ML20315A267
| ML20315A267 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/17/2020 |
| From: | Audrey Klett Plant Licensing Branch IV |
| To: | Entergy Operations |
| Klett A | |
| References | |
| EPID L-2020-LLA-0164 | |
| Download: ML20315A267 (18) | |
Text
OFFICIAL USE ONLY - PROPRIETARY INFORMATION December 17, 2020 LICENSEE: Entergy Operations, Inc.
FACILITY: Waterford Steam Electric Station, Unit 3
SUBJECT:
SUMMARY
OF OCTOBER 21, 2020, CATEGORY 1 PUBLIC MEETING WITH ENTERGY OPERATIONS, INC. REGARDING LICENSE AMENDMENT REQUEST TO INSTALL DIGITAL UPGRADE IN ACCORDANCE WITH DIGITAL INSTRUMENTATION AND CONTROL INTERIM STAFF GUIDANCE NO. 06, REVISION 2, LICENSING PROCESSES (EPID L-2020-LLA-0164)
On October 21, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff held a virtual Category 1 public meeting with representatives from Entergy Operations, Inc. (the licensee) and Westinghouse Electric Company, LLC. The purpose of the meeting was to discuss the licensees amendment request dated July 23, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20205L588), 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 core protection calculator system with a Common Q-based system. The meeting notice and agenda, dated October 7, 2020, are available in ADAMS under Accession No. ML20281A233. Enclosure 1 is a list of attendees.
During the meeting, the licensee described its progress with the CPCS modification development and its vendor oversight activities. The NRC staff then 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 NRC and licensee asked clarifying questions about the open items and the licensees responses to them. During the closed portion of the meeting, the NRC staff and licensee discussed proprietary information associated with Open Item No. 9, potential audit interview topics, and portal access for auditing vendor documents.
Enclosure 2 to this letter contains proprietary information. When separated from Enclosure 2, this document is DECONTROLLED.
OFFICIAL USE ONLY - PROPRIETARY INFORMATION
OFFICIAL USE ONLY - PROPRIETARY INFORMATION Based on the meeting discussions, the NRC staff updated Open Item Nos. 6, 18, and 26.
The NRC staff has determined that the Open Items list contains proprietary information pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 2.390, Public inspections, exemptions, requests for withholding. The proprietary information is indicated by bold text enclosed within ((double brackets)). The proprietary version of the Open items list is provided as Enclosure 2. Accordingly, the NRC staff has also prepared a nonproprietary version of the Open Items list which is provided as Enclosure 3.
The NRC staff did not make any regulatory decisions or commitments at the meeting. No members of the public identified themselves on the teleconference.
Please direct any inquiries to me at 301-415-0489 or by e-mail to Audrey.Klett@nrc.gov.
/RA/
Audrey L. Klett, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382
Enclosures:
- 1. List of Attendees
- 2. Open Items List (Proprietary)
- 3. Open Items List (Non-proprietary) cc w/o Enclosure 2: Listserv OFFICIAL USE ONLY - PROPRIETARY INFORMATION
Enclosure 1 List of Attendees
LIST OF ATTENDEES OCTOBER 21, 2020, VIRTUAL PUBLIC MEETING WITH ENTERGY OPERATIONS, INC., ET AL.
WATERFORD STEAM ELECTRIC STATION, UNIT 3, LICENSE AMENDMENT REQUEST TO INSTALL DIGITAL UPGRADE U.S. Nuclear Regulatory Commission Entergy Operations, Inc.
Eric Benner, NRR1/DEX2 Jacob Champagne Richard Stattel, NRR/DEX/EICB3 Remy DeVoe Michael Waters, NRR/DEX/EICB Ron Gaston Jack Zhao, NRR/DEX/EICB Loren Miller Samir Darbali, NRR/DEX/ELTB4 Roger Rucker Jeanne Johnston, NRR/DEX/ELTB John Schrage Ian Tseng, NRR/DEX/EMIB5 Christopher Talazac Jennifer Dixon-Herrity, NRR/DORL6/LPL47 William Truss Audrey Klett, NRR/DORL/LPL4 Maria Zamber DaBin Ki, NRR/DRO8/IOLB9 Greg Galletti, NRR/DRO/IQVB10 Deanna Zhang, NRR/DRO/IQVB Sargent and Lundy Summer Sun, NRR/DSS11/SNSB12 Pareez Golub Members of the Public Westinghouse Electric Company, LLC None introduced Warren Odess-Gillett Steven Slowik John Wiesemann 1
Office of Nuclear Reactor Regulation 2
Division of Engineering and External Hazards 3
Instrumentation and Controls Branch 4
Long Term Operations and Modernization Branch 5
Mechanical Engineering and Inservice Testing Branch 6
Division of Operating Reactor Licensing (DORL) 7 Plant Licensing Branch IV 8
Division of Reactor Oversight 9
Operator Licensing and Human Factors Branch 10 Quality Assurance and Vendor Inspection Branch 11 Division of Safety Systems 12 Nuclear Systems Performance Branch
Enclosure 3 (Non-proprietary)
Open Items List Proprietary information pursuant to Section 2.390 of title 10 of the Code of Federal Regulations has been redacted from this document.
