ML13267A129
Text
Attachments 7-9 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. 0. Box 56 Avila Beach, CA 93424 March 7, 2013 805.545.4888 Internal: 691.4888 Fax: 805.545.6445 PG&E Letter DCL-13-016 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 Setpoint Calculations, Setpoint Methodology, and Justification for Application of Technical Specification Changes in WCAP-14333 and WCAP-1 5376 Documents for the License Amendment Request for Digital Process Protection System Replacement
References:
- 1. PG&E Letter DCL-1 1-104, "License Amendment Request 11-07, Process Protection System Replacement," dated October 26, 2011 (ADAMS Accession No. ML11307A331).
- 2. Digital Instrumentation and Controls Digital I&C-ISG-06, "Task Working Group #6: Licensing Process, Interim Staff Guidance,"
Revision 1, January 19, 2011 (ADAMS Accession No. MLI 10140103).
- 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. 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 (ADAMS Accession No. ML12094A072).
- 5. 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).
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 Attachments 7-9 to the Enclosure contain Proprietary Information When.separated from Attachments. 7-9 to the Enclosure, this document is decontrolled.
A member of the STARS (Strategic Teaming and Resource Sharing)
Alliance Caltaway
- Comanche Peak
- Diablo Canyon -
Palo Verde -
San Onofre
- South Texas Project -
Wolf Creek
Attachments 7-9 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 Document Control Desk PG&E Letter DCL-13-016 March 7, 2013 Page 2 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, "Task Working Group #6: 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. PG&E's response to the staffs request for further clarification was submitted in Reference 4.
In Reference 4, PG&E stated that setpoint calculations are being performed by Westinghouse Electric Company LLC (Westinghouse) for the PPS replacement and that the setpoint calculations will be made available for inspection by NRC staff in Washington DC. This letter is submitting the setpoint calculations document, setpoint methodology document, and the document providing justification for application of Technical Specifications Changes in WCAP-14333 and WCAP-1 5376 to the PPS replacement.
The setpoint calculations are contained in Westinghouse document WCAP-1 7696-P, Revision 0, "Westinghouse Setpoint Calculations for the Diablo Canyon Power Plant Digital Replacement Process Protection System," dated January 2013, and are contained in Attachment 7 to the Enclosure. The setpoint calculations satisfy all of the informational requirements set forth in section D.9.4.3.8 of Reference 2 and determine the as-found and as-left tolerances. The setpoint calculations contained in to the Enclosure supersede the setpoint summary evaluation for the PPS replacement related setpoints contained in Westinghouse document, "PGE-12-52 P-Attachment, Westinghouse Input to Diablo Canyon Digital Process Protection System Replacement Uncertainty Calculations Summary LAR," and submitted in Attachments 15 and 16 to the Enclosure of Reference 5. The non-proprietary setpoint calculations are contained in Westinghouse document WCAP-1 7696-NP, Revision 0, "Westinghouse Setpoint Calculations for the Diablo Canyon Power Plant Digital Replacement Process Protection System," dated January 2013, and are contained in Attachment 4 to the Enclosure.
The setpoint calculations contained in Attachment 7 to the Enclosure contain information proprietary to Westinghouse. Accordingly, Attachment 1 to the Enclosure includes a Westinghouse authorization letter, CAW-13-3598, an accompanying affidavit, a Proprietary Information Notice, and a Copyright Notice. The affidavit is signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the Westinghouse proprietary information contained in Attachment 7 to the Enclosure may be withheld from public disclosure by the Commission, and it Attachments 7-9 to the Enclosure contain Proprietary Information When separated from Attachments 7-9 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
Attachments 7-9 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 Document Control Desk PG&E Letter DCL-13-016 March 7, 2013 Page 3 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 Westinghouse 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 Westinghouse proprietary information or the Westinghouse affidavit provided in Attachment 1 to the Enclosure should reference Westinghouse Letter CAW-13-3598, and be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.
The setpoint methodology is contained in Westinghouse document WCAP-1 7706-P, Revision 0, "Westinghouse Setpoint Methodology as Applied to the Diablo Canyon Power Plant", dated January 2013, and is contained in Attachment 8 to the Enclosure.
The non-proprietary setpoint methodology is contained in Westinghouse document WCAP-1 7706-NP, Revision 0, "Westinghouse Setpoint Methodology as Applied to the Diablo Canyon Power Plant", dated January 2013, and is contained in Attachment 5 to the Enclosure.
