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| {{#Wiki_filter:OFFICIAL USE ONLY - PROPRIETARY INFORMATION April 1, 2021 LICENSEE: Entergy Operations, Inc. | | {{#Wiki_filter:}} |
| FACILITY: Waterford Steam Electric Station, Unit 3
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| ==SUBJECT:==
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| ==SUMMARY==
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| OF FEBRUARY 17, 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)
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| On February 17, 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 .
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| 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.
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| A redacted copy of the open items list is in Enclosure 3.
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| During the public portion of the meeting, the NRC staff and licensee discussed Open Item Nos. 30.1, 31, 33, and 35. As a result of the meeting discussions, the NRC updated Open Item No. 35. The NRC staff and licensee also discussed logistics for the licensee providing a supplement to its amendment request. The closed portion of the meeting was replaced with audit-related discussions, which will be documented in an audit summary in accordance with the NRCs audit plan dated October 1, 2020 (ADAMS Accession No. ML20268B324).
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| Enclosure 2 to this letter contains proprietary information. When separated from Enclosure 2, this document is DECONTROLLED.
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| OFFICIAL USE ONLY - PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY - PROPRIETARY INFORMATION 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.
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| The NRC staff did not make any regulatory decisions or commitments at the meeting. No members of the public identified themselves on the teleconference. Public Meeting Feedback forms were not received.
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| Please direct any inquiries to me at 301-415-1383 or by e-mail to Perry.Buckberg@nrc.gov.
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| /RA Audrey Klett for/
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| Perry H. Buckberg, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382
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| ==Enclosures:==
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| : 1. List of Attendees
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| : 2. Open Items List (Proprietary)
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| : 3. Open Items List (Non-proprietary) cc w/o Enclosure 2: Listserv OFFICIAL USE ONLY - PROPRIETARY INFORMATION
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| Enclosure 1 List of Attendees
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| LIST OF ATTENDEES FEBRUARY 17, 2021, VIRTUAL PUBLIC MEETING WITH ENTERGY OPERATIONS, INC., ET AL.
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| WATERFORD STEAM ELECTRIC STATION, UNIT 3, LICENSE AMENDMENT REQUEST TO INSTALL DIGITAL UPGRADE U.S. Nuclear Regulatory Commission Entergy Operations, Inc.
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| Odunayo Ayegbusi, NRR1/DRA2/APLB3 Jacob Champagne Eric Benner, NRR/DEX4 Phil Couture Samir Darbali, NRR/DEX/ELTB5 Remy DeVoe Jennifer Dixon-Herrity, NRR/DORL6/LPL47 Ron Gaston Greg Galletti, NRR/DRO8/IQVB9 Loren Miller Bhagwat (BP) Jain, NRR/DORL/LPL4 Dave Moody Kerri Kavanagh, NRR/DRO/IQVB Roger Rucker DaBin Ki, NRR/DRO/IOLB10 John Schrage Ki Lawson-Jenkins, NSIR11/DPCP12/CSB13 Christopher Talazac Richard Stattel, NRR/DEX/EICB14 William Truss Summer Sun, NRR/DSS15/SNSB16 Tarico Sweat, NRR/DSS/STSB17 Jensen Hughes, Inc.
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| Mike Waters, NRR/DEX/EICB Alan Harris Tom Wengert, NRR/DORL/LPL4 Deanna Zhang, NRR/DRO/IQVB Sargent and Lundy Jack Zhao, NRR/DEX/EICB Pareez Golub Members of the Public Westinghouse Electric Company, LLC None introduced Warren Odess-Gillett John Wiesemann 1
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| Office of Nuclear Reactor Regulation 2
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| Division of Risk Assessment 3
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| Probabilistic Risk Assessment Licensing Branch B 4
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| Division of Engineering and External Hazards 5
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| Long-Term Operations and Modernization Branch 6
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| Division of Operating Reactor Licensing (DORL) 7 Plant Licensing Branch IV 8
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| Division of Reactor Oversight 9
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| Quality Assurance and Vendor Inspection Branch 10 Operator Licensing and Human Factors Branch 11 Office of Nuclear Security and Incident Response 12 Division of Physical and Cyber Security Policy 13 Cyber Security Branch 14 Instrumentation and Controls Branch 15 Division of Safety Systems 16 Nuclear Systems Performance Branch 17 Technical Specifications Branch
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| Enclosure 3 (Non-proprietary)
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| 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.
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| Redacted information is identified by blank space enclosed within ((double brackets)).
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION 1.
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| Topic & LAR/LTR LAR/ LTR Audit, RAI or IMS ID NRC Comment / Open Item Description Licensee Response Status (Reviewer) Section Page RCI No.
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| Acronyms and abbreviations are defined on the last page of this document.
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| Certrec IMS Request ID Format (second column of this table)
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| Updated by Entergy on 10/19/20 A- Audit (Generic/Multiple Documents)
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| 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
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| ((
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| PSAI- Plant Specific Action Items
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| - - - - - RC- Regulatory Commitments - -
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| 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 ))
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| 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 diagnostics (V)
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| (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 Richard Stattel, faults within the I&C system, such as Random-Access Memory (RAM) errors. be revised as follows:
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| Samir Darbali)
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| Though this is a quote out of the Vogtle LAR safety evaluation, it is a Crediting Self-Diagnostics for TS Surveillance Requirement Elimination 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 tests. The interpretation being made that the BTP criterion calls for complete continually monitoring the health of the hardware and software.
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| functional testing of the self-diagnostic functions is incorrect. Instead, the BTP Appendix B to the Licensing Technical Report (LTR) (Attachment 4) and states that the licensee should confirm the execution of self-diagnostic tests the Waterford System Engineer and Operations Actions Supporting TS 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.
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| included in the Enclosure for this LAR.
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| 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.
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| 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:
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| 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..."
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| 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
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| 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..."
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| (W3F1-2020-0038 Page 18 of 27)
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| 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.
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| 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.
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| 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 This should be A. an RAI to get (Jack Zhao, (( this response Richard Stattel, on the docket.
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| ((
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| Samir Darbali)
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| ))
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| B.
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| ((
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| ))
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| ))
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| ((
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| ))
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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 BASES 81/377 (V)
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| (Jack Zhao, mark-up The performance of channel checks validates that the self-diagnostics are The LTR Appendix B will be revised as follows:
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| Richard Stattel, continuing to perform their self-checking functions.
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| Samir Darbali) ((
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| It is not clear how a channel check can validate performance of self-diagnostics. Please provide clarification to allow the NRC staff to understand how channel checks can validate performance of self-diagnostics.
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| ))
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| A Channel Check to review that these screens contain no alarms verifies that the system is functioning correctly.
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| 4 ST-04 Self-Tests B.7.1 B-39 Appendix B of WCAP 18464 contains the following statement: (Entergy 11/3/20 Update) PROPRIETARY RESPONSE Closed (V)
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| (Jack Zhao, Richard Stattel, This is correct. The sentence in the LTR will be revised as follows:
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION Samir Darbali) ((
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| ((
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| ))
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| ))
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| 5 ST-05 Self-Tests B.3.2.1 B-10 The WCAP 18464 states: IEC 60880 is comparable to IEEE 7-4.3.2, and the Consistent with Westinghouse WCAP-18461, the following text will be Closed staff has found IEC 880 to be an acceptable equivalent. deleted from the LTR (WCAP-18464): (V)
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| (Jack Zhao, Richard Stattel, This was a statement in the NRC original safety evaluation of Common Q "B.3.2.1 Common Q Topical Report - NRC Safety Evaluation Samir Darbali) which has been superseded. The statement has been removed from the current Common Q platform TR safety evaluation report. The Common Q Platform diagnostics were developed under a robust process that was reviewed by the NRC. In 2000, the NRC issued a The NRC does not consider IEC 880 to be an equivalent to IEEE 7-4.3.2. As safety evaluation report (ML003740165, Bibliography 8) on the such, the NRC evaluates all digital systems to the criteria of IEEE 7-4.3.2. Common Q Topical Report (CENP-396-P, Rev. 01 which is the predecessor to WCAP-16097-P-A, Reference 4). In that report the NRC acknowledged receipt of Westinghouse document GKWF700777, "Design and Life Cycle Evaluation Report on Previously-Developed Software in ABB AC160, I/O Modules and Tool Software" (Bibliography 9) in support of the commercial dedication of the AC160.
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| The safety evaluation report states that the, AC160 PDS [Previously Developed Software] is composed of the AC160 software, S600 I/O Module(s) software, and ABB Tool software. The evaluation is based on the requirements specified in International Electrotechnical Commission (IEC) standard IEC-60880, "Software for Computers in the Safety Systems of Nuclear Power Stations." IEC 60880 is referenced in IEEE 7-4.3.2-2003, "IEEE Standard Criteria for Digital Computers in Safety Systems of Nuclear Power Generating Stations".
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| EC 60880 is comparable to IEEE 7-4.3.2-2003, and the staff has found standard IEC 880 to be an acceptable equivalent.
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| The Design and Lifecycle Evaluation (DLCE) applies to all aspects of the PDS including the system software that executes the nuclear application program and the diagnostics integrated with the system software. In other words, the same software quality approach applied to both aspects of the system software. The results of this report were discussed with the NRC staff during the licensing of the Common Q OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION platform. The NRC also reviewed this document as part of their review of LAR 19-001 for Vogtle 3&4 (Reference 42)."
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| 6 SA-01 Sys. Req. Spec. LAR 3.1 The licensee provided two CPCS System Requirements Specification (SyRS) (a) As previously described to the NRC during the Acceptance (a) Closed documents: the reference CPCS design (Palo Verde) SyRS (00000-ICE- Review discussions:
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| (Samir Darbali, LTR 3 30158 (LAR Attachment 7 and LTR Reference 2)) and the WF3-specific
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| * The intent of the statements in the Enclosure and LTR, as well as (a.1)
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| Deanna Zhang) delta SyRS (WNA-DS-04517-CWTR3 (LAR Attachment 8 and LTR the entire paragraph in the Enclosure, was to communicate that the Closed LTR 5 5-1 Reference 21)). NRC has reviewed the overall design of the replacement CPC system in a previous license amendment (i.e., PVNGS 1, 2, and 3, (b)
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| The staff noticed that the SyRS for the reference CPCS design (00000-ICE- Amendment No. 150; ML033030363). Open 30158) revision is Revision 14. The SyRS that was reviewed as part of the
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| * It was not Entergy's intent to state, or even suggest, that the specific Palo Verde CPCS upgrade is Revision 7. revision of the reference design document that was used for the (c)
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| Waterford CPC replacement (i.e., Revision 14) has been reviewed by Closed The LAR and LTR make several inaccurate statements regarding which the NRC, or that the NRC's review of the previous revision (i.e.,
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| revision of 00000-ICE-30158 was previously reviewed by the NRC. For Revision 7, submitted in ML032830027) could be used for the NRC's example: review of the Waterford project. However, Entergy understands how the wording of the statement is ambiguous in this respect.
