ML19326A937

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Audit Report for Vogtle Electric Generating Plant Units 3 and 4, Request for License Amendment: Crediting Previously Completed First Plant Only Startup Tests (LAR-19-011) - Publicly Available Version
ML19326A937
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 11/22/2019
From: Jennivine Rankin
NRC/NRR/VPOB
To: Victor Hall
NRC/NRR/VPOB
References
LAR-19-011
Download: ML19326A937 (20)
v • d • e


Text

OFFICIAL USE ONLY - PROPRIETARY INFORMATION November 22, 2019 MEMORANDUM TO: Victor E. Hall, Chief Vogtle Project Office Office of Nuclear Reactor Regulation FROM: Jennivine Rankin, Project Manager /RA/

Vogtle Project Office Office of Nuclear Reactor Regulation

SUBJECT:

AUDIT REPORT FOR VOGTLE ELECTRIC GENERATING PLANT UNITS 3 AND 4, REQUEST FOR LICENSE AMENDMENT: CREDITING PREVIOUSLY COMPLETED FIRST PLANT ONLY STARTUP TESTS (LAR-19-011)

By letter dated June 28, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML19179A209), Southern Nuclear Operating Company (the licensee) requested an amendment to Combined License (COL) Numbers NPF-91 and NPF-92, for 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 COLs.

The requested amendment includes changes to credit previously completed first plant only startup testing described in licensing basis documents, including License Conditions 2.D.(4)(b) and 2.D.(5)(b) of the COLs. The first plant only startup testing deliberated in the proposed amendment includes the Natural Circulation (Steam Generator) Test, the Rod Cluster Control Assembly Out of Bank Measurements, the Load Follow Demonstration, and the Passive Residual Heat Exchanger Test.

CONTACT: Jennivine Rankin, NRO/VPO 301-415-1530 OFFICIAL USE ONLY - PROPRIETARY INFORMATION

OFFICIAL USE ONLY - PROPRIETARY INFORMATION V. Hall The Nuclear Methods, Systems and New Reactor Branch (NRR/DSS/SNRB), the Mechanical Engineering and Inservice Testing Branch (NRR/DEX/EMIB), and the Quality Assurance Vendor Inspection Branch (NRR/DRO/IQVB) conducted an audit from August 5 - October 16, 2019.

The purpose of the audit was to gain better understanding of the proposed changes and to 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:

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

ML19309E508 (Proprietary Audit Report)

ML19326A937 (Non-Proprietary Audit Report)

  • via e-mail NRR-008 OFFICE VPO/PM VPO/LA DRO/IQVB DEX/EMIB NAME JRankin RButler KKavanagh* SBailey*

DATE 11/7/2019 11/6/2019 11/8/2019 11/12/2019 OFFICE DSS/SNRB VPO/BC VPO/PM(s)

NAME BKaras* VHall* JRankin*

DATE 11/6/2019 11/15/2019 11/22/2019 Vogtle Mailing List (Revised 11/06/2019) cc:

Resident Manager Resident Inspector Oglethorpe Power Corporation Vogtle Plant Units 3 & 4 Alvin W. Vogtle Nuclear Plant 8805 River Road 7821 River Road Waynesboro, GA 30830 Waynesboro, GA 30830 Mr. Barty Simonton Office of the Attorney General Team Leader 40 Capitol Square, SW Environmental Radiation Program Atlanta, GA 30334 Air Protection Branch Environmental Protection Division Southern Nuclear Operating Company, Inc. 4244 International Parkway, Suite 120 Document Control Coordinator Bin N-226-EC Atlanta, GA 30354-3906 3535 Colonnade Parkway Birmingham, AL 35243 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 Mailing List Email aagibson@southernco.com (Amanda Gibson) acchambe@southernco.com (Amy Chamberlian) awc@nei.org (Anne W. Cottingham) becky@georgiawand.org (Becky Rafter) bhwhitley@southernco.com (Brian Whitley)

Bill.Jacobs@gdsassociates.com (Bill Jacobs) corletmm@westinghouse.com (Michael M. Corletti) crpierce@southernco.com (C.R. Pierce) dahjones@southernco.com (David Jones) david.hinds@ge.com (David Hinds) david.lewis@pillsburylaw.com (David Lewis) 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) fhwillis@southernco.com (Fred Willis)

G2NDRMDC@southernco.com (SNC Document Control)

George.Taylor@opc.com (George Taylor) graysw@westinghouse.com (Scott W. Gray) harperzs@westinghouse.com (Zachary S. Harper) 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) 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)

