ML19007A375
| ML19007A375 | |
| Person / Time | |
|---|---|
| Issue date: | 12/18/2018 |
| From: | Michael Snodderly Advisory Committee on Reactor Safeguards |
| To: | |
| Snodderly M | |
| References | |
| NRC-0002 | |
| Download: ML19007A375 (253) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
NuScale Subcommittee Meeting Docket Number: N/A Location: Rockville, MD Date: 12-18-18 Work Order No.: NRC-0002 Pages 1-253 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 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 (ACRS) 6 + + + + +
7 NuSCALE SUBCOMMITTEE 8 + + + + +
9 TUESDAY 10 DECEMBER 18, 2018 11 + + + + +
12 ROCKVILLE, MARYLAND 13 + + + + +
14 The Subcommittee met at the Nuclear 15 Regulatory Commission, Three White Flint North, Room 16 1C3 & 1C5, 11601 Landsdown Street, at 1:00 p.m.,
17 Harold B. Ray and Peter Riccardella, Co-Chairmen, 18 presiding.
19 20 COMMITTEE MEMBERS:
21 HAROLD B. RAY, Co-Chairman 22 PETER RICCARDELLA, Co-Chairman 23 MICHAEL L. CORRADINI, Member 24 RONALD G. BALLINGER, Member 25 DENNIS C. BLEY, Member*
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2 1 CHARLES H. BROWN, JR., Member 2 MARGARET SZE-TAI Y. CHU, Member*
3 WALTER KIRCHNER, Member 4 JOSE MARCH-LEUBA, Member 5 JOY L. REMPE, Member 6 GORDON R. SKILLMAN, Member 7 MATTHEW W. SUNSERI, Member 8
9 DESIGNATED FEDERAL OFFICIAL:
10 MIKE SNODDERLY 11 12 13 *Present via telephone 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 1 T-A-B-L-E O-F C-O-N-T-E-N-T-S 2
3 Opening Remarks, Harold Ray, ACRS.. . . . . . . . 4 4 Overview of Chapter 17, "Quality Assurance. . . . 11 5 and Reliability Assurance," NuScale Design 6 Certification Application 7 Chapter 17, "Quality Assurance and. . . . . . . . 14 8 Reliability Assurance," Safety 9 Evaluation With Open Items 10 Overview of Chapter 2, "Site Characteristics. . . 88 11 and Site Parameters," NuScale Design 12 Certification Application 13 Chapter 2, "Site Characteristics and Site.. . . . 91 14 Parameters," Safety Evaluation With 15 Open Items (Open Session) 16 Discussion. . . . . . . . . . . . . . . . . . . 149 17 Adjourn.. . . . . . . . . . . . . . . . . . . . 162 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 P-R-O-C-E-E-D-I-N-G-S 2 1:02 p.m.
3 CO-CHAIR RAY: The meeting will now come 4 to order. This is a meeting of the Advisory Committee 5 on Reactor Safeguards, NuScale Subcommittee. I'm 6 Harold Ray and I'll serve as co-chairman for today's 7 Subcommittee meeting along with Pete Riccardella.
8 Members in attendance are Members Rempe, 9 Kirchner, Corradini, Riccardella, Skillman, Sunseri, 10 March-Leuba, Ballinger, and Brown. Members Dennis 11 Bley and Margaret Chu are participating via 12 teleconference as we just heard. Mike Snodderly is 13 the designated federal official for the meeting.
14 The Subcommittee will review the status 15 evaluation of Chapter 2, Site Characteristics and Site 16 Parameters, and Chapter 17, Quality Assurance and 17 Reliability Assurance of NuScale Design Certification 18 Application. Today we have members of the NRC staff 19 and NuScale to brief the Subcommittee.
20 The ACRS was established by statute and is 21 governed by the Federal Advisory Committee Act, FACA.
22 That means the Committee can only speak through its 23 published letter reports. We hold meetings to gather 24 information to support our deliberations.
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5 1 can contact our office requesting time after the 2 meeting announcement is published in the Federal 3 Register. That said, we set aside 10 minutes for 4 comments from members of the public attending or 5 listening to our meetings. Written comments are also 6 welcomed.
7 The ACRS section of the U.S. NRC public 8 website provides our charter by-laws, letter reports, 9 and full transcripts of all full and subcommittee 10 meetings including slides presented there. We may 11 close the meeting after the open portion to discuss 12 proprietary material and presenters can defer 13 questions that should not be answered in the public 14 session to that time.
15 No written statement or request for making 16 an oral statement to the Subcommittee has been 17 received from the public concerning this meeting. A 18 transcript of the meeting is being kept and will be 19 made available. Therefore, we request that 20 participants in this meeting use the microphones 21 located throughout the meeting room -- actually, 22 behind me here, I believe.
23 When addressing the Subcommittee 24 participants should first identify themselves and 25 speak with sufficient clarity and volume so that they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 can be readily heard.
2 We have a bridge line established to the 3 public to listen to the meeting. To minimize 4 disturbance the public line will be kept in a listen 5 only mode. To avoid disturbance I request that 6 attendees in the room put their electronic devices 7 like cell phones in the off or noise-free mode.
8 To accommodate the availability of 9 interested members, we will begin with Chapter 17.
10 And, of course, as always, any member can participate 11 at any time, but Mike Corradini will take the lead on 12 Reliability Assurance Program matters and I will do so 13 on the rest of the chapter overall.
14 Because we have to share the half-day 15 meeting with discussion of Chapter 2, which will be 16 led by Pete Riccardella, as I mentioned, and we have 17 members who need to get off to the airport this 18 evening, I'll begin both the discussion of Chapter 2 19 with NuScale and with the staff by stating a couple of 20 items that I believe deserve focused responses and I 21 hope can receive them.
22 As always, our aim is to resolve questions 23 at Subcommittee if at all possible.
24 Does staff management have any comments?
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7 1 but, hearing none, we'll proceed.
2 Okay. NuScale is at the table on the 3 opposite here so let me do as I said I would and give 4 you a couple of items that I hope we can address 5 during the limited time we have.
6 Regarding the Quality Assurance Program 7 Revision 3 of the NuScale Topical Report has been 8 found acceptable as documented in the final Safety 9 Evaluation issued September 22, 2016. This revision 10 is referenced in Section 17.5 of the final Safety 11 Analysis Report and it is identified there as 12 nonproprietary.
13 Section 2.3.1 of the Topical Report is 14 entitled "Design Verification" and it includes the 15 statement that, "NuScale normally completes design 16 verification activities before the design outputs are 17 used by other organizations for design work and before 18 they're used to support other activities such as 19 procurement or testing.
20 Procedures are established that require 21 identification and control of any portion of the 22 design where verification has not been completed.
23 When such timing cannot be achieved, the design 24 verification is completed before relying on the item 25 to perform its intended design or safety function."
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8 1 One of the items of interest to us is the 2 procedures referred to in this statement. In its 3 letter dated July 24, 2017, NRC reported the results 4 of an initial inspection which included design 5 control.
6 It included substantial discussion related 7 to the implementation of the procedure for open design 8 item management. We will refer to open design items 9 as ODIs. At the time of the inspection a year-and-a-10 half ago, there were over 1,500 ODIs.
11 The inspection report includes a statement 12 that neither the design control process, nor the ODI 13 procedure, have a requirement to establish a date or 14 event, such as DCH submittal, to close the ODI. It 15 indicates that NuScale stated only that they would 16 need to be closed "prior to the affected systems, 17 structures, or components being considered operable."
18 And that ODIs do not need to be closed prior to DCA 19 submittal.
20 Personally, I've been involved as an 21 applicant in three separate Part 50 construction 22 permit applications each for a new plant design. One 23 of them was a HTGR. I completely understand the 24 necessity to accept and track unverified design 25 assumptions at that stage in the process.
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9 1 So my first question is about how you're 2 implementing the requirement in Section 2.3.1 of your 3 Topical Report to ensure that design verification is 4 completed before relying on the item to perform its 5 intended design or safety function in this somewhat 6 different process involving the initial stage of 7 design certification.
8 I believe the second question I would like 9 to ask up front just involves the wording that I find 10 confusing concerning applicability of the QA program.
11 Section 17.5 of the NuScale FSAR states 12 that the QA program description for the standard 13 design is provided in the Topical Report and that "a 14 COL applicant that references the NuScale power plant 15 design certification will describe the Quality 16 Assurance Program applicable to site-specific design 17 activities and to the construction and operation 18 phases." That's a clear and consistent statement 19 concerning the respective responsibilities of NuScale 20 and a COL applicant.
21 However, a seemingly different description 22 appears elsewhere including on the NuScale slide 4 to 23 be presented shortly, and in the staff SER Section 24 17.5.1 where it says that, "The QA program description 25 submitted by NuScale addresses the design QA NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 1 activities in support of design certification. The 2 NuScale QA program description does not address 3 construction and design through activities that occur 4 once construction begins."
5 I don't read this the same as in the FSAR, 6 especially given that the design activities are 7 expected to continue after design certification and 8 before approval of a future COLA. I think it's just 9 a wording problem that needs to be -- I need to be 10 clarified on at least.
11 With that, those two items, Mike, is there 12 anything you want to say about reliability assurance 13 at this time?
14 MEMBER CORRADINI: No. I think we'll wait 15 and get them when we get the 17.4.
16 CO-CHAIR RAY: As we go if we don't go by 17 the numbers.
18 Okay. With that, I will call on Paul 19 Infanger of NCO to begin today's presentations.
20 MR. INFANGER: My name is Paul Infanger.
21 I am license and project manager at NuScale. I've 22 been doing licensing for about 35 years, 25 years in 23 the operating fleet. I was licensing manager at 24 Crystal River and Turkey Point. Later I was licensing 25 manager in Part 52 space for the EPR with UniStar.
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11 1 I've been with NuScale for about three-and-a-half 2 years. I went to Iowa State University and have a 3 masters in nuclear engineering.
4 CO-CHAIR RAY: Paul your microphone is on, 5 isn't it? You have a strong enough voice that I can't 6 tell.
7 MR. INFANGER: Okay. Yeah, I'm on.
8 I'm going to be presenting the Quality 9 Assurance portion of the Chapter 17 presentation. The 10 D-RAP portion will be with my cohort here Mr. Patrick 11 Conley.
12 Patrick, why don't you give a little 13 background on yourself.
14 MR. CONLEY: Yes. My name is Patrick 15 Conley. I'm the programs engineer for NuScale Power.
16 I've been with the company about two-and-a-half years.
17 Before NuScale I was at the Vogtle construction 18 project on 3 and 4 where I was in quality assurance 19 with ITAAC procedures as well. I left that to come to 20 NuScale for an opportunity to do some design.
21 Prior to that I received my degree from 22 Auburn University in --
23 MEMBER BLEY: Excuse me. Could you talk 24 into the microphone a little better? I can't hear 25 online.
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12 1 MR. CONLEY: Is that better?
2 MEMBER BLEY: Yes.
3 MR. CONLEY: Prior to that I was in the 4 Nuclear Navy as a machinist mate and that's how I got 5 my interest in nuclear power.
6 MR. INFANGER: Thank you, Patrick.
7 Moving on to slide 2, just an overview of 8 Chapter 17 which includes the Quality Assurance 9 Program and Design Reliability Assurance Program, D-10 RAP.
11 The Quality Assurance Program is 12 established in accordance with 10 CFR 50 Appendix B, 13 and ASME NQA-1-2008 with the 2009 addenda which is 14 endorsed by Req. Guide 1.28.
15 Consistent with the guidance in the NUREGs 16 and also we use the NEI template for the QAPD, Quality 17 Assurance Program Description. It consist of our 18 Topical Report which is approved and has a dash A, and 19 the Quality Management Plan which identifies 20 requirements fully implemented in the requirements now 21 within the scope of design phase but may be 22 implemented in the future. We have implementing 23 procedures as listed in the Quality Management Plan.
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13 1 three sections pretty much just point to 17.5 which 2 has a brief description that we follow the Topical 3 Report for the Quality Assurance Program and has the 4 COL items for the applicants to provide information 5 during the construction and operation phases. The 6 QAPD for NuScale is just for the design certification 7 phase.
8 CO-CHAIR RAY: Okay. You're not going to 9 go beyond that without answering my question, are you?
10 MR. INFANGER: Okay.
11 CO-CHAIR RAY: Because that's certainly 12 not what the Topical Report said. It says it deals 13 with essentially everything except site-specific 14 design activities, but it doesn't end when the design 15 certification is issued. Anyway, I'm repeating 16 myself. Go ahead.
17 MR. INFANGER: The COL item indicates that 18 the NuScale QAPD provides in the Topical Report what 19 we believe is needed for design certification. The 20 template includes some portions that will be 21 applicable later, but the applicant is responsible for 22 everything after the design certification phase. It's 23 not itself -- it's not a stand-alone document for the 24 applicants.
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14 1 back to the folks back at NuScale to see if I can get 2 some additional collaboration on that?
3 CO-CHAIR RAY: Absolutely. I just want to 4 be really clear as to what the heck the question is 5 that we're talking about here. I'm trying to find the 6 words here. Go ahead. I'll come back to this in a 7 second.
8 MR. INFANGER: NuScale, come up, Carolyn 9 or someone in the QA organization who can fill in more 10 details.
11 MS. MONACO: Yeah, good afternoon. This 12 is Carolyn Monaco, the Director of Quality here at 13 NuScale. I'm in the Corvallis offices.
14 Responding to the structure of the QAPD, 15 the activities that NuScale will do are QAPD will 16 carry us forward into working with the applicant when 17 we get to site-specific stages.
18 Our program will cover our design 19 activities as we go forward as well. Should the 20 applicant want to designate additional activities to 21 us, then we'll obviously work with them as appropriate 22 as we go forward.
23 CO-CHAIR RAY: Well, the way I interpret 24 what you just said is consistent with what the FSAR 25 states and the Topical Report states which is that the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 1 QA program description for the standard design forget 2 about design certification.
3 The QA program for the standard design is 4 provided in the Topical Report. That's what it says 5 plainly. It doesn't say that the standard design will 6 transition to some other QA program at some indefinite 7 time after the design certification is approved or 8 issued. That's what is said elsewhere and that's what 9 continues to be confusing.
10 A COL applicant it says in the FSAR, 11 Section 17.5, "References a NuScale power plant 12 applicable to site-specific design activities and to 13 construction and operation." That is absolutely fine.
14 No problem. The issue is does the QA program that 15 we're talking about here today only apply to design 16 certification and not thereafter?
17 MS. MONACO: I think the difference or the 18 language may be that our program could be used and 19 carried forward into site design and certain 20 construction aspects, but the applicant could also 21 choose to use a different program, their own program.
22 CO-CHAIR RAY: That's right, but I'm 23 asking what NuScale is going to use for its design 24 activities after certification. That's what is clear 25 in the FSAR but not at all clear in these other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 citations I've given you.
