ND-18-0826, Enclosure 2 to ND-18-0826, Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests

Enclosure 2 to ND-18-0826, Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests

ML18215A384
Person / Time
Site:	Vogtle
Issue date:	08/03/2018
From:	Southern Nuclear Operating Co
To:	Office of New Reactors
Shared Package
ML18215A382	List: ND-18-0826, Enclosure 2 to ND-18-0826, Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests
References
LAR-18-019, ND-18-0826
Download: ML18215A384 (397)

Text

Southern Nuclear Operating Company ND-18-0826 Enclosure 2 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Request for License Amendment:

Crediting Previously Completed First Plant and First Three Plant Tests (Non-Proprietary)

(LAR-18-019)

(This Enclosure consists of 38 pages, including this cover page)

ND-18-0826 Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests (Non-Proprietary) (LAR-18-019)

Table of Contents

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION and TECHNICAL EVALUATION

3. TECHNICAL EVALUATION (Included in Section 2)

4. REGULATORY EVALUATION 4.5 Applicable Regulatory Requirements/Criteria 4.6 Precedent 4.7 Significant Hazards Consideration 4.8 Conclusions

5. ENVIRONMENTAL CONSIDERATIONS

6. REFERENCES Page 2 of 38

ND-18-0826 Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests (Non-Proprietary) (LAR-18-019)

Pursuant to 10 CFR 52.98(c) and in accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC, or the Licensee) hereby requests an amendment to Combined License (COL) Nos. NPF-91 and NPF-92 for Vogtle Electric Generating Plant (VEGP) Units 3 and 4, respectively.

1.

SUMMARY

DESCRIPTION The requested amendment involves changes to the design-specific pre-operational tests listed in COL Condition 2.D.(2)(a), and the first plant only tests and first three plant only tests described in UFSAR Sections 3.9.2.4, 14.2.5, 14.2.9.1.3 and 14.2.9.1.9. It also involves changes to COL Appendix C (and plant-specific Tier 1) Inspections, Tests, Analyses and Acceptance Criteria (ITAAC) 2.1.03.07.i for reactor internal flow induced vibration testing. The proposed changes would revise the COLs concerning the performance of first plant testing and first three plant testing during preoperational testing, as described by License Condition 2.D.(2)(a). The proposed changes would revise the COL to delete conditions requiring the following tests:

2.D.(2)(a)1. In-Containment Refueling Water Storage Tank (IRWST) Heatup Test; 2.D.(2)(a)3. Reactor Vessel Internals Vibration Testing; 2.D.(2)(a)4. Core Makeup Tank Heated Recirculation Tests.

The requested amendment proposes changes to the COL Conditions, COL Appendix C (and corresponding plant-specific Tier 1) and Updated Final Safety Analysis Report (UFSAR) in the form of departures from the plant-specific DCD Tier 2* and Tier 2 information (as detailed in Section 2). This enclosure requests approval of the license amendment necessary to implement these changes.

UFSAR Subsection 14.2.5 provides the basis that [b]ecause of the standardization of the AP1000 design, these special tests (designated as first plant only tests) are not required on follow plants. UFSAR Subsection 14.2.5 also states for subsequent plants justification shall be provided that the results of the first plant only tests or first three plant tests are applicable to the subsequent plant. The purpose of the first plant and first three plant tests is to further establish the unique phenomenological performance parameters of the AP1000 design features.

These special tests are in addition to preoperational testing that will be completed at every AP1000 unit. The three preoperational first plant and first three plant tests listed above have been completed at the first AP1000 units at Sanmen Unit 1 and Sanmen Units 1 & 2 and Haiyang Unit 1, respectively.

A review of the Quality Assurance Regulations governing Sanmen and Haiyang has been performed to demonstrate that the requirements governing these tests are equivalent to 10 CFR 50 Appendix B. To confirm appropriate adherence to these requirements, applicability of the first plant and first three plant only tests and acceptability of the results, SNC has worked with the Sanmen and Haiyang owners and Westinghouse to review the applicable Administrative Procedures, test procedures, test reports and results. Additionally, SNC had individuals on site at Sanmen Unit 2 observing the performance of the first three plant tests. The reviews of the Quality Assurance Regulations, Administrative Procedures governing testing and the test procedures and reports have been documented by SNC. The observations made while on site at Sanmen Unit 2 have also been documented. These reviews have concluded that the test results from Sanmen Units 1 & 2 and Haiyang Unit 1 are acceptable.

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ND-18-0826 Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests (Non-Proprietary) (LAR-18-019)

The applicability of the tests to Vogtle Units 3 & 4 was validated by determining the systems, structures and components (SSCs) within the scope of the tests are designed and procured using the same standard AP1000 design requirements across Sanmen Units 1 & 2, Haiyang Unit 1 and Vogtle Units 3 & 4. Reviews of design changes were completed to confirm Sanmen Units 1 & 2 and Haiyang Unit 1 did not have any changes that would take the SSCs involved in the testing outside of the standard plant design such that the test performance would be impacted. Vogtle Units 3 & 4 have ITAAC and pre-operational test requirements associated with the SSCs involved in these tests. Completion of these ITAAC and pre-operational tests will verify that Vogtle Units 3 & 4 are within the standard plant AP1000 design as described in the Vogtle Units 3 & 4 UFSAR. The reviews completed by SNC have concluded that the first plant and first three plant testing and results completed at Sanmen Units 1 & 2 and Haiyang Unit 1 are also applicable to Vogtle Units 3 & 4.

Additionally, the Reactor Vessel Internals Vibrations Testing completed at Sanmen Unit 1 was performed following Regulatory Guide 1.20, Rev. 2. The preliminary and final reports, as specified in Regulatory Guide 1.20, Rev. 2, for Sanmen Unit 1 have been reviewed by SNC and are submitted with this requested amendment with the intent of classifying the Sanmen 1 reactor vessel internals as the valid prototype. The reactor internals design at Sanmen Unit 1 is substantially the same as the Vogtle Units 3 & 4 reactor internals.

2. DETAILED DESCRIPTION and TECHNICAL EVALUATION As described in the Combined License (COL) Condition 2.D.(2)(a), the licensee shall perform design-specific pre-operational tests including In-Containment Refueling Water Storage Tank (IRWST) Heatup Test, Reactor Vessel Internals Vibration Testing, and Core Makeup Tank (CMT) Heated Recirculation Tests.

The three tests listed above are designated as first plant only tests or first three plant only tests.

The first plant only tests and first three plant only tests are described in UFSAR Subsection 14.2.5. The tests are described as [s]pecial tests to further establish a unique phenomenological performance parameter of the AP1000 design features beyond testing performed for Design Certification of the AP600 and that will not change from plant to plant.

UFSAR Subsection 14.2.5 also provides the basis that [b]ecause of the standardization of the AP1000 design, these special tests (designated as first plant only tests) are not required on follow plants.

UFSAR Subsection 14.2.5 also states for subsequent plants justification shall be provided that the results of the first plant only tests or first three plant tests are applicable to the subsequent plant.

There are four AP1000 units being completed ahead of the Vogtle Units 3 & 4 schedule. These are Sanmen Units 1 & 2 and Haiyang Units 1 & 2. Sanmen Unit 1 has already performed the pre-operational first plant only tests described in UFSAR Subsection 14.2.5 and Sanmen Units 1

& 2 and Haiyang Unit 1 have performed the pre-operational first three plant tests described in UFSAR Subsection 14.2.5. The results of these tests have been provided to SNC for review for applicability to Vogtle Units 3 & 4. To determine if the test results are acceptable and applicable to Vogtle Units 3 & 4, various efforts have been completed to evaluate the performance of the tests and the results. The reviews performed focused on key areas including the Quality Assurance (QA) regulations and administrative procedures governing the performance of the testing, evaluation of test procedures and results, and the use of standard AP1000 designed Page 4 of 38

ND-18-0826 Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests (Non-Proprietary) (LAR-18-019)

Systems, Structures and Components (SSCs). SNC determined that the completed tests and test results accomplished their purpose and are applicable to Vogtle Units 3 & 4.

The following sections describe assessments of the QA regulations applicable to the first plant only and first three plant only tests, the Westinghouse oversight of the design and testing, the SNC observation and review of the testing, and the test results and applicability to Vogtle Units 3 & 4.

2.1 Assessment of Quality Assurance Regulation 10 CFR Part 50 Appendix B requirements apply to all activities affecting the safety-related functions of those structures, systems, or components including testing. For the first plant and first three plant tests, the design of the SSCs, the testing methods and acceptance criteria and evaluation of test results were developed by Westinghouse under a 10 CFR Part 50 Appendix B compliant program.

Performance of the first plant and first three plant only tests at Sanmen Units 1 & 2 and Haiyang Unit 1 were performed following the China regulatory quality assurance requirements specified in HAF-003-1991, Safety Regulations for Quality Assurance of Nuclear Power Plants. A review comparing the requirements of 10 CFR Part 50 Appendix B and HAF-003-1991 was completed.

This review used a matrixed table approach to compare the two regulations. The review compares the introduction and 13 sections of HAF-003-1991 to the introduction and 18 criteria of 10 CFR Part 50 Appendix B. The review concluded that the requirements of HAF-003-1991, as implemented, are comparable to and encompass the requirements of 10 CFR Part 50 Appendix B. For any specific requirements in 10 CFR Part 50 Appendix B that are not directly included in HAF-003-1991, other standards were identified that implement the same requirements of 10 CFR Part 50 Appendix B.

Based on the review of the QA regulations, the first plant and first three plant tests performed at Sanmen Units 1 & 2 and Haiyang Unit 1 were conducted following QA standards that encompass the 10 CFR Part 50 Appendix B requirements applied at Vogtle Units 3 & 4.

2.2 Oversight and Design Control Westinghouse is the design authority for the scope of systems and components involved in the first plant and first three plant testing. Because Westinghouse is the design authority for Sanmen Units 1 & 2, Haiyang Unit 1 and Vogtle Units 3 & 4 for this scope, they play a key role in maintaining standardization of the design across the units and in oversight of testing.

Westinghouse has an NRC approved 10 CFR Part 50 Appendix B program including governance of design and document control.

10 CFR Part 50 Appendix B, Criterion III states Design control measures shall be applied to items such as the following: delineation of acceptance criteria for inspections and tests.

Westinghouse engineering developed and approved the test specifications for the first plant and first three plant tests including the acceptance criteria for the tests. After initial issuance of the test specifications, changes were authorized and approved using the Westinghouse design control process. Westinghouse also worked directly with the Sanmen Units 1 & 2 and Haiyang Unit 1 owners to develop the test procedures for the first plant and first three plant tests. The test procedures and test reports were authored, verified and approved by Westinghouse test engineers and cosigned by the owners engineers. The procedures were approved by a Test Page 5 of 38

ND-18-0826 Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests (Non-Proprietary) (LAR-18-019)

Review Board, which included Westinghouse personnel, prior to use. Major changes to the test procedures were also approved by the Test Review Board. Minor changes were reviewed and approved by Westinghouse personnel. Using this process, the acceptance criteria for the first plant and first three plant tests were developed and maintained under the Westinghouse Appendix B process.

10 CFR Part 50, Appendix B, Criterion III states Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the original design unless the applicant designates another responsible organization.

The AP1000 plant is a standard design across the Sanmen, Haiyang and Vogtle units for the scope of the first plant and first three plant tests. Westinghouse created, approved and maintained the design documents governing the scope of SSCs in the first plant and first three plant tests. Any design change made to an SSC involved in the first plant or first three plant tests has been reviewed and approved by Westinghouse under the Westinghouse design control process. In the Westinghouse design control process, each of these design changes is designated with an applicability for any plant where the change would be applied. Changes which were only applicable to Sanmen Units 1 & 2 or Haiyang Unit 1 AP1000 units were reviewed for potential impacts to the first plant and first three plant test design parameters. The review was completed after completion of the testing to confirm all design changes were captured. The purpose of the review was to confirm the design of the SSCs involved in the first plant and first three plant tests at Sanmen Units 1 & 2 and Haiyang Unit 1 were not altered to be outside the standard AP1000 design such that test results could be impacted. The review of design changes concluded that there were no site-specific design changes for the Sanmen Units 1 & 2 or Haiyang Unit 1 AP1000 units which would alter any of the critical design attributes for first plant or first three plant only tests. The components involved in the testing were procured using the same design specification requirements. There is no difference between the units for these design requirements. Based on the standard AP1000 design, review of design changes, and procurement to the same quality requirements imposed by the design specification, the Sanmen Units 1 & 2 and Haiyang Unit 1 SSCs for the first plant and first three plant tests are within the standard AP1000 design. The Vogtle 3&4 units follow the same design control process described above to maintain the standard plant design. Additionally, Vogtle 3 &

4 have ITAAC on the SSCs involved in the first plant and first three plant tests. The specific ITAAC relating to each test are described in the subsections below on each specific test. The completion of these ITAAC will confirm the SSCs for the first plant and first three plant tests meet the AP1000 standard design described in the Vogtle 3&4 UFSAR.

HAF-003-1991, criterion XII requires calibration and testing of test equipment, which is comparable to 10 CFR Part 50 Appendix B criterion XII requirements. Calibration requirements for measurement and test equipment (M&TE) are specified in the Sanmen Units 1 & 2 and Haiyang Unit 1 localized procedures. Westinghouse had a team of engineers on site at both Sanmen Units 1 & 2 and Haiyang Unit 1 during performance of the first plant and first three plant tests. The Westinghouse engineers were embedded in the startup organization at the sites and worked alongside the owners as the testing was performed. Prior to the testing, Westinghouse and the owners walked-down instrumentation to confirm proper installation.

Calibration records for temporary instrumentation used for the engineering analysis were provided by the owners.

Post-test analysis of the test data was performed by Westinghouse to confirm the test results met the acceptance criteria. Westinghouse compared the test data with the predictive analysis Page 6 of 38

ND-18-0826 Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests (Non-Proprietary) (LAR-18-019) models. All computer codes used for the models used existing computer codes described in the UFSAR. No new computer codes were used for the first plant or first three plant testing. Test reports for each first plant and first three plant tests included Westinghouse engineering and safety analysis reports. The test reports were created and approved under the Westinghouse QA Program.

SNC reviewed the administrative manual procedures, test procedures, test reports and post-test analysis. The reviews were performed by knowledgeable individuals in engineering, testing and operations. NRC Inspection Procedure 70367, Inspection of Preoperational Test Program, was used for guidance in creating criteria to review the Sanmen and Haiyang administrative manual procedures. The purpose of the review was to assess the procedural processes and controls for the conduct of testing at Sanmen Units 1 & 2 and Haiyang Unit 1. NRC Inspection Procedure 70702, Part 52, Inspection of Preoperational Test Performance, was used for guidance in creating criteria to review the test procedures and reports against. The conclusion of the administrative manual procedures review is that the procedures satisfy the requirements of the NRC Inspection Procedure. For instances where the NRC Inspection Procedure requirement was not explicitly addressed in a single administrative procedure, the requirement was addressed through a combination of procedures. There were no issues identified from the administrative manual procedures reviewed that would challenge any test results. The test procedures were reviewed line-by-line using the established criteria. For any inconsistencies identified in the procedures, the issue was reviewed and dispositioned for impact to the test results. Additionally, these items were reviewed by Westinghouse. The review concluded that none of these inconsistencies would impact the test results. The post-test analysis was reviewed to confirm proper documentation, the analysis methods were appropriate and the test results meet the acceptance criteria in the Vogtle 3&4 UFSAR for each test. All reviews completed by SNC have been documented following SNC procedures.

In addition to reviewing test documentation and results, SNC performed observations of pre-operational testing at Sanmen Unit 2. Two SNC individuals, with backgrounds in engineering and operations, were on site at Sanmen Unit 2 to perform observations of the pre-operational testing including the CMT recirculation first three plant test. The objective of the visit was to observe the following activities for those specific tests:

performance of pre-test requirements, confirmation of M&TE 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.

The observations were documented in a report. The report chronicles the daily observations and access the individuals had throughout their time on site. The observations concluded the first three plant test at Sanmen Unit 2 was conducted in accordance with the test procedures.

SNC concludes that the test results are sufficient to support crediting first plant and first three plant testing completed at Sanmen Units 1 & 2 and Haiyang Unit 1 for Vogtle Units 3 & 4.

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ND-18-0826 Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests (Non-Proprietary) (LAR-18-019) 2.3 Sanmen and Haiyang Test Results and Applicability to Vogtle Units 3 & 4 2.3.1 IRWST Heatup Test - UFSAR Subsection 14.2.9.1.3, item (h)

The primary function of the passive core cooling system (PXS) is to provide emergency core cooling following postulated design basis events. The passive core cooling system emergency core decay heat removal function is verified by testing of the passive residual heat removal (PRHR) heat exchanger. One of these tests is a first plant only test to observe heatup of the IRWST. The IRWST is a large, stainless-steel lined tank located underneath the operating deck inside the containment. The IRWST is AP1000 Equipment Class C and is designed to meet seismic Category I requirements. The tank is constructed as an integral part of the containment internal structures and is isolated from the steel containment vessel except for the bottom portion of the tank wall, which is separated from the containment vessel by concrete.

The PRHR heat exchanger consists of inlet and outlet channel heads connected by vertical C-shaped tubes. The tubes are supported inside the IRWST. The top of the tubes is several feet below the IRWST water level. The passive residual heat removal heat exchanger is AP1000 Equipment Class A and is designed to meet seismic Category I requirements.

During preoperational testing of the passive core cooling system, a natural circulation test of the PRHR heat exchanger is conducted. In accordance with UFSAR Subsection 14.2.5, for the first plant only, thermocouples are placed in the IRWST to observe the thermal profile developed during the heatup of the IRWST water during PRHR heat exchanger operation. The purpose of this test is to confirm the results of the AP600 Design Certification Program PRHR tests with regards to IRWST mixing, and to quantify the conservatism in the UFSAR Chapter 15 transient analyses.

In addition to this first plant IRWST heatup test, Vogtle Units 3 and 4 will perform a PRHR heat transfer natural circulation test and a PRHR forced flow test. These tests are described in UFSAR Subsection 14.2.9.1.3, items f and g.

During the first plant test, the heatup characteristics of the IRWST water are verified by measuring the vertical water temperature gradient that occurs in the IRWST water at the PRHR heat exchanger tube bundle and at several distances from the tube bundle during the PRHR natural circulation preoperational test and the PRHR forced flow test. The acceptance criterion demonstrates that the average IRWST heatup is consistent with the PRHR heat transfer modeling in the Chapter 15 analysis. These results (in conjunction with Items f and g) are evaluated to demonstrate that the overall PRHR heat transfer performance, i.e., heat removal from the Reactor Coolant System (RCS), is conservative with respect to the analysis documented in Chapter 15.

The acceptance criterion listed in UFSAR Subsection 14.2.9.1.3, Item (h) is not intended to represent a specific quantitative value, rather it is a part of the acceptance of the tests described in UFSAR Subsection 14.2.9.1.3, Items f and g, to demonstrate that the PRHR heat exchanger heat transfer is conservatively predicted in the Chapter 15 analyses. The purpose of the IRWST Heatup Test is to collect data of the IRWST heatup profile to be used in conjunction with the other data obtained during the PRHR heat exchanger tests described in Items f and g to determine the as built PRHR heat exchanger heat transfer performance. As such, no explicit predictive analysis is performed for the IRWST heatup test alone.

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ND-18-0826 Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests (Non-Proprietary) (LAR-18-019)

The heat transfer rates calculated from the PRHR heat exchanger test data are compared to the Chapter 15 LOFTRAN code. The input parameters in the LOFTRAN code are adjusted to account for differences in the IRWST temperatures, among other parameters, as stated in Items (f) and (g) of UFSAR Subsection 14.2.9.1.3. This adjustment is necessary to normalize the Chapter 15 LOFTRAN code (which is calculated with specified conditions as described in Item (f) and Item (g) with an inlet temperature of 520°F and 250°F respectively, initial IRWST temperature of 80°F, and the design basis number of tubes plugged) with the test results to compare the allowable heat transfer rates predicted versus measured. (The LOFTRAN computer code is described in UFSAR Subsection 15.0.11.2.) The normalized test results are reviewed to confirm that the PRHR heat exchanger performs as predicted (or better than predicted) by the analysis model. Since the analysis model used for the tests is the same analysis model used for the UFSAR Chapter 15 analyses, with differences in input parameters due to the differences in the test conditions from the postulated accident conditions, the test results demonstrate that the UFSAR Chapter 15 LOFTRAN model and methodology are sufficient to conservatively predict PRHR heat exchanger performance documented in the safety analyses. Therefore, the acceptance criteria for the IRWST Heatup Test is considered satisfied if the measured IRWST temperatures demonstrate that the average IRWST heatup during the test supports a normalized PRHR heat exchanger heat transfer rate that is greater than or equal to the LOFTRAN predicted heat transfer rate for the specific conditions described for the acceptance criteria of the PRHR heat exchanger heat transfer tests.

Test Overview During Hot Functional Testing (HFT), the IRWST thermal profile developed during the heatup of the IRWST water during PRHR heat exchanger operation is measured during two tests; the PRHR heat exchanger natural circulation test and the PRHR heat exchanger forced flow test.

The results of the IRWST heatup measurement along with the measurement of the PRHR heat transfer performance of both tests are evaluated together to demonstrate that the overall PRHR heat transfer performance is conservative with respect to the UFSAR Chapter 15 LOFTRAN PRHR heat exchanger performance. A description of the PRHR heat exchanger tests and the relationship to the IRWST heatup test is provided below.

The PRHR heat exchanger forced flow test is conducted with the four reactor coolant pumps (RCPs) in operation and the RCS at a reduced temperature. Flow through the heat exchanger is initiated with the four RCPs running at 50% pump speed. The initial RCS hot leg temperature for the test is 350F. The test continues until the RCS hot leg temperature decreases to 250F.

The acceptance criteria for this test is from UFSAR Chapter 3 Table 3.9-17. The calculated heat transfer rate is 8.46E7 Btu/hr with an inlet temperature of 250°F and an initial IRWST temperature of 80°F and the design basis number of tubes plugged. The allowable calculated heat transfer rate (calculated with the Chapter 15 LOFTRAN model) is adjusted after the test to account for differences in the initial conditions of the actual test and is compared to the test calculated heat transfer rate to validate the acceptance criterion.

The PRHR heat exchanger natural circulation test is conducted by tripping the four RCPs and initiating the PRHR heat exchanger in a natural circulation mode of operation. The elevation difference between the heat exchanger and the rest of the RCS and the density change over the heat exchanger provides the driving head to circulate flow and cool the RCS. The test is initiated with an initial RCS hot leg temperature of 540°F. The test continues until the RCS hot leg temperature decreases to 420°F. The acceptance criteria for this test is from UFSAR Subsection 14.2.9.1.3, item (f), the heat transfer rate is 1.78E+08 Btu/hr based on a 520°F hot Page 9 of 38

ND-18-0826 Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests (Non-Proprietary) (LAR-18-019) leg temperature and 1.11 E+08 Btu/hr based on 420°F hot leg temperature with an 80°F IRWST temperature and the design number of tubes plugged. The allowable calculated heat transfer rate (calculated with the Chapter 15 LOFTRAN model) is adjusted after the test is run to account for differences in the initial conditions of the actual test and is compared to the test calculated heat transfer rate to verify the acceptance criterion is met.

The primary objective of the test is to determine the IRWST heatup characteristics and demonstrate that the overall PRHR heat transfer performance is conservative with respect to the UFSAR Chapter 15 safety analyses.

The IRWST heatup characteristics are verified by measuring the vertical water temperature gradient occurring in the IRWST water at the PRHR tube bundle and at different distances from the tube bundle during the PRHR heat exchanger performance tests. Resistance Temperature Detectors (RTDs) are mounted on standpipes and placed at several locations inside the IRWST for the IRWST heatup test. RTDs are mounted along each standpipe at the same vertical elevations across all the standpipes, providing a direct comparison of the vertical temperature readings and gradient. The data gathered from the RTDs for both PRHR tests provides the information necessary to characterize the IRWST heatup profile. The RTDs are separate from the permanent plant instrumentation.

The heat transfer performance of the PRHR heat exchanger is calculated using data from instruments along the flow loop from the RCS Loop 1 hot leg, through the PRHR heat exchanger, and into the Loop 1 Steam Generator. RTDs are located on the inlet and outlet lines of the PRHR heat exchanger flowpath to measure the process fluid temperature directly. A local pressure transmitter is located on the inlet line prior to the PRHR heat exchanger. These instruments are permanently installed plant instruments. In addition to the temperature measurement at the outlet of the heat exchanger, there is a flow element (pitot tube) in the PRHR heat exchanger outlet line which is used in conjunction with two temporary differential pressure transmitters to provide the volumetric flowrate in the outlet line.

The results are evaluated using a steady flow energy balance using the data taken from the instrumentation and the PRHR heat exchanger flow rate and heat transfer rate calculated.

Engineering evaluations of the PRHR performance account for measurement errors and uncertainties as identified in Regulatory Guide 1.68. ASME PTC 19.1-2005 Test Uncertainty is used as code of reference for the test evaluations. A two-sided 95% confidence level is chosen for the calculation results.

