ML18257A310

LLC Submittal of NRC Request to Provide Information on the Final Safety Analysis Report Section 14.2, Initial Plant Test Program

ML18257A310
Person / Time
Site:	NuScale
Issue date:	09/14/2018
From:	Rad Z NuScale
To:	Document Control Desk, Office of New Reactors
References
LO-0918-61791
Download: ML18257A310 (49)

Text

LO-0918-61791 September 14, 2018 Docket No.52-048 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738

SUBJECT:

NuScale Power, LLC Submittal of NRC Request to Provide Information on the Final Safety Analysis Report Section 14.2, Initial Plant Test Program During an August 30, 2018, public teleconference between the NRC and NuScale Power, LLC (NuScale), NRC requested that NuScale provide, in writing, NuScales expectations of the scope of the NRC staff review of FSAR Section 14.2, Intial Plant Test Program, and that NuScale outline those parts of Section 14.2 that would be reviewed under that scope.

The purpose of this letter is to respond to the above requested information in Enclosure 1.

This letter makes no regulatory commitments and no revisions to any existing regulatory commitments.

If you have any questions, please contact Carrie Fosaaen at 541-360-0677 or at cfosaaen@nuscalepower.com.

Sincerely, Zackary W. Rad Director, Regulatory Affairs NuScale Power, LLC Distribution: Samuel Lee, NRC, OWFN-8G9A Gregory Cranston, NRC, OWFN-8G9A Omid Tabatabai, NRC, OWFN-8G9A

Enclosure:

NuScale Final Safety Analysis Report Section 14.2, Initial Plant Test Program Scope Outline NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com

LO-0918-61791

Enclosure:

NuScale Final Safety Analysis Report, Tier 2, Section 14.2, Initial Plant Test Program Scope Outline NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com

CONTENTS 1.0 Introduction - Requested Review of NuScale FSAR Section 14.2, Initial Plant Test Program.......................................................................................................... 2 2.0 Overview of Preoperational and Startup Testing ......................................................... 6 3.0 Organization of Preoperational and Startup Testing ................................................... 7 4.0 RG 1.68 Rev 4 Component Testing Guidance .............................................................. 8 5.0 NuScale D-RAP System Functions: Use in Initial Test Program Testing ................. 10 5.1 NuScale Initial Test Program Testing of NuScale Systems Containing A1, A2 and B1 System Functions .............................................................................. 10 5.2 Testable A1 System Functions ............................................................................ 11 5.3 NuScale Testable A1 System Functions .............................................................. 13 5.4 NuScale Testable A2 Testable System Functions ............................................... 15 5.5 NuScale Testable B1 Testable System Functions ............................................... 15 6.0 Type of RG 1.68 Rev 4 Testing Not Applicable to NuScale Design ........................... 17 7.0 First-of-a-Kind Tests ..................................................................................................... 18 8.0 NuScale Control Systems ............................................................................................ 19 8.1 NuScale Control System Testing ......................................................................... 19 8.2 NuScale Control System Testing/Field Testing Overlap ...................................... 20 9.0 NuScale Test Abstract Attributes ................................................................................. 21 9.1 Scope of Testing for Preoperational Tests ........................................................... 21 9.2 NuScale Test Abstract Prerequisites ................................................................... 21 9.3 Impact of Digital Control Systems versus Analog Control Systems on the NuScale Initial Test Program ............................................................................... 22 10.0 RG 1.68 Test Program Guidance.................................................................................. 24 11.0 COL Items related to the NuScale Initial Test Program ............................................. 25 Appendix A. ............................................................................................................................... 26 Appendix B. ............................................................................................................................... 33 TABLES Table 1-1 NRC Risk-Significant Review of NuScale Preoperational Tests and Startup Tests ...................................................................................................................... 3 Table 4-1 RG 1.68 List of Components that Require a Generic Component Test ................. 9 Table 5-1 NuScale Testable A1 System Functions .............................................................. 13 Table 5-2 NuScale Testable A2 System Functions .............................................................. 15 Table 5-3 NuScale Testable B1 System Functions.............................................................. 16 Table 10-1 Adherence to RG 1.68 Program Guidance ......................................................... 24 Table A-1 NuScale Initial Test Program Tests ......................................................................26 Table B-1 RG 1.68 Rev 4 Preoperational Testing Guidance versus NuScale PreoperationalTests .............................................................................................33 Page 1 of 47

1.0 Introduction - Requested Review of NuScale FSAR Section 14.2, Initial Plant Test Program On August 30, 2018, the NRC requested that NuScale Power, LLC restate, in writing, NuScales expectations of the scope of the NRC staff review of Section 14.2, Initial Plant Test Program. NuScales requested review scope was previously described in the August 1, 2018, presentation on Risk-Informed Review of the NuScale Initial Test Program (ML18213A157), and is reiterated herein.

NuScales requested review scope is that NRC staff focus the FSAR Section 14.2 review on initial test program (ITP) abstracts for safety-related (SR) and risk-significant SSCs (A1 - safety-related, risk-significant; A2 - safety-related, not risk-significant; and B1 -

nonsafety-related, risk-significant) in accordance with the guidance in NUREG-0800, Introduction Part 2, and DSRS Section 14.2 for DCA scope. Additionally, NuScale requests that the NRC staffs FSAR Section 14.2 review scope include test abstracts pertaining to ITAAC and first-of-a-kind (FOAK) design features. The reasons for including this review scope are: 1) some ITAAC require verification of design features of non-risk significant components through preoperational testing of the design; 2) FOAK tests verify design features that are new and unique and have not been tested previously; and 3) the need to achieve finality of these test abstracts at the DCA stage.

Review of the remaining B2 (NSR, non-risk significant) test abstracts would be out of scope of the DC and COL FSAR Section 14.2 review. The NRC would reach reasonable assurance for those based on the following:

• DCA review of test abstracts and the DCA/COLA review of administrative requirements provide sufficient review of the ITP.

• Review of programmatic aspects at COL stage does not impact the scope of test abstracts by risk-informing them.

• Programmatic requirements, including the COL holder quality assurance program, provide assurance that the COL holder develops and implements an effective ITP.

• The COL holder is required to develop adequate test procedures for the full RG 1.68, Rev. 4 scope, and make it available for NRC inspection.

The follow-on sections in this white paper describe how FSAR Section 14.2 was developed, including how Design Reliability Assurance Program (D-RAP) system functions were used and tied to test abstracts, the specific contents of FOAK tests and control system tests, COL items to the NuScale ITP, and the NRC-requested roadmap that explicitly ties classification of functions tested and ITAAC verified to its associated test abstract.

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The following Table 1-1 provides the NuScale initial test program test abstracts that are the part of requested review of NuScales initial test program.

Table 1-1 NRC Risk-Significant Review of NuScale Preoperational Tests and Startup Tests Test System Number Abb. Test Abstract A1 A2 B1 ITAAC Preoperational Tests 4 PSCS Pool Surge Control X System 9 ABS Auxiliary Boiler X System 18 CRHS Control Room X Habitability System 19 CRVS Normal Control X Room HVAC System 20 RBVS Reactor Building X HVAC System 24 BPDS Balance-of-Plant X Drains 25 FPS Fire Protection X System 35 LRWS Liquid Radioactive X Waste System 36 GRWS Gaseous X Radioactive Waste System 38 CVCS Chemical and X Volume Control System 41 CES Containment X Evacuation System 42 CFDS Containment X Flooding and Drain System 43 CNTS Containment X X System 51 FHE Fuel Handling X Equipment System 52 RBC Reactor Building X Cranes 60 PLS Plant Lighting X System 63 MPS Module Protection X X X System 66 SDIS Safety Display and X Indication 68 COMS Communication X System 73 N/A Security Access X Control 74 N/A Security Detection X and Alarm Initial Fuel Loading Precritical Tests 76 N/A Initial Fuel Load 77 N/A Reactor Coolant System Flow Measurement Page 3 of 47

78 N/A NuScale Power Module Temperatures 79 N/A Primary and Secondary System Chemistry 80 N/A Control Rod Drive System-Manual Operation, Rod Speed, and Rod Position Indication 81 N/A Control Rod Assembly Full-Height Drop Time 81A N/A Control Rod Assembly Ambient Temperature Full-Height Drop Time Test 82 N/A Pressurizer Spray Bypass Flow 83 N/A Initial Criticality 84 N/A Post-Critical Reactivity Computer Checkout Low Power Tests 86 N/A Determination of Zero-Power Physics Testing Range 87 N/A All Rods Out Boron Endpoint Determination 88 N/A Isothermal Temperature Coefficient Measurement 89 N/A Bank Worth Measurement Power-Ascension Tests 91 N/A Core Power Distribution Map 92 N/A Nuclear Monitoring System Power Range Flux Calibration 93 N/A Reactor Coolant System Temperature Instrument Calibration 94 N/A Reactor Coolant System Flow Calibration 95 N/A Radiation Shield Survey 96 N/A Reactor Building Ventilation System Capability Page 4 of 47

97 N/A Thermal Expansion 98 N/A Control Rod Assembly Misalignment 99 N/A Steam Generator Level Control 100 N/A Ramp Change in Load Demand 101 N/A Step Change in Load Demand 102 N/A Loss of Feedwater Heater 103 N/A 100 Percent Load Rejection 104 N/A Reactor Trip from 100 Percent Power 105 N/A Island Mode Test for NuScale Power Module #1 106 N/A Island Mode Test for Multiple NuScale Power Modules 107 N/A Remote Shutdown Workstation 108 N/A NuScale Power Module Vibration Test Page 5 of 47

2.0 Overview of Preoperational and Startup Testing Regulatory Guide 1.68 defines the ITP as:

a) preoperational testing.

b) initial fuel loading testing.

c) pre-criticality testing.

d) initial criticality testing.

e) low power tests.

f) power ascension tests.

