ML19290H114

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Audit Report for Vogtle Units 3 and 4 LAR 19-006 (Public)
ML19290H114
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 10/21/2019
From: Chandu Patel
NRC/NRR/VPOB
To: Jennifer Dixon-Herrity
NRC/NRO/DLSE/LB2
References
LAR 19-006
Download: ML19290H114 (17)
v • d • e


Text

OFFICIAL USE ONLY - PROPRIETARY INFORMATION October 21, 2019 MEMORANDUM TO: Jennifer L. Dixon-Herrity, Chief Licensing Branch 2 Division of Licensing, Siting, and Environmental Analysis Office of New Reactors FROM: Patel Chandu, Senior Project Manager /RA/

Licensing Branch 2 Division of Licensing, Siting, and Environmental Analysis Office of New Reactors

SUBJECT:

AUDIT REPORT FOR VOGTLE ELECTRIC GENERATING PLANT UNITS 3 AND 4, REQUEST FOR LICENSE AMENDMENT: CREDITING PREVIOUSLY COMPLETED ADS BLOWDOWN FIRST THREE PLANT TESTS (LAR 19-006)

By letter dated April 26, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19119A249), Southern Nuclear Operating Company (SNC) requested an amendment to Combined License (COL) Numbers NPF-91 and NPF-92, for the Vogtle Electric Generating Plant (VEGP) Units 3 and 4.

The requested amendment requires changes to the Updated Final Safety Analysis Report (UFSAR) in the form of departures from the incorporated plant-specific Design Control Document Tier 2* and Tier 2 information and related changes to the VEGP Units 3 and 4 COL, associated with the design-specific pre-operational Automatic Depressurization System (ADS) Blowdown Test.

The requested amendment involves changes to credit the previously completed ADS Blowdown first three plant tests as described in the licensing basis documents, including COL Condition 2.D.(2)(a). Specifically, the proposed change would revise the COL, Condition 2.D.(2)(a)2, by removing the requirement to perform the ADS Blowdown first three plant only tests during preoperational testing.

CONTACT: Patel Chandu, NRO/DLSE/LB2 301-415-3025 OFFICIAL USE ONLY - PROPRIETARY INFORMATION

OFFICIAL USE ONLY - PROPRIETARY INFORMATION J. Dixon-Herrity The Reactor Systems, Nuclear Performance & Code Review Branch, the Mechanical Engineering Branch and the Quality Assurance Vendor Inspection Branch staff conducted an audit on May 20, 2019 - August 13, 2019. The purpose of the audit was to gain better understanding of proposed changes to reach reasonable findings and review related documentation and non-docketed information to evaluate conformance with the Standard Review Plan or technical guidance.

Docket Nos.: 52-025 and 52-026

Enclosure:

Regulatory Audit Report cc: See next page OFFICIAL USE ONLY - PROPRIETARY INFORMATION

ML19290H114 NRO-008 OFFICE DLSE/LB2:LA DLSE/LB2:PM DESR/SRSB:BC NRR/DIRS/IQVB:BC NAME RButler CPatel RKaras KKavanagh DATE 9/25/19 9/27/19 10/01/19 9/27/19 OFFICE DLSE/LB2:BC DESR/MEB:BC DLSE/LB2:PM (s)

NAME JDixon-Herrity TLupold CPatel DATE 9/26/19 10/3/19 10/21/19 Vogtle Units 3 & 4 Mailing List (Revised 08/13/2019) cc:

Southern Nuclear Operating Company, Inc. Resident Inspector Document Control Coordinator Bin N-226-EC Vogtle Plant Units 3 & 4 3535 Colonnade Parkway 8805 River Road Birmingham, AL 35243 Waynesboro, GA 30830 Office of the Attorney General Mr. Barty Simonton 40 Capitol Square, SW Team Leader Atlanta, GA 30334 Environmental Radiation Program Air Protection Branch Resident Manager Environmental Protection Division Oglethorpe Power Corporation 4244 International Parkway, Suite 120 Alvin W. Vogtle Nuclear Plant Atlanta, GA 30354-3906 7821 River Road Waynesboro, GA 30830 Brian H. Whitley 3535 Colonnade Parkway, Bin N-226-EC Anne F. Appleby 42 Inverness Center Parkway, BIN B237 Olgethorpe Power Corporation Birmingham, AL 35243 2100 East Exchange Place Tucker, GA 30084 Mr. Michael Yox Site Regulatory Affairs Director County Commissioner Vogtle Units 3 & 4 Office of the County Commissioner 7825 River Road, Bin 63031 Burke County Commission Waynesboro, GA 30830 Waynesboro, GA 30830 Mr. Wayne Guilfoyle Commissioner District 8 Augusta-Richmond County Commission 4940 Windsor Spring Rd Hephzibah, GA 30815 Gwendolyn Jackson Burke County Library 130 Highway 24 South Waynesboro, GA 30830 Mr. Reece McAlister Executive Secretary Georgia Public Service Commission Atlanta, GA 30334 Page 1 of 3