Melissa.Smith@Hq.Doe.Gov (Melissa Smith) mike.price@opc.com (M.W. Price)

MKWASHIN@southernco.com (MKWashington) mlgraves@southernco.com (Michelle Graves) mphumphr@southernco.com (Mark Humphrey)

Page 2 of 3

Vogtle Mailing List MSF@nei.org (Marvin Fertel) myox@southernco.com (Mike Yox) 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) sjones@psc.state.ga.us (Shemetha Jones) skauffman@mpr.com (Storm Kauffman) slieghty@southernco.com (Steve Leighty) sroetger@psc.state.ga.us (Steve Roetger) syagee@southernco.com (Stephanie Agee)

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)

X2edgran@southernco.com (Eddie R. Grant) x2gabeck@southernco.com (Gary Becker)

X2hagge@southern.com (Neil Haggerty) x2kmseib@southernco.com (Kristin Seibert)

X2wwill@southernco.com (Daniel Williamson)

Page 3 of 3

OFFICIAL USE ONLY - PROPRIETARY INFORMATION Report of Regulatory Audit License Amendment Related to Crediting Previously Completed First Plant Only Startup Tests Vogtle Electric Generating Plant, Units 3 and 4 License Amendment Request (LAR 19-011)

A. Background By letter dated June 28, 2019 (Reference 1), Southern Nuclear Operating Company (SNC or the licensee) 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 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 COLs.

The requested amendment includes changes to credit previously completed first plant only startup testing described in licensing basis documents, including License Conditions 2.D.(4)(b) and 2.D.(5)(b) of the COLs. The first plant only startup testing deliberated in the proposed amendment includes the Natural Circulation (Steam Generator) Test, the Rod Cluster Control Assembly Out of Bank Measurements, the Load Follow Demonstration, and the Passive Residual Heat Exchanger Test.

The purpose of this audit is to gain a better understanding of the test results and quality assurance aspects of the testing.

B. Bases This regulatory audit is based on the following:

  • VEGP Unit 3, Current Facility Combined License NPF-91, Revised June 12, 2019, License Condition 2.D.(4)(b) and 2.D.(5)(b) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14100A106).
  • VEGP Unit 4, Current Facility Combined License NPF-92, Revised June 12, 2019, License Condition 2.D.(4)(b) and 2.D.(5)(b) (ADAMS Accession No. ML14100A135).

The audit plan is available in ADAMS under Accession No. ML19211C835.

OFFICIAL USE ONLY - PROPRIETARY INFORMATION

OFFICIAL USE ONLY - PROPRIETARY INFORMATION C. Logistics Date: August 5, 2019 - October 16, 2019 Location: The audit was conducted through the Westinghouse Electric Companys (Westinghouse) electronic reading room (ERR). A meeting with Westinghouse subject matter experts was conducted on September 10 and October 8, 2019, by telephone conference.

D. Audit Team Members The following U.S. Nuclear Regulatory Commission (NRC) staff members participated in substantive discussions during the audit:

Hanry Wagage, Senior Safety and Plant Systems Engineer, Technical Reviewer John Budzynski, Nuclear Engineer, Technical Reviewer Nicholas Hansing, Mechanical Engineer, Technical Reviewer Aaron Armstrong, Reactor Operations Engineer, Technical Reviewer Jennivine Rankin, Project Manager E. Applicant and Industry Staff Participants Pamela Fergen (SNC)

Karen Bobkowski (SNC)

Nick Kellenberger (SNC)

Karen Bobkowski (SNC)

Jeffrey Hausaman (SNC)

Steve Unikewicz (SNC)

Mark Wilson (SNC)

Anthony Schoedel (Westinghouse)

F. Documents Audited

  • Westinghouse APP-PXS-M3C-509, AP1000 PRHR [Passive Residual Heat Removal]

Plant Startup Test Criteria Development, Revision 1, September 30, 2016.

