Text

Transmittal of Slides for Third Partially Closed Presubmittal Meeting with Entergy Operations, Inc. to Discuss a Planned License Amendment Request for Digital Instrumentation and Control Modification
	ML20008F008
Person / Time
Site:	Waterford
Issue date:	01/08/2020
From:	Wood P; Entergy Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML20008F006	List: W3F1-2020-0002, Transmittal of Slides for Third 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-0093, W3F1-2020-0002
	Download: ML20008F008 (75)
	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 W3F1-2020-0002 January 8, 2020 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Transmittal of Slides for Third 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-0093)

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

Reference:

Meeting Notice, "Third 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-0093)," (ADAMS Accession No. ML19365A097), dated December 31, 2019 A partially closed meeting between Entergy Operations, Inc. (Entergy) and the U.S. Nuclear Regulatory Commission (NRC) staff is scheduled for January 16, 2020. The purpose of this meeting is to discuss, in detail, a planned license amendment request (LAR) to replace the Core Protection Calculator and Control Element Assembly Calculator Systems with digital 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 Pre-submittal Meeting #2" [Westinghouse document WAAP-11643-NP (Non-Proprietary)] (Attachment 1).

W3F1-2020-0002 Page 2 of 3 Westinghouse Letter CAW-20-4988, which includes the Affidavit, Proprietary Information Notice, and Copyright Notice (Attachment 2).

Presubmittal Meeting Slides, "Waterford Unit 3 CPC/CEAC Replacement License Amendment Request NRC Pre-submittal Meeting #2" [Westinghouse document WAAP-11643-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-20-4988 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

W3F1-2020-0002 Page 3 of 3 Attachments: 1. Waterford Unit 3 CPC/CEAC Replacement License Amendment Request NRC Pre-submittal Meeting #2 [Westinghouse document WAAP-11643-NP (Non-Proprietary)]

2. Westinghouse Letter CAW-20-4988

3. Waterford Unit 3 CPC/CEAC Replacement License Amendment Request NRC Pre-submittal Meeting #2 [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 W3F1-2020-0002 Waterford Unit 3 CPC/CEAC Replacement License Amendment Request NRC Pre-submittal Meeting #2

[Westinghouse document WAAP-11643-NP (Non-Proprietary)]

Westinghouse Non-Proprietary Class 3 © 2020 Westinghouse Electric Company LLC. All Rights Reserved Waterford Unit 3 CPC/CEAC Replacement License Amendment Request NRC Pre-submittal Meeting #2 January 16, 2020 WAAP-11643-NP

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Ron Gaston, Director - Fleet Regulatory Assurance

William Steelman, Design Manager - Waterford

John Schrage, Senior Staff Engineer - Corporate Licensing

Janice Cruz, Manager, Major Fleet Projects - Engineering

Christopher Talazac, Supervisor, Major Fleet Projects - Engineering

Roger Rucker, Lead Responsible Engineer, Major Fleet Projects -

Engineering

William Truss, I&C Engineer, Major Fleet Projects - Engineering

Jacob Champagne, I&C Engineer, Major Fleet Projects - Engineering

Loren Miller, Project Manager, CPC Replacement Project

David Constance, Assistant Operations Manager - Support

Pareez Golub, SME, Major Fleet Projects - Engineering

Alan Harris, Site Regulatory Assurance 2

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Warren Odess-Gillett, Licensing Lead

Steven Merkiel, Senior Engineer

Allen Denyer, Project Technical Advisor

Eric Fredrickson, Project Manager 3

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Engage with NRC Staff prior to LAR submittal and describe the WF3 CPC/CEAC digital upgrade

Provide an overview of LAR content

Gain alignment on use of ISG-06 Alternate Review process and submittal/review process

Solicit Staff feedback prior to LAR submittal to facilitate a more efficient NRC review 4

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Project milestones

CPC/CEAC Existing and New System Overview

Westinghouse Licensing Technical Report (LTR)

Table of Contents (TOC)

