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Category:Legal-Affidavit
MONTHYEARML24162A0792024-06-0707 June 2024
OEDO-24-00083 - 10 CFR 2.206 - Diablo Canyon Units 1 and 2 Seismic CDF - Supplemental Declaration 6-7-2024 -
DCL-23-022, 2023 Annual Statement of Insurance for Pacific Gas and Electric Company’S Diablo Canyon Power Plant2023-03-29029 March 2023
2023 Annual Statement of Insurance for Pacific Gas and Electric Company’S Diablo Canyon Power Plant
DCL-19-082, Submittal of Site-Specific Decommissioning Cost Estimate2019-12-0404 December 2019
Submittal of Site-Specific Decommissioning Cost Estimate
DCL-18-100, License Amendment Request 18-02 - License Amendment Request to Revise Technical Specification 5.6.5b1 Core Operating Limits Report (COLR) for Full Spectrum Loss-of-Coolant Accident Methodology2018-12-26026 December 2018
License Amendment Request 18-02 - License Amendment Request to Revise Technical Specification 5.6.5b1 Core Operating Limits Report (COLR) for Full Spectrum Loss-of-Coolant Accident Methodology
ML16061A4522016-02-11011 February 2016
Submittal of Tricon Phase 2 Documents for the License Amendment Request for Process Protection System Replacement
DCL-16-020, Diablo Canyon, Units 1 and 2 - Submittal of Tricon Phase 2 Documents for the License Amendment Request for Process Protection System Replacement2016-02-11011 February 2016
Diablo Canyon, Units 1 and 2 - Submittal of Tricon Phase 2 Documents for the License Amendment Request for Process Protection System Replacement
ML16026A3882016-01-0505 January 2016
Westinghouse Electric Company, LLC, Submittal of Proprietary Version of LTR-DCPPS-15-008 Response to NRC RAI 73 (Open Item 129).
ML15090A2752015-03-26026 March 2015
Independent Spent Fuel Storage Installation - Consent and Hearing Waiver Form
ML14171A2372014-06-11011 June 2014
Submittal of Supplemental Analysis for Inservice Inspection Program Relief Request SWOL-REP-1 U2
DCL-14-034, Affidavit No. 993754-AFF-104T, Dated 03/12/2014, Signed by Mark Herschthal2014-03-12012 March 2014
Affidavit No. 993754-AFF-104T, Dated 03/12/2014, Signed by Mark Herschthal
ML14205A0352014-03-12012 March 2014
Affidavit No. 993754-AFF-104T, Dated 03/12/2014, Signed by Mark Herschthal
DCL-13-061, CS Innovations - Application for Witholding Proprietary Information from Public Disclosure, Enclosure, Attachment 22013-04-25025 April 2013
CS Innovations - Application for Witholding Proprietary Information from Public Disclosure, Enclosure, Attachment 2
ML13078A2922013-03-0505 March 2013
Areva Affidavit for Areva Calculations #32-9199805-000, Diablo Canyon Power Plant Unit 2 Pzr Safety and Spray Nozzles Planar Flaw Analysis (Proprietary) and #32-9199937-000, DCPP Unit 2 - Evaluation of Laminar Indications in Pressurizer Noz
DCL-13-021, Areva Affidavit for Areva Calculations 32-9199805-000, Diablo Canyon Power Plant Unit 2 Pzr Safety and Spray Nozzles Planar Flaw Analysis (Proprietary) and 32-9199937-000, DCPP Unit 2 - Evaluation of Laminar Indications in Pressurizer N2013-03-0505 March 2013
Areva Affidavit for Areva Calculations #32-9199805-000, Diablo Canyon Power Plant Unit 2 Pzr Safety and Spray Nozzles Planar Flaw Analysis (Proprietary) and #32-9199937-000, DCPP Unit 2 - Evaluation of Laminar Indications in Pressurizer Noz
DCL-12-069, Diablo Canyon, Units 1 and 2 - Submittal of Attachment 1, Quality Assurance Plan and Revised Phase 1 Documents for the License Amendment Request for Digital Process Protection System Replacement and Attachment 8 Affidavit 993754-AFF-38T2012-08-0202 August 2012
Diablo Canyon, Units 1 and 2 - Submittal of Attachment 1, Quality Assurance Plan and Revised Phase 1 Documents for the License Amendment Request for Digital Process Protection System Replacement and Attachment 8 Affidavit 993754-AFF-38T