Redacted information is identified by blank space enclosed within ((double brackets)).
OFFICIAL USE ONLY PROPRIETARY INFORMATION LAR/
Audit, Topic & LTR LAR/ LTR No. IMS ID NRC Comment / Open Item Description Licensee Response Status RAI or (Reviewer) Secti Page RCI No.
on Certrec IMS Request ID Format (second column of this table)
A- Audit (Generic/Multiple Documents) Updated by Entergy on 10/19/20 CCF-Common Cause Failure/D3 EQ- Equipment Qualification Proprietary Documents will be uploaded to the Westinghouse HFE - Human Factors Engineering Sharepoint site at the below address; PSAI- Plant Specific Action Items RC- Regulatory Commitments ((
- - - - - RT- Response Time - -
SA- System Architecture SDOE- Secure Development and Operational Environment ST- Surveillance Testing/Self-Diagnostics/SR Elimination SDP- System Development Processes, including SPM PSAIs TS- Technical Specifications VOP- Vendor Oversight Plan
))
1 ST-01 Self-Tests B.2.5 B-5 The BTP 7-17 Evaluation conclusion states that It is not possible to test self-diagnostics Open as part of surveillance testing because it would require creating destructive faults within the I&C (Jack Zhao, system, such as Random-Access Memory (RAM) errors.
Richard Stattel, Samir Darbali) Though this is a quote out of the Vogtle LAR safety evaluation, it is a statement made by the licensee and not the NRC to address this criterion in BTP 7-17, self-test functions should be verified during periodic functional tests. The interpretation being made that the BTP criterion calls for complete functional testing of the self-diagnostic functions is incorrect. Instead, the BTP states that the licensee should confirm the execution of self-diagnostic tests during plant operation and the NRC staff believes that it is possible to do so by implementing the following necessary plant monitoring activities as already included in the Enclosure for this LAR.
The licensee (Waterford) has addressed this in the LAR as follows:
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) Technical Requirements Manual (TRM) 3/4.3.1, "Reactor Protective Instrumentation" and associated surveillance procedures; and 3) Waterford TS 6.5.1.8, "Surveillance Frequency Control Program (SFCP). A failure of credited automated diagnostics to detect a fault will be either detected by other diagnostics in the system or by checker(s) of diagnostics. This condition 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 alarm or abnormal conditions, the station operating procedures will require the operators to perform system checks and verify operability of the CPCS deviation / function. The procedure will direct the operator to dispatch a maintenance technician to determine the source of the alarm as needed.
(W3F1-2020-0038 Page 18 of 27)
The NRC staff agrees with the licensees proposed actions in the LAR. So, for this LAR the licensee should cite both the credited self-diagnostic functions in Appendix B and proposed monitoring activities to justify the SR elimination in Section 2.2 of the LAR, not just the Appendix B. However, since Section 2.2 of the LAR cites Appendix B to WCAP-18464 as the sole justification for SR elimination (see Enclosure W3F1-2020-0038, Page 5 of 27) and Appendix B does not include any OFFICIAL USE ONLY PROPRIETARY INFORMATION
OFFICIAL USE ONLY PROPRIETARY INFORMATION plant monitoring activity, it could lead to the misunderstanding that if the NRC accepts this LAR, it would also be accepting Appendix B as the only basis for the SR elimination. In addition, the LAR says on Page 18 of 27, in part, that while LTR Appendix B states that monitoring is not required in order to credit self-diagnostic features. The NRC staff does not agree with this statement to address the above criterion in BTP 7-17. Furthermore, Appendix B says to leverage the Vogtle LAR for the SR elimination. But, the Vogtle LAR included plant monitoring activities as one of bases for the SR elimination. Therefore, the SR Elimination basis in both Section 2.2 of this LAR and Appendix B will need to include the licensees commitment to perform self-diagnostic monitoring activities and the appendix B interpretations should be revised to establish consistency with the LAR.