Also, RG 1.68 refers to the collection of tests b through f as Startup Tests.

In addition, RG 1.68 defines preoperational testing as those tests conducted following completion of construction inspections and tests, but before fuel loading, to demonstrate, to the extent practical, the capability of SSCs to meet the performance requirements to satisfy the design criteria. NuScale reflects this guidance in considering the RG 1.68 phrase construction inspections and tests as those activities completed by the COL holders Construction organization before the system care, custody, and control turnover from the COL holders Construction organization to the Startup organization. NuScale also considers preoperational testing as those tests conducted by Startup after the system care, custody, and control turnover from the COL holders Construction organization to the Startup organization and before the commencement of the initial fuel loading testing.

NuScale preoperational tests consists of (1) generic component testing (reference Section 4.0 of this document) completed on each system before the commencement of a system preoperational test, and (2) system preoperational tests listed in FSAR Table 14.2-109: List of Test Abstracts. NuScale preoperational tests are numbered test 1 through 74 in FSAR Table 14.2-109.

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3.0 Organization of Preoperational and Startup Testing Identification of NuScale Initial Test Program Preoperational Tests and Startup Tests FSAR Table 14.2-109: List of Test Abstracts contains a listing of all preoperational and startup test abstracts. FSAR Table 14.2-109 has been duplicated in Appendix A of this document with the following additional information provided:

a) The Design Reliability Assurance Program (D-RAP) classification of each function tested by a preoperational test b) The ITAAC number for each ITAAC associated with a preoperational test Startup tests do not have references to D-RAP system functions because startup tests are integrated tests verifying multiple functions. Startup tests do not have any ITAAC references because ITAAC must be completed before fuel load.

Refer to Section 5.0 for a discussion of how system D-RAP functions were used to develop preoperational test abstracts.

Refer to FSAR Table 14.3-1: Module-Specific Structures, Systems, and Components Based Design Features and Inspections, Tests, Analyses, and Acceptance Criteria Cross Reference and FSAR Table 14.3-2: Shared/Common Structures, Systems, and Components and Non-Structures, Systems, and Components Based Design Features and Inspections, Tests, Analyses, and Acceptance Criteria Cross Reference for a discussion of how each NuScale ITAAC is verified. The tables are organized by ITAAC number. If the successful completion of a preoperational test is required to verify an ITAAC, the verifying preoperational test abstract number is provided in the discussion of the ITAAC. In addition, the preoperational test acceptance criteria column is annotated with the ITAAC number in the associated preoperational test abstract contained in FSAR Table 14.2.

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4.0 RG 1.68 Rev 4 Component Testing Guidance Regulatory Guide 1.68 identifies types of components to be tested as part of the initial test program. Many of these listed component types are not applicable to NuScale design (reference Section 6.0 of this document). The component types listed in RG 1.68 that are applicable to NuScale design would be tested as part of the NuScale generic component testing. NuScales generic component testing is largely completed after system care, custody, and control transfer of the system from Construction to Startup, and completed by Startup before the performance of the associated preoperational test. Generic component testing executes standardized tests for a family of related components, independent of the components system assignment. Each generic component test procedure will be executed and approved before the component is required as a prerequisite to a preoperational test performance.

The completion of generic component testing is not listed as a prerequisite in NuScales test abstracts. For a discussion of test prerequisites in the NuScale test abstracts see Section 9.2 of this document. However, each detailed preoperational test procedure will itemize the completed generic component tests as a prerequisite.

The component types described in RG 1.68 are listed below in Table 4-1. The RG 1.68 system reference is not included for each component, because the components may occur in multiple NuScale systems. The RG 1.68 component type list in Table 4-1 is a subset of components that will require testing as part of NuScale generic testing.

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Table 4-1 RG 1.68 List of Components that Require a Generic Component Test Component Type Component Mechanical components Pumps Motors Valves Pressure relief Safety Isolation Turbine bypass Electrical distribution components Initiating devices Trip devices Heaters Breakers Motor controllers Switchgear Transformers Cables Batteries Battery chargers Transfer devices Converters Inverters Protective devices Instruments Instrumentation used to monitor system performance or perform permissive and prohibit interlock functions Instrument (instrument calibration)

Other components Pressurizer heater Heat tracing for freeze protection Rotating machinery vibration testing Cathodic protection High-efficiency particulate air filters Charcoal adsorbers Page 9 of 47

5.0 NuScale D-RAP System Functions: Use in Initial Test Program Testing FSAR Section 17.4.3 describes the NuScale process to evaluate and classify system functions and system components, called the Design Reliability Assurance Program. The scope of preoperational testing was determined using both RG 1.68 guidance and the functions identified in the NuScale D-RAP process.

The D-RAP SSC classification process uses a functional hierarchy concept in which each system function is classified and components required to support each system function are classified with respect to the associated system function they support. The defined standard functions are categorized as A1 (safety-related and risk-significant), A2 (safety-related, not risk-significant), B1 (nonsafety-related, risk-significant) or B2 (nonsafety-related, not risk-significant).

The functions identified by the D-RAP process have an inter-system dependence. The D-RAP system functions are of the form [the supporting system name] supports the

[supported system name] by [identification of the method].

The functions identified by the D-RAP process were directly used in defining the scope of preoperational tests. The system functions for each system from the D-RAP results were analyzed to identify the testable functions for that system. The testable system functions were then recorded within the systems preoperational test abstract.

The FSAR Table 17.4-1, D-RAP SSC Functions, Categorization, and Categorization Basis, lists the results of the D-RAP process for risk-significant functions only (function category A1 and B1). However, Appendix A, Table 7 provides all the D-RAP system function categories A1, A2, B1 and B2 for each preoperational test. RG 1.68 was used to verify that scope of system functions required to be tested by RG 1.68 guidance in a preoperational test were identified by the D-RAP system functions.

For the purpose of preoperational testing, there is no discrimination in the testing of A1 and A2 system functions. Preoperational test abstracts identify either A1 or A2 system functions as safety-related functions.

5.1 NuScale Initial Test Program Testing of NuScale Systems Containing A1, A2 and B1 System Functions NuScale Systems Containing A1 System Functions FSAR Table 17.4-1 lists safety-related, risk-significant (A1) system functions. The systems containing A1 functions are listed below. Each of the systems is a sub-system of the reactor module except the ultimate heat sink system.

a) Containment system (CNTS) b) Steam generator system (SGS) c) Reactor core (RXC) system d) Control Rod Drive System (CRDS) e) Reactor coolant system (RCS) f) Emergency core cooling system (ECCS) g) Decay heat removal system (DHRS) h) Ultimate heat sink (UHS)

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NuScale Systems Containing B1 System Functions FSAR Table 17.4-1 lists nonsafety-related, risk-significant (B1) system functions. The systems containing B1 functions are listed below.

a) Containment system (CNTS) b) Reactor Building crane (RBC) 5.2 Testable A1 System Functions Not every A1 D-RAP system function is a testable function required to be tested by preoperational or startup testing. The preoperational testing includes both generic component testing and system preoperational testing.

NuScale system functions identified as testable are verified by NuScale preoperational and startup testing. NRC regulations and regulatory guidance does not contain a definition or explanation for testable system functions. It is easier to describe system functions that are not testable; the remaining system functions describe in the D-RAP process become the inventory of testable system functions. NuScale uses the following attributes to classify system functions as a non-testable function.

• The system function is related to providing structural or mechanical support of another system.

• The system function provides a portion of the RCPB or the containment pressure boundary.

• The system function provides transfer of thermal energy (heat).

• The system function provides housing or allows access to another system.

• The system function describes a system flow, drain, or vent path.

• The system function describes the supporting system providing effluent for chemistry analysis.

The following A1 system functions contained in FSAR Table 17.4-1 are not testable and thus are not addressed in a NuScale preoperational testing or startup testing.

Structural or mechanical support functions:

a) The CNTS supports the CRDS by providing structural support for the control rod drive mechanisms.

b) The CNTS supports the RCS by providing structural support for the reactor pressure vessel (RPV).

c) The CNTS supports the ECCS by providing structural support of the trip and reset valves for the ECCS reactor vent and recirculation valve.

d) The CNTS supports the neutron monitoring system (NMS) by providing structural support for the ex-core detectors.

e) The CNTS supports the ECCS by providing electrical penetration assemblies for reactor instrumentation cables through containment vessel (CNV).

f) The RXC system supports the control rod assembly (CRA) by providing control rod guide tubes to receive and align the CRA.

g) The RXC system supports the RCS by maintaining a coolable geometry h) The RCS supports the CRDS by the RPV and the reactor vessel internals supporting and aligning the control rods.

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i) The RCS supports the ECCS by providing mechanical support for the ECCS valves.

j) The RCS supports in-core instrumentation by providing structural support of the in-core instrumentation guide tubes.

k) The RCS supports the RXC system by the reactor vessel internals providing mechanical support to orient, position, and seat the fuel assemblies.

l) The RCS supports the SGS by providing physical support for the steam generator tube supports and for the integral steam and feed plenums.

m) The RXB supports the CNTS by housing and providing structural support.

n) The RXB supports the chemical and volume control system (CVCS) by housing, allowing access, and providing structural support.

o) The RXB supports the UHS by housing and providing structural support.

p) The RXB supports the module protection system (MPS) by housing and providing structural support.

q) The RXB supports the NMS by housing and providing structural support.

r) The CRB supports the MPS by housing and providing structural support.