ML12222A0942012-08-0202 August 2012
Submittal of Attachment 1, Quality Assurance Plan and Revised Phase 1 Documents for the License Amendment Request for Digital Process Protection System Replacement and Attachment 8 Affidavit 993754-AFF-38T
ML12137A0242012-05-15015 May 2012
Diablo Canyon - May Hearing File Update
ML11297A0562011-10-18018 October 2011
Diablo Canyon - October Hearing File Update
ML0715501312007-05-23023 May 2007
SER Compliance with WCAP-16260-P-A the Spatially Corrected Inverse Count Rate (Scicr) Method for Subcritical Reactivity Measurement
DCL-05-121, Correction of Information Contained in License Amendment Request 05-04. Revision to Technical Specification 5.3.1. 'Unit Staff Qualifications.'2005-12-23023 December 2005
Correction of Information Contained in License Amendment Request 05-04. Revision to Technical Specification 5.3.1. 'Unit Staff Qualifications.'
DCL-05-018, License Amendment Request 05-01 Revision to Technical Specification 5.5.9, Steam Generator Tube Surveillance Program, and 5.6.10, Steam Generator Tube Inspection Report. to Allow Use of the W* Alternate Repair Criteria.2005-03-11011 March 2005
License Amendment Request 05-01 Revision to Technical Specification 5.5.9, Steam Generator Tube Surveillance Program, and 5.6.10, Steam Generator Tube Inspection Report. to Allow Use of the W* Alternate Repair Criteria.
DCL-04-149, License Amendment Request 04-07, Revision to Technical Specifications 3.7.17 and 4.3 for Cycles 14-16 for a Cask Pit Spent Fuel Storage Rack2004-11-0303 November 2004
License Amendment Request 04-07, Revision to Technical Specifications 3.7.17 and 4.3 for Cycles 14-16 for a Cask Pit Spent Fuel Storage Rack
DCL-04-123, License Amendment Request 04-06 Removal of Technical Specifications 5.6.1, Occupational Radiation Exposure Report, and 5.6.4, Monthly Operating Reports2004-11-0101 November 2004
License Amendment Request 04-06 Removal of Technical Specifications 5.6.1, Occupational Radiation Exposure Report, and 5.6.4, Monthly Operating Reports
DCL-04-104, Response to NRC Request for Additional Information Regarding License Amendment Request 04-01, 'Revised Steam Generator Voltage-based Repair Criteria Probability of Detection Method for Plant.2004-08-18018 August 2004
Response to NRC Request for Additional Information Regarding License Amendment Request 04-01, 'Revised Steam Generator Voltage-based Repair Criteria Probability of Detection Method for Plant.
DCL-04-089, Response to June 14 and July 6, 2004, NRC Request for Additional Information Re License Amendment Request 03-18, Revision to Technical Specifications 5.5.9, 'Steam Generator (SG) Tube Surveillance Program,' & 5.6.10.2004-07-30030 July 2004
Response to June 14 and July 6, 2004, NRC Request for Additional Information Re License Amendment Request 03-18, Revision to Technical Specifications 5.5.9, 'Steam Generator (SG) Tube Surveillance Program,' & 5.6.10.
DCL-04-095, 60-Day Response to NRC Bulletin 2004-01, Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized Water Reactors2004-07-27027 July 2004
60-Day Response to NRC Bulletin 2004-01, Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized Water Reactors
DCL-04-066, Response to NRC Request for Additional Information Regarding License Amendment Request 03-12, Revision to Technical Specifications 3.3.1, 'Rts Instrumentation,' and 3.3.2, 'Esfas Instrumentation.'2004-06-0404 June 2004
Response to NRC Request for Additional Information Regarding License Amendment Request 03-12, Revision to Technical Specifications 3.3.1, 'Rts Instrumentation,' and 3.3.2, 'Esfas Instrumentation.'
