ML21075A032

Summary of Redacted - Category 1 Public Meeting with Entergy Operations, Inc. Regarding LAR to Install Digital Upgrade in Accordance with Digital I&C ISG No. 06, Revision 2, Licensing Processes

ML21075A032
Person / Time
Site:	Waterford
Issue date:	04/02/2021
From:	Perry Buckberg, Audrey Klett Plant Licensing Branch IV
To:	Entergy Operations
Klett A
References
EPID L-2020-LLA-0164
Download: ML21075A032 (40)

Text

OFFICIAL USE ONLY - PROPRIETARY INFORMATION April 2, 2021 LICENSEE: Entergy Operations, Inc.

FACILITY: Waterford Steam Electric Station, Unit 3

SUMMARY

OF MARCH 3, 2021, 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)

On March 3, 2021, the U.S. Nuclear Regulatory Commission (NRC) staff held a virtual Category 1 public meeting with representatives from Entergy Operations, Inc. (the licensee) and its contract support staff. The purpose of the meeting was to discuss the licensees amendment request dated July 23, 2020, as supplemented by letters dated January 22 and 29, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML20205L588, ML21024A005, and ML21029A156, respectively), for the Waterford Steam Electric Station, Unit 3, regarding a replacement to an existing digital core protection calculator system (CPCS). The upgrade, if approved, would replace the existing CPCS with a Common Q-based system. The meeting notice and agenda, dated December 22, 2020, are available in ADAMS under Accession No. ML21036A265. A list of attendees is provided in .

During the meeting, the NRC staff discussed its open items list, which is a list of NRC staff questions and informal licensee responses regarding the license amendment request for the NRC staff to track and eventually disposition as requests for additional information, requests for confirmation of information, audits, or as needing no additional action. The proprietary version of the open items list, which is being withheld from public disclosure, is in Enclosure 2.

A redacted copy of the open items list is in Enclosure 3.

During the public portion of the meeting, the NRC staff and licensee discussed Open Item Nos. 35 and 38. As a result of the meeting discussions, the NRC revised Open Item No. 35.8.

The NRC staff also discussed which open items it was closing, and information needs for those that are remaining open.

Enclosure 2 to this letter contains proprietary information. When separated from Enclosure 2, this document is DECONTROLLED.

OFFICIAL USE ONLY - PROPRIETARY INFORMATION

OFFICIAL USE ONLY - PROPRIETARY INFORMATION During the closed portion of the meeting, the NRC staff discussed proprietary information related to Open Item Nos. 2 and 3. The NRC staff also discussed its plans to increase the scope of its licensing audit to include the licensees vendor oversight plan implementation of the requirements phase.

The NRC staff has determined that the open items list contains proprietary information pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 2.390, Public inspections, exemptions, requests for withholding. The proprietary information is indicated by bold text enclosed within ((double brackets)). The proprietary version of the open items list is provided as Enclosure 2. Accordingly, the NRC staff has also prepared a nonproprietary version of the open items list which is provided as Enclosure 3.

The NRC staff did not make any regulatory decisions or commitments at the meeting. A member of the public was in attendance. Public Meeting Feedback Forms were not received.

Please direct any inquiries to me at 301-415-1383 or by e-mail to Perry.Buckberg@nrc.gov.

/RA Audrey L. Klett/

Perry H. Buckberg, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382

Enclosures:

1. List of Attendees

2. Open Items List (Proprietary)

3. Open Items List (Non-proprietary) cc w/o Enclosure 2: Listserv OFFICIAL USE ONLY - PROPRIETARY INFORMATION

Enclosure 1 List of Attendees

LIST OF ATTENDEES MARCH 3, 2021, VIRTUAL PUBLIC MEETING WITH ENTERGY OPERATIONS, INC., ET AL.

WATERFORD STEAM ELECTRIC STATION, UNIT 3, LICENSE AMENDMENT REQUEST TO INSTALL DIGITAL UPGRADE U.S. Nuclear Regulatory Commission Entergy Operations, Inc.