Containment pressure boundary and reactor coolant pressure boundary system (RCPB) functions:

a) The SGS supports the RCS by supplying part of the RCPB.

b) ECCS supports the RCS by providing a portion of the RCPB for maintaining RCPB integrity.

c) The ECCS supports the CNTS by providing a portion of the containment boundary for maintaining containment integrity.

Heat transfer system functions:

a) The CNTS supports the RCS by transferring core heat from reactor coolant in containment to the UHS.

b) The RCS supports the RXC system by removing heat to ensure core thermal design limits are not exceeded.

c) The UHS supports the CNTS by providing heat removal via direct water contact with the containment vessel for the removal of core heat.

d) The UHS supports the spent fuel storage system by providing the removal of decay heat from spent fuel via direct water contact with spent fuel assemblies.

e) The UHS supports the DHRS by accepting heat from decay heat removal heat exchanger.

f) The UHS supports the RXC system by direct water contact with fuel assemblies during refueling to remove decay heat.

Radiation protection system functions to minimize contamination or provide radiation shielding a) The RXC system supports the RCS by containing fission products and transuranics within the fuel rods to minimize contamination of the reactor coolant.

b) The UHS supports the spent fuel storage system by providing radiation shielding and iodine scrubbing for spent fuel via water surrounding the components.

c) The UHS supports the RXC system by providing radiation shielding and iodine scrubbing for fuel assemblies via the water surrounding the components.

d) The RCS supports RXC system by containing soluble neutron poison.

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5.3 NuScale Testable A1 System Functions Table 5-1 below is a list of A1 testable functions that were derived by eliminating the non-testable A1 functions contained in Section 5.2 of this document from the list of A1 functions in FSAR Table 17.4-1.

Table 5-1 identifies the preoperational test where the NuScale testable A1 system functions are tested.

Table 5-1 NuScale Testable A1 System Functions System Testable Function Tested in Preoperational Test Number CNTS Supports the Reactor Building (RXB) by providing a barrier to CNTS Test #43-1 contain mass, energy, and fission product release from a degradation of the RCPB.

CNTS Supports ECCS operations by providing a sealed containment CNTS Test #43-1 and thermal conduction for the condensation of steam that provides makeup water to the RCS.

CNTS Supports the RXB by providing a barrier to contain mass, MPS Test #63-6 energy, and fission product release by closure of the containment isolation valves (CIVs) upon containment isolation signal.

CNTS Supports the RCS by closing the CIVs for pressurizer spray, MPS Test #63-6 chemical and volume control system (CVCS) makeup, CVCS letdown, and RPV high point degas when actuated by the MPS for RCS Isolation.

SGS None RXC None CRDS Supports the CRA by releasing control rod during a reactor MPS Test #63-5 trip.

RCS Supports the MPS by providing instrument information signals MPS Test #63-1 for MPS actuation.

ECCS Supports the RCS by opening ECCS reactor vent valves MPS Test #63-6 (RVVs) and reactor recirculation valves (RRVs) when their respective trip valve is actuated by the MPS.

DHRS Supports by providing MPS actuation instrument information MPS Test #63-1 signals.

MPS Supports low-voltage AC electrical distribution system (ELVS) MPS Test #63-4 by removing electrical power to the pressurizer on a MPS Test #63-6 pressurizer heater trip actuation signal.

MPS Supports the ECCS by removing electrical power to the trip MPS Test #63-4 solenoids of the RVVs on an ECCS actuation signal. MPS Test #63-6 Page 13 of 47

System Testable Function Tested in Preoperational Test Number MPS Supports the DHRS by removing electrical power to the trip MPS Test #63-6 solenoids of the decay heat removal actuation valves on a DHRS actuation signal.

MPS Supports the CNTS by removing electrical power to the trip MPS Test #63-4 solenoids of the main steam isolation valves, the main steam MPS Test #63-6 bypass isolation valves, and the feedwater isolation valves on a DHRS actuation signal.

MPS Supports the CNTS by removing electrical power to the trip MPS Test #63-4 solenoids of MPS Test #63-6 the following CIVs on a CNTS isolation actuation signal:

- RCS injection CIVs

- RCS discharge CIVs

- Pressurizer spray CIVs

- RPV high point degasification CIVs

- Feedwater isolation valves

- Main steam isolation valves

- Main steam bypass isolation valves

- Containment evacuation isolation valves

- Reactor component cooling water inlet and outlet CIVs

- Containment flooding and drain CIVs MPS Supports the CNTS by removing electrical power to the trip MPS Test #63-4 solenoids of MPS Test #63-6 the following CIVs on a CVC isolation actuation signal:

- RCS injection CIVs

- RCS discharge CIVs

- Pressurizer spray CIVs

- RPV high point degasification CIVs MPS Supports the CVCS by removing electrical power to the trip MPS Test #63-4 solenoids of the demineralized water system isolation valves MPS Test #63-6 on a DWS isolation actuation signal.

MPS Supports non-safety DC electrical and AC distribution system MPS Test #63-4 by removing electrical power to the CRDS for a reactor trip. Test #63-5 MPS Supports the CNTS by providing power to sensors. CNT instrument calibration MPS Supports the DHRS by providing power to main steam DHR instrument pressure sensors. calibration MPS Supports the RCS by providing power to sensors. RCS instrument calibration Page 14 of 47

System Testable Function Tested in Preoperational Test Number NMS Supports the MPS by providing neutron flux data for various MPS Test #63-4 reactor trips, operating bypasses, and actuations.

Testing of the NMS is limited before core load. NMS is also tested by the following power ascension tests:

Test #91 Core Power Distribution Map Test Test #92 Neutron Monitoring System Power Range Flux Calibration Test Test #98 Control Rod Misalignment Test 5.4 NuScale Testable A2 Testable System Functions In FSAR Table 17.4-1, safety-related, nonrisk-significant system functions are not identified. The D-RAP design information identifies four safety-related, nonrisk-significant (A2) system functions. Table 5-2 below identifies the A2 system functions and lists the preoperational test that verifies each function.

Table 5-2 NuScale Testable A2 System Functions System Testable Function Tested in Preoperational Test #

DHRS The DHRS supports the RCS by opening the DHRS actuation MPS Test #63-6 valves on a DHRS actuation signal.

ECCS The ECCS supports RCS by providing low temperature over MPS Test #63-6 pressure protection for maintaining the RCPB integrity.

CVCS The CVCS supports the RCS by isolating dilution sources. MPS Test #63-6 RCS The RCS supports the MPS by providing instrument information MPS Test #63-6 signals for low temperature overpressure protection actuation.

5.5 NuScale Testable B1 Testable System Functions Table 5-3 below contains the two NuScale nonsafety-related, risk-significant (B1) system functions, which are both testable.

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Table 5-3 NuScale Testable B1 System Functions System Testable Function Tested in Preoperational Test #

CNTS The CNTS supports the RBC by providing lifting attachment points RBC Test #52-1 that the RBC can connect to so that the module can be lifted. RBC Test #52-2 RBC The RBC supports the NPM by providing structural support and RBC Test #52-1 mobility while moving from refueling, inspection, and operating RBC Test #52-2 bay.

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6.0 Type of RG 1.68 Rev 4 Testing Not Applicable to NuScale Design Because of NuScales simple passive design with fewer systems, many design features identified in RG 1.68 are not tested because the NuScale does not have the design feature. The following are examples of components and systems that are listed in RG 1.68, but are NOT contained in the NuScale design. The list is not comprehensive.

• Emergency AC power distribution system

• Emergency bus loading or sequencing

• Emergency diesel generator

• Emergency feedwater system

• Emergency boration system

• Emergency feedwater system

• Emergency cooling towers

• ECCS pumps

• ECCS tanks

• Safety-related UHS cooling towers and associated auxiliaries

• Load shedding of electrical busses

• Auxiliary feedwater system

• Refuel transfer canal

• Anticipated transients without scram system

• Automatic depressurization system

• Automatic reactor power control systems

• Traversing in-core probe system

• Failed fuel detection systems

• Loose parts monitoring system

• Steam generator blowdown

• Standby liquid control system

• Born recovery system

• Shield cooling system

• Pyrotechnic-actuated valves

• Containment:

o Containment spray system o Combustible gas control system o Containment recirculation fans o Containment air locks o Containment inerting o Containment annulus o Containment penetration cooling o Containment sump o Post-accident hydrogen monitors o Containment cooling fans during normal operation

• RCS components:

o Pumps, motors and associated power sources o Block valves and associated dump valves o Acoustic monitors for safety and relief valves o Jet pumps o Pyrotechnic-actuated squib valves o Rotating machinery o Reactor coolant pumps (which eliminates pump flow coast down requirements)

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7.0 First-of-a-Kind Tests The FSAR section 14.2.3.3 describes NuScales first-of-a-kind (FOAK) testing. The following ITP test abstracts describe the Comprehensive Vibration Assessment Program testing of FOAK design features:

a) Table 14.2-44: Control Rod Drive System Flow-Induced Vibration Test #44 b) Table 14.2-45: Reactor Vessel Internals Flow-Induced Vibration Test #45 c) Table 14.2-75: Steam Generator Flow-Induced Vibration Test #72.

d) Table 14.2-108: NuScale Power Module Vibration Test #108 The FOAK tests #44, #45, and #72 are performed at the factory. Test #108 is performed on site at 100 percent power.