  • Westinghouse APP-RCS-GEF-428, Update to AP1000 Natural Circulation Startup Test Specification and Procedure Acceptance Criteria, Revision 0, February 26, 2018.
  • Westinghouse APP-RCS-T1-606, AP1000 Natural Circulation Startup Test Specification, Revision 0, March 26, 2013.
  • Westinghouse APP-RCS-T1P-606, AP1000 Natural Circulation Startup Test Procedure, Revision 0, March 26, 2013.
  • Westinghouse APP-SSAR-GSC-195, AP1000 Steam Generator Natural Circulation Startup Test Acceptance Criteria Generation, Revision 1, October 7, 2016.
  • Comparison of Chinas Regulatory Quality Assurance Program to US 10 CFR Appendix B, dated February 15, 2018.
  • SNC ND-CX-001-F04, China Testing Observation Plan and Report, Version 1.0, June 11, 2019.
  • SNC ND-EN-006-F01, Vendor Document Acceptance - LAR 19-011, Revision 3.
  • Review of Sanmen and Haiyang Administration Manual Procedures to NRC Inspection OFFICIAL USE ONLY - PROPRIETARY INFORMATION 2

OFFICIAL USE ONLY - PROPRIETARY INFORMATION Manual 72401.

  • Westinghouse ND-Vogtle34-RFI-1055, A LAR is being written to propose crediting previously completed First Plant Only Startup Tests, June 19, 2019.
  • Westinghouse SM1-PXS-T2C-018, Sanmen Unit 1 PXS Startup Test Results and Validation of PRHR Performance, Revision 0, December 20, 2018.
  • Westinghouse Letter SMG_CSM_001587, Westinghouse Preliminary Evaluation on Test Data of SM1-PXS-T1P-602, September 10, 2018.
  • SNC Engineering Review - PRHR and SG [Steam Generator], ND-EN-006-F001 for LAR 19-011, June 17, 2019.

G. Description of Audit Activities and Summary of Observations The NRC audit team reviewed SNC documentation and calculations, and quality assurance (QA) provisions, that provide technical support for the request in LAR-19-011 to apply the results of the following tests performed at the Sanmen Nuclear Power Plant Unit 1 (SM1) to VEGP Units 3 and 4: Natural Circulation Test (Steam Generator), Rod Cluster Control Assembly (RCCA) Out of Bank Measurements, Load Follow Demonstrations, and Natural Circulation Test (Passive Residual Heat Removal Heat Exchanger). 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.

The NRC audit team reviewed SNC ND-CX-001-F04, China Testing Observation Plan and Report, which states that personnel from SNC observed startup testing at SM1, including the following first plant only startup tests that SNC requests crediting for VEGP Units 3 and 4:

Natural Circulation Test (Steam Generator), RCCA Out of Bank Measurements, Load Follow Demonstrations, and Natural Circulation Test (Passive Residual Heat Removal Heat Exchanger). The SNC observations included the following activities for the above tests:

performance of pre-test requirements, confirmation of measuring and test equipment usage; adherence to the approved procedure; execution of test changes; handling of anomalies, problems, and/or interruptions; handling of deficiencies; recording of data; maintenance of the test narrative log; and maintenance of operator logs.

SNC noted that its personnel first reviewed SM1 test procedures and test acceptance criteria and then observed the first plant only startup tests from within the SM1 Control Room Envelope.

Following completion of the tests, SM1 provided test reports, for each startup test listed above, to both Westinghouse and SNC for review. The SNC personnel compared the completed test packages to NRC inspection procedures developed for use by the NRC inspectors during startup testing of AP1000 units and provided a record of comparison in the Test Report Review for each test. SNC noted that testing at SM1 was completed satisfactorily and with minimal deviations from expected results.

SNC determined that the tests have been performed successfully and the tests have been completed in such a way that the results are acceptable and applicable to SNC and that SNC standards and acceptance criteria were met.

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 3

OFFICIAL USE ONLY - PROPRIETARY INFORMATION Quality Assurance The staff reviewed the documentation associated with quality assurance testing and documentation for the referenced first plant only startup tests. NRC staff requested clarification regarding the procedures used at Haiyang for when an instrument was found to be out of calibration. SNC responded that those identified instruments procured were not used in crediting the applicable First Plant Only Startup Tests. The NRC staff also requested clarification on the SMI-GW-TIP-620, AP1000 Rod Cluster control Assembly out of bank measurement startup test procedure as the M&TE Usage Log of that test procedure had the appendix labeled as N/A. SNC responded that the plant instrumentation was used for measurement and had been calibrated for the test. The staff did not note any discrepancies during the review and determined the documentation supported the submitted LAR.

