Text

Transmittal of Slides for Fourth Partially Closed Pre-submittal Meeting with Entergy Operations, Inc. to Discuss a Planned License Amendment Request for Digital Instrumentation and Control Modification
	ML20072P204
Person / Time
Site:	Waterford
Issue date:	03/12/2020
From:	Wood P; Entergy Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML20072P200	List: W3F1-2020-0017, Transmittal of Slides for Fourth Partially Closed Pre-submittal Meeting with Entergy Operations, Inc. to Discuss a Planned License Amendment Request for Digital Instrumentation and Control Modification;
References
	EPID L-2020-LRM-0016, W3F1-2020-0017
	Download: ML20072P204 (51)
	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 W3F1-2020-0017 March 12, 2020 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Transmittal of Slides for Fourth 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-2020-LRM-0016)

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

Reference:

Meeting Notice, "Fourth 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-2020-LRM-0016)," (ADAMS Accession No. ML20059N287), dated February 28, 2020 A partially closed meeting between Entergy Operations, Inc. (Entergy) and the U.S. Nuclear Regulatory Commission (NRC) staff is scheduled for March 19, 2020. The purpose of this meeting is to discuss a planned license amendment request (LAR) regarding the effect of a digital modification to the core protection calculator and control element assembly calculator at Waterford Steam Electric Station, Unit 3. Entergy will discuss the effect of the planned modification on the plant's Technical Specifications, Failure Mode and Effects Analysis, and Vendor Oversight Program.

Attached to this letter are:

Presubmittal Meeting Slides, "Waterford Unit 3 CPC/CEAC Replacement License Amendment Request NRC Pre-submittal Meeting #3" [Westinghouse document WAAP-11715-NP (Non-Proprietary)] (Attachment 1).

W3F1-2020-0017 Page 2 of 3 Westinghouse Letter CAW-20-5015, 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 #3" [Westinghouse document WAAP-11715-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-20-5015 and should be addressed to Zachary S. Harper, Manager, Licensing Engineering, 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

W3F1-2020-0017 Page 3 of 3 Attachments: 1. Waterford Unit 3 CPC/CEAC Replacement License Amendment Request NRC Pre-submittal Meeting #3 [Westinghouse document WAAP-11715-NP (Non-Proprietary)]

2. Westinghouse Letter CAW-20-5015

3. Waterford Unit 3 CPC/CEAC Replacement License Amendment Request NRC Pre-submittal Meeting #3 [Westinghouse document WAAP-11715-P (Proprietary)]

cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector - Waterford 3 NRC Project Manager - Waterford 3

Attachment 1 W3F1-2020-0017 Waterford Unit 3 CPC/CEAC Replacement License Amendment Request NRC Pre-submittal Meeting #3

[Westinghouse document WAAP-11715-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 #3 March 19, 2020 WAAP-11715-NP

John Schrage, Senior Staff Engineer - Corporate Licensing

Loren Miller, Project Manager, CPC Replacement Project

David Constance, Assistant Operations Manager - Support

Alan Harris, Site Regulatory Assurance

Pareez Golub, Major Fleet Projects - Engineering Westinghouse

Warren Odess-Gillett, Licensing Lead

Steven Merkiel, Senior Engineer 2

WAAP-11715-NP

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

Solicit Staff feedback prior to LAR submittal to facilitate a more efficient NRC review 3

WAAP-11715-NP

Project Milestones

Acronym List Closed Portion

Technical Specification Changes

FMEA & FMEDA Discussion

VOP Update

Miscellaneous Topics

Test Procedure Plan 4

WAAP-11715-NP

Draft LAR Submitted 6/2020

NRC Pre-submittal Meeting 6/2020

LAR Submittal 7/2020 *

Request NRC approval 7/2021 *

System Installation (RF 24) 4/2022

Discuss Expectations, Timing and Impact of 6/2020 Submittal of Draft LAR 6

WAAP-11715-NP

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 WAAP-11715-NP

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 WAAP-11715-NP

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 WAAP-11715-NP

Westinghouse Non-Proprietary Class 3 © 2020 Westinghouse Electric Company LLC. All Rights Reserved CPC/CEAC System Overview Westinghouse Proprietary Class 2 3-7 a,c Figure 3.2-1 Common Q CPC/CEAC Architecture Block Diagram46 WCAP-18484-P February 2020 Revision B

- - This record was final approved on 2/21/2020 8:39:14 AM. (This statement was added by the PRIME system upon its validation) 13 WAAP-11715-NP

Westinghouse Non-Proprietary Class 3 © 2020 Westinghouse Electric Company LLC. All Rights Reserved Technical Specification Changes Waterford 3 will use the Palo Verde TSs as benchmark, noting the below differences:

PV - NUREG 1432 Improved Standard Tech Specs WF3 - Custom Tech Specs

PV - dedicated CEAC TS 3.3.3 WF3 - CEACs included in TS 3.3.1 with CPCs

WF3 utilizing operational flexibility allowed by 8 CEAC design configuration 14 WAAP-11715-NP

Westinghouse Non-Proprietary Class 3 © 2020 Westinghouse Electric Company LLC. All Rights Reserved Technical Specification Changes (Refer to handout of TS markups) 2.2.1 Reactor Trip Setpoints Table 2.2-1 "Reactor Protective Instrumentation Trip Setpoint Limits"

- Combined CPC, CEAC, LPD, DNBR under single Functional Unit 9 3.1.3.1 CEA Position SR 4.1.3.1.1 CEA Position Verification

- Revised wording to align with 8 CEAC configuration 3.2.4 DNBR Margin Reformatted LCO wording similar to Palo Verde

- Separated conditions into COLSS in Service and COLSS Out of Service

- Action statements unchanged from current WF3 TS 15 WAAP-11715-NP

Westinghouse Non-Proprietary Class 3 © 2020 Westinghouse Electric Company LLC. All Rights Reserved Technical Specification Changes (Refer to handout of TS markups) 3.3.1 Reactor Protective Instrumentation SR 4.3.1.2 Reactor Trip Response Time

- added CPC and CEAC to exemptions from Response Time Testing SR 4.3.1.4 Isolation Amp and Optical Isolator checks

- Deleted entire SR SR 4.3.1.5 Auto Restart count verification

- Deleted entire SR SR 4.3.1.6 Cabinet High Temperature Alarm

- Deleted entire SR SR 4.3.1.7 CPC Output Trip Test

- New SR to perform manual trip test 16 WAAP-11715-NP

Westinghouse Non-Proprietary Class 3 © 2020 Westinghouse Electric Company LLC. All Rights Reserved Technical Specification Changes (Refer to handout of TS markups) 3.3.1 Reactor Protective Instrumentation Table 3.3-1 "Reactor Protective Instrumentation"

- Combined CPC, CEAC, LPD, DNBR under single Functional Unit 9

- Revised values under Total No. of Channels, Channels to Trip, and Minimum Channels OPERABLE to align with 8 CEAC configuration

- Added Notes (g), (h) and (i) addressing CEAC & CPC operability

- Revised entry criteria for Action 6 depending on number of CEACs Inoperable.

NOTE: Actions taken are unchanged, based on impact on CPCs.

- Deleted Action 7 addressing Auto Restarts 17 WAAP-11715-NP

Westinghouse Non-Proprietary Class 3 © 2020 Westinghouse Electric Company LLC. All Rights Reserved Technical Specification Changes (Refer to handout of TS markups) 3.3.1 Reactor Protective Instrumentation Table 4.3-1 "Reactor Protective Instrumentation Surveillance Requirements"

- Combined CPC, CEAC, LPD, DNBR under single Functional Unit

- Replaced all Channel Functional Test requirements for CPCS (Functional Unit 9) with "NONE"

- Deleted Note (6) describing refuel interval trip test requirement

- Deleted Note (9) for verification of addressable constant values 6.8.1 Procedures and Programs

- Note (2) updated with Common Q Software Program Manual information 18 WAAP-11715-NP

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

TS SR 4.3.1.4 (Isolation Amplifier)

TS SR 4.3.1.5 (CPC/CEAC Operability)

TS SR 4.3.1.6 (High Temperature Alarm)

TS Table 4.3-1 (CPC Functional Testing) 19 WAAP-11715-NP

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

CPCS Response Time Testing

CPCS Functional Testing

Refer to draft CPCS TS markups 20 WAAP-11715-NP

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

SR 4.3.1.3 (CPCS portion of the RTT SR)

SR 4.3.1.4 - Isolation amplifiers and opto-isolators no longer part of the CPCS design, so this SR is no longer needed.

SR 4.3.1.5 - This SR was in reference to the legacy CPCS auto-restart feature that does not exist in the Common Q CPCS (the processor module halts). As a result, this SR is no longer required to ensure operability of the CPCS based on self-diagnostics being credited to confirm operability of the system.

SR 4.3.1.6 - This SR is no longer required to ensure operability of the CPCS after receipt of a high-cabinet temperature alarm based on design margins and self-diagnostics being credited to confirm operability of the system.

23 WAAP-11715-NP

FMEAs are used to reveal potential single points of vulnerability within a system design.

The Waterford 3 CPCS FMEA will be included with LAR submittal.

