ML18058A555
| ML18058A555 | |
| Person / Time | |
|---|---|
| Issue date: | 01/24/2018 |
| From: | Charles Brown Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| NRC-3485 | |
| Download: ML18058A555 (285) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards APR1400 Subcommittee: Open Session Docket Number: (n/a)
Location: Rockville, Maryland Date: Wednesday, January 24, 2018 Work Order No.: NRC-3485 Pages 1-173 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 1
2 3
4 DISCLAIMER 5
6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9
10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.
16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.
20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS)
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APR1400 SUBCOMMITTEE
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OPEN SESSION
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WEDNESDAY JANUARY 24, 2018
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ROCKVILLE, MARYLAND
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The Subcommittee met at the Nuclear Regulatory Commission, Two White Flint North, Room T2B1, 11545 Rockville Pike, at 1:00 p.m., Ronald G.
Ballinger, Chairman, presiding.
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2 COMMITTEE MEMBERS:
RONALD G. BALLINGER, Chairman CHARLES H. BROWN, JR., Member MICHAEL CORRADINI, Member VESNA B. DIMITRIJEVIC, Member WALTER L. KIRCHNER, Member JOSE A. MARCH-LEUBA, Member DANA A. POWERS, Member GORDON R. SKILLMAN, Member JOHN W. STETKAR, Member MATTHEW W. SUNSERI, Member ACRS CONSULTANT:
STEPHEN SCHULTZ DESIGNATED FEDERAL OFFICIAL:
CHRISTOPHER BROWN ALSO PRESENT:
JOE ASHCRAFT, NRO JOHN BUDZYNSKI, NRO ALEX BURJA, NRO SANG-JU CHO, KNF NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 MANSEOK DO, KNF ASHLEY FERGUSON, NRR KEN GEELHOOD, PNNL JIM GILMER, NRO ZACH GRAN, NRO CRAIG HARBUCK, NRR JOHN HONCHARIK, NRO*
REBECCA KARAS, NRO KERRI KAVANAGH, NRO LAUREN KENT, NRO IL-KYU KIM, KNF JUNGHO KIM, KHNP YOUNGLEI KIM, KEPCO E&C YUNHO KIM, KHNP NICK KLYMYSHYN, NRO OHHYUN KWON, KNF HIEN LE, NRO SANWON LEE, KHNP DAEHEON LIM, KEPCO E&C TIM LUPOLD, NRO MIKE MCCOPPIN, NRO JILL MONAHAN, Westinghouse JIYONG OH, KHNP JONATHAN ORTEGA, NRO JAEHYUK PARK, KEPCO E&C NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 CAYETANO SANTOS, NRO KEN SCAROLAR, NAE ROB SISK, Westinghouse ANGELO STUBBS, NRO ED STUTZCAGE, NRO ROBERT SWEENEY, KHNP MATT THOMAS, NRO CARL THURSTON, NRO T.R. TJADER, NRR JESSICA UMANA, NRO CHRIS VAN WERT, NRO ANDREA D. VEIL, Executive Director, ACRS DAVE WAGNER, AECOM BILL WARD, NRO STEVE WILLIAMS, NRO CHENG-IH WU, NRO GEORGE WUNDER, NRO
- Present via telephone NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 C-O-N-T-E-N-T-S Opening Remarks & Objectives.......................6 Staff Opening Remarks.............................10 Chapter 4 Reactor/PLUS7 Fuel Topic Report Chapter 14.1 (specific information to be addressed for the initial plant test program) & 14.2 (initial plant test program)....................................52 Chapter 16 Technical Specification................75 Chapter 18 HFE...................................117 Public Comments..................................155 Subcommittee Discussion..........................156 Adjourn..........................................173 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 P R O C E E D I N G S 2 1:00 p.m.
3 CHAIRMAN BALLINGER: The meeting will now 4 come to order, please. I got it, it's on.
5 This is a meeting of the APR1400 6 Subcommittee of the Advisory Committee on Reactor 7 Safeguards.
8 I'm Ron Ballinger, now a Professor 9 Emeritus, Chairman of the APR1400 Subcommittee.
10 MEMBER POWERS: And I assume that students 11 throughout MIT campus are celebrating, right?
12 CHAIRMAN BALLINGER: Yes, major 13 demonstrations. I'm getting gifts of vanilla, 14 Swiss-almond ice cream.
15 The ACRS in attendance are Vesna 16 Dimitrijevic. Did I get it right? Perfect, that's 17 the last time that'll happen.
18 (Laughter.)
19 Walt Kirchner. I think Charlie Brown is 20 lurking around here somewhere.
21 John Stetkar, Matt Sunseri, Dana Powers, 22 Gordon Skillman, Stephen Schultz, former ACRS member 23 and esteemable consultant. Michael Corradini.
24 We may have others join on the line but 25 I'm not exactly sure. But Jose March-Leuba will be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 1 here. Chris Brown is the Designated Federal Official, 2 along with Zeynab Abdullahi. I probably did that bad.
3 The purpose of today's meeting is for the 4 Subcommittee to receive briefings from Korea Electric 5 Power Corporation, and Korea Hydro and Nuclear Power 6 Company, HNP, regarding their design certification 7 application, and the NRC Staff regarding their Safety 8 Evaluation Report with no open items, no open items 9 specific to verification programs, Chapter 14.1; 10 specific information to be addressed in the initial 11 plant test program, 14.2; Chapter 16, Technical 12 Specifications; Chapter 18, Human Factors in 13 Engineering.
14 Also, the topic report of NCR on the PLUS7 15 fuel design will also be presented.
16 The ACRS was established by statute and 17 is governed by the Federal Advisory Committee Act, FACA.
18 That means that the Committee can only speak through 19 its published letter reports.
20 We hold meetings to gather information to 21 support our deliberations. Interested parties who 22 wish to provide comments can contact our Offices 23 requesting time after the meeting announcement is 24 published in the Federal Register.
25 That said, we also set aside ten minutes NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 for comments from members of the public attending or 2 listening to our meetings. Written comments are also 3 welcome.
4 The ACRS section of the U.S. NRC public 5 website provides our charter bylaws, letter reports, 6 and full transcripts of all full and Subcommittee 7 meetings, including slides presented at the meetings.
8 The rules for participation in today's 9 meeting were announced in the Federal Register on 10 January 12, 2018. The meeting was announced as an open, 11 closed-to-the-public meeting.
12 This meant that the Chairman can close the 13 meeting as needed, and we will do that for the staff 14 presentation on the PLUS7 fuel.
15 I think everything else is 16 non-proprietary, and the reason it is that way on the 17 schedule the way you see it is that a consultant or 18 somebody has to leave quickly to catch an airplane.
19 So, that's why the order is what it is. No 20 requests for making statements of the Subcommittee has 21 been received from the public. The transcript of the 22 meeting is being kept and will be made available, as 23 stated in the Federal Register notice.
24 Therefore, I would request that 25 participants of this meeting use the microphones NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 1 located throughout the meeting room when addressing 2 the Subcommittee, and make sure the little green light 3 is on when you're talking.
4 Participants are to first identify 5 themselves and speak with sufficient clarity and volume 6 so that they can be readily heard.
7 We have a bridge line established and I 8 think there's one for Westinghouse, right? And also 9 for interested members of the public to listen in.
10 The bridge number and password were published 11 in the agenda posted on the NRC website.
12 To memorize disturbance, this public line 13 will be kept in the listen-only mode. The public will 14 have an opportunity to make a statement or provide 15 comments at a designated time towards the end of the 16 meeting.
17 I would request now that the meeting 18 attendees and participants silence all their cell 19 phones and other electronic devices.
20 Oh, he is here. Okay, he's hiding behind 21 the post.
22 I invite Bill Ward, the NRO Project 23 Manager, to introduce the presenters and start the 24 Meeting.
25 Bill?
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10 1 MR. WARD: Thank you. Once again, we 2 thank the ACRS for having the meetings and we're getting 3 pretty close to the end of Phase 5 here.
4 There's a couple more months left and we're really 5 thankful for the flexibility the ACRS has shown in 6 helping us get Meetings together a little bit, as we 7 get chapters done so that we can meet our goals.
8 Thank you again.
9 MR. SISK: Thank you, Chairman. I'd like 10 to echo the Staff's comments.
11 We do appreciate very much this opportunity 12 to continue our presentations on our Phase 5 Review 13 for SERs with no open items.
14 And we certainly appreciate ACRS's working 15 with us and the Staff to make these meetings possible 16 and maintain our schedules as we go forward.
17 So, without any further comments at this 18 point in time, I'd like to turn this over to Mr. Il-Kyu 19 Kim, who will be leading the presentation on Chapter 20 4.
21 MR. I. KIM: Good afternoon, my name is 22 Il-Kyu Kim from KEPCO Nuclear Fuel. I will present 23 Chapter 4, Reactors.
24 This presentation consists of four 25 sections of review over Chapter 4, some are open items, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 1 current status, and attachments.
2 Chapter 4 consists of six sections, which 3 some are a description of fuel system design, nuclear 4 design, thermal-hydro design, reactor motors, and the 5 functional design of the reactivity control system.
6 This slide shows the lists of summary to 7 the documents and the summary of RAIs.
8 This uncontrolled document of Chapter 4 9 and the six Topical Reports and the technical report 10 was submitted for this Chapter 4.
11 62 RAIs were issued for Chapter 4 and there 12 were four open items at Page 3. However, all of the 13 RAIs have been resolved and there is no open item now.
14 Description and the resolution for the four 15 open items will be explained in the next slide. This 16 slide shows the list of open items.
17 There were four open items at Page 3.
18 The open items are impact of thermal 19 conductivity degradation, fuel-assembly structural 20 response, CPS set-point, analysis, and methodology, 21 and also then to classification and experience.
22 This and the next slide show the summary 23 of open items related to the impact of thermal 24 conductivity degradation.
25 The description of the issue, NRC Staff NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 1 noted that 33B does not account for the effect over 2 thermal conductivity degradation, and requested a TCD 3 impact on fuel-rod design and the CFT analysis.
4 The resolution is TCD penalty was 5 conservatively determined based on the analysis of a 6 comparison to experimental data at various points.
7 And the KHMP responded that the 8 (unintelligible due to accent) visuals for the fuel-rod 9 design was satisfied with the constellation of the TCD.
10 Also, KHMP responded that as the original 11 toggle for safety analysis with the constellation of 12 the TCD, all the TCD-affected areas were satisfied here.
13 The following Topical Report and the 14 technical report were revised to reflect the impact 15 of TCD, and the following TCD-affected TCD Tier RAI 16 sections were revised to reflect the impact of TCD.
17 And the next slide shows the summary of 18 open item related to fuel-assembly structural response.
19 MEMBER KIRCHNER: May I stop you and go 20 back one slide, please?
21 I was looking at the list of revisions, 22 could you just explain why the TCD had an impact on 23 your containment functional design?
24 MR. I. KIM: Chapter 6? Will you please 25 explain for the Chapter 6.21 section?
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13 1 MR. JEONG: Okay, this is Jaehoon Jeong 2 from KEPCO Nuclear Fuel. Because TCD impacts the 3 initial store of energy which is used for containment 4 pressure and temperature calculations.
5 So, we reflected the TCD penalty on our 6 containment analysis, we concluded that the current 7 (unintelligible due to accent) is too varied. Even 8 we considered the TCD impact on other systems.
9 MEMBER KIRCHNER: So, you still retain the 10 significant margin?
11 MR. JEONG: Yes.
12 MEMBER KIRCHNER: On the containment 13 response?
14 MR. JEONG: That's right.
15 MEMBER KIRCHNER: Okay, thank you.
16 MR. I. KIM: Okay, I will continue.
17 Okay, description of this issue, KPHM had 18 provided a technical report, Revision 0, for the PLUS7 19 EOL analysis.
20 The report contains PLUS7 LOCA analysis 21 result at EOL condition, to consider NRC Implementation 22 Notice 2012-09.
23 The EOL PLUS7 fuel assembly model for the 24 analysis was developed here based on EOL PLUS7 test 25 data, and the BOL and the EOL test data from CENPD-178-P.
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14 1 (Unintelligible due to accent) requested 2 to provide the findings at the review, the technical 3 report, seismic LOCA analysis result for the BOL 4 conditions.
5 Because the technical report does not 6 contain EOL analysis results and applicability of the 7 EOL test data from CENPD-178-P, and the methodology 8 used to obtain (unintelligible due to accent) over fuel 9 assembly.
10 And the justification for the critical 11 ratio uses the four-sided LOCA analysis. The last one 12 is the justification for the closest strings of the 13 breed.
14 This next slide shows the resolutions for 15 the NRC request. KHMP performed the site LOCA analysis 16 based on the new test to response the RAIs.
17 Following new tests for PLUS7 fuel assemblies 18 and the (unintelligible due to accent) were performed 19 using Westinghouse's Columbia facility, at BOL and/or 20 EOL conditions to define their fuel-line assembly and 21 characteristics.
22 The fuel assembly model for the site LOCA 23 analysis was developed here. Site and LOCA analysis 24 were performed at BOL and the EOL conditions.
25 The analysis results show that the PLUS7 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 1 fuel assembly maintains structural integrity for 2 seismic or LOCA event at BOL and EOL conditions.
3 The methodology used for the test, model 4 development and analysis is based on the CENDP-178-P, 5 Revision 1, which was approved by NRC.
6 KHMP provided the following to NRC, the 7 revision over the technical input for seismic and LOCA 8 analysis and the responses for the RAIs, which was an 9 open item.
10 This slide shows the summary of open items 11 related to CPC set-point analysis methodology.
12 Description, analysis requested to provide the 13 basis for using a one-sided tolerance limiting factor 14 of 1.645 in the technical report.
15 And to discuss why this factor is 16 consistent with Regulatory Guide 1.105. Set-point for 17 safety-related instrumentation, Revision 3.
18 Resolution, KHMP responded that the application 19 of the set-points for the CPC, CPC's the Core Protection 20 Calculator, is inherently one-sided so that the value 21 of 1.645 is the 95 by 95 one-sided tolerance limiting 22 factor for an infinite number of data-points.
23 Other later protection system set-points 24 complied with Reg Guide 1.105, Revision 3, except the 25 CPC set-point complied with CPC set-point methodology NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 technical report.
2 Therefore, KHMP will revised the TCD Table 3 1.9-1, Table 7.1-1, Chapter 7 and the Chapter 15, with 4 the exception of compliance with Regulatory Guide 5 1.105, Revision 3.
6 This slide shows the summary of open items 7 related to adverse-event classification and 8 experience.
9 Description of issue, the step did not 10 believe that the adverse event is not the pressure 11 boundary component since it replaces pressure boundary 12 house nut.
13 KHMP was requested to provide data and 14 operational experience that demonstrates work in 15 practice.
16 Resolution, KHMP provided the explanation 17 of functionality principle between the adverse event 18 as the venting device seal, and the housing nut as a 19 pressure boundary component with the seal weld.
20 KHMP provided relevant data and 21 operational experience.
22 And this slide explains the current status 23 of TCD Chapter 4. Chapter 4 is completed; KHMP 24 continues to monitor Chapter 4 to assure any conforming 25 changes are addressed.
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17 1 All open items that were identified in Page 2 3 have been resolved with adequate discussion on the 3 step.
4 Changes in Chapter 4, as it reviewed and 5 marked up in response to the RAI, will be incorporated 6 into the next revision, Revision 2, of the TCD.
7 This presentation has been finished.
8 Thank you so much for listening.
9 MR. SISK: So, this is Rob Sisk.
10 So, this is on Chapter 4; we'll move to 11 PLUS7 if there are no other additional comments on 12 Chapter 4 at this point.
13 So, not hearing questions at this point, 14 I would like to invite Mr. Kwon to provide a Chapter 15 7 overview?
16 MR. KWON: Good afternoon, my name is 17 Ohhyun Kwon from KEPCO Nuclear Fuel. I represent the 18 PLUS7 topical approach.
19 This slide shows the brief content such 20 as introduction, summary of PLUS7 purity design Topical 21 Report, RAI status, and quality status.
22 PLUS7 purity design Topical Report is to 23 evaluate mechanical integrity of PLUS7 fuel assembly 24 and PLUS7 purity design procurement.
25 PLUS7 fuel was developed to comply with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 1 the 10CFR Regulatory Guide and the Review Plan.
2 The contents of PLUS7 purity design report 3 consist of six chapters: introduction, fuel assembly, 4 and component design, fuel design, PLUS7 fuel 5 experience, and conclusion and reference.
6 Open disk describes various mechanical 7 tests, operating experience, scram data, verification, 8 and various improvements analysis.
9 This slide shows the PLUS7 design 10 features. The fuel rod is 16 by 16, and the number 11 of fuel rods in an assembly are 236. 9 number of degrees 12 and 4 numbers of shingles are used.
13 On top, on bottom, and one protective grate 14 are used at the top and the bottom position of fuel 15 assembly.
16 For fuel assembly design evaluation, the 17 integrity of PLUS7 fuel was verified based on RO5 test 18 and the calculation.
19 In later performance data and operating 20 experience, it compounded the performance of the PLUS7 21 fuel. PLUS7 fuel met all the design criteria related 22 to the mechanical integrity.
23 For fuel-rod design evaluation, fuel-rod 24 design evaluation was performed for design criteria 25 including creating stress, strain, fatigue, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 1 oscillation, high driving, rod internal pressure, 2 collapse, overheating, and (unintelligible due to 3 accent) interaction.
4 All of the fuel-rod design criteria were 5 met up to the maximum fuel rod eligible for 60 kilowatts 6 a day for the battery.
7 CHAIRMAN BALLINGER: I have a number of 8 questions, I'm not sure where to ask them, and I'm just 9 trying to find where in the presentation is appropriate, 10 but this probably is good enough to start.
11 I'm looking at the fatigue analysis that 12 was done, and I'm trying to figure out what the actual 13 duty cycle was for the fuel to get to the cumulative 14 usage factor.
15 I think it's 0.77 that you came up with.
16 And so I can identify the load follow 10 percent to 17 100 percent, I can get that more or less.
18 I can get the AOOs and things like that, 19 but is there a table somewhere -- and I couldn't find 20 it, maybe it's in another Chapter -- where it lets me 21 determine that usage factor?
22 Because the usage factor is presented as 23 0.77 but I can't get to there by looking at the data 24 in the PLUS7 Fuel Design Chapter.
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20 1 where -- it may be somewhere, I just don't know where 2 it is.
3 MR. KWON: In the Topical Report, Chapter 4 3.43.
5 CHAIRMAN BALLINGER: 3.4, I have some of 6 it here. 3.4, okay, that was the thing that got me 7 going here on this.
8 And that is fatigue damage factor for the 9 daily load following operation was calculated using 10 the same -- you know, the FATES3B code.
11 So, that's all that says there, and it says 12 the total cumulative fatigue damage factor from daily 13 load following operation.
14 I'm assuming that's the 10 percent to 100 15 percent power and back? Reactor trips and starts and 16 shutdowns was 0.77. So, I just can't deconvolute the 17 0.77.
18 I can get two out of the three, or three 19 out of the four, components to the fatigue light, but 20 I can't get everything.
21 MEMBER SKILLMAN: Rob, and others, I'm 22 complicit with Ron in asking this question, and the 23 question really starts on Chapter 3.2.3. and there, 24 you identify startup and shutdown, power variations 25 during normal operation and reactor trip.
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21 1 And we kind of figured there must be a table 2 in and around Table 3-4 that would account for those 3 cycles.
4 And I'm looking through all of the tables 5 in Chapter 3; we were not able to find an accounting 6 for the startups and shutdowns, the power variations.
7 And they are 10 percent and 100 percent 8 on a daily basis for each day. That would suggest in 9 a 24-month fuel cycle a fairly large number of those 10 cycles.
11 And then the reactor trips, we just 12 couldn't find a table to account for those transients.
13 And it may be in another place and we just 14 couldn't find it so we're not saying it's not there.
15 We were just not able to find it.
16 CHAIRMAN BALLINGER: I think they could 17 get back to us on that, right? We don't need to go 18 hunting and pecking here.
19 MEMBER SKILLMAN: Yes, if we can have it 20 sometime later, point us to it, that would be fine.
21 MR. SISK: We've taken the note down. We 22 have limitations on time obviously, but we'll keep that 23 going.
24 MEMBER SKILLMAN: The action item is 25 reconcile 3.2.3.
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22 1 MR. SISK: That's right.
2 MEMBER SKILLMAN: Reconcile 3.2.3.
3 MR. SISK: Reconcile 3.2.3, I've written 4 that down.
5 MEMBER SKILLMAN: Thank you. Thanks, 6 Ron.
7 CHAIRMAN BALLINGER: Okay, in 3.2.4, we 8 are talking about oxidation and clotting oxidation and 9 hydrating.
10 You're saying that as far as the parameters 11 that you're using for the evaluation, a crud thickness 12 of 0.3 millimeters.
13 And I understand how you got the 0.3 14 millimeters from the data that's also in the Chapter, 15 but my question is how sensitive are the analysis 16 results due to that crud thickness?
17 Because that's one variable where location 18 plant to plant, how people operate the plant, that'll 19 affect the crud thickness.
20 MR. SISK: We're going to take that aside.
21 We'll come back if we can, but we're going to take a 22 look at this on the side for time purposes.
23 CHAIRMAN BALLINGER: On 3.3.4, you're 24 talking about the difference between ZIRLO and 25 Zircaloy-4. And the original multiplier, conversion NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 1 multiplier, was 0.75.
2 I thought that was kind of unusual but not 3 crazy. But it's been changed to 0.92, and to me, that 4 is crazy because all the data I've seen, ZIRLO is a 5 factor of 10 or more better than Zircaloy-4 for 6 corrosion.
7 So, I'm curious as to -- I understand, I 8 saw the data, the measurements that you made at various 9 reactors in Korea and things to get that number.
10 But I'm just curious as to why -- that's 11 basically saying that ZIRLO isn't any different than 12 Zircaloy-4 from a corrosion point of view. And so it's 13 kind of startling to me that that would be the case.
14 So, I'm just wondering whether or not 15 there's something different about the reactors that 16 you measured the corrosion rate in, although, you 17 identified temperatures, and things like that, that 18 compensated in one way or another.
19 But it just seems to me like a very small 20 difference between ZIRLO and Zircaloy-4 for this 21 application.
22 It's got to be very conservative, very 23 conservative, but I'm just curious.
24 MR. KWON: The multiplier ZIRLO, 0.92, was 25 determined under the experiment data.
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24 1 CHAIRMAN BALLINGER: Yes, I understand it 2 was determined by actual measurements, but I'm curious 3 as to why there's such a small difference that was 4 observed.
5 Because in the literature and in practical 6 experience, ZIRLO is much better than Zircaloy-4. I 7 mean, the data is what it is.
8 Okay, my inquisition is over for now. Thank 9 you.
10 MR. KWON: For PLUS7 LTAs, two-sided 11 imaging relations were conducted for LTA. Assay 12 examination of LTAs has been completed after 13 validation.
14 PSC and in-house examination shows the 15 design requirements were met.
16 For operating experience, more than 5200 17 PLUS7 fuel assemblies have been supplied as of 2017.
18 PLUS7 fuel assemblies will be supplied for 19 Barakah, and APR1400 NPPS in UAE, and 5 APR1400 NPPS 20 in Korea.
21 As shown in this table, more than 5200 PLUS7 22 fuel assemblies have been loaded in 13 nuclear plants 23 in Korea.
24 For conclusion, in PLUS7 in Topical Report, 25 the design evaluation was performed to comply with the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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25 1 Regulatory Guide Requirements. The fuel assembly met 2 all the design criteria for mechanical integrity.
3 The fuel rods were evaluated up to the 4 maximum fuel rod burnup of 60 kilowatts a day. The 5 fuel rod satisfied all the design criteria related to 6 the rod's overall performance and mechanical integrity.
7 The PLUS7 design was verified through the 8 (unintelligible due to accent) test, the verification 9 test, and operating experience.
10 RAI status, a total of 24 questions were 11 ranging for the Topical Report. The responses for the 12 24 questions have been submitted. The impact of TCD 13 was the main issue. TCD status will be explained in 14 the next page.
15 For the TCD issues, NRC Staff noted that 16 33B does not account for the impact of TCD and the 17 requested TCD impact on fuel design and safety analysis.
18 For the resolution, TCD penalty was 19 conservatively determined based on the analysis of a 20 comparison to the experimental data at various points.
21 KHMP performed the analysis for the design 22 evaluation and the related safety areas with a TCD 23 penalty.
24 As a result of the analysis, all the 25 TCD-affected areas were satisfied.
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26 1 RAI status continued, Topical Report was 2 advised to consider TCD impact and was submitted in 3 2017.
4 The following TCD Chapters have been 5 revised to include the impact of TCD. The TCD-affected 6 areas have been covered in the previous presentations 7 so I will skip this page.
8 The current status for PLUS7 Topical Report 9 is complete. All the RAIs, including impact of TCD 10 have been reserved.
11 Topical Report was revised and submitted 12 in 2017, changes in TCD in response to the RAI have 13 been incorporated in the last revision, Revision Number 14 2.
15 Thank you.
16 MR. SCHULTZ: I have one general question 17 and I didn't want to include it in the discussion in 18 the presentation because what you've presented with 19 regards to the thermal conductivity degradation 20 approach, to me, is fine.
21 But it does take the approach of using a 22 computer code that does not have the degradation factors 23 in it, and applies a penalty factor.
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27 1 this has been done by others.
2 My question is more general, longer-term, 3 because in going forward, licensees will have to repeat 4 the analysis on a cycle-by-cycle basis to demonstrate 5 that, in their cycle design and operations, the fuel 6 temperatures are going to meet limits, and that the 7 analyses that you performed in the base case apply to 8 their fuel cycles.
9 Is there any future plan in your 10 organization to develop a fuel performance code that, 11 in fact, will include the thermal conductivity 12 degradation technology, in itself included in the fuel 13 performance code and the event fuel performance code, 14 that would be licensed sometime in the future?
15 I know you wouldn't have time to have done 16 that in the last year or two, but going forward, it 17 would seem right to have a plan that would develop a 18 more advanced methodology that would incorporate it 19 distinctly.
20 MR. JEONG: This is Jaehoon Jeong from 21 KEPCO Nuclear Fuel.
22 Actually, we have finished development of 23 the code which considers TCD impact, but the start of 24 these applications, we haven't finished that yet.
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28 1 application.
2 MR. SCHULTZ: Thank you, I appreciate 3 that.
4 MR. SISK: If there are no other questions, 5 we're going to caucus while you have the NRC to talk 6 about the issues.
7 CHAIRMAN BALLINGER: I think we've checked 8 that the room is sanctified so we can get the Staff 9 to come up.
10 Thank you.
11 Oh, I think Chris has got -- oh, the open 12 session's over, we're now in closed session.
13 (Whereupon, the above-entitled matter went 14 off the record at 1:39 p.m. and resumed at 2:19 p.m.)
15 MR. WUNDER: Okay, I guess we'll move on 16 now to Chapter 4. We'll be presenting our safety 17 evaluation with no open items. This is our outstanding 18 review team. Matter of fact, it's like the 1927 Yankees 19 of review teams. From Reactor Systems, we have 20 Alexander Burja, Jim Gilmer, Carl Thurston, and Chris 21 Van Wert.
22 From the Materials and Chemical 23 Engineering Branch, our team members were John 24 Honcharik and Dan Widrevitz. Contributing from the 25 Office of Research were Andrew Bielen and Peter Yarsky.
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29 1 And finally, providing additional assistance we have 2 Nick Klymyshyn of PNNL. It's looks like Chris is 3 probably going to be starting off for us today, so Chris, 4 whenever you're ready.
5 MR. VAN WERT: All right, well thank you 6 very much, you're not rid of me yet. So as we discussed 7 before when we came in front of you before with the 8 4.2 with open items, we had two open items. The first 9 one we just closed out, which is related to the fuel 10 assembly mechanical design analysis, which was PLUS7 11 topical report.
12 At that time, the topical report was still 13 under review. And due to at that time the question 14 was revolving around TCD, we thought there were 15 potential implications on DCD Sections 4.2, 4.3, and 16 4.4, which will all depend on the resolution path chosen 17 by the applicant.
18 So now that we've closed out the topical 19 report, we concluded, again, the four criteria that 20 the SRP 4.2 guidance tells us to look at. And we assured 21 that the fuel and cladding integrity is maintained.
22 That allowed us to, well, because of that, the thermal 23 design margin calculations in DCD Section 4.4 remained 24 unaffected.
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30 1 changes were necessary based on the resolution passed, 2 so therefore DCD Section 4.3 was not impacted by the 3 issue. Based on that and the completion of the topical 4 report review, the staff concludes that this item is 5 now closed. So no further questions.
6 The second open item on 4.2 was related 7 to the structural analysis of fuel assemblies for 8 seismic and loss of cooling accident loading. At that 9 time, the applicant was in the middle of revising their 10 referenced technical report, which is now currently 11 Revision 2, in order to address staff concerns. That 12 was not completed at the time of our last presentation.
13 Now, Revision 2 has been completed as of 14 July 2017, and we have completed our review of that.
15 And it did address all the staff's concerns that we 16 had at the time.
17 I will discuss in the next three slides 18 the staff's review, but the, and the summary at this 19 point is that the staff reviewed the information 20 provided and determined that PLUS7 fuel assembly will 21 meet the requirements of GDC-2 in terms of fuel assembly 22 structural response to externally applied loads.
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31 1 of the analysis of loads for the PLUS7 fuel assembly, 2 they did rely on previously approved CE codes and 3 methods. And I've listed them here for your review.
4 The fuel assembly response characteristics 5 were determined by testing, and they covered both BOL 6 and EOL conditions, which did address the staff's 7 Information Notice 2012-09. And they also performed 8 tests in air, still water, and flowing water conditions.
9 The staff reviewed the tests and analyses 10 and concluded that the referenced methodology was 11 correctly followed, and that the seismic damping credit 12 was supported by the test results. Therefore, the fuel 13 assembly loading values are acceptable.
14 In terms of determination of strength, the 15 application does follow the methodology highlighted 16 in CENP-178-P, Rev. 1, for the strength calculations.
17 And this included performing one-sided drop tests to 18 represent grid to barrel impacts through grid long pulse 19 testing to represent grid-to-grid impacts. And it did 20 follow ASME Code Section 3 for components other than 21 grids. And the acceptance criteria for grids were 22 developed based on the grid crush test data.
23 These limits follow the staff guidance 24 provided in SRP Section 4.2, Appendix A, and are 25 therefore acceptable.
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32 1 And in terms of the acceptance criteria 2 and analysis performed, Revision 2 of the tech report 3 presents the analysis of the PLUS7 fuel assembly in 4 the APR1400 reactor design and provides the acceptance 5 criteria by which the PLUS7 fuel assembly is evaluated.
6 The staff reviewed and concluded that the 7 applicant adequately demonstrated that fuel rod 8 fragmentation would not occur as a direct result of 9 LOCA blowdown and SSE loads, and that the control rod 10 insertability is always ensured.
11 Are there any questions on this topic?
12 Okay, thank you very much.
13 MR. WUNDER: We have too, excuse me, Mr.
14 Chairman, we have too many people to sit up here all 15 at once. So we're going to briefly change out panels 16 for the remainder of the chapter.