Only the vibration testing listed above is considered as NuScale FOAK testing. However, there are additional new design features in the NuScale design that will be verified for each plant, instead of the one time or three time verification required by FOAK testing.

FSAR Table 14.2-110: ITP Testing of New Design Features lists the new and unique design features that are subject to FOAK testing. FSAR Table 14.2-110 lists the associated test numbers for each new NuScale design features.

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8.0 NuScale Control Systems NuScale Control System Testing In FSAR Section 7.0, an introduction and overview of instrumentation and controls (I&C) systems are provided, which includes safety-related and nonsafety-related systems. The control systems addressed in Section 7.0 include the following:

a) module protection system (MPS) b) neutron monitoring system (NMS) c) plant protection system (PPS) d) safety display and indication system (SDIS) e) module control system (MCS) f) plant control system (PCS) g) in-core instrumentation system (ICIS) h) health physics network i) fixed area radiation monitoring Also, FSAR Section 14.2.1.1 describes how the testing of the above I&C systems will be completed before the care, custody, and control of the systems from Construction to Startup.

The successful testing of the digital I&C systems will not require Startup to re-perform the following type of testing in preoperational or startup tests:

a) control logic testing b) parameter display tests c) parameter alarm tests d) trip settings e) setpoint verification The following list contains examples where RG 1.68 recommends testing of control system design features in the initial test program. These tests are not required in the NuScale initial test program, because the control system design features will be verified in the factory acceptance test and/or in the site acceptance test for the control system. The RG 1.68 examples below are not intended to be comprehensive, but, taken together, they describe the general scope of control system design features.

a) Verify operation of instrumentation, controls, interlocks, and alarms.

b) Verify proper operation in all combinations of logic; proper trip and alarm settings; proper operation of permissive, prohibit, and bypass functions; and operability of bypass switches.

c) Demonstrate proper operation of relaying and logic, permissives and prohibit interlocks, instrumentation and alarms.

d) Testing should include demonstrations of proper operation of associated alarms, indicators, controls.

e) Testing should include demonstrations of correct logic and set points, as well as proper operation of bypasses, permissive and prohibit interlocks, f) Testing should also confirm the operation of local and remote alarm functions, including radioactivity or radiation levels above established set-points and tank content levels.

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g) The following list illustrates the equipment and component tests that the program should include: high-radiation alarms and low-water-level alarms.

h) Demonstrate relaying and logic.

i) Verify proper trip and alarm settings; proper operation of permissive, prohibit, and bypass functions.

8.2 NuScale Control System Testing/Field Testing Overlap After a NuScale I&C system has completed its site acceptance test, the care, custody, and control of the system will be transferred from Construction to Startup. To place an I&C system in operation for a given system will require additional field activities to be completed. The following activities are performed on a preoperational test (generally a system) basis.

a) Instruments required for a preoperational test must be calibrated as a prerequisite to the preoperational test.

b) If the instrument calibration procedure did not require the instrument signal to be displayed on an MCS or a PCS workstation, then a preoperational test step will require this action to be taken in the preoperational test procedure. The completion of the following component-level test will ensure that all system variables are properly monitored by the associated control system.

c) The standard test abstract statement to verify an instrument signal is available on the MCS or the PCS is:

o Component-level test objective: Verify each [tested system] instrument is available on an MCS or a PCS display.

o Test Method: Initiate a single real or simulated instrument signal from each

[tested system] transmitter.

o Acceptance Criteria: The instrument signal is displayed on an MCS or a PCS display, or is recorded by the applicable control system historian.

d) The remaining actions necessary to make a control system functional for a given system is to operate the systems remotely-operated equipment from the main control room. This is completed by executing component-level tests in the preoperational test that will open and close all valves and operate all equipment from the main control room which will require the speed of variable-speed equipment to be manually controlled from the main control room.

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9.0 NuScale Test Abstract Attributes 9.1 Scope of Testing for Preoperational Tests NuScales scope of testing is defined by D-RAP system functions for the system under test. Each function was developed by NuScale using the process described in Section 5.0 of this document. A standardized method was used to describe each system function of the form The [supporting system] supports the [supported system] by [description of the support method].

Regulatory Guide 1.68 was reviewed to ensure alignment of test scope defined by the NuScale system functions with NRC guidance. This result of the alignment check revealed conformity between developing the test scope using system functions and test guidance contained in RG 1.68. The check was performed by using several methods:

a) Regulatory Guide 1.68 was reviewed to determine the potential test scope of a DCA by identifying the test features described by RG 1.68 that are applicable to the NuScale design. An inventory of design features not applicable to NuScale was compiled. Section 6.0 of this document has examples of the design features not applicable to the NuScale design.

b) Table B-1 in Appendix B of this document was used to parse the RG 1.68 regulatory guidance applicable to the associated NuScale design features. Table B-1 cross references the applicable regulatory guidance to the NuScale testing that satisfies the guidance. Table B-1 also identifies the specific design feature contained in RG 1.68 guidance that is not contained in the NuScale design. In this way, the NuScale test abstracts could be measured against NRC test guidance.

c) NuScale reviewed RG 1.68 for references to component testing versus system testing. The instances where RG 1.68 referenced component tests were recorded in Table 1-1 in Section 4.0 of this document. This table allowed NuScale to differential between component-level test guidance and system-level test guidance.

9.2 NuScale Test Abstract Prerequisites NuScale test abstracts provide only the essential prerequisites necessary to prepare a test procedure from the abstract.

a) Operating experience from the startups of operating U.S. commercial nuclear power plants identified numerous issues related to prerequisites contained in Chapter 14 test abstracts that required a change to the FSAR.

b) Prerequisites had to be revised, because the prerequisite was no longer valid at test conduct due to configuration changes made during detailed design after the PSAR was issued for a construction license. Some DCAs attempted to compensate for this unknown design condition by using phrases in the prerequisite such as as necessary, if required, or to the extent possible.

c) The following are quotes (with emphasis added) from an approved DCA. Many DCAs have similar content.

o The following interfacing and support systems are available as necessary to support testing: component cooling water system; service water system; reactor coolant system; electrical power and distribution systems.

o Data collection is available as needed to support the specified testing and system configurations.

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o The cooled components are operational and operating to the extent possible.

o Related system interfaces are available or simulated as necessary.

o The interfacing and support systems required for testing and data collection are available as needed to support the specified testing and system configurations.

d) NuScale included test prerequisites in NuScale preoperational and startup test abstracts to provide for unique prerequisite circumstances that would be required to ensure a successful test. These unique circumstances are:

o The plant must be operated at plant conditions other than ambient conditions.

For example, the plant may be required to operate at elevated temperatures, elevated pressures, specified power levels, specified boron concentrations, or the reactor must be critical.

o Temporary test instrumentation is installed.

o Temporary data collection equipment is available.

o Specific tests that must be completed before test conduct to ensure the quality of preoperational or startup test data. For example, specific generic component tests for pump curves, calibrations, or a system flow balance must be completed.

o Completion of factory acceptance test or a site acceptance test may be specified.

e) Regulatory Guide 1.68 does not provide guidance for test prerequisite content for test abstracts contained in FSAR Section 14.2 f) Regulatory Guide 1.68 has specific guidance in Appendix C-1 for test procedure prerequisites. This section states Each test of the operation of a system normally requires that certain other activities be performed first (e.g., completion of construction, construction and/or preliminary tests, inspections, and certain other preoperational tests or operations). The preoperational testing procedures should include, as appropriate, these specific prerequisites.

g) Section 10.0 Table 10-1: RG 1.68 Test Program Guidance describes how the NuScale test program addresses test procedure prerequisites.

9.3 Impact of Digital Control Systems versus Analog Control Systems on the NuScale Initial Test Program Section 8.0 of this document describes how the NuScale digital systems are tested. As described in Section 8.0 the testing of digital systems is completed before the care, custody, and control transfer of the system from Construction to Startup. Therefore, Startup test abstracts and Startup test procedures are not required to address testing of displays, alarms, and controls. This is a significant decrease in scope for the NuScale test program as contrasted to traditional operating plants where displays, alarms, and control testing required the following test actions, and others, such as:

a) placement of electrical jumpers.

b) lifted leads.

c) manual operation of control relays.

d) injection of test signals.

e) manual actuation of analog bistables by signal injection.

f) testing of the ESF control system hardware.

g) manual operation of electrical protective relays.

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As contrasted to operating U.S. nuclear power plants, the NuScale initial test program test abstract content, the NuScale initial test procedure content and volume and the NuScale test complexity have been reduced significantly compared to operating U.S nuclear power plant initial test programs.

Section 8.2 of this document describes the content of NuScale test abstracts and NuScale test procedures required to ensure proper test overlap with control systems testing.

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10.0 RG 1.68 Test Program Guidance The conformance to RG 1.68 test program guidance is described in the FSAR Sections listed in Table 10-1 below.

