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{{Adams
#REDIRECT [[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 Replacement]]
| number = ML16049A009
| issue date = 01/25/2016
| title = 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
| author name = Welsch J M
| author affiliation = Pacific Gas & Electric Co
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000275, 05000323
| license number = DPR-080, DPR-082
| contact person =
| case reference number = PG&E Letter DCL-16-011
| package number = ML16049A006
| document type = Letter, Response to Request for Additional Information (RAI)
| page count = 29
}}
 
=Text=
{{#Wiki_filter:The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390WI Pacific Gas andElectric Company°James M. Weisch Diablo Canyon Power PlantVice President, Nuclear Generation P.O. Box 56Avila Beach, CA 93424805.545.3242 E-Mail: JMW1l5pge.corn January 25, 2016PG&E Letter DCL-16-011 U.S. Nuclear Regulatory Commission 10 CER 50.90ATTN: Document Control DeskWashington, DC 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units I and 2Response to Request for Additional Information and Submittal of Advanced LogqicSystem Phase 2 Documents for the License Amendment Request for ProcessProtection 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 ofthe Process Replacement System LAR (TAC Nos. ME7522 andME7523),"
dated December 23, 2015 (ADAMS Accession No.MLI5357A382).
: 3. NRC Letter "Summary of August 5, 2015, Teleconference Meeting withPacific Gas and Electric Company on Digital Replacement of theProcess Protection System Portion of the Reactor Trip System andEngineered Safety Features Actuation System at Diablo CanyonPower 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 LicenseAmendment Request 11-07 to request NRC Staff (Staff) approval to replace the DiabloCanyon Power Plant (DCPP) Eagle 21 digital process protection system (PPS) with anew digital PPS that is based on the Invensys Operations Management TriconProgrammable Logic Controller, Version 10, and the Westinghouse Electric CompanyAdvanced Logic System (ALS). The Staff requested additional information to completethe 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)
AltianceCattaway
* Diablo Canyon
* Palo Verde
* Wotf Creek The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390D ocument Control Desk PG&E Letter DCL-16-011 January 25, 2016Page 2This letter submits PPS Replacement Project documents in the following Attachments to the Enclosure in this letter:Attachment 1 -PPS Replacement Functional Requirements Specification, Revision 9Attachment 2 -Interface Requirements Specification, Revision 9Attachment 3 -Controller Transfer Functions Design Input Specification, Revision 4Attachment 4 -Westinghouse Application for Withholding Proprietary Information LetterCAW-1 5-4313, Affidavit, Proprietary Information Notice, and Copyright NoticeAttachment 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 theEnclosure 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 theEnclosure are listed in Table 1 in the Enclosure to this letter. The CD contents are inAdobe Acrobat portable document format. The ALS documents are predominantly proprietary in content and, therefore, non-proprietary versions of the documents are notprovided.
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 beto:James A. GreshamManager, Regulatory Compliance Westinghouse Electric Company1000 Westinghouse Drive, Building 3 Suite 310Cranberry
: Township, Pennsylvania 16066A copy of the proprietary CD is being provided to-the following individuals:
Regional Administrator, Region IVDCPP Nuclear Reactor Regulation Project ManagerDCPP NRC Senior Resident Inspector Branch Chief, California Department of Public HealthThe CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled A member of the STARS (Strategic Teaming and Resource Sharing)
AllianceCa[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 2.390D ocument Control Desk PG&E Letter DCL-16-011 January 25, 2016Page 3The 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) inthis letter.If you have any questions, or require additional information, please contactMr. 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. WelschVice President, Nuclear Generation kjse/4328/50271 918Enclosure cc: Diablo Distribution cc/enc: Marc L. Dapas, NRC Region IVSiva P. Lingam, NRR Project ManagerGonzalo L. Perez, Branch Chief, California Department of Public HealthBinesh 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 2.390When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled A member of the STARS (Strategic Teaming and Resource Sharing)
AtlianceCaL~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 2.390Enclosure PG&E Letter DCL-16-011I Response to Request for Additional Information on License Amendment Requestfor 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 processprotection system (PPS) with a new digital PPS that is based on the InvensysOperations Management (IOM) Tricon Programmable Logic Controller (PLC), Version10, and the Westinghouse Electric Company Field Programmable Gate Array (FPGA)based Advanced Logic System (ALS). The LAR 11-07 format and contents areconsistent with the guidance provided in Enclosure E and Section C.3 of DigitalInstrumentation and Controls (l&C), Revision 1, of Interim Staff Guidance (ISG) DigitalI&C-ISG-06, "Task Working Group #6: Licensing Process."
The Staff documented itsacceptance 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 DigitalProcess Protection System Replacement (TAC Nos. ME7522 and ME7523),"
datedJanuary 13, 2012.The Staff requested additional information to support the review of [AR 11-07 in NRCemail "Diablo Canyon 1 and 2 -RAIs for Digital Replacement of the Process Protection System [AR (TAC Nos. ME7522 and ME7523),"
dated December 23, 2015 (ADAMSAccession No; ML1 5357A382).
The request for additional information (RAl) isaddressed below for RAls 71 to 77. Each RAl contains a reference to an open itemthat corresponds to the number of the item in the Open Item table that PG&E hasdiscussed 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 theequipment vendors are required to confirm equipment compliance with physicalrequirements in the DCPP Functional Requirements Specification (ERS). Theserequirements include the Electro Magnetic Compatibility (EMC) requirements fromSection 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 anelectromagnetic 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 V10PLC system did not fully meet the guidance of RG 1.180, Revision 1, for conducted orradiated emissions or susceptibility.
As a result, the safety evaluation (SE) of theTricon 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 ofThe 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 2.390Enclosure PG&E Letter DCL-1 6-011the 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 EMIrequirements to be enveloped by the Tricon VIG test levels achieved and documented in the Tricon VIO safety evaluation.
PG&E Response to RAI 71The 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 undertest complied with the allowable emissions and susceptibility levels required byRG 1.180 with the exception of allowable conducted emissions level (MIL-STD-461 E,"Requirements for the Control of Electromagnetic Interference Emissions andSusceptibility, US Department Of Defense, August 1999" tests CE101 and CE1 02) forlow 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.
Withthe line filter installed, the MIL-STD-461-E, CE102 conducted emissions wereacceptable.
Therefore, PG&E is including a Corcom Model 30VSK6 line filter on theinput of the 120 VAC power supply for the PPS Replacement design. With use of theCorcom Model 30VSK6 line filter on the input of the 120 VAC power supply, the highfrequency conducted emissions meets the guidance of RG 1.180.RG 1.180 provides an exemption from CEl01 testing if: (1) the power qualityrequirements of the equipment are consistent with the existing power supply anddesign practices include power quality controls and, (2) the new equipment will notimpose additional harmonic distortion on the power distribution system exceeding 5 percent total harmonic distortion or other power quality criteria established with avalid technical basis. The 120 VAC power to the Tricon is to be supplied by Class I1Evital instrument power with appropriate quality requirements and design practices inplace. Based on testing performed for another similar application at DCPP (powersupplies located in a Tricon chassis located in safety-related auxiliary building and fuelhandling ventilation control system cabinets),
no appreciable difference in the harmonicdistortion of the instrument Alternating Current (AC) system was observed before andafter the power supplies were installed.
Therefore, the RG 1.180 criteria for exemption from CE101 testing are met for the PPS Replacement Tricon equipment.
2The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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-16-011I NRC RAI 72 (Open Item 119) IOM LaptopsInvensy Operations Management (IOM) is using laptops, one per Protection Set plusone 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 fivedevelopment laptops and IOM will be delivering them to PG&E as part of the Triconproduct delivery.
: However, during the Invensys audit on June 3-5, 2014, PG&Einformed the staff that it does not plan to use these laptops, and only plans to use theTniStation installed on the PPS maintenance work stations.
