DCL-12-120, Submittal of Revised Phases 1 & 2 Documents for License Amendment Request for Digital Process Protection System Replacement

Submittal of Revised Phases 1 & 2 Documents for License Amendment Request for Digital Process Protection System Replacement

ML13004A468
Person / Time
Site:	Diablo Canyon
Issue date:	11/27/2012
From:	Allen B Pacific Gas & Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML130040687	List: DCL-12-120, Submittal of Revised Phases 1 & 2 Documents for License Amendment Request for Digital Process Protection System Replacement ML13004A469 ML13004A470 ML13004A471 ML13004A472 ML13004A473 ML13004A474
References
DCL-12-120
Download: ML13004A468 (13)

Text

Attachments 8-13 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 Pacific Gas and Electric Company' Barry S. Allen Diablo Canyon Power Plant Site Vice President Mail Code 104/6 P.0. Box 56 Avila Beach, CA 93424 November 27, 2012 805.545.4888 Internal: 691.4888 PG&E Letter DCL-12120 Fax: 805.545.6445 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Submittal of Revised Phase 1 and Phase 2 Documents for the License Amendment Request for Diqital Process Protection System Replacement

References:

1. PG&E Letter DCL-1 1-104, "License Amendment Request 11-07, Process Protection System Replacement," dated October 26, 2011 (ADAMS Accession No. MI1 1307A331).

2. Digital Instrumentation and Controls DI&C-ISG-06 Task Working Group #6: "Licensing Process Interim Staff Guidance," Revision 1, January 19, 2011 (ADAMS Accession No. ML110140103).

3. NRC Letter "Diablo Canyon Power Plant, Unit Nos. 1 and 2 -

Acceptance Review of License Amendment Request for Digital Process Protection System Replacement (TAC Nos. ME7522 and ME7523)," dated January 13, 2012.

4. PG&E Letter DCL-12-069, "Submittal of Quality Assurance Plan and Revised Phase 1 Documents for the License Amendment Request for Digital Process Protection System Replacement,"

dated August 2, 2102 (ADAMS Accession No. ML12222A094)

5. Invensys Operations Management Letter, "Invensys Operations Management Submittal to Support License Amendment Request from PG&E for Replacement of the Eagle 21 Process Protection System at Diablo Canyon Power Plant," dated October 26, 2011 (ADAMS Accession No. ML113190392).

6. Invensys Operations Management Letter, "Invensys Operations Management Submittal to Support License Amendment Request from PG&E for Replacement of the Eagle 21 Process Protection System at Diablo Canyon Power Plant," dated October 28, 2011 (ADAMS Accession No. MI1 1307A267).

7. PG&E Letter DCL-12-050, "Submittal of Phase 2 Documents for the License Amendment Request for Digital Process Protection Attachments 8-13 to the Enclosure contain Proprietary Information When separated from Attachments 8-13 to the Enclosure, this document is decontrolled.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway - Comanche Peak - Diablo Canyon

• Palo Verde

• San Onofre

• South Texas Project

• Wolf Creek I

Attachments 8-13 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390

• Document Control Desk PG&E Letter DCL-12-120 November 27, 2012 Page 2 System Replacement," dated June 6, 2012 (ADAMS Accession No. ML12170A837).

Dear Commissioners and Staff:

In Reference 1, Pacific Gas and Electric (PG&E) submitted License Amendment Request (LAR) 11-07 to request NRC approval to replace the Diablo Canyon Power Plant Eagle 21 digital process protection system (PPS) with a new digital PPS that is based on the Invensys Operations Management Tricon Programmable Logic Controller, Version 10, and the CS Innovations, LLC (a Westinghouse Electric Company), Advanced Logic System. The LAR format and contents in Reference 1 are consistent with the guidance provided in Enclosure E and Section C.3, respectively, of Digital Instrumentation and Controls (I&C) Revision 1 of Interim Staff Guidance Digital I&C-ISG-06, "Licensing Process" (ISG-06) (Reference 2). In Reference 3, the NRC staff documented its acceptance of Reference 1 for review and identified ISG 06 Phase 2 documents to support the LAR that needed to be submitted.