17 I'm now joined by Alex Burja and Jim Gilmer.
18 And I was supposed to be joined by someone from 19 Materials, but they don't appear to be here yet. So 20 I will, fortunately their slide is the last one, and 21 maybe they'll show up. So I'll turn it over to Jim 22 and Alex.
23 CHAIRMAN BALLINGER: Those Materials 24 people can't be trusted.
25 (Laughter.)
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33 1 MS. BURJA: Thanks, George. Again, my 2 name is Alex Burja, and I'm the staff reviewer for DCD 3 Section 4.3.
4 Though there were no significant open items 5 as of our last presentation to you, I will be addressing 6 two questions or comments that have come up. The first 7 is why Shin Kori data was allowed to be used to validate 8 MCNP to calculate shape annealing functions when the 9 staff did not accept a foreign plant as a prototype 10 plant during the Phase 3 review.
11 So as will be discussed later today during 12 the Chapter 14 presentation, the staff's position on 13 referencing foreign plants as prototype plants is that 14 it is acceptable, provided that the quality assurance 15 program for construction and testing is consistent with 16 the applicant's approved QA program.
17 But in this particular case for 4.3, it's 18 a little bit of a different situation, because the Shin 19 Kori data is being used to show that MCNP is an 20 acceptable method for calculating shape annealing 21 functions. It's not being used as a way to exempt the 22 design from testing.
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34 1 annealing functions. So it is something that will be 2 tested.
3 In terms of guidance that is specific to 4 nuclear design calculations, Standard Review Plan 5 Section 4.3 states that critical experiments and 6 operating reactors should be used to validate codes 7 and analysis procedures. But there isn't any hard and 8 fast guidance on whether the data comes from domestic 9 or foreign sources.
10 What is important in our view is that the 11 data sources satisfy our QA requirements, and this 12 validation technical report did go through KHNP's QA 13 process. So for these reasons, the staff concludes 14 that the use of Shin Kori data for validating MCNP is 15 acceptable.
16 MR. SCHULTZ: Alex, in the first bullet, 17 you say the applicant's approved QA program. Who has 18 performed the approval of that program?
19 MS. BURJA: So that would the Quality 20 Assurance Branch. I believe that topical report has 21 been approved by them.
22 MR. SCHULTZ: And so we have these things 23 done in the right sequence. In other words, that review 24 has been done and the QA program has been found 25 acceptable.
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35 1 MS. BURJA: That's correct.
2 MR. SCHULTZ: Good, thank you.
3 MS. BURJA: Are there any other questions?
4 All right, next slide, please. During the Phase 3 5 presentation, there was a lot of comments or concern 6 about the fact that the staff didn't document the issue 7 of load following in the safety evaluation, as it could 8 lead to confusion or problems in the future.
9 So the staff took that into consideration 10 and has revised SER Section 4.3 to explicitly discuss 11 the related RAI that the staff issued to confirm that 12 there would be no load following, and to explicitly 13 state that the APR1400 is approved for base load 14 operation only.
15 In addition, the staff did ensure that any 16 references to load following throughout the DCD have 17 been removed, with the exception of one confirmatory 18 item that will be changed in the upcoming DCD revision.
19 CHAIRMAN BALLINGER: You might take a look 20 at the topical report on the PLUS7 fuel and search on 21 load following. It's there.
22 MEMBER SKILLMAN: But I think that the 23 distinction is --
24 CHAIRMAN BALLINGER: Yeah, I know the 25 distinction.
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36 1 MEMBER SKILLMAN: The reactor coolant 2 system on the NSSS versus the fuel. I mean, the fuel 3 can be designed to do all kinds of things, whereas the 4 commitment for load following on the NSSS is quite 5 candidly just a different kettle of fish. That's a 6 whole different deal. So the fuel's great, but --
7 CHAIRMAN BALLINGER: Yeah, it's just a 8 matter of terminology, I think. But once a day ten 9 percent to 100% power and back.
10 MR. SCHULTZ: What you're saying, Ron, is 11 that the documentation ought to reflect the situation 12 between what's been done for the fuel.
13 CHAIRMAN BALLINGER: Yeah.
14 MR. SCHULTZ: And what it is for the NSSS.
15 CHAIRMAN BALLINGER: Yeah.
16 MEMBER SKILLMAN: Well, it think that's 17 what Alex just said, that the document, Chapter 4, for 18 the NSSS has been purged of load following.
19 MS. BURJA: That's correct.
20 MEMBER CORRADINI: So can I ask a question?
21 I'm just curious. So what is load following as a 22 definition? If I go from 100% power to 90% power over 23 two hours, is that load following?
24 MS. BURJA: So I --
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37 1 I know what Dick, I'm going from 10% to 100%, yeah, 2 I get it. But if the plant maneuvers from 100 to 90 3 in half a day, that's not load following, in my mind.
4 So where's the definition in all this documentation?
5 MR. LU: This Shanlai Lu from Reactor 6 System. I'll just give you my perspective. In the 7 load follow, basically what we mean is you follow the 8 grade demand instantaneously.
9 So basically you have a change, if for 10 example, you don't need that kind of power. And one 11 of the steel mills shut down their, you know, their 12 electrical oven. And then that's a lot demand is just 13 shut down. So basically local grid that's not needed 14 instantaneously, you drop the power, the map.
15 MEMBER CORRADINI: I understand, I figured 16 that might be an answer. But practically I thought 17 where Dick, where Member Skillman was going was that 18 the vessel components may have a ramp rate this is more 19 limiting than the fuel. So in the fuel section, I would 20 expect you got some sort of ramp rate limits that are 21 listed such that that's the limiting thing if it were 22 the fuel only.
23 And then the plant has some sort of other 24 limit, which is listed, so that we're clear as to what's 25 what. Because load following to me is kind of mushy.
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38 1 CHAIRMAN BALLINGER: There are no ramp or 2 rate limits on the fuel. But there are this 10% to 3 100% cycles, one per day, which is counted in the fatigue 4 data for the fatigue usage factor.
5 MR. VAN WERT: This is Chris Van Wert and 6 --
7 UNIDENTIFIED SPEAKER: Closer to the mic.
8 MR. VAN WERT: Okay. The only thing I 9 would like to add just for clarification too is that 10 the PLUS7 Fuel Topical Report is a standalone topical 11 report. So the limits on the APR1400 design are what 12 you would see in the DCD, and that's what Alex has just 13 discussed being put in there.
14 The referenced topical report might allow, 15 and going to extremes here, but if the, for whatever 16 reason the topical report showed and they had approval 17 for a 100 gigawatt day burnup but the plant designed 18 the DCD, only allowed it to go up to 60, then 60 is 19 the limit, regardless of whatever the topical reports 20 says.
21 MEMBER CORRADINI: Okay, all right, so 22 then, so back to my original question. Should there 23 be somewhere in the DCD which says load following is 24 ramp rates that are greater than X over a time period?
25 It seems to me there's got to some sort of engineering.
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39 1 Otherwise, I can have normal maneuvering, PWRs do it 2 now.
3 MR. VAN WERT: Yeah, I'm pretty sure you've 4 been listening in on our conversations.
5 MEMBER CORRADINI: Okay, well, no I'm 6 just, this is a hot topic.
7 MR. VAN WERT: Yes.
8 MEMBER CORRADINI: So I'm kind of curious 9 what it means.
10 MEMBER MARCH-LEUBA: From my point of 11 view, Mike, is you can have preplanned maneuvers from 12 10% to 100% and that's not load following. As long 13 as it's preplanned and the Engineering Department has 14 analyzed it before you send it on. So you knew it was 15 okay.
16 Load following is you put it in automatic 17 on the control system and it may give you demand to 18 ten percent like that, which you have not pre-analyzed, 19 and you don't know if it's going to be okay.
20 MEMBER CORRADINI: Okay, fine.
21 MEMBER MARCH-LEUBA: So in order for a 22 plant to be approved for load following, they have to 23 put drop limiters, they have to put some stuff.
24 MEMBER CORRADINI: Okay, thank you.
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40 1 comments?
2 CHAIRMAN BALLINGER: We're lucky this only 3 too that long.
4 MR. GILMER: Good afternoon, I'm going to 5 talk on the second topic, the core thermal hydraulic 6 design. When we last met with you for Phase 3, there 7 were two open items associated with this section, both 8 of which you heard earlier today, either from KHNP or 9 the staff.
10 The first one was actually tied to Chapter 11 7 open item on the instrument set point methodology.
12 It affects 4.4 because of the core protection 13 calculator, the limiting safety systems settings, in 14 particular linear power density and the departure from 15 nucleic boiling.
16 In order to resolve the open item during 17 an audit, KHNP showed us data that backed up their 18 assertion that those particular limiting safety 19 settings are inherently single sided. And in addition, 20 during the startup testing, a large number of power 21 shapes are collected, which effectively makes it a 22 semi-infinite power shape. Or, uncertainty curves.
23 So we were satisfied that it meets the 9595 criteria.
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41 1 done that now, so we consider that issue closed.
2 We did have one COL information item that 3 we wanted added to require the COL holder to develop 4 procedures for the core protection calculator that 5 were, this was not part of the design certification, 6 but it would be done during the COL stage. And we were 7 shown example procedures from Shin Kori, which 8 presumably the COL holder would use as a starting point 9 for developing their own.
10 There is one question from the Phase 3 11 meeting that Member Skillman raised on the three percent 12 flow bypass, and we had a separate sidebar meeting as 13 well. During the meeting we argued that three percent 14 bypass is treated as a model uncertainty. And that 15 it clearly is in the Thermodesign Methodology Technical 16 Report.
17 Our sidebar discussion got into the hot 18 versus cold gaps, and our mechanical engineering branch 19 supported us, because they had some open RAIs on that 20 issue. And KHNP provided their calculations. So from 21 a 4.4 point of view, we were satisfied that that was 22 not still a concern.
23 MR. SCHULTZ: Is that, when you say it's 24 applied, treated as an uncertainty, that's in any 25 analyses associated with that for safety analysis?
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42 1 MR. GILMER: Well, at least for the TORQUE 2 and CTOP, which are the two codes that are used for 3 the core thermal design. And it's also applied in the 4 large break LOCA methodology.
5 MR. SCHULTZ: And that's the application 6 for RELAP.
7 MR. GILMER: Right, which we'll talk about 8 in --
9 MR. SCHULTZ: Chapter 15.
10 MR. GILMER: Chapter 15.
11 MR. SCHULTZ: Okay, thank you.
12 MEMBER KIRCHNER: Do they make a three 13 percent adjustment in core flow, a decrement for the 14 core protection calculator input?
15 MR. GILMER: I don't remember the answer 16 to that, honestly. But I believe there was some 17 adjustment to the.
18 MEMBER KIRCHNER: Yeah, their CHF ratio 19 is going to be a function of flow.
20 MR. GILMER: Right, and one place where 21 that will probably enter in is the daily and monthly 22 power calibration. Any deviations should show up 23 there, and they're addressable constants that can be 24 applied by the operator.
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43 1 on the middle bullet there, with the CPC, that for the 2 actual plant they would consistently implement 3 constants? In other words, would they adjust that CPC 4 to account for what their flow balance is telling them 5 they're losing on bypass?
6 MR. GILMER: Yes, that's correct. Any 7 additional questions? Okay.
8 MR. WUNDER: I'm told that our materials 9 guy will be, is calling in on the phone, which is good, 10 because I was afraid for a minute that I was going to 11 have to become the resident expert on Versa-Vent. And 12 they don't have Versa-Vents on submarines, and if they 13 don't have them on submarines, I don't know what they 14 do. So I think --
15 MEMBER KIRCHNER: You had the Yankee '27 16 team, and they have a lot of backup hitters.
17 MR. WUNDER: I guess we're not as deep in 18 the bench.
19 MR. WARD: John, I'm sure, did you call 20 in?
21 MR. HONCHARIK: Yes, this is John 22 Honcharik.
23 MEMBER SKILLMAN: John, this George 24 Wunder. Your slide is up on the Versa-Vent, and we're 25 just, if you'd please be so kind as to talk to it.
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44 1 MR. HONCHARIK: Okay. My name is John 2 Honcharik, Senior Materials Engineer at NRO. And the 3 topic here is the control rod drive system materials.
4 That previously had an open item with two questions.
5 Basically, the issue was that the DCD 6 didn't have sufficient information of why the 7 Versa-Vent does not considered reactor coolant pressure 8 boundary. And also it didn't provide the operating 9 experience of the Versa-Vent to reduce the dissolved 10 oxygen levels in the CRD system.
11 We asked those RAIs and they responded.
12 And basically they provided justification for why the 13 Versa-Vent's not considered pressure boundary.
14 Basically, they only credit the ball and vent stem for 15 the pressure boundary and not the Versa-Vent. Only 16 if the housing nut is installed, if the Versa-Vent were 17 to leak, is when they credit the housing.
18 Also, they provided operating experience 19 of Versa-Vent that's used in some Korean plants, and 20 also I think Palo Verde had it. And basically it shows 21 that they could reduce the dissolved oxygen levels to 22 acceptable level.
23 And in addition, these CRD housings and 24 vent stems, they're pretty, at lower temperatures than 25 operating plants, about 135 degrees Fahrenheit. So NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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45 1 this also helps minimize the occurrence of stress 2 corrosion cracking. So based on their response, we 3 reviewed the information and found that it was 4 acceptable. And basically it met the intent of the 5 GDC-1, 14, and 26. And that concludes my presentation.
6 Are there any questions?
7 MEMBER SKILLMAN: I'm good, thank you.
8 CHAIRMAN BALLINGER: Okay.
9 MR. WUNDER: Mr. Chairman, if there are 10 no other questions, that concludes our presentation 11 on Chapter 4. Thank you, gentlemen.
12 CHAIRMAN BALLINGER: Do I just -- I just 13 keep turning it on. You need to shift to Chapter 14, 14 page --
15 MR. SISK: This is Rob Sisk, Westinghouse.
16 Before we shift to 14, KNF would like to offer a couple 17 of comments based on the questions that were raised 18 during our session. If that would be appropriate, we'd 19 just offer a few, a brief response to some of the 20 comments that were raised just a little bit earlier.
21 So, Mr. Kwan.
22 So the purpose of this is really to address 23 the three comments the Committee raised earlier that 24 we were caucusing on here just briefly, and just wanted 25 to get back some preliminary responses to your concerns.
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46 1 So Mr. Kwon, why don't we start with the 0.77.
2 MR. KWON: Yeah, 0.77 for the particular 3 calculation, this calculation was based on the power 4 variation between 10% and 100%. Ten is the load 5 following and the practical damage factor during the 6 load following, which has its own stress, but the 7 different stress makes the damage factor and for during 8 the whole time of lifetime, the practical damage factor 9 is cumulative. So --
10 CHAIRMAN BALLINGER: Yeah, I understand, 11 it's like a minors rule thing. So it's a summation 12 of various cycles. And the 10% to 100% is explicitly 13 called out in the chapter. The AOOs are explicitly 14 called out in the chapter, the number of them.
15 So there are several categories which are 16 called out explicitly. But there's nowhere where those 17 usage factors add up to 0.77. So that's what I was 18 interested in.
19 UNIDENTIFIED SPEAKER: So the incremental 20 usage factor for each --
21 CHAIRMAN BALLINGER: Yeah, how did you get 22 to the 0.77?
23 MR. KWON: So yeah, right. This is a 24 accumulated by the minor rule.
25 CHAIRMAN BALLINGER: Yeah.
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47 1 MR. KWON: Yeah, the cumulative is 2 calculated by the code.
3 CHAIRMAN BALLINGER: Yeah.
4 MR. KWON: Yeah.
5 CHAIRMAN BALLINGER: Oh, okay, I guess, 6 it's not that a big deal, I guess. But you got 0.77, 7 okay. Let's just say that the 10% to 100% excursions 8 over the life gives you 0.5 of the 0.77, and the AOOs 9 give you 0.2. So 0.7 now. But then there are other 10 cycles -- what adds up to 0.77? What dominates? Does 11 that load following thing dominate, which I suspect 12 is true? What is the dominant fatigue usage factor?
13 MR. KWON: I understand the 100% of power 14 dominate, which already surely exceeds the reactor 15 power. That makes the boundary power. And between 16 the lower power, 10%.
17 MEMBER SKILLMAN: May I ask this?
18 CHAIRMAN BALLINGER: Can you?
19 MEMBER SKILLMAN: You're on a 24-month 20 fuel cycle, right. It's two years. You shut down for 21 about 30 days, okay. So the fuel is in for three cycles.
22 MR. KWON: Yes, three cycles.
23 MEMNBER SKILLMAN: So in the first cycle, 24 that fuel sees about 700 cycles. In the second fuel 25 cycle, that fuel assembly sees 700 cycles. In the third NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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48 1 fuel cycle, that fuel sees 700 cycles. So that one 2 fuel assembly, if it was in the first batch and the 3 first core, sees about 2100 cycles, 100, 10%, 100, in 4 accordance with your 3.2.
5 And in addition, it sees startups and 6 shutdowns, three, and it sees some reactor trips, 7 hopefully none. But you have at a minimum 2100 cycles.
8 Is that the basis of the utilization factor that Dr.
9 Ballinger asked about?
10 CHAIRMAN BALLINGER: If it's 0.77, and 11 let's say you were to remove all of the 10% to 100%
12 cycles, what would the fatigue usage factor be?
13 MR. SISK: This is Rob Sisk, Westinghouse.
14 We're going to move on. The individual that would 15 be most efficient on that is not really available today 16 to go into the code detail.
17 CHAIRMAN BALLINGER: I'm just suspicious 18 that this thing is completely dominated by an artificial 19 --
20 MR. SISK: Understand.
21 CHAIRMAN BALLINGER: Set of transients.
22 MEMBER SKILLMAN: And you know, we know 23 someone knows. We know that there's an individual that 24 has this down to a third decimal place. We were just 25 looking for it and we couldn't find it. And that's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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49 1 why Ron asked the question.
2 MR. SISK: Understand, and we can only go 3 to certain level today. But we want to get back to 4 the extent that they could, and appreciate that. Thank 5 you very much. So Mr. Kwon, let's move on to the 0.3 6 mils.
7 MR. KWON: Current thickness assumption 8 of 0.3 mils. The current thickness comes from the 9 corrosion model, yes, and this was assumed in the code 10 model, in the model. Let me see, regular model.
11 CHAIRMAN BALLINGER: It can't really come 12 from the corrosion model, can it? The crud thickness, 13 that's not the same as oxide thickness. The crud 14 thickness I thought came from measurements on rods from 15 various reactor plants. Crud is an accumulation based 16 on operating experience.
17 MR. SISK: Thank you for the patience, but 18 I think we're going need to get the other. We'll look 19 at this. We understand the comment, but we have no 20 prepared responses today.
21 CHAIRMAN BALLINGER: Okay.
22 MR. SISK: So let's move on.
23 MR. KWON: Yeah, and the multiplier --
24 MR. SISK: Okay, this is --
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50 1 what you're saying?
2 MR. SISK: 0 for 2 so far.
3 MEMBER STETKAR: But even the '27 Yankees, 4 batting 333 is not bad, so.
5 MR. SCHULTZ: One in three, right, one in 6 three.
7 MR. KWON: And the model for load used 8 0.75. In the small group of data, in all data group, 9 so in that case, CHOLO is better than the Zircaloy.
10 CHAIRMAN BALLINGER: Well, it better be.
11 MR. KWON: Yeah. But with many data 12 accumulation, in the high burnup exceeding 50 13 kilowatt-days.
14 CHAIRMAN BALLINGER: Fifty or 59?
15 MR. KWON: More than 59.
16 CHAIRMAN BALLINGER: More than 59.
17 MR. KWON: Yeah.
18 CHAIRMAN BALLINGER: See the data, the 19 data that I see, and I can, there's a plenty of papers 20 which plot the oxide thickness versus burnup. Where 21 you get the big advantage for ZIRLO is at high burn.
22 No, I've got-- okay, all right. If we're going to 23 say something, because I have a --
24 MR. SISK: I also want to caution this, 25 I guess are we still closed?
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51 1 CHAIRMAN BALLINGER: Oh, okay, we have to 2 be careful then.
3 MR. SISK: Well, I think, I don't think 4 we're ready for this. Let's just take it out. Yeah, 5 three strikes, we're out.
6 CHAIRMAN BALLINGER: We're 0 for 3.
7 MR. SISK: So we're going to move Chapter 8 16 out.
9 CHAIRMAN BALLINGER: Good idea.
10 MR. SISK: Fourteen, going up to 14, I'm 11 sorry, 14.1. O for 4. Ken.
12 UNIDENTIFIED SPEAKER: So M-5 does indeed.
13 UNIDENTIFIED SPEAKER: So this our factor 14 of two different.
15 UNIDENTIFIED SPEAKER: So 0.92?
16 UNIDENTIFIED SPEAKER: But they showed 17 data. So you know, in the US we have, EPRI has all 18 these chemistry guidelines. But I don't know what they 19 have there. So.
20 CHAIRMAN BALLINGER: Okay, I'm sorry.
21 MR. SISK: Okay, so this is Rob Sisk, 22 Westinghouse. We're prepared now that we're going to 23 begin the discussion on Chapter 14. I've introduced 24 Mr. Sanwon Lee.
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52 1 Lee, and I work for KHNP as a technical manager of 2 enterprise design of APR1400. Today I'd like to talk 3 about Chapter 14 verification program.
4 This slide shows the overview of my 5 presentation. And I will just briefly talk about the 6 overview of Chapter 14 and technical topics and finalize 7 with the current status.
8 Chapter 14 includes three sections. Today 9 I will cover the Chapter 14.1 and 14.2. And the 14.3 10 ITAAC is to be discussed at future ACRS meeting. In 11 Chapter 14.2, initial task program, most of the contents 12 is Subsection 12, task description. It contains 13 lateral system-based test program and integrity test 14 program.
15 Test description consists of four phase.
16 Phase one is the pro-operational test. And then 17 geoloading and post-core hot functional testing. And 18 initial criticality and low-power physics test. And 19 finally we do some power ascension testing.
20 As of Rev 0, we submit the 178 individual 21 test program. But during the RAI process, finally 22 we've got a 199 test will be submitted at DCD Rev 2.
23 Summary of RAIs. We got 71 RAIs. And in 24 page three, we got a open item of 12, 16 open items.
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53 1 any open items now.
2 From this slide, I will briefly talk about 3 several open items that is important in Chapter 16, 4 or Chapter 14. Open item number one is the device that 5 startup up the administrative manual in accordance with 6 the SRP. So we advise the staff to incorporate into 7 the SRP requirement.
8 And open item number two, some of the 9 vibration monitoring tests. NRC require both, based 10 on the required 1.2, but with some discussion. This 11 is a monitoring system, so it's not a, for example, 12 CVAP program. So it is related, but not directly 13 related to the required 1.2.
14 And open item number three is natural 15 circulation test as a book test. We designate Palo 16 Verde as a prototype reactor of AP1400. So natural 17 circulation test is not done as a book test.
18 And open item number six, radiation signal 19 transmit, should be transmit to the emergency response 20 data system. So we revised Chapter 11 and Chapter 12 21 because it's not a procedure-related issue, it is a 22 design issue. So we modified Chapter 11 and 12.
23 And open item number nine, revised remote 24 shutdown console test to verify manual control in the 25 MCRs. So we revised the relative ITP, such as ESF NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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54 1 component control system test.
2 And open item number thirteen, radiation 3 check source should be used to verify the radiation 4 monitoring function. There are some calibrated, so 5 sometimes calibrated sources used and sometimes 6 radiation check sources used. But in the practical 7 region, we, in the ITP process, we uses simulated, 8 calibrated source. But in ITAAC, radiation check 9 source will be used as a part of an ITAAC. So there 10 is a result.
11 And finally, number sixteen, post-core, 12 ex-core neutron flux monitoring systems is deleted as 13 a post-quad test instead of it is performed in 14 pre-operational testing period.
15 This slide shows the question when Phase 16 38 ACRS meeting, the question is that why the CVAP is 17 not included as part of ITP. The answer is that APR1400 18 is classified as a non-prototype category one plant 19 recording Palo Verde Nuclear Power Plant as a prototype 20 plant.
21 In accordance with the required 1.2 22 vibration measure on the program can be omitted if the 23 non-prototype category one reactor if the inspection 24 program is fully implemented.
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55 1 information about the inspection program and assessment 2 program. So implementation of the vibration 3 measurement program is not necessary in APR1400.
4 So this is final slide. Currently Chapter 5 14.1 and 14.2 are completed. And sixteen open items, 6 there was this identified in Phase 3 is all resolved.
7 And changes in Chapter 14.1 and .2, and markup, and 8 during the response to the RAI will be revised in the 9 revision with DCD left to February of this year. Thank 10 you for your listen.
11 MEMBER BROWN: I just wanted to clarify 12 a couple of things. Number one, you said ITAAC will 13 still, they'll deferred. That's Section 14.3, so 14 that'll come later, okay. But there were some items 15 in the SER relative to response time testing. And it 16 goes back, I'm trying to get back into the actual 14.2, 17 which was Section 14.2.12.1.24, which is the PTS 18 testing.
19 And between, I was trying to decipher what 20 was going on, because there it says you're supposed 21 to, to do time response, you're supposed to inject 22 signals into the appropriate sensors or terminals and 23 measure the elapsed time to achieve tripping of the 24 circuit, trip circuit breakers, or to initiate an ESFAS 25 signal. And it can be tested by overlapped testing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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56 1 method.
2 And that was also mentioned in the SER.
3 However, it was in a section that was only talking about 4 the CPSC, the core protection -- no, CTCS, calculator 5 system. Whereas it talked about a modular system in 6 the SER. And I guess right now I'm kind of confused 7 as to what's the difference between modular and 8 overlapped. Does the modular apply to the regular trip 9 part of this, or just the CPCS?
10 So the response time is kind of confusing 11 to me in terms of how that's done. I have a number 12 of comments on the ITAACs part of it, but that's, they're 13 relative to Section 2.5 and Tier 1. And I guess if 14 we do ITAACs later, I guess I ought to defer those 15 questions. Am I correct on that?
16 CHAIRMAN BALLINGER: Yeah.
17 MEMBER BROWN: Okay. I hate that, I'll 18 forget it by then. Okay, any, I guess maybe I ought 19 to address this to the staff when we get to the staff 20 section so that I can try to get a feel for what you're 21 talking about? Okay.
22 MR. WARD: Yes, we'll do our best to answer 23 it then.
24 MEMBER BROWN: Okay, let me -- there were 25 also questions relative to, there's just single NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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57 1 statements relative to the WD, the watchdog timers in 2 this same section, as well as a section on acceptance 3 criteria. I guess I can't comment on the, acceptance 4 criteria don't seem to see, have the same type of 5 delineation or detail that they have in the Tier 1, 6 Section 2.5. They're just statements that you verify.
7 And there are some differences between 2.5 8 or lack of actual reference to them, even. So I'll 9 bring that up when I talk to you, I guess. It's a matter 10 of things that are missing right now.
11 MR. WARD: Okay.
12 MEMBER BROWN: Okay? I'm sorry, that's 13 all I had right now. I guess it's just a statement 14 in there. I guess I'll have to get it clarified with 15 the staff as where we go with that.
16 MEMBER KIRCHNER: I have a question on the 17 C, the Comprehensive Vibration Assessment Program.
18 Now if you're using, maybe I don't know the Palo Verde 19 plant, but they don't have your accumulator design, 20 do they, the APR1400 accumulators? So how much of a 21 prototype is Palo Verde when you have a much different 22 accumulator injection system for APR1400?
23 Something when we had reviewed last year, 24 and questions about vibration, when that discharges, 25 was something I remember us discussing at great length.
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58 1 So will you test the accumulators in the pre -- I guess 2 you would do that in the initial Phase 1 and measure 3 the vibration?
4 MR. SISK: For my help, but to clarify for 5 me, when you're talking about the accumulator, you're 6 talking about the SIT tank?
7 MEMBER KIRCHNER: Yes, with the fluidic 8 device.
9 MR. LEE: We have SIT with the fluidic 10 device, but Palo Verde only have a SIT. But SIT is 11 safety related component. CVAP test is for the 12 vibration of the reactor vessel internals. And the 13 normal operation component. So --
14 MEMBER KIRCHNER: I thought it included 15 the RCS as well, our primary coolant system.
16 MR. LEE: Yeah, in -- for example, the 17 reactor vessel and the main piping and fuel design is 18 very closely related to the CVAP test. And it is very 19 close to the Palo Verde and our reactor.
20 But the difference is, as you mentioned, 21 the fluidic device is not installed in Palo Verde.
22 But that might affect the vibration, but it might be 23 very small or negligible effect can be. We assume that 24 that's not a important design barriers to the CVAP 25 vibration test.
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59 1 MEMBER KIRCHNER: Yes, okay, thank you.
2 MEMBER CORRADINI: I guess just to make 3 sure, I think what Walt was asking you is are you going 4 to test it in this test sequence. That's what I thought 5 you were going, in the initial testing.
6 MR. LEE: We do the SIT test as a different 7 procedure. Yeah, but independent to the CVAP, we do 8 some safety injection tank test. But measuring data 9 is different. We have turn-down time and flow rate 10 of high flow and low flow, but in accumulator, all the 11 cases, they only have a flow rate. So data measurement 12 is different for the Palo Verde and our reactors.
13 MEMBER KIRCHNER: Okay, thank you.
14 MEMBER BROWN: Excuse me, I did have one 15 other comment. When I went through the objectives, 16 this is in 14.2, that same section that I referenced, 17 there is no objective in there. There's no objective 18 in there to, no test or inspection verifies that there 19 are no communications between divisions, other than 20 those that exist between the function processor, the 21 bias table processors, and the voting processors, which 22 are generally referred to as LCL processors.
23 So there's no verification. The only 24 thing you can do is check wiring diagrams to ensure 25 there are no connections. And there's nothing in even NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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60 1 an inspection to do that within this particular section.
2 It's also lacking in the ITAACs, but I mean it's lacking 3 in this particular PTS test verification section, 14.2.
4 UNIDENTIFIED SPEAKER: Which would be 5 different than your preoperational tests.
6 MEMBER BROWN: These are preoperational 7 tests.
8 MR. SISK: This is Rob Sisk. I don't think 9 we have a comment on that right now, Charlie.
10 MEMBER BROWN: Okay, I'm just saying it's 11 an observation.
12 MR. SISK: We'll take a look.
13 MEMBER BROWN: It's a lack right now, 14 Chapter 14 doesn't have anything that verifies 15 communications independence in that particular 16 section. And I presume that's the section where it 17 should go, based on what I saw. Even though you refer 18 to ITAACs later in this document that are in Tier 1.
19 MR. SISK: Thank you.
20 CHAIRMAN BALLINGER: Switch out again.
21 MS. FERGUSON: Good afternoon, I'm Ashley 22 Ferguson. I'm representing the Quality Assurance 23 Vendor Inspection Branch, and doing the presentation 24 on Chapters 14.1 and 14.2., the staff's review.