2 It sounds like the QA program that we're 3 talking about today only applies to design 4 certification and it will be something imposed by a 5 future customer, COL applicant, on you for work on the 6 certified design after it's issued, and there's a lot 7 of work to be done as we all know.
8 Whereas, what you say in the FSAR is, "No, 9 this QA program is for the certified design full 10 stop." Not for site-specific activities. That's 11 clearly the COL applicant. And also the construction 12 and operation. That's the COL application just like 13 the FSAR says.
14 Well, listen I don't want to take up more 15 time now. I guess the question is clear but the 16 answer is not. We can always take note of it and seek 17 further clarification later.
18 MEMBER SKILLMAN: I want to weigh in on 19 this because I've got the same comment. Let me read 20 text from the SER, Section 17.0. This is exactly what 21 Harold pointed to. Actually, this in the SER. "The 22 NuScale QAPD Topical Report covers the activities 23 associated with the certification of the NuScale power 24 plant."
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17 1 the question. "The QAPD is based on the applicable 2 portions of Appendix B." I'll stop there. Which 3 portions of Appendix B are not applicable?
4 CO-CHAIR RAY: Okay. I think we've posed 5 the question clearly enough and I don't want to get 6 into a bog-down debate. We're asking for a clear 7 answer and we'll just have to move on.
8 MEMBER SKILLMAN: That's good. Thanks.
9 CO-CHAIR RAY: Please go ahead, Paul.
10 MR. INFANGER: There's a number of COL 11 items in Chapter 17. They describe the Reliability 12 Assurance Program to be conducted during operations.
13 The site-specific SSCs in the RAP identify QA controls 14 for the RAP. They describe the QAP applicable to 15 site-specific construction and operation. The last 16 one in 17.6 is just a COL items that the application 17 has to have a maintenance rule program in conformance 18 with 10 CFR 50.65.
19 CO-CHAIR RAY: The wording, by the way, 20 for the RAP QA is different than what we just debated 21 here about the Appendix B and in QA 1 applicable 22 requirements. The QA program controls for the 23 Reliability Assurance Program are as stated here, 24 "during site-specific design procurement instruction, 25 but they are specified as opposed to being left at the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 1 COL holder."
2 It just seems strange why the Reliability 3 Insurance Program and the Appendix B ASME Section 3 of 4 the program are treated differently in this regard.
5 MEMBER BLEY: It sounds like somebody is 6 not muted. It's really noisy on the line.
7 CO-CHAIR RAY: It sounds like what, 8 Dennis?
9 MEMBER CORRADINI: Somebody has to mute 10 their line, please, because we are hearing background 11 noise.
12 CO-CHAIR RAY: Thank you. I don't mean to 13 bug you, Paul. I just want to get the record 14 straight. Please proceed.
15 MR. INFANGER: Okay. We had three RAIs on 16 Chapter 17. All of them are resolved and closed. The 17 topics are listed there. One was on the CVCS, one on 18 the expert panel, and one on the backup power 19 supplies.
20 MEMBER CORRADINI: We are going to come 21 back to the first for these, right? Is that correct?
22 Is Patrick going to come back and talk about the 23 expert panel CVCS later?
24 MR. INFANGER: We can talk about D-RAP and 25 include the expert panel.
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19 1 With that I'm going to introduce again 2 Patrick for the D-RAP process.
3 MR. CONLEY: Thank you, Paul.
4 Can everyone hear me okay? Okay. So our 5 D-RAP process was modeled after complies with NUREG 6 800 Section 17.4. We do have a process that documents 7 and controls that process of D-RAP including the 8 expert panel.
9 All of the SCCs, of course, were looked at 10 for cauterization. The initial determination was 11 declared by the subject matter expert and system 12 engineer. Then it was confirmed through deliberation 13 with the expert panel which makes the final decision.
14 Our expert panel did consist of a diverse 15 group of personnel including design engineering, 16 operations, PRA, and safety analysis. We also had a 17 licensing member but they were a non-mandatory member.
18 They could vote but it wasn't required for a quorum.
19 MEMBER CORRADINI: So these are internal 20 to NuScale or these are external people?
21 MR. CONLEY: These are internal to 22 NuScale.
23 MEMBER CORRADINI: Internal?
24 MR. CONLEY: Yes, sir.
25 MEMBER CORRADINI: Okay.
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20 1 MR. CONLEY: Next slide, please.
2 Our PRA report is based upon the Topical 3 Report we submitted. You can see the number there, 4 the risk significance determination process, Rev. 0.
5 As far as classification, we always assumed that a 6 component was classified as risk significant unless 7 PRA told us otherwise. We didn't start at the bottom 8 and work out way up. We started at the top and worked 9 our way down.
10 The engineering change control process 11 determines if an expert panel is needed. We allow the 12 engineering change control process to change the 13 design and then, as part of that process, the expert 14 panel will be determined if it's needed for further 15 classification.
16 Next slide, please. If you look at 17 17.4.3.3 it states that the process for evaluating 18 SSCs for regulatory treatment. It's described in 19 19.3. We had no RTNSS criterion met and, therefore, 20 we had no RTNSS SSCs in the design.
21 MEMBER CORRADINI: Let me ask a question 22 since one of our experts is on the line, but I'm sure 23 he's going to jump in. If the PRA identifies by your 24 risk-significant measures that something is not 25 meeting the criterion, but later component reliability NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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21 1 testing of a particular component changes such that it 2 might, does this all occur prior in the DCD portion of 3 the analysis, or is this a COL item that the applicant 4 has to deal with in terms of --
5 MR. CONLEY: As far as updates to the PRA?
6 MEMBER CORRADINI: Yes. In terms of if 7 there's an update to the PRA that something's 8 reliability estimate after testing is different. It 9 rises. Is it up to the COL applicant to deal with the 10 change in what's in the D-RAP and then it falls into 11 the old RAP? That's what I didn't understand.
12 MR. CONLEY: We do have COL items in 13 Chapter 17 and there are other COL items in 19 that 14 deal with the site-specific portion. As far as the 15 follow-up PRA prior to that, if there's information 16 that is gained.
17 Sarah, can you speak, please to the 18 process of update as needed? I know we frequently 19 look at updates, but I'm not sure of that process 20 entirely.
21 MS. BRISTOL: Yeah, this is Sarah Bristol.
22 In a PRA update if a candidate rose to the level of 23 potential risk significance, the candidate would be 24 then brought to the D-RAP board for consideration 25 either during the DCA phase or, as you mentioned, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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22 1 there is a COL item to go back and look at those 2 candidates again at the COL stage.
3 MEMBER CORRADINI: So is that -- so I 4 guess I don't understand the process. Let me take an 5 example. Let's say one of the RRV valves assume 6 probability of failure or reliability is some value 7 and after testing it rises. Then that changes the 8 analysis that something falls into a RTNSS. Whose 9 responsibility is that to identify it and track it?
10 Is it the COL applicant? Is it NuScale as the holder 11 of the DCD? I'm not clear.
12 MR. GREENWOOD: This is Dustin Greenwood 13 at NuScale.
14 MEMBER CORRADINI: Can you guys speak 15 louder? Can you guys get closer to the mic?
16 MR. GREENWOOD: This is Dustin Greenwood 17 at NuScale. Sorry about that. At any phase during 18 the COLA or the DCA this identified through testing, 19 then it would be through our engineering change 20 control process and gets filtered through the D-RAP.
21 In general, the entire process goes 22 through the Operational Reliability Assurance Program 23 after procurement of a specific item. So to determine 24 the maintenance in the M rule requirements, this 25 entire process will be done again with the site-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 1 specific PRA and all of the actual design components.
2 So our process and our change control 3 process would capture something if we identified it 4 during this phase but, in general, to ensure that it 5 happened, this whole program is done again during the 6 construction phase and needs to be verified prior to 7 going into operation.
8 MEMBER CORRADINI: Okay. Thank you.
9 CO-CHAIR RAY: Excuse me for just a 10 second. Let me just ask one question because it's 11 pertinent to Appendix B also.
12 When we say we're talking about a holder 13 of an approved combined operating license, right, it's 14 not just somebody who has applied for a combined 15 license and work is ongoing. Not site work but 16 there's other work ongoing. We're not talking about 17 the COLA holder at that time. It's only after the 18 COLA is approved that their status is what you just 19 said. Is that correct?
20 MR. GREENWOOD: This is Dustin. I'm not 21 sure if that question was directed at me.
22 CO-CHAIR RAY: To NuScale generally.
23 MEMBER CORRADINI: It's addressed to 24 NuScale so whoever can answer.
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24 1 question, is there a transition from one process to 2 the other?
3 CO-CHAIR RAY: Well, I'm more worried 4 about the gap than the transition. In other words, 5 having been through AP1000, as an example, a real-life 6 thing that went into construction, the idea that on 7 the day that the COLA is approved, suddenly things 8 change and prior to that time they were as they were 9 back to the beginning of time is not something we're 10 familiar with in real experience.
11 What we're familiar with is the design 12 certification holder retains responsibility under the 13 programs described in the design certification, even 14 though it's been approved three years ago, to do what 15 they are doing in accordance with that program.
16 That's the way I read your FSAR, by the way.
17 MR. CONLEY: Yes.
18 CO-CHAIR RAY: But it's all the other 19 discussion that has got us terribly confused because 20 it sounds like once the design certification is 21 issued, we go into a space that isn't defined until 22 the COLA is approved at which time then the COLA 23 becomes effective for the things that are taking place 24 then whether it's the D-RAP or whatever else it may 25 be. I'm sure that's not what you intend but it's what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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25 1 you can read in this is what I'm saying.
2 MR. CONLEY: I understand how you view it 3 and I appreciate your comment. It is not our intent.
4 MEMBER CORRADINI: So help us. What is 5 the bridge? Because my next question is going to be 6 in the SE, the draft SE that we have in front of us, 7 there's an open item about that there's nothing from 8 D-RAP in ITAAC.
9 My thought was before I read this that the 10 logical thing is thou shall go and do this as an ITAAC 11 item to make sure the D-RAP is rechecked before fuel 12 up, for example. But it's not there so that leaves 13 me, again, a bridge.
14 MR. CONLEY: So the process is up to the 15 DCA you're still responsible. Through the DCA and 16 through the continuing design NuScale is still 17 responsible.
18 The process will be once we get into 19 certain things like you talk about testing and 20 procurement, some of that will have to be deliberated 21 in a contractual commercial space. Do you want to do 22 this? Are you going to procure these proponent and 23 take care of that testing or not?
24 For the things that NuScale will be 25 responsible for, we will make sure that the D-RAP NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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26 1 process continues for that piece. There's a line of 2 demarcation once you get into the COLA space that 3 there's some deliberations with the applicants that we 4 can continue this process for you.
5 We will model it for you. That's what the 6 COL items are intended to cover is that transition and 7 the setup of the program and making sure that the 8 reliability of the components is still considered and 9 updated.
10 CO-CHAIR RAY: Well, we just need to make 11 that really clear. Specifically, like I say, the FSAR 12 reads fine. It says things that are site specific are 13 fine, or construction, or operation. That all fits 14 the COLA. It's things that are related to the 15 certified design completion that has got us worried.
16 MR. CONLEY: I understand. Because we 17 were silent on it, you're unsure if it was going to 18 continue.
19 CO-CHAIR RAY: That's right.
20 MR. CONLEY: Okay. I appreciate the 21 comment.
22 MEMBER CORRADINI: Or who owns it. The 23 design will be done by the DCD. Therefore --
24 MR. CONLEY: Correct. So it's our intent 25 to keep the D-RAP program up through the process.
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27 1 CO-CHAIR RAY: I'm was sure it was.
2 That's why I said it was something that I thought was 3 just a lack of clarity or some confusion. But it does 4 need to be explicit and clear because I think you'll 5 hear a similar discussion with our staff when they 6 come up in which it was even less clear.
7 MR. CONLEY: I understand.
8 CO-CHAIR RAY: So we need to be -- I'm 9 talking about an earlier discussion we had. We need 10 to be crisp about this point that we're trying to make 11 which is the certification is based on a program that 12 continues on for the applicable -- for the certified 13 design and we're going to talk, I hope, here in a 14 little bit about open item verification and closure.
15 That's an activity that will go on until 16 the plant is ready to start up as it's described here, 17 and so we don't want it to be handed off for the 18 certified design itself, to somebody else, and wait 19 until the COLA is approved before we have a program 20 that we can oversee. I think you understand.
21 MR. BERGMAN: Tom Bergman, Vice President, 22 Regulatory Affairs. Just to be clear, our programs 23 continue, but the agency's approval is of what is in 24 the certification. The process, I mean, the ideal 25 process is the COL fully incorporates the DCD by NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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28 1 reference with no changes. There would be no change 2 if that were the case in the COLA. Only the site-3 specific portions would be addressed.
4 In reality, we know from past experience 5 there will be departures from the certified design.
6 To the extent those change the design, we address it 7 at that time. And it's clear that all those design 8 changes will have to have been done under our QA 9 program, our D-RAP program, and the COLA will then 10 justify the program that they're using for their 11 application, which will be some combination of ours 12 and theirs.
13 The programs don't stop, and that's clear 14 through -- they could stop, right? I doubt ABWR, or 15 I shouldn't use that one because that one is licensed, 16 CE System 80+ is still maintaining a QA program and a 17 D-RAP over their certified design, right? But we 18 expect to move into COL space, and so those programs 19 will continue indefinitely.
20 CO-CHAIRMAN RAY: Well, I just ask that 21 you be really clear regarding what the staff can and 22 cannot do. We'll discuss that with them and give them 23 our best advice. But the fact is that your work will 24 continue after the design is certified and it needs to 25 be covered by a program that we can provide oversight NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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29 1 to and that has the necessary controls.
2 MR. BERGMAN: We agree, but that's 3 separate from the certification in my view.
4 CO-CHAIRMAN RAY: Not in my view, but we 5 can agree to disagree on that. Since you're in the 6 position that you are, did you want to speak to the 7 issue of the coverage of the open design item closure 8 under the purview of this program while you're --
9 MR. BERGMAN: It's covered by procedures 10 under our QA program.
11 CO-CHAIRMAN RAY: I've got the number. I 12 know the procedure. What I'm not certain about is if 13 you had anything more to say about it because what we 14 know about it it's not clear that it's being -- it 15 will continue to be implemented in accordance with 16 your QA program, correct?
17 MR. BERGMAN: Yes.
18 CO-CHAIRMAN RAY: Do we need to take all 19 of the open ODIs at the time of design certification 20 and make an ITAAC out of each one?
21 MR. BERGMAN: Oh, no.
22 CO-CHAIRMAN RAY: No, we don't. Of 23 course. And, therefore, afterwards, you need, there 24 needs to be some relationship between the agency and 25 what you're doing to close those items that allows us NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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30 1 to be satisfied that, yes, they're all getting closed 2 and tracked and they're not being disregarded. Would 3 you agree with that?