Sanmen Unit 1 has successfully performed the first plant IRWST heatup test with satisfactory results. [

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ND-18-0826 Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests (Non-Proprietary) (LAR-18-019)

] There were no deviations observed for this test. The Westinghouse review and evaluation of the test results to verify acceptability is documented in a test report. SNC reviewed the test report and concurred with the conclusions.

Applicability of Test to Vogtle Units 3 & 4 Vogtle UFSAR Subsection 14.2.5 states that justification shall be provided that the results of the first plant only test are applicable to the subsequent plant. UFSAR Subsection 14.2.5 also provides the basis that [b]ecause of the standardization of the AP1000 design, these special tests (designated as first plant only tests) are not required on follow plants. Therefore, verifying standardization of the component design between Sanmen Unit 1 and Vogtle Units 3 &

4 provides the basis that the successful test results from Sanmen Unit 1 are applicable to Vogtle Units 3 & 4.

The critical design and construction attributes for this test and for the overall LOFTRAN PRHR heat transfer model are:

PRHR Heat Exchanger design including inlet and outlet channel heads; PRHR inlet and outlet piping and fittings, and valves design; Location of the PRHR heat exchanger relative to the hot and cold legs, steam generator, and IRWST; and Free IRWST volume.

For these components, standard design and procurement documentation is used for Sanmen Unit 1 and Vogtle Units 3 & 4. The reactor vessel, steam generators, reactor coolant pumps, PRHR heat exchanger and RCS pressure boundary piping including the PRHR inlet and outlet Page 11 of 38

ND-18-0826 Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests (Non-Proprietary) (LAR-18-019) lines are all manufactured using the same design specification, are procured to the same quality requirements imposed by the design specification and are built to the same standard tolerances.

The IRWST is formed by six structural modules (CA01, CA02, CA03, CA55, CA56 and CA57).

All of these structural modules are designed using the same standard design drawings. The IRWST has a standardized minimum volume requirement that is the same for all AP1000 Units.

The use of standard design documentation confirms that the PXS and RCS system components used for this test are within the standard AP1000 design parameters. Any design changes made to any of these standard components are captured in the Westinghouse design change process.

A review has confirmed that there are no site-specific design changes for either Sanmen Unit 1 or Vogtle Units 3 & 4 that alter the standard design features for any of the components involved in this test.

In addition to using standard design and procurement requirements, Vogtle Units 3 & 4 have multiple ITAAC which are applicable to the components involved in this test. Sanmen Unit 1 uses these same acceptance criteria. The following ITAAC will confirm the critical design and construction attributes related to this test for Vogtle Units 3 & 4:

ITAAC No. 2.2.03.08b.02 (PRHR center line elevation);

ITAAC No. 2.2.03.08c.vi.03 (PRHR inlet line sloping);

ITAAC No. 2.2.03.08c.iv.04 (PRHR outlet line to SG elevation); and ITAAC No. 2.2.03.08c.iii (IRWST volume).

Vogtle Units 3 & 4 will still perform all other PXS pre-operational tests described in UFSAR Subsection 14.2.9.1.3 which will verify the installed components and associated piping and valves properly perform their design function. These preoperational tests include the PRHR Heat Transfer capability and a natural circulation test.

Based on the use of standard designed components, ITAAC for critical design features and pre-operational tests, the boundary conditions for the IRWST heatup test are the same for Sanmen Unit 1 and Vogtle Units 3 & 4.

Therefore, the successful completion of the first plant IRWST heatup test at Sanmen Unit 1 is applicable to Vogtle Units 3 & 4 and the first plant test is not required to be performed at Vogtle Units 3 & 4.

Change Description As stated above, the first plant IRWST heatup test was successfully completed at the first AP1000, Sanmen Unit 1, and the results are applicable to Vogtle Units 3 & 4. Therefore, the IRWST heatup test is proposed to be deleted from the UFSAR Subsection 14.2.5, first plant tests, and UFSAR Subsection 14.2.9.1.3, PXS pre-operational tests. Specifically, the proposed changes are:

COL Condition 2.D.(2)(a)1 requires the licensee to perform an IRWST heatup test as described in UFSAR 14.2.9.1.3, item (h). This COL condition is proposed to be deleted based on the successful completion of the test at the first AP1000.

UFSAR Subsection 14.2.5 describes the first plant only tests, including IRWST heatup.

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ND-18-0826 Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests (Non-Proprietary) (LAR-18-019)

A statement is proposed to be added that the test will not be run at Vogtle Units 3 & 4 based on the successful completion of the test at the first AP1000.

UFSAR Subsection 14.2.9.1.3, item (h), describes the general test methods and acceptance criteria for the IRWST heatup test. The IRWST heatup test is proposed to be deleted from this section because the test will not be run at Vogtle Units 3 & 4 based on the successful completion of the test at the first AP1000.

2.3.2 Reactor Vessel Internals Vibration Testing - UFSAR Subsection 14.2.9.1.9 The Comprehensive Vibration Assessment Program (CVAP) confirms the long-term, steady-state vibration response of the reactor internals for operating steady-state and transient conditions. The three aspects of this evaluation are the following: a prediction of the vibrations of the reactor internals (based in part on previous scale model tests), a preoperational vibration test program of the internals of the first plant, and a correlation of the analysis and test results.

AP1000 vibration assessment program requirements are currently described in topical reports WCAP-17983 and WCAP-17984. These reports are incorporated by reference documents in the UFSAR. These program requirements are applicable to the testing completed at Sanmen Unit 1 and are also applicable to Vogtle Units 3 & 4.

UFSAR Subsections 14.2.5 and 14.2.9.1.9 describes the reactor internals instrumented vibration testing as a first plant only test. UFSAR Subsection 14.2.5 states the preoperational vibration test program for the reactor internals of the AP1000 conducted on the first AP1000 is consistent with the guidelines of Regulatory Guide 1.20 for a comprehensive vibration assessment program. This program is discussed in UFSAR Subsection 3.9.2. UFSAR Subsection 3.9.2.4 describes the first AP1000 reactor internals as a prototype. The UFSAR states with respect to the reactor internals preoperational test program, the first AP1000 plant reactor vessel internals are classified as a prototype as defined in Regulatory Guide 1.20.

Sanmen Unit 1, as the first AP1000 reactor internals, is proposed to be classified as a valid prototype in accordance with Regulatory Guide (RG) 1.20. Conformance to RG 1.20, Revision 2, is described in UFSAR Appendix 1A. In accordance with RG 1.20, to classify Sanmen as the valid prototype, the detailed results of the program should be included in an application related to a non-prototype and should address all the provisions within the Regulatory Guide. Vogtle Units 3 & 4, as a subsequent AP1000 plant, is proposed to be classified as the non-prototype, category 1 as defined in RG 1.20.

Test Overview As described in UFSAR Subsection 14.2.9.1.9, during hot functional testing (HFT) of the AP1000 plant, the reactor vessel internals (RVI) are monitored as a part of the CVAP. The program demonstrates that the RVI are adequately designed to withstand flow-induced vibration (FIV) forces during normal and anticipated transient plant operating conditions for the design life of the plant. The program is performed in accordance with Regulatory Guide 1.20, Revision 2, Comprehensive Vibration Assessment Program for Reactor Internals during Preoperational and Initial Startup Testing.

In accordance with RG 1.20, Revision 2, the first constructed AP1000 plant RVI assembly at Sanmen Unit 1 is classified as a Prototype. The CVAP for a Prototype RVI configuration includes the following elements:

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Vibration Analysis Program The analysis program consists of a vibration analysis for steady-state and anticipated transient conditions corresponding to preoperational and initial startup test and normal operating conditions. This includes creating structural and hydraulic models, determining natural frequencies and associated mode shapes, and estimating random and deterministic forcing functions. The analysis program also calculates expected and acceptable responses for selected vibration measurement program sensor locations and develops acceptance criteria for the vibration measurement program, including permissible deviations.

Vibration Measurement Program The in-plant vibration measurement program verifies the structural integrity of the RVI for FIV, determines the margin of safety associated with steady-state and anticipated transient conditions for normal operation, and verifies the results of the analysis program. Margin of safety in a particular component is established by comparing the limiting measured response in the component to the maximum allowable response at the measurement location. Appropriate transducers are placed throughout the RVI to monitor significant lateral, vertical, and torsional motions of major RVI components in the significant modes of vibration, and their hydraulic responses. The transducer data is recorded for the steady-state and bounding anticipated transient modes of operation (flow transients), including expected reactor coolant pump (RCP) speeds and combinations permissible during the hot functional test (HFT). The selected test duration with plant operation at normal operating modes confirms that each critical component experiences at least 106 cycles of vibration (computed at the lowest frequency for which the component has a significant structural response) prior to the final inspection.

Inspection Program The inspection program consists of pre-HFT and post-HFT inspections of the RVI. The inspection program includes a tabulation of the RVI components and local inspected areas, and a description of the inspection procedure including inspection method, documentation, access provisions, and any specialized equipment used during inspection.

Documentation of Results A review and correlation of the results of the analysis, vibration measurement, and inspection program are conducted following completion of the inspection program to determine if the acceptance criteria are satisfied. Evaluation of the results and a description of any modifications or actions necessary to demonstrate the structural adequacy of the RVI are documented in preliminary and final reports.

The analysis, measurement, and inspection programs for the AP1000 plant CVAP are provided in two WCAPs that satisfy the requirements of Regulatory Guide 1.20, Revision 2, Sections C.2.1, C.2.2, and C.2.3. WCAP-17984, Comprehensive Vibration Assessment Program (CVAP)

Vibration Analysis Program for the AP1000 plant contains a description of the AP1000 plant RVI, vibration analysis methodology, response predictions for the RVI components, and acceptance criteria for applicable sensor locations. WCAP-17983, Comprehensive Vibration Page 14 of 38

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Assessment Program (CVAP) Measurement and Inspection Programs for the AP1000 Plant contains the description of measurement and inspection programs for the AP1000 plant CVAP.

It is important to note that WCAP-17983 provides additional sensor locations that were not included in DCD, Rev. 19 (via the Incorporated by Reference document WCAP-15949). The additional sensor locations provide redundancy that was not included at the time of the AP1000 design certification.

For the CVAP performed at Sanmen Unit 1, Westinghouse wrote both a Preliminary Report (APP-GW-GLR-179 (Proprietary) and APP-GW-GLR-180 (Non-Proprietary)) and a Final Report (APP-GW-GLR-181 (Proprietary) and APP-GW-GLR-182 (Non-Proprietary)). The Preliminary Report contains the evaluation of the Sanmen Unit 1 CVAP Vibration Measurement and Inspection Program results with respect to the test acceptance criteria. [

] The Preliminary Report satisfies the requirements in Section C.2.4.1 of Regulatory Guide, 1.20 Revision 2.

The Final Report provides a comparison of analytical predictions, test measurements, and inspections. Descriptions of any significant deviations, comparisons between measured and analytical responses, determination of high-cycle fatigue margins for component responses, and evaluation of unanticipated observations are included. The Final Report concluded that there were no modifications or actions necessary to demonstrate the structural adequacy of the RVI.

The Final Report satisfies the requirements in Section C.2.4.2 of Regulatory Guide 1.20, Revision 2.

SNC reviewed the test reports and concurred with the conclusions.

Framework for Implementing Regulatory Guide 1.20 Guidance for the CVAP for prototype reactor internals is outlined in Section C.2 of Regulatory Guide 1.20, Revision 2. The framework established for the AP1000 CVAP to implement these regulatory guidelines is presented in Table 1. The regulatory guidelines are presented along with the corresponding elements of the AP1000 CVAP.

Table 1. Framework for AP1000 RVI CVAP Implementation of U.S. Regulatory Guide 1.20 U.S. Regulatory Guide 1.20, Part C.2 CVAP Report(s)

Section(s) Guidelines Section(s) Program Elements CVAP Vibration Analysis Program (WCAP-17984) 2.1 Vibration Analysis Program 5 Description of vibration analysis program 6, 7 Justification of the CVAP configuration and acceptance criteria 2.1.1 The theoretical structural and 5.2, 5.3 Structural models hydraulic models and analytical 5.4 Hydraulic models formulations or scaling laws and scale models used in the analysis. 7.1.2 Scaling relationships Page 15 of 38

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Table 1. Framework for AP1000 RVI CVAP Implementation of U.S. Regulatory Guide 1.20 U.S. Regulatory Guide 1.20, Part C.2 CVAP Report(s)

Section(s) Guidelines Section(s) Program Elements 2.1.2 The structural and hydraulic system 5.3 Structural modes and frequencies natural frequencies and associated mode shapes which may be excited during steady state and anticipated transient operation.

2.1.3 The estimated random and 5.4 Forcing function development deterministic forcing functions, including any very-low-frequency components, for steady state and anticipated transient operation.

2.1.4 The calculated structural and 5.5 Predictions are provided of RVI component hydraulic responses for steady state structural responses and subsequent and anticipated transient operation. limiting locations relative to normal operating and test related plant operating conditions.

2.1.5 A comparison of the calculated 6 General analysis methodologies are structural and hydraulic responses described, including the approach for for preoperational and initial startup extrapolating preoperational test results to testing with those for normal normal operating conditions.

operation.

2.1.6 The anticipated structural or 5.4 Component structural evaluations provide hydraulic vibratory response (defined predictions of anticipated structural in terms of frequency, amplitude, and responses at CVAP sensor locations modal contributions) that is during CVAP testing.

appropriate to each sensor location for steady-state and anticipated transient pre-operational and startup conditions.

2.1.7 The test acceptance criteria with 7, 8 Acceptance criteria include consideration permissible deviations and the basis of predictive analysis and measurement for the criteria. uncertainties.

CVAP Measurement Program (WCAP-17983) 2.2 Vibration Measurement Program 4 Description of the Measurement Program 2.2.1 Description of data acquisition and 4.2, 4.3 Transducer types, specifications, reduction system. frequency/amplitude ranges 4.1, 4.2 Transducer locations, descriptions 4.3 Precautions during design, installation 4.3 Transducer redundancy 4.3 Transducer testing Page 16 of 38

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Table 1. Framework for AP1000 RVI CVAP Implementation of U.S. Regulatory Guide 1.20 U.S. Regulatory Guide 1.20, Part C.2 CVAP Report(s)

Section(s) Guidelines Section(s) Program Elements 4.4 Data acquisition system and analysis, including frequency and modal content, precautions during data collection, signal conditioning, real-time frequency and time-domain analysis.

4.4 Discussion of data analysis 2.2.2 Test operating conditions 5.1, 5.2, CVAP steady-state and transient test 5.3 conditions, test data collection points, required duration of testing, description and justification of test vs. normal operating conditions and configurations, disposition of fuel assemblies.

3.1, 3.2 Design configuration (normal operating),

test configuration 2.3 Inspection Program 6 Description of the Inspection Program 2.3.1 Tabulation of RVI components and 6.1 Detailed tabulation of inspection locations, areas to be inspected. type of inspections performed, and inspection methods.

2.3.2 A tabulation of specific inspection 6.2 Areas to be inspected, basis for areas that can be used to verify inspections.

segments of the vibration analysis and measurement program.

2.3.3 A description of the inspection 6.1, 6.3 Detailed inspection methods noted for procedure each of the tabulated inspection locations.

CVAP Preliminary Report (APP-GW-GLR-179 (Proprietary) and APP-GW-GLR-180 (Non-Proprietary))

2.4, 2.4.1 The preliminary report should 3.2.1 [ ]

summarize an evaluation of the raw 3.5.5 [ ]

and, as necessary limited processed data and the results of the inspection 3.6 Component measured responses are program with respect to the test compared to the acceptance criteria acceptance criteria. Anomalous data 4.2 Pre-HFT and post-HFT inspection results that could bear on the structural integrity of the reactor internals 2, 5 Conclusions demonstrating acceptable should be identified, as should the measurement and inspection results.

method to be used for evaluating such data.

CVAP Final Report (APP-GW-GLR-181 (Proprietary) and APP-GW-GLR-182 (Non-Proprietary))

2.4, 2.4.2 The final report should include:

2.4.2.a A description of any deviations from 4.2.1 [ ]

the specified measurement and 4.5.5 [ ]

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Table 1. Framework for AP1000 RVI CVAP Implementation of U.S. Regulatory Guide 1.20 U.S. Regulatory Guide 1.20, Part C.2 CVAP Report(s)

Section(s) Guidelines Section(s) Program Elements inspection programs, including 4.7.2.3 [ ]

instrumentation reading and inspection anomalies, instrumentation malfunctions, and deviations from the specified operating conditions.

2.4.2.b A comparison between the 4.6 Comparison of predicted vs. measured measured and analytically responses, predicted vs. measured determined modes of structural and damping.

hydraulic response (including those 4.7 Discussion of forcing functions parameters from which the input forcing function is determined) for the purpose of establishing the validity of the analytical technique.

2.4.2.c A determination of the margin of 4.6 Detailed evaluation of measured margins safety associated with normal 2, 6 Overall conclusions demonstrating steady-state and anticipated successful analysis program and transient operation. acceptable measurement and inspection results.

2.4.2.d An evaluation of measurements that N/A No acceptance limits were exceeded; no exceeded acceptable limits not observations represented deviations in the specified as test acceptance criteria measured responses.

or of observations that were unanticipated and the disposition of such deviations.

2.4.3 If necessary, include an evaluation N/A No modifications or actions to the RVI and description of the modifications were necessary to demonstrate the or actions planned in order to justify structural adequacy of the RVI.

the structural adequacy of the reactor internals.

2.4.4 The collection, storage and CVAP Records related to the CVAP are stored in maintenance of all records relevant Functional accordance with the CVAP Functional to the analysis, measurement and Specificati Specification which comply with NQA-1 inspection phases of the CVAP on 1994. Note that Regulatory Guide 1.88 is should be consistent with U.S. withdrawn and not applicable to Vogtle Regulatory Guide 1.88. Units 3 & 4.

2.5 This section covers schedule during the construction permit review which is not applicable to Vogtle Units 3 & 4 at this point.

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[

]

Applicability to Vogtle Units 3 & 4 UFSAR Subsection 14.2.5 states that justification shall be provided that the results of the first plant only test are applicable to the subsequent plant. UFSAR Subsection 14.2.5 also provides the basis that [b]ecause of the standardization of the AP1000 design, these special tests (designated as first plant only tests) are not required on follow plants. RG 1.20 states that non-prototype, category I reactor internals are those configurations that have substantially the same arrangement, design, size and operating conditions as specified valid prototype, for which nominal differences in arrangement, design, size, and operating conditions have been shown (by test or analysis) to have no significant effect on the vibratory response and excitation of those reactor internals important to safety. Based on these UFSAR and RG 1.20 requirements, verifying standardization of the reactor internal configuration between Sanmen Unit 1 and Vogtle Units 3 & 4 provides the basis that the Vogtle Units 3 & 4 reactor internals are substantially the same as the valid prototype, Sanmen Unit 1.

Sanmen Unit 1 is an implementation of the AP1000 plant standard design, with the RVI designed in accordance with the generic AP1000 RVI design specification and qualified in the generic AP1000 RVI design report. The differences between the generic RVI design and the Sanmen Unit 1 RVI as-built configuration were reconciled in the Sanmen Unit 1 plant-specific RVI design report in accordance with ASME Boiler and Pressure Vessel Code,Section III, NCA-3554. Considering the as-built configuration, the Sanmen Unit 1 RVI are substantially similar to, and therefore representative of, the generic RVI design.

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As with Sanmen Unit 1, the Vogtle Units 3 & 4 RVI are designed and qualified in accordance with the generic RVI design specification and design report, with as-built conditions to be reconciled in a plant-specific design report. The as-built configuration at Vogtle Units 3 & 4 is to be evaluated and any necessary ASME Code reconciliations will be performed. It is expected that the as-built configuration will be substantially similar to the generic design; therefore, the RVI would be appropriately represented by the Sanmen Unit 1 RVI.

For Sanmen Unit 1, the electrical grid operates at 50 Hz, while the reactor coolant pumps (RCP) are driven by variable frequency drives (VFD) operating at 60 Hz. For Vogtle Units 3 & 4, both the electrical grid and RCP VFDs operate at 60 Hz. Since the VFDs operate at the same frequency in both cases, there is no impact on the CVAP. Furthermore, potential line noise or VFD noise is accounted for in the analysis/post-processing of the test data.

In addition to using standard design and procurement requirements, Vogtle Units 3 & 4 has multiple ITAAC which are applicable to the components involved in CVAP. Sanmen 1 uses these same acceptance criteria. The following ITAAC will confirm the critical design and construction attributes related to CVAP:

ITAAC No. 2.1.02.01 (Inspection of As-built System - RCS functional arrangement);

ITAAC No. 2.1.03.01 (Inspection of As-built System - RXS functional arrangement);

ITAAC No. 2.1.03.02a (Inspection of As-built System - Fuel assembly positions and CRDMs);

ITAAC No. 2.1.03.02b (Inspection of As-built System - Control assemblies and drive rods); and ITAAC No. 2.1.03.02c (Inspection of As-built System - Reactor Vessel Arrangement).

Based on the standard AP1000 reactor internals design, use of standard design and procurement requirements and ITAAC confirming the as-built reactor internals design, the Vogtle Units 3 & 4 reactor internals are substantially the same as Sanmen Unit 1 reactor internals, the specified valid prototype. Therefore, Vogtle Units 3 & 4 satisfies the RG 1.20 guidelines to be classified as non-prototype, category I and is proposed to be classified as such.

As a proposed non-prototype, category I reactor internal design, Vogtle Units 3 & 4 would not perform an instrumented CVAP as specified in RG 1.20 and described in UFSAR Subsections 3.9.2.4, 14.2.5 and 14.2.9.1.9, and ITAAC 2.1.03.07.i. Vogtle Units 3 & 4 would perform a non-instrumented CVAP which is consistent with RG 1.20 for non-prototype, category I. This is specified in ITAAC 2.1.03.07.ii.

In accordance with RG 1.20, the results of the prototype reactor internals CVAP should be submitted to the Commission in the form of preliminary and final reports. These reports are also required to satisfy the acceptance criteria of ITAAC 2.1.03.07.i. These reports (SM1-CVAP-T2R-200 and SM1-CVAP-T2R-300) are being submitted as part of this amendment request.

Therefore, the intent of ITAAC 2.1.03.07.i is satisfied by submittal of the preliminary and final reports and is no longer necessary for Vogtle Units 3 & 4 and is proposed to be deleted.

Change Description As stated above, the first plant vibration test program for the reactor internals was successfully Page 20 of 38

ND-18-0826 Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests (Non-Proprietary) (LAR-18-019) completed at the first AP1000, Sanmen Unit 1. Sanmen Unit 1 is proposed to be classified as the prototype reactor internals as defined in RG 1.20. Vogtle Units 3 & 4 are proposed to be classified as non-prototype, category I reactor internals as defined in RG 1.20. Specifically, the proposed changes are:

COL Condition 2.D.(2)(a)3 requires the licensee to perform reactor vessel internals vibration testing as described in UFSAR Subsection 14.2.9.1.9. This COL condition is proposed to be deleted based on the successful completion of the test at the first AP1000.

COL Appendix C (and plant-specific Tier 1) Table 2.1.3-2, ITAAC 2.1.03.07.i requires a vibration type test be conducted on the first unit reactor internals representative of AP1000 and that a report exists and concludes the reactor internals have no observable damage or loose parts as a result of the vibrations type test. This portion of the ITAAC is proposed to be deleted because Vogtle Units 3 & 4 will not perform an instrumented vibration test. The report for the first AP1000 unit referenced in the acceptance criteria of the ITAAC is being submitted as part of this amendment request.

COL Appendix C, Subsection 2.1.3, is editorially revised to renumber the items under the Design Description consistent with the Plant-Specific Tier 1 information numbering.

UFSAR Subsection 3.9.2.4 describes the pre-operational flow-induced vibration testing of reactor internals. This subsection is proposed to be revised to describe Sanmen Unit 1 as the prototype reactor internals and Vogtle Units 3 & 4 as non-prototype, category I reactor internals consistent with the guidance in RG 1.20. Discussion of reference plants used prior to Sanmen Unit 1 testing is proposed to be deleted.

UFSAR Table 3.9-4 provides the locations for the first plant reactor internals vibration measurement program transducer locations. This table is proposed to be deleted because Vogtle Units 3 & 4 will not perform an instrumented CVAP and the instruments described in the table will not be used.

UFSAR Subsection 14.2.5 describes the first plant only tests, including reactor internals vibration testing. A statement is proposed to be added that the instrumented vibration test will not be run at Vogtle Units 3 & 4 based on the successful completion of the test at the first AP1000. Vogtle Units 3 & 4 will perform a non-instrumented CVAP which is consistent with the guidance of RG 1.20 for non-prototype, category I reactor internals.

UFSAR Subsection 14.2.9.1.9, describes the reactor vessel internals vibration testing.

The test requirements for an instrumented CVAP are proposed to be deleted from this subsection because Vogtle Units 3 & 4 will not perform an instrumented CVAP. Vogtle Units 3 & 4 will perform a non-instrument CVAP which is consistent with the guidance of RG 1.20 for non-prototype, category I reactor internals.