This letter submits revised PG&E software requirements specification and revised Invensys Operations Management Tricon software quality assurance plan (SQAP),

software project management plan (PMP), and project quality plan (PQP) ISG 06 Phase 1 documents. This letter also submits the Invensys Operations Management Tricon requirement traceability matrix, verification and validation (V&V) reports, and software safety analysis ISG 06 Phase 2 documents.

PG&E has revised the ISG-06 Phase 1 software requirements specification documents, "Diablo Canyon Power Plant Units 1 & 2 Process Protection System (PPS) Replacement Functional Requirements Specification" (FRS) and "Diablo Canyon Power Plant Units 1 & 2 Process Protection System (PPS) Replacement Interface Requirements Specification" (IRS). The revised "Diablo Canyon Power Plant Units 1 & 2 PPS Replacement FRS, Revision 7," and "Diablo Canyon Power Plant Units 1 & 2 PPS Replacement IRS, Revision 7," are contained in Attachments 1 and 2 to the Enclosure, respectively. These revised FRS and IRS documents supersede those previously submitted in Attachments 2 and 3 to the Enclosure of Reference 4, respectively.

Invensys Operations Management has revised the Tricon ISG 06 Phase 1 documents, "993754-1-801, Process Protection System Replacement Diablo Canyon Power Plant Software Quality Assurance Plan (SQAP)," "993754-1-905, Process Protection System Replacement Diablo Canyon Power Plant Project Management Plan (PMP)," and "993754-1-900, Process Protection System Replacement Diablo Canyon Power Plant Project Quality Plan (PQP)." The revised non-proprietary versions, 993754-1-801, Revision 1, 993754-1-905, Revision 2, and 993754-1-900, Revision 1, are contained in Attachments 4, 5, and 6 to the Attachments 8-13 to the Enclosure contain Proprietary Information When separated from Attachments 8-13 to the Enclosure, this document is decontrolled.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway - Comanche Peak

• Diablo Canyon

• Palo Verde

• San Onofre

• South Texas Project

• Wolf Creek A

Attachments 8-13 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 Document Control Desk PG&E Letter DCL-12-120 November 27, 2012 Page 3 Enclosure, respectively, and the revised proprietary versions, 993754-1-801, Revision 1, and 993754-1-905, Revision 2, are contained in Attachments 8 and 9 to the Enclosure, respectively. These revised SQAP, PMP, and PQP documents supersede those previously submitted by Invensys Operations Management in Reference 5.

Invensys Operations Management has revised the Tricon software requirements specification ISG 06 Phase 1 documents, "993754-11-809, Process Protection System Replacement Diablo Canyon Power Plant Software Requirements Specification (SRS) Protection Set I," "993754-12-809, Process Protection System Replacement Diablo Canyon Power Plant Software Requirements Specification (SRS) Protection Set IH," "993754-13-809, Process Protection System Replacement Diablo Canyon Power Plant Software Requirements Specification (SRS) Protection Set IIl," and "993754-14-809, Process Protection System Replacement Diablo Canyon Power Plant Software Requirements Specification (SRS) Protection Set IV."

The revised proprietary versions of the SRS for each protection set are contained in 0 to the Enclosure. These revised SRS documents supersede those previously submitted by Invensys Operations Management in Reference 6.

In reference 7, PG&E committed to submit the Tricon software safety analysis, requirements traceability matrix, and V&V ISG 06 Phase 2 documents. The non-proprietary version of the Invensys Operations Management Tricon software safety analysis document, "993754-1-915, Revision 1, Process Protection System Replacement Diablo Canyon Power Plant Safety Analysis," is contained in to the Enclosure and the proprietary version, "993754-1-915, Revision 1, Process Protection System Replacement Diablo Canyon Power Plant Software Safety Analysis," is contained in Attachment 11. The proprietary versions of the Invensys Operations Management Tricon requirements traceability matrix document, "993754-1-804, Revision 1, Process Protection System Replacement Project, Project Traceability Matrix," and the V&V document "993754-1-860, Revision 1, Process Protection System Replacement Diablo Canyon Power Plant V&V Requirements Phase Summary Report," are contained in Attachments 12 and 13 to the Enclosure, respectively.

