december 3, 2018 from: paul kallan, senior project manager

OFFICIAL USE ONLY – PROPRIETARY INFORMATION


December 3, 2018

MEMORANDUM TO: Jennifer L. Dixon-Herrity, Chief Licensing Branch 4 Division of Licensing, Siting,

and Environmental Analysis Office of New Reactors FROM: Paul Kallan, Senior Project Manager /RA/ Licensing Branch 4 Division of Licensing, Siting,

and Environmental Analysis Office of New Reactors SUBJECT: AUDIT REPORT FOR VOGTLE ELECTRIC GENERATING

PLANT UNITS 3 AND 4, REQUEST FOR LICENSE AMENDMENT: CREDITING PREVIOUSLY COMPLETED FIRST PLANT AND FIRST THREE PLANT TESTS (LAR 18-019)

By letter dated August 3, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML18215A382), Southern Nuclear Operating Company (the licensee) requested an amendment to Combined License Numbers NPF-91 and NPF-92, for Vogtle Electric Generating Plant (VEGP) Units 3 and 4. The requested amendment requires changes to the Updated Final Safety Analysis Report (UFSAR) in the form of departures from the incorporated plant-specific Design Control Document (DCD) Tier 2* and Tier 2 information and related changes to the VEGP Units 3 and 4 COL and COL Appendix C (and corresponding plant-specific DCD Tier 1) information. The requested amendment includes changes to credit previously completed first plant only and first three plant only testing as described in the licensing basis documents, including COL Condition 2.D.(2)(a) and plant-specific Tier 1 Section 2.1.3. Specifically, the proposed changes would revise the COL to delete conditions requiring the following tests: In-Containment Refueling Water Storage Tank (IRWST) Heatup Test, Reactor Vessel Internals Vibration Testing and Core Makeup Tank Heated Recirculation Tests. The documentation to establish a valid prototype reactor internals in accordance with Regulatory Guide 1.20, “Comprehensive Vibration Assessment Program for Reactor Internals During Preoperational and Initial Startup Testing” is also included. CONTACT: Paul Kallan, NRO/DLSE/LB4 301-415-2809

OFFICIAL USE ONLY – PROPRIETARY INFORMATION J. Dixon-Herrity -2-


The Reactor Systems, Nuclear Performance & Code Review Branch, the Containment and Ventilation Branch, the Mechanical Engineering Branch and the Quality Assurance Vendor Inspection Branch staff conducted an audit on September 17 – October 31, 2018. The purpose of the audit was to gain better understanding of proposed changes to reach reasonable findings, and review related documentation and non-docketed information to evaluate conformance with the Standard Review Plan or technical guidance. Docket Nos.: 52-025 and 52-026 Enclosure: Non-Proprietary Regulatory Audit Report cc: See next page



U.S. NUCLEAR REGULATORY COMMISSION AUDIT REPORT FOR VOGTLE ELECTRIC GENERATING PLANT UNITS 3 AND 4, REQUEST FOR LICENSE AMENDMENT: CREDITING PREVIOUSLY COMPLETED FIRST PLANT AND FIRST THREE PLANT TESTS (LAR 18-019) DATED: DECEMBER 3, 2018

DISTRIBUTION: Public LB4 R/F RidsAcrsAcnwMailCenter RidsOgcMailCenter CPatel PKallan RButler ADAMS Accession Nos.: ML18338A089 - Package

ML18338A090 (Non-Proprietary Audit Report) ML18310A015 (Proprietary Audit Report) NRO-008

OFFICE DLSE/LB4/PM DLSE/LB4/LA DLSE/LB4/BC NAME PKallan RButler JDixon-Herrity DATE 11/6/18 11/6/18 11/6/18