2.3.3. Core Makeup Tank Heated Recirculation Tests - UFSAR Subsection 14.2.9.1.3, items (k) and (w)

The PXS has two core makeup tanks (CMTs). The CMTs are vertical, cylindrical tanks with hemispherical upper and lower heads. They are made of carbon steel, clad on the internal Page 21 of 38

ND-18-0826 Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests (Non-Proprietary) (LAR-18-019) surfaces with stainless steel. The core makeup tanks are AP1000 Equipment Class A and are designed to meet seismic Category I requirements. They are located inside containment on the 107-foot floor elevation. The core makeup tanks are located above the direct vessel injection line connections to the reactor vessel, which are located at an elevation near the bottom of the hot leg. The core makeup tanks provide injection for an extended time after core makeup tank actuation when in recirculation mode.

As described in UFSAR Subsection 14.2.5, during preoperational testing of the PXS, a test is performed for each plant to verify the CMT inlet piping resistances. In addition, cold draining tests of the CMTs are conducted that verify the discharge piping resistance and proper drain rate of the CMTs for each plant. For the first three plants, two additional CMT tests are conducted during hot functional testing of the RCS. These tests are a natural circulation heatup of the CMTs followed by a test to verify the ability of the CMTs to transition from a recirculation mode to a draindown mode while at elevated temperature and pressure.

Operation of the CMTs in their natural circulation mode is conducted on the first three plants only for the following reasons:

Natural circulation of the CMTs will not vary from plant to plant, provided that the other verifications discussed above are performed as specified; Natural circulation testing of the CMTs was extensively tested as part of the Design Certification Tests; and Performance of this test results in a significant thermal transient on Class 1 components including the CMTs and the direct vessel injection nozzles. The current component and system design considers 5 transient cycles. Elimination of this test will result in additional conservatism in the fatigue analysis.

2.3.3.1 Core Makeup Tank Recirculation Test UFSAR Subsection 14.2.9.1.3 describes the general test method and acceptance criteria for the CMT recirculation test. Proper operation of the core makeup tanks to perform their reactor water makeup and boration function is verified by initiating recirculation flow through the tanks during hot functional testing with the reactor coolant system at 530°F. This testing is initiated by simulating a safety signal which opens the tank discharge isolation valves and stops reactor coolant pumps after the appropriate time delay. The proper tank recirculation flow after the pumps have coasted down is verified. Based on the cold leg temperature, CMT discharge temperature, and temporary CMT flow instrumentation, the net mass injection rate into the reactor is verified.

Predictive Analysis The CMT recirculation test was simulated using the NOTRUMP computer code used for small break loss-of-coolant accident (SBLOCA) analyses and described in UFSAR Subsection 15.6.5.4B.2.1.

The UFSAR Chapter 15 SBLOCA NOTRUMP model was used as the starting model for the CMT recirculation predictive analysis. The model was updated to reflect the initial RCS conditions, including a reduced RCS pressure and nominal operating temperature. Additionally, Page 22 of 38

ND-18-0826 Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests (Non-Proprietary) (LAR-18-019) the NOTRUMP code does not contain a thermal stratification model, which along with coarse CMT noding, will lead to differences between the CMT fluid temperatures predicted by NOTRUMP and the test. This was observed and discussed within the NOTRUMP final validation report for the AP600. Due to the importance of the movement of the hot layer within the CMT for this test, increased CMT nodalization was implemented to help account for the lack of a CMT thermal stratification model in NOTRUMP and improve the prediction of the CMT temperature and flow rate.

The CMT recirculation test was initialized by manual CMT actuation which causes the CMT outlet valves to open and the RCPs to trip. To provide a range of expected flow rates, the predictive analysis modeled the minimum and maximum CMT line resistances.

The acceptance criteria are listed in UFSAR Subsection 14.2.9.1.3, Item (k). A number of the specific test acceptance criteria are demonstrated by proper operation of the equipment and are not dependent on the predictive analysis.

The test acceptance criteria to verify proper tank recirculation flow and the net mass injection rate into the reactor are based on the predictive analysis performed with the NOTRUMP code.

The predictive analysis varied the CMT line resistance (maximum and minimum line resistances were modeled) to provide the expected range of flow from the CMT outlet. The results of the predictive analysis are compared directly to the CMT outlet flow rates from the tests to demonstrate that the appropriate flow rate is obtained. The CMT temperatures in the NOTRUMP predictive analysis will diverge from the test results as the hot layer descends through the tank due to the perfect mixing that occurs in each control volume. Considering this expected behavior, the time to recirculate approximately half of the CMT tank was calculated using the NOTRUMP results and provides a direct comparison to when the hot layer will reach the thermocouple at the midpoint elevation of CMT in the test. This validates that the appropriate mass is injected into the reactor.

Test Overview During HFT, a CMT recirculation test is performed to verify that both CMTs provide sufficient reactor water makeup and boration. The initial conditions of the test include a uniform CMT temperature full of cold water and the RCS 530°F. This test is initiated by opening the CMT discharge isolation valves of both CMTs simultaneously which trips the RCPs after a certain delay. The CMT recirculation flow after the pumps have coasted down is measured with temporary instrumentation and is compared to the acceptance criteria established with the USFAR Chapter 15 LOCA NOTRUMP computer code. (The NOTRUMP computer code is described in UFSAR Subsection 15.6.5.4B.2.1.) In addition to verifying the CMT recirculation flow rates, this test confirms that the CMT recirculation behavior consistent with the AP600 separate effect and integral effect tests.

The CMTs are located at an elevation above the core and are filled with borated water and provide the RCS makeup and boration for the LOCA and non-LOCA events. Each CMT is made of carbon steel, clad on the inside surfaces with stainless steel and have a volume of greater than 2487 ft3 (COL Appendix C ITAAC 2.2.03.08c.vi.01) with an inlet line that connects one of the cold legs to the top of the CMT and an outlet line that connects the bottom of the CMT to the direct vessel injection (DVI) line. The DVI line is connected to the reactor vessel downcomer.

The CMT inlet valve is normally open, therefore the CMT is at primary system pressure. The Page 23 of 38

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CMT outlet valves are normally closed, preventing natural circulation during normal operation.

When one of the outlet valves is open, a natural circulation path is established. Cold borated water flows into the reactor vessel and hot primary fluid is drawn upward into the top of the CMT through the inlet line.

The CMTs can operate in two different modes, depending on the RCS conditions. If the cold legs are filled with water, CMTs operate in a water recirculation mode with the driving force based on gravity and on the density difference between the hot reactor coolant in the CMT balance line and the colder water in the CMT. If the cold legs become voided, as they do during LOCAs, the CMTs will operate in a steam displacement injection or steam drain-down mode. In this mode, the driving force is based on gravity and the density difference between steam from the cold legs and water in the CMTs.

The primary objective of the CMT recirculation test is to measure the CMT recirculation flow rates and the CMT temperature distribution in a natural circulation mode.

CMT temperature distribution is measured with permanently installed nonsafety related RTDs located inside the CMTs. These RTDs are used to confirm that the CMT temperature is maintained within the bounds of the plant Technical Specifications. Temperature indications of these RTDs are also used to monitor CMT temperature during PXS operation. Each channel provides a signal to the PLS, which provides temperature indication and alarms in the main control room.

Temporary test instrumentation is also installed on the CMT discharge line to measure flow and calibrated under cold conditions prior to the recirculation test. Differential pressure transmitters and ultrasonic flowmeters (UFMs) are installed to provide diverse flow measurements which allow for the full range of flows from the CMT to be measured with sufficient accuracy. UFMs provide direct flow measurement while the differential pressure transmitters provide the differential pressure of the CMT injection line. Differential pressure is then converted to flow.

Engineering evaluations of the CMT flow rates account for measurement errors and uncertainties as required by the Regulatory Guide 1.68. ASME PTC 19.1-2005, Test Uncertainty, is used as code of reference for the test evaluations. A two-sided 95% confidence level is chosen for the calculation results.

[

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]

The reproducibility of the results between the units demonstrates that the CMT performance during recirculation does not vary significantly from plant to plant. This reproducibility of plant performance is the result of the AP1000 standardization concept. No deviations were observed during these tests. The Westinghouse review and evaluation of the test results to verify acceptability is documented in a test report. Haiyang Unit 1 successfully performed the CMT recirculation test with similar results to Sanmen Units 1 & 2. SNC reviewed the test reports for Sanmen Units 1 & 2 and Haiyang Unit 1 and concurred with the conclusions.

2.3.3.2 Core Makeup Tank Draindown Test UFSAR Subsection 14.2.9.1.3 describes the general test method and acceptance criteria for the CMT draindown test. In conjunction with the verification of the core makeup tanks to perform their reactor water makeup function and boration function described above, the proper operation of the core makeup tanks to transition from their recirculation mode of operation to their draindown mode of operation after heatup is verified. This testing also verifies the proper operation of the core makeup tank level instrumentation to operate during draining of the heated tank fluid. The IRWST initial level is reduced to at least 3 feet below the spillway level as a prerequisite condition for this testing in order to provide sufficient ullage to accept the mass discharged from the reactor coolant system via the automatic depressurization stage 1.

The recirculation operation in the CMT, described above, is continued until the core makeup tank fluid has been heated to 350°F. The core makeup tank isolation valves are then closed, the reactor coolant pumps are started, and the reactor coolant system is reheated up to hot functional testing conditions. This testing is initiated by shutting off the reactor coolant pumps, opening the core makeup tank isolation valves, and by opening one of the automatic Page 25 of 38

ND-18-0826 Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests (Non-Proprietary) (LAR-18-019) depressurization stage 1 flow paths to the IRWST. This initiates a large loss of mass from the reactor coolant system, depressurization of the reactor coolant system to the bulk fluid saturation pressure, and additional recirculation through the core makeup tank. Core makeup tank draindown initiates in response to the continued depressurization and mass loss from the reactor coolant system. The automatic depressurization stage 1 flow path is closed after the core makeup tank level has decreased below the level at which stage 4 actuation occurs.

Predictive Analysis The CMT draindown test was simulated using the NOTRUMP computer code used for small break loss-of-coolant accident (SBLOCA) analyses and described in UFSAR Subsection 15.6.5.4B.2.1.

The UFSAR Chapter 15 SBLOCA NOTRUMP model was used as the starting model for the CMT draindown predictive analysis. The model updates performed for the CMT recirculation predictive analysis were also used for the CMT draindown predictive analysis in addition to updates modeling a single ADS stage 1 flow path in operation during the test.

The CMT draindown simulation was initialized with CMT temperatures from the CMT recirculation predictive analysis representing the expected conditions at the end of the CMT recirculation test. The RCS initial conditions were nominal operating pressure and temperature consistent with the expected conditions during the test following the heat-up after the CMT recirculation test.

The CMT draindown simulations were initiated by manually actuating the CMTs and the RCPs trip as a result. After CMT actuation, a delay period was modeled to simulate a time for the operators to confirm that the CMT discharge valves have been opened before opening ADS Stage 1 valves. After that delay, a single ADS Stage 1 flow path was opened causing the RCS to depressurize and RCS inventory to be discharged to the IRWST. The hot CMTs initially operated in recirculation mode until sufficient inventory had been lost to allow the CMTs to transition to a draindown mode of operation. The predictive analysis was run until the CMTs drained through the level at which ADS Stage 4 actuation occurs. The predictive analysis confirmed that the test design was expected to allow for the transition from CMT recirculation to draindown and sufficient RCS inventory discharge to allow the CMTs to drain through the necessary setpoints.

Consistent with the CMT recirculation test, two cases were modeled for the CMT draindown test, one with minimum and one with maximum CMT piping resistances, to provide a potential range of behavior.

Additional NOTRUMP simulations were performed following the tests at Sanmen Unit 1. After the test at Sanmen Unit 1, it was observed that the NOTRUMP analysis over predicted the discharge through the single ADS Stage 1 flow path. To better match the RCS conditions during the test, and the resulting CMT recirculation and draindown behavior, the ADS Stage 1 model was adjusted in an updated simulation. The updated simulation showed agreement of CMT recirculation and draindown behavior between the prediction and the test for Sanmen Unit 1 and Sanmen Unit 2.

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The test acceptance criteria are demonstrated by proper operation of the equipment and are not dependent on the predictive analysis. There is no specific acceptance criteria obtained from the predictive analysis. However, the predictive analysis provides the expected RCS and CMT behavior that can be compared to the actual test behavior.

Test Overview During HFT, a test is performed to verify that the CMTs properly transition from recirculation mode to draindown mode. This test is performed by opening automatic depressurization system (ADS) Stage 1 and the CMT discharge valves and continues until the CMT level is below the level at which ADS Stage 4 occurs. This test is conducted with an initial Reactor Coolant System (RCS) hot leg temperature of 550F and the temperature at the midpoint elevation of the CMT 350F. The test is initiated by stopping the RCPs and manually actuating the CMTs (i.e., opening the CMT discharge isolation valve and opening ADS Stage 1). In addition to verifying proper transition between recirculation and draindown mode, the test monitors the dynamic effects of the steam injection and mixing with CMT liquid on the CMT level instrumentation. This test provides confirmation that the CMTs properly transition to draindown following recirculation and proper operation of the CMT upper narrow and lower narrow range instrumentation used for the actuation of the ADS Stages 1, 2, 3, and 4 during LOCA events.

The test also verifies that the CMT level instrumentation is operating properly by comparing CMT wide range level instrumentation to CMT upper narrow and lower narrow range level instrumentation.

The primary objective of the CMT draindown test is to examine the CMT performance over the aforementioned temperature conditions to verify that the level instrumentation is properly operating and that the CMT transitions from recirculation to draindown mode. As described previously, proper operation of the CMT level instrumentation is verified by comparing the CMT upper narrow range level instrumentation and lower narrow range level instrumentation to the CMT wide range level instrumentation. During the CMT draindown test, permanent CMT wide range and upper/narrow range levels are collected. Test data of the CMT wide, narrow and upper range levels obtained are used to demonstrate that the acceptance criteria are met for the CMT draindown test. No temporary instrumentation is used for this test.

Sanmen Units 1 & 2 successfully performed the CMT draindown test. [

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]

The Westinghouse review and evaluation of the Sanmen Units 1 & 2 test results to verify acceptability is documented in a test report. Haiyang Unit 1 successfully performed the CMT draindown test with similar results to Sanmen Units 1 & 2. SNC reviewed the test reports for Sanmen Units 1 & 2 and Haiyang Unit 1 and concurred with the conclusions.

Applicability of CMT Recirculation and Draindown Tests to Vogtle Units 3 & 4 Vogtle UFSAR Subsection 14.2.5 states that justification shall be provided that the results of the first plant only test or first three plant test are applicable to the subsequent plant. UFSAR Subsection 14.2.5 also provides the basis that [b]ecause of the standardization of the AP1000 design, once these special tests have affirmed consistent passive system function they are not required on follow plants. Therefore, verifying standardization of the component design between Sanmen Units 1 & 2, Haiyang Unit 1 and Vogtle Units 3 & 4 provides the basis that the successful test results are applicable to Vogtle Units 3 & 4.

The critical design and construction attributes for the CMT recirculation and draindown tests are:

CMT Balance Line design (line resistance and layout);

CMT design (geometry, volume, location);

CMT Injection Line (line resistance and layout); and Direct Vessel Injection (DVI) Line design (line resistance, layout).

For these components, standard design and procurement documentation is used for both Sanmen Units 1 & 2, Haiyang Unit 1, and Vogtle Units 3 & 4. The reactor vessel, steam generators, reactor coolant pumps and CMTs are manufactured using the same design specifications, are procured to the same quality requirements imposed by the design specifications and are built to the same standard tolerances. The use of standard design documentation confirms that the PXS and RCS system components used for this test are the within the standard AP1000 design parameters. Design changes made to any of these standard components are captured in the Westinghouse design change process. A review has confirmed that there are no site-specific design changes for either Sanmen Units 1 & 2 or Haiyang Unit 1 that alter the standard design features for any of the components involved in this test.

In addition to using standard design and procurement requirements, Vogtle Units 3 & 4 has multiple ITAAC which are applicable to the components involved in this test. Sanmen Units 1 &

2 and Haiyang Unit 1 use these same acceptance criteria. The following ITAAC will confirm the critical design and construction attributes related to this test:

ITAAC No. 2.2.03.08vi, CMT volume ITAAC No. 2.2.03.08cii, CMT Balance Line resistance ITAAC No. 2.2.03.08ci, CMT Injection Line resistance Page 28 of 38

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Vogtle Units 3 & 4 will still perform all other PXS pre-operational tests described in UFSAR Subsection 14.2.9.1.3 which will verify the installed components and associated piping and valves properly perform their design function. Based on the use of standard designed components, ITAAC for critical design features and pre-operational tests, the boundary conditions for the CMT recirculation tests are the same for Sanmen Unit 1 & 2, Haiyang Unit 1, and Vogtle Units 3 & 4.

Therefore, the successful completion and results of the first three plant CMT recirculation tests at Sanmen Unit 1 & 2 and Haiyang 1 are applicable to Vogtle Units 3 & 4, and the tests are not required to be performed at Vogtle Units 3 & 4.

Change Description As stated above, the first three plant CMT recirculation tests were successfully completed at the first three AP1000 units, Sanmen Units 1 & 2 and Haiyang Unit 1, and the results are applicable to Vogtle Units 3 & 4. Therefore, the CMT recirculation tests are proposed to be deleted from the UFSAR Subsection 14.2.5, first three plant tests, and UFSAR Subsection 14.2.9.1.3, PXS pre-operational tests. Specifically, the proposed changes are:

COL Item 2.D.(2)(a)4 requires the licensee to perform an ADS blowdown test as described in UFSAR 14.2.9.1.3, items (k) and (w). This COL condition is proposed to be deleted based on the successful completion of the tests at the first three AP1000 units.

UFSAR Subsection 14.2.5 describes the first three plant only tests, including CMT recirculation tests. A statement is proposed to be added that the tests will not be run at Vogtle Units 3 & 4 based on the successful completion of the tests at the first three AP1000 units.

UFSAR Subsection 14.2.9.1.3, items (k) and (w), describe the general test methods and acceptance criteria for the CMT recirculation tests. The CMT recirculation tests are proposed to be deleted from this section because the tests will not be run at Vogtle Units 3 & 4 based on the successful completion of the tests at the first three AP1000 units.

2.4 Response to 2012 NRC Letter on Crediting First Plant and First Three Plant Tests By letter dated January 1, 2012 (ML120040121) the NRC provided SNC with six topics that should be addressed in order to support crediting the tests at Sanmen Units 1 & 2 and Haiyang Unit 1. As much has changed in the six years since this letter was sent, SNC is providing responses to each of the six topics identified in the letter below.

NRC Topic No. 1 Provide to the NRC staff copies of the quality assurance program, test control program, test specifications, and test procedures (which we understand are in English) for staff review.

SNC Response SNC has performed assessments of the quality assurance regulations and the test control program procedures. These assessments are available for NRC review. SNC has made the test procedures, reports and post-test analysis available for NRC review for each of the preoperational tests included in the scope of the LAR. All of these documents are in English.

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NRC Topic No. 2 Validate the adequacy of the quality assurance program for construction and performance of the initial test program by providing a comparison of the quality assurance program implemented for the construction and initial test program at Sanmen Units 1 & 2 and Haiyang Units 1 & 2 to the quality assurance program as described in Section 17 of the FSAR for VEGP Units 3 and 4.

This includes validating the adequacy of the quality assurance program for instrument calibration.

SNC Response The purpose of the first plant and first three plant tests is to further establish the unique phenomenological performance parameters of the AP1000 design features. These special tests are in addition to preoperational testing that will be completed at every AP1000 unit.

Additionally, the use of standard design documentation confirms that the system components used for these tests are within the standard AP1000 design parameters. Any design changes made to any of these standard components are captured in the Westinghouse design change process. A review has confirmed that there are no site-specific design changes for either Sanmen Units 1 & 2, Haiyang Unit 1, or Vogtle Units 3 & 4 that alter the standard design features for any of the components involved in this test. Because the purpose of these tests is to verify design phenomena and Westinghouse design control maintains a standard plant, a validation of the adequacy of the quality assurance program for construction is not necessary.

SNC has validated the adequacy of the quality assurance regulations and assessed adherence to these regulations through reviews of the tests. The reviews completed by SNC focused on the governing QA regulations, implementing procedures for the scope of tests in the LAR and the output documentation. SNC has reviewed the Quality Assurance regulations governing the tests to 10 CFR 50 Appendix B. SNC has also reviewed the implementing administrative procedures governing the testing. SNC reviewed the test procedures, reports and post-test analysis. These reviews in total demonstrated the QA requirements were implemented appropriately for the scope of the first plant and first three plant tests. All of these documents and the documentation of the reviews completed by SNC are available for NRC review.

Performance of the first plant and first three plant only tests at Sanmen Units 1 & 2 and Haiyang Unit 1 were performed following the China regulatory quality assurance requirements specified in HAF-003-1991, Safety Regulations for Quality Assurance of Nuclear Power Plants. A review comparing the requirements of 10 CFR Part 50 Appendix B and HAF-003-1991 was completed.

This review used a matrixed table approach to compare the two regulations. The review compares the introduction and 13 sections of HAF-003-1991 to the introduction and 18 criteria of 10 CFR Part 50 Appendix B. The review concluded that the requirements of HAF-003-1991, as implemented, are comparable and encompass the requirements of 10 CFR Part 50 Appendix B. For any specific requirements in 10 CFR Part 50 Appendix B that are not directly included in HAF-003-1991, other standards were identified that implement the same requirements of 10 CFR Part 50 Appendix B.

HAF-003-1991, criterion XII requires calibration and testing of test equipment, which is comparable to 10 CFR Part 50 Appendix B criterion XII requirements. Calibration requirements for measurement and test equipment (M&TE) are specified in the Sanmen Units 1 & 2 and Haiyang Unit 1 localized procedures. Westinghouse had a team of engineers on site at both Sanmen Units 1 & 2 and Haiyang Unit 1 during performance of the first plant and first three plant tests. The Westinghouse engineers were embedded in the startup organization at the sites Page 30 of 38

ND-18-0826 Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests (Non-Proprietary) (LAR-18-019) and worked alongside the owners as the testing was performed. Prior to the testing, Westinghouse and the owners walked-down instrumentation to confirm proper installation.

Calibration records for temporary instrumentation used for the engineering analysis were provided by the Owners.

NRC Topic No. 3 Demonstrate the fidelity of the design, construction, and as-built condition of Sanmen Units 1 &

2 and Haiyang Units 1 & 2 to VEGP Units 3 & 4 in relation to the applicability of the FPOT/F3POT tests. This includes identifying any physical verification(s) that have been or will be performed.

SNC Response The AP1000 plant is a standard design across the Sanmen, Haiyang and Vogtle units for the scope of the first plant and first three plant tests. Westinghouse created, approved and maintained the design documents governing the scope of SSCs in the first plant and first three plant tests. Any design change made to an SSC involved in the first plant or first three plant tests has been reviewed and approved by Westinghouse under the Westinghouse design control process. In the Westinghouse design control process, each of these design changes is designated with an applicability for any plant where the change would be applied. Changes which were only applicable to Sanmen Units 1 & 2 or Haiyang Unit 1 AP1000 units were reviewed for potential impacts to the first plant and first three plant test design parameters. The purpose of the review was to confirm the design of the SSCs involved in the first plant and first three plant tests at Sanmen Units 1 & 2 and Haiyang Unit 1 is within the standard AP1000 design and therefore substantially the same design as Vogtle 3&4. The review of design changes concluded that there were no site-specific design changes for the Sanmen Units 1 & 2 or Haiyang Unit 1 AP1000 units which would alter any of the critical design attributes for first plant or first three plant only tests. The components involved in the testing were procured using the same design specification requirements. There is no difference between the units for these design requirements. Based on the standard AP1000 design, review of design changes, and the use of the same procurement requirements, the Sanmen Units 1 & 2 and Haiyang Unit 1 SSCs for the first plant and first three plant tests are within the standard AP1000 design. The Vogtle 3

& 4 units follow the same design control process described above to maintain the standard plant design. Additionally, Vogtle Units 3 & 4 have ITAAC on the SSCs involved in the first plant and first three plant tests. The specific ITAAC relating to each test are described in the subsections below on each specific test. The completion of these ITAAC will confirm the SSCs for the first plant and first three plant tests meet the AP1000 standard design described in the Vogtle Units 3 & 4 UFSAR.

NRC Topic No. 4 Validate the adequacy of the initial test program. This includes a description of the administrative controls governing the initial test program at Sanmen Units 1 & 2 and Haiyang Units 1 & 2, including a comparison to the administrative controls governing the initial test program as described in Section 14.2 of the FSAR for VEGP Units 3 & 4.