Please clarify what PG&Ewill do with the five development laptops once they are delivered to them. Also, pleaseclarify what controls will be placed on the TriStation softvware installed on these laptopcomputers.
PG&E Response to RAI 72The PG&E laptops provided for development of the VI10 Tricon were not designated assafety-related and will not be used in the PPS Replacement system by PG&E in thefuture 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 tocause a board to enter the HALT mode.PG&E Response to RAI 73The detailed information on operation of the ALS HALT mode of operation and the vitalerrors that can occur to cause the board to enter the HALT mode is designated asWestinghouse proprietary information.
Therefore, Westinghouse submitted thisinformation directly to the NRC in Westinghouse Letter LTR-NRC-16-1, datedJanuary 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 staffneeds 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 SafetyEvaluation conclusions.
3The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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-16-011 PG&E Response to RAI 74The current revision of the ALS document 6116-00204, "ALS Subsystem Equipment Qualification Evaluation,"
Revision 2, is contained on the CD in Attachment 5 to theEnclosure of this letter.NRC RAI 75 (Open Item 147) EQ: Temperature and HumidityPlease clarify if FRS Section 3.1.4.1 specifies the temperature and relative humidityworst case conditions expected in the cable spreading room (i.e., mild environment) fornormal, 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, andc. 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 theALS and Tricon subsystems is acceptable for the broader range of RH specified in theFRS 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 inSection 3.11.2.1 of the Updated Final Safety Analysis Report under AccidentEnvironments.
PG&E Response to RAI 75FRS Section 3.1.4.1 states:3.1.4.1.1 Temperature:
40Oto 104°F3.1.4.1.2 Relative Humidity (RH): 0 to 95 percent (non-condensing)
The design basis for the cable spreading room ventilation system is the cablespreading room is maintained at an average temperature of 72+/-5° F and normalhumidity 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 onApril 13, 2015.4The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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 1DCM T-20 Table A4.2-1, Normal Operation
: Pressure, Temperature and Humiditystates:Cable Spreading Room (Auxiliary Building)
Temperature  104°FHumidity  95 percent RHPage 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 RHspecification.
There are no accident environmental conditions since the cable spreading roomenvironment is considered a "mild environment" as defined by DCM T-20:An environment that would at no time be significantly more severe than theenvironment 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(1010F setpoint with 2°F allowed for instrument uncertainty) by Equipment ControlGuideline 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 hours, or openthe cabinet doors and verify temperature less than 11 9°F, or perform an evaluation ofoperability, or to declare the equipment in the cabinet inoperable.
The Tricon Topical Report (7286-545-1-A, Revision
: 4) states that the equipment shallmeet its performance requirements during and following exposure to abnormalenvironmental conditions of 40°F to 140°F. The ALS Subsystem System DesignSpecification (6116-10201, Revision
: 5) provides a temperature limitation of less than140°F. The cable spreading room temperature range (40-104°F) is within the vendorspecified ranges for the Tricon and ALS equipment.
As discussed during the status phone call with the staff on December 22, 2015, thePG&E documentation for temperature rise within the cabinets and the design basisroom temperature (heat load) margin are being added to the Staff inspection item listfor Staff verification prior to the PPS Replacement design being placed in service.HumidityThe humidity in the cable spreading room is monitored and controlled to less than90 percent RH. If 90 percent RH is exceeded, procedural actions require restoration ofthe humidity to within limits. Procedure OP H-10:IV, "Auxiliary Building Ventilation
-OffNormal Operation" provides guidance to restore humidity to within limits.5The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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-16-011 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 SystemDesign Specification (6116-00011, Revision 9). The methodology used to perform theALS humidity environmental testing is contained in WCAP-8587-(NP),
Revision 6-A,"Methodology for Qualifying Westinghouse WRD (Water Reactor Division)
SuppliedNSSS 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) areenveloped by the more conservative humidity levels included in the test. The onlyfailure mechanism associated with low humidity is electrostatic discharge, which isaddressed by item R1610 of the ALS System Design Specification.
Therefore, the ALStest qualified range of 35 to 95 percent RH bounds the cable spreading room RH rangeof 0-95 percent RH.The test qualified range of RH for the Tricon subsystem is 5 to 95 percent.
InvensysOperations 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 therisks from electrostatic discharge, including proper equipment grounding andelectrostatic discharge prevention practices.
NRC RAI 76 (Open Items 151 and 152)PG&E "DCPP Project Procedure, System Verification and Validation Plan (SyVVP) forthe PPS Replacement Project" and "Quality Assurance Plan for the Diablo CanyonProcess Protection System Replacement" state that PG&E will perform management and activities during the design, development, and testing of the ALS and TriconSystem. Please describe the activities performed by PG&E.PG&E Response to RAI 76PG&E project and quality personnel performed activities in accordance with the SyVVPand Quality Assurance Plan during the design, development, and testing of the ALSand Tricon subsystems.
During the design of the PPS Replacement, plant specific project documents createdby the vendors were reviewed by PG&E project engineering and management personnel, and the vendors incorporated PG&E comments prior to issuance of thedocuments.
6The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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-16-011I In 2012, PG&E Quality Verification personnel performed an assessment of thequalifications and third party audits of the four main vendors for the project, AltranSolutions, Invensys Operations Management, Westinghouse Electric
: Company, andCS Innovations.
The assessment supported the listing of the four vendors on thePG&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 reviewedthe cyber security implementation and software development implementation for theproject.
The audit determined CS Innovations was following their program forsoftware/hardware design and development for the project purchase orders and designspecifications, 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 anaudit at the IOM facility in Lake Forest, California, and reviewed the cyber security, implementation and software development implementation for the project.
The auditdetermined IOM was following their program for software/hardware design anddevelopment for the project purchase orders and design specifications, and that thework was being performed in a Secure Development Operating Environment inaccordance with RG 1.152. One minor finding was identified related to the multipleversions of IEEE 1028, "Standard for Software Reviews,"
that were contained in IOMproject planning documents.
IOM corrected the reference to IEEE 1028 in the planningdocuments.
During the development of the PPS Replacement from 2013 to 2014, PG&E QualityVerification personnel assessed the technical adequacy of design phasedocumentation that was developed by PG&E and Altran Solutions personnel.
Thedocumentation 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 thatthe roles and responsibilities of the "Supervisor Supplier Quality,"
were not correctly defined in the SyQAP and Project Plan documents, and these documents were revisedto provide the correct definition.
7The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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-16-011I During testing of the PPS Replacement in 2014, PG&E Quality Verification and ProjectEngineering personnel attended the Factory Acceptance Testing (FAT) of the Triconportion of PPS Replacement system at the IOM facility in Lake Forest, California.
Thereview activities included review of the FAT plan documents being used for FATtesting, 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, andconfirmation that the hardware was being supplied in accordance with the hardwarepurchase order.During testing of the PPS Replacement in 2015, PG&E Quality Verification and ProjectEngineering 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 ofthe for FAT testing, review of the FAT test reports, verification that test anomalies orfailures were tracked by Westinghouse "On-time Tickets,"
and confirmation that thehardware was being supplied in accordance with the hardware purchase order.NRC RAI 77 (Open Item 156) Human Factorsa. Section 4.10.2.14, "Clause 5.14 Human Factors Considerations (SectionD.9.4.2.
14 of DI&C-ISG-06
[1])," of the Enclosure to the LAR states, in part: "Theexisting operator interface using control panel mounted switches and indicators ismaintained."
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 designshould follow the guidance provided in the DCPP HSI Development Guidelines
: Document, which reference NUREG 0700, and which will be implemented duringdevelopment of the formal design change following receipt by PG&E of the SER [safetyevaluation 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 theguidance 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 PPSoutputs to the MAS [Main Annunciator System] are modified to dry contacts.
Theexisting AC/DC [alternating current/direct current]
converters on the PPS outputs to theMAS are deleted.
Additional outputs to the MAS are provided..."
