LR-N15-0016, Pre-Application Meeting: Installation of Digital Power Range Neutron Monitor (Prnm) in Accordance with Interim Staff Guidance, Digital I&C-ISG-06

Pre-Application Meeting: Installation of Digital Power Range Neutron Monitor (Prnm) in Accordance with Interim Staff Guidance, Digital I&C-ISG-06

ML15021A500
Person / Time
Site:	Hope Creek  (NPF-057)
Issue date:	01/21/2015
From:	Duke P Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LR-N15-0016
Download: ML15021A500 (29)

Text

LR-N15-0016 Contains Proprietary Information to be Withheld from Public Disclosure Pursuant to 10 CFR 2.390 PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Facility Operating License No. NPF-57 NRC Docket No. 50-354 I)SFG NuclearLLC 10 CFR 2.390 10 CFR 50.90

Subject:

Pre-Application Meeting: Installation of Digital Power Range Neutron Monitor (PRNM) in accordance with Interim Staff Guidance, Digital I&C-ISG-06 In accordance with Interim Staff Guidance, "Digitaii&C-ISG-06", PSEG Nuclear LLC (PSEG) is submitting the enclosed information to support the PRNM Pre-Application (ISG-06 Phase 0) meeting on January 29, 2015 (ADAMS ML15015A677). As discussed with the NRC, the material to be presented is considered proprietary: provides the proprietary presentation material for the closed meeting. provides the non-proprietary version of the presentation material. provides an affidavit related to the proprietary material in Enclosure 1. contains proprietary information as defined by 10 CFR 2.390. General Electric Hitachi (GEH), as the owner of the proprietary information, has executed the Enclosure 3 affidavit identifying that the proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure.

GEH requests that the proprietary information in Enclosure 1 be withheld from public disclosure, in accordance with the requirements of 10 CFR 2.390(a)(4).

There are no regulatory commitments contained in this letter. If you have any questions or require additional information, please contact Mr. Brian Thomas at (856) 339-2022.

JAN* 2l 2015 Page2 LR-N15-0016 Contains Proprietary Information to be Withheld from Public Disclosure Pursuant to 10 CFR 2.390

Gerely, Paul:.::

.

Manager-Licensing

Enclosures:

(3) 1 0 CFR 2.390 10 CFR 50.90 - Proprietary presentation material for the closed PSEG PRNM Pre Application (Phase 0) Meeting - Non-Proprietary version of presentation material for the closed PSEG PRNM Pre-Application (Phase 0) Meeting - GEH Affidavit for Enclosure 1 cc:

Mr. D. Dorman, Administrator, Region I, NRC Ms. C. Sanders-Parker, Project Manager, NRC, Project Manager, NRC NRC Senior Resident Inspector, Salem Mr. P. Mulligan, Chief, NJBNE Mr. L. Marabella, Corporate Commitment Tracking Coordinator Mr. T. MacEwen, Hope Creek Commitment Tracking Coordinator LR-N15-0016 Non-Proprietary version of presentation material for the closed PSEG PRNM Pre Application (Phase 0) Meeting.

Non-Proprietary Information-Class I (Public)

Digitaii&C Life Cycle Development rocess for NUMAC Retrofits January 29, 2015 HITACHI

Non-Proprietary Information-Class I (Public)

Purpose Describe background leading to GEH update to standard NUMAC development process Describe and obtain feedback on the updated process "Technical & Baseline Reviews" to address independence of V&V team Relationship to LAR Phase 1 Submittal Alignment between updated process and current regulatory guidance Describe and obtain feedback on how the updated process will be applied to Hope Creek HITACHI

Non-Proprietary Information-Class I (Public}

"Initial" NUMAC PRNM Process Original (initial) process included 3 NUMAC-specific plans that supplemented the GEH QA program for digital safety systems Approved in 1996 as part of NUMAC PRNM System LTR Approval was based on applicable criteria at the time Led to multiple approvals and PRNM installations Installed in 18 domestic units HITACHI

Non-Proprietary Information-Class I (Public)

Grand Gulf and Columbia LARs Recent applications led to multiple RAis (Grand Gulf) and an LAR rejection (Columbia)

Initial process did not meet current independence criteria defined in IEEE Std 1012 as endorsed by RG 1.168 Both PRNM LARs were ultimately approved, but with initial process PLUS compensatory actions:

Independent Software Module Testing Independent Software Integration Testing Performed as a Technical Design Review under direction of GEH Chief Engineers' Office HITACHI

Non-Proprietary Information-Class I (Public)

Key Elements of Enhanced NUMAC Process Formalize involvement of Chief Engineer's office to provide oversight of V&V activities Improve alignment with current regulatory guidance Additional enhancements:

Incorporate activities related to security Incorporate activities related to qualification Methodology is otherwise similar to initial process NUMAC-specific Plans supplement GEH QA program Documentation is very similar Hope Creek PRNM: first submittal using updated process HITACHI

Non-Proprietary Information-Class I (Public)

Summary of Approach for LAR Submit:

Hope Creek (project specific) PRNM System Management Plan Standard NUMAC Process that will be applied to Hope Creek NUMAC Systems Engineering Development Plan NUMAC Systems Independent Verification and Validation Plan NUMAC Systems QA Plan Methodology Modifications Report Refers and relies on Grand Gulf RAis, Columbia LAR Describes and discusses difference in process HITACHI

Non-Proprietary Information-Class I (Public)

Cross-reference with DI&C-ISG-06 sot:tware.*.

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Requirement Traceability Matrix HITACHI

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Alignment: Hope Creek PRNM plans to BTP 7-14

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BTP 7-14 Criteria for Software Development Plan

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BTP 7-14 Criteria for Software V&V Plan HITACHI

Non-Proprietary Information-Class I (Public)

GEH NUMAC Design Outputs The design outputs are expanded and better defined in the updated process, but mostly unchanged.

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Non-Proprietary Information-Class I (Public)

Alignment with IEEE Std 1012 generation Independent V&V Test Procedures

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Alignment with each phase is shown in Methodology Modifications Report.

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Non-Proprietary Information-Class I {Public)

Conclusion NUMAC process was updated in response to recent licensing activities Updated process leverages success and experience with in iti a I process Motivation for update:

Meet current criteria for independence Improve alignment with regulatory guidance Meets criteria for LAR, as outlined in DI&C-ISG-06 HITACHI LR*N 15-0016 GEH Affidavit for Enclosure 1

GE-Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, James F. Harrison, state as follows:

(1) I am Vice President, Fuel Licensing, Regulatory Affairs, GE-Hitachi Nuclear Energy Americas LLC ("GEH"), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in Enclosure 1 of GEH letter, GEH KT0-182455-078, "Hope Creek Phase 0 January 29, 2015 Meeting Presentation," dated January 21, 2015.

The GEH proprietary information in Enclosure 1, which is entitled "Digital I&C Life Cycle Development Process for NUMAC Retrofits," is identified by double square brackets. ((This sentence is an example.{3})) Figures and large objects are identified with double square brackets before and after the object.

In each case, the superscript notation {3} refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GEH relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 U.S.C. Sec. 552(b)(4), and the Trade Secrets Act, 18 U.S.C.

Sec. 1905, and NRC regulations 10 CPR 9.17(a)(4), and 2.390(a)(4) for trade secrets (Exemption 4). The material for which exemption from disclosure is here sought also qualifies under the narrower definition of trade secret, within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975 F.2d 871 (D.C. Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F.2d 1280 (D.C. Cir. 1983).

( 4) The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. Some examples of categories of information that fit into the definition of proprietary information are:

a.

Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GEH's competitors without license from GEH constitutes a competitive economic advantage over other companies;

b.

Information that, if used by a competitor, would reduce their expenditure of resources or improve their competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;

c.

Information that reveals aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential products to GEH;

d.

Information that discloses trade secret or potentially patentable subject matter for which it may be desirable to obtain patent protection.

Affidavit for GEH-KT0-182455-078 Enclosure 1 Page 1 of3

GE-Hitachi Nuclear Energy Americas LLC (5) To address 10 CPR 2.390(b)(4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GEH, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GEH, not been disclosed publicly, and not been made available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary or confidentiality agreements that provide for maintaining the information in confidence. The initial designation of this information as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in the following paragraphs (6) and (7).

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, who is the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or who is the person most likely to be subject to the terms under which it was licensed to GEH.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist, or other equivalent authority for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GEH are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary or confidentiality agreements.

(8) The information identified in paragraph (2), above, is classified as proprietary because it contains detailed information regarding the plans and organization of power range neutron monitoring projects. These plans and the project organization methods associated with the power range neutron monitoring system were achieved at a significant cost to GEH.

The development of the evaluation processes along with the interpretation and application of the analytical results is derived from the extensive experience and information databases that constitute a major GEH asset.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit making opportunities. The information is part of GEH's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost.

The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GEH. The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial. GEH's competitive advantage will be lost if its Affidavit for GEH-KT0-182455-078 Enclosure 1 Page 2 of3

GE-Hitachi Nuclear Energy Americas LLC competitors are able to use the results of the GEH experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to GEH would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on this 21st day of January 2015.

James F. Harrison Vice President, Fuel Licensing Regulatory Affairs GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Road Wilmington, NC 28401 james.harrison@ge.com Affidavit for GEH-KT0-182455-078 Enclosure 1 Page 3 of3