Acronym List 5

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Technical Specifications Impacts o Limiting Condition for Operations (LCO) o Surveillance Requirement (SR) Elimination

September 2019 Pre-submittal meeting summary and follow-up actions

Plant Specific Action Items (PSAIs)

DI&C-ISG-06 C.2.2 Commitments

Vendor Oversight Update

LAR Content for DI&C-ISG-06 Sections of Interest

Human Factors Considerations 6

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Open Portion 7

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Draft LAR Submitted 5/2020

NRC Pre-submittal Meeting 5/2020

LAR Submittal 6/2020

Request NRC approval 6/2021

System Installation (RF 24) 4/2022 8

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WF3 Plant Protection System (PPS) is comprised of an Engineered Safety Features Actuation System (ESFAS) and a Reactor Protection System (RPS)

Core Protection Calculator (CPC) System provides two reactor trip signals in the RPS to assure fuel design limits are not exceeded and aids the ESFAS in limiting consequences of an accident 10 WAAP-11643-NP

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Westinghouse Non-Proprietary Class 3 © 2020 Westinghouse Electric Company LLC. All Rights Reserved CPC/CEAC System Overview The CPCs provide the following Auxiliary trips, to the RPS, to initiate a reactor trip (no pre-trip alarms):

CPC Failure

Less than two RCPs running

Asymmetrical Steam Generator Trip (ASGT)

Variable Overpower Trip (VOPT)

Thot at Saturation

Any input parameter outside of CPC operating space:

o Cold Leg temperature o Primary pressure o Radial Peaking Factor (RPF) o Axial Shape Index (ASI) 11 WAAP-11643-NP

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The Control Element Assembly Calculators (CEACs) provide the CPCs with information about individual CEA deviations o Each CEAC monitors the CEAs distributed to the four CPC channels and sends penalty factors for deviations of CEA position between the CPC channels o Each CEAC receives input from its Reed Switch Position Transmitters (RSPT) 12 WAAP-11643-NP

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The CPCs provide the following two trips, to the RPS, to initiate a reactor trip:

o Low Departure From Nucleate Boiling Ratio (DNBR) trip o High Local Power Density (LPD) trip

Each trip has a pre-trip Main Control Room alarm 13 WAAP-11643-NP

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Replace the existing system with Westinghouse Common Qualified (Common Q) digital platform for CPC and CEAC functionality

Each CPC channel (A-D) will have two CEACs each for eight total CEACs

Replace Operator Modules with new touchscreen Flat Panel Displays

Each channel has its own Maintenance Test Panel (MTP)

Replace control room board indicators for Reactor Fuel Therm(al) Limits - LPD and DNBR Margin 17 WAAP-11643-NP

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Westinghouse Non-Proprietary Class 3 © 2020 Westinghouse Electric Company LLC. All Rights Reserved Digital upgrade - Functional Architecture No design basis changes to the algorithms or functional architecture from the existing CPC system:

Initiates two trips in the RPS:

o Low Departure From Nucleate Boiling Ratio (DNBR) trip o High Local Power Density (LPD) trip

Initiates CEA Withdrawal Prohibit (CWP) signal for use in the PPS

Initiates annunciator alarms

Provides analog outputs for control room board indicators for DNBR margin and LPD margin CPC algorithm will be changed to add pre-trip alarms for the Auxiliary trips 18 WAAP-11643-NP

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1. INTRODUCTION

2. PLANT SYSTEM DESCRIPTION (D.1)

3. SYSTEM ARCHITECTURE (D.2)

1. EXISTING ARCHITECTURE (D.2.1)

2. NEW SYSTEM ARCHITECTURE (D.2.2)

3. NEW SYSTEM FUNCTIONS (D.2.3 AND 2.3.1)

4. FUNCTION ALLOCATION (D.2.4 AND D.2.4.1)

5. SYSTEM INTERFACES (D.2.5)

6. FUNDAMENTAL DESIGN PRINCIPLES IN THE NEW ARCHITECTURE (D.2.6)

4. HARDWARE EQUIPMENT QUALIFICATION (D.3)

5. I&C SYSTEM DEVELOPMENT PROCESSES (D.4)

6. APPLYING REFERENCED TOPICAL REPORT SAFETY EVALUATION (D.5) 19 WAAP-11643-NP

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7. COMPLIANCE/CONFORMANCE MATRIX FOR IEEE STANDARDS 603-1991 AND 7-4.3.2-2003 (D.6)