OFFICIAL RECORD COPY

Vogtle Units 3 & 4 Mailing List (Revised 08/16/2018) cc: Office of the Attorney General Resident Inspector 40 Capitol Square, SW Vogtle Plant Units 3 & 4 Atlanta, GA 30334 8805 River Road Waynesboro, GA 30830 Resident Manager Oglethorpe Power Corporation Mr. Barty Simonton Alvin W. Vogtle Nuclear Plant Team Leader 7821 River Road Environmental Radiation Program Waynesboro, GA 30830 Air Protection Branch Environmental Protection Division Southern Nuclear Operating Company, Inc. 4244 International Parkway, Suite 120 Document Control Coordinator Bin N-226-EC Atlanta, GA 30354-3906 3535 Colonnade Parkway Birmingham, AL 35243 George B. Taylor, Jr. 2100 East Exchange Pl Anne F. Appleby Atlanta, GA 30084-5336 Olgethorpe Power Corporation 2100 East Exchange Place Brian H. Whitley Tucker, GA 30084 3535 Colonnade Parkway, Bin N-226-EC 42 Inverness Center Parkway, BIN B237 County Commissioner Birmingham, AL 35243 Office of the County Commissioner Burke County Commission Mr. Michael Yox Waynesboro, GA 30830 Site Regulatory Affairs Director Vogtle Units 3 & 4 Mr. Wayne Guilfoyle 7825 River Road, Bin 63031 Commissioner District 8 Waynesboro, GA 30830 Augusta-Richmond County Commission 4940 Windsor Spring Rd Hephzibah, GA 30815 Gwendolyn Jackson Burke County Library 130 Highway 24 South Waynesboro, GA 30830 Mr. Reece McAlister Executive Secretary Georgia Public Service Commission Atlanta, GA 30334

Page 1 of 3

Vogtle Units 3 & 4 Mailing List

Email [email protected] (Amy Chamberlian) [email protected] (Amy Aughtman) [email protected] (Amanda Pugh) [email protected] (Anne W. Cottingham) [email protected] (Becky Rafter) [email protected] (Brian Whitley) [email protected] (Bill Jacobs) [email protected] (Brad Adams) [email protected] (Brandon Waites) [email protected] (Curtis Castell) [email protected] (James Comer) [email protected] (C.R. Pierce) [email protected] (David Jones) [email protected] (David Hinds) [email protected] (David Lewis) [email protected] (Danny Bost) [email protected] (Dale Fulton) [email protected] (Randy Culver) [email protected] (David Durham) [email protected] (Ed Burns) [email protected] (Ed David) [email protected] (Eddie R. Grant) [email protected] (Forrest Hundley) [email protected] (Fred Willis) [email protected] (SNC Document Control) [email protected] (Scott W. Gray) [email protected] (J.D. Williams) [email protected] (James Beard) [email protected] (Jannina Blanco) [email protected] (David Jantosik) [email protected] (Jennifer Buettner) [email protected] (Jeremiah Haswell) [email protected] (Jim Warren) [email protected] (John Bozga) [email protected] (Joseph Hegner) [email protected] (Jason R. Redd) [email protected] (Jerry Ranalli) [email protected] (Karen Patterson) [email protected] (Karl Gross) [email protected] (Kara Stacy) [email protected] (Kathryn M. Sutton) [email protected] (Kenneth O. Waugh) [email protected] (Markus Popa) Page 2 of 3

Vogtle Units 3 & 4 Mailing List

[email protected] (Matthew Williams) [email protected] (Mike Meier) [email protected] (Scott Peterson) [email protected] (Melissa Smith) [email protected] (Michael Kuca) [email protected] (M.W. Price) [email protected] (MKWashington) [email protected] (Michelle Graves) [email protected] (Marvin Fertel) [email protected] (Mike Yox) [email protected] (Michael Mariotte) [email protected] (Robert Temple) [email protected] (Patricia L. Campbell) [email protected] (Paul Gunter) [email protected] (Paul Bessette) [email protected] (Ravi Joshi) [email protected] (Russell Bell) [email protected] (Ronald Jones) [email protected] (Roger Wink) [email protected] (Steve A. Bennett) [email protected] (Sara Barczak) [email protected] (Stanford Blanton) [email protected] (Shiva Granmayeh) [email protected] (Steven Jackson) [email protected] (Storm Kauffman) [email protected] (Steve Roetger) [email protected] (Stephan Moen) [email protected] (Stephen Burdick) [email protected] (Tom Miller) [email protected] (Tom Clements) [email protected] (Vanessa Quinn) [email protected] (Brian McIntyre) [email protected] (Wesley A. Sparkman) [email protected] (Wayne Marquino) [email protected] (Doug Weaver) [email protected] (Gary Becker) [email protected] (Kristin Seibert)

Page 3 of 3



Report of Regulatory Audit License Amendment Related to

Crediting Previously Completed First Plant and First Three Plant Tests Vogtle Electric Generating Plant, Units 3 and 4 (LAR 18-019)

