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Pacific Gas & Electric Company Diablo Canyon Units 1 and 2 - Response to Request for Additional Information and Submittal of Advanced Logic System Phase 2 Documents for the License Amendment Request for Process Protection System Replacement
	ML16049A009
Person / Time
Site:	Diablo Canyon
Issue date:	01/25/2016
From:	Welsch J M; Pacific Gas & Electric Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML16049A006	List: DCL-16-011, Attachment 2 - Pacific Gas and Electric Company Diablo Canyon Power Plant Units 1 and 2, Process Protection System (PPS) Replacement Interface Requirements Specification Nuclear Safety-Related, Rev 9; DCL-16-011, Attachment 3 - Process Protection System Controller Transfer Function Design Input Specification No 110000000552, Rev. 4; DCL-16-011, Pacific Gas & Electric Co. Diablo Canyon Power Plant Units 1 & 2 Functional Requirements Specification Process Protection System (PPS) Replacement Nuclear Safety-Related,08-0015-SP-001, Rev. 9; DCL-16-011, Pacific Gas & Electric Company Diablo Canyon Units 1 and 2 - Response to Request for Additional Information and Submittal of Advanced Logic System Phase 2 Documents for the License Amendment Request for Process Protection System Replaceme; ML16049A009; ML16049A010; ML16049A011;
References
	PG&E Letter DCL-16-011
	Download: ML16049A009 (29)
	v • d • e

The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 WI Pacific Gas and Electric Company°James M. Weisch Diablo Canyon Power Plant Vice President, Nuclear Generation P.O. Box 56 Avila Beach, CA 93424 805.545.3242 E-Mail: JMW1l5pge.corn January 25, 2016 PG&E Letter DCL-16-011 U.S. Nuclear Regulatory Commission 10 CER 50.90 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 I and 2 Response to Request for Additional Information and Submittal of Advanced Logqic System Phase 2 Documents for the License Amendment Request for 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. MLII1307A33 1).2. NRC email "Diablo Canyon I and 2 -RAIs for Digital Replacement of the Process Replacement System LAR (TAC Nos. ME7522 and ME7523)," dated December 23, 2015 (ADAMS Accession No.MLI5357A382).

3. NRC Letter "Summary of August 5, 2015, Teleconference Meeting with Pacific Gas and Electric Company on Digital Replacement of the Process Protection System Portion of the Reactor Trip System and Engineered Safety Features Actuation System at Diablo Canyon Power Plant, Unit Nos. I and 2 (TAO NOS. ME7522 AND ME7523)," dated September 10, 2015 (ADAMS Accession No. ML15233A006).

Dear Commissioners and Staff: In Reference 1, Pacific Gas and Electric Company (PG&E) submitted License Amendment Request 11-07 to request NRC Staff (Staff) 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 Westinghouse Electric Company Advanced Logic System (ALS). The Staff requested additional information to complete the review of Reference

1. This letter responds to the additional information requested inReernc 2The CD in Attachment 5 of the Enclosure Contains Proprietary Information P When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled v, A member of the STARS (Strategic Teaming and Resource Sharing) Altiance Cattaway

Diablo Canyon

Palo Verde

Wotf Creek The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 D ocument Control Desk PG&E Letter DCL-16-011 January 25, 2016 Page 2 This letter submits PPS Replacement Project documents in the following Attachments to the Enclosure in this letter: Attachment 1 -PPS Replacement Functional Requirements Specification, Revision 9 Attachment 2 -Interface Requirements Specification, Revision 9 Attachment 3 -Controller Transfer Functions Design Input Specification, Revision 4 Attachment 4 -Westinghouse Application for Withholding Proprietary Information Letter CAW-1 5-4313, Affidavit, Proprietary Information Notice, and Copyright Notice Attachment 5 -Compact Disk -"Advanced Logic System Phase 2 Documents

-Proprietary" The Staff requested that the documents contained in Attachments 1, 2, 3, and 5 of the Enclosure to be submitted in Open Item 145 contained in Enclosure 2 of Reference 3.The Westinghouse ALS documents contained on the compact disk (CD), labeled"Advanced Logic System Phase 2 Documents

-Proprietary," in Attachment 5 to the Enclosure are listed in Table 1 in the Enclosure to this letter. The CD contents are in Adobe Acrobat portable document format. The ALS documents are predominantly proprietary in content and, therefore, non-proprietary versions of the documents are not provided.The Westinghouse ALS documents on the CD in Attachment 5 contain proprietary information as identified by Westinghouse Electric Company, LLC. Accordingly, Attachment 4 includes a Westinghouse application for withholding proprietary information letter CAW-15-.4313, an accompanying affidavit, a Proprietary Information Notice, and a Copyright Notice. 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 Westinghouse affidavit, copyright, or proprietary aspects of the application for withholding the Westinghouse proprietary information provided in Attachment 5 should reference Westinghouse Letter CAW-1 5-4313, and be to: James A. Gresham Manager, Regulatory Compliance Westinghouse Electric Company 1000 Westinghouse Drive, Building 3 Suite 310 Cranberry Township, Pennsylvania 16066 A copy of the proprietary CD is being provided to-the following individuals:

Regional Administrator, Region IV DCPP Nuclear Reactor Regulation Project Manager DCPP NRC Senior Resident Inspector Branch Chief, California Department of Public Health The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Ca[laway

Diabto Canyon

Palo Verde

Wotf Creek The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 D ocument Control Desk PG&E Letter DCL-16-011 January 25, 2016 Page 3 The information in the Enclosure to this letter does not affect the results of the technical evaluation or the significant hazards consideration determination previously transmitted in Reference 1.PG&E makes no new or revised regulatory commitments (as defined by NEI 99-04) in this letter.If you have any questions, or require additional information, please contact Mr. Hossein Hamzehee at (805) 545-4720.I state under penalty of perjury that the foregoing is true and correct.Executed on January 25, 2016.Sincerely, James M. Welsch Vice President, Nuclear Generation kjse/4328/50271 918 Enclosure cc: Diablo Distribution cc/enc: Marc L. Dapas, NRC Region IV Siva P. Lingam, NRR Project Manager Gonzalo L. Perez, Branch Chief, California Department of Public Health Binesh K. Tharakan, Acting NRC Senior Resident Inspector The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled A member of the STARS (Strategic Teaming and Resource Sharing) Atliance CaL~away