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61 1 myself along with 32 other technical, 38 --
2 UNIDENTIFIED SPEAKER: Are you actually 3 qualified to --
4 MEMBER POWERS: I was actually going to 5 ask that. We're very suspect of him.
6 CHAIRMAN BALLINGER: He has a history.
7 (Laughter.)
8 MS. FERGUSON: Okay, so I performed a 9 review of Chapters 14.1 and .2, along with 38 other 10 technical review staffs from the NRC. So in this 11 presentation, I will discuss some follow-up items 12 regarding prototype plants, specifically NuScale's 13 reference of Palo Verde Unit 1 as the prototype plant 14 in regards to performing vibration and natural 15 circulations tests.
16 Additionally, I will discuss the staff's 17 conclusion of the review of Sections 14.1 and 14.2, 18 as well as a closeout of the 16 open items during the 19 Phase 4 review. So I won't spend a lot time on the 20 closeout of those 16 open items, just because KHNP 21 covered all of those in their presentation.
22 MEMBER BROWN: With the exception of the 23 one I asked about.
24 (Laughter.)
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62 1 discussion during the last of Phase 3 ACRS meeting 2 regarding the staff's position on allowing foreign 3 plants to be referenced as a prototype plant for US 4 design certification. So currently there is no formal 5 documented NRC position regarding the use of foreign 6 data when referencing domestic licensing applications.
7 However, in regards to the initial test 8 program, the staff has determined that it is acceptable 9 to reference a foreign plant as a prototype plant, 10 provided that the applicant can demonstrate that the 11 quality assurance program for construction and 12 performance of the initial test program is consistent 13 with the applicant's approved quality assurance 14 program.
15 And so this question was raised in regards 16 to performing vibration and natural circulation tests.
17 And so specifically, for the comprehensive vibration 18 analysis program as discussed in Reg. Guide 1.20, it 19 states that if a valid prototype CVAP was conducted 20 on a reactor outside of the United States, the details 21 and results of the program would need to be included 22 in the application related to the non-prototype plant.
23 And it has to of course meet the criteria in the reg 24 guide.
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63 1 to the analysis done for the dimensions of the APR1400 2 in Palo Verde Unit 1, in regards to the CVAP program.
3 And so the particular table that was mentioned was 4 DCD Table 1.3. However, the comparison of Palo Verde 5 Unit 1 data for the reactor internals is located in 6 DCD Tier 2, Tables 3.9-16 and 3.9-17.
7 So for the review of Section 14.1, the staff 8 concluded that information provided adequately 9 addressed the specific information to be included in 10 the ITP and is acceptable.
11 So the next couple of slides go over the 12 open items. There were 16 of them. All 16 have been 13 posed. Nine, or eight of those, I'm sorry, remain 14 confirmatory items. So we can kind of go through these.
15 Mr. Brown, which specific one did you want to?
16 MEMBER BROWN: Excuse me, are you done with 17 everything else? You zipped right through.
18 MS. FERGUSON: Yeah, which specific open 19 item?
20 MEMBER BROWN: It is 198-8208, I think.
21 Let me look again.
22 MS. FERGUSON: Okay.
23 MEMBER BROWN: 198-82082, question 24 14.02-21.
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64 1 seven.
2 MEMBER BROWN: And your part of the SER 3 is page 14-39 and 40. And so it begins with 14.2.12.124 4 with plant protection system test. And then comma 5 14.212.1.138 CPCS system. And then it seems to be all 6 jumbled, the discussion. I can't segregate it.
7 It implies, you talk about the CPCS testing 8 and that you can't do a beginning to end, insert a 9 signal, and test it, because of the large number of 10 sensors you have. I'm trying to remember why, but I 11 think that's where you agglomerate a whole bunch of 12 in-core sensors.
13 And then you do an analysis if there's an 14 algorithm that calculates stuff. And how you input 15 data into one sensor and run a time response test, I 16 can kind of maybe understand that. And you have to 17 do something on an analysis basis, and you talk about 18 modular versus, it's on page 39 of your thing here.
19 You all asked the question why is overlap 20 testing required. The response time test should 21 include each safety system from sensor to actuated 22 equipment as practical in a single test. Where it's 23 not practical, you can do it piecemeal and add them 24 up.
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65 1 do a response time testing in a single test because 2 it would be more efficient and beneficial for 3 maintenance purposes to have a modular testing method 4 rather than a single test. And I presume all that 5 applied to the CPCS, not to the rest of the PPS system.
6 But it's all jumbled up.
7 MS. FERGUSON: Okay, so your question is 8 the response, the answer on the response time, does 9 that apply to the other INC systems outside of the CPCPS?
10 MEMBER BROWN: Yeah, the lead-in paragraph 11 is not, because it, the first part of the lead-in talks 12 about Subsection .24. And then as you continue, you 13 talk about 138, and you mix the stuff up. The rest 14 of the PPS system can easily be tested with an input 15 to output. So what we're, I don't, what we're using 16 a different methodology for is not clear.
17 MS. FERGUSON: Okay.
18 MEMBER BROWN: I wasn't able to get a hold 19 of, I don't have the RAI on that one, so I was unable 20 to see any of the details. But that's my question on 21 that.
22 MS. FERGUSON: Okay, so I'm going to take 23 your question back. The reviewer is not present at 24 the moment. But from what was included in the safety 25 evaluation, we identified that they didn't include NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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66 1 testing for the core protection calculator system, and 2 they proposed to include redundancy in independents, 3 specifically for the CPCS.
4 So as far as the other systems on the PPS, 5 I will have to take that back.
6 MR. CHOI: Could I answer? My name is 7 Woongsoek Choi, KEPCO E&C SC Engineer. So we provided 8 RAI response to answer for the question. So CPCS 9 response time testing is performed by similar method 10 with as a PPS modular.
11 I think the modular terminology cause a 12 little confusion. So CPC consists of CPP processor, 13 CH processor, and CPC processor. So the processor 14 phase to response time testing is performed.
15 So our testing overall diagram in Chapter 16 7.2 shows the PPS testing diagram. We will include 17 with all the included CPC. So for likely is PPS. So 18 the response time testing is performed by testing 19 injection signal injecting. And then to verify the 20 result on the output.
21 MEMBER BROWN: That's for the CPCS?
22 MR. CHOI: Yeah, right.
23 MEMBER BROWN: Okay, so you're saying that 24 you do it the same way that you do the rest of the PPS 25 system.
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67 1 MR. CHOI: Right.
2 MEMBER BROWN: There was very little 3 definition. I didn't see the RAI, so I couldn't find 4 it. So I have no problem with looking at that. But 5 I also, in reading your SER, it doesn't come across 6 as there's no discussion of the PTS testing. It's all 7 lumped together, so it gets confusing as to what 8 applies, is there a difference or not.
9 MS. FERGUSON: Okay.
10 MEMBER BROWN: I'm just trying to make sure 11 we understand how that is done. Okay?
12 MS. FERGUSON: Okay.
13 MEMBER BROWN: Now the other, I guess the 14 other question I had on this is that, and this is just 15 from looking at the ITAACs, as well as this particular 16 section talks about testing of the watchdog timer.
17 When I looked later in the Tier 1 stuff, it was not 18 clear. They say -- it was not clear how that, it's 19 not even mentioned in the ITAACs, that the watchdog 20 timer is tested.
21 So it was not, and how you do that should 22 have at least, there should have been some type of 23 reference or acceptance criteria in this thing. And 24 I presume it's not in this RAI relative to that either.
25 MS. FERGUSON: No, it isn't.
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68 1 MEMBER BROWN: That's for processor 2 lockup. Okay. The next question or comment I had, 3 there's no, in this particular let me find the, where's 4 the slide? Oh. There is no -- oh, here it is.
5 Right now there is, included in this 6 objectives here, there are no tests to verify, no tests 7 or inspections that verify that there are no 8 communications between the divisions that exist, other 9 than the function processor trip data, which is an 10 on-off data, to other division voting processors, which 11 you have to have to be able to vote. But that should 12 be the only communication.
13 And there's no verification of 14 communication independence in this section, 15 14.2.12.1.24 rather. Which would, there's no 16 discussion of it anywhere relative to that.
17 MS. FERGUSON: Take that back as well.
18 MR. CHOI: So can I answer?
19 MEMBER BROWN: Sure.
20 MR. CHOI: For your concern. My name is 21 Woongsoek Choi, KEPCO E&C. So your second question 22 is about watchdog timer. So watchdog timer was added 23 in ITAAC. That was integrated with entire common-cure 24 watchdog timer issue. So ITAAC requires that the 25 watchdog timer shall not be dependent on the internal NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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69 1 CPU. So --
2 MEMBER BROWN: Oh, I understand that.
3 I've seen your other piece of, the data that you all, 4 you know, the paper that you all put out. If you look 5 at, staying out of the ITAAC, the watchdog timer is, 6 if you added it to the ITAAC, that's fine. I don't 7 have a version of the ITAAC that shows that.
8 I'm looking at Rev. 1 of the Chapter 14.
9 So I, okay, if that's, if you've done something with 10 that, I guess we'll see that at some point.
11 MR. CHOI: Okay.
12 MEMBER BROWN: The other question relative 13 to communication independence, by the way, in Rev. 1, 14 the watchdog timer is mentioned, but it's not mentioned 15 in the ITAACs. It wasn't in Rev. 1, so that's all I'm 16 talking about there.
17 The communication independence is talked 18 about in the ITAACs, but it refers to only basic of 19 the communication within a processor, like the bias 20 table process talks about the processing and the 21 communication part, and with the dual port RAM. It 22 doesn't talk about sending data and not doing it in 23 the processing part but only sending it to the voting 24 units.
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70 1 know, intercommunications between the divisions, other 2 than that particular communication. It's not talked 3 about either in the 14.2 chapter or that particular 4 feature in the ITAACs, so. Or at least in the Rev.
5 1 ITAACs.
6 MR. CHOI: Chapter 14.2.212.1.24, PPS 7 include the testing requirement for Y interface between 8 other systems and our safety assessment technical 9 report.
10 MEMBER BROWN: Are you talking about 11 Section 1.6?
12 MR. CHOI: 14.2.12.1.12 -- 24.
13 MEMBER BROWN: Yeah.
14 MR. CHOI: The section include --
15 MEMBER BROWN: Section which? I'm 16 looking at it and I couldn't find it in the objective 17 section. It talks about testing functions between the, 18 whatever the test, the maintenance test processor and 19 the interface test processor and the interface. But 20 not, it doesn't talk about communications between 21 divisions.
22 At least, I couldn't interpret the words 23 to make it come out that way. Under the objectives.
24 MR. CHOI: I understood your comment. So 25 the communication independence shall be added in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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71 1 section, in Chapter 14.
2 MEMBER BROWN: Okay.
3 MR. CHOI: Okay.
4 MEMBER BROWN: All right. And then 5 fundamentally, that's not something you test, unless 6 I'm wrong, it's not something you can test for. You 7 have to make sure there's no connections between the 8 divisions, other than the signal that goes from a 9 processing bias table unit to a voting unit.
10 Other than that, there should be no 11 communications, other than when you're in the test mode.
12 I think I have -- I think --
13 MR. CHOI: I think objective 1.7 check to 14 verify the validity of using manual testing. That is 15 testing for, test interface. And the communication 16 independence is not described in detail in Chapter 14.
17 MEMBER BROWN: That's right.
18 MR. CHOI: However, in this section 19 describe all the interface, and our technical report, 20 safety ISTR, describe about communication independence 21 in detail.
22 MEMBER BROWN: I understand that, it's 23 just that we're not verifying that the design meets 24 those requirements that are specified in the safety 25 technical report. And they're not, that purpose of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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72 1 this, all the requirements that are listed in there, 2 a good, most of them are listed right in here that you're 3 going to verify those at some point in the initial test 4 program. So that's where it's missing right now.
5 MR. CHOI: Thank you for your comments, 6 and we will consider them.
7 MEMBER BROWN: Okay, thank you.
8 CHAIRMAN BALLINGER: I'm actually not sure 9 where we are.
10 MEMBER BROWN: I'm finished. Does that 11 confirm where we are?
12 MS. FERGUSON: We jumped to open item 13 number seven. As I said earlier, the other open items 14 were addressed during KHNP's presentation. So we can 15 now jump to the last slide.
16 So the staff has determined that all of 17 the open items associated with Sections 14.1 and 14.2 18 have been adequately addressed and resolved.
19 And the staff includes that the information 20 presented in the DCD, pending the confirmation of the 21 remaining eight confirmatory items that the applicant 22 has determined compliance with NRC regulations and 23 guidance. So that concludes this presentation. Are 24 there any further questions?
25 CHAIRMAN BALLINGER: No questions?
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73 1 MEMBER BROWN: Only to make sure that, I'm 2 still a little unclear on the response time part of 3 it.
4 MS. FERGUSON: Okay.
5 MEMBER BROWN: It'd be nice if that was 6 clarified in the SER.
7 MS. FERGUSON: Okay.
8 MEMBER BROWN: That response time is done 9 in a manner in which we, your question asked that ought 10 to be done in. Or at least the, so that all these words 11 about modular and add them up and beginning to end don't 12 get all messed up, that's all.
13 MS. FERGUSON: Right.
14 MEMBER BROWN: I don't see anything for 15 KHNP to do, other than you all to make sure the SER 16 is clear.
17 MS. FERGUSON: Will do.
18 CHAIRMAN BALLINGER: Again, again? Okay, 19 let's take a 15 minute recess. Long overdue.
20 (Whereupon, the above-entitled matter went 21 off the record at 3:30 p.m. and resumed at 3:45 p.m.)
22 CHAIRMAN BALLINGER: Okay, we're back in 23 session. So we're up to chapter, yes, 16.
24 MR. SISK: Without any further delay, I'm 25 going to pass it over to Mr. Sanwon Lee.
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74 1 MR. LEE: Hello, my name is Sanwon Lee.
2 I will talk about the Chapter 16 technical 3 specification.
4 CHAIRMAN BALLINGER: Can you move that a 5 little closer. I can't --
6 MR. LEE: Yes. Chapter 16, technical 7 specification. This is the contents, first overview 8 of the Chapter 16. And I will talk about the major 9 open items and finalize with the summary.
10 This is overview of Chapter 16. APR1400 11 technical specifications were developed based on the 12 standard tech spec for formerly CE plant. And there 13 are some differences between the APR1400 tech spec and 14 the standard tech spec, mainly the unique design feature 15 of APR1400 including the RCS system and safety injection 16 system, IRWST and aux feedwater, et cetera.
17 And this kind of deviation was summarized 18 in the Deviation Report between NUREG-1432 and APR1400.
19 That one was submitted 2015, December.
20 There's a section or overview of 16. Our 21 main section is the Section 3, our limiting condition 22 for operation and the surveillance requirement for 23 every nine sub-sections.
24 Basically, in Phase 3, there are 223 25 question was raised, and there are lots of sub-question NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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75 1 just included. So actually, there are over --- lots 2 of questions were raised. And in Phase 3, there are 3 135 open items were issued.
4 And then, we have some communication with 5 the NRC staff, technical staff. And right now, all 6 the item was reserved, and there is no -- no open item 7 was remained currently.
8 So open item was 135. So lots of open items 9 related to the expression, and some expression was some 10 --- some exact expression on the technical 11 specifications. So I will now talk about major 12 technical issues related to the open items.
13 So first one is disposition of the NRC 14 approved the TSTF report. The issues that --- that's 15 on TSTF report, something is issued before the standard 16 tech spec was issued. And something is issued after 17 the TSTF was published.
18 So all NRC approved the TSTF Travelers, 19 including those approved since NUREG-1432 was fully 20 reviewed. And we summarized that something is 21 included, something is not included in our tech spec.
22 So we summarized that table and some rationales and 23 just reflected on the Deviation Report. And right now, 24 it's reserved.
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76 1 operation selection criteria. Basically, it has --
2 10 CFR 50.36 has four different category for the LCO 3 selection criteria. But the issue is how to select 4 the LCO for the APR1400.
5 So we systematically evaluate the LCO 6 selection criteria that is related to the other chapters 7 which are Chapter 5, 6, 7, 15, and 19. So we have 8 compared all of that and some with, oh, a different 9 a table for each LCO selection criteria, so met the 10 LCO selection criteria.
11 And as a result, we add some LCO that is 12 not reflected in previously DCD. So, for example, CPS 13 aux-three function and charging flow is included with 14 the LCO. And right now, it is also reserved.
15 And the third one is safety injection 16 system diagonally operable is issued during the Phase 17 3 ACRS meeting also. The full clarity, the LCO 18 condition is two separate, two different loads. And 19 the diagonal and Train 1 and 3, well, Train 2 and 4 20 is identical. But we showed two different expression 21 at the same time to remove the full clarity of the 22 operator.
23 Finally, auxiliary feedwater system for 24 conventional NRC plant and APR1400 is --- that's a 25 different design. Because conventional NRC plant has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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77 1 two motor-driven pumps and one turbine-driven pump.
2 But we have two motor-driven and two turbine-driven.
3 And water source is different.
4 So this system is not directly compared 5 to the conventional NRC plant auxiliary feedwater 6 system. So we communicate with the NRC staff on which 7 one is the appropriate LCO and accomplish a time of 8 our plant. And this was reflected, so current status 9 is it is also resolved.
10 This final slide, all RAIs on Chapter 16 11 were resolved and all responses were decided to be 12 acceptable. And the DCD Rev. 2 will be published in 13 February of 2018. And also the Deviation Report 14 between standard tech spec and APR1400 tech spec is 15 being updated based on the DCD Rev. 2 and will be 16 submitted at the DCD submission. Thank you for your 17 listening.
18 CHAIRMAN BALLINGER: Questions?
19 (No audible response) 20 CHAIRMAN BALLINGER: Thank you. The 21 staff ready to go?
22 MR. HARBUCK: My name is Craig Harbuck.
23 I work in the technical specifications branch in NRR.
24 And I'm one of the principal reviewers for the tech 25 specs. And when we were here for the SER with open NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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78 1 items, we discussed at some length all the different 2 issues that we were discussing with the Applicant.
3 And we came up with a round number of 4 identifying around 135 issues among the 223 questions.
5 And so it's been a long exercise in trying to resolve 6 all of those. But fortunately, we've done that. And 7 what I would like to do is go over those issues which 8 are technical.
9 From a tech spec reviewer standpoint, 10 clarity is important, so some of the issues we had we're 11 trying to achieve a level of clarity and unambiguity 12 that, if you don't settle now, it can become more 13 difficult to fix at later times, such as through license 14 amendments, or exemptions, that sort of thing. It's 15 better to fix it now. And so that was our motivation.
16 And I think we've come to a very high 17 quality set of tech specs. Now, project managers are 18 Bill Ward and Jessica Umana, who I guess could not be 19 here.
20 Slide 3 lists all the reviewers. This 21 slide is identical to what we showed you last March.
22 So there were a lot of people who had issues that 23 overlapped into the tech spec area. And we appreciate 24 their efforts.
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79 1 basically six slides listing these items, and I'm going 2 to speak to each one. So the first area where we had 3 some issues were in defined terms. They had proposed 4 a number of terms which we thought were not needed, 5 so they were withdrawn.
6 Some definitions were revised based on the 7 design analysis and terminology in APR1400. Some of 8 the definitions were related to specific water levels 9 during shutdown conditions. And we generally just 10 replaced those definitions by using the actual 11 elevation that corresponded to it.
12 The next big issue was the shutdown risk 13 mitigation. And we've concluded that an action to 14 raise a water level to above about three feet below 15 the reactor vessel flange is an acceptable and adequate 16 action in MODEs 5 and 6 following a loss of shutdown 17 coolant, considering that LCO 3.5.3 on safety injection 18 requires two operable SI trains, and because this level 19 is consistent with the guidance in Generic Letter 8817 20 regarding shutdown risk.
21 Specific LCOs I would like to mention 22 related to this is LCO 3.4.8, RCS loops, MODE 5 with 23 loops not filled. This LCO requires two shutdown 24 cooling trains, and one containment spray pump to be 25 operable, and one shutdown cooling train to be in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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80 1 operation.
2 This is a lot of requirements for 3 mitigating an event if you're going to lose your 4 shutdown coolant. So the one thing that was not clear 5 between this LCO and the one preceding it in MODE 5 6 was what constitutes loops not filled.
7 And so we discussed this with the 8 Applicant, and we finally came to the conclusion that, 9 at about four feet above the reactor vessel flange when 10 you're draining down the pressurizer, you start to form 11 voids in the top of the steam generator tubes. And 12 as you lower level more you get more voids in more of 13 the tubes.
14 And this interferes with natural 15 circulation flow which, when you're in the loops filled 16 condition, you're supposed to be able to use secondary 17 heat sink with natural circulation.
18 So since the discussions that were 19 originally provided seemed to imply that you could go 20 down to the top of the hot leg, in terms of draining 21 down the surge line, that did not seem to address this 22 issue.
23 So we did come up with it so that the base 24 is now clearly explained, what constitutes entering 25 a loops not filled condition and also what you have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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81 1 to do to go back to the loops filled condition. And 2 that's important, because you need to know when these 3 requirements apply.
4 And that's an improvement over what's in 5 the current tech specs for most PWRs which don't really 6 discuss this very much. And in contrast, the AP 1000 7 simply says a reactor coolant system intact or not 8 intact. That's how it separates these two different 9 MODE 5 conditions.
10 MEMBER SKILLMAN: Craig, how is that 11 addressed when the fuel has been removed? At 241 fuel 12 assemblies, if there's a reason --
13 MR. HARBUCK: You mean if you don't have 14 any fuel in the ---
15 MEMBER SKILLMAN: Correct. Is there a 16 caveat that says this only applies when there's ---
17 MR. HARBUCK: There's no LCO that applies 18 to the RCS when you've removed all the fuel.
19 MEMBER SKILLMAN: Are those words in 20 there?
21 MR. HARBUCK: Well, it's contained in the 22 applicability requirements.
23 MEMBER SKILLMAN: But those words are in 24 there, if there's no fuel these don't apply?
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82 1 for totally, you know, vessel on fuel. MODE 6 is you 2 have any fuel in the vessel with the head detentioned, 3 okay, and so if there's no fuel then you're no longer 4 in a defined MODE.
5 MEMBER SKILLMAN: Is that defined?
6 MR. HARBUCK: Only to the extent that I've 7 just explained it.
8 MEMBER SKILLMAN: Wait a minute, wait a 9 minute.
10 MR. HARBUCK: I'm not sure what you're 11 asking ---
12 (Simultaneous speaking) 13 MEMBER SKILLMAN: Hundreds and hundreds 14 of hours in a control room with tech spec, and here 15 we sit. We're going to do some steam generator work.
16 We've chosen to de-fuel. And I've got these tech 17 specs. And we all look around and say these don't 18 apply. And then I have an inspector come in and say, 19 well, I think you're right. They don't apply, but 20 that's the way they're written no matter where your 21 fuel is.
22 So my only point is, with your discussion 23 of clarity in terms, it seems that there ought to be 24 a term that says if fuel's not in the vessel these don't 25 apply. And there are conditions where you do, in fact, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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83 1 de-fuel.
2 MR. HARBUCK: There are requirements for 3 the spent fuel pool.
4 MEMBER SKILLMAN: I'm not talking about 5 the spent fuel pool.
6 MR. HARBUCK: And there's requirements 7 when you're removing fuel, irradiated fuel assemblies.
8 So at all times there's going to be some requirements 9 that address protecting the fuel.
10 MEMBER SKILLMAN: Well, certainly. I 11 understand that.
12 MR. HARBUCK: Right. And so I'm not sure 13 I understand your question.
14 MEMBER SKILLMAN: The point I'm making is 15 you made a very strong point of making clarification 16 of terms. And I'm asking you for, when fuel has been 17 removed from the reactor vessel, if it is clear to the 18 operations personnel that these, say these three 19 bullets right here, are non-applicable. Is there 20 something that lets them point to the tech specs and 21 say these don't apply because my fuel is over in the 22 spent fuel pool?
23 MR. HARBUCK: Well, if your vessel's 24 empty, you're not in MODE 5. And that's what LCO 3.4.8 25 addresses.
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84 1 MEMBER SKILLMAN: And is it clear?
2 MR. HARBUCK: Yes, MODE 5 with reduced 3 inventory is what we're addressing here.
4 MEMBER SKILLMAN: Okay.
5 MR. HARBUCK: And the next one addresses 6 MODE 6 with reduced inventory, okay, but also MODE 5 7 with reduced inventory in terms of an extra --- an 8 additional requirement that's not in the standard for 9 having containment closure when you're in this 10 condition, or the ability to have your purge system 11 automatically close, or if you lose shutdown coolant.
12 So the provisions that have been added to the tech 13 specs, compared to the standard to address shutdown 14 risk, are a plus for this application.
15 MEMBER SKILLMAN: Okay.
16 MR. HARBUCK: And I don't --- beyond this 17 --- Oh, I just wanted to point out that this is one 18 of the issues we had. And these are some of the details 19 of how these requirements apply.
20 MEMBER SKILLMAN: Okay.
21 MR. HARBUCK: Okay, next slide. There's 22 a pretty thorough set of requirements that address the 23 boron dilution event. The basic difference between 24 these requirements is there's one group that requires 25 demineralized water sources or unborated water sources NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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85 1 to be isolated. Therefore, you preclude the event.
2 And the other is to either have an alarm 3 to give adequate warning to the operator or some other 4 notification to let them know that there's something 5 going on with reactivity.
6 The reason for having LCOs, and one of the 7 new ones is LCO 3.1.2, is that if you don't have adequate 8 mixing then your instrumentation to detect a change 9 in the activity would not necessarily detect it. And 10 so instead of trying to provide some analysis to support 11 that particular situation, we have an LCO that says 12 if your reactor coolant pumps are all idle, then we're 13 going conclude a dilution event.
14 So the next item is going back to LCO 3.6.7.
15 This is modeled on what normally has been an LCO in 16 the refueling section. And in the refueling LCO, which 17 is 3.9.3, there's a provision that says you can either 18 isolate your purge system or you can have an operable 19 means of isolating it. And that could mean automatic 20 or manual.
21 The way it's interpreted in these 22 specifications is that it includes the automatic. But 23 the difference is, in what's required during 24 re-fueling, is that the applicability is during 25 movement of irradiated fuel or during core alterations.
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86 1 And in order to do either of those, LCO 3.9.6 requires 2 the level to be 23 feet above the flange, reactor vessel 3 flange.
4 In 3.6.7, it addresses the situation where 5 you're in MODE 5 with the loops not filled or MODE 6 6 with a level below 23 feet above the flange. And we 7 just collectively call this, you know, low inventory 8 condition or reduced inventory condition.
9 And what you're concerned about there is 10 being able to mitigate a loss of shutdown cooling, since 11 a loss of shutdown cooling could result in a boiling 12 and perhaps, if the RCS is open, it could have steaming 13 into containment.
14 You're not allowed to use a provision that 15 is allowed in 3.9.3 which is designed just to mitigate 16 a fuel handling accident where the principle mitigative 17 feature is the water in which the fuel assembly has 18 been damaged. The activity release gets reduced by 19 passing through the water. And you don't have a threat 20 of a pressurization or steam forming in the containment.
21 And so you can get by with what's termed 22 an equivalent isolation method. And that has to be 23 something the staff has pre-approved. And that's 24 explained in the bases.
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87 1 of their findings on the adequacy of the shutdown risk 2 assessment on being able to mitigate an event that 3 resulted in steaming into containment. And they wanted 4 to make sure that you didn't have this equivalent method 5 option. And so that's been removed, and we've made 6 this distinction. So that was something that came out 7 just right at the end of the review.
8 So, let's see. Okay, next slide. We were 9 previously talking about core protection calculator 10 system. And there's an LCO 3.3.3. on the core element 11 assembly calculators. These take -- every control rod 12 has two rod position indications, and they feed into 13 some processors which are positioned processors for 14 the control rods.
15 And there's redundancies built in and what 16 have you, but they end up providing core element 17 assembly position calculators which are input into the 18 CPC calculations to provide penalty factors in the 19 output of the CPCs regarding the low DNBR or high linear 20 power density trips.
21 And so this LCO is provided to address what 22 do you do if you have an invalid signal coming from 23 your CEACs. Like Palo Verde, the APR1400 has two CEACs 24 per channel of CPCs. And the older designs you had 25 just two CEAC computers that supported all four NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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88 1 channels.
2 So the action requirements that we 3 developed are largely based on what had been established 4 for Palo Verde with some slight enhancements to clarify 5 what we think is the best practice depending upon how 6 many CPC channels are affected.
7 Essentially what it does, it says if the 8 CEAC is inoperable, you can either implement manual 9 measures that ensure the CEACs are getting appropriate 10 inputs for that condition, and you're doing manual 11 verifications of oppositions. And that's a kind of 12 repetitive thing that you do to justify continuing to 13 operate with this downed piece of equipment.
14 Or alternatively you can say, well, this 15 whole channel of LPD high and DNBR low is out of service.
16 So I'm going to consider them to be inoperable and 17 enter my instrumentation LCO. And if it's just one 18 channel affected, I have the option of either putting 19 that instrument channel in trip or bypass, okay.
20 If two channels were affected, then I would 21 have the option of putting one in trip and one in bypass.
22 This still leaves adequate protected capability from 23 the automatic trip system for these two functions.
24 But you don't have as much margin to an inadvertent 25 trip occurring. So it may or may not be advisable to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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89 1 operate for any length of time. But generally, if 2 you've just got one channel affected, it's something 3 that you can possibly live with.
4 Now, the thing that we wanted to make clear 5 was that once you get, you know, multiple channels 6 affected, that it's probably better just to not declare 7 your CPC channels inoperable. And it's better just 8 to take the actions that are provided. And since 9 they're manual and kind of onerous, probably would 10 provide good incentive to get these things fixed right 11 away. So we'll make clear that's what we would prefer 12 to do.
13 The other point was that -- and this is 14 not something that's very clear in the tech specs, 15 because we don't really have this arrangement anywhere 16 else. But if the action said declare the CPC 17 inoperable, then causes you to enter the 18 instrumentation spec, what if I had another CEAC go 19 out, or something changed, and so it looked like it 20 would be advantageous for me to un-declare that channel 21 inoperable and simply take those manual actions.
22 And since that involves saying that we just 23 don't have any real rules for the tech specs, we 24 clarified in the bases that the preference is --- or 25 the intent is that, until you've restored the CEAC that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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90 1 sent you to the instrumentation LCO in the first place, 2 you're not going to be able to undo that declaration 3 of the operability. And that's something that the 4 Applicant agreed to. And so that's what we decided.
5 Again, this is over and above what's in 6 the Palo Verde explanations for their very similar LCO 7 actions. But we think this is an improvement and needed 8 clarification.
9 Instrumentation testing, we looked at the 10 list of testing that's provided in Chapter 7, Section 11 72 and 73, and could not figure out how they correspond 12 with the instrument test in the tech specs. And so 13 we asked them to help us do that.
14 In the process of trying to get this 15 clarification, we ended up being able to make such a 16 correlation. We were able to improve an existing 17 figure in Chapter 7, Figure 72-11, and add a new figure, 18 7.3-24.