A. Background By letter dated August 3, 2018 (Reference 1), Southern Nuclear Operating Company (SNC or the licensee) requested an amendment to Combined License (COL) Numbers NPF-91 and NPF-92, for Vogtle Electric Generating Plant (VEGP) Units 3 and 4 (References 2 and 3). The requested amendment requires changes to the Updated Final Safety Analysis Report (UFSAR) in the form of departures from the incorporated plant-specific Design Control Document (DCD) Tier 2* and Tier 2 information and related changes to the VEGP Units 3 and 4 COL and COL Appendix C (and corresponding plant-specific DCD Tier 1) information. The requested amendment includes changes to credit previously completed first plant only and first three plant only testing as described in the licensing basis documents, including COL Condition 2.D.(2)(a) and plant-specific Tier 1 Section 2.1.3. Specifically, the proposed changes would revise the COL to delete conditions requiring the following tests: In-Containment Refueling Water Storage Tank (IRWST) Heatup Test, Reactor Vessel Internals Vibration Testing, and Core Makeup Tank (CMT) Heated Recirculation Tests. The documentation to establish a valid prototype reactor internals in accordance with Regulatory Guide 1.20, “Comprehensive Vibration Assessment Program for Reactor Internals During Preoperational and Initial Startup Testing,” is also included. The purpose of this audit is to gain a better understanding of the test results and quality assurance aspects of the testing. B. Bases This regulatory audit is based on the following:

• Vogtle Electric Generating Plant, Unit 3, Current Facility Combined License NPF-91,

Revised 09/11/2018, License Condition 2.D.(2)(a) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14100A106).

• Vogtle Electric Generating Plant, Unit 4, Current Facility Combined License NPF-92, Revised 09/11/2018, License Condition 2.D.(2)(a) (ADAMS Accession No. ML14100A135).

• Vogtle Electric Generating Plant, Units 3 and 4 Updated Final Safety Analysis Report, Revision 6 and Tier 1, Revision 5, August 11, 2017, Section 14.2.9.1.3 (ADAMS Accession No. ML17172A218).

The audit plan is available in ADAMS under Accession No. ML18256A323.



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C. Logistics Date: September 17, 2018 – October 31, 2018 Location: The audit was conducted primarily through the Westinghouse Electric Company’s (Westinghouse) electronic reading room. A meeting with Westinghouse subject matter experts was conducted on October 4, 2018, at Westinghouse Electric Company’s (the vendor’s) office at 11333 Woodglen Drive Suite 202, Rockville, Maryland 20852. D. Audit Team Members The following U.S. Nuclear Regulatory Commission (NRC) staff members participated in substantive discussions during the audit: Paul Kallan, Senior Project Manager (NRC), Lead Timothy Drzewiecki, Reactor Systems Engineer (NRC), Technical Reviewer Boyce Travis, Reactor Systems Engineer (NRC), Technical Reviewer Chakrapani Basavaraju, Mechanical Engineer (NRC), Technical Reviewer Yuken Wong, Mechanical Engineer (NRC), Technical Reviewer Michael Breach, Mechanical Engineer (NRC), Technical Reviewer Jeff Jacobson, Senior Reactor Operations Engineer (NRC), Technical Reviewer Aaron Armstrong, Reactor Operations Engineer (NRC), Lead Technical Reviewer E. Applicant and Industry Staff Participants Steve Leighty SNC) Kelli Roberts (SNC) Mark Wilson (SNC) Oscar Vinals Atienza (Westinghouse Electric Company (WEC)) Eddie Riffle (WEC) Gregory Meyer (WEC) Zachary Harper (WEC) F. Documents Audited General and Quality Assurance

• ND-EN-006-F01, Vendor Document Acceptance, “Sanmen 1&2 and Haiyang 1 First Plant Only and First 3 Plant Only Passive Core Cooling and Reactor System Tests,” July 27, 2018.

• ND-EN-006-F01, Vendor Document Acceptance, “NRC IP 70367 Comparison to Sanmen and Haiyang Admin Procedures,” July 30, 2018.

• HY1-PXS-T2R-504, “Partial Pre-Op Test Report for HY1-PXS-T1P-504,” July 7, 2017.

• HY1-PXS-T2R-504S01, “Partial Pre-Op Test Report for HY1-PXS-T1P-504,” July 6, 2017.