Table 10-1 Adherence to RG 1.68 Program Guidance RG 1.68 Program FSAR Section Containing a Comment Requirements Description of the NuScale Test Program Construction and installation 14.2.1.1 None Testing of digital I&C systems 14.2.1.1 Logic testing of digital I&C systems is not repeated in the initial test program Scope, conditions, and length 14.2.1 Reference COL Item 14.2-2 of testing Initial test program 14.2.2 Reference COL Item 14.2-1 management and execution of the initial test program FOAK features 14.2.3.3 Reference FSAR Table 14.2-44; Table 14.2-45; Table 14.2-75, Table 14.2-108; and Table 14.2-110 Test prerequisites 14.2.4 Reference COL Item 14.2-2 14.2.10.1 Test Conduct 14.2.4 Reference COL Item 14.2-2 Test procedures 14.2.3.1 Reference COL Item 14.2-2 14.2.5 14.2.11 Test Results/ Test Reports 14.2.5 Reference COL Item 14.2-2 Test Records 14.2.6 Reference COL Item 14.2-2 Graded approach: 14.2.3.2 None Standardized component -

level tests in preoperational tests Utilization operating 14.2.8 None experience Trial Testing of Plant 14.2.9 None Emergency, Operating, and Surveillance Test Procedures Test Schedule 14.2.11 Reference COL Item 14.2-4 Milestones and Power Hold 14.2.10.5 Reference COL Item 14.2-4 Points 14.2.11 Page 24 of 47

11.0 COL Items related to the NuScale Initial Test Program COL Item 14.2-1: A COL applicant that references the NuScale Power Plant design certification will describe the site-specific organizations that manage, supervise, or execute the Initial Test Program, including the associated training requirements.

COL Item 14.2-2: A COL applicant that references the NuScale Power Plant design certification is responsible for the development of the Startup Administration Manual that will contain the administrative procedures and requirements that control the activities associated with the Initial Test Program. The COL applicant will provide a milestone for completing the Startup Administrative Manual and making it available for NRC inspection.

COL Item 14.2-3: A COL applicant that references the NuScale Power Plant design certification will identify the specific operator training to be conducted during low-power testing related to the resolution of TMI Action Plan Item I.G.1, as described in NUREG-0660, NUREG-0694, and NUREG-0737.

COL Item 14.2-4: A COL applicant that references the NuScale Power Plant design certification will provide a schedule for the Initial Test Program.

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Appendix A.

Appendix A Table A-1 data reveal that the only NuScale Preoperational Tests that verify safety-related (A1 or A2) functions are:

a) Test #43 Containment System b) Test #63 Module Protection System Appendix A Table A-1 data also reveal that the only NuScale Preoperational Test that verifies B1 functions is c) Test #52 Reactor Building Cranes Table A-1 NuScale Initial Test Program Tests Classification of Functions ITAAC Verified Tested for Each for Each Preoperational Test Preoperational Test System Test Number Abb. Test Abstract A1 A2 B1 B2 1 SFPCS Spent Fuel Pool X Cooling System 2 PCUS Pool Cleanup System X 3 RPCS Reactor Pool Cooling X System 4 PSCS Pool Surge Control X 03.09.10 (B2) (1)

System 5 UHS Ultimate Heat Sink X 6 PLDS Pool Leakage X Detection System 7 RCCWS Reactor Component X Cooling Water System 8 CHW Chilled Water System X 9 ABS Auxiliary Boiler System X 03.09.08 (B2) (1) 03.09.09 (B2) (1) 10 CWS Circulating Water X System 11 SCW Site Cooling Water X System 12 PWS Potable Water System X 13 UWS Utility Water System X 14 DWS Demineralized Water X System 15 NDS Nitrogen Distribution X System 16 SAS Service Air System X 17 IAS Instrument Air System X 18 CRHS Control Room X 03.01.01 (B2) (2)

Habitability System 03.01.02 (B2) (2) 03.01.03 (B2) (2) 03.01.05 (B2) (2) 03.09.02 (B2) (1) 19 CRVS Normal Control Room X 03.02.01 (B2) (3)

HVAC System 03.02.02 (B2) (3) 03.02.03 (B2) (3) 03.09.01 (B2) (3)

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Classification of Functions ITAAC Verified Tested for Each for Each Preoperational Test Preoperational Test System Test Number Abb. Test Abstract A1 A2 B1 B2 20 RBVS Reactor Building X 03.03.01 (B2) (4)

HVAC System 03.03.02 (B2) (4) 03.03.03 (B2) (4) 03.09.03 (B2) (1) 21 RWBVS Radioactive Waste X Building HVAC System 22 TBVS Turbine Building X Ventilation 23 RWDS Radioactive Waste X Drain System 24 BPDS Balance-of-Plant X 03.17.02 (B2) (1)

Drains 03.17.03 (B2) (1) 03.17.04 (B2) (1) 03.18.02 (B2) (1) 03.18.03 (B2) (1) 25 FPS Fire Protection System X 03.07.02 (B2) (6) 26 FDS Fire Detection X 27 MSS Main Steam X 28 CFWS Feedwater System X 29 FWTS Feedwater Treatment X 30 CPS Condensate Polisher X Resin Regeneration System 31 HVD Heater Vents and X Drains 32 CARS Condenser Air X Removal System 33 TGS Turbine Generator X 34 TLOS Turbine Lube Oil X System 35 LRWS Liquid Radioactive X 03.09.07 (B2) (1)

Waste System 36 GRWS Gaseous Radioactive X 03.09.04 (B2) (1)

Waste System 03.09.05 (B2) (1) 03.09.06 (B2) (1) 37 SRWS Solid Radioactive X Waste System 38 CVCS Chemical and Volume X 02.02.03 (B2) (7)

Control System 02.02.04 (B2) (7) 02.02.05 (B2) (7) 02.07.02 (B2) (1) 02.07.03 (B2) (1) 02.07.04 (B2) (1) 39 BAS Boron Addition X System 40 MHS Module Heatup X System 41 CES Containment X 02.03.01(B2) (5)

Evacuation System 02.03.02(B2) (5) 02.07.01(B2) (1) 42 CFDS Containment Flooding X 03.17.01 (B2) (1) and Drain System 03.18.01 (B2) (1) 43 CNTS Containment System X 02.01.07 (A1) (8) 02.01.21 (A1) (9)

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Classification of Functions ITAAC Verified Tested for Each for Each Preoperational Test Preoperational Test System Test Number Abb. Test Abstract A1 A2 B1 B2 44 CRDS Control Rod Drive Factory Acceptance Test System Flow-Induced Vibration 45 RVI Reactor Vessel Factory Acceptance Test Internals Flow-Induced Vibration 46 RCS Reactor Coolant System 47 ECCS Emergency Core Cooling System 48 DHRS Decay Heat Removal System 49 ICIS In-core Instrumentation X 50 MAE Module Assembly There are no preoperational tests for module Equipment assembly equipment. MAE testing will be performed by Construction.

51 FHE Fuel Handling 03.04.05 (B2) (11)

Equipment System 03.04.06 (B2) (12) 52 RBC Reactor Building X X Cranes 53 PSS Process Sampling X System 54 EHVS 13.8 kV and X Switchyard System 55 EMVS Medium Voltage AC X Electrical Distribution System 56 ELVS Low Voltage AC X Electrical Distribution System 57 EDSS Highly Reliable DC X Power System 58 EDNS Normal DC Power X System 59 BPSS Backup Power Supply X 60 PLS Plant Lighting System X 03.08.01 (B2) (13) 03.08.02 (B2) (13) 03.08.03 (B2) (13) 61 MCS Module Control X System 62 PCS Plant Control System X Page 28 of 47

Classification of Functions ITAAC Verified Tested for Each for Each Preoperational Test Preoperational Test System Test Number Abb. Test Abstract A1 A2 B1 B2 63 MPS Module Protection X X X 02.01.08 (15)

System 02.01.13 (16) 02.01.14 (17) 02.01.15 (18) 02.01.18 (19) 02.01.19 (20) 02.01.20 (21) 02.02.03 (22) 02.02.05 (23) 02.05.02 (24) 02.05.08 (24) 02.05.09 (24) 02.05.10 (24) 02.05.11 (24) 02.05.12 (25 02.05.13 (26) 02.05.14 (24) 02.05.15 (24) 02.05.16 (27) 02.05.17 (28) 02.05.18 (24) 02.05.19 (24) 02.05.20 (24) 02.05.21 (24) 02.05.22 (24) 02.05.23 (24) 02.05.26 (29) 64 PPS Plant Protection X System 65 NMS Neutron Monitoring System 66 SDIS Safety Display and X 02.05.25 (B2) (14)

Indication 67 RMS Fixed Area Radiation X Monitoring System 68 COMS Communication X 03.16.11 (B2)

System 03.16.12 (B2) 03.16.13 (B2) 69 SMS Seismic Monitoring Test provided by COL (COL item 3.7-1)

System 70 HFT Hot Functional Testing The Test #70 abstract list all hot functional tests.

The Test #70 abstract also provides the associated test objectives and classification of the systems functions associated the hot functional tests.

71 MAEB Module Assembly X Equipment Bolting 72 SG Steam Generator Flow- Separate affects tests using prototype.

Induced Vibration 73 N/A Security Access 03.16.04 (B2)

Control 74 N/A Security Detection 03.16.05 (B2) and Alarm 03.16.07 (B2) 03.16.08 (B2) 03.16.09 (B2) 03.16.10 (B2)

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Classification of Functions ITAAC Verified Tested for Each for Each Preoperational Test Preoperational Test System Test Number Abb. Test Abstract A1 A2 B1 B2 75 N/A Initial Fuel Loading The Test #75 abstract lists all precritical tests. The Precritical Test COL will provide the sequence and schedule of testing for precritical tests (COL Item 14.2-4).