Steam Generator, Natural Circulation Test The NRC audit team reviewed ND-EN-006-F01 for LAR 19-011, which provided the SNC evaluation of the SM1 first plant only startup test for the SG natural circulation test. SNC had reviewed the following documents:

  • SM1-CV5-T2R-60028, AP1000 Steam Generator Natural Circulation Test Procedure, Revision 2.
  • APP-RCS-GEF-428, Update to AP1000 Natural Circulation Startup Test Specification and Procedure Acceptance Criteria, Revision 0, February 26, 2018.
  • Westinghouse APP-RCS-T1-606, AP1000 Natural Circulation Startup Test Specification, Revision 0, March 26, 2013.
  • Westinghouse APP-RCS-T1P-606, AP1000 Natural Circulation Startup Test Procedure, Revision 0, March 26, 2013.
  • Westinghouse APP-SSAR-GSC-195, AP1000 Steam Generator Natural Circulation Startup Test Acceptance Criteria Generation, Revision 1, October 7, 2016.
  • Westinghouse ND-Vogtle34-RFI-1055, A LAR is being written to propose crediting previously completed First Plant Only Startup Tests, June 19, 2019.

VEGP Units 3 and 4 UFSAR Section 14.2.10.3.6 states that the Natural Circulation (First Plant Only) test objective is to [d]emonstrate that core decay heat can be removed by the steam generators under the conditions of natural circulation (no reactor coolant pumps operating), and the performance criterion as [t]he measured average vessel T under natural circulation conditions is equal to or less than limiting design predictions for the measured reactor power level as specified in the applicable design specifications. As stated in ND-EN-006-F01 for LAR 19-011, the SNC review included confirming that the SM1 test met this criterion. ((

)). SNC concluded that the Steam Generator Natural OFFICIAL USE ONLY - PROPRIETARY INFORMATION 4

OFFICIAL USE ONLY - PROPRIETARY INFORMATION Circulation Test performed at the SM1 AP1000 Plant successfully showed that the AP1000 design meets the test acceptance criteria specified by the Plant Design Authority to show Steam Generator Natural Circulation cooling of the plant. SNC stated that the SM1 design and the VEGP Units 3 and 4 design are the same with respect to the primary system and steam generators, and there is enough justification to credit the testing performed at SM1 as first plant only startup testing as specified in the VEGP UFSAR.

The NRC audit team reviewed ND-Vogtle34-RFI-1055, A LAR is being written to propose crediting previously completed First Plant Only Startup Tests, which responds to an SNC request for Westinghouse to review AP1000 design changes which were made at one site (either SM1 or VEGP Units 3 and 4), and were not also made applicable to the other site, which could have affected a standard plant design feature such that the results of tests, including SG Natural Circulation Test, would be potentially impacted. In addition, SNC requested Westinghouse to (a) verify that the test specification APP-RCS-T1-606 and test procedure APP-RCS-T1P-606, Revision 0 are consistent regarding the acceptance criteria and (b) provide the rationale for the slight difference in the acceptance criteria used in the SG Natural Circulation test report and test specification, and the updated table provided for APP-SSAR-GSC-195 in APP-RCS-GEF-428. Westinghouse noted that its review of SG Natural Circulation test procedure APP-RCS-T1P-606 and design changes did not identify any non-conformances. Regarding additional request (a), Westinghouse noted that test procedure SM1-GV5-T2R-60028 incorporated APP-RCS-GEF-428 and the acceptance criteria are appropriate based on the change made in the E&DCR (Engineering & Design Coordination Report).

Regarding additional request (b), Westinghouse noted that the acceptance criteria values presented in Section 5.2 of APP-SSAR-GSC-195 Revision 1 are consistent with those presented in APP-RCS-GEF-428 and the startup test report.

Rod Cluster Control Assembly Out of Bank Measurements With respect to the RCCA Out of Bank Test, the NRC staff reviewed the SM1 first plant only startup test procedural steps and test results to ensure it is applicable to SNCs VEGP Units 3 and 4 UFSAR Chapter 14, Test 14.2.10.4.6. The startup test consisted of a pseudo-dropped test event and a pseudo-ejected test event. The staff reviewed the following documents:

  • Summary Startup Test Report (SM1-GV5-T2R-60056)
  • Startup Test Procedure (SM1-GW-T1P-620)

- Test Procedure Attachment Log,

- Test Narrative Log,

- Pre-Job/Post-Job Brief Record,

- Data Collection Table,

- Open Items Report,

- Test Report Change Form, and

- Reactivity Change Record.