3

• SV3-JE61-VQQ-002, “Quality Release & Certificate of Conformance,” March 16, 2016. IRWST Heatup Test

• SM1-PXS-T2C-010, “SM1-PXS-T1P-504 Section 7.2 Passive Residual Heat Removal

(PRHR) Heat Exchanger (HX) Force Flow Heat Transfer Capability Test,” January 30, 2018.

• SM1-PXS-T2C-011, “SM1-PXS-T1P-504 Section 7.4 PRHR HX Natural Circulation Test,” December 16, 2016.

• SM1-PXS-T2P-001, “Sanmen Unit 1 PXS Hot Functional Test Results Validation for PRHR Performance,” December 16, 2016.

Reactor Vessel Internals Vibration Testing

• APP-CVAP-GER-003 (WCAP-17984), Rev. 0 “CVAP Vibration Analysis Program for the AP1000 Plant,” July 2015.

• APP-CVAP-GER-004 (WCAP-17983), Rev. 0, “CVAP Measurement and Inspection Programs for the AP1000 Plant,” March 2015

• SM1-CVAP-T2R-100, “Sanmen 1 Pre-FT Visual Inspection Report of the AP1000 of AP1000 RVI,” May 27, 2016.

• APP-GW-GLR-179 (SM1-CVAP-T2R-200), Rev. 0, “CVAP Preliminary Report for the Sanmen 1 AP1000 Plant,” September 2017

• APP-GW-GLR-181 (SM1-CVAP-T2R-300), Rev. 1, “CVAP Final Report for the Sanmen 1 AP1000 Plant,” March 2017.

• SM1-CVAP-T2R-400, Rev. 0, “Sanmen Unit 1 Post HFT Visual Inspection Report of the AP1000 RVI,” May 24, 2016.

• SM1-RXS-T2R-50007, “SM1-RXS-T1P-502 RV Vibration Test Pre-Op Test Report,” June 15, 2017.

• SM1-MI01-GNR-4154 (SM1-MI01-GQR-5064), Rev. 0, “Field Deviation Notice for Deficiencies Found in Guide Tube Flange Bolts and Locking Devices (Location 5),” March 11, 2016.

• SM1-MI01-GQR-5054, Rev. 0, “B8 Upper Guide Tube 270° Locking Cup is damaged,” March 1, 2017.

• SM1-MI01-GNR-4177 (SM1-MI01-GQR-5060), Rev. 0, “Field Deviation Notice for Dimple/Nick in Locking Cup Rim (CVAP Inspection Location 5),” February 6, 2017.



4

• SM1-MI01-GNR-4169 (SM1-MI01-GQR-5051), Rev. 0, “Field Deviation Notice for Post-HFT core barrel nozzle deficiencies,” March 11, 2016.

• APP-MI01-V2-140, Rev. 0, “AP1000 Reactor Internals Lower Core Barrel Assembly,” July 24, 2012.

• APP-MI01-V6-530, Rev. 1, “Ap1000 Reactor Internals Upper Core Plate,” November 27, 2007.

• SM1 RVI AS Built _ C-CB-12191-M06-1_R1_V3I-006, “Reactor Vessel Internals Core Cavity As-Built,” January 12, 2012.

• SV3 RVI As Built _ 2404908-0005 Rev 00_APP-MI01-V3I-006], Reactor Vessel Internals Core Cavity As-Built,” March 5, 2015.

• SV4 RVI As Built_2404909-0005_R1_V3I-006, Reactor Vessel Internals Core Cavity As-Built,” (Date not indicated).

• APP-MI01-V2-140, Rev. 0, “AP1000 Reactor Internals Lower Core Barrel

Assembly,”July 24, 2012.

• APP-MI01-V6-530, Rev. 1, “Ap1000 Reactor Internals Upper Core Plate,” November 27, 2007.

• SM1 RVI AS Built _ C-CB-12191-M06-1_R1_V3I-006, “Reactor Vessel Internals Core Cavity As-Built,” January 12, 2012.

• SV3 RVI As Built _ 2404908-0005 Rev 00_APP-MI01-V3I-006], Reactor Vessel Internals Core Cavity As-Built,” March 5, 2015.

• SV4 RVI As Built_2404909-0005_R1_V3I-006, Reactor Vessel Internals Core Cavity As-Built,” (Date not indicated).

CMT Heated Recirculation Tests

• APP-SSAR-GSC-810, “NOTRUMP Predictive Analysis of the CMT Recirculation, CMT Draindown, and ADS Blowdown Pre-Operational Tests”, September 7, 2016.