76 N/A Initial Fuel Load System functions are not provided for precritical tests.

77 N/A Reactor Coolant The precritical tests have no associated ITAAC.

System Flow Measurement 78 N/A NuScale Power Module Temperatures 79 N/A Primary and Secondary System Chemistry 80 N/A Control Rod Drive System-Manual Operation, Rod Speed, and Rod Position Indication 81 N/A Control Rod Assembly Full-Height Drop Time 81A N/A Control Rod Assembly Ambient Temperature Full-Height Drop Time Test 82 N/A Pressurizer Spray Bypass Flow 83 N/A Initial Criticality 84 N/A Post-Critical Reactivity Computer Checkout 85 N/A Low Power Test Test #85 abstract lists all low power tests (test #86 Sequence though test #89). The COL will provide the sequence and schedule of testing for low power tests (COL Item 14.2-4).

86 N/A Determination of System functions are not provided for low power tests.

Zero-Power Physics The low power tests have no associated ITAAC.

Testing Range 87 N/A All Rods Out Boron Endpoint Determination 88 N/A Isothermal Temperature Coefficient Measurement 89 N/A Bank Worth Measurement 90 N/A Power-Ascension Test #90 abstract lists all power-ascension tests (test

1. 91 though test #108). The COL will provide the sequence and schedule of testing for power-ascension tests (COL Item 14.2-4)

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Classification of Functions ITAAC Verified Tested for Each for Each Preoperational Test Preoperational Test System Test Number Abb. Test Abstract A1 A2 B1 B2 91 N/A Core Power System functions are not provided for power-Distribution Map ascension tests (test #91 though test #108. The 92 N/A Nuclear Monitoring power-ascension tests have no associated ITAAC.

System Power Range Flux Calibration 93 N/A Reactor Coolant System Temperature Instrument Calibration 94 N/A Reactor Coolant System Flow Calibration 95 N/A Radiation Shield Survey 96 N/A Reactor Building Ventilation System Capability 97 N/A Thermal Expansion 98 N/A Control Rod Assembly Misalignment 99 N/A Steam Generator Level Control 100 N/A Ramp Change in Load Demand 101 N/A Step Change in Load Demand 102 N/A Loss of Feedwater Heater 103 N/A 100 Percent Load Rejection 104 N/A Reactor Trip from 100 Percent Power 105 N/A Island Mode Test for NuScale Power Module

1. 1 106 N/A Island Mode Test for Multiple NuScale Power Modules 107 N/A Remote Shutdown Workstation 108 N/A NuScale Power Module Vibration Test Table A-1 Notes:

(1) System response to a high-radiation signal (radiation protection)

(2) Control room habitability system performance (3) Normal control room HVAC System performance (radiation protection)

(4) Reactor Building HVAC system performance (radiation protection)

(5) Containment evacuation system performance (RCS leakage detection)

(6) Fire protection system pump performance (7) ASME Code Class 3 air-operated valves and check valve performance (8) Containment vessel Type B and Type C local leak rate test (9) CNTS safety-related check valve performance.

(10) NOT USED (11) Fuel handling machine travel limitation Page 31 of 47

(12) New fuel jib crane travel limitation (13) Normal and emergency illumination of workstations in the MCR and the RSS; emergency illumination for post-fire activities outside control room (14) SDIS displays of PAM Type B and Type C displays in the main control room (15) Containment isolation valve stroke time (16) Containment isolation valve stroke from main control room (17) ECCS safety-related valve stroke from main control room (18) DHRS safety-related valve stroke from main control room (19) CNTS safety-related hydraulic-operated valve fail position on loss of power (20) ECCS RRVs and RVVs safety-related hydraulic-operated valve fail position on loss of power (21) DHRS safety-related hydraulic-operated valve fail position on loss of power (22) CVCS ASME Code Class 3 air-operated valves stroke from main control room (23) CVCS ASME Code Class 3 air-operated valve fail position on loss of power (24) MPS logic testing (25) MPS manual reactor trip (26) MPS manual ESF actuations (27) Completion of safety-related protective actions (28) Response times for safety-related MPS reactor trip functions and safety-related MPS ESF functions (29) The controls located on the operator workstations in the MCR operate to perform important human actions (IHAs).

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Appendix B.

RG 1.68 Rev 4 Preoperational System Testing Guidance Regulatory Guide 1.68 Appendix A-1 makes reference to specific systems or design features that should be tested during an initial test program. The following Table B-1 contains extracts from RG 1.68 Appendix A-1 that provide NRC guidance for the scope of testing. The table identifies the NuScale initial test program tests that satisfy the Appendix A-1 guidance applicable to the NuScale design.

Section 6.0 of this document discusses examples of design features discussed in RG 1.68 that are not contained in the NuScale design.

Table B-1 RG 1.68 Rev 4 Preoperational Testing Guidance versus NuScale Preoperational Tests RG 1.68 Test Guidance NuScale Initial Test Program Test A-1.a. Reactor Coolant System Tests Section A-1.a contains items that are RCS design features. The RCS design features that are not applicable to the NuScale design are:

1; 2.b.; 2.c.; 2.d. (block valves and dump tank); 2.f.; 2.h.; 2.i (acoustic monitoring); 2.j.;

2.l; 3 (rotating machinery)

A-1.a. item 2.a Initial Fuel Loading Precritical Test Pressurizer spray and throttle valves Test #82: Pressurizer Spray Bypass Flow Test A-1.a. item 3. Power Ascension Test Vibrations tests Test #108: NuScale Module Vibration Test A-1.a. item 4. Performed by vendor RCS pressure boundary integrity test A-1.b.1. Control Rod System Tests Section A-1.b.1 contains items that are CRDS design features. The CRDS design features that are not applicable to the NuScale design are:

1.b.; 1.c. (CRDS interaction with other design features such as automatic reactor power and refueling equipment);

A-1.b. item 1.a Initial Fuel Loading Precritical Test Normal operation of the CRDS Test #80: Control Rod Drive System-Manual Operation, Rod Speed, and Rod Position Indication A-1.b. item 1.a MPS Test #63-5 Reactor trip A-1.b item 1.c Initial Fuel Loading Precritical Test Rod position indication Test #80: Control Rod Drive System-Manual Operation, Rod Speed, and Rod Position Indication Page 33 of 47

RG 1.68 Test Guidance NuScale Initial Test Program Test A-1.b. item 1.d MPS Test #63-2 Operation of CRDS on loss of power A-1.b.2. Chemical Control System Tests Section A-1.b.2 contains items that are CVCS design features. The CVCS design features that are not applicable to the NuScale design are:

2.b, 2.c (redundancy, electrical independence)

A-1.b. item 2.a Preoperational Test Proper blending of boron solution and Chemical and Volume Control System water; uniform mixing Test # 38-3 A-1.b. item 2.c Preoperational Test Correct failure mode on loss of power to Chemical and Volume Control System system components Test # 38 component level test ii.

A-1.c. Reactor Protection and Engineered Safety Features Actuation Systems Tests Time response MPS Test #63-7 Redundancy, electrical independence, EDSS Test #57-1, #57-2 and #57-3 coincidence, and safe failure on loss of (RG 1.41 Independence Test) power A-1.d. Decay Heat Removal System Tests Section A-1.d contains items that are DHRS design features. The DHRS design features that are not applicable to the NuScale design are:

3. (Redundancy, electrical independence); 3.f; 3.h; 3.i.; 3.j; 3.k.; and 3.l.

Items 3.b; 3.c. 3.d. and 3.g are components tested by the generic component testing program.

A-1.d. item 1. Power Ascension Test Verify design features provided or relied on Test #103: 100% Load Rejection Test to dissipate or channel thermal energy from the reactor to the atmosphere or to the main condenser following off-normal conditions or anticipated transients, including reactor scram.

A-1.d. item 2. Power Ascension Test Verify design features provided for makeup Test #103: 100% Load Rejection Test of coolant, to dissipate residual heat, to cool the reactor down to a cold-shutdown condition, and to maintain long-term cooling.

A-1.d. item 3.a Power Ascension Test Turbine bypass valves Test #103: 100% Load Rejection Test Test #106 Island Mode Test Test #33 TG Test (HFT)

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RG 1.68 Test Guidance NuScale Initial Test Program Test A-1.e. Power Conversion System Tests Section A-1.e contains items that are power conversion system design features.

Items 3, 4, and 6 are components tested by the generic component testing program.

A-1.e. item 1 None Steam generators A-1.e. item 2 Preoperational Test Main steam system Test #27 Main Steam Test Test #33-2 TG Test A-1.e. item 3 Generic component tests Main steam isolation valves A-1.e. item 4 Generic component tests Steam generator pressure relief and safety valves A-1.e. item 5 Preoperational Test Steam extraction system Test #27 Main Steam Test A-1.e. item 6 Generic component tests Turbine stop, control, bypass, and intercept valves A-1.e. item 7 MCS control system factory acceptance Main condenser hotwell level control testing (FAT) and site acceptance testing system (SAT)

A-1.e. item 8 Preoperational Test Condensate system Test #28 Feedwater Test Test #33-1,-2 TG Test A-1.e. item 9 Preoperational Test Feedwater system Test #28 Feedwater Test Test #33-1,-2 TG Test A-1.e. item 10 Preoperational Test Feedwater heater and drain systems Test #31 Heater Vents and Drains Test Power Ascension Test Test #102 Loss of FW Heater Test (50 and 90% power)

A-1.e. item 11 Preoperational Test Makeup water and chemical treatment Test #38 CVCS Test (makeup:

systems pressurizer level control)

A-1.e. item 12 Preoperational Test Main condenser off gas system used to Test #32 Condenser Air Removal Test maintain condenser vacuum main condenser off gas system used to maintain condenser vacuum Page 35 of 47

RG 1.68 Test Guidance NuScale Initial Test Program Test A-1.f. Waste Heat Rejections Systems Section A-1.f contains items that are waste heat rejection systems design features.