This letter contains Invensys Operations Management documents contained in Attachments 8 to 13 to the Enclosure that contain information proprietary to Invensys Operations Management. Accordingly, Attachment 3 to the Enclosure includes Invensys Operations Management Affidavit No. 993754-AFF-46T. The affidavit is signed by Invensys Operations Management, the owner of the information. The affidavit sets forth the basis on which the Invensys Operations Management proprietary information contained in Attachments 8 to 13 to the Enclosure may be withheld from public disclosure by the Commission, and it addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390 of the Commission's regulations. PG&E requests that the Invensys Attachments 8-13 to the Enclosure contain Proprietary Information When separated from Attachments 8-13 to the Enclosure, this document is decontrolled.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Caltaway

• Comanche Peak

• Diabto Canyon

• Palo Verde

• San Onofre

• South Texas Project

• Wolf Creek

Attachments 8-13 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 Document Control Desk PG&E Letter DCL-12-120 November 27, 2012 Page 4 Operations Management proprietary information be withheld from public disclosure in accordance with 10 CFR 2.390. Correspondence with respect to the Invensys Operations Management affidavit or the Invensys Operations Management proprietary information provided in Attachments 8 to 13 of the Enclosure should reference Invensys Operations Management Affidavit No. 993754-AFF-46T and be addressed to Roman Shaffer, Project Manager, Invensys Operations Management, 26561 Rancho Parkway South, Lake Forest, CA 92630.

If you have any questions, or require additional information, please contact Tom Baldwin at (805) 545-4720.

This information does not affect the results of the technical evaluation or the significant hazards consideration determination previously transmitted in Reference 1.

This letter satisfies the portion of commitment Number 1 of Attachment 1 to the Enclosure of Reference 7 to submit the Invensys Operations Management requirement traceability matrix, (V&V) reports, and software safety analysis ISG 06 Phase 2 documents.

This communication does not contain regulatory commitments (as defined by NEI 99-04).

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

Executed on November 27, 2012.

Sincerely, Barry S.Allen Site Vice President kjse/4328 SAPN 50271918 Enclosure cc: Diablo Distribution cc/enc: Gonzalo L. Perez, Branch Chief, California Department of Public Health Elmo E. Collins, NRC Region IV Laura H. Micewski, Acting NRC Senior Resident Inspector Joseph M. Sebrosky, NRR Project Manager Attachments 8-13 to the Enclosure contain Proprietary Information When separated from Attachments 8-13 to the Enclosure, this document is decontrolled.

A member of the STARS (Strategic Teaming and Resource Sharing) Altiance Catlaway - Comanche Peak

• Diablo Canyon - Palo Verde

• San Onofre

• South Texas Project

• Wotf Creek

Attachments 8-13 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 Enclosure PG&E Letter DCL-12-120 Submittal of Revised Phase I and Phase 2 Documents for the License Amendment Request for Digital Process Protection System Replacement In Pacific Gas and Electric (PG&E) Letter DCL-1 1-104, "License Amendment Request 11-07, Process Protection System Replacement," dated October 26, 2011, PG&E submitted License Amendment Request (LAR) 11-07 to request NRC approval to replace the Diablo Canyon Power Plant Eagle 21 digital process protection system (PPS) with a new digital PPS that is based on the Invensys Operations Management Tricon Programmable Logic Controller, Version 10, and the CS Innovations, LLC (a Westinghouse Electric Company), Field Programmable Gate Array based Advanced Logic System. The LAR 11-07 format and contents are consistent with the guidance provided in Enclosure E and Section C.3, respectively, of Digital Instrumentation and Controls (I&C) Revision 1 of Interim Staff Guidance Digital I&C-ISG-06, "Licensing Process" (ISG-06).