Vogtle Units 3 & 4 Mailing List Email acchambe@southernco.com (Amy Chamberlian) agaughtm@southernco.com (Amy Aughtman) awc@nei.org (Anne W. Cottingham) becky@georgiawand.org (Becky Rafter) bhwhitley@southernco.com (Brian Whitley)

Bill.Jacobs@gdsassociates.com (Bill Jacobs) bjadams@southernco.com (Brad Adams) bwwaites@southernco.com (Brandon Waites) castelca@westinghouse.com (Curtis Castell) comerj@westinghouse.com (James Comer) crpierce@southernco.com (C.R. Pierce) dahjones@southernco.com (David Jones) david.hinds@ge.com (David Hinds) david.lewis@pillsburylaw.com (David Lewis) dgbost@southernco.com (Danny Bost) dlfulton@southernco.com (Dale Fulton) drculver@southernco.com (Randy Culver) durhamdc@westinghouse.com (David Durham) ed.burns@earthlink.net (Ed Burns) edavis@pegasusgroup.us (Ed David) erg-xl@cox.net (Eddie R. Grant) fdhundle@southernco.com (Forrest Hundley) fhwillis@southernco.com (Fred Willis)

G2NDRMDC@southernco.com (SNC Document Control)

George.Taylor@opc.com (George Taylor) graysw@westinghouse.com (Scott W. Gray) jadwilli@southernco.com (J.D. Williams) james1.beard@ge.com (James Beard) jantol1dj@westinghouse.com (David Jantosik) jenmorri@southernco.com (Jennifer Buettner)

JHaswell@southernco.com (Jeremiah Haswell) jim@ncwarn.org (Jim Warren)

John.Bozga@nrc.gov (John Bozga)

Joseph_Hegner@dom.com (Joseph Hegner) jpredd@southernco.com (Jason R. Redd) karen.patterson@ttnus.com (Karen Patterson) karlg@att.net (Karl Gross) kmstacy@southernco.com (Kara Stacy) kroberts@southernco.com (Kelli Roberts)

KSutton@morganlewis.com (Kathryn M. Sutton) kwaugh@impact-net.org (Kenneth O. Waugh) markus.popa@hq.doe.gov (Markus Popa) mdmeier@southernco.com (Mike Meier) media@nei.org (Scott Peterson)

Page 2 of 3

Vogtle Units 3 & 4 Mailing List Melissa.Smith@Hq.Doe.Gov (Melissa Smith) mike.price@opc.com (M.W. Price)

MKWASHIN@southernco.com (MKWashington) mlgraves@southernco.com (Michelle Graves)

MSF@nei.org (Marvin Fertel) myox@southernco.com (Mike Yox) nirsnet@nirs.org (Michael Mariotte)

Nuclaw@mindspring.com (Robert Temple)

Paul@beyondnuclear.org (Paul Gunter) pbessette@morganlewis.com (Paul Bessette) r.joshi15@comcast.net (Ravi Joshi)

Ronald.Jones@scana.com (Ronald Jones) rwink@ameren.com (Roger Wink) sabinski@suddenlink.net (Steve A. Bennett) sara@cleanenergy.org (Sara Barczak) sblanton@balch.com (Stanford Blanton)

Shiva.Granmayeh@hq.doe.gov (Shiva Granmayeh) sjackson@meagpower.org (Steven Jackson) skauffman@mpr.com (Storm Kauffman) sroetger@psc.state.ga.us (Steve Roetger) stephen.burdick@morganlewis.com (Stephen Burdick) tom.miller@hq.doe.gov (Tom Miller)

TomClements329@cs.com (Tom Clements)

Vanessa.quinn@dhs.gov (Vanessa Quinn) vcsummer2n3@gmail.com (Brian McIntyre) wasparkm@southernco.com (Wesley A. Sparkman) wayne.marquino@gmail.com (Wayne Marquino) weave1dw@westinghouse.com (Doug Weaver)

William.Birge@hq.doe.gov (William Birge) x2gabeck@southernco.com (Gary Becker) x2kmseib@southernco.com (Kristin Seibert)

