ML17023A258

APR1400 Chapter 14, Verification Programs, (Section 14.2 - ITP) Phase 2 Safety Evaluation with Open Items

ML17023A258
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Site:	05200046
Issue date:	03/17/2017
From:	Roy T NRC/NRO/DNRL/LB2
To:	McCoppin M NRC/NRO/DNRL/LB2
Tarun R
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ML17058A396	List: ML17023A258 ML17058A393 ML17058A445
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Download: ML17023A258 (84)

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14-1 14 VERIFICATION PROGRAMS Chapter 14, "Verification Programs," of this safety evaluation report (SER) describes the U.S. Nuclear Regulatory Commission (NRC or Commission) staff's review of Chapter 14, "Verification Programs," of Revision 0 to the U.S. Advanced Power Reactor 1400 (APR1400) Design Control Document (DCD), submitted in December 2014. The information provided in Chapter 14 of the APR1400 DCD addresses major phases of the initial test program (ITP), including preoperational tests, initial fuel loading and initial criticality, low

-power tests, and power ascension tests.

This chapter also describes the bases, processes, and selection criteria used to develop the Tier 1 material, which are to be verified appropriately by inspection s, test s , analys es, and acceptance criteria (ITAAC)

. This chapter of the SER, with open items, provides the NRC staff's review of the ITP and the ITAAC for the APR1400 as part of the NRC design certification (DC) review being conducted by the NRC staff under Title 10 of the Code of Federal Regulations (10 CFR), Part 52, "Licenses, Certifications and Approvals for Nuclear Power Plants." The NRC staff conducted this review in accordance with the Standard Review Plan (SRP), NUREG

-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: Light Water Reactor (LWR) Edition," March 2007, Chapter 14.

Specific Information to be addressed for the Initial Plant Test Program Introduction APR1400 DCD , Section 14.1, "Specific Information to be Addressed for the Initial Plant Test Program," lists the relevant requirements of the applicable regulations and the 12 areas covered by the ITP.

There was no Combined License (COL) information required in regard to APR1400 DCD Subsection 14.1. Additionally, APR1400 DCD S ubsection 14.1.2 references the six applicable regulations.

Evaluation The NRC staff reviewed conformance of the APR1400 DCD Section 14.1 to RG 1.206, Section s C.I.14.1 and C.I.14.

2 and the introduction section of RG 1.68. RG 1.206, Section C.I.14.1 describes six regulations that address the scope of the ITP. In addition, the introduction section of RG 1.68 references GDC 1, "Quality Standards and Records," of Appendix A to 10 CFR Part 50 which requires, in part, that SSCs

[structures, systems, and components] important to safety shall be tested to quality standards commensurate with the importance of the safety functions to be performed.

These seven regulations are referenced in Section 14.2.3 of this SER.

Additionally, RG 1.206, Section C.I.14.2, identifies the 12 areas that should be covered by the ITP.

The NRC staff evaluated DCD Section 14.1, Revision 0, and determined that DCD Section 14.1 referenced the regulations identified in Section 14.2.3 of this SER and the 12 areas covered by the ITP listed in Section 14.2.2 of this SER

, as described by RG 1.206 and RG 14-2 1.68, with one exception.

Specifically, the NRC staff determined that the DC applicant did not include 10 CFR Part 50, Appendix A, GDC 1, "Quality Standards and Records," as it relate s to testing important

-to-safety SSCs that are within the scope of the Quality Assurance Program (QAP) and the ITP.

In RAI 278-8226 , NRC Question 14.02-39 (Agency-Wide Documents Access and Management System (ADAMS) Accession Number ML15303A502)

, the NRC staff requested that the DC applicant add 10 CFR Part 50, Appendix A, GDC 1 as a regulatory basis for SSCs that should be tested within the scope of the QAP and ITP.

In the response to RAI 278-8226, Question 14.02

-39 (ML16012A550), the DC applicant proposed to add a reference to 10 CFR Part 50, Appendix A, GDC 1 as it relates to important to safety SSCs in DCD Sections 14.1 and 14.2. The NRC staff determined the RAI response is acceptable because the proposed change to the DCD will include the seven regulations identified in RG 1.206 and RG 1.68; therefore RAI 278-8226, Question 14.02

-39 is resolved and this proposed change is being tracked as Confirmatory Item 14.1-1. Conclusion With the inclusion of the proposed DCD change

, the NRC staff concludes that the information provided in Section 14.1 adequately describes the specific information to be addressed for the ITP, and is thus acceptable. Inclusion of the proposed change in the DCD is being tracked by Confirmatory Item 14.1

-1 associated with RAI 278-8226, Question 14.02

-39. Initial Plant Test Program Introduction The APR1400 initial test program is intended to verify that the as

-built facility configuration and operation complies with the approved plant design and applicable regulations. The initial test program consists of preoperational and initial startup testing.

Major phases of testing include:

Preoperational Tests

- The preoperational tests are conducted following the completion of construction but before fuel loading.

Initial Fuel Loading

- Initial fuel loading starts after completion of the preoperational testing. Initial Criticality and L ow-Power Tests

- The initial criticality phase of the startup test program confirms that criticality is achieved in a safe and controlled manner.

Following initial criticality, a series of low

-power physics tests are performed to verify selected core design parameters.

Power-Ascension Tests

- A series of power ascension tests is conducted to bring the reactor to full power.

The scope of the initial test program, as well as its general plans for accomplishing the test program, is described to demonstrate that due consideration has been given to matters that normally require advance planning.

14-3 The technical aspects of the initial test program are described to show that: (1) the test program adequately verifies the functional requirements of plant SSCs; and (2) the sequence of testing is such that the safety of the plant does not depend on untested SSCs. In addition, the measures are described to ensure that: (1) The initial test program is accomplished with adequate numbers of qualified personnel; (2) adequate administrative controls will be established to govern the initial test program; (3) the test program is used, to the extent practicable, to train and familiarize the plant's operating and technical staff in the operation of the facility; and (4) the adequacy of plant operating and emergency procedures is verified, to the extent practicable, during the period of the initial test program.

The NRC staff reviewed the DC applicant's ITP in accordance with the review guidance in RG 1.206, "Combined License Applications for Nuclear Power Plants"

Section C.I.14.2, "Initial Plant Test Program," dated June 2007, NUREG

-0800, SRP Section 14.2, "Initial Plant Test Program - Design Certification and New License Applicants," dated March 2007

and RG 1.68, "Initial Test Programs for Water

-Cooled Nuclear Power Plants," Revision 4, dated June 2013.

Summary of Application for DCD Section 14

.2 The DC applicant provided specific information which addressed the ITP in 12 different subsections: (1) summary of test program and objectives; (2) organization and staffing; (3) test procedures; (4) conduct of test program; (5) review, evaluation, and approval of test results; (6) test records; (7) test program conformance with NRC Regulatory Guides (RG); (8) utilization of reactor operating and testing experience in developing the plant ITP; (9) trial use of plant operating and emergency procedures; (10) initial fuel loading and initial criticality; (11) ITP schedule and sequence; and (12) individual test descriptions.

Regulatory Basis for DCD Section 14.2 The relevant requirements of U.S. Nuclear Regulatory Commission (NRC) regulations for the initial plant test program, and the associated acceptance criteria, are specified in NUREG

-0800, Section 14.2, "Initial Plant Test Program

- Design Certification and New Licens e Applicants," and are summarized below. Review interfaces with other SRP sections can also be found in NUREG

-0800, Section 14.2.

10 CFR 30.53(c) which requires that each licensee (defined as an entity licensed to receive and possess byproduct material in this context) perform, or permit the Commission to perform, tests of radiation detection and monitoring instruments. In nuclear power plants, radiation detection and monitoring instruments are used for ambient monitoring related to worker radiation protection, effluent monitoring, automatic initiation of features to mitigate accidental releases of radioactive materials, and automatic initiation of engineered safety features to minimize the consequences of design-basis accidents. Application of 10 CFR 30.53(c) to the ITP ensures that the capabilities to perform these functions are adequately verified initially and that deficiencies are identified and corrected. This provides increased assurance of reliable radiation detection/monitoring and instrument response to any detected adverse radiological conditions.

10 CFR 50.34(b)(6)(iii) which requires plans for preoperational testing and initial operations

.

14-4 10 CFR Part 50, Appendix A, General Design Criteria (GDC) 1, "Quality Standards and Records," which require s important-to-safety SSCs be tested under the both the Quality Assurance Program (QAP) and the ITP. Appendix B to 10 CFR Part 50, Criterion XI which require s test controls for safety related SSCs under the scope of the QAP and ITP. Appendix J to 10 CFR Part 50, which require s Type A, B and C preoperational leakage rate test s of the primary containment and related systems and components that penetrate the primary containment pressure boundary as specified in Section III.A, "Leakage Testing Requirements.

" The primary reactor containment provides a barrier against the release of fission products after accidents. The extent of overall containment leakage at pressures associated with accident conditions affects the public dose and environmental damage consequences of accidents.

Application of Appendix J to the ITP ensures that the containment performs as a leakage barrier as specified in the design and as assumed/credited in safety analyses that evaluate the public dose and environmental consequences of design basis accidents.

10 CFR 52.79(a

)(28) which require s plans for preoperational testing and testing during initial operations.

10 CFR Part 52, Subpart A, Subpart B, and Subpart C which requires inspections, tests, analyses, and acceptance criteria (ITAAC). Although the ITAAC review is conducted in Section 14.2, ITP tests are often used as the basis for ITAAC, so the relationship between the ITP and the ITAAC is addressed in this section of the SER where pertinent

. Technical Evaluation for DCD Subsection s 14.2.1 through 14.2.12 DCD Section 14.2.1 , Summary of Test Program and Objectives Introduction APR1400 DCD Section 14.2.1 describes the ITP that is performed during the initial startup of the APR1400 plant and identifies general prerequisites and specific objectives for each phase. The ITP commences with the completion of construction and installation and ends with the completion of power ascension testing. The ITP consists of operational tests and initial startup tests following in four phases:

Phase I: Preoperational Testing Phase II: Fuel loading and post

-core hot functional testing Phase III: Initial criticality and low

-power physics testing Phase IV: Power ascension testing The purpose of these tests is to demonstrate that the facility operates in accordance with its design during steady-state conditions and, to the extent practicable, during anticipated transients.

14-5 Evaluation The staff reviewed conformance of the APR1400 DCD Section 14.2.1 to the guidance in NUREG-0800, Section 14.2.II.1, "Summary of Test Program and Objectives"; RG 1.206, Section C.I.14.2.1, "Summary of Test Program and Objectives"

and the general guidelines and applicable regulatory positions in RG 1.68.

RG 1.206, Section C.I.14.2.1, states in part, that, the applicant should describe "major phases of the initial test program as well as the general prerequisites and specific objectives to be achieved for each phase."

The staff confirmed that the DC applicant described the summary of the startup testing and included a description of the objectives of each of the appropriate major phases of the test program in Section 14.2.1 of the APR1400 DCD.

RG 1.68, Appendix A, "Initial Test Program", identifies the major phases of the ITP which include: (1) Preoperational Testing, (2) Initial Fuel Loading and Pre

-Criticality Testing, (3) Initial Criticality Testing, (4) Low

-Power Testing, and (5) Power

-Ascension Testing.

RG 1.206, Section C.I.14.2.1, "Summary of Test Program and Objectives," provides that the COL applicant should address major phases of the initial test program as well as the general prerequisites and specific objectives to be achieved for each phase.

The staff noted that the applicant's proposed test program provided the following phases and objectives:

Phase I - Preoperational Testing Demonstrate that structures, systems, and components (SSCs) operate in accordance with design operating modes throughout the full design operating range.

Preoperational testing provides reasonable assurance that systems and equipment perform in accordance with the safety analysis report.

Phase II - Fuel Loading and Post

-Core Hot Functional Testing Provide a systematic process for safely accomplishing and verifying the initial fuel loadings. Provide additional assurance that plant systems necessary for normal plant operation function as expected and to obtain performance data on core

-related systems and components

. Phase III

- Initial Criticality and Low

-Power Physics Testing Provide reasonable assurance that initial criticality is achieved in a safe and controlled manner. Substantiate that the Safety Analysis and Technical Specifications assumptions and limits have been met. Demonstrate that core characteristics are within the expected limits and provide data for benchmarking the design methodology used for predicting the core characteristics later in the life of the plant.

Phase IV - Power Ascension Testing Demonstrate that the facility operates in accordance with its design during ste ady-state conditions and, to the extent practicable, during anticipated transients.

14-6 The staff finds that the applicant's has adequately identified and described the major phases of the ITP because (1) the applicant included the major phases identified in RG 1.68, and (2) the applicant adequately described the general prerequisites and specific objectives to be achieved for each phase, consistent with RG 1.206. Conclusion The NRC staff concludes that the information provided in the APR100 DCD Section 14.2.1 adequately describes the activities related to the phases of the initial test program: (1) preoperational testing; (2) fuel loading and post

-core hot functional testing; (3) initial criticality and low power physics testing; and (4) power ascension testing, and is therefore acceptable. All issues relating to this section of the initial test program have been resolved.

DCD Section 14.2.2, Organization and Staffing Introduction In APR1400 DCD , Section 14.2.2 , "Organization and Staffing," the DC applicant stated that the staff responsibilities, authorities and personnel qualifications for performing the APR1400 ITP are the responsibility of the combined license (COL) applicant.

Evaluation The NRC staff reviewed conformance of APR1400 DCD Section 14.2.2 to the guidance in RG 1.206, Section C.I.14.2.2, "Organization and Staffing"; SRP 14.2,Section II, "SRP Acceptance Criteria" Section 3.A A, "Management Organizations," and Section 3.D, "Staff Responsibilities, Authorities and Qualifications"; and RG 1.68, Staff Regulatory Guidance Section C.6, "Participation of Plant Operating and Technical Staff."

In APR1400 DCD, Section 14.2.2, the DC applicant stated that the site

-specific organization, the participation of staff in the test program, and the training program are all the responsibility of the COL applicant. The staff finds that because staffing will be determined by the COL applicant and is, thus, outside the scope of design certification, it is acceptable to defer responsibility for the site

-specific organization to the COL applicant. The NRC staff determined that a number of COL Information items were not sufficient to meet RG 1.206. NRC Question 14.02

-04 of RAI 91

-7867 requested changes to COL Information Items 14.2(1), 14.2(2), 14.2(3), 14.2(4), and 14.2(6), the creation of a new 14.2(7), renumbering of existing 14.2(7) through 14.2(11) to 14.2(8) through 14.2(12), and the creation of a new 14.2(1 3). The NRC staff reviews of the DC applicant responses are provided below and in Section 14.2.5, "COL Information

," of this SER.

COL Information Item 14.2(1) is pertinent to the review of DCD Section 14.2.2 and is discussed in the following paragraph.

In NRC RAI 91-7867 , Question 14.02

-04 (ADAMS accession no. ML15201A768), the NRC staff requested the DC applicant to revise COL Information item 14.2(1) in DCD Section 14.2.13, "Combine License Information,"

to include specific direction for the COL applicant's plant operating and plant technical staff to participate, to the extent practical, in developing and conducting the ITP and evaluating the test results.

In the DC applicant response to RAI 91-7867, Question 14.02

-04 (ML16182A597), the DC applicant proposed to add the information requested by the staff to COL Informati on Item 14.2(1) in DCD Section 14.2.13. The staff finds that this response meets RG 1.68 and it is 14-7 acceptable

. The proposed addition to COL item 14.2(1) is being tracked as part of Confirmatory Item 14.2.13

-1. Conclusion With the inclusion of the proposed DCD change , the NRC staff concludes that the information provided in the APR1400 DCD Section 14.2.2 adequately describes the activities related to the organization and staffing for the initial test program, and is thus acceptable. Inclusion of the proposed change in the DCD is being tracked by Confirmatory Item 14.2.13

-1 associated with RAI 91-7867. The staff also concludes that because staffing will be determined by the COL applicant and is, thus, outside the scope of design certification, it is acceptable to defer responsibility for the site

-specific organization to the COL applicant. This is identified as COL Information Item 14.2(1). DCD Section 14.2.3, Test P rocedures Introduction In APR1400 DCD Section 14.2.3, "Test Procedures," the DC applicant provided guidelines for the development of test procedures, including format requirements, adherence to applicable RGs, and provisions for review and approval by responsible personnel.

In general, testing during all phases of the initial test program is conducted using detailed, step

-by-step written procedures to control the conduct of each test.

Such test procedures specify testing prerequisites, describe desired initial conditions, include appropriate methods to direct and control test performance (including the sequencing of testing), and specify acceptance criteria by which the test is to be evaluated, and provide for or specify the format by which data or observations are to be recorded.

Evaluation The NRC staff reviewed the conformance of APR1400 DCD Section 14.2.3 with the guidance in RG 1.68, Staff Regulatory Guidance Section C.4, "Procedures," and SRP Section 14.2. The NRC staff notes that the DC applicant followed the guidance of the SRP and provided the controls to develop test procedures.

The DC applicant provided for detailed procedure guidelines and procedures used to develop the test procedures, a minimum set of topic areas to be included in each procedure, and the reference materials to be used in the preparation of each test procedure.

The APR1400 DCD, Section 14.2.3 indicates that a COL applicant is responsible for providing site-specific controls for the review and approval of test procedures for preoperational and startup tests.

Additionally, the applicant stated that the submittal by the COL applicant of applicable procedures and guidelines to the staff for review will be conducted as described in APR1400 DCD, Section 14.2.11, "Test Program Schedule." The APR1400 DCD Section 14.2.3, states, in part that "the plant operator provides reasonable assurance for preparation and designates the approval process for Phases I through IV test procedures

-[T]est procedures are based on the requirements of system designers and applicable NRC Regulatory Guides (RGs)." The staff finds that because site specific controls for the review and approval of test procedures will be determined by the COL applicant and is, thus, outside the scope of design certification, it is acceptable to defer responsibility for the control of site

-specific ITP test procedures to the COL applicant.

The DCD discussion is also acceptable 14-8 because it references the need to account for system design and directs the applicant to use NRC guidance.

However, upon review of APR1400 DCD, Section 14.2.3, the NRC staff identified the following area where additional information is needed. A description of the specific issue identified by the NRC staff is as follows:

In NRC Question 14.02

-04 in RAI 91-7867 , the NRC staff noted that the COL applicant is to prepare the site

-specific initial test procedures and/or guidelines that are used for the conduct of the ITP. These procedures are to be submitted at least 60 days prior to their intended use to the NRC staff for review as described in Subsection 14.2.11.

In order to conform with RG 1.206, Section C.I.14.2.3 guidance, the NRC staff suggested that COL Information Item 14.2(2) in DCD Section 14.2.13 should be revised "to include site specific preoperational and startup test specifications and test procedures that are used to conduct the plant I TP. The preoperational and startup test procedures should have controls in place to ensure that test procedures include appropriate prerequisites, objectives, safety precautions, initial test conditions, methods to direct and control test performance and test acceptance criteria by which the test is evaluated. Testing performed at other than design operating conditions for systems is to be reconciled either through the test acceptance criteria or post-test data analysis." In its response to RAI 91-7867, Question 14.02

-04 (ML16182A597) the applicant committed to update COL Information item 14.2(2) as noted above in DCD Section 14.2.13. The NRC staff determined that this change meets RG 1.206, Section C.I.14.2.3 and it is acceptable

. Therefore, this part of RAI 91-7867, Question 14.02

-04 is resolved and this proposed change is being tracked as part of Confirmatory Item 14.2.13

-1. The NRC staff also reviewed APR1400 DCD Section 14.2.3 related to the COL applicant

's preparation of the startup administrative manual (SAM) and preoperational and startup test summaries that contain testing objectives and acceptance criteria applicable for its scope of the plant design.

In its review of DCD Section 1 4.2.3 and 14.2.13, the NRC staff determined that COL Information item 14.2(3) was not in accordance with RG 1.68 and SRP Section 14.2 and should be revised. In NRC RAI 91

-7867, Question 14.02

-0 4, the NRC staff requested the DC applicant add administrative control information that governs the ITP to COL Information Item 14.2(3) in DCD Section 14.2.13. Specifically, Question 14.02

-04 suggested , "the COL applicant is to prepare a SAM which contains the administrative controls that govern the conduct of each major phase of the ITP. This description should include the administrative controls used to ensure that necessary prerequisites are satisfied for each major phase and for individual tests. The COL applicant should also describe the methods to be followed in initiating plant modifications or maintenance tasks that are deemed to be necessary to conduct the ITP. This description should include methods used to ensure retesting following such modifications or maintenance.

In addition, the description should discuss the involvement of design organizations with the COL applicant in reviewing and approving proposed plant modifications.

The COL applicant should also describe in the SAM adherence to approved test procedures during the conduct of the ITP as well as the methods for effecting changes to approved test procedures.

"

14-9 In its response to RAI 91-7867, Question 14.02

-04 (ML16182A597) the applicant committed to adding administrative controls which govern the ITP

, to COL Information Item 14.2(3) in DCD Section 14.2.13. The NRC staff determined that th is change to the DCD satisfies the RG 1.68 guidance to include provisions for the application of administrative controls that govern the conduct of the test program (e.g., test program objectives, organizational elements, personnel qualifications, evaluation and approval of test results, and test records retention)

, and thus RAI 91-7867, Question 14.02

-04 is resolved. The proposed additions to COL Information Item 14.2(3) are being track ed as a part of Confirmatory Item 14.2.13

-1. In the NRC staff review of DCD Section 14.2.3 and 14.2.13, the NRC staff determined that the DC applicant did not meet the guidance of RG 1.68, Sections A

, B, and C. Specifically, the NRC staff concluded that the DC applicant should reference an ITP administrative manual or SAM in APR1400 DCD Section 14.2.3 and place the ITP administrative manual on the docket which covers the DC applicant's responsibilities for ITP administrative controls that govern the development and conduct of the APR1400 Design Certification ITP. The COL applicant will then complete the SAM for the COL applicant's portion of responsibilities for conducting and implementing the APR1400 ITP.

In NRC RAI 9 1-7867, Question 14.02

-08 (ML16182A597), the NRC staff requested that the DC applicant place the SAM on the docket.

The NRC staff also requested as part of Question 14.02-04 that the DC applicant add a reference to the SAM in COL Information Item 14.2(3) that will request the COL applicant to complete the SAM for the COL applicant's portion of responsibilities for conducting and implementing the APR1400 ITP.

In its response to RAI 91-7867, Question 14.02-08 (ML16182A597), the DC applicant responded with some ITP administrative controls found in the DC applicant's SAM; however; the NRC staff determined that this response was not acceptable since it did not meet SRP Section 14.2. In follow up NRC RAI 513-8663, Question 14.02

-67 (ML16221A563), the staff requested the DC applicant to address bullet items A through D identified in NUREG

-0800, SRP Section 14.2, related to DC applicant administrative control responsibilities for completing the SAM. Based on this guidance in SRP Section 14.2, the staff asked the DC applicant to provide more information in the SAM to cover Items A through D including administrative controls for the list of test abstracts in DCD Section 14.2. The staff also asked the DC applicant to add the list of test abstracts in DCD Section 14.2 to the SAM which is being tracked as Open Item 14.2.3

-1 associated with RAI 513-8663. Conclusion Because of Open Item 14.2.3

-1, the staff is unable to finalize its conclusions for SER Section 14.2.4.3.

14-10 DCD Section 14.2.

4 , Conduct of Test P r ogram Introduction In APR1400 DCD, Section 14.2.4, "Conduct of Test Program," the DC applicant stated that the COL applicant is responsible for planning and conducting the plant startup test program. The applicant also provided the format of the administrative procedures that will be used to conduct the initial test program. This section describes the administrative controls that govern the conduct of the test program. This description includes the administrative controls used to ensure that necessary prerequisites are satisfied for each major phase and for individual tests.

The administrative controls pertaining to adherence to approved test procedures during the conduct of the test program, as well as the methods for effecting changes to approved test procedures, are described.

Evaluation The NRC staff reviewed conformance of APR1400 DCD Section 14.2.4 to guidance in RG 1.206, Section C.I.14.2.4, "Conduct of Test Program"

SRP Section 14.2, "SRP Acceptance Criteria," Section 3, "Administrative Procedures," COL/OL Applicants, Subsection B, "Conduct of the Initial Test Program"

and RG 1.68, Staff Regulatory Guidance Position C.2, "Prerequisites for Testing."

The NRC staff finds that the DC applicant followed the guidance of the SRP, RG 1.206, and RG 1.68 in that APR1400 DCD Section 14.2.4 states that the COL applicant is responsible for the planning and the conduct of the initial test programs. Also, the DC applicant stated that the startup test group will conduct the initial test program in accordance with administrative procedures and requirements. In addition, the DC applicant included specific direction that the COL applicant's procedures will (1) define the format and content of startup test procedures, and (2) define the review and approval process for both initial procedures and subsequent revisions or changes, consistent with Section C.I.14.2.4 of RG 1.206.

However, upon review of APR1400 DCD, Section 14.2.4

, the NRC staff identified an area where additional information is needed. As described in Section 14.2.

4 above, RAI 91-7867, Question 14.02

-08 was issued to address the DC applicant's ITP administrative manual or SAM to address the DC applicant's responsibilities for ITP administrative controls

. In the June 30, 2016, response to RAI 91-7867, Question 14.02

-08 (ML16182A597), the DC applicant stated the objectives of the ITP in the DC application are to provide adequate test plans for the development and safe execution of the ITPs by the COL applicants, as noted in COL item 14.2(3). In addition, the DC applicant provided an initial copy of the general requirements of the SAM.

The NRC staff reviewed the initial copy of the SAM and determined that it provides the framework for the COL applicant s to develop their own SAM to conduct the ITP. No change to the DCD is required. Based on the above, RAI 91-7867, Question 14.02

-08 is resolved and closed.

Conclusion The NRC staff determined that DCD Section 14.2.4 describes the activities related to review, evaluation, and approval of test results for the initial test program, and is thus acceptable.

14-11 The staff also concludes that, because the conduct of the test program will be completed by the COL applicant, it is acceptable to defer responsibility for the development of detailed administrative procedures to the COL applicant

. DCD Section 14.2.5, Review, Evaluation

, and Approval of Test Results Introduction In APR1400 DCD Section 14.2.5, "Review, Evaluation, and Approval of Test Results,"

the DC applicant stated that the COL applicant is responsible for the site

-specific administrati ve procedures for review and approval of test results.

This section describes the specific controls to be established for the review, evaluation, and approval of test results for each major phase of the program by appropriate personnel and/or organizations. This description includes specific controls to be established to ensure notification of affected and responsible organizations or personnel when test acceptance criteria are not met, as well as the controls established for corrective actions and retests, as required.

Evaluation The NRC staff reviewed conformance of APR1400 DCD, Section 14.2.5 to the guidance in RG 1.206, Section C.I.14.2.5, "Review, Evaluation and Approval of Test Results"

SRP Section 14.2, "SRP Acceptance Criteria," Section 3, "Initial Test Program Administrative Procedures," COL/OL Applicants, Subsection F, "Review, Evaluation and Approval of Test Results"; and RG 1.68, Staff Regulatory Guidance Section C.9, "Test Reports,"

The staff finds that the DC applicant followed the guidance of the SRP, RG 1.206, and RG 1.68 in that APR1400 DCD Section 14.2.5 states that

The COL applicant is to review and evaluate individual test results. Individual test results are reviewed and approved as provided in the site

-specific administrative procedures

. Completed procedures and test reports are reviewed for acceptance. The specific acceptance criteria for determining the success or failure of the test are included as part of the procedure and are used during the review. Test deficiencies or results that do not meet acceptance criteria are identified to the affected and responsible design organizations, and corrective actions and retests, as required, are performed.

The COL applicant's responsibility to review and evaluate individual test results is captured in COL item 14.2(4) in DCD Section 14.2.13.

The staff finds that APR1400 DCD, Section 14.2.5 included specific direction for the COL applicant to review, evaluate, and approve test records in accordance with RG 1.206, Section C.I.14.2.5.

Conclusion The NRC staff concludes that the information provided in APR1400 DCD, Section 14.2.5 adequately describes the activities related to review, evaluation, and approval of test results for the initial test program, and is thus acceptable

. The NRC staff finds that all issues relating to this section of the initial test program have been resolved.

14-12 Also, the NRC staff concludes that, because review and approval of the test results will be completed by the COL applicant, it is acceptable to defer responsibility for the development of detailed administrative procedures for the review and approval of test results to the COL applicant.

DCD Section 14.2.6, Test Records Introduction In APR1400 DCD, Section 14.2.6, "Test Records,"

the DC applicant provided a description of the controls that will be implemented to maintain initial test program records.

Evaluation The NR C staff reviewed conformance of APR1400 DCD, Section 14.2.6 to the guidance in RG 1.68, Regulatory Guidance Section C.9, "Test Reports."

APR1400 DCD, Section 14.2.6 states that the official copy of each test procedure and the information specifically called for in the test procedure shall be retained for the life for the plant by the COL applicant consistent with the guidance of RG 1.28. However, RG 1.28 only covers preoperational tests under the ITP , not startup tests. Regulatory guidance for preoperational and startup testing procedures is provided in RG 1.68, Staff Regulatory Guidance Section C.9, "Test Reports."