19 And where before we had tried to address 20 both RPS and SFAS, now the 72 figure addresses it, just 21 the RPS logic testing, and shows overlap and indicates 22 the names of all the tests that are described in the 23 chapter. And then same thing for the SFAS. So we've 24 made an improvement. So where we're trying to clarify 25 how we implement the tech specs, we resulted in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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91 1 improving Chapter 7 as well.
2 Let's see. There is an --- for the SFAS, 3 for its actuation logic, you have the coincidence logic, 4 initiation logic, actuation logic, and then there's 5 the name of the function.
6 Well, for these logics, there's testing.
7 And they're covered by an LCO, 3.6, yes, LCO 3.3.6 8 covers the logic for SFAS. And there's a surveillance 9 requirement which is focused on testing the actuated 10 devices. And there's a note that says that you'll test 11 this on a staggered test basis by testing groups of 12 actuated components associated with Channels A, and 13 C, and B, and D. And we found the language of that 14 note to be a bit confusing and not very clear.
15 And we were able to verify that, how the 16 equipment is, these actuated devices are arranged into 17 subgroups such that when they're tested it doesn't cause 18 any unusual or unexpected plant transient. We were 19 able to verify that that's all been adequately 20 determined. So that was the result of that exercise.
21 Slide Number 4, or seven, I guess, seven, 22 okay. Auxiliary feed water system, you heard 23 previously that there were issues with auxiliary feed.
24 And I'll just briefly talk about some of the highlights 25 of that, how that came out.
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92 1 In the standard tech specs, and tech specs 2 in general, we typically allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to correct a 3 loss of redundancy situation. In the AFW system, this 4 would correspond to having one steam generator with 5 one of its AFW trains inoperable or both steam 6 generators with one AFW train inoperable.
7 The event that you're thinking about when 8 you're establishing the times to, you know, where you'd 9 have loss of redundancy or not, is where you have one 10 steam generator with its AFW pumps affected by an 11 inoperable train. And then the other generator is the 12 one that has the accident, so it's not available for 13 AFW.
14 So if you have just one generator affected, 15 you still have capability even with that kind of a 16 failure. If you have one of the two trains for each 17 generator affected, you still have capability for that 18 failure. But if you have one steam generator with both 19 of its trains out, and you lose the other generator, 20 then you have no aux feedwater.
21 So we do sometimes provide time for a 22 potential loss of function in cases where the scenario 23 for which the condition would mean not having the 24 function, because the event contributed to not having 25 it. Sometimes we give time for that.
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93 1 The CE standard incorporates TSTF that we 2 had where, if you had lost one of your steam supplies 3 to your auxiliary feedwater pump, your turbine driven 4 pump, that you could get some time provided the decay 5 heat load wasn't that great, or it's not starting up 6 or something. And you were going to get seven days 7 for that. And originally it was proposed by the 8 Applicant that they could get that too, even though 9 the systems don't really compare very well.
10 And so --- but that was the case that I 11 just mentioned where there's a small, not that likely 12 set of circumstances for which that action could result 13 in you not having a function. But we gave it a little 14 bit more time for that. I think for that particular 15 case, it also involved failure of another motor driven 16 pump.
17 Okay. So what we did was that we 18 established Condition C where it was one steam generator 19 with two trains inoperable. And because this could 20 lead to a loss of function, we figured a time shorter 21 than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> would be appropriate. Whereas, if you 22 don't have that event, then you would have the whole 23 --- you wouldn't have loss of redundancy.
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94 1 it's a COL item. And we believe that the 24-hour time, 2 deterministically, was acceptable, because this event 3 we're concerned about would have a low probability of 4 occurrence.
5 And you do have the availability of safety 6 injection and then a water relief path through the pilot 7 operated safety relief valves to, one, to remove decay 8 heat. So with that capability there, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is 9 adjudged to be acceptable.
10 Now, we also put the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> that we 11 allowed for the other two conditions where you just 12 have one pump out for each generator or just one pump 13 for one generator. We allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for that, but 14 we also put in brackets indicating that if, in both 15 cases, indicating that if you can do a risk evaluation 16 of a longer time, and you can justify it to the staff 17 for a COL application, then you would be able to do 18 that. And so that's how we resolved that issue.
19 The other issue related to aux feedwater 20 was allowing seven days for one of the water supplies 21 to be inoperable and, of course, the water tank to be 22 inoperable for a number of reasons.
23 But from the tech spec point of view, we 24 look for the most severe reason. And if you have no 25 flow path from your tank, it's obstructed in some way, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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95 1 then the ability to open a valve between the bottoms 2 of the tanks to the other divisions is not going to 3 really help you in the division each tank is blocked.
4 And so we were having a hard time 5 understanding how we could say you have seven days if 6 you're saying that you have to verify availability of 7 the other tank.
8 But then, we came to understand that each 9 division in aux feedwater has a condensate storage tank.
10 It's not as big as the regular tank, but it has a pretty 11 good size volume that all you have to do is open up 12 a manual valve, and you have access to that water through 13 the suction of the pumps in that division.
14 So we figured seven days would be okay as 15 long as you verified the availability of this non-safety 16 tank. And this is consistent with the standard which 17 is based on having one tank only for both trains or 18 both divisions. And you simply verify an unspecified 19 back up water source. So that's how we agreed to keep 20 the seven days for having an operable tank, again, LCO 21 3.7.6.
22 CHAIRMAN BALLINGER: Yes?
23 MEMBER KIRCHNER: Can I ask a question just 24 ---
25 CHAIRMAN BALLINGER: Okay.
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96 1 MEMBER KIRCHNER: Philosophically, how do 2 you approach these tech specs? I know you just talked 3 us through a few scenarios. And then you come up with 4 round numbers which feel good and probably bracket the 5 time that a deterministic calculation would say you've 6 got two low a level, or you've got unacceptable fuel 7 condition, or you're got whatever the upset is. But 8 it seems like it always comes back to 24, 72, seven 9 days. Is this just a --
10 MR. HARBUCK: This has been the practice 11 of tech specs since their inception. We have these 12 standard times. And I would hazard a guess that there's 13 reasons for that. I'm don't know if I go into all of 14 them, but they have to be based on perceptions of what's 15 an acceptable period to be vulnerable to a single 16 failure --
17 MEMBER KIRCHNER In this construction of 18 tech specs, then there's no risk informed, so to speak 19 ---
20 MR. HARBUCK: Right.
21 MEMBER KIRCHNER --- quantitative ---
22 MR. HARBUCK: There are number of ---
23 MEMBER KIRCHNER --- assessment that would 24 allow you -- I'm not recommending, by the way, you go 25 to 12.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, and 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br />, and so on. So in this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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97 1 case, where you've made these decisions, these were 2 not based on risk informed?
3 MR. HARBUCK: No. No, no they weren't.
4 They're based on --
5 MEMBER KIRCHNER Thank you.
6 MR. HARBUCK: -- the deterministic.
7 MEMBER STETKAR: I wouldn't call it ---
8 Craig, be careful.
9 MR. HARBUCK: Okay.
10 MEMBER STETKAR: They were made up 40 years 11 ago by people saying, well, we could probably get it 12 fixed in seven days.
13 MR. HARBUCK: Yes.
14 MEMBER STETKAR: It wasn't deterministic.
15 There was no technical basis whatsoever. They are 16 simply historic numbers that people have used. And 17 if you want to differ with that, I'd be really thrilled 18 to hear where the basis is. There isn't any.
19 MR. HARBUCK: No, I sense that.
20 MEMBER STETKAR: They're just made up.
21 MR. HARBUCK: I think over the years people 22 have come up with wishful thinking reasons for why these 23 are okay from a technical perspective.
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98 1 be 12. And this ought to be 24. That's just saying 2 this ought to be red, or it ought to be purple. Because 3 we've always used purple for this condition. There's 4 no basis for it.
5 This whole notion of, well, we looked at 6 this plant design, and it's different from anything 7 else. But we're going to try to force fit it to things 8 that people have used in the past.
9 I've seen plants that have two trains of 10 auxiliary feedwater. Your whole notion of, gee, if 11 we have one steam generator not available, and the other 12 steam generator gets into a problem, you don't think 13 about that stuff for other plants --
14 MR. HARBUCK: Well, that's because --
15 MEMBER STETKAR: -- that are currently 16 operating, do you?
17 MR. HARBUCK: Because both pumps can feed 18 both steam generators.
19 MEMBER STETKAR: Not all plants.
20 MR. HARBUCK: But you're right, there must 21 be some out there.
22 MEMBER STETKAR: There must be some.
23 MR. HARBUCK: There must be some. I know 24 that ANO Unit 1 didn't originally have it.
25 MEMBER STETKAR: Right.
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99 1 MR. HARBUCK: But they modified their 2 system to do so.
3 MEMBER STETKAR: But the point is that you 4 spend a lot of time trying to force fit people into 5 a mold that has had no technical basis for it. And 6 that's why people want the option to go to the new 7 risk-informed tech specs that are tailored to their 8 plant design. They don't come up with 12.273 hours0.00316 days <br />0.0758 hours <br />4.513889e-4 weeks <br />1.038765e-4 months <br />.
9 Because, you know, that doesn't make sense to try to 10 get something done in a day.
11 MR. HARBUCK: Well, as you can see, what 12 we've done here is try to stick with numbers that are 13 consistent with what we've deterministically ---
14 MEMBER STETKAR: Don't say 15 deterministically. You have traditionally based on 16 the accepted story involved. It's not 17 deterministically. There's no deterministic basis.
18 MR. HARBUCK: We say we follow precedent.
19 MEMBER STETKAR: Precedent would be a good 20 word.
21 MEMBER KIRCHNER So, yes, I wanted to test 22 that then. So if the Applicant in this case, KHNP and 23 company, have put extra systems in and such, do you 24 find that you're changing the time window that you're 25 allotting them? Or do you just fall back to what has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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100 1 been precedent?
2 MR. HARBUCK: Well, our general approach 3 is to try and approve what is consistent with the 4 standard, since that is something that we have found 5 acceptable. And one could argue with the basis for 6 that if you wanted to, I suppose.
7 But if the system is designed with a certain 8 capability and a certain lack of flexibility, as this 9 system is, you're kind of limited in what you can allow, 10 given the conventions for thinking about these things 11 and the need to be able to minimize how long you're 12 going with potentially not having a function.
13 MEMBER KIRCHNER Maybe a different way to 14 ask my question is that, as a result of your review 15 of tech specs, and we're going to hear about human factor 16 engineering, I assume that factors into response times 17 to fix equipment and such, to make decisions on time 18 windows.
19 Are there any major changes in the tech 20 specs for this plant versus a Palo Verde or the others?
21 Or are you finding you're falling back on that 22 precedent from that ---
23 (Simultaneous speaking) 24 MR. HARBUCK: Well, Palo Verde has the 25 standard tech specs.
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101 1 MEMBER KIRCHNER Yes.
2 MR. HARBUCK: I believe they were licensed 3 with the old standards, and then they adopted the CE 4 standard, keeping whatever, more flexibility, 5 probably, that they already had, which was allowed.
6 And therefore, by comparing and, in part, reviewing 7 this application against the standard, I think we're 8 fairly consistent. For those systems that are the 9 same, we're consistent.
10 Where this plant differs is in the addition 11 of these other LCOs because of deficiencies. And there 12 are now evaluation boron dilution event with no reactor 13 coolant pumps running, or inadequate mixing, or because 14 they are choosing to provide additional margins of 15 conditions of LCO, the conditions to address shutdown 16 risk. Those we have to look at separately.
17 But typically, the actions that we come 18 up with are consistent with what we do. You know, each 19 mode has its own set of places you can go to to try 20 to minimize the potential hazards associated with being 21 in the condition. So I wouldn't say there's any major 22 differences with the existing CE ---
23 MEMBER KIRCHNER Thank you.
24 MR. HARBUCK: -- digital plants.
25 Okay, the next thing, next slide is, let's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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102 1 see, okay, control of heating, ventilation, air 2 conditioning system. They have --- this is one of the 3 exceptions. Their design is pretty, well, I'll say 4 it's got a lot of capability. But it does have some, 5 the way it's set up to operate automatically, has led 6 us to ask about, well, what is required for this system.
7 For an existing plant, typically you 8 initiate control of emergency ventilation, that is you 9 divert flow into the control room using various filters.
10 And it's essentially what happens. And that's done 11 based on radiation monitors you have in the air intakes.
12 And this plant has two separate air intakes 13 separated by some distance. And one of the things they 14 do is they compare the radiation signals, and whichever 15 one has the higher signal, that intake gets isolated.
16 So all the airflow is coming in through the one with 17 the lower signal.
18 But during the course of the event, every 19 so often it resets and compares them again. And the 20 possibility exists that it could switch to the air 21 intakes.
22 Another thing is that when --- normally 23 you have one air handling unit with a fan, and a cooler, 24 and a heater that's providing normal control room 25 ventilation from the outside. And this is what they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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103 1 call a control room supply and return system.
2 And when they get the actuation signal, 3 and let me just backup. There's two divisions, and 4 each division has two of these air handling units.
5 So when you get the actuation signal from the radiation 6 monitors to initiate the filtered ventilation, only 7 the components associated with that running AHU fan, 8 in terms of its electrical power, are actuating. And 9 so you basically have one-fourth of your system is doing 10 the work.
11 Now, if for some reason it is determined 12 by the instrumentation available that some aspect of 13 that emergency ventilation is not working, it will start 14 the other train in the same division. If that train 15 fails, it will start another train in the opposite 16 division and so forth.
17 And so we were wondering, well, if it did 18 fail, and you're not allowing, by what's stated in 19 Chapter 15, that you need 30 minutes before you can 20 allow operators to do anything, does your dose calcs 21 allow you to have 30 minutes of unfiltered ventilation 22 if you're relying on operators to manually start the 23 standby train, since you're not taking credit for or 24 requiring operability as an automatic feature?
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104 1 and stuff that direct flow are all tied to the operation 2 of the fans. And the filtration train has a fan too, 3 and there's two of them. But there's only one filter 4 train in each division.
5 And so we ended up requiring, for 6 operability of each control room HVAC train, that all 7 these interlocks and automatic start features, even 8 if some of them are not safety related, would be needed 9 to be available in order to establish operability.
10 So that's something that goes beyond what 11 we normally require. But in this case, it seemed like 12 an appropriate thing to do, absent some other evaluation 13 that would make it unnecessary.
14 Okay, on accident monitoring 15 instrumentation, originally the list that was provided 16 in Chapter 7 and the list that was provided in the tech 17 specs were not the same. And Chapter 7 was the lead 18 on the selection of variables for the post-accident 19 monitoring. And they ended up adding a number of new 20 functions. But the end result is that we now have 21 identical lists. And that was the goal.
22 And we're confident from the Chapter 7 23 review that all the functions that were needed to be 24 there by the applicable regulatory guidance and 25 industry standards has been met.
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105 1 Okay, let's see, Slide Number 8. Briefly 2 on --- and I hope it's okay that I'm going over. I 3 just wanted to --- and this is just a highlight of the 4 big issues.
5 Normally in your AC sources, you have a 6 requirement to do a check of the opposite division 7 that's unaffected by an inoperable source to make sure 8 that there's not something that's supported by your 9 electrical in the division with the inoperability, that 10 the other division, that the redundant component's not 11 inoperable or degraded to some extent so that you no 12 longer have a real good assurance of there being ---
13 that you're maintaining the capability to perform the 14 function.
15 So calling that a cross train check, the 16 only difficulty in this case is that you've got two 17 diesels in each division have electrical power. And 18 the bus is supplied by the diesels. They don't have 19 identical sets of loads on them.
20 To the extent you have a four train system, 21 such as a safety injection system, yes, that's true.
22 But for other systems like the containment spray, or 23 shutdown cooling, or chilled water, you don't --- it's 24 not, you know, you may not have four trains of that.
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106 1 meeting redundancy, you know, loss redundancy means 2 that you've lost one or both diesels on one division.
3 The question that we had was, well, how 4 do you know what is the redundancy in the other division?
5 And so we asked them to clarify that, and they did, 6 and so just to make sure that the action, as written 7 and as described in the bases, could be accomplished.
8 An interesting thing is that, during the 9 Condition C of LCO 3.8.1, it's two offsite circuits 10 inoperable. And this could lead to having inoperable, 11 well, this could lead to buses in both divisions not 12 having onsite power.
13 And so the cross train check in this case 14 would require you, one, you have a shorter time to do 15 it and, two, you would have to check both divisions.
16 And we've clarified that in the basis.
17 Now, next slide has to do with some general 18 things, some that --- the first two were touched on 19 by the Applicant in their presentation. And just 20 briefly, we added the auxiliary trips for the core 21 protection calculators. Because there were a number 22 of events in Chapter 15 which inexplicably choose to 23 credit those trips instead of the normal trip that is 24 equivalent to them.
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107 1 just to pick out those that were associated with events, 2 they decided to just require all of them, since it's 3 all really done in software. And it's kind of hard 4 to separate them out within a channel. So that's 5 required.
6 So if you were to have these auxiliary trips 7 out, you would declare the LPD high and the DNBR low 8 trip channels inoperable. And that would then take 9 you over to LCO 3.3.1.
10 For the case of where you still have reactor 11 coolant pump running so you have adequate mixing, you 12 needed to have a protection of the flow limit on charging 13 system of 180 gallons per minute.
14 So we revised LCO 3.1.8 which had 15 originally been focused on a dilution event when you 16 were in a mid-loop operation. And we changed it so 17 it applies in MODEs 1, 2, 3, 4, and 5 with at least 18 one reactor coolant pump running. And so that was an 19 addition to what we normally have in the standard.
20 And then there was LCO 3.1.12 which, like 21 LCO 3.9.6, requires you to isolate your shutdown, I 22 mean, your unborated water source. And that covers 23 MODEs 4, 5, and 6.
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108 1 selection criteria that were referenced in the bases 2 for LCO 3.6.7 which was changed to Criterion 4. And 3 3.9.6 was changed to meet Criterion 3 as well Criterion 4 2.
5 Just with Travelers, they provided a list 6 which is contained in the Deviation Report, that 7 addresses all the Travelers included in the standard 8 that they chose not to adopt, all the Travelers approved 9 since the standard and whether they adopted it or not.
10 They did not adopt any of the -- what's 11 called risk informed tech spec initiatives. However, 12 they did add LCO 3.0.8 which addresses inoperability 13 of snubbers. And there's a risk component to that, 14 but it's more of a --- if you, you know, it allows you 15 to go for a period of time provided you're managing 16 the risk. That's essentially what it boils down to.
17 If you have a snubber affecting, say, one 18 division of something, or in some cases where systems 19 share piping or whatever, a snubber could potentially 20 affect more than one division. And therefore, you get 21 less time. LCO 3.0.8 addresses that.
22 And then LCO 3.0.9 does a similar thing 23 for safety related barriers. But we left this one as 24 a COL item with reviewers' notes to explain what you 25 had to do to adopt that. And that would be left to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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109 1 the COL applicant.
2 Now, one thing I'll just mention about the 3 risk assessment, I understand that the PRA that was 4 originally provided with the application has been or 5 is being redone using a different set of tools or 6 software. I'm not sure what the details are.
7 But in the beginning, we thought, well, 8 should this impact anything, you know, related to risk 9 arguments that are used in the tech specs. And we 10 decided that we could address those kinds of things 11 by making the assumption that the risk would be adequate 12 to support whatever argument that was being made. And 13 there aren't very many.
14 MEMBER STETKAR: Craig, didn't you talk 15 to your PRA branch and ---
16 MR. HARBUCK: Oh, yes.
17 MEMBER STETKAR: Okay.
18 MR. HARBUCK: Yes, yes.
19 MEMBER STETKAR: Because it --- the 20 changes are not --
21 MR. HARBUCK: I haven't caught up with him 22 lately. I've been busy.
23 MEMBER STETKAR: Well, you ought to keep 24 in touch with him. The changes are not just whether 25 I'm using an HP or a TI calculator which is the platform.
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110 1 They've made substantive changes to the risk 2 assessment.
3 MR. HARBUCK: Okay. Well, my hope is that 4 those are --
5 (Simultaneous speaking.)
6 MEMBER STETKAR: It made substantive 7 changes to the risk assessment.
8 MR. HARBUCK: Improving -- an improving 9 trend there. And that -- so we'll be -- so we're okay 10 in our assumption is what I am wanting to say. And 11 then last thing, COL action items, it's important to 12 have those clearly defined, marked and, if needed, 13 suitable guidance or reviewers' notes provided so that 14 the COL applicant can very straightforwardly know how 15 to complete them and -- and whether or not to -- if 16 it's an optional kind of an item, whether they want 17 to adopt it at all.
18 So that concludes the major issues on open 19 items that -- that I wanted to discuss with you. And 20 maybe a little bit of information about how tech specs 21 work. And so based on our review, and pending 22 completion of the considerably large number of 23 confirmatory items we have, we find that the generic 24 tech specs, the bases, are acceptable because they --
25 they meet 50.36 and 50.36(a).
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111 1 MEMBER STETKAR: Craig, it's kind of 2 interesting because for this meeting we have your SER 3 with us -- a substantial number of confirmatory items.
4 Then we have Rev. 1 of the tech specs. For -- and 5 I've been kind of trying to follow a few things. Your 6 -- your long discussion about all of the stuff on 7 auxiliary feedwater is not reflected in Rev. 1 of the 8 tech specs. So for --
9 (Simultaneous speaking.)
10 MR. HARBUCK: You're right.
11 MEMBER STETKAR: Our purposes -- yes, I 12 know.
13 MR. HARBUCK: Right.
14 MEMBER STETKAR: So for our purposes that 15 means we're going to have to take a close look at Rev.
16 2 of the tech specs, aren't we?
17 MR. HARBUCK: Yes, you will.
18 MEMBER STETKAR: Yes.
19 MR. HARBUCK: And I've been -- to do my 20 work I've been relying on a living mark-up of Rev. 1 21 that's going to eventually be Rev. 2. But it -- the 22 last update I have available was posted on the 8th of 23 November. And -- and -- so there's been a lot of things 24 happening since then.
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112 1 that eventually the ACRS, the committee, will need to 2 write a letter on the design certification. And 3 getting closure on exactly what is the final design 4 certification document that has been indeed reviewed 5 and accepted by the NRC staff in some areas is a bit 6 challenging.
7 MR. HARBUCK: Yes. Well, in this case, 8 we anticipate having Rev. 2 by -- by next month?
9 MEMBER STETKAR: Yes, but we hear time 10 schedules -- part -- part of the reason -- when I read 11 through the tech specs, I don't care about whether it's 12 10 or 12 or 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> or that kind of -- I look for 13 philosophical consistency. In -- if I look through 14 a set of systems and I understand how the systems are 15 configured, are the tech specs philosophically 16 consistent? In other words, am I applying 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 17 here? Am I being excessively -- this -- this whole 18 notion, if I have both -- I'll call them trains of 19 auxiliary feedwater out to one steam generator, I have 20 a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with a bracket -- well, that doesn't show 21 up here. So I -- I can't even think about all I hear 22 about it -- is what I can see in your SER or the draft 23 of the tech specs, which I don't have. So I can't even 24 think about that to even ask questions about.
25 MR. HARBUCK: I have the same problem.
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113 1 MEMBER STETKAR: Okay.
2 MR. HARBUCK: And -- so it's been a -- you 3 know, there's quite a volume of -- of paper, or 4 documentation of all these changes and -- and arguments 5 and -- and that's sort of is what's behind the size 6 of the SER. Once you start out deciding there's plenty 7 to describe your open items, if you have a large number 8 of them it's going to result in a lot of writing. But 9 --
10 MEMBER STETKAR: Well, but -- but the other 11 -- the other trap that people fall into is one of the 12 functions that I think the ACRS provides is that we 13 try to stay -- step back from things and take an 14 integrated look at stuff. And if you get into the 15 schedule-driven focus on an open item or a -- a question 16 about a particular condition within a particular system 17 in a particular operating mode, sometimes you'll lose 18 the bubble on this integrated perspective. And it's 19 really hard to step back from all of that without --
20 (Simultaneous speaking.)
21 MR. HARBUCK: I know if you don't have --
22 MEMBER STETKAR: That coherent document.
23 MR. HARBUCK: If you don't have the end 24 product --
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114 1 product it's hard to --
2 MR. HARBUCK: Kind of hard to know -- hard 3 to --
4 (Simultaneous speaking.)
5 MEMBER STETKAR: Hard to do that due 6 diligence. Yes.
7 MR. HARBUCK: Hard to fully grasp what the 8 -- what the overall resolution is. And I appreciate 9 that. And -- so I hope that -- I -- there's a lot of 10 things we have to confirm. We couldn't really do a 11 lot of it in the Rev. 1 version because that was put 12 out, what, last -- last March. And that's about the 13 time we were meeting with you with our 135 issues.
14 And so -- so we've got a -- you know, we've got a lot 15 of work left to do just to get the confirmatory items 16 closed. But if it -- but if -- if they -- the final 17 product matches what they have indicated in their 18 responses, then should be -- that should be fine. And 19 I think we've -- we've -- we've achieved a pretty good 20 set of tech specs, then. Does anyone else have any 21 questions?
22 CHAIRMAN BALLINGER: Any questions?
23 Against all odds, we have managed to get way behind.
24 (Laughter.)
25 CHAIRMAN BALLINGER: So we would -- I think NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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115 1 the committee would appreciate some expeditious 2 presentations. So -- thank you.
3 (Pause.)
4 MR. SCAROLAR: I am actually not known for 5 being expeditious, but I'll do my best. My name is 6 Ken Scarolar.
7 CHAIRMAN BALLINGER: Can you speed it up 8 a little bit?
9 MR. SCAROLAR: Yes, I will. Sorry.
10 (Simultaneous speaking.)
11 MEMBER STETKAR: Ron, we're going to take 12 as much time as we need. Okay? So they can present 13 what they have to present. And if -- if you have to 14 leave early, I will stay till 8:00.
15 MR. SCAROLAR: My name is Ken Scarolar.
16 I've been working on human systems interface design, 17 human factors engineering and digital INC since the 18 mid '70s, and working with KHNP and KEPCO since the 19 late '80s -- including this APR 1400 project.
20 I will overview the contents of Chapter 21 18. I intend to discuss the RAIs since the last ACRS 22 subcommittee meeting and then summarize the current 23 status of Chapter 18. Chapter 18 provides a summary 24 of the basic HSI design. It also provides a summary 25 of all the HFE program elements which govern the design NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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116 1 processes that will be executed after the design 2 certification. So there's both a mix of design in 3 Chapter 18 and design process.
4 The details -- excuse me -- there's an HFE 5 program plan that administratively governs 11 technical 6 program elements, the program plan as well as each one 7 of the program elements is part of Chapter 18. And 8 Chapter 18 references more detailed documentation --
9 go to the next page -- that describes the details of 10 the program plan, the details of the HSI design and 11 the details of each one of these HFE program elements.
12 This is what we call implementation plans.
13 For example, the details of the HFE program 14 plan include things like the resolution of human 15 engineering discrepancies. Although we have a design 16 and we have a design process, as we go through the 17 implementation of each one of these program elements, 18 we will engage licensed U.S. reactor operators, senior 19 reactor operators. We'll engage INC digital design 20 experts. We'll engage human factors engineering 21 experts. As they go through the implementation, they 22 may find issues. So the program plan says here is how 23 you document an issue and here is how you track that 24 issue through resolution.
25 The details of every program element, for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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117 1 example task analysis, are documented in separate 2 implementation plans. And there is an implementation 3 plan for each one of these program elements. The IPs 4 not only say what needs to be done, they define the 5 qualifications of the people that need to do it, they 6 define the format and content of what we call result 7 summary reports where you document the results of those 8 program elements. So the IPs are pretty extensive.
9 In things like the verification and 10 validation IP, even though we have not yet conducted 11 what we call integrated system validation, that IP does 12 define the scenarios that will be executed -- the 13 minimum scenarios. We will use -- it says that we'll 14 use a full-scope simulator, we'll use licensed U.S.
15 operators and as a minimum, these are the scenarios 16 that we will encounter during that. In addition it 17 goes on to say that if we need more scenarios to 18 encompass all of the important human actions -- such 19 as those that are defined by the PRA, those that are 20 defined by the transient and accident analysis, more 21 scenarios will be added to encompass all the important 22 human actions. So the ISV, the IPs are very 23 comprehensive.
24 MEMBER STETKAR: Ken, let me -- let me stop 25 you right there.
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118 1 MR. SCAROLAR: Sure.
2 MEMBER STETKAR: Because you don't have 3 a -- a further slide that I can see on -- on what you 4 were just talking about. And I have to be careful 5 because all of the implementation plans are -- are 6 proprietary. So I can't speak too much about details.
7 That being said, from what you -- you just mentioned, 8 there -- there is -- there are specific scenarios that 9 have been defined for the integrated verification and 10 validation process. And they're listed. And they're 11 -- there's quite an extensive description in the 12 implementation plan of those scenarios. And I don't 13 even know -- I don't even know if the number of scenarios 14 is proprietary, so I won't say the number.
15 There is also an implementation plan that 16 identifies those important human actions that you just 17 mentioned. That particular implementation plan has 18 similarly a list of specific actions. And -- and some 19 of those are so-called deterministic actions that have 20 been derived from the Chapter 15 transient and accident 21 analyses and the so-called diversity, defense in-depth 22 analysis of the protection and control systems.
23 And then there are those risk-informed 24 human actions -- the RIHAs. There's a list of those 25 in that implementation plan. That list is both NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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119 1 incomplete and inconsistent with the current version 2 of the risk assessment. So now my question is, since 3 the implementation plans are referenced in the 4 certified design, therefore they are part of the 5 certified design, how do you reconcile two parts of 6 the certified design that are inconsistent with one 7 another? Or -- or are we going to see new changes?
8 MR. SCAROLAR: The implementation plans 9 govern the execution of the program element. The very 10 important part of that is to illustrate the outcome 11 of the program element, the list of important human 12 actions that is in the IP is flagged as preliminary.
13 It's only there to illustrate the output of that 14 program element, not to define today the list of 15 important human actions. That list of important human 16 actions will be defined when KHNP actually executes 17 that program element. So this list that you see is 18 only illustrative. It is not intended by any means 19 to be the final list. The final list will be determined 20 when this particular program element is executed.
21 Now, that may be a year from now, five years 22 from now, ten years from now. The DCD doesn't define 23 that. It simply says when you do it, these are the 24 things you have to do. So yes, I agree, there may be 25 some inconsistency because the IP is an illustrative NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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120 1 example of the list. The PRA may still be evolving.
2 They're the transient and accident analysis in Chapter 3 15 may still be evolving. The list is only an example 4 to illustrate the outcome of that program element.
5 MEMBER DIMITRIJEVIC: But in the same 6 document you have -- sorry -- but what will happen --
7 the same document you're going to have it -- the Chapter 8 19 showing one list of important human actions and then 9 your chapter showing a different list. In the same 10 document, which is FSAR.
11 MR. SCAROLAR: Well, actually in Chapter 12 18 there's a list of human actions.
13 MEMBER DIMITRIJEVIC: Right.
14 MR. SCAROLAR: Whether they become 15 important human actions or not is based on the 16 extraction process that's defined for the HFE program 17 element. So in the end, that long list of human actions 18 may be pared down to important human actions based on 19 the HFE analysis. So that can happen also. Again, 20 the PRA documents risk. The human factors -- IP 21 documents process with illustrative output. It is not 22 intended to document the output.