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| LAR Section 3.1 states: The SyRS project document has a reference design document (Attachment 7), which has been previously reviewed (b) 00000-ICE-30158, Rev 14, System Requirements Specification by the NRC, and a delta document (Attachment 8) which describes for the Common Q Core Protection Calculator System, is the basis differences for the Waterford project. document for WNA-DS-04517-CWTR3, System Requirements Specification for the Core Protection Calculator System. WNA-DS-LTR Section 5, item b. states: The base system requirements for the 04517-CWTR3 is the WF3 delta document for WF3. Requirements WF3 CPCS is the CPCS System Requirements Specification traceability is to WNA-DS-04517-CWTR3. When WNA-DS-04517-(Reference 2), which have already been reviewed by the NRC as part CWTR3, Rev 0, was reviewed and approved for owners acceptance of the Palo Verde CPCS replacement. per procedure EN-DC-149, the applicable sections of 00000-ICE-30158, Rev 14, were reviewed. Based on the regression analysis for LTR Section 5.2.4 states As stated earlier, the reference design for n-th of kind systems described in WCAP-16096-P, Software the WF3 CPCS replacement is documented in Reference 2. These Program Manual for Common Q Systems," the only requirements requirements and their traceability have already been reviewed and traceability will be for the modified sections provided in WNA-DS-approved by the NRC as part of the Palo Verde CPCS replacement. 04517-CWTR3. There is a VOP audit action to compare the non-modified sections of 00000-ICE-30158, Rev 14, to the Requirements Again, these statements are inaccurate because the SyRS that was reviewed Traceability as part of the Requirements Traceability Matrix (RTM) for the Palo Verde CPCS upgrade review is Revision 7 of 00000-ICE-30158. VOP Audit.
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| The staff has not reviewed nor performed traceability of requirements for 00000-ICE-30158 after Revision 7. Additionally, the licensee has not A regression analysis of the software is at a lower level of review than demonstrated in the LAR or LTR that they have performed these activities. doing a regression analysis of the System Requirements Specification, and WF3 considered this review to be of greater value Clarification questions: that a document review since this include the complete
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| * (a) Are the statements that the NRC staff had previously reviewed the implementation of any changes. WF3 performed a regression SyRS (00000-ICE-30158) meant as background information, or for analysis VOP audit of the current Palo Verde code (release 6.7),
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| crediting the previous evaluation? which was the base line for the WF3 project, to the Palo Verde initial code (release 5.0) to confirm the SPM was followed for design
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| * (b) Is the licensee performing independent design quality, traceability quality, requirements traceability, and IV&V including testing.
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| and other oversight activities for:
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| o 00000-ICE-30158 Revision 7? 00000-ICE-30158, Rev 7 to Rev 13 were not specifically reviewed or o 00000-ICE-30158 Revisions 8 thru 14? audited, since these were not credited for any vendor oversight o or only for the WF3-specific delta SyRS (WNA-DS-04517- activity or project activity. The VOP audit of the regression analysis of CWTR3)? the software was considered by WF3 to be the best method to access the difference from the Palo Verde software to be used as the
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| * (c) Slide 37 of the March 19, 2020 pre-application meeting identified baseline for the WF3 software.
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| the SyRS as a living document, as defined in ISG-06 (i.e., a document OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION that will be revised as system development activities progress). (c) Slide 37 of the March 19, 2020 pre-application meeting identified Please clarify if this statement refers to 00000-ICE-30158, WNA-DS- the SyRS as a living document, as defined in ISG-06 (i.e., a 04517-CWTR3, or both documents. document that will be revised as system development activities progress). This statement refers to only WNA-DS-04517-CWTR3 10/28/2020 Update:
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| (a.1) Yes, the LAR Enclosure will be revised per the response to SA-(a.1) The last sentence of the response states that However, Entergy 01a.
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| understands how the wording of the statement is ambiguous in this respect.
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| Please explain if the LAR and LTR will be revised to address the ambiguous Yes, the LTR Section 3.3.4, System Requirements Documentation wording. (D.2.3.3 and D.2.3.3.1), will be revised as follows:
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| From: "Reference 2 is the CPCS System Requirements Document. It is the system requirements specification for the reference design for the Common Q CPCS. The reference design system requirements is based on two requirements documents that define the legacy CPCS functionality:
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| - Functional Design Requirements for a Core Protection Calculator (Reference 36) and
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| - Functional Design Requirements for a Control Element Assembly Calculator (Reference 37)
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| The Common Q CPCS reference design system requirements specification (Reference 2) was developed to migrate the functional requirements of References 36 and 37) to a Common Q CPCS architecture. The result was the Palo Verde CPCS implementation.
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| The existing Waterford CPCS is based on the same two functional design requirements documents (References 36 and 37). Therefore, the CPCS reference design is also applicable to the Waterford CPCS replacement plus additional changes to accommodate plant interface differences, requested licensee improvements, and changes in technology in the Common Q platform."
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| To: "Reference 2 is the CPCS System Requirements Document for the reference design for the Common Q CPCS. The reference design system requirements is based on two requirements documents that define the legacy CPCS functionality:
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| - Functional Design Requirements for a Core Protection Calculator (Reference 36) and
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| - Functional Design Requirements for a Control Element Assembly Calculator (Reference 37)
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| The Common Q CPCS reference design system requirements specification (Reference 2) was developed to migrate the functional requirements of References 36 and 37 to a Common Q CPCS architecture. The result was the Palo Verde CPCS implementation.
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| Note that Revision 7 of Reference 2 (ML032830027) was reviewed by the NRC.
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION The existing Waterford CPCS is based on the same two functional design requirements documents (References 36 and 37). Therefore, the CPCS reference design is also applicable to the Waterford CPCS replacement plus additional changes to accommodate plant interface differences, requested licensee improvements, and changes in technology in the Common Q platform. Reference 2 is the current revision of the CPCS System Requirements Document for the reference design.
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| 7 SDP-01 SW Dev Plan LTR Section This section of the LTR states, Any exceptions to the SPM would be Entergy Update 11/3/20 Open RAI, 5.1.1 documented in the WF3 CPCS Software Development Plan (Reference 25).
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| (Deanna Zhang The Software Development Plan also includes clarifications to particular items The LTR will be revised to include the following: Audit the SW Samir Darbali) to make clear how certain aspects of the SPM are being fulfilled. The WF3 CPCS Software Development Plan (WNA-PD-00594- Dev. Plan CWTR3) documents the following alternatives to the Common Q SPM For the ARP, ISG-06, Rev 2 provides guidance on what should be submitted. (WCAP-16096-P-A):
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| This includes a summary of the application software planning and processes. Section 5.6.1 of the SPM states:
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| The LTR does not provide sufficient information to summarize the differences between the SPM and the WF3 CPCS Software Development Plan in 1. IV&V phase summary reports: These reports are issued after each accordance with the guidance of ISG-06, Rev. 2. ife cycle phase of the IV&V task to summarize the IV&V review. Phase summary reports may be consolidated into a single report if desired.
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| Please summarize the differences between the SPM and the WF3 CPCS These reports shall contain the following:
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| Software Development Plan. a. Description of IV&V tasks performed
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| : b. Summary of task results
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| : c. Summary of discrepancies and their resolution
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| : d. Assessment of software quality
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| : e. Recommendations Alternative:
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| The IV&V activities will be performed at their respective phases per the Software V&V Plan (SVVP); however, the IV&V team will not issue phase summary reports after each life cycle phase. The results of ndividual tasks are documented, and anomalies are reported in the RITS system for their resolution. A final IV&V report will be issued encompassing all software development phases.
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| Justification:
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| Due to the limited scope of the project, which is based on a previously completed reference design, the Concept, Requirements, Design, and mplementation phases are impacted concurrently and iterated frequently. Therefore, having intermediate summary reports does not produce additional value to the stakeholders than what is already being provided through underlying task reports and RITS. The Phase Summary Report (PSR) is not the only method of gatekeeper for design progression to the next phase. The design can proceed based on the result of the individual tasks. Therefore, the PSR will be produced only once for this project, which will report on all activities, and will serve as the Final IV&V Report. This is an acceptable alternative to SPM Section 5.6.1, since the feedback to design team is provided timely based on formally issued anomalies and other underlying reports.
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION Section 6.3.2 of the SPM states:
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| Project-specific software goes to the Lead SW engineer for approval/rejection.
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| the Lead SW engineer determines the feasibility and appropriateness of project-specific software changes. They sign the form for approval / rejection.
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| Alternative:
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| All software modifications shall be documented with a Software Change Request (SCR) via Global Instrumentation and Control Issue Tracking System [RITS]. All functional deviations shall be documented with RITS. Modifications can be initiated because of a change in functional requirements or because of a functional deviation from the ntended functional requirements.
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| The RITS system does not include a method for the Lead SW engineer to approve a software change request; therefore, an alternative approach for approval by the Lead SW engineer or subsystem lead will be taken.
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| Justification:
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| RITS that are identified as functional RITS require approval by a software lead and/or subsystem lead for inclusion in a baseline. The nitiator of the functional RITS shall:
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| * Require a detailed evaluation of the RITS.
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| * Route the RITS to the software lead or designated subsystem lead for formal approval of the RITS in a baseline through the detailed evaluation.
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| 8 SDP-02 Common Q LTR Section LTR Section 5.1.6 states in part, Appendix 5 of the Common Q Topical The LTR Section 5.1.6 will be revised as follows: Closed Changes 5.1.6 Report (Reference 13) is the output document for the change process (V.)
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| described in Reference 12. The document provides a summary of changes There have been no changes to the SPM since its approval by the (Deanna Zhang and then detailed recording of analysis and/or qualification documents, and a NRC. As a result, the Common Q Record of Changes document will Samir Darbali) conclusion statement on the status of the change relative to the NRC safety not include any assessments of changes to the SPM.
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| conclusions. Reference 13 can be audited by the NRC staff...
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| The response to SPM PSAI 6 refers to the Common Q PSAI regarding the record of changes, but it does not address the validity of the previously derived safety conclusions if changes have been made to the Common Q SPM. The response to SPM PSAI 1 refers to the WF3 CPCS Software Development Plan and does not identify if there are any exceptions to the SPM (see the previous open item).
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| LTR Section 6.2.2.16 provides a list of the current product revisions used for the WF3 CPCS project. However it does not describe whether the new revisions invalidate any of the safety conclusions in the safety evaluation of the Common Q platform. This section also states that WF3 will review the topical report record of changes document in Reference 13 for adequate qualification documentation that the changes do not invalidate safety conclusions in the safety evaluation of the Common Q platform.
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| It is not clear whether the WF3 review will verify that safety conclusions for the differences will only be on qualification or whether it would include other topics (e.g., software quality, etc.).
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION 9 SDP-04 SW LTR Section This section states in part, The allocation of CPCS reference design system (a) The RTM only includes requirements on the differences between Open Requirements 5.2.5 requirements (Reference 2) to software have already been accomplished as the WF3 CPCS replacement system/corresponding software part of the NRC-approved Palo Verde CPCS replacement. The WF3 delta requirements and the system requirements/corresponding software (Deanna Zhang requirement from the reference design are documented in Reference 21. requirements in the Westinghouse Rev 14 baseline of the CPCS Samir Darbali) These are allocated to software as described in Section 5, item c and requirements specification.