SNC Response SNC reviewed the Sanmen and Haiyang administrative manual procedures governing the first plant and first three plant tests. NRC Inspection Procedure (IP) 70367, Inspection of Preoperational Test Program, was used for guidance in creating criteria to review the Sanmen and Haiyang administrative manual procedures. The purpose of the review was to assess the Page 31 of 38

ND-18-0826 Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests (Non-Proprietary) (LAR-18-019) procedural processes and controls for the conduct of testing at Sanmen Units 1 & 2 and Haiyang Unit 1. This review followed the same process as the review of the Vogtle Units 3 & 4 administrative manual procedures against the NRC Inspection Procedure. Each line item in NRC IP Section 70367-02 was assessed individually against the Sanmen and Haiyang procedures. The overall conclusion of the review is that the Sanmen and Haiyang administrative manual procedures satisfy the requirements within NRC IP 70367. For instances where the NRC Inspection Procedure requirement was not explicitly addressed in a single administrative procedure, the requirement was addressed through a combination of procedures. There were no issues identified from the administrative manual procedures reviewed that would challenge any test results.

NRC Topic No. 5 Identify all the test critical parameters, calculations, and verification methods used during the initial test program. For calculated values this includes the calculated validation methodology, software verification and validation (when applicable), and the actual data inputs and outputs from the initial test results to support calculated values.

SNC Response Within the LAR, each test critical parameter is described. All post-test calculations have been identified and made available to the NRC for review. These calculations described the methodology, any codes used and the evaluation of the test data.

NRC Topic No. 6 Document the controls that WEC will have in place during the initial test program to ensure that work performed to non-English procedures or instructions are correctly translated from English.

SNC Response For the first plant and first three plant tests, all necessary test documentation is available in English. SNC has reviewed the administrative manual procedures, test procedures, test reports and post analysis, which are all in English. Based on SNC reviews of these test documents, SNC is confident that there are no communication concerns due to language.

2.5 Changes to Current Licensing Basis Documents COL Condition Changes Combined License Condition 2.D.(2)(a), Pre-operational Testing, is revised to remove the requirements to perform design-specific pre-operational first plant and first three plant tests including In Containment Refueling Water Storage Tank (IRWST) Heatup Test, Reactor Vessel Internals Vibration Testing, and Core Makeup Tank Heated Recirculation Tests. The changes credit previously completed tests which confirmed the design functions of the involved SSCs.

COL Appendix C (and Plant-Specific Tier 1) Changes

3. COL Appendix C, Subsection 2.1.3, is editorially revised to renumber the items under the Design Description consistent with the Plant-Specific Tier 1 information numbering.

4. Table 2.1.3-2 is revised to delete ITAAC 2.1.03.07.i; item i) in the ITA and the AC Page 32 of 38

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UFSAR Tier 2 Changes

6. UFSAR Subsection 3.9.2.4 is revised to describe Sanmen Unit 1 as the prototype for AP1000 reactor internals and Vogtle Units 3 & 4 reactor internals as non-prototype, Category 1.

7. UFSAR Table 3.9-4 is deleted and identified as not used.

8. UFSAR Subsection 14.2.5 is revised to add a statement that the IRWST heatup, CVAP, and CMT recirculation tests will not be run at Vogtle Units 3 & 4 based on the successful completion of the tests at the first AP1000 units.

9. UFSAR Subsection 14.2.9.1.3 is revised to remove the test descriptions for IRWST heatup first plant test and CMT recirculation first three plant tests, A statement is added that the test will not be run at Vogtle Units 3 & 4 based on the successful completion of the test at the first AP1000 units.

10. UFSAR Subsection 14.2.9.1.9 is revised to reflect the RG 1.20 guidance for a non-prototype, category I reactor internal design.

2.6 Summary The proposed changes credit previously completed first plant and first three plant tests which confirmed the design functions of the involved SSCs. There are no changes to any pre-operational testing requirements from Regulatory Guide 1.68. The proposed changes involving CVAP comply with Regulatory Guide 1.20. The proposed changes do not affect any function or feature used for the prevention and mitigation of accidents or their safety analyses. No changes were made to the assumptions used in the Chapter 15 analyses. No safety-related structure, system, or component (SSC) function is changed. The proposed changes do not involve nor interface with any SSC accident initiator or initiating sequence of events related to the accidents evaluated in the plant-specific Design Control Document (DCD) or UFSAR. The proposed changes do not affect the radiological source terms (i.e., amounts and types of radioactive materials released, their release rates and release durations) used in the accident analyses. No system or design function or equipment qualification is adversely affected by the proposed changes. The changes do not result in a new failure mode, malfunction or sequence of events that could adversely affect a radioactive material barrier or safety-related equipment. The proposed changes do not allow for a new fission product release path, result in a new fission product barrier failure mode, or create a new sequence of events that would result in significant fuel cladding failures. The proposed changes do not adversely affect any design code limit allowable value, design analysis, nor do they adversely affect any safety analysis input or result, or design/safety margin. The proposed changes do not revise any aspects of the plant that could have any adverse effect on safety or security, including the site emergency plan.

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3. TECHNICAL EVALUATION (Included in Section 2)

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 10 CFR Part 52.98(c) requires an amendment to the license for any modification to, addition to, or deletion from the terms and conditions of a combined license, including modification to, addition to, or deletion from the inspections, tests, analyses, or related acceptance criteria contained in the license. This change involves changes to UFSAR Subsections 14.2.5 and 14.2.9, which requires a revision to the COL 2.D.(2)(a) and COL Appendix C ITAAC. Therefore, a license amendment request (LAR) (as supplied herein) is required.

10 CFR Part 52, Appendix D, Section VIII.B.5.a allows an applicant or licensee who references this appendix to depart from Tier 2 information, without prior NRC approval, unless the proposed departure involves a change to or departure from Tier 1 information, Tier 2*

information, or the Technical Specifications, or requires a license amendment under paragraphs B.5.b or B.5.c of the section. The proposed changes to first plant and first three plant tests include changes to Tier 1 and Tier 2* information in UFSAR Subsections 14.2.5 and 14.2.9.1.3.

Therefore, NRC approval is required for the departures.

10 CFR Part 50, Appendix A, General Design Criterion (GDC) 1, requires that structures, systems, and components (SSCs) important to safety be designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety functions to be performed. The proposed changes involve crediting first plant only and first three plant tests which were previously completed at the lead AP1000 units and do not need to be repeated at Vogtle Units 3 & 4. The test results confirmed the design functions of the involved SSCs. The proposed changes do not alter any design, analysis or test acceptance criteria. Therefore, the proposed changes comply with the requirements of GDC 1.

10 CFR Part 50, Appendix A, GDC 35 requires that a system to provide abundant emergency core cooling be provided. The system safety function shall be to transfer heat from the reactor core following any loss of reactor coolant at a rate such that (1) fuel and clad damage that could interfere with continued effective core cooling is prevented and (2) clad metal-water reaction is limited to negligible amounts. The proposed changes to credit previously completed first plant and first three plant tests involving PXS do not include changes to any design feature or function described in the UFSAR. The changes credit previously completed tests which confirmed the design functions of the involved SSCs. Therefore, the proposed changes comply with the requirements of GDC 35.

10 CFR Part 50, Appendix A, GDC 36 requires that the emergency core cooling system be designed to permit appropriate periodic inspection of important components, such as spray rings in the reactor pressure vessel, water injection nozzles, and piping, to assure the integrity and capability of the system. The proposed changes to credit previously completed first plant and first three plant tests involving PXS do not include physical changes to any component. The changes credit previously completed tests which confirmed the design functions of the involved SSCs. Therefore, the proposed changes do not adversely affect the capability to perform appropriate inspections and comply with the requirements of GDC 36.

10 CFR Part 50, Appendix A, GDC 37 requires that the emergency core cooling system be designed to permit appropriate periodic pressure and functional testing to assure (1) the structural and leak tight integrity of its components, (2) the operability and performance of the Page 34 of 38

ND-18-0826 Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests (Non-Proprietary) (LAR-18-019) active components of the system, and (3) the operability of the system as a whole and, under conditions as close to design as practical, the performance of the full operational sequence that brings the system into operation, including operation of applicable portions of the protection system, the transfer between normal and emergency power sources, and the operation of the associated cooling water system. The proposed changes to credit previously completed first plant and first three plant tests involving PXS do not included changes to any design feature or function described in the UFSAR. The changes credit previously completed tests which confirmed the design functions of the involved SSCs. Therefore, the proposed changes comply with the requirements of GDC 37.

Regulatory Guide (RG) 1.20 describes the approved methodology to be used for vibratory stress analysis and measurement, inspections, documentation of results and schedule for CVAP. The proposed changes follow the guidance of RG 1.20 and do not adversely impact the UFSAR in terms of conformance to RG 1.20.

Regulatory Guide 1.68 describes the Initial Test Program (ITP) requirements. The proposed changes to first plant and first three plant tests do not alter compliance with RG 1.68 and the SSCs within the scope of RG 1.68 are still included in the ITP. The proposed changes to credit previously completed first plant and first three plant testing do not adversely impact the UFSAR in terms of conformance to RG 1.68.

The proposed changes have been evaluated to determine whether applicable regulations continue to be met. It was determined that the proposed changes do not affect conformance with the General Design Criteria differently than described in the plant-specific DCD or UFSAR.

4.2 Precedent No precedent is identified.

4.3 Significant Hazards Consideration The requested amendment involves changes to credit previously completed first plant and first three plant preoperational testing requirements in the VEGP Units 3&4 COLs and UFSAR Subsections 14.2.5 and 14.2.9 for IRWST heatup test, reactor vessel internals vibration testing, and CMT recirculation tests based on the successful completion of the tests at the lead AP1000 units.

The requested amendment proposes a change to COL Condition 2.D.(2)(a) and associated Tier 1 and UFSAR information supporting this change.

An evaluation to determine whether or not a significant hazards consideration is involved with the proposed amendment was completed by focusing on the three standards set forth in 10 CFR 50.92, Issuance of Amendment, as discussed below.

4.3.1 Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change does not affect the operation of any systems or equipment that initiates an analyzed accident or alter any structures, systems, or components (SSC) accident initiator or initiating sequence of events. The proposed changes remove first plant and first three plant only Page 35 of 38

ND-18-0826 Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests (Non-Proprietary) (LAR-18-019) tests including the IRWST heatup test, reactor vessel internals vibration testing, and CMT recirculation tests based on the successful completion of the tests at the lead AP1000 units. The change does not adversely affect any methodology which would increase the probability or consequences of a previously evaluated accident.

The change does not impact the support, design, or operation of mechanical or fluid systems.

There is no change to plant systems or the response of systems to postulated accident conditions. There is no change to predicted radioactive releases due to normal operation or postulated accident conditions. The plant response to previously evaluated accidents or external events is not adversely affected, nor does the proposed change create any new accident precursors.

Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of a previously evaluated accident.

4.3.2 Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change does not affect the operation of any systems or equipment that may initiate a new or different kind of accident, or alter any SSC such that a new accident initiator or initiating sequence of events is created.

The proposed change credits previously completed first plant and first three plant only tests including the IRWST heatup test, reactor vessel internals vibration testing, and CMT recirculation tests based on the successful completion of the tests at the lead AP1000 units. The proposed changes do not adversely affect any design function of any SSC design functions or methods of operation in a manner that results in a new failure mode, malfunction, or sequence of events that affect safety-related or non-safety-related equipment. This activity does not allow for a new fission product release path, result in a new fission product barrier failure mode, or create a new sequence of events that result in significant fuel cladding failures.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

4.3.3 Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed change maintains existing safety margin and provides adequate protection through continued application of the existing requirement in the UFSAR. The proposed change satisfies the same design functions in accordance with the same codes and standards as stated in the UFSAR. This change does not adversely affect any design code, function, design analysis, safety analysis input or result, or design/safety margin. No safety analysis or design basis acceptance limit/criterion is challenged or exceeded by the proposed change.

Since no safety analysis or design basis acceptance limit/criterion is challenged or exceeded by this change, no significant margin of safety is reduced.

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ND-18-0826 Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests (Non-Proprietary) (LAR-18-019)

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, it is concluded that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

4.4 Conclusions This assessment addresses the considerations discussed above. The plant licensing basis, safety analyses, and design bases evaluations demonstrate that the requested change is accommodated without an increase in the probability or consequences of an accident previously evaluated, without creating the possibility of a new or different kind of accident from any accident previously evaluated, and without a significant reduction in the margin of safety. In conclusion, based on the considerations discussed above, (1) there is a reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. Having arrived at negative declarations with regard to the criteria of 10 CFR 50.92, this assessment determined that the requested change does not involve a Significant Hazards Consideration.

5. ENVIRONMENTAL CONSIDERATIONS This review supports a request to amend the Combined License (COL) to revise various elements of the certification information related to pre-operational first plant and first three plant test requirements including IRWST heatup test, reactor vessel internals vibration testing, and CMT recirculation tests in Updated Final Safety Analysis Report (UFSAR), the plant-specific Tier 1 information, and COL Condition 2.D.(2)(a).

Sections 2 and 3 of this license amendment request provide the details of the proposed change.

The Licensee has determined that the anticipated construction and operational effects of the proposed amendment meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9), in that:

(i) There is no significant hazards consideration.

As documented in Section 4.3, Significant Hazards Consideration, of this license amendment request, an evaluation was completed to determine whether or not a significant hazards consideration is involved by focusing on the three standards set forth in 10 CFR 50.92, Issuance of Amendment. The significant hazards consideration determined that (1) the requested amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated; (2) the requested amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated; and (3) the requested amendment does not involve a significant reduction in a margin of safety. Therefore, it is concluded that the requested amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of no significant hazards consideration is justified.

Page 37 of 38

ND-18-0826 Request for License Amendment: Crediting Previously Completed First Plant and First Three Plant Tests (Non-Proprietary) (LAR-18-019)

(ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

The proposed change is unrelated to any aspect of plant construction or operation that would introduce any change to effluent type (e.g., effluents containing chemicals or biocides, sanitary systems effluents, and other effluents), or affect any plant radiological or non-radiological effluent release quantities. Furthermore, the proposed changes do not affect any effluent release path or diminish the design function or operational features that are credited with controlling the release of effluents during plant operation. Therefore, it is concluded that the requested amendment does not involve a significant change in the types or a significant increase on the amounts of any effluents that may be released offsite.

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The proposed changes do not adversely affect walls, floors, or other structures that provide shielding. Plant radiation zones are not affected, and there are no changes to the controls required under 10 CFR Part 20 that preclude a significant increase in occupational radiation exposure. Therefore, the requested amendment does not involve a significant increase in individual or cumulative occupational radiation exposure.

Based on the above review of the requested amendment, it has been determined that the anticipated construction and operational impacts of the requested amendment do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and (iii) a significant increase in the individual or cumulative occupational radiation exposure. Accordingly, the requested amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection the requested amendment.

6. REFERENCES None.

Page 38 of 38

Southern Nuclear Operating Company ND-18-0826 Enclosure 3 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Exemption Request:

Crediting Previously Completed First Plant and First Three Plant Tests (LAR-18-019)

(This Enclosure consists of 7 pages, including this cover page)

ND-18-0826 Exemption Request: Crediting Previously Completed First Plant and First Three Plant Tests (LAR-18-019) 1.0 Purpose Southern Nuclear Operating Company (SNC, the Licensee) requests a permanent exemption from the provisions of 10 CFR Part 52, Appendix D, Section III.B, Design Certification Rule for the AP1000 Design, Scope and Contents, to allow a departure from elements of the certification information in Tier 1 of the generic AP1000 Design Control Document (DCD). The regulation, 10 CFR Part 52, Appendix D, Section III.B, requires an applicant or licensee referencing Appendix D to 10 CFR Part 52 to incorporate by reference and comply with the requirements of Appendix D, including certified information in DCD Tier 1. The Tier 1 information for which a plant-specific departure and exemption is being requested includes revisions to Inspections, Tests, Analysis and Acceptance Criteria (ITAAC) for reactor internal flow induced vibration first plant test.

This request for exemption provides the technical and regulatory basis to demonstrate that 10 CFR 52.63, §52.7, and §50.12 requirements are met and will apply the requirements of 10 CFR Part 52, Appendix D, Section VIII.A.4 to allow departures from generic Tier 1 information to delete ITAAC 2.1.03.07.i for the first plant reactor internal flow induced vibration report in Table 2.1.3-2.

2.0 Background As described in the Combined License (COL) Condition 2.D.(2)(a), the licensee shall perform design-specific pre-operational tests including Reactor Vessel Internals Vibration Testing. The Reactor Vessel Internals Vibration Testing is designated as a first plant only test. First plant only tests are described in UFSAR Subsection 14.2.5. The tests are described as special tests to further establish a unique phenomenological performance parameter of the AP1000 design features beyond testing performed for Design Certification of the AP600 and that will not change from plant to plant.

The reactor vessel internals vibration testing is part of the Comprehensive Vibration Assessment Program (CVAP). CVAP is performed in accordance with Regulatory Guide 1.20 Revision 2. The AP1000 vibration assessment program requirements are described in UFSAR Subsection 3.9.2.4 and topical reports WCAP-17983 and WCAP-17984.

CVAP is directed toward confirming the long-term, steady-state vibration response of the reactor internals for operating steady-state and transient conditions. The three aspects of this evaluation are the following: a prediction of the vibrations of the reactor internals (based in part on previous scale model tests), a preoperational vibration test program of the internals of the first plant, and a correlation of the analysis and test results.

3.0 Technical Justification of Acceptability Vogtle UFSAR Subsection 14.2.5 states justification shall be provided that the results of the first plant only test are applicable to the subsequent plant. UFSAR Subsection 14.2.5 also provides the basis that because of the standardization of the AP1000 design, these special tests (designated as first plant only tests) are not required on follow plants.

Page 2 of 7

ND-18-0826 Exemption Request: Crediting Previously Completed First Plant and First Three Plant Tests (LAR-18-019)

In addition to Vogtle Units 3 & 4, there are four other AP1000 units. These are Sanmen Units 1 & 2 and Haiyan Units 1 & 2. Sanmen Unit 1 has already performed the first plant only Reactor Vessel Internals Vibration Testing described in UFSAR Subsections 3.9.2.4, and 14.2.5. AP1000 vibration assessment program requirements are currently described in topical reports WCAP-17983 and WCAP-17984. These program requirements are applicable to the testing completed at Sanmen Unit 1 and are also applicable to Vogtle Units 3 & 4.

As described in UFSAR Subsection 3.9.2.4, with respect to the reactor internals preoperational test program, the first AP1000 plant reactor vessel internals are classified as a prototype as defined in Regulatory Guide 1.20. Although the AP1000 reactor internals do not represent a first-of-a-kind or unique design based on the arrangement, design, size, or operating conditions, for the purposes of the reactor internals preoperational test program, the first operational AP1000 reactor vessel internals are classified as a prototype. Sanmen Unit 1, as the first AP1000, is proposed to be classified as prototype as defined in RG 1.20. In accordance with RG 1.20, the results of the prototype reactor internals CVAP should submitted to the Commission in the form of preliminary and final reports. These reports are also required to satisfy the acceptance criteria of ITAAC 2.1.03.07.i. These reports are being submitted to the Commission in support of this exemption. Based on the proposed classification of Sanmen Unit 1 as prototype, Vogtle Units 3 & 4 reactor internals are proposed to be classified as non-prototype, Category I. Based on this classification, the instrumented first plant test is not required for Vogtle Units 3 & 4. Vogtle Units 3 & 4 will perform the required inspections per RG 1.20 for non-prototype, Category I. ITAAC 2.1.03.07.ii captures this requirement.

Therefore, ITAAC 2.1.03.07.i is satisfied by submittal of the preliminary and final reports and is no longer necessary for Vogtle Units 3 & 4 and is proposed to be deleted.

Detailed technical justification supporting this request for exemption is provided in Section 2 of the associated License Amendment Request in Enclosure 1 of this letter.

4.0 Justification of Exemption 10 CFR Part 52, Appendix D, Section VIII.A.4 and 10 CFR 52.63(b)(1) govern the issuance of exemptions from elements of the certified design information for AP1000 nuclear power plants. Since SNC has identified changes to the Tier 1 information as discussed in Enclosure 1 of the accompanying License Amendment Request, an exemption from the certified design information in Tier 1 is needed.

10 CFR Part 52, Appendix D, and 10 CFR 50.12, §52.7, and §52.63 state that the NRC may grant exemptions from the requirements of the regulations provided six conditions are met: 1) the exemption is authorized by law [§50.12(a)(1)]; 2) the exemption will not present an undue risk to the health and safety of the public [§50.12(a)(1)]; 3) the exemption is consistent with the common defense and security [§50.12(a)(1)]; 4) special circumstances are present [§50.12(a)(2)]; 5) the special circumstances outweigh any decrease in safety that may result from the reduction in standardization caused by the exemption [§52.63(b)(1)]; and 6) the design change will not result in a significant decrease in the level of safety [Part 52, App. D, VIII.A.4].

The requested exemption satisfies the criteria for granting specific exemptions, as described below.

Page 3 of 7

ND-18-0826 Exemption Request: Crediting Previously Completed First Plant and First Three Plant Tests (LAR-18-019)

1) This exemption is authorized by law The NRC has authority under 10 CFR 52.63, §52.7, and §50.12 to grant exemptions from the requirements of NRC regulations. Specifically, 10 CFR 50.12 and §52.7 state that the NRC may grant exemptions from the requirements of 10 CFR Part 52 upon a proper showing. No law exists that would preclude the changes covered by this exemption request. Additionally, granting of the proposed exemption does not result in a violation of the Atomic Energy Act of 1954, as amended, or the Commissions regulations.

Accordingly, this requested exemption is authorized by law, as required by 10 CFR 50.12(a)(1).

2) This exemption will not present an undue risk to the health and safety of the public The proposed exemption from the requirements of 10 CFR Part 52, Appendix D, Section III.B would allow changes to elements of the plant-specific Tier 1 DCD to depart from the AP1000 certified (Tier 1) design information. The plant-specific DCD Tier 1 will continue to reflect the approved licensing basis, and will maintain a consistent level of detail with that which is currently provided elsewhere in Tier 1 of the DCD. Therefore, the affected plant-specific DCD Tier 1 ITAAC will continue to serve its required purpose.

The revisions to ITAAC on first plant reactor internal flow induced vibration testing do not represent an adverse impact to the design functions supported by the equipment, or the associated systems, structures and components and will continue to protect the health and safety of the public in the same manner. The clarifications and additional exceptions do not introduce any new industrial, chemical, or radiological hazards that would represent a public health or safety risk, nor do they modify or remove any design or operational controls or safeguards intended to mitigate any existing on-site hazards.

Furthermore, the proposed change would not allow for a new fission product release path, result in a new fission product barrier failure mode, or create a new sequence of events that would result in fuel cladding failures. Accordingly, this change does not present an undue risk from any existing or proposed equipment or systems.

Therefore, the requested exemption from 10 CFR Part 52, Appendix D, Section III.B would not present an undue risk to the health and safety of the public.

3) The exemption is consistent with the common defense and security The requested exemption from the requirements of 10 CFR Part 52, Appendix D, Section III.B would allow the licensee to depart from elements of the plant-specific Tier 1 design information. The proposed exemption does not alter the design, function, or operation of any structures or plant equipment that is necessary to maintain a safe and secure status of the plant. The proposed exemption has no impact on plant security or safeguards procedures.

Therefore, the requested exemption is consistent with the common defense and security.

4) Special circumstances are present 10 CFR 50.12(a)(2) lists six special circumstances for which an exemption may be granted. Pursuant to the regulation, it is necessary for one of these special Page 4 of 7

ND-18-0826 Exemption Request: Crediting Previously Completed First Plant and First Three Plant Tests (LAR-18-019) circumstances to be present in order for the NRC to consider granting an exemption request. The requested exemption meets the special circumstances of 10 CFR 50.12(a)(2)(ii). That subsection defines special circumstances as when Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule.

The rule under consideration in this request for exemption is 10 CFR Part 52, Appendix D, Section III.B, which requires that a licensee referencing the AP1000 Design Certification Rule (10 CFR Part 52, Appendix D) shall incorporate by reference and comply with the requirements of Appendix D, including Tier 1 information. The VEGP Units 3 and 4 COLs reference the AP1000 Design Certification Rule and incorporate by reference the requirements of 10 CFR Part 52, Appendix D, including Tier 1 information.

The underlying purpose of Appendix D,Section III.B is to describe and define the scope and contents of the AP1000 design certification, and to require compliance with the design certification information in Appendix D.

The proposed exemption would provide revisions to ITAAC on reactor internal flow induced vibration. The proposed revisions reflect the design functions of the associated systems and components as described in the licensing basis documents. Accordingly, this exemption from the certification information enables the Licensee to safely construct and operate the facility consistent with the design certified by the NRC in 10 CFR Part 52, Appendix D.

Therefore, special circumstances are present, because application of the current generic certified design information in Tier 1 as required by 10 CFR Part 52, Appendix D, Section III.B, in the particular circumstances discussed in this request is not necessary to achieve the underlying purpose of the rule.

5) The special circumstances outweigh any decrease in safety that may result from the reduction in standardization caused by the exemption.

Based on the nature of the changes to the plant-specific Tier 1 information and the understanding that these changes support the design function of the supported equipment, it is expected that this exemption may be requested by other AP1000 licensees and applicants. However, a review of the reduction in standardization resulting from the departure from the standard DCD determined that even if other AP1000 licensees and applicants do not request this same departure, the special circumstances will continue to outweigh any decrease in safety from the reduction in standardization because the key design functions of the equipment associated with this request will continue to be maintained. Furthermore, the justification provided in the license amendment request and this exemption request and the associated mark-ups demonstrate that there is a limited change from the standard information provided in the generic AP1000 DCD, which is offset by the special circumstances identified above.