4 MR. BERGMAN: Yes, and that's, I think, 5 addressed by the regulations.
6 CO-CHAIRMAN RAY: Well, if we're back to 7 the regulations, then that's fine. But we're trying 8 to get it into the program that we're looking at now, 9 and that's what -- I agree -- pardon me -- that it's 10 covered by the regulations, but what we want to be is 11 covered by this. Excuse me. I ate an apple, and it's 12 the apple that's got me.
13 Anyway, sorry. So thank you for 14 responding.
15 MR. BERGMAN: Yes, they'll be brought to 16 closure under a controlled process as late as 17 construction.
18 CO-CHAIRMAN RAY: Well, do remember that 19 we've been through this. I chaired the AP1000 20 subcommittee. I've done this for years, and I realize 21 we may be in a different circumstance now for 22 certainly reasons, and I just want to know what the 23 differences are.
24 MR. BERGMAN: The differences in what?
25 CO-CHAIRMAN RAY: With regard to the NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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31 1 application of the QA program to work that continues 2 after the design certification.
3 MR. BERGMAN: So the QA program, I mean 4 the design continues to evolve even during the 5 certification. And all that work and work subsequent 6 to certification continues under our own QA program, 7 some of which will involve closure of open design 8 items. I'm sure you've all seen that we're doing a 9 power uprate. The power uprate isn't part of the 10 design certification, but the power uprate, of course, 11 would be done under the QA program. So that's 12 standard practice.
13 A COL who then, that would be a good 14 example of a departure. If a COL came in and added 15 the power uprate, all that design would be departures 16 from the certified design and that would all be done 17 under the QA program. And if it impacted the D-RAP 18 results, that would have to be reflected in the COL at 19 that time, as well. But the program never stops. All 20 the programs keep going.
21 CO-CHAIRMAN RAY: Well, that's fine. And 22 you've made that clear enough, I think. It satisfies 23 me, at least. We just, we'll see if everybody else 24 agrees that that's what you're required to do 25 following design certification.
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32 1 MR. CONLEY: If I could, I'd like to add 2 a comment about your -- maybe there's a difference in 3 the term ODI, open design item. ODIs are unverified 4 assumptions. So they're in the design, we just have 5 to verify them. So I just want to make sure everybody 6 was clear --
7 CO-CHAIRMAN RAY: Yes, it's not required 8 testing. I understand that.
9 MR. CONLEY: Okay.
10 CO-CHAIRMAN RAY: But the point is you got 11 a good system, as far as I can see, to track them, 12 identify them, and so on. Our concern includes what 13 visibility the agency has to the status of all of 14 those.
15 MR. CONLEY: I understand.
16 CO-CHAIRMAN RAY: Because a certified 17 design is different than a construction permit, as we 18 all know. And, therefore, what we're interested in is 19 how do we assess the status of the ODIs at the time of 20 certification and then ensure that they're closed in 21 time for operability requirements to be met. And 22 that's, you referred to the fact that there are 23 procedures in the Section 17.5, but it's the 24 procedures used with respect to ODIs that we wanted to 25 pursue here. And we may have some more questions on NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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33 1 that before you're done, but, please, I've held you up 2 long enough now.
3 MR. CONLEY: Okay. That's fine. If you 4 have specific questions, we'll do our best to answer 5 them.
6 MEMBER BLEY: I think I remember that I 7 had a question earlier. This is Dennis Bley. I 8 wanted to ask you about the D-RAP board expert panel.
9 The idea of expert panels in this sort of area, on the 10 one hand they're looking to see at things pointed out 11 in the PRA. It may not be as risk significant as the 12 CDF. And, two, if there are things that aren't 13 modeled in the PRA that the experts think would be 14 important to safety at the plant, maybe because 15 they're needed to keep the operators' understanding of 16 the situation clear enough that what we model in the 17 human reliability analysis still holds up.
18 Two questions for you. Can you give me 19 any examples of where your D-RAP board either found 20 something that was in the PRA that they thought wasn't 21 really a risk issue and maybe the PRA was revised 22 because of it? And, two, were any areas where the 23 panel brought up issues that are not modeled in the 24 PRA that they think could have been important?
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34 1 two questions. The first one was is there something 2 through operating experience that may have caused us 3 to go back and want to revise the PRA and make 4 something that was not risk significant become risk 5 significant? Is that your first question?
6 MEMBER BLEY: That was pointed out by one 7 of your panelists, yes.
8 MR. CONLEY: Okay. We will not, the PRA 9 is the PRA. We don't update it, and I'll let Sarah 10 speak to that. We do deliberate at the board, at the 11 panel, and there are items, speaking to your second 12 question, where we have brought something in and it 13 wasn't risk significant and we deliberated whether it 14 needed to be evaluated or elevated to risk 15 significant.
16 Off the top of my head, I can't speak 17 specifically to any one example. I'm sure we can find 18 some for you that may fit in that or Dustin may have 19 one.
20 Sarah, can you please speak to the other 21 question about going back to revised PRA based on 22 operating experience?
23 MS. BRISTOL: Yes. And this is Sarah 24 Bristol. We did not, we looked at OE throughout 25 developing the PRA for different aspects, but there NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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35 1 was no specific OE related to NuScale that was 2 incorporated, that needed to be incorporated in the 3 PRA update that indicated risk significance was more 4 significant. You know, we used the generic 5 reliability data that was, you know, based on industry 6 OE and put that into our model.
7 MEMBER BLEY: That wasn't quite what I was 8 asking. I expected that. My issue was, my question 9 was the experts in your panel might know things beyond 10 what's in the public operating experience that leads 11 them to Ray's questions about things that are in the 12 PRA and are they appropriate. I was asking did they 13 find anything like that and, if they did, rather than 14 just adding them to the risk or deleting them from the 15 risk, I would think they'd want to have incorporated 16 them in their PRA.
17 MR. GREENWOOD: This is Dustin Greenwood.
18 And I think that's a great question. We took a little 19 bit different strategy, and one of the items I think 20 is important to point out, and I appreciate that you 21 asked the question, the expert panel oftentimes 22 identified items and the PRA identified items that 23 would have screened as risk significant through the D-24 RAP process. But instead of adding them to the list 25 of the D-RAP process using the risk-informed design NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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36 1 process, we challenged ourselves to put redundancy or 2 add some design feature that removed it from the risk 3 significance. So instead of identifying as risk 4 significant, we found a design solution. Typically, 5 it was using redundancy or other method of doing it to 6 remove it from the risk significance.
7 So I hope that kind of answers your 8 question, but we --
9 MEMBER BLEY: Yes, that's a more helpful 10 answer. Thanks.
11 MR. GREENWOOD: Okay. Thank you.
12 MR. CONLEY: Okay. Any further discussion 13 on that? If not, we'll move forward. Okay. The next 14 slide, please.
15 What you see here is a figure from the DCA 16 submittal in Chapter 17.4, and this basically outlines 17 the D-RAP process. What I wanted to point out on this 18 slide are a few things here, and it kind of goes back 19 to your question about the program and process itself.
20 We have the safety analysis. We have the results. We 21 look at RTNSS during this process. We also look at 22 other considerations, like Fukushima, other operating 23 experience, what we've learned through our own 24 experiences working with the design. And those will 25 be inputs for the classification that the system NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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37 1 expert will use to make his initial or her initial 2 determination.
3 Now, once that goes to the expert panel, 4 you'll see here in the lower left, the expert panel, 5 again, uses their own experiences, PRA results and 6 assumptions. We also, as Dustin mentioned, we have a 7 defense-in-depth approach and then system interactions 8 again with RTNSS.
9 So all those things were considered at the 10 expert panel. And then, through the discussion, it 11 was either determined to be risk significant or not 12 and then, from there, it was categorized.
13 And, again, going back to the process, our 14 engineering change control process, any design change 15 or a change to a calc has to go through that process 16 and it gets evaluated for impacts. So ODI's updates 17 impacts the PRA. All those things were considered 18 through our processes.
19 Next slide, please. So for the risk-20 significance determination, this is from the, this 21 table is in the topical. You can see the component 22 system-level CDF and LRF values and then what we call 23 the basic event contributor greater than 20 percent or 24 equal to.
25 There were four key limitations in the NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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38 1 topical report. This is applicable to NuScale. And 2 the second one is that the risk-informed applications 3 include risk-significant SSCs with other concepts, and 4 what that means is that we have, we consider the risk 5 insights along with deterministic approaches and 6 defense-in-depth concepts. And, therefore, we're 7 implementing a risk-informed, rather than a risk-based 8 approach.
9 The technically-adequate PRA addresses all 10 hazards and all modes and the thresholds for low CDF, 11 you can see there 10 to the minus 7 per year. NuScale 12 meets all these conditions, as documented in the 13 topical report.
14 Next slide, please. What you see before 15 you is a list of the PRA candidates that came out 16 through our evaluations. They're listed by system and 17 components. ECCS, MPS, module protection system, the 18 ultimate heat sink, those are the systems that were 19 candidates based on their functions.
20 Components below, ECCS vent valves and re-21 circ valves, decay heat removal, actuation valves. I 22 won't read all these for time, but you can get the 23 gist of the idea that containment isolation valves, 24 CVCS, CIVs, and the combustion turbine generator.
25 Next slide. So for other events and NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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39 1 initiators that were considered through the Fussel-2 Vesely, the reactor building crane, the LOCA inside 3 and outside of containment, LOCA, loss of cooling 4 accident, loss of off-site power, and internal fires 5 and floods. We also looked at human actions with the 6 20-percent threshold, as well. And the chemical 7 control volume system actuation and the containment 8 flooding drain system were those that were analyzed 9 for that.
10 MEMBER CORRADINI: Let me make sure I 11 understand. So eventually you're going to get to the 12 bottom line that neither of these two systems appear, 13 but the human actions to initiate them do appear?
14 MR. CONLEY: The CVCS specifically was one 15 --
16 MEMBER CORRADINI: And the containment 17 flood and drain system.
18 MR. CONLEY: Yes. I'll speak to the CVCs 19 one for sure, and then I'll come back to your other 20 question.
21 MEMBER CORRADINI: All right. Thank you.
22 MR. CONLEY: So if you look at one of the 23 previous slides, I don't know the slide number, but it 24 was one of the three RAI questions specifically 25 questioning the risk significance of the CVCS. We NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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40 1 responded to the RAI and we determined and basically 2 specified that, from a system component function, it 3 was not considered through the D-RAP as risk 4 significant. It was considered through the important 5 human actions. It's covered under that program.
6 MEMBER CORRADINI: So this will appear in 7 Chapter 18 discussion? I don't think I understand 8 that.
9 MR. CONLEY: I believe that's correct.
10 Sarah, can you confirm that it's in Chapter 18?
11 MEMBER CORRADINI: Because I'd like Dr.
12 Bley to pay attention to that.
13 MR. GREENWOOD: Yes, those actions are 14 covered in Chapter 18 under the important human 15 action.
16 MEMBER CORRADINI: So let me say it 17 another way. I've got these systems. These systems, 18 in some sense, are complementary. They overlap in 19 function to provide appropriate actuation of boration 20 or connection to the containment to the pool for an 21 ultimate heat sink. But they're not risk significant, 22 but the human actions to initiate them are.
23 MS. BRISTOL: That's correct.
24 MEMBER CORRADINI: Okay, all right. And 25 that's not covered here in the D-RAP. That's covered NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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41 1 in Chapter 18 relative to operator actions/human 2 reliability?
3 MR. GREENWOOD: That's right.
4 MEMBER CORRADINI: Okay, all right.
5 MEMBER BLEY: And we'll be doing Chapter 6 18 with you in about a month.
7 MEMBER CORRADINI: Exactly.
8 MEMBER BLEY: Mid-January.
9 MEMBER CORRADINI: So we won't forget.
10 MEMBER BLEY: It's close enough we'll 11 remember that one.
12 MR. CONLEY: Did that answer your question 13 for now? Okay, thank you. Okay.
14 Moving on to the results of the process.
15 Again, this is a dynamic process, so there could be 16 changes forthcoming as the design evolves. Table 17 17.4-1 in the FSAR shows you the systems. It also, if 18 you look the table up itself, will show you some of 19 the components. So the containment system, steam 20 generator system, reactor core, reactor coolant 21 system, CRDS, decay heat removal, ECCS, ultimate heat 22 sink, MPS, and neutron monitoring, and then there's 23 some non-modulate-related systems that are structures.
24 The crane and the building and the control building 25 were also considered risk significant.
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42 1 MEMBER KIRCHNER: May I make an 2 observation? So you screened out the two systems on 3 the preceding, the CVCS system and the containment 4 flooding drain system. They're risk significant 5 because of human actions, so it strikes me, as a 6 former designer designing advanced reactors, you don't 7 want to be in this position. You want to design for 8 that not to be the case, which suggests that they 9 should be in your risk-significant list and be 10 designed accordingly to prevent inadvertent operation 11 because you're relying then on administrative 12 operational controls rather than design to take them 13 out of the risk-significant category, and that just 14 seems counterintuitive to me for what we expect of an 15 advanced reactor design and that needs to be caveated 16 that's one member's opinion.
17 MR. CONLEY: Thank you for that. And if 18 I understood your comment, you believe we should have 19 designed that out using other things other than 20 administrative controls so we weren't relying upon 21 just the controls themselves. Okay.
22 MEMBER SKILLMAN: I want to join Walt and 23 I want to re-ask Dr. Bley's question. His question 24 was are there any systems or structures or components 25 that operating experience suggested should be in and NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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43 1 that you screened out, and I'm wondering if CVCS was 2 one of those systems. And I ask that as a guy who 3 responded to a loss of coolant accident on a PWR whose 4 ECCS system was disabled.
5 MR. CONLEY: So the question was if there 6 were any operating experience components considered 7 that screened out, was that your comment?
8 MEMBER SKILLMAN: Specifically, was CVCS 9 screened out?
10 MR. CONLEY: CVCS was not risk 11 significant; that's correct. There are multiple ways 12 to add moderator and also to add coolant to the RCS, 13 and, once the containment is isolated, that's where we 14 drew the line as far as getting into the human 15 actions. But it was screened out as not risk 16 significant.
17 MEMBER SKILLMAN: I understand it was 18 screened out. The question, I think, that Dr. Bley 19 asked was was there any system that operating 20 experience would have suggested should be in your list 21 that was screened out and was CVCS among those that 22 was screened out?
23 MR. CONLEY: I'll have to take that as a 24 question and respond back, unless Dustin can speak to 25 that specifically. I don't know the complete list.
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44 1 We had, like, a hundred systems, and I can't recall 2 each one. Dustin, can you speak to a place where we 3 had operator experience that we screened it out?
4 MR. GREENWOOD: Where we screened the 5 system out of the risk-significant discussion based on 6 operator experience?
7 MR. CONLEY: I believe that was the 8 question.
9 MR. GREENWOOD: We did not. We did not.
10 MEMBER CORRADINI: No, just the opposite.
11 I think Member Skillman's question was it was his 12 impression that CVCS, based on operating experience, 13 would be screened in, not screened out. That's what 14 I think he was trying to get at.