In the review of DCD Section 14.2.6, the NRC staff determined that DCD Section14.2.6 should be revise d. In NRC RAI 91-7867 , Question 14.02

-05 (ML15201A768

), the NRC staff requested the DC applicant revise DCD Section 14.2.6 to address retention of startup testing procedures and startup test results as part of the plant's historical records in accordance with RG 1.68. In the June 30, 2016, response to RAI 91-7867, Question 14.02

-5 (ML16182A597), the DC applicant proposed to revise DCD Section 14.2.6 to state that the preoperational and startup test procedures and test results are to be retained for the life of the plant by the COL applicant (COL item 14.2(12

)). The NRC staff determined that this change to the DCD Section 14.2.6 meets RG 1.68 , Regulatory Guidance Section C.9, "Test Reports," because it describes retention of startup test procedur es and startup test report results; therefore, it is acceptable.

RAI 91-7867, Question 14.02-5 is resolved and t he proposed change to DCD Section 14.2.6 is being tracked as Confirmatory Item 14.2.6

-1. Conclusion With the inclusion of the proposed DCD change s , the NRC staff concludes that the information provided in APR14000 DCD, Section 14.2.6 adequately describes protocols pertaining to the disposition of test procedures and test data following completion of the test program, and is thus acceptable. Inclusion of the proposed change s in the DCD is being tracked by Confirmatory Item 14.2.6

-1 associated with RAI 91-7867, Question 14.02

-5.

14-13 DCD Section 14.2.7, Conformance of Test Programs with NRC Regulatory Guides Introduction In APR1400 DCD, Section 14.2.7, "Conformance of Test Programs with Regulatory Guides," the DC applicant references DCD Subsection 1.9.1 and Table 1.9

-1 which provide a list of specific RGs related to testing and testing programs. This section also references Table 14.2

-7 , "Conformance Matrix of RG 1.68 Appendix A versus Individual Test Descriptions," which cross-references the matrix of the applicable guidance in NRC RG 1.68 (Reference 3) Appendix A (Initial Test Program) to the test descriptions listed in DCD Subsection 14.2.12 to demonstrate compliance with RG 1.68. Evaluation The NRC staff reviewed conformance of APR1400 DCD, Section 14.2.7 to the guidance in SRP Section 14.2.II.2, "Test Program's Conformance with Regulatory Guides,"

RG 1.20, Regulatory Position C.1.4, "Non

-Prototype Category I plants"

and the general guidelines and applicable regulatory positions in RG 1.68.

SRP Section 14.2 states, in part, that the applicant should establish and describe an initial test program that is consistent with the regulatory positions outlined in RG 1.68. SRP Section 14.2 also includes a list of RGs that provide more detailed information pertaining to the testing. RG 1.68, Appendix A, "Initial Test Program," references a set of supplemental regulatory guides that provide guidance for particular tests during the preoperational and initial startup phases. The supplemental RGs contain additional information to help determine if performance of the tests in the proposed manner will likely accomplish the objectives of certain plant tests.

In APR14000 DCD, Section 14.2.7, the DC applicant referenced Table 1.9

-1, which lists RGs utilized for the development of the APR1400 initial test program. In addition, Table 14.2-7 lists the system test descriptions that conform with RG 1.68, Appendix A. The NRC staff reviewed the tables mentioned above to ensure that the applicable RGs were included in the development of the initial test program.

For those instances in which the applicant determined that RGs were not applicable to the APR1400 design or where exception to RGs were proposed, the NRC staff reviewed the DC applicant's justification for the exception to ensure that the test program scope remained sufficient.

DCD Subsections 14.2.7.1.1 through 14.2.7.1.13 provide s exceptions and/or clarifications between the proposed initial test program, as described in 14.2.12, to the regulatory positions in RG 1.68.

In most cases, the exceptions provide bases as to why the APR1400 will not be tested as described in RG 1.68 due to differences in the design. The NRC staff reviewed DCD Subsections 14.2.7.1.1 through 14.2.7.1.13 and concluded that the proposed exceptions and/or clarifications were acceptable because the principal design criteria established in Appendix A to 10 CFR Part 50 are met, except as described below.

Upon review of APR1400 DCD, Section 14.2.7, the NRC staff identified the following areas where additional information was needed

. The NRC staff determined that in Table 14.2-7 which provides the matrix of applicable guidance of NRC RG 1.68 Appendix A (Initial Test program) versus individual test descriptions listed in DCD Subsection 14.2.12, the DC applicant does not reference APR1400 Subsections 14-14 14.2.12.1.2, Reactor Coolant System Test," and 14.2.12.1.37, "Safety Depressurization and Vent System Test." Therefore, testing of the reactor coolant gas vent system using vent valves for a number of major RCS components (e.g., reactor vessel upper head vent valves, pressurizer vent valves, etc.) in the RCS is not referenced to the appropriate testing in RG 1.68. In NRC RAI 91

-7867, Question 14.02

-2 (ML15201A768), the following changes were requested:

1. The DC applicant should add DCD subsections 14.2.12.1.2 and 14.2.12.1.37 as noted below to this part of Table 14.2

-7 (noted in italics).

RG 1.68, APP A Subsection #

Individual Test 1.a.2.h 14.2.12.1.2 14.2.12.1.37 14.2.12.1.41 14.2.12.1.42 14.2.12.1.43 Reactor coolant system test Safety depressurization and vent system test Internals vibration monitoring system test Loose parts monitoring system test Acoustic monitoring system test

2. The DC applicant should verify if other APR1400 test abstract subsections are correctly referenced in Table 14.2

-7 for conformance with RG 1.68, Appendix A.

In the December 9, 2015, response to RAI 91-7867, Question 14.02

-2 (ML15343A502), the DC applicant revised Table 14.2

-7 to add references to DCD Subsections 14.2.12.1.2 and 14.2.12.1.37 and verified that no other test abstract subsections were missing. The NRC staff determined that this response adequately addressed the staff's requested revisions to meet RG 1.68, Appendix A, related to the list of tests and is acceptable. Therefore, the staff considers RAI 91-7867, Question 14.02

-2 resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.7

-3. In DCD S ubsection 14.2.7.1.13, "Reference Section C, Regulatory Position 4," which discussed exceptions to RG 1.68, Regulatory Position C.4

, the DC applicant states: This section requires inclusion of acceptance criteria that account for uncertainties. The test summaries in Subsection 14.2.12.2.1, "Post

-Core Hot Functional Test Controlling Document," and 14.2.12.1.46, "Pre

-Core Hot Functional Test Controlling Document" are essential to the demonstration of conformance to the requirement of structures, components and features important to safety.

In its review the NRC staff determined that the DC applicant should provide additional information on what uncertainties, if any, should be included in the test acceptance criteria related to DCD Subsections 14.2.12.1.46, "Pre

-Core Hot Functional Test Controlling Document," and 14.2.12.2.1, "Post Core Hot Functional Test Controlling Document." The DC applicant also needed to describe the differences the DC applicant is taking in these test abstracts from the guidance in RG 1.68, Regulatory Position C.4. The staff requested this information in NRC RAI 91

-7867, Question 14.02

-06 (ML15201A768)

, In the December 9, 2015, response to RAI 91-7867, Question 14.02

-06 (ML15343A502

), the DC applicant provided the following response

14-15 Uncertainties include the design value that should be met to satisfy the safety analysis assumption and to maintain the safety related function(s). These values will be included in each specific test procedure acceptance criteria, such as the design flowrate of the pump, response time of the valve, actuation set

-point of the control system, etc. However, the exact value to be used in the procedure will be provided by the COL applicant. Test plans for 14.2.12.1.46, "Pre-Core Hot Functional Test Controlling Document," and 14.2.12.2.1, "Post

-Core Hot Functional Test Controlling Document," are the controlling documents for all the pre

-core and post

-core evolutions and plans. Therefore, these two test "procedures" [abstracts] do not include the design related uncertainties.

The NRC staff determined that the DC applicant's response is acceptable because uncertainties should only be found in the COL's site specific test procedures and test plans and should not be found in individual DCD Section 14.2 test abstracts. Based on the above, RAI 91-7867, Question 14.2.6 is resolved and closed.

No additional information is needed in DCD Section 14.2.7. In NRC RAI 91

-7867, Question 14.02

-09 (ML15201A768) and RAI 187

-8101, Question 14.02-10 (ML15292A501), the NRC staff requested the DC applicant add some ITP tests needed to comply with RG 1.20.

Specifically, the DC applicant needed to revise DCD Table 1.9.1, "APR1400 Conformance with NRC Regulatory Guides," to include individual ITP tests that meet RG 1.20. For a non-prototype plant like the APR1400, the DC applicant should consider adding two tests which include the Internals Vibration Monitoring System Test in DCD Section 14.2.12.1.41 and the NSSS Integrity Monitoring System Test in DCD Section 14.2.12.4.18.

In the August 28, 2015, response to RAI 91-7867, Question 14.02

-09 (ML15240A044) and in the May 19, 2016, response to RAI 187-8101, Question 14.02-10 (ML16142A015), the DC applicant stated that the comprehensive vibration assessment program (CVAP) is used to verify the structural integrity of the reactor internals for flow

-induced vibration prior to commercial operation. Since an analysis program and an inspection program are being implemented for the APR1400 and the results are being assessed in those programs, implementation of a vibration measurement program is not necessary in accordance with RG 1.20. The DC applicant stated that the reactor internal vibration test is excluded from CVAP because the APR1400 is classified as a non

-prototype category I plant in accordance with the guidance provided in RG 1.20. This is also stated in DCD Subsection 14.2.7.1.6.

The DC applicant also noted that the Nuclear Instrument Monitoring System (NIMS) (which includes the Internal Vibration Monitoring System (IVMS), Loose Parts Monitoring System (LPMS), and the Acoustic Leak Monitoring System (ALMS)

) is used to verify the proper operation of vibration monitoring of these systems and that test results are used to establish alarm set

-points and to evaluate the adequacy of system design parameters. Also, most of NIMS is a non-safety test (e.g., except for LPMS, which is designed to meet RG 1.33). The DC applicant also noted that none of the preoperational test and startup tests are needed for the DC applicant's commitments to vibration monitoring in RG 1.20. Therefore, since the system tests for IVMS, LPMS, and ALMS are not related to RG 1.20 testing, it is not necessary to include reference to DCD S ubsections 14.2.12.1.41, 14.2.12.1.42, 14.2.12.1.43 or 14.2.12.4.18 in Table 1.9.1 for RG 1.20 applicability.

14-16 The NRC staff reviewed the DC applicant's response to RAI 91-7867, Question 14.02

-09 and RAI 187-8101, Question 14.02

-10. The NRC staff determined that DCD Section 14.2.12.1.41, "Intervals Vibration Monitoring System Test," and DCD Section 14.2.12.4.18, "Baseline Nuclear Steam Supply System Integrity Test," test procedures will include inspections and some IVMS test monitoring activities for non

-prototype reactors such as the APR1400 which meets the intent of the guidance in RG 1.20, Regulatory Position C.1.4, Non-Prototype, Category I. However, the NRC staff determined that KHNP should again consider adding DCD Sections 14.2.12.1.41 and 14.2.12.4.18 to DCD Table 1.9.1 since both these tests reference IVMS Testing to meet inspections and test activities that apply to RG 1.20, Regulatory Position C.1.4, Non-Prototype Category I plants. This is Open Item 14.2.7

-1. Conclusion Because of Open Item 14.2.7

-1, the staff is unable to finalize its conclusions for SER Section 14.2.4.7. DCD Section 14.2.8, Use of Reactor Operating and Test Experience in the Development of the Initial Test Program Introduction In APR1400 DCD, Section 14.2.8, "Use of Reactor Operating and Testing Experience in the Development of Initial Test Program," the DC applicant discusses the COL applicant's ability to use relevant operating and testing experiences gained from previous successful startups

. This section states that the COL applicant is to describe its program for reviewing available information on reactor operating and testing experiences and discusses how it used this information in developing the initial test program.

Evaluation The NRC staff reviewed conformance of FSAR Tier 2, Section 14.2.8 to the guidance in NUREG-0800, Section 14.2.II.3.G, "Utilization of Reactor Operating and Testing Experiences in Development of Test Program," and the general guidelines and applicable regulatory positions in RG 1.68 and RG 1.20.

In APR1400 DCD Section 14.2.8, the DC applicant noted that a COL applicant would have the benefit of experience acquired with the successful and safe startup of the reference plant, Shin

-Kori Nuclear Unit 3 (SKN #3) APR1400 PWR plant. The reactor operating and testing experience gained from the reference plant and other reactor types is factored into the design and test system information for plant equipment and systems that are demonstrated during the preoperational and startup test programs.

Upon review of APR1400 DCD, Section 14.2.8, the staff identified the following areas where additional information is needed.

A description of the specific issues identified by the staff is as follows: In DCD Section 14.2.8.1, First

-of-a-kind (FOAK) Tests, the DC applicant stated that

14-17 FOAK tests are new, unique, or special tests for new design features in plants.

The functional testing requirements necessary to verify FOAK test performance should be identified if these design features are used in the APR1400 in the United States. These tests are performed only for the first plant. The APR1400 is not a first

-of-a-kind plant since it is preceded by SKN3&4 in Korea, which will begin commercial operation in late December 2016 and 2017. Therefore, FOAK testing and operational data will be available prior to the first APR1400 in the United States.

The NRC staff determined that the first APR1400 plant built in the USA will not be a prototype plant with FOAK tests per the regulations in 10 CFR 50.2, "Prototype Plant," and 10 CFR 50.43(e). However, the NRC staff does not accept the DC applicant's position that the first APR1400 plant built in South Korea is a FOAK plant.

As such, the DC applicant cannot take credit for prototype plant test that occurred at SKN3&4 in South Korea.

In NRC RAI 91

-7867, Question 14.02

-07 (ML15201A768), the NRC staff requested that the DC applicant revise DCD Section 14.2.8.1 to be consistent with 10 CFR 50.2, 10 CFR 50.43(e), Revision 4 to RG 1.68, Regulatory Guidance C.7, "Trial Testing of Plant Emergency, Operating and Surveillance Test Procedures,"

RG 1.68, Appendix A, Section A

-6, "First-of-a-Kind (FOAK) Testing," and Section A

-7, "Design Qualification Tests for Advanced Reactors."

I n the June 30, 2016, response to RAI 91-7867, Question 14.02

-07 (ML16182A597), the DC applicant proposed to revise DCD S ubsection 14.2.8.1 by deleting the reference s to SKN 3&4 being a prototype plant and to refer to Palo Verde Nuclear Generation Station (PVNGS) Unit 1, as the prototype plant of the APR1400 for the vibration monitoring system and the natural circulation test. The NRC staff has reviewed the proposed DCD revision and determined that it is acceptable because PVNG S Unit 1 and the APR1400 design both have the same number of fuel assemblies, enrichment and almost the exact same core thermal power (APR1400 thermal power = 3983 Mwt, PVN G S Unit 1 core thermal power = 3990 Mwt). In accordance with RG 1.20, the first APR1400 built in the USA will be a non

-prototype Category I plant. The APR1400 does not have any FOAK tests. The NRC staff determined that the DC applicant's s response and the proposed update to DCD Section 14.2.8.1 meets the guidance in RG 1.20 and RG 1.68 for non-prototype plants and it is acceptable; therefore, RAI 91-7867, Question 14.02-07 is resolved and this change is being tracked as Confirmatory Item 14.2.8.1

-1. Conclusion With the inclusion of the proposed DCD changes , the staff finds that the information provided in APR1400 DCD, Section 14.2.8 adequately describes the activities related to the review of relevant operating and testing experiences gained from previous successful startups, and is therefore acceptable. Inclusion of the proposed changes in the DCD is being tracked by Confirmatory Item 14.2.8.1

-1 associated with RAI 91-7867, Question 14.02

-07. DCD Section 14.2.9, Trial Use of Plant Operating and Emergency Procedures Introduction In APR1400 DCD, Section 14.2.9, "Trial Use of Plant Operating and Emergency Procedures,"

the DC applicant described the COL applicant responsibilities related to development of plant procedures, as well as a description of how, and to what extent, the plant operating, 14-18 emergency, and surveillance procedures are use

-tested during the initial test program. The DC applicant also identified COL Information Item 14.2(8) in DCD Sections 14.2.9 and 14.2.

13. For more details on the COL Information Item 14.2(8), see DCD Section 14.2.13, "Combine License Information," and SER Section 14.2.5, "COL Information Items."

Evaluation The staff reviewed conformance of APR1400 DCD, Section 14.2.9 to the guidance in SRP , Section 14.2.II.3.H, "Trial Use of Plant Operating and Emergency Procedures," and RG 1.68, Regulatory Guidance Section C.7, "Trial Testing of Plant Emergency, Operating and Surveillance Test Procedures."

SRP Section 14.2 indicates that the applicant should incorporate, to the extent practicable, plant operating, emergency, and surveillance procedures into the test program, or otherwise verify these procedures through use during the test program. APR1400 DCD Section 14.2.9 indicates that the COL applicant is to provide a schedule for the development of plant procedures, as well as a description of how, and to what extent, the plant operating, emergency, and surveillance procedures are use

-tested during the initial test program.

Additionall y SRP Section 14.2 indicates the applicant should provide additional operator training and participation based on the performance and evaluation of the test results of certain initial tests, and that an acceptable program will satisfy the criteria described in Three Mile Island (TMI) Action Plan Item I.G.1 of NUREG

-0660 and NUREG

-0737. The NRC staff notes that APR1400 DCD Section 14.2.9 states that the COL applicants are to identify the operator training to be conducted as part of the low

-power testing program related to the resolution of TMI Action Plan Item I.G.1, as described in (1) NUREG

-0660 - NRC Action Plans Developed as a Result of the TMI

-2 Accident, Revision 1, August 1980 and (2) NUREG

-0737 - Clarification of TMI Action Plan Requirements.

The NRC staff finds that it is acceptable to defer the review of the trial use of operating and emergency procedures to the COL phase, because the development of operating and emergency procedures will depend upon detailed plant

-specific design information. The NRC staff also finds that the information provided in APR1400 DCD, Section 14.2.9 adequately describes that the schedule for the development of the plant operating and emergency procedures will allow sufficient time for trial use of these procedures during the initial test program as appropriate and to the extent possible, and is thus acceptable.

Conclusion The staff concludes that the information provided in APR1400 DCD, Section 14.2.9 adequately addresses the trial use of plant operating and emergency procedures. All issues relating to this section of the initial test program have been resolved.

DCD Section 14.2.10, Initial Fuel Loading and Initial Criticality Introduction In APR1400 DCD, Section 14.2.10, "Initial Fuel Loading and Initial Criticality," the DC applicant stated that initial fuel loading and initial criticality will be performed in a controlled manner during the startup test program.

The minimum initial conditions for the core and the criteria for 14-19 the safe loading of fuel are specified. Criteria are also specified for a safe and controlled approach to criticality.

Evaluation The NRC staff reviewed conformance of DCD Tier 2, Section 14.2.10 to the guidance in NUREG-0800, Section 14.2.II.4.A, "Initial Fuel Loading/Initial Criticality/Low Power /Power Ascension Testing," and RG 1.68, Appendix A, Sections A

-2, and A-3. As stated in the regulatory guidance, initial fuel loading and pre

-critical tests should (1) ensure safe initial core loading, (2) ensure that provisions are in place to maintain shutdown margin, and (3) ensure that the facility is in a final state of readiness to achieve criticality and perform low

-power testing. In APR1400 DCD Section 14.2.10, "Initial Fuel Loading and Initial Criticality," the DC applicant provided five Subsections: 14.2.10.1, "Initial Fuel Loading"

14.2.10.1.1, "Safe Loading Criteria"; 14.2.10.1.2, "Fuel Loading Procedure"

14.2.10.2, "Initial Criticality"

and 14.2.10.2.1, "Safe Criticality Criteria," which addressed RG 1.68, Appendix A, "Initial Fuel Loading and Pre

-Critical Tests," and Section A

-3, "Initial Criticality."

Initial Fuel Loading The DC applicant included provisions for initial fuel loading prerequisites.

The NRC staff noted that these provisions included Technical Specifications compliance, use of approved plant procedures, proper verification of water level and chemistry, continuous area radiation monitoring and calibration and response of nuclear instrumentation.

The staff verified that the applicant identified those prerequisites necessary for safe initial fuel loading in accordance with RG 1.68 and SRP Section 14.2.

The NRC staff finds that the DC applicant provided an adequate description of the prerequisites for initial fuel load, and is thus acceptable Safe Loading Criteria The DC applicant described the criteria that require fuel loading operations to stop, which include if 1) the neutron count rate from either temporary nuclear channel unexpectedly doubles during any single loading step, and 2) the neutron count rate on any individual nuclear channel increases by a factor of 5 during any single loading step excluding an anticipated change due to detector/source

. The NRC staff finds that the DC applicant provided an adequate description of the safety criteria for halting fuel loading operations, and is thus acceptable Fuel Loading Procedure The DC applicant describes the applicable precautions and limitations, prerequisites, initial conditions, and the necessary procedural steps that will be included in the initial fuel loading procedure.

The NRC staff finds that the DC applicant provided an adequate description of the procedural steps for initial fuel load, and is thus acceptable 14-20 Initial Criticality In APR1400 DCD, Section 14.2.10, the DC applicant described the controls to be used for controlled approach to criticality.

These controls include the use of approved plant procedures, use of an orderly combination of control element assembly withdrawal and boron concentration reduction, and monitoring of the core response.

The DC applicant included provisions for initial criticality perquisites.

The NRC staff finds that the DC applicant provided an adequate description of the controls t o be implemented during the initial approach to criticality, and is thus acceptable Safe Criticality Criteria The DC applicant provided the criteria for reasonable assurance of a safe approach to criticality.

The NRC staff noted the criteria included that the Technical Specifications are met, a sustained start up rate not in excess of one decade per minute, and a minimum of 1 decade per minute overlap is observed between the startup and log safety channels of the ex

-core nuclear instruments.

The NRC staff finds that the DC applicant provided an adequate description of the process to provide reasonable assurance of a safe approach to criticality, and is thus acceptable.

Conclusion The NRC staff concludes that the information provided in APR1400 DCD, Section 14.2.10 adequately describes the minimum initial conditions for the core and the criteria for the safe loading of fuel and the criteria for providing a safe and controlled approach to criticality, and is thus acceptable.

The NRC staff finds that all issues relating to this section of the initial test program have been resolved.

DCD Section 14.2.11, Test Program Schedule Introduction In APR1400 DCD, Section 14.2.11, the DC applicant stated that the scheduling of individual tests or test sequences will be established so that systems and components that are required to prevent or mitigate the consequences of postulated accidents are tested prior to fuel loading. Tests that require a substantial core power level for proper performance will be performed at the lowest power level commensurate with obtaining acceptable test data.

In addition, the DC applicant stated that the COL applicant is to specify the testing sequence to provide reasonable assurance that safety of the plant is not compromised during the test program and to provide reasonable assurance that the conduct of a specific test does not place the plant in a condition for which untested systems would be relied on for safety.

Evaluation The NRC staff reviewed conformance of APR1400 DCD, Section 14.2.11 to the guidance in RG 1.206, Section C.I.14.2.11, "Test Program Schedule"

RG 1.68, Regulatory Guidance Section C.5, "Schedule"

and SRP Section 14.2,Section II, Acceptance Criteria, Subsection C, 14-21 "Test Program Schedule and Sequence." RG 1.68 states that sufficient time should be scheduled to perform an orderly and comprehensive testing, providing for a minimum time of approximately 9 months for conducting the preoperational testing phase, and a minimum time of approximately 3 months for conducting the initial startup testing phase. In addition, SRP Section 14.2 states, in part, that the safety of the plant should not depend entirely on the performance of untested systems, components, or features.

In APR1400 DCD Section 14.2.11, the DC applicant states that it is the responsibility of the COL applicant to develop a test program that considers the following components:

The applicant should allow at least 9 months for conducting preoperational testing.

The applicant should allow at least 7 months for conducting startup testing, including fuel loading, low

-power tests, and power

-ascension tests. Approved test procedures should be in a form suitable for review by regulatory inspectors at least 60 days prior to their intended use or at least 60 days prior to fuel loading for fuel loading and startup test procedures.

The staff finds that APR1400 DCD, Section 14.2.11 included specific direction for the COL applicant to develop a test program that allots sufficient time to perform orderly and comprehensive testing. In addition, the staff finds that APR1400 DCD, Section 14.2.11 is acceptable because it provides that the COL applicant will schedule test s so that systems an d components that are required to prevent or mitigate the consequences of postulated accidents are tested prior to fuel loading. Additionally, the DCD provides that the COL applicant's test schedule and sequence of testing is to ensure that tests that require a substantial core power level for proper performance will be performed at the lowest power level commensurate with obtaining acceptable test data.

Conclusion The NRC staff concludes that the information provided in APR1400 DCD, Section 14.2.11 adequately describes the test program schedule. All issues relating to this section of the initial test program have been resolved.

DCD Section 14.2.12, Individual Test Descriptions Introduction APR1400 DCD, Section 14.2.12 contains individual preoperational and startup test abstracts. Each abstract identifies test objectives, prerequisites for conducting testing, test methods, test data requirements, and acceptance criteria for successful completion of the tests. The minimum test requirements are generally based on system or component functional design requirements that were used in the safety analysis.

Detailed preoperational and startup test procedures will be developed using these test abstracts.

14-22 Evaluation The NRC staff reviewed conformance of APR1400 DCD, Section 14.2.12 to the guidance in SRP Section 14.2.II.5, "Individual Test Descriptions/Abstracts," and the general guidelines and applicable regulatory positions in RG 1.68.

RG 1.68, Appendix A addresses the specific tests required for each of the five phases of the initial test program, which are: (1) preoperational testing; (2) initial fuel loading and pre

-criticality testing; (3) initial criticality testing; (4) low

-power testing; and (5) power ascension testing.

In APR1400 DCD Section 14.2.12, "Individual Test Descriptions," the NRC staff identified 135 preoperational tests, 1 1 post core load hot functional tests, 6 low power tests and 26 power ascension tests.

For each of the test abstracts, the NRC staff reviewed the test objective s , test prerequisites, test method s, data requirements, and acceptance criteria to verify conformance with NRC regulatory guidance.

From the start of the review in March 2015 until October 2015, the NRC staff reviewed these tests and identified the same generic issues with the format and descriptions for all 17 8 listed tests and a failure to follow the guidance of RG 1.68, Appendix A for SSCs that should be tested

. This resulted in NRC staff issuing a large number of RAI questions (90).

Since the issues applied to all of Section 14.2, on October 8, 2015, the NRC staff held a conference call with the DC applicant and requested the applicant to revise all of DCD Section 14.2.

The NRC staff suspended issuing any new RAIs and asked the applicant to delay responding to currently issued RAIs until the tests referenced in each RAI question were revised. During the call discussion, the applicant provided a sample revision which NRC staff agreed was much improved and followed the guidance of RG 1.68.

The DC applicant provided the revised Section 14.2 on February 24, 2016 (ML16056A002).

The revised Section 14.2 served as a new starting point, still as DCD revision 0, for the review.

By December 2016, the DC applicant proposed to update DCD Section 14.2.12.1 with 5 new preoperational tests.

The revised DCD Section 14.2.12 included 139 preoperational tests, 11 post-core hot functional tests, 6 low power physics tests and 2 6 power ascension tests, 1 82 tests total. The DC applicant also upgraded each test description with new objectives, prerequisites, test methods, data requirements and acceptance criteria. The NRC staff reviewed the new tests and the upgrades to each test description and determined that the proposed changes to DCD Section 14.2.12 meet s the guidance in RG 1.68, Appendix A for the list of APR1400 tests that should be included in the ITP

. For those aspects of DCD Section 14.2.12 for which no RAIs were necessary, the NRC staff determined the applicant provided an adequate test program to address those specific functions. The staff also verified that the tests are appropriately sequenced so that plant safety is never entirely dependent on the performance of untested SSCs.

The NRC also determined , using applicable guidance, that the test descriptions

1) contained appropriate content for the descriptions of test objectives

, test prerequisites, test methods, data requirements and acceptance criteria, and 2) were acceptable because they were consistent with the general guidelines and applicable regulatory positions contained in RG 1.68

. However, the NRC staff determined that additional information was required to complete its review. The discussion below first addresses those RAIs that are not specific to an ITP phase. Then the discussion addresses RAIs specific to an ITP phase (pre

-operational tests, post

-core hot functional tests, low power physics tests, and power ascension tests).

14-23 The NRC staff was not able to verify inclusion of several inspections and ITP test activities in DCD Section 14.2.12.

Specifically, the NRC staff identified a list of systems, components, and features for which the ITP should demonstrate operability consistent with the guidance in RG 1.68, Section A

-1.m, "Radioactive Waste Handling and Storage System."

The staff requested this information in NRC RAI 284

-8234, Question 14.02

-65 (ML15306A358).

In the June 17, 2016, response to RAI 284-8234, Question 14.02

-65 (ML16169A374), the DC applicant proposed revisions to DCD Subsections 14.2.12.1.65, 14.2.12.1.66, 14.2.12.1.67, 14.2.12.1.99, 14.2.12.1.104, and 14.2.12.1.105 to address preoperational testing of off-gas monitors; radiation monitors; isolation features for the steam generator blowdown system (SGBS), including thermal protection of demineralizer resin beds; automatic isolation features for ventilations systems

ventilation system gaseous effluent radiation release limits; diversion of exhaust flows; gas, liquid and solid rad

-waste systems; and waste process systems, including testing of mobile process equipment carrying radioactive fluids.

The NRC staff reviewed the DC applicant's response to RAI 284-8234, Question 14.02

-65 and determined that the applicant provided the requested information, consistent with the guidance in RG 1.68, with one exception. Namely, there was no attachment for a revision to DCD Section 14.2.12.1.66 to address testing of (1) the isolation features for the SGBS, based on the presence of radioactivity and (2) thermal protection of the demineralizer beds. DCD Section 10.4.8 also mentions these two features. However, there were no references to testing these features, nor were the two testing features discussed in the DC applicant's June 30, 2016 response to RAI 277

-8227, Question 14.02

-38 (ML16182A554).