The setpoint methodology contained in Attachment 8 to the Enclosure contains information proprietary to Westinghouse. Accordingly, Attachment 2 to the Enclosure includes a Westinghouse authorization letter, CAW-13-3599, an accompanying affidavit, a Proprietary Information Notice, and a Copyright Notice. The affidavit is signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the Westinghouse proprietary information contained in Attachment 8 to the Enclosure 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 Westinghouse 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 Westinghouse proprietary information or the Westinghouse affidavit provided in Attachment 2 to the Enclosure should reference Westinghouse Letter CAW-13-3599, and be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.
The document providing justification for application of Technical Specifications Changes in WCAP-14333 and WCAP-1 5376 to the PPS replacement is contained in Westinghouse document LTR-RAM-1-13-002 P-Attachment, "Justification for the Application of Technical Specifications Changes in WCAP-14333 and WCAP-15376 to the Tricon/ALS Process Protection System at the Diablo Canyon Power Plant,"
Revision 0, dated January 31, 2013, and is contained in Attachment 9 to the Enclosure. The non-proprietary justification document is LTR-RAM-1-1 3-002 NP-Attachment, "Justification for the Application of Technical Attachments 7-9 to the Enclosure contain Proprietary Information When separated from Attachments 7-9 to the Enclosure, this document is decontrolled.
A member of the STARS (Strategic Teaming and Resource Sharing)
Alliance Caltaway
- Comanche Peak
- Diablo Canyon
- Palo Verde -
San Onofre -
South Texas Project
- Wolf Creek
Attachments 7-9 to the Enclosure contain Proprietaryinformation -Withhold Under 10 CFR 2.390 Document Control Desk PG&E Letter DCL-13-016 March 7, 2013 Page 4 Specifications Changes in WCAP-14333 and WCAP-1 5376 to the Tricon/ALS Process Protection System at the Diablo Canyon Power Plant", Revision 0, dated January 31, 2013, and is contained in Attachment 6 to the Enclosure.
The document providing justification for application of Technical Specifications Changes in WCAP-14333 and WCAP-1 5376 to the PPS replacement contained in to the Enclosure contains information proprietary to Westinghouse.
Accordingly, Attachment 3 to the Enclosure includes a Westinghouse authorization letter, CAW-13-3596, an accompanying affidavit, a Proprietary Information Notice, and a Copyright Notice. The affidavit is signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the Westinghouse proprietary information contained in Attachment 9 to the Enclosure 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 Westinghouse 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 Westinghouse proprietary information or the Westinghouse affidavit provided in to the Enclosure should reference Westinghouse Letter CAW-13-3596, and be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.
If you have any questions, or require additional information, please contact Tom Baldwin at (805) 545-4720.
This letter satisfies commitment Number 6 of Attachment 3 to the Enclosure of Reference 4.
This communication does not contain regulatory commitments (as defined by NEI 99-04).
I state under penalty of perjury that the foregoing is true and correct.
Executed on March 7, 2013.
Sincerely, Barry S.
7Allen Site Vice President Attachments 7-9 to the Enclosure contain Proprietary Information When separated from Attachments 7-9 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
Attachments, 7-9 to the Enclosure contain Proprietary Infdrrnation - Withhold Under 10 CFR,2.390 Fl Document Control Desk March 7, 2013 Page 5 PG&E Letter DCL-13-016 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 James T. Polickoski, NRR Project Manager Attachments 7-9 to the Enclosure contain Proprietary Information When separated from Attachments 7-9 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
Attachments 7-9 to the E.nclosure contain Proprietary Informatio.n - Withhold Urder 10 CFR 2.390 Enclosure PG&E Letter DCL-13-016 Submittal of Setpoint Calculations, Setpoint Methodology, and Justification for application of Technical Specification Changes in WCAP-14333 and WCAP-1 5376 Documents for the License Amendment Request for Digital Process Protection System Replacement In Pacific Gas and Electric (PG&E) Letter DCL-1 1-104, "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, "Task Working Group
- 6: 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 PG&E Letter DCL-1 2-030, PG&E stated that setpoint calculations are being performed by Westinghouse Electric Company LLC (Westinghouse) for the PPS replacement and that the setpoint calculations will be made available for inspection by Staff in Washington DC. This letter submits the setpoint calculations document, setpoint methodology document, and the document providing justification for application of Technical Specifications Changes in WCAP-14333 and WCAP-15376 to the PPS replacement.
Setpoint Calculations The setpoint calculations are contained in Westinghouse document WCAP-1 7696-P, Revision 0, "Westinghouse Setpoint Calculations for the Diablo Canyon Power Plant Digital Replacement Process Protection System", dated January 2013, and are contained in Attachment 7 to this Enclosure. The setpoint calculations satisfy all of the informational requirements set forth in section D.9.4.3.8 of Digital Instrumentation and Controls Digital I&C-ISG-06, "Task Working Group #6:
Licensing Process, Interim Staff Guidance," Revision 1, dated January 19, 2011.