23 MEMBER DIMITRIJEVIC: I understand that, 24 I'm just saying -- I completely understand what you're 25 saying.
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121 1 MR. SCAROLAR: Okay.
2 MEMBER DIMITRIJEVIC: And you have -- you 3 -- when you defined the program, define -- but -- what 4 is going to happen is then the same document will say 5 -- because Chapter 19 also provide list of important 6 human actions.
7 MEMBER STETKAR: What's the purpose in --
8 let me try it this way. What specifically is the 9 purpose of that list of risk-important human actions 10 in the implementation plan document? What purpose does 11 it serve?
12 MR. SCAROLAR: It serves to establish the 13 minimum set of scenarios that will be conducted during 14 integrated system validation. Because there is a 15 commitment that those scenarios encompass all those 16 human actions. It also is used to establish rigor in 17 other -- in the other program elements. For example, 18 task analysis will go deeper for the important human 19 actions than it will for other actions.
20 MEMBER STETKAR: But -- but, Ken, you 21 didn't answer my question. What's the purpose of this 22 specific list? I have a list of things here that I'm 23 not going -- it's -- I don't want to go into a situation 24 where we close this meeting. We don't have time. But 25 I have a table of a list of specific actions. They NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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122 1 -- they've got names, they've got times, they've got 2 places where I extracted them from. That list --
3 (Simultaneous speaking.)
4 MR. SCAROLAR: They're only there -- it's 5 only to illustrate the output.
6 MEMBER STETKAR: Nowhere does it say that.
7 It just says this is it.
8 MR. SCAROLAR: Well, it says preliminary.
9 MEMBER STETKAR: No, it doesn't. I'm 10 sorry, it does not. I haven't found that word anywhere 11 here.
12 MR. SCAROLAR: In the title of the list?
13 MEMBER STETKAR: Can I read the title, 14 since it's a proprietary document? Probably not.
15 That's -- up in the Appendix, it says. Not in the table.
16 MEMBER MARCH-LEUBA: And that's not 17 proprietary. You can read it.
18 (Simultaneous speaking.)
19 PARTICIPANT: Yes, it is. The whole 20 document.
21 PARTICIPANT: You probably could have done 22 a better job clarifying this point.
23 MEMBER MARCH-LEUBA: Only a bracketed --
24 MEMBER STETKAR: That's true. It does say 25 Appendix C. The problem is that that list comes only NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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123 1 from an outdated version and it -- of the PRA, and it 2 only has operator actions that are important from level 3 one, meaning core damage frequency, internal events 4 at power. The current PRA identifies many more, and 5 I can say this because they are identified in the 6 non-proprietary version of Chapter 19. Human actions 7 that contribute to large early release frequency during 8 -- or, large release frequency during power operation.
9 Human actions that contribute to fire during power 10 operation, to large release frequency from fire during 11 power operation. Core damage shut down -- during shut 12 -- core damage during shut down. Large release 13 frequency during shut down.
14 All of those are about equal contributors, 15 and they're a much larger list. So if this is supposed 16 to be an example of how people are supposed to think 17 about the process, this is a very poor example. So 18 I don't know why I have this appendix. Why do I have 19 these lists?
20 (No audible response.)
21 MEMBER STETKAR: Why do I have this list?
22 MR. SCAROLAR: As I said, it was only 23 intended to be illustrative of the output, not to 24 attempt to defend that the output is complete.
25 MEMBER STETKAR: Okay.
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124 1 MR. SCAROLAR: Even if we updated that list 2 today to reflect the current PRA --
3 MEMBER STETKAR: It would change.
4 MR. SCAROLAR: It would change.
5 MEMBER STETKAR: That's right.
6 MR. SCAROLAR: And it would still not 7 reflect things like site specifics --
8 (Simultaneous speaking.)
9 MEMBER STETKAR: That's exactly right.
10 The final list is final when you have the COL PRA.
11 MR. SCAROLAR: So I think in hindsight one 12 might argue that it was a mistake to put any list here.
13 But again, it was well intentioned to illustrate the 14 output.
15 MEMBER DIMITRIJEVIC: Why cannot you 16 reference tables which have a specific number since 17 Section 19 and its example? And then you're all set?
18 MEMBER STETKAR: I understand --
19 MR. SCAROLAR: That was not -- yes, we 20 probably could have done that. But that was not the 21 method that was selected.
22 MEMBER STETKAR: I understand what you 23 were trying to do. The problem is is that the two parts 24 of the -- the -- the certified design reports with its 25 supporting technical reports have gotten out of synch NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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125 1 with one another. And there is information in this 2 technical report compiled in a way that is useful for 3 the human factors engineering that is not immediately 4 available in the tables and tables and tables of stuff 5 in the DCD. I will -- you can -- you can figure it 6 out, but --
7 So I -- I understand kind of where you were 8 trying to get. It's just that my fear -- because of 9 the way that the existing V&V scenarios have been 10 defined -- the V&V scenarios are a -- what I'd call 11 a fairly standard set of scenarios that fortunately 12 capture all of these actions that are in this list from 13 the core damage during full power operation they --
14 those -- those V&V scenarios that you've defined don't 15 capture several of the other actions like -- as far 16 as -- for example fire-related actions. Certainly 17 actions during shutdown.
18 MR. SCAROLAR: But again, the V&V 19 scenarios were never intended to be the complete list 20 of V&V scenarios.
21 MEMBER STETKAR: Yes.
22 MR. SCAROLAR: The V&V IP says we will have 23 scenarios encompassing all the important human actions.
24 (Simultaneous speaking.)
25 MEMBER STETKAR: All the -- yes.
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126 1 MR. SCAROLAR: So if the list of IHAs 2 expands, the task analysis is going to expand, the HSA 3 design is going to expand because we handle the HSA 4 for the IHAs in a unique manner. And of course, 5 ultimately, the V&V scenarios will expand. So -
6 MEMBER STETKAR: Okay.
7 MR. SCAROLAR: There's a lot of hip bones 8 connected to the shin bones here.
9 MEMBER STETKAR: I just wanted to -- to 10 kind of probe this because it -- it -- you know, 11 obviously I am pretty heavily invested in the -- the 12 PRA side of things. And I get -- I get concerned about 13 people having lists of specific things in something 14 that then becomes a rule. And the certified design 15 is a rule. Now, this is -- admittedly it's not tier-one 16 information. It's tier-two and it's in the technical 17 report. So you can change things. But, it's here --
18 (Simultaneous speaking.)
19 MR. SCAROLAR: Okay, on this list of 20 documentation I wanted to specifically point out the 21 last two items -- the basic human system interface and 22 the style guide. I think there is a certain 23 misconception about the content of Chapter 18 being 24 only process oriented. And these two documents are 25 clearly not process oriented. These documents show NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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127 1 the what -- no, excuse me -- they show the how of the 2 HSI. Basically says this is how we're going to display 3 information inside the control room.
4 For example, the large display panel is 5 the how of how you display the information that is 6 important to the critical safety functions and the 7 critical power production functions. This is large 8 screen, spatially dedicated, continuously visible 9 information because it's the most important information 10 that the operators are going to deal with. There are 11 other parts of the HSE design that describe how we're 12 going to handle things like reactor trip initiation 13 and engineered safety features initiation. Again, 14 this is the how we're going to do things in the control 15 room.
16 The what of what we're going to do -- like, 17 what are we going to display for every critical 18 function? What is the HSI needed to complete the tasks 19 for any important human action? The what comes out 20 of the design process documentation. So there is a 21 mix of both what -- process oriented -- and how, design 22 oriented.
23 MEMBER STETKAR: There's even some what 24 in -- in your vernacular, there's even some what in 25 these documents.
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128 1 MR. SCAROLAR: Sure.
2 MEMBER STETKAR: Because you describe 3 certain types of -- again, trying to stay away from 4 proprietary stuff. You describe certain types of 5 controls and the way they're implemented, let's say.
6 MR. SCAROLAR: Right. But the what, 7 again, is really illustrative. For example, the 8 critical safety functions and the systems that support 9 those critical safety functions that are in the HSI 10 -- the basic HSI document -- are really illustrative.
11 The actual functions and the actual success paths will 12 come out of the FRAFA, the functional requirements 13 analysis and function allocation.
14 So if everything was process oriented, I 15 think we would all feel uncomfortable. So there's 16 illustrative information in the design documentation 17 as well.
18 MEMBER STETKAR: Ken, are there going to 19 be a Rev. 2 of these technical reports issued?
20 MR. SCAROLAR: Yes, I believe there will 21 -- right? We have RAIs without standing commitment 22 --
23 (Simultaneous speaking.)
24 MEMBER STETKAR: Yes, that's -- okay, I 25 just wanted to make --
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129 1 MR. SCAROLAR: So all the commitments in 2 the RAIs will ultimately become documented in these 3 IP revisions. Or the design document --
4 (Simultaneous speaking.)
5 MEMBER STETKAR: Because here, too, I've 6 learned things between Rev. 0 and Rev. 1 about both 7 how and to some extent what the changed -- that I didn't 8 necessarily expect. So being a Bayesian, I would say 9 that I might learn things between Rev. 1 and Rev. 2 10 that might not necessarily be expected. I am just 11 trying to think about, you know, the effort that --
12 that we're going to have put forth to -- to read --
13 there's 11 of them. They're -- well, 12 of them. And 14 some of them are pretty big.
15 MR. SCAROLAR: Yes.
16 MEMBER STETKAR: Okay.
17 MR. SCAROLAR: Here, let me go on to the 18 next slide. So since the last subcommittee meeting 19 there were five RAIs that were issued by the staff, 20 worked through jointly with the staff and KHNP and 21 KEPCO. And all these RAIs have now been resolved.
22 I will go through each of them to highlight the key 23 points.
24 The first one was related to the treatment 25 of important human actions. And for this one the staff NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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130 1 identified that the extraction was a snapshot. And 2 it does not necessarily reflect ongoing PRA changes 3 and then potential site-specific changes. So the IP 4 was clarified that the -- that the implementation 5 program execution would in fact encompass these 6 changes. So that's what we talked about before.
7 MEMBER STETKAR: The thing -- if you go back 8 to this slide, the reason -- I brought the previous 9 discussion up for two reasons. One is to try to get 10 it on the record. The other is, on that first checkmark 11 bullet there that says the whole list of RAHIs supports 12 the basis for the initial HSI design. That's what's 13 -- bothers me. It's -- if -- if that list in Appendix 14 C -- you've identified it as Appendix C -- supports 15 the basis for the initial HSI design, I am going to 16 have to do a lot of redesign work. Because there's 17 a bunch of other things that I need to think about.
18 I -- I would not feel comfortable designing 19 my initial HSI based on that particular list of things 20 in Appendix C because I might miss a bunch of stuff.
21 And that's -- that's really where I'm trying to come 22 from is -- is if you want to put lists of things together, 23 then put the list of everything that you can identify 24 from the PRA, which will give me a much better feeling 25 for the basis for the initial HSI design that I might NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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131 1 later refine a bit -- a bit is the key -- compared to 2 an abbreviated list that I might be faced with thinking 3 about a lot of additional design decisions.
4 MR. SCAROLAR: Yes, I understand your 5 point.
6 MEMBER STETKAR: So I don't -- we don't 7 -- I don't need to discuss anymore. I mean, that's 8 the thing that I am kind of hanging up on is --
9 (Pause.)
10 MR. SCAROLAR: Go to the next slide.
11 Okay, the next RAI pertain to the responsibility for 12 completing the analyses and design activities that are 13 defined in the IPs. And for this one we need to 14 understand that all the HFE program elements will be 15 completed after design certification. And this is a 16 prerequisite to conducting verification and 17 validation. So we added a table -- as you see on this 18 slide -- into this -- into the HFE program so that it 19 was very clear that the result summary reports are in 20 fact prerequisites for verification and validation.
21 And this was considered acceptable to the staff. Go 22 on to the next one.
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132 1 prepare. Well obviously if you only have a certain 2 number of operating procedures and the operators are 3 going through an event, they're kind of swayed to 4 diagnose the event based on the operating procedures 5 they have. Well, that was deemed to be unacceptable, 6 so we agreed to add more operating procedures so that 7 we don't sway the operator's decision making based on 8 the inventory of procedures. That was resolved to the 9 satisfaction of the staff.
10 (Simultaneous speaking.)
11 MEMBER KIRCHNER: Could you clarify that 12 -- what you just said? That befuddles me a little bit.
13 Maybe it's late in the day. Why add more procedures?
14 You impugn the existing ones and then -- well, we'll 15 give the operator more options.
16 MR. SCAROLAR: Well, let's say --
17 MEMBER KIRCHNER: That doesn't sound like 18 a rational approach to --
19 (Simultaneous speaking.)
20 MR. SCAROLAR: Well, let's say that the 21 only --
22 MEMBER KIRCHNER: Operator's under 23 duress.
24 MR. SCAROLAR: The only emergency 25 procedure we had was for a steam generator tube rupture.
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133 1 Now we have an event. The first thing the operators 2 have to try and do is diagnose the event. Well, if 3 they know they only have a steam generator tube rupture 4 procedure of this simulator --
5 MEMBER KIRCHNER: I understand that.
6 MR. SCAROLAR: That's -- that was the only 7 point.
8 MEMBER KIRCHNER: Oh, all right.
9 MR. SCAROLAR: So we added more procedures 10 so we don't guide them to the answer.
11 (Simultaneous speaking.)
12 MEMBER STETKAR: Because part of this --
13 MR. SCAROLAR: Based on the procedure 14 inventory.
15 MEMBER STETKAR: Is how -- how well do the 16 alarms and computer-based procedures work with one 17 another? In other words, can -- can the operators be 18 led astray? And -- and without having the stray path 19 available, they can't.
20 MR. SCAROLAR: Next slide. This RAI 21 pertained to the operating experience review which is 22 another one of these program elements. The original 23 OER did not discuss getting operating experience from 24 Shin Kori 3 and 4. And it didn't because KHNP felt 25 that the experience from Shin Kori 3 and 4 was already NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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134 1 reflected in the basic HSI design and already reflected 2 in the implementation plans.
3 But in hindsight it was recognized that 4 the OE criteria in NUREG 07-11, Revision 3, is different 5 than what was used for Shin Kori 3 and 4, which was 6 07-11, Revision 1. So the IP was revised to say that 7 we would revisit the OE from Shin Kori 3 and 4 using 8 the selection criteria from 07-11, Revision 3.
9 Next RAI was specifically related to task 10 analysis, but it -- it's really representative of all 11 the IPs. In this particular IP it identifies 12 explicitly that there will be site-specific assumptions 13 made so that you have a complete plant to conduct the 14 tasks analysis against. And the staff asked why do 15 you need assumptions? Why can't you use the specific 16 site information -- or, the actual site information?
17 Well, the answer is that the way the IPs are written 18 you can execute the IPs before you have a COL applicant.
19 You don't need a site. You make site-specific 20 assumptions and you execute the IP. And you can 21 actually complete the IP based on that. So you can 22 complete the IP generically.
23 Later on, when you actually have a COL 24 applicant and you have a site, the design implementation 25 IP -- which is down the list of IPs and there's an ITAAC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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135 1 for it -- requires that you go back and validate any 2 of those assumptions that you put into your previous 3 IP executions. So when you look at those assumptions 4 you can say they're valid, I don't have to do anything 5 else. Or you may look at the assumptions and say no, 6 they're not valid. They've actually changed. Based 7 on that, the design implementation IP requires that 8 you go back and reassess the impact on all the previous 9 IPs that you've executed.
10 So that's the intent. The wording was 11 revised and the staff and KHNP have reached agreement 12 on that wording. So in summary, Chapter 18 is complete 13 with no outstanding RAIs. The content, in my opinion, 14 is the right mix between design information and design 15 process. If we only had design process information, 16 very frankly, I'd not feel comfortable about Chapter 17 18.
18 But there's a good mix of design 19 information and there's a process that requires 20 qualified U.S. senior reactor operators, human factors 21 engineering experts, plant design experts as well as 22 digital design experts. And through the execution of 23 that process there's an HED process -- human engineering 24 discrepancies -- that's governed by the IPs that allows 25 these qualified personnel to identify problems and make NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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136 1 sure that those problems are tracked through 2 resolution. So Chapter 18 is complete.
3 MR. SISK: And I believe -- this is Rob 4 Sisk, Westinghouse -- I believe that would conclude 5 KHNP's presentations for today.
6 CHAIRMAN BALLINGER: Well, I am still 7 recovering from the surgery from Stetkar, but this 8 current status worries me. Because we have to write 9 a letter at some point, and the schedule is rough.
10 We went -- we went through that this morning. And if 11 there's substantial changes in Chapter 18 through Rev.
12 2, we have to look at that, right? Am I losing -- losing 13 the bubble, as Charlie would say?
14 (Pause.)
15 CHAIRMAN BALLINGER: I am looking at the 16 Chairman over there.
17 MEMBER CORRADINI: I have an opinion, but 18 I guess I'm not a human factors all --
19 MEMBER STETKAR: It isn't just human 20 factors because if you're listening to what I said on 21 the record for Chapter 16, for example --
22 (Simultaneous speaking.)
23 MEMBER CORRADINI: I was occupied in a 24 different meeting for Chapter 16. So I am sorry.
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137 1 two of the chapters that we heard about today, there 2 will be a Rev. 2 -- and Rev. 2 of the -- in this particular 3 instance supporting technical reports for the final 4 design certification document. Now, again, it's 5 dangerous to expect that there will not be any new 6 information because I have been surprised between Rev.
7 0 and Rev. 1 in some places where I didn't expect new 8 information and there was new information.
9 (Simultaneous speaking.)
10 MEMBER CORRADINI: Can I just summarize?
11 What you're telling me is similar to Chapter 19. We're 12 still in a revision mode which means --
13 (Simultaneous speaking.)
14 MEMBER STETKAR: We're not quite -- no, 15 no. This is much more stable. Don't bring Chapter 16 19 into it.
17 (Laughter.)
18 (Simultaneous speaking.)
19 MEMBER STETKAR: This is not Chapter 19.
20 MEMBER CORRADINI: But -- but if I'm --
21 but make sure -- I want to make sure I understand.
22 Maybe this is the wrong time. Shouldn't we have the 23 staff up first before we discuss this?
24 MEMBER STETKAR: We probably should.
25 MEMBER CORRADINI: Okay.
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138 1 MEMBER STETKAR: But again, Mike and --
2 and Ron, we -- I believe the ACRS is planning to write 3 a letter on the phase -- whatever this is. Four?
4 MEMBER CORRADINI: No, five.
5 MEMBER STETKAR: Five? We still have to 6 write a final, final letter on the certified design, 7 right?
8 MEMBER CORRADINI: Yes.
9 MEMBER STETKAR: At some time in the 10 future. That letter might have to capture differences 11 between Rev. 1 and Rev. 2.
12 MR. SCAROLAR: Yes, but I'd like to clarify 13 what the differences are going to be. The revisions 14 between the IPs that we have today and what will become 15 Rev. 2 are the commitments in the RAIs. These are 16 confirmatory items.
17 MEMBER STETKAR: Ten?
18 MR. SCAROLAR: Now KHNP does not intend 19 to make design process changes or design changes that 20 were not already documented in the RAI responses.
21 MEMBER STETKAR: I don't want to go into 22 proprietary information. I will tell you I -- I have 23 identified at least one, and in fact there's more than 24 one, change from Rev. 0 to Rev. 1 of the IP that had 25 substantive stuff changed that was not a result of an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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139 1 RAI. And therefore, given that experience, I have no 2 reason to believe that it might not also occur between 3 Rev. 1 and Rev. 2 when people take a look at it and 4 say, oh, we'll make this other change. People can shake 5 their heads -- and yes indeed, all the best intentions 6 -- but -- but indeed, it could occur. And -- and we 7 need to be cognizant of that.
8 MR. SISK: I just would like to say, I 9 appreciate the comment. It's something that we take 10 very much to heart as we look to what happened between 11 Rev. 0, Rev. 1. Rev. 2 that is coming forward -- the 12 intent, I am going to say -- and I think the purpose 13 and the effort being applied to Rev. 2 is -- there is 14 no change to Rev. 2 that has not been seen and approved 15 by the staff as a part of a RAI response such that the 16 changes between Rev. 1 and Rev. 2 is to incorporate 17 the changes that were identified such that the staff 18 has now identified those changes as confirmatory items.
19 And those were the only changes that are intended.
20 The only place that I guess that always 21 comes up is the Type D finding. If there are errors 22 or other things that come about unintended, our intent 23 is to minimize that to the maximum possible. But there 24 are no -- there is no intention to make any change other 25 than what the staff has reviewed. So I just want to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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140 1 go on the record with that.
2 CHAIRMAN BALLINGER: But we're on the 3 record, so that's -- that's good.
4 MEMBER CORRADINI: But I'm still not sure 5 -- I still think we should want to have the staff come 6 up and then discuss this.
7 CHAIRMAN BALLINGER: Yes.
8 MS. KENT: Good afternoon/evening. I am 9 Lauren Kent and I'm representing the HFE staff 10 performing the review of Chapter 18. We just heard 11 Mr. Scarolar talk about the responses to the RAIs that 12 we issued following the Phase 3 subcommittee. So the 13 majority of my presentation discusses those issues and 14 their -- their resolution.
15 I would like to ask the committee if you'd 16 like me to review those slides, or if we would like 17 to start with some questions? Or I could start with 18 a portion of the presentation I had prepared that 19 touched on a different issue in Chapter 7 related to 20 accident monitoring instrumentation? Any 21 preferences?
22 (Simultaneous speaking.)
23 PARTICIPANT: You should just proceed.
24 MS. KENT: Carry on. I will do so. Okay.
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141 1 RAI questions after the Phase 3 subcommittee from issues 2 that came out of that meeting. One of the issues --
3 we can go to the next slide, please -- was what KHNP 4 discussed with the completeness of the test bed. And 5 there was some discussion about procedures. And I 6 think that that was addressed as I saw here at the table.
7 So we'll go on to the next.
8 Again we asked the Applicant to provide 9 some revisions to the operating experience review 10 implementation plan. Really the intent here was to 11 make sure that relevant operating experience wasn't 12 excluded from the review when it is performed in 13 accordance with the implementation plan. And they made 14 sufficient changes to alleviate that concern. Let's 15 go to the next slide. And then we can go to the next 16 as well. Thank you.
17 When performing the task analysis and the 18 function requirements analysis and function 19 allocation, again, we discussed with the Applicant that 20 it would be prudent as well as more efficient to have 21 site-specific information that is known at the time 22 if the COL performs these activities addressed to be 23 addressed. Again, they did provide changes to the 24 implementation plans to address this issue. Next 25 slide. And next. Thank you.
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142 1 Okay, so this brings me to the treatment 2 of the risk-important human actions. So I -- I'd like 3 to start with the topic that was discussed, which is 4 the preliminary list that is in the implementation plan.
5 So I'd like to give a little bit of history and some 6 context as to how that information came to exist in 7 the DCD. And this may alleviate some concerns about 8 surprise information coming to light in subsequent 9 revision of the DCD.
10 I've been on staff for about three and a 11 half years now and KHNP was the first project that I 12 ever worked on as a technical reviewer here on staff.
13 So to say that learning has occurred between three 14 and a half years ago and now would be an understatement.
15 One of the first RAIs that I wrote when I started 16 reviewing the application was to ask why, if you've 17 submitted important human actions in Chapter 19 with 18 the DCD, why are you deferring the development of such 19 a list to the COL applicant? I had no appreciation 20 at that point for the iterations and subsequent changes 21 that would come about in the PRA and the need to 22 basically leave the implementation plan as they had 23 it, which is -- there is a table in the implementation 24 plan which will be completed by the COL in accordance 25 with that implementation plan when that activity --
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143 1 when it's time to complete that activity.
2 So I actually had issued an RAI requesting 3 that the -- the information be provided because I 4 thought that it existed. And it -- it did not. So 5 the RAI was issued to the Applicant. They provided 6 the list. Issued a second RAI requesting that they 7 then remove it, which -- they decided to retain the 8 list in the implementation plan. So we've run into 9 the problem that was discussed at the table about having 10 -- having two lists that have different sets of 11 information in addition to the fact that this is not 12 even the list that is to be ultimately developed as 13 a result of this element.
14 So the list is described as Mr. Scarolar 15 said, as preliminary information to support previous 16 design work that has been done. My understanding was 17 that that list supports the conceptual HSI design that 18 is reflected in the Korean design that is the -- the 19 conceptual design -- the foundation for this HFE design 20 that has to be developed through the process. So that 21 is how -- that is the back story on how that information 22 came to be.
23 Let's go to the next slide. Ultimately, 24 with respect to treatment of important human actions 25 we have -- now we're at a point where the implementation NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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144 1 plan says that personnel with a certain level of 2 expertise -- that expertise has been clarified in the 3 implementation plan. We'll work with the iteration 4 of the PRA that exists at the time. This activity is 5 performed to complete this activity. Next slide.
6 And next, please. We just covered that.
7 And the next. Okay. And we can move on from here.
8 Again we -- KHNP discussed in the previous 9 presentation, the -- the relationship between the 10 results of the implementation plans and -- completing 11 the activities, the implementation plans and how they 12 are inputs ultimately to the integrated system 13 validation test -- and how that has been illustrated 14 in the application to illustrate the scope of work that 15 will need to be completed. And next.
16 Okay, and finally, during the subcommittee 17 meeting there was some discussion about post-accident 18 monitoring instrumentation and the adequacy of the 19 variables selected to monitor the status of some of 20 the critical safety functions. At the time that we 21 had this subcommittee meeting for Phase Three, we were 22 participating in an audit -- that has subsequently been 23 closed -- of the accident monitoring instrumentation.
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145 1 resolved -- as well as the other -- identification of 2 other accident monitoring instrumentation variables 3 needed to monitor the safety functions. And the next 4 slide?
5 And our finding at this point is that the 6 Applicant's HFE design does conform to our NRC human 7 factors related guidance, and therefore provides 8 reasonable assurance that requirements will be 9 satisfied for providing a control room design that 10 reflects state of the art human factors principles.
11 That's the conclusion of my pared remarks. So I'd like 12 to turn it over to the Chairman. Thank you.
13 MEMBER SUNSERI: I guess I would have just 14 one question regarding this table that's there for 15 illustrative purposes that -- it was requested to be 16 out, but left in. So how confident are you that the 17 information as contained in that table won't be 18 misconstrued as plant-specific design information that 19 a future applicant might pick up on? So in other words, 20 is it clear enough in there that it's an example --
21 it's illustrative? It is not plant-specific, it's 22 there just to --
23 MS. KENT: Well here's where my confidence 24 comes from. First of all the -- the implementation 25 plan itself has a detailed set of steps that -- not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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146 1 just one person, but more than one individual that meets 2 a certain level of qualifications that are described 3 in that plan, which requires a certain specified level 4 of PRA and HRA expertise. It directs looking at 5 site-specific probabilistic risk analysis information 6 to develop a table. And the table is there. Each of 7 the headings -- it tells you what to put into the output 8 that goes into this -- to generate this table. So it 9 needs to be completed, first of all. What needs to 10 go into the table is specified and who needs to complete 11 it is also specified.
12 Those individuals have a level of 13 expertise, and my judgment, that they would know that 14 also by having this information labeled as preliminary 15 and not having -- the Applicant doesn't have any 16 guidance in the implementation to use that preliminary 17 output in the appendix. It says to go use information 18 from another source -- the period exists at that time.
19 So that's where my confidence comes from.
20 MEMBER SUNSERI: Right, and so they would 21 not be -- this team of people that would be doing the 22 real work, would not be misled by looking at this table 23 and misled in a way that something in this table now 24 would be construed as important and should be included 25 in -- in their work going forward? Which -- when it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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147 1 may in fact not be important at all?
2 MS. KENT: Well, there might be some --
3 there might be some overlap between what exists as a 4 preliminary product and what comes out as a final 5 product. But I have reasonable assurance that the 6 ultimate product will follow the -- it should follow 7 because they should be following the implementation 8 plan. And that tells you to go look at a specific set 9 of source of information. And with -- the team is 10 having a specific set of expertise I -- I am not. I 11 think that they will be able to identify that table 12 for what it is, which is preliminary information from 13 a older version of the PRA.
14 MEMBER SUNSERI: Yes, all right. Thank 15 you.
16 MEMBER CORRADINI: What you just said --
17 would such a note or warning should be there? In other 18 words, warning, this is a preliminary list. It's from 19 five years ago, ten years ago. Do not use this 20 directly. You must check A, B and C. In other words, 21 a user's guide to a preliminary list.
22 MS. KENT: I don't think it's important.
23 I mean, I --
24 MEMBER CORRADINI: Okay.
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148 1 is and the way that the process is set up and the 2 implementation plan -- the fact that it's there is not 3 very important. It's just not very important 4 information and I --
5 MEMBER STETKAR: The problem is that 6 indeed that list appears in -- and we've had 7 presentations today that identify it. One table that 8 Lauren is referring to is a Table 4-1 -- and that appears 9 in your slide, so I can say that -- in the implementation 10 plan. And Table 4-1 is just -- is just a -- a blank 11 table. It just says you need to fill in this stuff.
12 And as Lauren said, you need to go to the following 13 sources. One of the sources is the PRA and you need 14 to have the right kind of people and all that stuff.
15 Good. Fine.
16 There -- and this was also in the 17 presentations. There is this mysterious Appendix C 18 -- Charlie. It is not referred to anywhere in the text.
19 It simply appears. It's simply there.
20 MEMBER CORRADINI: What good does it do?
21 MEMBER STETKAR: And it's there as the --
22 and -- and this is not bracketed -- so it's the 23 preliminary treatment of important human action output 24 for risk-informed human actions. That's the title of 25 that appendix. And it is this table that lists a bunch NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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149 1 of scenarios, specific actions, times, and sources in 2 the PRA supporting documentation.
3 MEMBER CORRADINI: But I remembered this 4 from your previous --
5 (Simultaneous speaking.)
6 MEMBER STETKAR: And they don't want to 7 take it out is the problem. The staff in fact asked 8 them to --
9 (Simultaneous speaking.)
10 MEMBER CORRADINI: But your concern -- let 11 me make sure I understand your concern. Your concern 12 is that if left there the natural human reaction is 13 to take that as gospel and run with it.
14 MEMBER STETKAR: Right. And they've 15 already said on the KHNP slides that that table forms 16 the basis for the initial design. And that's the 17 troubling thing.
18 MEMBER CORRADINI: So then, in a letter 19 -- if we choose to write a letter, we should identify 20 that. If we feel collectively that that's important.
21 MEMBER STETKAR: I mean, my personal 22 concern is exactly somewhat of what Matt said -- is 23 that it's too easy to misconstrue this table because 24 --
25 (Simultaneous speaking.)
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150 1 MEMBER CORRADINI: The one you're speaking 2 of?
3 MEMBER STETKAR: Appendix Charlie Table.
4 MEMBER SUNSERI: And in fact they already 5 have been because Lauren wrote an RAI and she was 6 supported in it by her whole management team.