The revision to DCD Section 14.2.12.1.66 should reference these testing features for the SGBS. This is Open Item 14.2.12.1-1. In NRC Question 14.02

-19 in RAI 198

-8208 (ML15254A546), the NRC staff requested the DC applicant provide the acceptance criteria used to select plant features to be tested to meet Criterion XI of Appendix B to 10 CFR Part 50.

Criterion XI, "Test Control," RG 1.68 also provides guidance on the ITP and states that "[t]he ITP should be designed to demonstrate the performance of SSCs and design features that will be used during normal facility operations, as well as the performance of standby systems and features that must function to maintain the plant in a safe condition in the event of malfunctions or accidents. The startup tests should be sequenced so that plant safety is never entirely dependent on the performance of untested SSCs." Further SRP Section 14.2, "Acceptance Criteria," Item 1.A states that the ITP should describe the criteria for selection of plant features to be tested by the applicant.

The NRC staff could not determine the acceptance criteria the applicant used for the selection of plant features to be tested in APR1400 DCD Tier 2, Section 14.2.

Therefore, the NRC staff requested the applicant to modify DCD Tier 2, Section 14.2 to include this information.

In the July 14, 2016, response to RAI 198-8208, Question 14.02

-19 (ML16196A339), the DC applicant proposed a revision to DCD Section 14.2.1 which would add a statement that the scope of the testing program includes SSCs that meet one or more of seven criteria consistent with the guidance in RG 1.68.

The NRC staff determined that the DC applicant's response is acceptable because it conforms to NRC guidance. However, the NRC staff determined that the DC applicant should add one more SSC test selection criteria from RG 1.68, page 3, noted in the bullet below

, and requested this information in RAI 278-8226, Question 14.02

-39 (ML160112A550).

14-24 SSCs that are identified within the scope of 10 CFR Part 50, Appendix A, GDC 1, "Quality Standards and Records," where SSCs important to safety shall be designed, fabricated, erected and tested to quality standards commensurate with the importance of the safety functions to be performed.

In response to RAI 278-8226, Question 14.02

-39, the DC applicant committed to including the additional SSC selection criteria for SSCs important to safety in DCD Section 14.1

-1. The NRC staff finds the proposed revision provides the appropriate measures for conducting an ITP to demonstrate that the plant can be operated in accordance with design requirements important to safety, and is thus acceptable. RAI 198-8208, Question 14.02

-19 and RAI 278

-8226, Question 14.02

-39 are resolved and the proposed revisions to the DCD are being tracked as Confirmatory Item 14.1-1. In NRC RAI 279

-8175, Question 14.02

-42 (ML15303A547) the NRC staff requested that the DC applicant discuss testing performed for Reactor Coolant Pump (RCP) components, including the pump, motor, and associated power sources. In addition the staff requested the DC applicant to discuss the performance of Moto r Current, Motor Power, Pump Motor Vibration, Motor Stator temperature, and Proper transfer from variable speed startup preoperational test for the RCPs. In the June 15, 2016, response to RAI 279-8175, Question 14.02

-42 (ML16167A540), the DC applicant proposed extensive updates to preoperational, post core hot functional and power ascension tests in DCD Sections 14.2.12.1.1 and 14.2.12.1.2, 14.2.12.1.56, 14.2.12.1.136, 14.2.12.1.137, 14.2.12.2.2 and 14.2.12.4

-18 for the RCP motors; the RCP Vibration Monitoring System; Pre

-Core and Post Core Nuclear Steam Supply System (NSSS) Integrity Monitoring, and many other reactor coolant system (RCS) components. The DC applicant also stated that the variable speed startup operation and the over

-speed trip function of the RCP motor are not applicable to the APR1400 design. The NRC staff determined that the revis ions to the aforementioned test included adequate testing for the Motor Current, Motor Power, Pump Motor Vibration , and Motor Stator temperature, to verify acceptable RCP pump and motor performance; therefore, the DC applicant response is acceptable.

RAI 279-8175, Question 14.02-42 is resolved

. The proposed revisions to the DCD are being tracked as Confirmatory Item 14.2.12.1

-3. In NRC RAI 279

-8175, Question 14.02-41 (ML15303A547), the NRC staff requested the DC applicant to provide additional information related to preoperational test methods in DCD Sections 14.2.12.1.2 and/or 14.2.12.1.7 to address important

-to-safety functions related to the reactor c oolant pumps (RCPs).

In the July 12, 2016, response to RAI 279-8175, Question 14.02

-41 (ML1619A348), the DC applicant summarized extensive revisions to DCD Subsections 14.2.12.1.2, 14.2.12.1.7, 14.2.12.1.43, 14.2.12.1.136, 14.2.12.1.137, and 14.2.12.2.2 and 14.2.12.4.18 related to testing RCP seal pressure and temperature; RCP seal injection performance, including RCP seal filters; RCP vapor seals, RCP seal differential pressure alarms; operational checks for CVCS auxiliary charging pumps and discharge check valves; the acoustic lead rate monitoring system; and pre

-core and post core NSSS integrity monitoring.

The DC applicant also stated the instrumentation calibration for RCP bearing metal temperature, oil flow and pressure, oil levels, cooling water flow and temperatures are included in prerequisites 2.2 and 2.3 for the RCS test (14.2.12.1.2). The acceptance criteria for 14-25 performing the initial run of the RCPs (test method 3.4) with RCP bearing metal temperature detectors, oil flow and pressure, oil levels within design limits, and normal operating ranges are included in acceptance criteria 5.11 of the RCS Test (14.2.12.1.2).

The NRC staff determined that the DC applicant

's response to RAI 279-8175, Question 14.02

-4 1 was acceptable because it included an adequate description of the test to be implemented for the important

-to-safety functions, noted in the paragraph above, in accordance with 10 CFR Part 50, Appendix A, GDC 1 , "Quality Standards and Records." The NRC staff also determined that the DC applicant appropriately updated DCD 14.2.12 with vibration monitoring of the RCP seal shaft and frame as part of the tests described in 14.2.12.2.2 and 14.2.12.4.18. The NRC staff determined that the DC applicant response and changes to these tests meet 10 CFR Part 50, Appendix A, GDC 1 and the guidance in RG 1.68 and it is acceptable; therefore RAI 279-8175, Question 14.02

-42 is resolved and the proposed revisions to the DCD are being tracked as Confirmatory Item 14.2.12.1-4. The NRC staff reviewed DCD Tier 2, Section 3.9.2.1 and Section 14.2.12.1, but did not find where the DC applicant identified which specific systems are included in the ITP, and whether, as stated in SRP Section 3.9.2, testing is conducted on all American Society of Mechanical Engineer (ASME) Class 1, 2, and 3 piping systems.

In NRC RAI 151

-8078, Question 03.09.02-3 (ML15234A007), the staff requested the applicant to (a) provide a listing of the high- and moderate

-energy piping systems inside containment that are covered by the vibration, thermal expansion, and dynamic effects testing program, (b) verify that the systems to be monitored include all ASME Class 1, 2, and 3 piping systems, and (c) provide the list of snubbers on systems that are subjected to sufficient thermal movements from cold to hot position. The NRC staff further requested the DCD Section 14.2 be revised to clarify the scope of the ITP.

In the March 24, 2016 response to RAI 151-8078, Question 03.09.02

-3 (ML16084A989), the DC applicant stated the following:

In performing the upgrade of the Initial Test Plans for DCD Section 14.2, it was determined that an alternate approach was more appropriate in responding to the above question. Therefore, a revision to the original response is being submitted. The response to items (a)

- (c) is as follows:

(a) A listing of the high

- and moderate

-energy piping systems inside containment that are covered by the vibration, thermal expansion, and dynamic effects testing program will be provided at the detailed design phase after the piping physical layout is designed. A listing of these piping systems will be included in the test procedure, which is the responsibility of the COL applicant. Therefore, DCD Tier 2, Subsection 3.9.2.1, which defines the test scope and criteria, will be revised to state these piping systems recommended in SRP 3.9.2, section I (1), A, B, C and D will be in the test procedure.

(b) DCD Tier 2, Section 3.9.2.1.a contains all ASME Class 1, 2, and 3 piping systems for the APR1400, as recommended by SRP 3.9.2, section I (1), A. To clarify the scope of ASME Class 1, 2, and 3 piping systems, DCD Tier 2, Section 3.9.2.1 will be revised as identified by SRP Section 3.9.2

14-26 (c) The list of snubbers on systems that are subjected to sufficient thermal movements from cold to hot position will be provided by KHNP at the detailed design phase after the piping analyses and supports design are completed. The list of snubbers will be included in the test procedure, which is the responsibility of the COL applicant. The staff determined that the RAI response is acceptable because DCD Tier 2, Subsection 3.9.2.1 will be changed to: 1) describe that the ITP is implemented to verify that the piping for all ASME Code,Section III Class 1, 2, and 3 piping systems, with exceptions allowed by the ASME Code, will remain within acceptable limits when subjected to piping vibrations and dynamic transients such as those caused by in

-line component trips; 2) clarify the scope of ASME Class 1, 2, and 3 piping systems to be tested, consistent with SRP Section 3.9.2

and 3) indicate the list of snubbers on systems that experience sufficient thermal movement to measure snubber travel from cold to hot position, will be provided by the COL license e as part of the test procedure. In addition, the NRC staff determined that the DC applicant's response meets the testing guidance for Class 1, 2, and 3 piping systems in RG 1.68, Appendix A, Section A-1, Preoperational Testing, Page A

-2, fourth paragraph, and is acceptable. The DC applicant proposed to add COL item 14.2(14) to Table 1.8

-2 to address the COL applicant developing a test procedure to include a listing of high

- and moderate

-energy piping systems inside containment that are covered by the vibration, thermal expansion, and dynamic effects testing program as described in DCD Subsection 3.9.2.1. The DC applicant also proposed to add COL Item 14.2(14) to DCD Section 14.2.13. The COL information item is acceptable because it reflects the COL applicant's testing responsibilities describe above. Based on the above, the NRC staff finds that the response is consistent with the guidance in SRP Section 3.9.2, and is therefore, acceptable because it provides the information needed to determine that the piping systems will remain within acceptable limits. RAI 151-8078, Question 03.09.02-3 is resolved and these changes to the DCD are being tracked as a Confirmatory Item in the Chapter 3 SER Section 3.9

.2. NRC Bulletin (BL) 88

-11, "Pressurizer Surge Line Stratification Test," and SRP Section 3.12 "ASME Code Class 1, 2, and 3 Piping Systems, Piping Components and Their Associated Supports," discuss the potential for stresses induced by thermal stratification in the pressurizer (PZR) surge line (SL). In particular, BL 88

-11 requested the establishment of a program that would monitor the PZR SL for the effects of thermal stratification beginning with hot functional testing (HFT). APR1400 DCD Tier 2, Section 3.12.5.10 states the APR1400 conforms with BL 88-11, but the APR1400 DCD did not include the description of a test program to implement monitoring of the PZR SL consistent with BL 88

-11, SRP Sections 3.2 and 14.2 (as was included in other DC applications that have been reviewed and approved by the NRC). Therefore, in NRC RAI 70

-8027, Question 03.12

-3 (ML15196A596), the NRC staff requested the following from the DC applicant:

1. According to BL 88

-11, thermal stratification occurs in the PZR SL during heat up, cool down and steady state operation of the plant. The staff requested that the DC applicant discuss whether a monitoring or test program is planned to verify the design transients used in the structural design of the SL or how this verification will take place. The staff asked the applicant to describe the test program for the PZR surge line and its implementation consistent with BL 88

-11 and SRP Section 3.2, that will demonstrate that stratification temperature measurements for the APR1400 PZR SL will be within deflection limits and result in no adverse consequences (such as contacting the pipe whip restraints), and discuss the effects of PZR SL stratification testing for which this 14-27 test continues at least through the first cycle of plant operation (i.e., hot functional and power ascension testing portions of the ITP).

2. Given the PZR SL monitoring is the responsibility of the COL applicant, please discuss in future DCD revisions the COL applicant responsibilities. Specifically, DCD Table 1.8.2 and COL Subsections 3.12.7 and 14.2.13 should be updated to identify COL items for PZR SL monitoring.

In the September 7, 2016, response to RAI 70-8027, Question 03.12

-03 (ML16251A 336), the DC applicant added DCD Section 14.2.12.1.140, "Pre

-Core Pressurizer Surge Line Stratification Test," which included acceptance criteria 5.1 which states:

Verification that surge line temperatures are within design limits The NRC staff reviewed the test objectives, prerequisites, test methods, data required, and acceptance criteria in the proposed test abstract.

The NRC staff determined that the DC Applicant's response and proposed update to DCD Section 14.2.12.1.140 to monitor PZR surge line temperatures meets the testing guidance in NRC BL 88

-11 and RG 1.68, Appendix A, Section A

-1.j, "Instrumentation and Control Systems;" which requires the implementation of a program to confirm pressurizer surge line integrity, therefore, this part of RAI 8027, Question 03.13-03 is resolved. This change to the DCD is being tracked as Confirmatory Item 14.2.12.1-59. For additional details related to the DC applicant's resolution of power ascension tests related to monitoring the PZR surge line, see SER Section 14.2.4.12.4 In NRC RAI 151

-8078, Question 03.09.02

-12 (ML15234A007), the NRC staff requested that the DC applicant justify not including a vibration assessment for the shutdown cooling and other ECCS lines, given operating experience at the similar Palo Verde Nuclear Generating Station (PVGNS) plant where a flow

-excited acoustic resonance was experienced in the shutdown cooling system, resulting in leaking and failure of an isolation valve. This information is necessary for the NRC staff to make a finding in accordance with 10 CFR 52.47(a)(22) that operating experience insights have been incorporated into the design.

In the October 23, 2015, response to RAI 151-8078, Question 03.09.02

-12 (ML15296A568), the DC applicant stated that:

The vibration assessment for the shutdown cooling system lines is not required for the APR1400 based on the operating experience insights from the PVNGS plant and the Korean plant (OPR1000). PVGNS Unit 1 experienced extensive outages or periods of low power operation during the first half of 2006 due to excessive vibration levels in the Unit 1 Train A Shutdown Cooling System (SCS) suction line. The PVGNS conducted extensive investigations to determine the source of the SCS suction line vibrations and to determine the reasons for the increased vibration levels. PVNGS concluded that the vibration was flow induced and was caused by coupling between an excitation source, vortex shedding in the SCS suction line tee due to RCS flow over the SCS suction nozzle, and an acoustic resonator. After evaluating many options, PVNGS resolved the problem by moving the SCS suction line isolation valve SI

-V651 nearer to the RCS hot leg. The new location of the SCS suction line isolation valve SI

-V651 is 11 feet from the RCS nozzle compared to the original location which was approximately 52.5 feet from the nozzle.

14-28 The SCS suction line designs of the OPR1000 and APR1400 are similar to the PVNGS plant SCS suction line re

-design. Specifically, the SCS suction line diameters (16 inches) and hot leg diameters (42 inches) of the OPR1000 and APR1400 are the same as those of the PVNGS plant. The locations of the SCS suction line isolation valves SI

-V651/V652 are 11 feet 4 inches from the RCS nozzle for the OPR1000 and 12 feet 8 inches from the RCS nozzle for the APR1400. All locations are similar to the new location of SI

-V651 in the PVNGS plant. In addition, an excessive vibration in the SCS suction line has not been reported in any of the OPR1000 plants. Therefore, based on the design configuration and similar plant operating experience, the possibility of excessive vibration levels in the SCS suction line experienced in the PVNGS Unit 1 SCS Train A is very low for the APR1400 and inclusion in the vibration assessment program is not necessary.

The NRC staff determined the that the DC applicant included an appropriate basis for not including a vibration assessment based on operating experience insights in its response based on OPR1400 operating experience and based on similarities between the APR1400 design and the PVNGS re

-design, which was intended to address the operating issues previously experience at PVNGS. Therefore, the DC applicant's response related to operational experience for vibration assessment of the shutdown cooling system and ECCS in similar reactor designs meets 10 CFR 52.47(a)(22). Therefore, RAI 151-8078, Question 03.09.02

-12 is resolved and no confirmatory item is needed because no changes to the DCD Section 14.2 were proposed or are necessary.

For COL applications under 10 CFR Part 52, the applicant must describe the ITP, in accordance with 10 CFR 52.79(a)(28). The requirements in 10 CFR 52.47 do not require a DC applicant to submit an ITP. However, DC applications should include proposed testing activities for the ITP to support the COL applications. The RG 1.68, Revision 4 provides guidance on initial fuel load and initial criticality tests in Appendix A, Section A

-2, "Initial Fuel Load and Pre

-Critical Tests," and Section A

-3, "Initial Criticality," and initial fuel load and initial criticality test procedures in Appendix C, "Preparation of Procedures," Section C

-2, "Fuel Loading," and Section C

-3, "Initial Criticality Procedures."

However, the APR1400 DC application did not include any initial fuel load/initial criticality tests to conform to the guidance in RG 1.68, which specifies the following tests:

Initial Fuel Loading, to establish prerequisites and conditions for initial fuel loading and procedures to ensure safe loading.

Inverse Count Ratio or 1/M Plot Test for Fuel Loading, for verification of sub

-criticality during fuel loading.

Initial Criticality, to describe the procedure for achieving initial criticality in a controlled manner. The NRC staff determined that the above

-described tests should constitute a separate initial fuel load/initial criticality phase of the ITP; therefore, the NRC staff determined that the DC applicant should consider creating a new table, similar to APR1400 DCD Tables 14.2

-1, "Preoperational Tests," 14.2

-2, "Post Core Hot Functional Tests," 14.2

-3, "Low-Power Physics 14-29 Tests," and 14.2

-4, "Power Ascension Tests" or consider renaming one of those tables, as appropriate.

To be consistent with the guidance in RG 1.68, Revision 4, the three initial fuel load/initial criticality tests noted above should be in DCD Section 14.2 and listed in a new table of initial fuel load/initial criticality tests.

NRC RAI 524-8697, Question 14.02-69 requested that the DC applicant add the above information to the DCD and provide a markup. This is being tracked as Open Item 14.2.12.2

-1. In NRC RAI 281

-8232, Question 14.02

-49 (ML15306A018), the NRC staff requested the DC applicant to:

1. Update DCD Chapters 11 and 12 to specify which radiation monitors are responsible for transmitting the emergency response data system (ERDS) parameters required in 10 CFR Part 50, Appendix E.

2. Include a test in the applicable initial test program DCD section 14.2 to ensure that each of these radiation monitors are accurately transmitting data to the ERDS and the ERDS is accurately providing the correct data.

3. 10 CFR Part 50, Appendix E, Section VI.2.a.(i), identifies that reactor coolant radioactivity monitors should be included as monitors that send a signal via ERDS. It was unclear which monitors identified are meeting this function.

The NRC staff asked the DC applicant to indicate which monitors are being relied on to perform this function and describe how the monitors provide reactor coolant radioactivity levels.

As an alternative, the applicant was requested to add a new monitor(s) and describe how reactor coolant radioactivity levels are measured.

In the July 6, 2016 DC applicant response to RAI 281-8232, Question 14.02

-49 (ML16188A428), the DC applicant revised Subsections 11.5.2.2.e, "Containment air monitors (RE

-039A and 040B," 11.5.2.2.g, "Condenser vacuum pump vent effluent monitor (RE

-063)," and 11.5.2.2.m, "Main steam line area and N

-16 radiation monitors (RE-217, 218, 219, and 220)," to state that these monitors transmit the radiation signals to the ERDS.

The DC applicant stated that the signals from the RMS monitors stated above are sent to the gaseous process effluent radiation monitoring and sampling system (PERMSS). The gaseous PERMSS communicates with the IPS to transmit these parameters to ERDS. The IPS receives these parameters via unidirectional communication and transmits these parameters to the ERDS. The communication test between the gaseous PERMSS and the IPS is performed at the manufacturer's facility during the factory acceptance testing (FAT). The communication test between the IPS and the ERDS is performed at the site during the initial test period. Since the manufacturer for the gaseous PERMSS has not been determined for APR1400, the DC applicant states that the test method for the communication between the gaseous PERMSS and IPS cannot be determined at this time. Therefore, the communication test between the gaseou s PERMSS and the ERDS will be performed by the COL applicant

. Additionally, the DC applicant identified that 10 CFR Part 50, Appendix E, Section VI.2.a.(i), indicates that containment radiation level is one of the parameters required to 14-30 be monitored by the ERDS. Therefore, the containment upper operating area monitors (RE-233A and RE

-234B) should be included as monitors that transmit signals to the ERDS because the purpose of RE

-233A and RE

-234B is to identify containment high range radiation levels during accident conditions, as required by 10 CFR 50.34.

The DC applicant provided markups for the Subsections 11.5.2.2.5.e and 11.5.2.2.5.g in the revised response to the RAI 131

-8087 Question 11.05

-1 via KHNP letter MKD/NW 0480L, dated May 11, 2016 (ML16132A380). The NRC staff determined that Subsections 11.5.2.2.5.e and 11.5.2.2.5.g were appropriately revised to state that these monitors transmit the radiation signals to the ERDS in accordance with the NRC staff's request; therefore the NRC staff considers RAI 281-8232, Question 14.02

-49 resolved

. The DC applicant also added COL Item 14.2(12) to ensure that the COL applicant will perform the appropriate interface testing of the monitors with ERDS. Finally, the NRC staff also determined that the DC applicant should provide an update to include the containment upper operating area monitors as monitors that transmit a signal via ERDS and include information in DCD Chapter 12 to specify that these monitors send a signal to ERDS, or explain why these monitors need not be included. This is part of Open Item 14.2.12.1

-50. The RG 1.68 provides guidance on initial tests that are acceptable to staff as part of the ITP. RG 1.68, Appendix A provides guidance on the types of tests that should be included as part of the ITP. Various radiation

-protection

-related items that RG 1.68 states should be tested were not addressed in the ITP for the APR1400 design.

These included the following:

1. Testing of laboratory equipment used to analyze or measure radiation levels and radioactivity concentrations (see RG 1.68, Appendix A, Section A

-1.k. item 3).

2. Testing for leakage control and detection for the CVCS and testing of the gaseous systems for leak detection or equivalent testing (see RG 1.68, Appendix A, Section A

-1.l). 3. Testing of components to control the temperature of the SGBS, as discussed in DCD Section 10.4.8, to protect the steam generator blowdown resin beds, preventing a sudden loss of resin bed efficiency and the release of radioactivity above established limits and contamination of otherwise clean portions of plant systems (see RG 1.68, Appendix A, Section A

-1.k). In NRC RAI 281

-8232, Question 14.02

-54 (ML15306A018), the NRC staff requested the DC applicant provide the above tests in the ITP or justify an alternative.

In the June 30, 2016, response to RAI 281-8232, Question 14.02

-54 (ML16182A588), the DC applicant updated COL item 14.2(10) to state, in part, that:

The COL applicant is to develop the test program for personnel monitors, radiation survey instruments, and laboratory equipment used to analyze or measure radiation levels and radioactivity concentrations.

The NRC staff reviewed the proposed change to COL item 14.2(10) and determined that the DC applicant satisfactorily addressed the testing of the laboratory equipment as requested in RAI 281

-8232, Question 14.02

-54, part 1.

14-31 In addition, the applicant indicated that testing of leakage control and detection of the CVCS and gaseous radwaste systems are not necessary, since the accident source term does not enter into these systems due to the containment isolation as a result of the accident. The NRC staff determined that the DC applicant's response is acceptable because the CVCS and gaseous radwaste systems can be isolated during an accident, if necessary. Additionally, the containment isolation valve is tested in Section 14.2.12.1.124

thus the NRC staff concluded that the DC applicants explanation for not performing test leak detection of CVCS and gaseous radwaste systems is consistent with the testing guidance in RG 1.68, Appendix A, Section A

-5, "Power Ascension Tests," Test Item n, for radiation leakage testing, and Test Item z, related to independent laboratory testing. As a result, RAI 281-8232, Question 14.02

-54, parts 1 and 2 are resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.5-6. The applicant also provided a response to RAI 281-8232, Question 14.02

-54, part 3. The NRC determined that more information is needed and this is being tracked as part of Open Item 14.2.12.1

-1. Preoperational Tests The following is a list of "Phase I: Preoperational Testing" abstracts described in APR1400 DCD, Sections 14.2.12.1.1 through 14.2.12.1.139:

14.2.12.1.1 Reactor Coolant Pump Motor Initial Operation Test 14.2.12.1.2 Reactor Coolant System Test 14.2.12.1.3 Pressurizer Pilot

-Operated Safety Relief Valve Test 14.2.12.1.4 Pressurizer Pressure and Level Control Systems Test 14.2.12.1.5 Chemical and Volume Control System Letdown Subsystem Test 14.2.12.1.6 Volume Control Tank Subsystem Test 14.2.12.1.7 Chemical and Volume Control System Charging Subsystem Test 14.2.12.1.8 Chemical Addition Subsystem Test 14.2.12.1.9 Reactor Drain Tank Subsystem Test 14.2.12.1.10 Equipment Drain Tank Subsystem Test 14.2.12.1.11 Boric Acid Batching Tank Subsystem Test 14.2.12.1.12 Concentrated Boric Acid Subsystem Test 14.2.12.1.13 Reactor Makeup Subsystem Test 14.2.12.1.14 Holdup Subsystem Test 14.2.12.1.15 Boric Acid Concentrator Subsystem Test 14.2.12.1.16 Gas Stripper Subsystem Test 14.2.12.1.17 Boronometer Subsystem Test 14.2.12.1.18 Process Radiation Monitor Subsystem Test 14.2.12.1.19 Gas Stripper Effluent Radiation Monitor Subsystem Test 14.2.12.1.20 Shutdown Cooling System Test 14.2.12.1.21 Safety Injection System Test 14.2.12.1.22 Safety Injection Tank Subsystem Test 14.2.12.1.23 Engineered Safety Features

- Component Control System Test 14.2.12.1.24 Plant Protection System Test 14.2.12.1.25 Ex

-Core Neutron Flux Monitoring System 14.2.12.1.26 Fixed In

-Core Nuclear Signal Channel Test 14.2.12.1.27 Digital Rod Control System

14-32 14.2.12.1.28 Reactor Regulating System Test 14.2.12.1.29 Steam Bypass Control System Test 14.2.12.1.30 Feedwater Control System Test 14.2.12.1.31 Core Operating Limit Supervisory System Test 14.2.12.1.32 Reactor Power Cutback System Test 14.2.12.1.33 Fuel Storage and Handling system Test 14.2.12.1.34 Auxiliary Feedwater System Test 14.2.12.1.35 Reactor Coolant System Hydrostatic Test 14.2.12.1.36 Control Element Drive Mechanism Cooling System Test 14.2.12.1.37 Reactor Coolant Gas Vent System Test 14.2.12.1.38 Containment Spray System Test 14.2.12.1.39 Integrated Engineered Safety Features / Loss of Power Test 14.2.12.1.40 In

-Containment Water Storage System Test 14.2.12.1.41 Internals Vibration Monitoring System Test 14.2.12.1.42 Loose Parts Monitoring System Test 14.2.12.1.43 Acoustic Leak Monitoring System Test 14.2.12.1.44 Information Processing System and Qualified Information and Alarm System Test 14.2.12.1.45 Turbine Generator Building Open Cooling Water System Test 14.2.12.1.46 Pre

-Core Hot Functional Test Controlling Document 14.2.12.1.47 Pre-Core Instrument Correlation 14.2.12.1.48 Remote Shutdown Console Test 14.2.12.1.49 Diverse Protection System Test 14.2.12.1.50 Pre

-Core Test Data Record 14.2.12.1.51 Pre

-Core Reactor Coolant System Expansion Measurements 14.2.12.1.52 Pre

-Core Reactor Coolant and Secondary Water Chemistry Data 14.2.12.1.53 Pre

-Core Pressurizer Performance Test 14.2.12.1.54 Pre

-Core Control Element Drive Mechanism Performance Test 14.2.12.1.55 Pre

-Core Reactor Coolant System Flow Measurements 14.2.12.1.56 Pre

-Core Reactor Coolant System Heat Loss Measurement 14.2.12.1.57 Pre

-Core Reactor Coolant System Leak Rate Measurement 14.2.12.1.58 Pre

-Core Chemical and Volume Control System Integrated Test 14.2.12.1.59 Pre

-Core Safety Injection Check Valve Test 14.2.12.1.60 Pre

-Core Boration / Dilution Measurements 14.2.12.1.61 Downcomer Feedwater System Water Hammer Test 14.2.12.1.62 Main Turbine Systems Test 14.2.12.1.63 Main Steam Safety Valve Test 14.2.12.1.64 Main Steam Isolation Valves and MSIV Bypass Valves Test 14.2.12.1.65 Main Steam System Test 14.2.12.1.66 Steam Generator Blowdown System Test 14.2.12.1.67 Main Condenser and Condenser Vacuum Systems Test 14.2.12.1.68 Feedwater System Test 14.2.12.1.69 Condensate System Test 14.2.12.1.70 Turbine Steam Seal System Test 14.2.12.1.71 Circulating Water System Test 14.2.12.1.72 Steam Generator Hydrostatic Test 14.2.12.1.73 Heater Drains System Test 14.2.12.1.74 Chilled Water System Test 14.2.12.1.75 Essential Service Water System Test 14.2.12.1.76 Component Cooling Water System Tes t 14.2.12.1.77 Spent Fuel Pool Cooling and Cleanup System Test

14-33 14.2.12.1.78 Turbine Generator Building Closed Cooling Water System Test 14.2.12.1.79 Condensate Storage System Test 14.2.12.1.80 Normal Lighting System Test 14.2.12.1.81 Emergency Lighting System Test 14.2.12.1.82 Compressed Air and Gas Systems Test 14.2.12.1.83 Process and Primary Sampling System Test 14.2.12.1.84 Heat Tracing System Test 14.2.12.1.85 Fire Protection System Test 14.2.12.1.86 Emergency Diesel Generator Mechanical System Test 14.2.12.1.87 Emergency Diesel Generator Electrical System Test 14.2.12.1.88 Emergency Diesel Generator Auxiliary Systems Test 14.2.12.1.89 Alternate AC Source System Test 14.2.12.1.90 Alternate AC Source Support Systems Test 14.2.12.1.91 Containment Polar Crane Test 14.2.12.1.92 Fuel Handling Area Cranes Test 14.2.12.1.93 Reactor Containment Building HVAC System Test 14.2.12.1.94 Reactor Containment Purge System Test 14.2.12.1.95 Control Room HVAC System Test 14.2.12.1.96 Turbine Generator Building HVAC System Test 14.2.12.1.97 Emergency Diesel Generator Area HVAC System Test 14.2.12.1.98 Fuel Handling Area HVAC System Test 14.2.12.1.99 Compound Building HVAC System Test 14.2.12.1.100 Balance of Control Room HVAC System Test 14.2.12.1.101 Hydrogen Mitigation System Test 14.2.12.1.102 Containment Hydrogen Recombiner System Test 14.2.12.1.103 Liquid Waste Management System Test 14.2.12.1.104 Solid Waste Management System Test 14.2.12.1.105 Gaseous Waste Management System Test 14.2.12.1.106 Process and Effluent Radiological Monitoring System Test 14.2.12.1.107 Area Radiation Monitoring System Test 14.2.12.1.108 4,160V Class 1E Auxiliary Power System Test 14.2.12.1.109 480V Class 1E Auxiliary Power System Test 14.2.12.1.110 Unit Main Power System Test 14.2.12.1.111 13,800V Normal Auxiliary Power System Test 14.2.12.1.112 4,160V Normal Auxiliary Power System Test 14.2.12.1.113 480V Normal Auxiliary Power System Test 14.2.12.1.114 Non

-Class 1E DC Power Systems Test 14.2.12.1.115 Class 1E DC Power System Test 14.2.12.1.116 Offsite Power System Test 14.2.12.1.117 Balance

-of-Plant Piping Thermal Expansion Measurement Test 14.2.12.1.118 Balance

-of-Plant Piping Vibration Measurement Test 14.2.12.1.119 Containment Integrated Leak Rate Test and Structural Integrity Test 14.2.12.1.120 Fuel Transfer Tube Functional Test and Leak Test 14.2.12.1.121 Equipment Hatch Functional Test and Leak Test 14.2.12.1.122 Containment Personnel Airlock Functional Test and Leak Test 14.2.12.1.123 Containment Electrical Penetration Assemblies Test 14.2.12.1.124 Containment Isolation Valves Leakage Rate Test 14.2.12.1.125 Loss of Instrument Air Test 14.2.12.1.126 Mid

-Loop Operations Verification Test 14.2.12.1.127 Seismic Monitoring Instrumentation System Test

14-34 14.2.12.1.128 Auxiliary Steam System Test 14.2.12.1.129 Containment Isolation Valves Test 14.2.12.1.130 Post

-Accident Monitoring Instrumentation Test 14.2.12.1.131 Electrical and I&C Equipment Areas HVAC System Test 14.2.12.1.132 Auxiliary Building Controlled Area HVAC System Test 14.2.12.1.133 Auxiliary Building Clean Area HVAC System Test 14.2.12.1.134 Leakage Detection System Test 14.2.12.1.135 Leakage Control and Detection of outside Containment System 14.2.12.1.136 RCP Vibration Monitoring System 14.2.12.1.137 NSSS Integrity Monitoring System (Pre

-core) 14.2.12.1.138 Core Protection Calculator System Test 14.2.12.1.139 Diverse Indication System Test In comparing the APR1400 preoperational tests to the preoperational testing recommended in RG 1.68, Appendix A, Section 1, the NRC staff identified several areas where additional information was required to complete its review.