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| documented in the SRS....Similar to the WF3 system requirements specification, the SRS is independently reviewed, approved and baselined as (b) input to the ongoing life cycle activities. In addition, the RTM is updated (Entergy 11/3/20 Update) showing the tracing of software requirements to the WF3 system requirements specification (Reference 21). The following summarizes the revisions to 00000-ICE-30158 since Revision 7.
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| (a) Based on this description, it is not clear whether the RTM only include requirements on the differences between the WF3 CPCS replacement Revision 08 system/corresponding software requirements and the system This revision was to change the state of the Operating Bypass requirements/corresponding software requirements in Westinghouse Rev 14 Contact annunciator outputs as a result of field installation. Some baseline of the CPC system requirements specification or whether it includes additional typographical errors and inconsistencies were also all CPCS system requirements. corrected.
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| Change Summary:
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| (b) Given that (1) the WF3 system requirements specification only includes Text Main Body Changes deltas between the WF3 CPCS project and the referenced System 1. Corrected Figure 2.1-1.
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| Requirements Specification of the Common Q Core Protection Calculator 2. Section 2.2.1.5.2.2.1: Deleted "or CPP" from the third bullet.
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| System (0000-ICE-30158), Revision 14, and (2) the System Requirements 3. Section 2.3.9.6.3: Revised discussion of Operating Bypass relays Specification of the Common Q Core Protection Calculator System (0000-ICE- so that form A contacts are used on all outputs.
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| 30158) version that was reviewed and approved during the referenced Palo 4. Table 3.1.1.1.7-1: Deleted CPC Trouble for CEAC processor global Verde CPCS Digital Upgrade LAR is Revision 7, it is unclear what types of memory failure.
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| regression analysis have been performed between the Revision 7 and 5. Section 3.5.3: Revised to define that an availability analysis shall Revision 14 of the System Requirements Specification of the Common Q be performed not a reliability analysis.
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| Core Protection Calculator System to use Revision 14 as the new baseline for 6. Added requirement for ANSIN45.2.2 Level B storage in new the WF3 CPCS project? section 3.6.
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| (c) It is also not clear whether Entergy performed appropriate oversight on the Appendix Changes:
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| activities related to addressing the differences between Revision 7 and None Revision 14 of the System Requirements Specification of the Common Q Core Protection Calculator System. Revision 09 This revision only changed page A121 in the Appendix. The change was to clarify the calculation of the row index.
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| Revision 10 This revision incorporates changes to various display pages based on customer comments.
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| Change Summary:
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| Text Main Body Changes
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| : 1. Moved table of Contents prior to the Revision Abstract and increase number of entries.
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| : 2. Revision 09 was issued with various bookmarks printed as "Error!
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| Reference source not found". Corrected these or removed the reference (pgs 23, 30, 103, 210).
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| : 3. Section 1.4.2: Removed revision level on CEAPD SysRS (Ref.
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| 1.4.2.9) and added footnote.
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| : 4. Section 2.1: Reworded last bullet and removed Reference to CEAPD SysRS.
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| : 5. Section 2.1.1.4.3.4: Clarified and added reference to CEAPD data OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION link section
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| : 6. Section 2.1.2.2.4.1: added CEA positions to items transmitted to CEAPD.
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| : 7. Section 2.1.2.2.4.3: Removed reference to CEAPD SysRS.
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| : 8. Section 2.2.1.4.4: Added requirement for CEA trip snapshot page with live CEA position data.
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| : 9. Section 2.2.1.4.6: added CRC value to Addressable Constants page.
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| : 10. Section 2.2.1.4.7: added CRC value to Change Addressable constants page.
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| : 11. Section 2.2.1.4.12: added missing colon for "Page 3".
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| : 12. Section 2.2.1.4.19: defined CEA inputs to be displayed as SUBGRPx on this page.
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| : 13. Section 2.2.1.4.20: Corrected spelling of capability.
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| : 14. Section 2.2.1.5.2.1.2: clarified trouble alarm occurs for loss of other display.
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| : 15. Section 2.2.1.5.2.2: Added alarm icon label to sentence.
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| : 16. Section 2.2.1.5.2.2.1 and 2, added OM and MTP CRCs do not agree to trouble list.
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| : 17. Section 2.2.2.4: changed heading text and changed requirements for AI calibration testing for CPC, CPP1, and CPP2 functional tests.
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| : 18. Section 2.2.2.4: Removed requirement to enable the Exit Functional test icons only if the associated AI calibration is complete.
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| This section was modified to reflect the as implemented software.
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| : 19. Section 2.2.2.4.6: added section to describe functional test interlock requirements.
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| : 20. Section 2.3: corrected CEAPD description and removed reference.
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| : 21. Section 2.3.4.1.3: added missing period to end of sentence.
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| : 22. Section 2.3.4.4.3.2: corrected description since CEAPD does not use trip buffer data.
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| : 23. Section 3.1.1.1.6.3.1: added "minimum" to description.
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| : 24. Section 3.1.1.1.9.13: removed reference to CEAPD and added reference to applicable sections.
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| : 25. Section 3.1.1.1.9.13.1: Clarified data being sent to CEAPD.
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| : 26. Section 3.1.1.1.10.3: defined the CEA position data being sent to CEAPD and usage.
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| : 27. Section 3.1.1.1.10.8: added CEA positions to CEAPD cross channel comparison information.
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| Appendix Changes:
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| : 1. Corrected Table of contents to remove "symbol" link after Sec.
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| 3.2.5.6.
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| : 2. Pg 116: Added IRPC decision statement to reflect text description.
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| : 3. Pg 217: Added definition of CEAIW.
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| : 4. Pg 217, 219: Moved all variable definitions to end of section 3.2.6.1.1
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| : 5. Pg 220: Clarified that CPOS(i,1) is the CEA position of the current execution cycle.
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| Revision 11 Change Summary:
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION Text Main Body Changes
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| : 1. Pg 59 clarified the conditions for taking the CEAC snapshot.
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| : 2. This revision incorporated changes to the Reactor Power Cutback detection algorithm in Appendix A.
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| Revision 12 Change Summary:
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| Appendix Changes
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| : 1. Pg A224, added footnote for starting the RPC timer.
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| Revision 13 Change Summary:
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| Text Main Body Changes
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| : 1. Page 150, incorporated CAPs Commitment 07-285-W006.02 for both CEACs inoperable.
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| Revision 14 Change Summary:
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| Text Main Body Changes
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| : 1. Re-numbered Sections to match Table of Contents per CAPAL 100074239.
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| Appendix Changes:
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| : 1. Correct QHOT definition in Sections 3.2.4.5 & 3.2.4.16 of Appendix A per CAPS #08-315-W001.
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| 11/16/20 Update:
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| Entergy did not perform a regression analysis between the 00000-ICE 30158 Revision 7 and 00000-ICE 30158 Revision 14 documents.
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| 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.
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| This regression analysis audit is documented in an Entergy regression analysis audit report (AUD-WF3-2019-236-CA058).
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| There were no hardware design changes to the CPCS since NRC approval.
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| (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-CWTR3, Rev 0, was reviewed and approved for owners acceptance per procedure EN-DC-149, the applicable sections of 00000-ICE-30158, Rev 14, were reviewed. Based on the regression analysis for OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION n-th of kind systems described in WCAP-16096-P, Software Program Manual for Common Q Systems," the only requirements traceability will be for the modified sections provided in WNA-DS-04517-CWTR3. There is a VOP audit action to compare the non-modified sections of 00000-ICE-30158, Rev 14, to the Requirements Traceability as part of the Requirements Traceability Matrix (RTM)
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| VOP Audit.
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| A regression analysis of the software is at a lower level of review than doing a regression analysis of the System Requirements Specification, and WF3 considered this review to be of greater value that a document review since this include the complete implementation of any changes. WF3 performed a regression analysis VOP audit of the current Palo Verde code (release 6.7),
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| which was the base line for the WF3 project, to the Palo Verde initial code (release 5.0) to confirm the SPM was followed for design quality, requirements traceability, and IV&V including testing.
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| 00000-ICE-30158, Rev 7 to Rev 13 were not specifically reviewed or audited, since these were not credited for any vendor oversight activity or project activity. The VOP audit of the regression analysis of the software was considered by WF3 to be the best method to access the difference from the Palo Verde software to be used as the baseline for the WF3 software 10 SDP-03 SW Design LTR Section This section states in part, System Validation Test - this is formal integration The intention is to re-run the complete set of PVNGS system tests with Closed 5.2.8 testing of the software and hardware performed by the independent test team. the design changes made for the WF3 implementation. Therefore, no (Deanna Zhang The System Validation Test traces the test cases to the WF3 CPCS credit is being taken for past system tests.
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| Samir Darbali) replacement system requirements specification (Reference 21).
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| Please explain whether the system validation test only includes test cases for the WF3 CPCS replacement system requirements specification or if it also includes the CPCS reference system requirements specification (Rev. 14).
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| 11 VOP-01 Critical VOP Table of It appears that the VOP does not have complete identification of activities for (a) Per VOP Section 7, "The scope of vendor oversight is expected to Open Characteristics Summary Contents providing oversight of the project and will only be a plan to develop or evolve during the project. Project-specific performance measures determine them while the expectation is to have the activities and associated that warrant vendor oversight are updated as this list changes."
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| (Deanna Zhang acceptance criteria completed. Examples include:
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| Samir Darbali) a. Section 6: Development and Assessment of Potential Project and Technical The performance measures are divided into three categories:
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| Risk Factors
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| * Critical Characteristics,
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| : b. Section 7: Determine Performance Measures and Acceptance Criteria
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| * Design Artifacts, and (Critical Characteristics/Design Artifacts)
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| * Programmatic Elements.
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| (a) It is also not clear what oversight activities are associated with Section 7 of As listed in VOP Section 7, the following activities are used to provide the VOP to verify the vendor has satisfied the critical characteristics. oversight of the each category:
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| (b) Section 2 of the VOP Summary states in part The level of vendor Critical Characteristics:
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| oversight follows a graded approach, based on project and technical risk factors, which are described in VOP Section 6. All levels of the graded " Oversight of critical characteristics utilizes the following vendor approach will include specifically defined performance measures and oversight activities:
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| acceptance criteria which are described in VOP Section 7. Based on this
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| * Conducting vendor audits and quality surveillances description, the project and technical risk factors and the performance
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| * Reviewing WEC design output documents OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION measures and acceptance criteria for the critical characteristics and
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| * Participating in Factory Acceptance Testing programmatic elements should already have been identified in the VOP. This
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| * Conducting Site Acceptance Testing does not appear to be consistent with the titles of Sections 6 and 7.
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| * Conducting Post-Modification Testing
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| * Observing or witnessing specific vendor activities (c) It is also not clear based on the title of Section 8 in the Table of Contents for
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| * Capturing issues in WF3/WEC corrective action programs" the VOP, what Implement Appropriate Oversight Methods will entail.