The staff documented its acceptance of LAR 11-07 for review in the NRC Letter "Diablo Canyon Power Plant, Unit Nos. 1 and 2 - Acceptance Review of License Amendment Request for Digital Process Protection System Replacement (TAC Nos. ME7522 and ME7523)," dated January 13, 2012, and requested further clarification be provided for nine items. PG&E's response to the staffs request for further clarification was submitted in PG&E Letter DCL-12-030, "Response to Items Contained in NRC Acceptance Review of License Amendment Request for Digital Process Protection System Replacement," dated April 2, 2012.

This letter submits revised PG&E software requirements specification and revised Invensys Operations Management Tricon software quality assurance plan (SQAP),

software project management plan (PMP), and project quality plan (PQP) ISG 06 Phase 1 documents. This letter also submits the Invensys Operations Management Tricon requirement traceability matrix, verification and validation (V&V) reports, and software safety analysis ISG 06 Phase 2 documents.

PG&E has revised the ISG-06 Phase 1 software requirements specification documents, "Diablo Canyon Power Plant Units 1 & 2 Process Protection System (PPS) Replacement Functional Requirements Specification" (FRS) and "Diablo Canyon Power Plant Units 1 & 2 Process Protection System (PPS) Replacement Interface Requirements Specification" (IRS). Revisions have been made to add new requirements, to incorporate a design change to provide separate maintenance workstations (MWSs) for the Tricon and Advanced Logic System in each protection set with use of a keyboard/video/mouse switch between the MWSs, to provide additional clarification, and to correct typographical errors. The revised "Diablo Canyon Power Plant Units 1 & 2 PPS Replacement FRS, Revision 7," and "Diablo Canyon Power Plant Units 1 & 2 PPS Replacement IRS, Revision 7," are contained in Attachments 1 and 2 to the Enclosure, respectively. These revised FRS and IRS documents supersede those previously submitted in Attachments 2 and 3 to the 1

Attachments 8-13 to the Enclosure contain Proprietary Information When separated from Attachments 8-13 to the Enclosure, this document is decontrolled.

Attachments 8-13 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 Enclosure PG&E Letter DCL-12-120 Enclosure of PG&E Letter DCL-12-069, "Submittal of Quality Assurance Plan and Revised Phase 1 Documents for the License Amendment Request for Digital Process Protection System Replacement," dated August 2, 2012, respectively.

Invensys Operations Management has revised the Tricon ISG 06 Phase 1 documents, "993754-1-801, Process Protection System Replacement Diablo Canyon Power Plant Software Quality Assurance Plan (SQAP)," "993754-1-905, Process Protection System Replacement Diablo Canyon Power Plant Project Management Plan (PMP)," and "993754-1-900, Process Protection System Replacement Diablo Canyon Power Plant Project Quality Plan (PQP)." These documents have been updated to reflect issuance of a new PG&E purchase order, to reflect the current project milestones and latest project documents, and to incorporate PG&E comments. The changes to the SQAP and PQP documents are identified by revision bars in the right side of the page. The revised non-proprietary versions, 993754-1-801, Revision 1, 993754-1-905, Revision 2, and 993754-1-900, Revision 1, are contained in Attachments 4, 5, and 6 to the Enclosure, respectively, and the revised proprietary versions, 993754-1-801, Revision 1, and 993754-1-905, Revision 2, are contained in Attachments 8 and 9 to the Enclosure, respectively.

These revised SQAP, software PMP, and PQP documents supersede those previously submitted by Invensys Operations Management Letter, "Invensys Operations Management Submittal to Support License Amendment Request from PG&E for Replacement of the Eagle 21 Process Protection System at Diablo Canyon Power Plant," dated October 26, 2011.