ML0412804352004-04-30030 April 2004
Notice of Change of Address
ML0409704212004-03-31031 March 2004
Saybrook Capital, LLC Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for February 1 Through February 29, 2004
ML0409805912004-03-18018 March 2004
Public Policy Advocates Llc'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expense for February 1, 2004 Through February 29, 2004
ML0406204532004-02-23023 February 2004
Declaration of Sandip Sen in Support of Debtor'S Motion for Authority to Establish Cash-collateralized Letter of Credit Program and Facility to Secure Gas Purchases, and to Incur Secured Debt Related Thereto (the Motion)'
ML0403706042004-01-29029 January 2004
Declaration of Michael J. Donnelly in Support for Authority to Establish Cash-Collaterized Letter of Program and Facility to Secure Gas Purchases, and to Incur Secured Debt Related Thereto
ML0403706012004-01-29029 January 2004
Declaration of Raymond X. Welch in Support of Motion for Authority to Establish Cash-Collateralized Letter of Credit Program and Facility to Secure Gas Purchases, and to Incur Secured Debt Related Thereto
ML0400700982003-12-30030 December 2003
Howard, Rice Nemerovski, Canady, Falk & Rabkin Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for November, 2003
ML0400200602003-12-22022 December 2003
Declaration of Grant Guerra in Support of Motion for Order Authorizing the Debtor to Settle Claim No. 13377 Filed by the Presidio Trust
ML0333810452003-11-26026 November 2003
Cooley Godward Llp'S Twenty-Ninth Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period October 1, 2003 - October 31, 2003
ML0331800932003-11-0606 November 2003
Proof of Service
ML0331701792003-10-31031 October 2003
Declaration of Michael J. Donnelly in Support of Pg&E'S Application for Authority to Incur Plan Implementation Expenses in Connection with Certain Financings
DCL-03-133, Full Compliance with Order for Compensatory Measures Related to Fitness-For-Duty Enhancements Applicable to Nuclear Facility Security Force Personnel, Dated 04/29/03 (EA-03-038)2003-10-28028 October 2003
Full Compliance with Order for Compensatory Measures Related to Fitness-For-Duty Enhancements Applicable to Nuclear Facility Security Force Personnel, Dated 04/29/03 (EA-03-038)
ML0331800902003-10-23023 October 2003
Declaration of Jennifer A. Becker in Support of City of Oakland and Port of Oakland'S Motion for Relief from Automatic Stay
ML0331800862003-10-23023 October 2003
Relief from Stay Cover Sheet
ML0328703662003-09-29029 September 2003
Skadden, Arps, Slate, Meagher & Flom Llp'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period August 1, 2003 Through August 31, 2003
ML0327312982003-09-24024 September 2003
(Reorganized) California Power Exchange Corporation'S Limited Objection to Motion for Order Authorizing Pacific Gas and Electric Company to Compromise Claims Against El Paso Natural Gas Company Et Alia and to Enter Into Agreements Resolving
ML0327314402003-09-23023 September 2003
Fact Witness Disclosure of Satellite Senior Income Fund, Satellite Senior Income Fund II and Deutsche Bank Trust Company Americas to Objection to Confirmation of Plan of Reorganization Under Chapter 11 of the Bankruptcy Code for Pacific Gas
ML0327313322003-09-22022 September 2003
Notice of Hearing on Interim Compensation Applications of Professionals and Final Expense Application of Creditors' Committee Members
ML0326810702003-09-16016 September 2003
Declaration of Michael J. Donnelly in Support of Debtor'S Notice of Motion and Motion for Order Approving Debtor'S Execution and Performance Under the Amendment to First Amended and Restated Summary of Terms with Respect to Forbearance and
ML0325412082003-09-11011 September 2003
Order Re Ex Parte Application of Pacific Gas and Electric Company Authorizing Settlement and Withdrawal of Claim of Laguna Irrigation District
ML0325911092003-09-0505 September 2003
Declaration of Joshua Bar-Lev in Support of Debtor'S Motion for Order Authorizing Pacific Gas and Electric Company to Compromise Claims Against El Paso Natural Gas Company Et Alla and to Enter Into Agreements Resolving the Claims
ML0325411442003-09-0404 September 2003
Relief from Stay Cover Sheet - Motion & Notice of Motion of Smud for Relief from Automatic Stay in Litigation
ML0325213432003-08-29029 August 2003
Declaration of Joseph Sauvage in Support of Motion for Authority to Enter Into Certain Hedging Transactions in Connection with Financing Under Proposed Plan of Reorganization, and to Incur Secured Debt Related Thereto
2024-06-07
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993754-AFF-I04T AFFIDAVIT No. 993754-AFF-I04T Re: Request for Withholding from Public Disclosure per lOCFR2.390 STATE OF CALIFORNIA ) ) ss COUNTY OF ORANGE ) I, Mark Herschthal, being duly sworn, hereby say and depose: 1. I am the North American Nuclear Project Director for Invensys, and as such I have been specifically delegated the function of reviewing company proprietary infonnation sought to be withheld from public disclosure in connection with nuclear 1 E 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 ofInvensys Operations Management.