• SM1-PXS-T2C-012, “SM1-PXS-T1P-504 Section 7.5 (CMT) Recirculation Test Results Comparison to Predictive Analysis,” February 9, 2017.

• SM1-PXS-T2C-013, “SM1-PXS-T1P-504 Section 7.5 Core Makeup Tank Recirculation Test Flow Rate,” January, 23, 2017.



5

• SM1-PXS-T2C-014, “SM1-PXS-T1P-504 Section 7.7 CMT Draindown Test Results,” February 16, 2017.

• SM2-PXS-T2C-010, ““SM2-PXS-T1P-504 Section 7.5 Core Makeup Tank (CMT) Recirculation Test Results Comparison to Predictive Analysis,” March 16, 2018.

• SM2-PXS-T2C-011, “SM2-PXS-T1P-504 Section 7.7 Core Makeup Tank (CMT) Draindown Test Results Comparison to Predictive Analysis,” March 1, 2018.

• SM2-PXS-T2C-013, “SM2-PXS-T1P-504 Section 7.5 Core Makeup Tank Recirculation Test Flow Rate,” March 12, 2018.

• SM2-PXS-T2C-014, “SM2-PXS-T1P-504 Section 7.7 CMT Draindown Test Results,” March 12, 2018.

• HY1-PXS-T2C-016, “HY1-PXS-T1P-504 Section 7.5 Core Makeup Tank (CMT) Recirculation Test Results Comparison to Predictive Analysis,” July 13, 2017.

• HY1-PXS-T2C-018, “HY1-PXS-T1P-504 Section 7.5 Core Makeup Tank Recirculation Test Flow Rate,” July 11, 2017.

• HY1-PXS-T2C-019, “HY1-PXS-T1P-504 Section 7.7 CMT Draindown Test Results,”

July 24, 2017. G. Description of Audit Activities and Summary of Observations Staff examined documentation supporting LAR-18-019 and discussed material with subject matter experts in the areas of Quality Assurance, IRWST Heatup Testing, Reactor Internals Vibration Testing, and CMT Heated Recirculation Tests. Audit activities within each of these areas is described below. General and Quality Assurance Staff examined ND-EN-006-F01, Vendor Document Acceptance Form, “Sanmen 1&2 and Haiyang 1 First Plant Only and First 3 Plant Only Passive Core Cooling and Reactor System Tests.” During this examination staff made the following observations:

• SNC used the ND-EN-006-F01, Vendor Document Acceptance Form to document their review of the the vendor’s evaluations of the IRWST heatup test, CMT recirculation tests, and CMT draindown tests. The vendor document acceptance form states that the reviewed documents are not being accepted by SNC. During a clarification call, conducted as part of the audit, SNC clarified that access to the reviewed vendor’s reports are not part of Vogtle Units 3 and 4 permanent plant records, however, access to the reports is maintained through an owners’ agreement.

• SNC determined that the documents are acceptable with comments.



6

Staff examined ND-EN-006-F01, Vendor Document Acceptance, “NRC IP 70367 Comparison to Sanmen and Haiyang Admin Procedures.” During this examination staff made the following observations:

• SNC reviewed the following test procedures and reports for tests performed at Haiyang Unit 1, Sanmen Unit 1, and Sanmen Unit 2:

o HY1-PXS-T2R-504

o HY1-PXS-T1P-504

o HY1-PXS-T1P-505

o SM1-PXS-T1P-504

o SM1-PXS-T1P-505

o SM2-PXS-T1P-501

o SM2-PXS-T1P-504

o SM2-PXS-T1P-505

o ND-CX-001-F04

SNC reviewed the tests against NRC Inspection Plan 70702, “Part 52 Inspection of Preoperational Test Performance,” (ADAMS Accession No. ML17229B640). SNC completed Section 3.03, “Procedure Review,” and Section 3.05 “Test Results Review” of NRC Inspection Procedure 70702.

Staff examined ND-CX-001-F04, Vendor formal test and observation report, “China Testing Observation Plan and Report: First-3-Plant only Preoperational Test at Sanmen Unit 2.” During this examination staff observed that SNC formal test and observation report documented the observation and oversight of activities affecting quality at Sanmen Unit 2.

The staff examined SNC comparison of China’s Regulatory Quality Assurance Program requirements to the requirements of 10 CFR Appendix B. SNC determined that the documents are acceptable with comments.

