ML20268B324

Regulatory Audit in Support of Review of Digital Upgrade License Amendment Request

ML20268B324
Person / Time
Site:	Waterford
Issue date:	10/01/2020
From:	Audrey Klett Plant Licensing Branch IV
To:	Entergy Operations
Klett A
References
EPID L-2020-LLA-0164
Download: ML20268B324 (6)

Text

October 1, 2020 Site Vice President Entergy Operations, Inc.

Waterford Steam Electric Station, Unit 3 17265 River Road Killona, LA 70057-3093

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 - REGULATORY AUDIT IN SUPPORT OF REVIEW OF DIGITAL UPGRADE LICENSE AMENDMENT REQUEST (EPID L-2020-LLA-0164)

Dear Sir or Madam:

By letter W3F1-2020-0038 dated July 23, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20205L588), Entergy Operations, Inc. (the licensee) requested a license amendment to Renewed Facility Operating License No. NPF-38 for the Waterford Steam Electric Station, Unit 3 related to a digital upgrade to the core protection calculator system and control element assembly calculator system.

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the licensees application and determined that a regulatory audit would assist in the timely completion of the review. The NRC staff will conduct a regulatory audit to support its review in accordance with the enclosed audit plan. A regulatory audit is a planned activity that includes the examination and evaluation of primarily non-docketed information.

The NRC staff will conduct the audit to increase its understanding of the application and identify information that will require docketing to support the NRC staffs regulatory findings. The NRC staff will conduct the audit virtually at NRC Headquarters in Rockville, Maryland via a licensee-established electronic portal from October 2020 through July 2021. The enclosed audit plan was discussed with your staff on September 22 and September 28, 2020.

If you have any questions, please contact me at (301) 415-0489 or by e-mail at Audrey.Klett@nrc.gov.

Sincerely,

/RA/

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

Enclosure:

Audit Plan cc: Listserv

ML20268B324

• by email OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DSS/SNSB/BC*

NAME AKlett PBlechman SKrepel DATE 09/30/2020 09/29/2020 09/24/2020 OFFICE NRR/DRO/IOLB/BC*

NRR/DRO/IQVB/BC*

NRR/DEX/EICA/BC*

NAME CCowdrey KKavanagh JJohnston DATE 09/28/2020 09/24/2020 09/29/2020 OFFICE NRR/DSS/STSB/BC*

NRR/DEX/EICB/BC*

NRR/DORL/LPL4/BC NAME VCusumano MWaters JDixon-Herrity DATE 09/28/2020 09/24/2020 10/01/2020 OFFICE NRR/DORL/LPL4/PM NAME AKlett DATE 10/01/2020

Enclosure REGULATORY AUDIT PLAN BY THE OFFICE OF NUCLEAR REACTOR REGULATION IN SUPPORT OF REVIEW OF DIGITAL UPGRADE LICENSE AMENDMENT REQUEST ENTERGY OPERATIONS, INC.

WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NO. 50-382

1.0 BACKGROUND

By letter W3F1-2020-0038 dated July 23, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20205L588), Entergy Operations, Inc. (the licensee) requested a license amendment to Renewed Facility Operating License No. NPF-38 for the Waterford Steam Electric Station, Unit 3 (Waterford 3) related to a digital upgrade to the core protection calculator system (CPCS) and control element assembly calculator system (CEACS).

Staff from the U.S. Nuclear Regulatory Commissions (NRCs) Office of Nuclear Reactor Regulation (NRR) identified the need to better understand the licensees supporting analyses by reviewing supporting documentation for the Waterford CPCS and CEACS systems that is not available in ADAMS and interviewing licensee staff. Because this is the NRC staffs initial review of an application using the alternative review process (ARP) from the digital instrumentation and control Interim Staff Guidance (ISG)-06, Revision 2, Licensing Processes (ADAMS Accession No. ML18269A259), the NRC staff will be requesting information and interviews via the audit process throughout its review.

2.0 REGULATORY AUDIT BASIS A regulatory audit is a planned license or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. The audit is conducted with the intent to gain understanding, to verify information, and to identify information that will require docketing to support the basis of a licensing or regulatory decision. Performing a regulatory audit is expected to assist the NRC staff in efficiently conducting its review and gaining insights to the licensees processes and procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket.