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| Design Artifacts:
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| "Oversight of the design artifacts utilizes the following vendor oversight activities:
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| * Conducting vendor audits
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| * Reviewing WEC design output documents (e.g., specifications, drawings, analyses)
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| * Providing input to and review/confirmation of specific vendor activities and related information items
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| * Coordinating multi-disciplined interactions between various stakeholders
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| * Capturing issues in WF3/WEC corrective action programs" Programmatic Elements:
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| "Conducting vendor audits
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| * Reviewing WEC design output documents
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| * Providing input to and review/confirmation of specific vendor activities and related information items
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| * Observing or witnessing specific vendor activities
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| * Participating directly in specific vendor activities
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| * Coordinating multi-disciplined interactions between various stakeholders
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| * Capturing issues in WF3/WEC corrective action programs" (b) The acceptance criteria and oversight activities have been identified in VOP Sections 6 and 7. The VOP is a plan and can be revised pending the design/project evolution. As the design/project progresses, it may be necessary to add more acceptance criteria or design artifacts to conduct adequate vendor oversight.
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| (c) Section 8 is intended to show escalation of oversight methods based on the risk factors. If the risk factors which are periodically evaluated indicate that risks are increasing, then supplemental oversight methods may need to be used.
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| 12 VOP-02 CPP VOP Section 2 This section of the VOP Summary, states in part, Monitoring, verification and As indicated in VOP Section 2, Vendor Oversight Plan (VOP) Scope, Open Summary acceptance phase activities are defined in the Critical Procurement Plan "The CPCS Replacement Project Critical Procurement Plan (CPP)
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| (Deanna Zhang (CPP) during the Planning Phase. Verification can be either through the (Reference 6), prepared under Entergy procedure EN-MP-100, Critical Samir Darbali) normal Receipt Inspection process or other activities outlined in the CPP. The Procurements (Reference 13), is incorporated by reference into the Critical Procurement Plan provides a summary of the requirements and VOP."
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| necessary actions including on-site services (when required), to ensure that a critical procurement will meet Entergys expectations...The CPP credits the management of procurement risks based on the Westinghouse software verification and validation process, factory acceptance testing, performance of OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION site acceptance testing, and rigorous software testing. QA surveillances will be performed to ensure the approved Westinghouse processes were followed.
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| Given that the VOP summary states that the CPP will be an input to the VOP, what is the relationship between the CPP and the VOP (e.g., the CPP will be referenced in the VOP or parts of the CPP will be incorporated into the VOP)?
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| 13 VOP-03 Oversight of VOP Section 3 This section of the VOP Summary, states in part, Some of the SPM plans will Vendor Oversight Plan Revision 2 was uploaded to Item A-01c for Open SPM project- Summary have project-specific instances (i.e., SVVP, SCMP, and Software Test Plan). reference. VOP section 7 provides some details on how Entergy will specific These project-specific plans will be evaluated to ensure they are developed in review plans and what acceptance criteria will be used. Specifically, instances accordance with the SPM. subsection Software Verification and Validation describes acceptance criteria for software V&V detail.
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| (Deanna Zhang Please explain what specific activities will be performed by Entergy to review Samir Darbali) these plans and what the acceptance criteria are. The VOP Plan includes the use of other Entergy processes and procedures.
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| 14 VOP-04 V&V VOP Section 3 This section of the VOP Summary states that reviews will be performed of a. VOP Revision 2 was uploaded to item A-01c for reference. Section Open Summary V&V for each applicable lifecycle phase for each plan through test. 2 discusses the overall review process, including the relationship to (Deanna Zhang risk ranking and how items are reviewed. Section 7 (specifically Samir Darbali) a. Please explain what these reviews will entail. For example, will all lifecycle Design Artifacts and Programmatic Elements subsections) discusses phase design outputs be reviewed and will the review only cover the WF3 the reviews throughout the life cycle development.
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| project specific application without including the baseline (e.g., Rev. 14 of the .
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| System Requirements Specification of the Common Q Core Protection n summary, the VOP, when executed by WF3, does ensure that Calculator System (0000-ICE-30158))? Westinghouse executes the CPCS system and software lifecycle development consistent with the LAR. The execution of the VOP
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| : b. Will Entergy audit the design change packages performed between the ncludes other processes, and procedure EN-DC-149 is used for previous versions of the System Requirements Specification of the Common owner acceptance of design artifacts.
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| Q Core Protection Calculator System (up to Revision 7) and corresponding design and implementation documentation between those versions? EN-DC-149 Rev 15 "Acceptance of Vendor Documents" attached in MS
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| : b. This question is similar to the question asked in item SA-01b and SDP-04c. These responses to those items describe how the SyRS was reviewed and how previous revisions were handled.
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| Additionally, there was discussion on this topic during the VOP audit meeting on 11/19/2020 15 VOP-05 Vendor oversight VOP Section 3 This section lists a number of vendor oversight activities that will be applied to VOP Revision 2 has been attached to item A-01c for reference. Open activities Summary the programmatic elements. Section 7 (specifically, Programmatic Elements and Quality Assurance subsections) discuss in detail how vendor oversight activities (Deanna Zhang Please explain how the vendor oversight activities correspond to specific correspond to specific programmatic elements.
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| Samir Darbali) programmatic elements.
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| 16 VOP-06 Criterion VII of VOP All, The VOP Summary does not address Appendix B, Criterion VII, Control of a. VOP Audits and WF3 Quality Assurance (QA) surveillances (EN- Open Appendix B to Summary Section 8 Purchased Items and Services and the VOP Summary language is QV-108, QA Surveillance Process) are used in conjunction with the 10 CFR Part 50 inconsistent with Criterion VII. Please explain: CPCS Replacement Project Critical Procurement Plan (CPP), CPP-WF3-2019-002, to provide adequate vendor oversight as defined in the (Deanna Zhang a. whether the surveillances planned are consistent with source Vendor Oversight Plan.
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| Samir Darbali) verification. Source verification needs to be performed at intervals consistent with the importance and complexity of the item or service, Per EN-QV-108, a surveillance is "a process of reviewing or observing and shall include monitoring, witnessing, or observing selected an activity, process, or end product to verify that certain actions have activities. been or are being accomplished to obtain desired results. This OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| : b. how the VOP addresses Control of Suppliers Nonconformances ncludes the terms Monitoring, Observations, Walk-downs, Site including evaluation of nonconforming items, review of Vendor Audit, and Source Verification. A surveillance activity is nonconformances to procurement requirements or purchaser- normally documented as a surveillance report." In addition, approved documents (e.g., technical or material requirement violated, "Surveillances may not be used in lieu of a required audit."
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| requirement in supplier documents, which has been approved by the Purchaser, is violated, purchaser disposition of supplier b. The VOP incorporates the Critical Procurement Plan (CPP-WF3-recommendation, verification of the implementation of the disposition). 2019-002) and specific existing Entergy QA procedures by reference,
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| : c. how supplier evaluation and selection, acceptance of items or ncluding EN-QV-108 (QA Surveillance Process). The CPP ensures services, supplier non conformances, including their evaluation and adequate and timely Supplier QA involvement. Additionally, Work disposition will be documented. Section 8 of the VOP Summary, Tracking items (within Entergy's PCRS program) track development of Documentation, is not clear on this. QA surveillances. Procedure EN-LI-102 controls the Entergy Corrective Action Program.
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| : c. As discussed in VOP-06b, the Critical Procurement Plan (CPP) is ncorporated by reference in the Vendor Oversight Plan (VOP). The CPP provides details Entergy's Supplier QA involvement. Additionally, within the CPP, an evaluation template is used to evaluate the different categories in the project to discrete criteria. If that criteria is not currently available, a tracking action is created to ensure the criteria is evaluated and accepted. The CPP is controlled by Entergy procedure EN-MP-100.
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| 17 RT-01 Response Time LTR 3.2.6 Effect of the CPC Response Time on Thermal Margin Degradation (1) Waterford 3 letters W3F1-2015-0040 [Reference 1] and W3F1- Open 2015-0061 [Reference 2] submitted a control element assembly (Summer Sun, Section 3.2.6 of Attachment 4 in the LAR describes the estimated impact of drop time increase request to the NRC. This request was Samir Darbali) the CPCS delay time on thermal margin degradation. It indicates that the approved under Waterford 3 license amendment 246 [Reference basis of the estimate is the CEA rod drop time LAR submitted in 2015 that 3]. Letter W3F1-2015-0061 provided the limiting events results increased the CEA rod drop time in the safety analysis an additional 200 ms with a control element assembly drop time increase of 200 due to a hold coil delay that needed to be accounted for. The method used milliseconds. The W3F1-2015-0040 and W3F1-2015-0061 results for the CPCS delay time estimate on thermal margin results is to take the can be used to extrapolate the new CPC time impacts on the thermal margin degradation of the CEA rod drop 200 ms delay and then analysis results. The letter W3F1-2015-0061 showed small extrapolate for the increase in CPCS response times. changes for the 200 milliseconds and within the acceptance (1) Discuss acceptability of the extrapolation method used to estimate the limits. It is reasonable to use the same extrapolation to judge that effect of the CPCS delay time on thermal margin degradation. the analysis results will remain within the acceptance limits (i.e.,
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| (2) Identify and justify the values of the CPCS delay times used in the thermal the largest delay is 53.5 msec). In addition, the reload analyses margin estimate for each of the applicable transients and accidents listed will incorporate the new CPC response times to ensure the in Table 3.2.6-1 of Attachment 4. accident analyses thermal margin requirements cover any (3) Discuss what will be done to assure that the values of the CPCS delay analysis impacts.
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| time used in the thermal margin estimate are the limiting values applicable to Waterford 3 when the CPCS is installed for operation. References (4) Discuss and justify what will be done to assure that the thermal margin 1. W3F1-2015-0040, License Amendment Request to Revise estimate for the pre-installed CPCS condition is acceptable, if the values Control Element Assembly Drop Times, July 2, 2015 [ADAMS of the CPCS delay time used in thermal margin estimate are not limiting Accession Number ML15197A106].
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| values. 2. W3F1-2015-0061, Supplement to Revise Control Element Assembly Drop Times Associated with Technical Specification 10/15/2020 Update: 3.1.3.4, August 13, 2015 [ADAMS Accession Number (1.1) Follow-up question to OI 17(1): The last paragraph of the response ML15226A346].
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| states that In addition, the reload analyses will incorporate the new 3. NRC License Amendment 246, Control Element Assembly Drop CPC response times Times, November 13, 2015 [ADAMS Accession Number ML15289A143].
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| Please clarify the methods that will be used for performing the reload analysis. (1.1) The actual WF3 CPCS calculated response times will be used as input for the reload analysis.
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION (3.1) Follow-up question to OI 17(3): The first sentence of the response states that The response times calculated in WNA-CN-00572-CWTR3 (2) The identification and justification for the CPCS delay time values for the CPCS are bounded by the current response time requirements in the thermal margin estimate for each applicable transient and specified in the reference design (00000-ICE-30158). accident listed in Table 3.2.6-1 is documented in Westinghouse document LTR-GIC-20-003, Waterford 3 CPCS Response Time Please clarify the adequacy of the response time requirements Information for FSAR and Technical Specification. A 2nd specified in the reference design in terms of the thermal limits (i.e., document, WNA-CN-00572-CWTR3, Core Protection Calculator DNBR and LHGR) calculation. System Response Time Calculation provides the response time calculation for the WF3 CPCS. Both of these can be submitted to the NRC.