Diablo Canyon

Pato Verde ° WoLf Creek The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold f~rom public disclosure under 10 CER 2.390 Enclosure PG&E Letter DCL-16-011I Response to Request for Additional Information on License Amendment Request for Digital Process Protection System Replacement Pacific Gas and Electric Company (PG&E) Letter DCL-1 1-104; "License Amendment Request 11-07, Process Protection System Replacement," dated October 26, 2011, submitted License Amendment Request (LAR) 11-07 to request NRC Staff (Staff)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 (IOM) Tricon Programmable Logic Controller (PLC), Version 10, and the Westinghouse Electric Company Field Programmable Gate Array (FPGA)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 of Digital Instrumentation and Controls (l&C), Revision 1, of Interim Staff Guidance (ISG) Digital I&C-ISG-06, "Task Working Group #6: Licensing Process." The 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.The Staff requested additional information to support the review of [AR 11-07 in NRC email "Diablo Canyon 1 and 2 -RAIs for Digital Replacement of the Process Protection System [AR (TAC Nos. ME7522 and ME7523)," dated December 23, 2015 (ADAMS Accession No; ML1 5357A382).

The request for additional information (RAl) is addressed below for RAls 71 to 77. Each RAl contains a reference to an open item that corresponds to the number of the item in the Open Item table that PG&E has discussed with the Staff during various public'meetings.

NRC RAI 71 (Open Item 115) Electro Magnetic Compatibility (Tricon)Section 4.14 -Application Specific Action Item (A SAl) 6 of the LAR) states the equipment vendors are required to confirm equipment compliance with physical requirements in the DCPP Functional Requirements Specification (ERS). These requirements include the Electro Magnetic Compatibility (EMC) requirements from Section 3.1.6 of the PPS ERS which states: "the PPS shall be qualified by test, analysis, or a combination thereof, to function without fault or error in an electromagnetic environment in accordance with the guidance of-Re gulatory Guide (RG) 1.180." In contrast to this, the Tricon VIO safety evaluation determined that the Tricon V10 PLC system did not fully meet the guidance of RG 1.180, Revision 1, for conducted or radiated emissions or susceptibility.

As a result, the safety evaluation (SE) of the Tricon plafform states: "before using the Tricon VIO system equipment in systems in a nuclear power plant, licensees must determine that the plant-specific Electro Magnetic Interference (EMI) requirements are enveloped by the capabilities of The CD in Attachment 5 of the Enclosure Contains Proprietary Information When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 Enclosure PG&E Letter DCL-1 6-011 the Tricon VIO system as approved in this SE." To complete its safety evaluation, the U.S. Nuclear Regulatory Commission (NRC)requires the licensee to provide documentation to show the DCPP specific EMI requirements to be enveloped by the Tricon VIG test levels achieved and documented in the Tricon VIO safety evaluation.

PG&E Response to RAI 71 The PG&E FRS Section 3.1.6.2 requires the PPS Equipment to be EMI/Radio Frequency Interference (RFI) qualified in accordance with the guidance in RG 1.180.The Triconex EMI/RFI test report 9600 164-527 concluded that the Tricon unit under test complied with the allowable emissions and susceptibility levels required by RG 1.180 with the exception of allowable conducted emissions level (MIL-STD-461 E,"Requirements for the Control of Electromagnetic Interference Emissions and Susceptibility, US Department Of Defense, August 1999" tests CE101 and CE1 02) for low and high frequency conducted emissions on the 120 volts alternating current (VAC)chassis power supply line.In section 7.2.2 of the Triconex test report, documentation is included for a final CE1 02 (high frequency) test performed with a Corcom Model 30VSK6 line filter installed.

With the line filter installed, the MIL-STD-461-E, CE102 conducted emissions were acceptable.

Therefore, PG&E is including a Corcom Model 30VSK6 line filter on the input of the 120 VAC power supply for the PPS Replacement design. With use of the Corcom Model 30VSK6 line filter on the input of the 120 VAC power supply, the high frequency conducted emissions meets the guidance of RG 1.180.RG 1.180 provides an exemption from CEl01 testing if: (1) the power quality requirements of the equipment are consistent with the existing power supply and design practices include power quality controls and, (2) the new equipment will not impose additional harmonic distortion on the power distribution system exceeding 5 percent total harmonic distortion or other power quality criteria established with a valid technical basis. The 120 VAC power to the Tricon is to be supplied by Class I1E vital instrument power with appropriate quality requirements and design practices in place. Based on testing performed for another similar application at DCPP (power supplies located in a Tricon chassis located in safety-related auxiliary building and fuel handling ventilation control system cabinets), no appreciable difference in the harmonic distortion of the instrument Alternating Current (AC) system was observed before and after the power supplies were installed.

Therefore, the RG 1.180 criteria for exemption from CE101 testing are met for the PPS Replacement Tricon equipment.

2 The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 Enclosure PG&E Letter DCL-16-011I NRC RAI 72 (Open Item 119) IOM Laptops Invensy Operations Management (IOM) is using laptops, one per Protection Set plus one backup, each with TniStation 1131 installed, to develop the VIO Tricon protection set application code for the DCPP PPS Replacement project. PG&E bought these five development laptops and IOM will be delivering them to PG&E as part of the Tricon product delivery.

However, during the Invensys audit on June 3-5, 2014, PG&E informed the staff that it does not plan to use these laptops, and only plans to use the TniStation installed on the PPS maintenance work stations.

Please clarify what PG&E will do with the five development laptops once they are delivered to them. Also, please clarify what controls will be placed on the TriStation softvware installed on these laptop computers.

PG&E Response to RAI 72 The PG&E laptops provided for development of the VI10 Tricon were not designated as safety-related and will not be used in the PPS Replacement system by PG&E in the future because they are now obsolete.NRC RAI 73 (Open Item 129) ALS Halt Mode Operation Please describe the HALT mode of operation and the vital errors that can occur to cause a board to enter the HALT mode.PG&E Response to RAI 73 The detailed information on operation of the ALS HALT mode of operation and the vital errors that can occur to cause the board to enter the HALT mode is designated as Westinghouse proprietary information.

Therefore, Westinghouse submitted this information directly to the NRC in Westinghouse Letter LTR-NRC-16-1, dated January 5, 2016.NRC RAI 74 (Open Item 146)In the response to 0I194 (ASAI-04), PG&E referred to document 6116-00204, Revision 1, "ALS Subsystem Equipment Qualification Evaluation." The NRC staff needs to review this document.