7 MEMBER STETKAR: That's right.
8 MS. KENT: Lauren is not -- does not have 9 the PRA expertise that these people completing this 10 element have --
11 (Simultaneous speaking.)
12 MEMBER CORRADINI: Common sense is 13 allowed.
14 MEMBER SUNSERI: The people on your team, 15 though, that reviewed your RAI supported it as well, 16 though. So I mean, it was a team effort, not just an 17 individual.
18 MEMBER STETKAR: I just don't -- I don't 19 know what positive purpose that table serves. I can 20 see an awful lot of potential negative applications.
21 An awful lot of pushback that says, well, the table 22 is in the certified -- you know, in a report that 23 supports the certified design and we've already based 24 our initial HSI design on these things and my God, I 25 am a COL applicant. How -- how should I be forced to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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151 1 change my design based on new things?
2 CHAIRMAN BALLINGER: There's a certain 3 amount of inertia that develops when these things start 4 going. And it's awful hard to turn around.
5 MEMBER STETKAR: Now the -- there's two 6 other appendices in this particular -- technical 7 report. And I am assuming I can quote the -- yes.
8 Those -- I am sorry. There is an Appendix B that has 9 -- it's also called preliminary treatment of important 10 human action output for deterministic important human 11 actions. Remember, the deterministic ones are the ones 12 that come out of the Chapter 15 analysis and the 13 diversity and defense in-depth analysis which -- which 14 are clearly part of the certified design.
15 And it's -- you know, there are two. There 16 are a list of specific actions, times. You know, if 17 I were a betting person -- and I don't -- I would bet 18 that there's not much chance that they will change.
19 I haven't found any discrepancies. So whether that 20 Appendix B needs to be excised or, you know, what purpose 21 it serves is questionable. But -- but it's not nearly 22 as -- it's also quite abbreviated compared to the 23 Appendix Charlie table. Anyway, we -- we've talked 24 enough about those tables.
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152 1 Office. The reason one for the IP, there's no -- the 2 description for that Appendix B and C. But during a 3 RAI response where we incorporated some of the mark-up 4 of the IP, identified that in support the IHA from the 5 -- each document will be updated actively as design 6 process including site-specific PRA. So we clearly 7 identified that -- the Table 4-1 will be generated 8 incorporating site-specific PRA.
9 And also for Appendix B is we identified 10 that is for -- will be updated correctively as a design 11 process. So as the staff said in a -- in a future one 12 is implementation plan is implemented that it -- those 13 -- those words and -- will be interpreted to the person 14 who will implement it that that is -- as a preliminary 15 information that is -- Appendix B and C is only 16 preliminary purpose. But ultimately, in order to 17 generate for Table 1 and 2 the -- the implementation 18 performer have to incorporate for site-specific PRA 19 and also the incorporated some of design process. So 20 I think from now on is it -- those two table -- the 21 statement is very -- becomes very clear.
22 MEMBER STETKAR: We'll have to -- it's like 23 -- you know, when Rev. 2 comes out we'll see what the 24 words say because right now there's no discussion of 25 those appendices.
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153 1 CHAIRMAN BALLINGER: Okay, I think we're 2 okay. I think we're all set. Unless there are other 3 questions?
4 (No audible response.)
5 CHAIRMAN BALLINGER: I think we're getting 6 the line open. And while we're getting the line open 7 are there any public -- any members of the public that 8 would like to make a comment? The public looks a little 9 vacant.
10 (No audible response.)
11 CHAIRMAN BALLINGER: Is the bridge line 12 open? I don't hear any cracking or popping or anything.
13 MR. BROWN: The bridge is open.
14 CHAIRMAN BALLINGER: I guess the bridge 15 is open.
16 MR. BROWN: The bridge is open.
17 CHAIRMAN BALLINGER: If there's anybody 18 -- any members of the public that would like to make 19 a comment out there, please identify yourself. In the 20 comment.
21 (Pause.)
22 CHAIRMAN BALLINGER: Hearing none, we'll 23 close the bridge line. And now are there any -- is 24 there any discussion around the table from members that 25 we need to address?
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154 1 MEMBER CORRADINI: I'm not sure -- I wasn't 2 here for part of the -- the afternoon. But I think, 3 at least with Chapter 4, which I was listening to, a 4 lot of my questions were answered. I guess I want to 5 bring up how you want to handle a potential letter.
6 Are you going to accumulate all of these subcommittee 7 meetings to a -- a rolled-up letter? In other words, 8 we've heard now part -- in Phase 5 we've heard a number 9 of chapters. You -- are you looking as -- as Chair 10 to write something out at this point to let staff know 11 where we sit?
12 CHAIRMAN BALLINGER: The -- I -- we had 13 a -- we had part of that discussion this morning at 14 a meeting that the most likely scenario is that we'll 15 write a letter on these chapters. And then Chapter 16 19 kind of has to be discussed.
17 MEMBER CORRADINI: Yes, but I mean -- we 18 have a number that we yet to have. We haven't heard 19 about long-term cooling. We haven't heard about the 20 LOCA -- large-break LOCA yet, even in Phase 2.
21 CHAIRMAN BALLINGER: But we're required 22 to write a letter on long-term cooling.
23 MEMBER CORRADINI: Right.
24 CHAIRMAN BALLINGER: That's a rule. And 25 so we'll definitely write a letter on that.
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155 1 MEMBER CORRADINI: But -- so your thinking 2 is to write a letter on this group of chapters, and 3 we're still going to have Chapter 15 and long-term 4 cooling to appear and talk to us?
5 MEMBER STETKAR: Let me -- let me ask this, 6 though. Because if we write a letter on what we heard 7 today -- which is the SER written against Rev. 1 that 8 still has confirmatory items to be incorporated into 9 a known Rev. 2 -- where does that put the ACRS in terms 10 of finality on the certified design? Do we then write 11 yet another letter later on?
12 MEMBER CORRADINI: If you don't have it 13 in front of you and you want to look --
14 MEMBER STETKAR: No, that -- but -- but 15 my question is, do we then write -- do we get Rev. 2 16 or not?
17 CHAIRMAN BALLINGER: Rev. 2 is scheduled 18 for February 2018. Next month.
19 (Off-microphone comment.)
20 MEMBER CORRADINI: You need your green 21 light on.
22 MEMBER STETKAR: Yes, but my point is, the 23 final -- we don't have the final DCD today.
24 MEMBER POWERS: Then you're not going to 25 write a letter on the final --
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156 1 MEMBER STETKAR: We can't write the final 2 DCD.
3 (Simultaneous speaking.)
4 MEMBER POWERS: That's right.
5 MEMBER STETKAR: And then my point is -
6 MEMBER POWERS: He's just writing a letter 7 on these chapters that says we haven't identified 8 anything that is a major roadblock. But whoa, 9 remember, eventually we have to look at the whole 10 integrated things. And knee bones do get connected 11 to thigh bones here, and there can be a difference.
12 He's not writing -- he's just saying to the staff, so 13 far we haven't found anything that --
14 MEMBER STETKAR: But I want to make sure 15 that -- that the staff is clear that any letter that 16 comes out of us in response to Rev. 1 of the DCD and 17 the SER written against that Rev. 1 is not the ACRS's 18 final letter --
19 (Simultaneous speaking.)
20 MEMBER POWERS: I think the staff is very 21 aware of that. These are interim letters. It says 22 so right up at the top of them.
23 MEMBER STETKAR: They have so far.
24 CHAIRMAN BALLINGER: And they will -- this 25 one will, too.
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157 1 MEMBER POWERS: And there's no reason for 2 that process to change. And then this was understood 3 when we agreed to do it chapter by chapter rather than 4 as an integrated whole because there's a problems that 5 knee bones are connected to the thigh bones and that 6 what you see about one part of it may look benign until 7 you find out how it interfaces with the other part.
8 MEMBER CORRADINI: The only letter -- I 9 mean, I am just harkening back to a lovely eight years 10 ago when we wrote the one on ESBWR and this -- in December 11 of '09 is when we wrote that. That was the only final 12 letter where we expected to see finality in the 13 documentation.
14 MEMBER STETKAR: Yes, but what I don't 15 remember, Mike, is we didn't have three iterations on 16 ACRS letters there, did we? We only had two.
17 MEMBER CORRADINI: You're asking a detail 18 I don't remember. I know -- I know there were --
19 particularly in digital I&C we did have some interim 20 back and forth with the staff because there wasn't 21 enough detail for functional diagrams. And I seem to 22 remember at least a couple letters on digital I&C.
23 Don't ask me what phase it was in, but I remember a 24 couple of letters. More than -- more than one, and 25 then a closed with all the open items.
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158 1 MEMBER BROWN: Which design?
2 MEMBER CORRADINI: ESBWR.
3 MEMBER BROWN: Oh -- oh, yes.
4 MEMBER SUNSERI: So has it been -- has it 5 always been the ACRS protocol to review the SER with 6 open items prior to reviewing the one with no open items?
7 MEMBER POWERS: Originally the design 8 certifications were done as an integrated whole.
9 MEMBER CORRADINI: Yes, so there was a 10 letter.
11 MEMBER POWERS: And that -- that produces 12 headaches all the way around when you do it that way.
13 There -- first of all, you -- I can remember when the 14 -- the ABWR was wheeled in and said, okay, here are 15 ACRS -- it was a cart of documents that you have to 16 review in some finite period of time. And that was 17 formidable for us. It was formidable for the staff 18 because they got it as close to final form as they 19 possibly could.
20 We went to this other system to try it out.
21 It's -- it has its pluses and it has its minuses.
22 One of the minuses that we knew immediately is, again, 23 knee bones connected to thigh bones. And so we built 24 that into the system that -- we put out these interim 25 letters mostly just to say here's a rough spot that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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159 1 you, staff, need to work out. If we haven't identified 2 any of those things, then focus on the things that --
3 all the other stuff you have to get done because we 4 -- we haven't identified any -- it doesn't mean there 5 isn't something. It just means we haven't identified 6 it yet.
7 CHAIRMAN BALLINGER: So far we've only 8 written Phase 2 letters.
9 MEMBER STETKAR: Well, but that's --
10 CHAIRMAN BALLINGER: This is really a 11 Phase 5 letter.
12 MEMBER STETKAR: Well, but what is Phase 13 5? Right.
14 CHAIRMAN BALLINGER: No open items.
15 MEMBER STETKAR: Well, but it's not the 16 ACRS. My only question is --
17 (Simultaneous speaking.)
18 MEMBER POWERS: Over and over again, how 19 many times do I have to tell you?
20 MEMBER STETKAR: You don't have to tell 21 me anymore, Dana. I'm questioning whether this 22 apparent requirement, as it's being cast, to write a 23 Phase 5 letter right now makes any sense at all. Does 24 the ACRS need to waste our time and the staff's time 25 and the Applicant's time to go through a full ACRS NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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160 1 meeting because somebody believes that we need to write 2 yet another interim letter right now? Or do we just 3 wait until the end?
4 MEMBER CORRADINI: I don't think there's 5 a requirement to write the letter.
6 MEMBER STETKAR: No, there isn't.
7 MEMBER POWERS: Right. The interim letters 8 are not required.
9 MEMBER CORRADINI: Yes.
10 MEMBER STETKAR: No, there not.
11 MEMBER CORRADINI: To the extent -- to the 12 extent that the -- if I might -- to the extent that 13 the staff has gotten good -- have taken good notes and 14 have communicate -- understand the communication of 15 what we're worried about -- and it's not a show-stopper.
16 It's rough around the edges that need to be smooth.
17 It's up to us if we want to decide to write something 18 at this point. Whether we want to document it in black 19 and white or essentially communicate it by 20 conversation.
21 CHAIRMAN BALLINGER: You see, the way I 22 would look at it -- and I have never done this before, 23 so there are people around this table who have done 24 it multiple times. And that is if it's part of our 25 review with Phase 5, we suddenly discover something NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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161 1 which is pretty major. Then we write a letter.
2 MEMBER CORRADINI: But I think -
3 CHAIRMAN BALLINGER: If we don't see 4 anything, then there's no reason to do that.
5 MEMBER CORRADINI: Right. I think that's 6 what -- that's I think where Dana was coming from.
7 MEMBER POWERS: I mean there -- there's 8 always some -- I mean the -- the interim letters have 9 been proved of some use in that it forces us to -- to 10 codify our thinking and write things down. They serve 11 as the basis of what you're going to write in the final 12 letter. Are there things to bring up there? I mean, 13 they serve some function, but if you don't want to do 14 them, you don't have to do them.
15 Here are my recommendation -- these are 16 diverse chapters. I would go ahead and write 17 something. If I were doing that --
18 (Simultaneous speaking.)
19 MEMBER CORRADINI: Particularly --
20 something in 16 or 18 that really concerns you that 21 you want to get on the record that they need to fix 22 before you see a Rev. 2. A final version of whatever 23 --
24 MEMBER POWERS: Even if there was nothing.
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162 1 -- here's what our thinking is. Does everybody agree 2 that this is our thinking? That's -- that's all I want.
3 So even if there was nothing important, I would go 4 ahead and do it just because here's a block of work.
5 You can decide how much you're going to go back to 6 it.
7 CHAIRMAN BALLINGER: I mean, I have no 8 problem writing -- writing a letter. You know, just 9 -- has to serve some purpose. And it sounds like it 10 would serve a -- would serve a purpose. What are other 11 opinions around the -- around the table here? This 12 is normally the kind of discussion we have at a full 13 committee meeting, right?
14 PARTICIPANT: No, this is fine.
15 MEMBER STETKAR: This is a subcommittee 16 meeting because we typically will poll the members to 17 see whether or not we feel that it should be before 18 the full committee. And that could or could not prompt 19 a letter. So it -- no, we typically have this 20 discussion.
21 CHAIRMAN BALLINGER: So let's ask Vesna 22 what she thinks before the drugs wear off and she 23 realizes what she's gotten herself into.
24 MEMBER STETKAR: Turn your mic on.
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163 1 good. And I got my badge. It's -- this was very 2 interesting discussion for me. My concern is if we 3 are going to write final like the -- and we identify 4 something important, that's not right. I mean, it --
5 we should identify the full -- this before we wrote 6 the final attempt. So.
7 CHAIRMAN BALLINGER: Oh, yes. That's for 8 sure.
9 MEMBER DIMITRIJEVIC: So if we have 10 something important our definition of what is important 11 -- if we have addressed concern. I mean, I don't know.
12 It depend on what the politics was before.
13 CHAIRMAN BALLINGER: What's important is 14 up to the members, right? I mean, we have some diverse 15 chapters and stuff like that where individuals have 16 different expertise. So we have to leave it up to 17 individual members to voice a concern if it's a concern.
18 I think.
19 MEMBER SKILLMAN: My thought is that the 20 -- not the concerns. The items that we raised, KHNP 21 has acted on.
22 CHAIRMAN BALLINGER: That's from Phase 2 23 to Phase -- to now. Yes, sure.
24 MEMBER SKILLMAN: Yes, so -- so I think 25 similarly as Dana, probably good policy to say these NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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164 1 are the chapters we reviewed, the items that we raised 2 in past months have been addressed. And we're -- we're 3 waiting for the next round. But this is the work that 4 we've -- that we've accomplished.
5 CHAIRMAN BALLINGER: So that's a pretty 6 straightforward letter.
7 MEMBER SKILLMAN: Bingo. So I think 8 there's value in basically creating a work log or a 9 -- our collectively communicating we've done this work 10 and this is the status. But I'm impressed at how many 11 of the items that we raised, they've really acted on.
12 They've taken them to heart. They changed 13 documentation. They changed the DCD. So I say salute.
14 Let's tell them great, thank you.
15 CHAIRMAN BALLINGER: Okay.
16 MEMBER DIMITRIJEVIC: Did -- did we 17 document those concerns in the letter?
18 CHAIRMAN BALLINGER: Earlier letters, yes.
19 MEMBER DIMITRIJEVIC: How many letters we 20 wrote on this?
21 CHAIRMAN BALLINGER: Chris, three?
22 MR. BROWN: On this topic, it's about --
23 (Simultaneous speaking.)
24 PARTICIPANT: No, not on this topic. No, 25 no. Generally. For Phase 2 -- how many Phase 2 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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165 1 letters? I forgot. Three I think?
2 MR. BROWN: It's about three. Every about 3 four or five chapters.
4 MEMBER DIMITRIJEVIC: So we wrote just 5 Phase 2 -- for example, let's choose this human factors.
6 We only wrote one letter so far. That was in Phase 7 2 and we wrote Phase 1 and Phase 2, right?
8 MEMBER CORRADINI: No, this is the second 9 time around for all the chapters. This is the -- the 10 start of the next round.
11 MEMBER DIMITRIJEVIC: So we only wrote one 12 letter so far?
13 CHAIRMAN BALLINGER: We wrote three 14 letters, but one on -- only one on these chapter.
15 MEMBER DIMITRIJEVIC: Right. On 16 different chapters. Three letters on different 17 chapters.
18 MEMBER BROWN: We can also -- if we had 19 an issue or an item that we think wasn't addressed, 20 I did have a couple of -- I can try to write something 21 up for you for if you decide to try to write a letter.
22 On the chapter -- whatever it was, 14 items.
23 CHAIRMAN BALLINGER: Much appreciated.
24 MEMBER BROWN: If and when we're going to 25 do it. Just let me know when we're going to do it.
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166 1 CHAIRMAN BALLINGER: Soon. There's a --
2 (Simultaneous speaking.)
3 MEMBER BROWN: Well, is it going to be --
4 is it going to be in the February meeting? Is it going 5 to be at the March meeting? It's kind of late for the 6 February meeting.
7 CHAIRMAN BALLINGER: Probably March.
8 Well, Chris, we'll have to go through and see what --
9 MR. BROWN: It's late for March, also.
10 We have to work on schedules. The agenda is already 11 out. We're not going to do March. Long-term cooling 12 and --
13 CHAIRMAN BALLINGER: A large-break LOCA?
14 MR. BROWN: No, PLUS7 is in March.
15 CHAIRMAN BALLINGER: That's -- yes.
16 Okay, well that's a logistics issue. A big one, but 17 --
18 MEMBER BROWN: Well, just inform me before 19 my allocator bits disappear.
20 (Laughter.)
21 CHAIRMAN BALLINGER: Anybody else? Walt 22 seemed like he was about ready to push the green button 23 --
24 (Simultaneous speaking.)
25 MEMBER KIRCHNER: Well, I was. A little NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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167 1 levity. Hossein can add another data point to the 2 letters that are on the bar charts for the history of 3 the ACRS.
4 CHAIRMAN BALLINGER: Oh, that's 5 important.
6 MEMBER KIRCHNER: So that's important as 7 well. But no, seriously, I think I agree with Dana 8 in that we should -- we reviewed this material. We 9 didn't find -- well, maybe. Maybe I shouldn't say --
10 (Laughter.)
11 MEMBER KIRCHNER: For everyone. But we 12 reviewed it. If we have a problem we should say so.
13 If we don't then we've done it and check the box and 14 it's -- I think the appropriate thing to do.
15 CHAIRMAN BALLINGER: Okay. Okay, so we 16 will just have to figure out the logistics.
17 MEMBER SKILLMAN: I'd like to say, I was 18 kind of impressed at Lauren's having raised the RAI, 19 the staff having moved on the RAI and then John points 20 out the table on which the RAI was written isn't 21 recognized anywhere else. That, to me, is a 22 substantial finding. That's one that -- it says, gee 23 whiz, something kind of fell through the cracks.
24 MEMBER CORRADINI: But I -- but if I might 25 just interject. If I heard what KHNP gave us at the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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168 1 very end, in their Revision 2 of --
2 (Simultaneous speaking.)
3 MEMBER STETKAR: That's sort of what I 4 heard, there might be more explanatory text around that 5 thing. Because right now it's just -- it's -- it's 6 just there.
7 MEMBER CORRADINI: But we have not seen 8 Revision 2 or --
9 (Simultaneous speaking.)
10 MEMBER STETKAR: But we have not seen 11 Revision 2.
12 MR. OH: I would like to explain a little 13 bit of history --
14 PARTICIPANT: And you are?
15 MR. OH: Yes, this is Andy Oh, KHNP, 16 Washington Office. We got us under the RAI from the 17 staff about -- the staff says and please remove Appendix 18 B and C. So we agree with that basically. So from 19 now on, we think it's Appendix B and C, there's no value.
20 However, because --
21 MEMBER CORRADINI: Can you say that again?
22 I guess --
23 MR. OH: Yes, for --
24 (Simultaneous speaking.)
25 MEMBER STETKAR: It's on the record.
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169 1 (Laughter.)
2 MEMBER CORRADINI: You just gave us a piece 3 of information that may have saved us a whole lot of 4 --
5 MR. OH: Appendix B and C, that is for --
6 if you see the RAI -- 18-133 is -- actually staff is 7 request for those Appendix B and C is have to be removed.
8 I think for -- I have some RAI for that. So --
9 MEMBER CORRADINI: But you've given us a 10 piece of information that we then have to check on.
11 I think that's appropriate.
12 MR. OH: Staff is in 18-133 is for Question 13 C is remove Appendix B and C from the TIHAIP. Yes, 14 but we all says it don't have much value. So however 15 that is referenced in some other RAI, so that's the 16 reason we just -- but then we also made some of 17 statement. Because those information will be provided 18 in the -- the site-specific PRA. Because the -- this 19 is only for the preliminary for -- for the table.
20 We state very clearly about that. So we 0 I think the 21 staff is also agreeing with that. From now on, because 22 that -- the answer for the RAI, from now on, there's 23 no value for the Appendix B and C. That is just for 24 the preliminary -- kind of -- as the Ken said is --
25 it is kind of, you know, example or something. So NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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170 1 that's the -- the common understanding from the staff 2 and KHNP for B and C.
3 CHAIRMAN BALLINGER: But not having them 4 solves the problem.
5 (Simultaneous speaking.)
6 MEMBER STETKAR: Speculation is 7 speculation. We have to see what they come out with 8 Rev. 2. Period. I mean it -- speculation is 9 speculation.
10 CHAIRMAN BALLINGER: Anybody else?
11 MEMBER SUNSERI: I would just say, you 12 know, words are important. And if the tables are 13 characterized as preliminary versus illustrative, then 14 preliminary connotes that this is some important piece 15 of work that is going to be built upon, not irrelevant.
16 So just be careful on how you describe that table when 17 you clarify it.
18 CHAIRMAN BALLINGER: Any more?
19 (No audible response.)
20 CHAIRMAN BALLINGER: Well, thank you very 21 much. It's been a long day, but we were warned. And 22 I was admonished. We are adjourned.
23 (Whereupon, the above-entitled matter went 24 off the record at 6:08 p.m.)
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171 1
2 3
4 5
6 7
8 9
10 11 12 13 14 15 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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NON-PROPRIETARY APR1400 DCA Chapter 4: Reactor ACRS15 SC Pre-application Meeting th Meeting (Jan.25, 2018)
KEPCO/KHNP January 24, 2018 APR1400-F-C-EC-18001-NP
NON-PROPRIETARY Contents Overview of Chapter 4 Section Overview List of Submitted Documents and Summary of RAIs List of Open Items Summary of Open Items Current Status ACRS15 SC Pre-application Meeting th Meeting (Jan.25, 2018)
Attachments:
Acronyms 1 APR1400-F-C-EC-18001-NP
NON-PROPRIETARY Overview of Chapter 4 Section Title Major Contents
- Initial Core Design Description and Permissible Changes 4.1 Summary Description
- Analytical Techniques
- Design Bases
- Description and Design Drawings 4.2 Fuel System Design
- Design Evaluation
- Testing and Inspection Plan
- Design Bases
- Description 4.3 Nuclear Design
- Analytical Methods
- Changes
- Design Bases
- Description of Thermal-Hydraulic Design of the Reactor Core
- Description of Thermal-Hydraulic Design of the Reactor Coolant ACRS15 SC Pre-application Meeting th 4.4 Thermal-Hydraulic Design System
- Evaluation
- Testing and Verification Meeting (Jan.25, 2018)
- Instrumentation Requirements
- Control Rod Drive System Structural Materials 4.5 Reactor Materials
- Reactor Internals and Core Support Materials
- Information for the Control Rod Drive System
- Evaluation of the Control Rod Drive System
- Testing and Verification of the Control Rod Drive System Functional Design of 4.6
- Information for Combined Performance of the Reactivity Control Reactivity Control System Systems
- Evaluation of Combined Performance of the Reactivity Control Systems 2 APR1400-F-C-EC-18001-NP
NON-PROPRIETARY Overview of Chapter 4 List of Submitted Documents for Chapter 4 ADAMS Document No. Title Revision Type Accession No.
APR1400-K-X-FS- APR1400 Design Control Document 1 DCD -
14002-NP Tier 2: Chapter 4 REACTOR APR1400-F-M-TR-PLUS7 Fuel Design for APR1400 1 TR ML17237A025 13001-P & NP Structural Analysis of Fuel Assemblies for APR1400-Z-M-NR-Seismic and Loss of Coolant Accident 2 TeR ML17228A787 14010-P & NP Loading Functional Design Requirements for a APR1400-F-C-NR-Core Operating Limit Supervisory System 1 TeR ML17094A132 14002-P & NP for APR1400 APR1400-F-C-TR- KCE-1 Critical Heat Flux Correlation for 0 TR ML17115A556 12002-P-A & NP-A PLUS7 Thermal Design ACRS15 SC Pre-application Meeting th APR1400-F-C-NR-Thermal Design Methodology 2 TeR ML17181A052 12001-P & NP Meeting (Jan.25, 2018)
Evaluation of Irradiation Assisted Stress APR1400-Z-M-NR-Corrosion Cracking and Void Swelling on 0 TeR ML16096A280 14017 Reactor Vessel Internals Summary of RAIs No. of Questions No. of Responses No. of OI 62 62 0
- There were 4 open items at phase 3.
3 APR1400-F-C-EC-18001-NP
NON-PROPRIETARY Overview of Chapter 4 List of Open Items No. Related RAI Topic ADAMS Accession #
RAI 5-7954 Impacts of Thermal Conductivity ML17335A069 1
(Q 11, 12, 16 & 18) Degradation ML17223B387 RAI 275-8294 (Q 4.2.5 - 7) ML17082A416 2 Fuel Assembly Structural Response RAI 425-8405 ML17080A138 (Q 4.2.9 - 14)
RAI 301-8280 3 CPC Setpoint Analysis Methodology ML17214A221 ACRS15 SC Pre-application Meeting th (Q 7.1.45)
RAI 523-8684 ML16309A074 Meeting (Jan.25, 2018) 4 Versa Vent classification and experience (Q 4.5.1.15 & 16) ML16335A465 4 APR1400-F-C-EC-18001-NP
NON-PROPRIETARY Summary of Open Items Open Item: Impacts of Thermal Conductivity Degradation Related RAIs : 5-7954 (Q 11, 12, 16, and 18)
Description of issue
- NRC Staff noted that FATES3B does not account for the effect of thermal conductivity degradation (TCD) and requested a TCD impact on fuel rod design and safety analysis.
FATES3B is used for fuel rod performance analysis and generation of interface data for safety analysis.
Resolution:
ACRS15 SC Pre-application Meeting th
- TCD penalty was conservatively determined based on the analysis of comparison to the experimental data at various burnups.
Meeting (Jan.25, 2018)
- KHNP responded that the evaluation results for the fuel rod design were satisfied with consideration of TCD.
5 APR1400-F-C-EC-18001-NP
NON-PROPRIETARY Summary of Open Items Open Item: Impacts of Thermal Conductivity Degradation Resolution (Contd):
- KHNP responded that as a result of the safety analyses with consideration of TCD, all the TCD-affected areas were satisfied.
- Topical Report and Technical Report were revised to reflect the impact of TCD.
Topical Report : PLUS7 Fuel Design for APR1400 (APR1400-F-M-TR-13001)
Technical Report : Criticality Analysis of NFR and SFR (APR1400-Z-A-NR-14011)
- TCD-affected DCD Tier 2 sections were revised to reflect the impact of TCD as ACRS15 SC Pre-application Meeting th followings.
Section 4.3.2.3.8 : Impact of Thermal Conductivity Degradation on Reactivity Meeting (Jan.25, 2018)
Coefficients Section 6.2.1 : Containment Functional Design Section 9.1.1 : Criticality Safety of New Spent Fuel Storage Section 15.0.0 : General Information for Safety Analysis Section 15.4.8 : Element Assembly Ejection Accidents Section 15.6.5 : Loss-of-Coolant Accidents 6 APR1400-F-C-EC-18001-NP
NON-PROPRIETARY Summary of Open Items Open Item: Fuel Assembly Structural Response Related RAIs : 275-8294(Q 4.2.5 - 7), 425-8405(Q 4.2.9 - 14)
Description of issue
- KHNP provided Technical Report for the PLUS7 Seismic/LOCA analysis (APR1400-Z-M-NR-14010-P, Revision 0)
The report contains PLUS7 Seismic/LOCA analysis results at EOL condition to consider NRC IN 2012-09*.
The EOL PLUS7 fuel assembly model for the analysis was developed based on BOL PLUS7 test data and BOL&EOL test data from CENPD-178-P**.
ACRS15 SC Pre-application Meeting th
- Staff requested to provide the followings:
Seismic/LOCA Analysis results for the BOL conditions Meeting (Jan.25, 2018)
Applicability of the EOL test data from CENPD-178-P Methodology used to obtain frequency of fuel assembly Justification for the critical damping ratio used for Seismic/LOCA Analysis Justification for the crush strength of grid
- IN 2012-09, Irradiation Effects on Fuel Assembly Spacer Grid Crush Strength
- CENPD-178-P, Structural Analysis of Fuel Assemblies for Seismic and Loss of Coolant Accident Loading 7 APR1400-F-C-EC-18001-NP
NON-PROPRIETARY Summary of Open Items Open Item: Fuel Assembly Structural Response Resolution:
- KHNP performed Seismic/LOCA analysis based on the new test to response the RAIs New tests for PLUS7 fuel assemblies and grids were performed using Westinghouse Columbia facility at BOL and/or EOL conditions to define the fuel assembly dynamic characteristics.
Fuel Assembly Mechanical Tests Load Deflection Test, Free Vibration Test, Pluck Impact Test, Forced Vibration Test, Fuel Assembly Flowing Water Damping Test ACRS15 SC Pre-application Meeting th Grid Crush Tests Meeting (Jan.25, 2018)
Static Compression Test, One-Sided Impact Test, Through-Grid Impact Test Fuel assembly model for the Seismic/LOCA analysis was developed.
Seismic/LOCA analysis was performed at BOL and EOL conditions.
The analysis results show that the PLUS7 fuel assembly maintains structural integrity for Seismic/LOCA events at BOL and EOL conditions.
8 APR1400-F-C-EC-18001-NP
NON-PROPRIETARY Summary of Open Items Open Item: Fuel Assembly Structural Response Resolution (Contd):
- The methodology used for the tests, model developments and analysis is based on the CENPD-178-P, Revision 1 (ML14122A087) which was approved by NRC.