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| WNA-CN-00572-CWTR3, Core Protection Calculator System Response Time Calculation was attached to the LAR. LTR-GIC-20-003, Waterford 3 CPCS Response Time Information for FSAR and Technical Specification is on the Westinghouse document portal.
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| See OI 26 (h)
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| (3) The response times calculated in WNA-CN-00572-CWTR3 for the CPCS are bounded by the current response time requirements specified in the reference design (00000-ICE-30158). The response time testing conducted during FAT and post installation testing will confirm that the system meets these response time criteria.
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| (3.1) It is LTR-GIC-20-003 that correlates the response time calculated in WNA-CN-00572-CWTR3 to the various CPCS trips.
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| LTR-GIC-20-003 describes the adequacy of the new response time requirements. After further investigation, it was determined that the revised calculated response times are not bounded by the reference design, and the WF 3 SyRS, WNA-DS-04517-CWTR3, needs to specify these new response time requirements. A Westinghouse Corrective Action Issue Report (IR-2020-11971) was issued accordingly. A new revision 5 of WNA-DS-04517-CWTR3 with the new response time requirements is now issued.
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| The Licensing Technical Report is not impacted by this revision because the LTR only referred to the Palo Verde response times and stating that WF3 specific response times would be calculated.
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| Resolution. WNA-DS-04517-CWTR3, Revision 5 will be docketed by 12/31/2020.
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| (4) LTR Section 3.2.6 states, As part of the normal fuel reload process, Waterford runs the safety analysis of record with the WF3 CPCS calculated response times to validate that acceptable margin is maintained. It is the fuel reload process performed under 10 CFR 50.59 that evaluates the results of the rerun of the safety analysis prior to core reload. If the results become more limiting, the analyses results will be evaluated against the 10CFR50.59 criteria. If the 10CFR50.59 criteria requires NRC OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION approval, then a new submittal will be generated. Based upon previous analysis impacts, it is expected that the response time changes will be covered in the reload under 50.59.
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| In addition, Waterford 3 letter W3F1-2015-0062 [Reference 1] NRC request for additional information question #8 describes the Westinghouse reload process.
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| Reference
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| : 1. W3F1-2015-0062, Control Element Assembly Drop Times Submittal Request for Additional Information, September 23, 2015
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| [ADAMS Accession Number ML15268A019].
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| 18 CCF-01 CCF LTR Common Cause Failure Analysis (updated 10/05/2020) (a) The intent of the new paragraphs in Enclosure to Entergy letter Open 3.2.18 number W3F1-2020-0038, dated July 23, 2020, Section 3, Technical (Summer Sun, Section 3.2.18 of Attachment 4 in the LAR discusses the common cause Evaluation, sub-section 2, Licensing Technical Report (LTR) is to Samir Darbali, failure (CCF) analysis and indicates that the original licensing basis for WF3 credit the WF3 ATWS instead of the ANO-2 and PVNGS SEs Richard Stattel, assumes a potential CCF of the CPCS and that the replacements of the described in Attachment 4 of the Enclosure to Entergy letter number Jack Zhao) current digital CPCS with the Common Q platform does not change the WF3 W3F1-2020-0038 (WCAP-18484-P, Licensing Technical Report for licensing basis for defense in depth and diversity (D3) (see LTR page 3-60). the Waterford Steam Electric Station Unit 3 Common Q Core In support of the D3 CCF analysis for WF3 CPC updates, the licensee quoted Protection Calculator System"). The W3F1-2020-0038 Enclosure the NRC safety evaluation (SE) approving the CCF analysis for the Arkansas Section 3, Technical Evaluation, sub-section 2, provides the Nuclear One, Unit 2 ANO-2 original CPC design and Palo Verde Nuclear justification of the acceptability of crediting ATWS for CPCS failure to Generating Station (PVNGS) CPC replacements (see LTR pages 3-61 and 3- trip due to a CCF.
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| 62).
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| (b) Background.
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| LAR Section 2. Licensing Technical Report (LTR), paragraphs 3 - 8 credit 1. The of the ANO-2 CPCS to perform its normal function was the WF3 Anticipated Transients Without Scram (ATWS) Mitigation Systems considered by the NRC and documented in NUREG 0308 described in FSAR Chapter 7.8. These paragraphs were added after the draft Supplement 1, "Safety Evaluation Report related to the operation of LAR review pre-application meeting discussions regarding LTR Section Arkansas Nuclear One, Unit 2, dated June 1978. Supplement No. 1 3.2.18. to Appendix D of the Safety Evaluation Report documents the basis for the NRCs approval. In summary, analog backup trips exist for five (a) Please explain if the intent of the new paragraphs in LAR Section 2 is to (5) of the six (6) credited events, as well as 5 other events. The CEA credit the WF3 ATWS instead of the ANO-2 and PVNGS SEs (LTR pages 3- misoperation event does not have a backup analog reactor trip.
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| 61 and 3-62). Automatic reactor trips have not been provided in previous Combustion Engineering protection system designs for this event. In In a public meeting held September 22, 2020, the licensee discussed open the unlikely event that a CEA deviation event, which required a item 18, Common Cause Failure Analysis, and indicated that it would rely on reactor trip, occurred without a CPC trip, the operator would get the information related to the ATWS mitigation systems in FSAR Section 7.8 alarms from COLSS on CEA position and flux tilt similar to the non-to address the open item 18 for the CCF analysis. CPCS plants. Operators could then initiate a manual trip. The conclusion documented in Appendix D of Supplement 1, Section D.2 (b) Since the licensee is crediting ATWS, please describe how the ATWS is that the backups to the CPCS failure to trip at ANO-2 are analysis is sufficient to address a CCF failure of the replacement CPCS for acceptable.
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| the events which credit the CPCS.
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| : 2. In NUREG 787, "Safety Evaluation Report related to the operation (c) Please discuss the current technical and licensing basis for the current of Waterford Steam Electric Station, Unit No. 3," dated July 1981, digital CPCS and whether the Common Q platform maintains this technical Section 7.2.3, the NRC wrote:
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| and licensing basis for defense in depth and diversity (D3).
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| The CPCs were not reviewed, per se, at Waterford 3. The staff has (d) Please address inconsistencies in the LAR and Section 3.2.18 of the LAR taken the operating experience of ANO-2, the previous review, and Attachment 4 to reflect the information used for supporting the D3 discussion acceptance of the ANO-2 CPCs, and the similarity of the Waterford 3 related to CCF of the CPCS. and ANO-2 CPCs, into account in reaching this decision.
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION 10/28/2020 Update: 3. In NUREG 0787 Supplement 5, Section 4.4.2 dated June 1983, the NRC indicated that the CPCS/CEACs are essentially the same as the (d.1) The second paragraph in LAR Section 3, sub-section 2, Licensing ANO-2 Cycle-2 CPCs and since the ANO-2 CPC/CEAC were Technical Report (LTR), refers to LTR Section 3.2.18 and the ANO-2 and approved by the NRC staff (July 21, 1981 Memorandum), the review PVNGS evaluations. Please explain if this paragraph will also be revised. of the Waterford 3 CPC/CEAC concentrated on the software modifications and its implementation. Because there is no additional documentation in any of the subsequent supplements, the implicit 11/10/2020 Update: conclusion is that the acceptability of the CPCs failing to meet design (c.1) The response to item (c) suggests that conformance with BTP 7-19 is not function at ANO-2 also applies to Waterford 3.
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| required. However, LAR Section 4.1 Applicable Regulatory Requirements/Criteria lists BTP 7-19. LTR Section 3.2.18 also identifies BTP 4. FSAR Section 7.2.1 describes the Reactor Protection System 7-19. Please clarify if the LAR and LTR will be revised to remove references (RPS). FSAR Section 7.2.1.1.8 describes how the system is designed to BTP 7-19? to eliminate credible multiple channel failures originating from a common cause. This section applies to all of the RPS, which includes CPCs. This section is unchanged since Revision 0 of the FSAR (circa 1985)
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| Discussion The CPC digital upgrade project does not alter how the diversity within the RPS is achieved, as described in the FSAR 7.2.1.1.8.
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| However, industry and regulatory developments over the past 35 years have provided further improvements to address reactor protection systems common cause failures. The most noteworthy is the Anticipated Transient Without Scram (ATWS) rule (i.e., 10 CFR 50.62). Implementation of the ATWS Mitigation System is described in FSAR section 7.8. The system is designed to mitigate the consequences of Anticipated Operational Occurrences (AOOs) coupled with a failure of the RPS to trip the reactor. The Diverse Reactor Trip System (DRTS) provides an independent means of sensing a high pressurizer pressure and then de-energizing the MG set output contactor coils that provide the power to the Control Element Drive Mechanisms, and subsequently trip the reactor.
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| The NRC provided the acceptance for the Waterford 3 ATWS mitigating systems design in the Safety Evaluation dated September 8, 1989 (ML8909180108). The NRC inspection of Compliance with the 10 CFR 50.62 (ATWS Rule) is documented in Inspection Report 89-39 dated December 5, 1989 (ML8912110063). There were no violations or deviations noted in the report concerning the implementation of the ATWS system at Waterford 3.
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| The ATWS system at Waterford 3 is a more rigorous backup to a postulated common cause failure of the CPCS relative to reliance on the NRC's evaluation of a similar system at ANO-2. The ATWS system at Waterford 3 is plant specific, incorporated in the design basis, and is continually evaluated as the overall plant design evolves. Both the extended power uprate and replacement steam generator projects resulted in evaluations of the ATWS mitigating systems to ensure the major plant changes did not negatively impact the ATWS systems (SGT-LTR-TDA-09-20, Evaluation of Anticipated Transients Without Scram (ATWS) Rule Compliance for Waterford 3 with RSGs and a Full Core of NGF Fuel OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION Conclusion The function of the CPCS to calculate and provide LPD and DNBR trip signals to the RPS to prevent fuel damage during AOOs is unchanged. The features of the RPS which provide analog trips as a backup to failure of the CPCS to cause trips is unchanged as a result of the CPCS digital upgrade project. However, since initial startup of Waterford 3, the implementation of the ATWS rule provides complete protection of the fuel for AOOs that should result in the RPS tripping the reactor. The ATWS systems are independent from the RPS, have been inspected by the NRC and continually evaluated for impacts as the plant design evolves.
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| (c) Entergy Update 11/3/20 The technical and licensing basis for the existing CPCS are the following sections of the WF3 UFSAR:
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| * Chapter 7.2 (Since the CPCS is an integral part of the Reactor Protective System, the CPCS basis is described throughout the section. Note Section 7.2.1.1.8 establishes the licensing basis for diversity against a predictable common failure mode)
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| * Appendix 4.3A.5.2 & 4.3A.5.3 To summarize what is described in UFSAR Chapter 7.2.1.1.2.5, the basic architecture for the CPCS is a four channel computer system (i.e., Core Protection Calculator [CPC]) that calculates these parameters and initiates reactor trip signals to the analog reactor protection system. This basic architecture also includes two computers (CEAC 1 and CEAC 2) that calculate a CEA position penalty factor used by all four CPC computers.