This Environmental Qualification (EQ) evaluation document will need to be submitted on docket to be used as a basis for the Safety Evaluation conclusions.

3 The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 Enclosure PG&E Letter DCL-16-011 PG&E Response to RAI 74 The current revision of the ALS document 6116-00204, "ALS Subsystem Equipment Qualification Evaluation," Revision 2, is contained on the CD in Attachment 5 to the Enclosure of this letter.NRC RAI 75 (Open Item 147) EQ: Temperature and Humidity Please clarify if FRS Section 3.1.4.1 specifies the temperature and relative humidity worst case conditions expected in the cable spreading room (i.e., mild environment) for normal, abnormal, and accident conditions.

Please provide evaluation results for plant-specific configuration of Tricon and ALS components to establish:

a. Maximum temperature rise in each cabinet, b. Maximum ambient temperature in the cable spreading room, and c. Design basis temperature margin has not been affected?The licensee has specified a broader range of relative humidity (RH) than the qualified and tested range for the ALS and Tricon platforms.

Please clarify how the use of the ALS and Tricon subsystems is acceptable for the broader range of RH specified in the FRS Section 3.1.4.1.2.

Provide DCM T-20, Environmental Qualification including Appendix A titled"Environmental Conditions for EQ of Electric Equipment." This reference is cited in Section 3.11.2.1 of the Updated Final Safety Analysis Report under Accident Environments.

PG&E Response to RAI 75 FRS Section 3.1.4.1 states: 3.1.4.1.1 Temperature:

40Oto 104°F 3.1.4.1.2 Relative Humidity (RH): 0 to 95 percent (non-condensing)

The design basis for the cable spreading room ventilation system is the cable spreading room is maintained at an average temperature of 72+/-5° F and normal humidity of 50 percent relative humidity.DCM T-20, Environmental Qualification, including Appendix A titled "Environmental Conditions for EQ of Electric Equipment," was provided to the Staff on sharepoint on April 13, 2015.4 The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390Enclosure PG&E Letter DCL-16-01 1 DCM T-20 Table A4.2-1, Normal Operation Pressure, Temperature and Humidity states: Cable Spreading Room (Auxiliary Building)Temperature 104°F Humidity 95 percent RH Page 31 of DCM T-20 also contains a 0 to 95 percent RH that includes an abnormal, non-condensing relative humidity.

This is the basis for the FRS Section 3.1.4.1 RH specification.

There are no accident environmental conditions since the cable spreading room environment is considered a "mild environment" as defined by DCM T-20: An environment that would at no time be significantly more severe than the environment that would occur during normal plant operation, including anticipated operational occurrences (Reference 10CFR50.49(c)).

Temperature The temperature in the cable spreading room is monitored and controlled to 103°F (101 0 F setpoint with 2°F allowed for instrument uncertainty) by Equipment Control Guideline 23.1, "Area Temperature Monitoring." If the temperature exceeds 1 03°F, actions are required to restore the temperature to less than 103°F in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , or open the cabinet doors and verify temperature less than 11 9°F, or perform an evaluation of operability, or to declare the equipment in the cabinet inoperable.

The Tricon Topical Report (7286-545-1-A, Revision 4) states that the equipment shall meet its performance requirements during and following exposure to abnormal environmental conditions of 40°F to 140°F. The ALS Subsystem System Design Specification (6116-10201, Revision 5) provides a temperature limitation of less than 140°F. The cable spreading room temperature range (40-104°F) is within the vendor specified ranges for the Tricon and ALS equipment.

As discussed during the status phone call with the staff on December 22, 2015, the PG&E documentation for temperature rise within the cabinets and the design basis room temperature (heat load) margin are being added to the Staff inspection item list for Staff verification prior to the PPS Replacement design being placed in service.Humidity The humidity in the cable spreading room is monitored and controlled to less than 90 percent RH. If 90 percent RH is exceeded, procedural actions require restoration of the humidity to within limits. Procedure OP H-10:IV, "Auxiliary Building Ventilation

-Off Normal Operation" provides guidance to restore humidity to within limits.5 The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 Enclosure PG&E Letter DCL-16-011 The test qualified range of RH for the ALS subsystem is 35 to 95 percent RH.Additional information on the ALS humidity testing is contained in the ALS System Design Specification (6116-00011, Revision 9). The methodology used to perform the ALS humidity environmental testing is contained in WCAP-8587-(NP), Revision 6-A,"Methodology for Qualifying Westinghouse WRD (Water Reactor Division)

Supplied NSSS Safety Related Electrical Equipment," Westinghouse Electric Company, LLC, and justifies the 0 to 95 percent RH levels based on test levels of 35 to 95 percent RH.The low humidity is not an environmental failure mechanism for electronic equipment, and, therefore, all humidity conditions below 35 percent (0-35 percent RH) are enveloped by the more conservative humidity levels included in the test. The only failure mechanism associated with low humidity is electrostatic discharge, which is addressed by item R1610 of the ALS System Design Specification.

Therefore, the ALS test qualified range of 35 to 95 percent RH bounds the cable spreading room RH range of 0-95 percent RH.The test qualified range of RH for the Tricon subsystem is 5 to 95 percent. Invensys Operations Management evaluated operation at 0 to 5 percent non-condensing and/determined operation in this range will not affect the functionality of the electronics directly and thus not adversely impact equipment operability.

The Invensys Operations Management installation guidance for the Tricon VIl0 provides guidance to control the risks from electrostatic discharge, including proper equipment grounding and electrostatic discharge prevention practices.

NRC RAI 76 (Open Items 151 and 152)PG&E "DCPP Project Procedure, System Verification and Validation Plan (SyVVP) for the PPS Replacement Project" and "Quality Assurance Plan for the Diablo Canyon Process Protection System Replacement" state that PG&E will perform management and activities during the design, development, and testing of the ALS and Tricon System. Please describe the activities performed by PG&E.PG&E Response to RAI 76 PG&E project and quality personnel performed activities in accordance with the SyVVP and Quality Assurance Plan during the design, development, and testing of the ALS and Tricon subsystems.

During the design of the PPS Replacement, plant specific project documents created by the vendors were reviewed by PG&E project engineering and management personnel, and the vendors incorporated PG&E comments prior to issuance of the documents.