14.2.12.1.3 Pressurizer Pilot

-Operated Safety Relief Valve Test In NRC RAI 233

-8244, Question 05.02.02

-5 (ML15296A004), the NRC staff noted that GDC 30 requires the RCS pressure boundary be designed, fabricated, erected and tested to the highest quality standards practical. Application of GDC 30 provides assurance that the RCS pressure boundary will have an extremely low probability of failure because of manufacturing or design defects. The NRC staff requested the DC applicant define the complete pre

-service or preoperational test to be performed on the pressurizer pilot operated safety relief valves (POSRVs) and update DCD Section 14.2 accordingly. In the June 30, 2016, response to RAI 233-8244, Question 05.02.02

-5 (ML16182A585), the DC applicant proposed to update DCD Section 14.2.12.1.3, "Pressurizer Pilot

-Operated Safety Relief Valve Test," with the following:

Test Method

3.3 Determine

opening dead times, stroke times and closing times Data Required

4.3 Opening

dead times, stroke times and closing times 4.4 Lead detection temperatures The NRC staff determined that this DC applicant response and proposed changes to DCD Subsection 14.2.12.1.3, meet the guidance in RG 1.68 which requires testing of the POSRVs' function to ensure integrity of the pressure boundary. RAI 233-8244, Question 05.02.02

-5 is resolved and the proposed changes to the DCD are being tracked as Confirmatory Item 14.2.12.1-6. 14.2.12.1.7 Chemical and Volume Control System Charging Subsystem Test In accordance with 10 CFR Part 50, Appendix A, GDC 1 and RG 1.68, Section B, the NRC staff reviewed APR1400 DCD Table 17.4

-1, "Risk-Significant Within

-Scope RAP SSCs," and DCD Chapter 19 , the NRC staff identified the Auxiliary Charging Pump, SSC ID CV

-PP03, and the Auxiliary Charging Pump Discharge Check Valve, SSC ID CV334, in DCD Table 17.4

-1 as risk-significant components; however, no test method and test acceptance criteria were identified to demonstrate a diverse means of Reactor Coolant Pump (RCP) seal cooling to 14-35 prevent an RCP seal Loss of Coolant Accident (LOCA) event. In NRC RAI 278

-8226, Question 14.02

-40 (ML15303A502), the NRC staff requested the DC applicant to provide test methods and acceptance criteria for all non

-safety-related risk significant SSCs that are also considered important to safety and identify these in APR1400 DCD Table 17.4

-1 and include them within the scope of the ITP in APR1400 DCD Section 14.2.

In the June 30, 2016, response to RAI 278-8226, Question 14.2

-40 (ML16182A545), the DC applicant proposed changes to DCD Subsection 14.2.12.1.7, "Chemical and Volume Control System Charging Subsystem Test," which included the addition of 14 test objectives and acceptance criteria related to testing the chemical volume control system (CVCS) charging subsystem; RCP seal cooling functions, including cycling of CVCS testing of CVCS discharge check valves; CVCS charging pumps; CVCS flow paths to RCP seal injection lines; auxiliary charging pump lubricating oil system and alarms; seal injection flow instrumentation channels, including signal output, indications, alarm locations, control of seal injection control valves, seal filter differential pressure alarms, etc. The NRC staff also finds the proposed revisions to DCD Section 14.2.12.1.7 to add CVCS component testing adequately addresses the important-to-safety testing requirements necessary to demonstrate that the CVCS will function as required so that the facility can be operated in accordance with design requirements. In particular, the staff verified that the proposed revisions are consistent with CVCS testing guidance in RG 1.68, Section A

-1.a, "Reactor Coolant System" and Subsection A

-1.b.2, Chemical Control System Test (PWR Only)." RAI 278-8226, Question 14.02

-40 is resolved and the changes to the DCD are being tracked as Confirmatory Item 14.2.12.1

-2. 14.2.12.1.18 Process Radiation Monitor Subsystem Test In NRC RAI 285

-8202, NRC Question 14.02

-66 (ML15306A468), the NRC staff requested an explanation for an inconsistency in the acceptance criteria of DCD Section 14.2.12.1.18, "Process Radiation Monitor Subsystem Test." The acceptance criteria references DCD Subsection 9.3.4.5.6, which directs the reader to the Boronometer topic instead of 9.3.4.5.5.2, "Process Radiation Monitor" In the May 19, 2016, response to RAI 285-8202, Question 14.02

-66 (ML16142A012), the DC applicant proposed to revise DCD Subsection 14.2.12.1.18, Acceptance Criteria 5.1, to reference the correct DCD Subsection 9.3.4.5.5.2. The NRC staff determined the proposed change identifies the correct DCD Subsection and is acceptable; therefore, RAI 285-8282, Question 14.02

-66 is resolved and this item is being tracked as Confirmatory Item 14.2.12.1-7. 14.2.12.1.20 Shutdown Cooling System Test; 14.2.12.1.21 Safety Injection System Test In APR1400 DCD Chapter 1, Table 1.91, "APR1400 Conformance to NRC Regulatory Guides," and DCD Subsection 14.2.7.3, the DC applicant commits to Regulatory Guidance in RG 1.79, "Preoperational Testing of Emergency Core Cooling Systems for Pressurized Water Reactors."

The NRC staff determined that since the DC applicant committed to RG 1.79, more information should be added to DCD Sections 14.2.12.1.20 and 14.2.12.1.21. Specifically, the prerequisite sections, should be updated to state "vent valves should be closed before starting these ECCS pumps" since RG 1.79, "Prerequisite Section C," states that "vent valves should be closed before starting ECCS pumps." The staff also determined that additional information was 14-36 needed on non-condensable gas intrusion into ECCSs. In NRC RAI 91

-7867, Question 14.02

-03 (ML15201A768) the staff asked for an engineering evaluation for non

-condensable gas intrusion into ECCSs and prerequisite test checks to verify vent valves are closed before starting the shutdown cooling system pumps consistent with the prerequisite section of RG 1.79. In the August 26, 2016, response to RAI 91-7867, Question 14.02

-03 (ML16239A430), the DC applicant provided a detailed summary on how gas accumulation would be managed in ECCSs, including a list of potential pathways for gas intrusion in the APR1400 safety injection system (SIS) and shutdown cooling system (SCS) and APR1400 SIS and SCS design features to prevent or control gas accumulation to acceptable levels in order to maintain system operability. Thus, the staff finds that the DC applicant has adequately addressed the staff's concerns regarding non

-condensable gas intrusion into ECCSs.

The DC applicant also updated the prerequisite section in DCD Sections 14.2.12.1.20 and 14.2.12.21 to include verification that the SCS and SIS are vented and the vent valves are closed before starting the SIP or SCP. The pre

-operational test procedure for ECCS will describe the criteria for the amount of gas that would be considered acceptable rather than this information being included in the ITP. The NRC staff determined that this response meets the guidance in RG 1.79, Regulatory Position C and is acceptable; therefore, RAI 91-7867, Question 14.02

-03 is resolved and this change to the DCD is being tracked as Confirmatory Item 14.2.12.1

-8. 14.2.12.1.23 Engineered Safety Features

- Component Control System Test APR1400 DCD Tier 2, Section 14.2.12.1.23 provides a preoperational test for the Engineered Safety Feature

- Component Control System (ESF

-CCS). In NRC RAI 198

-8208, Question 14.02-20 (ML15245A54 56), the NRC staff determined that additional information is required regarding the objectives, prerequisites, test methods, and acceptance criteria to determine whether this test meets the requirements of Criterion XI of Appendix B to 10 CFR Part 50.

In the August 17, 2016, response to RAI 198-8208, Question 14.02

-20 (ML16230A479), the DC applicant revised test plans for ESF

-CCS, the basis for conducting the ESF

-CCS test, test objectives for the ESF

-CCS, component operation within the ESF

-CCS, including inter-cabinet interfaces with digital instrumentation and control (I&C) that need to be met, enhanced prerequisites for ESF

-CCS components, enhanced test method steps, more detailed tests for ESF-CCS divisions, more detail on ESF actuation signals generated by the Plant Protection System (PPS), more detail on loss of offsite power and emergency diesel generator (EDG) sensor inputs to the ESF

-CCS, use of the Diverse Protection System (DPS) to generate diverse actuations signals, manual controls for ESF plant components, ESF

-CCS transfer controls from the Main Control Room (MCR) to the Remote Shutdown Room (RSR), enhanced electrical independence tests for each ESF

-CCS division, and upgraded acceptance criteria for each ESF-CCS division to match up with each E SF-CCS test objective and test method which confirms no unexpected interaction between ESF

-CCS divisions.

Based on the DC applicant's proposed changes, the NRC staff determined that the initial tests for the ESF

-CCS are adequate to verify the as

-built and as

-installed equipment meet the functional requirements for the ESF

-CCS in conformance with the requirements of Criterion XI of Appendix B to 10 CFR Part 50 and RG 1.68, Appendix A, Section A

-1, "Engineered Safety

14-37 Features," As such, RAI 198-8208, Question 14.02

-20 is resolved and the proposed revisions to DCD are being tracked as Confirmatory Item 14.2.12.1-9. In NRC RAI 151

-8078, Question 03.09.02

-4b (ML15234A007), the NRC staff requested the DC applicant provide a listing of the different flow modes to which the systems will be subjected during the vibration, thermal expansion, and dynamic effects testing program to confirm that the piping systems, restraints, components, and supports have been adequately designed to withstand flow

-induced dynamic loadings under the steady

-state and operational transient conditions anticipated during service.

In the March 24, 2016 response to RAI 151-8078, Question 03.09.02

-4b (ML16084A989), the DC applicant stated the following:

In performing the upgrade of the Initial Test Plans for DCD Section 14.2, it was determined that an alternate approach was more appropriate in responding to the above question. Therefore, a revision to the original response is being submitted. A listing of the different flow modes will be provided at the COL applicants detailed design phase since the flow modes and their results on the piping systems are determined after the piping analyses are completed. However, to ensure the elements of an acceptable startup test

-program are incorporated, as identified by SRP 3.9.2, the different flow modes of operation and transients to which the systems will be subjected during startup functional testing of the specified piping systems will be added in DCD Tier 2, Subsection 3.9.2.1.

Therefore, DCD Subsection 3.9.2.1 will be revised to identify the different flow modes, i.e., pump trips and valve closures, of operation and transients to which the systems will be subjected during startup functional testing of the specified piping systems. The NRC staff finds that the response is acceptable because it addresses the different flow modes to verify adequate design to withstand flow

-induced dynamic loadings under the steady

-state and operational transient conditions anticipated during service.

The staff finds that because a listing of the different flow modes will be determined by the COL applicant and is, thus, outside the scope of design certification, it is acceptable to defer to the COL applicant for the descriptions of vibration, thermal expansion, and dynamic effects testing in accordance with RG 1.20 and RG 1.68, Appendix A, Section A

-1a, "Reactor Coolant System," and Section A

-5, "Power Ascension Tests," Test Item o. Based on the above, RAI 151-8078 Question 03.09.02-4 is resolved and the proposed revision to the DCD is being tracked as a Confirmatory Item in the Chapter 3 SER Section 3.09.

02. In addition, based on the DC applicant response stating that a listing of different flow modes will be provided at the COL applicant's detailed design phase, the DC applicant proposed to add COL item 14.2(15) to Table 1.8

-2 to address the COL applicant developing a test procedure to include a listing of the different flow modes to which the systems will be subjected during the vibration, thermal expansion, and dynamic effects testing program as described in DCD Subsection 3.9.2.1. The DC applicant also proposed to add COL item 14.2(15) to DCD Section 14.2.13. The COL information item is acceptable because it reflects the COL applicant responsibilities described above. This is being tracked as a Confirmatory Item in the Chapter 3 SER Section 3.09.02.

14-38 14.2.12.1.24 Plant Protection System Test APR1400 DCD Tier 2, Section 14.2.12.1.24, provides the initial test for the Plant Protection System (PPS).

In NRC RAI 198

-8208, Question 14.02

-21 (ML15254A546), the NRC staff determined that additional information is required regarding the objectives, prerequisites, test methods, and acceptance criteria to determine whether this test meets the requirements of Criterion XI of Appendix B to 10 CFR Part 50.

This question was issued prior to the upgrade of DCD Section 14.2 discussed at the beginning of this SER section (14.2.4.12). The response of June 22, 2016 (ML16174A465) included changes made after the upgrade and specific to the RAI question. The NRC staff reviewed this response and determined corrections were needed to parts of the response

. This included the re

-inclusion of test objectives 1.9 and 1.13, added as part of the upgrade and deleted by the June 2016 response. The June 2016 response also removed test method item 3.11 as it was not applicable to this test. However, NRC staff believed it was applicable to the core protection calculator system (CPSC) test in 14.2.12.1.138, and needed the applicant to state that it would be included there. Additional editing for clarity needs were identified in the response.

The details of these corrections were discussed in a publicly

-noticed teleconference on August 25, 2016.

The NRC staff found that except for the parts of the response needing clarification, the response was acceptable because it met the guidance of RG 1.68 for the PPS system. The changes to test 14.2.12.1.24 committed to in the response are being tracked as part of Confirmatory Item 14.2.12.1

-11. The DC applicant provided a revised response in September 2016.

The revised response provided the requested clarifications and met the guidance of RG 1.68. This resolved this aspect of RAI 198

-8208, Question 14.02

-21. These new changes are also tracked as part of Confirmatory Item 14.2.12.1

-11. In reviewing the DC applicant's September 26, 2016 response to RAI 198-8208, Question 14.02-21 (ML16270A372), the NRC staff identified the following new issues, which it discussed with the applicant in a follow-up teleconference on October 20, 2016.

1) For the CPCS test in 14.2.12.1.138, where are redundancy and independence of the as-installed CPCS verified?

2) Item 3) j) of the RAI response does not address the NRC staff's questions from the previous supplemental response request.

Specifically, why can't the design accommodate a single test to verify response time for each RT and ESF function?

Why is overlap testing required?

Per IEEE Std 338

-1987, "the response time test should include as much of each safety system, from sensor input to actuated equipment, as is practicable in a single test. Where it is not practical to simultaneously test the entire set of equipment from sensor to actuated equipment in one test, verification of system response time shall be accomplished by measuring the response times of discrete portions of the system and showing that the sum of all the response times is within limits of the overall system requirement."

For the response time testing, does the RT trip path include the CPCS?

In the December 19, 2016 DC applicant response to RAI 198

-8208, Question 14.02

-21 (ML16354B588), the DC applicant stated that that it doesn't want to do response time testing in a single test because it would be more efficient and beneficial for maintenance purposes to 14-39 have a modular testing methodology rather than one single test methodology for measuring the system response time.

The NRC staff determined that the DC applicant's response to perform modular testing is an acceptable method to meet 10 CFR Part 50, Appendix B, Criterion XI and RG 1.68, Appendix A, Section A

-1.j, "Instrumentation and Control Systems," because if there are response time delays beyond the expected response time, the DC applicant can determine which portion of the system resulted in the additional delays.

The December 2016 response also revised test section 14.2.12.1.138 to satisfactorily provide the details relating to the CPCS redundancy and independence testing which meet the guidance of RG 1.68 for the CPCS system.

Therefore, the DC applicant's response to this part of RAI 198-8208, Question 14.02

-21 is resolved and this change to the DCD is being tracked as part of Confirmatory Item 14.2.12.1

-11. 14.2.12.1.25 Ex

-Core Neutron Flux Monitoring System The APR1400 DCD Tier 2, Section 14.2.12.1.25 provides the preoperational test for the Ex

-Core Neutron Flux Monitoring System (ENFMS).

The NRC staff determined that additional information is required to determine whether this test meets the requirements of Criterion XI of Appendix B to 10 CFR Part 50.

Therefore, in NRC RAI 198

-8208, Question 14.02

-22 (ML15254A546), the staff requested that the DC applicant provide clarification for the objectives, prerequisites

, and how electrical independence is verified.

In the November 29, 2016, response to RAI 198-8208, Question 14.02

-22 (ML16334A537), the DC applicant stated that DCD Subsection 14.2.12.1.25 will be updated with the following additions: (1) The applicant will add Subsection 7.2.1.1.c to the Acceptance Criteria to verify the functional performance of all channels of the ENFMS and add the completion of the ENFMS FAT as a prerequisite in the test plan. The applicant will also add (2) an objective, test method and acceptance criteria to verify electrical independence between the safety and non

-safety related channels of the ENFMS.

The NRC staff determined the DC applicant's response to provide the appropriate test objectives, prerequisites and electrical independence test requirements will result in adequate testing of the ENFMS. The proposed changes meet 10 CFR Part 50, Appendix B, Criterion XI and RG 1.68, Appendix A Section A

-1.j, "Instrumentation and Control Systems," and are acceptable

. Therefore , RAI 198-8208, Question 14.02

-22 is resolved and these D CD changes are being tracked as Confirmatory Item 14.2.12.1

-12. 14.2.12.1.26 Fixed In

-Core Nuclear Signal Channel Test The APR1400 DCD Tier 2, Section 14.2.12.1.26 describes the initial test for the fixed in

-core nuclear instrumentation system.

The NRC staff requested additional information to determine whether this test meets the requirements of Criterion XI of Appendix B to 10 CFR Part

50. Therefore, in NRC Question 14.02

-23 in RAI 198

-8208 (ML15254A546), the staff requested that the applicant clarify the objectives of the test by providing verification of the proper operation of both the in

-core instrumentation and core exit thermocouple (CET) and that the test prerequisites do not specify verification of the location of each in

-core detector

.

14-40 In the June 30, 2016, response to RAI 198-8208, Question 14.02

-23 (ML16182A569), the DC applicant stated:

As the title of FSAR Tier 2, Section 14.2.12.1.26 implies, item 1.2 is to verify the proper amplifier operation inside FIDAS cabinet itself, but does not include the verification of Core Exit Thermocouple (CET), which is addressed in the post

-core and power ascension test stages. Instead, as specified in items 1.3 and 1.4 of amended Section 14.2.12.2.26 that was submitted to the NRC staff (ref. KHNP submittal MKD/NW 0156L dated February 24, 2016; ML16056A003), only the cable continuity and insulation resistance of the interface cables related with CET and in-core detectors is to be verified. In addition, the coverage of verification is clearly specified in items 1.1 and 1.2 for the amended Section 14.2.12.2.26.

Additionally, the DC applicant stated the following:

Each in-core instrumentation (ICI) assembly is assembled such that five in

-core detectors are located equidistant from the ICI bullet nose with the allowance of +/

- 1 inch, which is ensured by the quality control program required by the procurement specification and administered by the vendor at the time of manufacturing. Verifying that the detectors are positioned correctly within the ICI bullet nose assembly is not an attribute that would be performed by the licensee after receipt of the equipment. Unlike in-core detector testing and core performance testing where it is important to assure that the ICI bullet nose is in the proper location within the fuel assembly, the Fixed In

-Core Nuclear Signal Channel Test is performed by injecting test signals to ensure proper circuit processing. Based on this justification, it is not necessary to add a prerequisite to specify that the proper location of each in

-core detector is to be verified in DCD 14.2.12.1.26.

The NRC staff reviewed APR1400 DCD Section 14.2.12.4.16, "in

-core detector test," and determined the proposed objectives adequately describe proper operation of the in

-core instrumentation and CET. However, the prerequisites of this test do not specify that the proper location of each in

-core detectors are verified. Pending the resolution of these issues, RAI 198-8208, Question 14.02

-23 is tracked as Open Item 14.2.12.1

-13. 14.2.12.1.27 Digital Rod Control System; 14.2.12.1.36 Control Element Drive Mechanism Cooling System Test; 14.2.12.1.54 Pre

-Core Control Element Drive Mechanism Performance Test The NRC staff determined that the DC applicant needed to provide sufficient acceptance criteria to ensure adequacy of the test results for the tests described in DCD Sections 14.2.12.1.27, "Digital Rod Control System, 14.2.12.1.36, "Control Element Drive Mechanism Cooling System Test," 14.2.12.1.54, Pre

-Core Control Element Drive Mechanism Performance Test," and 14.2.12.2.4, "Post

-Core Control Element Drive Performance Test." The staff requested this information in NRC RAI 136-8081, Question 04.06

-02 (ML15227A013).

Additionally, NRC RAI 136

-8081, Question 04.06

-02 (ML15227A013) asked questions related to Section 14.2 preoperational testing of the CEDM. Specifically, the acceptance criteria reference in the digital rod control system ITP in Section 14.2.12.1.27 did not contain the referenced information, the acceptance criteria in the CEDM cooling system ITP in Section 14.2.12.1.36 did not specify the required system airflow rate or the system interlocks and 14-41 alarms, and the acceptance criteria referenced in the pre

-core control element drive mechanism performance test in Section 14.2.12.1.54 did not include coil temperatures.

In the September 14, 2015, response to RAI 136-8081, Question 04.06

-02 (ML15257A308), the DC applicant proposed changes to DCD Section 14.2.12.1.27, DCD Section 9.2.5.2.1.3, DCD Section 9.4.6.5.1 and DCD 14.2.12.1.54 to resolve the concerns. The NRC staff determined that these changes were acceptable because they correct the references in the ITP acceptance criteria and add the requested information to the relevant DCD sections. The revisions meet the testing guidance in RG 1.68, Appendix A, Section A-1b The DC applicant also updated the DCD Sections noted in RAI 136

-8081, Question 04.06

-02, with more clear and complete acceptance criteria. The proposed revisions to the DCD include: 1) deleted reference to DCD Subsections 4.6.1 and 4.6.2 from DCD Subsection 14.2.12.1.27 as these subsections do not apply to the preoperational test described in DCD Subsection 14.2.12.1.27; 2) added alarm set points and the interlock design of the CEDM cooling subsystem to DCD Subsection 9.4.6.2.1.3 and added indication and alarm of the CEDM cooling subsystem to DCD Subsection 9.4.6.5.1; 3) added CEDM coil temperature acceptance limit to DCD Subsection 14.2.12.1.54; and 4) added CEA withdrawal speed and CEDM coil resistance to the data requirements and clarified the acceptance criteria in DCD Subsection 14.2.12.2.4 to state that CEA withdrawal speed meets DCD Subsection 4.3.1.7. The NRC staff reviewed the DC applicant's response along with the updated information in the DCD sections noted above and determined that the information proposed to be added to the DCD would provide sufficient acceptance criteria to ensure that the functional design requirements covered by these tests will be verified before startup. The proposed changes also meet GDC 18 and RG 1.68, Appendix A, Section A

-1.b, "Reactivity Control Systems," Section A

-2, Initial Fuel Load and Pre

-Critical Tests," and Section A

-3, "Initial Criticality," and are acceptable. RAI 8081, Question 04.06

-02 is resolved and the changes to the DCD are being tracked as Confirmatory Items 14.2.12.1.27 and 14.2.12.2

-2. There were additionally changes, associated with RAI 8081, Question 04.06

-02, made to the DCD to address Section 14.2.12.1.54, "Pre

-Core Control Element Drive Mechanism Performance Test." These changes are discussed in Section 14.2.4.12.2 of this SER.

14.2.12.1.28 Reactor Regulating System Test The APR1400 DCD Tier 2, Section 14.2.12.1.28 describes the preoperational test for the Reactor Regulation System (RRS).

In NRC Question 14.02

-24 of RAI 198

-8208 (ML15245A546), the staff requested additional information regarding the pre

-requisites for the RRS test. Specifically, the NRC staff asked for clarification as to why the RRS test included software installation prerequisites that were not included for all systems that include software.

In the October 18, 2016, response to RAI 198-8208 Question 14.02

-24 (ML16292A856)

, the DC applicant summarized the following changes to APR1400 DCD Section 14.2:

For the software installation of the Plant Protection System (PPS), the ESF

-CCS, the FIDAS and the Reactor Power Cutback System (RPCS), DCD Sections 14.2.12.1.23, 14.2.12.1.24, 14.2.12.1.26 and 14.2.12.1.32 will be revised.

In addition, DCD Section 14.2.12.1 will be revised to add the software installation prerequisite for the following system tests: Boronometer Subsystem 14-42 (14.2.12.1.17), Process Radiation Monitor Subsystem (14.2.12.1.18), Gas Stripper Effluent Radiation Monitor Subsystem (14.2.12.1.19), Remote Shutdown Console (14.2.12.1.48), Diverse Protection System (DPS) (14.2.12.1.49), Process and Primary Sampling System (14.2.12.1.83), Hydrogen Mitigation System (14.2.12.1.101), Process and Effluent Radiological Monitoring System (14.2.12.1.106), Area Radiation Monitoring System (14.2.1.12.1.107), Seismic Monitoring Instrumentation System (14.2.12.1.127), Core Protection Calculator System (CPCS) (14.2.12.1.138), and the Diverse Indication System (DIS) (14.2.12.1.139).

The NRC staff determined that the DC applicant proposal to include software installation as prerequisites for all the systems that contain software meets 10 CFR 52.47(a)(2) for installation of I&C systems and the guidance in RG 1.68, Regulatory Guidance Position C.2, "Prerequisites for Testing," Appendix A, Section A

-1.j, "Instrumentation and Control Systems."

Therefore, RAI 8208, Question 14.2

-24 is resolved. The incorporation of the proposed markups into the next revision to the APR1400 DCD is being tracked as Confirmatory Item 14.2.12.1-14. 14.2.12.1.29 Steam Bypass Control System Test The APR1400 DCD Tier 2, Section 14.2.12.1.29, "Steam Bypass Control System Test," describes the initial test for the Steam Bypass Control System (SBCS).