8The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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-16-011I Section 1.1, "System Purpose,"
of the Functional Requirements Specification Document No. 08-0015-SP-OO1, Revision 9, states, in part: "Output signals of PPSparameters 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 forstatus indication, manual trip switches, and manual bypass switches applicable to allPPS channels.
Section 3.2.1.5,
'Alarms and Annunciators,"
identifies the requirements for alarms andannunciators 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 alarmsand annunciators that are specific to the respective channels.
Please clarify what additional indicators, status lights, alarms, and annunciators arebeing 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 proposedlicense amendment.
If possible, identify which procedures will be revised.If the Emergency Operating procedures are affected, please describe any changes thatwere required of the Control Room task analysis that was done as part of your DetailedContfrol 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, orchanged to support the proposed license amendment.
If there are any new or changedmanual operator
: actions, describe the process used to verify and validate the ability ofyour operators to accomplish the tasks required for the proposed LAR. In lieu of adescription, 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 PowerOperations]
: reports, and other relevant sources.
If so, describe what sources ofinformation were considered and the outcome of the review (i.e., list any relevant[Human Factors Engineering]
HEE-related problems that were identified,
: analyzed, andaddressed).
9The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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-16-011I PG&E Response to RAI 77a. For the PPS Replacement, the existing operator interface with the control panelmounted switches and indicators will not be revised and therefore will not utilize theHuman System Interface (HSI) Development Guidelines Document.
As part of the PPS Replacement, an existing HSI unit in the control room (that waspreviously installed for a Process Control System replacement project) will also beused 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 obtainPPS data through a connection to an existing plant data network non-safety Gatewaycomputer that is installed in the plant. The HSI Development Guidelines Document willbe 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 eightMWSs for the PPS) that will be installed in the PPS instrumentation cabinets.
The HSIDevelopment Guidelines Document was used by the vendors to develop the displayscreens and operator interface with the MWSs.b. The digital PPS Replacement design is replacing the existing digital Eagle-21protection system. The existing control room control panel indicators, status lights,controls, alarms, and annunciators are sufficient and will be utilized for the PPSReplacement design. PG&E notes that the LAR was written to address all digitalinstrumentation 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 closedPPS instrumentation cabinets that are manually opened to access the chassis.
Tosupport system monitoring, surveillances, troubleshooting, and maintenance, thechassis for the Tricon and ALS subsystems contain local controls, indicators, andstatus 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 moduleis 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 bypass10The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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*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 toperform its function.
The operational aspects of the digital PPS Replacement are beingdesigned to be consistent with the existing digital Eagle-21 protection system for nearlyall operationa!
aspects.
There are no Technical Specification instrument setpointchanges required due to the PPS Replacement and no revised surveillance intervals are being implement as part of the PPS Replacement Project.
Therefore, the requiredoperating 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. Forexample, when a control panel alarm occurs, the procedures will be updated to provideinstructions for use of the HSI unit in the control room to display detailed systemdiagnostic results to support determination of what specific failure occurred to supporttroubleshooting, repair, and return of the PPS to Technical Specification Operablestatus. 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 verifyoperational procedures.
Operating Procedures "OP AP-5, Malfunction of Eagle 21 Protection Channel andControl" 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).
Theprocedure includes guidance to determine the extent of the Eagle 21 instrumentation failure using control panel and plant process computer information.
The OP AP-5procedure for each unit will need to be updated to include the control panel and plantprocess computer information that will be provided when instrumentation failures occurin the PPS Replacement equipment to facilitate diagnosis of the failed PPSReplacement equipment.
Revisions to the Technical Specification Surveillance procedures
("STP I-" seriessurveillance 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 actionsneeded to perform the tests. It is noted that the plant design already includesinstrument loop bypass testing capability and this feature will continue to be utilizedwith the PPS Replacement equipment.
As described in Section 4.15.1 of the LAR, theintegrated PPS Replacement system used for Site Acceptance Testing will also beused to develop and verify the maintenance procedures.
Emergency Operating Procedure "EOP E-0, Reactor Trip or Safety Injection,"
for eachunit provides actions to ensure proper response of the automatic protection systems11The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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-16-011I following manual or automatic actuation of a reactor trip or safety injection.
Nochanges affecting operators are required for EOP E-0 for the PPS Replacement equipment because the procedure directs manual actions to initiate a reactor trip andsafety injection signal if they do not occur automatically (i.e., a postulated failure of aPPS automatic actuation) and these operator actions will not be changed due to thePPS Replacement equipment.
The PPS Replacement design does not alter thecurrent plant system level manual actions to initiate a reactor trip, safety injection, orother engineered safety features actuation.
As part of the design change process, which uses the training Systematic Approach toTraining Process for plant modifications, the required operator training needs to bedeveloped and implemented to support the PPS Replacement modification.
Operatorsimulator training is developed and implemented as needed as part of the designchanges process.
As described in Section 4.15.1 of the LAR, the integrated PPSReplacement system used for Site Acceptance Testing will also be used to performtraining.
The simulator computer code will need to be modified to model the operational characteristics of the PPS Replacement system Tricon and ALS equipment.
Nophysical changes to the simulator control board are required for installation of the PPSReplacement system.d. The PPS is an automatic system that does not require operator involvement toperform 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 designis 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 theprotection function.
The PPS Replacement contains new, additional diversity featuresthat prevent a common-cause software failure from completely disabling the processprotection 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 thatwill no longer be required with the PPS Replacement.
: e. PG&E personnel performed a review of industry operating experience for thePPS Replacement Tricon and ALS technology, including, performing a review andinspection of installed applications of the technology.
No relevant HFE-related problems have been identified for the PPS Replacement Tricon and ALS technology.
12The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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-16-011I For the Tricon subsystem portion of the PPS Replacement design, PG&E hassignificant operating experience with the Tricon system as a result of installation of thetechnology in multiple non-safety related control system applications (e.g., ProcessControl System, Feedwater Control System, Turbine Control System) at DCPP. TheTricon hardware performance at DCPP and in the industry has been exceptional withno hardware actuation failures due to the triple modular redundant architecture of theTricon hardware.