Therefore, the special circumstances associated with the requested exemption outweigh any decrease in safety that may result from the reduction in standardization caused by the exemption.

6) The design change will not result in a significant decrease in the level of safety.

The exemption revises the plant-specific DCD Tier 1 information by revising ITAAC on reactor internal flow induced vibration. The revisions do not change the design Page 5 of 7

ND-18-0826 Exemption Request: Crediting Previously Completed First Plant and First Three Plant Tests (LAR-18-019) requirements of the associated equipment. Because these functions continue to be met, there is no reduction in the level of safety.

5.0 Risk Assessment A risk assessment was not determined to be applicable to address the acceptability of this proposal.

6.0 Precedent Exemptions None 7.0 Environmental Consideration The Licensee requests a departure from elements of the certified information in Tier 1 of the generic AP1000 DCD. The Licensee has determined that the proposed departure would require a permanent exemption from the requirements of 10 CFR Part 52, Appendix D, Section III.B, Design Certification Rule for the AP1000 Design, Scope and Contents, with respect to installation or use of facility components located within the restricted area, as defined in 10 CFR Part 20, or which changes an inspection or a surveillance requirement; however, the Licensee evaluation of the proposed exemption has determined that the proposed exemption meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Based on the above review of the proposed exemption, the Licensee has determined that the proposed activity does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed exemption meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), an environmental impact statement or environmental assessment of the proposed exemption is not required.

Specific details of the environmental considerations supporting this request for exemption are provided in Section 5 of the associated License Amendment Request provided in Enclosure 1 of this letter.

8.0 Conclusion The proposed changes to Tier 1 are necessary to revise ITAAC on reactor internal flow induced vibration. The exemption request meets the requirements of 10 CFR 52.63, Finality of design certifications, 10 CFR 52.7, Specific exemptions, 10 CFR 50.12, Specific exemptions, and 10 CFR Part 52 Appendix D, Design Certification Rule for the AP1000. Specifically, the exemption request meets the criteria of 10 CFR 50.12(a)(1) in that the request is authorized by law, presents no undue risk to public health and safety, and is consistent with the common defense and security. Furthermore, approval of this request does not result in a significant decrease in the level of safety, satisfies the Page 6 of 7

ND-18-0826 Exemption Request: Crediting Previously Completed First Plant and First Three Plant Tests (LAR-18-019) underlying purpose of the AP1000 Design Certification Rule, and does not present a significant decrease in safety as a result of a reduction in standardization.

9.0 References None Page 7 of 7

Southern Nuclear Operating Company ND-18-0826 Enclosure 4 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Proposed Changes to the Licensing Basis Documents (LAR-18-019)

Note:

Added text is shown as Blue Underline Deleted text is shown as Red Strikethrough Relocated text is show in Green Underline and Strikethrough Omitted text is shown as three asterisks (*...*...*)

(This Enclosure consists of 11 pages, including this cover page)

ND-18-0826 Proposed Changes to Licensing Basis Documents (LAR-18-019)

COL Changes Combined License Condition 2.D.(2)(a), Pre-operational Testing - Revise information related to design-specific pre-operational first plant and first three plant tests including In Containment Refueling Water Storage Tank (IRWST) Heatup Test, Reactor Vessel Internals Vibration Testing, and Core Makeup Tank Heated Recirculation Tests as shown below.

(2) Pre-operational Testing (a) SNC shall perform the design-specific pre-operational tests identified below:

1. In-Containment Refueling Water Storage Tank (IRWST) Heatup Test (first plant test as identified in UFSAR Section 14.2.9.1.3 Item (h));

1.2. Pressurizer Surge Line Stratification Evaluation (first plant test as identified in UFSAR, Section 14.2.9.1.7 Item (d));

3. Reactor Vessel Internals Vibration Testing (first plant test as identified in UFSAR Section 14.2.9.1.9);

4. Core Makeup Tank Heated Recirculation Tests (first three plants test as identified in UFSAR Section 14.2.9.1.3 Items (k) and (w)); and 2.5. Automatic Depressurization System Blowdown Test (first three plants test as identified in UFSAR Section 14.2.9.1.3 Item (s)).

Page 2 of 11

ND-18-0826 Proposed Changes to Licensing Basis Documents (LAR-18-019)

COL Appendix C, Subsection 2.1.3 is revised to renumber items under Design Description.

The component locations of the RXS are as shown in Table 2.1.3-3.

1. The functional arrangement of the RXS is as described in the Design Description of this Section 2.1.3.

2. a) The reactor upper internals rod guide arrangement is as shown in Figure 2.1.3-1.

b) The rod cluster control and drive rod arrangement is as shown in Figure 2.1.3-2.

c) The reactor vessel arrangement is as shown in Figure 2.1.3-3.

32. The components identified in Table 2.1.3-1 as ASME Code Section III are designed and constructed in accordance with ASME Code Section III requirements.

43. Pressure boundary welds in components identified in Table 2.1.3-1 as ASME Code Section III meet ASME Code Section III requirements.

54. The pressure boundary components (reactor vessel [RV], control rod drive mechanisms

[CRDMs], and incore instrument QuickLoc assemblies) identified in Table 2.1.3-1 as ASME Code Section III retain their pressure boundary integrity at their design pressure.

65. The seismic Category I equipment identified in Table 2.1.3-1 can withstand seismic design basis loads without loss of safety function.

76. The reactor internals will withstand the effects of flow induced vibration.

87. The reactor vessel direct injection nozzle limits the blowdown of the reactor coolant system (RCS) following the break of a direct vessel injection line.

Page 3 of 11

ND-18-0826 Enclosure 4 Proposed Changes to Licensing Basis Documents (LAR-18-019)

COL Appendix C (and plant-specific Tier 1), Subsection 2.1.3, Table 2.1.3-2, Revise to delete ITAAC 2.1.03.07.i Table 2.1.3-2 Inspections, Tests, Analyses, and Acceptance Criteria No. ITAAC No. Design Commitment Inspections, Tests, Analyses Acceptance Criteria 78 2.1.03.07.i 7. The reactor internals will withstand the i) Not Used per Amendment i) Not Used per Amendment effects of flow induced vibration. XXX. A vibration type test XXX. A report exists and will be conducted on the (first concludes that the (first unit) unit) reactor internals reactor internals have no representative of AP1000. observable damage or loose parts as a result of the vibration type test.

Page 4 of 11

ND-18-0826 Proposed Changes to Licensing Basis Documents (LAR-18-019)

UFSAR Tier 2 Changes UFSAR Subsection 3.9.2.4, Pre-operational Flow-Induced Vibration Testing of Reactor Internals, revise to describe Sanmen Unit 1 as the valid protype and Vogtle Units 3 & 4 as non-prototype.

The pre-operational vibration test program for the reactor internals of the AP1000 conducted on the first AP1000 is consistent with the guidelines of Regulatory Guide 1.20 for a comprehensive vibration assessment program. Design features that have not previously been tested in the reference plants or subsequent testing are tested to verify the vibration analysis. The VEGP Units 3 & 4 reactor internals are classified as non-prototype, Category I as defined in Regulatory Guide 1.20. Sanmen Unit 1, as the first AP1000 plant, is the valid prototype for the AP1000 reactor internal design. Based on this classification, an instrumented test is not required. The recommendations of Regulatory Guide 1.20 are satisfied by conducting the confirmatory pre-and post-hot functional examination for integrity. Conformance with Regulatory Guide 1.20 is summarized in Subsection 1.9.1.

The program is directed toward confirming the long-term, steady-state vibration response of the reactor internals for operating conditions. The three aspects of this evaluation are the following:

a prediction of the vibrations of the reactor internals, a preoperational vibration test program of the internals of the first plant, and a correlation of the analysis and test results.

With respect to the reactor internals preoperational test program, the first AP1000 plant reactor vessel internals are classified as a prototype as defined in Regulatory Guide 1.20. The AP1000 reactor vessel internals do not represent a first-of-a-kind or unique design based on the arrangement, design, size, or operating conditions. The units referenced in Subsection 3.9.2.3 as supporting the AP1000 reactor vessel internals design features and configuration have successfully completed vibration assessment programs including vibration measurement programs. These units have subsequently demonstrated extended satisfactory inservice operation.

The reactor internals flow-induced vibration assessment program is documented in WCAP-17983 (Reference 40) and WCAP-17984 (Reference 41), including comparison of the AP1000 plant and operating plants that have undergone vibration measurement programs.

The pre-operational test program of the first AP1000 plant includes a vibration measurement program and a pre- and post-hot functional inspection program. This program satisfies the guidelines for a Regulatory Guide 1.20 Prototype Category plant. The program for plants subsequent to the first plant satisfies the guidelines for the appropriate Non-prototype Category plant.

The acceptance criteria for the vibration predictions are established and related to the ASME Code allowables for long term steady-state conditions.

During the hot functional test, the internals are subjected to flow conditions representative of normal operation for a sufficient length of time go generate a cyclic loading of greater than 106 cycles on the main structural elements of the internals. In addition, there is some operating time with one, two, or three pumps operating.

Instrumentation is designed and installed to measure the vibration of the internals during hot Page 5 of 11

ND-18-0826 Proposed Changes to Licensing Basis Documents (LAR-18-019) functional testing. The instrumentation includes devices attached to reactor vessel internals to measure component strains and accelerations.

Inspection before and after the hot functional test serves to confirm the structural integrity of the internals with regard to flow-induced vibrations. When no indications of harmful vibrations or signs of abnormal wear are detected and no apparent structural changes take place, the core support structures are considered to be structurally adequate and sound for operation. If such indications are detected, further evaluation is required.

The testing and inspection plan for the first plant includes features with emphasis on the areas susceptible to FIV, including flow-induced wear. Consistent with Regulatory Guide 1.20, these areas include as a minimum:

The major load-bearing elements of the reactor internals relied upon to retain the core support structures in position, The lateral, vertical, and torsional restraints provided within the vessel, The locking and bolting components whose failure could adversely affect the structural integrity of the reactor internals, Those surfaces that are known to be or may become contact surfaces during operation, Those critical locations on the reactor vessel internal components as identified by the vibration analysis, and The interior of the reactor vessel for evidence of loose parts or foreign material.

The reactor internals flow-induced vibration measurement program will be conducted during preoperational tests of the first AP1000. The response of the reactor and the internals due to flow-induced vibration will be measured during the hot functional test. Data will be acquired at several temperatures from cold startup to hot standby conditions. The location of the is outlined in Table 3.9-4.

Page 6 of 11

ND-18-0826 Enclosure 4 Proposed Changes to Licensing Basis Documents (LAR-18-019)

Table 3.9-4, First Plant AP1000 Reactor Internals Vibration Measurement Program Transducer Locations, delete table as shown below Table 3.9-4 Not Used Table 3.9-4 Selected First Plant AP1000 Reactor Internals Vibration Measurement Program Transducer Locations Number and Type of Approximate Transducer Direction of Instrumented Component Transducers1 Locations Sensitivity Core Shroud (Inner Wall) 4 accelerometers 0°, 45°, 180°, 315° Radial Core Shroud to Core Barrel 4 relative 225°, 315° 2 Radial displacement transducers 2 Tangential Core Barrel Flange (Outer Wall) 4 strain gages 0°, 90°, 180°, 270° Axial Core Barrel (Inner Wall) 1 strain gage 180° Axial Core Barrel Mid-elevation (Outer 3 accelerometers 0°, 45°, 180° Radial Wall)

Core Barrel Mid-elevation 1 pressure transducer 90° Radial Upper Support Skirt (Inner Wall) 3 strain gages 0°, 90°, 180° Axial Upper Support Plate (Outer 1 strain gage 90° Axial Wall)

Lower Core Support Plate 1 accelerometer Near the center of the plate Veritical Vortex Suppression Plate 4 strain gages On outside of columns at an Axial Support Columns (2) elevation near LCSP with 3 gages on one column and 1 gage on another column; these two columns are 180° apart Reactor Vessel (Head Studs) 4 accelerometers Studs at 0°, 90°, 180°, 270° Vertical 3 accelerometers Studs at 0°, 90°, stud at 180° Horizontal (x-direction), stud at 180° (y-direction)

IGA Guide Tubes (2) 4 strain gages 0°, 90° Axial IGA Guide Tube Support 3 strain gages Bottom of support Axial Lower Guide Tube on B-6 4 strain gages 0°, 90°, 180°, 270° Axial Upper Guide Tube on B-6 2 strain gages 0°, 90° Axial Upper Support Column on B-7 4 strain gages 0°, 90°, 180°, 270° Axial Notes:

1. Additional sensors are installed throughout the reactor internals assembly for redundancy and enhanced data collection. WCAP-17983 (Reference 40) Table 4-1 provides additional detailed information on the sensors.

Page 7 of 11

ND-18-0826 Proposed Changes to Licensing Basis Documents (LAR-18-019)

UFSAR Subsection 14.2.5, Utilization of Reactor Operating and Testing Experience in the Development of Initial Test Program, revise text as shown below.

IRWST Heatup Test (14.2.9.1.3, item (h))

This first plant only test was completed at the first AP1000 unit. This test is not required to be conducted at Vogtle Units 3 & 4.

During preoperational testing of the passive core cooling system, a natural circulation test and a forced flow test of the passive residual heat removal (PRHR) heat exchanger is conducted (items f and g). For the first plant only, temperature sensors are placed in the IRWST to observe the thermal profile developed during the heatup of the IRWST water during PRHR heat exchanger operation. This test will be useful in confirming the results of the AP600 Design Certification Program PRHR tests with regards to IRWST mixing, and is useful in quantifying the conservatism in the Chapter 15 transient analyses.

Due to the standardization of the AP1000, the heatup and thermal stratification characteristics of the IRWST will not vary from plant to plant. The PRHR heat exchanger design, and the size and configuration of the IRWST are standardized, such that the heatup characteristics will not significantly change from plant to plant.

Therefore, since the phenomenon to be tested (i.e., heatup and mixing characteristics of the IRWST) will not vary significantly from plant to plant due to standardization, a first plant only test of the IRWST heatup characteristics is justified.

Core Makeup Tank Heated Recirculation Tests (14.2.9.1.3, Items (k) and (w))

This first three plant only tests were completed at the first three AP1000 units. These tests are not required to be conducted at Vogtle Units 3 & 4.

During preoperational testing of the passive core cooling system, a test is performed for each plant to verify the CMT inlet piping resistances. In addition, cold draining tests of the CMTs are conducted that verify the discharge piping resistance and proper drain rate of the CMTs for each plant. For the first three plants, two additional CMT tests are conducted during hot functional testing of the RCS. These tests are a natural circulation heatup of the CMTs followed by a test to verify the ability of the CMTs to transition from a recirculation mode to a draindown mode while at elevated temperature and pressure.

Operation of the CMTs in their natural circulation mode is conducted on the first three plants only for the following reasons:

Natural circulation of the CMTs will not vary from plant to plant, provided that the other verifications discussed above are performed as specified.

Natural circulation testing of the CMTs was extensively tested as part of the Design Certification Tests.

Performance of this test results in significant thermal transients on Class 1 components including the CMTs and the direct vessel injection nozzles.

Page 8 of 11

ND-18-0826 Proposed Changes to Licensing Basis Documents (LAR-18-019)

Reactor Vessel Internals Vibration Testing (14.2.9.1.9)

This first plant only instrumented vibration test was completed at the first AP1000 unit. This test is not required to be conducted at Vogtle Units 3 & 4.

The preoperational vibration test program for the reactor internals of the AP1000 conducted on the first AP1000 is consistent with the guidelines of Regulatory Guide 1.20 for a comprehensive vibration assessment program. This program is discussed in Subsection 3.9.2.

UFSAR Subsection 14.2.9.1.3, delete general test method and acceptance criteria for items h, k and w as shown below.

14.2.9.1.3 Passive Core Cooling System Testing h) This first plant only test was completed at the first AP1000 unit. This test is not required to be conducted at Vogtle Units 3 & 4. The heatup characteristics of the in-containment refueling water storage tank water are verified by measuring the vertical water temperature gradient that occurs in the in-containment refueling water storage tank water at the passive residual heat removal heat exchanger tube bundle and at several distances from the tube bundle, during testing in Items f) and g), above. Note that this verification is required only for the first plant. The acceptance criterion demonstrates that the average IRWST heatup is consistent with the PRHR heat transfer modeling in the Chapter 15 analysis. These results (in conjunction with Items f) and g)) are evaluated to demonstrate that the overall PRHR heat transfer performance, i.e., heat removal from the RCS, is conservative with respect to the analysis documented in Chapter 15.

k) This first three plant only test was completed at the first three AP1000 units. This test is not required to be conducted at Vogtle Units 3 & 4. [Proper operation of the core makeup tanks to perform their reactor water makeup and boration function is verified by initiating recirculation flow through the tanks during hot functional testing with the reactor coolant system at 530°F.

This testing is initiated by simulating a safety signal which opens the tank discharge isolation valves, and stops reactor coolant pumps after the appropriate time delay. The proper tank recirculation flow after the pumps have coasted down is verified. Based on the cold leg temperature, CMT discharge temperature, and temporary CMT flow instrumentation, the net mass injection rate into the reactor is verified. Note that this verification is required only for the first three plants.]*

w) This first three plant only test was completed at the first three AP1000 units. This test is not required to be conducted at Vogtle Units 3 & 4.[In conjunction with the verification of the core makeup tanks to perform their reactor water makeup function and boration function described in item k) above, the proper operation of the core makeup tanks to transition from their recirculation mode of operation to their draindown mode of operation after heatup will be Page 9 of 11

ND-18-0826 Proposed Changes to Licensing Basis Documents (LAR-18-019) verified. This testing will also verify the proper operation of the core makeup tank level instrumentation to operate during draining of the heated tank fluid. The in-containment refueling water storage tank initial level is reduced to at least 3 feet below the spillway level as a prerequisite condition for this testing in order to provide sufficient ullage to accept the mass discharged from the reactor coolant system via the automatic depressurization stage 1.

The recirculation operation in Item k) above, should be continued until the core makeup tank fluid has been heated to 350°F. The core makeup tank isolation valves are then closed, the reactor coolant pumps are started, and the reactor coolant system is reheated up to hot functional testing conditions. This testing is initiated by shutting off the reactor coolant pumps, opening the core makeup tank isolation valves, and by opening one of the automatic depressurization stage 1 flow paths to the in-containment refueling water storage tank. This will initiate a large loss of mass from the reactor coolant system, depressurization of the reactor coolant system to the bulk fluid saturation pressure, and additional recirculation through the core makeup tank. Core makeup tank draindown initiates in response to the continued depressurization and mass loss from the reactor coolant system. The automatic depressurization stage 1 flow path is closed after the core makeup tank level has decreased below the level at which stage4 actuation occurs. Note that this verification is required only for the first three plants.]*

UFSAR Subsection 14.2.9.1.9, Reactor Vessel Internals Vibration Testing, revise to remove instrumented first plant CVAP test requirements as shown below.

Purpose The AP1000 reactor internals testing is part of a comprehensive vibration assessment program performed in accordance with Regulatory Guide 1.20 as discussed in Subsection 3.9.2.4. This testing obtains data to verifies verify the structural integrity of the AP1000 reactor internals with regard to flow-induced vibrations, as part of an internals vibration assessment program. This program also includes visual examination of the reactor internals before and after hot functional testing., and analysis of the test data.

AP1000 plants The reactor internals are visually inspected before and after the hot functional test to confirm the structural integrity of the reactor internals with regard to flow-induced vibrations. The major features of the reactor internals outlined in Subsection 3.9.2.4 are visually inspected for signs of abnormal wear and structural changes.

Prerequisites The component testing of the reactor coolant system has been completed. The first plant only portions of this test have been completed at the first AP1000 unit. The testing and calibration of the required test instrumentation has been completed. The test instrumentation is located on the internals as specified in Table 3.9-4 and the. internals pre-test visual inspection has been completed. The internals, test instrumentation, and instrumentation lead wires are installed in the reactor vessel. The reactor vessel head is installed in preparation for the cold hydrostatic test of the reactor coolant system. and instrument leads have been properly sealed. The proper Page 10 of 11

ND-18-0826 Proposed Changes to Licensing Basis Documents (LAR-18-019) operation and calibration of the test instrumentation and recording equipment is verified during the hydrostatic testing of the reactor coolant system.

General Test Method and Acceptance Criteria Reactor vessel internals testing is performed by measuring and recording component strains and accelerations in order to determine actual displacements that occur with the reactor coolant pumps operating. This testing is performed at several reactor coolant system temperatures during the system hot functional test. The analysis of data obtained from this testing, combined with a pPre-test and post-test visual inspections of the internals are performed to confirm that the stresses and wear on the AP1000 internals, due to flow induced vibration during plant operation, are acceptably low. The criteria for evaluating testing results are established in the AP1000 reactor internals flow-induced vibration assessment program (see Section 7 of WCAP-17984), and appropriate design specifications.

When an instrumented test is performed, the internals are instrumented to obtain data during the following reactor coolant system operating conditions:

a) Background noise in the instrumentation and recording equipment is recorded with no reactor coolant pumps running b) Data is recorded during the initial startup of the reactor coolant pumps and with all four pumps operating and with the reactor coolant at cold temperature c) Data is recorded at several increasing coolant temperatures with the pumps operating d) Data is recorded at the hot functional testing temperature with all four pumps operating e) Data is recorded at the hot functional testing temperature with the appropriate combinations of reactor coolant pumps operating, including pump start and stop transients f) Shutdown conditions including temperature cooldown and pump speed reduction When viusals inpsections are performed, vVisual inspections are performed before and after the hot functional test. When no indications of harmful vibrations or signs of abnormal wear are detected and no structural damage or changes are apparent, the core support structures are considered to be structurally adequate and sound for operation. If such indications are detected, further evaluation is required.

For the first plant, the vibration assessment program includes an instrumented test, analysis of the data, and visual inspections.

Page 11 of 11

Southern Nuclear Operating Company ND-18-0826 Enclosure 5 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Westinghouse Proprietary Information Notice, Copyright Notice and CAW-18-4753, Application for Withholding Proprietary Information from Public Disclosure and Affidavit (LAR-18-019)

(This Enclosure consists of 8 pages, including this cover page)

ND-18-0826 Westinghouse Proprietary Information Notice, Copyright Notice and CAW-18-4753, Application for Withholding Proprietary Information from Public Disclosure and Affidavit (LAR-18-019)

Page 2 of 8

ND-18-0826 Westinghouse Proprietary Information Notice, Copyright Notice and CAW-18-4753, Application for Withholding Proprietary Information from Public Disclosure and Affidavit (LAR-18-019)

Page 3 of 8

ND-18-0826 Westinghouse Proprietary Information Notice, Copyright Notice and CAW-18-4753, Application for Withholding Proprietary Information from Public Disclosure 3 and Affidavit (LAR-18-019) CAW-18-4753 (1) I am Manager, Licensing Inspection and Special Programs, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Nuclear Regulatory Commissions (Commissions) regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commissions regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitute Westinghouse policy and provide the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Page 4 of 8

ND-18-0826 Westinghouse Proprietary Information Notice, Copyright Notice and CAW-18-4753, Application for Withholding Proprietary Information from Public Disclosure 4 and Affidavit (LAR-18-019) CAW-18-4753 Westinghouses competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage (e.g., by optimization or improved marketability).

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

(iii) There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

Page 5 of 8

ND-18-0826 Westinghouse Proprietary Information Notice, Copyright Notice and CAW-18-4753, Application for Withholding Proprietary Information from Public Disclosure 5 and Affidavit (LAR-18-019) CAW-18-4753 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iv) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, is to be received in confidence by the Commission.

(v) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(vi) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in APP-GW-GLR-179 Revision 0, Comprehensive Vibration Assessment Program (CVAP) Preliminary Report for the Sanmen 1 AP1000 Plant (Proprietary) and APP-GW-GLR-181 Revision 0, Comprehensive Vibration Assessment Program (CVAP) Final Report for the Sanmen 1 AP1000 Plant (Proprietary), for submittal to the Commission, being transmitted by Southern Nuclear Operating Company letter ND-18-0826. The proprietary information as submitted by Westinghouse is that associated with the First Plant Only license amendment request, Southern LAR number LAR-18-019, and may be used only for that purpose.

(a) This information is part of that which will enable Westinghouse to manufacture and deliver products to utilities based on proprietary designs.

Page 6 of 8

ND-18-0826 Westinghouse Proprietary Information Notice, Copyright Notice and CAW-18-4753, Application for Withholding Proprietary Information from Public Disclosure 6 and Affidavit (LAR-18-019) CAW-18-4753 (b) Further, this information has substantial commercial value as follows:

(i) Westinghouse plans to sell the use of similar information to its customers for the purpose of licensing new nuclear power stations.

(ii) Westinghouse can sell support and defense of industry guidelines and acceptance criteria for plant-specific applications.