8. TECHNICAL SPECIFICATIONS (D.7)

9. SECURE DEVELOPMENT AND OPERATIONAL ENVIRONMENT (D.8)

10. REFERENCES

11. BIBLIOGRAPHY

12. APPENDIX A WSES-3 CPCS TECHNICAL SPECIFICATION MARKUPS

13. APPENDIX B UFSAR MARKUPS

14. APPENDIX C ELIMINATION OF SPECIFIC CPCS TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENTS 20 WAAP-11643-NP

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Westinghouse Non-Proprietary Class 3 © 2020 Westinghouse Electric Company LLC. All Rights Reserved Acronym List Alternate Review Process ARP Asymmetrical Steam Generator Trip ASGT Auxiliary Multiplexer Aux MUX Axial Shape Index ASI CEA Withdrawal Prohibit CWP Common Cause Failure CCF Control Element Assembly CEA Control Element Assembly Calculator CEAC Control Element Assembly Position Display System CEAPDS Control Panel CP Core Operating Limit Supervisory System COLSS Core Protection Calculator CPC Core Protection Calculator System CPCS Departure From Nucleate Boiling Ratio DNBR Digital Instrumentation and Control DI&C Electromagnetic Interference/Radio Frequency Interference EMI/RFI Electromagnetic Compatibility EMC Equipment Qualification EQ Equipment Qualification Summary Report EQSR 21 WAAP-11643-NP

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Westinghouse Non-Proprietary Class 3 © 2020 Westinghouse Electric Company LLC. All Rights Reserved Acronym List Flat Panel Display FPD Generic Open Item GOI Human Factors Engineering HFE Inter-Range Instrument Group IRIG Institute of Electrical and Electronics Engineers IEEE Interim Staff Guidance ISG License Amendment Request LAR Local Power Density LPD Main Control Room MCR Maintenance Test Panel MTP Operator Module OM Plant Protection System PPS Plant Specific Action Item PSAI Pressurizer PZR Quality Assurance QA Radial Peaking Factor RPF Reactor Coolant Pump RCP Reactor Protection System RPS Record of Changes ROC 22 WAAP-11643-NP

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Westinghouse Non-Proprietary Class 3 © 2020 Westinghouse Electric Company LLC. All Rights Reserved Acronym List Reed Switch Position Transmitter RSPT Requirements Traceability Matrix RTM Response Time Test RTT Safety Evaluation Report SER Secure Development and Operational Environment SDOE Secure Development Environment SDE Secure Operational Environment SOE Single Point Vulnerabilities SPV Site Acceptance Test SAT Software Program Manual SPM Standard Std.

System Requirements Specification SyRS Technical Specifications TS Topical Report TR United States Nuclear Regulatory Commission NRC Variable Overpower Trip VOPT Vendor Oversight Plan VOP Waterford Unit 3 WF3 Westinghouse Common Qualified Platform Common Q 23 WAAP-11643-NP

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Closed Portion 24 WAAP-11643-NP

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Increasing from two CEACs total per four channels to two CEACs per channel (eight CEACs total) o TS 3/4.2.4, DNBR Margin o TS 3/4.3.1, Reactor Protective Instrumentation

CEAC Operability incorporated under each CPC Channel Functional Unit in Table 3.3-1

Elimination of auto-restart in legacy system o TS 3/4.2.4, DNBR Margin o TS 3/4.3.1, Reactor Protective Instrumentation

Revision of reference to software change procedure o TS 6.8, Procedures and Programs 26 WAAP-11643-NP

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TS SR 4.3.1.1 (Channel Functional Testing of the CPCS portion of the SR)

TS SR 4.3.1.3 (RTT of the CPCS portion of the SR)

TS SR 4.3.1.5 (CPC/CEAC Operability) 27 WAAP-11643-NP

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Westinghouse Non-Proprietary Class 3 © 2020 Westinghouse Electric Company LLC. All Rights Reserved Technical Specification Impact The LAR will propose eliminating certain TS Surveillance Testing by crediting self-diagnostics of Common Q.