The only operating experience issue at DCPP for the Triconhardware 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 inputsin the same Tricon due to the grounding configuration used in the Process ControlSystem; a circuit ground was used instead of an earth ground. All Process ControlSystem and Instrument Rack Tricons were modified so that earth grounds were used inlieu of circuit grounds in accordance with manufacturer recommendation and weresuccessfully tested. Revision of the grounding method to use of an earth ground hasbeen added as a lesson learned.For the ALS subsystem portion of the PPS Replacement design, Wolf Creek hasinstalled the CS Innovations FPGA-based ALS design in the Main Steam andFeedwater Isolation System. There have been no actuation failures of the ALShardware 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 inTable 1 below and contained on one compact disk (CD), labeled "Advanced LogicSystem Phase 2 Documents
-Proprietary,"
contained in Attachment 5 to the Enclosure of this letter. The contents are in Adobe Acrobat portable document format.13The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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-16-011I Table 1Enclosure 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 8Diablo Canyon PPS W Plan, 6116-00003 Yes 6116-00003-P
[0.4](-P), Revision 3Diablo Canyon PPS Test Plan, 6116-00005 Yes 6116-00005-P
[0.3](-P), Revision 4Diablo Canyon PPS ALS Subsystem Yes 6116-00011-P
[7.6]Design Specification, 6116-00011
(-P),Revision 9Diablo Canyon PPS ISG04 Matrix, Yes 6116-00054-P
[0.4]6116-00054
(-P), Revision 0Diablo Canyon PPS TxB1 and TxB2 Yes 6116-00100-P
[1.5]Communications Protocol Specification, 6116-00100
(-P), Revision 7Diablo Canyon PPS ALS Subsystem Yes 6116-00204-P
[0.6]Equipment Qualification Evaluation, 6116-00204
(-P), Revision 2Diablo Canyon PPS ALS Subsystem Yes 6116-00400-P
[1.0]Configuration Management Report, 6116-00400 (-P), Revision 7Diablo Canyon PPS Configuration Yes 6116-00401-P
[0.2]Management Baseline Report, 6116-00401
(-P), Revision 4Diablo Canyon PPS Independent Yes 6116-00500-P
[1.4]Verification and Validation SummaryReport, 6116-00500
(-P), Revision 1Diablo Canyon PPS Software Safety Plan, Yes 6116-10020-P
[0.3]6116-10020
(-P), Revision 214The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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-1 6-011Diablo Canyon PPS W Simulation Yes 6116-10216-P 11.2]Environment Specification, 6116-10216
(-P), Revision 2Diablo Canyon PPS System Test Design Yes 6116-70030-P
[0.2]Specification, 6116-70030
(-P), Revision 5Diablo Canyon PPS Factory Acceptance Yes 6116-70033-P
[58.4]Test Report Protection Set I, 6116-70033
(-P), Revision 0Diablo Canyon PPS Factory Acceptance Yes 6116-70034-P
[42.6]Test Report Protection Set II, 6116-70034
(-P), Revision 0Diablo Canyon PPS Factory Acceptance Yes 6116-70035-P
[35.6]Test Report Protection Set III, 6116-70035
(-P), Revision 0Diablo Canyon PPS Factory Acceptance Yes 6116-70036-P
[41.8]Test Report Protection Set IV, 6116-70036
(-P), Revision 015The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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 Attachment 1PG&E Letter DCL-16-01 1PPS Replacement Functional Requirements Specification, Revision 9The CD in Attachment 5 of the Enclosure Contains Proprietary information Withhold from public disclosure under 10 CFR 2.390When 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 Attachment 4PG&E Letter DCL-16-011 Westinghouse Application for Withholding Proprietary Information Letter CAW-1 5-431 3, Affidavit, Proprietary Information Notice,and Copyright NoticeThe CD in Attachment 5 of the Enclosure Contains Proprietary information Withhold from public disclosure under 10 CFR 2.390When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled W e in houseWestinghouse Electric Comnpany1000 Westinghouse DriveUSAU.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643Document Control Desk Direct fax: (724) 940-856011555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 Project Letter: PGE-15-109 CAW-15-4313 October 27, 2015APPLICATION 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 DesignSpecification" (Proprietary) 6116-00054, Rev. 0, "Diablo Canyon PPS ISG04 Matrix" (Proprietary) 6116-00100, Revy. 7, "Diablo Canyon Process Protection System TxB 1 & TxB2 Communication ProtocolSpecification" (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 BaselineReport" (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 ReportProtection Set r'(Proprietary) 6116-70034, Rev. 0, "Diablo Canyon Process Protection System Factory Acceptance Test ReportProtection Set IF' (Proprietary) 6116-70035, Rev. 0, "Diablo Canyon Process Protection System Factory Acceptance Test ReportProtection Set III"(Proprietary) 6116-70036, Rev. 0, "Diablo Canyon Process Protection System Factory Acceptance Test ReportProtection Set IV"(proprietary)
The Application for Withholding Proprietary Information from Public Disclosure is submitted byWestinghouse Electric Company LLC (Westinghouse),
pursuant to the provisions of paragraph (b)(1) of CAW-1 5-4313Section 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 isfurther 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 basison which the information may be withheld from public disclosure by the Commission and addresses withspecificity 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 versionwill 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 theWestinghouse 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, ManagerRegulatory Compliance CAW- 15 -4313October 27, 2015AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
8SCOUNTY OF BUTLER:* I, James A. Gresham, am authorized to execute this Affidavit on behalf of Westinghouse ElectricCompany LLC (Westinghouse),
and that the averments of fact set forth in this Affidavit are true andcorrect to the best of my knowledge, information, and belief.James A. Gresham, ManagerRegulatory Compliance 22 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 plantlicensing and rule making proceedings, and am authorized to apply for its withholding on behalfof Westinghouse.
(2) I am making this Affidavit in conformance with the provisions of 10 CER Section 2.390 of theCommission'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 theinformation 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 heldin confidence by Westinghouse.
(ii) The information is of a type customarily held in confidence by Westinghouse and notcustomarily 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 inconfidence.
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 severaltypes, 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 93 CAW- 15-4313Westinghouse's competitors without license from Westinghouse constitutes acompetitive economic advantage over other companies.
(b) It consists of supporting data, including test data, relative to a process (orcomponent, structure, tool, method, etc.), the application of which data secures acompetitive economic advantage, e.g., by optimization or improvedmarketability.
(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive 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, orcommercial strategies of Westinghouse, its customers or suppliers.
(e) It reveals aspects of past, present, or future Westinghouse or customer fundeddevelopment 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 thefollowing:
(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors.
It is, therefore, withheld from disclosure toprotect the Westinghouse competitive position.
(b) It is information that is marketable in many ways. The extent to which suchinformation is available to competitors diminishes the Westinghouse ability tosell products and services involving the use of the information.
(c) Use by our competitor would put Westinghouse at a competitive disadvantage byreducing his expenditure of resources at our expense.
44 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.
Ifcompetitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage.
(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse in the world market, and thereby give a market advantage to thecompetition of those countries.
(f) The Westinghouse to invest corporate assets in research anddevelopment depends upon the success in obtaining and maintaining acompetitive advantage.
(iv) The information is being transmitted to th~e Commission in confidence and, under theprovisions 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 tothe best of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which iscontained in 6116-00000, Rev. 8, "Diablo Canyon Process Protection SystemManagement 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 ALSSubsystem System Design Specification" (Proprietary),
6116-00054, Rev. 0, "DiabloCanyon PPS IS5G04 Matrix" (Proprietary),
6116-00100, Rev. 7, "Diablo Canyon processProtection 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 CanyonProcess Protection System ALS Subsystem Configuration Management Report"(Proprietary),
6116-00401, Rev. 4, "Diablo Canyon Process Protection SystemConfiguration Management Baseline Report" (Proprietary),
6116-00500, Rev. 1, "Diablo 55 ~CAW- 15-43 13Canyon Process Protection System Independent Verification and Validation SummaryReport" (Proprietary),
61 16-10020, Rev. 2, "Diablo Canyon Process Protection SystemSoftware Safety Plan" (Proprietary),
6116-10216, Rev. 2, "Diablo Canyon PPS VVSimulation Environment Specification" (Proprietary),
6116-70030, Rev.5, "DiabloCanyon 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 ProcessProtection System Factory Acceptance Test Report Protection Set II" (Proprietary),
6116-70035, Rev. 0, "Diablo Canyon Process Protection System Factory Acceptance TestReport Protection Set III"(Proprietary),
6116-70036, Rev. 0, "Diablo Canyon Process"Protection System Factory Acceptance Test Report Protection Set IV"(Proprietary),
forsubmittal to the Commission, being transmitted by Pacific Gas & Electric letter andApplication for Withholding Proprietary Information from Public Disclosure, to theDocument Control Desk. The proprietary information as submitted by Westinghouse isthat associated with the Diablo Canyon Process Protection System Upgrade, and may beused only for that purpose.(a) This information is part of that which will enable Westinghouse to assist thecustomer 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 andacceptance 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 thecompetitive position of Westinghouse because it would enhance the ability ofcompetitors to provide similar technical evaluation justifications and licensing defense 66 CAW- 15-431 3services for commercial power reactors without commensurate expenses.
Also, publicdisclosure of the information would enable others to use the information to meet NRCrequirements for licensing documentation without purchasing the right to use theinformation.
The development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort andthe 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 therequisite talent and experience, would have to be expended.
Further the deponent sayeth not.
PROPRIETARY INFORMATION NOTICETransmitted herewith are the proprietary versions of documents furnished to the NRC associated with theDiablo Canyon Process Protection System Upgrade The documents are to be considered proprietary intheir entirety.