Odunayo Ayegbusi, NRR1/DRA2/APLB3 Jacob Champagne Samir Darbali, NRR/DEX4/ELTB5 Phil Couture John Dixon, RIV6/DRP7 Remy DeVoe Jennifer Dixon-Herrity, NRR/DORL8/LPL49 Loren Miller Greg Galletti, NRR/DRO10/IQVB11 Dave Moody DaBin Ki, NRR/DRO/IOLB12 Roger Rucker Audrey Klett, NRR/DORL/LPL4 John Schrage Shiattin Makor, RIV/DRS13 Christopher Talazac Mike Marshall, NRR/DORL/LPL114 William Truss Phil McKenna, NRR/DORL Wendell Morton, NRR/DEX/ELTB Jensen Hughes, Inc.

Richard Stattel, NRR/DEX/EICB15 Alan Harris Summer Sun, NRR/DSS16/SNSB17 Tarico Sweat, NRR/DSS/STSB18 Sargent and Lundy Nick Taylor, RIV/DRS Pareez Golub Dan Warner, NSIR19/DPCP20/CSB21 Mike Waters, NRR/DEX/EICB Westinghouse Electric Company, LLC Tom Wengert, NRR/DORL/LPL4 Alan Denyer Deanna Zhang, NRR/DRO/IQVB Kim Jones Jack Zhao, NRR/DEX/EICB Warren Odess-Gillett John Wiesemann Members of the Public Robert Armistead, Naval Nuclear Laboratory 1

Office of Nuclear Reactor Regulation 2 Division of Risk Assessment 3

Probabilistic Risk Assessment Licensing Branch B 4 Division of Engineering and External Hazards 5 Long Term Operations and Modernization Branch 6 Region IV 7 Division of Reactor Projects 8 Division of Operating Reactor Licensing (DORL) 9 Plant Licensing Branch IV 10 Division of Reactor Oversight 11 Quality Assurance and Vendor Inspection Branch 12 Operator Licensing and Human Factors Branch 13 Division of Reactor Safety 14 Plant Licensing Branch I 15 Instrumentation and Controls Branch 16 Division of Safety Systems 17 Nuclear Systems Performance Branch 18 Technical Specifications Branch 19 Office of Nuclear Security and Incident Response 20 Division of Physical and Cyber Security Policy 21 Cyber Security Branch

Enclosure 3 (Non-proprietary)

Open Items List Proprietary information pursuant to Section 2.390 of title 10 of the Code of Federal Regulations has been redacted from this document.

Redacted information is identified by blank space enclosed within ((double brackets)).

OFFICIAL USE ONLY PROPRIETARY INFORMATION 1.

Topic & LAR/LTR LAR/ LTR Audit, RAI or IMS ID NRC Comment / Open Item Description Licensee Response Status (Reviewer) Section Page RCI No.

Acronyms and abbreviations are defined on the last page of this document.

Certrec IMS Request ID Format (second column of this table)

Updated by Entergy on 10/19/20 A- Audit (Generic/Multiple Documents)

CCF-Common Cause Failure/D3 Proprietary Documents will be uploaded to the Westinghouse EQ- Equipment Qualification Sharepoint site at the below address HFE - Human Factors Engineering

((

PSAI- Plant Specific Action Items

- - - - - RC- Regulatory Commitments - -

RT- Response Time SA- System Architecture SDOE- Secure Development and Operational Environment ST- Surveillance Testing/Self-Diagnostics/SR Elimination SDP- System Development Processes, including SPM PSAIs TS- Technical Specifications ))

VOP- Vendor Oversight Plan 1 ST-01 Self-Tests B.2.5 B-5 The BTP 7-17 Evaluation conclusion states that It is not possible to test self- (Entergy 11/3/20 Update) Closed This is a diagnostics (V) proposed (Jack Zhao, as part of surveillance testing because it would require creating destructive The LAR Enclosure Section 2.3, Reason for the Proposed Changes, will change to the Richard Stattel, faults within the I&C system, such as Random-Access Memory (RAM) errors. be revised as follows: LAR enclosure Samir Darbali) and not to the Though this is a quote out of the Vogtle LAR safety evaluation, it is a Crediting Self-Diagnostics for TS Surveillance Requirement Elimination WCAP.

statement made by the licensee and not the NRC to address this criterion in The Common Q design also provides additional reliability and BTP 7-17, self-test functions should be verified during periodic functional operational margin via the self-diagnostics. These self-diagnostics are Therefore I am tests. The interpretation being made that the BTP criterion calls for complete continually monitoring the health of the hardware and software. unable to verify functional testing of the self-diagnostic functions is incorrect. Instead, the BTP Appendix B to the Licensing Technical Report (LTR) (Attachment 4) and changes as of states that the licensee should confirm the execution of self-diagnostic tests the Waterford System Engineer and Operations Actions Supporting TS 2/25/2021.

during plant operation and the NRC staff believes that it is possible to do so SR Reduction (LAR Enclosure Section 3.4) provides the justification to by implementing the following necessary plant monitoring activities as already remove selected SRs.

included in the Enclosure for this LAR.

