IR 05000382/2021011
| ML21308A066 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/18/2021 |
| From: | Nick Taylor NRC/RGN-IV/DRS/EB-2 |
| To: | Ferrick J Entergy Operations |
| References | |
| IR 2021011 | |
| Download: ML21308A066 (13) | |
Text
November 18, 2021
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - DIGITAL INSTRUMENTATION AND CONTROL INSPECTION REPORT 05000382/2021011
Dear Mr. Ferrick:
On October 19, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Waterford Steam Electric Station, Unit 3 and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
No findings or violations of more than minor significance were identified during this inspection.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Nicholas Digitally signed by Nicholas H. Taylor H. Taylor Date: 2021.11.18 10:17:58 -06'00'
Nicholas H. Taylor, Chief Engineering Branch 2 Division of Reactor Safety Docket No. 05000382 License No. NPF-38
Enclosure:
As stated
Inspection Report
Docket Number: 05000382 License Number: NPF-38 Report Number: 05000382/2021011 Enterprise Identifier: I-2021-011-0051 Licensee: Entergy Operations, Inc.
Facility: Waterford Steam Electric Station, Unit 3 Location: Killona, LA Inspection Dates: July 25, 2021 to October 19, 2021 Inspectors: S. Makor, Reactor Inspector, Team Lead M. Brown, Senior Reactor Engineer S. Darbali, Electronics Engineer K. Lawson-Jenkins, IT Specialist Approved By: Nicholas H. Taylor, Chief Engineering Branch 2 Division of Reactor Safety Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Digital Instrumentation and Control Inspection at Waterford Steam Electric Station, Unit 3, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
52003 - Digital Instrumentation and Control Modification Inspection Digital Instrumentation and Control Modification Inspection
- (1) Westinghouse Electric Company (WEC) located in Warrendale, PA, provides the Core Protection Calculator System (CPCS) for Entergys Waterford Unit 3 (WF3)digital modification project. For this project, WEC develops the system requirements, software and hardware requirements, detailed software and hardware design; implements the software and manufactures the hardware; integrates the software and hardware; conducts testing and delivers the completed CPCS to the WF3 site.
The inspectors performed this inspection to evaluate whether the licensee:
- (1) Conducted acceptance reviews of the design outputs for this phase, including but not limited to the following: test plans, test procedures, independent verification &
validation (IV&V) reports, test records, test result reports, anomaly reports, and regression analysis performed to identify additional or modified tests, in accordance with the licensees procedures identified in the VOP and
- (2) confirmed that the vendor performed the factory acceptance tests in accordance with the processes described in the license amendment request. Specific activities evaluated during this inspection are described in the following paragraphs.
The inspectors evaluated whether the licensee performed enhanced vendor oversight activities as defined by the Vendor Oversight Plan (VOP) for designs licensed by NRC staff using the Digital Instrumentation and Control (I&C) Interim Staff Guidance (ISG)-06 Revision 2, Alternate Review Process. The inspectors verified that the licensee implemented procedures, documented audit results, and initiated corrective action documents.
This confirmatory inspection focused on the Factory Acceptance Testing (FAT) and verified the licensees performance of VOP activities through direct observation of the licensees VOP performance at the vendor facility. The inspectors reviewed supporting documents including implementing procedures, work orders, inspection reports, engineering evaluations, and condition reports; and conducted interviews with licensee staff.
INSPECTION RESULTS
Observation: Factory Acceptance Testing (FAT) 52003
Factory Acceptance Testing (FAT) (1 Sample)
1. The inspectors conducted an inspection of the FAT Phase of the digital instrumentation and control modification as described below:
1.1 Licensee Vendor Oversight Plan
a. Inspection Scope
The inspectors verified that the licensee is performing vendor oversight in accordance with their VOP through document reviews and observation of Entergys staff performing oversight. The inspectors reviewed Entergys VOP, observed the licensee staff performing vendor oversight in accordance with the VOP, and verified that the licensee had performed the FAT related VOP activities. The inspectors reviewed ENT-WF3-CPC-374, Witness of Four Channel Factory Acceptance VOP Audit, dated July 23, 2021, which documents Entergys audit plan to witness the FAT. The plan covers witnessing the test of the secure operational environment design features and verification of design requirements. The inspectors observed that Entergy and its contractor, Enercon, were witnessing the various FAT tests according to the FAT audit plan. The inspectors interviewed Entergy staff which explained that most of the test plan covered V&V activities that would take place the week after the completion of the tests. Entergy also informed the inspectors that the technician writing the Site Acceptance Testing (SAT) procedure was present witnessing the FAT.