- KHNP provided the followings:
Revision of the Technical Report for Seismic/LOCA analysis (APR1400-Z-M-NR-14010-P, Revision 2)
Responses for the RAIs ACRS15 SC Pre-application Meeting th Meeting (Jan.25, 2018) 9 APR1400-F-C-EC-18001-NP
NON-PROPRIETARY Summary of Open Items Open Item: CPC Setpoint Analysis Methodology Related RAIs : 301-8280 (Q 7.1.45)
Description of issue
- Provide the basis for using one-sided tolerance limit factor of 1.645 in the Technical Report APR1400-F-C-NR-14001.
- Discuss this factor is consistent with Regulatory Guide 1.105, Setpoints for Safety-Related Instrumentation, Revision 3.
Resolution:
- KHNP responded that the application of the setpoints for the CPC is inherently ACRS15 SC Pre-application Meeting th one-sided so that the value of 1.645 is the 95/95 one-sided tolerance limit factor for an infinite number of data points.
Meeting (Jan.25, 2018)
- KHNP will revise the DCD Table 1.9 -1, Table 7.1-1, Chapters 7 and 15 with exceptions to compliance with Regulatory Guide 1.105, Revision 3.
10 APR1400-F-C-EC-18001-NP
NON-PROPRIETARY Summary of Open Items Open Item: Versa Vent classification and experience Related RAIs : RAI 523-8684 (4.5.1.15 and 16)
Description of issue
- The staff did not agree that the Versa Vent is not a pressure boundary component since it replaces pressure boundary housing nut.
- KHNP was requested to provide data/operational experience that demonstrates venting works in practice.
Resolution:
ACRS15 SC Pre-application Meeting th
- KHNP provided explanation of functional differences between the Versa Vent Meeting (Jan.25, 2018) as a venting device and the housing nut as a pressure boundary component with seal weld.
- KHNP provided relevant data and operational experience.
11 APR1400-F-C-EC-18001-NP
NON-PROPRIETARY Current Status Chapter 4 is complete.
KHNP continues to monitor Chapter 4 to assure any conforming changes are addressed.
4 open items, that were identified in Phase 3, have been resolved with adequate and sufficient discussion with the staff.
Changes in Chapter 4 as reviewed and marked-up in response to ACRS15 SC Pre-application Meeting th the RAIs will be incorporated into the next revision (Rev.2) of the DCD.
Meeting (Jan.25, 2018) 12 APR1400-F-C-EC-18001-NP
NON-PROPRIETARY
Attachment:
Acronyms BOL Beginning of Life CPC Core Protection Calculator EOL End of Life DCD Design Control Document IN Information Notice KHNP Korea Hydro and Nuclear Power Co.
LOCA Loss of Coolant Accident NFR New Fuel Rack RAI Request for Additional Information ACRS15 SC Pre-application Meeting th SFR Spent Fuel Rack Meeting (Jan.25, 2018)
TCD Thermal Conductivity Degradation TeR Technical Report TR Topical Report 13 APR1400-F-C-EC-18001-NP
Presentation to the ACRS Subcommittee Korea Hydro Nuclear Power Co., Ltd (KHNP) APR1400 Design Certification Application Review Safety Evaluation with No Open Items:
Chapter 4 REACTOR January 24, 2018
Staff Review Team NRO/DSRA/SRSB Staff NRO/DEI/MCB Staff Alexandra Burja John Honcharik James Gilmer Daniel Widrevitz Carl Thurston RES/RSAB Staff Christopher Van Wert Andrew Bielen Peter Yarsky Project Managers Bill Ward - Lead Project Manager George Wunder - Chapter 4 Project Manager Additional Review Support - Consultant Nick Klymyshyn, PNNL January 24, 2018 Chapter 4: Reactor 2
Technical Topics Section 4.2 - Fuel System Design Open Item 04.02-1 (Fuel assembly mechanical design analysis)
Issue: DCD fuel system design analysis was dependent upon PLUS7 topical report APR1400-F-M-TR-13001-P, which was still under review. This open item had potential implications on DCD Sections 4.2, 4.3, and 4.4, depending on the path for resolution.
Resolution: The staff completed review of the topical report and concluded that (1) the fuel system is not damaged as a result of normal operations and AOOs, (2) fuel system damage is never so severe as to prevent control rod insertion when it is required, (3) the number of fuel rod failures is not underestimated for postulated accidents, and (4) coolability is always maintained. By ensuring that fuel and cladding integrity is maintained, the thermal design margin calculations in DCD Section 4.4 are unaffected. No nuclear design limitations or changes were necessary based on the resolution path, so DCD Section 4.3 is not impacted by this issue.
Open Item Closure: Based on the completion of the staffs review of the referenced topical report, the staff concludes that this open item is now closed.
January 24, 2018 Chapter 4: Reactor 3
Technical Topics Section 4.2 - Fuel System Design Open Item 04.02-2 (Structural analysis of fuel assemblies for seismic and loss of coolant accident loading)
Issue: The applicant needed to revise technical report APR1400-Z-M-NR-14010-P (now Revision 2) in order to address staff concerns, but was not completed in time for Phase 2 review.
Resolution: Revision 2 of the technical report was completed in July 2017. The staffs review of the information has been incorporated into the latest version of the Section 4.2 SER, and the review is summarized in the following slides.
Open Item Closure: The staff reviewed the information provided by the applicant and determined that the PLUS7 fuel assembly will meet the requirements of GDC 2 in terms of fuel assembly structural response to externally applied loads.
January 24, 2018 Chapter 4: Reactor 4
Fuel Assembly Structural Analysis Analysis of Loads
- Application is based on previously approved CE codes and methods:
- CENPD-42 was used to determine the dynamic response of the reactor vessel internals (RVI)
- CENPD-178-P, Revision 1, was used for the structural analysis of the fuel assemblies based on the RVI dynamic response
- CENPD-252-P-A was used for the analysis of blowdown loads from pipe ruptures
- Fuel assembly response characteristics were determined by testing. The tests covered:
- BOL and EOL conditions (to address IN-2012-09)
- Air, still water, and flowing water conditions
- Staff reviewed the tests and analyses and concluded that the referenced methodology was correctly followed and that the seismic damping credit was supported by the test results. Therefore, the fuel assembly loading values are acceptable.
January 24, 2018 Chapter 4: Reactor 5
Fuel Assembly Structural Analysis Determination of Strength
- Application follows the methodology of topical report CENPD-178-P, Rev 1, for the strength calculations
- One-sided drop test is used to determine one-sided grid crush strength (representing grid-to-barrel impacts).
- Through-grid long pulse test is used to determine the through-grid crush strength (representing grid-to-grid impacts).
- Acceptance criteria for fuel assembly components other than grids are based on ASME Boiler and Pressure Vessel (BPV) CodesSection III
- Acceptance criteria for grids are developed from grid crush test data
- These limits follow the staff guidance provided in SRP Section 4.2, Appendix A, and are therefore acceptable.
January 24, 2018 Chapter 4: Reactor 6
Fuel Assembly Structural Analysis Acceptance Criteria and Analysis
- APR1400-A-M-NR-14010-P, Revision 2, presents the analysis of the PLUS7 fuel assembly in the APR1400 and provides the acceptance criteria by which the PLUS7 fuel assembly is evaluated.
- The staffs review concluded that the applicant adequately demonstrated that fuel rod fragmentation would not occur as a direct result of LOCA blowdown and safe-shutdown earthquake loads and that control rod insertability is ensured.
January 24, 2018 Chapter 4: Reactor 7
Technical Topics Section 4.3 - Nuclear Design ACRS Question: Why was Shin-Kori data allowed to be used to validate MCNP to calculate shape annealing functions (SAFs) when the staff did not accept a foreign plant as a prototype plant during the Phase 3 review?
- As discussed in the Chapter 14 presentation, the staffs position on referencing foreign plants as prototype plants is that it is acceptable provided that the quality assurance (QA) program for construction and testing is consistent with the applicants approved QA program
- In this case, Shin-Kori data was being used to show that MCNP is an acceptable tool for calculating SAFs, not as a means to exempt the design from testing
- Power ascension test Verification of Core Protection Calculator Power Distribution Related Constants Test verifies SAFs
- Standard Review Plan Section 4.3 states that critical experiments and operating reactors should be used to validate codes and analysis procedures, but no guidance exists on the use of domestic vs. foreign data for core calculations
- Validation technical report went through KHNPs QA process before being submitted January 24, 2018 Chapter 4: Reactor 8
Technical Topics Section 4.3 - Nuclear Design ACRS Comment: The staff did not document the issue of load following in the SER, which could lead to confusion or problems in the future.
Resolution:
- The staff revised SER Section 4.3 to discuss the related RAI (RAI 8332, Question 04.03-4) and to explicitly state that the APR1400 is approved for baseload operation only
- The staff ensured that any references to load following throughout the DCD were removed, with the exception of a pending revision to Chapter 10 that is still being tracked as Confirmatory Item 4.3-1 January 24, 2018 Chapter 4: Reactor 9
Technical Topics Section 4.4 - Thermal-Hydraulic Design
- Chapter 7 Open Item, RAI 8280, Question 07.01-45 Issue: Single versus double-sided confidence level in setpoint methodology Resolution: Applicant provided statistical justification for key safety-related setpoints and modified DCD and technical reports to indicate exceptions to Revision 3 of RG 1.105.
Chapter 7 reviewers have approved these changes.
- COL Information Item 04.02-1 Issue: A COL Information Item is needed to develop the specific plant procedures necessary to ensure that Core Protection Calculator constants are correctly and consistently implemented.
Resolution: The applicant added a COL Information Item to accomplish this.
- ACRS Question from Phase 3 Meeting:
How is the 3 percent core bypass flow fraction in the RELAP model validated?
Resolution: The bypass fraction cannot be directly measured in the plant, but can be indirectly confirmed by calorimetric balance calculations performed during plant startup and periodically during plant operation. It is treated as an uncertainty in the RELAP model.
January 24, 2018 Chapter 4: Reactor 10
Technical Topics Section 4.5.1 - Control Rod Drive Systems Structural Materials Open Item - RAI 523-8684, Questions 04.05.01-15 and 04.05.01-16 Issue: DCD lacked sufficient information of why the Versa-Vent is not considered reactor coolant pressure boundary and also did not provide operating experience of the Versa-Vent to reduce dissolved oxygen levels.
Resolution: A response to RAI 523-8684 was provided and included:
- justification for classification of the ball and vent stem (and the housing nut if installed and welded) as pressure boundary components, and therefore the Versa-Vent is not credited as a pressure boundary component.
- operating experience of the Versa-Vent (approximately 20 years of satisfactory operation) with no history of cracking in the Versa-Vent or the CRD components.
- APR1400 CRD upper housing and vent stem are at low temperatures, 57°C (135°F),
which also minimizes the occurrence of stress corrosion cracking.
Open Item Closure: The staff reviewed the information provided by the applicant and determined that the Versa-Vent is not credited as a pressure boundary component, and the use of the Versa-Vent reduces the dissolved oxygen levels to minimize stress corrosion cracking to satisfy the SRP guidance and therefore meets the intent of GDCs 1, 14, and 26, as well as 10 CFR 50.55a.
January 24, 2018 Chapter 4: Reactor 11
NON-PROPRIETARY APR1400 DCA Chapter 14: Verification Programs ACRS15 SC Pre-application Meeting th Meeting (Jan.24, 2018)
KEPCO/KHNP January 24, 2018 APR1400-K-X-EC-18001-NP
NON-PROPRIETARY Contents Overview of Chapter 14 Section Overview List of Submitted Documents and Summary of RAIs List of Open Items Technical Topic Current Status ACRS15 SC Pre-application Meeting th Meeting (Jan.24, 2018)
Attachments:
Acronyms List of COL Items related to Open Items 1 APR1400-K-X-EC-18001-NP
NON-PROPRIETARY Overview of Chapter 14 Contents of Chapter 14 Section No. Description Remark Specific Information to be Addressed for the Initial 14.1 Plant Test Program 14.2 Initial Plant Test Program Inspection, Tests, Analyses, and Acceptance To be discussed 14.3 Criteria at future ACRS ACRS15 SC Pre-application Meeting th Meeting (Jan.24, 2018) 2 APR1400-K-X-EC-18001-NP
NON-PROPRIETARY Overview of Chapter 14 Contents of 14.2 Initial Test Program Section No.
Description (14.2.X) 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 ACRS15 SC Pre-application Meeting th 7 Conformance of Test Program with NRC Regulatory Guides 8 Use of Reactor Operating Experience in the Development of the ITP Meeting (Jan.24, 2018) 9 Trial Use of Plant Operating and Emergency Procedures 10 Initial Fuel Loading and Initial Criticality 11 Test Program Schedules 12 Test Description 13 Combined License Information 14 Reference 3 APR1400-K-X-EC-18001-NP
NON-PROPRIETARY Overview of Chapter 14 14.2.12 Test Description consists of four phases Phase Test Description No of tests No of tests No of tests (DCD Rev.0) (DCD Rev.1) (DCD Rev.2)
-To be submitted-I Pre-operational testing 135 153 154 II Fuel loading and post-core 11 10 11 hot functional test ACRS15 SC Pre-application Meeting th III Initial Criticality and low- 6 6 7 power physics testing Meeting (Jan.24, 2018)
IV Power ascension testing 26 26 27 Total 178 195 199 4 APR1400-K-X-EC-18001-NP
NON-PROPRIETARY Overview of Chapter 14 List of Submitted Documents for Chapter 14 ADAMS Document No. Title Revision Type Accession No.
APR1400-K-X-FS- APR1400 Design Control Document 0 DCD ML15006A041 14002-NP Tier 2: Chap 14 Verification Programs 1 DCD -
APR1400-K-X-IT-14001 APR1400 Design Control Document 0 DCD ML15006A039
-P & NP Tier 1 1 DCD -
Summary of RAIs (RAIs directly for Section 14.2)
ACRS15 SC Pre-application Meeting th Meeting (Jan.24, 2018)
No. of Questions No. of Responses Not Responded No. of Open Items 71 71 0 0 5 APR1400-K-X-EC-18001-NP
NON-PROPRIETARY Overview of Chapter 14 List of Open Items No. RAI No. Question Topic Resolution ADAMS No. Accession #
1 513-8663 14.02-67 Revision of the Startup Administrative Revised SAM ML17155A002 (91-7867) (14.02-08) Manual (SAM) in accordance with SRP 14.2.II.3 2 91-7867 14.02-09 Addition of two tests to DCD Table 1.9-1 for Resolved with discussion ML15240A044 conformance with RG 1.20
- Not directly related to
- Internal Vibration Monitoring System Test RG 1.20 187-8101 14.02-10
- Nuclear Steam Supply System (NSSS) ML16142A017 Integrity Monitoring System Test 3 528-8709 14.02-70 Need for Natural Circulation Test (First-of-a- Resolved with discussion ML17034A402 Kind Test)
- Performed at PVGNS Unit 1 ACRS15 SC Pre-application Meeting th 4 281-8232 14.02-54 Revision of Steam Generator Blowdown Revised ITP ML16182A590 System Test in accordance with RG 1.68 Meeting (Jan.24, 2018) 277-8227 14.02-38 ML16182A556 5 524-8697 14.02-69 Addition of Initial fuel load/Inverse Count Revised ITP ML17201Q508 Ratio Tests 6 APR1400-K-X-EC-18001-NP
NON-PROPRIETARY Overview of Chapter 14 List of Open Items No. RAI No. Question Topic Resolution ADAMS No. Accession #
6 281-8232 14.02-49 Radiation signal transmit to Emergency Revised Ch.11 & 12 ML17223B359 Response Data System 7 198-8208 14.02-21 Redundancy and independence test of Core Revised ITP ML16354B590 Protection Calculator System 8 198-8208 14.02-23 Addition of prerequisite to Fixed In-Core Resolved with discussion ML17082A454 Nuclear Signal Channel Test for clarification
- Confirmed by In-core of ICI functions and location Detector Test 9 198-8208 14.02-37 Revision of Remote Shutdown Console Test Revised other ITP ML16174A467 to verify manual controls in the MCR
- ESF Component Control System Test ACRS15 SC Pre-application Meeting th Need for integrated test of the MCR manual Resolved with discussion controls
- Confirmed by individual tests Meeting (Jan.24, 2018) 10 529-8711 14.02-71 Revision of Alternate AC Source System Revised ITP ML17006A397 Test in accordance with RG 1.68 7 APR1400-K-X-EC-18001-NP
NON-PROPRIETARY Overview of Chapter 14 List of Open Items No. RAI No. Question Topic Resolution ADAMS No. Accession #
11 283-8229 14.02-63 Identification radiation source in testing Resolved with discussion ML16279A543
- Liquid Waste Management System Test
- Related to PERMSS
- Gaseous Waste Management System test (Item No. 10) 12 283-8229 14.02-64 Test 13 281-8232 14.02-50 Use a radiation check source to verify that Resolved with discussion ML17212B046 radiation monitors are functional
- Radiation check
- Process and Effluent Radiological source will be used as Monitoring System Test part of an ITAAC
- Area Radiation Monitoring System Test 14 192-8180 14.02-15 Revision of Gaseous Waste Management Revised ITP ML18167A249 ACRS15 SC Pre-application Meeting th System Test in accordance with 10CFR50, App. I 15 Revision of Process and Effluent Revised ITP Meeting (Jan.24, 2018) 195-8182 14.02-18 ML16089A516 Radiological Monitoring System Test in accordance with 10CFR50, App. I 16 198-8208 14.02-35 Justification of the deletion of Post-Core Ex- Resolved with discussion ML17201Q513 Core Neutron Flux Monitoring System Test
- ENFMS test is conducted in pre-operational testing 8 APR1400-K-X-EC-18001-NP
NON-PROPRIETARY Technical Topic Exemption of CVAP Why is CVAP not included as part of the ITP? The design of the RCS should be verified to be identical to the prototype plant in order to exempt CVAP.
- The APR1400 is classified as a non-prototype category I plant referring Palo Verde Nuclear Generation Station (PVNGS) Unit 1 as the prototype plant.
- In accordance with the guidance of RG 1.20, the vibration measurement program can be omitted for non-prototype category I reactors if an inspection program is ACRS15 SC Pre-application Meeting th implemented.
- Since an analysis program and an inspection program are being implemented as Meeting (Jan.24, 2018) described in APR1400 DCD, Section 3.9 and the results are being assessed in those programs, implementation of a vibration measurement program is not necessary.
9 APR1400-K-X-EC-18001-NP
NON-PROPRIETARY Current Status Chapter 14.1 and 14.2 are complete KHNP continues to monitor Chapter 14.1 and 14.2 to assure any conforming changes are addressed.
16 open items, that were identified in Phase 3 have been resolved with adequate and sufficient discussion with the staff.
Changes in Chapter 14.1 and 14.2 as reviewed and marked-up in ACRS15 SC Pre-application Meeting th response to the RAIs will be incorporated into the next revision Meeting (Jan.24, 2018)
(Rev.2) of the DCD.
10 APR1400-K-X-EC-18001-NP
NON-PROPRIETARY
Attachment:
Acronyms AAC alternate alternating current ARMS area radiation monitoring system COL combined license CPCS core protection calculator system CVAP comprehensive vibration assessment program ENFMS ex-core neutron flux monitoring system ERDS emergency response data system GTG gas turbine generator GWMS gaseous waste management system HFT hot functional test ITAAC inspection, test, analyses, and acceptance criteria ACRS15 SC Pre-application Meeting th ITP initial test program Meeting (Jan.24, 2018)
IVMS internal vibration monitoring system LWMS liquid waste management system MCR main control room NIMS nuclear steam supply system integrity monitoring system NSSS nuclear steam supply system SGBS steam generator blowdown system SAM startup administrative manual PERMSS process and effluent radiation monitoring and sampling system 11 APR1400-K-X-EC-18001-NP
NON-PROPRIETARY Attachment : List of COL Item related to OIs COL Description Identifier COL 14.2(14) The COL applicant is to perform the appropriate interface testing of the gaseous PERMSS monitors with ERDS.
ACRS15 SC Pre-application Meeting th Meeting (Jan.24, 2018) 12 APR1400-K-X-EC-18001-NP
NON-PROPRIETARY Attachment : List of Changes in ITP No. Status Title 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 14.2.12.1.140 Pre-Core Pressurizer Surge Line Stratification Test 14.2.12.1.141 Location of vital equipment 14.2.12.1.142 Access to vital equipment 14.2.12.1.143 Equipment to permit observation of abnormal presence or activity of persons or vehicles 14.2.12.1.144 Vehicle barrier system to protect against the design basis threat vehicle bombs 14.2.12.1.145 Vital areas with active intrusion detection systems 14.2.12.1.146 Security alarm annunciation and video assessment information 14.2.12.1.147 Location and equipment of the central and secondary alarm stations 14.2.12.1.148 Secondary security power supply system ACRS15 SC Pre-application Meeting th 14.2.12.1.149 Intrusion detection and assessment systems 14.2.12.1.150 Equipment and emergency exits 14.2.12.1.151 Security communication systems Meeting (Jan.24, 2018) 14.2.12.1.152 Bullet-Resisting Barriers 14.2.12.1.153 Security Alarm Devices and Transmission Lines 14.2.12.1.154 Plant Communication Systems 14.2.12.2.1 Initial Fuel Loading 14.2.12.2.11 Deleted Post-Core Ex-Core Neutron Flux Monitoring System Test 14.2.12.3.1 Initial Criticality Test 14.2.12.4.22 Deleted Natural Circulation Test (First-of-a-Kind-Test) 14.2.12.4.26 Fatigue Monitoring System Test 14.2.12.4.27 Ex-core Neutron Flux Monitoring System Calibration 13 APR1400-K-X-EC-18001-NP
Presentation to the ACRS Subcommittee Korea Hydro & Nuclear Power Co., Ltd (KHNP)
APR1400 Design Certification Application Review Safety Evaluation with No Open Items:
CHAPTER 14 VERIFICATION PROGRAMS January 24, 2018
Staff Review Team
- Project Managers
- Lead Project Manager: William Ward, NRO/DNRL/LB2
- Project Manager: Cayetano Santos, NRO/DNRL/LB2
- Technical Staff
- Lead Reviewer: Ashley Ferguson, NRO/DCIP/QVIB
- Supporting Reviewers: 38 Technical Reviewers from 11 NRO Branches and 1 NRR Branch
Technical Topics
- Prototype Plants
- Comparison of APR1400 with Palo Verde Unit 1
- 14.1 Specific Information to be addressed for the Initial Plant Test Program
- 14.2 Initial Plant Test Program
Technical Topics Prototype Plants
- What is the staffs position regarding allowing foreign plants to be referenced as the prototype plant for a US design certification?
- The staff finds that referencing a foreign plant as a prototype plant is acceptable provided the applicant can demonstrate that the quality assurance (QA) program for construction and performance of the initial test program for the foreign plant is consistent with the applicants approved QA program.
Technical Topics Comparison of APR1400 with Palo Verde Unit 1
- DCD Table 1.3, Comparison of NSSS components compares the APR1400, System 80+, and SKN3&4. Where is the comparison of the Palo Verde data included in DCD Table 1.3?
- For the reactor internals comprehensive vibration assessment program (CVAP), KHNP referenced Palo Verde Unit 1 as prototype. DCD Tier 2, Table 3.9-16 lists the comparison of dimensions of major reactor internals components for APR1400 and Palo Verde, while Table 3.9-17 lists the comparison of operating conditions for reactor internals for APR1400 and Palo Verde.
Technical Topics Section 14.1 - Specific Information to be addressed for the Initial Plant Test Program
- 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.
Technical Topics Section 14.2 - Initial Plant Test Program Open Item #1 (RAI 513-8663, Question 14.02-67)
- Issue: The applicant did not address the administrative control responsibilities listed in bullet items A through D of SRP Section 14.2.II.3, Initial Test Program Administrative Procedures, for completing the Startup Administrative Manual (SAM). Additionally the applicant did not reference all of the ITP test abstracts for the preoperational, post core hot functional, low power physics, and power accession test phases in the SAM.
- Resolution: The applicant updated the SAM to include the administrative control responsibilities referenced in SRP Section 14.2.II.3 for the applicant. Additionally the applicant updated the SAM to reference all the ITP abstracts that have been incorporated into the APR1400 DCD, Revision 1, Section 14.2.
- Staff
Conclusion:
The staff determined that the proposed change provides that the SAM meets the guidance in SRP Section 14.2.II.3 for administrative controls, and includes all the test abstracts of SSCs that will be tested in the ITP per the guidance in RG 1.68, Appendix A, Section A-2, Initial Fuel Loading and Pre-Critical Tests, and Section A-3; Initial Criticality.
Technical Topics Section 14.2 - Initial Plant Test Program Open Item #2 (RAI 91-7867, Question 14.02-9 and RAI 187-8101, Question 14.02-10)
- Issue: The applicant did not reference RG 1.20 for the Internal Vibration Monitoring System (IVMS) Test (14.2.12.1.41), Loose Parts Monitoring System (LPMS) Test (14.2.12.1.42),
Acoustic Leak Monitoring System (ALMS) Test (14.2.12.1.43), Baseline Nuclear Steam Supply System (NSSS) Integrity Test (14.2.14.4.18), which contain test objectives, prerequisites, methods, and acceptance criteria related to compliance with RG 1.20.
- Resolution: The applicant stated that it will satisfy the commitment for CVAP by implementing an inspection program that provides for inspection of the reactor internals as described in APR1400 DCD, Section 3.9.
- Staff
Conclusion:
In accordance with the guidance of RG 1.20, the vibration measurement program can be omitted for non-prototype category I reactors if an inspection program is implemented. The NRC staff determined that although the IVMS, LPMS, ALMS, and Baseline NSSS Integrity tests include some vibration monitoring activities, these tests are not required to meet the guidance in RG 1.20.
Technical Topics Section 14.2 - Initial Plant Test Program Open Item #3 (RAI 528-8709, Question 14.02-70)
- Issue: The applicant did not include testing to demonstrate that 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 shutdown cooling system (SCS) inservice.
- Resolution: The applicant stated that testing to verify the design heat removal, boron mixing plant cool down/depressurization, and stable natural circulation conditions are maintained was performed at PVGNS Unit 1, which is the prototype plant for the APR1400 design. The DC applicant collected operating experience data from PVGNS Unit 1.
- Staff
Conclusion:
The staff determined that comparison of the plants reactor coolant system hydraulic data to a reference prototype plant of similar design and configuration is an acceptable means for verification of natural circulation.
Technical Topics Section 14.2 - Initial Plant Test Program Open Item #4 (RAI 277-8227, Question 14.02-38 and RAI 281-8232, Question 14.02-54)
- Issue: The applicant did not address testing of (1) the isolation features for the Steam Generator Blowdown System (SGBS), based on the presence of radioactivity and (2) thermal protection of the demineralizer beds.
- Resolution: The applicant updated the DCD to include testing of the SGBS valves used to control the temperature in the resin beds and the potential release of radioactivity.
- Staff
Conclusion:
The staff determined that testing of the automatic isolation function due to high temperature will be performed consistent with the regulatory guidance in RG 1.68, Appendix A, Section A-1.k, which states that the temperature of the SGBS should be monitored to protect resin beds from excessive temperature, which could damage them and result in an unacceptable radioactive release or contamination event.
Technical Topics Section 14.2 - Initial Plant Test Program Open Item #5 (RAI 524-8697, Question 14.02-69)
- Issue: The applicant did not include tests for initial fuel load and initial criticality to conform to the guidance in RG 1.68.
- Resolution: The applicant proposed to update the DCD to include two new tests for initial fuel loading and initial criticality. These updates to APR1400 DCD, Section 14.2 are being tracked as a confirmatory item.
- Staff
Conclusion:
The staff determined that the proposed initial fuel loading and initial criticality tests provide assurance that the facility is in a final state of readiness to achieve initial criticality.
Technical Topics Section 14.2 - Initial Plant Test Program Open Item #6 (RAI 281-8232, Question 14.02-49)
- Issue: The applicant did not specify that the containment upper operating area monitors transmit a signal via the emergency response data system (ERDS).
- Resolution: The applicant proposed to revised the DCD to specify that all radiation process and effluent monitors (gaseous and liquid), the containment air monitor, the main control room (MCR) air intake monitors, gaseous radwaste system exhaust monitor, main steam line monitors, and containment upper operating area monitors, transmit radiation signals to the ERDS. The proposed change is being tracked as a confirmatory item.
- Staff
Conclusion:
The NRC staff determined that the applicants response provided that the radiation monitoring system parameters, as required per 10 CFR Part 50, Appendix E, Section VI, will be transmitted to the ERDS.
Technical Topics Section 14.2 - Initial Plant Test Program Open Item #7 (RAI 198-8208, Question 14.02-21)
- Issue: The applicant did not include testing for redundancy and independence of the Core Protection Calculator System (CPCS).
- Resolution: The applicant proposed to revise APR1400 DCD, Subsection 14.2.12.1.138 to provide the details relating to the CPCS redundancy and independence testing. The proposed changes are being tracked as a confirmatory item.
- Staff
Conclusion:
The staff determined the proposed changes meet the guidance of RG 1.68 for the CPCS system.
Technical Topics Section 14.2 - Initial Plant Test Program Open Item #8 (RAI 198-8208, Question 14.02-23)
- Issue: The prequisites of the In-core Detector Test (APR1400 DCD Section 14.2.12.4.16) do not specify that the proper location of each in-core detector are verified.
- Resolution: The applicant clarified that after the in-core detectors are installed, there is no credible means to check the mis-positioning of the detector before the Power Ascension Test (PAT) stage. During the PAT, mis-positioning of the detector can be found by the In-core Detector Test using the neutron flux signals from the in-core detectors. Therefore, verifying the proper location of each in-core detector is not a prerequisite for the In-core Detector Test.
- Staff
Conclusion:
Based on the clarification provided and the identification of other initial tests to verify that in-core detectors are aligned, the staff finds that the verification of proper location of each in-core detector does not need to be a pre-requisite for APR1400 DCD, Subsection 14.2.12.1.26.
Technical Topics Section 14.2 - Initial Plant Test Program Open Item #9 (RAI 198-8208, Question 14.02-37)
- Issue: It was not clear to the staff which test verifies the operation of the diverse manual engineered safety features (ESF) actuation (DMA). Further, there was no integrated test of the MCR manual controls.
- Resolution: The applicant proposed to add a test objective to verify the interface of the DMA switches, for each ESF component with a DMA interface, including correct ESF component response.
Additionally, the DC applicant provided clarification as to why an integrated test of the MCR will not be performed. The proposed changed is being tracked as a confirmatory item.
- Staff
Conclusion:
The staff determined that although the DC applicant will not perform an integrated test of the MCR manual controls, the controls for each system and component are tested from MCR individually as specified in APR1400 DCD, Tier 2, Section 14.2.12. In addition, the integrated system design (i.e., hardware, software, procedure and personnel elements) is evaluated in accordance with NUREG-0711, Human Factors Verification and Validation.
Technical Topics Section 14.2 - Initial Plant Test Program Open item #10 (RAI 529-8711, Question 14.02-71)
- Issue: The DC applicant did not address how the initial test program demonstrates that the alternate ac (AAC) gas turbine generator (GTG) and its supporting systems can be started, controlled, and monitored from the remote shutdown room (RSR) to cope with an station blackout (SBO).
