ML20080L927

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Audit Summary for LAR 19-017, Removal of the Preoperational Passive Residual Heat Removal Heat Exchanger Natural Circulation Test (Public)
ML20080L927
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 03/20/2020
From: Donald Habib
NRC/NRR/VPOB
To:
Don Habib EX. 1035
References
LAR 19-017
Download: ML20080L927 (5)
v • d • e


Text

Regulatory Audit Summary for License Amendment Request:

Removal of the Preoperational Passive Residual Heat Removal Heat Exchanger Natural Circulation Test (LAR 19-017)

Southern Nuclear Operating Company Vogtle Electric Generating Plant, Units 3 and 4 Docket Nos.52-025 and 52-026 A. Background By letter dated September 6, 2019, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19249C739), and supplemented by letter dated January 31, 2020, (ADAMS Accession No. ML20031E665), Southern Nuclear Operating Company (SNC) requested that the Nuclear Regulatory Commission (NRC) amend Vogtle Electric Generating Plant (VEGP) Units 3 and 4, Combined License (COL) Numbers NPF 91 and NPF 92, respectively. The License Amendment Request (LAR)19-017 requested changes to remove the preoperational passive residual heat removal (PRHR) heat exchanger natural circulation test from the scope of the VEGP Units 3 and 4 Initial Test Program (ITP). The proposed changes would revise licensing basis documents, including the Updated Final Safety Analyses Report (UFSAR) Subsections 1.9.4.2.1, 3.9.1.1.1.17, 6.3.6.1.2, and 14.2.9.1.3. In addition, COL Appendix C (and plant-specific Tier 1) Inspections, Tests, Analyses and Acceptance Criteria (ITAAC) 2.2.03.08b.01 (No. 175) would be revised to replace the PRHR heat exchanger natural circulation test with the PRHR heat exchanger forced flow test, which is described in UFSAR Subsection 14.2.9.1.3.

An audit plan was issued by the NRC staff by letter dated December 12, 2019 (ADAMS Accession No. ML19346F122). The scope of the audit was primarily focused on the review of the licensees calculations related to PRHR testing [ ]

to determine if the licensee needs to submit any additional information contained in the analyses performed in support of the requested change to support or develop conclusions for the staffs safety evaluation.

B. Regulatory Audit Basis 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) (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).

C. Audit Location and Dates The regulatory audit was conducted both on-site at the Westinghouse Electric Company (Westinghouse) office in Rockville, Maryland as well as via internet portal from November 21, 2019 to January 31, 2020.

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

  • Rebecca Patton, Branch Chief, Nuclear Methods, Systems, and New Reactors Branch
  • Nick Kellenberger, SNC
  • Kelli Roberts, SNC
  • Adana Stanish, Westinghouse F. Documents Audited Westinghouse and SNC made the documents listed in Table 1 available on the portal for NRC staff review. The documents were mostly calculations related to the [

] and performance of the PRHR system during testing.

Table 1: Documents Available for the Audit Westinghouse Title Revision Document Document No. No. Date APP-FSAR-GEF-066 Non-FPOT Preoperational PRHR HX 17 July 1, 2019

- APP-PXS-T1-501 Test Removal; Engineering & Design Markups Coordination Report, E&DCR No:

APP-FSAR-GEF-066 APP-FSAR-GLN- SNC Licensing Document Change 2, 1 June 13, 1118_Revision 1 Request (LDCR) Input; Non-FPOT 2018 Preoperational PRHR HX Test Removal APP-FSAR-GLN-1118 SNC Licensing Document Change 2, 1 June 13, LAR 19-017 Request (LDCR) Input; Non-FPOT 2018 Supplement Preoperational PRHR HX Test Removal APP-PV20-Z0R-001 Ball Valves, American Society of 3 June 7, 2019 Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class 1 APP-PXS-M3-001 Passive Core Cooling System, System 10 April 4, 2019 Specification Document APP-PXS-M3C-010 PRHR HX Line Resistances 3 December 20, 2013 APP-PXS-M3C-020 PRHR HX Sizing / Performance 2 May 4, 2018 2

Westinghouse Title Revision Document Document No. No. Date APP-PXS-M3C-101 PXS Instrumentation and Packaged 15 January 29, Mechanical System Interface 2019 Requirements APP-PXS-M3C-516 AP1000 Plant Hot Functional Tests of 1 August 12, PRHR Performance 2016 APP-PXS-M6-002 Piping and Instrumentation Diagram, 16 June 7, 2019 Passive Core Cooling System APP-PXS-T2R-101 Draft Passive Residual Heat Removal 0 August 28, (PRHR) Subsystem Report to Support 2019 the Removal of the Preoperational PRHR Natural Circulation Test APP-RCS-M3C-062 Reactor Coolant Loop Piping 2 August 7, Resistance 2013 APP-RCS-M3R-002 Baseline RCS Flow Measurement 1 February 22, Specification 2019 APP-RCS-M6-001 Piping and Instrumentation Diagram, 18 October 13, Reactor Coolant System 2017

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N/A PRHR NRC Meeting 20191205: SNC 0 December 5, LAR 19-017 Technical Discussion 2019

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Westinghouse Title Revision Document Document No. No. Date

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N/A Backup Slides: PRHR HX Natural Circ 0 August 22, Preoperational Test Removal 2019 G. Description of Audit Activities and Summary of Observations A kick-off meeting was held at the Westinghouse office in Rockville, Maryland on December 5, 2019. At this meeting Westinghouse and SNC staff gave a presentation to specify and clarify the work that Westinghouse intends to perform to support the NRC requests communicated during a public meeting on November 21, 2019 and clarified on November 26, 2019 related to SNC LAR 19-017. Technical discussions were held to determine what information NRC staff specifically wanted to see in the planned supplement to the LAR as well as a general understanding of the Westinghouse/SNC approach.

The audit continued with NRC staff review of the calculations listed in Section F via internet-based portal. NRC staff prepared two lists of questions related to the LAR and documents reviewed on the portal. The questions are available in the following: ADAMS Accession Nos. ML20042C616 and ML20042C631 (publicly available) and ML20009D083 and ML20042C588 (proprietary; non-publicly available). A clarification call was held on January 14, 2020 to assure Westinghouse and SNC understood what was being asked.

On January 24, 2020, a teleconference with Westinghouse and SNC was held to go over the NRC staff questions. At this teleconference, Westinghouse and SNC provided acceptable responses to all NRC questions. Additionally, Westinghouse and SNC made their responses available in a document on the portal for staff review.

Based on the review of the calculations made available in support of the proposed change and provided for the NRC staff review via the internet portal and SNCs supplemental submittal, dated January 31, 2020, (ADAMS Accession No. ML20031E665), the NRC staff did not identify any outstanding issues or the need for the licensee to submit any additional information on the docket.

H. Exit Briefing No outstanding issues remained at the end of the audit and no exit briefing was held.

I. Requests for Additional Information Resulting from Audit No requests for additional information were issued as a result of this audit.

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

K. Deviations from The Audit Plan The duration of the audit was extended in order to allow the staff to ask additional questions.

L. References

1. NRR-LIC-111, Regulatory Audits, December 16, 2008 (ADAMS Accession No. ML082900195).

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