APR1400 DCD Tier 2, Section 7.1.1.1.d describes the three signals generated for the two different modes of operation for the SBCS control of the turbine bypass valve, including the modulation mode, the quick opening mode, and a valve permissive signal mode.

The NRC staff reviewed the test methods specified in Item 3.0 of this test and could not determine where all the different modes of operation for the turbine bypass valves are tested. In NRC RAI 198

-8208, Question 14.02

-25 (ML15254A546), the NRC staff requested the DC applicant modify this test to include testing of the SBCS for all the modes described in APR1400 DCD Tier 2, Section 7.1.1.1.d.

In the June 22, 2016, revised response to RAI 198-8208, Question 14.02

-25 (ML16174A465), the DC applicant updated the test methods in DCD Section 14.2.12.1.29 to verify that the SBCS ITP tests the two different modes (the modulation mode and the quick opening mode) and the three types of control signals (the modulation signal, the quick opening signal, and the valve permissive signal). The NRC staff determined the DC applicant response meets 10 CFR Part 50, Appendix A, GDC 1 and RG 1.68, Appendix A, Section A

-1.j, "Instrumentation and Control Systems," and is acceptable to verify as

-installed SBCS components. Therefore, RAI 198-8208, Question 14.02

-25 is resolved and this change to the DCD is being tracked as Confirmatory Item 14.2

-12.1-15. 14.2.12.1.30 Feedwater Control System Test The APR1400 DCD Tier 2, Section 14.2.12.1.30 provides the preoperational test for the Feedwater Control System (FWCS).

In NRC RAI 198

-8028, Question 14.02

-26 (ML15254A546), the NRC staff requested the DC applicant to modify this test to include testing for the FWCS during all conditions described in APR1400 DCD Section 7.1.1.1.c.

In a January 4, 2017 response to RAI 198-8208, Question 14.02

-26 (ML17004A031), the DC applicant proposed changes to the objectives and acceptance criteria in DCD Tier 2 Subsection 14.2.12.1.30 "Feedwater and Auxiliary Feedwater Systems Test" to address the staff's concerns. The DC applicant also explained how the testing of the FWCS across all plant 14-43 conditions is covered by several tests, identified the test associated with each plant condition, and proposed a change to DCD Tier 2 Section 14.2.12.4.3,"Control Systems Checkout Test" to clearly describe that a test is performed to verify the flow percentage.

The NRC staff determined that the DC applicant's response and proposed revisions to the DCD provide objectives and acceptance criteria and meets 10 CFR Part 50, Appendix A, GDC 1 and RG 1.68, Appendix A, Section A

-1.j, "Instrumentation and Control Systems." RAI 198-8208, Question 14.02

-26 is resolved and the changes to DCD Tier 2 Sections 14.2.12.1.30 and 14.2.12.4.3 of the DCD are being tracked as a Confirmatory Item 14.2.12.1-60. 14.2.12.1.32 Reactor Power Cutback System Test The APR1400 DCD Section 14.2.12.1.32 describes the preoperational test for the Reactor Power Cutback System (RPCS).

In NRC RAI 198

-8208, Question 14.02

-27 (ML15254A546

), the NRC staff determined that these RPCS functions should be verified in this test and should be identified as test objectives.

The corresponding test method and acceptance criteria should support demonstrating how these functions are verified in the ITP.

The NRC staff requested that the DC applicant modify APR1400 DCD Section 14.2.12.1.32 to include this information.

In the November 8, 2016, response to RAI 1 98-8028, Question 14.02

-27 (ML16313A591), the DC applicant added objectives and prerequisites to DCD Section 14.2.12.1.32, "Reactor Power Cutback System Test," and updated the prerequisites in DCD Section 14.2.12.4.6, "Unit Load Rejection Test," to include assurance that the RPCS functions properly.

The NRC staff determined that with these updates to DCD Section 14.2.12.1.32 and DCD Section 14.2.12.4.6 are acceptable because the revised test methods provide adequate assurance that the RPCS functions properly, RPCS functions are captured in the test objectives and the test prerequisites define what must be accomplished before the tests are to be conducted. Therefore, the staff finds that the DC applicant meets 10 CFR Part 50, Appendix A, GDC 1 and RG 1.68 Appendix A, Section A

-1.j, "Instrumentation and Control Systems." Therefore, RAI 198-8208, Question 14.02

-27 is resolved and the proposed changes to the DCD are being tracked as Confirmatory Item 14.2.12.1

-16. 14.2.12.1.33 Fuel Storage and Handling system Test APR14000 DCD Tier 2, Section 14.2.12.1.33 provides the preoperational tests for the fuel handling and storage systems. In NRC RAI 181

-8011, Question 09.01.04

-4 (ML15244B159), the NRC staff asked the DC applicant to justify why the DC did not include a static load test at 125 percent rated load and a dynamic load test at 100 percent rated load for the refueling equipment in accordance with RG 1.68 Section A

-1.n. In the January 6, 2016, response to RAI 181-8011, Question 09.01.04

-4 (ML16006A568), t he DC applicant proposed adding the requested testing as Step 3.9.4 in DCD Subsection 14.2.12.1.33, "Fuel Handling and Storage System Test."

The NRC staff determined that by adding the rated load tests to the DCD, the DC applicant's response meets RG 1.68, Appendix A, Section A.

-1.n, "Fuel Storage and Handling Systems," and is acceptable. NRC RAI 181

-8011, Question 09.01.04

-4 is resolved and this change to the DCD is being tracked as Confirmatory Item 14.2.12.1

-10.

14-44 14.2.12.1.34 Auxiliary Feedwater System Test DCD Tier 2, Section 14.2.12.1.34 provides the initial test descriptions for the Auxiliary Feedwater System (AFWS).

In NRC RAI 198-82 08, Question 14.02

-28 (ML15254A546), the NRC staff requested that the DC applicant identify the test method item that verifies the AFWS response to manual controls, or alternatively that the applicant modify APR1400 DCD Section 14.2.12.1.34, "Auxiliary Feedwater System," to include this information.

In the June 30, 2016

, response to RAI 198-8208, Question 14.02

-28 (ML16182A548), the DC applicant upgraded DCD Section 14.2.12.1.34 with a revised test plan that included several changes to verify the AFWS response to several different manual, simulated and automatic controls.

Based on the proposed changes to APR1400 DCD Section 14.2.12.1.34 to include manual controls for the AFWS, the NRC staff determined that the issues identified in RAI 8208, Question 14.02

-28 are resolved. As such, the NRC staff finds the AFWS test described in DCD Section 14.2.12.1.34 verifies the as

-installed AFWS component and meets RG 1.68 Appendix A

-1.d and is acceptable; Therefore, NRC RAI 198

-8208, Question 14.02

-28 is resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.1-17. 14.2.12.1.37 Reactor Coolant Gas Vent System Test DCD Tier 2, Subsection 14.2.12.1.37 provides the initial test descriptions for the Safety Depressurization and Reactor Coolant Gas Vent System (RCGVS). The NRC staff determined that the acceptance criteria was incomplete and also referenced incorrect DCD design sections. In NRC RAI 175

-8034, Question 05.04.12

-9 (ML15295A499), the staff requested that the DC applicant correct the erroneous references to the acceptance criteria for the RCVGVS. In the May 4, 2016, response to RAI 175-8034, Question 05.04.12

-9 (ML16125A479), the DC applicant clarified that DCD Tier 2, Subsection 14.2.12.1.37 describes RCGVS testing, whereas DCD Tier 2, Section 14.2.12.1.3 describes testing of the safety depressurization of the POSRVs. Therefore, the applicant committed to revise the title of Subsection 14.2.12.1.37 to "Reactor Coolant Gas Vent System Test," and remove references to the POSRVs. The applicant provided a revised Subsection 14.2.12.1.37 that removed incorrect references to other parts of the DCD and now included acceptance criteria that clearly relate to the test objectives and methods. The NRC staff determined the revised preoperational test procedures and their acceptance criteria are adequate to verify RCGVS operation; therefore, the NRC staff determined that the response to RAI 175-8034, Question 05.04.12

-9 is acceptable. The proposed DCD changes are being tracked as Confirmatory Item 14.2.12.1

-18. 14.2.12.1.38 Containment Spray System Test DCD Tier 2, Subsection 14.2.12.1.38 provides the initial test descriptions for the Containment Spray System (CSS). The Section 5.0, Acceptance Criteria states:

14-45 1.1 The containment spray system and containment spray pumps perform as described in Subsection 6.2.2.2.

The NRC staff determined that the test method as written was too vague to meet 10 CFR Part 50, Appendix A, GDC 40 for the Containment Heat Removal System. Therefore, in NRC RAI 19-7899, Question 14.02

-01 (ML15152A518), the NRC staff requested that the test method be revised such that the test acceptance criteria in DCD Subsection 14.2.12.1.38 have items in the test methods that: (1) verify spray flow under minimum net positive suction head conditions, and (2) verify that static head as measured from the pumps ensures the design assumptions made in DCD Subsection 6.2.2.2 remain valid.

In the July 2, 2015 response to RAI 19-7899, Question 14.02

-1 (ML15183A077), the DC applicant made additions to the test methods in DCD Tier 2, Section 14.2.12.1.38. The NRC staff determined that the revisions are acceptable because the added test items clarify that the CSS system head requirements (i.e. characteristics such as frictional loss terms) are test acceptance criteria for the entire system and because the RAI response includes the static head of the as

-built pumps in the test method to meet the test assumptions for the analyses in DCD Chapter 6. Therefore, the staff concludes that the applicant meets the containment spray testing guidance in RG 1.68, Appendix A, Section A

-1.i, "Integrity of Systems Outside of Containment that Contain Radioactive Material for BWRs and PWRs."

RAI 19-7899, Question 14.02

-1 is resolved and the DCD changes are being tracked as Confirmatory Item 14.2.12.1-19. 14.2.12.1.39 Integrated Engineered Safety Features / Loss of Power Test DCD Subsection 14.2.12.1.39 provides the initial test descriptions for the integrated Engineering Safety Features (ESF)/loss of power test. In NRC RAI 198

-8208, Question 14.02-29 (ML15254A546), the NRC staff requested the DC applicant demonstrate how the ESF-CCS functions that mitigate loss of power to Class 1E buses are verified.

In addition, staff requested that the applicant demonstrate which test method verifies the test objective of demonstrating electrical redundancy, independence, and load group assignment.

In the August 17, 2016, response to RAI 198-8208, Question 14.02

-29 (ML16230A478), the DC applicant proposed changes to the test methods and acceptance criteria in DCD Tier 2, Section 14.2.12.1.39 to verify ESF

-CCS functions, electrical redundancy, independence and load group assignment, and EDG full load capability.

Based on the applicant's proposed changes, the NRC staff determined th e integrated ESF/loss of power test is adequate to verify the as

-built and as

-installed equipment to meet RG 1.68, Appendix A, Section A

-1.j, Instrumentation and Control Systems," and the requirements of Criterion XI of Appendix B to 10 CFR Part 50. As such, the NRC staff determined that the issues identified in RAI 198-8208, Question 14.02

-29 are resolved; therefore, this change to the DCD is being tracked as Confirmatory Item 14.2.12.1

-20. 14.2.12.1.41 Internals Vibration Monitoring Systems Test DCD Subsection 14.2.12.1.41 provides the initial test descriptions for the Internals Vibration Monitoring System (IVMS). In NRC RAI 198

-8208, Question 14.02

-30 (ML15254A546), the 14-46 NRC staff requested the DC applicant justify why operation of the ENFMS is not a prerequisite for the IVMS Test.

In the October 18, 2016

, response to RAI 198-8208, Question 14.02

-30 (ML16292A856), the DC applicant included the following:

Neutron flux signals from ENFMS are not needed to check the IVMS function for preoperational testing; rather, simulated neutron flux signals are used in accordance with Section 14.2.1.1, which states that simulated signals or inputs are used to demonstrate the full range of the systems that are used during normal operation.

and The acceptance criterion 5.2 in KHNP submittal MKD/NW 0156L for test plan 14.2.12.1.41 states that all 12 channels of ex

-core signals are received at the IVMS system as described in the related design specification...In performing the test, the 12 channels of the ex

-core simulated signals are generated from signal generators and transmitted by injecting into the Fiber Optic Transmitter (FOT) of the ENFMS and not directly into the IVMS The NRC staff determined that the DC applicant response provides adequate justification for why operation of ENFMS is not a prerequisite for the IVMS test and meets the testing guidance for nuclear instrumentation in RG 1.68, Appendix A, Section A

-1.j, "Instrumentation and Control;" therefore, it is acceptable. RAI 198-8208, Question 14.02-30 is resolved and no change to the DCD is required. 14.2.12.1.48 Remote Shutdown Console Test DCD Section 14.2.12.1.48 describes the remote shutdown console test which verifies the capability to shut down the reactor from the remote shutdown console. In NRC RAI 198

-8208, Question 14.02

-37 (ML15254A546), the NRC staff requested the DC applicant to demonstrate how the manual controls in the main control room (MCR) are verified in the ITP to meet the requirements of Criterion XI of Appendix B to 10 CFR Part 50.

In the June 22, 2016 response to RAI 198-8208, Question 14.02

-37 (ML16174A465), the DC applicant stated that:

Verifying the manual controls to control safety

-related equipment required to shut down the reactor are described in each subsection of the APR1400 DCD Section 14.2.12. DCD Tier 2, Section 14.2.1 will be revised to include the description that testing of manual controls for the capability to shut down the reactor will be performed from the MCR for safety

-related equipment.

Based on the NRC staff's evaluation of APR1400 DCD Section 14.2.12, it was not clear where manual controls to control safety

-related equipment are verified in this section. For example, it was not clear which test verifies the operation of the diverse manual ESF actuation (DMA). Further, there was no integrated test of the MCR manual controls (similar to the APR1400 DCD Section 14.2.12.48, Objective 1.2, "To determine transfer of control occurs and that the plant can be cooled down from the remote shutdown console") to verify that the plant can be cooled down. The applicant should submit a supplemental response to resolve these issues raised in 14-47 the RAI response. Pending the resolution of these issues, RAI 198-8208, Question 14.02

-37 is tracked as an Open Item 14.2.12.1

-22. 14.2.12.1.49 Diverse Protection System Test In NRC RAI 198

-8208, Question 14.02

-31 (ML15245A546), the NRC staff requested the DC applicant justify why all the automatic functions performed by the DPS were not verified in the DPS test described in APR1400 DCD Section 14.2.12.1.49. The objective of this test is to verify the proper operation of the DPS.

However, the test methods for this test only verified the operation of the RTSS trip circuit breaker and operation of the alternate auxiliary feedwater actuation signals using simulated input signals.

It was not clear to the NRC staff whether the simulated signals will be injected into the DPS.

The NRC staff requested the applicant to clarify this in the test methods description of this section. In addition, APR1400 DCD Tier 2, Section 7.8 and the referenced technical reports identified additional automatic safety actuation signals performed by the DPS.

The NRC staff requested the DC applicant to justify why these functions are not verified in this preoperational test.

In the June 20, 2016 response to RAI 198-8208, Question 14.02

-31 (ML16173A245), the DC applicant summarized the major DPS automatic actuation signal functions from DCD Section 7.8.1.1, such as the generation of reactor trip signal, turbine trip signal, auxiliary feedwater actuation signal (AFAS), and safety injection actuation signal (SIAS), that will be added to DCD Section 14.2.12.1.49. The applicant also determined that additional clarifications pertaining to the DPS signals, (in particular the turbine trip signal), and other editorial changes should be made to enhance the ITP.

In the October 7, 2016, response to RAI 198

-8208, Question 14.02

-31 (ML1628A223), the DC applicant clarified that the ITP for the DMA switches is addressed in DCD Section 14.2.12.1.23 (as shown in the proposed markups in the response to RAI 198-8208, Question 14.02-20 (ML16230A478).

The applicant also clarified that the ITP for the DIS is addressed in DCD Section 14.2.12.1.139 as shown in the revised DCD Section 14.2 markups submitted in February 24, 2016 (ML16056A003). Based on the above clarification and the review of the DIS and DPS ITPs included in the DCD Section 14.2 markups which address all of the functions of the DPS, the NRC staff finds that the response meets RG 1.68, Appendix A, Section A-1.j, "Instrumentation and Control Systems," and is acceptable; therefore, RAI 198-8208, Question 14.02

-31 is resolved and this change to the DCD is being tracked as Confirmatory Items 14.2.12.1

-23. 14.2.12.1.53 Pre

-Core Pressurizer Performance Test In NRC RAI 198

-8208, Question 14.02

-32 (ML15254A546), the NRC staff requested the DC applicant demonstrate how the operation of the low

-level interlock is verified in the pre

-core pressurizer performance test described in DCD Subsection 14.2.12.1.53.

In the June 20, 2016, response to RAI 198-8208, Question 14.02

-32 (ML16173A245), the DC applicant stated that:

All interlocks related to pressurizer pressure and level are verified by increasing and decreasing the pressure and level in the pre

-core pressurizer performance

14-48 test in DCD Section 14.2.12.1.53. Specifically, the pressurizer low

-level interlock signal, which is the pressurizer low level heater cutoff signal, turns all pressurizer heaters off. Once pressurizer level drops below the pressurizer low level heater cutoff setpoint (as specified in test method 3.6), verification of the interlock is made by operator actions in an attempt to turn all heaters on manually with the pressurizer low

-level interlock signal activated. If all the heaters are not able to be turned on at these conditions, the pressurizer low

-level interlock signal is considered valid. Additionally, DCD Tier 2, 14.2.12.1.53, test method 3.6 will be revised to clarify the specified level for the verification as indicated in the attached test abstract.

Based on the proposed revision to DCD Subsection 14.2.12.1.53, Test Method 3.6, the NRC staff determined the issues identified in RAI 198-8208, Question 14.02

-32 are resolved because DCD Subsection 14.2.12.1.53 will clearly indicate that the pressurizer level should be set below the low

-level interlock set point for this test. Therefore, operation of the low

-level interlock will be verified in the pre

-core pressurizer performance test. As such, the NRC staff determined that the pre

-core pressurizer performance test described in DCD Section 14.2.12.1.53 meets 10 CFR Part 50, Appendix A, GDC 1; 10 CFR Part 50, Appendix B, Criterion XI, "Test Control;" and RG 1.68, Appendix A, Section A-1.a, "Reactor Coolant System," and Section A

-1,j, "Instrumentation and Control Systems." RAI 198-8208, Question 14.02-32 is resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.1

-28. 14.2.12.1.54 Pre

-Core Control Element Drive Mechanism Performance Test In NRC RAI 198

-8208, Question 14.02

-33 ML15254A546), the NRC staff requested the DC applicant demonstrate how the test objective to verify proper operation and sequencing of the control element drive assembly (CEDM) is accomplished in the pre

-core CEDM performance test described in DCD Subsection 14.2.12.1.54.

In the June 20, 2016

, response to RAI 198-8208, Question 14.02

-33 (ML16173A245), the DC applicant stated that:

During the pre

-core CEDM performance test in DCD Section 14.2.12.1.54, the functions of the digital rod control system (DRCS) and the CEDM without CEA extension shaft are tested to verify that the CEDM operates in the proper power sequence with four CEDM coils for CEA insertion and withdrawal. In every insertion/withdrawal step operation, the sequence of the CEDM coil power for each CEDM is monitored by the power regulator of the DRCS power cabinets. The test includes a check to ensure that the DRCS trouble alarm is actuated if abnormal CEDM power is sensed or CEDM motion is stopped. The recorded CEDM coil trace is also used to verify that the coil traces for withdrawal and insertion motion occur in the proper sequence. Verification of the proper sequencing will be added to the Acceptance Criteria in the ITP for 14.2.12.1.54.

For the proper operation of the regulating control groups, the out

-of-sequence alarm is provided by the nuclear steam supply system (NSSS) application program of the Information Processing System (IPS). The out

-of-sequenc e alarm, which is different than the above mentioned DRCS trouble alarm, is tested 14-49 in Tier 2, Section 14.2.12.2.4 with the manual individual operation of each individual CEA when the other CEAs are positioned at the bottom of the core. For clarification, the out-of-sequence alarm test will be added to Tier 2, Section 14.2.12.2.4.

The NRC staff evaluated the proposed revisions to DCD Subsection 14.2.12.1.54 to add proper sequencing of the CEDM as an acceptance criterion and clarify that the direct current voltage across the shunt indicates the CEDM coil power trace and the proposed changes to DCD Subsection 14.2.12.2.4 to add an out

-of-sequence alarm test. The NRC staff determined that the above proposed revisions will provide verification of proper operation and sequencing of the CEDM.

As such, the NRC staff determined that the pre

-core CEDM performance test described in DCD Section 14.2.12.1.54 is acceptable to verify the as

-installed CEDM meets 10 CFR 50, Appendix A, GDC 1 and the guidance in RG 1.68; Appendix A, Section A

-1.b, "Reactivity Control Systems;" therefore, RAI 198-8208, Question 14.02

-33 is resolved and the proposed changes to the DCD are being tracked as Confirmatory Item 14.2.12.1

-29. 14.2.12.1.66 Steam Generator Blowdown System Test In NRC RAI 277

-8227, Question 14.02

-38 (ML15303A462), the NRC staff requested additional information about the objectives of the test, test methods and acceptance criteria for the preoperational testing plan for the Steam Generator Blowdown System (SGBS) to evaluate the plan in accordance with RG 1.68 Appendix A, Section A

-1.m. In the June 30, 2016, response to RAI 277-8227, Question 14.02

-38 (ML16182A554), the DC applicant proposed expanding DCD Subsection 14.2.12.1.66 with a new list of test objectives explicitly addressing valve operation, actuation signals, alarms, status lights, and flow path for secondary water processing. The DC applicant also proposed adding a list of acceptance criteria based on the specific design attributes described in DCD Section 10.4.8 ("Steam Generator Blowdown System"). In addition, the DC applicant proposed removing the resin regeneration requirement from the test plan since resin regeneration is not an SGBS function.

The NRC staff determined that these changes to DCD Subsection 14.2.12.1.66 are acceptable because the DC applicant updated the preoperational test objectives and acceptance criteria for the SGBS. Specifically, DCD Subsection 14.2.12.1.166 was updated to include six new SGBS test objectives and test acceptance criteria, including lists of several components (e.g., valves, interlocks, alarms, status lights, ESFAS and DPS response signals, etc.) which are functionally tested. Therefore, this DCD change meets RG 1.68; Appendix A, Section A

-1.m , "Radiation Protection Systems," page A

-16 related to testing steam generator blowdown; therefore, RAI 277-8227, Question 14.02

-38, is resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.1

-30. 14.2.12.1.80 Normal Lighting System Test To establish compliance with 10 CFR Part 50, Appendix A, GDC 17, the NRC staff issued NRC RAI 280-8220, Question 14.02

-44 (ML15306A016), which requested the DC applicant to discuss (1) how the normal lighting system test verifies that required electrical power supplies and control circuits are available or provide adequate justification that it is not needed and (2) confirm that when testing normal lighting systems, other lighting systems will be de

-energized in the rooms.

14-50 In the July 16, 2016, response to RAI 280-8220, Question 14.02

-44 (ML16198A009), the DC applicant noted that for the normal lighting system test, the power sources for the lighting distribution panels are energized and the circuit breakers for the panels are closed. This testing configuration verifies that required electrical power supplies and control circuits are available. According to the applicant, the normal lighting system is not important to safety and the requirements of GDC 17 and GDC 18 do not apply to this system. The emergency alternating current (ac) lighting system (EDG backed) is always turned on and combines with lighting supplied by non

-safety power to provide adequate illumination levels that support operation and maintenance activities during normal plant operation. Therefore, when testing the normal lighting, only the emergency dc lighting fixtures are not turned on. The applicant stated that DCD Section 14.2.12.1.80 will be revised to incorporate these clarifications.

The NRC staff reviewed the DC applicant's response to RAI 8220, Question 14.02

-44 and the planned update to DCD Section 14.2.12.1.80 and determined the normal lighting test, as described in the paragraph above, meets the guidance for testing normal lighting in RG 1.68, Appendix A, Section A

-1.g, "Electrical Systems," because the proposed change verifies that required electrical power supplies and control circuits are available.

The NRC staff agrees that the normal lighting system is not important to safety and therefore is not required to meet the requirements of GDC 17. As such, the NRC staff determined that the DC applicant's response is acceptable and therefore, RAI 280-8220, Question 14.02

-44 is resolved and the proposed DCD change is being tracked as Confirmatory Item 14.2.12

-31. 14.2.12.1.81 Emergency Lighting System Test To establish compliance with 10 CFR Part 50, Appendix A, GDC 17 and GDC 18, the NRC staff issued NRC RAI 280-8220, Question 14.02

-45 (ML15306A016), which requested that the DC applicant confirm the ability of the emergency lighting system by simulating a loss of the normal lighting and observing that the emergency system automatically activates. The NRC staff also requested the applicant discuss how this test verifies that required electrical power supplies and control circuits are available or provide adequate justification that it is not needed.

In the July 16, 2016, response to RAI 280-8220, Question 14.02-45 (ML16198A009), the DC applicant stated, in part that:

The ability of emergency dc lighting system is verified by simulating a loss of the normal lighting and observing that the emergency dc lighting system automatically activates. The emergency ac lighting system is always turned on and combines with the normal lighting system to provide adequate illumination levels during normal plant operation. Therefore, a loss of the normal lighting system causing an automatic activation is not simulated in the emergency ac lighting system test. For the emergency lighting system test, the power sources for the lighting distribution panels are energized and the circuit breakers for the panels are closed as stated in DCD Tier 2, Subsection 14.2.12.1.81, "Emergency Lighting System Test," 2.0 prerequisites. This test configuration verifies that required electrical power supplies and control circuits are available. DCD Tier 2, Subsection 14.2.12.1.81 will be revised to incorporate the clarification above

.

14-51 The NRC staff determined that DC applicant response to RAI 8220, Question 14.02

-45 for testing the emergency lighting system, as described in the paragraph above, is adequate because the proposed change verifies that required electrical power supplies and control circuits are available. The NRC staff also determined that the proposed revisions to DCD Subsection 14.2.12.1.81 meet the testing guidance for emergency lighting in RG 1.68, Appendix A, Section A

-1.g, "Electrical Systems," and is acceptable. RAI 280-8220, Question 14.02-45 is resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.1

-32. 14.2.12.1.84 Heat Tracing System Test In NRC RAI 57

-7965, Question 08.03.01

-4 (ML15189A490), the NRC staff requested the DC applicant to identify any safety

-related mechanical systems protected by Class 1E sources that require heat tracing and freeze protection to maintain process temperatures. The NRC staff requested that if there are any mechanical systems protected by Class 1E sources that need to be heat traced, the DC applicant should justify why non

-Class 1E power is used for the heat tracing circuits. The NRC staff also requested that the DC applicant describe equipment associated with the heat tracing/freeze protection system. Finally, DCD Subsection 14.2.12.1.84, "Heat Tracing System Test,"

does not mention verification of redundancy and electrical independence as acceptance criteria for the heat tracing system test.

Therefore, the NRC staff requested the DC applicant to describe how the redundancy and electrical independence will be verified for Class 1E equipment/systems during the initial testing phase.

In the August 19, 2015, response to RAI 57-7965, Question 08.03.01

-4 (ML15231A804), the DC applicant stated:

The heat tracing system mentioned in DCD Tier 2, Subsection 8.3.1.1.7 does not provide heat tracing or freeze protection for any safety

-related piping or equipment. Accordingly, Class 1E power is not provided.

Apart from the heat tracing system mentioned above, there are sample lines for containment air monitors in the process and effluent radiological monitoring system (PERMS, refer to DCD Tier 2, Subsection 11.5.2.2), which are equipped with local heat tracing to which Class 1E power is supplied.

The local heat tracing provided as part of PERMS and the heat tracing test for the sample lines will be performed along with other supporting systems of PERMS. Redundancy and electrical independence of the local heat tracing for PERMS will be verified by reviewing the PERMS detailed design before the initial testing phase for PERMS.

In order to clearly identify the local heat tracing test required for PERMS, KHNP will revise DCD Subsection 14.2.12.1.106.

The NRC staff determined that the DC applicant's response to RAI 57

-7965, Question 08.02.01-4 and the proposed revision to DCD Subsection 14.2.12.1.106 meets the testing guidance for heat tracing in RG 1.68, Appendix A, Section A

-1.o, "Auxiliary and Miscellaneous Systems," in that the proposed testing demonstrates operability and verifies redundancy and

14-52 electrical independence of the associated systems. RAI 57-7965, Question 08.03.01

-4 is resolved and the proposed DCD change is being tracked as Confirmatory Item 14.2.12.1

-33. 14.2.12.1.85 Fire Protection System Test As part of NRC Question 09.05.01

-33 in RAI 140

-8139 (ML15295A464), the NRC staff requested the DC applicant to revise DCD Subsection 14.2.12.1.85 to state that the initial fire protection systems' testing will be in accordance the criteria in the codes and standards referenced in DCD Subsection 9.5.1.

In the September 4, 2015, response to RAI 140-8139, Question 09.05.01

-33 (ML15247A253), the DC applicant stated:

DCD Subsection 14.2.12.1.85 will be revised to move the seven items listed under Tier 2, Subsection 14.2.12.1.85, "Fire Protection System Test," Item 3.0, "TEST METHOD," to Item 1.0,"OBJECTIVES" and under Item 3.0, "TEST METHOD," and the following statement will be added: "Demonstrate that the initial fire protection system testing is in accordance with the criteria in the codes and standards referenced in DCD Tier 2, Subsection 9.5.1, 'Fire Protection Program.