The waste heat rejection systems design feature that is not applicable to the NuScale design is Item 2.

A-1.f. item 1 Preoperational Test Circulating water system Test #10 Circulating Water System Test A-1.f. item 3 Preoperational Test Raw water system Test #13 Utility Water System A-1.f. item 3 Preoperational Test Service cooling water cooling Test #7 Reactor Component Cooling Water System Test A-1.f. item 3 Preoperational Test Ultimate heat sink system Test #11 Site Cooling Water System Test A-1.g. Electrical Systems Section A-1.g contains items that are electrical systems design features. The electrical systems design features that are not applicable to the NuScale design are:

Item 1.f. (load shedding features); items 2 and 3 (emergency AC power distribution system).

Items 1.a; 1.b.; 1.c (trip devices) and f.a. through f.e. are components tested by the generic component testing program.

Normal AC Power Distribution System: Power Ascension Tests Tests should demonstrate that the Test #105 Island Mode Test for NPM #1 integrated system will perform as designed Test #106 Island Mode Test for Multiple in response to simulated partial and full NPMs losses of offsite power sources. Tests also should demonstrate degraded protection systems designed to transfer from offsite to onsite power sources during degraded voltage conditions.

DC System: Preoperational Test Demonstrate the design capability of the PLS Test #60 component level tests ii.

emergency lighting systems. and iii.

DC System: Preoperational Test Demonstrate redundancy and electrical EDSS Test #57-1, #57-2 and #57-3 independence) and show that actual total (RG 1.41 Independence Test) system amperage loads are in agreement with design loads.

A-1.h. Engineered Safety Features Emergency Core Cooling System: Power Ascension Test #97 expansion and restraint tests Thermal Expansion Test #97 Page 36 of 47

RG 1.68 Test Guidance NuScale Initial Test Program Test Cold Water Interlocks (including logic, Preoperational Test circuitry, and final control devices used to MPS Test #63-6 prevent cold water injection into the reactor vessel)

A-1.i. Primary and Secondary Containments Section A-1.i contains items that are primary and secondary containment design features. The primary and secondary containment design features that are not applicable to the NuScale design are:

Items 1 (vacuum tests), 3 (in-leakage tests), 5, 6, 7, and 9 through 21.

A-1.i. item 1 Performed by vendor Containment design overpressure structural tests A-1.i. item 2 Preoperational Test Containment isolation valve functional test MPS Test #63-6 A-1.i. item 2 Preoperational Test Containment isolation valve closure timing MPS Test #63-7 tests A-1.i. item 3 Preoperational Test Containment isolation valve leakage tests CNT Test #43-1 A-1.i. item 4 Preoperational Test Containment penetration leakage tests CNT Test #43-1 A-1.j. Instrumentation and Control Systems I&C system testing is completed before the I&C systems care, custody, and control turnover from Construction to Startup.

Section A-1.i contains the following statement:

The following list illustrates instrumentation and control systems that should be included in the test program (some of these tests can be conducted in conjunction with the appropriate system level tests).

The list contains descriptions of control features or a system name, but does NOT list I&C systems.

Section A-1.i has 31 line items. The following items are design features that are not applicable to the NuScale design:

2, 4, 6-9, 11, 12, 14, 15, 16, 18, 20, 21 Section A-1.j The list contains items that are descriptions of control design features.

The following control design features are applicable to the NuScale design:

1, 3, 17, 19, 22 and 24 A-1.j. Item 1: Power Ascension Test Pressurizer pressure and level control Test #101 Step Change in Load Demand systems including transient response for Test (25, 50, 75, 100% power) pressurizer in-surge and out-surge Page 37 of 47

RG 1.68 Test Guidance NuScale Initial Test Program Test A-1.j. Item 3: Power Ascension Test Secondary system steam pressure control Test #101 Step Change in Load Demand system Test (25, 50, 75, 100% power)

Test #99 SG Level Control Test A-1.j. Item 17: Preoperational Test Feedwater heater temperature, level, and Test #27 Main Steam Test, component bypass control systems level test #iv A-1.j. Item 19: Preoperational Test Instrumentation and controls used for Test #107 Remote Shutdown shutdown from outside the control room Workstation Test A-1.j. Item 22: Preoperational Test Instrumentation that can be used to track Test #66-2 Safety Display and Indication the course of postulated accidents (such Test as containment wide range pressure indicators and reactor vessel water level monitors)

A-1.j. Item 22: Preoperational Test Instrumentation that can be used to track Test # 67 Fixed Area Radiation the course of postulated accidents (such Monitoring System as high radiation devices)

Test #9, 19, 24, 35, 36, 38, 41, and 42 valve or damper close on high radiation signal.

A-1.j. Item 24: Annunciators for reactor control and Annunciators for reactor control and engineered safety features are engineered safety features contained in the MPS system which is tested before the MPS care, custody, and control transfer to Startup Section A-1.j The list contains items that are names to describe systems. The following systems are applicable to the NuScale design:

5, 10, 13, 26, 28, and 31 A-1.j. Item 5: Preoperational Test Reactor coolant system leak detection Test #41-3 Containment Evacuation systems System A-1.j. Item 10: Preoperational Test Seismic instrumentation Test #69 Seismic Monitoring System (provided by COL)

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RG 1.68 Test Guidance NuScale Initial Test Program Test A-1.j. Item 13: Preoperational Test In-core and ex-core neutron Test #63-4 NMS neutron flux data to instrumentation MPS Low Power Test Test # 86 Determination of Zero-Power Physics Testing Range Test Power Ascension Test Test #91 Core Power Distribution Map Test Test #92 Neutron Monitoring System Power Range Flux Calibration Test Test #98 Control Rod Misalignment Test A-1.j. Item 26: Preoperational Test Component cooling water Test #7 Reactor Component Cooling Chilled water Water System Ultimate heat sink Test # 11 Site Cooling Water System Test #8 Chilled Water System (no test for ultimate heat sink)

A-1.j. Item 28: Preoperational Test Fire water system Test #25 Fire Protection System Test A-1.j. Item 31: Process computers are tested before the Process computers computers care, custody, and control transfer to Startup Section A-1.j The list contains items that are tests applicable to the NuScale design:

7 A-1.j. Item 7: Preoperational Test Leak detection test used to detect failures Test #43-1 Containment System Test in the ECCS and containment A-1.k. Radiation Protection Systems Appropriate tests should be conducted to demonstrate the proper operation of the following types of systems and components used to monitor or measure radiation levels, provide for personnel protection, or control or limit the release of radioactivity:

A-1.k. Item 1: Preoperational Test Test process, criticality, effluent, and area Test #67 Fixed Area Radiation Monitor radiation monitors. System Test #9, 19, 24, 35, 36, 38, 41, and 42 Valve or damper close on high radiation signal.

A-1.k. Item 2: COL responsibility Test personnel monitors and radiation survey instruments.

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RG 1.68 Test Guidance NuScale Initial Test Program Test A-1.k. Item 3: COL responsibility Test laboratory equipment used to analyze or measure radiation levels and radioactivity concentrations.

A-1.k. Item 4: Commodity item. Component test Test high-efficiency particulate air filters and charcoal adsorbers.

A-1.k. Item 5: Preoperational Test Test leakage detection system sensitivity Test #41-3 Containment Evacuation and capability meets TS leakage detection System guidance in Regulatory Guide 1.45 (Ref.

25). This may include leakage detection Reference COL Item 5.4-1.

system sensitivity and capability to detect RCS leakage from Steam Generators within the guidance in Nuclear Energy Institute (NEI) 97-06, Steam Generator Program Guidelines, (Ref. 26) and in Electric Power Research Institute (EPRI)

TR-1008219, PWR Primary-to-Secondary Leak Guidelines, (Ref. 27) (e.g., radiation monitor detection sensitivity is 30 gallons per day or 1.25 gallons per hour).

A-1.k. Item 6: COL responsibility Test radiation monitor computer system.

A-1.k. Item 7: COL responsibility Test radiation data transmission to the emergency response data system.

A-1.l. Integrity of Systems Outside of Containment that Contain Radioactive Materials In accordance with the requirement in COL Responsibility

§50.34(f)(2)(xxvi), applicants shall provide Reference COL Item 9.3-1.

for a leakage control and detection program in the design of systems outside containment that could contain radioactive material following an accident. As part of the initial test program, applicants shall submit a leakage control program, a schedule for retesting the systems, and actions taken to minimize leakage from these systems. The tests should include leak rate test results and a discussion of actions to reduce leakage from systems outside containment that could contain radioactive fluids or gases during or following a serious transient or accident.

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RG 1.68 Test Guidance NuScale Initial Test Program Test A-1.m. Radioactive Waste Handling and Storage Systems Section A-1.m has 12 line items. Items #3, #5 and #6 are design features that are not applicable to the NuScale design.