The inspectors observed Entergys review and oversight of various Westinghouse artifacts, Westinghouse staff performing samples of the FAT procedure, communicating with Westinghouse at daily meetings during the inspection, and the capturing of issues in the corrective action program (CAP).
The inspectors observed the licensees oversight by reviewing the Test plan and Procedure, IV&V reports, and the test records generated during the FAT performance. The inspectors verified the licensees observation that the vendor performed the tests as described in the license amendment request. The tests observed during the FAT included safety functions, proper communications between various modules, operability of the displays, diagnostics associated with hardware inputs, and performance (e.g., time response).
The inspectors verified that the licensee had conducted acceptance reviews of the test plan and FAT procedures. The inspectors reviewed letter ENT-WF3-CPC-368, Test Plan for the Common Q Core Protection Calculator System, dated July 20, 2021, which documents Entergys review and approval of comment resolutions to WNA-PT-00303-CWTR3, CPCS Test Plan, Revision 2. The NRC inspectors also reviewed ENT-WF3-CPC-369, Four Channel Factory Acceptance VOP Audit, dated July 23, 2021, which documented Entergys review and approval of comment resolutions to the CPCS Four Channel Test Procedure, WNA-TP-06781-CWTR3. The inspectors determined the licensee performed the FAT vendor oversight in accordance with their VOP but will inspect the licensees review and acceptance of the FAT audit report during SAT.
This combined inspection scope portion partially completed sections 2.01(a), 2.01(b), 2.01(c),and 2.01(d) of Inspection Procedure 52003, Digital Instrumentation and Control Modification Inspection, dated July 1, 2021 (IP52003).
b. Observations and Findings
No findings were identified.
1.2 Requirements Phase
a. Inspection Scope
The inspectors reviewed the EN-IT-103-15, Cyber Security Defensive Architecture &
Technical Controls Integration Form, Revision 1, attachment 9.6, to verify that key cyber security capabilities were included in system requirements and that the licensee was communicating the requirements for the digital modification to the vendor. This portion of the inspection partially completed section 2.01(c)(1)(a)(1) of IP52003.
The inspectors verified the status of supply chain protection, trustworthiness, integration of security capabilities in accordance with the CSP had been included in system requirements.
Supply chain protections were discussed with licensee and vendor and the inspectors were informed that the CPCS components would be shipped with tamper seals. The inspectors noted that the licensee requested several security capabilities be added to the CPCS and the inspectors plan to look at this in more detail during the SAT. The security test and evaluation plan required by NEI 08-09, E.11.5, Developer Security Testing, at the time of this inspection was still under development and would not be available until SAT. This portion of the inspection partially completed section 2.01(c)(1)(a)(3) of IP52003.
The inspectors were unable to verify that testing and independent verification and validation (IV&V) requirements since the FAT audit report was not complete. Verification will be completed during the SAT. This portion of the inspection partially completed section 2.01(c)(1)(a)(5) of IP52003.
b. Observations and Findings
No findings were identified.
1.3 Design Phase
a. Inspection Scope
The inspectors held meetings with the licensee and vendor to verify that the licensee required the vendor to create a security and evaluation test plan and conducted cyber security acceptance reviews of the design outputs for this phase in accordance with the licensees Cyber Security Plan.
The inspectors were informed that this test plan would not be completed until SAT. This portion of the inspection partially completed sections 2.01(c)(2)(c) and 2.01(c)(2)(d) of IP52003.
The inspectors verified that the licensee conducted acceptance reviews by interviewing staff and reviewing Entergys audit reports for the requirements phase (AUD-WF3-2019-00236-CA127) and the design phase (AUD-WF3-2019-00236-CA189). During these audits, the licensee performed requirements traceability from the system requirement specification to the software requirement specification, and to the software design descriptions, and identified discrepancies that the vendor incorporated into the Regulatory Issues Tracking System (RITS). NRC staff will inspect the licensees FAT audit report during SAT. This portion of the inspection partially completed sections 2.01(c)(2)(a)(1), 2.01(c)(2)(a)(2), and 2.01(c)(2)(b) of IP 52003.
b. Observations and Findings
No findings were identified.