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| The WF3 I&C architecture mirrors the echelons of defense described in NUREG 6303, Method for Performing Diversity and Defense-in-Depth Analyses of Reactor Protection Systems, to protect the health and safety of the public. The first echelon is the non-safety control systems which controls the nuclear plant process within its technical specification limits. The second echelon of defense is the plant protection system to automatically shutdown reactivity and provide heat removal in case of an accident. And the third echelon of defense is the manual indications and controls to allow operators to manually control the plant. In addition to these echelons of defense, there is an ATWS system to protect the health and safety of the public should an anticipated transient occur without a scram.
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| This plant modification only impacts the second echelon of defense, the plant protection system, and in particular the reactor protection system. The WF3 operating license allows for a computerized digital system to calculate and initiate a reactor trip on low DNBR and High LPD in support of the WF3 accident analysis, as described in the WF3 UFSAR Chapter 7.2.1.1.2.5. As summarized above and OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION described in detail in WF3 UFSAR Chapter 7.2.1.1.2.5, the basic architecture for this aspect of the reactor protection system is a four channel computer system (i.e., CPC) that calculates these parameters and initiates reactor trip signals to the analog reactor protection system. This basic architecture also includes two computers (CEAC 1 and CEAC 2) that calculate a CEA position penalty factor used by all four CPC computers. This plant modification does not invalidate the diversity claims in UFSAR Section 7.2.1.1.8.
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| The Common Q CPCS upgrade preserves this basic architecture but improves upon it by multiplying the number of CEAC computers from two to eight (2 in each channel) to improve system reliability. There are still four independent CPC channels calculating DNBR and LPD as in the existing architecture. Therefore the D3 strategy for WF3 is not impacted by this plant modification.
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| There are no plans at this time to replace any of the non-safety plant control systems with the Common Q platform which could potentially impact the WF3 D3 strategy. Should the PPS be replaced with a digital system, then compliance to BTP 7-19 would be required.
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| (d) Attachment 4 of the Enclosure to Entergy letter number W3F1-2020-0038 (WCAP-18484-P, Licensing Technical Report for the Waterford Steam Electric Station Unit 3 Common Q Core Protection Calculator System"), Section 3.2.18 will be revised to delete reference to the ANO-2 diversity analysis and refer to the LAR for the D3 assessment for the Common Q CPCS.
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| (d.1) Yes, LAR Enclosure Section 3.2, Licensing Technical Report (LTR) will be revised as part of a LAR Supplement. The following paragraph will be deleted:
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| "LTR Section 3.2.18 describes the NRC evaluation of the first CPCS at Arkansas Nuclear One, Unit 2 (ANO-2) in NUREG-0308, "Safety Evaluation Report Related to the Operation of Arkansas Nuclear One, Unit 2," Supplement 1 (i.e., the ANO-2 NRC SER) in regards to CPCS Common Cause Failure (CCF). This was also the evaluation the NRC staff referred to in their PVNGS safety evaluation for the Common Q CPCS upgrade license amendment (Reference 6.10, Section 3.4.6.11). The NRC cited the ANO-2 evaluation to conclude, in part, that CCF is adequately addressed for the Common Q CPCS replacement for PVNGS. The Waterford LTR included this as part of the reference design licensing precedence."
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| (c.1) In LAR Section 4.1, "Applicable Regulatory Requirements/Criteria", under the bullet, "The applicable portions of the following branch technical positions within NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition" (SRP), Chapter 7, "Instrumentation and Controls," as follows:"; the sub-bullet "Branch OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION Technical Position 7-19, "Guidance for Evaluation of Diversity and Defense-In- Depth in Digital Computer-Based Instrumentation and Control Systems", will be removed.
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| In regards to the LTR, Section 3.2.18, "Common Cause Failure (CCF)", the 1st paragraph in that section will be deleted removing the citation to BTP 7-19.
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| 19 TS-01 Clean TS pages Encl, Att 2 Cover Clean TS Pages The information on the coversheet of Attachment is incorrect. The Closed to RCI page Markup page is correct. There is no intention to submit a corrected RCI (Tarico Sweat, Attachment 2 cover page lists 3/4 2-6a as a clean TS page; however, the coversheet.
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| Audrey Klett, mark-up and submitted clean page is numbered 3/4 2-6, not 3/4 2-6a.
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| Samir Darbali)
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| Confirm that this was a typo and that the Attachment 2 list entry should be 3/4 2-6 and not 3/4 2-6a.
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| 11/20/20 Update:
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| PROPOSED DRAFT RCI: The cover page for Attachment 2 lists 3/4 2-6a as a clean TS page; however, the mark-up and submitted clean page is numbered 3/4 2-6, not 3/4 2-6a. The NRC staff requests the licensee to confirm that the page number (3/4 2-6a) listed in the Attachment 2 cover page was a typographical error and that page 3/4 2-6 is the correct page number.
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| 20 TS-02 Marked up and Encl, Att 1 Cover Marked up and Clean TS Pages The change to TS 3.10.2 is partially described in the table on page 11 Closed to RAI Clean TS pages Encl, Att 2 pages of 27 in the Enclosure to W3F1-2020-0038. The table entry for TS RAI The cover page of Attachment 1 lists page 3/4 10-2 as having mark-ups; 3.10.2 will be enhanced to indicate that the editorial change for (Tarico Sweat, however, the marked up version of this page is not provided in the LAR. The "Functional Unit 15" to "Functional Unit 9c" occurs four times on the Audrey Klett, cover page of Attachment 2 lists page 3/4 10-2, however, a clean version of page, as shown on the markup. (see below).
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| Samir Darbali) this page is not included in Attachment 2 (assuming that the licensee intended to provide a mark-up of page 3/4 10-2). TS 3.10.2 is being revised in four places to replace "Functional Unit 15" with Functional Unit 9c". This is purely editorial as a result of the NRC staff requests the licensee to confirm whether it intended to propose changes to TS 2.2.1 and 3.3.1 described above, which redesignated changes to this TS page and, if so, to provide the proposed marked up and the CPCs as Functional Unit 9c in Tables 2.2-1 and 3.3-1.
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| clean TS pages.
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| The Markup and Clean copies were inadvertently absent from the LAR 11/20/20 Update: submittal and will be provided along with the revised table entry with PROPOSED DRAFT RAI: The cover page of Attachment 1 lists page 3/4 10- the next docketed CPC correspondence. Copies attached to this 2 as having mark-ups; however, the marked up version of this page is not response.
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| provided in the LAR. The cover page of Attachment 2 lists page 3/4 10-2, however, a clean version of this page is not included in Attachment 2 (assuming that the licensee intended to provide a mark-up of page 3/4 10-2).
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| The NRC staff requests the licensee to licensee to confirm whether it intended to propose changes to this TS page and, if so, to provide the proposed marked up and clean TS pages, as applicable.
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| 21 EQ-01 Oversight of EQ VOP In the earlier pre-submittal meetings, the licensee stated that it would include The VOP Summary (included with the LAR) Section 5.1, Critical Closed Audit the EQ Summary the equipment qualification (EQ) for some unqualified items as a licensee Characteristics, includes Environmental Critical Characteristics. In part of the (Jack Zhao, commitment. But, in the final pre-submittal meeting, the licensee did not addition, VOP Section 5.2, Design Artifacts, includes review of VOP Deanna Zhang, include the commitment and stated that EQ would be performed as part of the Westinghouse design documents. This section provides examples of Samir Darbali) VOP. The VOP Summary does not describe how the VOP will cover the Westinghouse design documents including the System Requirements equipment qualification for the unqualified items. Please clarify which VOP Specification (SyRS), Software Requirements Specification (SRS), etc.
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| Summary section includes the oversight of EQ. Another example, not listed, includes the Equipment Qualification Summary Report (EQSR).
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION Note that VOP Section 7, Determine Performance Measures and Acceptance Criteria, includes oversight of EQ. The Environmental Critical Characteristics section includes acceptance criteria which will be evaluated as part of vendor oversight. In addition, the Design Artifacts section includes a review of the Westinghouse Equipment Qualification Summary Report (EQSR) per Entergy procedure EN-DC-149, Acceptance of Vendor Documents.
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| 22 EQ-02 GDC 4 LAR Please clarify why the applicable GDC 4 was not addressed and evaluated in A LAR Supplement will contain a revision to LAR Section 4, Closed (V)
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| Section 4 Section 4 of the LAR. Regulatory Evaluation. This revision will include the following:
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| (Jack Zhao, Samir Darbali) "10 CFR 50, Appendix A, GDC 4 requires that the core protection calculator system (CPCS) be designed and qualified to operate under the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents. The protection system shall also be appropriately protected against dynamic effects. The CPCS equipment qualification s contained in the Equipment Qualification Summary Report (EQSR) which is referenced in the LTR (Reference 35)."
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| 23 EQ-03 CPCS Attachme In Section 2.1 it says that the CPCS primary digital components identified in The following components are covered by the subsequent EQSR: Closed components Not nt 11, Table 2.1-1 are addressed. Please list the components which are not ((
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| Listed in Table Section addressed in Attachment 11.
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| 2.1-1 2.1 (Jack Zhao, Samir Darbali)
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| ))
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| 24 EQ-04 EQ assessments Attachme In Section 3 it says that an assessment was performed for seismic, References 10 and 11 will are now in the Westinghouse ERR. Open This item can nt 11, environmental, and EMC qualification in Reference 10 and 11 of Attachment. be closed after (Jack Zhao, Section 3 But, except the conclusion statement in Attachment 11, no summary of these (PDF files CN-EQT-19-11_Revision_0.pdf and CN-EQT doc. CN-EQT-Samir Darbali) assessments is provided. 12_Revision_0.pdf are in the Westinghouse ERR under the folder 20-2 and CN-
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| "Open Item 24 (EQ-04)".)
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| Please place on the portal either References 10 and 11 or their assessment EQT-20-05 are summaries for the staffs evaluation. UPDATE: References 10 and 11 have since been superseded by CN- docketed.
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| EQT-20-2 and CN-EQT-20-5. CN-EQT-19-11 and CN-EQT-19-12 are (Depending on the information contained in these references, either excerpts referenced by CN-EQT-20-2 and CN-EQT-20-5. EQ-QR-412-CWTR3 or the entire of documents mentioned in the response may need to be only references CN-EQT-20-2 and CN-EQT-20-5. Westinghouse docketed.) recommends only docketing CN-EQT-20-2 and CN-EQT-20-5.
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION 25 EQ-05 Licensees EQ Attachme In Attachment 11, it says a few times that the qualification of all components (a) The LTR, Section 4, states, Further equipment qualification testing Closed Summary Report nt 11 used in the final CPCS design will be addressed in the CPCS equipment and/or analysis of lower level CPCS equipment such as HSL (V) for CPCS qualification summary report for Waterford Unit 3 and will not be addressed in modems, power supply assembly, interposing relays is required this report (i.e., Attachment 11). However, according to Section D.3 of ISG- after the detailed hardware design is complete.