1
,Attachments 7-9 to the Enclosure contain Proprietary Information When separated-from Attachments 7-9 to the Enclosure, this docurheht is decontrolled.
Attachments 7-9 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 Enclosure PG&E Letter DCL-13-016 The setpoint calculations confirm that an adequate margin exists between operating limits and setpoints, such that there is a low probability for inadvertent actuation of the system and confirm that an adequate margin exists between setpoints and safety limits.
The algorithms used to determine the PPS replacement Technical Specification setpoints, when supported by appropriate plant procedures and equipment qualification, are believed to provide total instrument loop uncertainties, termed channel statistical allowance, at a two-sided 95 percent probability and 95 percent confidence level; as stated in Nuclear Regulatory Commission Regulatory Guide (RG) 1.105, Revision 3, Regulatory Position C.1. In addition, the setpoint calculations determine the as-found and as-left tolerances.
Setpoint Methodology The setpoint methodology is contained in Westinghouse document WCAP-1 7706-P, Revision 0, "Westinghouse Setpoint Methodology as Applied to the Diablo Canyon Power Plant", dated January 2013, and is contained in Attachment 8 to this Enclosure.
The approach used for the methodology is consistent with the American National Standards Institute (ANSI)/ International Society of Automation (ISA) standard ANSI/ISA-67.04.01, "Setpoints for Nuclear Safety-Related Instrumentation," dated May 2006. The basic uncertainty algorithm is the square root sum of the squares (SRSS) of the applicable uncertainty terms, which is endorsed by the standard. All appropriate and applicable uncertainties, as defined by a review of the plant baseline design input documentation, have been included in each PPS related reactor trip system (RTS) or engineered safety features actuation system (ESFAS) function uncertainty calculation.
ISA standard ISA-RP67.04.02, "Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation," dated December 2010, was considered, as a general guideline, but each uncertainty and its treatment is based on Westinghouse methods which are consistent or conservative with respect to this document. The current version of NRC RG 1.105, Revision 3, endorses the 1994 version of ISA standard ISA-S67.04, Part I. Westinghouse has evaluated this NRC document and has determined that the uncertainty algorithms contained in the setpoint calculations are consistent with the guidance contained in RG 1.105, Revision 3 and NRC Branch Technical Position 7-12, "Guidance on Establishing and Maintaining Instrument Setpoints," Revision 5, dated March 2007.
2 Attachments 7-9 to the Enclosure contain Proprietary Information When separated from Attachments 7-9 to the Enclosure, this document is decontrolled.
Attachments 7-9 to the Enclosure contain Proprietary Information - Withhold Under 10 GFR 2.390 Enclosure PG&E Letter DCL-13-016 Justification for application of Technical. Specifications Changes in WCAP-14333 and WCAP-15376 The document providing justification for application of Technical Specifications (TS)
Changes in Westinghouse document WCAP-14333-P-A, Revision 1, "Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times," dated October 1998, and Westinghouse document WCAP-1 5376-P-A, Revision 1, "Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times," dated March 2003, to the PPS replacement is contained in Westinghouse document LTR-RAM-1-13-002 P-Attachment, "Justification for the Application of Technical Specifications Changes in WCAP-14333 and WCAP-15376 to the Tricon/ALS Process Protection System at the Diablo Canyon Power Plant", Revision 0, dated January 31, 2013, and is contained in Attachment 9 to this Enclosure.
Section 5 of the NRC Safety Evaluation contained in WCAP-15376-P-A, Revision 1, stated, "For future digital upgrades with increased scope, integration and architectural differences beyond that of Eagle 21, the Staff finds the generic applicability of WCAP-1 5376-P, Rev. 0 to future digital systems not clear and should be considered on a plant-specific basis." Therefore, an assessment has been performed that provides a qualitative comparison of the Tricon and ALS subsystems to the Eagle 21 system. The assessment in Westinghouse document LTR-RAM-1-13-002 P Attachment provides a qualitative comparison of features important to the reliability of the Tricon and ALS subystems and the Eagle 21 system, evaluates the applicability of the WCAP-1 4333-P-A, Revision 1, and WCAP-1 5376-P-A, Revision 1, analyses to the PPS replacement configuration, and evaluates the compliance with the Staff conditions and limitations contained in the NRC safety evaluations for WCAP-14333 and WCAP-15376.