Reference licensing precedence of Vogtle 3&4 SR Elimination LAR (ML19084A309) for Waterford 3 CPCS LAR

Present markups of CPCS TS surveillances to be eliminated:

o TS SR 4.3.1.1 (Channel Functional Testing of the CPCS portion of the SR) o TS SR 4.3.1.3 (RTT of the CPCS portion of the SR) 28 WAAP-11643-NP

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Below are follow-up items listed in the Meeting Summary dated 11/5/2019:

Further details of the vendor oversight plan (VOP)

Potential licensee commitments and license conditions in the LAR that are associated with early design approval under the ARP

Potential reduction of technical specification surveillance testing by crediting self-diagnostic/testing functions of the Common Q platform

Crediting anticipated transient without scram (ATWS) in an updated diversity and defense-in-depth analysis

Addressing the independence clause in IEEE Std. 603-1991, IEEE Standard Criteria for Safety Systems for Nuclear Power Generating Stations 33 WAAP-11643-NP

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Westinghouse Non-Proprietary Class 3 © 2020 Westinghouse Electric Company LLC. All Rights Reserved 9/19/2019 Pre-submittal Meeting Follow-up Below are follow-up items listed in the Meeting Summary dated 11/5/2019:

Disposition of Common Q platform generic open items and plant application-specific action items for Waterford 3

Future revision to the equipment qualification summary report after the submittal of the LAR

Timing analysis of the Common Q platform

Frequency of interactions and use of an open items list during the NRC review of the LAR 34 WAAP-11643-NP

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CPCs provide 2 of the 12 Reactor Trip signals to the RPS.

ATWS provides mitigation when the RPS fails to trip the reactor o Uses independent high pressurizer (PZR) pressure indications o CCF review shows various RPS trips provide backup to the DNBR and LPD trips generated by CPCs

Summary:

o RPS provides backup when CPCs fail to generate a trip signal o Failure of the CPCs does not directly lead to operation of the ATWS system 35 WAAP-11643-NP

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Site Licensing Basis IEEE 279

WF3 designed with 2 trains RSPT signals

IEEE-603 5.6.1 states: redundant portions of a safety system provided for a safety function shall be independent of, and physically separated from each other to the degree necessary to retain the capability to accomplish the safety function 36 WAAP-11643-NP

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Westinghouse Non-Proprietary Class 3 © 2020 Westinghouse Electric Company LLC. All Rights Reserved Common Q Topical Report PSAIs The WF3 CPCS Replacement LAR will address Generic Open Items (GOI) 8 & 12 and the 24 Plant-Specific Action Items (PSAIs)

The dispositions for these GOIs and PSAIs will be in the LAR addressing DI&C-ISG-06 Revision 2, D.5.1.1

Certain PSAIs of interest are discussed in subsequent slides 38 WAAP-11643-NP

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The DI&C-ISG-06, Revision 2, Section D.5.1.2, Resolution of Topical Report Plant-Specific Action Items states:

Based on a topical report review in accordance with SRP BTP 7-14, some topical reports include plant-specific items stating that the NRC staff should review detailed design, implementation, testing, and ongoing life cycle activities. For the Alternate Review Process, the licensee will provide oversight of the performance of these activities, in accordance with the licensees QA program and Vendor Oversight Plan.

