Text

Transmittal of Slides for Second Partially Closed Presubmittal Meeting with Entergy Operations, Inc. to Discuss a Planned License Amendment Request for Digital Instrumentation and Control Modification
	ML19339J407
Person / Time
Site:	Waterford
Issue date:	12/05/2019
From:	Wood P; Entergy Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML19339J405	List: W3F1-2019-0082, Transmittal of Slides for Second Partially Closed Presubmittal Meeting with Entergy Operations, Inc. to Discuss a Planned License Amendment Request for Digital Instrumentation and Control Modification;
References
	EPID L-2019-LRM-0079, W3F1-2019-0082
	Download: ML19339J407 (23)
	v • d • e

Proprietary Information Withhold From Public Disclosure Under 10 CFR 2.390 The balance of this letter may be considered nonproprietary upon removal of Attachment 3.

Entergy Operations, Inc.

17265 River Road Killona, LA 70057-3093 Tel 504-464-3786 Paul Wood Manager, Regulatory Assurance Waterford 3 W3F1-2019-0082 December 5, 2019 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Transmittal of Slides for Second Partially Closed Presubmittal Meeting with Entergy Operations, Inc. to Discuss a Planned License Amendment Request for Digital Instrumentation and Control Modification at Waterford Steam Electric Station, Unit 3 (EPID L-2019-LRM-0079)

Waterford Steam Electric Station, Unit 3 NRC Docket No. 50-382 Renewed Facility Operating License No. NPF-38

Reference:

Meeting Notice, "Second Partially Closed Presubmittal Meeting with Entergy Operations, Inc. to Discuss a Planned License Amendment Request for Digital Instrumentation and Control Modification at Waterford Steam Electric Station, Unit 3 (EPID L-2019-LRM-0079), (ADAMS Accession No. ML19337B567), dated November 26, 2019 A partially closed meeting between Entergy Operations, Inc. (Entergy) and the U.S. Nuclear Regulatory Commission (NRC) staff is scheduled for December 11, 2019. The purpose of this meeting is to discuss one feature of a planned license amendment request to replace the Waterford 3 Core Protection Calculator and Control Element Assembly Calculator Systems in accordance with Digital Instrumentation and Control (DI&C) Interim Staff Guidance (ISG)

DI&C-ISG-06, Revision 2.

Attached to this letter are:

Presubmittal Meeting Slides, "Waterford Unit 3 CPC/CEAC Replacement License Amendment Request NRC Technical Meeting" [Westinghouse document WAAP-11619-NP (Non-Proprietary)] (Attachment 1).

W3F1-2019-0082 Page 2 of 3 Westinghouse Letter CAW-19-4979, Affidavit, Proprietary Information Notice, and Copyright Notice (Attachment 2).

Presubmittal Meeting Slides, "Waterford Unit 3 CPC/CEAC Replacement License Amendment Request NRC Technical Meeting" [Westinghouse document WAAP-11619-P (Proprietary)] (Attachment 3).

As Attachment 3 contains information proprietary to Westinghouse Electric Company LLC

("Westinghouse"), it is supported by an Affidavit signed by Westinghouse, the owner of the information. The Affidavit sets forth the basis on which the information may be withheld from public disclosure by the Nuclear Regulatory Commission ("Commission") and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.

Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse Affidavit should reference CAW-19-4979 and should be addressed to Camille T. Zozula, Manager, Infrastructure & Facilities Licensing, Westinghouse Electric Company, 1000 Westinghouse Drive, Suite 165, Cranberry Township, Pennsylvania 16066.

This letter contains no new regulatory commitments.

If you have any questions or require additional information, please contact the Regulatory Assurance Manager, Paul Wood, at (504) 464-3786.

Respectfully, Paul Wood PW/mmz

W3F1-2019-0082 Page 3 of 3 Attachments: 1. Waterford Unit 3 CPC/CEAC Replacement License Amendment Request NRC Technical Meeting Slides [Westinghouse document WAAP-11619-NP (Non-Proprietary)]

2. Westinghouse Letter CAW-19-4979

3. Waterford Unit 3 CPC/CEAC Replacement License Amendment Request NRC Technical Meeting Slides [Westinghouse document WAAP-11619-P (Proprietary)])

cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector - Waterford 3 NRC Project Manager - Waterford 3

Attachment 1 W3F1-2019-0082 Waterford Unit 3 CPC/CEAC Replacement License Amendment Request NRC Technical Meeting Slides

[Westinghouse document WAAP-11619-NP (Non-Proprietary)]

John Schrage, Senior Staff Engineer - Corporate Licensing, Entergy

Jerry Holman, Safety Analysis SME, Entergy

Amanda Charleroy, Westinghouse Manager, Transient Analysis, Westinghouse

Kim Jones, Fellow Engineer, Transient Analysis, Westinghouse 2

WAAP-11619-NP

Meeting

Purpose:

Describe the approach that Entergy will utilize in the planned LAR for the Core Protection Calculator (CPC)/Control Element Assembly Calculator (CEAC) upgrade project to demonstrate that the calculated response times in the new CPCS design are bounded by the accident analysis (i.e., DI&C ISG-06, Revision 2, Item D.2.4.1).