  • Startup Quality Observation Report (SM1-JE92-GQR-6002)
  • Chapter 14 Applicability Summary Startup Test Report The summary startup test report contains a description of significant related steps of the pseudo-dropped/ejected tests, predicted to actual data deviations, open items, and acceptance OFFICIAL USE ONLY - PROPRIETARY INFORMATION 5

OFFICIAL USE ONLY - PROPRIETARY INFORMATION criteria results. The tests were performed between 30% and 50% Reactor Thermal Power (RTP) to provide sufficient margin such that the tests did not challenge the design basis limits of the fuel. During the tests where rod movements were conducted, boron concentrations were adjusted by boration or dilution operations to compensate for reactivity changes to maintain a constant power level.

Core power distribution was continuously monitored by the on-line power distribution monitoring system (OPDMS) to alarm the operator to any potential technical specification (TS) LCO 3.2.5 event. The NRC staff noted that there were no OPDMS alarms during the tests which indicated the power distribution remained within the TS limits.

Also, the tests were completed with no open or incomplete items noted during the testing.

However, there was a sensitivity concern with Channel B ex-core detector when the final total current dropped below the initial total current when RCCA withdraw motion stopped.

Westinghouse evaluated the data and concluded that the Channel B response was acceptable.

The NRC agreed with Westinghouses conclusion.

The NRC staff confirmed that all acceptance criteria requirements were satisfied. This included the following parameters:

  • Measured power distributions and power peaking factors within TS 3.2.5 limits,
  • Measured power distributions from self-powered neutron detector data maps consistent with predictions,
  • In-core instrumentation sensitivity to RCCA misalignment confirmed through power distribution and power peaking measurements,
  • Ex-core instrumentation sensitivity to RCCA misalignment confirmed through power distribution measurements, and
  • Core exit thermocouples sensitivity to RCCA misalignment confirmed through core exit temperature measurements.

Startup Test Procedure A preliminary assessment of the VEGP Test 14.2.10.4.6 to the SM1 startup test indicate (1) no anomalous result was identified that would impact or invalidate the first plant only startup test, and (2) the SM1 test is applicable to the VEGP test.

All of the VEGP test sections were included and consistent in the SM1 first plant only startup test.

An assessment summary is included in Table 1 below.

Table 1: Assessment of Sanmen Unit 1 Startup Test to Vogtle Units 3/4 UFSAR Chapter 14 Test 14.2.10.4.6 Rod Cluster Control Assembly Out of Bank Measurements (First Plant Only)

Vogtle Startup (S/U) Test Section SM1 S/U VEGP & SM1 S/U Tests Requirements Test Step Assessment Objectives Objectives are

- Demonstrate the sensitivity of the -1.2.1 consistent, and a Scope OFFICIAL USE ONLY - PROPRIETARY INFORMATION 6

OFFICIAL USE ONLY - PROPRIETARY INFORMATION Rod Cluster Control Assembly Out of Bank Measurements (First Plant Only)

Vogtle Startup (S/U) Test Section SM1 S/U VEGP & SM1 S/U Tests Requirements Test Step Assessment incore and excore instrumentation section is included in the system to RCCA misalignments S/U Test that provides supplemental information

- Demonstrate the design -1.2.2 supportive of the test, conservatism for predicted power such as rod location and distributions with a fully misaligned movement for dropped rod cluster control assembly rod and, for ejected rod, all RCCAs near the Hot

- Monitor the power distribution -1.2.3 Full Power (HFP) is following the recovery of a misaligned aligned with the insertion rod cluster control assembly limit and one rod location for full withdraw from the core.

Prerequisites Prerequisites are

- The reactor is operating between 30 -6.2, 6.7 consistent with the Initial and 50% of full licensed power and Conditions section and has been at that power for a sufficient Procedure Section. A time to reach xenon equilibrium. Precautions and Limitations section is

- The reactor power level, reactor -6.2 - 6.7 added to include other coolant system boron concentration, test limitations such as and temperature are stable. core average burnup limit, TSs, neutronic and

- The control and shutdown banks are -7.2.4 - 7.2.5, thermohydraulic positioned as required for the 7.4.4 - 7.4.5 monitoring systems, specific measurement, near fully operational restrictions withdrawn for RCCA insertion, and at on systems required their respective insertion limits for rod during the test.

cluster control assembly withdrawal.