2 ST-02 Self-Tests B.2.5 B-6 The bullet item on this page states the following: Open (Jack Zhao, ((
Richard Stattel, Samir Darbali)
))
3 ST-03 Self-Tests TS 52/377 Insert C includes the following statement: Open BASE 81/377 (Jack Zhao, S The performance of channel checks validates that the self-diagnostics are continuing to perform their Richard Stattel, mark- self-checking functions.
Samir Darbali) up 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.
4 ST-04 Self-Tests B.7.1 B-39 Appendix B of WCAP 18464 contains the following statement: Open (Jack Zhao, ((
Richard Stattel, Samir Darbali)
))
OFFICIAL USE ONLY PROPRIETARY INFORMATION
OFFICIAL USE ONLY PROPRIETARY INFORMATION 5 ST-05 Self-Tests B.3.2. B-10 The WCAP 18464 states: IEC 60880 is comparable to IEEE 7-4.3.2, and the staff has found IEC 880 Open 1 to be an acceptable equivalent.
(Jack Zhao, Richard Stattel, This was a statement in the NRC original safety evaluation of Common Q which has been Samir Darbali) superseded. The statement has been removed from the current Common Q platform TR safety evaluation report.
The NRC does not consider IEC 880 to be an equivalent to IEEE 7-4.3.2. As such, the NRC evaluates all digital systems to the criteria of IEEE 7-4.3.2.
6 SA-01 Sys. Req. LAR The licensee provided two CPCS System Requirements Specification (SyRS) documents: the (a) As previously described to the NRC during the Acceptance Open Spec. 3.1 reference CPCS design (Palo Verde) SyRS (00000-ICE-30158 (LAR Attachment 7 and LTR Review discussions:
Reference 2)) and the WF3-specific delta SyRS (WNA-DS-04517-CWTR3 (LAR Attachment 8 and
- The intent of the statements in the Enclosure and LTR, as well (Samir Darbali, LTR 3 LTR Reference 21)). as the entire paragraph in the Enclosure, was to communicate Deanna Zhang) 5-1 that the NRC has reviewed the overall design of the replacement LTR 5 The staff noticed that the SyRS for the reference CPCS design (00000-ICE-30158) revision is CPC system in a previous license amendment (i.e., PVNGS 1, 2, Revision 14. The SyRS that was reviewed as part of the Palo Verde CPCS upgrade is Revision 7. and 3, Amendment No. 150; ML033030363).
- It was not Entergy's intent to state, or even suggest, that the The LAR and LTR make several inaccurate statements regarding which revision of 00000-ICE-30158 specific revision of the reference design document that was used was previously reviewed by the NRC. For example: for the Waterford CPC replacement (i.e., Revision 14) has been reviewed by the NRC, or that the NRC's review of the previous LAR Section 3.1 states: The SyRS project document has a reference design document revision (i.e., Revision 7, submitted in ML032830027) could be (Attachment 7), which has been previously reviewed by the NRC, and a delta document used for the NRC's review of the Waterford project. However, (Attachment 8) which describes differences for the Waterford project. Entergy understands how the wording of the statement is ambiguous in this respect.
LTR Section 5, item b. states: The base system requirements for the WF3 CPCS is the CPCS System Requirements Specification (Reference 2), which have already been reviewed Updated 10/19/20 by Entergy by the NRC as part of the Palo Verde CPCS replacement.
(b) To be provided later LTR Section 5.2.4 states As stated earlier, the reference design for the WF3 CPCS replacement is documented in Reference 2. These requirements and their traceability have (c) Slide 37 of the March 19, 2020 pre-application meeting already been reviewed and approved by the NRC as part of the Palo Verde CPCS identified the SyRS as a living document, as defined in ISG-06 replacement. (i.e., a document that will be revised as system development activities progress). This statement refers to only WNA-DS-Again, these statements are inaccurate because the SyRS that was reviewed for the Palo Verde 04517-CWTR3.