COPYRIGHT NOTICEThe report transmitted herewith bears a Westinghouse copyright notice. The NRC is permitted to makethe number of copies of the information contained in this report which is necessary for its internal use inconnection 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 publicdisclosure 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 2.390WI Pacific Gas andElectric Company°James M. Weisch Diablo Canyon Power PlantVice President, Nuclear Generation P.O. Box 56Avila Beach, CA 93424805.545.3242 E-Mail: JMW1l5pge.corn January 25, 2016PG&E Letter DCL-16-011 U.S. Nuclear Regulatory Commission 10 CER 50.90ATTN: Document Control DeskWashington, DC 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units I and 2Response to Request for Additional Information and Submittal of Advanced LogqicSystem Phase 2 Documents for the License Amendment Request for ProcessProtection 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 ofthe Process Replacement System LAR (TAC Nos. ME7522 andME7523),"
dated December 23, 2015 (ADAMS Accession No.MLI5357A382).
: 3. NRC Letter "Summary of August 5, 2015, Teleconference Meeting withPacific Gas and Electric Company on Digital Replacement of theProcess Protection System Portion of the Reactor Trip System andEngineered Safety Features Actuation System at Diablo CanyonPower 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 LicenseAmendment Request 11-07 to request NRC Staff (Staff) approval to replace the DiabloCanyon Power Plant (DCPP) Eagle 21 digital process protection system (PPS) with anew digital PPS that is based on the Invensys Operations Management TriconProgrammable Logic Controller, Version 10, and the Westinghouse Electric CompanyAdvanced Logic System (ALS). The Staff requested additional information to completethe 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)
AltianceCattaway
* Diablo Canyon
* Palo Verde
* Wotf Creek The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390D ocument Control Desk PG&E Letter DCL-16-011 January 25, 2016Page 2This letter submits PPS Replacement Project documents in the following Attachments to the Enclosure in this letter:Attachment 1 -PPS Replacement Functional Requirements Specification, Revision 9Attachment 2 -Interface Requirements Specification, Revision 9Attachment 3 -Controller Transfer Functions Design Input Specification, Revision 4Attachment 4 -Westinghouse Application for Withholding Proprietary Information LetterCAW-1 5-4313, Affidavit, Proprietary Information Notice, and Copyright NoticeAttachment 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 theEnclosure 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 theEnclosure are listed in Table 1 in the Enclosure to this letter. The CD contents are inAdobe Acrobat portable document format. The ALS documents are predominantly proprietary in content and, therefore, non-proprietary versions of the documents are notprovided.
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 beto:James A. GreshamManager, Regulatory Compliance Westinghouse Electric Company1000 Westinghouse Drive, Building 3 Suite 310Cranberry
: Township, Pennsylvania 16066A copy of the proprietary CD is being provided to-the following individuals:
Regional Administrator, Region IVDCPP Nuclear Reactor Regulation Project ManagerDCPP NRC Senior Resident Inspector Branch Chief, California Department of Public HealthThe CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled A member of the STARS (Strategic Teaming and Resource Sharing)
AllianceCa[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 2.390D ocument Control Desk PG&E Letter DCL-16-011 January 25, 2016Page 3The 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) inthis letter.If you have any questions, or require additional information, please contactMr. 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. WelschVice President, Nuclear Generation kjse/4328/50271 918Enclosure cc: Diablo Distribution cc/enc: Marc L. Dapas, NRC Region IVSiva P. Lingam, NRR Project ManagerGonzalo L. Perez, Branch Chief, California Department of Public HealthBinesh 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 2.390When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled A member of the STARS (Strategic Teaming and Resource Sharing)
AtlianceCaL~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 2.390Enclosure PG&E Letter DCL-16-011I Response to Request for Additional Information on License Amendment Requestfor 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 processprotection system (PPS) with a new digital PPS that is based on the InvensysOperations Management (IOM) Tricon Programmable Logic Controller (PLC), Version10, and the Westinghouse Electric Company Field Programmable Gate Array (FPGA)based Advanced Logic System (ALS). The LAR 11-07 format and contents areconsistent with the guidance provided in Enclosure E and Section C.3 of DigitalInstrumentation and Controls (l&C), Revision 1, of Interim Staff Guidance (ISG) DigitalI&C-ISG-06, "Task Working Group #6: Licensing Process."
The Staff documented itsacceptance 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 DigitalProcess Protection System Replacement (TAC Nos. ME7522 and ME7523),"
datedJanuary 13, 2012.The Staff requested additional information to support the review of [AR 11-07 in NRCemail "Diablo Canyon 1 and 2 -RAIs for Digital Replacement of the Process Protection System [AR (TAC Nos. ME7522 and ME7523),"
dated December 23, 2015 (ADAMSAccession No; ML1 5357A382).
The request for additional information (RAl) isaddressed below for RAls 71 to 77. Each RAl contains a reference to an open itemthat corresponds to the number of the item in the Open Item table that PG&E hasdiscussed 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 theequipment vendors are required to confirm equipment compliance with physicalrequirements in the DCPP Functional Requirements Specification (ERS). Theserequirements include the Electro Magnetic Compatibility (EMC) requirements fromSection 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 anelectromagnetic 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 V10PLC system did not fully meet the guidance of RG 1.180, Revision 1, for conducted orradiated emissions or susceptibility.
As a result, the safety evaluation (SE) of theTricon 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 ofThe 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 2.390Enclosure PG&E Letter DCL-1 6-011the 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 EMIrequirements to be enveloped by the Tricon VIG test levels achieved and documented in the Tricon VIO safety evaluation.
PG&E Response to RAI 71The 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 undertest complied with the allowable emissions and susceptibility levels required byRG 1.180 with the exception of allowable conducted emissions level (MIL-STD-461 E,"Requirements for the Control of Electromagnetic Interference Emissions andSusceptibility, US Department Of Defense, August 1999" tests CE101 and CE1 02) forlow 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.
Withthe line filter installed, the MIL-STD-461-E, CE102 conducted emissions wereacceptable.
Therefore, PG&E is including a Corcom Model 30VSK6 line filter on theinput of the 120 VAC power supply for the PPS Replacement design. With use of theCorcom Model 30VSK6 line filter on the input of the 120 VAC power supply, the highfrequency conducted emissions meets the guidance of RG 1.180.RG 1.180 provides an exemption from CEl01 testing if: (1) the power qualityrequirements of the equipment are consistent with the existing power supply anddesign practices include power quality controls and, (2) the new equipment will notimpose additional harmonic distortion on the power distribution system exceeding 5 percent total harmonic distortion or other power quality criteria established with avalid technical basis. The 120 VAC power to the Tricon is to be supplied by Class I1Evital instrument power with appropriate quality requirements and design practices inplace. Based on testing performed for another similar application at DCPP (powersupplies located in a Tricon chassis located in safety-related auxiliary building and fuelhandling ventilation control system cabinets),
no appreciable difference in the harmonicdistortion of the instrument Alternating Current (AC) system was observed before andafter the power supplies were installed.
Therefore, the RG 1.180 criteria for exemption from CE101 testing are met for the PPS Replacement Tricon equipment.
2The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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-16-011I NRC RAI 72 (Open Item 119) IOM LaptopsInvensy Operations Management (IOM) is using laptops, one per Protection Set plusone 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 fivedevelopment laptops and IOM will be delivering them to PG&E as part of the Triconproduct delivery.
: However, during the Invensys audit on June 3-5, 2014, PG&Einformed the staff that it does not plan to use these laptops, and only plans to use theTniStation installed on the PPS maintenance work stations.
Please clarify what PG&Ewill do with the five development laptops once they are delivered to them. Also, pleaseclarify what controls will be placed on the TriStation softvware installed on these laptopcomputers.
PG&E Response to RAI 72The PG&E laptops provided for development of the VI10 Tricon were not designated assafety-related and will not be used in the PPS Replacement system by PG&E in thefuture 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 tocause a board to enter the HALT mode.PG&E Response to RAI 73The detailed information on operation of the ALS HALT mode of operation and the vitalerrors that can occur to cause the board to enter the HALT mode is designated asWestinghouse proprietary information.