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 7

OFFICIAL USE ONLY - PROPRIETARY INFORMATION Test Method Test Method section is

- For the RCCA insertion, insert a -7.2.8 - 7.2.20 consistent with group of selected rod cluster Procedure section. Steps control assemblies, one at a time, are documented and first to the limit of misalignment clearly contain the specified in subsection 15.0.5, information required to then fully inserted, and finally perform the pseudo-restored to the bank position. dropped and pseudo-Compensate for reactivity changes ejected rod tests.

by dilution and boration as Changes made to the required. procedure section was in accordance to

- For the RCCA withdrawal, -7.4.8 - 7.4.18 Optimization of the withdraw one or more selected rod Sequence for RCCA out cluster control assemblies, one at of Bank Test a time, to the fully withdrawn Specification Procedure position. Compensate for reactivity and Acceptance Criteria changes by boration and dilution Clarifications for Power as required. Ascension Testing Procedure based on

- Record incore and excore -7.2.3, 7.2.7, Westinghouse instrumentation signals to 7.2.11, 7.2.17, predictions.

determine their response and to 7.2.19, 7.2.21, determine the power distribution 7.2.23, 7.4.3, and power peaking factors prior to 7.4.7, 7.4.15, rod cluster control assembly 7.4.17, 7.4.27 misalignment, at partial misalignment, at full misalignment, and periodically after restoration to normal.

Performance Criteria Performance Criteria are

- Measured power distributions and -9.1, 9.2 consistent with SM1 test.

power peaking factors are within SM1 test results were TS limits and are consistent with within the TS limits and the predictions. were consistent with Westinghouse

- The sensitivity of the incore and -9.3, 9.4 predictions with no excore instrumentation to rod anomalies.

cluster control assembly Preliminary review misalignment is demonstrated by indicates the examination of the power excore/incore distribution and power peaking instrumentation factors measured for each sensitivity to rod misalignment. misalignment is acceptable as illustrated by power distribution &

peaking factors measure for each misalignment.

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 8

OFFICIAL USE ONLY - PROPRIETARY INFORMATION Load Follow Demonstration With respect to the Load Follow Test, the NRC staff reviewed the SM1 first plant only startup test procedural steps and test results to ensure applicability to SNCs VEGP Units 3 and 4 UFSAR Chapter 14, Test 14.2.10.4.22. The startup test consisted of reducing the reactor power to approximately 50% RTP plateau and performing additional power maneuvers at +/- 5% RTP around the plateau. The staff reviewed the following documents:

  • Summary Startup Test Report (SM1-GV5-T2R-60087)
  • Startup Test Procedure (SM1-GW-T1P-634)

- Test Procedure Attachment Log,

- Test Narrative Log.

- Pre-Job/Post-Job Brief Record,

- Data Collection Table,

- Open Items Report,

- Test Report Change Form, and

- Field deviation report.

  • Startup Quality Observation Report (SM1-PLS-GQR-5015)
  • Chapter 14 Applicability Startup Test Procedure A preliminary assessment of VEGPs Test 14.2.10.4.22 to SM1 S/U Test indicate (1) no anomalous result was identified that would impact or invalidate the first plant only startup test, and (2) the SM1 test is applicable to the VEGP test. All of VEGPs test sections were included and consistent in the SM1 first plant only startup test. An assessment summary is included in Table 2 below.

Table 2: Assessment of Sanmen Unit 1 Startup Test to Vogtle Units 3/4 UFSAR Chapter 14 Test 14.2.10.4.22 Load Follow Demonstration (First Plant Only)

VEGP S/U Test Section Requirements SM1 S/U Test VEGP & SM1 S/U Tests Step Assessment Objective Objectives are consistent,

- Demonstrate the ability of the AP1000 -1.1.1 and a Scope section is plant to follow a design basis daily load included in the S/U Test that follow cycle. provides supplemental information supportive of the

- Demonstrate the ability of the plant to -1.1.2 test, such as initial power respond to grid frequency changes while condition and the plant in the load follow cycle. control system (PLS) automatic control.

Prerequisites Prerequisites are consistent.

- The plant is operating at a stable power -6.1 level of approximately 100% power and An Initial Conditions section has been at that power for a sufficient is added to include length of time to have reached an confirmation that the reactor equilibrium xenon condition. control systems maintain OFFICIAL USE ONLY - PROPRIETARY INFORMATION 9

OFFICIAL USE ONLY - PROPRIETARY INFORMATION Load Follow Demonstration (First Plant Only)

VEGP S/U Test Section Requirements SM1 S/U Test VEGP & SM1 S/U Tests Step Assessment reactor conditions at

- Startup testing of the reactor and turbine -5.17 (5.16 equilibrium between 99.5 -

control and protection systems are corrected) 100% RTP and confirmation completed, and final setpoints are that the thermohydraulic installed. data is within limits.