Invensys Operations Management has revised the Tricon software requirements specification ISG 06 Phase 1 documents, "993754-11-809, Process Protection System Replacement Diablo Canyon Power Plant Software Requirements Specification (SRS) Protection Set I," "993754-12-809, Process Protection System Replacement Diablo Canyon Power Plant Software Requirements Specification (SRS) Protection Set IH," "993754-13-809, Process Protection System Replacement Diablo Canyon Power Plant Software Requirements Specification (SRS) Protection Set IIl," and "993754-14-809, Process Protection System Replacement Diablo Canyon Power Plant Software Requirements Specification (SRS) Protection Set IV."

These documents have been updated to incorporate design changes, to reflect the latest project documents, and to incorporate PG&E comments. The changes to the documents are identified in red and with strikethrough for deletions and in blue for additions. The revised proprietary versions of the SRS for each protection set are contained in Attachment 10 to the Enclosure. These revised SRS documents supersede those previously submitted by Invensys Operations Management Letter, "Invensys Operations Management Submittal to Support License Amendment Request from PG&E for Replacement of the Eagle 21 Process Protection System at Diablo Canyon Power Plant," dated October 28, 2011.

2 Attachments 8-13 to the Enclosure contain Proprietary Information When separated from Attachments 8-13 to the Enclosure, this document is decontrolled.

Attachments 8-13 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 Enclosure PG&E Letter DCL-12-120 In PG&E Letter DCL-1 2-050, "Submittal of Phase 2 Documents for the License Amendment Request for Digital Process Protection System Replacement," dated June 6, 2012, PG&E committed to submit the Tricon software safety analysis, requirements traceability matrix, and V&V ISG 06 Phase 2 documents. The non-proprietary version of the Invensys Operations Management Tricon software safety analysis document, "993754-1-915, Revision 1, Process Protection System Replacement Diablo Canyon Power Plant Safety Analysis," is contained in to the Enclosure and the proprietary version, "993754-1-915, Revision 1, Process Protection System Replacement Diablo Canyon Power Plant Software Safety Analysis," is contained in Attachment 11. The proprietary versions of the Invensys Operations Management Tricon requirements traceability matrix document, "993754-1-804, Revision 1, Process Protection System Replacement Project, Project Traceability Matrix," and the V&V document "993754-1-860, Revision 1, Process Protection System Replacement Diablo Canyon Power Plant V&V Requirements Phase Summary Report," are contained in Attachments 12 and 13 to the Enclosure, respectively.

ATTACHMENTS

1. PG&E Document "Diablo Canyon Power Plant Units 1 & 2 Process Protection System (PPS) Replacement Functional Requirements Specification, Revision 7."

(Non-Proprietary)

2. PG&E Document "Diablo Canyon Power Plant Units 1 & 2 Process Protection System (PPS) Replacement Interface Requirements Specification, Revision 7,"

(Non-Proprietary)

3. Invensys Operations Management Affidavit No. 993754-AFF-46T

4. Invensys Operations Management Document "993754-1-801, Revision 1, Process Protection System Replacement Diablo Canyon Power Plant Software Quality Assurance Plan (SQAP)," (Non-Proprietary)

5. Invensys Operations Management Document "993754-1-905, Revision 2, Process Protection System Replacement Diablo Canyon Power Plant Project Management Plan (PMP)," (Non-Proprietary)

6. Invensys Operations Management Document "993754-1-900, Revision 1, Process Protection System Replacement Diablo Canyon Power Plant Project Quality Plan (PQP)," (Non-Proprietary)

7. Invensys Operations Management Document "993754-1-915, Revision 1, Process Protection System Replacement Diablo Canyon Power Plant Safety Analysis," (Non-Proprietary)

8. Invensys Operations Management Document "993754-1-801, Revision 1, Process Protection System Replacement Diablo Canyon Power Plant Software Quality Assurance Plan (SQAP)," (Proprietary)

9. Invensys Operations Management Document "993754-1-905, Revision 2, Process Protection System Replacement Diablo Canyon Power Plant Project Management Plan (PMP)," (Proprietary) 3 Attachments 8-13 to the Enclosure contain Proprietary Information When separated from Attachments 8-13 to the Enclosure, this document is decontrolled.