(iii) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

Page 7 of 8

ND-18-0826 Westinghouse Proprietary Information Notice, Copyright Notice and CAW-18-4753, Application for Withholding Proprietary Information from Public Disclosure and Affidavit (LAR-18-019)

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and non-proprietary versions of a document, furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.390 of the Commissions regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the Affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Page 8 of 8

Southern Nuclear Operating Company ND-18-0826 Enclosure 6 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 (LAR-18-019)

(This Enclosure consists of 3 pages, including this cover page)

ND-18-0826 Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 (LAR-18-019)

Affidavit of Michael J. Yox

1. My name is Michael J. Yox. I am the Vogtle Units 3 &4 Regulatory Affairs Director for Southern Nuclear Operating Company (SNC). I have been delegated the function of reviewing proprietary information sought to be withheld from public disclosure and am authorized to apply for its withholding on behalf of SNC.

2. I am making this affidavit on personal knowledge, in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations, and in conjunction with SNC's filing on dockets52-025 and 52-026 requesting license amendment LAR-18019. I have personal knowledge of the criteria and procedures used by SNCto designate information as a trade secret, privileged or as confidential commercial or financial information.

3. Based on the reason(s) at 10 CFR 2.390(a)(4), this affidavit seeks to withhold from public disclosure Enclosures 1, 5 and 7 of SNC letter ND-18-0826 for Vogtle Electric Generating Plant Units 3 and 4, Request for License Amendment and Exemption: Crediting Previously Completed First Plant and First Three Plant Tests (LAR-18-019).

4. Thefollowing is furnished for consideration bythe Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

a. The information sought to be withheld from public disclosure has been held in confidence by SNC, Sanmen Nuclear Power Company Ltd., Shandong Nuclear Power Company Ltd., and/or Westinghouse Electric Company.

b. The information is of a type customarily held in confidence by SNC, Sanmen Nuclear Power Company Ltd., Shandong Nuclear Power Company Ltd., and/or Westinghouse Electric Company and not customarily disclosed to the public.

Page 2 of 3

ND-18-0826 Affidavit from Soutfiern Nuclear Operating Company for Withholding Under 10 CFR 2.390 (LAR-18-019)

c. The release of the information might result in the loss of an existing or potential competitive advantage to SNC, Sanmen Nuclear Power Company Ltd., Shandong Nuclear Power Company Ltd., and/or Westinghouse Electric Company.

d. Other reasons identified in Enclosures 5,11, and 12 of SNC letter ND-18-0826 for Vogtle Electric Generating Plant Units 3 and 4, Requestfor License Amendment and Exemption: Crediting Previously Completed First Plant and First Three Plant Tests (LAR-18-019). Those reasons are incorporated here by reference.

5. Additionally, release of the information may harm SNC because SNC has a contractual relationship with Westinghouse Electric Company regarding proprietary information. SNC is contractually obligated to seek confidential and proprietarytreatment of the information. Further, SNC is obligated to seek confidential treatment of Sanmen and Haiyang information.

6. The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

7. To the best of my knowledge and belief, the information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method.

1declare under penalty of perjury that the foregoing is true and correct.

Executed on chael J. Vox Date Page 3 of 3

Southern Nuclear Operating Company ND-18-0826 Enclosure 8 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 APP-GW-GLR-180, Revision 0, Comprehensive Vibration Assessment Program (CVAP)

Preliminary Report for the Sanmen 1 AP1000 Plant (Non-Proprietary)

(LAR-18-019)

(This Enclosure consists of 94 pages, including this cover page)

APP-GW-GLR-180 Rev. 0 ND-18-0826 2 of 94 W2-8.2-103.F01, Rev. 0 Enclosure 8 ii APP-GW-GLR-180 Rev. 0 (Non-Proprietary) (LAR-18-019)

WESTINGHOUSE PROPRIETARY CLASS 2

© 2017 Westinghouse Electric Company LLC, All Rights Reserved This document is the property of and contains Proprietary Information owned by Westinghouse Electric Company LLC and/or its subcontractors and suppliers. It is transmitted to you in confidence and trust, and you agree to treat this document in strict accordance with the terms and conditions of the agreement under which it was provided to you. Any unauthorized use of this document is prohibited.

DOCUMENT REVIEW SHEET DOCUMENT NO. SM1-CVAP-T2R-200 REVISION 0 ALTERNATE DOC. NO. N/A March 2017 ORGANIZATION Westinghouse Electric Company LLC - WNS TITLE Comprehensive Vibration Assessment Program (CVAP) Preliminary Report for the Sanmen 1 AP1000 Plant WORK BREAKDOWN CVAP STRUCTURE NUMBER:

WESTINGHOUSE CLASS 1 CLASS 2 CLASS 3 PROPRIETARY CLASS:

AUTHORS SECTION(S) SIGNATURE DATE

1. Richard O. Vollmer All except below Electronically Approved***

2. Jeremy R. Koether Sections 3.5.2, 3.5.5, 3.6.1.2 Electronically Approved***

3. David C. DiBasilio Section 3.6.1.3 Electronically Approved***

4. Adam P. Walker Sections 3.6.2.1, 3.6.2.2 Electronically Approved***

5. Gregory A. Banyay Sections 3.6.2.3, 3.6.3, App. C Electronically Approved***

6. Richard A. Basel Section 3.5.6, Section 4 Electronically Approved***

7. William L. Moody Sections 3.6.1.1, App. B Electronically Approved***

VERIFIERS

1. Adam P. Walker All except below Electronically Approved***

2. William L. Moody Sections 3, 3.1-3.3, 3.5.6, 3.6.2, 4, 5.2, 6, App. A Electronically Approved***

3. Richard A. Basel Section 4.2.2 Electronically Approved***

4. Scott E. Sidener App. B Electronically Approved***

REVIEWERS

1. Gregory A. Meyer All except below Electronically Approved***

2. Stephan L. Abbott Section 4.1 Electronically Approved***

3. George J. Demetri Section 4.1 Electronically Approved***

4. Eric M. Weisel Section 4.1 Electronically Approved***

5. David A. Altman Section 4.1 Electronically Approved***

6. Jeremy R. Koether Section 4 Electronically Approved***

• • • Electronically approved records are authenticated in the electronic document management system.

W2-8.2-103.F01, Rev. 0 WGMS/W2-8.2-103.F01.dotx Effective Date: JAN-08-2016

• • • This record was final approved on 6/7/2018 9:46:30 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-180 Rev. 0 Enclosure 8 3 of 94 APP-GW-GLR-180 Rev. 0 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 iii Comprehensive Vibration Assessment Program (CVAP) Preliminary Report for the Sanmen 1 AP1000 Plant SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:46:30 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-180 Rev. 0 Enclosure 8 4 of 94 APP-GW-GLR-180 Rev. 0 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 iv RECORD OF REVISIONS Rev. Date Revision Description 0 See EDMS Original Issue SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:46:30 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-180 Rev. 0 Enclosure 8 5 of 94 APP-GW-GLR-180 Rev. 0 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 v TABLE OF CONTENTS LIST OF TABLES ....................................................................................................................................... vi LIST OF FIGURES ................................................................................................................................... viii ACRONYMS AND TRADEMARKS ......................................................................................................... ix 1 BACKGROUND .......................................................................................................................... 1-1 2

SUMMARY

OF RESULTS .......................................................................................................... 2-1 3 MEASUREMENT PROGRAM ................................................................................................... 3-1

3.1 INTRODUCTION

........................................................................................................................ 3-1 3.2 INSTRUMENTATION ................................................................................................................. 3-1 3.2.1 Disposition of Failed Sensors .......................................................................... 3-1 3.3 DATA ACQUISITION .................................................................................................................. 3-7 3.3.1 Data Acquisition System ................................................................................. 3-7 3.3.2 Data Acquisition Method ................................................................................. 3-9

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3.4 TEST CONDITIONS.................................................................................................................. 3-10 3.5 DATA REDUCTION AND ANALYSIS ..................................................................................... 3-12 3.5.1 General Discussion ........................................................................................ 3-12 3.5.2 Calculation Methods ...................................................................................... 3-12 3.5.3 Measurement Uncertainty.............................................................................. 3-13 3.5.4 Measured CVAP Margin ................................................................................ 3-14

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3.5.6 Contact at Structural Interfaces ..................................................................... 3-15 3.6 COMPONENT MEASURED RESPONSES.............................................................................. 3-17 3.6.1 Lower Internals Response ............................................................................. 3-18 3.6.2 Upper Internals Response .............................................................................. 3-21 3.6.3 Instrumentation Grid Assembly (IGA) .......................................................... 3-24 4 INSPECTION PROGRAM .......................................................................................................... 4-1

4.1 INTRODUCTION

........................................................................................................................ 4-1 4.2

SUMMARY

OF INSPECTIONS ................................................................................................ 4-19 4.2.1 Pre-HFT Inspection Results........................................................................... 4-19 4.2.2 Post-HFT Inspection Results ......................................................................... 4-19 5

SUMMARY

AND CONCLUSIONS ............................................................................................ 5-1 5.1 VIBRATION MEASUREMENT RESULTS ................................................................................ 5-1 5.2 INSPECTION RESULTS ............................................................................................................. 5-2 6 REFERENCES ............................................................................................................................. 6-1 APPENDIX A TRANSDUCER LOCATIONS ....................................................................................... A-1 APPENDIX B RMS UNCERTAINTY ON MEASUREMENT ............................................................. B-1 APPENDIX C MEASUREMENT ACCEPTANCE CRITERIA ............................................................ C-1 SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:46:30 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-180 Rev. 0 Enclosure 8 6 of 94 APP-GW-GLR-180 Rev. 0 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 vi LIST OF TABLES Table 2-1 Acceptance Criteria and Measured Responses for AP1000 Reactor Vessel Internals ..... 2-3 Table 3-1 Transducer Locations for AP1000 CVAP Vibration Measurement Test .......................... 3-2 Table 3-2 Baseline and Limiting Test Conditions for AP1000 CVAP ........................................... 3-11

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Table 4-1 Pre- and Post-Hot Functional Test Inspections ................................................................ 4-2 Table A-1 Illustrations of Transducer Locations.............................................................................. A-1

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@ ....................................................................... B-2 DF SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:46:30 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-180 Rev. 0 Enclosure 8 7 of 94 APP-GW-GLR-180 Rev. 0 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 vii

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SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:46:30 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-180 Rev. 0 Enclosure 8 8 of 94 APP-GW-GLR-180 Rev. 0 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 viii LIST OF FIGURES Figure 2-1. AP1000 Reactor Vessel Internals ........................................................................................... 2-2

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Figure 4-1. Selected Pre-HFT and Post-HFT Inspection Locations ....................................................... 4-18

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@ ................................................................................................ A-18 DF

>

@ ............................................................................................. A-19 DF

>

@ ............................................................................................. A-20 DF

>

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Westinghouse Non-Proprietary Class 3 ix ACRONYMS AND TRADEMARKS CB Core Barrel DF

> @

CS Core Shroud CSS Core Support Structures CVAP Comprehensive Vibration Assessment Program DAQ Data Acquisition System DCD Design Control Document ECNC Eddy Current Non-Contact FFT Fast Fourier Transform FIV Flow-Induced Vibration HFT Hot Functional Test IGA Instrumentation Grid Assembly IITA Incore Instrument Thimble Assembly LCSP Lower Core Support Plate LGT Lower Guide Tube LRS Lower Radial Support NRC Nuclear Regulatory Commission PSD Power Spectral Density QIN Quickloc Instrument Nozzle RCP Reactor Coolant Pump RCS Reactor Coolant System RMS Root Mean Square RVCH Reactor Vessel Closure Head RVI Reactor Vessel Internals SCSS Secondary Core Support Structure UGT Upper Guide Tube U.S. United States USA Upper Support Assembly USC Upper Support Column USP Upper Support Plate VSP Vortex Suppression Plate VADE Vibration and Diagnosis Expansion VSE VADE Satellite Enclosures AP1000 is a trademark or registered trademark of Westinghouse Electric Company LLC, its affiliates and/or its subsidiaries in the United States of America and may be registered in other countries throughout the world. All rights reserved. Unauthorized use is strictly prohibited. Other names may be trademarks of their respective owners.

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Westinghouse Non-Proprietary Class 3 1-1 1 BACKGROUND The United States (U.S.) Nuclear Regulatory Commission (NRC) Regulatory Guide 1.20, Revision 2, Comprehensive Vibration Assessment Program for Reactor Internals during Preoperational and Initial Startup Testing (Ref. 1), provides guidance for the comprehensive vibration assessment program (CVAP) for nuclear power plants during preoperational and initial startup testing. The program demonstrates that the reactor vessel internals (RVI) are adequately designed to withstand flow-induced vibration (FIV) forces during normal and anticipated transient plant operating conditions for the design life of the plant.

In accordance with the commitment to Reg. Guide 1.20, Revision 2, in the AP1000 Design Control P P Document (DCD) (Ref. 2), the first constructed AP1000 plant RVI assembly at Sanmen 1 is classified as a Prototype, as defined in Reg. Guide 1.20. The CVAP for a Prototype RVI configuration includes the following elements:

x Vibration Analysis Program The analysis program (Ref. 3) consists of a vibration analysis for steady-state and anticipated transient conditions corresponding to preoperational and initial startup test and normal operating conditions. This includes creating structural and hydraulic models, determining natural frequencies and associated mode shapes, and estimating random and deterministic forcing functions. The analysis program also calculates expected and acceptable responses for selected vibration measurement program sensor locations and develops acceptance criteria for the vibration measurement program, including permissible deviations.

x Vibration Measurement Program The in-plant vibration measurement program (Ref. 4) verifies the structural integrity of the RVI for FIV, determines the margin of safety associated with steady-state and anticipated transient conditions for normal operation, and verifies the results of the analysis program. Margin of safety in a particular component is established by comparing the limiting measured response in the component to the maximum allowable response at the measurement location. Appropriate transducers are placed throughout the RVI to monitor significant lateral, vertical, and torsional motions of major RVI components in all significant modes of vibration, and their hydraulic responses. These transducer data are recorded for all steady-state and bounding anticipated transient modes of operation (flow transients), including expected reactor coolant pump (RCP) speeds and combinations permissible during the hot functional test (HFT). The selected test duration with plant operation at normal operating modes ensures that each critical component experiences at least 106 cycles of vibration P P (computed at the lowest frequency for which the component has a significant structural response) prior to the final inspection.

x Inspection Program The inspection program (Ref. 4) consists of pre- and post-HFT inspections of the RVI. The inspection program includes a tabulation of all RVI components and local inspected areas, and a description of the inspection procedure including inspection method, documentation, access provisions, and any specialized equipment used during inspection.

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Westinghouse Non-Proprietary Class 3 1-2 x Documentation of Results A review and correlation of the results of the analysis, vibration measurement, and inspection program are conducted following completion of the inspection program to determine if the acceptance criteria are satisfied. This evaluation of results and a description of any modifications or actions necessary to demonstrate the structural adequacy of the RVI are documented in preliminary (the present document) and final reports as specified in Reg. Guide 1.20 (Ref. 1).

The CVAP for the AP1000 plant is provided in two documents. The Vibration Analysis Program (Ref. 3) includes a description of the AP1000 plant RVI, vibration analysis methodology, response predictions for the RVI components, and acceptance criteria for applicable sensor locations. The Measurement and Inspection Programs for the AP1000 plant CVAP are documented in the CVAP Measurement and Inspection Program Report (Ref. 4).

The Vibration Analysis Program and Measurement and Inspection Program satisfy the requirements of Reg. Guide 1.20, as outlined in Table 2-2 of Ref. 3 and Table 2-1 of Ref. 4.

This Preliminary Report contains the evaluation of the Sanmen 1 CVAP Vibration Measurement and Inspection Program results with respect to the test acceptance criteria. Anomalous data that could affect the structural integrity of the RVI are identified and evaluated on a preliminary basis, including instrumentation failures that have occurred during the HFT. This Preliminary Report satisfies the requirements of Reg. Guide 1.20, Section C.2.4.1.

The Final Report will provide a detailed comparison of analytical predictions, test measurements, and inspections. Descriptions of any significant deviations, comparisons between measured and analytical responses, determination of high-cycle fatigue margins for component responses, and evaluation of unanticipated observations will be included. The Final Report satisfies the requirements of Reg. Guide 1.20, Section C.2.4.2.

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Westinghouse Non-Proprietary Class 3 2-1 2

SUMMARY

OF RESULTS The purpose of the CVAP is to verify the structural integrity of the RVI for flow-induced vibration prior to commercial operation. The dynamic flow-related loads considered are those associated with steady-state and anticipated transients during preoperational, initial startup, and normal operating conditions.

The RVI assembly is depicted in Figure 2-1. Components instrumented for vibration measurement during the HFT include >

The instrumentation is DF

@

described in detail in Section 3.2.

The Sanmen 1 HFT began in August 2016 and was completed in December 2016. Testing was performed at numerous steady-state and transient operating conditions during HFT, including the limiting conditions for the RVI shown in Table 3-2. The cumulative duration of testing at normal operating conditions was greater than 15 days, exposing the RVI to normal operating modes for greater than > @ cycles of DF vibration (see Section 3.4). This exceeds the Reg. Guide 1.20 (Ref. 1) requirement for a minimum of 106 P P cycles of vibration.

During HFT, vibration data were acquired for the RVI components listed in Table 2-1 to compare with acceptance criteria > @ Transducer signals were conditioned and recorded for DF post-test reduction and analysis. Responses during testing were monitored online and the signals were evaluated for spectral content. Root mean square (RMS) values of the signals related to structural response were computed and compared to the acceptance criteria based on analysis as described in the Vibration Analysis Program (Ref. 3). The limiting measured response values and the associated acceptance criteria are compared in Table 2-1; these results indicate positive measured margin for high-cycle fatigue in these critical RVI components.

To assess wear or fatigue of the components, the RVI were visually inspected before and after the HFT as specified in the Inspection Program (Ref. 4). The inspections included major load bearing surfaces, contact surfaces, welds, and maximum stress locations identified by analysis. Photographic records of the pre-HFT and post-HFT inspections were made. The inspections are documented in the Owners Pre-HFT and Post-HFT Inspection Reports (Ref. 9 and Ref. 10). Comparisons of the visual inspection results before and after HFT were performed (see Section 4.2); based on these results, no signs of abnormal wear or contact for the RVI components were found.

The evaluations documented in this report demonstrate the structural integrity of the Sanmen 1 AP1000 reactor vessel internals with respect to flow-induced vibration for the 60-year design life of the plant, in accordance with Reg. Guide 1.20, Revision 2.

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Westinghouse Non-Proprietary Class 3 2-2 Figure 2-1. AP1000 Reactor Vessel Internals SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 2-3 Table 2-1 Acceptance Criteria and Measured Responses for AP1000 Reactor Vessel Internals Total RMS Total RMS CVAP RVI Gage Total RMS Location Measured + Acceptance Measured Component(1) Identifier Measured(2)

Uncertainty(2) Criterion(3) Margin(4)

P P P P a,c SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 3-1 3 MEASUREMENT PROGRAM

3.1 INTRODUCTION

The objective of the measurement program is to obtain sufficient data to confirm predictions of the margin of safety at operating conditions for steady-state and transient normal operation. Hence, the RVI instrumentation includes transducers to measure the structural response.

3.2 INSTRUMENTATION The CVAP instrumentation mounted on the RVI is described in detail in the Vibration Measurement Program (Ref. 4) and summarized in Table 3-1. This table summarizes the types and locations of the CVAP sensors, and includes comments recorded for these sensors during HFT. A total of >

@ were monitored during testing.

DF The sensor locations are illustrated in Appendix A.

3.2.1 Disposition of Failed Sensors a,c SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 3-2 Table 3-1 Transducer Locations for AP1000 CVAP Vibration Measurement Test Approximate Instrumented Transducer Direction of ID Transducer Comments / Status Component Type Sensitivity Location(1)P a,c SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 3-3 Table 3-1 Transducer Locations for AP1000 CVAP Vibration Measurement Test Approximate Instrumented Transducer Direction of ID Transducer Comments / Status Component Type Sensitivity Location(1)P a,c SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 3-4 Table 3-1 Transducer Locations for AP1000 CVAP Vibration Measurement Test Approximate Instrumented Transducer Direction of ID Transducer Comments / Status Component Type Sensitivity Location(1)P a,c SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 3-5 Table 3-1 Transducer Locations for AP1000 CVAP Vibration Measurement Test Approximate Instrumented Transducer Direction of ID Transducer Comments / Status Component Type Sensitivity Location(1)P a,c SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 3-6 Table 3-1 Transducer Locations for AP1000 CVAP Vibration Measurement Test Approximate Instrumented Transducer Direction of ID Transducer Comments / Status Component Type Sensitivity Location(1)P a,c SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 3-7 3.3 DATA ACQUISITION 3.3.1 Data Acquisition System The CVAP data acquisition is performed using the Westinghouse Vibration and Diagnosis Expansion (VADE) system (Figure 3-1), which is described in detail in the Vibration Measurement Program (Ref. 4).

a,c During the HFT, the DAQ performed as expected, i.e., there were no issues that affected the collection or quality of the measurement data.

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Westinghouse Non-Proprietary Class 3 3-9 3.3.2 Data Acquisition Method The DAQ records electrical signals from the transducers mounted on the reactor vessel internals. These recorded time histories are post-processed and analyzed using Fast Fourier Transform (FFT) techniques.

>

@ Broadband RMS levels DF of selected channels are determined to establish that the response of the reactor vessel internals are within the acceptable design limits.

3.3.2.1 Signal Conditioning, Calibration, and Baseline Measurements A detailed description of the signal conditioning equipment is given in the Vibration Measurement Program (Ref. 4). All sensors and signal conditioning equipment were calibrated before installation.

Each transducer and its associated cables are uniquely identified. Confirmation of correct channel location and identification was performed during the installation of the instrumentation.

After installation and field wiring of the transducers, field system verification checks were performed for each channel prior to initial data acquisition. Thereafter, baseline data are collected to determine the channel noise level.

3.3.2.2 Data Recording Signals from > @ are DF recorded and monitored during testing. For transient testing >

DF

@ the transient event. Plant parameters are recorded in the control room during each test condition, >

@ These DF parameters are used to confirm the applicable test conditions for each CVAP Test Point.

3.3.2.3 Data Monitoring The DAQ is configured to monitor the incoming signals for over range and no signal conditions before and during data recording. >

DF The measurements are compared to the established acceptance criteria (Table 2-1) for each location to ensure that the structural response is within the acceptable limits. The acceptance criteria are based on the allowable vibratory stress limits for the instrumented components and the installed location of the transducers.

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Westinghouse Non-Proprietary Class 3 3-10 a,c 3.4 TEST CONDITIONS Vibration data required for the CVAP were obtained during HFT at Sanmen 1, which began in August 2016 and completed in December 2016. Testing was performed at numerous steady-state and transient operating conditions during HFT (Ref. 12), including the baseline condition and limiting test conditions for the RVI given in Table 3-2 (Ref. 4). The cumulative duration of testing at normal operating conditions was greater than 15 days (Ref. 12). Per Section 5.3 of Ref. 4, a duration of > @ generates DF over 106 cycles of vibration based on the lowest significant structural frequency of the RVI components P P

@ , as required by Reg. Guide 1.20 (Ref. 1). Therefore, the actual duration of 15+ days DF

>

exposed the RVI to normal operating modes for a minimum of > @ cycles of DF vibration, which exceeds the Reg. Guide 1.20 requirement.

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Westinghouse Non-Proprietary Class 3 3-11 Table 3-2 Baseline and Limiting Test Conditions for AP1000 CVAP Number of Best Estimate CVAP Test Inlet Coolant Pump Speed Description of Test Point Operating RCS Flow Rate Comments/Basis Point(1)(2) Temp. (°F) (rpm)

Pumps (gpm)

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Westinghouse Non-Proprietary Class 3 3-12 3.5 DATA REDUCTION AND ANALYSIS During the HFT, data signal time histories are monitored on-line for signal amplitude, electrical noise level, and frequency content. Broadband RMS levels of selected channels are compared to previously defined acceptance criteria to demonstrate the responses of the RVI are acceptable.

3.5.1 General Discussion

@ Analyses are DF

>

performed for each component to identify the amplitude of the FIV response, the frequency and mode shape of the resonance response peaks in the spectra, >

DF

@

Broadband measured responses, acceptance criteria, and CVAP margins are provided for components in the Lower Internals Assembly, Upper Internals Assembly, and IGA in Sections 3.6.1, 3.6.2, and 3.6.3, respectively. >

@ The specific DF frequency range for the RMS calculations is identified for each component. >

DF

@

3.5.2 Calculation Methods The following concepts apply to the data reduction as used in the analysis of the CVAP test results reported in Section 3.6.

3.5.2.1 Power Spectral Density, Cross-Spectral Density, and Coherence Functions Chapter 19 of Ref. 5 describes the power spectral density (PSD), cross-spectral density, and coherence functions as follows. The finite Fourier transform of a time sample of duration T (where = 1) is defined as:

(, ) = )( = )(cos(2 ) )(sin(2( )Ref. 5, Eq. 19.3)

The PSD, also referred to as the autospectral density function, is the Fourier transform of the autocorrelation function of a dynamic signal.