- The incore instrumentation system, -5.11 A Precautions and including signal processing software, is Limitations section is added operational. All preoperational and to include other test startup testing is completed. limitations such as changes to boron concentration or

- Instrumentation and data collection -5.13 any manual operation that equipment is operational and available impacts reactivity will for logging plant data. invalidate the test. Core power distribution continuously monitor during test.

Test Method Test Method is consistent

- Prior to any load reduction, obtain -7.1.10 - 7.1.21 with the procedure steps.

thermal power measurement and Initial data conditions statepoint data along with incore power recorded and data collection distribution maps to serve as the systems setup.

reference plant condition.

Reduce and maintain reactor

- Using normal plant procedures, reduce -7.2.1 - 7.2.5 power between 49.5 -

turbine load at a rate such that a reactor 50.5% RTP for at least 2 but thermal power level of approximately 50 less than 10 hours0.417 days <br />0.0595 weeks <br />0.0137 months <br /> while percent is achieved linearly in 2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br />. obtaining data at appropriate time.

- After remaining at 50% rated thermal -7.3.7, (7.4.1 After the power maneuvers, power for more than 2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br /> but less corrected) power is raised to 100%

than 10 hours0.417 days <br />0.0595 weeks <br />0.0137 months <br />, increase turbine load at a while obtaining data at rate such that a reactor power level of appropriate time.

approximately 100% rated thermal power is achieved linearly in 2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br />.

Data collection.

- At selected times during the power -7.1.10 - 7.1.14 decrease, while at reduced power, during the power increase, and after reaching Maneuver reactor power approximately full rated thermal power, around the 50% RTP plateau obtain data from both incore and excore +/- 5% at 2%/minute turbine instrumentation to monitor plant load, record appropriate performance. data, and confirm the plant responds to grid changes.

- While within the load-follow maneuver, -7.3.3 - 7.3.6 OFFICIAL USE ONLY - PROPRIETARY INFORMATION 10

OFFICIAL USE ONLY - PROPRIETARY INFORMATION Load Follow Demonstration (First Plant Only)

VEGP S/U Test Section Requirements SM1 S/U Test VEGP & SM1 S/U Tests Step Assessment demonstrate the ability to respond to grid frequency changes by increasing and decreasing load by as much as 10%, at a rate of 2% per minute.

Performance Criteria Performance Criteria are

- Core power distribution limits, as -9.1 consistent with the SM1 test.

specified in the plant Technical SM1 test results were within Specifications, are not exceeded when the TS limits and were the plant power is varied according to the consistent with design basis load-follow cycle, or while in Westinghouse predictions the cycle, responding to load changes with no anomalies.

simulating grid frequency changes. Load follow maneuvers, including response to grid

- Load follow maneuvers, including -9.2 frequency changes, were response to grid frequency changes, can performed without changes be accomplished without changes to the to the reactor coolant boron reactor coolant boron concentration concentration.

SM1 test includes step 9.3 to confirm no manual operation during load follow maneuvers.

Passive Residual Heat Removal Heat Exchanger, Natural Circulation Test The staff reviewed the documentation associated with the Passive Residual Heat Removal Heat Exchanger (PRHRHE) Natural Circulation Test. During this test, actuation of one of the heat exchanger isolation valves is necessary to initiate flow through the heat exchanger. The staffs review did not identify any performance discrepancies with regards to the valves in the test lineup at SM1. The staff sought additional information regarding the similarity of the SM1 valves to those at VEGP Units 3 and 4. During a clarification call with the licensee, SNC indicated that the valves were manufactured using the same design specification and are procured to the same quality requirements imposed by the design specification, but the word valves had been omitted from the LAR submittal. Through discussion and context from the rest of the submittal, the staff inferred that general references in the LAR such as system components used for this test could reasonably be understood to include the valves that are actuated to initiate the test, despite their omission from the list of components in the submittal.