Page 3 of 3

OFFICIAL USE ONLY - PROPRIETARY INFORMATION REPORT OF REGULATORY AUDIT LICENSE AMENDMENT REQUEST LAR 19-006:

CREDITING PREVIOUSLY COMPLETED ADS BLOWDOWN FIRST THREE PLANT TESTS SOUTHERN NUCLEAR OPERATING COMPANY VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4 Docket Nos.52-025 and 52-026 A. Background By letter dated April 26, 2019 (Reference 1), Southern Nuclear Operating Company (SNC) requested an amendment to Combined License (COL) Numbers NPF-91 and NPF-92 for Vogtle Electric Generating Plant (VEGP), Units 3 and 4 (References 2 and 3).

The requested amendment (LAR 19-006) proposes changes to the Updated Final Safety Analysis Report (UFSAR) (Reference 4) in the form of departures from the incorporated plant-specific Design Control Document Tier 2* and Tier 2 information and related changes to the VEGP Units 3 and 4 COLs.

LAR 19-006 includes changes to credit the previously completed Automatic Depressurization System (ADS) Blowdown first three plant only tests as described in the licensing basis documents, including COL Condition 2.D.(2)(a), performed at the Sanmen Units 1 and 2 (SM1 and 2) and Haiyang Unit 1 (HY1) nuclear power plants in China. SNC requested prior U.S. Nuclear Regulatory Commission (NRC) approval because the proposed changes impact the COL and plant-specific Tier 2* information.

The purpose of the regulatory audit was to review the documentation and calculations, and quality assurance (QA) provisions, needed by the staff to verify the information in LAR 19-006. The staff issued the audit plan on May 15, 2019 (Reference 5).

B. Regulatory Audit Basis This regulatory audit is based on the following:

  • VEGP Unit 3, Current Facility Combined License NPF-91, revised June 13, 2019, License Condition 2.D.(2)(a) (Agencywide Documents and Access Management System (ADAMS) Accession No. ML14100A106).
  • VEGP Unit 4, Current Facility Combined License NPF-92, revised June 25, 2019, License Condition 2.D.(2)(a) (ADAMS Accession No. ML14100A135).

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OFFICIAL USE ONLY - PROPRIETARY INFORMATION

The staff followed the guidance provided in NRC Office of New Reactors Office Instruction NRO-REG-108, Regulatory Audits, in developing this audit summary. The audit plan is available in ADAMS under Accession No. ML19134A222.

C. Logistics Dates: May 20, 2019 - August 13, 2019 Location: The staff conducted the audit by reviewing documentation available in the Westinghouse Electric Companys (Westinghouse) electronic reading room (eRR). Periodic telephone conferences were conducted with SNC and Westinghouse subject matter experts during the audit.

D. Audit Team Members The following staff members participated in the audit:

  • Andrea Keim, Reactor Operations Engineer (Quality Assurance Inspector)
  • Alina Schiller, Project Manager E. Applicant and Industry Participants The following personnel from SNC and Westinghouse participated in the periodic telephone conferences:
  • Steve Leighty, SNC
  • Pamela Fergen, SNC
  • Preston Vock, Westinghouse F. Documents Audited SNC ADS Valve Discussion, dated July 15, 2019.

SNC ND-CX-001-F04, Vendor Formal Test and Observation Report, China Testing Observation Plan and Report: First-3-Plant Only Preoperational Test at Sanmen Unit 2, not dated.

SNC ND-EN-006-F01, Vendor Document Acceptance, Sanmen 1&2 and Haiyang 1 First Plant Only and First 3 Plant Only Passive Core Cooling and Reactor System Tests, July 30, 2018.

SNC ND-EN-006-F01, Vendor Document Acceptance, NRC IP 70367 Comparison to Sanmen and Haiyang Admin Procedures, August 2, 2018.

SNC Request for Information ND-VOGTLE34-RFI-1031, Review of Design Changes at Sanmen and Haiyang AP1000 Units, May 21, 2018.

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 8

OFFICIAL USE ONLY - PROPRIETARY INFORMATION SNC Road Map of Documents in Support of ADS Blowdown First 3 Plant Testing, June 28, 2019.

Talisman International, LLC, Comparison of Chinas Regulatory Quality Assurance Program to US 10 CFR Appendix B, February 15, 2018.

HY1 Preoperational Test Procedure HY1-PXS-T1P-505, Passive Core Cooling Automatic Depressurization System Precore Hot Functional Test, Revision 3, June 21, 2017.

HY1 Preoperational Test Report HY1-PXS-T2R-505, Preoperational Test Report for HY1-PXS-T1P-505, July 26, 2017.