Attachments 8-13 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 Enclosure PG&E Letter DCL-12-120

10. Invensys Operations Management Document "993754-11-809, Revision 2, Process Protection System Replacement Diablo Canyon Power Plant Software Requirements Specification (SRS) Protection Set I," "993754-12-809, Revision 2, Process Protection System Replacement Diablo Canyon Power Plant Software Requirements Specification (SRS) Protection Set I1," "993754-13-809, Revision 2, Process Protection System Replacement Diablo Canyon Power Plant Software Requirements Specification (SRS) Protection Set III," and "993754 809, Revision 2, Process Protection System Replacement Diablo Canyon Power Plant Software Requirements Specification (SRS) Protection Set IV" (Proprietary)

11. Invensys Operations Management Document "993754-1-915, Revision 1, Process Protection System Replacement Diablo Canyon Power Plant Safety Analysis," (Proprietary)

12. Invensys Operations Management Document "993754-1-804, Revision 1, Process Protection System Replacement Project, Project Traceability Matrix,"

(Proprietary)

13. Invensys Operations Management Document "993754-1-860, Revision 1, Process Protection System Replacement Diablo Canyon Power Plant V&V Requirements Phase Summary Report," (Proprietary) 4 Attachments 8-13 to the Enclosure contain Proprietary Information When separated from Attachments 8-13 to the Enclosure, this document is decontrolled.

71 Attachments 8-13 to the Enclosure contain Proprietary Information - Withhold Under 10 CFR 2.390 Enclosure Attachment 3 PG&E Letter DCL-12-120 Invensys Operations Management Affidavit No. 993754-AFF-46T Attachments 8-13 to the Enclosure contain Proprietary Information When separated from Attachments 8-13 to the Enclosure, this document is decontrolled.

m am

993754-AFF-46T AFFIDAVIT No. 993754-AFF-46T Re: Request for Withholding from Public Disclosure per 10CFR2.390 STATE OF CALIFORNIA )

) ss COUNTY OF ORANGE )

I, Roman Shaffer, being duly sworn, hereby say and depose:

I. I am the Diablo Canyon PPS Replacement Project Manager for Invensys Operations Management, and as such I have been specifically delegated the function of reviewing company proprietary information sought to be withheld from public disclosure in connection with nuclear 1E qualification and application of the TRICON Programmable Logic Controller (PLC) and am authorized to apply for its withholding on behalf of the Nuclear Delivery Unit of Invensys Operations Management.

2. The information sought to be withheld is contained in the document(s) described below:

(1) ProjectTraceabilityMatrix, 993 754-1-804, Rev 1 (2) Software Requirements Specification, PSI, 993 754-11-809, Rev 2 (3) Software Requirements Specification, PS2, 993 754-12-809, Rev 2 (4) Software Requirements Specification, PS3, 993 754-13-809, Rev 2 (5) Software Requirements Specification, PS4, 993 754-14-809, Rev 2 (6) Safety Analysis, 993 754-1-915, Rev 1 (7) V&V Requirements Phase Summary Report, 993 754-1-860, Rev 1 (8) Software QA Plan, 993754-1-801, Rev 1 (9) ProjectManagement Plan, 993 754-1-905, Rev 2 The indicated documents contain information considered to be proprietary. Proprietary material in the enclosed documents is indicated by brackets [ ] or other similar markings as required by I0CFR2.390(b)(l)(i)(B). As indicated in the associated transmittal letter, non-proprietary versions of the documents are being provided, consistent with the level of proprietary content.

This information is associated with the Diablo Canyon Power Plant (DCPP) Process Protection System Replacement Project, which incorporates Invensys Operations Management TRICON systems and delegated digital application project integration services. This will allow the NRC to verify compliance with current regulatory requirements for certain Invensys Operations Management activities in support of the DCPP PPS Replacement Project.