CPCS upgrade review is Revision 7 of 00000-ICE-30158. The staff has not reviewed nor performed traceability of requirements for 00000-ICE-30158 after Revision 7. Additionally, the licensee has not demonstrated in the LAR or LTR that they have performed these activities.
Clarification questions:
(a) Are the statements that the NRC staff had previously reviewed the SyRS (00000-ICE-30158) meant as background information, of for crediting the previous evaluation?
(b) Is the licensee performing independent design quality, traceability and other oversight activities for:
o 00000-ICE-30158 Revision 7?
o 00000-ICE-30158 Revisions 8 thru 14?
o or only for the WF3-specific delta SyRS (WNA-DS-04517-CWTR3)?
(c) Slide 37 of the March 19, 2020 pre-application meeting identified the SyRS as a living document, as defined in ISG-06 (i.e., a document that will be revised as system development OFFICIAL USE ONLY PROPRIETARY INFORMATION
OFFICIAL USE ONLY PROPRIETARY INFORMATION activities progress). Please clarify if this statement refers to 00000-ICE-30158, WNA-DS-04517-CWTR3, or both documents.
7 SDP-01 SW Dev Plan LTR Section This section of the LTR states, Any exceptions to the SPM would be documented in the WF3 CPCS Open RAI, 5.1.1 Software Development Plan (Reference 25). The Software Development Plan also includes (Deanna Zhang clarifications to particular items to make clear how certain aspects of the SPM are being fulfilled. Audit Samir Darbali) the For the ARP, ISG-06, Rev 2 provides guidance on what should be submitted. This includes a SW summary of the application software planning and processes. The LTR does not provide sufficient Dev.
information to summarize the differences between the SPM and the WF3 CPCS Software Plan Development Plan in accordance with the guidance of ISG-06, Rev. 2.
Please summarize the differences between the SPM and the WF3 CPCS Software Development Plan.
8 SDP-02 Common Q LTR Section LTR Section 5.1.6 states in part, Appendix 5 of the Common Q Topical Report (Reference 13) is the Updated 10/19/20 by Entergy Open Changes 5.1.6 output document for the change process described in Reference 12. The document provides a summary of changes and then detailed recording of analysis and/or qualification documents, and a The LTR Section 5.1.6 will be revised as follows:
(Deanna Zhang conclusion statement on the status of the change relative to the NRC safety conclusions. Reference Samir Darbali) 13 can be audited by the NRC staff... There have been no changes to the SPM since its approval by the NRC. As a result, the Common Q Record of Changes The response to SPM PSAI 6 refers to the Common Q PSAI regarding the record of changes, but it document will not include any assessments of changes to the does not address the validity of the previously derived safety conclusions if changes have been made SPM.
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).
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.
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.).
9 SDP-04 SW LTR Section This section states in part, The allocation of CPCS reference design system requirements Updated 10/19/20 by Entergy Open Requirements 5.2.5 (Reference 2) to software have already been accomplished as part of the NRC-approved Palo Verde CPCS replacement. The WF3 delta requirement from the reference design are documented in For portion of request:
(Deanna Zhang Reference 21. These are allocated to software as described in Section 5, item c and documented in Samir Darbali) the SRS....Similar to the WF3 system requirements specification, the SRS is independently reviewed, Based on this description, it is not clear whether the RTM only approved and baselined as input to the ongoing life cycle activities. In addition the RTM is updated include requirements on the differences between the WF3 CPCS showing the tracing of software requirements to the WF3 system requirements specification replacement system/corresponding software requirements and (Reference 21). the system requirements/corresponding software requirements in Westinghouse Rev 14 baseline of the CPC system requirements Based on this description, it is not clear whether the RTM only include requirements on the specification or whether it includes all CPCS system differences between the WF3 CPCS replacement system/corresponding software requirements and requirements the system requirements/corresponding software requirements in Westinghouse Rev 14 baseline of the CPC system requirements specification or whether it includes all CPCS system requirements. Response:
Given that (1) the WF3 system requirements specification only includes deltas between the WF3 OFFICIAL USE ONLY PROPRIETARY INFORMATION
OFFICIAL USE ONLY PROPRIETARY INFORMATION CPCS project and the referenced System Requirements Specification of the Common Q Core The RTM only includes requirements on the differences between Protection Calculator System (0000-ICE-30158), Revision 14, and (2) the System Requirements the WF3 CPCS replacement system/corresponding software Specification of the Common Q Core Protection Calculator System (0000-ICE-30158) version that requirements and the system requirements/corresponding was reviewed and approved during the referenced Palo Verde CPCS Digital Upgrade LAR is software requirements in the Westinghouse Rev 14 baseline of Revision 7, it is unclear what types of regression analysis have been performed between the the CPCS requirements specification.