SM1 Preoperational Test Procedure SM1-PXS-T1P-505, Passive Core Cooling Automatic Depressurization System Hot Functional Test Procedure, Revision 4, June 8, 2017.

SM1 Preoperational Test Report SM1-PXS-T2R-505, Preoperational Test Report for SM1-PXS-T1P-505, July 26, 2017.

SM1 Startup Test Report SM1-PXS-T2R-50013, Test Report for SM1-PXS-T1P-505 Passive Core Cooling Automatic Depressurization System Hot Functional Test Procedure, July 21, 2017.

Westinghouse Engineering Report APP-SSAR-GSC-810, NOTRUMP Predictive Analysis of the CMT Recirculation, CMT Draindown, and ADS Blowdown Pre-Operational Tests, Revision 1, September 7, 2016.

Westinghouse Engineering Report SM1-PXS-T2C-017, SM1-PXS-T1P-505 ADS Blowdown Test Results for Loading on the IRWST, Revision 0, September 14, 2017.

Westinghouse Engineering Report SM2-PXS-T2C-017 R0, SM2-PXS-T2C-015 ADS Blowdown Test Results for Loading on the IRWST, March 20, 2018.

Westinghouse Engineering Report HY1-PXS-T2C-020 R0, HY1-PXS-T1P-505 ADS Blowdown Test results for Loading on the IRWST, Revision 0, April 2, 2018.

Westinghouse Engineering Report CPP-PV01-VTR-000001, SM1 and HY1 ADS Blowdown Test Valve Performance Report, Revision 0, July 14, 2017.

Westinghouse Engineering Report SM1-PXS-T2C-016, SM1-PXS-T1P-505 Automatic Depressurization System Test Results Comparison to Predictive Analysis, Revision 0, August 18, 2017.

Westinghouse Engineering Report SM2-PXS-T2C-012, SM1-PXS-T1P-505 Automatic Depressurization System Test Results Comparison to Predictive Analysis, Revision 0, February 22, 2018.

Westinghouse Engineering Report HY1-PXS-T2C-017, HY1-PXS-T1P-505 Automatic Depressurization System Test Results Comparison to Predictive Analysis, Revision 0, August 8, 2017.

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 9

OFFICIAL USE ONLY - PROPRIETARY INFORMATION Westinghouse Engineering Report SM2-PXS-T2C-012, SM2-PXS-T1P-505 Automatic Depressurization System Test Results Comparison to Predictive Analysis, Revision 0, February 22, 2018.

Westinghouse Engineering Report CPP-MT03-T2R-001, ADS Blowdown Testing - IRWST Wall Pressure Frequency Domain Evaluation, Rev. 0, February 13, 2019.

Westinghouse Engineering Report CPP-MT03-T2R-002, ADS Blowdown Testing - Comparison of China Test and Hydrodynamic Analysis Pressure Results, Revision 0, February 20, 2019.

Westinghouse Valve Drawing CPP-PV01-V2-131001, Edward Globe Balanced Stop Valve Stainless Steel with Limitorque SMB-00-10, NPS 4, Revision 3, February 21, 2017.

Westinghouse Valve Drawing CPP-PV01-V2-131002, Edward Globe Balanced Stop Valve Stainless Steel with Limitorque SMB-00-10, NPS 4, Revision 2, February 21, 2017.

Westinghouse Valve Drawing CPP-PV01-V2-131003, Edward Globe Balanced Stop Valve Stainless Steel with Limitorque SMB-00-10, NPS 4, Revision 1, February 21, 2017.

Westinghouse Valve Drawing CPP-PV01-V2-131004, Edward Globe Balanced Stop Valve Stainless Steel with Limitorque SMB-00-10, NPS 4, Revision 2, January 19, 2016.

Westinghouse Valve Drawing CPP-PV01-V2-131005, Edward Globe Balanced Stop Valve Stainless Steel with Limitorque SMB-00-10, NPS 4, Revision 0, February 11, 2011.

Westinghouse Valve Drawing CPP-PV01-V2-132001, Edward Globe Balanced Stop Valve Stainless Steel with Limitorque SMB-0-5, NPS 8, Revision 2, February 21, 2017.

Westinghouse Valve Drawing CPP-PV01-V2-132002, Edward Globe Balanced Stop Valve Stainless Steel with Limitorque SMB-0-5, NPS 8, Revision 2, February 21, 2017.

Westinghouse Valve Drawing CPP-PV01-V2-132003, Edward Globe Balanced Stop Valve Stainless Steel with Limitorque SMB-0-5, NPS 8, Revision 1, February 21, 2017.