6 The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 Enclosure PG&E Letter DCL-16-011I In 2012, PG&E Quality Verification personnel performed an assessment of the qualifications and third party audits of the four main vendors for the project, Altran Solutions, Invensys Operations Management, Westinghouse Electric Company, and CS Innovations.

The assessment supported the listing of the four vendors on the PG&E Qualified Supplier List for the scope of work associated with the project.In 2012, PG&E Quality Verification, Cyber Security, and Project Engineering personnel conducted an audit at the CS Innovations facility in Scottsdale, Arizona, and reviewed the cyber security implementation and software development implementation for the project. The audit determined CS Innovations was following their program for software/hardware design and development for the project purchase orders and design specifications, and that the work was being performed in a Secure Development Operating Environment in accordance with RG 1.152.Also in 2012, PG&E Quality Verification and Cyber Security personnel conducted an audit at the IOM facility in Lake Forest, California, and reviewed the cyber security, implementation and software development implementation for the project. The audit determined IOM was following their program for software/hardware design and development for the project purchase orders and design specifications, and that the work was being performed in a Secure Development Operating Environment in accordance with RG 1.152. One minor finding was identified related to the multiple versions of IEEE 1028, "Standard for Software Reviews," that were contained in IOM project planning documents.

IOM corrected the reference to IEEE 1028 in the planning documents.

During the development of the PPS Replacement from 2013 to 2014, PG&E Quality Verification personnel assessed the technical adequacy of design phase documentation that was developed by PG&E and Altran Solutions personnel.

The documentation assessed included the PPS Replacement System Quality Assurance Plan (SyQAP), SyWP, ERS, Interface Requirements Specification, and Controller Transfer Functions Design Input Specification.

The assessment was performed through review of the applicable procedural requirements, industry and regulatory requirements, and design and licensing basis documentation applicable to the PPS.The review included a technical review of the documentation to verify it was complete, technically correct, unambiguous, traceable, and in compliance with applicable industry, regulatory, and procedural requirements and guidance.

The assessment concluded the design phase documentation was in compliance with applicable industry, regulatory, and procedural requirements and guidance.

The assessment identified that the roles and responsibilities of the "Supervisor Supplier Quality," were not correctly defined in the SyQAP and Project Plan documents, and these documents were revised to provide the correct definition.

7 The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 Enclosure PG&E Letter DCL-16-011I During testing of the PPS Replacement in 2014, PG&E Quality Verification and Project Engineering personnel attended the Factory Acceptance Testing (FAT) of the Tricon portion of PPS Replacement system at the IOM facility in Lake Forest, California.

The review activities included review of the FAT plan documents being used for FAT testing, witnessing of the for FAT for one protection set, review of the FAT test reports, verification that test issues were entered in the IOM corrective action system, and confirmation that the hardware was being supplied in accordance with the hardware purchase order.During testing of the PPS Replacement in 2015, PG&E Quality Verification and Project Engineering personnel attended the FAT of the ALS portion of PPS Replacement system at the Westinghouse facility in Warrendale, Pennsylvania.

The review activities included review of the FAT plan documents being used for FAT testing, witnessing of the for FAT testing, review of the FAT test reports, verification that test anomalies or failures were tracked by Westinghouse "On-time Tickets," and confirmation that the hardware was being supplied in accordance with the hardware purchase order.NRC RAI 77 (Open Item 156) Human Factors a. Section 4.10.2.14, "Clause 5.14 Human Factors Considerations (Section D.9.4.2. 14 of DI&C-ISG-06

[1])," of the Enclosure to the LAR states, in part: "The existing operator interface using control panel mounted switches and indicators is maintained." It further states: "The PPS will share a Human System Interface (HSI)unit on CC4 that will be installed by the PCS [Plant Computer System] replacement project for system health and status displays." It also states: "The PPS HSI design should follow the guidance provided in the DCPP HSI Development Guidelines Document, which reference NUREG 0700, and which will be implemented during development of the formal design change following receipt by PG&E of the SER [safety evaluation report] approving this change." Section 3. 5.1, "System Human Factors," of the Functional Requirements Specification Document No. 08-0015-SP-001, Revision 9, states: "The PPS HSI should follow the guidance provided in the DCPP HSI Development Guidelines Document." Please provide in formation regarding what elements of the HSI are being added, deleted, or changed in accordance with the DCPP HSI Development Guidelines Document, as part of the proposed license amendment.

b. Section 4.10.2.14 of the Enclosure to the LAR states, in part: "Existing PPS outputs to the MAS [Main Annunciator System] are modified to dry contacts.

The existing AC/DC [alternating current/direct current] converters on the PPS outputs to the MAS are deleted. Additional outputs to the MAS are provided..." 8 The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 Enclosure PG&E Letter DCL-16-011I Section 1.1, "System Purpose," of the Functional Requirements Specification Document No. 08-0015-SP-OO1, Revision 9, states, in part: "Output signals of PPS parameters are provided to the Main Control Room (MCR) for indication and recording, to the Plant Process Computer (PPC) for monitoring, and to the Main Annunciator System (MA S) for alarming." Section 3.2.1.3, "Indicators, Status Lights, and Con trols, " identifies the requirements for status indication, manual trip switches, and manual bypass switches applicable to all PPS channels.Section 3.2.1.5, 'Alarms and Annunciators," identifies the requirements for alarms and annunciators that must be provided for each Protection Set, and the appropriate subsections of Sections 3.2.2 through 3.2.13 identify additional requirements for alarms and annunciators that are specific to the respective channels.Please clarify what additional indicators, status lights, alarms, and annunciators are being added as part of the proposed license amendment.

c. Please describe the impact, if any, of the proposed modification on operating procedures, operator training, and the training simulator.

Please describe any changes to operating procedures needed to support the proposed license amendment.

If possible, identify which procedures will be revised.If the Emergency Operating procedures are affected, please describe any changes that were required of the Control Room task analysis that was done as part of your Detailed Contfrol Room Design Review. If no update to the task analysis was necessary, describe how task requirements were developed.

d. Please identify any operator manual actions that will be added, deleted, or changed to support the proposed license amendment.

