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

Entergy Operations, Inc.

17265 River Road Killona, LA 70057-3093 Tel 504-464-3786 Paul Wood Manager, Regulatory Assurance Waterford 3 ProprietaryInformationWithholdFromPublicDisclosureUnder10CFR2.390 ThebalanceofthislettermaybeconsiderednonproprietaryuponremovalofAttachment3.

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

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

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

Waterford Unit 3 CPC/CEAC Replacement License Amendment Request NRC Pre-submittal Meeting #2 January 16, 2020 Westinghouse Non-Proprietary Class 3

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Participants Entergy Waterford Unit 3 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

Westinghouse Non-Proprietary Class 3

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Participants Westinghouse Warren Odess-Gillett, Licensing Lead Steven Merkiel, Senior Engineer Allen Denyer, Project Technical Advisor Eric Fredrickson, Project Manager 3

Westinghouse Non-Proprietary Class 3

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Pre-submittal Meeting Purpose 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

Westinghouse Non-Proprietary Class 3

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Agenda - Open Portion Project milestones CPC/CEAC Existing and New System Overview Westinghouse Licensing Technical Report (LTR)

Table of Contents (TOC)

Acronym List 5

Westinghouse Non-Proprietary Class 3

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Agenda - Closed Portion 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

Westinghouse Non-Proprietary Class 3

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Pre-submittal Meeting -

Open Portion 7

Westinghouse Non-Proprietary Class 3

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Project Milestones

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

Westinghouse Non-Proprietary Class 3

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CPCS/CEAC System Description System Overview Functional Architecture Main Control Room Overview 9

Westinghouse Non-Proprietary Class 3

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CPC/CEAC System Overview 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 Westinghouse Non-Proprietary Class 3

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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 Westinghouse Non-Proprietary Class 3

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CPC/CEAC System Overview

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 Westinghouse Non-Proprietary Class 3

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CPC/CEAC System - Functional Architecture 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 Westinghouse Non-Proprietary Class 3

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Main Control Room Overview 14 Westinghouse Non-Proprietary Class 3

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MCR CP-7 Channel B 15 Westinghouse Non-Proprietary Class 3

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Digital Upgrade Project Description Overview Functional Architecture 16 Westinghouse Non-Proprietary Class 3

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Planned digital upgrade overview 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 Westinghouse Non-Proprietary Class 3

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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 Westinghouse Non-Proprietary Class 3

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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)

Licensing Technical Report (LTR) TOC 19 Westinghouse Non-Proprietary Class 3

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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 Licensing Technical Report (LTR) TOC 20 Westinghouse Non-Proprietary Class 3

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Acronym List 21 AlternateReviewProcess ARP AsymmetricalSteamGeneratorTrip ASGT AuxiliaryMultiplexer AuxMUX AxialShapeIndex ASI CEAWithdrawalProhibit CWP CommonCauseFailure CCF ControlElementAssembly CEA ControlElementAssemblyCalculator CEAC ControlElementAssemblyPositionDisplaySystem CEAPDS ControlPanel CP CoreOperatingLimitSupervisorySystem COLSS CoreProtectionCalculator CPC CoreProtectionCalculatorSystem CPCS DepartureFromNucleateBoilingRatio DNBR DigitalInstrumentationandControl DI&C ElectromagneticInterference/RadioFrequencyInterference EMI/RFI ElectromagneticCompatibility EMC EquipmentQualification EQ EquipmentQualificationSummaryReport EQSR Westinghouse Non-Proprietary Class 3

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Acronym List 22 FlatPanelDisplay FPD GenericOpenItem GOI HumanFactorsEngineering HFE Inter-Range Instrument Group IRIG InstituteofElectricalandElectronicsEngineers IEEE InterimStaffGuidance ISG LicenseAmendmentRequest LAR LocalPowerDensity LPD MainControlRoom MCR MaintenanceTestPanel MTP OperatorModule OM PlantProtectionSystem PPS PlantSpecificActionItem PSAI Pressurizer PZR QualityAssurance QA RadialPeakingFactor RPF ReactorCoolantPump RCP ReactorProtectionSystem RPS RecordofChanges ROC Westinghouse Non-Proprietary Class 3

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Acronym List 23 ReedSwitchPositionTransmitter RSPT RequirementsTraceability Matrix RTM ResponseTimeTest RTT SafetyEvaluationReport SER SecureDevelopmentandOperationalEnvironment SDOE SecureDevelopmentEnvironment SDE SecureOperationalEnvironment SOE SinglePointVulnerabilities SPV SiteAcceptanceTest SAT SoftwareProgramManual SPM Standard Std.

System RequirementsSpecification SyRS TechnicalSpecifications TS TopicalReport TR UnitedStatesNuclearRegulatoryCommission NRC VariableOverpowerTrip VOPT VendorOversightPlan VOP WaterfordUnit3 WF3 WestinghouseCommonQualifiedPlatform CommonQ Westinghouse Non-Proprietary Class 3

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Pre-submittal Meeting -

Closed Portion 24 Westinghouse Non-Proprietary Class 3

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Technical Specifications Impacts 25 Westinghouse Non-Proprietary Class 3

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Technical Specification Impact Limiting Condition for Operations (LCO) changes:

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 Westinghouse Non-Proprietary Class 3

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Technical Specification Impact Surveillance Requirements Elimination

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 Westinghouse Non-Proprietary Class 3

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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)

Technical Specification Impact 28 Westinghouse Non-Proprietary Class 3

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Technical Specification Impact 29 a,c Westinghouse Non-Proprietary Class 3

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Technical Specification Impact 30 a,c Westinghouse Non-Proprietary Class 3

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Technical Specification Impact 31 a,c Westinghouse Non-Proprietary Class 3

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September 19, 2019 Pre-submittal Meeting Follow-up 32 Westinghouse Non-Proprietary Class 3

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9/19/2019 Pre-submittal Meeting Follow-up Entergy-NRC first pre-submittal meeting held on 9/19/2019.

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 Westinghouse Non-Proprietary Class 3

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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 Westinghouse Non-Proprietary Class 3

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ATWS in CCF discussion 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 Westinghouse Non-Proprietary Class 3

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IEEE Std. 603, Clause 5.6, Independence To address CEAC conformance to Clause 5.6:

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 Westinghouse Non-Proprietary Class 3

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IEEE Std. 603, Clause 5.6, Independence 37 a,c Westinghouse Non-Proprietary Class 3

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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 Westinghouse Non-Proprietary Class 3

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