Revision 7 and Revision 14 of the System Requirements Specification of the Common Q Core Protection Calculator System to use Revision 14 as the new baseline for the WF3 CPCS project? It is also not clear whether Entergy performed appropriate oversight on the activities related to addressing the differences between Revision 7 and Revision 14 of the System Requirements Specification of the Common Q Core Protection Calculator System.
10 SDP-03 SW Design LTR Section This section states in part, System Validation Test - this is formal integration testing of the software Open 5.2.8 and hardware performed by the independent test team. The System Validation Test traces the test (Deanna Zhang cases to the WF3 CPCS replacement system requirements specification (Reference 21).
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).
11 VOP-01 Critical VOP Table of It appears that the VOP does not have complete identification of activities for providing oversight of Updated 10/19/20 by Entergy Open Characteristic Sum Contents the project and will only be a plan to develop or determine them while the expectation is to have the s mary activities and associated acceptance criteria completed. Examples include: Per VOP Section 7, "The scope of vendor oversight is expected
- a. Section 6: Development and Assessment of Potential Project and Technical Risk Factors to evolve during the project. Project-specific performance (Deanna Zhang b. Section 7: Determine Performance Measures and Acceptance Criteria (Critical measures that warrant vendor oversight are updated as this list Samir Darbali) Characteristics/Design Artifacts) changes."
It is also not clear what oversight activities are associated with Section 7 of the VOP to verify the The performance measures are divided into three categories:
vendor has satisfied the critical characteristics. Critical Characteristics, Design Artifacts, and Section 2 of the VOP Summary states in part The level of vendor oversight follows a graded Programmatic Elements.
approach, based on project and technical risk factors, which are described in VOP Section 6. All levels of the graded approach will include specifically defined performance measures and As listed in VOP Section 7, the following activities are used to acceptance criteria which are described in VOP Section 7. Based on this description, the project provide oversight of the each category:
and technical risk factors and the performance measures and acceptance criteria for the critical characteristics and programmatic elements should already have been identified in the VOP. This Critical Characteristics:
does not appear to be consistent with the titles of Sections 6 and 7.
" Oversight of critical characteristics utilizes the following vendor It is also not clear based on the title of Section 8 in the Table of Contents for the VOP, what oversight activities:
Implement Appropriate Oversight Methods will entail.
- Conducting vendor audits and quality surveillances
- Reviewing WEC design output documents
- Participating in Factory Acceptance Testing
- Conducting Site Acceptance Testing
- Conducting Post-Modification Testing
- Observing or witnessing specific vendor activities
- Capturing issues in WF3/WEC corrective action programs" Design Artifacts:
"Oversight of the design artifacts utilizes the following vendor oversight activities:
n
- Conducting vendor audits n
- Reviewing WEC design output documents (e.g.,
OFFICIAL USE ONLY PROPRIETARY INFORMATION
OFFICIAL USE ONLY PROPRIETARY INFORMATION specifications, drawings, analyses) n
- Providing input to and review/confirmation of specific vendor activities and related information items n
- Coordinating multi-disciplined interactions between various stakeholders n
- Capturing issues in WF3/WEC corrective action programs" Programmatic Elements:
"Conducting vendor audits n
- Reviewing WEC design output documents n
- Providing input to and review/confirmation of specific vendor activities and related information items n
- Observing or witnessing specific vendor activities n
- Participating directly in specific vendor activities n
- Coordinating multi-disciplined interactions between various stakeholders n
- Capturing issues in WF3/WEC corrective action programs" 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.
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.
12 VOP-02 CPP VOP Section 2 This section of the VOP Summary, states in part, Monitoring, verification and acceptance phase Updated 10/19/20 by Entergy Open Sum activities are defined in the Critical Procurement Plan (CPP) during the Planning Phase. Verification (Deanna Zhang mary can be either through the normal Receipt Inspection process or other activities outlined in the CPP. As indicated in VOP Section 2, Vendor Oversight Plan (VOP)
Samir Darbali) The Critical Procurement Plan provides a summary of the requirements and necessary actions Scope, "The CPCS Replacement Project Critical Procurement including on-site services (when required), to ensure that a critical procurement will meet Entergys Plan (CPP) (Reference 6), prepared under Entergy procedure expectations...The CPP credits the management of procurement risks based on the Westinghouse EN-MP-100, Critical Procurements (Reference 13), is software verification and validation process, factory acceptance testing, performance of site incorporated by reference into the VOP."
acceptance testing, and rigorous software testing. QA surveillances will be performed to ensure the approved Westinghouse processes were followed.