Therefore, Westinghouse submitted thisinformation directly to the NRC in Westinghouse Letter LTR-NRC-16-1, datedJanuary 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 staffneeds 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 SafetyEvaluation conclusions.
3The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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-16-011 PG&E Response to RAI 74The current revision of the ALS document 6116-00204, "ALS Subsystem Equipment Qualification Evaluation,"
Revision 2, is contained on the CD in Attachment 5 to theEnclosure of this letter.NRC RAI 75 (Open Item 147) EQ: Temperature and HumidityPlease clarify if FRS Section 3.1.4.1 specifies the temperature and relative humidityworst case conditions expected in the cable spreading room (i.e., mild environment) fornormal, 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, andc. 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 theALS and Tricon subsystems is acceptable for the broader range of RH specified in theFRS 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 inSection 3.11.2.1 of the Updated Final Safety Analysis Report under AccidentEnvironments.
PG&E Response to RAI 75FRS Section 3.1.4.1 states:3.1.4.1.1 Temperature:
40Oto 104°F3.1.4.1.2 Relative Humidity (RH): 0 to 95 percent (non-condensing)
The design basis for the cable spreading room ventilation system is the cablespreading room is maintained at an average temperature of 72+/-5° F and normalhumidity 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 onApril 13, 2015.4The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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 1DCM T-20 Table A4.2-1, Normal Operation
: Pressure, Temperature and Humiditystates:Cable Spreading Room (Auxiliary Building)
Temperature  104°FHumidity  95 percent RHPage 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 RHspecification.
There are no accident environmental conditions since the cable spreading roomenvironment is considered a "mild environment" as defined by DCM T-20:An environment that would at no time be significantly more severe than theenvironment 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(1010F setpoint with 2°F allowed for instrument uncertainty) by Equipment ControlGuideline 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 hours, or openthe cabinet doors and verify temperature less than 11 9°F, or perform an evaluation ofoperability, or to declare the equipment in the cabinet inoperable.
The Tricon Topical Report (7286-545-1-A, Revision
: 4) states that the equipment shallmeet its performance requirements during and following exposure to abnormalenvironmental conditions of 40°F to 140°F. The ALS Subsystem System DesignSpecification (6116-10201, Revision
: 5) provides a temperature limitation of less than140°F. The cable spreading room temperature range (40-104°F) is within the vendorspecified ranges for the Tricon and ALS equipment.
As discussed during the status phone call with the staff on December 22, 2015, thePG&E documentation for temperature rise within the cabinets and the design basisroom temperature (heat load) margin are being added to the Staff inspection item listfor Staff verification prior to the PPS Replacement design being placed in service.HumidityThe humidity in the cable spreading room is monitored and controlled to less than90 percent RH. If 90 percent RH is exceeded, procedural actions require restoration ofthe humidity to within limits. Procedure OP H-10:IV, "Auxiliary Building Ventilation
-OffNormal Operation" provides guidance to restore humidity to within limits.5The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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-16-011 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 SystemDesign Specification (6116-00011, Revision 9). The methodology used to perform theALS humidity environmental testing is contained in WCAP-8587-(NP),
Revision 6-A,"Methodology for Qualifying Westinghouse WRD (Water Reactor Division)
SuppliedNSSS 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) areenveloped by the more conservative humidity levels included in the test. The onlyfailure mechanism associated with low humidity is electrostatic discharge, which isaddressed by item R1610 of the ALS System Design Specification.
Therefore, the ALStest qualified range of 35 to 95 percent RH bounds the cable spreading room RH rangeof 0-95 percent RH.The test qualified range of RH for the Tricon subsystem is 5 to 95 percent.
InvensysOperations 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 therisks from electrostatic discharge, including proper equipment grounding andelectrostatic discharge prevention practices.
NRC RAI 76 (Open Items 151 and 152)PG&E "DCPP Project Procedure, System Verification and Validation Plan (SyVVP) forthe PPS Replacement Project" and "Quality Assurance Plan for the Diablo CanyonProcess Protection System Replacement" state that PG&E will perform management and activities during the design, development, and testing of the ALS and TriconSystem. Please describe the activities performed by PG&E.PG&E Response to RAI 76PG&E project and quality personnel performed activities in accordance with the SyVVPand Quality Assurance Plan during the design, development, and testing of the ALSand Tricon subsystems.
During the design of the PPS Replacement, plant specific project documents createdby the vendors were reviewed by PG&E project engineering and management personnel, and the vendors incorporated PG&E comments prior to issuance of thedocuments.
6The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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-16-011I In 2012, PG&E Quality Verification personnel performed an assessment of thequalifications and third party audits of the four main vendors for the project, AltranSolutions, Invensys Operations Management, Westinghouse Electric
: Company, andCS Innovations.
The assessment supported the listing of the four vendors on thePG&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 reviewedthe cyber security implementation and software development implementation for theproject.
The audit determined CS Innovations was following their program forsoftware/hardware design and development for the project purchase orders and designspecifications, 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 anaudit at the IOM facility in Lake Forest, California, and reviewed the cyber security, implementation and software development implementation for the project.
The auditdetermined IOM was following their program for software/hardware design anddevelopment for the project purchase orders and design specifications, and that thework was being performed in a Secure Development Operating Environment inaccordance with RG 1.152. One minor finding was identified related to the multipleversions of IEEE 1028, "Standard for Software Reviews,"
that were contained in IOMproject planning documents.
IOM corrected the reference to IEEE 1028 in the planningdocuments.
During the development of the PPS Replacement from 2013 to 2014, PG&E QualityVerification personnel assessed the technical adequacy of design phasedocumentation that was developed by PG&E and Altran Solutions personnel.
Thedocumentation 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 thatthe roles and responsibilities of the "Supervisor Supplier Quality,"
were not correctly defined in the SyQAP and Project Plan documents, and these documents were revisedto provide the correct definition.
7The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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-16-011I During testing of the PPS Replacement in 2014, PG&E Quality Verification and ProjectEngineering personnel attended the Factory Acceptance Testing (FAT) of the Triconportion of PPS Replacement system at the IOM facility in Lake Forest, California.
Thereview activities included review of the FAT plan documents being used for FATtesting, 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, andconfirmation that the hardware was being supplied in accordance with the hardwarepurchase order.During testing of the PPS Replacement in 2015, PG&E Quality Verification and ProjectEngineering 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 ofthe for FAT testing, review of the FAT test reports, verification that test anomalies orfailures were tracked by Westinghouse "On-time Tickets,"
and confirmation that thehardware was being supplied in accordance with the hardware purchase order.NRC RAI 77 (Open Item 156) Human Factorsa. Section 4.10.2.14, "Clause 5.14 Human Factors Considerations (SectionD.9.4.2.
14 of DI&C-ISG-06
[1])," of the Enclosure to the LAR states, in part: "Theexisting operator interface using control panel mounted switches and indicators ismaintained."
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 designshould follow the guidance provided in the DCPP HSI Development Guidelines
: Document, which reference NUREG 0700, and which will be implemented duringdevelopment of the formal design change following receipt by PG&E of the SER [safetyevaluation 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 theguidance 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 PPSoutputs to the MAS [Main Annunciator System] are modified to dry contacts.
Theexisting AC/DC [alternating current/direct current]
converters on the PPS outputs to theMAS are deleted.
Additional outputs to the MAS are provided..."
8The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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-16-011I Section 1.1, "System Purpose,"
of the Functional Requirements Specification Document No. 08-0015-SP-OO1, Revision 9, states, in part: "Output signals of PPSparameters 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 forstatus indication, manual trip switches, and manual bypass switches applicable to allPPS channels.
Section 3.2.1.5,
'Alarms and Annunciators,"
identifies the requirements for alarms andannunciators 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 alarmsand annunciators that are specific to the respective channels.