IRWST Heatup Testing The staff reviewed SM1-PXS-T2CP-001, “Sanmen Unit 1 PXS Hot Functional Test Results Validation for PRHR Performance” in order to examine the vendor’s evaluation of the IRWST heatup test results. At Sanmen Unit 1, both natural and forced circulation tests of the PRHR were performed, in accordance with the AP1000 design bases as documented in DCD Chapter 14. These tests measured PRHR flow, hot leg temperature and PRHR outlet temperature and calculated heat transfer through the PRHR. These test results were compared to LOFTRAN calculations for performance acceptance criteria. [ ] Staff did not review the acceptance criteria for these tests specifically, as they are not part of the scope of the LAR, but did familiarize themselves with



7

the test procedure and test conditions, as the same tests were also used to measure IRWST heatup. Appendix C of SM1-PXS-T2P-001 documents the vendor’s evaluation of the IRWST heatup results. The vendor states that the purpose of the test is to demonstrate that the non-LOCA accident analyses are performed conservatively with respect the LOFTRAN model. The stated test acceptance criteria are: [ ], that heatup characteristics are acceptable and conservative with respect to Chapter 15 analysis conditions, and IRWST heatup characteristics support meeting the RCS safe shutdown temperature criteria in Chapter 19. Due to discrepancies between the DCD and the UFSAR versions used in Sanmen Unit 1 versus those used by the applicant, not all of these acceptance criteria are applicable; namely, those regarding PRHR assumptions used in long term cooling related to Chapter 19. Staff reviewed the purposes and acceptance criteria stated in the UFSAR and determined that the set of acceptance criteria evaluated by the vendor as part of SM1-PXS-T2P-001 encompasses (and exceeds) those set forth in the UFSAR. Accordingly, Appendix C documents the test results for PRHR heatup. The water temperature in the IRWST was recorded at various elevations and positions. Those data were not provided directly in the document and instead attached in the vendor’s electronic document management system, and so staff requested the applicant provide the data. They did so in the form of temperature plots at the various positions in the IRWST. Staff examined the provided data and found no issues with the conclusions as drawn by the vendor as they relate to the data ([ ]). The LOFTRAN analysis performed by the vendor shows a calculated heat transfer rate of less than the observed test heat transfer rates, accounting for uncertainty, and the trends between the two calculations agree throughout. The licensee performed sensitivity studies for both the forced flow and natural circulation that included the effect of modeling the IRWST below the heat exchanger, and both calculations are conservative with respect to the observed heat transfer through the PRHR. As such, the vendor concluded that assumptions made in developing the PRHR and IRWST heat transfer model, including the effect of IRWST heatup, are conservative, and the LOFTRAN model is therefore acceptable for the non-LOCA accident analysis. [ ] the heatup characteristics of the IRWST and the conservatism of the Chapter 15 analyses are required acceptance criteria. As stated above, the vendor performed an evaluation of the test data and determined these acceptance criteria to be satisfied in accordance with those documented in the UFSAR as the reasoning for this test. The licensee documented a review and evaluation of the Sanmen test data and the vendor’s evaluation in ND-EN-006-F01. The licensee accepted the conclusions as drawn by the vendor and



8

the validity of the documented test data inputs. The licensee then documented the conclusions drawn from the test data in the LAR. Reactor Internals Vibration Testing The staff reviewed SM1-CVAP-T2R-200 Table 4-1, “Pre- and Post-Hot Functional Test Inspections” to determine if there are loose parts or abnormal wear due to adverse flow-induced vibration. [ .] [ ] There were no broken or loose parts of the reactor vessel internals assembly that would require a design change. [ ] The statement could be reworded as: “No broken or loose parts of the reactor internals assembly were found.” The staff reviewed the following drawings furnished by the licensee:

• APP-MI01-V2-140, Rev. 0 • APP-MI01-V6-530, Rev. 1 • SM1 RVI AS Built _ C-CB-12191-M06-1_R1_V3I-006 • SV3 RVI As Built _ 2404908-0005 Rev 00_APP-MI01-V3I-006



9

• SV4 RVI As Built_2404909-0005_R1_V3I-006 The staff was able to confirm the following dimensions and as-built gaps for the units.

Design dimensions:

Item (Reference)

Design Dimensions (in) Nominal Tolerances Min. Max.