() = lim (l[ , )l ] , > 0 (Ref. 5, Eq. 19.13) where E[] denotes the expected value of [], which implies an ensemble average (i.e., arithmetic average).

Given two stationary random vibrations, x(t) and y(t), the cross-spectral density function is defined as:

() = lim ([ , )(, )] , > 0 (Ref. 5, Eq. 19.17)

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Westinghouse Non-Proprietary Class 3 3-13 Then, the coherence function between two random vibrations x(t) and y(t) is:

()

() =

() () , > 0 (Ref. 5, Eq. 19.20)

Physically, the coherence function is an indication of the degree of linear relationship between two signals. For frequencies where () = 0 there is no linear relationship between x(t) and y(t)

(vibrations are uncorrelated), whereas at frequencies where () = 1 there is a perfect relationship between x(t) and y(t) (one vibration can be exactly predicted from the other).

a,c 3.5.2.2 Root Mean Square (RMS) Calculation Method To determine the narrow band RMS result (equivalent RMS value of the time history result that is filtered to include only a specified frequency band), it is recognized that the mean square value over a specified frequency range is the sum of the autospectral density coefficients for that range (Ref. 5). The equivalent RMS value of the signal over that range is the square root of the mean square value for the range.

3.5.3 Measurement Uncertainty Appendix B documents the uncertainty applicable to the measured responses, including uncertainty associated with data analysis and post-processing. Uncertainty in the acceptance criteria is addressed with conservative bias as part of the predictive analysis and acceptance criteria development (Ref. 3).

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Westinghouse Non-Proprietary Class 3 3-14 a,c 3.5.4 Measured CVAP Margin The measured CVAP margins are calculated by comparing the measured RMS response, including uncertainty, to the corresponding RMS acceptance criterion from Appendix C. Thus, margin is defined as:

= 1

+

Where:

Maximum allowable sensor response (RMS) at the limiting condition (Appendix C)

Measured sensor response (RMS) at the limiting condition Measurement uncertainty (Appendix B)

In general, margins are reported for the limiting condition for each component, that is, the condition that produces the smallest measured margin. For components with large measured margins, the component margin may be conservatively calculated using the highest overall measured response and the smallest overall acceptance criterion.

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Westinghouse Non-Proprietary Class 3 3-15 a,c 3.5.6 Contact at Structural Interfaces There are three guidance features in the RVI where small structural gaps that exist during normal operation may come into contact under certain conditions:

x Between the lower radial support (LRS) keys and clevis inserts x Between the core barrel and reactor vessel outlet nozzles x Between the alignment plates on the core barrel and inserts in the core shroud and in the upper core plate a,c SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 3-16 a,c SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 3-17 3.6 COMPONENT MEASURED RESPONSES The measured responses are due >

DF a,c The component measured responses, acceptance criteria, and calculated CVAP margin are presented in the following sections.

a,c For the results presented in these sections, the units for strain are micro-strain ( , 10-6 in/in), and the units for displacement are mils (10-3 in).

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Westinghouse Non-Proprietary Class 3 3-18 3.6.1 Lower Internals Response a,c SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 3-19 a,c SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 3-21 a,c 3.6.2 Upper Internals Response SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 3-24 3.6.3 Instrumentation Grid Assembly (IGA) a,c SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 4-1 4 INSPECTION PROGRAM

4.1 INTRODUCTION

The planned pre-HFT and post-HFT inspection methods and locations are provided on inspection drawings (Ref. 6 and Ref. 7, respectively), with inspection activities specified in Ref. 6.g, Ref. 7.g, and Ref. 13. The inspections are visual, checking for cracks, wear, and debris or loose parts. The RVI are removed from the reactor vessel for these inspections. Inspections were performed in accordance with the RVI installation manual (Ref. 8) and CVAP inspection procedure (Ref. 11).

The inspection locations of interest were selected in accordance with guidance given in Ref. 1. The components and areas of inspection include all major load-bearing elements that retain the position of the CSS; lateral, vertical, and torsional restraints; locking and bolting components; contact surfaces; and the reactor vessel interior for debris and loose parts. The inspection locations and methods are described in Ref. 4 and presented in detail in Ref. 6, Ref. 7, and Ref.10. A representative subset of the inspection locations is also shown in Figure 4-1.

The results of the pre-HFT and post-HFT inspections at each location are recorded in the form of inspection notes and photographs, and are documented in the pre-HFT and post-HFT inspection reports (Ref. 9 and Ref. 10). Pertinent observations from these inspection reports are summarized in Table 4-1.

The inspections consider the items listed in Ref. 6.g and Ref. 7.g, including:

x Identification of any broken or loose parts detected before or after the HFT.

x Examination of weld surfaces on the CB for abnormal markings or cracks.

x Examination of interface surfaces such as the contact surfaces of the lower radial support keys and clevis inserts, the CB and reactor vessel outlet nozzle contact surfaces, the alignment plate contact surfaces, the CB flange top and bottom surfaces, the upper support assembly flange top and bottom surfaces, and the hold-down spring interfaces with the CB and upper support assembly flanges.

It should be noted that the inspection drawings (Ref. 6) were updated after the pre-HFT inspections to incorporate lessons learned from those inspections, specifically to clarify instructions and level of detail for the inspections (see Ref. 7 and Ref. 13). The features to be inspected in Table 4-1 and inspection locations shown in Figure 4-1 are based on the updated inspection drawings (Ref. 7).

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Westinghouse Non-Proprietary Class 3 4-2 Table 4-1 Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4)

Notes(1) Notes(2) a,c 1 Core Shroud Studs, Nuts, Locking Caps, and Dowel Pin 1, 2 7, 11 Welds 2 Hold-Down Spring Interface Surface Condition 6 9 3 Upper Support Column Screw Locking Devices 1, 2, 13 7, 11 4 Upper Core Plate Inserts 3, 6 9, 12 SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 4-3 Table 4-1 Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4) a,c Notes(1) Notes(2) 5 Guide Tube Flange Bolts and Locking Devices 1, 2, 13 7, 11 6 USP Skirt Longitudinal Weld (Inner and Outer Surface) N/A 6, 13 (For the pre-HFT inspection, Location 6 duplicated the Location 10 inspections and was omitted as redundant) 7 Upper Support Skirt to Upper Support Plate Girth Weld 1 6 8 Upper Support Skirt to Upper Support Flange Girth Weld 1 6 9 Guide Tube Welds 1, 19 6, 16 (The upper guide tubes were not installed at core locations D-12, E-11 and F-10 during the Hot Functional Test. Special cover plates were installed at these three locations to accommodate the CVAP instrumentation.)

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Westinghouse Non-Proprietary Class 3 4-4 Table 4-1 Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4)

Notes(1) Notes(2) a,c 10 Upper Core Plate Insert Locking Devices and Welds 1, 2 7, 11 11 Upper Core Barrel to Core Barrel Flange Girth Weld 1 6 (Inner and Outer Surface) 12 Upper Core Barrel to Mid Barrel Girth Weld (Inner and 1 6 Outer Surface) 13 Lower Core Barrel to Lower Core Support Plate Girth 1 6 Weld 14 Alignment Plate Interface Surfaces 9 9 15 Core Barrel Outlet Nozzle Interface Surfaces 6 9 SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 4-5 Table 4-1 Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4)

Notes(1) Notes(2) a,c 16 Neutron Shield Panel Dowel Pin Welds 1 6 17 Neutron Shield Panel Screw Locking Devices and Welds 1, 2 7, 11 18 Interface Surfaces at the Spacer Pads Along the Top and 8 12 Bottom Ends of the Neutron Panels 19 Core Shroud C-Panel to W-Panel Welds 1 6 20 Lower Core Support Plate Fuel Alignment Pin 1 7 Lockwasher Welds 21 Secondary Core Support Assembly to Base Plate Weld 1 6 SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 4-6 Table 4-1 Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4) a,c Notes(1) Notes(2) 22 Locking Devices and Contact of the Butt Columns Where 1, 2, 8 7, 11, 12 Attached to the Lower Core Support Plate and Vortex Suppression Plate and Welds 23 Locking Devices and Contact of the Secondary Core 1, 2, 8 7, 11, 12 Support Columns at the Lower Core Support Plate and at the Vortex Suppression Plate and Welds 24 Radial Support Key Welds 1 6 25 Radial Support Key Interface Surfaces 4 9 SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 4-7 Table 4-1 Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4) a,c Notes(1) Notes(2) 26 Head And Vessel Alignment Pins, Contact Surfaces and 1,4 7, 8 Lock Bar Welds 27 Irradiation Specimen Basket Screw Locking Devices, 1, 2 7, 11 Welds, and Dowel Pins 28 Vessel Nozzle Interface Surface Condition 6 9 29 Vessel Clevis Interface Surfaces, Locking Devices, and 1, 3, 9 7, 9, 12 Dowel Pin Welds SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 4-8 Table 4-1 Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4)

Notes(1) Notes(2) a,c 30 Reinforcement Pad Welds 1 6 31 Core Barrel Longitudinal Welds (Inner and Outer) 1, 12 6, 13, 15 (For the pre-HFT inspection, this location included the USP skirt longitudinal weld)

(For the post-HFT inspection, the USP skirt longitudinal weld was deleted from Location 31 and renumbered as Location 6) 32 Direct Vessel Injection (DVI) Deflector Stud Lock Bar 1, 6 7 Welds 33 Core Shroud Top Plate Inserts 6 9, 12 (The radial inserts were not installed at any of the four locations during the Hot Functional Test to accommodate CVAP instrumentation fixtures. The CVAP instrumentation fixtures were replaced with the standard radial inserts after the Hot Functional Test) 34 Core Shroud Top Plate Insert Locking Devices 1, 2 7, 11 (The radial inserts were not installed at any of the four locations during the Hot Functional Test)

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Westinghouse Non-Proprietary Class 3 4-9 Table 4-1 Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4) a,c Notes(1) Notes(2) 35 Alignment Plate Screws and Locking Devices 1 7 (The lock bars for the middle elevation screws at 225 and 315 degrees extend beyond the reinforcement pad surface as part of the special CVAP hardware and were replaced with the standard items after the Hot Functional Test) 36 Roto-Lock Inserts and Locking Tab Welds 1, 6 6, 9 37 Head Cooling Spray Nozzle Weld 1 6 38 Inside Diameter of the Quickloc Instrument Nozzle 5, 9 9 (QIN) 39 Direct Vessel Injection (DVI) Deflector Stud Tack Welds 1 7 40 Reactor Vessel Direct Vessel Injection (DVI) Nozzle 9 9 Interior Face SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 4-10 Table 4-1 Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4) a,c Notes(1) Notes(2) 41 DVI Deflector Outer Surface 9 9 42 Upper Support Assembly Flange Top and Bottom 6 9 Surface 43 Core Barrel Flange Top and Bottom Surface 6 9 44 Reactor Vessel Closure Head Bottom Surface 6 9 45 Reactor Vessel Support Ledge Top Surface 6 9 SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 4-11 Table 4-1 Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4)

Notes(1) Notes(2) a,c 46 Head and Vessel Alignment Pin Keyways in Reactor 4 9 Vessel Closure Head 47 Head and Vessel Alignment Pin Keyways in Reactor 4 8, 9 Vessel 48 Core Barrel Outlet Nozzle Weld 1 6 49 Mid to Lower Core Barrel Girth Weld 1 6 SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 4-12 Table 4-1 Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4) a,c Notes(1) Notes(2) 50 Interface Surface of Upper Support Assy Skirt Outer 6 9 Wall and Core Barrel Inner Wall 51 Bottom Of Base Plate and Reactor Vessel 6 9 52 Upper Core Plate Fuel Alignment Pin Nuts and Lock 1, 13 7 Welds 53 Lower Guide Tube Support Pin Locking Devices 1, 2, 13 11, 15 54 Lower Core Support Plate Access Plug Cap Screw Lock 1 7 Bar Welds and Lock Pin Welds 55 Interior of Reactor Vessel and Outside of Flow Skirt 11 10 SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 4-13 Table 4-1 Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4) a,c Notes(1) Notes(2) 56 Flow Skirt to Reactor Vessel Support Lug Welds 1 6 57 Inner Surfaces of Flow Skirt 4 8 58 Top Surface of Flow Skirt (Absence of Contact) 6 9 59 Flow Skirt Tabs, Slots and Area Around Adjacent Holes 4 8 60 Vertical Welds Between Flow Skirt and Flange Sections 1 6, 13 61 Flow Skirt Shell to Flange Welds 1 6 62 IITA Tubes at Compression Fitting Assemblies 9, 12 15, 17 63 Welds at Compression Fitting Locations 1, 12 15, 17 64 IITA Tubes as They Exit the Quickloc Upper Support 9 17 Flange Assembly SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 4-14 Table 4-1 Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4) a,c Notes(1) Notes(2) 65 Threaded Structural Fasteners and Locking Cups at All 1, 2, 9, 12 11, 17 Locations on the IGA Plate 66 Locking Nut to Support Pin and Locking Nut to IGA 1 17 Plate Welds 67 Locking Nut to Locating Pin and Locking Nut to IGA 1 17 Plate Welds 68 Interface Surfaces of Locating Pins, Support Pins, and 9 9 Corresponding Seating Surface and the Locating Holes and Seating Surface on the Upper Support Plate 69 Joints Between The IGA Instrument Tube, IGA Split 1, 2, 9, 13 11, 17 Collar Threaded Structural Fasteners and Locking Cups 70 All Welds in the Quickloc Upper & Lower Support 1 6 Assemblies 71 IGA Instrument Tube Outside Surface at the IGA Spring 7, 9, 13 14, 15 Can Bottom Interface SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 4-15 Table 4-1 Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4) a,c Notes(1) Notes(2) 72 IGA Spring Can Bottom Surface Interface with the IGA 9, 13 9, 15 Instrument Tube Sleeve Top Surface 73 Top Surface and the Top 2 Inches of the OD of the IGA 9, 13 9, 15 Instrument Tube Sleeve 74 OD Surfaces of the Quickloc Stalk Can and the IGA 9 9 Quickloc Upper Support Flange Assembly 75 IGA Guide Studs at the Interface Location of the Guide 9 17 Bushings 76 IGA IITA Tube Support Welds to IGA Plate 1, 12 6, 15 77 IGA Guide Stud Attachment Bolts & Locking Devices 1, 2 7, 11 78 Upper Support Column Nut to Upper Support Column 1, 2, 13 7 Lock Welds SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 4-16 Table 4-1 Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4)

Notes(1) Notes(2) a,c 79 IGA Guide Bushing Attachment (Bolts, Locking Cups 1, 2 11, 17 and Welds) 80 Welds on Upper Support Column Instrumentation 1 17 Adaptor 81 Quickloc Stalk Alignment Screws and Hold-Down 1, 2 17 Screws 82 Contact Locations Between Full Flow Restrictors and 6 9 Upper Core Plate and Fuel Alignment Pins 83 IGA IITA Tube Support Welds to Quickloc Lower 1, 12 6, 15 Support Assemblies 84 SCSS guide post to energy absorber welds 1 6 85 SCSS energy absorber to housing welds 1 6 SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 4-17 Table 4-1 Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4)

Notes(1) Notes(2)

Notes:

1. See Ref. 6.g for pre-HFT inspection notes.

2. See Ref. 7.g for post-HFT inspection notes.

3. Refer to the indicated page number(s) in Ref. 9.

4. Refer to the indicated page number(s) in Ref. 10.

DF

> @

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Westinghouse Non-Proprietary Class 3 4-18 Figure 4-1. Selected Pre-HFT and Post-HFT Inspection Locations SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 4-19 4.2

SUMMARY

OF INSPECTIONS 4.2.1 Pre-HFT Inspection Results The pre-HFT inspections of the reactor vessel internals are complete and were performed in accordance with the Inspection Program (Ref. 4) and inspection drawings (Ref. 6). The pre-HFT inspection results are documented in Ref. 9 and summarized in Table 4-1. As noted in Table 4-1, no major defects were observed and the pre-HFT inspection results are acceptable. The pre-HFT inspections are summarized below:

a,c 4.2.2 Post-HFT Inspection Results The post-HFT inspections of the reactor vessel internals are complete and were performed in accordance with the Inspection Program (Ref. 4), inspection instructions (Ref. 13), and inspection drawings (Ref. 7).

The post-HFT inspection drawings were updated (from those in Ref. 6) and Reference 13 was added based on the experience gained during the pre-HFT inspections, specifically to clarify instructions and level of detail for the inspections. The inspection results are documented in Ref. 10 and summarized in Table 4-1. The post-HFT inspections are summarized below: a,c SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 4-20 a,c SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 5-1 5

SUMMARY

AND CONCLUSIONS The HFT at Sanmen 1 was conducted between August 2016 and December 2016. This period of operation resulted in greater than > @ cycles of vibration at normal operating conditions accumulated DF by the core support structures, which exceeds the Reg. Guide 1.20 requirement for a minimum of 106 P P cycles of vibration (see Section 3.4).

Based on the evaluation of the measurement results and comparison of the pre-HFT and post-HFT inspection results described below, it is concluded that the dynamic response of the RVI due to FIV loading is acceptable for long-term operation of the reactor.

5.1 VIBRATION MEASUREMENT RESULTS An evaluation was conducted of the vibration measurements recorded during HFT >

@ As documented in DF Section 3.6 and summarized in Table 2-1, the RVI component measured responses are acceptable, i.e.,

lower than their respective acceptance criteria. a,c SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 5-2 a,c 5.2 INSPECTION RESULTS Inspections of the RVI before and after HFT were compared to evaluate evidence of unusual contact, wear, or broken or damaged parts. The inspection results were also compared for consistency with the measured vibration results. a,c SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 6-1 6 REFERENCES

1. U.S. NRC Regulatory Guide 1.20, Rev. 2, Comprehensive Vibration Assessment Program for Reactor Internals During Preoperational and Initial Startup Testing, May 1976.

2. Westinghouse Document, APP-GW-GL-700, Rev. 19, AP1000 Design Control Document, June 17, 2011.

3. Westinghouse Document, APP-CVAP-GER-003 (WCAP-17984), Rev. 0, Comprehensive Vibration Assessment Program (CVAP) Vibration Analysis Program for the AP1000 Plant, July 28, 2015 (as modified by APP-CVAP-GEF-024, Rev. 0, Changes to IGA Strain Gage Locations and Routing).

4. Westinghouse Document, APP-CVAP-GER-004 (WCAP-17983), Rev. 0, Comprehensive Vibration Assessment Program (CVAP) Measurement and Inspection Programs for the AP1000 Plant, March 26, 2015.

5. A. G. Piersol and T. L. Paez, Harris Shock and Vibration Handbook, 6th Edition, McGraw Hill, P P 2009.

6. Westinghouse Inspection Drawings (Westinghouse Proprietary) (as modified by APP-MI01-GEF-371, Rev. 0, Updates to CVAP Inspections):

a. APP-MI01-T2I-001, Rev. 2, AP1000 Reactor Internals Vibrational Check-Out Functional Test Inspection Data.

b. APP-MI01-T2I-002, Rev. 1, AP1000 Reactor Internals Vibrational Check-Out Functional Test Inspection Data.

c. APP-MI01-T2I-003, Rev. 1, AP1000 Reactor Internals Vibrational Check-Out Functional Test Flow Skirt Inspection Data.

d. APP-MI01-T2I-004, Rev. 1, AP1000 Reactor Internals Vibrational Check-Out Functional Test Instrumentation Grid Assembly Inspection (IGA Lowered Operating Elevation).

e. APP-MI01-T2I-005, Rev. 1, AP1000 Reactor Internals Vibrational Check-Out Functional Test Instrumentation Grid Assembly Inspection (IGA Raised Refueling Elevation).

f. APP-MI01-T2I-006, Rev. 1, AP1000 Reactor Internals Vibrational Check-Out Functional Test Instrumentation Grid Assembly Inspection.

g. APP-MI01-T2I-007, Rev. 0, AP1000 Reactor Internals Vibrational Check-Out Functional Test Inspection Data.

7. Westinghouse Inspection Drawings (Westinghouse Proprietary):

a. APP-MI01-T2I-001, Rev. 3, AP1000 Reactor Internals Vibrational Check-Out Functional Test Inspection Data.

SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 6-2

b. APP-MI01-T2I-002, Rev. 2, AP1000 Reactor Internals Vibrational Check-Out Functional Test Inspection Data.

c. APP-MI01-T2I-003, Rev. 2, AP1000 Reactor Internals Vibrational Check-Out Functional Test Flow Skirt Inspection Data.

d. APP-MI01-T2I-004, Rev. 2, AP1000 Reactor Internals Vibrational Check-Out Functional Test Instrumentation Grid Assembly Inspection (IGA Lowered Operating Elevation).

e. APP-MI01-T2I-005, Rev. 2, AP1000 Reactor Internals Vibrational Check-Out Functional Test Instrumentation Grid Assembly Inspection (IGA Raised Refueling Elevation).

f. APP-MI01-T2I-006, Rev. 2, AP1000 Reactor Internals Vibrational Check-Out Functional Test Instrumentation Grid Assembly Inspection.

g. APP-MI01-T2I-007, Rev. 1, AP1000 Reactor Internals Vibrational Check-Out Functional Test Inspection Data.

8. Westinghouse Document, APP-MI01-Z0M-001, Rev. 4, AP1000 RVI Installation Requirements Manual, (Westinghouse Proprietary), December 8, 2016.

9. Westinghouse Document, SM1-CVAP-T2R-100, Rev. 0 (SMRC-VT-RS-03), Sanmen Unit 1 Pre-Hot Functional Test Visual Inspection Report of the AP1000 Reactor Vessel Internals, July 13, 2016.

10. Westinghouse Document, SM1-CVAP-T2R-400, Rev. 0 (SMRC-M-00557-SCPP), Sanmen Unit 1 Post-Hot Functional Test Visual Inspection Report of the AP1000 Reactor Vessel Internals, March 10, 2017.

11. Westinghouse Document, SM1-RXS-T2R-50006, Rev. A (SM1-RXS-T1P-501), Pre and Post-Hot Functional Inspection Test of Reactor Vessel Internals Preoperational Test Procedure, March 1, 2017 (attached to this report in EDMS).

12. Westinghouse Document, SM1-RXS-T2R-50007 Rev. A (SM1-RXS-T1P-502), Reactor Vessel Vibration Test Preoperational Test Procedure, March 1, 2017 (attached to this report in EDMS).

13. Westinghouse Document, APP-CVAP-T2I-001, Rev. 0, AP1000 Comprehensive Vibration Assessment Program (CVAP) Pre and Post Hot Functional Test (HFT) Visual Inspection Instructions, November 4, 2016.

14. ASME Boiler & Pressure Vessel Code,Section III, 1998 Edition with Addenda through 2000.

15. ASME OM-S/G-2007, Standards And Guides For Operation And Maintenance Of Nuclear Power Plants.

16. Westinghouse Document, SM1-MI01-GNR-4165, Rev. 0, Field Deviation Notice for Failed Lower Internals CVAP sensors, November 15, 2016.

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Westinghouse Non-Proprietary Class 3 A-1 APPENDIX A TRANSDUCER LOCATIONS This appendix provides figures to illustrate transducer locations for the Vibration Measurement Program.

In these figures, sensors are labeled by instrument ID as shown in Table 3-1. The figures are summarized in Table A-1.

a,c Table A-1 Illustrations of Transducer Locations Figure No. Description a,c SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 B-1 APPENDIX B RMS UNCERTAINTY ON MEASUREMENT a,c SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Westinghouse Non-Proprietary Class 3 C-1 APPENDIX C MEASUREMENT ACCEPTANCE CRITERIA a,c SM1-CVAP-T2R-200 March 2017 Revision 0 © 2018 Westinghouse Electric Company LLC All Rights Reserved

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Southern Nuclear Operating Company ND-18-0826 Enclosure 10 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 APP-GW-GLR-182, Revision 0, Comprehensive Vibration Assessment Program (CVAP)

Final Report for the Sanmen 1 AP1000 Plant (Non-Proprietary)

(LAR-18-019)

(This Enclosure consists of 233 pages, including this cover page)

APP-GW-GLR-182 Rev. 0 ND-18-0826 2 of 233 W2-8.2-103.F01, Rev. 0 Enclosure 10 ii APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

WESTINGHOUSE PROPRIETARY CLASS 2

© 2016 Westinghouse Electric Company LLC, All Rights Reserved This document is the property of and contains Proprietary Information owned by Westinghouse Electric Company LLC and/or its subcontractors and suppliers. It is transmitted to you in confidence and trust, and you agree to treat this document in strict accordance with the terms and conditions of the agreement under which it was provided to you. Any unauthorized use of this document is prohibited.