The NRC staff will perform the audit to support its evaluation of whether the licensees request can be approved per Title 10 of the Code of Federal Regulations (10 CFR), Section 50.90, Application for amendment of license, construction permit, or early site permit. This audit will be conducted in accordance with NRR Office Instruction LIC-111, Regulatory Audits, Revision 1, dated October 2019 (ADAMS Accession No. ML19226A274), with exceptions noted because of the nature of this review being the NRC staffs initial review of an application using the ARP from ISG-06, Revision 2.

3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY The objective of this audit is to verify, via an independent evaluation, the Common Q based CPCS and CEACS systems to be used at Waterford 3 to conform to applicable regulations, standards, guidelines, plans, and procedures by assessing the implementation of the systems developmental life cycle processes. A review of activities associated with the establishment of a secure development environment will also be conducted.

The NRC staff will also review the licensees vendor oversight plan (VOP) and other supporting documents, as discussed in Section 4.0 of this audit plan, to determine if additional information will require docketing to develop and support conclusions for the NRC staffs safety evaluation of the requested amendment.

Because this is the NRC staffs initial review of an application using the ARP from ISG-06, Revision 2, the NRC staff may review additional areas within with the scope of the amendment request, as discussed in Section 4.0 of this plan.

4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE AUDIT Because this is the NRC staffs initial review of an application using the ARP from ISG-06, Revision 2, the NRC staff will be requesting information and interviews throughout the review period. Therefore, the NRC staff will use the Open Items list to identify the information to be audited. The Open Items list will be initially shared with the licensee via the NRCs Box portal in support of periodic public meetings to discuss the Open Items list, and the NRC will attach redacted versions of the Open Items to the public meeting summaries. The NRC staff requests the licensee to have the information requested to be audited readily available and accessible for the NRC staffs review via an internet-based portal (e.g., Certrec IMS and Westinghouses SharePoint portal).

The NRC staff will then determine if additional documentation will need to be made available on the portal after reviewing the requested information and will generate new open items to request such information.

5.0 TEAM ASSIGNMENTS AND LOGISTICS The audit team will consist of the following NRC staff from NRR.

Mr. Odunayo Ayegbusi, Probabilistic Risk Assessment (PRA) Licensing Branch B (APLB)

Mr. Samir Darbali, Instrumentation and Controls Branch B (EICB)

Ms. DaBin Ki, Operator Licensing and Human Factors Branch (IOLB)

Ms. Audrey Klett, Plant Licensing Branch 4 (LPL4)

Mr. Richard Stattel, Instrumentation and Controls Branch B (EICB)

Mr. Summer Sun, Nuclear Systems Performance Branch (SNSB)

Mr. Tarico Sweat, Technical Specifications Branch (STSB)

Mr. Shilp Vasavada, PRA Licensing Branch C (APLC)

Mr. Justin Vazquez, Operator Licensing and Human Factors Branch (IOLB)

Ms. Khadijah West, Technical Specifications Branch (STSB)

Ms. Deanna Zhang, Quality Assurance and Vendor Inspection Branch (IQVB)

Mr. Jack Zhao, Instrumentation and Controls Branch A (EICA)

The NRC staff will use the periodic public meetings for the Open Items to discuss the purpose of the audit requests and information needs. The NRC staff will confirm with the licensee the sensitivity of any information discussed or presented on the online portal.

The audit will occur via an internet-based portal at NRC Headquarters Office in Rockville, Maryland, from October 2020, through July 2021. The NRC staff requests the licensee to have the information discussed in Section 4 readily available and accessible for the NRC staffs review via an internet-based portal. The NRC staff requests the licensee to have its staff available at mutually agreeable business daytimes (e.g., Monday - Thursday, 9:00 a.m.

to 4:00 p.m., Eastern Time) by telephone if the NRC staff has any questions during the audit related to any information on the portal. The NRC staff will inform the licensee of any information needed on the docket using the Open Items list and the request for additional information or confirmation of information processes in lieu of using an exit meeting for that purpose. The NRCs licensing project manager will inform the licensee via routine communications when the NRC staff no longer needs access to the portal.

6.0 DELIVERABLES The NRC staff will develop any requests for additional information or confirmation of information, as needed, which it will provide the licensee via separate docketed correspondence. The NRC staff intends to issue one or more audit reports prior to issuance of its decision on the requested license amendment. The audit report(s) will contain the list of reviewed documents reviewed and conducted interview topics.