Note: "and the Waterford System Engineer and Operations Actions The licensee (Waterford) has addressed this in the LAR as follows: Supporting TS SR Reduction (LAR Section 3.4) provides the ustification to remove selected SRs is new inserted text.

Post installation, CPCS operability will be verified using 1) the automated diagnostics credited in this LAR (i.e., as described in LTR Appendix B), 2) The LAR Enclosure Section 2.4, Description of the Proposed TS Technical Requirements Manual (TRM) 3/4.3.1, "Reactor Protective Changes, for TS 3.3.1/Table 4.3-1, will be revised as follows:

Instrumentation" and associated surveillance procedures; and 3) Waterford TS 6.5.1.8, "Surveillance Frequency Control Program (SFCP). A failure of For row TS 3.3.1/Table 4.3-1, the sentence "LTR Appendix B provides credited automated diagnostics to detect a fault will be either detected by the detailed justification that demonstrates that the self-diagnostics other diagnostics in the system or by checker(s) of diagnostics. This condition meet the requirements of 10 CFR 50.36 for the CPCS..."

will be alarmed and displayed on the main control room (MCR) operator modules (OM) and/or the main control room annunciators. Upon receipt of an with alarm or abnormal conditions, the station operating procedures will require the operators to perform system checks and verify operability of the CPCS "LTR Appendix B along with the Waterford System Engineer and Operations Actions Supporting TS SR Reduction (LAR Enclosure OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY PROPRIETARY INFORMATION deviation / function. The procedure will direct the operator to dispatch a Section 3.4), provides the detailed justification that demonstrates that maintenance technician to determine the source of the alarm as needed. the self-diagnostics meet the requirements of 10 CFR 50.36 for the CPCS..."

(W3F1-2020-0038 Page 18 of 27)

The NRC staff agrees with the licensees proposed actions in the LAR. So, for this LAR the licensee should cite both the credited self-diagnostic functions in Appendix B and proposed monitoring activities to justify the SR elimination in Section 2.2 of the LAR, not just the Appendix B. However, since Section 2.2 of the LAR cites Appendix B to WCAP-18464 as the sole justification for SR elimination (see Enclosure W3F1-2020-0038, Page 5 of 27) and Appendix B does not include any plant monitoring activity, it could lead to the misunderstanding that if the NRC accepts this LAR, it would also be accepting Appendix B as the only basis for the SR elimination. In addition, the LAR says on Page 18 of 27, in part, that while LTR Appendix B states that monitoring is not required in order to credit self-diagnostic features. The NRC staff does not agree with this statement to address the above criterion in BTP 7-17.

Furthermore, Appendix B says to leverage the Vogtle LAR for the SR elimination. But, the Vogtle LAR included plant monitoring activities as one of bases for the SR elimination. Therefore, the SR Elimination basis in both Section 2.2 of this LAR and Appendix B will need to include the licensees commitment to perform self-diagnostic monitoring activities and the appendix B interpretations should be revised to establish consistency with the LAR.

2 ST-02 Self-Tests B.2.5 B-6 The bullet item on this page states the following: (Entergy 11/3/20 Update) PROPRIETARY RESPONSE Open These A. changes are (Jack Zhao, (( not in Revision Richard Stattel, 1 of WCAP

((

Samir Darbali) 18484 as of 2/25/2021.

))

B.

((

))

))

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((

))

3 ST-03 Self-Tests TS 52/377 Insert C includes the following statement: (Entergy 11/3/20 Update) PROPRIETARY RESPONSE Closed Reviewed BASES 81/377 (V) Revision 1 (Jack Zhao, mark-up The performance of channel checks validates that the self-diagnostics are The LTR Appendix B will be revised as follows: WCAP-18484 Richard Stattel, continuing to perform their self-checking functions. Appendix B Samir Darbali) (( and could not It is not clear how a channel check can validate performance of self- find this diagnostics. Please provide clarification to allow the NRC staff to understand change.

how channel checks can validate performance of self-diagnostics. 2/25/2021

))

A Channel Check to review that these screens contain no alarms verifies that the system is functioning correctly.