The NRC staff determined that this RAI response and the planned update to DCD Section 14.2.12.1.1.85 adequately meets the testing guidance for fire protection in RG 1.68, Appendix A, Section A

-1.o, "Auxiliary and Miscellaneous Systems," because it provides a requirement to verify that the initial fire protection system testing is in accordance with the criteria in the codes and standards referenced in DCD Subsection 9.5.1.

RAI 140-8139, Question 09.05.01

-33 is resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.1-34. 14.2.12.1.86 Emergency Diesel Generator Mechanical System Test In NRC RAI 191

-8210, Question 14.02-12 (ML15245A786), the NRC staff requested the DC applicant to upgrade DCD Section 14.2.12.1.86 to describe how the test verifies EDG and auxiliary system alarms, interlocks, and control functions and describe how the test demonstrates EDG responses consistent with GDC 17 and GDC 18.

In the June 28, 2016, response to RAI 191-8210, Question 14.02

-12 (ML16180A629), the DC applicant proposed to revise DCD Subsection 14.2.12.1.86 in its entirety to:

A) To verify that EDG diesel generator system alarms, interlocks, and control functions perform as designed, Items 1.1, 1.2, 3.2, 3.3, 4.1, 4.3, 4.5, 5.2, 5.3, 5.4, and 5.5 will be provided, as shown in the attachment to this response.

B) To verify how the mechanical and electrical trips, as listed in Subsection 8.3.1.1.3.3, "Tripping Devices" are demonstrated, Items 1.2, 3.3, 4.3, 4.5, and 5.4 will be provided, as shown in the attachment to this response.

C) For performing this test, "Prerequisites" Items 2.2 and 2.3 must be completed to verify that EDG instrumentation operates over the design range, as shown in the attachment to this response.

14-53 D) To verify that alarms and interlocks perform as designed, Items 1.2, 3.3, 4.3, 4.5, 5.4, and 5.5 will be provided, as shown in the attachment to this response. To verify that the EDG alarm occurs as designed, a simulated signal for each alarm is used during the testing.

To verify that interlocks occur as designed, a simulated trip signal is used during the testing. To test the operation of the interlock upon a normal trip signal, the following procedure is performed.

a) Simulate the normal trip signal, b) Start the EDG, c) Verify that the EDG does not start.

To test the operation of the interlock upon an emergency start signal, the following procedure is performed:

a) Simulate the emergency trip signal.

b) Attempt to stop the EDG when the EDG is operating, then verify that the EDG does not stop.

c) Simulate the normal trip signal, then verify that the EDG does not stop.

d) Detailed procedures will be described in the detailed design phase.

e) EDG instrumentation calibration is a prerequisites condition for testing of the EDG. Therefore, it is included as prerequisite condition Item 2.3.

f) Prerequisite condition item 2.3 ensures that EDG instrumentation response meets the accident analysis assumptions, such as time response, accuracy, and control stability.

g) To demonstrate an acceptable level of reliability of the EDG starting, reliability tests are performed by ensuring 25 consecutive tests without failures in accordance with IEEE 387, "Standard for Diesel

-Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations." The ability of the EDG to reliably start is verified through items 1.2, 3.3, 4.2, and 5.6 as shown in the attachment.

The NRC staff reviewed the proposed revision to DCD Subsection 14.2.12.1.86 and determined that the proposed revision is acceptable because it (1) provides an adequate level of detail to ensure that the test verifies EDG and auxiliary system alarms, interlocks, and control functions and (2) describes acceptable EDG responses consistent with GDC 17 and GDC 18 by verifying that onsite power systems provide sufficient capacity and capability. In addition, proposed DCD Subsection 14.2.12.1.86, with the clarification described in the following paragraphs, meets the guidance in Section 7.3, "Pre

-operational testing," of IEEE Std. 387

-1995 by requiring a minimum of 25 valid start and load tests without failure on each installed EDG. Therefore, RAI 191-14-54 8210, Question 14.02-12 is resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.1

-35. In RAI 515-8681, Question 14.02

-68 (ML16226A022), the NRC staff requested the DC applicant confirm that 25 consecutive tests without failures i s 25 start and load tests, in accordance with IEEE Std. 387

-1995 and confirm that the load tests are in accordance with IEEE Std. 387

-1995, Section 7.2.1.3, "Rated Load test."

In the October 7, 2016 response to RAI 515-8681, Question 14.02

-68 (ML16281A24 0), the DC applicant updated DCD Subsection 14.2.12.1.86, to replace "valid tests" with "valid start and load-run tests."

The NRC staff determined that the DC applicant response to RAI 515-8681, Question 14.02

-68 for testing EDG mechanical systems is acceptable because it clearly states the guidance of IEEE Std. 387

-1995 and meets GDC 17 and GDC 18; testing guidance in RG 1.68, Appendix A, Subsection A

-1.g, Item 3; and RG 1.9, which endorses IEEE 387

-1995. RAI 515-8681, Question 14.02

-68 is resolved and the proposed change to the DCD is being tracked as part of Confirmatory Item 14.2.12.1

-35. 14.2.12.1.87 Emergency Diesel Generator Electrical System Test In NRC RAI 191

-8210, Question 14.02

-13 (ML15245A786), the NRC staff requested the DC applicant revise DCD Section 14.2.12.1.87, "EDG Electrical System Test," to add the following two items:

a. Discuss whether this test verifies that EDG alarms, interlocks, and control functions are as designed and if so, how.

b. Adequate ventilation is necessary for the operation of EDGs. Discuss how adequate ventilation is verified before performing tests of the EDG.

In the June 28, 2016, response to RAI 191-8210, Question 14.02

-13 (ML16180A269), the DC applicant stated that the testing of EDG alarms, interlocks, and control functions is performed in accordance with DCD Subsection 14.2.12.1.86. The testing described in DCD Subsection 14.2.12.1.87 is performed when the EDG mechanical system test in DCD Subsection 14.2.12.1.86 is completed. The DC applicant also revised DCD Subsection 14.2.12.1.87 in its entirety to address how the test verifies the EDG electrical system. To address the NRC staff's question with regard to adequate ventilation for the EDG during operation, the DC applicant stated that the testing of the EDG area HVAC is provided in DCD Subsection 14.2.12.1.97, "Emergency Diesel Generator Area HVAC System Test."

The NRC staff determined that the DC applicant's response to RAI 191-8210, Question 14.02

-13, and the proposed revision to DCD Subsection 14.2.12.1.87 is acceptable because it provides adequate testing requirements for the EDG electrical system and meets the testing guidance in RG 1.68, Appendix A, Section A

-1.g, Electrical Systems. The applicant also adequately clarified how other tests address verification of EDG alarms, interlocks, and control functions and adequate EDG ventilation.

RAI 191-8210, Question 14.02

-13 is resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.1

-36.

14-55 14.2.12.1.88 Emergency Diesel Generator Auxiliary Systems Test In NRC RAI 191

-8210, Question 14.02

-14 (ML15245A786), the NRC staff requested the DC applicant to address why the EDG intake air and exhaust gas systems' ability to support full load capacity is not included in DCD Subsection 14.2.12.1.88 and to discuss how DCD Subsection 14.2.12.1.88 verifies that the starting air system is capable of achieving a single EDG start when the receiver is at the minimum receiver design pressure.

In the July 8, 2016, response to RAI 191-8210, Question 14.02

-14 (ML16190A355), the DC applicant stated that all of the EDG auxiliary systems are included in the EDG test package (i.e., 14.2.12.1.86) except for the emergency fuel oil system. To prevent redundancy in testing, the DC applicant added testing of all support systems, including air intake and exhaust, to DCD Subsection 14.2.12.1.86 (see RAI 191-8210, Question 14.02

-12 (ML16180A629)

). The DC applicant also revised DCD Subsection 14.2.12.1.88 in its entirety to only contain the test guidance for the emergency diesel fuel oil system. In response to the NRC staff question on the starting air system, the DC applicant that the EDG mechanical test (i.e., 14.2.12.1.86) will demonstrate that each air receiver is capable of providing five cranking cycles without being recharged, and thus capable of achieving EDG successful starts. According to the applicant, no further change to DCD Subsection 14.2.12.1.88 is necessary.

The NRC staff reviewed the proposed revisions to DCD Subsections 14.2.12.1.86 and 14.2.12.1.88 and determined that this response demonstrates that: 1) the EDG intake air and exhaust gas systems' ability to support full load capacity is tested in DCD Subsection 14.2.12.1.86; 2) the EDG fuel oil system is tested in DCD Subsection 14.2.12.1.88; and 3) and DCD Subsection 14.2.12.1.86 verifies that the starting air system is capable of achieving a single EDG start when the receiver is at the minimum receiver design pressure. Based on the above, the NRC staff determined that the DC applicant's proposed revisions are acceptable and meet the testing guidance for EDG sub

-systems in RG 1.68, Appendix A, Subsection A

-1.g, Item 3.

RAI 191-8210, Question 14.02

-14 is resolve d and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.1

-37. 14.2.12.1.103 Liquid Waste Management System Test The NRC staff determined that the test method and acceptance criteria in DCD Subsection 14.2.12.1.103 for the liquid waste management system (LWMS) was not fully described. In NRC RAI 194

-8172, Question 14.02

-17 (ML15246A077), the NRC staff requested the DC applicant to provide verification of manual and automatic response to normal control, alarms, and indication in the acceptance criteria of DCD Subsection 14.2.12.1.103.

In the September 24, 2016 response to RAI 194-8172, Question 14.02

-17 (ML16268A001), the DC applicant stated, in part, that:

The LWMS test objectives have been expanded from one general objective to four, more detailed objectives and eight new acceptance criteria have been incorporated. Among various items included in the revised test plan is verification of manual and automatic system controls on key system alarms including high

-level alarms associated with liquid tanks and other alarms such as radiation monitor and dual isolation valves , and includes those associated with the Detergent Waste Tank.

14-56 If a release from the Detergent Waste Tank exceeds the predetermined setpoint, an alarm is initiated, the discharge valve closes automatically, and the operator manually turns off the detergent waste pump and diverts the flow to the chemical waste tank. Though Section 14.2.12.1.103 does not specifically reference the Detergent Waste Tank liquid effluent release, it is part of the Liquid Waste Management System and is included in the test plan. The test plan is written to test all of the components in the system, including the associated Detergent Waste Tank components. Objectives 1.1, 1.2, and 1.3, Test Methods 3.1, 3.3, 3.5, and 3.6, and Acceptance Criteria 5.2, 5.5, 5.6 and 5.7 were written in general terms and also encompasses the process to adequately test the Detergent Waste Tank portion of the system.

The NRC staff reviewed the DC applicant response and proposed revisions to DCD Subsection 14.2.12.1.103 and determined that it provides an acceptable test method and acceptance criteria for the LWMS, including the Detergent Waste Tank. The NRC staff concluded that the proposed revision to DCD Subsection 14.2.12.1.103 meets the guidance for testing the LWMS in RG 1.68, Appendix A, Section A.1.m.

RAI 194-8172, Question 14.02

-17 is resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.1

-38. 14.2.12.1.89 Alternate AC Source System Test; 14.2.12.1.90 Alternate AC Source Support Systems Test The NRC staff determined that DCD Subsections 14.2.12.1.89 and 14.2.12.1.90 did not provide sufficient detail to demonstrate that the AAC GTG can obtain rated voltage and frequency within 2 minutes after the receipt of a starting signal. In NRC RAI 191

-8210, Question 14.02

-11 (ML15245A786), the NRC staff requested the DC applicant discuss the specific mechanical and electrical trips, indications, alarms, and number of starts required. Furthermore, the DC applicant was asked to discuss, a) how adequate ventilation is assessed, b) how the continuous rating is verified, c) how the time requirements are verified for reaching required voltage and frequency, d) how these tests verify that upon a simulated station blackout (SBO) that the GTG starts from standby to energize the buses, e) how these tests demonstrate the capability to reject a loss of the largest single load, and f) how these tests demonstrate the ability to synchronize the GTG with offsite power while loaded upon a simulated restoration of offsite power.

In the October 5, 2016, response to RAI 191-8210, Question 14.02

-11, (ML16279A508), the DC applicant proposed to revise in its entirety DCD Subsections 14.2.12.1.89 and 14.2.12.1.90 to include: 1) assessment of adequate ventilation; 2) verification of continuous rating; 3) verification of time requirements for reaching required voltage and frequency; 4) verification that upon a simulated SBO that the GTG starts from standby to energize the buses; 5) demonstration of the capability to reject a loss of the largest single load; 6) demonstration of 14-57 the ability to synchronize the GT G with offsite power while loaded upon a simulated restoration of offsite power; 7) demonstration of the adequacy and operation of the fuel systems; 8) demonstration of the operation of the lube oil and cooling systems; and 9) demonstration of the operation of the exhaust/intake system.

The NRC staff determined that the DC applicant's response to RAI 191-8210, Question 14.02

-11 and the proposed revisions to DCD Subsections 14.2.12.1.89 and 14.2.12.1.90 related to testing the AAC GTG is acceptable because it addresses the specific concerns raised in the RAI and provides sufficient detail to demonstrate that the AAC GTG can obtain rated voltage and frequency within 2 minutes after the receipt of a starting signal. Based on the above, the NRC staff determined that the proposed revisions to DCD Subsections meet 10 CFR Part 50, Appendix A, GDC 17 and 18, and RG 1.68, Appendix A, Section A

-1.g, Item 3. RAI 191-8210, Question 14.02

-11 is resolved and these proposed changes to the DCD are being tracked as Confirmatory Item 14.2.12.1

-39. In NRC RAI 8711, Question 14.02

-71 (ML16319A337), the NRC staff requested the DC applicant discuss how the initial test program in DCD Tier 2 Section 14.2.12.1.89, demonstrates that the AAC GTG and its supporting systems can be started, controlled, and monitored from the RSR to cope with an SBO.

RAI 8711, Question 14.02

-71 is being tracked as Open Item 14.2.12

-1.40. 14.2.12.1.99 Compound Building HVAC System Test; 14.2.12.1.132 Auxiliary Building Controlled Area HVAC System Test In NRC RAI 281-8232, Question 14.02

-47 (ML15306A018), the NRC staff requested the DC applicant to update DCD Sections 14.2.12.1.99, "Compound Building HVAC [Heating, Ventilation and Air Conditioning] System Test," and 14.2.12.1.132, "Auxiliary Building Controlled Area HVAC System Test," to provide for testing to verify the airflow rate acceptance criteria provided in DCD Table 12.2

-26. The HVAC system airflow rates provided in this table are airflow rates relied upon to provide reasonable assurance that airborne concentrations remain below derived airborne concentration (DAC) limits.

In the June 15, 2015, response to RAI 281-8232, Question 14.02

-47 (ML16167A537), the DC applicant added acceptance criteria to DCD Sections 14.2.12.1.99 and 14.2.12.1.132, to ensure that the ITP provides for testing of the Compound Building HVAC system and the Auxiliary Building controlled area HVAC system to maintain exhaust airflow rates from the radiologically controlled rooms at a minimum to the HVAC flows in DCD Table 12.2

-26. The staff determined that the DC applicant's response to RAI 281-8232, Question 14.02

-47 and the proposed revision to Subsections 14.2.12.1.99 and 14.2.12.1.132 meets the testing guidance in RG 1.68, Appendix A, Section A

-1.m, for minimum exhaust airflow rates from these radiologically controlled rooms in accordance with DCD Table12.2

-26 and therefore, is acceptable. RAI 281-8232, Question 14.02

-47 is resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.1

-48.

14-58 14.2.12.1.101 Hydrogen Mitigation System Test; 14.2.12.1.103 Liquid Waste Management System Test In NRC RAI 283

-8229, Question 14.02

-62 (ML15306A269), the NRC staff requested the DC applicant to address why DCD Subsection 14.2.12.1.103 and 14.2.12.1.105 did not identify specific test methods or acceptance criteria for SSCs that are non

-safety related but risk significant. The NRC staff also requested the following information:

1. Provide a description of what key SSCs would be identified by the Expert Panel for index numbers 184 and 375.

2. Provide a description of the testing method to verify the operation of the Gaseous Radwaste System

- Containment Isolation Valve in section 14.2.12.1.105 or wherever applicable.

3. Provide a description of the testing method to verify the operation of 'key SSCs' in the Gaseous Waste Management System in 14.2.12.1.105 or wherever applicable.

4. Provide a description of the testing method to verify the operation of 'key SSCs' in the Liquid Waste Management System in section 14.2.12.1.103 or wherever applicable.

5. Please address these items and provide a markup for the proposed DCD changes.

In the October 26, 2016, response to RAI 283-8229, Question 14.02

-62 (ML16300A432

), the DC applicant provided the following:

1. The Expert Panel considered PRA importance and deterministic method to identify the Key SSCs. The gaseous waste management system (GWMS - 184) and the liquid waste management system (LWMS

- 375) were identified by deterministic consideration. These systems are those that are designed to maintain radwaste materials contained within the system boundary to prevent spreading of radwaste materials outside of the defined boundary. As shown in Table 17.4

-1, the specific SSCs identified by the Expert Panel for GWMS and LWMS included only the containment isolation valves (Level 2) because GWMS and LWMS are not credited in the PRA model except for the containment isolation valves.

2.- 4. As a result of the upgrade effort described in the original response (ref. KHNP submittal MKD/NW-16-0156L "Submittal of Revised DCD Section 14.2 Initial Plant Test Program" dated February 24, 2016; ML16056A003), the contents of Section 14.2.12.1.103 and 14.2.12.1.105 of DCD Tier 2 has been generally enhanced. The preoperational test for liquid and gaseous waste management system has also included the description for testing of the key system control, alarms and indications in accordance with RG 1.68 as required by sub

-questions 2 through 4 of this RAI. The revised Sections 14.2.12.1.103 and 14.2.12.1.105 including previous markups are provided in the Attachment for clarity.

Since the test for the containment isolation valve operation of gaseous radwaste system will be performed in accordance with Section 14-59 14.2.12.1.129, Section 14.2.12.1.105 will be revised as indicated in Attachment to this response. Section 14.2.12.1.129 was previously revised to address the CIV, (also submitted by MKD/NW 0156L), and is provided in the Attachment for information.

The NRC staff determined that the DC applicant's response to RAI 283-8229, Question 14.02

-62 and the proposed revisions to DCD Subsections 14.2.12.1.103 and 14.2.12.1.105 are acceptable because they (1) adequately identify the non-safety but risk significant SSCs in the GWMS and LWMS for the reasons stated by the applicant, and (2) provide sufficient test methods and acceptance criteria for SSCs that are non

-safety but risk significant. Based on the above, the NRC staff determined that the proposed revisions are acceptable and meet the LWMS and GWMS testing guidance in RG 1.68, Section A

-1.m. The staff's general evaluation of the post

-upgrade test descriptions is discussed in the beginning paragraphs of SER Section 14.2.4.12.

RAI 283-8229, Question 14.02

-62 is resolved and the proposed changes to the DCD are being tracked as Confirmatory Item 14.2.12.1

-41. The NRC staff concluded that the test method provided in DCD Subsection 14.2.12.1.103 for testing the features of the LWMS did not test the system as a whole as it did not functionally test the radiation detector. In NRC RAI 283

-8229, Question 14.02

-63 (ML15306A269), the NRC staff requested the DC applicant to address the use of a radiation source in testing the system features, controls alarms, indicating instrumentation, and status lights are functional for the LWMS. In the October 5, 2016, response to RAI 283-8229, Question 14.02

-63 (ML16279A542), the applicant provided the following:

Since the LWMS discharge radiation monitor is considered as a part of the Process and Effluent Radiological Monitoring System (PERMS), the test for the radiation monitor, including the functionality of the detector, alarms, status lights, etc., will be performed in accordance with Section 14.2.12.1.106. The DCD Section 14.2.12.1.103 pertains to the verification that the LWMS discharge valve closes and pump operation stops upon receipt of a high radiation signal from the radiation monitors. One of the changes proposed in the referenced upgrade of 14.2.12.1.103 was to include a reference to Section 14.2.12.1.106 in the ITP related to the test method of the radiation monitor.

A radiation check source cannot be used to verify the monitor alarm set points and radiation level indications. Verification of the alarm set points and radiation level indications will normally be accomplished periodically using an appropriate calibration source. A simulated radiation signal will be used to replicate the radiation level required to test the BOP ESFAS signals and RMS alarm functionality. Since the LWMS radiation monitors are tested with a radiation check source as part of an ITAAC, they do not need to be re

-tested with a radiation check source as part of the ITP. DCD Tier 2, Subsection 14.2.12.1.106 will be revised to consistently refer to a simulated signal that is to be used for the testing of the radiation monitors.

The NRC staff determined that the above DC applicant response is slightly flawed. The GRS radiation monitors are tested with a radiation check source under both the ITAAC and the ITP preoperational test; therefore, this test should be performed and counted once under both the 14-60 ITAAC and the ITP preoperational test. The NRC staff determined that this response does not meet RG 1.68 because the DC applicant needs to change this response to note that the ITAAC will also be counted under the ITP preoperational test using a radiation check source to test the radiation monitors; therefore, RAI 283-8229, Question 14.02

-63 is not resolved and this is Open Item 14.2.12.1

-42. 14.2.12.1.104 Solid Waste Management System Test In NRC RAI 193

-8181, Question 14.02

-16, the NRC staff requested the DC applicant to revise DCD Subsection 14.2.12.1.104 acceptance criteria to include verification of manual and automatic response to normal control, alarms, and indications for the SWMS.

In the June 16, 2016, response to RAI 193-8181, Question 14.02

-16 (ML16168A467), the DC applicant proposed revisions to DCD Subsection 14.2.12.1.104 to add a cross reference to DCD Table 11.4

-6 where the following indications from the Rad

-Waste Storage Room were added to the test:

1. Tank level, tank pressure, and demineralized water inlet flow rate of the Low

-Activity Spent Resin Bed.

2. Tank level of the Spent Resin Long

-Term Storage Tank.

3. High alarms for tank level of the Low

-Activity Spent Resin Tank and Spent Resin Long-Term Storage Tank.

The NRC staff determined that the proposed revision to DCD Subsection 14.2.12.1.104 is acceptable because it provides acceptance criteria for the verification of manual and automatic response to normal control, alarms and indications for the SWMS. Based on the above, the NRC staff determined that the proposed DCD revision meets RG 1.68, Appendix A, Section A

-1.m, .RAI 193-8181, Question 14.02

-16 is resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.1

-45. 14.2.12.1.105 Gaseous Waste Management System Test The NRC staff concluded that the test method provided in DCD Subsection 14.2.12.1.105 for testing the features of the GWMS did not test the system as a whole as it did not functionally test the radiation detector. In NRC RAI 283

-8229, Question 14.02

-64 (ML15306A269), the NRC staff requested the DC applicant to address the use of a radiation source in testing the system features, controls alarms, indicating instrumentation, and status lights for the GWMS to verify that they are functional.

In the October 5, 2016, response to RAI 283-8229, Question 14.02

-64 (ML16169A371), the DC applicant stated:

Since the GRS [Gaseous Radiation System] discharge radiation monitor is considered a part of the Process and Effluent Radiological Monitoring System (PERMS), the test for the radiation monitor, including the functionality of the detector, alarms, status lights, etc., will be performed in accordance with Section 14.2.12.1.106. DCD Section 14.2.12.1.105 pertains to the verification that the GRS discharge valve closes upon receipt of a high radiation signal from the 14-61 radiation monitors. One of the changes proposed in the referenced upgrade of 14.2.12.1.105 was to include a reference to Section 14.2.12.1.106 in the ITP related to the test method of the radiation monitor. A radiation check source cannot be used to verify the monitor alarm set point and radiation level indication. Verification of the alarm set point and radiation level indication will normally be accomplished periodically using an appropriate calibration source. A simulated radiation signal will be used to replicate the radiation level required to test the BOP ESFAS signals and RMS alarm functionality. Since the GRS radiation monitors are tested with a radiation check source as part of an ITAAC, they do not need to be re

-tested with a radiation check source as part of the ITP.

The NRC staff determined the GRS radiation monitors are tested with an actual radiation signal under both the ITAAC and the preoperational test ITP; therefore, this test should be performed and counted once under both the ITAAC and the ITP preoperational test. The NRC staff determined that these responses do not meet RG 1.68. The DC applicant needs to update the response to this test to note that the ITP preoperational test will use a radiation check source to test radiation monitors; therefore, RAI 283-8229, Question 14.02

-64 is not resolved and this is Open Item 14.2.12.1

-43. In NRC RAI 192

-8180, Question 14.02

-15, the NRC staff requested the DC applicant revise the DCD Subsection 14.2.12.1.105 to include verification of manual and automatic response to normal control, alarms, and indications.

The applicant responded to this RAI on the April 7, 2016. However, the NRC staff determined that the April 7, 2016 response to RAI 192-8180, Question 14.02

-15 (ML16098A297), did not include adequate information for the NRC staff to complete its evaluation.

This is Open Item 14.2.12.1-44. 14.2.12.1.106 Process and Effluent Radiological Monitoring System Test In NRC RAI 195

-8182, Question 14.02

-18 (ML152534A346), the NRC staff requested the DC applicant to revise DCD Subsection 14.2.12.1.106 to include verification of manual and automatic response to normal control, alarms, and indications for the PERMS.

The applicant responded to this RAI on the March 29, 2016. However, in the NRC staff's review of the March 29, 2016, response to RAI 195-8182, Question 14.02

-18 (ML16089A514), the NRC staff determined that the DC applicant did not revise the test methods, data requirements and acceptance criteria to address the system's monitoring and signal generation when the radiation level detected exceeds the preset levels in accordance with the system design criteria and the description in DCD Section 11.5. The NRC staff determined that NR C RAI 195-8182, Question 14.02

-18 is not resolved and this issue is being tracked as Open Item 14.2.12.1

-46.

14-62 14.2.12.1.106 Process and Effluent Radiological Monitoring System Test; 14.2.12.1.107 Area Radiation Monitoring System Test The DCD Sections 14.2.12.1.106 and 14.2.12.1.107 indicate that simulated signals will be used to test control actions and alarms, instead of using a calibration source.

In NRC RAI 281

-8232, Question 14.02

-50 (ML15306A018), the NRC staff requested the DC applicant to:

1. Revise the ITP in order to test the functionality of the radiation monitor computer system in order to ensure that radiation levels, alarms, and control actions are properly being communicated between the radiation monitors, the monitor computer system, the main control room, and any applicable system actuation with a radiation calibration source, or justify why the use of simulated signals is acceptable.

2. Update DCD Sections 14.2.12.1.106 and 14.2.12.1.107, to test the control functions or alarms associated with high radiation levels with a radiation calibration source, or justify why the use of simulated signals is acceptable.

In the June 15, 2016, response to RAI 281-8232, Question 14.02

-50 (ML16167A537), the DC applicant stated, in part that:

1. -The advantage of using a simulated test signal is the ability to adjust the signal level to check various actuation set

-points such as alarm set

-points and interlock set

-points. This adjustability is not readily available with a radioactive check source, which generally provides just a fixed level and for this reason, sections 14.2.12.1.106 and 14.2.12.1.107 describe tests using a simulated test signal. The functionality check of the system using the simulated test signal is more suitable for the intended test. In conjunction with the use of a simulated signal for verification of the set

-point for the alarm and radiation level, the calibration source is used to verify the calibration/drift of the detector sensor during the periodic surveillance functional test period of the radiation monitor.

2. In accordance with the discussion provided in Item (1) above, the use of a simulated test signal is suitable for the intended test.

The NRC staff's review of the response to RAI 281-8232, Question 14.02

-50, concluded that all radiation monitors should be tested with a radiation check source.

The NRC staff determined that the above response is not acceptable and the DC applicant should consider revising its response to use a radiation check source to verify that radiation monitors are functional under the ITP to meet the testing guidance in RG 1.68, Appendix A, Section A

-1.k, "Radiation Protection Systems." Therefore, RAI 281-8232, Question 14.02

-50 is not resolved and this is Open Item 14.2.12.1

-51. 14.2.12.1.107 Area Radiation Monitoring System Test In NRC RAI 281

-8232, Question 14.02

-46 (ML15306A018), the NRC staff requested the DC applicant include preoperational testing of the area radiation monitors. Testing was provided for the airborne radiation monitors. The DC applicant was asked to include area radiation testing or provide justification why it is unnecessary.

14-63 In the June 30, 2016, response to RAI 281-8232, Question 14.02

-46 (ML16182A588), the DC applicant indicated that the airborne radiation monitors are part of the process and effluent radiological monitors (airborne monitors) that are tested under test 14.2.12.1.106. The applicant revised the title of test 14.2.12.1.107 in Table 14.2

-1, to delete the airborne monitors and specify testing of the area radiation monitoring system.

The NRC staff determined that the DC applicant's response to RAI 281-8232, Question 14.02

-46 and the proposed revision to Table 14.2

-1 meets the testing guidance for area and airborne radiation testing in RG 1.68, Appendix A, Section A

-1.m, "Radioactive Waste Handling and Storage Systems," to demonstrate operability of these radiation monitoring systems and therefore, is acceptable. The NRC staff considers RAI 281-8232, Question 14.02

-46 is resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.1-47. 14.2.12.1.108 4,160V Class 1E Auxiliary Power System Test DCD Tier 2 Section 14.2.1.12.1.108, Revision 0, stated that the preoperational test will verify the 4,160V and 480V safety

-related systems load shed as designed on undervoltage. In NRC RAI 282-8238, Question 14.02

-59 (ML15306A232), the NRC staff requested the DC applicant discuss whether this included degraded voltage conditions and loss-of voltage conditions to meet Appendix A to 10 CFR Part 50, Criterion 17, "Electric power systems" and Criterion 18, "Inspection and testing of electric power systems," for the 4.16kV and 480V safety

-related systems. Specifically, GDC 17 requires onsite and offsite power systems to provide sufficient capacity and capability to permit functioning of SSCs that are important to safety, and GDC 18 requires the testing of electric power systems that are important to safety.