15 MEMBER SKILLMAN: That's what I was trying 16 to get at.
17 MR. GREENWOOD: That's the way I 18 understood the question also, and the answer is no.
19 We didn't bring any in and identify them as risk 20 significant and we did have extensive discussions 21 about CVCS, but the idea that we had to un-isolate 22 containment to initiate CVCS as a core makeup was the 23 topic of the discussion. So that was discussed more 24 clearly in the RAI when we asked why CVCS wasn't a 25 risk significant because there are competing scenarios NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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45 1 that we discussed in the expert panel is all I'll talk 2 about in this, to just quickly answer the question.
3 MEMBER BLEY: This is Dennis Bley. I'd go 4 back to what Walt asked, and I'd suggest that, while 5 I don't disagree with what he said, is these folks 6 have broken what they're looking at in the hardware 7 and into the human participation with the hardware.
8 When we get to Chapter 18 and however they dealt with 9 this, depending on how risk significant the operator 10 action was, you know, sometimes that leads to a 11 hardware change to make it less likely. But I would 12 hope that's where we would see that, and I think we 13 ought to return to this in January when we look at 14 Chapter 18.
15 MEMBER CORRADINI: Okay. Why don't we 16 move on?
17 MR. CONLEY: Okay. I believe that was our 18 final slide for the presentation on Chapter 17. Thank 19 you for your time.
20 CO-CHAIRMAN RAY: Okay. Well, we're now 21 one hour in. We've got the staff to go, and we've got 22 another whole chapter to do. I do want you, however, 23 please speak more fully. I believe I've acknowledged 24 that the ODI management system is a visible system.
25 It's been checked. The inspection that was performed NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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46 1 so far identified some shortcomings. It identified, 2 for example, that there's no clear restraint on a 3 design product based on underlying ODIs. Presumably, 4 you get at them by coming from the ODI list, not by 5 looking at the final design document, whatever it is.
6 But they can be tracked. I understand that.
7 What I'm asking you to speak to or 8 someone, if you can, please, is how they are actually 9 managed and if you, I'm not trying to get hung up on 10 specific findings in the inspection because it was an 11 initial inspection. There will be a follow-up 12 inspection. I'm not wanting to get over dramatic 13 about the issues that were raised.
14 The thing that is of concern is it wasn't 15 clear to me that these ODIs went beyond just a list 16 that existed, such that the products themselves 17 identified that this is an assumption, not a verified 18 item. And I'm trying to get you to talk a little bit 19 about how you gained confidence that we're going to 20 get all these things closed by the time they need to 21 be and we're not going to have stuff manufactured that 22 has problems with it because we didn't close an ODI in 23 time and things like that.
24 None of that is in the topical report. It 25 just says a procedure exists. I've looked at the NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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47 1 procedure. I understand it. But can you talk some 2 more about how ODIs get managed so that you can give 3 us assurance? I'll be asking the staff. They talked 4 about in the inspection report being sufficient 5 closure to have, enough closure to have sufficient 6 confidence to make the reasonableness finding in the 7 design certification issuance. I don't know how they 8 go to do that, but I just want to know how you guys 9 see yourselves managing this large number of ODIs that 10 existed at least a year and a half ago.
11 MR. CONLEY: Okay. I'll take an attempt 12 to answer your question. So I'll agree with you we 13 didn't specify all that level of detail in the 14 submittal or in the topical. Basically, we have a 15 procedure, as we mentioned earlier, that governs open 16 design issues or open design items. That is 17 dovetailed with our engineering change control 18 process, so there's many mechanisms that work together 19 to ensure that we attach the appropriate level of 20 identification that something needs to be changed and 21 the way we do that is through what's called ensuring 22 change order, an ECO.
23 What will happen is when a document needs 24 to be revised or changed it goes through the 25 engineering change control board process. It gets NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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48 1 analyzed for impacts through systems for the license.
2 And as part of that, we will do an impact analysis to 3 see where that change might be filtered through the 4 design.
5 Once we identify those documents that are 6 impacted, those ECOs are posted against those 7 documents, so they're there attached to it so we see 8 them visibly that there's an outstanding item here 9 that needs to be resolved or incorporated.
10 Now, as far as the ODI process itself, 11 that's part of the change process. We have an 12 administrator who keeps the list, but when we go 13 through to do, let's say we're going to close or 14 resolve an open design item, that means I've got to go 15 touch this document for revision, we'll generate an 16 engineering change request which kicks off that 17 process that identified, gives it the visibility. We 18 see where it goes. The appropriate ECOs go out and 19 get attached to the documents that won't necessarily 20 be updated at that moment, but they are attached to 21 show that the change is there.
22 Also, if we have the open design items 23 added through a design or a calculation that's 24 updated, if we have an unverified assumption, again, 25 that will be identified through that process, ECOs NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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49 1 will be updated, and it will be part of that change 2 control process.
3 So there are many things that work 4 together through that, but it all hinges on the 5 administration of the engineering change control 6 process and that interacts with the ODI process 7 itself. The number of items that you're specifically 8 speaking about, as things get resolved those get 9 worked off and those numbers, we do have a track on 10 those numbers. We know what they are, what 11 outstanding items we have, what the source documents 12 are, what the implementing document is. So we know 13 exactly where they are, how many we have, and the 14 process that controls them.
15 So I hope that gives you a little more 16 insight of how we handle that.
17 CO-CHAIRMAN RAY: Well, honestly, I 18 inferred most of what you said from what I have seen.
19 It just seems like a backlog that carries with it 20 uncertainty. And from where I sit now, it's a backlog 21 that needs visibility as one approaches. Really, it 22 doesn't concern me about at the issuance of the design 23 certification, provided there's an answer to the 24 question about reasonable assurance. But the real 25 problem is how the backlog avoids becoming a NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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50 1 significant problem.
2 You're probably aware that AP1000, before 3 construction started, went through something called 4 Amendment 6, and it had been issued previously but 5 there was an enormous amount of the same sort of 6 thing. And it was difficult, extremely difficult, to 7 identify what it was that needed to be done to get it 8 put into ITAAC and so on. Just a very big job. And, 9 yet, that was something that had at least gone through 10 the stages, almost like getting an OL after getting a 11 CP because of how it evolved.
12 I appreciate you got to have a customer 13 before you do a lot of this work. That's absolutely 14 clear. Having been a customer, I know that that's the 15 case. And so what I'm concerned about is, once that 16 happens, how these things gain the necessary 17 visibility and get done in time because we've been 18 through it before and it wasn't a very comfortable 19 process.
20 But you said all I think you can 21 reasonably say. It's something that you have given 22 visibility to. You do have a write-up in the topical 23 on design verification. It would be good if you 24 revised that thing to say a bit more on this subject 25 if you revise it for some other reason because the NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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51 1 implication is that it's infrequent, whereas the 2 reality is it's going to be much more infrequent that 3 these things exist throughout the design.
4 Okay. Well, with that, if there's nothing 5 more for you folks to say, we better --
6 MEMBER SKILLMAN: May I please ask a 7 question?
8 CO-CHAIRMAN RAY: Yes, of course.
9 MEMBER SKILLMAN: Patrick, what you 10 described is, by and large, a work management program, 11 how items are identified, how they're sifted, how they 12 are identified for work. What, to me, is the 13 complicated part of this riddle is you're dealing with 14 Tier 1 and Tier 2 information. And when you're in 15 Tier 1 information, you're into a license amendment.
16 When you're in Tier 2 information, you can pretty much 17 do whatever you want, do a 5059, screen it out, and 18 say I'm going to go.
19 And so compounding the issue of the number 20 of items that Harold pointed to, it seems to me that 21 you have the added burden of how are you going to 22 handle what might be unforeseen and emergent changes 23 that bump into Tier 1 information? And that can stop 24 the whole show because you've got to come back to this 25 office for, at the minimum, discussion.
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52 1 Can you briefly state how you're 2 envisioning handling the difference between changes 3 that might emerge on Tier 1 information?
4 MR. CONLEY: Yes, I can't personally speak 5 to that. I don't know if, Dustin, if you can speak to 6 that since it's related to ITAAC and Tier 1, I'd 7 appreciate that. If not, we'll just have to get back 8 to you on that.
9 CO-CHAIRMAN RAY: But before he responds, 10 let me just say we've been through it, so I think I 11 know the answer. It is what Dick said it was. I 12 think we're more expressing a concern and a desire for 13 visibility, something that we can hang our hat on.
14 MR. CONLEY: Your concern is very 15 warranted. We understand, and it is something that 16 bothers us, as well, and we have had lessons-learned 17 meetings and it --
18 CO-CHAIRMAN RAY: If you want to have 19 somebody speak to it further but keep it short.
20 MR. CONLEY: Go ahead, Dustin, if you have 21 something to offer.
22 MR. GREENWOOD: Yes, this is Dustin 23 Greenwood. Sorry. Thanks, Patrick. This is Dustin 24 Greenwood, and I will keep it short because I know we 25 all recognize that as a concern. In general, we tried NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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53 1 to ensure that we pointed to Tier 2 wherever possible 2 in anything that was required in Tier 1 just to make 3 sure that if a design process went through and changed 4 it in the Tier 2 material, rather than specifically 5 pointing it out in Tier 1 and requiring an LAR to 6 resolve it, we just pointed back to the Tier 2 7 information so that that change would reflect.
8 But, yes, it's a long process ahead of us, 9 and I appreciate the foresight and caution.
10 CO-CHAIRMAN RAY: Thank you. Anything 11 else? All right. We will not take a break at this 12 time. We will ask you to trade places with the staff 13 and we'll try and wrap up Chapter 17. Again, it 14 sounds like someone needs to mute their phone.
15 Do you guys got enough chairs? Okay. If 16 I may, let me again, as I did with NuScale, express, 17 for the purposes of all the members here, as well as 18 the staff, stuff that I'll be looking for and hoping 19 that you'll respond to as part of the presentation 20 you're about to make.
21 2017 inspection report forwarding letter 22 includes a statement that, "As part of the DCA review, 23 NRC technical staff audits and additional inspections 24 of quality activities will be performed to ensure that 25 open design items are sufficiently closed to enable NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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54 1 the NRC to make its 52.54 finding." And as I said to 2 NuScale, I've been through this several times at the 3 CP stage under Part 50. But then we were followed by 4 the OL stage.
5 Here, I don't know if the intent is to 6 incorporate all ODIs that aren't closed into ITAAC.
7 I'm sure it's not. But how do we deal with this open 8 item issue? We went through it in AP1000, and it 9 wasn't very pleasant, or it was difficult. Let's put 10 it that way.
11 Last year's NRC inspection, which I 12 referred to, included a number of findings that would 13 seem to make visibility to incomplete design 14 verification difficult. We've heard from NuScale 15 about that now, but the ODIs themselves are enumerated 16 and presumably can be tracked to closure through to 17 when operability is required, but there were errors 18 and omissions cited in the inspection and I'm sure 19 those will be followed up when the subsequent 20 inspection or inspections are done.
21 Also, in that inspection report, it was 22 stated that "ODIs may exist in supporting documents' 23 references to calculations and that the NRC inspection 24 team did not find examples of ODI placeholders in the 25 body of the documents reviewed," and that's what I NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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55 1 meant by the question in which I ask how do you find 2 the ODIs that are outstanding? You've got a list of 3 them, but you have to go look for where they are and 4 what tier of design documents. They aren't reflected, 5 according to the inspection anyway, as a placeholder 6 in the design document.
7 They've committed to tracking all of the 8 open design items properly and ensure closure before 9 operability. However, we're interested in how the NRC 10 will be able to verify that the management, ODI 11 management has completed this process, most of which 12 will take place after the design certification occurs.
13 And I guess none of us see it as part of the COL QA 14 program, but then you may see it differently. So 15 please proceed.
16 MR. TABATABAI: Good afternoon, everyone.
17 Thanks for giving us an opportunity to present the 18 staff's review up to this point of Phase 2 of the 19 review. This is a briefing of Chapter 17, which 20 consists of two major parts: quality assurance and 21 reliability assurance program.
22 With me today, and we apologize for not 23 having name tags, but to my right Alissa --
24 MEMBER CORRADINI: You guys look familiar 25 to us.
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56 1 MR. TABATABAI: Yes. Alissa Neuhausen.
2 She will be presenting reliability assurance program 3 for the staff. Andrea Keim. She will be presenting 4 quality assurance. And we have Ian Jung, as well, who 5 will be helping us with the reliability assurance 6 program.
7 I will go through some background 8 information to just get the discussions started. I 9 just wanted to recognize the staff who have reviewed 10 this chapter. Since we presented risk significance 11 determination topical report, Mark Caruso was our main 12 reviewer and he has since retired. Alissa is going to 13 talk about that if there's anything to discuss. For 14 project management, Greg Cranston is our lead project 15 manager for NuScale. And I'm Omid Tabatabai. I'm a 16 senior project manager and responsible for Chapter 17.
17 Just an overview of the staff's review.
18 We received Revision 0 of DCA back in December 2016, 19 Revision 1 in March 2018, and recently we received 20 Revision 2 of the DCA in late October. I just want to 21 make sure that you know that the review is based on 22 Revision 1 of the application.
23 We issued two RAIs containing three 24 questions to NuScale related to Chapter 17, and they 25 were all related to reliability assurance program.
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57 1 And all of the questions have been responded to and 2 they have been resolved.
3 For reliability assurance program, we 4 conducted two regulatory audits in 2017 and 2018. And 5 for quality assurance program, we, as you mentioned, 6 in June of 2017, we had a quality assurance 7 implementation inspection. And we have a follow-up 8 inspection that we are going to plan to conduct again.
9 We have two open items in Chapter 17, but 10 we don't have any confirmatory item. We will discuss 11 in more detail what those two open items are.
12 With that, that concludes my portion of 13 the presentation and I will turn the microphone to 14 Andrea to talk about quality assurance program.
15 MS. KEIM: Hi, good afternoon. My name is 16 Andrea Keim. I'm a reactor operations engineer at the 17 NRC. I've been with the agency for more than 20 18 years. I have a BE and an MS in material science and 19 engineering from Stevens Institute of Technology in 20 Hoboken, New Jersey. I work in the Quality Assurance 21 and Vendor Inspection Branch. The branch leads and 22 performs routine and reactive vendor inspections, and 23 we also conduct QA implementation inspections for new 24 reactors. We also perform QA reviews for Part 50 and 25 52 applicants, and we also review the initial test NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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58 1 program.
2 Next slide. The main regulatory -- oh, 3 back one. The regulatory requirements are Appendix A 4 to Part 50, which gives us our general design 5 criteria, and quality assurance is number one. So 6 that means that licensees and applicants have to make 7 sure their structure systems and components important 8 to safety are designed, fabricated, erected, and 9 tested to quality standards commiserate with the 10 importance of the safety function they are to perform.