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4. Section 2.1: Reworded last bullet and removed Reference to CEAPD SysRS.

5. Section 2.1.1.4.3.4: Clarified and added reference to CEAPD data link section

6. Section 2.1.2.2.4.1: added CEA positions to items transmitted to CEAPD.

7. Section 2.1.2.2.4.3: Removed reference to CEAPD SysRS.

8. Section 2.2.1.4.4: Added requirement for CEA trip snapshot page with live CEA position data.

9. Section 2.2.1.4.6: added CRC value to Addressable Constants page.

10. Section 2.2.1.4.7: added CRC value to Change Addressable constants page.

11. Section 2.2.1.4.12: added missing colon for "Page 3".

12. Section 2.2.1.4.19: defined CEA inputs to be displayed as SUBGRPx on this page.

13. Section 2.2.1.4.20: Corrected spelling of capability.

14. Section 2.2.1.5.2.1.2: clarified trouble alarm occurs for loss of other display.

15. Section 2.2.1.5.2.2: Added alarm icon label to sentence.

16. Section 2.2.1.5.2.2.1 and 2, added OM and MTP CRCs do not agree to trouble list.

17. Section 2.2.2.4: changed heading text and changed requirements for AI calibration testing for CPC, CPP1, and CPP2 functional tests.

18. Section 2.2.2.4: Removed requirement to enable the Exit Functional test icons only if the associated AI calibration is complete.

This section was modified to reflect the as implemented software.

19. Section 2.2.2.4.6: added section to describe functional test interlock requirements.

20. Section 2.3: corrected CEAPD description and removed reference.

21. Section 2.3.4.1.3: added missing period to end of sentence.

22. Section 2.3.4.4.3.2: corrected description since CEAPD does not use trip buffer data.

23. Section 3.1.1.1.6.3.1: added "minimum" to description.

24. Section 3.1.1.1.9.13: removed reference to CEAPD and added reference to applicable sections.

25. Section 3.1.1.1.9.13.1: Clarified data being sent to CEAPD.

26. Section 3.1.1.1.10.3: defined the CEA position data being sent to CEAPD and usage.

27. Section 3.1.1.1.10.8: added CEA positions to CEAPD cross channel comparison information.

Appendix Changes:

1. Corrected Table of contents to remove "symbol" link after Sec.

3.2.5.6.

2. Pg 116: Added IRPC decision statement to reflect text description.

3. Pg 217: Added definition of CEAIW.

4. Pg 217, 219: Moved all variable definitions to end of section 3.2.6.1.1

5. Pg 220: Clarified that CPOS(i,1) is the CEA position of the current execution cycle.

OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY PROPRIETARY INFORMATION Revision 11 Change Summary:

Text Main Body Changes

1. Pg 59 clarified the conditions for taking the CEAC snapshot.

2. This revision incorporated changes to the Reactor Power Cutback detection algorithm in Appendix A.

Revision 12 Change Summary:

Appendix Changes

1. Pg A224, added footnote for starting the RPC timer.

Revision 13 Change Summary:

Text Main Body Changes

1. Page 150, incorporated CAPs Commitment 07-285-W006.02 for both CEACs inoperable.

Revision 14 Change Summary:

Text Main Body Changes

1. Re-numbered Sections to match Table of Contents per CAPAL 100074239.

Appendix Changes:

1. Correct QHOT definition in Sections 3.2.4.5 & 3.2.4.16 of Appendix A per CAPS #08-315-W001.

11/16/20 Update:

Entergy did not perform a regression analysis between the 00000-ICE 30158 Revision 7 and 00000-ICE 30158 Revision 14 documents.

Entergy performed a lower level regression analysis audit of the Palo Verde CPCS software changes between the initial release of the software that was approved by the NRC and the current baseline of the Palo Verde CPCS software. This VOP audit included all software change requests for the Palo Verde CPCS software. These software changes in some cases required a revision to the 00000-ICE 30158.

