View source for 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

{{Adams
| number = ML20008F008
| issue date = 01/08/2020
| title = 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
| author name = Wood P
| author affiliation = Entergy Operations, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000382
| license number = NPF-038
| contact person = 
| case reference number = EPID L-2019-LRM-0093, W3F1-2020-0002
| package number = ML20008F006
| document type = Legal-Affidavit, Letter type:W, Slides and Viewgraphs
| page count = 75
| project = EPID:L-2019-LRM-0093
| stage = Meeting
}}

=Text=
{{#Wiki_filter: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 W3F1-2020-0002 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

Attachment 1 W3F1-2020-0002 Waterford Unit 3 CPC/CEAC Replacement License Amendment Request NRC Pre-submittal Meeting #2
[Westinghouse document WAAP-11643-NP (Non-Proprietary)]

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Waterford Unit 3 CPC/CEAC Replacement License Amendment Request NRC Pre-submittal Meeting #2 January 16, 2020 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved 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
WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Participants Westinghouse
* Warren Odess-Gillett, Licensing Lead
* Steven Merkiel, Senior Engineer
* Allen Denyer, Project Technical Advisor
* Eric Fredrickson, Project Manager 3
WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved 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
WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Agenda - Open Portion
* Project milestones
* CPC/CEAC Existing and New System Overview
* Westinghouse Licensing Technical Report (LTR)
Table of Contents (TOC)
* Acronym List 5
WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved 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
WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Pre-submittal Meeting -
Open Portion 7
WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved 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
WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved CPCS/CEAC System Description System Overview Functional Architecture Main Control Room Overview 9
WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved 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 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved 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 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved 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 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved 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 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Main Control Room Overview 14 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved MCR CP-7 Channel B 15 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Digital Upgrade Project Description Overview Functional Architecture 16 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved 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 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved 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 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Licensing Technical Report (LTR) TOC
: 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) 19 WAAP-11643-NP
                        *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Licensing Technical Report (LTR) TOC
: 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 20 WAAP-11643-NP
                        *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 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 21 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 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 22 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 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 23 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Pre-submittal Meeting -
Closed Portion 24 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Technical Specifications Impacts 25 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved 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 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved 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 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Technical Specification Impact 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) 28 WAAP-11643-NP
                        *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Technical Specification Impact a,c 29 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Technical Specification Impact a,c 30 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Technical Specification Impact a,c 31 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved September 19, 2019 Pre-submittal Meeting Follow-up 32 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved 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 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved 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 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved 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 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved 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 WAAP-11643-NP
                        *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved IEEE Std. 603, Clause 5.6, Independence a,c 37 WAAP-11643-NP
                        *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved 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 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Common Q Topical Report PSAIs (cont.)
a,c 39 WAAP-11643-NP
                        *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Common Q Topical Report PSAIs (cont.)
The DI&C-ISG-06, Revision 2, Section D.5.1.2, Resolution of Topical Report Plant-Specific Action Items states:
Based on a topical report review in accordance with SRP BTP 7-14, some topical reports include plant-specific items stating that the NRC staff should review detailed design, implementation, testing, and ongoing life cycle activities. For the Alternate Review Process, the licensee will provide oversight of the performance of these activities, in accordance with the licensees QA program and Vendor Oversight Plan.
40 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Common Q Topical Report PSAIs (cont.)
a,c 41 WAAP-11643-NP
                        *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Common Q Topical Report PSAIs (cont.)
a,c 42 WAAP-11643-NP
                        *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Common Q Topical Report PSAIs (cont.)
a,c 43 WAAP-11643-NP