DOCUMENT REVIEW SHEET DOCUMENT NO. SM1-CVAP-T2R-300 REVISION 1 ALTERNATE DOC. NO. N/A September 2017 ORGANIZATION Westinghouse Electric Company LLC - WNS TITLE Comprehensive Vibration Assessment Program (CVAP) Final Report for the Sanmen 1 AP1000 Plant WORK BREAKDOWN STRUCTURE NUMBER: CVAP WESTINGHOUSE CLASS 1 CLASS 2 CLASS 3 PROPRIETARY CLASS:

AUTHORS SECTION(S) SIGNATURE DATE

1. Richard A. Basel Electronically Approved***

All except below

2. Richard O. Vollmer Electronically Approved***

3. Gregory A. Banyay 4.6.2.3, 4.6.3, 0, App. C.1, App. J Electronically Approved***

4. Inessa E. Berman App. K Electronically Approved***

5. David C. DiBasilio 4.6.1.3, 4.6.2.2, 4.7, App. G, App. I Electronically Approved***

6. Jeremy R. Koether 4.5.5, 4.6.1.2, App. F Electronically Approved***

7. William L. Moody 4.6.1.1, App. B, App. C.2, App. E Electronically Approved***

8. Adam P. Walker 4.6.2.1, App. H Electronically Approved***

VERIFIERS

1. William L. Moody All except below Electronically Approved***

2. Gregory A. Banyay App. K Electronically Approved***

3. Inessa E. Berman 4.6.3 Electronically Approved***

4. Dave C. DiBasilio 4.6.1.2, App. D, App. F Electronically Approved***

5. Richard J. Klimek App. L Electronically Approved***

6. Jeremy R. Koether App. M Electronically Approved***

7. Scott E. Sidener App. B Electronically Approved***

4.5.3, 4.6.1.1, 4.6.2.2, 4.6.2.3, App. C, App. E,

8. Adam P. Walker Electronically Approved***

App. I, App. J REVIEWERS

1. Gregory A. Meyer All Electronically Approved***

• • • Electronically approved records are authenticated in the electronic document management system.

W2-8.2-103.F01, Rev. 0 WGMS/W2-8.2-103.F01.dotx Effective Date: JAN-08-2016

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Comprehensive Vibration Assessment Program (CVAP) Final Report for the Sanmen 1 AP1000 Plant



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RECORD OF REVISIONS Rev. Date Revision Description

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TABLE OF CONTENTS

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 13 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 14 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 16 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 17 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

Table 1-1. Framework for AP1000 RVI CVAP Implementation of U.S. Reg. Guide 1.20 U.S. Reg. Guide 1.20, Part C.2 and C.3 CVAP Report(s)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 18 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

Table 1-1. Framework for AP1000 RVI CVAP Implementation of U.S. Reg. Guide 1.20 U.S. Reg. Guide 1.20, Part C.2 and C.3 CVAP Report(s)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 19 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

Table 1-1. Framework for AP1000 RVI CVAP Implementation of U.S. Reg. Guide 1.20 U.S. Reg. Guide 1.20, Part C.2 and C.3 CVAP Report(s)

Section Guidelines Section(s) Program Elements CVAP Final Report (this document)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 20 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

2 EXECUTIVE

SUMMARY

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2.1 MEASUREMENT AND INSPECTION RESULTS 7KH6DQPHQ+)7EHJDQLQ$XJXVWDQGZDVFRPSOHWHGLQ'HFHPEHU7HVWLQJZDVSHUIRUPHG

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7RDVVHVVZHDURUIDWLJXHRIWKHFRPSRQHQWVWKH59,ZHUHYLVXDOO\LQVSHFWHGEHIRUHDQGDIWHUWKH+)7DV

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 21 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 22 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 

Figure 2-1. AP1000 Reactor Vessel Internals 60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 23 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

3 ANALYSIS PROGRAM 3.1 OVERVIEW 7KHYLEUDWLRQDQDO\VLVSURJUDPSURYLGHVSUHGLFWHGUHVSRQVHVDQGFRUUHVSRQGLQJDFFHSWDQFHFULWHULD

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60&9$375 6HSWHPEHU

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 24 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

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3.2

SUMMARY

OF ANALYSES 7KHIROORZLQJVXEVHFWLRQVSURYLGHDQRYHUYLHZRIWKHDQDO\VLVSURJUDP

3.2.1 Structural Models 7KHG\QDPLFDQDO\VLVRIWKH59,LVSHUIRUPHGXVLQJWZRPRGHOV+/-RQHIRUWKHRYHUDOO59,DVVHPEO\DQG

RQHIRUWKH,*$DVVHPEO\7KHPDVVDQGVWLIIQHVVUHSUHVHQWDWLRQRIWKH,*$LVFRQWDLQHGLQWKHRYHUDOO

59,PRGHO7KLVDOORZVWKHRYHUDOO59,PRGHOWRFDSWXUHWKHFRUUHFWG\QDPLFUHVSRQVHRIWKHXSSHU

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60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 25 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

IOXLGFRXSOLQJDQGK\GURG\QDPLFPDVVHIIHFWV7KHPRGHOFRQILUPDWLRQLVSHUIRUPHGE\EHQFKPDUNLQJ

WKHVLJQLILFDQWPRGHVRIWKH59,FRPSRQHQWWRDYDLODEOHWHVWGDWD

7KH,*$PRGHOLVDILQLWHHOHPHQWPRGHO )(0 WKDWLQFOXGHVDOOVWUXFWXUDOFRPSRQHQWVFULWLFDOWRWKH

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RIWKH,*$7KHPRGHVRIWKHPRGHODUHEHQFKPDUNHGWRWKHUHVXOWVRIWKLVSURJUDP

3.2.2 Forced Response Analysis 7KH59,FRPSRQHQWVDUHVXEMHFWHGWRVHYHUDOFDWHJRULHVRIIORZDQGDFRXVWLFUHODWHGORDGV7KHIRUFLQJ

IXQFWLRQVFDQUHVXOWLQGLIIHUHQWUHVSRQVHVIURPWKHFRPSRQHQWV7KHIRUFLQJIXQFWLRQVJHQHUDWHORDGVRQ

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3.2.3 Predicted Responses for the CVAP Measurement Locations

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3.2.4 Measurement Acceptance Criteria 7KH$60(KLJKF\FOHIDWLJXHHYDOXDWLRQVFRQVLGHUWKHPD[LPXPVWUHVVORFDWLRQVRIWKH59,FRPSRQHQWV

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QRWH[FHHGWKHPDWHULDOHQGXUDQFHOLPLW7KHDFFHSWDQFHFULWHULDGHYHORSHGIRUWKH&9$3FRQVLVWRIOLPLWV

60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 26 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

RQWKH506DPSOLWXGHVRIWKHWHVWPHDVXUHPHQWV$WUDQVIHUIXQFWLRQLVXVHGWRUHODWHWKHPHDVXUHG506

UHVSRQVHDWHDFKVHQVRUWRWKHSUHGLFWHGVWUHVVDWWKHOLPLWLQJORFDWLRQ7KHDFFHSWDQFHFULWHULDIRUWKH

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3.2.4.1 Extrapolation

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 27 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

4 MEASUREMENT PROGRAM

4.1 INTRODUCTION

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4.2 INSTRUMENTATION 7KH&9$3LQVWUXPHQWDWLRQPRXQWHGRQWKH59,LVGHVFULEHGLQGHWDLOLQWKH9LEUDWLRQ0HDVXUHPHQW

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5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 28 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

Table 4-1. Transducer Locations for AP1000 CVAP Vibration Measurement Test Approximate Instrumented Transducer Direction of ID(6) Transducer Comments / Status Component Type Sensitivity Location(1)P a,c

     









60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 29 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

Table 4-1. Transducer Locations for AP1000 CVAP Vibration Measurement Test Approximate Instrumented Transducer Direction of ID(6) Transducer Comments / Status Component Type Sensitivity Location(1)P a,c

     



60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 30 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

Table 4-1. Transducer Locations for AP1000 CVAP Vibration Measurement Test Approximate Instrumented Transducer Direction of ID(6) Transducer Comments / Status Component Type Sensitivity Location(1)P a,c

     



60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 31 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

Table 4-1. Transducer Locations for AP1000 CVAP Vibration Measurement Test Approximate Instrumented Transducer Direction of ID(6) Transducer Comments / Status Component Type Sensitivity Location(1)P a,c

     

60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 32 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

Table 4-1. Transducer Locations for AP1000 CVAP Vibration Measurement Test Approximate Instrumented Transducer Direction of ID(6) Transducer Comments / Status Component Type Sensitivity Location(1) a,c P



 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 33 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

4.3 DATA ACQUISITION 4.3.1 Data Acquisition System 7KH&9$3GDWDDFTXLVLWLRQLVSHUIRUPHGXVLQJWKH:HVWLQJKRXVH9LEUDWLRQDQG'LDJQRVLV([SDQVLRQ

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 34 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 35 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

4.3.2 Data Acquisition Method 7KH'$4UHFRUGVHOHFWULFDOVLJQDOVIURPWKHWUDQVGXFHUVPRXQWHGRQWKH59,7KHVHUHFRUGHGWLPH

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4.3.2.1 Signal Conditioning, Calibration, and Baseline Measurements

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4.4 TEST CONDITIONS 9LEUDWLRQGDWDUHTXLUHGIRUWKH&9$3ZHUHREWDLQHGGXULQJ+)7DW6DQPHQZKLFKEHJDQLQ$XJXVW

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 36 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 37 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

Table 4-2. Baseline and Limiting Test Conditions for AP1000 CVAP (Ref. 12)

Inlet Number of Pump Best Estimate Comments/

CVAP Test Test Run Description of Test Point Coolant Operating Speed RCS Flow Rate Basis Point(1) Number(s)

Temp. (°F) Pumps (rpm) (gpm)

P a,c

       

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 38 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

Table 4-2. Baseline and Limiting Test Conditions for AP1000 CVAP (Ref. 12)

Inlet Number of Pump Best Estimate Comments/

CVAP Test Test Run Description of Test Point Coolant Operating Speed RCS Flow Rate Basis Point(1) Number(s)

Temp. (°F) Pumps (rpm) (gpm)

P a,c

       



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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 39 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

Table 4-2. Baseline and Limiting Test Conditions for AP1000 CVAP (Ref. 12)

Inlet Number of Pump Best Estimate Comments/

CVAP Test Test Run Description of Test Point Coolant Operating Speed RCS Flow Rate Basis Point(1) Number(s)

Temp. (°F) Pumps (rpm) (gpm)

P a,c





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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 40 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

4.5 DATA REDUCTION AND ANALYSIS

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() = lim (l[ , )l ] , > 0 5HI(T 

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 41 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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() =

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 42 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 43 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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4.5.2.5 Spectra Plotting 7KHHYDOXDWLRQVLQ6HFWLRQDQGWKH$SSHQGLFHVPDNHXVHRIYDULRXVW\SHVRIVSHFWUDSORWV)LJXUH

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4.5.3 Measurement Uncertainty

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 44 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

4.5.4 Measured CVAP Margin 7KHPHDVXUHG&9$3PDUJLQVDUHFDOFXODWHGE\FRPSDULQJWKHPHDVXUHG506UHVSRQVHLQFOXGLQJ

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 45 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 46 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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4.5.6 Contact at Structural Interfaces 7KHUHDUHWKUHHJXLGDQFHIHDWXUHVLQWKH59,ZKHUHVPDOOVWUXFWXUDOJDSVWKDWH[LVWGXULQJQRUPDO

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 47 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 48 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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4.6 COMPONENT MEASURED RESPONSES 7KHPHDVXUHGUHVSRQVHVDUH> 









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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 49 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 50 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 51 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 52 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 53 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 54 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 55 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 56 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 57 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 58 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 59 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 60 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 61 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 62 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 63 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 64 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 65 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 66 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 67 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 68 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 69 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 70 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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4.6.3 Instrumentation Grid Assembly (IGA) a,c

























































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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 71 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 72 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 73 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 74 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 75 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 76 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 77 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

a,c



 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 78 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 79 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 80 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 81 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 82 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 83 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 84 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

Table 4-38. Summary of RVI Measurements, Acceptance Criteria, and CVAP Margins Total RMS Total RMS CVAP RVI Gage Total RMS Location Measured + Acceptance Measured Component(1) Identifier Measured(2)

Uncertainty(2) Criterion(3) Margin(4)

P P P P a,c

 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 85 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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4.7 FORCING FUNCTIONS

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 86 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 87 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 88 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 89 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 90 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

5 INSPECTION PROGRAM

5.1 BACKGROUND

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FRUHVXSSRUWVWUXFWXUHV &66 ODWHUDOYHUWLFDODQGWRUVLRQDOUHVWUDLQWVORFNLQJDQGEROWLQJFRPSRQHQWV

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PHWKRGVDUHGHVFULEHGLQ5HIDQGSUHVHQWHGLQGHWDLOLQ5HI5HIDQG5HI$UHSUHVHQWDWLYH

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7KHUHVXOWVRIWKHSUH+)7DQGSRVW+)7LQVSHFWLRQVDWHDFKORFDWLRQDUHUHFRUGHGLQWKHIRUPRI

LQVSHFWLRQQRWHVDQGSKRWRJUDSKVDQGDUHGRFXPHQWHGLQWKHSUH+)7DQGSRVW+)7LQVSHFWLRQUHSRUWV

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x ,GHQWLILFDWLRQRIDQ\EURNHQRUORRVHSDUWVGHWHFWHGEHIRUHRUDIWHUWKH+)7

x ([DPLQDWLRQRIZHOGVXUIDFHVRQWKH&%IRUDEQRUPDOPDUNLQJVRUFUDFNV

x ([DPLQDWLRQRILQWHUIDFHVXUIDFHVVXFKDVWKHFRQWDFWVXUIDFHVRIWKHORZHUUDGLDOVXSSRUWNH\VDQG

FOHYLVLQVHUWVWKH&%DQGUHDFWRUYHVVHORXWOHWQR))OHFRQWDFWVXUIDFHVWKHDOLJQPHQWSODWHFRQWDFW

VXUIDFHVWKH&%IODQJHWRSDQGERWWRPVXUIDFHVWKHXSSHUVXSSRUWDVVHPEO\IODQJHWRSDQGERWWRP

VXUIDFHVDQGWKHKROGGRZQVSULQJLQWHUIDFHVZLWKWKH&%DQGXSSHUVXSSRUWDVVHPEO\IODQJHV

5.2 INSPECTION RESULTS 5.2.1 Pre-HFT Inspection Results 7KHSUH+)7LQVSHFWLRQVRIWKHUHDFWRUYHVVHOLQWHUQDOVZHUHSHUIRUPHGLQDFFRUGDQFHZLWKWKH,QVSHFWLRQ

3URJUDP 5HI DQGLQVSHFWLRQGUDZLQJV 5HI 7KHSUH+)7LQVSHFWLRQUHVXOWVDUHGRFXPHQWHGLQ

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 91 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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5.2.2 Post-HFT Inspection Results 7KHSRVW+)7LQVSHFWLRQVRIWKHUHDFWRUYHVVHOLQWHUQDOVZHUHSHUIRUPHGLQDFFRUGDQFHZLWKWKH

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DUHVXPPDUL]HGEHORZ

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 92 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 93 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

6

SUMMARY

OF RESULTS AND CONCLUSIONS 7KH+)7DW6DQPHQZDVFRQGXFWHGEHWZHHQ$XJXVWDQG'HFHPEHU7KLVSHULRGRI

DF RSHUDWLRQUHVXOWHGLQJUHDWHUWKDQ> @ F\FOHVRIYLEUDWLRQDWQRUPDORSHUDWLQJFRQGLWLRQVDFFXPXODWHG

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%DVHGRQHYDOXDWLRQVRIWKHSUHGLFWHGDQGPHDVXUHGUHVSRQVHVFRPSDULVRQRIPHDVXUHGUHVSRQVHVWRWKHLU

UHVSHFWLYHDFFHSWDQFHFULWHULDDQGFRPSDULVRQRIWKHSUH+)7DQGSRVW+)7LQVSHFWLRQUHVXOWVDV

VXPPDUL]HGEHORZWKLVUHSRUWGHPRQVWUDWHVWKHVWUXFWXUDOLQWHJULW\RIWKH6DQPHQ$3UHDFWRU

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6.1

SUMMARY

OF MEASUREMENT RESULTS

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@ $VGRFXPHQWHGLQ6HFWLRQDQGVXPPDUL]HGLQ7DEOHWKH59,FRPSRQHQW

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 94 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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6.2

SUMMARY

OF INSPECTION RESULTS

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ZHDURUEURNHQRUGDPDJHGSDUWV7KHLQVSHFWLRQUHVXOWVZHUHDOVRFRPSDUHGIRUFRQVLVWHQF\ZLWKWKH

PHDVXUHGYLEUDWLRQUHVXOWV a,c





























6.3 CORRELATION OF PREDICTIONS, MEASUREMENTS, AND INSPECTIONS 7KH&9$3KDVGHPRQVWUDWHGJRRGRYHUDOODJUHHPHQWEHWZHHQSUHGLFWHGDQGPHDVXUHGFRPSRQHQW

IUHTXHQFLHVWKHSUHGLFWHG506UHVSRQVHVDUHFRQVLVWHQWZLWKRUFRQVHUYDWLYHO\KLJKFRPSDUHGWRWKH

PHDVXUHGUHVSRQVHVDQGDQDO\WLFDOGDPSLQJYDOXHVXVHGLQWKHSUHGLFWLRQVDUHVLPLODURUFRQVHUYDWLYHO\

ORZFRPSDUHGWRWKHPHDVXUHGGDPSLQJYDOXHV7KHUHVXOWVRIWKHLQVSHFWLRQSURJUDPDUHFRQVLVWHQWZLWK

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 95 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 

7 REFERENCES

 8615&5HJXODWRU\*XLGH5HY³&RPSUHKHQVLYH9LEUDWLRQ$VVHVVPHQW3URJUDPIRU

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-XQH

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9LEUDWLRQ$VVHVVPHQW3URJUDP &9$3 9LEUDWLRQ$QDO\VLV3URJUDPIRUWKH$33ODQW'-XO\

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 96 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 97 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 98 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 99 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 100 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 101 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 102 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 103 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 104 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 105 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 106 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 107 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 108 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 $

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 109 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 110 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 $

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 111 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 $

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 112 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 $

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 113 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 $

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 114 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 $

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 115 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 $

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 116 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 $

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 117 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 $

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 118 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 119 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 120 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 121 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 122 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 123 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 &

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 124 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 125 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 126 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 127 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 128 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 129 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 130 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 131 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 132 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 133 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 134 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 135 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 136 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 137 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 138 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 139 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 140 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 141 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 )

a,c







































60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 142 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 )

a,c





















60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 143 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 )

a,c

































60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 144 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 )

a,c











































60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 145 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 )

a,c





60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 146 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 )

a,c 60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 147 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 )

a,c



60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 148 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 )

a,c



















60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 149 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 )

a,c































60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 150 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 )

a,c































60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 151 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 )

a,c







60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 152 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 )

a,c























60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 153 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 *

a,c

$33(1',;*

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60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 154 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 *

a,c





































60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 155 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 *

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60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 156 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 *

a,c



























60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 157 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 *

a,c





















60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 158 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 *

a,c



60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 159 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 *

a,c





































60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 160 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 *

a,c















60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 161 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 *

a,c











60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 162 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 *

a,c















60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 163 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 *

a,c































60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 164 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 *

a,c











































60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 165 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 *

a,c























60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 166 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 *

a,c































60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 167 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 *

a,c































































60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 168 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 *

a,c









60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 169 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 *

a,c























60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 170 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 *

a,c











































60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 171 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 +

a,c

$33(1',;+ a,c





































60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 172 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 +

a,c



60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 173 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 +

a,c 60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 174 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 +

a,c





























60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 175 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 +

a,c



60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 176 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 +

a,c































60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 177 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 +

a,c





































60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 178 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 +

a,c



















60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 179 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 +

a,c





  









  















60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 180 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 +

a,c



























60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 181 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 +

a,c









60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 182 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 ,

a,c

$33(1',;, a,c

























60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 183 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 ,

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60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 184 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 ,

a,c























60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 185 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 ,

a,c

















60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 186 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 ,

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60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 187 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 ,

a,c









60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 188 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 -

a,c

$33(1',;- a,c























 

60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 189 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 -

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60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 190 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 -

a,c



























60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 191 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 .

a,c

$33(1',;.

a,c















































60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 192 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 .

a,c









 

60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 193 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 .

a,c















60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 194 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 .

a,c















60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 195 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 .

a,c









60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 196 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 .

a,c











60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 197 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 .

a,c













60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 198 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 .

a,c







60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 199 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 .

a,c































60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 200 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 .

a,c





















 

60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 201 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 202 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 .

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 203 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 .

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 204 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 205 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 206 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 207 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 208 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 209 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 210 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 211 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 212 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 0

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 213 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 0

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 214 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 215 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 0

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 216 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 1

$33(1',;1 PRE-HFT AND POST-HFT INSPECTION RESULTS 7KHSUHDQGSRVW+)7LQVSHFWLRQUHVXOWVDUHVXPPDUL]HGLQ7DEOH11RWHWKDWWKHLQVSHFWLRQGUDZLQJV

5HI ZHUHXSGDWHGDIWHUWKHSUH+)7LQVSHFWLRQVWRLQFRUSRUDWHOHVVRQVOHDUQHGIURPWKRVHLQVSHFWLRQV

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ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 217 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 1

Table N-1. Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4) a,c Notes(1) Notes(2)

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HOGV

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 218 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 1

Table N-1. Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4)

Notes(1) Notes(2) a,c

 *XLGH7XEH)ODQJH%ROWVDQG/RFNLQJ'HYLFHV  

 8636NLUW/RQJLWXGLQDO:HOG ,QQHUDQG2XWHU6XUIDFH  1$ 

For the pre-HFT inspection, Location 6 duplicated the Location 10 inspections and was omitted as redundant)

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 8SSHU6XSSRUW6NLUWWR8SSHU6XSSRUW)ODQJH*LUWK:HOG  

 *XLGH7XEH:HOGV  

The upper guide tubes were not installed at core locations D-12, E-11 and F-10 during the Hot Functional Test. Special cover plates were installed at these three locations to accommodate the CVAP instrumentation.)

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 219 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 1

Table N-1. Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4)

Notes(1) Notes(2) a,c

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 220 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 1

Table N-1. Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4)

Notes(1) Notes(2) a,c

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 221 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 1

Table N-1. Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4)

Notes(1) Notes(2) a,c

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 222 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 1

Table N-1. Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4)

Notes(1) Notes(2) a,c

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 223 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 1

Table N-1. Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4)

Notes(1) Notes(2) a,c

 5HLQIRUFHPHQW3DG:HOGV  

 &RUH%DUUHO/RQJLWXGLQDO:HOGV ,QQHUDQG2XWHU  

(For the pre-HFT inspection, this location included the USP skirt longitudinal weld)

(For the post-HFT inspection, the USP skirt longitudinal weld was deleted from Location 31 and renumbered as Location 6)

 'LUHFW9HVVHO,QMHFWLRQ '9, 'HIOHFWRU6WXG/RFN%DU  

HOGV

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The radial inserts were not installed at any of the four locations during the Hot Functional Test to accommodate CVAP instrumentation fixtures. The CVAP instrumentation fixtures were replaced with the standard radial inserts after the Hot Functional Test)

 &RUH6KURXG7RS3ODWH,QVHUW/RFNLQJ'HYLFHV  

The radial inserts were not installed at any of the four locations during the Hot Functional Test)

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 224 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 1

Table N-1. Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4)

Notes(1) Notes(2) a,c

 $OLJQPHQW3ODWH6FUHZVDQG/RFNLQJ'HYLFHV  

The lock bars for the middle elevation screws at 225 and 315 degrees extend beyond the reinforcement pad surface as part of the special CVAP hardware and were replaced with the standard items after the Hot Functional Test)

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 225 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 1

Table N-1. Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4)

Notes(1) Notes(2) a,c

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6XUIDFH

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 226 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 1

Table N-1. Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4)

Notes(1) Notes(2) a,c

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9HVVHO&ORVXUH+HDG

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 227 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 1

Table N-1. Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4)

Notes(1) Notes(2) a,c

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 228 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 1

Table N-1. Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4)

Notes(1) Notes(2) a,c

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 229 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 1

Table N-1. Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4)

Notes(1) Notes(2) a,c

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• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 230 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 1

Table N-1. Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4)

Notes(1) Notes(2) a,c

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60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 231 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 1

Table N-1. Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4)

Notes(1) Notes(2) a,c

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60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 232 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

 Westinghouse Non-Proprietary Class 3 1

Table N-1. Pre- and Post-Hot Functional Test Inspections Pre-HFT Post-HFT Pre-HFT Comments and Post-HFT Comments and Location Features To Be Inspected Inspection Inspection Observations(3) Observations(4)

Notes(1) Notes(2) 1RWHV

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60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

ND-18-0826 APP-GW-GLR-182 Rev. 0 Enclosure 10 233 of 233 APP-GW-GLR-182 (Non-Proprietary) (LAR-18-019)

Westinghouse Non-Proprietary Class 3 1

Figure N-1. Selected Pre-HFT and Post-HFT Inspection Locations 60&9$375 6HSWHPEHU

5HYLVLRQ © 2018 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 6/7/2018 9:50:19 AM. (This statement was added by the PRIME system upon its validation)

Southern Nuclear Operating Company ND-18-0826 Enclosure 11 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Sanmen Nuclear Power Company Ltd. Affidavit supporting the proprietary nature of the information in enclosure 1 (LAR-18-019)

(This Enclosure consists of 3 pages, including this cover page)