11 The second criteria here is Appendix B, 12 the second regulation is Appendix B to 10 CFR Part 50, 13 which provides our quality assurance criteria for 14 nuclear power plants and it lays out the 18 criteria 15 for quality assurance. 10 CFR 52.47 addresses the 16 contents of an application and, for a DC applicant, 17 must include a quality assurance program that 18 satisfies the applicable portions of 10 CFR Part 50.
19 Next slide. That's the one. So the way 20 we did this, the topical report was submitted and it 21 was separate from the design certification 22 application, and this was reviewed prior to getting 23 the application. The approval was prior. NuScale's 24 QR review was completed outside of the DC process.
25 The topical report was reviewed separately to ensure NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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59 1 that the preliminary work on the application was done 2 in accordance with the requirements of Appendix B to 3 10 CFR Part 50.
4 The staff used the guidance of the NUREG-5 800, Section 17.5, for quality assurance program 6 description for design certifications, early site 7 permits, and new licensee applicants as guidance for 8 the review.
9 Again, the applicant's QA topical report 10 was submitted in accordance, submittal was in 11 accordance with Reg Guide 1.28 Rev 4, which endorses 12 the ASME NQA-1 2008 edition through the NQA-1A 2009 13 addenda. The staff found this acceptable and that the 14 submittal met the requirements of Appendix B to 10 CFR 15 Part 50 and the staff's SER was dated September 22, 16 2016.
17 So then we go to the next one, and it 18 talks about our review for the design certification 19 application. And what we do with that is we verify 20 that they referenced the approved topical report. We 21 verified the COL application, and the staff identified 22 an open item where we're going to do an additional QA 23 implementation inspection.
24 And the last part of our review was the QA 25 implementation inspection that has already taken NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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60 1 place. This occurred on June 5th through the 9th of 2 2017 at the NuScale office facility in Corvallis, 3 Oregon. The inspection followed Inspection Procedure 4 35017. There were no significant findings identified, 5 and the inspection report is publicly available.
6 Again, we plan to perform another QA 7 implementation inspection and it's being held in the 8 SER as an open item 17.5-1.
9 MR. TABATABAI: Okay. That concludes our 10 QA presentation. Any question?
11 MEMBER CORRADINI: So can I ask a 12 question?
13 CO-CHAIRMAN RAY: Please.
14 MEMBER CORRADINI: Okay. So I'm listening 15 to Harold and I want to make sure that it's clear. So 16 is it the staff's position that this is an issue 17 strictly for NuScale, as Dick calls it a work 18 management program for the ODIs, or is this something 19 that you're watching so that, once the DCD is done and 20 before the COL is issued, you're making sure that 21 these things are appropriately closed? Put another 22 way, why isn't this an ITAAC?
23 MS. KEIM: We've reviewed this as a 24 process, and, during the inspections, we evaluated how 25 they keep track of the ODIs and the process that NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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61 1 they're using. But we're not following each and every 2 ODI --
3 MEMBER CORRADINI: No, I wasn't expecting 4 that.
5 MS. KEIM: But then there's the technical 6 staff that go and do audits for their calculations and 7 they have some documentation in their audit program 8 and through RAIs that also close the ODIs.
9 MEMBER CORRADINI: So if I've got it 10 right, you now are, you're satisfied that their 11 program to track and close the ODIs is appropriate, 12 but you don't see the need to essentially assure 13 closure of them before the COL is issued?
14 MS. KEIM: Not all of them, no.
15 MEMBER CORRADINI: Okay. Fine.
16 MEMBER SKILLMAN: Let me explain where I'm 17 going with this. I've got your SER at Chapter 17.0, 18 quality assurance. The statement is very clear. The 19 QA PD is based on the applicable portions of Appendix 20 B. Criterion III is design control. Criterion XVI, 21 16, is corrective action program.
22 Did you look at their Criterion III, 23 design control program, in a context of Harold Ray's 24 comments about the open items? Why are we asking the 25 question? Because this is a killer. Unless these NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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62 1 pieces are knit together, the end product is going to 2 be a quagmire for everybody. It's going to be a 3 quagmire for NuScale, and it's going to be a real 4 rat's nest for the staff. And unless it's designed 5 properly on the front end, and it's not just work 6 management but it's the integration of the 18 points 7 of Appendix B, then we're probably all going to be 8 wishing that we had done something differently a 9 couple of years before. Now is the time to do it.
10 When this says applicable portions, I've 11 got to ask, what isn't applicable?
12 CO-CHAIRMAN RAY: Well, the inspection 13 report itself didn't refer to Criterion XVI, which 14 seemed a little odd to me, but maybe it's the right 15 thing to do in this context.
16 Do you know how the NRC will determine 17 that the open design items are sufficiently closed to 18 issue the design certification? That's what's stated 19 in the forwarding letter for the inspection report.
20 MS. KEIM: Some are being closed through 21 the audit process and through RAI --
22 CO-CHAIRMAN RAY: Well, they're not being 23 closed to the audit process. They're being recognized 24 as having been closed by NuScale through the audit 25 process; is that correct?
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63 1 MS. KEIM: Yes.
2 CO-CHAIRMAN RAY: Okay. But how do we, as 3 an agency, decide that they've closed enough of them 4 that we can issue the design certification?
5 MS. KEIM: Because they're following their 6 processes through the, if their assumption comes --
7 they had a process which they talked about where if 8 one of their assumptions comes out to be wrong then 9 they have to go through the whole design control 10 process to figure out how broad does this error --
11 CO-CHAIRMAN RAY: I'm asking how we 12 decide, we, the agency, decide that they're 13 sufficiently closed. That's what it says.
14 MS. KEIM: I'm not sure.
15 CO-CHAIRMAN RAY: I'm not either, and I've 16 been around here perhaps as long as you have. I have 17 never seen a statement like that before, and I'm 18 trying to understand what it means.
19 MEMBER CORRADINI: Are you looking for 20 other staff to help you? Someone was up, and they sat 21 down.
22 CO-CHAIRMAN RAY: All I can do is ask 23 who's in front of us here, but the question --
24 MS. KEIM: And that's in the cover letter 25 of the inspection report.
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64 1 CO-CHAIRMAN RAY: The forwarding letter of 2 the inspection report says what I just read you, that 3 they're sufficiently closed to -- as part of the DCA 4 review, NRC technical staff audits, which you referred 5 to, and additional inspections, plural, of quality 6 activities will be performed to ensure that open 7 design items are sufficiently closed, not that they're 8 being managed properly. Sufficiently closed is the 9 phrase.
10 MS. KEIM: Sufficiently closed is for the 11 ones that are of high significance that they're going 12 to be done through our RAI process and through the DCA 13 review.
14 CO-CHAIRMAN RAY: Let me suggest 15 something. Perhaps this is something which, at the 16 full committee meeting, you'd want to get a more well-17 prepared answer for because I've never seen this kind 18 of statement made. I don't know how it's done. I can 19 imagine some things, but that's just all it is at this 20 point. But I'd rather the staff tell us this is how 21 we reached this conclusion that they're sufficiently 22 closed. And as I said to NuScale, nobody in their 23 right mind would expect them to all be closed or any 24 given number remain outstanding, but we don't know how 25 to ensure after the design certification is completed NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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65 1 that they're closed. NuScale has told us they will be 2 closed in accordance with their program, which will 3 remain in effect contrary to how I read what the staff 4 has said about the applicability of the program, that 5 it only applies to the design certification.
6 But be that as it may, the concern that I 7 think is shared by Dick and others of us here is, 8 okay, this is a necessary situation, it's not 9 something that's a problem, so long as we understand 10 how the heck it gets resolved. And the only 11 mechanisms that we know about are the ones that we've 12 used so far, you know. The one Part 52 plant under 13 construction we went through this process, so if we're 14 going to do it differently here tell us how we do it.
15 MR. LEE: Good afternoon. My name is Sam 16 Lee. I'm the Chief of Licensing Branch 1 responsible 17 for project managing the NuScale DCA review. I think, 18 so I understand your point, Mr. Ray, and perhaps there 19 will be an opportunity where we can discuss what an 20 ODI is and what that consists of.
21 I think the question at hand is what 22 constitutes the scope of the staff's review? ODI, 23 open design item, is not an open item. I think it was 24 earlier somebody mentioned that it was referred to as 25 open item. Open item is really an unresolved issue or NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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66 1 unresolved RAI, if you will, that is found through the 2 Phases 1 and 2 of the review, right? And at the end 3 of the Phase 2 --
4 CO-CHAIRMAN RAY: No, no, let me interrupt 5 you. I'm sorry to interrupt you, but I think it would 6 be best if you read NuScale's definition of ODI. They 7 call it a design assumption. It's not something 8 that's found, it's an assumption that allows them to 9 proceed with a design without verifying the 10 assumption, and it's perfectly fine. There's nothing 11 wrong with it. But it's not a finding, it is an 12 assumption that is made that allows the design to 13 proceed on the basis that you will later verify that 14 assumption in some manner. We had lots of them in the 15 Westinghouse AP1000. The ones that existed when the 16 Amendment 6 were issued were all put into ITAAC. It 17 was a dozen or so. This is a much bigger number.
18 We're wondering how it's going to be managed, which we 19 asked NuScale and we're asking you guys how it will be 20 overseen. But it's not a finding.
21 MR. LEE: So within the scope of the 22 design certification application review, the finding 23 that the staff will make would be related to the open 24 items coming out of Phase 2. We will not make a 25 finding on every ODI. If it happens that, as part of NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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67 1 the staff's review, whether it's through the RAI 2 process or through the audit, that there is a 3 particular ODI that needs to be addressed within the 4 scope of the DCA, we will, as Andrea has said. But we 5 will, we do not plan to review and close or review of 6 how every open design item would be closed.
7 CO-CHAIRMAN RAY: And, of course, you 8 never heard me ask that. But I did ask how you would 9 decide that they were sufficiently closed to issue the 10 design certification. How is it done?
11 MR. LEE: I think that would be case 12 specific, depending on what the question at hand would 13 be.
14 CO-CHAIRMAN RAY: Will there be visibility 15 to it, as was done when we did the final amendment on 16 AP1000?
17 MR. LEE: The visibility would be through 18 the audit process or the RAI process.
19 CO-CHAIRMAN RAY: But not through the 20 process of recognizing what was outstanding, not yet 21 closed, at the time of the issuance of the design 22 certification?
23 MS. KAVANAGH: This is Kerri Kavanagh.
24 I'm the Chief of the Quality Assurance Vendor 25 Inspection Branch. NuScale does not supply the NRC NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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68 1 with their list of ODIs. That is something that the 2 staff would come across during our inspection or 3 through the audits of specific design documents. So 4 the staff does not have first-hand knowledge of what 5 that list looks like unless we're on-site doing an 6 inspection or an audit of NuScale.
7 CO-CHAIRMAN RAY: How does sufficient 8 closure get determined then?
9 MS. KAVANAGH: We have to determine what 10 are reasonable assurances based on our regulatory 11 requirements, so the staff would make that for each 12 chapter that is reviewed.
13 MEMBER CORRADINI: Can I try something?
14 I keep on listening to you guys going back and forth, 15 and I wrote something down, but maybe this is not 16 accurate. But my interpretation of it is, based on 17 inspections and audits, the staff feels that they need 18 to find reasonable assurance that the ODIs can be 19 managed and closed. So by the audits, you look at 20 what they've closed one by one and you gain assurance 21 by essentially a fraction sampling of what they're 22 doing? That's what I'm struggling with. I think 23 that's what Harold is struggling with.
24 CO-CHAIRMAN RAY: Excuse me. And I'll let 25 you speak in just a second. I'm actually, the thing NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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69 1 that I'm struggling with the most is a determination 2 that open items are sufficiently closed to enable a 3 reasonableness finding. I don't know what that means, 4 but that's precisely what I'm trying to ask.
5 MS. KAVANAGH: Right. So for a QA 6 implementation inspection, we don't do 100 percent.
7 It's a sampling basis. So depending on what it is 8 that we sample or who we have, which specialist we 9 have with us on our particular team, I mean, that's 10 the scope that we would be looking at and we'd have to 11 make an assumption on our part that that whole process 12 will be relayed to the rest of the program.
13 CO-CHAIRMAN RAY: Okay. I think we've 14 gone around and around enough. I'm using some of 15 Pete's time now. I appreciate you stepping up to 16 answer. I'll just say this is not something, at least 17 speaking for myself alone, understand sufficiently.
18 I understand what NuScale will do. That's not a 19 problem. And they're going to continue to do what 20 they do before and after the design certification is 21 issued, and before operability everything has got to 22 get closed.
23 The question I'm asking is how do we 24 decide that they've closed it enough to issue the 25 design certification? We'll follow that as we go NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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70 1 forward, and that's about the best we can do right 2 now.
3 If you have something more to offer us, 4 plan to do so in February at the full committee 5 meeting, and we'll greatly appreciate it.
6 MR. LEE: This is Sam Lee. I'll just 7 restate what I've said. Staff will make a reasonable 8 assurance finding. If that reasonable assurance 9 finding needs a review of the ODI to reach that point, 10 we will do so. Otherwise, we will not.
11 CO-CHAIRMAN RAY: I see. Well, that's 12 fine. Glad to have it on the record. Appreciate it.
13 Okay. Anything more for the staff?
14 MR. JUNG: This is Ian Jung. I'm speaking 15 more from a Chapter 19 review. There are a set of 16 very significant assumptions made in developing PRA, 17 given the lack of design details or some of the 18 limitations associated with the design stage. So 19 those assumptions that are significant staff's review 20 has been focusing on. And not only those assumptions 21 are listed in FSAR and staff is also including those 22 significant assumptions to be carried forward to a COL 23 applicant, so there are tables, there are COL action 24 items for verifying those assumptions. So I just want 25 to mention that.
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71 1 I was a part of the training that was 2 offered to branch chiefs last year on ODI, and my 3 impression coming out -- I don't want to go into 4 detail, it was a closed meeting -- is that ODIs are, 5 in general, so far below the design certification 6 material that's needed for the reasonable assurance of 7 safety finding. However, the ODIs are ongoing 8 activity for NuScale. Any of those activities rises 9 to a level that's going to have an impact on design 10 certification, staff's finding on reasonable 11 assumptions finding, they have to either come back 12 with FSAR changes during design certification or carry 13 forward through the COL stage. That's what my --
14 CO-CHAIRMAN RAY: Yes, I agree with part 15 of what you said. But, of course, the ODIs don't have 16 to do with PRA. That's not an Appendix B design 17 verification issue.
18 MR. JUNG: There's a slight programmatic 19 difference, but assumptions in PRAs are --
20 CO-CHAIRMAN RAY: I'm sure that's right.
21 Absolutely. But I'm really just focused on the ODIs 22 that are related to Appendix B scope or --
23 MR. JUNG: I understand. I just want to 24 share my thoughts on much broader --
25 CO-CHAIRMAN RAY: And I appreciate the NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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72 1 input on a difficult thing. I did convey this issue 2 to the staff a week ago or so, so I hope I'm hearing 3 what you had to say after thinking about it. But I 4 still don't understand what the mechanism is, although 5 I think it's better now than it was.