                        *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Common Q SPM PSAIs a,c 44 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Proposed LAR commitments Per ISG-06 Section C.2.2.3, LAR to include regulatory commitments for:
* Referenced topical reports plant-specific action items
* Completion of life cycle activities after LAR submittal o Under Tier 1, 2, 3 these would be complete prior to LAR review completion o LAR will include regulatory commitments for life cycle activities listed as DI&C-ISG-06, Enclosure B, Tier 1 items to be completed post-LAR submittal 45 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Proposed LAR commitments
* Entergy will evaluate WF3 CPCS Replacement Project Site Acceptance Test (SAT) and Installation Test Plans using the software process testing characteristics described in BTP 7-14 Section B.3.2.4. This is Plant-specific Action Item #6 per WCAP-16097, Common Qualified Platform Topical Report.
* Entergy will complete the following document in accordance with Entergys Quality Assurance program:
o Westinghouse Technical Manual (Enclosure B Item 2.2, As-Manufactured, System Configuration Documentation)
* Entergy will complete the following activity in accordance with Entergys Quality Assurance program and WCAP-16096, Software Program Manual for Common Q' Systems, Rev. 5:
o Factory Acceptance Test (Enclosure B Items 2.3 and 2.4, Summary Test Reports and System Response Time Confirmation Report)
* Entergy will complete the following activity in accordance with Entergys Quality Assurance program and WCAP-16097, Common Qualified Platform Topical Report:
o Equipment qualification of CPCS equipment determined upon completion of detailed design (Enclosure B Item 2.7, Qualification Test Methodologies) 46 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Proposed LAR commitments a,c 47 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Vendor Oversight Update Planned Audits (dates are tentative):
* Regression Analysis for the CPC Reference Design (Feb 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 48 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved LAR Content for DI&C-ISG-06 Sections of Interest 49 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Licensing Technical Report (LTR) TOC a,c 50 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Licensing Technical Report (LTR) TOC a,c 51 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved DI&C-ISG-06 Section D.4 a,c 52 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved DI&C-ISG-06 Section D.4 a,c 53 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved DI&C-ISG-06 Section D.4 a,c 54 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved DI&C-ISG-06 Section D.4 a,c 55 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved DI&C-ISG-06 Section D.5 a,c 56 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved DI&C-ISG-06 Section D.6 a,c 57 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved DI&C-ISG-06 Section D.8 a,c 58 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Human Factors Considerations 59 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Human Factors Considerations
* In accordance with DI&C-ISG-06 and IEEE 603-1991 clause 5.14, human factors is being considered at each stage throughout the design to ensure safety functions can be successfully accomplished.
* Waterford 3 CPC Project HFE Considerations:
o No existing automatic actions become manual actions with the new system o No change to existing staff levels o Minimal procedural changes expected (Operations team member involved in identifying impacts and reviewing) o Project team is multi-disciplinary (e.g., Engineering, Operations, Maintenance) to ensure HFE is considered at each level 60 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Human Factors Considerations
* Human factors considerations from the NRC-approved Palo Verde CPCS implementation are being used in addition to the 15 years of Palo Verde operating experience.
* WNA-IG-00871-GEN, Human Factors Engineering Guideline for the Common Q Display System is being used to ensure Common Q Display software complies with applicable human factor design principles.
* Palo Verde October 2019 refueling outage benchmark -
Maintenance personnel
* Factory Acceptance Test and Site Acceptance Test will be developed to ensure all conditions are tested and human-error mechanisms are considered 61 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Human Factors Considerations
* WF3 Training organization involved in Engineering Change package development and review
* Entergy design process and procedures include identifying the applicable design inputs. Key HFE design inputs include:
o      Design functions and performance requirements o      Layout/arrangement requirements o      Operational requirements o      Accessibility/maintenance/repair requirements, and o      Interface requirements between equipment and operations/maintenance personnel.
62 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved MCR Photos                                                                                                                                                                a,c 63 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Human Factors - Conceptual OM screen a,c 64 WAAP-11643-NP
                        *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Human Factors - Conceptual OM screen a,c 65 WAAP-11643-NP
                        *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3                                                                          &#xa9; 2020 Westinghouse Electric Company LLC. All Rights Reserved Questions?
66 WAAP-11643-NP
                       *** This record was final approved on 1/8/2020 11:47:48 AM. (This statement was added by the PRIME system upon its validation)

Attachment 2 W3F1-2020-0002 Westinghouse Letter CAW-20-4988 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-20-4988 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-11643-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.
 *** This record was final approved on 1/8/2020 1:36:18 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 CAW-20-4988 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
  *** This record was final approved on 1/8/2020 1:36:18 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 CAW-20-4988 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:
Zaclfary S. Harper, Manager Licensing Engineering
  *** This record was final approved on 1/8/2020 1:36:18 PM. (This statement was added by the PRIME system upon its validation)

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.
  *** This record was final approved on 1/8/2020 1:36:18 PM. (This statement was added by the PRIME system upon its validation)}}