In the August 16, 2016, response to RAI 282-8238, Question 14.02

-59 (ML16230A116), the DC applicant proposed to clarify the test methods and acceptance criteria and to keep consistency with DCD Chapter 8, "Electric Power," as well as the other subsections of Chapter

14. Specifically, DCD Tier 2, Subsection 14.2.12.1.108 was revised to incorporate in Test Method 3.4, a clarification that load shedding of the 4.16 kV safety loads occurs on undervoltage conditions (i.e., loss of voltage and degraded voltage condition) of the switchgear. DCD Tier 2, Subsections 14.2.12.1.109 (480 V Class 1E) and 14.2.12.1.113 (480 V non-Class 1E) and Tables 14.2

-1 and 14.2

-7 were also revised to reflect this testing.

The NRC staff reviewed the DC applicant's response and determined that the proposed update to add electrical system test methods and acceptance criteria to DCD Section 14.2.1.1.108 and Subsections 14.2.12.1.109 (480 V Class 1E) and 14.2.12.1.113 (480 V non

-Class 1E) and Tables 14.2

-1 and 14.2

-7 is acceptable because it clarifies that loss of voltage and degraded voltage conditions are included in the tests. Therefore, the staff concludes that the revised description of the electrical system testing will meet 10 CFR Part 50, Appendix A, GDC 17 and GDC 18, and the testing guidance in RG 1.68, Appendix A Section A

-1g. Therefore, the NRC staff considers RAI 282-8238, Question 14.02

-59 resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.52

. 14.2.12.1.110 Unit Main Power System Test The DCD Tier 2 Section 14.2.1.12.1.110 discusses the Unit Main Power System Test. Test Method 3.6 states, "verify the operation of interlocks, alarms, and protective relays." In NRC 14-64 RAI 282-8238, Question 14.02

-57 (ML15306A232), the NRC staff requested the DC applicant discuss how this test verifies that the backup relay protection scheme works for simulated single failures by verifying operation of the primary and backup relay systems in order to meet the regulatory requirements of GDC 17 for onsite and offsite power systems to provide sufficient capacity and capability to permit functioning of SSCs that are important to safety and GDC 18 for the testing of electric power systems that are important to safety.

In the August 16, 2016, response to RAI 282-8238, Question 14.02

-57 (ML16230A116), the DC applicant stated that, after a more detailed review of the ITP for the electrical items, the DC applicant developed a general revision of DCD Tier 2, Subsections 14.2.12.1.108 through 14.2.12.1.116 to clarify the test methods and acceptance criteria and to keep consistency with DCD Tier 2 Chapter 8 as well as the other subsections of Chapter 14. The DC applicant also stated: Protection of the major components (e.g., main generator, main transformer, and unit auxiliary transformers) of the unit main power system is provided by three multifunction protective systems (MPSs).

When a protective function in one MPS detects a fault, the MPS provides a signal (e.g., trip and/or alarm) for operation of a lockout relay and associated protective equipment.

The MPSs of major components are provided with a two

-out-of-three (2oo3) coincidence logic in order to preclude spurious operation of protective equipment due to any erroneous operation of any single MPS and to provide reasonable assurance o f secure operation of the protective equipment under a fault condition.

Upon receipt of at least two individual signals out of three MPSs, the lockout relay is energized and trips the associated protective device(s).

In the preoperational tests phase, operation of the protection scheme is checked and verified by circuit operational tests, which ensure the relay protection scheme works in the event of a single failure.

The revised DCD Tier 2, Subsections 14.2.12.1.110 were included in an enclosure of th e DC applicant's letter (Reference KHNP submittal MKD/NW 0156L, dated February 24, 2016; ML16056A002).

The NRC staff reviewed the DC applicant's response and the revision to DCD Section 14.2.12.1.110 and determined that the more detailed test methods and acceptance criteria for the Unit Main Power System Test meets the regulatory requirements for electrical systems in Appendix A to10 CFR Part 50, GDC 17 and GDC 18, and the testing guidance in RG 1.68, Appendix A, Section A

-1.g, Electrical Systems." Specifically, the proposed testing verifies that the backup relay protection scheme works for simulated single failures by verifying operation of the primary and backup relay systems in order to meet the regulatory requirements of GDC 17 for onsite and offsite power systems to provide sufficient capacity and capability to permit functioning of SSCs that are important to safety and GDC 18 for the testing of electric power systems that are important to safety. Therefore, the NRC staff considers RAI 8238, Question 14.02-57 resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.1

-53.

14-65 14.2.12.1.111 13,800V Normal Auxiliary Power System Test The DCD Tier 2, Section 14.2.1.12.1.111, "13,800V Normal Auxiliary Power System Test,"

discusses the 13,800 V normal auxiliary power system test. In NRC RAI 282

-8238, Question 14.02-58 (ML15306A232), the NRC staff requested the DC applicant discuss how this test verifies the alignment of the 13.8kV buses to the alternate offsite supply, upon a loss of normal offsite power supply in order to meet the regulatory requirements of GDC 17 for onsite and offsite power systems to provide sufficient capacity and capability to permit functioning of SSCs that are important to safety and GDC 18 for the testing of electric power systems that are important to safety.

In the August 16, 2016, response to RAI 282-8238, Question 14.02

-58 (ML16230A116), the DC applicant proposed a general revision of DCD Subsections 14.2.12.1.108 (4.16 kV Class 1E), 14.2.12.1.111 (13.8 kV non

-Class 1E), and 14.2.12.1.112 (4.16 kV non

-Class 1E) to incorporate changes that will comprise the test methods and acceptance criteria for the automatic bus transfer tests. Detailed procedures for the bus transfer tests for the 4.16 kV and 13.8 kV auxiliary power systems will be developed and provided by the COL applicant as specified by COL action item 14.2(2).

The NRC staff reviewed and determined that the DC applicant's response adequately incorporates testing for automatic bus transf er s in accordance with the regulatory requirements for electrical systems in Appendix A to 10 CFR Part 50, GDC 17 and GDC 18, and the test guidance in RG 1.68, Appendix A, Subsection A.1.g, "Electrical System

," for DCD Subsections 14.2.12.1.108, 14.2.12.1.111 and 14.2.12.1.112

. Therefore, the NRC staff considers RAI 282-8238, Question 14.02

-58 resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.1

-54. 14.2.12.1.114 Non

-Class 1E DC Power Systems Test The DCD Tier 2, Section 14.2.12.1.114, discusses the non

-Class 1E DC Power Systems Test. Test Methods 3.1, 3.2 and 3.3 for the batteries and battery chargers of the 125Vdc, 250Vdc, and alternate AC 125Vdc power systems, respectively. Each states that the battery discharge and charging tests will be performed. In NRC Question RAI 282

-8238, 14.02

-55 (ML15306A232)

, the NRC staff requested the DC applicant to discuss the tests for the battery chargers to verify that the battery charger DC output meets design criteria in order to meet the regulatory requirements in Appendix A to 10 CFR Part 50, GDC 17 for onsite and offsite power. In the August 16, 2016, response to RAI 282-8238, Question 14.02

-55 (ML16230A116), the applicant proposed a revision of Subsection 14.2.12.1.114, to specify the discharge test stated in Test Method 3.1.1 is for the batteries and the charging test stated in Test Method 3.1.2 is for the battery chargers. There will be related items to verify that the battery charger DC output meets design criteria included in the following Parts of the test: Objectives 1.3, 1.8, and 1.9; Test Methods 3.1.2 and 3.5; Data Required 4.2; and Acceptance Criteria 5.2, 5.4, 5.5, and 5.6.

The NRC staff reviewed the DC applicant's response and the upgrade to DCD Section 14.2.12.1.114 and determined that the more descriptive test methods and acceptance criteria adequately verifies that the battery charger DC output meets design criteria, and therefore meets the regulatory requirements for electrical systems in Appendix A to 10 CFR Part 50, GDC 17 and the test guidance for electrical systems in RG 1.68 Appendix A, Section A.1.g.

14-66 Therefore, the NRC staff considers RAI 282-8238, Question 14.02

-55 resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.1

-55. 14.2.12.1.115 Class 1E DC Power System Test In NRC RAI 282

-8238, Question 14.02

-56 (ML15306A232), the NRC staff requested the DC applicant to revise DCD Section 14.2.12.1.115, "Class 1E DC Power Systems Test," to (1) clarify whether this test demonstrates the Class 1E DC power systems is capable of performing as designed in the required operating modes; (2) modify Test Method 3.1 to discuss battery charger tests to verify that the battery charger DC output meets design criteria; (3) discuss how the electrical independence and redundancy of power supplies for safety

-related functions are checked for the Class 1E DC power system; and (4) discuss how this test determines that the voltage that would be available at the Class 1E inverters would exceed the design minimum if the batteries were discharged to the minimum voltage limit.

In the August 16, 2016, response to RAI 282-8238, Question 14.02

-56 (ML16230A116), the applicant proposed to revise Subsection 14.2.12.1.115 to reflect that the capacity and capability of Class 1E dc system in the required operating modes is demonstrated by the tests as described in Parts 1.1, 1.2, 3.1.1, 3.1.2, 5.1, 5.2, and 5.3. The discharge test stated in Test Method 3.1.1 is for the batteries and the charging test stated in Test Method 3.1.2 is for the battery chargers. Related items to verify that the battery charger DC output meets design criteria are included in the following Parts of the test: Objectives 1.3, 1.8, and 1.9; Test Methods 3.1.2 and 3.5; Data Required 4.2; and Acceptance Criteria 5.2, 5.4, 5.5, and 5.6. The electrical independence and redundancy of power supplies for safety related functions are tested and verified as stated in Parts 1.10, 3.7, and 5.18. The minimum voltages of the battery bank and individual cells are checked and verified in accordance with Parts 3.2 and 4.1. The minimum available voltage at the Class 1E inverters is tested and verified as stated in Parts 1.5, 1.6, 3.3, 3.4, 4.3, and 5.16.

The NRC staff reviewed the DC applicant's response and determined that the update to DCD Subsection 14.2.12.1.115 objectives, test methods and acceptance criteria meets the regulatory requirements for electrical systems in Appendix A to 10 CFR Part 50, GDC 17 and testing guidance in RG 1.68, Appendix A, Section A

-1.g, "Electrical Systems." Specifically, the revised test description addresses the staff's concerns by adequately describing (1) how the test demonstrates proper functioning of the Class 1E DC system, (2) how the test verifies that the battery charger DC output meets design criteria, (3) verification of electrical independence and redundancy of power supplies for safety related functions, and (4) verification that the voltage that would be available at the Class 1E inverters would exceed the design minimum if the batteries were discharged to the minimum voltage limit. Therefore, the NRC staff considers RAI 282-8238, Question 14.02

-56 resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.1

-56. 14.2.12.1.116 Offsite Power System Test The DCD Tier 2, Section 14.2.1.12.1.116, "Offsite Power System," discusses the offsite power system test. In NRC RAI 282

-8238, Question 14.02

-60 (ML15306A232), the NRC staff requested the DC applicant to confirm that this test includes demonstrating the operation of protective relaying, alarms, and control devices of the main, unit auxiliary and standby auxiliary transformers.

14-67 In the August 16, 2016, response to RAI 282-8238, Question 14.02-60 (ML16200A116), the applicant proposed a general revision of DCD Subsection 14.2.12.1.116 to clarify the test methods and acceptance criteria and to keep consistency with DCD Tier 2 Chapter 8 as well as the other subsections of Chapter 14. The revised offsite power system test does include demonstrating the operation of protective relaying and alarms of the main, unit auxiliary, and standby auxiliary transformers (Main Transformers, Unit Auxiliary Transformers, and Standby Auxiliary Transformers); collectively called power transformers. The general revision of DCD Subsection 14.2.12.1.116 has incorporated a change by adding a new Test Method 3.5 to clearly indicate that the test will demonstrate the operation of protective relaying, alarms, and associated control devices of the power transformers.

The NRC staff reviewed and determined that the DC applicant's response and update to DCD Section 14.2.12.1.116 test methods and acceptance criteria are acceptable because they clearly include testing of the SSCs identified in the staff's RAI. Therefore, the staff concludes that the revised test description meets the regulations for electrical systems in Appendix A to 10 CFR Part 50, GDC 17 and electrical system testing requirements in GDC 18, and the testing guidance for electrical systems in RG 1.68 Appendix A, Section A

-1.g. Therefore, the NRC staff considers RAI 8238, Question 14.02

-60 resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.1

-57. 14.2.12.1.117 Balance-of-Plant Piping Thermal Expansion Measurement Test In NRC RAI 151

-8078, Question 03.09.02

-7 (ML15234A407), the NRC stated that the DCD did not provide a description of the thermal expansion tests and as such the staff requested the DC applicant to provide a description of the thermal motion monitoring program for verification of snubber movement, adequate clearances and gaps, the acceptance criteria, and the method regarding how motion will be measured.

In the March 24, 2016, response to RAI 151-8078, Question 03.09.02

-7 (ML16084A989), the DC applicant noted that in performing the upgrade of the Initial Test Plans for DCD Section 14.2, it was determined that an alternate approach was more appropriate in responding to the above question. DCD Subsection 3.9.2.1.3 would be changed to state that the thermal motion monitoring program will include verification of snubber movement, adequate clearances and gaps, the acceptance criteria, and how the motion is to be measured. The thermal motion monitoring program would be included as part of the test procedure completed by the COL applicant. The DCD Section 14.2.12.1.117 acceptance criteria were also updated to add the correct reference to DCD Subsection 3.9.2 for ITP testing commitments related to the ASME OM Code. The NRC staff determined that the DC applicant's response is acceptable because it provides a commitment to include the detailed description of the thermal motion monitoring program as part of the COL applicant test procedure, and the DCD will identify the necessary topics the procedure must address. The staff also agrees with the applicant's correction to reference DCD Subsection 3.9.2. Given this, the proposed change to the DCD meets RG 1.68, Appendix A, Section A

-1, "Preoperational Testing," Page A-2, first paragraph. RAI 151-8078, Question 13.09.02-7 is resolved and the proposed changes to the DCD are being tracked as Confirmatory Item 14.2.12.1

-26.

14-68 In addition, based on the DC applicant response that the detail description of the thermal motion monitoring program will be part of the COL applicant test procedure, the DC applicant proposed to add COL Item 14.2(16) to Table 1.8.2 to address this action described in DCD Subsection 3.9.2.1.3. The DC applicant also proposed to add COL Item 14.2(16) to DCD Section 14.2.13. This change is being tracked as a Confirmatory Item in the Chapter 3 SER Section 03.09.02.

14.2.12.1.118 Balance

-of-Plant Piping Vibration Measurement Test In NRC RAI 151

-8078, Question 03.09.02

-6 (ML15234A007), the NRC staff requested the DC applicant to provide appropriate ITP test descriptions for each of the transient vibration conditions in accordance with provisions of RG 1.68 and ASME OM-3 such that the APR1400 would meet 10 CFR Part 50, Appendix A, GDCs 14 and 15. As pertinent here, GDCs 14 and 15 require that the reactor coolant pressure boundary does not fail and can withstand normal operation, including anticipated operational occurrences

. In the March 24, 2016, response to RAI 151-8078, Question 03.09.02

-6 (ML16084A989), the DC applicant provided the following information:

In performing the upgrade of the Initial Test Plans for DCD Section 14.2, it was determined that an alternate approach was more appropriate in responding to the above question. Therefore, a revision to the original response is being submitted. Each piping transient test will be performed in connection with the system test during the Power Ascension Test

. 14.2.12.1.118, "Balance

-of-Plant Piping Vibration Measurement Test" includes testing of the systems to withstand flow induced dynamic loadings under the steady state and operational transient conditions and references DCD Section 3.9. The associated test procedures will include the detailed test specifications in accordance with the general requirements of RG 1.68 and the specific vibration testing requirements of ASME OM Part 3. To ensure that the requirements of RG 1.68 and ASME OM are included, DCD Tier 2, Subsection 3.9.2.1 will be updated to specify that these specific provisions are addressed as part of the test program.

The NRC staff determined that the DC applicant's response is acceptable because it describes testing for each of the transient vibration conditions and references the acceptable testing methodologies in RG 1.68 and the ASME OM Code. Given this, the proposed DCD change meets 10 CFR Part 50, Appendix A, GDC 14, "Reactor Coolant Pressure Boundary," GDC 15, "Reactor Coolant System Design," and RG 1.68, Appendix A, Section A

-1, "Preoperational Testing," Page A

-2, first paragraph. RAI 151-8078, Question 03.09.02

-6 is resolved and the proposed changes to the DCD are being tracked as Confirmatory Item 14.2.12.1.25.

14.2.12.1.128 Auxiliary Steam System Test In NRC 281-RAI 8232, Question 14.02

-48 (ML15306A018), the NRC staff requested the DC applicant to:

14-69 1. Update DCD Section 14.212.1.128, Auxiliary Steam System Test, to include a test to ensure that the radiation monitor performs its function of automatically redirecting the condensate to the LWMS.

2. Specify which radiation monitor performs this function and update DCD Chapters 11 and 12 to ensure it is clear which monitor performs this function.

In the August 17, 2016, response to RAI 281-8232, Question 14.02

-48 (ML16230A490), the DC applicant included testing of radiation monitor PR

-RE/RT-103, associated with the Auxiliary Steam System, in DCD Section 14.2.12.1.128, to verify automatic redirection of the condensate to the LWMS. The applicant also included acceptance criteria 5.3 in Section 14.2.12.1.128. This acceptance criteria ensures that the monitor functions as described in DCD Section 10.4.10. DCD Section 10.4.10, indicates that the monitor actuates an alarm in the MCR and automatically diverts potential radioactive material in the condensate to the LWMS. In addition, the DC applicant addressed which radiation monitors perform the function to automatically redirect the condensate to the liquid radwaste management system. The NRC staff finds that this test meets RG 1.68, Section A

-1.k., "Radiation Protection Systems," for testing the function of the radiation monitor and therefore, is acceptable. The NRC staff considers RAI 281-8232, Question 14.02

-48 to be resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.1

-49. 14.2.12.1.134 Leakage Detection System Test The DCD Tier 2, Subsection 14.2.12.1.134, "Leakage Detection System Test," demonstrates the operation of the various leakage detection systems. It will test the sump level switches and flow monitors, airborne radioactivity monitor, and/or atmosphere humidity monitors using simulated signals.

Subsection 5.0/5.1, "Acceptance Criteria," of this test states that "the leakage detection system operates as described in Subsection 5.2.6.1.

However, the NRC staff could not find the referenced DCD Subsection 5.2.6.1. It was not clear that this preoperational test includes the verification of the capability of RCS leakage detection instrumentations.

Therefore, as part of NRC RAI 80

-8040, Question 05.02.05

-2 (ML15295A317), the NRC staff requested the DC applicant revise information (supposedly in DCD Tier 2 Subsection 5.2.6.1) but incorrectly referenced in DCD section 14.2.2.12.1.134 and demonstrate that the proposed ITP has adequately addressed the tests identified in RG 1.68, Appendix A.

In the February 24, 2016, update to DCD Tier 2, Section 14.2.12.1.134, "Leakage Detection System Test,"

the DC applicant changed acceptance criteria 5.1 to:

5.1 The leakage detection system operates as designed and described in subsection 5.2.5.2.2 This is a cross reference to DCD Subsection 5.2.5.2.2, "Primary Indicators of Reactor Coolant Unidentified Leakage." The NRC staff determined that this change to DCD Section 14.2.12.1.134 acceptance criteria satisfies requirements to test that leakage detection sensitivity and capability meets TS leakage guidance in RG 1.245 in accordance with guidance in RG 1.68, Appendix A, Section A.1k, "Radiation Protection Systems," Item 5. Therefore, 14-70 NRC RAI 80

-8040, Question 05.02.05

-2 is resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.1

-58. 14.2.12.1.138 Core Protection Calculator System Test In NRC RAI 198

-8208, Question 14.02

-21, the NRC staff determined that additional information is required regarding the objectives, prerequisites, test methods, and acceptance criteria to determine whether the CPCS test meets the guidance in RG 1.68 Section A, Introduction that testing is performed to demonstrate the SSC will perform satisfactorily in service. In the December 19, 2016, third revised response to RAI 198

-8208, Question 14.02

-21 (ML16354B588) on the ITP for the PPS, the DC applicant proposed to add a CPCS test method for redundancy and independence in Section 14.2.12.1.138; however, the NRC staff finds the proposed test method needed additional clarification. Specifically, it was unclear to the NRC staff how the proposed test method will verify redundancy and independence. The NRC staff also could not identify the corresponding test objective which covers redundancy and independence. The applicant should also review the test objectives, test methods, and acceptance criteria for the PPS and the ESF

-CCS to ensure consistency. The DC applicant response to Question 14.02

-21 of RAI 198

-8208 is not resolved and this is Open Item 14.2.12.1-11. Post-Core Hot Functional Tests The following is a list of "Phase II: Fuel Loading and Post

-Core Hot Functional Testing" abstracts described in APR1400 DCD, Sections 14.2.12.2.1 through 14.2.12.2.11

14.2.12.2.1 Post

-Core Hot Functional Test Controlling Document 14.2.12.2.2 NSSS Integrity Monitoring System (Post-core) 14.2.12.2.3 Post

-Core Reactor Coolant System Flow Measurements 14.2.12.2.4 Post

-Core Control Element Drive Mechanism Performance 14.2.12.2.5 Post

-Core Reactor Coolant and Secondary Water Chemistry Data 14.2.12.2.6 Post

-Core Pressurizer Spray Valve and Control Adjustments 14.2.12.2.7 Post

-Core Reactor Coolant System Leak Rate Measurement 14.2.12.2.8 Post

-Core In-Core Neutron Flux Detector Test 14.2.12.2.9 Post

-Core Instrument Correlation 14.2.12.2.10 Post

-Core Acoustic Leak Monitoring System 14.2.12.2.11 Post

-Core Ex-Core Neutron Flux Monitoring System Test The NRC staff reviewed and evaluated the 11 post core hot functional test objectives, test prerequisites, test methods, test data requirements and test acceptance criteria included in APR1400 DCD, Section 14.2.12.2. In comparing the APR1400 hot functional tests to the testing recommended in RG 1.68, Appendix A, Section 2, "Initial Fuel Loading and Precritical Tests" the staff determined that a number of post core hot functions tests reviewed in DCD Section 14.2.12.2 did not contain acceptable test objectives, test prerequisites, test methods, test data requirements and test acceptance criteria to demonstrate that these hot functional tests can verify that the tested SSCs can perform their intended safety

-related, defense

-in-depth and normal operation functions; therefore, parts of DCD Section 14.2.12.2 were not 14-71 acceptable. The NRC staff identified areas where additional information was required to complete its review. Descriptions of the specific issues are as follows:

14.2.12.2.4 Post

-Core Control Element Drive Mechanism Performance Section 14.2.12.2.4 describes the post

-core hot functional testing of the control element drive mechanism (CEDM). In NRC RAI 136-8081, Question 04.06

-02 (ML15227A013), the staff asked the applicant to provide the testing requirements and acceptance criteria for the control element assembly (CEA) insertion and withdrawal times and to clarify data requirements on CEDM coil resistance and RCS temperature and pressure.

In the September 19, 2015 , response to RAI 136-8081, Question 04.06-02 (ML15257A308), the DC applicant proposed changes to DCD Section 14.2.12.2.4 to require data on the CEA withdrawal speed and CEDM coil resistance, to add a reference to the CEA withdrawal speed under the acceptance criteria, and to remove the acceptance criteria on insertion time. Also, the DC applicant revised the data requirements for the CEDM test to include coil resistance and RCS temperature and pressures as requested by the NRC staff.

The NRC staff determined that the proposed updates to DCD Section 14.2.12.2.4 to include data for CEA withdrawal speed

, acceptance criteria for CEA withdrawal speed referenced in DCD Subsection 4.3.1.7, and additional data requirements for coil temperature and RCS pressure and temperature meets the testing guidance in RG 1.68, Appendix A, Subsection A

-2, "Initial Fuel Loading and Pre

-Critical Tests," for control rod testing and is acceptable.

Additionally, the DC applicant stated that only withdrawal speed is related to safety and is measured by the Post-Core CEDM test. The NRC staff determined this justification is acceptable because the Post-Core CEDM performance test verifies CEA drop times which are a required safety

-related parameter. The CEA insertion times are not a required technical specification or safety

-related parameter. Therefore, RAI 136-8081, Question 04.06

-02, is resolved and this DCD change is being tracked as Confirmatory Item 14.2.12.3

-1. 14.2.12.2.9 Post

-Core Instrument Correlation DCD Section 14.2.12.2.9

, provides the post

-core instrument correlation test. In NRC RAI 198-8208 , Question 14.02

-34 (ML15245A546), the NRC staff requested the DC applicant to demonstrate how the test objective of the Post

-Core Instrument Correlation Test stated in APR1400 DCD Section 14.2.12.2.9 can be accomplished with the test methods described in this section.

The test objective is

"[t]o demonstrate proper operation of the plant protection system (PPS), core protection calculator s (CPC s), information processing system (IPS), and qualified indication and alarm system (QIAS)."

However, the test methods only require d the PPS, CP Cs, IPS and QIAS readouts and the main control room instrument readings to be obtained. It d id not appear that these test methods would demonstrate the proper operation of the PPS, CPC s, IPS, and QIAS.

In addition, the acceptance criteria for this test state d, "The IPS, QIAS, PPS, and CPCs perform as described in Sections 7.2 and 7.7."

Sections 7.2 and 7.7 of the APR1400 DCD Tier 2 contain ed a significant amount of design descriptions for these systems. It was unclear what specific design criteria need ed to be met for these systems with this test.

As part of NRC RAI 198

-8208, Question 14.02

-34, the NRC staff request ed the DC applicant identify the specific acceptance criteria that need to be met with this test.

14-72 In the November 1, 2016, response to RAI 198-8208, Question 14.02

-34 (ML16306A436), the DC applicant states:

The purpose of the Post

-Core instrument Correlation is to verify that the as

-installed instrumentation is functional for specific I&C systems. Therefore, the objectives in Section 14.2.12.2.9 will be modified to align with the purpose of this test. The NRC staff determined that the DC applicant's proposed revision to DCD Section 14.2.12.2.9 related to PCIC test objectives adequately describes the functional tests to be performed to demonstrate that the PCIC will perform satisfactorily in service, in accordance with the guidance in RG 1.68, Appendix A, Section A

-1.j, "Instrumentation and Control Systems," and it is acceptable

. Therefore, RAI 198-8208, Question 14.02

-34 is resolved and the proposed revision to the DC D is being tracked as Confirmatory Item 14.2.12.3

-2. 14.2.12.2.11 Post

-Core Ex-Core Neutron Flux Monitoring System Test The APR1400 DCD Tier 2, Section 14.2.12.2.11 , "13,800V Normal Auxiliary Power System Test," describes the post

-core ENFMS test.

The acceptance criteria for this test states that the "[ENFMS] performs as described in Subsection 7.7.1.1.h."

APR1400 DCD Tier 2 Subsection 7.7.1.1.h only describes the operation of the non

-safety channels of the ENFM S. As such, it was not clear to the NRC staff whether this test is only applicable to the non

-safety channels or whether it is also supposed to test the safety channels.

In NRC RAI 198-8208, Question 14.02-35 (ML15254A546), the NRC staff request ed the DC applicant to clarify the scope of this test (i.e. whether it is for both safety and non

-safety channels of the ENFMS

, or just the non

-safety channels).

In addition, if this test is only applicable to the non

-safety channel of the ENFMS, the NRC staff request ed the applicant to identify where the safety channels of the ENFMS are tested in the post core ITP. In the June 20, 2016

, response to RAI 198-8208, Question 14.02

-3 5 (ML16173A245), the DC applicant stated that:

According to RG 1.68, the proper functional performance tests of the ENFMS and the proper performance tests of the audio and visual indications for both safety and non

-safety channels of ENFMS are conducted in the pre

-operational testing described in 14.2.12.1.25. During the initial fuel loading, neutron count rate is continuously monitored by displaying, recording, and audible information using two temporary source

-range channels or at least one temporary channel and one permanent channel (startup channel of the ENFMS) as described in 14.2.10.1 so that all changes in the multiplication factor are observed. Before this step, the startup channels of the ENFMS are calibrated. For consistency, Section 14.2.10.1 will be revised to add this calibration.

The proper functional performance tests of the ENFMS and the proper performance tests of the audio and visual indications for both safety and non

-safety channels of ENFMS are not required during post

-core HFT in RG 1.68. Therefore, APR1400 DCD Section 14.2.12.2.11 will be deleted.

14-73 As the Section 14.2.12.2.11 is deleted, the Table 14.2

-7 in the APR1400 FSAR Tier 2 will be revised. For 2.g of RG 1.68, App. A, Subsection # and Individual Test will be revised to "14.2.10.1 Initial Fuel Loading". For 4.c of RG 1.68, App. A, Subsection # and Individual Test will be revised to "14.2.10.2.1 Safe Criticality Criteria" because a minimum of 1 decade of overlap is observed between the startup and log safety channels of the ex

-core nuclear instruments as describe d in g of the Section 14.2.10.2.1. For 4.d of RG 1.68, App. A, Subsection # and Individual Test will be revised to "14.2.12.1.24 Plant Protection System Test" because the operation of associated protective functions and alarms for plant protection is tested as described in the Section 14.2.12.1.24.