Upper Core Plate OD

(APP-MI01-V6-530) [ ] [ ] [ ] [ ] [ ]

Core Barrel ID (APP-MI01-V2-140) [ ] [ ] [ ] [ ] [ ] Design

Gaps (in)

Min. [ ] Avg. [ ] Max. [ ]

As-built gaps:

Circumferential Location (deg.)

As-Built Gaps (in) SM1 SV3 SV4

[ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ]

Min. Gap [ ] [ ] [ ] Avg. Gap [ ] [ ] [ ] Max. Gap [ ] [ ] [ ]

The staff reviewed the discussion of the design to address leakage-based instability in the CVAP pre-test report, APP-CVAP-GER-003, Section 5.4.1.5.4. [ ] The staff concurs that instability is not a concern at this location. CMT Heated Recirculation Tests Predictive Analysis Staff examined APP-SSAR-GSC-810 and noted the purpose of the calculation, important input into the analysis, and the main results associated with the CMT recirculation and CMT Draindown tests. In particular, staff noted: the purpose of the calculation note is to document predictive analysis for the CMT heated recirculation tests and ADS blowdown test. Predictive analyses are provided for the tests described in the following UFSAR sections:

o 14.2.9.1.3.k



10

o 14.2.9.1.3.w o 14.2.9.1.3.s (note that this test is not subject to the proposed changes under LAR-

18-019)

• The predictive analyses of the CMT recirculation test assume: o [

] o [

] o [ ]

• The predictive analyses of the CMT draindown test assume:

o [ ]

o [ ]

• [ ]

• [

]

• [ ] [ [ ] [ ]

[ ]

[ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ]

] • [

].

• The pretest analysis for the CMT recirculation test stated:

o [ ]

o [



11

]

o [

]

o [

]

o [

]

o [

]

• The pretest analysis for the CMT draindown test stated:

o [ ]

o [ ]

o [

]

o [



12

]

Sanmen Unit 1 Recirculation Test Staff examined SM1-PXS-T2C-012 and noted the purpose of the calculation, important input into the analysis, and the main results. In particular, staff noted:

• The purpose of this calculation note is to (1) compare the NOTRUMP prediction to the test data, specifically, the CMT recirculation volumetric flow rates along with other pertinent initial conditions, and (2) demonstrate that the CMT recirculation test is acceptable with respect to the safety analysis.

• The calculation notes that [

]

• The calculation notes the following acceptance criteria for the CMT recirculation test :

o [ ]

o [ ]

o [ ]

o [

]

• Differences between the predictive analysis and the tests include:

o The initial conditions of the test:

[ [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ]

[ ] [ ]



13

] [

]

[

.]

[

]

[

]

• The analysis compares the data from the CMT flow rates to the predictive analysis and

states: o [

]

o [ ]



14

• The calculation note concludes that (1) the CMT injection flow rate is consistent with the predictive analysis, (2) the test demonstrated that the CMT will recirculate and inject its cold water into the reactor coolant system, and (3) the acceptance criteria for the hot functional CMT test are satisfied.

Staff examined SM1-PXS-T2C-013, “SM1-PXS-T1P-504 Section 7.5 Core Makeup Tank Recirculation Test Flow Rate.” During this examination, staff noted the purpose of the calculation, important input into the analysis, and the main results. In particular, staff noted:

• The purpose of the calculation note is to determine the CMT outlet flow rates during the CMT recirculation test and evaluate the CMT temperature distribution during the CMT recirculation test.

• Flow measurements were made using redundant and diverse instrumentation. In particular, flow measurements [ ]

o [ ]

o [ ]

o [

]

o A pre-test calibration was performed [ ]

[

]

[ ]



15

[ ]

• Uncertainty was determined according to ASME PTC 19.1-2005 “Test Uncertainty”. [

]

Sanmen Unit 1 Draindown Test Staff examined SM1-PXS-T2C-014, “SM1-PXS-T1P-504 Section 7.7 CMT Draindown Test Results.” During this examination, staff noted the purpose of the calculation, important input into the analysis, and the main results. In particular, staff noted:

• The purpose of this calculation note is to examine CMT performance to ensure that the level instrumentation is properly operating and to compare CMT performance with predictive analysis.