This regression analysis audit is documented in an Entergy regression analysis audit report (AUD-WF3-2019-236-CA058).

There were no hardware design changes to the CPCS since NRC approval.

(c) Reference SA-01a and SA-01b 00000-ICE-30158, Rev 14, System Requirements Specification for the Common Q Core Protection Calculator System, is the basis document for WNA-DS-04517-CWTR3, System Requirements Specification for the Core Protection Calculator System. WNA-DS-04517-CWTR3 is the WF3 delta document for WF3. Requirements traceability is to WNA-DS-04517-CWTR3. When WNA-DS-04517-OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY PROPRIETARY INFORMATION o Verify that Westinghouse properly propagates the response h. There is not a WF3 CPC project-specific Software Safety Plan, time requirements through the design, implementation, and test Section 3, Software Safety Plan, of the Common Q Software of the replacement CPCS Program Manual is followed. WCAP-16096-P R5 is the SPM

d. Software Development Plan for the Core Protection Calculator used for the CPC project.

System Upgrade, WNA-PD-00594-CWTR3 . In some cases the SPM requires project-specific plans (e.g., Test

e. Configuration Management Plan for the Core Protection Calculator Plan, Project Plan). However, there is no requirement for a project-System Upgrade Project, WNA-PC-00069-CWTR3 specific Safety Plan, so projects can choose to follow the generic plan in Section 3 of the SPM. So, there is no WF3 CPC project-

f. Westinghouse organization chart, as referenced in LTR Section specific Software Safety Plan, Section 3, Software Safety Plan, of 5.2.12, Software V&V Processes the Common Q Software Program Manual is followed for the

g. Control Panel 7 & 2 Cyber Security Door Lock Plan, ENT-WF3- project.

CPC-115 j. Located in WEC SharePoint

k. Provided in the WEC SharePoint New for 9/30/2020 l. WEC Uploaded to SharePoint (11/3/20 Update)

h. Document that identifies and justifies the values of the CPCS delay m. Provided in the WEC SharePoint times used in the thermal margin estimate for each of the applicable n. Provided in the WEC SharePoint transients and accidents listed in Table 3.2.6-1 of Attachment 4. o. Entergy Uploaded to IMS (11/3/20 Update)

i. N/A Software Safety Plan for the Core Protection Calculator System p. Entergy Uploaded to IMS (11/3/20 Update)

Upgrade q. Entergy Uploaded to IMS (11/3/20 Update)

j. SPEC-10-00001-MULTI, 73.55 Fleet Strategy Implementation - r. Entergy Uploaded to IMS (11/3/20 Update)

Fiber Optic Cable Common-Procurement Specification (Reference 40 s. Entergy Uploaded to IMS (11/3/20 Update) of the LTR) t. Entergy Uploaded to IMS (11/3/20 Update)

k. AC160 CPU Loading Restrictions, Document Number AN03007Sp u. Entergy Uploaded to IMS (11/3/20 Update)

(SyRS Reference 1.4.2.12) v. WEC Uploaded to SharePoint (11/3/20 Update)

w. Located in IMS New for 10/15/2020 x. Located in WEC SharePoint

l. Project Management Plan for the Waterford 3 Core Protection y. Requested and received during the 11/19/20 VOP Audit Calculator Upgrade, GPEP-PMP-2019-000020, Revision 1 z. Located in IMS

m. WF3 Project Quality Plan aa.

bb. Located in WEC SharePoint New for 10/28/2020 cc. Located in WEC SharePoint dd. Located in WEC SharePoint

n. Subsequent EQSR (see open item 23) ee. Located in WEC SharePoint

o. Waterford Unit 3 Common Q Implementation - Non-LOCA ff. Located in WEC SharePoint Evaluation of Updated CPCS gg. Located in WEC SharePoint Response Times, LTR-TA-20-4, Revision 0 (LTR Reference 24) hh. Located in WEC SharePoint

p. PO 10587546 - CPC, CEAC, CEAPDS Single Channel and Four ii. Located in WEC SharePoint Channel Components jj. Located in WEC SharePoint

q. PO 10591996 - Input / Output (I/O) Simulator Components kk. Located in WEC SharePoint

r. SPEC-18-00005-W, Rev 0 ll. Located in WEC SharePoint

s. CPCS Replacement Project Critical Procurement Project (CPP), mm. Located in WEC SharePoint CPP-WF3-2019-002 (WTWF3-2019-00236) nn. Located in WEC SharePoint oo. Located in WEC SharePoint

t. EN-MP-100, Critical Procurements pp.