The NRC staff determined that this response is not acceptable since deleting DCD Subsection 14.2.12.2.11 would not verify initial fuel loading/initial criticality testing of ENFMS neutron monitors when first loading fuel. The ENFMS preoperational test only covers simulated neutron signals and not actual neutron signals because there is no fuel in the reactor. Therefore, the DC applicant should update or move this test to the applicable portions of DCD Section 14.2.12 where ENFMS neutron monitor testing should be performed, or justify why the test is not needed. The DC applicant should also consider testing both in

-core and ex

-core neutron detectors, the CPC and any other digital I&C systems needed to support initial fuel load/initial criticality testing. RAI 198-8208, Question 14.02

-3 5 is also being tracked as Open Item 14.2.12.2

-2. DCD Section 14.2.12.3, Low Power Physics Tests The following is a list of "Phase III: Initial Criticality and Low

-Power Physics Testing" abstracts described in APR1400 DCD, Sections 14.2.12.3.1 through 14.2.12.3.6

14.2.12.3.1 Low

-Power Biological Shield Survey Test 14.2.12.3.2 Isothermal Temperature Coefficient Test 14.2.12.3.3 Shutdown and Regulating Control Element Assembly Group Worth Test 14.2.12.3.4 Differential Boron Worth Test 14.2.12.3.5 Critical Boron Concentration Test 14.2.12.3.6 Control Element Assembly Symmetry Test In comparing the APR1400 initial criticality and low power physics tests to the testing recommended in RG 1.68, Appendix A, Section 3 and Section 4, the staff identified areas where additional information was required to complete its review. A description of the specific issue is as follows:

14.2.12.3.1 Low

-Power Biological Shield Survey Test In DCD S ubsections 14.2.12.3.1, "Low

-power biological shield survey test" and 14.2.12.4.9, "Biological shield survey test," the acceptance criteria indicate d that the biological shield performs as described in DCD Subsection 12.3.2.2

however, Subsection 12.3.2.2 provide d no information on how the biological shield is expected to perform.

Therefore, in NRC RAI 281-8232, Question 14.02

-51 (ML15306A018), the NRC staff requested the DC applicant clarify what is meant by this statement, update DCD Subsection 12.3.2.2 to provide information on the shielding criteria for the biological shield, or update DCD Subsections 14.2.12.3.1 and 14.2.12.4.9 to reference an accurate section.

14-74 In the August 9, 2016, response to RAI 281-8232, Question 14.02

-51 (ML16222A939), the DC applicant stated, in part, that:

As a result of related comments that resulted from review of the DC applicant's response to RAI 281

-8232 Question 14.02

-52, changes to DCD Tier 2 Subsection 14.2.12.3.1, "Low

-Power Biological Shield Survey Test" and Subsection 14.2.12.4.9 "Biological Shield Survey Test" are being proposed. Subsection 14.2.12.3.1 is being revised to "Baseline Biological Shield (Primary Shield) Radiation Measurements Test," to describe the radiation survey to be performed around the primary shield structure areas prior to initial power operation to establish radiation baseline levels for comparison to the radiation levels during power ascension ((i.e., the "Biological Shield Survey Test") and normal power operation (Please refer to Attachment 1 of this response). In addition, the title of the "Biological Shield Survey Test" in Subsection 14.2.12.4.9 is being revised to "Biological Shield (Primary Shield) Radiation Measurements Test" and addresses radiation measurements at 5 percent or less, 50 percent, and 100 percent power levels to ensure that the radiation dose is acceptable and as designed (Please refer to Attachment 2 of this response). The Biological Shield (Primary Shield) Radiation Measurements Test includes, which may include [sic] areas adjacent to the reactor, steam generators, reactor coolant pumps, and the pressurizer (RCS components), high and very high radiation areas inside the Auxiliary Building and the Compound Building. These designated areas are identified in DCD Subsections 14.2.12.3.1 and 14.2.12.4.9 for clarity.

The reference to DCD Tier 2 Subsection 12.3.2.2 has been removed, since the acceptance criteria for "Baseline Radiation Measurements Test" and the "Radiation Measurements Test," are provided in Sub

-item 5 "Acceptance Criteria," of Subsections 14.2.12.3.1 and 14.2.12.4.9, respectively in DCD Tier 2 Chapter 14.

The term 'primary shield' refers to the heavily reinforced concrete structure that houses the reactor vessel, provides the primary radiation shielding, and provides protection for the reactor vessel from internal missiles (DCD Tier 2 Subsection 3.8.3.1.5). The term, 'secondary shield' refers to the reinforced concrete structure surrounding the steam generators, the reactor coolant pumps, and the pressurizer (DCD Tier 2 Subsection 3.8.3.1.6). The term, 'biological shield' is a general term used for the provision of shielding against radiation around the primary and the secondary shielding structures. Since the baseline and the regular radiation measurement tests not only include areas of the RCS components, but also include high and very high radiation areas adjacent to these components, DCD Subsections 14.2.12.3.1 and 14.2.12.4.9 are revised accordingly.

The NRC staff reviewed the acceptance criteria for "Baseline Radiation Measurements Test" and the "Radiation Measurements Test,"

provided in Sub

-item 5 "Acceptance Criteria," of Subsections 14.2.12.3.1 and 14.2.12.4.9 and determined that the acceptance criteria adequately addressed the performance of the biological shield and is consistent with the guidance in RG 1.68, Appendix A, Section A

-1.k, "Radiation Protection Systems,"

to demonstrate the proper operation of the components used to monitor or measure radiation levels, provide for personnel protection, or control or limit the release of radioactivity

. Therefore, RAI 281-8232, 14-75 Question 14.02

-51 is resolved and these proposed DCD changes are being tracked as Confirmatory Items 14.2.12.

4-1 and 14.2.12.

5-4. DCD Section 14.2.12.4, Power Ascension Tests The following is a list of "Phase IV: Power Ascension Testing" abstracts described in APR1400 DCD, Sections 14.2.12.2.1 through 14.2.12.2.11

14.2.12.4.1 Variable Tavg (Isothermal Temperature Coefficient and Power Coefficient) Test 14.2.12.4.2 Unit Load Transient Test 14.2.12.4.3 Control Systems Checkout Test 14.2.12.4.4 Reactor Coolant and Secondary Chemistry and Radiochemistry Test 14.2.12.4.5 Turbine Trip Test 14.2.12.4.6 Unit Load Rejection Test 14.2.12.4.7 Shutdown from Outside the Main Control Room Test 14.2.12.4.8 Loss of Offsite Power Test 14.2.12.4.9 Biological Shield Survey Test 14.2.12.4.10 Steady

-State Core Performance Test 14.2.12.4.11 Intercomparison of Plant Protection System, Core Protection Calculator, Information Processing System, and Qualified Information and Alarm System Inputs

\ 14.2.12.4.12 Verification of Core Protection Calculator Power Distribution Related Constants Test 14.2.12.4.13 Feedwater and Auxiliary Feedwater Systems Test 14.2.12.4.14 Core Protection Calculator Verification 14.2.12.4.15 Main Steam Atmospheric Dump and Turbine Bypass Valves Capacity Test 14.2.12.4.16 In

-Core Detector Test 14.2.12.4.17 Core Operating Limit Supervisory System Verification 14.2.12.4.18 NSSS Integrity Monitoring System 14.2.12.4.19 Loss of One Main Feedwater Pump 14.2.12.4.20 Penetration Temperature Survey Test 14.2.12.4.21 HVAC Capability Test 14.2.12.4.22 Natural Circulation Test (First

-of-a-Kind Test) 14.2.12.4.23 Liquid Waste Management System Test 14.2.12.4.24 Gaseous Waste Management System Test 14.2.12.4.25 Pseudo

-Ejected CEA Test 14.2.12.4.26 Pseudo

-Dropped CEA Test In comparing the APR1400 power ascension tests to the testing recommended in RG 1.68, Appendix A, Section 5, "Power

-Ascension Tests," the staff identified a number of power ascension tests in DCD Section 14.2.12.4 that did not contain acceptable test prerequisites, test methods, test data requirements and test acceptance criteria to adequately demonstrate that APR1400 power ascension tests can perform their intended safety

-related, defense

-in-depth and normal operation functions; therefore, parts of DCD Section 14.2.12.4 were not acceptable. The NRC staff identified several areas where additional information was required to complete its review. Descriptions of the specific issues are as follows:

14-76 14.2.12.4.7 Shutdown from Outside the Main Control Room Test In NRC RAI 198-8208, Question 14.02

-36 (ML15254A546), the NRC staff requested the DC applicant demonstrate how the test objective for safely cooling down the plant from hot standby to cold shutdown conditions from outside the MCR is met with the test methods described in APR1400 DCD Tier 2, Section 14.2.12.4.7.

"Shutdown from Outside the Main Control Room." In the June 22, 2016, response to RAI 198-8208, Question 14.02

-36, (ML16174A46 5), the DC applicant stated, in part that:

As described in the attached markup and DCD Tier 2 section 14.2.12.1.48, the capability to cool down the plant to the cold shutdown condition from the remote shutdown room

[RSR] is demonstrated during pre

-core hot functional testing. Therefore, during power ascension tests, the objective of the test for shutdown from outside the MCR is to demonstrate the plant can be placed in the hot shutdown condition and maintained for at least 30 minutes from outside the MCR. According to NRC RG 1.68.2 "Initial Startup Test Program to Demonstrate Remote Shutdown Capability for Water Cooled Nuclear Power Plants," Revision 2, licensees do not need to demonstrate cold shutdown capability immediately following the test but must maintain a safe hot shutdown from outside the MCR. KHNP submitted a revised DCD Tier 2 section 14.2.12.4.7 as a result of the DCD Section 14.2 upgrade effort-As a result of the subsequent review, the ITP for Shutdown from Outside the Main Control Room test will be further enhanced to make additional clarifications to the test objectives, test methods and test acceptance criteria to meet NRC Regulatory Guide 1.68.2, Revision 2. The NRC staff determined that t he proposed update to DCD Tier 2 Section 14.2.12.4.7 to clarify test objectives, test method s and acceptance criteria to place the plant in a safe hot shutdown condition for at least 30 minutes from the RSR ensures the design capability for prompt hot shutdown of the reactor in accordance with the requirements of GDC 19 for equipment outside the control room to safely shut down the reactor and bring it to hot shutdown condition and the guidance in RG 1.68.2 to demonstrate this capability and is thus acceptable. Therefore, RAI 198-8208, Question 14.02

-36 is resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.

5-2. 14.2.12.4.8 Loss of Offsite Power Test DCD Tier 2 Section 14.2.12.4.8 discusses the Loss

-of-Offsite-Power Test.

In NRC RAI 282-82 38, Question 14.02

-61 (ML15306A232), the NRC staff requested the DC applicant to discuss how this test demonstrates that upon a loss of offsite power, there is an automatic transfer from offsite power to the onsite emergency diesel generators.

In the August 16, 2016, response to RAI 282-8238, Question 14.02

-61 (ML16230A116), the applicant stated:

The ITP demonstrates an automatic transfer from offsite power to the onsite EDGs upon a loss of offsite power (LOOP), as discussed in DCD Section 14.2.12.1.87, "Emergency Diesel Generator Electrical System Test." The preoperational test described in Part 3.3 of DCD Section 14.2.12.1.87, which was 14-77 provided in the revised response to RAI 19 1-8210, Question 14.2

-13 (reference KHNP submittal: MKD/NW 0684L dated June 28, 2016; ML16180A271), evaluates the ability of the EDG to start and provide power to safety related components.

The NRC staff reviewed the DC applicant's update to DCD Subsections 14.2.12.1.87 for EDG Electrical Systems test objectives, test methods and test acceptance criteria. The NRC staff determined that the proposed change satisfies the testing requirements to demonstrate proper operation of transfer schemes for the EDG electrical system in accordance with the regulations in 10 CFR Part 50, Appendix A, GDC 17 and GDC 18, and the testing guidance for electrical systems in RG 1.68, Appendix A, Section A

-1.g, "Electrical Systems," and is thus, acceptable.

The NRC staff also agrees that it is appropriate to perform this testing in the preoperational phase rather than the power ascension phase. RAI 282-8238, Question 14.02

-61 is resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.

5-3. 14.2.12.4.9 Biological Shield Survey Test In NRC RAI 281-8232, Question 14.02

-53 (ML15306A018), the NRC staff requested the DC applicant to update the objective for the biological shield survey test in the DCD, as appropriate, to specify that the test will assist in determining allowable occupancy times for areas outside the biological shield.

In the April 19, 2016

, response t o RAI 281-8232, Question 14.02

-53 (ML16110A460), the DC applicant updated DCD Section 14.2.12.4.9, Test Objective 1.2, to state:

To assist in determination of allowable occupancy times for th ese areas outside the biological shield during power operation.

The NRC staff determined that the proposed change to DCD Section 14.2.12.4.9 is acceptable because it satisfies the requirements for conducting neutron and gamma radiation surveys to establish the adequacy of the airborne activity monitoring system in accordance with the testing guidance in RG 1.68, Appendix A, Section A.5, "Power Ascension Tests," Test Item bb, for radiation shields which also references RG 1.69, "Concrete Radiation Shields and Generic Shield Testing for Nuclear Power Plants." RAI 281-8232, Question 14.02

-53 is resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.

5-5. 14.2.12.4.16 In

-Core Detector Test The NRC staff posed RAI 198-8208, Question 14.02

-23 , as discussed in the SER Section 14.2.4.12 discussion of preoperational test 14.2.12.1.26 Fixed In

-Core Nuclear Signal Channel Test. The NRC staff requested the applicant to submit a supplemental response to resolve the issues discussed in the aforementioned section of this SER. RAI 198-8208, Question 14.02-23 is tracked as Open Item 14.2.12.1

-13. 14.2.12.4.22 Natural Circulation Test (First

-of-a-Kind Test)

In DCD Section 14.2.12.4.22, "Natural Circulation Test (First

-of-a-Kind Test)," Section 5.0, Acceptance Criteria, the DC applicant noted in acceptance criterion 5.1 that

14-78 "The natural circulation power

-to-flow ratio is less than 1.0.

" The NRC staff could not identify any information in DCD Section 5.4.7 related to the natural circulation power

-to-flow ratio of less than 1.0 being an adequate power ascension test acceptance criterion in DCD Section 14.2.12.4.22. In addition, the NRC staff performed a search of applicable DCD Chapters 4, 5, 15, and 16 including technical reports without identifying any information o n natural circulation, boron and thermal stratification, and appropriate margin to specified acceptable fuel design limits related to power to flow ratio; therefore, in NRC RAI 384-8100, Question 05.04.07

-3 (ML16032A106), the NRC staff requested the DC applicant to provide more information in DCD S ubsections 5.4.7 and 14.2.12.4.22 to justify meeting NRC SRP BTP 5

-4, Section B, Branch Technical Position, Subsection 5, "Test Requirements."

The staff also requested the DC applicant to provide the documents related to this test

, including a discussion of the relationship of the above conditions with respect to the reactor power conditions at the initiation of the test.

In the March 17, 2016, response to RAI 384-8100, Question 05.04.07

-03 (ML16077A291), the DC applicant noted that the APR1400 has a design criterion indicating that a temperature increase during natural circulation shall be less than that of full power design conditions. The same degree of sub

-cooling margin compared to full power design condition is automatically preserved after the reactor trip when the design criterion is met. The natural circulation test is performed to verify the design criterion. During the test, the power

-to-flow ratio is calculated to verify the heat removal capability of the NSSS under natural circulation condition

s. The power

-to-flow ratio is defined as follows:

The enthalpy rise is used instead of temperature increase to consider the pressure difference during the test. Because the power

-to-flow ratio is not used in any section of the applicable DCD, the applicant stated that the acceptance criteria in DCD S ubsection 14.2.12.4.22 will be changed as follows:

5.1 Adequate

natural circulation flow shall be maintained following trips of all RCPs. 5.2 The enthalpy rise of natural circulation condition is less then at design full power conditions.

The APR1400 is designed to have decay heat removal capability by natural circulation. The flow by natural circulation shall be enough that the temperature increase across the core during natural circulation is less than that of the full power design condition at the same core inlet temperature and pressure conditions. The fuel integrity during the natural circulation is preserved by maintaining the sub

-cooling margin of the RCS. DCD Section 5.4.7.3.1 shows that when the RCS sub

-cooling margin is decreased to 15 degrees Celsius (°C) 14-79 (59 degrees Fahrenheit (°F)), the operator stops the RCS depressurization and begins to cooldown.

The boron mixing and cooldown to SCS entry condition by natural circulation is not a test item in initial test program of APR1400. The boron mixing and natural circulation cooldown tests were performed in the 1980's in United States, as required by NRC. The BNL

-NUREG-41512, "Evaluation of Natural Circulation Cooldown Tests Performed at Diablo Canyon, San Onofre, and Palo Verde Nuclear Power Plants," concludes that adequate boron mixing could be achieved in less than one hour by natural circulation within the main flow path of the RCS and that relatively un

-borated water entering the RCS from the upper head and pressurizer will not have significant effect on criticality as long as the depressurization is conducted carefully to limit the size of possible void formation. Palo Verde plants use the System 80 design which is the reference design of System 80+ and the APR1400, which has basically the same design as System 80+ design in thermal power and system configuration, is also evaluated to have adequate boron mixing capability during natural circulation operation

. The NRC staff determined the DC applicant's proposed update to DCD Section 14.2.12.4.22 to include adequate test acceptance criteria for natural circulation:

(1) confirms that adequate mixing of borated water added before or during cooldown can be achieved under natural circulation conditions and permit estimation of the times required to achieve such mixing, and (2) confirms that cooldown under natural circulation conditions can be achieved within the limits specified in the emergency operating procedures in accordance with the testing guidance for the pressurizer surge line in NUREG-0800, Branch Technical Position (BTP) 5-4 and RG 1.68, Appendix A, Section A

-1.j, Test Item 1. Therefore, RAI 384-8100, Question 05.04.07

-03 is resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.5-7. In NRC RAI 8709, Question 14.02

-70 (ML16319A333), the NRC staff request ed the DC applicant to provide justification for the use of BNL

-NUREG-41512 to avoid performing boron mixing. The NRC staff determined that the DC applicant should verify sufficient boron mixing to cool down the reactor from hot standby to hot shutdown conditions when the Shutdown Cooling System (SCS) is placed in

-service. The DC applicant should submit a response to revis e the natural circulation test to include other SSCs to safely complete this test and verify boron mixing and natural circulation can be used to cool down the reactor from hot standby to hot shutdown conditions with suitable test acceptance criteria to place the SCS in

-service. RAI 8709, Question 14.02

-70 is not resolved and this issue is being tracked as Open Item 14.2.12.5-8. 14.2.12.4.18 NSSS Integrity Monitoring System In NRC RAI 70-8027, Question 03.12

-03, the NRC staff noted that NRC BL 88

-11 and SRP Section 3.12 discuss the potential for stress induced by thermal stratification in the pressurizer (PZR) surge line (SL). In particular, BL 88

-11 requested the establishment of a program that would monitor the PZR SL for the effects of thermal stratification beginning with HFT. APR1400 DCD Tier 2, Section 3.12.5.10 states the APR1400 conforms with BL 88

-11, but the APR1400 did not include a description of a test program to implement monitoring of the PZR SL consistent with BL 8 8-11, SRP Sections 3.2 and 14.2 (as was included in other DC 14-80 applications that have been reviewed and approved by the NRC). For these reasons, staff sent the following requests to the DC applicant:

1. According to BL 88

-11, thermal stratification occurs in the PZR SL during heat up, cool down and steady state operation of the plant. The NRC staff requests the DC applicant to discuss: whether a monitoring or test program is planned to verify the design transients used in the structural design of the SL or how this verification will take place. Describe the program, testing and its implementation consistent with BL 88

-11 and SRP Section 3.2, that will demonstrate that stratification temperature measurements for the APR1400 PZR SL will be within thermal deflections, resulting in no adverse consequences (such as contacting the pipe whip restraints). Testing of the effects of PZR SL stratification should also continue at least during the first cycle of plant operation (i.e., hot functional and power ascension testing portions of the ITP).

2. The PZR SL monitoring is the responsibility of the COL applicant. Therefore DCD Table 1.8.2 and COL Subsections 3.12.7 and 14.2.13 should be updated to identify COL items for PZR SL monitoring.

The NRC staff reviewed the DC applicant's response to RAI 70-8027, Question 03 03, and noted a commitment to monitor Pressurizer Surge Line Stratification through the first fuel cycle. However, the DC applicant did not add anything to require a power ascension test. The NRC staff determined that the DC applicant should add more information to DCD Subsection 14.2.12.4.18, "NSSS Monitoring System Test," and address testing during the first cycle of plant operation (i.e., hot functional and power ascension testing portions of the ITP). The DC applicant provided a supplemental response in the September 7, 2016

, to RAI 70-8027, Question 03.12

-03 (ML16251A336)

. The DC applicant added DCD Section 14.2.12.4.27, "Fatigue Monitoring System Test," which includes monitoring the fatigue usages for the early identified locations

, including the PZR surge line

, which will experience thermal stratification. The NRC determined that this response is acceptable because it satisfies the requirement for the implementation of a program to monitor the effects of thermal stratification on pressurizer surge line integrity in accordance with testing guidance in BL 88

-11 and RG 1.68 and it addresses testing during the first cycle of plant operation. Therefore, this part of RAI 70-8027, Question 03 03 is resolved and the proposed change to the DCD is being tracked as Confirmatory Item 14.2.12.

5-9. Conclusions Because of the open items identified above, the staff is unable to finalize its conclusions for SER Section 14.2.4

. Combine License Information Items Introduction In DCD Section 14.2.13, COL Information Items, the DC applicant identified t he following COL Action Items:

COL 14.2(1)

The COL applicant is to develop the site

-specific organization and staffing level appropriate for its facility.

14-81 COL 14.2(2)

The COL applicant is to prepare the site

-specific test procedures and/or guidelines that is to be used for the conduct of the plant startup program.

COL 14.2(3)

The COL applicant is to prepare a startup administrative manual and also provide preoperational and startup test summaries that contain testing objectives and acceptance criteria applicable for its scope of the plant design. Testing performed at other than design operating conditions for systems is to be reconciled either through the test acceptance criteria or post

-test data analysis.

COL 14.2(4)

The COL applicant is to perform review and evaluation of individual test results. COL 14.2(5)

The COL applicant is to develop the detailed description of test and acceptance criteria for the Security System.

COL 14.2(6)

The COL applicant is to develop a schedule for the development of the plant operating and emergency procedures and should allow sufficient time for trial use of these procedures during the ITP. The schedule for plant startup is to be developed by the COL applicant to allow sufficient time to systematically perform the required testing in each phase.

COL 14.2(7) The COL applicant is to describe its program for reviewing available information on reactor operating and testing experiences and discuss how it used this information in developing the ITP. The description is to include the sources and types of information reviewed, the conclusions or findings, and the effect of the review on the ITP. COL 14.2(8)

The COL applicant that references the APR1400 design certification is to identify the specific operator training to be conducted as part of the low

-power testing program related to the resolution of TMI Action Plan Item I.G.1, as described in (1) NUREG

-0660 , "NRC Action Plans Developed as a Result of the TMI-2 Accident," Revision 1, August 1980 and (2) NUREG

-0737 "Clarification of TMI Action Plan Requirements." COL 14.2(9)

The COL applicant is to prepare the preoperational test of the cooling tower and associated auxiliaries, and raw water and service water cooling systems.

COL 14.2(10)

The COL applicant is to develop the test program of personnel monitors and radiation survey instruments.

COL 14.2(11)

The COL applicant is to develop the test procedure of the communication system. Evaluation The NRC staff reviewed the list of COL responsibilities related to the ITP in DC Section 14.2.13, Combined Licensee Information, for consisten cy with RG 1.206, Section C.I.14, "Verification Programs,"

and RG 1.68, Section A, "Introduction

." In NRC RAI 91

-7867, Question 14.02

-4 (ML15201A768) the NRC staff identified administrative control text 14-82 corrections below (identified in italics) related to COL applicant responsibilities that the DC applicant should add to DCD Subsection 14.2.13:

COL 14.2(1)

The COL applicant is to develop the site

-specific organization and staffing levels appropriate for its facility to implement the initial test program. The COL applicant's plant operating and plant technical staff should participate, to the extent practical, in developing and conducting the ITP and evaluating the test results. COL 14.2(2)

The COL applicant is to prepare the site specific preoperational and startup test specifications and test procedures that is to be used for the conduct of the plant Initial Test Program. The preoperational and startup test procedures should have controls in place to ensure that test procedures include appropriate prerequisites, objectives, safety precautions, initial test conditions, methods to direct and control test performance and test acceptance criteria by which the test is evaluated. Testing performed at other than design operating conditions for systems is to be reconciled either through the test acceptance criteria or post-test data analysis. These procedures are to be submitted at least 60 days prior to their intended use to the NRC staff for review as described in Subsection 14.2.11. COL 14.2(3)

The COL applicant is to prepare a startup administrative manual (SAM) which contains administrative controls that govern the conduct of each major phase of the ITP. This description should include the administrative controls used to ensure that necessary prerequisites are satisfied for each major phase and for individual tests. The COL applicant should also describe the methods to be followed in initiating plant modifications or maintenance tasks that are deemed to be necessary to conduct the ITP. This description should include methods used to ensure retesting following such modifications or maintenance. In addition, the description should discuss the involvement of design organizations with the COL applicant in reviewing and approving proposed plant modifications. The COL applicant should also describe in the SAM adherence to approved test procedures during the conduct of the ITP as well as the methods for effecting changes to approved test procedures. COL 14.2(4)

The COL applicant is to perform a review and evaluation of individual test results in a test report made available to NRC personnel after preoperational and startup tests are completed. The specific test acceptance criteria for determining success or failure of a test shall be included in the test report approval of the test results. The test report should also include test results associated with any license conditions in the plant specific ITP

. COL 14.2.(6)

The COL applicant is to develop a sequence an d schedule for the development of the plant operating and emergency procedures should allow sufficient time for trial use of the procedure during the Initial Test Program. The sequence and schedule for plant startup is to be developed by the COL applicant to allow sufficient time to systematically perform the required testing in each phase.

COL 14.2(7)

The COL applicant is responsible for establishing hold points at selected milestones throughout the power ascension test phase to ensure that 14-83 designated personnel or groups evaluate and approve relevant test results before proceeding to the next power

-ascension test phase. At a minimum, the COL applicant should establish hold points at approximately 25

-percent, 50-percent, and 75

-percent power

-level test conditions for pressurized

-water reactors. COL 14.2(13)

The COL applicant is responsible for retaining preoperational and startup test procedures and test results as part of the plant's historical records in accordance with 10 CFR 50.36, "Technical Specification," 10 CFR 50.71, "Maintenance of Records, Making of Reports," 10 CFR 50, Appendix B, Criterion XVII, "Test Records," and RG 1.28, "Quality Assurance Program Criteria (Design and Construction)

." The staff also requested the DC applicant to make number sequence changes to COL 14.2(8) through COL 14.2(12) but no text changes were needed. The DC applicant was also asked to revise APR1400 DCD Sections 14.2.2, "Organization and Staffing," 14.2.3, "Test Procedures," and 14.2.6, "Test Records," to note these changes in COL applicant responsibilities for implementing the ITP in DCD Section 14.2.13, "COL Information Items." On August 28, 2015, the DC applicant responded to NRC RAI 91

-7867, Questions 14.02-04 and 14.02

-05 and proposed to incorporate the NRC staff's revisions noted above in italics to meet Regulatory Guide 1.206, Section C.I.14, SRP Section 14.2, and RG 1.68. The modifications were be based on the NRC staff's proposed text modifications. Also, applicant stated that the related subsections below will be modified to maintain consistency between each DCD Subsection:

DCD Section 14.2.2, "Organization and Staffing" DCD Section 14.2.3, "Test Procedures" DCD Section 14.2.5, "Review, Evaluation and Approval of Test Results" DCD Section 14.2.6, "Test Records" DCD Section 14.2.11, "Test Program Schedule" The NRC staff reviewed the DC applicant's June 30, 2016, response to NRC RAI 91

-7867, Question 14.02

-4 (ML16182A597), and determined that by adopting the proposed text, and making the appropriate modifications to DCD Subsections 14.2 and 14.2.13, the response meets RG 1.206, Section C.I.14, SRP Section 14.2

, and RG 1.68 and is acceptable. RAI 91-7867, Question 14.02

-04 is resolved and the proposed DCD change is being tracked as part of Confirmatory Item 14.2.13

-1.

14-84 Conclusion With the inclusion of the DCD changes described above , th e staff finds the above listing of confirmatory items to be complete. No additional COL information items need to be included in for initial test program consideration.

The list adequately describes the actions necessary for the COL applicant or holder

, satisfies the guidance of RG 1.206, Section C.I.14, SRP Section 14.2, and RG 1.68, and is therefore acceptable

. Inclusion of the proposed changes in the DCD is being tracked as Confirmatory Item 14.2.13

-1. Conclusions Because of the open items identified above, the staff is unable to finalize its conclusions for SER Section 14.2

. Inspections, Tests, Analyses, and Acceptance Criteria The Inspections, Tests, Analyses and Acceptance Criteria (ITAAC) are undergoing review, the results of which will be presented in the advanced SER with no open items

.