DCL-10-030, 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
| ML11319A069 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/26/2011 |
| From: | Shaffer R Invensys Operations Management |
| To: | Document Control Desk, Office of New Reactors |
| References | |
| 993754-26T, DCL-10-030 | |
| Download: ML11319A069 (6) | |
Text
n V'e. n s"i s Operations Management Transmittal No. 993754-26T Invensys Operations Management 26561 Rancho Parkway South Lake Forest, CA 92630 USA iom.invensys.com S0- 205/303 October 26, 2011 U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, Maryland 20852 Project: PPS Replacement Project PG&E PO# 3500897372 Invensys SO# 993754
Reference:
PG&E Letter DCL-10-030, From James R. Becker (PG&E) to the Chief Financial Officer of the NRC, dated April 9, 2010 (ML101100646)
Subject:
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
Dear Sir or Madam:
As discussed in the referenced letter, PG&E intends to submit a License Amendment Request (LAR) to upgrade the existing Eagle 21 Process Protection System (PPS) at Diablo Canyon Power Plant (DCPP) with a digital system based, in part, on the VI0 Tricon Triple-Modular-Redundant Programmable Logic Controller (ML110140443). Furthermore, the letter indicates that DCPP is the pilot plant for DI&C-ISG-06, the interim staff guidance on performing licensing reviews of LARs involving digital systems and the supporting technical documentation necessary to support the staff's reviews. As one of the selected platform vendors for the PPS upgrade, Invensys Operations Management is pleased to submit the documents listed in the table in Attachment 1 in accordance with DI&C-ISG-06 to support the DCPP LAR. The enclosed documents will be incorporated by reference in the DCPP LAR from PG&E.
Any Requests for Additional Information associated with the staff's review of the enclosed documents should be sent to Mr. Tom Baldwin of PG&E. PG&E is responsible for the payment of any NRC review fees associated with the DCPP LAR review. Therefore, Mr. Baldwin is the point of contact for any questions or requests from the staff regarding the enclosed documents.
The documents listed in the table in Attachment I are designated with either a "P" or "NP" suffix.
Documents with a "P" contain proprietary information regarding the V10 Tricon Programmable Logic Controller as well as the processes and procedures utilized by Invensys Operations Management in the development of nuclear safety-related systems. Documents with a "NP" are redacted versions of the proprietary documents.
DI -Do 2 Avantis Foxboro SimSci-Esscor Triconex &(Pz Page 1 of 3
i nv e.n s*i s 0 0 TM Operations Management Transmittal No. 993754-26T Because this submittal contains proprietary information from Invensys Operations Management, an Application for Withholding Proprietary Information from Public Disclosure is enclosed in compliance with the requirements of 10 CFR Part 2.390, as amended. Also enclosed is an affidavit that sets forth the basis on which the information identified as proprietary may be withheld from public disclosure.
Correspondence with respect to the proprietary aspects of the application for withholding or the Invensys Operations Management affidavit should reference 993754-26T and sent to the Lake Forest, California, address shown above with attention to Mr. Roman Shaffer.
Sincerely, Project Manager Invensys Operations Management cc: Mr. Scott Patterson - Pacific Gas & Electric Mr. Clayton Scott - Invensys - Letter Only Mr. Christopher Wiegand - Invensys - Letter Only Mr. Richard Lilleston - Invensys - Letter Only Mr. Brian Haynes - Invensys - Letter Only
Enclosures:
As stated Avantis Foxboro SimSci-Esscor Triconex Page 2 of 3
Transmittal No. 993754-26T ATTACHMENT 1 Enclosure Listing - CD 1 & 2 Content EnclosureDescription CDI
- CD2 [filenamne] [size MB]
Enclosure 1: - Affidavit #993754-AFF-26T X X [DCOOlAffida'it_26Tpdf] [1.4]
Enclosure 2: Invensvs DI&C-ISG-06 Documents Project Quality Plan, Rev 0, 993754-1-900 X X [DC002 900 PQP.pdfl [0.5]
Software QA Plan, Rev 0, 993754-1-801 (-P)* X [DC003_80ISQAPP.pd))[0. 7]
Software QA Plan, Rev 0, 993754-1-801 (-NP)** X X [DCOO4_801 SQAP_NP.pdfl [2.0]
RG 1.152 Conformance Report, Rev 0, 993754-1-913 (-P)* X [DC005_913 RGII52_P.pdf] [1.1]
