ML20113E836

From kanterella
Jump to navigation Jump to search

Summary of March 19, 2020, Category 1 Public Meeting with Entergy Operations Inc. a Planned LAR to Install Digital Systems in Accordance with Di&C ISG-06 Revision 2, Licensing Processes at Waterford Steam Electric Station
ML20113E836
Person / Time
Site: Waterford Entergy icon.png
Issue date: 04/23/2020
From: April Pulvirenti
Plant Licensing Branch IV
To:
Entergy Operations
Pulvirenti A
References
EPID L-2020-LRM-0016
Download: ML20113E836 (33)


Text

April 23, 2020 LICENSEE:

Entergy Operations, Inc.

FACILITY:

Waterford Steam Electric Station, Unit 3

SUBJECT:

SUMMARY

OF MARCH 19, 2020, CATEGORY 1 PUBLIC MEETING WITH ENTERGY OPERATIONS, INC. REGARDING A PLANNED LICENSE AMENDMENT REQUEST TO INSTALL DIGITAL SYSTEMS IN ACCORDANCE WITH DIGITAL INSTRUMENTATION AND CONTROL INTERIM STAFF GUIDANCE (DI&C ISG)-06 REVISION 2, LICENSING PROCESSES (EPID L-2020-LRM-0016)

On March 19, 2020, a Category 1 partially closed public meeting was held between the U.S. Nuclear Regulatory Commission (NRC), representatives of Entergy Operations, Inc.

(Entergy, the licensee), and Westinghouse Electric Company, LLC (Westinghouse) regarding a planned license amendment request (LAR) for Waterford Steam Electric Station, Unit 3 (Waterford 3). The meeting notice and agenda, dated February 28, 2020, are available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML20059N287. A public version of the licensees presentation is available at ADAMS Accession No. ML20072P204. In addition, the NRC staff prepared a list of topics for discussion, which is available at ADAMS Accession No. ML20059K156. The list of attendees to this meeting is included as Enclosure 1. The licensee provided a draft version of the proposed technical specifications (TSs) markup, which is included as Enclosure 2.

By letter dated May 16, 2019 (ADAMS Accession No. ML19137A082), the licensee expressed intent to submit an LAR for an upgrade to the digital instrumentation and control (DI&C) system at Waterford 3 in spring 2020. The same letter also requested a fee waiver for the review of the application. A partial fee waiver was granted by letter dated October 30, 2019 (ADAMS Accession No. ML19280C270).

The purpose of this partially closed meeting was to further discuss a planned LAR to replace the core protection calculator (CPC) and control element assembly calculator (CEAC) systems with digital systems in accordance with DI&C Interim Staff Guidance (ISG) DI&C-ISG-06, Revision 2, Licensing Processes (ADAMS Accession No. ML18269A259). This letter summarizes the fourth presubmittal meeting pertaining to this planned LAR. Specifically, the primary topics discussed at this meeting were impacts of the LAR on the Waterford 3 TSs, the failure mode effects analysis (FMEA) and failure modes effects and diagnostic analysis (FMEDA), and the vendor oversight program (VOP).

During the open portion of the meeting, the licensee and NRC staff discussed an updated timeline for submittal of the LAR. During the public meeting held on January 16, 2020, the licensee had proposed to submit a draft version of the LAR in early June 2020 for cursory initial review by the NRC staff, followed by a final presubmittal meeting. During the meeting on March 19, 2020, the NRC staff indicated that providing a brief initial review for this particular draft LAR would be acceptable due to the first-of-a-kind nature of the alternate review process

outlined in DI&C-ISG-06 Revision 2. The NRC staff indicated that review of this draft LAR should not set a precedent for future LARs.

During the closed portion of the meeting, the licensee presented additional proprietary details of the impact of the proposed digital modification on the current Waterford 3 TSs. The licensee stated that the TS changes will be modeled after the TS changes made for a digital modification at Palo Verde Nuclear Generating Station. The licensee also stated that the revised TSs include new actions that would ensure the CPC and CEAC systems would never be in a configuration that represents an action not described in the TSs. The NRC staff expressed concern with the licensees proposal to eliminate the channel function test surveillance requirement in the TSs, and requested that the licensee include in its application how the performance of the self-diagnostics function of the Common Q platform would be verified if this surveillance was removed from the TSs. Entergy and Westinghouse also clarified the difference between the FMEA and FMEDA and described how each would be utilized in the Waterford 3 digital systems.

The licensee gave further details about its planned VOP and provided tentative dates for planned audits of the regression analyses and requirements tracability. The licensee stated that it intends to audit Westinghouses design process for the Common Q platform. The licensee also stated that the VOP would provide acceptance criteria for life-cycle development topics such as quality assurance, software verification and validation, and secure development environment. The NRC staff expressed interest in observing Entergys audits, because similar vendor audits were normally conducted by the staff for prior applications.