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)?
13 VOP-03 Oversight of VOP Section 3 This section of the VOP Summary, states in part, Some of the SPM plans will have project-specific Open SPM project- Sum instances (i.e., SVVP, SCMP, and Software Test Plan). These project-specific plans will be mary evaluated to ensure they are developed in accordance with the SPM.
OFFICIAL USE ONLY PROPRIETARY INFORMATION
OFFICIAL USE ONLY PROPRIETARY INFORMATION In addition, Waterford 3 letter W3F1-2015-0062 [Reference 1]
NRC request for additional information question #8 describes the Westinghouse reload process.
Reference
- 1. W3F1-2015-0062, Control Element Assembly Drop Times Submittal Request for Additional Information, September 23, 2015 [ADAMS Accession Number ML15268A019].
18 CCF-01 CCF LTR Common Cause Failure Analysis (updated 10/05/2020) Updated 10/19/20 by Entergy Open 3.2.18 (Summer Sun, Section 3.2.18 of Attachment 4 in the LAR discusses the common cause failure (CCF) analysis and Response to part 1 of 4 Samir Darbali, indicates that the original licensing basis for WF3 assumes a potential CCF of the CPCS and that the The intent of the new paragraphs in Enclosure to Entergy letter Richard Stattel, replacements of the current digital CPCS with the Common Q platform does not change the WF3 number W3F1-2020-0038, dated July 23, 2020, Section 3, Jack Zhao) licensing basis for defense in depth and diversity (D3) (see LTR page 3-60). In support of the D3 Technical Evaluation, sub-section 2, Licensing Technical CCF analysis for WF3 CPC updates, the licensee quoted the NRC safety evaluation (SE) approving Report (LTR) is to credit the WF3 ATWS instead of the ANO-2 the CCF analysis for the Arkansas Nuclear One, Unit 2 ANO-2 original CPC design and Palo Verde and PVNGS SEs described in Attachment 4 of the Enclosure to Nuclear Generating Station (PVNGS) CPC replacements (see LTR pages 3-61 and 3-62). Entergy letter number W3F1-2020-0038 (WCAP-18484-P, Licensing Technical Report for the Waterford Steam Electric LAR Section 2. Licensing Technical Report (LTR), paragraphs 3 - 8 credit the WF3 Anticipated Station Unit 3 Common Q Core Protection Calculator System").
Transients Without Scram (ATWS) Mitigation Systems described in FSAR Chapter 7.8. These The W3F1-2020-0038 Enclosure Section 3, Technical paragraphs were added after the draft LAR review pre-application meeting discussions regarding Evaluation, sub-section 2, provides the justification of the LTR Section 3.2.18. acceptability of crediting ATWS for CPCS failure to trip due to a CCF.
Please explain if the intent of the new paragraphs in LAR Section 2 is to credit the WF3 ATWS instead of the ANO-2 and PVNGS SEs (LTR pages 3-61 and 3-62). Response to part 4 of 4 Attachment 4 of the Enclosure to Entergy letter number W3F1-In a public meeting held September 22, 2020, the licensee discussed open item 18, Common Cause 2020-0038 (WCAP-18484-P, Licensing Technical Report for the Failure Analysis, and indicated that it would rely on the information related to the ATWS mitigation Waterford Steam Electric Station Unit 3 Common Q Core systems in FSAR Section 7.8 to address the open item 18 for the CCF analysis. Protection Calculator System"), Section 3.2.18 will be revised to delete reference to the ANO-2 diversity analysis and refer to the Since the licensee is crediting ATWS, please describe how the ATWS analysis is sufficient to LAR for the D3 assessment for the Common Q CPCS.
address a CCF failure of the replacement CPCS for the events which credit the CPCS. Please discuss the current technical and licensing basis for the current digital CPCS and whether the Common Q platform maintains this technical and licensing basis for defense in depth and diversity (D3). Please address inconsistencies in the LAR and Section 3.2.18 of the LAR Attachment 4 to reflect the information used for supporting the D3 discussion related to CCF of the CPCS.