If there are any new or changed manual operator actions, describe the process used to verify and validate the ability of your operators to accomplish the tasks required for the proposed LAR. In lieu of a description, you may provide the relevant administrative procedure(s) for verification and validation.

e. Please explain if an operating experience review has been done, including plant-specific condition reports, Licensee Event Reports, INPO [Institute of Nuclear Power Operations]

reports, and other relevant sources. If so, describe what sources of information were considered and the outcome of the review (i.e., list any relevant[Human Factors Engineering]

HEE-related problems that were identified, analyzed, and addressed).

9 The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 Enclosure PG&E Letter DCL-16-011I PG&E Response to RAI 77 a. For the PPS Replacement, the existing operator interface with the control panel mounted switches and indicators will not be revised and therefore will not utilize the Human System Interface (HSI) Development Guidelines Document.As part of the PPS Replacement, an existing HSI unit in the control room (that was previously installed for a Process Control System replacement project) will also be used for system health and status displays and to provide detailed system diagnostic results when failure indication on the control panel occurs. This HSI unit will obtain PPS data through a connection to an existing plant data network non-safety Gateway computer that is installed in the plant. The HSI Development Guidelines Document will be utilized for the development of displays of PPS information on the HSI unit.Each of the four protection sets contains a separate non-safety related maintenance workstation (MWS) for the Tricon subsystem and the ALS subsystem (a total of eight MWSs for the PPS) that will be installed in the PPS instrumentation cabinets.

The HSI Development Guidelines Document was used by the vendors to develop the display screens and operator interface with the MWSs.b. The digital PPS Replacement design is replacing the existing digital Eagle-21 protection system. The existing control room control panel indicators, status lights, controls, alarms, and annunciators are sufficient and will be utilized for the PPS Replacement design. PG&E notes that the LAR was written to address all digital instrumentation and control (DI&C) DI&C-ISG-06 and IEEE Standard 603 guidance, and in some cases the existing plant equipment can be utilized to meet the guidance.The chassis for the Tricon and ALS subsystems will be installed in normally closed PPS instrumentation cabinets that are manually opened to access the chassis. To support system monitoring, surveillances, troubleshooting, and maintenance, the chassis for the Tricon and ALS subsystems contain local controls, indicators, and status lights.The PPS Replacement equipment will provide alarms for several new situations specific to the equipment including:

Tricon keyswitch not in the RUN position* One or more disabled variables in Tricon subsystem* Tricon subsystem power module fails, primary power to a power module is lost, or power module has a low battery or over temperature condition* Significant errors between Tricon processing legs* ALS subsystem power supply failures (loss of output voltage)* ALS subsystem Test ALS Bus is enabled* Tricon and ALS subsystem trouble or bypass 10 The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 Enclosure PG&E Letter DCL-16-01 1*Tricon and ALS subsystem input failure or an out-of-range low or out-of-range high input condition c. The PPS is an automatic system that does not require operator involvement to perform its function.

The operational aspects of the digital PPS Replacement are being designed to be consistent with the existing digital Eagle-21 protection system for nearly all operationa!

aspects. There are no Technical Specification instrument setpoint changes required due to the PPS Replacement and no revised surveillance intervals are being implement as part of the PPS Replacement Project. Therefore, the required operating procedures changes will be limited to alarm response procedures

('AR PK" series control panel alarm procedures) to incorporate the use of the significant improvements in the diagnostic capabilities of the PPS Replacement design. For example, when a control panel alarm occurs, the procedures will be updated to provide instructions for use of the HSI unit in the control room to display detailed system diagnostic results to support determination of what specific failure occurred to support troubleshooting, repair, and return of the PPS to Technical Specification Operable status. As described in Section 4.15.1 of the LAR, the integrated PPS Replacement system used for Site Acceptance Testing will also be used to develop and verify operational procedures.

Operating Procedures "OP AP-5, Malfunction of Eagle 21 Protection Channel and Control" for each unit provides guidelines for operator actions if an Eagle 21 protection rack or Process Control System instrument/control channel fails due to a protection rack or instrument failure (i.e., not as a result of an actual emergency situation).

The procedure includes guidance to determine the extent of the Eagle 21 instrumentation failure using control panel and plant process computer information.

The OP AP-5 procedure for each unit will need to be updated to include the control panel and plant process computer information that will be provided when instrumentation failures occur in the PPS Replacement equipment to facilitate diagnosis of the failed PPS Replacement equipment.

Revisions to the Technical Specification Surveillance procedures

("STP I-" series surveillance test procedures) for the channel check, trip actuating device operational test, channel operability test; and channel calibrations will be required to incorporate the Tricon and ALS equipment component names and equipment specific actions needed to perform the tests. It is noted that the plant design already includes instrument loop bypass testing capability and this feature will continue to be utilized with the PPS Replacement equipment.

As described in Section 4.15.1 of the LAR, the integrated PPS Replacement system used for Site Acceptance Testing will also be used to develop and verify the maintenance procedures.

Emergency Operating Procedure "EOP E-0, Reactor Trip or Safety Injection," for each unit provides actions to ensure proper response of the automatic protection systems 11 The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 Enclosure PG&E Letter DCL-16-011I following manual or automatic actuation of a reactor trip or safety injection.

No changes affecting operators are required for EOP E-0 for the PPS Replacement equipment because the procedure directs manual actions to initiate a reactor trip and safety injection signal if they do not occur automatically (i.e., a postulated failure of a PPS automatic actuation) and these operator actions will not be changed due to the PPS Replacement equipment.

The PPS Replacement design does not alter the current plant system level manual actions to initiate a reactor trip, safety injection, or other engineered safety features actuation.

As part of the design change process, which uses the training Systematic Approach to Training Process for plant modifications, the required operator training needs to be developed and implemented to support the PPS Replacement modification.

Operator simulator training is developed and implemented as needed as part of the design changes process. As described in Section 4.15.1 of the LAR, the integrated PPS Replacement system used for Site Acceptance Testing will also be used to perform training.The simulator computer code will need to be modified to model the operational characteristics of the PPS Replacement system Tricon and ALS equipment.

No physical changes to the simulator control board are required for installation of the PPS Replacement system.d. The PPS is an automatic system that does not require operator involvement to perform its function to initiate a reactor trip and engineered safety features actuation.

The PPS does not require manual intervention or acknowledgement of actuation commands to complete a protective function.

Therefore, the PPS Replacement design is not adding new or changed manual operator actions.Although extremely unlikely, the current Eagle 21 PPS is susceptible to a common-cause software failure that could adversely affect automatic performance of the protection function.