6 In any event, anything more for the staff?
7 We need to go around the members quickly and -- oh, I 8 beg your pardon. We stopped before we did reliability 9 assurance. I thought you hadn't asked many questions, 10 Mike. It was my effort to beat the clock here.
11 Please, go ahead.
12 MS. NEUHAUSEN: I'll be presenting on 13 reliability -- okay. Good afternoon. My name is 14 Alissa Neuhausen again. I'll be covering Section 17.4 15 on the reliability assurance program. And for the 16 reliability assurance program, or RAP, staff's review 17 was performed in accordance with SRP 17.4 Revision 1.
18 The staff reviewed the program description 19 in implementation, programmatic controls, SSC 20 selection, expert panel member requirements, and the 21 list of D-RAP SSCs. The first stage of the 22 reliability assurance program is referred to as the D-23 RAP, which encompasses those reliability assurance 24 activities that occur before initial fuel load, which 25 includes both the DC and COL phases.
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73 1 The second stage comprises the reliability 2 assurance activities conducted during the operations 3 phase. Of course, what I'm talking about today is the 4 DC phase.
5 The applicant's description includes 6 sufficient detail of the process used to identify what 7 is risk significant at the design phase. That way, 8 any design changes done to those SSCs can be 9 controlled and, as construction progresses, 10 appropriate QA controls are applied to those SSCs.
11 The programmatic controls, which ensure 12 the risk insights and key assumptions are consistent 13 with the plant design, adjust the appropriate 14 activities as outlined in the SRP. The selection 15 methodology for the risk-significant SSCs considered 16 probabilistic information that is that PRA information 17 as approved in the risk significance determination 18 topical report, deterministic evaluations including 19 defense-in-depth considerations, operating experience, 20 expert panel reviews, and severe accident analysis.
21 The applicant met the conditions and limitations 22 stipulated in the topical report for the described 23 methodology to be acceptable.
24 The staff reviewed the expert panel 25 membership requirements and found them consistent with NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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74 1 the SRP. The staff confirmed that the expert panel 2 considered the appropriate inputs, in addition to the 3 probabilistic information, for the selection of risk-4 significant SSCs. And the staff reviewed the final 5 list of D-RAP SSCs which are those required to perform 6 risk-significant system functions and verified the 7 process described in FSAR Figure 17.4-1.
8 So based on the review of the previously-9 described information, the staff found that the D-RAP 10 list was developed in accordance with its RAP 11 methodology, that NuScale adequately implemented the 12 expert panel in developing the D-RAP list, and that 13 the D-RAP list is comprehensive. The three COL items 14 respectively for integrating RAP into operational 15 programs, QA controls during site-specific design 16 procurement, fabrication, construction, and pre-17 operational testing activities, and the identification 18 of site-specific SSCs provide an appropriate level of 19 assurance that a COL applicant referencing the NuScale 20 design will implement an adequate reliability 21 assurance program.
22 And, lastly, the inclusion of the D-RAP 23 ITAAC is currently the only open item in Section 17.4.
24 SECY-18-0093 is currently with the Commission. Staff 25 has recommended that the Commission discontinue the NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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75 1 use of the D-RAP ITAAC, and we're currently waiting 2 for a response.
3 MEMBER CORRADINI: So can we go to that 4 last thing, and can you explain to me -- my first 5 conclusion was, because I didn't read Section 6 17.4.4.8, was there ought to be an ITAAC about doing 7 a D-RAP before fuel load to check everything is 8 kosher. But this says you're going to the Commission 9 to say ITAACs aren't needed anymore. Why? Explain 10 the logic. Can you explain the logic for me?
11 MS. NEUHAUSEN: I can explain a little bit 12 of the logic. It is --
13 MEMBER CORRADINI: But you've got 14 lifelines here. You can get other people to --
15 MS. NEUHAUSEN: So it is lined out in the 16 SECY paper, and so the basis is that we've done it 17 before several times. Nothing significant was really 18 identified. And it's consistent with how the 19 Commission has acted for additional operational 20 programs, so the remainder of the operational 21 programs, the Commission said we don't need ITAAC as 22 long as it's sufficiently described in the DC. So we 23 would consider it to be sufficiently described in the 24 DC.
25 MEMBER CORRADINI: So let me try it a NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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76 1 different way. So as long as it's sufficiently 2 described, so is it described somewhere in Chapter 17 3 that the D-RAP will be re-visited with the new PRA 4 values prior to fuel load so that it's very clear the 5 D-RAP will be checked? Because I couldn't find that.
6 MS. NEUHAUSEN: That is part of the 7 programmatic controls.
8 MEMBER CORRADINI: That's part of the 9 programmatic controls?
10 MS. NEUHAUSEN: Yes.
11 MEMBER BLEY: Did we get that SECY? I 12 don't remember seeing it.
13 MEMBER CORRADINI: Dennis, you have to 14 speak a bit louder. You're kind of fuzzy.
15 MEMBER BLEY: Did we get the SECY? I do 16 not remember seeing it.
17 MEMBER CORRADINI: I don't either. I was 18 going to ask for it eventually, but, no, I'm not aware 19 of this. This was new to me when I read the 20 paragraph.
21 MS. HAYES: So I'm Michelle Hayes. I'm 22 the Branch Chief for the PRA and Severe Accidents 23 Branch, and we wrote the SECY, as Alissa said, based 24 on the programmatic controls that it has to be 25 approved, it has to be submitted and described in the NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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77 1 COL and then approved by staff.
2 I think what you're talking about, having 3 everything done before operation starts or fuel load 4 starts, that's the second phase of the RAP program and 5 that's part of that 17.3 COLA item, that is -- or 17.1 6 actually, maybe 17.4-1, where that the COLA applicant 7 is going to put something in place during operations 8 phase to take care of the reliability insurance 9 activities.
10 MEMBER CORRADINI: Well, I guess maybe 11 every time I get to talk about process I do it wrong, 12 so Harold looks at me with a funny face. What I'm 13 worried about is there's a gap. In other words, we 14 have the D-RAP now based on a list of things, based on 15 the PRA and expert panel, and now time marches along, 16 they build components, the RRV, the RVV. There's 17 assumptions about reliability of these things. The 18 reliability changes or is estimated to be different, 19 and some things may become risk significant and 20 warrant or vice versa. Where does it stand that 21 somebody is going to do another check on all of this 22 so that before fuel load this is checked and I have 23 another D-RAP?
24 MS. HAYES: So the PRA is required to be 25 updated before fuel load, and then that would be the NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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78 1 part where they would go into their operational 2 programs. That would be fed into the operational 3 programs.
4 MEMBER CORRADINI: So it's only 5 operational. The D-RAP would not change. The D-RAP 6 is set once the DCD, once the certification is 7 approved?
8 MS. HAYES: No, the programmatic controls 9 for the D-RAP and what they're explaining with that 10 flow chart is every time you make a design change, 11 either the NuScale or the COLA applicant is going to 12 be maintaining that D-RAP list.
13 MEMBER CORRADINI: Okay. So let me, I 14 have to go by specific examples. So we build some 15 first-of-a-kind RVVs and RRVs and I test them and they 16 work well, but they don't work as well as assumed.
17 That will go into the design process, and that will 18 then be funneled in through the PRA and --
19 MS. HAYES: Yes, the PRA, a change in the 20 PRA feeds back into the D-RAP process.
21 MEMBER CORRADINI: Okay, okay, all right.
22 Thank you.
23 MR. JUNG: Yes, we will provide the SECY 24 paper, although it's in public website right now.
25 MR. TABATABAI: Okay. This concludes our NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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79 1 presentation. Any other questions from the members?
2 CO-CHAIRMAN RAY: I'll go back to where I 3 was some time ago and ask if there are other 4 questions. We appreciate you being responsive, and, 5 as I said in the beginning, we've got to move on.
6 Yes, Pete?
7 CO-CHAIRMAN RICCARDELLA: This is so much 8 different than Chapter 2. I wonder if maybe you ought 9 to go around --
10 CO-CHAIRMAN RAY: I am going --
11 CO-CHAIRMAN RICCARDELLA: -- for 12 individual members' comments before we move on.
13 CO-CHAIRMAN RAY: Appreciate it, yes.
14 Absolutely. It is different in topic. That's what I 15 was starting to do a bit ago when I got reminded that 16 we still had reliability assurance to go. Thank you, 17 staff.
18 Okay. With that, let me do as you say.
19 I've got note-taking capability here. Let me ask, 20 starting with Walt, about any comments on Chapter 17.
21 MEMBER KIRCHNER: Just one observation.
22 I have been struggling with how to phrase a 23 constructive question out of this but mindful of 24 events to the southeast that had QA kind of issues.
25 This sufficiently closed on ODI, to what extent have NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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80 1 you factored lessons, are there any lessons learned 2 from previous certified designs that are in 3 construction in the area of QA implementation and 4 design control? Sufficiently closed is sufficiently 5 vague that it leaves me pondering as to what your 6 process is to make that determination. Do you 7 actively engage subject matter experts from your 8 design disciplines, like Chapter 4, the people that 9 would review 4, 5, you know, some of the areas that 10 really are going to be important factors in making a 11 reasonable assurance determination? Has there been 12 any change to the NRC processes in terms of evaluating 13 quality assurance programs as a result of previous 14 activities with the certified design and to what 15 extent do you actively engage other subject matter 16 experts in this assessment of open design issues?
17 CO-CHAIRMAN RAY: So this is a question 18 you want us to take note of here, or did you, were you 19 directing that to the staff to have them respond?
20 MEMBER KIRCHNER: It was to the staff.
21 It's just something I'm pondering and perhaps --
22 CO-CHAIRMAN RAY: Yes, it's a tough 23 question to answer at this moment.
24 MEMBER KIRCHNER: Yes. And it was a 25 rambling question, I will admit that. But it does NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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81 1 make me think hard about sufficiently closed.
2 CO-CHAIRMAN RAY: Yes.
3 MEMBER KIRCHNER: Maybe they can address 4 that --
5 CO-CHAIRMAN RAY: I'll take note of it.
6 MEMBER KIRCHNER: -- at the February 7 meeting.
8 CO-CHAIRMAN RAY: We'll try to see how it 9 fits in. Certainly, staff understood your question.
10 You know, the other side of it for me is I don't see 11 how we can expect the NuScale design at this point to 12 be further along than it is. This is really an agency 13 process issue, as I see it. I happened to be somewhat 14 involved when Part 52 was adopted. We're now applying 15 it in a different context, so I know that we're 16 struggling to find out how to get things done.
17 I will ask the staff a question I forgot 18 to ask. You don't object to us saying that NuScale 19 has affirmed that their QA program will apply beyond 20 the design certification, even though you can read 21 some of the stuff that's been written as indicating it 22 only applies up to design certification? You don't 23 mind us saying that it was clarified that it applies 24 beyond then, right?
25 MR. TABATABAI: I think that's what Tom NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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82 1 mentioned during his -- maybe he wants to clarify.
2 CO-CHAIRMAN RAY: I heard him say that, 3 too. But I just want to be sure you don't mind us --
4 MR. BERGMAN: I want to distinguish 5 between what we do to be practical and what is 6 required by regulation. I'm not willing to make that 7 regulatory commitment here. If it's not required, 8 that doesn't mean we won't do it.
9 CO-CHAIRMAN RAY: Okay. Well, you won't 10 be surprised then if we happen to advise the 11 Commission that it should be required like anything 12 else in the design certification is required.
13 MR. BERGMAN: I can't object to that. I 14 can't object to that.
15 CO-CHAIRMAN RAY: Yes, okay. Mike?
16 MEMBER CORRADINI: I've asked enough. I 17 pass.
18 CO-CHAIRMAN RAY: Okay. We're not asking 19 more questions here. I'm trying to get note for the 20 record of member reflections on what we've been 21 through and --
22 MEMBER CORRADINI: Okay. So my reflection 23 is, I think my confusion about the ITAAC, I guess, is 24 resolved based on we're going to see the SECY in terms 25 of what that implies. In terms of the QA program, NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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83 1 you've asked enough questions. I think I understand 2 what the staff is, how the staff would determine 3 reasonable assurance, so I think my questions have 4 been answered.
5 MR. SNODDERLY: This is Mike Snodderly.
6 Just to clarify, that SECY did not come before the 7 committee and is not expected to come before the 8 committee. Right, okay. Sorry. I thought you meant 9 . . .
10 CO-CHAIRMAN RICCARDELLA: I just sense 11 there's kind of a serious timing issue here, you know, 12 regarding the D-RAP and the PRA. We're not going to 13 have a final PRA until prior to fuel load, and, yet, 14 that final PRA, as Ian said, has got a lot of, the 15 current PRA has a lot of assumptions in it and those 16 assumptions have fed into some key decisions that if 17 that were to change just before fuel load, I mean, in 18 reality, what are you going to do about it? What if 19 the source term changes? I mean, there's assumptions 20 from the PRA that went into choosing the size of the 21 source term. There's assumptions in the PRA that went 22 into picking this site boundary limits and things of 23 that sort. If those were to change at the, you know, 24 at the very end like that, I can't imagine we'd do 25 anything other than some hand-waving.
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84 1 CO-CHAIRMAN RAY: Well, you guys are going 2 to talk PRA as a separate topic. This is --
3 CO-CHAIRMAN RICCARDELLA: We've had a 4 meeting on that a couple of months ago, and, you know, 5 I'm not critical of that. That seemed like it was 6 very well done. Our PRA experts thought it was well 7 done, but there still are a lot of inherent 8 assumptions.
9 CO-CHAIRMAN RAY: Okay. Thank you. Dick?
10 MEMBER SKILLMAN: No further comments.
11 Thank you.
12 CO-CHAIRMAN RAY: Matt?
13 MEMBER SUNSERI: I've been following along 14 the QA discussions. As you know, we had several 15 conversations out here, and I share many of the 16 members' questions about this. So I'll just not 17 answer because all my questions have been asked 18 already. Thanks.
19 CO-CHAIRMAN RAY: Okay. Jose?
20 MEMBER MARCH-LEUBA: I want to emphasize 21 what Pete said. I mean, he took the thought out of my 22 head. We are making a lot of decisions about the plan 23 based on an assumption on a PRA, and I would like from 24 the staff to make sure that they tell NuScale that 25 NuScale is doing that at their own risk. Don't expect NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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85 1 us to hand-wave anything if you're wrong at the end of 2 the design, which is probably the most likely 3 scenario.
4 So the staff should make sure that if you 5 make an assumption and you are wrong, you are wrong.
6 You lose your money. Okay. So that should be very 7 clear.
8 CO-CHAIRMAN RAY: Thank you. Ron?
9 MEMBER BALLINGER: No further comment.
10 CO-CHAIRMAN RAY: And Charlie?
11 MEMBER BROWN: No further comment.
12 CO-CHAIRMAN RAY: Okay. So the reason we 13 do this last part here is more setting an agenda for 14 our discussions --
15 MEMBER BLEY: Dennis is still here.
16 CO-CHAIRMAN RAY: Yes, I know, Dennis.
17 And I was just, I had written your name at the top of 18 the list, and I wasn't going to forget it. But I just 19 wanted to say I appreciate your speaking up. But, 20 anyway, we're trying to set an agenda of items, and so 21 we'll turn to our expert on PRA, Dennis, and ask you 22 to finish us up.