Westinghouse Valve Drawing CPP-PV01-V2-132004, Edward Globe Balanced Stop Valve Stainless Steel with Limitorque SMB-00-5, NPS 8, Revision 2, January 19, 2016.

Westinghouse Valve Drawing CPP-PV01-V2-132005, Edward Globe Balanced Stop Valve Stainless Steel with Limitorque SMB-0-5, NPS 8, Revision 0, February 22, 2011.

Westinghouse Valve Drawing SVO-PV01-V2-131001, AP1000 Motor Operated Globe Valve, 4, Class 1530, Assembly Drawing APP-PV01-ZOD-131, Revision 3, November 30, 2018.

Westinghouse Valve Drawing SVO-PV01-V2-131002, AP1000 Motor Operated Globe Valve, 4, Class 1530, Assembly Drawing APP-PV01-ZOD-131, Revision 1, November 30, 2018.

Westinghouse Valve Drawing SVO-PV01-V2-131003, AP1000 Motor Operated Globe Valve, 4, Class 1530, Assembly Drawing APP-PV01-ZOD-131, Revision 1, November 30, 2018.

Westinghouse Valve Drawing SVO-PV01-V2-131004, AP1000 Motor Operated Globe Valve, 4, Class 1530, Assembly Drawing APP-PV01-ZOD-131, Revision 1, August 17, 2016.

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 10

OFFICIAL USE ONLY - PROPRIETARY INFORMATION Westinghouse Valve Drawing SVO-PV01-V2-131005, AP1000 Motor Operated Gate Valve, 4, Class 1530, Assembly Drawing APP-PV01-ZOD-131, Revision 0, February 13, 2012.

Westinghouse Valve Drawing SVO-PV01-V2-132001, AP1000 Motor Operated Globe Valve, 8, Class 1530, Assembly Drawing APP-PV01-ZOD-132, Revision 3, November 30, 2018.

Westinghouse Valve Drawing SVO-PV01-V2-132002, AP1000 Motor Operated Globe Valve, 8, Class 1530, Assembly Drawing APP-PV01-ZOD-132, Revision 2, November 30, 2018.

Westinghouse Valve Drawing SVO-PV01-V2-132003, AP1000 Motor Operated Globe Valve, 8, Class 1530, Assembly Drawing APP-PV01-ZOD-132, Revision 2, November 30, 2018.

Westinghouse Valve Drawing SVO-PV01-V2-132004, AP1000 Motor Operated Globe Valve, 8, Class 1530, Assembly Drawing APP-PV01-ZOD-132, Revision 2, March 28, 2016.

Westinghouse Valve Drawing SVO-PV01-V2-132005, AP1000 Motor Operated Gate Valve, 8, Class 1530, Assembly Drawing APP-PV01-ZOD-132, Revision 1, November 2, 2012.

G. Description of Audit Activities and Summary of Observations The audit team reviewed SNC documentation and calculations, and QA provisions, that provide technical support for the request in LAR-19-006 to apply the results of the ADS Blowdown Tests performed at the Sanmen and Haiyang nuclear power plants to VEGP Units 3 and 4. In addition, the audit team discussed with SNC and Westinghouse subject matter experts applicable support for the request, including (1) applicable differences between VEGP Units 3 and 4, and the Sanmen and Haiyang nuclear power plants, (2) QA of the test data, (3) physical phenomena observed in the test data, and (4) design changes to the ADS valves [

] In the paragraphs below, the audit team describes the results of its review of the applicable SNC documentation and calculations, and QA provisions; and the discussions with SNC and Westinghouse subject matter experts related to this audit.

In its review of the administrative quality controls for the ADS Blowdown Tests at Sanmen and Haiyang, the audit team examined SNC ND-EN-006-F01, NRC IP 70367 Comparison to Sanmen and Haiyang Admin Procedures. NRC Inspection Procedure (IP) 70367, Part 52, Inspection of Preoperational Test Program, provides guidance to confirm that an NRC licensees administrative quality controls over preoperational testing at nuclear power plants licensed under Title 10 of the Code of Federal Register (10 CFR) Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants, have been developed in accordance with the UFSAR commitments and regulatory requirements, including controls related to the test program and organization, test procedures and engineering documents, design changes and modifications, maintenance during preoperational testing, equipment protection, and measuring and test equipment. SNC reported that the Sanmen and Haiyang Administrative Manual procedures satisfy the provisions in IP 70367 except for a process for actions to be taken when an instrument is found out of calibration. This exception did not apply to the ADS Blowdown Tests at Sanmen and Haiyang because no instruments were found to be out of calibration during those tests. Based on its review of the applicable documentation, the audit team determined that the Sanmen and Haiyang administrative procedures were acceptable for applying the ADS Blowdown Test results to VEGP Units 3 and 4.