The PPS Replacement contains new, additional diversity features that prevent a common-cause software failure from completely disabling the process protection system. Section 4.5.4 of the PPS Replacement LAR Supplement contained in PG&E Letter DCL-1 3-043, "Supplement to License Amendment Request 11-07,'Process Protection System Replacement'," dated April 30, 2013, contains additional detail on the NRC approved manual actions credited for the current Eagle 21 PPS that will no longer be required with the PPS Replacement.

e. PG&E personnel performed a review of industry operating experience for the PPS Replacement Tricon and ALS technology, including, performing a review and inspection of installed applications of the technology.

No relevant HFE-related problems have been identified for the PPS Replacement Tricon and ALS technology.

12 The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 Enclosure PG&E Letter DCL-16-011I For the Tricon subsystem portion of the PPS Replacement design, PG&E has significant operating experience with the Tricon system as a result of installation of the technology in multiple non-safety related control system applications (e.g., Process Control System, Feedwater Control System, Turbine Control System) at DCPP. The Tricon hardware performance at DCPP and in the industry has been exceptional with no hardware actuation failures due to the triple modular redundant architecture of the Tricon hardware.

The only operating experience issue at DCPP for the Tricon hardware was a grounding issue that was discovered during maintenance activities associated with theProcess Control System. During investigation it was determined that shorting of one input field cable to plant ground momentarily affected other inputs in the same Tricon due to the grounding configuration used in the Process Control System; a circuit ground was used instead of an earth ground. All Process Control System and Instrument Rack Tricons were modified so that earth grounds were used in lieu of circuit grounds in accordance with manufacturer recommendation and were successfully tested. Revision of the grounding method to use of an earth ground has been added as a lesson learned.For the ALS subsystem portion of the PPS Replacement design, Wolf Creek has installed the CS Innovations FPGA-based ALS design in the Main Steam and Feedwater Isolation System. There have been no actuation failures of the ALS hardware since it has been installed.

Submittal of ALS ISG-06 Phase 2 Documents The remaining outstanding Westinghouse ALS ISG-06 Phase 2 documents are listed in Table 1 below and contained on one compact disk (CD), labeled "Advanced Logic System Phase 2 Documents

-Proprietary," contained in Attachment 5 to the Enclosure of this letter. The contents are in Adobe Acrobat portable document format.13 The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 Enclosure PG&E Letter DCL-16-011I Table 1 Enclosure Listing -Compact Disk Content"Advanced Logic System Revised Phase 2 Documents

-Proprietary" Enclosure Description Proprietary Filename [size MB]Diablo Canyon PPS Management Plan, Yes 6116-00000-P

[0.5]6116-00000

(-P), Revision 8 Diablo Canyon PPS W Plan, 6116-00003 Yes 6116-00003-P

[0.4](-P), Revision 3 Diablo Canyon PPS Test Plan, 6116-00005 Yes 6116-00005-P

[0.3](-P), Revision 4 Diablo Canyon PPS ALS Subsystem Yes 6116-00011-P

[7.6]Design Specification, 6116-00011

(-P), Revision 9 Diablo Canyon PPS ISG04 Matrix, Yes 6116-00054-P

[0.4]6116-00054

(-P), Revision 0 Diablo Canyon PPS TxB1 and TxB2 Yes 6116-00100-P

[1.5]Communications Protocol Specification, 6116-00100

(-P), Revision 7 Diablo Canyon PPS ALS Subsystem Yes 6116-00204-P

[0.6]Equipment Qualification Evaluation, 6116-00204

(-P), Revision 2 Diablo Canyon PPS ALS Subsystem Yes 6116-00400-P

[1.0]Configuration Management Report, 6116-00400 (-P), Revision 7 Diablo Canyon PPS Configuration Yes 6116-00401-P

[0.2]Management Baseline Report, 6116-00401

(-P), Revision 4 Diablo Canyon PPS Independent Yes 6116-00500-P

[1.4]Verification and Validation Summary Report, 6116-00500

(-P), Revision 1 Diablo Canyon PPS Software Safety Plan, Yes 6116-10020-P

[0.3]6116-10020

(-P), Revision 2 14 The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 Enclosure PG&E Letter DCL-1 6-011 Diablo Canyon PPS W Simulation Yes 6116-10216-P 11.2]Environment Specification, 6116-10216

(-P), Revision 2 Diablo Canyon PPS System Test Design Yes 6116-70030-P

[0.2]Specification, 6116-70030

(-P), Revision 5 Diablo Canyon PPS Factory Acceptance Yes 6116-70033-P

[58.4]Test Report Protection Set I, 6116-70033

(-P), Revision 0 Diablo Canyon PPS Factory Acceptance Yes 6116-70034-P

[42.6]Test Report Protection Set II, 6116-70034

(-P), Revision 0 Diablo Canyon PPS Factory Acceptance Yes 6116-70035-P

[35.6]Test Report Protection Set III, 6116-70035

(-P), Revision 0 Diablo Canyon PPS Factory Acceptance Yes 6116-70036-P

[41.8]Test Report Protection Set IV, 6116-70036

(-P), Revision 0 15 The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 Enclosure Attachment 1 PG&E Letter DCL-16-01 1 PPS Replacement Functional Requirements Specification, Revision 9 The CD in Attachment 5 of the Enclosure Contains Proprietary information Withhold from public disclosure under 10 CFR 2.390 When separated from the CD in Attachment 5 to the Enclosure, this'document is decontrolled The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 Enclosure Attachment 4 PG&E Letter DCL-16-011 Westinghouse Application for Withholding Proprietary Information Letter CAW-1 5-431 3, Affidavit, Proprietary Information Notice, and Copyright Notice The CD in Attachment 5 of the Enclosure Contains Proprietary information Withhold from public disclosure under 10 CFR 2.390 When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled W e in houseWestinghouse Electric Comnpany 1000 Westinghouse Drive USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 940-8560 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 Project Letter: PGE-15-109 CAW-15-4313 October 27, 2015 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