u. EN-DC-115, Engineering Change Process qq. Located in WEC SharePoint

v. EN-IT-104, Software Quality Assurance Program rr. Located in IMS

w. 00000-ICE-36369, Rev. 02, CPC Timing Analysis for the Common ss. Located in IMS Q Core Protection Calculator System tt. Located in IMS uu. Located in IMS New for 11/10/2020 vv. Located in IMS ww. Located in IMS

x. EN-DC-149, Acceptance of Vendor Documents xx. Located in IMS OFFICIAL USE ONLY PROPRIETARY INFORMATION

OFFICIAL USE ONLY PROPRIETARY INFORMATION

y. Waterford 3 Core Protection Calculator System Safety Function yy. Located in IMS Table, LTR-TA-19-154, Revision 0 zz. Located in IMS

z. Entergy Quality Assurance Program Manual aaa.

ccc.

New for 12/07/2020 aa. Entergy Specification SPEC-18-00005-W, Revision 0, Core Protection Calculator Purchase Specification, April 2, 2019.

bb. Westinghouse Letter CWTR3-19-21, Revision 2, Transmittal of Westinghouse Final Compliance Matrix for SPEC-18-00005-W, June 28, 2019.

cc. Westinghouse Calculation Note CN-EQT-19-6, Revision 0, Determination of In-Equipment Response Spectra for Waterford Unit 3 Core Protection Calculator System, August 12, 2019.

dd. Westinghouse Document WCAP-16166-P Supplement 1-E09, Revision 1, Equipment Qualification Report for AC160 Platform - AI687 and AI688 Modules and Supporting Components for Use in Common Qualified (Common Q) Post Accident Monitoring System.

ee. Westinghouse Document WCAP-16166-P Supplement 1-E05, Revision 5, Equipment Qualification Report for AC160 Platform - PC Node Box / Flat Panel Display System Components.

ff. Westinghouse Document 00000-ICE-37778, Revision 0, Qualification Summary Report for the PVNGS Common Q Based CPCS.

gg. Westinghouse Document 00000-ICE-37764, Revision 4, Summary Qualification Report of Hardware Testing for Common Q Applications.

hh. Westinghouse Document 00000-ICE-37773, Revision 0, Supplemental Qualification Test Report for Common Q Applications.

ii. Westinghouse Document CN-EQT-20-7, Revision 0, Seismic Evaluation of Waterford Unit 3 Auxiliary Protection Cabinet, May 11, 2020.

jj. Westinghouse Document CN-EQT-20-5, Revision 1, Qualification Evaluation of Core Protection Calculator System Equipment for Waterford Unit 3 Main Control Room, August 27, 2020.

kk. Westinghouse Test Report, EQLR-463, Revision 0, Electromagnetic Compatibility Report for the Waterford 3 Core Protection Calculator Upgrade Equipment, August 2020.

ll. Westinghouse Document EQLR-470, Revision 0, Mild Environment Test Report for the Core Protection Calculator System Equipment, September 2020.

mm. Westinghouse Document EQ-TP-496-CWTR3, Revision 0, Environmental Test Procedure for the Core Protection Calculator System Equipment, June 2020.

nn. Westinghouse Document EQLR-475, Revision 0, Seismic Qualification Test Report for the Core Protection Calculator System Equipment, September 2020.

oo. Westinghouse Document EQ-TP-499-CWTR3, Revision 0, Seismic Test Procedure for the Core Protection Calculator System Equipment, July 2020.

pp. CN-EQT-20-2 (see OI#32)