19 TS-01 Clean TS Encl, Cover Clean TS Pages The information on the coversheet of Attachment is incorrect. The Open RCI pages Att 2 page Markup page is correct. There is no intention to submit a Attachment 2 cover page lists 3/4 2-6a as a clean TS page; however, the mark-up and submitted corrected coversheet.
(Tarico Sweat, clean page is numbered 3/4 2-6, not 3/4 2-6a.
Audrey Klett, Samir Darbali) 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.
20 TS-02 Marked up Encl, Cover Marked up and Clean TS Pages The change to TS 3.10.2 is partially described in the table on Open RAI and Clean TS Att 1 pages page 11 of 27 in the Enclosure to W3F1-2020-0038. The table pages Encl, The cover page of Attachment 1 lists page 3/4 10-2 as having mark-ups; however, the marked up entry for TS 3.10.2 will be enhanced to indicate that the editorial Att 2 version of this page is not provided in the LAR. The cover page of Attachment 2 lists page 3/4 10-2, change for "Functional Unit 15" to "Functional Unit 9c" occurs four (Tarico Sweat, however, a clean version of this page is not included in Attachment 2 (assuming that the licensee times on the page, as shown on the markup. (see below).
Audrey Klett, intended to provide a mark-up of page 3/4 10-2).
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OFFICIAL USE ONLY PROPRIETARY INFORMATION NRC staff requests the licensee to confirm whether it intended to propose changes to this TS page TS 3.10.2 is being revised in four places to replace "Functional and, if so, to provide the proposed marked up and clean TS pages. Unit 15" with Functional Unit 9c". This is purely editorial as a result of the changes to TS 2.2.1 and 3.3.1 described above, which redesignated the CPCs as Functional Unit 9c in Tables 2.2-1 and 3.3-1.
The Markup and Clean copies were inadvertently absent from the LAR submittal and will be provided along with the revised table entry with the next docketed CPC correspondence. Copies attached to this response.
21 EQ-01 Oversight of VOP In the earlier pre-submittal meetings, the licensee stated that it would include the equipment Updated 10/19/20 by Entergy Open Audit EQ Sum qualification (EQ) for some unqualified items as a licensee commitment. But, in the final pre- the mary submittal meeting, the licensee did not include the commitment and stated that EQ would be The VOP Summary (included with the LAR) Section 5.1, Critical EQ (Jack Zhao, performed as part of the VOP. The VOP Summary does not describe how the VOP will cover the Characteristics, includes Environmental Critical Characteristics. part of Deanna Zhang, equipment qualification for the unqualified items. Please clarify which VOP Summary section In addition, VOP Section 5.2, Design Artifacts, includes review of the Samir Darbali) includes the oversight of EQ. Westinghouse design documents. This section provides VOP examples of Westinghouse design documents including the System Requirements Specification (SyRS), Software Requirements Specification (SRS), etc. Another example, not listed, includes the Equipment Qualification Summary Report (EQSR).
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.
22 EQ-02 GDC 4 LAR Section 4 Please clarify why the applicable GDC 4 was not addressed and evaluated in Section 4 of the LAR. Open (Jack Zhao, Samir Darbali) 23 EQ-03 CPCS Attach Section 2.1 In Section 2.1 it says that the CPCS primary digital components identified in Table 2.1-1 are Open components ment addressed. Please list the components which are not addressed in Attachment 11. Updated 10/19/20 by Entergy Not Listed in 11 Table 2.1-1 The following components are covered by the subsequent EQSR:
(Jack Zhao, Samir Darbali) ((
))
OFFICIAL USE ONLY PROPRIETARY INFORMATION
ML20315A250 (Proprietary)
ML20315A267 (Non-Proprietary)
ML20315A273 (Package) *by e-mail OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA* NRR/DSS/SNSB/BC* NRR/DRO/IQVB/BC*
NAME AKlett PBlechman SKrepel KKavanagh DATE 11/18/2020 11/16/2020 11/09/2020 11/13/2020 OFFICE NRR/DEX/EICB/BC* NRR/DORL/LPL4/BC* NRR/DORL/LPL4/PM*
NAME MWaters JDixon-Herrity AKlett DATE 11/13/2020 11/19/2020 12/17/2020