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Referenced topical reports plant-specific action items

Completion of life cycle activities after LAR submittal o Under Tier 1, 2, 3 these would be complete prior to LAR review completion o LAR will include regulatory commitments for life cycle activities listed as DI&C-ISG-06, Enclosure B, Tier 1 items to be completed post-LAR submittal 45 WAAP-11643-NP

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Entergy will evaluate WF3 CPCS Replacement Project Site Acceptance Test (SAT) and Installation Test Plans using the software process testing characteristics described in BTP 7-14 Section B.3.2.4. This is Plant-specific Action Item #6 per WCAP-16097, Common Qualified Platform Topical Report.

Entergy will complete the following document in accordance with Entergys Quality Assurance program:

o Westinghouse Technical Manual (Enclosure B Item 2.2, As-Manufactured, System Configuration Documentation)

Entergy will complete the following activity in accordance with Entergys Quality Assurance program and WCAP-16096, Software Program Manual for Common Q' Systems, Rev. 5:

o Factory Acceptance Test (Enclosure B Items 2.3 and 2.4, Summary Test Reports and System Response Time Confirmation Report)

Entergy will complete the following activity in accordance with Entergys Quality Assurance program and WCAP-16097, Common Qualified Platform Topical Report:

o Equipment qualification of CPCS equipment determined upon completion of detailed design (Enclosure B Item 2.7, Qualification Test Methodologies) 46 WAAP-11643-NP

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Regression Analysis for the CPC Reference Design (Feb 2020) o Includes software test plans and results, IV&V reports, and the regression analysis documents

Requirements Traceability (May 2020) o Includes system requirements specifications, drawings, analysis, calculations, etc.

Regression Analysis for the WF3 changes (Aug 2020) o Includes the software test plans and results, IV&V reports, and the regression analysis documents

Testing Observation and Requirements Traceability (Sep-Oct 2020) o Includes observation of testing for the WF3 project associated with the WF3 software and hardware 48 WAAP-11643-NP

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In accordance with DI&C-ISG-06 and IEEE 603-1991 clause 5.14, human factors is being considered at each stage throughout the design to ensure safety functions can be successfully accomplished.

Waterford 3 CPC Project HFE Considerations:

o No existing automatic actions become manual actions with the new system o No change to existing staff levels o Minimal procedural changes expected (Operations team member involved in identifying impacts and reviewing) o Project team is multi-disciplinary (e.g., Engineering, Operations, Maintenance) to ensure HFE is considered at each level 60 WAAP-11643-NP

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Human factors considerations from the NRC-approved Palo Verde CPCS implementation are being used in addition to the 15 years of Palo Verde operating experience.

WNA-IG-00871-GEN, Human Factors Engineering Guideline for the Common Q Display System is being used to ensure Common Q Display software complies with applicable human factor design principles.

Palo Verde October 2019 refueling outage benchmark -

Maintenance personnel

Factory Acceptance Test and Site Acceptance Test will be developed to ensure all conditions are tested and human-error mechanisms are considered 61 WAAP-11643-NP

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WF3 Training organization involved in Engineering Change package development and review

Entergy design process and procedures include identifying the applicable design inputs. Key HFE design inputs include:

o Design functions and performance requirements o Layout/arrangement requirements o Operational requirements o Accessibility/maintenance/repair requirements, and o Interface requirements between equipment and operations/maintenance personnel.

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Attachment 2 W3F1-2020-0002 Westinghouse Letter CAW-20-4988 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-20-4988 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-11643-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 1/8/2020 1:36:18 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 CAW-20-4988 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 1/8/2020 1:36:18 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 CAW-20-4988 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:

Zaclfary S. Harper, Manager Licensing Engineering

- - This record was final approved on 1/8/2020 1:36:18 PM. (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 1/8/2020 1:36:18 PM. (This statement was added by the PRIME system upon its validation)

v t e Letter Sequence Meeting
EPID:L-2019-LRM-0093, (Open)
Initiation Acceptance... Administration Withholding Request Acceptance Meeting, Meeting Questions Answers Results Approval... Other:
MONTHYEAR2020-02-21 [Table View]

W3F1-2020-0002, Transmittal of Slides for Third 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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