Meeting Goal: Inform NRC and obtain feedback concerning topics and information that should be included in LAR.

3 WAAP-11619-NP

Topic Statement

Estimated Response Time Changes

Estimated Impacts on Response Times

Impact on Safety Analysis

Qualitative Assessment Approach

Conclusion 4

WAAP-11619-NP

Changes in calculated response times will impact the Waterford analyses of record (AOR).

Revised analyses using the updated Common Q CPC response times will not be completed prior to LAR submittal in June 2020.

This concludes the open portion of the meeting.

5 WAAP-11619-NP

WAAP-11619-NP

The current Waterford 3 CPCS response time acceptance criteria is based on the calculated response time of legacy CPCS digital equipment, and not a bounding response time assumption.

Common Q architectural changes will result in some response times for the new CPC system to be slightly different than those credited in Waterford-3 Safety Analysis Report (SAR) Chapter 15 Non-LOCA Safety Analyses 7

WAAP-11619-NP

The LAR will include a complete description of Waterford-specific calculated Common Q response times, and comparison with current response times.

The LAR will include a complete description of qualitative approach used to evaluate the impact of the Common Q response times on the Chapter 15 non-LOCA transients that use a CPCS trip.

The revised safety analyses will be completed prior to new fuel load, in accordance with 10 CFR 50.59 process. The 50.59 process will ensure the CPC response time changes remains within the existing operating margins.

8 WAAP-11619-NP

Common Q Architectural Changes o Single minicomputer to multiple Programmable Logic Controllers (PLCs) in a channel o Multiplication of CEACs from 2 to 8 o Conservative estimates in the Common Q calculation

Gathering data from the additional components [increases] a,c the overall time required for CPC to complete its calculations and functions.

The calculated response times will be determined as part of design process, with an expected completion date of January 2020.

The expected Waterford-3 Common Q response times are based on the Palo Verde Nuclear Generation Stations (PVNGS) calculated Common Q values.

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

9 WAAP-11619-NP

Westinghouse Non- Proprietary Class 3 © 2019 Westinghouse Electric Company LLC. All Rights Reserved Estimated Impact on Response Times Table 1 Examples Waterford-3 Current versus Expected Common Q Response Time Assumption

[ [

Waterford-3 Current Analysis Assumption Response Time msec ] a,c ] a,c Neutron Flux Power from Excore Detector 275 [ ]a,c [ ] a,c CEA Position - CPC 1343 [ ] a,c [ ] a,c Cold Leg Temperature (Tcold) 370 [ ] a,c [ ] a,c Hot Leg Temperature Variable Overpower Trip 370 [ ] a,c [ ] a,c Hot Leg Saturation Trip 2952 [ ] a,c [ ] a,c RCP Shaft Speed 232 [ ] a,c [ ] a,c Pressurizer Pressure 270 [ ] a,c [ ] a,c (a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

10 WAAP-11619-NP

[

CPCS Auxiliary Trip SAR Chapter 15 Events Functions

] a,c HFP and HZP CEA Bank Withdrawal, Variable Overpower Trip Excess Load, [ ] a,c Pre-trip Steam Line Break, CEA Ejection Tcold Trip Asymmetric SG Transient [ ] a,c Loss of Forced Reactor Coolant Flow, RCP Shaft Speed Trip Single RCP Shaft Seizure/Sheared Shaft [ ] a,c Hot Leg Saturation Trip SG Tube Rupture [ ] a,c Pressurizer Pressure Letdown Line Break [ ] a,c Table 2 presents the impact on expected Common Q assumed response time assumptions for a representative set of Non-LOCA safety analyses from SAR Chapter 15.

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

11 WAAP-11619-NP

June 2020 CPC/CEAC LAR will utilize a qualitative approach, comparing the new calculated response times against the acceptance criteria, to demonstrate that Safety Analysis limits will not be exceeded with the calculated changes in response times.