RG 1.152 Conformance Report, Rev 0, 993754-1-913 (-NP)** X X [DC006 913 RGI152_NP.pdfJ [1.2]
ISG-04 Conformance Report, Rev 0, 993754-1-912 (-P)* X [DCO07 91I2ISG4_P.pdf] [1.1]
ISG-04 Conformance Report, Rev 0, 993754-1-912 (-NP)** X X [DCO08 912 ISG4 NP.pdj] [1.2]
Software Development Plan, Rev 0, 993754-1-906 (-P)* X [DCO09 906 SDPP.pdJ][1.2]
Software Development Plan, Rev 0, 993754-1-906 (-NP)** X X [DCOIO 906 SDPNP.pdJ][1.7]
Software Configuration Mgmt Plan, Rev 0, 993754-1-909 (-P)* X [DCOII 909 SCMPP.pdf] [0.8]
Software Configuration Mgmt Plan, Rev 0, 993754-1-909 (-NP)** X X [DCOI2 909 SCMP NP.pdJ] [1.9]
Software Safety Plan, Rev 1, 993754-1-911 (-P)* X [DCOI3_911 SSPP.pdJ] [1.0]
Software Safety Plan, Rev 1, 993754-1-911 (-NP)** X X [DC014 911 SSPNP.pdj] [1.9]
Software Integration Plan, Rev 1, 993754-1-910 (-P)* X [DCO15 910 SIP P.pdJ] [0.9]
Software Integration Plan, Rev 1, 993754-1-910 (-NP)** X X [DCOl6 910 SIP NP.pdf] [1.8]
Project Management Plan, Rev 1, 993754-1-905 (-P)* X [DCOI7 905 PMP P.pdj] [1.4]
Project Management Plan, Rev 1, 993754-1-905 (-NP)** X X [DC018 905 PMPNP.pqf] [1.9]
Software V&V Plan, Rev 1, 993754-1-802 (-P)* X [DCOI9 802_SVVPP.pd. [0.9]
Software V&V Plan, Rev 1, 993754-1-802 (-NP)** X X [DCO20 802 SVIP_NP.pdJ] [1.9]
Validation Test Plan, Rev 0, 993754-1-813 (-P)* X [DC021 813 VTPP.pdtf [0.8]
Validation Test Plan, Rev 0, 993754-1-813 (-NP)** X X [DC022.f813 VTPNP.pdf] [2.0]
System Architecture Description, Rev 0, 993754-1-914 (-P)* X [DC023 914 SAD P.pdfl [1.2]
System Architecture Description, Rev 0, 993754-1-914 (-NP)** X X [DC024 914 SAD NP.pdf] [1.1]
- ) Document contains Invensys Proprietary material
- ) Non-proprietary version of Proprietary document Document with no asterisk or P/NP notation is fully public (no proprietary information)
Notes:
(a) CD#1 contains Proprietary Documents (among all files). CD#2 contains only Non-Proprietary Documents (Publicly Available.).
993754-AFF-26T AFFIDAVIT No. 993754-AFF-26T Re: Request for Withholding from Public Disclosure per IOCFR2.390 STATE OF CALIFORNIA )
) ss COUNTY OF ORANGE I, Roman Shaffer, being duly sworn, hereby say and depose:
- 1. 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 IE 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) Software Quality Plan, Rev 0, 993 754-1-801 (2) RG 1.152 Conformance Report, Rev 0, 993 754-1-913 (3) ISG-04 ConformanceReport, Rev 0, 993754-1-912 (4) Software Development Plan,Rev 0, 993 754-1-906 (5) Software ConfigurationMgmt Plan,Rev 0, 993 754-1-909 (6) Software Safety Plan,Rev 1, 993 754-1-911 (7) Software IntegrationPlan,Rev 1, 993 754-1-910 (8) ProjectManagement Plan, Rev 1, 993 754-1-905 (9) Software V&V Plan, Rev 1, 993 754-1-802 (10) Validation Test Plan, Rev 0, 993 754-1-813 (11) System Architecture Description,Rev 0, 993754-1-914 Each of the indicated documents contains information considered to be proprietary. Proprietary material in the enclosed documents are indicated by brackets [ ] or other similar markings as required by 10CFR2.390(b)(I)(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. 1 am making this affidavit in conformance with the provisions of 10CFR Part 2.390 of the Commission's regulations and in conjunction with the Invensys Operations Management application for withholding accompanying this affidavit.
- 4. 1 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 infomation which fit into the definition of proprietary information are:
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993754-AFF-26T 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 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 a 10 year time period 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 IE 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.
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993754-AFF-26T 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.
(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 Shaffei ProjectManager, DCPPPPS Replacement Project Invensys OperationsManagement Sworn to and subscribed before me this d26 day of 0od'. ,2011 N*
J)*I V.MAT'HESON COMM. # 1862131 X NOTAR-PUBL.CA-IFORNLAX
],ORANGE COUNTY My.Comm, Eoi AUG 21. 213 Sroved to me on the basis of
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prldto meonhe-bs is) 1S Signabirev[
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