1.4 Design and Documentation Verification
a. Inspection Scope
The inspectors verified that applicable operating experience (OE) was correctly applied to the system. The inspector interviewed the licensees staff on their testing approach, benchmarking, and review of OE from WEC and Palo Verde Nuclear Generating Station for implementation issues and lessons learned. This portion of the inspection completed section 2.02(a)(4) of IP52003 for the FAT phase.
The inspectors verified that the CPCS was being developed and tested in a secure environment commensurate with the systems secure operational environment. The inspectors verified that the test floor where the CPCS equipment FAT was being performed incorporated logical, physical, and administrative protective measures to control access and prevent unauthorized and undocumented changes to the system. NRC staff will inspect the licensees FAT audit report during SAT. This portion of the inspection partially completed section 2.02(a)(10) of IP52003.
b. Observations and Findings
No findings were identified.
1.5 Vendor Oversight
a. Inspection Scope
The inspectors verified that the licensees audit of vendor activities to ensure establishment and implementation of each Quality Assurance (QA) program attribute were performed in accordance with the licensees NRC-approved QA program and the VOP. The inspectors witnessed the four-channel FAT testing activities and reviewed the requirements in the CPP-WF3-2019-002, Critical Procurement Plan, revision 1, and purchasing contract, the QA surveillance plan, and the FAT audit plan. The inspectors verified that the licensee performed the oversight activities in accordance with the procedures referenced in the VOP and reviewed the four-channel test procedure and QA surveillance plan.
The inspectors verified the licensee auditors training and qualifications to perform audits/surveillances of vendor by reviewing the training certifications and through interviews.
The inspector verified the effectiveness of the licensee and vendor interface during system development by observing meetings, discussions, testing, and demonstrations between the licensee and vendor. The inspectors reviewed the licensees audit plan for the four-channel factory acceptance VOP audit, the four-channel system test procedure, and the vendors final compliance matrix.
This portion of the inspection completed section 2.01(g), 2.01(h), 2.01(i), 2.02(e) of IP52003 for the FAT phase.
b. Observations and Findings
No findings were identified 1.6 Review of Testing, Operations
a. Inspection Scope
The inspectors observed the licensees involvement in the FAT and reviewed supporting documentation. The inspectors verified that the licensee had reviewed the equipment qualification test results and anomalies. The inspectors reviewed Westinghouse document CWTR3-20-113, Transmittal of Westinghouse Responses to Entergy Comments on EQ-QR-412-CWTR3, dates April 29, 2021, which addressed 20 comments provided by Entergy on EQ-QR-412-CWTR3, Equipment Qualification Summary Report (EQSR), Revision 2-A, and documents Westinghouses responses to Entergys comments. Entergy comments 13, 14, 16 and 17 are related to the EQSR test anomalies.
The inspectors also reviewed Entergys letter ENT-WF3-CPC-331, EQSR EQ-QR-412-CWTR3, Rev 2-A, dated May 4, 2021, which documents Entergys review of CWTR3-20-113 and includes clarifications to be added in the EQSR for the test anomalies that do not apply to the Waterford 3 CPCS or were successfully dispositioned. The inspectors reviewed licensee provided comments regarding the testing configuration and test results. Entergys comment 5 refers to the installation, operational and maintenance restrictions provided by the EQSR to ensure they are followed through the design and implementation process. The inspectors assessed Entergy staffs review of RITS 75864 and their oversight of Westinghouses response which is to track all restrictions from Section 5 of the EQSR by RITS 75864.
This portion of the inspection completed section 3.04(c) and 3.04(d) of IP52003 for the FAT phase.
b. Observations and Findings
No findings were identified 1.7 Identification and Resolution of Problems
a. Inspection Scope
The inspectors reviewed the CAP for the vendor, Westinghouse, and for Entergy. The inspectors reviewed the licensees CAP and verified that they were identifying issues related to the FAT at an appropriate threshold. The inspectors focused on the licensees oversight of the vendor and noted that the licensee also reviewed the items the vendor entered in their CAP for deficiencies identified during VOP activities.
Additionally, the inspectors followed up on a change made to the test procedure, WNA-TP-06781-CWTR3, Four Channel Test Procedure, Revision 0, acceptance criteria for the cold leg temperature response time test. The inspectors observed the licensees oversight of this change and had multiple discussions on the sites plan to review and approve the revisions to the cold leg temperature response time test procedure using EN-DC-149. The inspectors reviewed the revised test procedure, WNA-TP-06781-CWTR3, Revision 1, and the EN-DC-149 form the licensee used to document their review and acceptance of the change.