Finally, the licensee addressed the questions in Item Nos. 5 and 6 of the NRC-prepared discussion topics. The licensee clarified the definition of the term architecture level and clarified the version of the Common Q topical report that would be referenced in the LAR. The licensee also provided the planned dates for implementation testing, factory acceptance testing, and site acceptance testing.

No regulatory decisions were reached at this meeting. No members of the public attended the meeting. No Public Meeting Feedback forms were received.

Please direct any inquiries to me at 301-415-1390 or April.Pulvirenti@nrc.gov.

Sincerely,

/RA/

April Pulvirenti, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382

Enclosures:

1. List of Attendees
2. Draft Technical Specifications Markup cc: Listserv

LIST OF ATTENDEES MARCH 19, 2019, PARTIALLY CLOSED PRESUBMITTAL MEETING WITH ENTERGY OPERATIONS, INC WATERFORD STEAM ELECTRIC STATION, UNIT 3 U.S. Nuclear Regulatory Commission Sargent and Lundy Rossnyev Alvarado Pareez Golub Kristy Bucholtz Calvin Cheung Samir Darbali Jensen Hughes, Inc.

Jennifer Dixon-Herrity Alan Harris DaBin Ki April Pulvirenti Richard Stattel Westinghouse Electric Company, LLC Dinesh Taneja Allen Denyer Michael Waters Steven Merkiel Jack Zhao Warren Odess-Gillett Matthew Shakun John Wiesemann Entergy Operations, Inc.

Jacob Champagne David Constance Janice Cruz Ron Gaston Loren Miller Roger Rucker John Schrage Paul Wood

ENCLOSURE 2 DRAFT TECHNICAL SPECIFICATIONS MARKUP

Note that indicates no changes on page, included for completeness

on any OPERABLE CEAC.

all

Version 1 - With Strikeouts

Version 1 - With Strikeouts

Version 2 - Strikeouts Removed

Version 2 - Strikeouts Removed

WATERFORD - UNIT 3 3/4 3-12 AMENDMENT NO. 69, 125, 145, 222 TABLE 4.3-1 (Continued)

TABLE NOTATIONS (Continued)

(3)

Above 15% of RATED THERMAL POWER, verify that the linear power subchannel gains of the excore detectors are consistent with the values used to establish the shape annealing matrix elements in the Core Protection Calculators.

(4)

Neutron detectors may be excluded from CHANNEL CALIBRATION.

(5)

After each fuel loading and prior to exceeding 70% of RATED THERMAL POWER, the incore detectors shall be used to determine or verify acceptable values for the shape annealing matrix elements used in the Core Protection Calculators.

(6)

This CHANNEL FUNCTIONAL TEST shall include the injection of simulated process signals into the channel as close to the sensors as practicable to verify OPERABILITY including alarm and/or trip functions. DELETED (7)

Above 70% of RATED THERMAL POWER, verify that the total RCS flow rate as indicated by each CPC is less than or equal to the actual RCS total flow rate determined by either using the reactor coolant pump differential pressure instrumentation or by calorimetric calculations and if necessary, adjust the CPC addressable constant flow co-efficients such that each CPC indicated flow is less than or equal to the actual flow rate. The flow measurement uncertainty is included in the BERR1 term in the CPC and is equal to or greater than 4%.

(8)

Above 70% of RATED THERMAL POWER, verify that the total RCS flow rate as indicated by each CPC is less than or equal to the actual RCS total flow rate determined by calorimetric calculations.

(9)

The CHANNEL FUNCTIONAL TEST shall include verification that the correct values of addressable constants are installed in each OPERABLE CPC.

DELETED (10)

In accordance with the Surveillance Frequency Control Program and following maintenance or adjustment of the reactor trip breakers, the CHANNEL FUNCTIONAL TEST shall include independent verification of the undervoltage trip function and the shunt trip function.

(11)

The CHANNEL FUNCTIONAL TEST shall be scheduled and performed such that the Reactor Trip Breakers (RTBs) are tested at least every 6 weeks to accommodate the appropriate vendor recommended interval for cycling of each RTB 12a

WCAP-16096-P-A, "Software Program Manual for Common Q TM Systems,"

ML20113E836

  • by e-mail OFFICE NRR/DORL/LPL4/PM*

NRR/DORL/LPL4/LA*

NRR/DORL/LPL4/BC*

NRR/DORL/LPL4/PM*

NAME APuvirenti PBlechman JDixon-Herrity APulvirenti DATE 4/23/2020 4/23/2020 4/23/2020 4/23/2020