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OFFICIAL USE ONLY PROPRIETARY INFORMATION 35 CCF-02 CCF LTR-TA-19-154, Waterford 3 Core Protection Calculator System Safety (1) The purpose of LTR-TA-19-154 is to identify the Chapter 15 35.1 RAIs for Function Table (item A-01y on the Certrec portal), Table A-1, identifies fifteen events for which the CPCS responds. It is an independently reviewed Closed 35.1, (Summer Sun, Chapter 15 events that credit the WF3 CPCS. engineering analysis, and as such the references listed in LTR-TA- 35.2, Samir Darbali)19-154 are the sources of information to inform the analysis. 35.2 35.3, (1) Please confirm that the events that credit the CPCS trips in the FSAR Closed 35.4.1, analysis are limited to those events listed in LTR-TA-19-154, Table A-1. (2) The attached document, LTR-TA-21-17 identifies the backup 35.4.2 (2) Please identify the backup safety-related analog trip for each of the events safety-related analog trips for each of the events that credit the 35.3 that credit the CPCS. If a backup analog trip does not exist for a specific CPCS. In all cases a backup safety-related analog trip exists except Closed event, please identify if an alarm is provided so that manual action can be for the CEA Misoperation - Single Rod Drop / CEA Sub-group Drop taken. event. The single CEA and subgroup drop events do not generate a 35.4.1 (3) Please reference the sources of information for items (1) and (2) above. reactor trip. Closed (4) LTR-TA-20-4, Waterford Unit 3 Common Q Implementation -Non-LOCA Evaluation of Updated CPCS Response Times (item A-01o on the Certrec (3) For CCF-02a response: The Reference section of LTR-TA 35.4.2 portal), Table 1, Waterford-3 Non-LOCA CPCS Trip Signals identifies 13 154 is the source of information. Closed events that credit the WF3 CPCS. CEA Misoperation - Single Rod Drop/CEA Sub-group Drop and Uncontrolled Boron Dilution are included in For CCF-02b response: LTR-TA-21-17 is the source of information 35.5 LTR-TA-19-154 but not on LTR-TA-20-4 Table 1. Open (4.1) Please explain why these events are not included in LTR-TA (4.1) LTR-TA-20-4 states, First, the Chapter 15 non-LOCA 4, Table 1. transients were screened to identify the impacted events. The 35.6 (4.2) Please explain if the response times for these events are affected impacted events only include those that: a) trip via a CPCS trip and b) Open by the Common Q CPCS replacement. have an increased response time. Updated CPCS response times that do not result in an increased response time have no unfavorable 35.7 2/2/2021 Update: impact on the non-LOCA analyses and "are therefore not required to Open be evaluated herein. These two events were not included in LTR-TA-(5) Please submit LTR-TA-20-4, Waterford Unit 3 Common Q 20-04 for the following reasons: 35.8 Implementation -Non-LOCA Evaluation of Updated CPCS Response Open Times on the docket. CEA Misoperation - Single Rod Drop/CEA Sub-group Drop falls under FSAR Section 15.4.1.4 CEA Misoperation. The single CEA 2/11/2021 Update: and subgroup drop events do not generate a reactor trip, thus the increases in CPCS response times due to the Common Q system (6) Please submit LTR-TA-21-17, Waterford 3 CPCS Safety Function Table - implementation would not impact these events.

PPS Backup Trips, on the docket.

Uncontrolled Boron Dilution falls under FSAR Section 15.4.1.5 (7) The third column of LTR-TA-21-17, Table A-1 refers to Table 7.2-4 of CVCS Malfunction (inadvertent boron dilution). The Boron dilution Reference 1. Reference 1 (ML19268A136) is for the WF3 FSAR Chapter 15 event is analyzed for all modes of plant operation. The operational only, and not the entire FSAR. Chapter 7, which contains Table 7.2-4, is not Modes 1 and 2 inadvertent boron dilution event is bounded by the included as one of the references. It might be clearer to keep Reference 1 for FSAR Sections 15.4.1.2 and 15.4.1.3 HFP and HZP CEAW events.

Chapter 15 and add a new Reference 3 for FSAR Chapter 7, and update the The increases in CPCS response times due to the Common Q reference number in the third column of Table A-1, accordingly. system implementation would not change the event characteristics, so the inadvertent boron dilution event remains bounded by existing (8) LTR-TA-21-17 Reference 1 points to FSAR Chapter 15. However, it is not UFSAR events. For the inadvertent boron dilution event in operational clear which section of Chapter 15 contains the information supporting the Modes 3, 4, 5 and 6, all CEAs have already been inserted. Thus, the identification of the PPS backup trip signals. Please list in Reference 1 the increases in CPCS response times due to the Common Q system Chapter 15 sections that contain the supporting information. implementation would have no impact on the inadvertent boron dilution event.