- Resolution: The applicant proposed to add tests for the AAC GTG and the AAC GTG support systems to APR1400 DCD, Subsection 14.2.12.1.89 and 14.2.12.1.90.
The proposed changes are being tracked as a confirmatory item.
- Staff
Conclusion:
The staff determined that this response meets 10 CFR 50, Appendix A, GDC 17 and 18, and RG 1.68, Appendix A, Section A-1.g, Item 3, Emergency or Standby AC Power Supplies, because the proposed change provides that testing will be completed to demonstrate that the AAC GTG and supporting systems can be controlled and monitored from the RSR.
Technical Topics Section 14.2 - Initial Plant Test Program Open Item #11 (RAI 283-8229, Question 14.02-63)
- Issue: The applicant did not note that the liquid waste management system (LWMS) radiation monitors are tested with a radiation check source under both the ITAAC and the ITP preoperational test; therefore, testing of the monitors should be performed and counted once under both the ITAAC and the ITP preoperational test.
- Resolution: The staff originally determined that LWMS radiation monitors should be tested with a radiation check source under both the ITAAC and the ITP preoperational test.
However, after further discussion with the applicant, the NRC staff determined that it was acceptable to use a simulated source during preoperational testing as long as the LWMS radiation monitors are tested with a radiation check source prior to fuel load.
- Staff
Conclusion:
The staff determined that since the LWMS radiation monitors are tested with a radiation check source as part of an ITAAC, it is acceptable to use a simulated source during preoperational testing.
Technical Topics Section 14.2 - Initial Plant Test Program Open Item #12 (RAI 283-8229, Question 14.02-64)
- Issue: The applicant did not note that the gaseous radwaste system (GRS) radiation monitors are tested with a radiation check source under both the ITAAC and the ITP preoperational test; therefore, testing of the monitors should be performed and counted once under both the ITAAC and the ITP preoperational test.
- Resolution: The NRC staff originally determined that GRS radiation monitors should be tested with a radiation check source under both the ITAAC and the ITP preoperational test. However, after further discussion with applicant, the NRC staff determined that it was acceptable to use a simulated source during preoperational testing as long as the GRS radiation monitors are tested with a radiation check source prior to fuel load.
- Staff
Conclusion:
The NRC staff determined that since the GRS radiation monitors are tested with a radiation check source as part of an ITAAC, it is acceptable to use a simulated source during preoperational testing.
Technical Topics Section 14.2 - Initial Plant Test Program Open Item #13 (RAI 281-8232, Question 14.02-50)
- Issue: The applicant proposed to used simulated signals to test radiation monitors instead of using a radiation check source.
- Resolution: The staff originally determined that each channel of the process and effluent radiation monitoring and sampling system (PERMSS) and area radiation monitoring system (ARMS) should be tested with a radiation check source under both the ITAAC and the ITP preoperational test; therefore, this test would be performed and counted once under both the ITAAC and the ITP preoperational test. However, after further discussion with the DC applicant, the staff determined that it was acceptable to use a simulated source during preoperational testing as long as each channel of the PERMSS and ARMS are tested with a radiation check source prior to fuel load.
- Staff
Conclusion:
The staff determined that since each channel of the PERMSS and ARMS are tested with a radiation check source as part of an ITAAC, the applicants response is acceptable.
Technical Topics Section 14.2 - Initial Plant Test Program Open Item #14 (RAI 192-8180, Question 14.02-15)
- Issue: The DC applicant did not include verification of manual and automatic response to normal control, alarms, and indications in the Gaseous Waste Management System (GWMS)
Test (DCD Subsection 14.2.12.1.105).
- Resolution: The DC applicant proposed to revise the test method and acceptance criteria for the GWMS to: (1) verify the operation of the GWMS equipment as described in APR1400 DCD, Section 11.3; (2) verify automatic valve operation upon the receipt of a low flow signal from the Gaseous Radwaste System (GRS) discharge line; (3) verify automatic valve operation upon the receipt of low-low Air Cleaning Unit (ACU) exhaust flow signal; and (4) verify automatic drain valve operation upon the receipt of low and high GRS header drain tank level.
- Staff
Conclusion:
The NRC staff determined that the proposed revisions provide for verification of manual and automatic response to normal control, alarms, and indications as it relates to monitoring and complying with the effluent concentration limits specified in Appendix I of 10 CFR Part 50.
Technical Topics Section 14.2 - Initial Plant Test Program Open Item #15 (RAI 195-8182, Question 14.02-18)
- Issue: The applicant did not test the PERMSS 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.
- Resolution: The applicant revised the DCD to expand the description in the acceptance criteria for the PERMSS to address the systems monitoring and signal generation when the radiation level detected exceeds the preset levels.
- Staff
Conclusion:
The staff determined that the proposed response provides that verification of radiation monitor and isolation valves to monitor and control effluent discharge to the environment are addressed as required by 10 CFR Part 50, Appendix I.
Technical Topics Section 14.2 - Initial Plant Test Program Open Item #16 (RAI 198-8208, Question 14.02-35)
- Issue: The staff disagreed with the applicants assessment that the Post-Core Ex-Core Neutron Flux Monitoring System (ENFMS) test (DCD Subsection 14.2.12.2.11) could be deleted because the applicant would not be verifying initial fuel loading/initial criticality testing of ENFMS neutron monitors when first loading fuel. Additionally, the applicant did not include testing for both in-core and ex-core neutron detectors, the core protection calculator system (CPCS) and any other digital I&C systems needed to support initial fuel load/initial criticality testing.
- Resolution: The applicant provided a table of how operability verification of the ex-core and in-core detector systems with actual neutron sources or by plant startup conditions after the systems pre-operational tests will be conducted. Additionally the applicant proposed to revise the DCD to incorporate the ex-core tests of safety linear power channel and control channel. The proposed change is being tracked as a Confirmatory Item.
- Staff
Conclusion:
The staff found the that the proposed provides for adequate testing of the ex-core neutron monitoring system within the power ascension tests, and conforms to RG 1.68. As such, the NRC staff determined that deleting APR1400 DCD, Subsection 14.2.12.2.11 is acceptable.
Technical Topics Section 14.2 - Initial Plant Test Program
- The staff has determined that all open items associated with Chapter 14, Sections 14.1 and 14.2, have been adequately addressed and the responses meet all applicable regulatory criteria.
- The staff concludes, using the information presented in the DCD, and pending the confirmation of the remaining confirmatory items, that the applicant has demonstrated compliance with NRC regulations and guidance.
NON-PROPRIETARY APR1400 DCA Chapter 16: Technical Specification ACRS Meeting (March 21-22 , 2017)
KEPCO/KHNP January 24, 2018 1 / 10 APR1400-K-X-EC-18002-NP
NON-PROPRIETARY Contents 1 Overview of Chapter 16 2 Major Open Items 3 Summary ACRS Meeting (March 21-22 , 2017) 2 / 10 APR1400-K-X-EC-18002-NP
NON-PROPRIETARY Overview of Chapter 16 APR1400 Technical Specifications were developed based on NUREG-1432 Rev.04(12.04), Standard Technical Specifications- CE plants Differences between APR1400 TS and STS are the unique APR1400 design features related to RCS, SIS, IRWST, AFWS, etc.
ACRS Meeting (March 21-22 , 2017)
Technical Report submitted, Deviation Report between NUREG-1432 Rev.4 and APR1400 TS, Rev01 (15.12, ML15338A328) 3 / 10 APR1400-K-X-EC-18002-NP
NON-PROPRIETARY Overview of Chapter 16 Section Overview Section Contents 1.0 USE AND APPLICATIONS 2.0 SAFETY LIMITS LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY 3.0 SUREVEILLANCE REQUIREMENT (SR) APPLICABILITY 3.1 REACTIVITY CONTROL SYSTEMS 3.2 POWER DISTRIBUTION LIMITS 3.3 INSTRUMENTATION ACRS Meeting (March 21-22 , 2017) 3.4 REACTOR COOLANT SYSTEM (RCS) 3.5 EMERGENCY CORE COOLING SYSTEM (ECCS) 3.6 CONTAINMENT SYSTEMS 3.7 PLANT SYSTEMS 3.8 ELECTRICAL POWER SYSTEMS 3.9 REFUELING OPERATIONS 4.0 DESIGN FEATURES 5.0 ADMINISTRATIVE CONTROLS 4 / 10 APR1400-K-X-EC-18002-NP
NON-PROPRIETARY Overview of Chapter 16 List of Submitted Document for Chapter 16 Document No. Title Revision Type Issued Date APR1400 Design Control APR1400-K-X-FS-Document Tier 2: Chap 16 1 DCD 2017.03 14002-NP Technical Specifications APR1400-K-X-IT-14001 APR1400 Design Control 1 DCD 2017.03
-P & NP Document Tier 1 Deviation Report between APR1400-K-O-NR-14001 NUREG -1432 Revision 4.0 Technical 1 2015.12
-NP and APR1400 Technical Report Specifications ACRS Meeting (March 21-22 , 2017)
Summary of RAIs No. of Questions No. of Responses No. of Open Items 223 223 0 5 / 10 APR1400-K-X-EC-18002-NP
NON-PROPRIETARY Summary of Major Open Items - (1/4)
Issue : Verify TSTF Travelers that are not included in APR1400 TS Resolution:
- All NRC-approved TSTF Travelers including those approved since NUREG-1432 Rev.4 were reviewed
- The TSTF Travelers list with rationale for not including, or ACRS Meeting (March 21-22 , 2017) including were reflected in the Deviation Report.
- T Status : Resolved 6 / 10 APR1400-K-X-EC-18002-NP
NON-PROPRIETARY Summary of Major Open Items - (2/4)
- 2. LCO selection criteria (RAI 154-8064)
Issue : Provided results of evaluation to apply LCO selection criteria to APR1400 design and safety analyses Resolution:
- Systematic evaluation of LCO selection criteria was completed against related DCD Chapter 5,6,7,15,19 ACRS Meeting (March 21-22 , 2017)
- Submit four tables for each LCO selection criteria
- Additional LCO included CPC auxiliary trip function, Charging flow..
Status : Resolved 7 / 10 APR1400-K-X-EC-18002-NP
NON-PROPRIETARY Summary of Major Open Items - (3/4)
Issue : Diagonally oriented safety injection trains inoperable - use two separate Condition rows Resolution:
- For clarity, statement revised
- Two trains inoperable and diagonally oriented with respect to the ACRS Meeting (March 21-22 , 2017) reactor vessel (Trains 1 and 3, or Trains 2 and 4)
Status : Resolved 8 / 10 APR1400-K-X-EC-18002-NP
NON-PROPRIETARY Summary of Major Open Items - (4/4)
- 4. AFWS (RAI 498-8595)
Issue : Improve LCO statement and modify the NOTE of TS 3.7.5 to highlight the distinguishing features of APR1400 compared to STS(NUREG-1432)
Resolution:
- Auxiliary Feedwater (AFW) System Required Actions &
ACRS Meeting (March 21-22 , 2017)
Completion Times appropriate to the APR1400 design were reflected Status : Resolved 9 / 10 APR1400-K-X-EC-18002-NP
NON-PROPRIETARY Summary AllRAIs on Chapter 16 were resolved and all responses were decided to be acceptable.
DCD Rev.2 will be published in February of 2018.
Deviation Report between NUREG-1432 Rev.4 and ACRS Meeting (March 21-22 , 2017)
APR1400 TS is being updated to match Rev.2 of DCD.
10 / 10 APR1400-K-X-EC-18002-NP
Presentation to the ACRS Subcommittee Korea Hydro Nuclear Power Co., Ltd (KHNP)
APR1400 Design Certification Application Review Safety Evaluation with No Open Items: Chapter 16 GENERIC TECHNICAL SPECIFICATIONS AND BASES JANUARY 24, 2018
- Technical Staff Presenters Craig Harbuck
- Project Managers Bill Ward - Lead Project Manager Jessica Umana - Chapter 16 Project Manager January 24, 2018 Chapter 16 Generic Technical Specifications and Bases 2
Staff Review Team Primary Reviewers Technical Specifications Branch*........................ Craig Harbuck, Bob Tjader Plant Systems Branch .................................................... Rick Scully, Hien Le
- Secondary Reviewers Containment and Ventilation Branch .......................... Nan Chien, Raj Goel,
................................................. Anne-Marie Grady, Syed Haider, Boyce Travis Mechanical Engineering Branch ............................ Tuan Le, James Strnisha Radiation Protection and Accident Consequences Branch ... Michelle Hart Reactor Systems, Nuclear Performance, and Code Review Branch ..........
.................................................. Matt Thomas, Carl Thurston, Alexandra Burja Instrumentation, Controls, and Electrical Engineering Branch .................
.................................................................. Joe Ashcraft, Ken Mott, Jack Zhao Plant Systems Branch ............................................................. Angelo Stubbs Probabilistic Risk Assessment Branch ................................... Marie Pohida Electrical Engineering Branch**............................................. Swagata Som Materials & Chemical Engineering Branch ............................... Greg Makar
- Center of expertise NRR/DSS/STSB ** Center of expertise NRR/DE/EEEB January 24, 2018 Chapter 16 Generic Technical Specifications and Bases 3
Chapter 16 Review Results (1 of 6)
- This safety evaluation chapter describes the staffs review of the GTS and Bases and the resolution of the approximately 135 open items in the following areas:
- Defined terms
- Shutdown risk mitigation
- Action requirements to raise RCS water level upon losing shutdown cooling system flow while in reduced RCS inventory condition (RV level 127 ft, 1/4 in; 3 ft below top of RV flange)
- Requirement for two operable safety injection system trains (diagonally oriented) in MODES 4 and 5; and in MODE 6 with RV level 130 ft (1/4 in below top of RV flange)
- Requirement for containment spray pump to backup the running shutdown cooling pump in MODE 5 with RCS loops not filled, and in MODE 6 while in reduced RCS inventory condition January 24, 2018 Chapter 16 Generic Technical Specifications and Bases 4
Chapter 16 Review Results (2 of 6)
- This safety evaluation chapter describes the staffs review of the GTS and Bases and the resolution of the approximately 135 open items in the following areas (continued):
- Requirements to prevent or mitigate inadvertent reactor coolant boron dilution
- Using an NRC-approved equivalent isolation method for containment penetrations that provide a direct flow path from the containment atmosphere to the outside environment, is allowed for fuel handling accident mitigation, but not for loss of shutdown cooling mitigation January 24, 2018 Chapter 16 Generic Technical Specifications and Bases 5
Chapter 16 Review Results (3 of 6)
- This safety evaluation chapter describes the staffs review of the GTS and Bases and the resolution of the approximately 135 open items in the following areas (continued):
- Control Element Assembly Calculator (CEAC) and Core Protection Calculator (CPC) Action Requirements
- Clarified correspondence between instrumentation SRs & RPS and ESFAS testing described in DCD Sections 7.2 and 7.3
- Verified that actuated components in each subgroup of each channel of ESFAS Actuation Logic have been identified (SR 3.3.6.2)
January 24, 2018 Chapter 16 Generic Technical Specifications and Bases 6
Chapter 16 Review Results (4 of 6)
- This safety evaluation chapter describes the staffs review of the GTS and Bases and the resolution of the approximately 135 open items in the following areas (continued):
- Auxiliary Feedwater (AFW) System Required Actions & Completion Times appropriate to the APR1400 design January 24, 2018 Chapter 16 Generic Technical Specifications and Bases 7
Chapter 16 Review Results (5 of 6)
- This safety evaluation chapter describes the staffs review of the GTS and Bases and the resolution of the approximately 135 open items in the following areas (continued):
- Operability, Action, and Surveillance requirements for CRHS active component actuation logic and interlocks
- AMI Functions and number of channels required for each Function
- Performing a cross train verification of operability of redundant subsystem upon loss of an AC Source - What constitutes the redundancy?
- Applicant provided list of divisions, trains, or subsystems to check for operability upon discovery of an inoperable offsite AC source or onsite AC source January 24, 2018 Chapter 16 Generic Technical Specifications and Bases 8
Chapter 16 Review Results (6 of 6)
- This safety evaluation chapter describes the staffs review of the GTS and Bases and the resolution of the approximately 135 open items in the following areas (continued):
- LCO selection criteria are met
- TSTF disposition is complete
- All COL action items are appropriate and clearly identified Pending completion of confirmatory items, staff finds that GTS and Bases meet §50.36 and §50.36a January 24, 2018 Chapter 16 Generic Technical Specifications and Bases 9
NON-PROPRIETARY APR1400 DCA Chapter 18: Human Factors Engineering ACRS15SCPre-application Meeting th Meeting (Jan.24, 2018)
KEPCO/KHNP January 24, 2018 APR1400-E-I-EC-18001-NP
NON-PROPRIETARY Contents Overview of Chapter 18 Section Overview List of Submitted Documents Summary of RAIs after Phase 3 ACRS SC Meeting List of RAIs Current Status ACRS15SCPre-application Meeting th Attachments:
Meeting (Jan.24, 2018)
Acronyms 1 APR1400-E-J-EC-18001-NP
NON-PROPRIETARY Overview of Chapter 18 Section Overview Section Title 18.1 Human Factors Engineering Program Management 18.2 Operating Experience Review Functional Requirements Analysis and Function 18.3 Allocation 18.4 Task Analysis 18.5 Staffing and Qualifications ACRS15SCPre-application Meeting th 18.6 Treatment of Important Human Actions Meeting (Jan.24, 2018) 18.7 Human-System Interface Design 18.8 Procedure Development 18.9 Training Program Development 18.10 Human Factors Verification and Validation 18.11 Design Implementation 18.12 Human Performance Monitoring 2 APR1400-E-J-EC-18001-NP
NON-PROPRIETARY Overview of Chapter 18 List of Submitted Documents for Chapter 18 ADAMS Document No. Title Revision Type Accession No.
APR1400-K-X-FS-14002-P Design Control Document TIER 2 Chapter 18, 1 DCD -
and NP Human Factors Engineering APR1400-E-I-NR-14001-P Human Factors Engineering Program Plan 1 IBR ML17094A192 and NP APR1400-E-I-NR-14002-P Operating Experience Review Implementation Plan 1 IBR ML17094A193 and NP APR1400-E-I-NR-14003-P Functional Requirements Analysis and Function 1 IBR ML17094A191 and NP Allocation Implementation Plan APR1400-E-I-NR-14004-P Task Analysis Implementation Plan 1 IBR ML17094A195 and NP APR1400-K-I-NR-14005-P ACRS15SCPre-application Meeting Staffing and Qualifications Implementation Plan 1 IBR ML17094A202 th and NP APR1400-E-I-NR-14006-P Treatment of Important Human Actions 1 IBR ML17094A200 Meeting (Jan.24, 2018) and NP Implementation Plan APR1400-E-I-NR-14007-P Human-System Interface Design Implementation 1 IBR ML17094A147 and NP Plan APR1400-E-I-NR-14008-P Human Factors Verification and Validation 1 IBR ML17094A198 and NP Implementation Plan APR1400-E-I-NR-14009-P Design Implementation 1 IBR ML17094A203 and NP APR1400-E-I-NR-14010-P Human Factors Verification and Validation Scenarios 1 TER ML17094A201 and NP APR1400-E-I-NR-14011-P Basic Human-System Interface 1 IBR ML17094A197 and NP APR1400-E-I-NR-14012-P Style Guide 1 IBR ML17094A194 and NP 3 APR1400-E-J-EC-18001-NP
NON-PROPRIETARY Summary of RAIs after Phase 3 ACRS SC Meeting List of RAIs No. Related RAI Title ADAMS Accession #
553-9084 1 Treatment of Important Human Actions ML17271A188 (Q.18-133) 553-9084 2 Procedures for ISV ML17317A397 (Q.18-135) 553-9084 3 HFE ITAAC ML17271A188 (Q.18-134) 553-9084 4 Operating Experience Review ML17271A188 (Q.18-136)
ACRS15SCPre-application Meeting th 553-9084 ML17271A188, 5 Site Specific Information (Q.18-137) ML17321A017 Meeting (Jan.24, 2018) 4 APR1400-E-J-EC-18001-NP
NON-PROPRIETARY Summary of RAIs after Phase 3 ACRS SC Meeting RAI 553-9084 Question 18-133: Treatment of Important Human Actions Description of issue
- The application does not address how the Risk Important Human Actions identified from the site-specific PRA (e.g.,
seismic PRA) are implemented in the HFE program Resolution
- The TIHA Implementation Plan (IP) has been revised to ACRS15SCPre-application Meeting th indicate the followings:
Meeting (Jan.24, 2018)
The preliminary TIHA output for RIHAs is addressed in Appendix C. The list of RIHAs supports the basis for the initial HSI design.
The IHAs from TIHA IP will be updated iteratively as the APR1400 detailed design progresses, including the site-specific PRA.
5 APR1400-E-J-EC-18001-NP
NON-PROPRIETARY Summary of RAIs after Phase 3 ACRS SC Meeting RAI 553-9084 Question 18-134: HFE ITAAC Description of issue
- The COL will need to complete the activities in the HFE IPs, but it was not clear how the COL will know it is the COLs responsibility to complete these activities Resolution
- The HF V&V IP has been revised to state the following:
ACRS15SCPre-application Meeting The APR1400 HF V&V assures th that each HFE program element Meeting (Jan.24, 2018) is conducted in accordance with corresponding IP, and the result of each HFE program element is documented in the corresponding ReSR and supports closure of the ITAAC, as illustrated in the figure below.
6 APR1400-E-J-EC-18001-NP
NON-PROPRIETARY Summary of RAIs after Phase 3 ACRS SC Meeting RAI 553-9084 Question 18-135: Procedures for ISV Description of issue
- The testbed used to conduct the ISV will only include the procedures that will be used during the ISV scenarios.
Resolution
- The HFE Program Plan and HSI Design IP have been revised to indicate the following:
The inventory of Computer-based Procedures (CBP) for ACRS15SCPre-application Meeting th the ISV scenarios includes additional procedures that are Meeting (Jan.24, 2018) related to the ISV scenarios to ensure the operator decisions are not influenced by the CBP inventory.
7 APR1400-E-J-EC-18001-NP
NON-PROPRIETARY Summary of RAIs after Phase 3 ACRS SC Meeting RAI 553-9084 Question 18-136: Operating Experience Review Description of issue
- Operating experiences (OEs) with dates before the SKN 3&4 construction are assumed to be included in the APR1400 and are not screened again Resolution
- The Operating Experience Review (OER) IP has been revised to ACRS15SCPre-application Meeting th indicate the following:
Meeting (Jan.24, 2018)
OEs that occurred before the SKN 3&4 close date will first be evaluated to determine whether they were included in the SKN 3&4 OER.
If they were included in the SKN 3&4 OER, then they may be screened out only if the lessons learned were identified and determined to be adequately addressed using the guidance in NRUEG-0711, Revision 3.
8 APR1400-E-J-EC-18001-NP
NON-PROPRIETARY Summary of RAIs after Phase 3 ACRS SC Meeting RAI 553-9084 Question 18-137: Site Specific Information Description of issue
- Why it is necessary to use generic assumptions for site-specific information when the COL applicant will perform the activities in the HFE implementation plans.
Resolution
- The Task Analysis IP has been revised to indicate the following:
The TA is based on generic assumptions that are made to ACRS15SCPre-application Meeting th establish a plant design that is reflected in the initial Meeting (Jan.24, 2018)
APR1400 HSI design. As site specific information is known, the generic assumptions are modified.
When the COL applicant performs the HFE activities, the site specific information that is applicable to develop the APR1400 HSI design at the site is updated accordingly.
9 APR1400-E-J-EC-18001-NP
NON-PROPRIETARY Current Status Chapter 18 is complete.
KHNP continues to monitor Chapter 18 to assure any conforming changes are addressed.
Five RAIs after Phase 3 ACRS SC Meeting have been resolved with adequate and sufficient discussion with the staff.
Changes in Chapter 18 as reviewed and marked-up in ACRS15SCPre-application Meeting th response to the RAIs will be incorporated into the next Meeting (Jan.24, 2018) revision (Rev.2) of the DCD.
10 APR1400-E-J-EC-18001-NP
NON-PROPRIETARY
Attachment:
Acronyms COL combined license COLA COL applicant DAC design acceptance criteria DI design implementation FRA/FA functional requirements analysis and function allocation HF human factors HFE human factors engineering HFEPP human factors engineering program plan HSI human system interface ITAAC inspections, tests, analyses, and acceptance criteria ISV integrated system validation ACRS15SCPre-application Meeting th TIHA treatment of important human actions Meeting (Jan.24, 2018)
V&V verification and validation 11 APR1400-E-J-EC-18001-NP
Presentation to the ACRS Subcommittee Korea Hydro & Nuclear Power Co., Ltd (KHNP)
APR1400 Design Certification Application Review Safety Evaluation with No Open Items:
Chapter 18 HUMAN FACTORS ENGINEERING January 24-25, 2018
Staff Review Team
- Technical Staff Lauren Kent and Brian Green - HOIB Former HOIB staff John OHara and Jim Higgins - Brookhaven National Laboratory
- Project Managers Bill Ward - Lead Project Manager Cayetano Santos - Chapter 18 Project Manager 2
Issues Addressed with the Applicant in Phase 4 RAI 9084, Questions18-133, -134, -135, -136, -137
- Completeness of ISV testbed
- Scope of OER
- Use of generic assumptions instead of site-specific information
- Treatment of RIHAs
- AMI Variables 3
Completeness of ISV Testbed RAI 9084, Question 18-135 Issue: NUREG-0711 says the ISV testbed (i.e., the control room simulator) should represent completely the integrated system.
Although the V&V IP conforms to the guidance, other portions of the application did not because they indicated that only the procedures used during ISV scenarios will be available.
Resolution: The applicant revised the portions of the application that were not consistent with the V&V IP.
Staff
Conclusion:
The other portions of the application will be consistent with the V&V IP, which conforms to regulatory guidance for testbed interface completeness.
4
Scope of OER RAI 9084, Question 18-136 Issue: The OER IP said the OER starts with the OER conducted for SKN 3&4. Events that occurred before the SKN 3&4 close date will be assumed to have been included in the SKN 3&4 OER. However, there was insufficient basis to conclude the SKN 3&4 OER conformed to guidance for OER in NUREG-0711 and to assume lessons learned from relevant and significant industry events have been addressed in the design.
5
Scope of OER (continued)
Resolution: The applicant revised the OER IP to say events that occurred before the SKN 3&4 close date will first be evaluated to determine whether they were included in the SKN 3&4 OER. If they were included in the SKN 3&4 OER, then they may be considered resolved only if the lessons learned were identified and determined to be adequately addressed.
Staff
Conclusion:
The revisions help ensure lessons learned from relevant and significant OE are evaluated and considered in the design.
6
Use of Generic Assumptions RAI 9084, Question 18-137 Issue: The FRA FA IP and the TA IP said generic assumptions for site-specific plant systems will be made during FRA, FA and TA, and changes will be made during design implementation, which occurs before fuel load, to address site-specific information.
However, when a COL performs the activities described in the IPs, site-specific information will be available.
7
Use of Generic Assumptions (continued)
Resolution: The applicant revised the application to say that when the COL performs the HFE activities, the site-specific information will be used.
Staff
Conclusion:
The revisions help to ensure that FRA, FA and TA is performed using current design information.
8
Treatment of RIHAs RAI 9084, Question 18-133 Issue 1/3: The TIHA IP said the list of RIHAs that will be included in the HFE design program activities will be developed using the PRA developed for the generic APR1400 DCD instead of the site-specific PRA.
However, when a COL performs the activities described in the TIHA IP, site-specific information will be available.
9
Treatment of RIHAs (continued)
Resolution: The applicant revised the TIHA IP to say the list of IHAs will be updated iteratively as the design progresses. To correctly identify the RIHAs and assumptions about performance of these actions from the PRA/HRA, the HFE design team will coordinate with the personnel who have been involved in the development of the site-specific PRA to complete Table 4-1 of the TIHA IP (i.e., the list of important human actions that will be included in the HFE design program activities).
Staff
Conclusion:
The revisions help ensure the COL uses current sources of information to identify the IHAs that will be addressed in the HFE design process.
10
Treatment of RIHAs (continued)
Issue 2/3: NUREG-0711 says the HFE design should pay special attention to those plant scenarios, risk-important HAs, and HSIs that the PRA/HRA highlights as vital to plant safety and reliability. As such, personnel familiar with the PRA/HRA should be involved in developing the list of RIHAs that will be included in the HFE design program activities.
Although the TIHA IP said personnel with PRA knowledge will help develop the list of RIHAs, other portions of the DCD said that personnel with PRA knowledge were not needed for this activity.
11
Treatment of RIHAs (continued)
Resolution: The applicant revised the DCD to be consistent with the TIHA IP. Also, the applicant added detail to the TIHA IP to explain how PRA expertise will be used to compile the list of RIHAs that will be included in the HFE design program activities.
Staff
Conclusion:
The changes help to ensure that Table 4-1, which provides input to the other HFE elements in the HFE design program, will be completed by personnel with sufficient expertise to reliably and correctly identify the RIHAs and their associated HFE characteristics.
12
Treatment of RIHAs (continued)
Issue 3/3: The PRA evolves over time and becomes more refined. For example, COLs need to quantify seismic risk prior to fuel load. It was not clear how any IHAs identified from subsequent revisions to the PRA will be addressed in the HFE program.
Resolution: The applicants response explained that IHAs identified after V&V may be evaluated during design implementation, and IHAs identified after design implementation will be addressed by the COLs corrective action program.
13
Treatment of RIHAs (continued)
Staff
Conclusion:
The HFE program elements, except for human performance monitoring, must be complete to close HFE-related ITAAC. All ITAAC must be closed prior to fuel load.
Subsequent revisions to the PRA may occur after the HFE-related ITAAC are closed.
Human performance monitoring continues for the life of the plant by implementation of operational programs including the operator training program and the corrective action program.
Such programs provide a means for identifying new operator tasks, updating training programs and procedures, and making design changes.
14
COL Activities RAI 9084, Question 18-134 (Addressed in SER Chapter 14)
Issue: The COL will need to complete the activities in the HFE IPs, but it was not clear how the COL will know it is the COLs responsibility to complete these activities.
Resolution: A design ITAAC verifies successful completion of the ISV in accordance with the V&V IP. The HFE PMP contains a figure that illustrates that the results from the other HFE elements are inputs to V&V. The applicant also added the figure to the V&V IP. Also, COL Item 14.3(2) says the COL is to provide a schedule for implementing the design ITAAC.
Staff
Conclusions:
The application illustrates the activities that need to be done to close the design ITAAC. 15
AMI Variables RAI 7878, Question 07.05-1 (Addressed in SER Chapter 7)
Issue: Some variables used to monitor CSFs were not identified.
For example, indication of hydrogen concentration was not identified as a means of assessing the combustible gas control CSF.
Resolution: The applicant revised the list of AMI variables to include hydrogen and other AMI variables needed to monitor the CSFs.
Staff
Conclusions:
The AMI conforms to regulatory guidance and requirements for AMI.
16
Staff Finding The applicants HFE design process conforms to NRC HFE-related guidance and therefore provides reasonable assurance that HFE-related NRC requirements will be satisfied.
17