This portion of the inspection completed section 2.01(e) of IP52003 for the FAT phase.
b. Observations and Findings
No findings were identified
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On October 19, 2021, the inspectors presented the Digital Instrumentation and Control Inspection results to John Ferrick and other members of the licensee staff.
- On August 4, 2021, the inspectors presented the Debrief inspection results to John Hornsby, Manager of Project Management and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
2003 Corrective Action 2021-00558,
Documents 2021-00322,
2019-08344,
21-00014,
21-03981,
21-00722,
21-00088,
21-00747,
21-00557,
20-06033,
21-03554,
21-00723,
21-00594,
21-00550,
21-00060,
21-00965
RITS 75864 EQ restrictions documented into the technical manuals, CPC 04/15/2021
and Mux
Drawings 2E10700 CPCS Mounting and Installation 2
2E10726 APC MUX Assembly 7
Engineering 0000083843 Core Protection Calculator System Replacement 0
Changes
Miscellaneous AUD-WF3-2019- Entergy VOP Audit Report: Design Phase IV&V VOP Audit 0
236-CA 189
AUD-WF3-2019- Entergy VOP Audit Report: Requirements Phase IV&V Audit 04/07/2021
236-CA127
CPP-WF3-2019- Critical Procurement Plan- Procure Waterford 3 Core 1
2 Protection Calculator (CPC) System Common Q Platform
CWTR3-19-23 Transmittal of Westinghouse Final Compliance Matrix-RTM 2
for ENT-IT-15-ATT-9.6 Cyber Security Checklist
CWTR3-20-113 Transmittal of Westinghouse Responses to Entergy 04/29/2021
Comments on EQ-QR-412-CWTR3, Revision 2-A, "Core
Inspection Type Designation Description or Title Revision or
Procedure Date
Protection Calculator System Upgrade Project Equipment
Qualification Summary Report for Waterford Unit 3"
ENT-WF3-CPC- Core Protection Calculator (CPC) System Input Processing 12/09/2019
064 Uncertainty Calculation, WNA-CN-00566-CWTR3, Rev A
and Rev 0 Draft
ENT-WF3-CPC- WNA-DS-04650-CWTR3, Hardware Design Description for 04/15/2021
317 the Core Protection Calculator
System, Draft Rev 3
ENT-WF3-CPC- EQSR EQ-QR-412-CWTR3 Rev 2-A 05/04/2021
331
ENT-WF3-CPC- CPC SRS, WNA-DS-04618-CWTR3, Draft Revision 3 06/21/2021
353
ENT-WF3-CPC- CEAPDS SRS, WNA-DS-04617-CWTR3, Draft Revision 3 06/21/2021
358
ENT-WF3-CPC- Test Plan for the Common Q Core Protection Calculator 06/20/2021
368 System, WNA-PT-00303-CWTR3
ENT-WF3-CPC- Four Channel Test Procedure, WNA-TP-06781-CWTR3 Rev 07/21/2021
369 A & Draft Rev 0 Approval
ENT-WF3-CPC- Witness of Four Channel Factory Acceptance VOP Audit 06/23/2021
374
SQ-SQHQN- Contract 10575450-01 WF3 Core Protection Calculator 07/20/2021
21-00146 (CPC) System Common Q Platform
VOP-WF3-2019- Waterford Unit Steam and Electric Station Unit 3 Core 4
236 Protection Calculator System Replacements Project Vendor
Oversight Plan
WNA-TP-06781- Four Channel System Test Procedure for the Common Q 08/08/2019
CWTR3 Core Protection Calculator System
Procedures EN-DC-115 Engineering Change Process 31
EN-DC-149 Acceptance of Vendor Documents 15
EN-DC-163 Human Factors Evaluation 2
EN-HU-104 Technical Task Risk & Rigor 11
EN-IT-103 Nuclear Cyber Security Program 15
EN-IT-103-15 Cyber Security Procurement and Disposal Requirements 2
EN-IT-104 Software Quality Assurance Program 16
Inspection Type Designation Description or Title Revision or
Procedure Date
EN-LI-102 Corrective Action Program 44
EN-MP-100 Critical Procurements 16
EN-OM-132 Nuclear Risk Management Process 3
EN-QV-108 QA Surveillance Process 12
Entergy Quality Assurance Program Manual 41
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