23 MEMBER BLEY: I have just a couple of 24 things to mention. One is the issue Pete brought up 25 is important, and we've brought it up before in other NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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86 1 design certs. What we've been told by other vendors, 2 designers, is that, although the PRA has to be in and 3 the operating has to be in place before fuel load, 4 they really expect to have all that in place two or 5 three years before that so that there's time to deal 6 with these issues. If that's not true, they're taking 7 a heck of a risk.
8 The other thing is I did take a quick 9 review of the SECY they brought up on the last slide.
10 This is just my own opinion. It's a reasonable 11 argument, I think, and it's backed up by other policy 12 decisions. So I'm not really concerned about that.
13 That's all.
14 CO-CHAIRMAN RAY: Thank you, Dennis.
15 Margaret, are you still with us?
16 MEMBER CHU: No comments.
17 CO-CHAIRMAN RAY: Any comments from anyone 18 else on the phone line? Or if there's anyone here in 19 the room, is there anyone who wants to make further 20 comment?
21 Okay. I'll say I've said perhaps too much 22 here today. My intent is to try to narrow the things 23 that are outstanding issues. One of them was 24 clarifying the applicability of the NuScale program.
25 I'm still mystified by the idea that we don't NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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87 1 recognize that it's a part of the design 2 certification, just like everything else is; and, 3 therefore, it remains in effect as the design 4 certification occurs for the scope of the certified 5 design. That's what I read in some places and not in 6 others. So we'll perhaps want to clarify that.
7 We'll reflect on the issues of PRA, but I 8 really think the best place to discuss the timing 9 issues created by PRA is in the context of PRA, rather 10 than QA. And that will come up shortly. We'll see 11 where that goes.
12 And with that, I appreciate everyone's 13 time. We've taken --
14 MEMBER CORRADINI: We'll take a break.
15 CO-CHAIRMAN RAY: -- two hours. It's time 16 for a break, according to the boss.
17 MEMBER CORRADINI: Ten minutes.
18 CO-CHAIRMAN RAY: And then we'll shift 19 gears to Chapter 2.
20 MEMBER CORRADINI: All right. We'll be 21 back at 3:10 to take on Chapter 2.
22 (Whereupon, the above-entitled matter went 23 off the record at 2:59 p.m. and went back on the 24 record at 3:12 p.m.)
25 MEMBER CORRADINI: Okay, why don't we come NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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88 1 back together? And we'll begin on Chapter 2. Paul, 2 are you going to take us through this?
3 MR. INFANGER: Yes, I'll start. I'm Paul 4 Infanger. Continuing from our presentation on Chapter 5 17, we'd just like to introduce J. J. Arthur from 6 Engineering.
7 MR. ARTHUR: Good afternoon. My name is 8 J. J. Arthur, Manager of Structures and Design 9 Analysis at NuScale. I've been at NuScale for just 10 over eight years. Prior to that was non-nuclear 11 experience working on refractory and reactive metals 12 industry, site mechanical engineering at Oregon State.
13 MR. INFANGER: All right, with that we'll 14 start with slide 2, which has the FSAR overview.
15 MR. ARTHUR: All right, so the purpose of 16 our presentation this afternoon is to present a 17 summary of Chapter 2 of the NuScale FSAR, which 18 provides assumed site characteristics and parameters 19 for the NuScale design. We will also summarize --
20 provide a summary of the RAIs received thus far in 21 this area, along with SER and confirmatory items, 22 which Paul will cover at the end.
23 Chapter 2 of the NuScale FSAR contains a 24 description of assumed site characteristics and 25 parameters that are intended to be representative of NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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89 1 a reasonable number of potential site locations in the 2 United States. These parameters are provided in Table 3 2.0-1 and described in the following subsection of 4 Chapter 2: Section 2.1, Geography and Demography; 5 Section 2.2, Nearby Industrial, Transportation, and 6 Military Facilities; Section 2.3, Meteorology; Section 7 2.4, Hydrology; and finally, Section 2.5, Geology, 8 Seismology, and Geotechnical Engineering.
9 As you will note throughout the 10 presentation, the site parameters contained within 11 Chapter 2 are generally consistent with past applicant 12 precedents, as well as the 2014 edition of the EPRI 13 Utility Requirements Document.
14 This slide depicts the conceptual layout 15 of the NuScale power plant. Maybe some of you have 16 seen this. In the center is the reactor building, 17 where the 12 reactors are located. It's flanked by 18 two turbine buildings, six turbines in each building; 19 the control building, where the control room resides, 20 as well as the rad waste building.
21 A minimum analytical X/Q distance from the 22 nearest release point to the exclusionary boundary and 23 the coincident outer boundary of the low population 24 zone boundary is also shown on this slide as 400 feet 25 there at the bottom.
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90 1 MEMBER MARCH-LEUBA: Is this a conceptual 2 design or you are sure the LPZ will be equal to the 3 EAB?
4 MR. ARTHUR: This is the assumed minimum 5 distance, the 400.
6 MEMBER MARCH-LEUBA: The LPZ could be 7 larger than this?
8 MR. ARTHUR: Correct.
9 MEMBER CORRADINI: So okay, can I say it 10 another way? Since the major open item in this 11 chapter is the source term that would determine this, 12 this is a starting point which can change.
13 MR. ARTHUR: Correct.
14 MEMBER CORRADINI: Okay.
15 MR. ARTHUR: Just to reiterate again, the 16 site design parameters in Chapter 2 are site-specific.
17 Therefore, the parameters chosen are believed to be 18 representative of a reasonable number of potential 19 site locations in the U.S. and the COL applicant will 20 demonstrate that their site is either bounded by the 21 parameters provided or demonstrate the acceptability 22 of their site-specific values.
23 This is a reiteration of a couple slides 24 earlier, this 400 feet value to the EAB and LPZ. In 25 Section 2.1, the COLA applicant will describe their NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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91 1 site-specific characteristics.
2 We do not -- sorry, was there a question?
3 Okay.
4 We do not postulate any hazards from 5 nearby industrial, transportation, or military 6 facilities. These are addressed by a COLA applicant, 7 if applicable.
8 MEMBER MARCH-LEUBA: Just for my 9 education, what if there is an airport close by, I 10 cannot site your plant?
11 MR. ARTHUR: I'm sorry. Can you repeat 12 the question?
13 MEMBER MARCH-LEUBA: What if there is an 14 airport close by? I cannot site your plant, or I have 15 to take an exception, or what?
16 MR. ARTHUR: Correct.
17 MEMBER MARCH-LEUBA: There are airports 18 near everywhere. I mean you cannot site your plant.
19 MR. ARTHUR: The applicant -- the COLA 20 applicant would be required to address that hazard.
21 MEMBER MARCH-LEUBA: Wouldn't it be more 22 wise to just assume a certain rate of flights, 23 minimum, because you are going to have? There are 24 airports every ten miles. That's my personal opinion.
25 MEMBER SKILLMAN: Let me ask this, please.
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92 1 Please back a slide.
2 I'm looking at your application for your 3 design cert and this is your security-related 4 information. And your COL item 2.2-1 is as follows:
5 A COL applicant that references the NuScale power 6 plant design certification will describe nearby 7 industrial, transportation, military facilities, just 8 like you have right there. The COL applicant will 9 demonstrate that the site is acceptable for each 10 potential accident or provide site-specific design 11 alternatives. I got that.
12 I see that over in the safety evaluation.
13 What I think you're really referring to is Part 14 100.20(b). And what this text is is different than 15 what is in your application.
16 Here is the text in 100.20(b): The nature 17 and proximity of manmade hazards, and then, in paren, 18 airports, dams, transportation routes, military and 19 chemical facilities must be evaluated to establish 20 site characteristics for use in determining whether a 21 plant design can accommodate commonly occurring 22 hazards and whether the risk of other hazards is very 23 low.
24 Here's my question: Why in your 25 application have you not included the words manmade?
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93 1 MR. INFANGER: Is anyone in the NuScale 2 office familiar with the use of the wording for 3 manmade hazards versus just general?
4 MEMBER CORRADINI: Also, there is some 5 background noise. If you are not going to make an 6 answer, can you please mute your phone line, please?
7 Thank you.
8 MR. PARKER: This is Josh Parker. I did 9 the structural analysis. I was involved with it in 10 the Chapter 2 work.
11 I don't think there was any intentional 12 reason for leaving out manmade, necessarily.
13 MEMBER SKILLMAN: The skeptic in me 14 suggests by wording this COL item the way you have, 15 you have avoided either accidentally or on purpose a 16 very major concern that we've dealt with on manmade 17 hazards. And it would seem to me that the remedy is 18 to make the wording in your COL item 2.2-1 the same as 19 the wording in 100.20. At least that would solve the 20 concern that I have.
21 MR. BERGMAN: So we'll take it -- we'll 22 look into that prior to the full committee but --
23 sorry. This is Tom Bergman with NuScale.
24 In our view, though, a COL item that is 25 just restating a requirement that applies regardless NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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94 1 of the existence of the COL item doesn't need to be a 2 COL item but that hasn't been accepted by the staff 3 yet, that approach. Because the COL has to comply 4 with all regulations that comply with it, whether or 5 not there is a COL item that reminds them of that 6 requirement.
7 So we'll look into either making the 8 language consistent with or removing the COL item.
9 MEMBER SKILLMAN: Thank you.
10 Thank you, J. J., proceed please.
11 MR. ARTHUR: Section 2.3 for meteorology, 12 the maximum assumed precipitation rate, the roof snow 13 load, and the 100-year return three-second wind gusts 14 are shown here and all come from the 2014 edition of 15 the URD.
16 The design basis tornado parameters are 17 taken directly from Regulatory Guide 1.76 and are 18 representative of Geographical Region I, which 19 represent the most severe set of characteristics 20 provided by the Reg Guide.
21 MEMBER SKILLMAN: Let me ask this, and 22 this is more perhaps trivia but curiosity.
23 If excluded, the protectorates, Guam, the 24 Virgin Islands, the Northern Marianas, American Samoa, 25 and Puerto Rico. Why?
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95 1 MEMBER CORRADINI: Where was that 2 excluded, Dick? Did I miss it?
3 MEMBER SKILLMAN: Yes, in the text the 4 territories are excluded. And I'm just wondering why 5 aren't those an opportunity for NuScale.
6 MEMBER CORRADINI: He's going to pass.
7 MR. ARTHUR: I don't think those words are 8 in our FSAR. I think they are in the SER.
9 MEMBER SKILLMAN: I think you're right.
10 But why are they excluded anyways? But I would think 11 NuScale might have something to say about that and 12 I'll ask the staff.
13 MEMBER CORRADINI: But I mean just a point 14 of information, there was a bulletin but it wasn't out 15 of NuScale. It was out of NEI that NuScale is one of 16 those going into Puerto Rico now considering modules 17 there for reliable power.
18 MEMBER SKILLMAN: It sounds like a perfect 19 application. I was just wondering why it's excluded.
20 I guess it's in the SER. I figured NuScale might have 21 something to say about that.
22 MR. ARTHUR: Do you have anything to say 23 about that, Tom?
24 MR. BERGMAN: Okay so I'm not familiar 25 with the details but Chapter 2 is a representative NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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96 1 range of sites. It doesn't preclude us from going 2 anywhere. It's just where the site we go to doesn't 3 meet the parameters in Chapter 2, they have to justify 4 the difference.
5 Why there is an exclusion of specific 6 portions of U.S. territories I can say but I wouldn't 7 see that as an impediment, even if it existed. We 8 would just have to justify why our design was 9 acceptable for Puerto Rico, even though the staff 10 didn't include it in their SER.
11 MEMBER SKILLMAN: Fair enough. Thank you.
12 MR. ARTHUR: The tornado missile spectra 13 are also taken from Reg Guide 1.76 with 14 characteristics associated with Region 1 as well.
15 Similarly, the design basis hurricane wind 16 speed and missile spectra are taken from Regulatory 17 Guide 1.221. And as with design basis tornado, the 18 most extreme characteristics were assumed for the 19 design.
20 For HVAC and cooling tower design, outdoor 21 air temperatures are categorized into three sets of 22 conditions: zero percent exceedance, which are shown 23 on this slide; and one and five percent exceedance 24 shown in the next slide.
25 Zero percent exceedance values were used NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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97 1 for the design of the control room ventilation system 2 as recommended by the EPRI URD.
3 One percent exceedance values were used 4 for the design of the reactor building and radioactive 5 waste building HVAC systems, as well as the site 6 cooling and circulating water designs.
7 We'll note the typo in the slide. That 8 should be RXB in the first bullet.
9 Finally, the five percent exceedance 10 values shown were used for the design of the turbine 11 building HVAC systems.
12 Again, these temperatures were chosen by 13 NuScale for the categories in which systems are design 14 and in accordance with which parameters was EPRI 15 recommendations.
16 As noted earlier, the distance from the 17 nearest release point to the exclusionary boundary and 18 the outer boundary of the low population zone boundary 19 is 400 feet. Given this comparatively short distance, 20 NuScale applied the ARCON96 methodology based on 21 Regulatory Guide 1.194 in calculating atmospheric 22 dispersion factors. This methodology is still under 23 review in the accident source term topical report.
24 The top of this slide shows the accident 25 release atmospheric dispersion factors for the EAB/LPZ NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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98 1 boundary and the bottom shows the accident release X/Q 2 values at the door to the main control room and the 3 technical support center, as well as the intake of the 4 HVAC system for the main control room.
5 CO-CHAIRMAN RICCARDELLA: Are these based 6 on that 400-foot boundary?
7 MR. ARTHUR: Correct.
8 CO-CHAIRMAN RICCARDELLA: But again, with 9 an assumed source term.
10 MR. ARTHUR: Right.
11 MEMBER CORRADINI: So let me ask it 12 different. Let me ask Pete's question a different 13 way. If the source term were different, the X/Q 14 values would not change. This is more based on 15 distance from the point of source.
16 MR. ARTHUR: Distance from the point of 17 source, assumptions about weather, release 18 notifications, and things like that.
19 MEMBER CORRADINI: These are nominal 20 assumptions.
21 MR. ARTHUR: Correct.
22 MEMBER CORRADINI: So this could change.
23 If the source term changes and you still want to meet 24 your limits, they could go further out, if necessary.
25 MR. ARTHUR: Right.
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99 1 MEMBER CORRADINI: Okay, thank you.
2 MR. ARTHUR: Routine release atmospheric 3 dispersion factors and the deposition factor at the 4 exclusionary boundary are shown here. And as was just 5 mentioned by you, the COL applicant will update these 6 factors consistent with their site meteorology.