Based on Reference Design CPCS FMEA

Modified by changes outlined in the Waterford 3 CPCS System a,c Requirements Specification (SyRS) 26 WAAP-11715-NP

FMEDA tables within Section B.6 of the LTR are used to show self-diagnostic coverage for CPCS-related failure modes (based on the specific WF3 CPCS architecture).

The self-diagnostics are either implemented in the platform or the application Software, and are defined within Section B.5 of the LTR.

a,c 27 WAAP-11715-NP

Regression Analysis for the CPC Reference Design (March 9-13, 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 29 WAAP-11715-NP

VOP describes the auditing of the WF3 design process in accordance with the following plans from the NRC-approved Westinghouse Software Program Manual (SPM):

Software Safety Plan

Software Quality Assurance Plan (SQAP)

Software Verification and Validation Plan*

Software Configuration Management Plan*

Software Test Plan*

Secure Development and Operational Environment Plan

There is also a WF3 specific plan 30 WAAP-11715-NP

VOP provides acceptance criteria for the following software lifecycle development topics - criteria is based, in part, on NRC input to industry (ML19087A230):

Quality Assurance

Configuration Management

Software Verification and Validation (V&V)

Software Safety

Secure Development Environment

Software Lifecycle Processes (Requirements, Design, Implementation, Integration, and Test) 31 WAAP-11715-NP

for information only - with the LAR as part of the LTR.

33 WAAP-11715-NP

Entergy will submit an EQ Summary Report that will document that the generic Common Q platform type tests meet the WF3 site requirements

The next slide lists the components included in the EQSR

This list is included in the Licensing Technical Report attached to the LAR, Section 4 Hardware Equipment Qualification (D.3)

Further equipment qualification testing and/or analysis required after detailed design phase due to obsolescence, e.g.:

HSL modems

Power supply assembly

Interposing relays 34 WAAP-11715-NP

Operators Module /Maintenance and Test Panel (MTP)

PC Node Box (Additional analysis and/or testing may be required based on final mounting design)

MTP Keyboard

AC160 Racks

Seismic Stiffening Kit with Fan (Additional analysis and/or testing may be required based on final mounting design)

AC160 Modules

PM646A

DP620

CI631

DI620

AI688

AO650

DO625 35 WAAP-11715-NP

The Licensing Technical Report will be attached to the LAR and will reference:

WCAP-16097-P-A, Common Qualified Platform Topical Report, Revision 4, (the latest NRC-approved Common Q Topical Report version)

WCAP-16096-P-A, Software Program Manual for Common QTM Systems, Revision 5 36 WAAP-11715-NP

ISG-06 defines living documents as documents associated with software development [that] will be revised as system development activities progress

Reviewing the required submittals from ISG-06 Enclosure B for the AR process (see next slide), Entergy does not anticipate nor has scheduled revisions to these submittals, with one exception:

System Requirements Specification (SyRS) (inferred by item 1.5 in the next slide) 37 WAAP-11715-NP

SyRS: At present only one revision is planned after the Licensing Technical Report is issued March 2020:

This revision is planned for May/June 2020

Incorporate editorial/clarification comments captured as the design phase commences

Would be available for NRC staff audit

In addition, the NRC staff requested that the FMEA be submitted to support the elimination of certain surveillances.

The FMEA is considered a living document that is reviewed after each life cycle phase for possible updating.

39 WAAP-11715-NP

System Level Integration

One Channel System Test

Procedure: April 2021

Report: July/August 2021

Factory Acceptance Test (FAT)

Four Channel FAT

Procedure: June 2021

Report: August 2021

Site Acceptance Test (SAT)

Performance November 2021 41 WAAP-11715-NP

42 WAAP-11715-NP

Attachment 2 W3F1-2020-0017 Westinghouse Letter CAW-20-5015 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-20-5015 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-11715-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.

Westinghouse Non-Proprietary Class 3 CAW-20-5015 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

Westinghouse Non-Proprietary Class 3 CAW-20-5015 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: $hzlzo-z r, D S. Harper, Manager Licensing Engineering

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.

v t e Letter Sequence Meeting
EPID:L-2020-LRM-0016, Response to Regulatory Issue Summary 2020-01, Preparation and Scheduling of Operator Licensing Examinations (Open)
Initiation Request Acceptance... Administration Withholding Request Acceptance Meeting, Meeting, Meeting Questions Answers Results Approval... Other:
MONTHYEAR2020-03-19 [Table View]

W3F1-2020-0017, Transmittal of Slides for Fourth Partially Closed Pre-submittal Meeting with Entergy Operations, Inc. to Discuss a Planned License Amendment Request for Digital Instrumentation and Control Modification

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