3. 1am making this affidavit in conformance with the provisions of IOCFR Part 2.390 of the Commission's regulations and in conjunction with the Invensys Operations Management application for withholding accompanying this affidavit.

4. I have personal knowledge of the criteria and procedures utilized by the Nuclear Delivery Unit of Invensys Operations Management in designating information as a trade secret, privileged, or as confidential commercial or financial information. Some examples of categories of information which fit into the definition of proprietary information are:

a) Information which discloses process, method, or apparatus, including supporting data and analyses, where prevention of its use by Invensys Operations Management's competitors without Page lof3

I 993754-AFF-46T license or contract from Invensys constitutes a competitive economic advantage over other companies in the industry.

b) Information, which if used by competitors, would reduce their expenditure of resources or improve their competitive position in the design, manufacture, shipment, application, installation, assurance of quality, or licensing of a similar product.

c) Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of Invensys Operations Management, its customers, its partners, or its suppliers.

d) Information which reveals aspects of past, present, or future Invensys Operation Management customer-funded development plans or programs, of potential commercial value to Invensys.

e) Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

f) Information obtained through Invensys Operation Management actions which could reveal additional insights into nuclear equipment qualification processes, customer applications, and regulatory proceedings, and which are not otherwise readily obtainable by a competitor.

Information to be withheld is considered to be proprietary based on 10CFR2.390(a)(4), with consideration of the reasons set forth above.

5. These documents describe the details of a program to qualify Invensys Triconex equipment for 1E application, product design details, and/or customer application approaches. Invensys Triconex is the first manufacturer of a PLC to fully implement the requirements set forth in the EPRI TR- 107330, which has been endorsed by the Commission in an SER. Invensys Triconex has expended a significant amount of money and effort involving numerous contractors over more than 10 years to develop and implement an ongoing successful approach to its test programs and nuclear applications. Information developed relating to test plans, approaches, equipment, specific problems encountered, licensing perspectives, application approaches, and lessons learned has significant value because of the resources expended to successfully accomplish this process and the usefulness of this knowledge to potential competitors.

Specific data showing compliance with requirements and demonstrating technical capability of the equipment has substantial commercial value because it provides the basis for qualifying Invensys Triconex equipment and implementing safety-related digital upgrades to nuclear plants. Existing options for digital upgrades in the nuclear industry are limited. We believe that ongoing successful 1E qualification upgrades of the TRICON PLC products and implementation of plant application projects will continue to give Invensys Operations Management a competitive advantage in this field.

Disclosure of information in these documents would cause substantial harm to the competitive position of the Invensys Operations Management, as there are other competing companies who wish to qualify digital PLC controllers and apply them in safety related applications in nuclear power plants. Competing firms could use our experience, successful approaches, and technical information to facilitate their own equipment qualification efforts, application approaches, and/or product design without compensating Invensys Operations Management.

6. Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Invensys Operations Management.

(ii) The information is of a type customarily held in confidence by Invensys Operations Management and not customarily disclosed to the public. Invensys Operations Management has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence.

The application of that system and the substance of that system constitute Invensys Operations Management policy and provide the rational basis required.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of IOCFR Part 2.390, it is to be received in confidence by the Commission.

Page 2 of 3

993754-AFF-46T (iv) This information is not readily available in public sources.

(v) Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Invensys Operations Management because it would enhance the ability of competitors to provide similar design and qualification of PLC systems and associated applications using similar project methods, equipment, testing approach, contractors, or licensing approaches. As described in section 5, this information is the result of considerable expense to Invensys and has great value in that it will assist Invensys in providing Invensys Triconex digital upgrade equipment and services to a new, expanding markets not currently served by the company.

7. The foregoing statements are true and correct to the best of my knowledge, information, and belief.

Roman Shaffer ProjectManager,DCPPPPS Replacement Project Invensys OperationsManagement Sworn to and subscribed before me this dayof ,2012 Notary Public \N EC c~)~fe C~ ý ~ /+(i~  %

Page 3 of 3

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