Section 4.3 of the Amendments 179 and 181 contained the Staffs findings on the applicability of WCAP-14333-P-A, Revision 1, and WCAP-1 5376-P-A, Revision 1 to DCPP. The Staff findings were based on tables submitted by PG&E that address the applicable assumptions, conditions, and limitations of WCAP-14333-P-A, Revision 1, and WCAP-15376-P-A, Revision 1. The Staff findings were also based on the DCPP procedures and commitments for avoidance of risk-significant plant-specific configurations and risk-informed plant configuration control and management. Finally, the Staff findings were based on the plant-specific configuration risk management program. The assessment in Westinghouse document LTR-RAM-1-1 3-002 P Attachment addresses the tables submitted by PG&E for the applicable assumptions, conditions, and limitations of WCAP-14333-P-A, Revision 1, and WCAP-15376-P-A, Revision 1, and the DCPP procedures for avoidance of risk-significant plant-specific configurations and risk-informed plant configuration control and management.
3 Attachments 7-9 to the Enclosure contain Proprietary Information When separated from.Attachlments 1-9 to theEEnCloture, this document is decontrolled.
Attachments 7-9 to the Enclosure contain Proprietary Information -Withhold Under 1 0 CFR 2.390 Enclosure PG&E Letter DCL-13-016 For the current Eagle 21 processed RTS or ESFAS functions for the condition of one inoperable channel, the DCPP TS 3.3.1 and 3.3.2 Actions allow a channel to be placed in trip in a completion time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and allow a bypass test time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. WCAP-14333-P-A, Revision 1, provided the justification for increasing completion times from 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and for increasing the bypass test time from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for the Eagle 21 PPS. PG&E obtained NRC approval for the current TS 3.3.1 and 3.3.2 Actions that allow a channel to be placed in trip in a completion time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and that allow a bypass test time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, based on WCAP-14333-P-A, Revision 1, in Amendments 179 for DCPP Unit 1 and 181 for DCPP Unit 2, respectively.
For the Eagle 21 processed RTS or ESFAS functions, the DCPP TS 3.3.1 and 3.3.2 surveillances allow a channel operability test (COT) surveillance test interval of 6 months. WCAP-1 5376-P-A, Revision 1, provided the justification for increasing the COT surveillance test intervals from 3 months to 6 months. PG&E obtained NRC approval for the current TS 3.3.1 and 3.3.2 COT surveillance test intervals of 6 months, based on WCAP 15376-P-A, Revision 1, in Amendments 179 for DCPP Unit 1 and 181 for DCPP Unit 2, respectively.
The assessment in Westinghouse document LTR-RAM-1-13-002 P-Attachment has concluded the current TS 3.3.1 and 3.3.2 completion times, bypass test times, and COT surveillance test intervals for the PPS replacement components based on WCAP-14333-P-A, Revision 1, and WCAP-1 5376-P-A, Revision 1, continue to be applicable for the PPS replacement.
ATTACHMENTS
- 1.
Westinghouse Authorization Letter, CAW-1 3-3598
- 2.
Westinghouse Authorization Letter, CAW-1 3-3599
- 3.
Westinghouse Authorization Letter, CAW-13-3596
- 4.
Westinghouse document WCAP-1 7696-NP, Revision 0,"Westinghouse Setpoint Calculations for the Diablo Canyon Power Plant Digital Replacement Process Protection System"
- 5.
Westinghouse document WCAP-1 7706-NP, Revision 0, "Westinghouse Setpoint Methodology as Applied to the Diablo Canyon Power Plant"
- 6.
Westinghouse document LTR-RAM-1-13-002 NP-Attachment, Revision 0, "Justification for the Application of Technical Specifications Changes in WCAP-14333 and WCAP-1 5376 to the Tricon/ALS Process Protection System at the Diablo Canyon Power Plant"
- 7.
Westinghouse document WCAP-17696-P, Revision 0,"Westinghouse Setpoint Calculations for the Diablo Canyon Power Plant Digital Replacement Process Protection System" (Proprietary)
- 8.
Westinghouse document WCAP-1 7706-P, Revision 0, "Westinghouse Setpoint Methodology as Applied to the Diablo Canyon Power Plant" (Proprietary) 4 Attachments 7-9 to the Enclosure contain Proprietary Information When separated from Attachments 7-9 to the Enclosure, this document is decontrolled.
Attachments 7-9 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 Enclosure PG&E Letter DCL-13-016
- 9.
Westinghouse document LTR-RAM-1-13-002 P-Attachment, Revision 0, "Justification for the Application of Technical Specifications Changes in WCAP-14333 and WCAP-1 5376 to the Tricon/ALS Process Protection System at the Diablo Canyon Power Plant" (Proprietary) 5 Attachments 7-9 to the Enclosure contain Proprietary Information When separated from Attachments 7-9 to tMe Enclosure, this document is decontrolled.