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| (Jack Zhao, 06, which says that The NRC staff should verify that the licensee has Samir Darbali) demonstrated that the system will perform its safety functions under the Attachment 11 summarizes the generic qualification performed on design-basis conditions at the location in which the equipment will be the Common Q platform to demonstrate that the platform can meet installed. This information should be found in equipment qualification test site environmental requirements. The subsequent EQSR is to plans, methodologies, and test reports. summarize the EQ for the detailed design implementation of the CPCS. (See the response to OI #23)
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| (a) Please explain the difference between Attachment 11 (Qualification Summary Report for Waterford Unit 3) and the CPCS equipment (b) The EQ Summary report referenced in the LTR, EQ-QR-400-qualification summary report for Waterford Unit 3 being referred to. CWTR3, Rev 0, "Core Protection Calculator System Primary Digital Components Qualification Summary Report for Waterford Unit 3" was (b) Please explain when the licensees CPCS equipment qualification attached to the LAR.
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| summary report will be submitted for evaluation.
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| The EQ Summary report for additional items, EQ-QR-412-CWTR3, (The EQ Summary report for additional items, EQ-QR-412-CWTR3, Revision Revision 0, "Core Protection Calculator System Upgrade Project 0 mentioned in the response may need to be docketed.) Equipment Qualification Summary Report for Waterford Unit 3" is now available and is in the Westinghouse ERR per request A-01 n.
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| UPDATE: EQ-QR-412-CWTR3, Revision 1 will be docketed by 12/31/2020.
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| 26 A-01 Audit Audit Documents #1: Please have the following information readily available Comments from the licensee or staff on each portal document. Open Audit Documents and accessible for the NRC staffs review via an internet-based portal:
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| : a. Provided in the WEC SharePoint Everyone a. Licensee documentation of Common Q platform changes b. Waterford 3's Vendor Oversight Plan (VOP-WF3-2019-00236) assessment activities performed in accordance with PSAI 6.17 Revision 2 has been uploaded to this response. Of particular response. (See WCAP-18484 LTR Section 6.2.2.16) note, VOP section 7 discusses how WF3 will review the
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| : b. Common Q Record of Changes document - Updated version of Common Q record of changes (Physical Critical Characteristics Reference 19 to the Common Q platform safety evaluation, (ADAMS subsection), how WF3 will verify Westinghouse complies with accession No. ML20020A003) (Reference 13 of LAR). requirements in the SPM (Design Artifacts and Secure
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| : c. The VOP and other documents that are referenced in the VOP that Development Environment subsections), and documents that the encompass the licensees plan for performing oversight of the vendor response time will be confirmed to meet the SyRS (Performance for the development of the CPCS. These documents should Critical Characteristics subsection).
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| demonstrate how the licensee will perform vendor oversight in relation c. Located in WEC SharePoint to the following system and lifecycle development activities: d. Located in WEC SharePoint o Review of the current Common Q Record of Changes e. See Attachment 1 of the VOP and WEC SharePoint Entergy o Verification that Westinghouse complies with the requirements Uploaded Organization chart to IMS (11/3/20 Update) in the SPM for a secure development environment f. Entergy Uploaded to IMS (11/3/20 Update) o Equipment Qualification g. Provided in response to OI 17.2, WEC Uploaded to SharePoint o Verify that Westinghouse properly propagates the response (11/3/20 Update) time requirements through the design, implementation, and test h. There is not a WF3 CPC project-specific Software Safety Plan, of the replacement CPCS Section 3, Software Safety Plan, of the Common Q Software Program Manual is followed. WCAP-16096-P R5 is the SPM
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| : d. Software Development Plan for the Core Protection Calculator used for the CPC project.
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| System Upgrade, WNA-PD-00594-CWTR3
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| . In some cases the SPM requires project-specific plans (e.g., Test
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| : 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
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| : f. Westinghouse organization chart, as referenced in LTR Section plan in Section 3 of the SPM. So, there is no WF3 CPC project-5.2.12, Software V&V Processes specific Software Safety Plan, Section 3, Software Safety Plan, of OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| : g. Control Panel 7 & 2 Cyber Security Door Lock Plan, ENT-WF3- the Common Q Software Program Manual is followed for the CPC-115 project.
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| : j. Located in WEC SharePoint New for 9/30/2020 k. Provided in the WEC SharePoint
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| : h. Document that identifies and justifies the values of the CPCS delay l. WEC Uploaded to SharePoint (11/3/20 Update) times used in the thermal margin estimate for each of the applicable m. Provided in the WEC SharePoint transients and accidents listed in Table 3.2.6-1 of Attachment 4. n. Provided in the WEC SharePoint
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| : i. N/A Software Safety Plan for the Core Protection Calculator System o. Entergy Uploaded to IMS (11/3/20 Update)
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| Upgrade p. Entergy Uploaded to IMS (11/3/20 Update)
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| : q. Entergy Uploaded to IMS (11/3/20 Update)
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| : j. SPEC-10-00001-MULTI, 73.55 Fleet Strategy Implementation -
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| : r. Entergy Uploaded to IMS (11/3/20 Update)
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| Fiber Optic Cable Common-Procurement Specification (Reference 40
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| : s. Entergy Uploaded to IMS (11/3/20 Update) of the LTR)
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| : t. Entergy Uploaded to IMS (11/3/20 Update)
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| : k. AC160 CPU Loading Restrictions, Document Number AN03007Sp u. Entergy Uploaded to IMS (11/3/20 Update)
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| (SyRS Reference 1.4.2.12) v. WEC Uploaded to SharePoint (11/3/20 Update)
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| : w. Located in IMS New for 10/15/2020 x. Located in WEC SharePoint
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| : 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
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| : m. WF3 Project Quality Plan aa.
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| bb. Located in WEC SharePoint New for 10/28/2020 cc. Located in WEC SharePoint
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| : n. Subsequent EQSR (see open item 23) dd. Located in WEC SharePoint
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| : o. Waterford Unit 3 Common Q Implementation - Non-LOCA ee. Located in WEC SharePoint Evaluation of Updated CPCS ff. Located in WEC SharePoint Response Times, LTR-TA-20-4, Revision 0 (LTR Reference 24) gg. Located in WEC SharePoint
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| : p. PO 10587546 - CPC, CEAC, CEAPDS Single Channel and Four hh. Located in WEC SharePoint Channel Components ii. Located in WEC SharePoint jj. Located in WEC SharePoint
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| : q. PO 10591996 - Input / Output (I/O) Simulator Components kk. Located in WEC SharePoint
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| : r. SPEC-18-00005-W, Rev 0 ll. Located in WEC SharePoint
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| : 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
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| : t. EN-MP-100, Critical Procurements oo. Located in WEC SharePoint
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| : u. EN-DC-115, Engineering Change Process pp.
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| : v. EN-IT-104, Software Quality Assurance Program qq. Located in WEC SharePoint rr. Located in IMS
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| : 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
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| : x. EN-DC-149, Acceptance of Vendor Documents ww. Located in IMS
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| : y. Waterford 3 Core Protection Calculator System Safety Function xx. Located in IMS Table, LTR-TA-19-154, Revision 0 yy. Located in IMS
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| : z. Entergy Quality Assurance Program Manual zz. Located in IMS aaa.
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| bbb.
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| New for 12/07/2020 aa. Entergy Specification SPEC-18-00005-W, Revision 0, Core Protection Calculator Purchase Specification, April 2, 2019.
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION bb. Westinghouse Letter CWTR3-19-21, Revision 2, Transmittal of Westinghouse Final Compliance Matrix for SPEC-18-00005-W, June 28, 2019.
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| 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.
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| 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.
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| 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.
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| ff. Westinghouse Document 00000-ICE-37778, Revision 0, Qualification Summary Report for the PVNGS Common Q Based CPCS.
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| gg. Westinghouse Document 00000-ICE-37764, Revision 4, Summary Qualification Report of Hardware Testing for Common Q Applications.
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| hh. Westinghouse Document 00000-ICE-37773, Revision 0, Supplemental Qualification Test Report for Common Q Applications.
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| ii. Westinghouse Document CN-EQT-20-7, Revision 0, Seismic Evaluation of Waterford Unit 3 Auxiliary Protection Cabinet, May 11, 2020.
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| 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.
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| kk. Westinghouse Test Report, EQLR-463, Revision 0, Electromagnetic Compatibility Report for the Waterford 3 Core Protection Calculator Upgrade Equipment, August 2020.
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| ll. Westinghouse Document EQLR-470, Revision 0, Mild Environment Test Report for the Core Protection Calculator System Equipment, September 2020.
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| mm. Westinghouse Document EQ-TP-496-CWTR3, Revision 0, Environmental Test Procedure for the Core Protection Calculator System Equipment, June 2020.
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| nn. Westinghouse Document EQLR-475, Revision 0, Seismic Qualification Test Report for the Core Protection Calculator System Equipment, September 2020.
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| oo. Westinghouse Document EQ-TP-499-CWTR3, Revision 0, Seismic Test Procedure for the Core Protection Calculator System Equipment, July 2020.
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| pp. CN-EQT-20-2 (see OI#32) qq. Human Factors Engineering Guideline for the Common Q Display System, WNA-IG-00871-GEN, Westinghouse Electric Company LLC (HFE) rr. NMM Procedure EN-DC-163, Human Factors Evaluation (HFE) ss. NMM Procedure EN-TQ-212, Conduct of Training and Qualification (HFE) tt. NMM Procedure EN-AD-101, NMM Procedure Process (HFE)
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION uu. NMM Procedure EN-TQ-201, Systematic Approach to Training Process (HFE) vv. NMM Procedure EN-DC-115, Engineering Change Process (HFE) ww. LO-HQNLO-2018-00081, CPCS Benchmarking Report (HFE) xx. LO-HQNLO-2019-00086, CPCS Benchmarking Report (HFE) yy. NMM Procedure EN-PL-101, Entergy Nuclear Organization and Functional Structure (HFE) zz. NUREG 0787 New for 02/01/2021 aaa. WEC EQLR-483, Revision 0, Mild Environment Test Report for the Auxiliary Protective Cabinet MUX Assembly, November 2020.
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| bbb. WEC EQ-TP-508-CWTR3, Revision 0, Environmental Test Procedure for the Core Protection Calculator MUX Assembly, September 2020.
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| New for 02/12/2021 ccc. LTR Reference 54, WNA-AR-00861-CWTR3, Software Hazard Analysis for the Core Protection Calculator System Upgrade Project 27 A-02 Audit Activities 1. Requirements Traceability Demonstration - show how requirements from Audit the reference CPCS design (Palo Verde) SyRS (00000-ICE-30158) and the Everyone WF3-specific delta SyRS (WNA-DS-04517-CWTR3 are traced all the way through testing.
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| 28 A-03 VOP Audit VOP Audit Discussion Requests: (Entergy 11/3/20 Update) See VOP Audit Activities 1. Discuss definitions of acronyms such as FME and DWGS. 1. The acronym FME is Foreign Material Exclusion. The Critical Audit
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| : 2. Discuss responsibilities of Entergy CPCS Project Digital or I&C Procurement Plan describes project considerations in accordance Questions (Deanna Zhang Engineer in Section 5 with Waterford's FME program. Document Samir Darbali) 3. Discuss risks identified in Table 5-1; specifically the risk associated with Hazards The acronym DWGS is for drawings.