Please clarify what additional indicators, status lights, alarms, and annunciators arebeing 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 proposedlicense amendment.
If possible, identify which procedures will be revised.If the Emergency Operating procedures are affected, please describe any changes thatwere required of the Control Room task analysis that was done as part of your DetailedContfrol 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, orchanged to support the proposed license amendment.
If there are any new or changedmanual operator
: actions, describe the process used to verify and validate the ability ofyour operators to accomplish the tasks required for the proposed LAR. In lieu of adescription, 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 PowerOperations]
: reports, and other relevant sources.
If so, describe what sources ofinformation were considered and the outcome of the review (i.e., list any relevant[Human Factors Engineering]
HEE-related problems that were identified,
: analyzed, andaddressed).
9The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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-16-011I PG&E Response to RAI 77a. For the PPS Replacement, the existing operator interface with the control panelmounted switches and indicators will not be revised and therefore will not utilize theHuman System Interface (HSI) Development Guidelines Document.
As part of the PPS Replacement, an existing HSI unit in the control room (that waspreviously installed for a Process Control System replacement project) will also beused 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 obtainPPS data through a connection to an existing plant data network non-safety Gatewaycomputer that is installed in the plant. The HSI Development Guidelines Document willbe 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 eightMWSs for the PPS) that will be installed in the PPS instrumentation cabinets.
The HSIDevelopment Guidelines Document was used by the vendors to develop the displayscreens and operator interface with the MWSs.b. The digital PPS Replacement design is replacing the existing digital Eagle-21protection system. The existing control room control panel indicators, status lights,controls, alarms, and annunciators are sufficient and will be utilized for the PPSReplacement design. PG&E notes that the LAR was written to address all digitalinstrumentation 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 closedPPS instrumentation cabinets that are manually opened to access the chassis.
Tosupport system monitoring, surveillances, troubleshooting, and maintenance, thechassis for the Tricon and ALS subsystems contain local controls, indicators, andstatus 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 moduleis 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 bypass10The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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*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 toperform its function.
The operational aspects of the digital PPS Replacement are beingdesigned to be consistent with the existing digital Eagle-21 protection system for nearlyall operationa!
aspects.
There are no Technical Specification instrument setpointchanges required due to the PPS Replacement and no revised surveillance intervals are being implement as part of the PPS Replacement Project.
Therefore, the requiredoperating 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. Forexample, when a control panel alarm occurs, the procedures will be updated to provideinstructions for use of the HSI unit in the control room to display detailed systemdiagnostic results to support determination of what specific failure occurred to supporttroubleshooting, repair, and return of the PPS to Technical Specification Operablestatus. 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 verifyoperational procedures.
Operating Procedures "OP AP-5, Malfunction of Eagle 21 Protection Channel andControl" 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).
Theprocedure includes guidance to determine the extent of the Eagle 21 instrumentation failure using control panel and plant process computer information.
The OP AP-5procedure for each unit will need to be updated to include the control panel and plantprocess computer information that will be provided when instrumentation failures occurin the PPS Replacement equipment to facilitate diagnosis of the failed PPSReplacement equipment.
Revisions to the Technical Specification Surveillance procedures
("STP I-" seriessurveillance 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 actionsneeded to perform the tests. It is noted that the plant design already includesinstrument loop bypass testing capability and this feature will continue to be utilizedwith the PPS Replacement equipment.
As described in Section 4.15.1 of the LAR, theintegrated PPS Replacement system used for Site Acceptance Testing will also beused to develop and verify the maintenance procedures.
Emergency Operating Procedure "EOP E-0, Reactor Trip or Safety Injection,"
for eachunit provides actions to ensure proper response of the automatic protection systems11The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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-16-011I following manual or automatic actuation of a reactor trip or safety injection.
Nochanges affecting operators are required for EOP E-0 for the PPS Replacement equipment because the procedure directs manual actions to initiate a reactor trip andsafety injection signal if they do not occur automatically (i.e., a postulated failure of aPPS automatic actuation) and these operator actions will not be changed due to thePPS Replacement equipment.
The PPS Replacement design does not alter thecurrent plant system level manual actions to initiate a reactor trip, safety injection, orother engineered safety features actuation.
As part of the design change process, which uses the training Systematic Approach toTraining Process for plant modifications, the required operator training needs to bedeveloped and implemented to support the PPS Replacement modification.
Operatorsimulator training is developed and implemented as needed as part of the designchanges process.
As described in Section 4.15.1 of the LAR, the integrated PPSReplacement system used for Site Acceptance Testing will also be used to performtraining.
The simulator computer code will need to be modified to model the operational characteristics of the PPS Replacement system Tricon and ALS equipment.
Nophysical changes to the simulator control board are required for installation of the PPSReplacement system.d. The PPS is an automatic system that does not require operator involvement toperform 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 designis 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 theprotection function.
The PPS Replacement contains new, additional diversity featuresthat prevent a common-cause software failure from completely disabling the processprotection 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 thatwill no longer be required with the PPS Replacement.
: e. PG&E personnel performed a review of industry operating experience for thePPS Replacement Tricon and ALS technology, including, performing a review andinspection of installed applications of the technology.
No relevant HFE-related problems have been identified for the PPS Replacement Tricon and ALS technology.
12The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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-16-011I For the Tricon subsystem portion of the PPS Replacement design, PG&E hassignificant operating experience with the Tricon system as a result of installation of thetechnology in multiple non-safety related control system applications (e.g., ProcessControl System, Feedwater Control System, Turbine Control System) at DCPP. TheTricon hardware performance at DCPP and in the industry has been exceptional withno hardware actuation failures due to the triple modular redundant architecture of theTricon hardware.