6116-00000, Rev. 8, "Diablo Canyon Process Protection System Management Plan" (Proprietary) 6116-00003, Rev. 3, "Diablo Canyon PPS VV Plan" (Proprietary) 6116-00005, Rev. 4, "Diablo Canyon Process Protection System Test Plan" (Proprietary) 6116-00011, Rev. 9, "Diablo Canyon Process Protection System ALS Subsystem System Design Specification" (Proprietary) 6116-00054, Rev. 0, "Diablo Canyon PPS ISG04 Matrix" (Proprietary) 6116-00100, Revy. 7, "Diablo Canyon Process Protection System TxB 1 & TxB2 Communication Protocol Specification" (Proprietary) 6116-00204, Rev. 2, "Diablo Canyon Process Protection System ALS Subsystem Equipment Qualification Evaluation" (Proprietary) 6116-00400, Rev. 7, "Diablo Canyon Process Protection System ALS Subsystem Configuration Management Report" (Proprietary) 6116-00401, Rev. 4, "Diablo Canyon Process Protection System Configuration Management Baseline Report" (Proprietary) 6116-00500, Rev. 1, "Diablo Canyon Process Protection System Independent Verification and Validation Summary Report" (Proprietary) 6116-10020, Rev. 2, "Diablo Canyon Process Protection System Software Safety Plan" (Proprietary) 6116-10216, Rev. 2, "Diablo Canyon PPS VV Simulation Environment Specification" (proprietary) 61 i6-70030, Rev. 5, "Diablo Canyon Process Protection System System Test Design Specification" (Proprietary) 6116-70033, Rev. 0, "Diablo Canyon Process Protection System Factory Acceptance Test Report Protection Set r'(Proprietary) 6116-70034, Rev. 0, "Diablo Canyon Process Protection System Factory Acceptance Test Report Protection Set IF' (Proprietary) 6116-70035, Rev. 0, "Diablo Canyon Process Protection System Factory Acceptance Test Report Protection Set III"(Proprietary) 6116-70036, Rev. 0, "Diablo Canyon Process Protection System Factory Acceptance Test Report Protection Set IV"(proprietary)

The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC (Westinghouse), pursuant to the provisions of paragraph (b)(1) of CAW-1 5-4313 Section 2.3 90 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 in the above-referenced report is further identified in Affidavit CAW-1 5-4313 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission'ss regulations.

The subject document was prepared and classified as Westinghouse Proprietary Class 2. Westinghouse requests that the document be considered proprietary in its entirety.

As such, a non-proprietary version will not be issued.Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Pacific Gas &Electric.Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW- 15-4313, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.~Jamnes A. Gresham, Manager Regulatory Compliance CAW- 15 -4313 October 27, 2015 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

8S COUNTY OF BUTLER:* I, James A. Gresham, am authorized to execute this Affidavit on behalf 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 my knowledge, information, and belief.James A. Gresham, Manager Regulatory Compliance 2 2 CAW-l 15-4313 (1) I am Manager,.Regulatory Compliance, Westinghouse Electric Company LLC (Westinghouse), 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 Westinghouse.

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

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse 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 Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse 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 Westinghouse policy and provide 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 9 3 CAW- 15-4313 Westinghouse's competitors without license from Westinghouse 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 Westinghouse, its customers or suppliers.(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.(f) It contains patentable ideas, for which patent protection may be desirable.(iii) There are sound policy reasons behind the Westinghouse system which include the following: (a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors.

It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 4 CAW-1 5-4313 (d) Each component of proprietary information pertinent to a particular competitive advantage is pote~ntially as valuable as the total competitive advantage.

If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.(f) The Westinghouse to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.(iv) The information is being transmitted to th~e Commission in confidence and, under the provisions of 10 CFR Section 2.390, is to be received in confidence by the Commission.(v) 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.(vi) The proprietary information sought to be withheld in this submittal is that which is contained in 6116-00000, Rev. 8, "Diablo Canyon Process Protection System Management Plan" (Proprietary), 6116-00003, Rev. 3, "Diablo Canyon PPS VV Plan" (Proprietary), 6116-00005, Rev. 4, "Diablo Canyon Process Protection System Test Plan" (Proprietary), 6116-00011, Rev. 9, "Diablo Canyon Process Protection System ALS Subsystem System Design Specification" (Proprietary), 6116-00054, Rev. 0, "Diablo Canyon PPS IS5G04 Matrix" (Proprietary), 6116-00100, Rev. 7, "Diablo Canyon process Protection System TxB 1 & TxB2 Communication Protocol Specification" (proprietary), 6116-00204, Rev. 2, "Diablo Canyon Process Protection System ALS Subsystem Equipment Qualification Evaluation" (Proprietary), 6116-00400, Rev. 7, "Diablo Canyon Process Protection System ALS Subsystem Configuration Management Report" (Proprietary), 6116-00401, Rev. 4, "Diablo Canyon Process Protection System Configuration Management Baseline Report" (Proprietary), 6116-00500, Rev. 1, "Diablo 5 5 ~CAW- 15-43 13 Canyon Process Protection System Independent Verification and Validation Summary Report" (Proprietary), 61 16-10020, Rev. 2, "Diablo Canyon Process Protection System Software Safety Plan" (Proprietary), 6116-10216, Rev. 2, "Diablo Canyon PPS VV Simulation Environment Specification" (Proprietary), 6116-70030, Rev.5, "Diablo Canyon Process Protection System System Test Design Specification" (Proprietary), 6116-70033, Rev. 0, "Diablo Canyon Process Protection System Factory Acceptance Test Report Protection Set r'(Proprietary), 6116-70034, Rev. 0, "Diablo Canyon Process Protection System Factory Acceptance Test Report Protection Set II" (Proprietary), 6116-70035, Rev. 0, "Diablo Canyon Process Protection System Factory Acceptance Test Report Protection Set III"(Proprietary), 6116-70036, Rev. 0, "Diablo Canyon Process" Protection System Factory Acceptance Test Report Protection Set IV"(Proprietary), for submittal to the Commission, being transmitted by Pacific Gas & Electric letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the Diablo Canyon Process Protection System Upgrade, and may be used only for that purpose.(a) This information is part of that which will enable Westinghouse to assist the customer in obtaining NRC review of their License Amendment Request.(b) Further this information has substantial commercial value as follows: (i) Westinghouse plans to sell the use of similar information to its customers for the purpose of plant-specific applications.(ii) Westinghouse can sell support and defense of industry guidelines and acceptance criteria for plant-specific applications.(iii) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense 6 6 CAW- 15-431 3 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.