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OFFICIAL USE ONLY - PROPRIETARY INFORMATION The audit team examined SNC ND-EN-006-F01, Sanmen 1&2 and Haiyang 1 First Plant Only and First 3 Plant Only Passive Core Cooling and Reactor System Tests, which describes the review of the ADS Blowdown Tests at Sanmen and Haiyang against the NRC IP 70702, Part 52, Inspection of Preoperational Test Performance. IP 70702 provides guidance for the inspection of preoperational tests at nuclear power plants licensed under 10 CFR Part 52 to verify that the tests are consistent with the UFSAR, are adequately performed and documented, and the results demonstrate that the plant, procedures, and personnel are ready for safe operation. SNC considered that the ADS Blowdown Tests satisfied the NRC preoperational test requirements and administrative guidelines [

] The audit team reviewed the applicable documentation supporting the performance of the ADS Blowdown Tests at Sanmen and Haiyang. Based on its review, the audit team determined that the NRC preoperational test requirements and administrative guidelines were satisfied in an acceptable manner during the ADS Blowdown Tests at Sanmen and Haiyang for application of the test results to VEGP Units 3 and 4.

The audit team evaluated the design of the valves used for the ADS Blowdown Tests at Sanmen and Haiyang with the ADS valves to be installed in VEGP Units 3 and 4. During a telephone conference with the audit team, SNC stated that the only difference in the ADS valves at Sanmen and Haiyang and those to be installed in VEGP Units 3 and 4 is related to the external bonnet seal weld area of the valves. In response to this discussion, SNC placed a diagram titled ADS Valve Discussion, in the Westinghouse eRR identifying the valve differences. SNC reported that both valve designs will be qualified in accordance with the ASME Standard QME-1-2007, Qualification of Active Mechanical Equipment Used in Nuclear Power Plants, which is accepted in NRC Regulatory Guide 1.100, Seismic Qualification of Electrical and Active Mechanical Equipment and Functional Qualification of Active Mechanical Equipment for Nuclear Power Plants. The audit team found that the valves used at Sanmen and Haiyang for the ADS Blowdown Tests and those to be installed in VEGP Units 3 and 4 are sufficiently similar in design and qualification to rely on the results of the ADS Blowdown Tests conducted at Sanmen and Haiyang for application to VEGP Units 3 and 4.

The audit team reviewed the handwritten markups of the test procedures used to perform the ADS Blowdown Tests at Sanmen and Haiyang. For example, the audit team reviewed Preoperational Test Procedure SM1-PXS-T1P-505 (Revision 4), Passive Core Cooling Automatic Depressurization System Hot Functional Test Procedure, for the ADS Blowdown Test at SM1 in June 2017 with the test objectives of verification of (1) the proper operation of the ADS Stage 1, 2, and 3 components under normal operating pressure and temperature conditions, and (2) the ability of the ADS spargers to limit loads imposed on the in-containment refueling water storage tank (IRWST). The audit team also reviewed Preoperational Test Procedure HY1-PXS-T1P-505 (Revision 3), Passive Core Cooling Automatic Depressurization System Precore Hot Functional Test, for the ADS Blowdown Test at HY1 in June 2017. The objectives for the ADS Blowdown Test at HY1 were verification of (1) proper operation of the ADS Stage 1, 2, and 3 components at reactor coolant system (RCS) depressurized conditions; (2) proper operation of ADS Stage 1, 2, and 3 components under normal operating pressure and temperature conditions; and (3) ability of the ADS spargers to limit loads imposed on the IRWST. Based on its review of the markup procedures, the audit team determined that the test procedures were followed during the ADS Blowdown Tests in June 2017 at Sanmen and Haiyang in an acceptable manner.