• The initial test conditions for this test are:

o [

]

o [ ]

o [ ]

o [ ]

o [ ]

o [ ]

o [

]

• The test is initiated [ ]

• [ ]



16

• The test acceptance criteria address the receipt of specific alarms and instrument measurement capability. The specific acceptance criteria are:

o [ ]

o [ ]

o [

]

• The test results indicated that the acceptance criteria were satisfied and that the CMT

transitioned from recirculation mode to draindown mode. Specifically:

o [ ]

o [ ]

o [

]

• Additional test results, that are beyond test acceptance criteria, indicated that:

o Consistent with the predictive analysis, the CMT draindown test confirm that, upon

a single ADS 1 valve is opening, the hot CMT will first operate in a recirculation mode and then transition to a draindown mode of operation as RCS inventory is lost.

o [

]

o [

]

Sanmen Unit 2 Recirculation and Draindown Tests



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Staff examined SM2-PXS-T2C-010 and compared it against SM1-PXS-T2C-012. Staff observations on the purpose of the calculation, important input into the analysis, and the main results documented for SM1-PXS-T2C-012, above, are applicable to staff’s examination of SM2-PXS-T2C-010 with the following exceptions:

• [ ]

• [ ]

Staff examined SM2-PXS-T2C-011 and compared it against SM1-PXS-T2C-014. Staff observed that the purpose of SM2-PXS-T2C-011 is limited to comparing the test results to the predictive analysis, but does not extend to ensuring that the level instrumentation is properly operating (level instrumentation is addressed in SM2-PXS-T2C-014). Additional observations associated with the test comparison to the predictive analysis include:

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Staff examined SM2-PXS-T2C-013 and compared it against SM1-PXS-T2C-013. Staff observation on the purpose of the calculation, important input into the analysis, and the main results documented for SM1-PXS-T2C-013, above, are applicable to staff’s examination of SM2-PXS-T2C-013 with the following exception:

• [ ] However, this does not impact the results because the only difference is [ ]



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Staff examined SM2-PXS-T2C-014 and compared it against SM1-PXS-T2C-014. Staff observed that the purpose of SM2-PXS-T2C-014 is limited to ensuring that the level instrumentation is properly operating and does not address the predictive analysis (test comparison with predictive analysis is address in SM2-PXS-T2C-011). Staff observations observation associated with the test documented in SM1-PXS-T2C-014 are applicable to staff’s examination of SM2-PXS-T2C-014 with the following exception:

• [ ]

Haiyang Unit 1 Recirculation and Draindown Tests Staff examined HY1-PXS-T2C-016 and compared it against SM1-PXS-T2C-012. Staff observations on the purpose of the calculation, important input into the analysis, and the main results documented for SM1-PXS-T2C-012, above, are applicable to staff’s examination of HY1-PXS-T2C-016 with the following exceptions:

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Staff examined HY1-PXS-T2C-018 and compared it against SM1-PXS-T2C-013. Staff observation on the purpose of the calculation, important input into the analysis, and the main results documented for SM1-PXS-T2C-013, above, are applicable to NRC staff’s examination of SM2-PXS-T2C-013 with the following exception:

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• Similar to the testing at Sanmen Unit 1, [ ] Like the testing at Sanmen Unit 1, [ ]

Staff examined HY1-PXS-T2C-019 and compared it against SM1-PXS-T2C-014. Staff observation on the purpose of the calculation, important input into the analysis, and the main results documented for SM1-PXS-T2C-014, above, are applicable to staff’s examination of SM2-PXS-T2C-014 with the following exceptions:

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H. Exit Briefing The staff’s audit exit briefing was conducted on October 31, 2018. The licensee and staff discussed the staff’s takeaways from the audit, and the staff indicated that the necessary information within the scope of the audit was provided to assist the staff in their review. I. Requests for Additional Information (RAI) Resulting from Audit No RAIs were issued as a result of this audit. J. Open Items and Proposed Closure Paths No open items were identified as a result of the audit. K. Deviations from the Audit Plan



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The duration of the audit was extended in order to allow staff to examine documents that were added to the electronic reading room following the meeting with the vendor subject matter experts on October 4, 2018. L. References

1. Southern Nuclear Operating Company, Vogtle Electric Generating Plant Units 3 and 4, Request for License Amendment and Exemption: Crediting Previously Completed First Plant and First Three Plant Tests (LAR-18-019), August 3, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML18215A382).

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

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

4. Vogtle Electric Generating Plant, Units 3 and 4 Updated Final Safety Analysis Report, Revision 6 and Tier 1, Revision 5, August 11, 2017 (ADAMS Accession No. ML17172A218).