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| : 4. Walk through of Section 7 and discuss performance measures, acceptance criteria and their relationships to specific oversight activities 29 SA-02 CPU Load Limit LTR 3-34, 3-35 (( (( Closed (V) RAI 3.2.7.2.7 (Samir Darbali)
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| ))
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| The LTR, Section 3.2.7.2.7 will be updated with the following additional tems:
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| 30 SA-03 CPU Load Limit / (( (( Open RAI VOP Audit (Samir Darbali,
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| Deanna Zhang) 12/10/2020 Update: 30.1 30.1 Please explain if implementation of all system requirements defined in 00000-ICE-30158, Rev 14, System Requirements Specification for the 00000-ICE-30158 (applicable to Waterford 3 CPCS as identified in WNA-DS-Common Q Core Protection Calculator System, was reviewed against 04517-CWTR3) will be ensured via the RTM.
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| WNA-DS-04517-CWTR3 System Requirements Specification for the
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| (( Core Protection Calculator System, Revision 5. Any design requirements from 00000-ICE-30158, Rev 14, that were not identified n WNA-DS-04517-CWTR3, Rev 5, will be reviewed against the RTM
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| )) during the Requirements Phase IV&V VOP Audit, and the Design Phase IV&V VOP Audit. This review will determine if these requirements are included as part of another document, such as WNA-DS-04618-CWTR3, Software Requirements Specification for the Core Protection Calculator System Replacement Project Upgrade, or if a requirement will need to be added to WNA-DS-04517-CWTR3.
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| 30.2
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| 31 EQ-06 Two Open Items EQ-QR- The new EQ Summary Report, EQ-QR-412-CWTR3, Rev. 0 contains two Open Unresolved in 412- open items which have not been resolved in the report. Whats the schedule the New EQ CWTR3, to resolve these two open items and to then revise this new EQ Summary Summary Report Rev. 0 Report accordingly?
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| (Jack Zhao) 32 EQ-07 Reference EQ-QR- Section In Section 3.1 it says that an assessment was performed for existing seismic, Westinghouse Document CN-EQT-20-2, Revision 2, Qualification Open This should be containing the 412- 3.1 environmental, and EMC testing in Reference 11 (CN-EQT-20-2), but only Evaluation of Core Protection Calculator System Equipment for an to get RAI assessment of CWTR3, conclusion statements are included in this new EQ Summary Report without Waterford Unit 3 Auxiliary Protection Cabinet, October 22, 2020 is this requested existing seismic, Rev. 0 adequate supporting information. (To be added to OI #26: Please place now in the WEC ERR. document on environmental, Reference 11 in the portal.) to the docket and EMC testing (Jack Zhao) 33 EQ-08 Different EQ-QR- Sections The Equipment Under Test (EUT) contains different items for the EMC, Open Equipment 412- 4.1, 4.2, environmental, and seismic testing. Please clarify why the EUT is different for Under Test CWTR3, and 4.3 the three types of EQ testing.
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| (EUT) Rev. 0 (Jack Zhao) 34 SA-04 CPP Processor 3.2.2 3-17 LTR Section 3.2.2 describes the CEAC AC160 controller modules and states That is a typographical error in the document. The statement "Two Open RCI CEAC in page 3-17: PM646A CPP processor module" will be replaced by "One PM646A (Samir Darbali) AC160
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| * Two PM646A CPP processor module CPP processor module".
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| Controller 34.1 Please confirm that the Two is a typo and that the correct subsection title is One PM646A CPP processor module.
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| 34.2 Please confirm if this typo will be corrected in a future LTR revision.
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| 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 Open RAI 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 (Summer Sun, Chapter 15 events that credit the WF3 CPCS. engineering analysis, and as such the references listed in LTR-TA-Samir Darbali) 19-154 are the sources of information to inform the analysis.
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| (1) Please confirm that the events that credit the CPCS trips in the FSAR (2) The attached document, LTR-TA-21-17 identifies the backup analysis are limited to those events listed in LTR-TA-19-154, Table A-1. safety-related analog trips for each of the events that credit the (2) Please identify the backup safety-related analog trip for each of the events CPCS. In all cases a backup safety-related analog trip exists except that credit the CPCS. If a backup analog trip does not exist for a specific for the CEA Misoperation - Single Rod Drop / CEA Sub-group Drop event, please identify if an alarm is provided so that manual action can be event. The single CEA and subgroup drop events do not generate a taken. reactor trip.
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| (3) Please reference the sources of information for items (1) and (2) above.
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION (4) LTR-TA-20-4, Waterford Unit 3 Common Q Implementation -Non-LOCA (3) For CCF-02a response: The Reference section of LTR-TA Evaluation of Updated CPCS Response Times (item A-01o on the Certrec 154 is the source of information.
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| portal), Table 1, Waterford-3 Non-LOCA CPCS Trip Signals identifies 13 events that credit the WF3 CPCS. CEA Misoperation - Single Rod For CCF-02b response: LTR-TA-21-17 is the source of information Drop/CEA Sub-group Drop and Uncontrolled Boron Dilution are included in LTR-TA-19-154 but not on LTR-TA-20-4 Table 1. (4.1) LTR-TA-20-4 states, First, the Chapter 15 non-LOCA (4.1) Please explain why these events are not included in LTR-TA transients were screened to identify the impacted events. The 4, Table 1. impacted events only include those that: a) trip via a CPCS trip and b)
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| (4.2) Please explain if the response times for these events are affected have an increased response time. Updated CPCS response times by the Common Q CPCS replacement. that do not result in an increased response time have no unfavorable impact on the non-LOCA analyses and "are therefore not required to 2/2/2021 Update: be evaluated herein. These two events were not included in LTR-TA-20-04 for the following reasons:
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| (5) Please submit LTR-TA-20-4, Waterford Unit 3 Common Q Implementation -Non-LOCA Evaluation of Updated CPCS Response CEA Misoperation - Single Rod Drop/CEA Sub-group Drop falls Times on the docket. under FSAR Section 15.4.1.4 CEA Misoperation. The single CEA and subgroup drop events do not generate a reactor trip, thus the 2/11/2021 Update: increases in CPCS response times due to the Common Q system implementation would not impact these events.
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| (6) Please submit LTR-TA-21-17, Waterford 3 CPCS Safety Function Table -
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| PPS Backup Trips, on the docket. Uncontrolled Boron Dilution falls under FSAR Section 15.4.1.5 CVCS Malfunction (inadvertent boron dilution). The Boron dilution (7) The third column of LTR-TA-21-17, Table A-1 refers to Table 7.2-4 of event is analyzed for all modes of plant operation. The operational Reference 1. Reference 1 (ML19268A136) is for the WF3 FSAR Chapter 15 Modes 1 and 2 inadvertent boron dilution event is bounded by the only, and not the entire FSAR. Chapter 7, which contains Table 7.2-4, is not FSAR Sections 15.4.1.2 and 15.4.1.3 HFP and HZP CEAW events.
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| included as one of the references. The increases in CPCS response times due to the Common Q system implementation would not change the event characteristics, so the inadvertent boron dilution event remains bounded by existing UFSAR events. For the inadvertent boron dilution event in operational Modes 3, 4, 5 and 6, all CEAs have already been inserted. Thus, the increases in CPCS response times due to the Common Q system implementation would have no impact on the inadvertent boron dilution event.
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| (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.
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| 36 RT-02 Response Times (( 36.1 ((
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| (Summer Sun, Samir Darbali)
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| (( ((
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| A figure correlating the columns in both documents is in the Westinghouse ERR under the folder Open Item 36 (RT-02).
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| ))
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| 2/2/2021 Update:
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| (36.2) Please submit LTR-GIC-20-003, Waterford 3 CPCS Response Time Information for FSAR and Technical Specification, on the docket.
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| 37 RT-03 Response Times ((
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| (Summer Sun, Samir Darbali)
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| 2/2/2021 Update:
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| (37.2) Please submit the last revision of WNA-CN-00572-CWTR3 on the docket.
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| OFFICIAL USE ONLY PROPRIETARY INFORMATION More audit activities may be added to OI 26 28 A-03 VOP Audit activities. These are being tracked in a separate file.
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| 29 SA-02 Closed No RAI needed if The LTR, Section 3.2.7.2.7 will be updated.
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| (V) LTR is updated 30 SA-03 Open 31 EQ-06 Open 32 EQ-07 Open RAI RAI will be issued to get the requested document on to the docket 33 EQ-08 Open 34 SA-04 Open RCI 35 CCF-02 Open RAI 36 RT-02 Open 37 RT-03 Open Note: Closed (V) indicates that NRC will need to verify changes to the specified documents after a supplement is received from the licensee.
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| ACRONYMS/ABBREVIATIONS ACRONYM/ DEFINITION ACRONYM/ DEFINITION ABBREVIATION ABBREVIATION A Audit (only used for identification of open items in IMS) MCR Main Control Room ANO Arkansas Nuclear One NRC U.S. Nuclear Regulatory Commission ARP Alternate Review Process OI Open Item Att. Attachment OM Operator Modure ATWS Anticipated Transient Without a Scram PSAI Plant Specific Action Items BTP Branch Technical Position PVNGS Palo Verde Nuclear Generation Station CCF Common Cause Failure/D3 RAI Request for Additional Information CEA Control Element Assembly RC Regulatory Commitments CPP Critical Procurement Plan RCI Request for Confirmation of Information CFR Code of Federal Regulations RT Response Time CPCS Core Protection Calculator System RTM Requirements Traceability Matrix CPU Central Processing Unit SA System Architecture (only used for identification of open items in IMS)
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| D3 Defense in Depth and Diversity SDOE Secure Development and Operational Environment DNBR Departure from Nucleate Boiling Ratio SDP Software Development Plan; System Development Processes, including SPM PSAIs (only used for identification of open items in IMS)
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| DWGS Drawings SE Safety Evaluation Encl. Enclosure SFCP Surveillance Frequency Control Program EQ Environmental Qualification SPM Software Program Manual EQSR Equipment Qualification Summary Report SR Surveillance Requirement FAT Factory Acceptance Testing SRS Software Requirements Specification FME Foreign Material Exclusion ST Surveillance Testing/Self-Diagnostics/SR Elimination (only used for identification of open items in IMS)
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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.
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| 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 OFFICIAL USE ONLY PROPRIETARY INFORMATION
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| [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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| ML21071A286 (Non-Proprietary Meeting Summary)
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| ML21071A285 (Proprietary Meeting Summary)
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| ML21071A288 (Package)
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| OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DSS/SNSB/BC NRR/DRO/IQVB/BC NAME PBuckberg (AKlett for) PBlechman SKrepel KKavanagh DATE 3/12/2021 3/16/2021 3/24/2021 3/29/2021 OFFICE NRR/DEX/EICB/BC NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME MWaters JDixon-Herrity PBuckberg (AKlett for)
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| DATE 3/29/2021 3/29/2021 4/1/2021}}
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