SNC provided Westinghouse Letter SMG_CSM_001587, Westinghouse Preliminary Evaluation on Test Data of SM1-PXS-T1P-602 Nuclear Island Contract for Nuclear Power Self-reliance Program Supporting Projects (Contract No. 07HT10500000293), dated September 10, 2018, available for audit. Noticing that the document provides only a preliminary evaluation on test data, the NRC audit team asked SNC to provide an evaluation of test data for audit, during an audit call on October 8, 2019. In response, SNC stated that the letter to the owner was preliminary in the sense that it provided immediate confirmation to the owners that the test was properly executed and the correct data collected. Therefore, the evaluation did not need to be re-performed. SNC also stated that the final calculation note is available on the ERR as OFFICIAL USE ONLY - PROPRIETARY INFORMATION 11

OFFICIAL USE ONLY - PROPRIETARY INFORMATION SM1-PXS-T2C-018, Sanmen Unit 1 PXS Startup Test Results and Validation of PRHR Performance, and that the Observation Report, also available on the ERR, includes an independent evaluation of the test data performed by SNC engineering. The NRC audit team found the SNC response satisfactory.

The NRC audit team reviewed SM1-PXS-T2C-018 that provided Westinghouse verification that the test acceptance criteria for the AP1000 PRHR performance startup test was met.

Westinghouse noted that it prepared this report according to the Westinghouse Global Management System. Westinghouse noted that key conditions reflected in the steps of the Sanmen-specific test procedure, SM1-PXS-T1P-602, AP1000 Passive Residual Heat Removal Heat Exchanger Startup Test Procedure, include the following: ((

)).

SM1-PXS-T2C-018 describes that Westinghouse adjusted the inputs developed in its predictive analysis to better match the actual test conditions to evaluate the test results against the PRHR acceptance criteria heat transfer versus time curves that were developed in the predictive analysis, which served as the initial go/no-go acceptance criterion used by the Sanmen owner immediately following the test. Westinghouse noted that following the test, it performed an initial LOFTRAN calculation. The calculation provided confidence that the test passed and that the LOFTRAN models are conservative, and the analysis provided in SM1-PXS-T2C-018 gave additional detail and sensitivity cases against the base case.

((

)).

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 12

OFFICIAL USE ONLY - PROPRIETARY INFORMATION The NRC audit team reviewed ND-EN-006-F01 for LAR 19-011, which provided SNCs evaluation of first plant only startup testing of SM1 PRHRHE natural circulation test. SNC had reviewed the following documents:

  • SM1-GV5-T2R-60091, Startup Test Report for AP1000 Passive Residual Heat Removal Heat Exchanger Startup Test Procedure, Revision 0
  • Westinghouse SM1-PXS-T2C-018, Sanmen Unit 1 PXS Startup Test Results and Validation of PRHR Performance, Revision 0
  • Westinghouse APP-PXS-M3C-509, AP1000 PRHR Plant Startup Test Criteria Development, Revision 1
  • Westinghouse Letter SMG_CSM_001587, Westinghouse Preliminary Evaluation on Test Data of SM1-PXS-T1P-602, September 10, 2018.

SNC noted that the test results were acceptable for concluding that the PRHR system performed as well, or better, then predicted by the safety analysis model with regards to the test acceptance criteria.

The NRC audit team reviewed ND-Vogtle34-RFI-1055, which responded to an SNC request for Westinghouse to review AP1000 design changes. These changes were made at one site (either SM1 or Vogtle Units 3&4) and were not also made applicable to the other site, which could have affected a standard plant design feature, such that the results of tests, including PRHRHE Natural Circulation Test, would be potentially impacted. Westinghouse noted that its review of PRHRHE Natural Circulation test procedure APP-PXS-T1P-602 and design changes did not identify any non-conformances.

H. Exit Briefing The staff conducted an exit briefing on October 16, 2019. The licensee and staff discussed that there was no need for any additional information to be provided.

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

J. Open Items and Proposed Closure Paths There were no open items as a result of this audit.

K. Deviations from the Audit Plan The duration of the audit was extended in order to allow staff additional time to examine documents that were added to the electronic reading room.

L. References

1. Southern Nuclear Operating Company, Vogtle Electric Generating Plant Units 3 and 4, Request for License Amendment Regarding Crediting Previously Completed First Plant Only OFFICIAL USE ONLY - PROPRIETARY INFORMATION 13

OFFICIAL USE ONLY - PROPRIETARY INFORMATION Startup Tests (LAR-19-011), June 28, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML19179A209).

2. Vogtle Electric Generating Plant, Unit 3, Current Facility Combined License NPF-91, Revised 09/11/2018 (ADAMS Accession No. ML14100A106).
3. Vogtle Electric Generating Plant, Unit 4, Current Facility Combined License NPF-92, Revised 09/11/2018 (ADAMS Accession No. ML14100A135).

OFFICIAL USE ONLY - PROPRIETARY INFORMATION 14

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