A-1.m. The following list illustrates the systems, components, and features for which the test program should demonstrate operability:

A-1.m. item 1 Preoperational Test Liquid radioactive waste handling systems Test #35 Liquid Radwaste System A-1.m. item 2 Preoperational Test Gaseous radioactive waste handling Test #36 Gaseous Radwaste System systems A-1.m. item 4 Preoperational Test Solid waste handling systems and resulting Test #37 Solid Radwaste System waste products complying with waste classification and characteristic requirements A-1.m. item 7 Preoperational Test Isolation features for ventilation systems CRVS Test #19-4 and diversion of exhaust flows to GRWS Test #36-vii and viii HEPA/charcoal filtration subsystems CFDS Test 42-4 and 42-55 A-1.m. item 8 Preoperational Test Isolation features for liquid radioactive LRWS Test 35-vi waste effluent systems and diversion of effluent flows to appropriate subsystems A-1.m. item 9 Generic component testing Isolation features (process interlocks, backflow preventers, differential pressures, etc.) of waste processing subsystems, as equipped, in preventing the cross contamination of nonradioactive systems and avoiding unmonitored and uncontrolled radioactive releases A-1.m. item 10 Preoperational Test Operability of plant process and effluent PSS Test #53 sampling systems for expected types of media Page 41 of 47

RG 1.68 Test Guidance NuScale Initial Test Program Test A-1.m. item 11 COL operating procedures Testing of liquid and wet waste solidification subsystems in verifying that residual amounts of free liquid present in process packaged wastes conform with regulatory requirements and waste acceptance criteria A-1.m. item 11 COL operating procedures For waste processing system supplemented with mobile skid-mounted processing equipment, as equipped, testing should include the hydraulic integrity of connections carrying radioactive fluids between mobile processing equipment and permanently installed plant subsystems.

A-1.n. Fuel Storage and Handling Systems Appropriate tests should be conducted to demonstrate that equipment and components used to handle or cool irradiated and non-irradiated fuel will operate in accordance with design.

The following list illustrates the equipment and component tests that the program should include:

A-1.n. item 1 Preoperational Test Spent fuel pool cooling system tests SFPC Test #1 A-1.n. item 1 Spent fuel pool cooling system alarms Spent fuel pool cooling system high are tested by the PCS FAT and SAT radiation alarms, and low-water-level before care, custody, and control of the alarms system from Construction to Startup.

A-1.n. item 1 Manual operator action performed with Spent fuel pool water makeup operating procedure.

A-1.n. item 2 Generic component testing Refueling equipment tests, including hand tools, power equipment, bridge and overhead cranes, and grapples.

A-1.n. item 3 The PLDS is described in Section Operability and leak tests of sectionalizing 9.1.3.2.5 Leakage from the UHS liner devices and drains and leak tests of gravity drains to the radiation waste gaskets or bellows in the refueling canal drain system (RWDS). RWDS Test #23-and fuel storage pool. 2 tests the MCR alarm when the RWDS sump fill rate exceeds the PLDS leakage rate setpoint.

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RG 1.68 Test Guidance NuScale Initial Test Program Test A-1.n. item 4 Preoperational Test Static and dynamic load testing of cranes, FHE Test #51 hoists A-1.n. item 4 Generic component testing Static and dynamic load testing of lifting and rigging equipment Static and dynamic load testing of fuel Not applicable to DCA cask A-1.n. item 5 Preoperational Test Fuel transfer devices FHE Test #51 A-1.n. item 6 Preoperational Test Irradiated fuel pool or building ventilation RBVS Test #20 system tests A-1.n. item 7 Preoperational Test Computerized automated fuel handling FHE Test #51 systems, programming, indexing, data base controls for fuel storage information and interlocks should be tested for proper operation.

A-1.n. item 8 Generic component testing Equipment in the fuel cavity, including reactor vessel seals, vessel seal leakage detection, refueling cavity fuel storage handling equipment including temporary fuel storage racks and weir gates should be tested for proper operation.

A-1.n. no item # Preoperational Test Refueling equipment testing should FHE Test #51 demonstrate the operability of protective interlocks and devices.

A-1.n. no item # RBC Test #52 Static testing of cranes, hoists, and associated lifting and rigging equipment should be at 125 percent of rated load, and full operational testing should be at 100 percent of rated load.

A-1.o. Auxiliary and Miscellaneous Systems The following list illustrates the types of systems and features for which performance should be demonstrated by testing:

Section A-1.o has 26 numbered line items. Items 8, 12, 14b, 14g, 15, 16, 17, 21, 22, 23, 24 and 26 are design features that are not applicable to the NuScale design.

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RG 1.68 Test Guidance NuScale Initial Test Program Test A-1.o. item 1 Preoperational Test Service and raw water cooling ultimate SCWS Test #11 heat sink systems A-1.o. item 2 Preoperational Test Closed-loop cooling water systems RCCWS Test #7 CHW Test #8 A-1.o. item 3 Preoperational Test Component cooling water and chilled water SCWS Test #11 systems RCCWS Test #7 CHW Test #8 A-1.o. item 4 Preoperational Test Reactor coolant makeup system CVCS Test #20 A-1.o. item 5 Preoperational Test Reactor coolant and secondary sampling PSS Test #53 systems A-1.o. item 6 Preoperational Test Chemistry control systems for the reactor CVCS Test #20 coolant and secondary coolant systems FWT Test #29 Power Ascension Test Test #79 Primary and Secondary System Chemistry Test A-1.o. item 7 Preoperational Test Fire protection systems (including FPS Test #25 demonstrations of proper manual and automatic operation of fire detection, alarm, suppression, and smoke control systems A-1.o. item 9 Vent and drain systems (for contaminated or potentially contaminated systems and areas), and drain and pumping systems serving essential areas (e.g.,

spaces housing diesel generators, essential electrical equipment, and essential pumps);

A-1.o. item 10 Preoperational Test Purification and cleanup systems for the CVCS Test #20 reactor coolant system Page 44 of 47

RG 1.68 Test Guidance NuScale Initial Test Program Test A-1.o. item 11 Compressed gas system supplying pneumatic equipment, components, or instrumentation that are required to function to support the normal operation of the facility A-1.o. item 13 Preoperational Test Communication systems COMS Test #68 A-1.o. item 14 Heating, cooling, and ventilation systems serving the following areas should meet the guidance in RG 1.140:

A-1.o. item 14.a Preoperational Test Spaces housing engineered safety RBVS Test #20 features CRVS Test #19 A-1.o. item 14.c Preoperational Test Battery rooms RBVS Test #20 CRVS Test #19 TBVS Test #22 A-1.o. item 14.d COL Item Diesel generator buildings A-1.o. item 14.e COL Item Auxiliary building A-1.o. item 14.e Preoperational Test Reactor building RBVS Test #20 A-1.o. item 14.e Preoperational Test Turbine building TBVS Test #22 A-1.o. item 14.e Preoperational Test Radioactive waste handling building RWBVS Test #22 A-1.o. item 14.f Preoperational Test Control room habitability systems CRHS Test #18 A-1.o. item 14.h Preoperational Test Fuel storage and handling area ventilation RBVS Test #20 system A-1.o. item 18 Generic component testing Heat tracing for freeze protection A-1.o. item 19 Preoperational Test Emergency lighting for safe egress, post RBVS Test #20 accident vital areas, and emergency facilities Page 45 of 47

RG 1.68 Test Guidance NuScale Initial Test Program Test A-1.o. item 20 Generic component testing Cathodic protection system for corrosion control of underground and submerged metallic surfaces (i.e., buried carbon steel pipes and tanks)

A-1.o. item 25 The PLDS is described in Section Leakage detection from the spent fuel 9.1.3.2.5 Leakage from the UHS liner pool, refueling cavity gravity drains to the radiation waste drain system (RWDS). RWDS Test #23-2 tests the MCR alarm when the RWDS sump fill rate exceeds the PLDS leakage rate setpoint.

A-1.o. no item # Preoperational Test Communication system tests should COMS Test #68 include demonstrations of the proper operation of evacuation and other alarms, the public address system within the plant, systems that may be used if the plant is required to be shut down from outside the control room, and communication systems required by the facilitys emergency plan.

This testing may include a check for frequency interferences from emergency communication devices used at multi-unit sites or other communication devices.

A-1.o. no item # Preoperational Test Control room habitability system testing CRVS Test #19 should include, as appropriate, CRHS Test #18 demonstrations of the proper operation of smoke and toxic chemical detection systems and ventilation shutdown Leak-tightness of ducts is tested by Construction.

devices, including leak-tightness of ducts and flow rates, proper direction of airflows, and proper control of space temperatures.

A-1.p. Reactor Component Handling Systems Include the following activities:

A-1.p. item 1 Preoperational Test Conduct dynamic and static load tests (see RBC Test #52 footnote 14) of cranes, hoists, and associated lifting and rigging equipment (e.g., slings and strong backs used during refueling or the preparation for refueling).

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RG 1.68 Test Guidance NuScale Initial Test Program Test A-1.p. item 2 Preoperational Test Conduct full operational testing of cranes, RBC Test #52 hoists, and associated lifting and rigging equipment at 100 percent of rated load.

A-1.p. item 3 Preoperational Test Conduct static testing of cranes, hoists, RBC Test #52 and associated lifting and rigging equipment at 125 percent of rated load A-1.p. item 4 Preoperational Test Demonstrate operability of protective RBC Test #52 devices and interlocks.

A-1.p. item 5 Preoperational Test Demonstrate operability of safety devices RBC Test #52 on equipment.

A-1.p. item 6 Preoperational Test Demonstrate clearance for safe movement RBC Test #52 of heavy loads through designated paths.

A-1.p. item 7 Preoperational Test Demonstrate operability of reactor RBC Test #52 component handling equipment in the refueling cavity and the spent fuel pool.

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