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 12

OFFICIAL USE ONLY - PROPRIETARY INFORMATION With respect to the ADS Blowdown Test at Sanmen, the audit team reviewed Startup Test Report SM1-PXS-T2R-50013, Test Report for SM1-PXS-T1P-505 Passive Core Cooling Automatic Depressurization System Hot Functional Test Procedure. [

] Also attached to the test report is a Westinghouse report concluding that the ADS Blowdown Test at SM1 in June 2017 met the acceptance criteria. [

]

With respect to the ADS Blowdown Test at Haiyang, the audit team reviewed a summary report prepared by Westinghouse dated July 6, 2017 (attached to Preoperational Test Report HY1-PXS-T2R-505) describing the ADS Blowdown Test at HY1 in June 2017. The Westinghouse summary report concluded that ADS Blowdown Test at HY1 was successfully executed and the acceptance criteria have been met, including RCS depressurization and proper operation of the ADS valves. Further, a Westinghouse report dated July 5, 2017 (also attached to Preoperational Test Report HY1-PXS-T2R-505) provided a detailed evaluation of the system depressurization, valve performance, and IRSWT pressures during the ADS Blowdown Test at HY1 in June 2017. The Westinghouse detailed report indicated that the RCS depressurized as predicted by analysis, the ADS valves opened in the correct sequence and within the expected times, and loadings within the IRWST were limited to less than 5 pounds per square inch along the walls. [

]

The audit team reviewed an overall summary of the ADS Blowdown Tests at Sanmen and Haiyang provided in Westinghouse Report CPP-PV01-VTR-000001, SM1 and HY1 ADS Blowdown Test Valve Performance Report, attached to Startup Test Report SM1-PXS-T2R-50013. This Westinghouse report provides a detailed description of the ADS valve performance during the blowdown tests at SM1 in November 2016 and at HY1 and SM1 in June 2017. [

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]

With respect to the ADS Blowdown Test at SM2 in January 2018, the audit team reviewed SNC Report ND-CX-001-F04 (Version 1.0), China Testing Observation Plan and Report, which provides a detailed description of the monitoring and observation by SNC personnel of the preoperational tests at SM2 from January 9 to February 8, 2018. The SNC observation included the following activities for the ADS Blowdown Test at SM2: (a) performance of pre-test requirements; (b) confirmation of measuring and test equipment usage; (c) adherence of approved procedures; (d) execution of test changes; (e) handling of anomalies, problems, and/or interruptions; (f) handling of deficiencies; (g) recording of data; (h) maintenance of the test narrative log; and (i) maintenance of operator logs. SNC also observed performance of station processes, procedures, proficiencies, behaviors, classroom training, and conduct of operations. The SNC report did not identify any performance issues with the capability of the ADS valves to depressurize the RCS during the ADS Blowdown Test at SM2 in January 2018.

The audit team also reviewed Westinghouse Engineering Report SM2-PXS-T2C-012, SM2-PXS-T1P-505 Automatic Depressurization System Test Results Comparison to Predictive Analysis, which described the intent and results of the ADS Blowdown Test at SM2 in January 2018. The Westinghouse report specified that the goal of the ADS Blowdown Test at SM2 was to demonstrate proper operation of the ADS Stage 1, 2, and 3 valves to depressurize the RCS and for the spargers to limit the loads imposed on the IRWST by the blowdown. The Westinghouse report indicated that the predictive analysis provided a good representation of the actual test data from the ADS Blowdown Test at SM2. The SNC and Westinghouse reports support the proper operation of the ADS Stage 1, 2, and 3 valves to depressurize the RCS during the ADS Blowdown Test at SM2 in January 2018.

[

] The audit team considers that SNC and Westinghouse monitored the ADS Blowdown Tests at Sanmen and Haiyang to verify that the test procedures were implemented in an acceptable manner. [

] The audit team did not identify any concerns with the application of the results of the ADS Blowdown Tests at the SM1, SM2, and HY1 nuclear power plants to support completion of the ADS Blowdown first three plant test requirement for VEGP Units 3 and 4. [

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]

Westinghouse performed NOTRUMP predictive analyses of the ADS blowdown test as provided in APP-SSAR-GSC-810 R1 and compared results to the test data from SM1 and 2 and HY1 provided in SM1-PXS-T2C-016, SM2-PXS-T2C-012, and HY1-PXS-T2C-017, respectively. The predictive analyses were performed for a small break loss-of-coolant accident as described in UFSAR Subsection 15.6.5.4B.2.1. [

] The Westinghouse Engineering Reports concluded that the tests were successful from a safety analysis perspective.

Westinghouse reviewed and analyzed the data obtained during the ADS Blowdown test for SM1 and 2 and HY1 as reported in SM1-PXS-T2C-017, SM2-PXS-T2C-017, and HY1-PXS-T2C-020, respectively. The acceptance criteria used was that engineering review and analysis of the test results show that average distributed pressures on the IRWST are less than

+/- 5 pounds per square inch differential (psid) for blowdown into a sub-cooled tank.

