W3F1-2021-0047, Open Item Response - License Amendment Request to Implement a Digital Upgrade to the Core Protection Calculator (CPC) System and Control Element Assembly Calculator (Ceac) System

Open Item Response - License Amendment Request to Implement a Digital Upgrade to the Core Protection Calculator (CPC) System and Control Element Assembly Calculator (Ceac) System

ML21172A299
Person / Time
Site:	Waterford
Issue date:	06/21/2021
From:	Gaston R Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML21172A298	List: W3F1-2021-0047, Open Item Response - License Amendment Request to Implement a Digital Upgrade to the Core Protection Calculator (CPC) System and Control Element Assembly Calculator (Ceac) System
References
W3F1-2021-0047
Download: ML21172A299 (11)

Text

Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 The balance of this letter may be considered non-proprietary upon removal of Enclosures 1 and 2.

Entergy Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5138 Ron Gaston Director, Nuclear Licensing 10 CFR 50.90 W3F1-2021-0047 June 21, 2021 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Open Item Response - License Amendment Request to Implement a Digital Upgrade to the Core Protection Calculator (CPC) System and Control Element Assembly Calculator (CEAC) System Waterford Steam Electric Station, Unit 3 NRC Docket No. 50-382 Renewed Facility Operating License No. NPF-38

References:

1) Entergy Operations, Inc. letter to U.S. Nuclear Regulatory Commission (NRC), "License Amendment Request to Implement a Digital Upgrade to the Core Protection Calculator (CPC) system and Control Element Assembly Calculator (CEAC) system," dated July 23, 2020, (ADAMS Accession No. ML20205L587)

2) NRC Meeting Summary, "Summary Of September 22, 2020, Category 1 Public Meeting With Entergy Operations, Inc. Regarding License Amendment Request To Install Digital Upgrade In Accordance With Digital Instrumentation And Control Interim Staff Guidance No. 06, Revision 2,

'Licensing Processes' (EPID L-2020-LLA-0164)," dated October 22, 2020, (ML20288A742)

In Reference 1, Entergy Operations, Inc. (Entergy) submitted a proposed amendment to Appendix A, "Technical Specifications" (TS) of Renewed Facility Operating License No. NPF-38 for Waterford Steam Electric Station, Unit 3 (Waterford). The proposed change would revise the Waterford TS in order to implement a planned digital instrumentation and control (DI&C) modification at Waterford. The DI&C modification will replace the existing digital minicomputers of the Core Protection Calculator (CPC) system and Control Element Assembly Calculator (CEAC) system with the more reliable, digital system based on the Westinghouse Electric Company (Westinghouse) Common Qualified (Common Q) Platform.

W3F1-2021-0047 Page 2 of 3 On September 22, 2020, the NRC conducted a virtual Category 1 public meeting with representatives from Entergy and Westinghouse Electric Company, LLC. (Westinghouse). The purpose of the meeting was to discuss Entergys license amendment request (Reference 1).

The results of that meeting are summarized in Reference 2.

During the meeting, the NRC discussed a proposed process for dispositioning open items (OIs).

The OIs are NRC questions regarding the LAR which the NRC would track and eventually disposition as requests for additional information, requests for confirmation of information, audits, or as needing no additional action. The OI list is an informal tool for increasing the efficiency of the NRC review, as well as promoting communication with Entergy. Enclosure 5 of the Reference 2 meeting summary provided a non-proprietary version of preliminary OIs.

Enclosures 1 and 2 to this letter provide additional design documents concerning one of the OIs (i.e., OI No. 24).

Enclosures 1 and 2 contain information proprietary to Westinghouse and are supported by an Affidavit signed by Westinghouse, the owner of the information. The Affidavit is provided as , and sets forth the basis on which the information may be withheld from public disclosure by the NRC and addresses, with specificity, the considerations listed in paragraph (b)(4) of Section 2.390 of the Commissions regulations. Accordingly, Entergy respectfully requests that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commissions regulations.

Correspondence with respect to the copyright or proprietary aspects of Enclosures 1 and 2, or the supporting Westinghouse Affidavits should reference CAW-20-5174 and CAW-20-5153 and should be addressed to Zachary S. Harper, Manager, Licensing Engineering, Westinghouse Electric Company, 1000 Westinghouse Drive, Suite 165, Cranberry Township, Pennsylvania 16066.:

Enclosure 1 provides Westinghouse Specification CN-EQT-20-2, Revision 4, Qualification Evaluation of Core Protection Calculator System Equipment for Waterford Unit 3 Auxiliary Protection Cabinet. This attachment contains information proprietary to Westinghouse and is supported by an Affidavit signed by Westinghouse, the owner of the information.

Enclosure 2 provides Westinghouse Specification CN-EQT-20-5, Revision 2, Qualification Evaluation of Core Protection Calculator System Equipment for Waterford Unit 3 Main Control Room. This attachment contains information proprietary to Westinghouse and is supported by an Affidavit signed by Westinghouse, the owner of the information.

Enclosure 3 provides Westinghouse Affidavit CAW-20-5174 in support of Enclosure 1.

The Affidavit sets forth the basis on which the information may be withheld from public disclosure by the NRC and addresses, with specificity, the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.

Enclosure 4 provides Westinghouse Affidavit CAW-20-5153 in support of Enclosure 2.

The Affidavit also requests proprietary portions of a CN-EQT-20-2 revision 3 to be withheld from public discourse under 10 CFR 2.390. CN-EQT-20-2 revision 3 is not being submitted as it has been superseded by Enclosure 1. The Affidavit sets forth the basis on which the information may be withheld from public disclosure by the NRC and

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Enclosure 3 W3F1-2021-0047 Westinghouse Affidavit CAW-20-5174, Proprietary Information Notice, and Copyright in support of CN-EQT-20-2, Revision 4, (Enclosure 1)

(3 Pages)

Westinghouse Non-Proprietary Class 3 CAW-21-5174 Page 1 of 3 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 CN-EQT-20-2, Revision 4 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) The information sought to be withheld is being transmitted to the Commission in confidence and, to Westinghouses knowledge, is not available in public sources.

(iii) Westinghouse notes that a showing of substantial harm is no longer an applicable criterion for analyzing whether a document should be withheld from public disclosure. Nevertheless, 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

• • • This record was final approved on 4/12/2021 2:19:25 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 CAW-21-5174 Page 2 of 3 others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

(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.

• • • This record was final approved on 4/12/2021 2:19:25 PM. (This statement was added by the PRIME system upon its validation)

• • • This record was final approved on 4/12/2021 2:19:25 PM. (This statement was added by the PRIME system upon its validation)

Enclosure 4 W3F1-2021-0047 Westinghouse Affidavit CAW-20-5153, Proprietary Information Notice, and Copyright in support of CN-EQT-20-5, Revision 2, (Enclosure 2)

(3 Pages)

Westinghouse Non-Proprietary Class 3 CAW-21-5153 Page 1 of 3 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 CN-EQT-20-2, Revision 3 and CN-EQT-20-5, Revision 2 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) The information sought to be withheld is being transmitted to the Commission in confidence and, to Westinghouses knowledge, is not available in public sources.

(iii) Westinghouse notes that a showing of substantial harm is no longer an applicable criterion for analyzing whether a document should be withheld from public disclosure. Nevertheless, 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

• • • This record was final approved on 2/19/2021 9:57:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 CAW-21-5153 Page 2 of 3 others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

(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.

• • • This record was final approved on 2/19/2021 9:57:48 AM. (This statement was added by the PRIME system upon its validation)

• • • This record was final approved on 2/19/2021 9:57:48 AM. (This statement was added by the PRIME system upon its validation)