The only operating experience issue at DCPP for the Triconhardware 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 inputsin the same Tricon due to the grounding configuration used in the Process ControlSystem; a circuit ground was used instead of an earth ground. All Process ControlSystem and Instrument Rack Tricons were modified so that earth grounds were used inlieu of circuit grounds in accordance with manufacturer recommendation and weresuccessfully tested. Revision of the grounding method to use of an earth ground hasbeen added as a lesson learned.For the ALS subsystem portion of the PPS Replacement design, Wolf Creek hasinstalled the CS Innovations FPGA-based ALS design in the Main Steam andFeedwater Isolation System. There have been no actuation failures of the ALShardware 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 inTable 1 below and contained on one compact disk (CD), labeled "Advanced LogicSystem Phase 2 Documents
-Proprietary,"
contained in Attachment 5 to the Enclosure of this letter. The contents are in Adobe Acrobat portable document format.13The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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-16-011I Table 1Enclosure 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 8Diablo Canyon PPS W Plan, 6116-00003 Yes 6116-00003-P
[0.4](-P), Revision 3Diablo Canyon PPS Test Plan, 6116-00005 Yes 6116-00005-P
[0.3](-P), Revision 4Diablo Canyon PPS ALS Subsystem Yes 6116-00011-P
[7.6]Design Specification, 6116-00011
(-P),Revision 9Diablo Canyon PPS ISG04 Matrix, Yes 6116-00054-P
[0.4]6116-00054
(-P), Revision 0Diablo Canyon PPS TxB1 and TxB2 Yes 6116-00100-P
[1.5]Communications Protocol Specification, 6116-00100
(-P), Revision 7Diablo Canyon PPS ALS Subsystem Yes 6116-00204-P
[0.6]Equipment Qualification Evaluation, 6116-00204
(-P), Revision 2Diablo Canyon PPS ALS Subsystem Yes 6116-00400-P
[1.0]Configuration Management Report, 6116-00400 (-P), Revision 7Diablo Canyon PPS Configuration Yes 6116-00401-P
[0.2]Management Baseline Report, 6116-00401
(-P), Revision 4Diablo Canyon PPS Independent Yes 6116-00500-P
[1.4]Verification and Validation SummaryReport, 6116-00500
(-P), Revision 1Diablo Canyon PPS Software Safety Plan, Yes 6116-10020-P
[0.3]6116-10020
(-P), Revision 214The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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-1 6-011Diablo Canyon PPS W Simulation Yes 6116-10216-P 11.2]Environment Specification, 6116-10216
(-P), Revision 2Diablo Canyon PPS System Test Design Yes 6116-70030-P
[0.2]Specification, 6116-70030
(-P), Revision 5Diablo Canyon PPS Factory Acceptance Yes 6116-70033-P
[58.4]Test Report Protection Set I, 6116-70033
(-P), Revision 0Diablo Canyon PPS Factory Acceptance Yes 6116-70034-P
[42.6]Test Report Protection Set II, 6116-70034
(-P), Revision 0Diablo Canyon PPS Factory Acceptance Yes 6116-70035-P
[35.6]Test Report Protection Set III, 6116-70035
(-P), Revision 0Diablo Canyon PPS Factory Acceptance Yes 6116-70036-P
[41.8]Test Report Protection Set IV, 6116-70036
(-P), Revision 015The CD in Attachment 5 of the Enclosure Contains Proprietary Information Withhold from public disclosure under 10 CFR 2.390When 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 Attachment 1PG&E Letter DCL-16-01 1PPS Replacement Functional Requirements Specification, Revision 9The CD in Attachment 5 of the Enclosure Contains Proprietary information Withhold from public disclosure under 10 CFR 2.390When 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 Attachment 4PG&E Letter DCL-16-011 Westinghouse Application for Withholding Proprietary Information Letter CAW-1 5-431 3, Affidavit, Proprietary Information Notice,and Copyright NoticeThe CD in Attachment 5 of the Enclosure Contains Proprietary information Withhold from public disclosure under 10 CFR 2.390When separated from the CD in Attachment 5 to the Enclosure, this document is decontrolled W e in houseWestinghouse Electric Comnpany1000 Westinghouse DriveUSAU.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643Document Control Desk Direct fax: (724) 940-856011555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 Project Letter: PGE-15-109 CAW-15-4313 October 27, 2015APPLICATION 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 DesignSpecification" (Proprietary) 6116-00054, Rev. 0, "Diablo Canyon PPS ISG04 Matrix" (Proprietary) 6116-00100, Revy. 7, "Diablo Canyon Process Protection System TxB 1 & TxB2 Communication ProtocolSpecification" (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 BaselineReport" (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 ReportProtection Set r'(Proprietary) 6116-70034, Rev. 0, "Diablo Canyon Process Protection System Factory Acceptance Test ReportProtection Set IF' (Proprietary) 6116-70035, Rev. 0, "Diablo Canyon Process Protection System Factory Acceptance Test ReportProtection Set III"(Proprietary) 6116-70036, Rev. 0, "Diablo Canyon Process Protection System Factory Acceptance Test ReportProtection Set IV"(proprietary)
The Application for Withholding Proprietary Information from Public Disclosure is submitted byWestinghouse Electric Company LLC (Westinghouse),
pursuant to the provisions of paragraph (b)(1) of CAW-1 5-4313Section 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 isfurther 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 basison which the information may be withheld from public disclosure by the Commission and addresses withspecificity 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 versionwill 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 theWestinghouse 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, ManagerRegulatory Compliance CAW- 15 -4313October 27, 2015AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
8SCOUNTY OF BUTLER:* I, James A. Gresham, am authorized to execute this Affidavit on behalf of Westinghouse ElectricCompany LLC (Westinghouse),
and that the averments of fact set forth in this Affidavit are true andcorrect to the best of my knowledge, information, and belief.James A. Gresham, ManagerRegulatory Compliance 22 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 plantlicensing and rule making proceedings, and am authorized to apply for its withholding on behalfof Westinghouse.
(2) I am making this Affidavit in conformance with the provisions of 10 CER Section 2.390 of theCommission'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 theinformation 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 heldin confidence by Westinghouse.
(ii) The information is of a type customarily held in confidence by Westinghouse and notcustomarily 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 inconfidence.
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 severaltypes, 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 93 CAW- 15-4313Westinghouse's competitors without license from Westinghouse constitutes acompetitive economic advantage over other companies.
(b) It consists of supporting data, including test data, relative to a process (orcomponent, structure, tool, method, etc.), the application of which data secures acompetitive economic advantage, e.g., by optimization or improvedmarketability.
(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive 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, orcommercial strategies of Westinghouse, its customers or suppliers.
(e) It reveals aspects of past, present, or future Westinghouse or customer fundeddevelopment 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 thefollowing:
(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors.
It is, therefore, withheld from disclosure toprotect the Westinghouse competitive position.
(b) It is information that is marketable in many ways. The extent to which suchinformation is available to competitors diminishes the Westinghouse ability tosell products and services involving the use of the information.
(c) Use by our competitor would put Westinghouse at a competitive disadvantage byreducing his expenditure of resources at our expense.
44 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.
Ifcompetitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage.
(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse in the world market, and thereby give a market advantage to thecompetition of those countries.
(f) The Westinghouse to invest corporate assets in research anddevelopment depends upon the success in obtaining and maintaining acompetitive advantage.
(iv) The information is being transmitted to th~e Commission in confidence and, under theprovisions 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 tothe best of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which iscontained in 6116-00000, Rev. 8, "Diablo Canyon Process Protection SystemManagement 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 ALSSubsystem System Design Specification" (Proprietary),
6116-00054, Rev. 0, "DiabloCanyon PPS IS5G04 Matrix" (Proprietary),
6116-00100, Rev. 7, "Diablo Canyon processProtection 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 CanyonProcess Protection System ALS Subsystem Configuration Management Report"(Proprietary),
6116-00401, Rev. 4, "Diablo Canyon Process Protection SystemConfiguration Management Baseline Report" (Proprietary),
6116-00500, Rev. 1, "Diablo 55 ~CAW- 15-43 13Canyon Process Protection System Independent Verification and Validation SummaryReport" (Proprietary),
61 16-10020, Rev. 2, "Diablo Canyon Process Protection SystemSoftware Safety Plan" (Proprietary),
6116-10216, Rev. 2, "Diablo Canyon PPS VVSimulation Environment Specification" (Proprietary),
6116-70030, Rev.5, "DiabloCanyon 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 ProcessProtection System Factory Acceptance Test Report Protection Set II" (Proprietary),
6116-70035, Rev. 0, "Diablo Canyon Process Protection System Factory Acceptance TestReport Protection Set III"(Proprietary),
6116-70036, Rev. 0, "Diablo Canyon Process"Protection System Factory Acceptance Test Report Protection Set IV"(Proprietary),
forsubmittal to the Commission, being transmitted by Pacific Gas & Electric letter andApplication for Withholding Proprietary Information from Public Disclosure, to theDocument Control Desk. The proprietary information as submitted by Westinghouse isthat associated with the Diablo Canyon Process Protection System Upgrade, and may beused only for that purpose.(a) This information is part of that which will enable Westinghouse to assist thecustomer 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 andacceptance 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 thecompetitive position of Westinghouse because it would enhance the ability ofcompetitors to provide similar technical evaluation justifications and licensing defense 66 CAW- 15-431 3services for commercial power reactors without commensurate expenses.
Also, publicdisclosure of the information would enable others to use the information to meet NRCrequirements for licensing documentation without purchasing the right to use theinformation.
The development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort andthe 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 therequisite talent and experience, would have to be expended.
Further the deponent sayeth not.
PROPRIETARY INFORMATION NOTICETransmitted herewith are the proprietary versions of documents furnished to the NRC associated with theDiablo Canyon Process Protection System Upgrade The documents are to be considered proprietary intheir entirety.
COPYRIGHT NOTICEThe report transmitted herewith bears a Westinghouse copyright notice. The NRC is permitted to makethe number of copies of the information contained in this report which is necessary for its internal use inconnection 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 publicdisclosure 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.}}

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