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 Westinghouse effort and the expenditure of a considerable sum of money.In order for competitors of Westinghouse 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 are the proprietary versions of documents furnished to the NRC associated with the Diablo Canyon Process Protection System Upgrade The documents are to be considered proprietary in their entirety.COPYRIGHT NOTICE The report transmitted herewith bears a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in this report 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.

The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 WI Pacific Gas and Electric Company°James M. Weisch Diablo Canyon Power Plant Vice President, Nuclear Generation P.O. Box 56 Avila Beach, CA 93424 805.545.3242 E-Mail: JMW1l5pge.corn January 25, 2016 PG&E Letter DCL-16-011 U.S. Nuclear Regulatory Commission 10 CER 50.90 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 I and 2 Response to Request for Additional Information and Submittal of Advanced Logqic System Phase 2 Documents for the License Amendment Request for 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. MLII1307A33 1).2. NRC email "Diablo Canyon I and 2 -RAIs for Digital Replacement of the Process Replacement System LAR (TAC Nos. ME7522 and ME7523)," dated December 23, 2015 (ADAMS Accession No.MLI5357A382).

3. NRC Letter "Summary of August 5, 2015, Teleconference Meeting with Pacific Gas and Electric Company on Digital Replacement of the Process Protection System Portion of the Reactor Trip System and Engineered Safety Features Actuation System at Diablo Canyon Power Plant, Unit Nos. I and 2 (TAO NOS. ME7522 AND ME7523)," dated September 10, 2015 (ADAMS Accession No. ML15233A006).

Dear Commissioners and Staff: In Reference 1, Pacific Gas and Electric Company (PG&E) submitted License Amendment Request 11-07 to request NRC Staff (Staff) 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 Westinghouse Electric Company Advanced Logic System (ALS). The Staff requested additional information to complete the review of Reference

1. This letter responds to the additional information requested inReernc 2The CD in Attachment 5 of the Enclosure Contains Proprietary Information P When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled v, A member of the STARS (Strategic Teaming and Resource Sharing) Altiance Cattaway

Diablo Canyon

Palo Verde

Wotf Creek The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 D ocument Control Desk PG&E Letter DCL-16-011 January 25, 2016 Page 2 This letter submits PPS Replacement Project documents in the following Attachments to the Enclosure in this letter: Attachment 1 -PPS Replacement Functional Requirements Specification, Revision 9 Attachment 2 -Interface Requirements Specification, Revision 9 Attachment 3 -Controller Transfer Functions Design Input Specification, Revision 4 Attachment 4 -Westinghouse Application for Withholding Proprietary Information Letter CAW-1 5-4313, Affidavit, Proprietary Information Notice, and Copyright Notice Attachment 5 -Compact Disk -"Advanced Logic System Phase 2 Documents

-Proprietary" The Staff requested that the documents contained in Attachments 1, 2, 3, and 5 of the Enclosure to be submitted in Open Item 145 contained in Enclosure 2 of Reference 3.The Westinghouse ALS documents contained on the compact disk (CD), labeled"Advanced Logic System Phase 2 Documents

-Proprietary," in Attachment 5 to the Enclosure are listed in Table 1 in the Enclosure to this letter. The CD contents are in Adobe Acrobat portable document format. The ALS documents are predominantly proprietary in content and, therefore, non-proprietary versions of the documents are not provided.The Westinghouse ALS documents on the CD in Attachment 5 contain proprietary information as identified by Westinghouse Electric Company, LLC. Accordingly, Attachment 4 includes a Westinghouse application for withholding proprietary information letter CAW-15-.4313, an accompanying affidavit, a Proprietary Information Notice, and a Copyright Notice. 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 Westinghouse affidavit, copyright, or proprietary aspects of the application for withholding the Westinghouse proprietary information provided in Attachment 5 should reference Westinghouse Letter CAW-1 5-4313, and be to: James A. Gresham Manager, Regulatory Compliance Westinghouse Electric Company 1000 Westinghouse Drive, Building 3 Suite 310 Cranberry Township, Pennsylvania 16066 A copy of the proprietary CD is being provided to-the following individuals:

Regional Administrator, Region IV DCPP Nuclear Reactor Regulation Project Manager DCPP NRC Senior Resident Inspector Branch Chief, California Department of Public Health The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Ca[laway

Diabto Canyon

Palo Verde

Wotf Creek The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 D ocument Control Desk PG&E Letter DCL-16-011 January 25, 2016 Page 3 The information in the Enclosure to this letter does not affect the results of the technical evaluation or the significant hazards consideration determination previously transmitted in Reference 1.PG&E makes no new or revised regulatory commitments (as defined by NEI 99-04) in this letter.If you have any questions, or require additional information, please contact Mr. Hossein Hamzehee at (805) 545-4720.I state under penalty of perjury that the foregoing is true and correct.Executed on January 25, 2016.Sincerely, James M. Welsch Vice President, Nuclear Generation kjse/4328/50271 918 Enclosure cc: Diablo Distribution cc/enc: Marc L. Dapas, NRC Region IV Siva P. Lingam, NRR Project Manager Gonzalo L. Perez, Branch Chief, California Department of Public Health Binesh K. Tharakan, Acting NRC Senior Resident Inspector The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390 When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled A member of the STARS (Strategic Teaming and Resource Sharing) Atliance CaL~away

Diablo Canyon

Pato Verde ° WoLf Creek The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold f~rom public disclosure under 10 CER 2.390 Enclosure PG&E Letter DCL-16-011I Response to Request for Additional Information on License Amendment Request for Digital Process Protection System Replacement Pacific Gas and Electric Company (PG&E) Letter DCL-1 1-104; "License Amendment Request 11-07, Process Protection System Replacement," dated October 26, 2011, submitted License Amendment Request (LAR) 11-07 to request NRC Staff (Staff)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 (IOM) Tricon Programmable Logic Controller (PLC), Version 10, and the Westinghouse Electric Company Field Programmable Gate Array (FPGA)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 of Digital Instrumentation and Controls (l&C), Revision 1, of Interim Staff Guidance (ISG) Digital I&C-ISG-06, "Task Working Group #6: Licensing Process." The 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.The Staff requested additional information to support the review of [AR 11-07 in NRC email "Diablo Canyon 1 and 2 -RAIs for Digital Replacement of the Process Protection System [AR (TAC Nos. ME7522 and ME7523)," dated December 23, 2015 (ADAMS Accession No; ML1 5357A382).