2015 Waterford LAR requested approval to increase the average and slowest CEA drop time by 200 msec.

o The analytical approach that Entergy utilized to support the 200 msec delay in CEA drop time will be used to determine the impact of [increased] a,c CPC response times on affected safety analyses.

o The Common Q [increase] a,c in CPCS response times produces the same effect as the 2015 license amendment, but the [increases] a,c in response times are significantly smaller.

There will be no changes to the accident analyses methodologies. The reload methodology will account for any changes in CPC response time by utilizing existing COLSS and CPC operating margins.

The following tables demonstrate that after accounting for new response times, the Chapter 15 non-LOCA Safety Analysis will still meet the acceptance criteria.

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

12 WAAP-11619-NP

Table 3A Assessment Results for the Loss of Reactor Coolant Flow Parameter Previous Analysis Value for Expected Value Acceptance Analysis 200 msec Delay including Response Criteria Value Time of [ ] a,c DNBR 1.302 1.282(1) [ ] a,c 1.24 Peak Pressure, psia 2395 2415 [ ] a,c 2750

1) Value based on 200 msec change only; reported value is 1.293 which includes other conservatisms.

Table 3B Assessments Result for the Pre-Trip Steam Line Break Parameter Previous Analysis Value for Expected Value Acceptance Analysis 200 msec Delay including Response Criteria Value Time of [ ] a,c DNBR 1.428 1.365 [ ] a,c NA Fuel Failure, % 0 0 [ ] a,c 8 Table 3C Assessment Results for the Uncontrolled CEA Bank Withdrawal from HZP Parameter Previous Analysis Value for Expected Value Acceptance Analysis 200 msec Delay including Response Criteria Value Time of [ ] a,c DNBR 3.44 2.90 [ ] a,c 1.24 Full Power Seconds Limit, (sec) 1.35 1.49 [ ] a,c 2.53(1)

Fuel Centerline Temp. °F < 3500 < 3500 [ ] a,c < 4663(2)

1) The 2.53 seconds corresponds to a fuel centerline temperature of 3500 °F.

2) Actual Criteria for maximum allowed burnup.

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

13 WAAP-11619-NP

14 WAAP-11619-NP

Attachment 2 W3F1-2019-0082 Westinghouse Letter CAW-19-4979 As Attachment 3 contains information proprietary to Westinghouse Electric Company LLC, it is supported by an Affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations

Westinghouse Non-Proprietary Class 3 CAW-19-4979 Page 1 of 3 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

COUNTY OF BUTLER:

(1) I, Zachary S. Harper, have been specifically delegated and authorized to apply for withholding and execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse).

(2) I am requesting the proprietary portions of WAAP-11619-P be withheld from public disclosure under 10 CFR 2.390.

(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 10 CFR 2.390, 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 Westinghouse and is not customarily disclosed to the public.

(ii) Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses.

Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

- - This record was final approved on 12/4/2019 10:31:16 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 CAW-19-4979 Page 2 of 3 AFFIDAVIT (5) Westinghouse has policies in place to identify proprietary information. Under that system, information is held in confidence if it falls in one or more of several types, 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 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage (e.g., by optimization or improved marketability).

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive 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, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

(6) The attached documents are bracketed and marked to indicate the bases for withholding. The justification for withholding is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters

- - This record was final approved on 12/4/2019 10:31:16 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 CA W-19-4979 Page 3 of 3 AFFIDAVIT refer to the types of information Westinghouse customarily holds in confidence identified in Sections (5)(a) through (f) of this Affidavit.

I declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief.

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

Executed on:

~lk=

Z~. f-farper, Manager Licensing Engineering

- - This record was final approved on 12/4/2019 10:31:16 AM. (This statement was added by the PRIME system upon its validation)

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and non-proprietary versions of a document, furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.390 of the Commissions regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted).

The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the Affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection 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 public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

- - This record was final approved on 12/4/2019 10:31:16 AM. (This statement was added by the PRIME system upon its validation)

v t e Letter Sequence Meeting
EPID:L-2019-LRM-0079, SECY-18-0100: Annual Update Regarding the Integrated Strategy to Modernize the Nuclear Regulatory Commission'S Digital Instrumentation and Control Regulatory Infrastructure (Open)
Initiation Request, Request Acceptance... Administration Withholding Request Acceptance Meeting, Meeting Questions Answers Results Approval... Other:
MONTHYEAR2019-12-05 [Table View]

W3F1-2019-0082, Transmittal of Slides for Second Partially Closed Presubmittal Meeting with Entergy Operations, Inc. to Discuss a Planned License Amendment Request for Digital Instrumentation and Control Modification

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