Shaffer Received By:
Date:
]
Transmittal 993754-53T (Page 2 of 2)
PPM Form 4-2, Rev. 0
993754-AFF-53T AFFIDAVIT No. 993754-AFF-53T Re: Request for Withholding from Public Disclosure per 10CFR2.390 STATE OF CALIFORNIA
)
) ss COUNTY OF ORANGE
)
I, Michael Kieu, being duly sworn, hereby say and depose:
I.
I am Director of Safety and Critical Control Development at Invensys, 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 the nuclear safety related qualification of the TRICON Programmable Logic Controller (PLC) system and am authorized to apply for its withholding on behalf of Invensys.
- 2.
The information sought to be withheld is contained in the document(s) described below:
(1) Product Discrepancy Report (PDR) 1RTX 21105 (2) Engineering Project Plan (EPP) V10.5.2, 9100346-001 (3) V10.5.2 V&V Test Report, 1/14/2011 (4) Software Release Definition (SRD) V10.5.2, 6200003-226 (5) Product Discrepancy Report (PDR) IRTX 22481 (6) ARR 932 NSC Evaluation, 8/11/2011 (7) Engineering Project Plan (EPP) V1 0.5.3, 9100428-001 (8) Tricon PAN 25 Master Test Report, 10/12/2011 (9) Software Release Definition (SRD) VI10.5.3, 6200003-230 (10) Engineering Project Plan (EPP) TriStation V4. 9, 9100359-001 (11) TriStation V4.9.0 Test Report, 5/16/2011 (12) Software Release Definition (SRD) TriStation V4.9.0, 620009 7-038 The indicated documents contain information considered to be proprietary. Proprietary material in the enclosed documents are indicated by brackets [ ] or other markings as required by 10CFR2.390(b)(I)(i)(B). As indicated in the associated Transmittal letter, non-proprietary versions of the documents may be provided, consistent with their level of proprietary content.
This information is documentation associated with ongoing upgrade and maintenance of qualification of the Tricon PLC and support for a Tricon System customer application project.
- 3.
1 am making this affidavit in conformance with the provisions of IOCFR Part 2.390 of the Commission's regulations and in conjunction with the Invensys Triconex application for withholding accompanying this Affidavit.
- 4.
I have personal knowledge of the criteria and procedures utilized by Invensys 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:
Page I of 3
993754-AFF-53T a)
Information which discloses process, method, or apparatus, including supporting data and analyses, where prevention of its use by Invensys Triconex'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 a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, 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, its customers, its partners, or its suppliers.
d) Information which reveals aspects of past, present, or future Invensys Triconex 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 Triconex actions which could reveal additional insights into Nuclear safety related PLC equipment qualification processes and regulatory proceedings, and which are not otherwise readily obtainable by a competitor.
Information to be withheld is considered to be proprietary based on the reasons set forth in paragraphs 4(a),
(b) and (f) above.
- 5. These documents describe the details of Triconex equipment which has undergone nuclear qualification testing. Product design and development details are also represented. 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 12 year time period to develop and implement an ongoing successful approach to its qualification and test program. Information developed relating to test plans, approaches, equipment, specific problems encountered, licensing perspectives, 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 test data showing compliance with requirements and demonstrating technical capability of the equipment has substantial commercial value because it provides the basis for qualifying Triconex equipment to be sold for safety-related digital upgrades to nuclear plants. Existing options for digital upgrades in the nuclear industry are limited. We believe that ongoing successful nuclear qualification upgrades of the Invensys Triconex products, already well known in non-nuclear applications, will continue to give Invensys a competitive advantage in this field.
Disclosure of information in these documents would cause substantial harm to the competitive position of the Invensys, as there are other competing companies who wish to develop, qualify, and sell digital control systems for safety related application in nuclear power plants. Competing firms could use our experience, successful approaches, and technical information to facilitate their own equipment qualification efforts and/or product design without compensating Invensys.
- 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.
Page 2 of 3
9'3754-AFF-53T (ii)
The information is of a type customarily held in confidence by Invensys and not customarily disclosed to the public. Invensys 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 policy and provide the rational basis required.
(iii)
The information is being transmitted to the Commission in confidence and, under the provisions of I OCFR 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, because it would enhance the ability of competitors to provide similar design of PLC or qualify similar equipment 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 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.
Michael Kieu Director of Safety and Critical Control Development Invensys State of California Subscribed and sworn to (or affirmed) before me on this County of ekAAI4/z.,/1 day of oFp h g.j'
,2013 by Name of Signer El ommission
- 2Co784 proved to me on the basis of satisfactory evidence Notary Public - California z
to be the person who appeared before me.
Orange'County IS M; Comm. Expires Jan 9. 2017j Signature _________________
Signature of Notay Public Place Notary Seal Above Page 3 of 3