- 2. The infonnation sought to be withheld is contained in the document(s) described below: (1) Software Requirements Specification, 993754-11-809, Rev 4 (2) Failure Modes and Effects Analysis, 993754-1-811, Rev 1 (3) ReliabilityAnalysis, 993754-1-819, Rev 0 The indicated document(s) contain infonnation considered to be proprietary. Proprietary material in the enclosed documents is indicated by brackets [ ] or other similar markings as required by 10CFR2.390(b)(1)(i)(B).
As indicated in the associated transmittal letter, non-proprietary versions of the document( s) mayor may not be provided, consistent with the level of proprietary content. This infonnation is associated with the Diablo Canyon Power Plant (DCPP) Process Protection System Replacement Project, which incorporates Invensys TRICON systems and delegated digital application project integration services.
This will allow the NRC to verify compliance with current regulatory requirements for certain Invensys activities in support of the DCPP PPS Replacement Project. 3. I am making this affidavit in confonnance with the provisions of I OCFR Part 2.3 90 of the Commission's regulations and in conjunction with the Invensys application for withholding accompanying this affidavit.
- 4. I have personal knowledge of the criteria and procedures utilized by the Nuclear Delivery Unit ofInvensys Operations Management in designating infonnation as a trade secret, privileged, or as confidential commercial or financial infonnation.
Some examples of categories of infonnation which fit into the defmition of proprietary infonnation are: a) Infonnation which discloses process, method, or apparatus, including supporting data and analyses, where prevention of its use by Invensys's competitors without license or contract from Invensys constitutes a competitive economic advantage over other companies in the industry.
b) Infonnation, 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) Infonnation which reveals cost or price infonnation , production capacities, budget levels, or commercial strategies ofInvensys, its customers, its partners, or its suppliers.
d) Infonnation which reveals aspects of past, present, or future Invensys customer-funded development plans or programs, of potential commercial value to Invensys.
Page 1 of3 993754-AFF-104T e) Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.
f) Information obtained through Invensys 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 lOCFR2.390(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 IE 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 EPR! TR-I07330, 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 15 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 IE qualification upgrades of the TRICON PLC products and implementation of plant application projects will continue to give Invensys a competitive advantage in this field. Disclosure of information in these documents would cause substantial harm to the competitive position of Invensys, 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.
- 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. (ii) The information is of a type customarily held in confidence by Invensys and not customarily disclosed to the public. Invensys 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 policy and provide the rational basis required. (iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10CFR 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 ofInvensys because it would enhance the ability of competitors to provide similar design and qualification ofPLC 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. Page 2 of3 993754-AFF-I04T
- 7. The foregoing statements are true and correct to the best of my knowledge, information, and belief. State of California County of 0,. Ck-9' '<.......
Place Notary Seal Above North American Nuclear Project Director InvensyslSchneider Electric Subscribed and sworn to (or affIrmed) before me on this __ day of I't C<... .. ,2014 by Date Month Name of Signer proved to me on the basis of satisfactory evidence to be the person who appeared before me. Page 3 of3