(4.2) The response times for these events are not affected by the Common Q CPCS replacement as discussed in Open Item 035c (4.1), CCF-02c.

(5)

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OFFICIAL USE ONLY PROPRIETARY INFORMATION (6)

(7)

(8) LTR-TA-21-17 will be revised to reference Chapter 7 to identify the PPS analog trips that serve as the backup trips for the CPCS.

The WF3 UFSAR does not define the PPS analog trips that backup the CPCS trips in the case of a Common Cause Failure (CCF) of all four channels of the CPCS. As described in the response to OI 18, CCF-01; The CPCS was not reviewed in its entirety by the NRC as stated in the NRC Waterford Unit 3 SER, NUREG 0787, Safety Evaluation Report related to the operation of Waterford Steam Electric Station, Unit No. 3, dated July 1981. Section 7.2.3 states:

The CPCs were not reviewed, per se, at Waterford 3. The staff has taken the operating experience of ANO-2, the previous review, and acceptance of the ANO-2 CPCs, and the similarity of the Waterford 3 and ANO-2 CPCs, into account in reaching this decision.

The NRC concluded in the SER that the NRC considers the CPC design acceptable.

In the Palo Verde Common Q CPCS SER, the NRC staff quotes from the ANO-2 NRC SER (NUREG-0308 Supplement 1, Appendix D) summarizing the CCF analysis and PPS backup trips to the CPCS and concludes the following:

- Palo Verde possesses an almost identical backup set of hardware implemented RPS trip functions as ANO-2.

- Palo Verde RPS trips are identical with the exception that Palo Verde also has Low Flow RPS trip based on Steam Generator primary side differential pressure. This trip is used to provide sheared

[RCP] shaft event protection, but would serve as a backup for any loss of flow event, including a seized RCP shaft. (OI Response Note:

this is also true for WF3)

- Replacement of the [existing] four CPC channel hardware with a common qualified platform presents a digital to digital upgrade of the Palo Verde CPC system. Licensing of this system addressed diversity issues by assuming a common cause failure of all four CPC channels. As noted in the Safety Evaluation Report issued to ANO-2 on the CPC channels, the NRC found the backup analog trips, inherent shutdown mechanisms, and provisions for manual operator action acceptable.

In summary the NRC staff accepted the ANO-2 analysis of analog PPS trips that back up the CPCS trips for the Palo Verde Common Q CPCS replacement. The Palo Verde plant is a C-E System 80 plant which is significantly different than the ANO-2 C-E 3410 plant design.

Whereas the WF3 plant design is a C-E 3410 plant evolutionary version of the C-E 3410 plant design at ANO-2. Since the NRC staff accepted the ANO-2 analysis for the Palo Verde plant CPC Common Q replacement, the same analysis could be applied to the WF3 plant, that is closer in design similarity than the Palo Verde plant. This would explain why the NRC staff chose not to review the original OFFICIAL USE ONLY PROPRIETARY INFORMATION

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FSAR Final Safety Analysis Report SVVP Software Verification and Validation Plan GDC General Design Criterion (or Criteria) SW. Dev. Plan Software Development Plan HFE Human Factors Engineering SyRS or Sys. System Requirements Specifications Req. Spec.

I&C Instrumentation and Control TR Topical Report ID Identification TRM Technical Requirements Manual IEC International Electrotechnical Commission TS Technical Specifications IEEE Institute of Electronic and Electrical Engineering V&V Validation and Verification ISG Interim Staff Guidance VOP Vendor Oversight Plan

[CERTREC] IMS Inspection Management System WF3 or W3 Waterford Steam Electric Station, Unit 3 LAR License Amendment Request WCAP Westinghouse document LHGR Linear Heat Generation Rate WEC Westinghouse Electric Corporation LTR Licensing Technical Report WWDT Window Watchdog Timer OFFICIAL USE ONLY PROPRIETARY INFORMATION

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OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL4/LA NRR/DSS/SNSB/BC NRR/DRO/IQVB/BC NAME AKlett PBlechman SKrepel KKavanagh DATE 03/12/2021 03/16/2021 03/24/2021 03/29/2021 OFFICE NRR/DEX/EICB/BC NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM PBuckberg NAME MWaters JDixon-Herrity (AKlett for)

DATE 03/29/2021 03/29/2021 04/02/2021