The following discussion is on the information available in SM1-PXS-T2C-017 and general findings of SM2-PXS-T2C-017, and HY1-PXS-T2C-020 are also similar. For this test, pressure measurements were taken in four locations around the IRWST during the blowdown of the RCS.

At each location, pressure transducers were mounted at four elevations above the IRWST floor.

Data were shown in graphical form during the blowdown of the RCS. SM1-PXS-T2C-017 listed peak pressures at four elevations for each location. [

]

SM1-PXS-T2C-017 calculated the root mean square (RMS) of the pressure data at four elevations for each location and provided the results in graphical form. [

] Considering that the intent of the test was to confirm the average distributed load across the tank, the vendor calculated the RMS of the RMS pressures at each location to determine the overall average distributed pressure across the tank and provided the results in graphical form.

[

] Therefore, SM1-PXS-T2C-017 concluded that the results of the ADS Blowdown test met the RWST design limit of 5 psi. Based on its review, the audit team finds the Westinghouse analysis of pressure data reasonable for obtaining average pressure across the tank during the blowdown.

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OFFICIAL USE ONLY - PROPRIETARY INFORMATION The audit team reviewed Westinghouse report, CPP-MT03-T2R-001, ADS Blowdown Testing -

IRWST Wall Pressure Frequency Domain Evaluation. [

]

  • AP600 testing showed that an ADS blowdown should present the power spectral densities (PSDs) centered through frequencies higher than 10 Hz, not a ski-sloped type of spectrum. The VAPORE1 tests developed for the AP600 presented frequency content for two-phase flow blowdown characterized by frequencies between 10 to 40 Hz whereas the pure steam blowdown had characteristic frequencies in the range from 40 to 70 Hz.
  • The pressure transient data should show clearly the phases of the test. Opening ADS Stages 1, 2 and 3 should be clearly identifiable or seen in the data. [

]

[

] The audit team finds applicants IRWST wall pressure frequency domain evaluation reasonable.

H. Exit Briefing The staffs audit exit briefing was conducted on August 13, 2019. The licensee and staff discussed the completion of the audit and plans for preparing a safety evaluation on LAR 19-006.

I. Requests for Additional Information (RAI) Resulting from Audit No RAIs were issued as a result of this audit.

1 The ADS test program for AP600 consisted of separate-effects tests performed at the facility called VAPORE, located at Central Research Establishment of Italian Energy Agency ENEA (Ente per le Nuove Technologie, lEnergia e lAmbiente, the Italian Energy Agency) at Casaccia, Italy. It had a full-size configuration of the AP600/AP1000 ADS Stages 1, 2, and 3 (ADS-1/2/3) piping network, exhaust pipe, and sparger.

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OFFICIAL USE ONLY - PROPRIETARY INFORMATION J. Open Items and Proposed Closure Paths No open items were identified as a result of the audit.

K. Deviations from Audit Plan The duration of the audit was extended in order to allow the staff to examine additional documents made available in the Westinghouse eRR.

L. References

1. Southern Nuclear Operating Company, Vogtle Electric Generating Plant Units 3 and 4, Request for License Amendment: Crediting Previously Completed ADS Blowdown First Three Plant Tests (LAR 19-006), April 26, 2019, ADAMS Accession No. ML19119A249.
2. Vogtle Electric Generating Plant Unit 3, Current Facility Combined License NPF-91, revised June 13, 2019, License Condition 2.D.(2)(a), ADAMS Accession No. ML14100A106.
3. Vogtle Electric Generating Plant Unit 4, Current Facility Combined License NPF-92, revised June 25, 2019, License Condition 2.D.(2)(a), ADAMS Accession No. ML14100A135.
4. Vogtle Electric Generating Plant, Units 3 and 4, Updated Final Safety Analysis Report, Tier 1, Revision 6; Tier 2, Section 3.9.6, Revision 6; Section 14.2.9.1.3, Revision 7; June 15, 2018 (ADAMS Accession Nos. ML18179A250, ML18179A275, and ML18179A289).
5. NRC Audit Plan for Vogtle Electric Generating Plant Units 3 and 4, Request for License Amendment: Crediting Previously Completed ADS Blowdown First Three Plant Tests (LAR 19-006), May 15, 2019, ADAMS Accession No. ML19134A222.
6. NRC Regulatory Guide 1.100, Seismic Qualification of Electrical and Active Mechanical Equipment and Functional Qualification of Active Mechanical Equipment for Nuclear Power Plants, Revision 3, September 2009, ADAMS Accession No. ML091320468.
7. ASME Standard QME-1-2007, Qualification of Active Mechanical Equipment Used in Nuclear Power Plants.

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