7 For hydrology, we have specified the 8 maximum flood elevation and maximum groundwater 9 elevation consistent with previous applicants and the 10 EPRI URD at 1 foot and 2 feet below the baseline plan 11 elevation respectively. COL applicant will confirm 12 these and describe their site-specific hydrology.
13 For geology and seismology, the design 14 assumes parameters that are representative of a 15 reasonable number of plant sites in the United States.
16 Two design basis earthquakes are assumed with a 17 certified seismic design response spectra or CSDRS and 18 a high frequency version of that.
19 These spectra bound most of the central 20 and eastern United States and sites in less 21 seismically active portions of the western U.S.
22 The balance of the parameters shown in 23 this slide are consistent with past applicants and the 24 recommendations of the URD.
25 CO-CHAIRMAN RICCARDELLA: I assume these NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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100 1 are based on the new updated central and eastern 2 United States seismology -- seismic risk report? I 3 forget the NUREG --
4 MR. ARTHUR: I'm going to phone a friend 5 here.
6 CO-CHAIRMAN RICCARDELLA: Pardon me?
7 MR. ARTHUR: Josh Parker, can you answer 8 that?
9 MR. PARKER: Yes, I mean our spectra was 10 developed initially in the 2010-2012 time frame and 11 they were consistent with the spectra available at the 12 time. The current spectra still bounds a number of 13 sites in the central and eastern United States --
14 CO-CHAIRMAN RICCARDELLA: Okay.
15 MR. PARKER: -- as well as the slide 16 indicates, the less seismically active areas of the 17 western United States.
18 CO-CHAIRMAN RICCARDELLA: Okay, thank you.
19 MR. ARTHUR: So we assume no potential for 20 liquefaction or slope failure. And the maximum 21 assumed settlement values are shown here: a total of 22 four inches, half an inch per 50-foot of building 23 length for tilt and a differential settlement of a 24 half inch.
25 MEMBER CORRADINI: There seems to be NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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101 1 background noise in a kitchen. Could somebody please 2 mute their phones? Thank you.
3 CO-CHAIRMAN RICCARDELLA: Whoever is doing 4 your dishes, mute your phone.
5 MEMBER SKILLMAN: Let me ask this. On 6 slide 16, back a slide -- excuse me -- on this slide, 7 the tilt and total. Is there a unique discipline that 8 will be required on this site because the reactor 9 building is basically filled with water and there are, 10 at least the full build, 12 modules in that building?
11 This building is going to have a very 12 strong footprint, probably stronger than any we've 13 seen. Does that obligate something different in terms 14 of settlement and tilt?
15 MR. ARTHUR: I'd point that back to Josh 16 Parker as well.
17 MR. PARKER: Yes, I don't think it 18 obligates anything different. We still account for 19 the total mass. We still evaluate that on the generic 20 soil profile and evaluate the overall settlement. And 21 the COL applicant wants to do a similar analysis for 22 the site-specific conditions.
23 So while you are right, it is obviously 24 different and it has a lot of water in it, the process 25 for determining the overall settlement and tilt is NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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102 1 still the same as it would be for any other applicant.
2 MEMBER SKILLMAN: Okay, just let me ask 3 one more question.
4 So you, not you personally, NuScale is 5 going to build one of these -- let's presume they 6 build one of these machines and they start with one 7 module and then a second. And there are ten vacant 8 spaces. And then they do the third and the fourth.
9 This is not different than loading a 10 supertanker and unless that loading is balanced, at 11 least in the supertanker, you can deflect and you can 12 destroy the haul unless you do it right. There is a 13 loading sequence, whether it is a bulk carrier or 14 particularly something that is carrying dry cargo 15 versus liquid cargo.
16 Is there a thought given to the settlement 17 that will occur because the loading beyond the water 18 footprint load is different because the module build 19 may be not symmetric?
20 MR. ARTHUR: I know we've done some 21 sensitivity studies in the seismic analysis for 22 different configurations of modules in the building.
23 I don't know if we specifically have addressed that 24 for settlement.
25 MR. PARKER: Yes, I was just going to NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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103 1 mention that same thing.
2 In Chapter 3 we talk about that aspect 3 that you are referring to. And there is a COL item 4 for the site-specific vendor to confirm how modules 5 are going to be loaded into the plant and then perform 6 subsequent analyses to ensure adequacy of the design.
7 MEMBER SKILLMAN: Thank you.
8 CO-CHAIRMAN RICCARDELLA: You know I saw 9 a number in your report in terms of the required 10 static pounds per square foot of the capacity of the 11 soil. Is that significantly different than say a 12 standard PWR or BWR?
13 MR. PARKER: No, that's similar to other 14 designs. It's consistent with them.
15 CO-CHAIRMAN RICCARDELLA: Okay, thank you.
16 MEMBER KIRCHNER: Just for clarification, 17 it's consistent with what EPRI has estimated as needed 18 or it is consistent with your fully loaded 12-module 19 building and the resultant load that that provides?
20 MR. PARKER: Yes, maybe I misunderstood 21 the initial question. I thought the initial question 22 was on the available bearing capacity. And that 23 bearing capacity is consistent with past applicants' 24 assumed values. The load bearing command values is 25 based on analyses.
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104 1 CO-CHAIRMAN RICCARDELLA: And is that 2 significantly different than the bearing demand for a 3 standard P or BWR?
4 MR. PARKER: I couldn't speak to that off 5 the top of my head. I would have to look at past 6 applications.
7 CO-CHAIRMAN RICCARDELLA: Okay. I was 8 just trying to get to Dick's point about whether the 9 density is greater or less than a current design. But 10 maybe you could have an answer to that by a full 11 committee meeting.
12 MEMBER SKILLMAN: Yes, the requirement for 13 the soil-bearing capacity, the gentleman is right. I 14 agree with that.
15 I'm just thinking of a large building 16 filled with water and you add 12 several hundred-ton 17 modules to that and you do not do that symmetrically.
18 Do you crack the building?
19 You can break a supertanker. You can 20 break a bulk carrier. You can snap its backbone if 21 you don't do it right.
22 MR. ARTHUR: Yes, we'll look into that.
23 MEMBER SKILLMAN: Okay.
24 MR. INFANGER: We had a number of RAIs on 25 Chapter 2. As you can see, we've -- the majority of NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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105 1 them are resolved closed, or the supplements have been 2 submitted and are under evaluation, and some of them 3 are in the confirmatory status.
4 We have one unresolved closed item. It 5 has to do with the release of radioactive of liquid 6 effluents in groundwater and we're proposing or in the 7 middle of discussions on how to resolve that issue.
8 MEMBER KIRCHNER: Just for clarification, 9 when you say accident release, now we're talking about 10 a single module, right, which is different from normal 11 effluence, where it would include all 12 modules, 12 right?
13 MR. INFANGER: I believe it's from the rad 14 waste building. So it would be common.
15 MEMBER KIRCHNER: Oh, from the rad waste 16 building. Okay.
17 MR. ARTHUR: Actually, no. It's from the 18 pool surge control tank that's outside the reactor 19 building.
20 MEMBER KIRCHNER: Oh.
21 MR. INFANGER: Thank you. That's a common 22 structure?
23 MR. ARTHUR: Yes.
24 MR. INFANGER: It's still common -- it's 25 a common structure.
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106 1 MEMBER CORRADINI: This is the open item.
2 I guess I misunderstood. This is not the same as the 3 unresolved closed.
4 What's such a thing as an unresolved 5 closed?
6 MR. INFANGER: That means we've had an 7 RAI, we've sent a response, and the response the staff 8 has said that they need additional information.
9 MEMBER CORRADINI: Oh, so they've come 10 back to you another time.
11 MR. INFANGER: Yes. We don't have a 12 written question yet. So we're in discussions.
13 MEMBER CORRADINI: Okay, thank you.
14 MR. INFANGER: There is one SER open item 15 is on the X/Q values for the EAB and LPZ. And that's 16 in the accident source term topical report which is 17 under review.
18 This is just one of the confirmatory 19 items. I believe there are 11 confirmatory items.
20 This slide has been deleted.
21 That concludes our presentation.
22 MEMBER MARCH-LEUBA: So the open items is 23 the method for calculating the LPZ.
24 MEMBER CORRADINI: The open items is the 25 source term that would be used in the calculation.
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107 1 MEMBER MARCH-LEUBA: Can you go to slide 2 18, acceptability of method for calculating accidents?
3 MR. INFANGER: Yes, it's the methodology 4 for calculating our X/Q. And a lot of it is using the 5 ARCON96 versus PAVAN. And it's the ARCON96 has been 6 used in the industry for control room doses. And 7 since our site boundary is essentially about the size 8 of most sites for control room dose, that code was 9 more applicable.
10 PAVAN is for much, much larger sites, 11 several miles.
12 MEMBER MARCH-LEUBA: But the calculation 13 keeps looking at the source term.
14 MEMBER CORRADINI: Yes, I guess maybe I'm 15 misreading the open item. I apologize. That could be 16 my mistake.
17 But I thought open item was to determine 18 the subject conditions limitations NuScale methodology 19 is acceptable for calculating accident offsite X/Qs.
20 This review is being tracked as an open item.
21 So I thought the methodology is dependent 22 upon the source term that is being used and I thought 23 that topical report was the alternative source term 24 you're proposing.
25 MR. ARTHUR: If would have Mark Shaver NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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108 1 jump in here, I think the answer is that this 2 methodology is described in the accident source term 3 topical report but it does not depend on the source 4 term itself.
5 Mark, can you confirm that is true?
6 MR. SHAVER: This is Mark Shaver. I'm a 7 radiological engineer at NuScale.
8 J. J. is correct, the accident source term 9 topical report has the methodology to develop the 10 accident source terms, as well as Section on our 11 methodology to determine the EAB and LPZ X/Qs.
12 So the open item is that it's contingent 13 on the source term topical for the X/Q methodology.
14 MEMBER CORRADINI: Oh, okay. That's my 15 mistake then. I apologize.
16 MR. SHAVER: But methodologies are in it.
17 MEMBER CORRADINI: Okay, I misunderstood.
18 You were referencing the topical report. I thought it 19 was the source term itself but it's the methodology 20 because the presumption is it's close in.
21 Okay, thank you.
22 MR. SHAVER: Correct and the X/Q is not 23 dependent on the source term.
24 CO-CHAIRMAN RICCARDELLA: The source term 25 part of that has been accepted?
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109 1 MR. ARTHUR: Both are under review.
2 CO-CHAIRMAN RICCARDELLA: Okay.
3 MEMBER MARCH-LEUBA: And that's not an 4 open item or is under review on a different chapter?
5 MR. INFANGER: It's not an open item for 6 Chapter 2.
7 MR. SHAVER: Yes, that's Chapter 15.
8 MR. INFANGER: Oh, okay.
9 MEMBER CORRADINI: It's your favorite 10 chapter.
11 MEMBER MARCH-LEUBA: That one has 12 problems.
13 CO-CHAIRMAN RICCARDELLA: They're both 14 covered in that topical report, though.
15 MR. ARTHUR: Yes.
16 CO-CHAIRMAN RICCARDELLA: All right.
17 MEMBER MARCH-LEUBA: One final question.
18 We recently have been reviewing the early site permit 19 for Clinch River where they have one review as you 20 guys. Is the methodology similar to the one that TVA 21 used? I mean, have you at least coordinated with 22 them?
23 MR. INFANGER: I'm not familiar with what 24 TVA has submitted.
25 MEMBER MARCH-LEUBA: Because it's a NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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110 1 completely independent operation.
2 MR. INFANGER: That's correct.
3 MEMBER CORRADINI: Just for the sake of 4 information remember for their sizing, they took a 800 5 megawatt thermal source term sized by four different 6 potential but it was at 800 megawatts thermal.
7 MEMBER MARCH-LEUBA: We're not talking 8 about source term here. We're talking about how to 9 propagate it to the boundary, which is what they did.
10 MEMBER CORRADINI: But that methodology is 11 similar.
12 MEMBER MARCH-LEUBA: I'm pretty sure it's 13 similar but they said they did not coordinate.
14 MR. INFANGER: Any other questions?
15 MR. SHAVER: This is Mark Shaver. That is 16 correct, we did not coordinate with TVA on our X/Qs.
17 MEMBER CORRADINI: Shall we move on? It 18 looks like the committee is silent. So, let's move 19 on.
20 Shall we get the staff up here?
21 MR. INFANGER: You guys are ready for the 22 staff?
23 MEMBER CORRADINI: There are a lot of 24 slides. So I assume there are a lot of staff.
25 MR. CHOWDHURY: Good afternoon. My name NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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111 1 is Prosanta Chowdhury. I am with NOR, Office of New 2 Reactors, Division of Safety and Environmental 3 Assessment. The branch is LB1, Licensing Branch 1.
4 I have been with the NRC for about 14 years now, 10 of 5 which I have been working as the project manager in 6 NRO. My background is I have a master's degree in 7 electrical engineering and one in nuclear engineering.
8 And today we are presenting the staff 9 evaluation of NuScale design certification application 10 Chapter 2, Site Characteristics.
11 So the technical branches that are 12 represented here today are Radiation Protection and 13 Accident Consequences Branch, Hydrology and 14 Meteorology Branch, and Geosciences and Geotechnical 15 Engineering Branch. So under RPAC, Radiation 16 Protection and Accident Consequences Branch, Section 17 2.1, Geography and Demography, and Section 2.2, Nearby 18 Industrial, Transportation, and Military Facilities, 19 these two sections will be presented by that branch.
20 Hydrology and Meteorology Branch, we present Section 21 2.3, Meteorology and Section 2.4, Hydrology 22 Engineering. Geosciences and Geotechnical Engineering 23 Branch will present 2.4 -- 2.5, Geology, Seismology, 24 and Geothermal Engineering -- Geotechnical Engineering 25 actually.
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112 1 So the staff interactions with NuScale for 2 Section 2.3, which is meteorology requests for 3 additional information, ten questions were asked.
4 Four questions closed, six confirmatory action pending 5 EPSAR update and one open item.
6 So the review here that the staff 7 completed is based on Revision 1 of the application.
8 So we received Revision 2 of the application in 9 October. And the SE will be updated accordingly 10 later.
11 Section 2.4 has one question and that has 12 been closed, three confirmatory actions pending EPSAR 13 update.
14 Section 2.5 had three question; one 15 closed, two confirmatory action pending EPSAR update.
16 So today we have with us Rao Tammara. He 17 will be -- he is sitting next to me and he will be 18 presenting the staff evaluation on Sections 2.1 and 19 2.2. Next to him is Michael Mazaika. He will be 20 covering his evaluation of Sections 2.3.1 through 21 2.3.3. Jason White, next to Mike, will cover Sections 22 2.3.4 and 2.3.5. Yuan Cheng will cover Section 2.4.
23 And finally, Weijun Wang will cover Section 2.5.
24 So branch chiefs involved in this review 25 is Stephanie Devlin-Gill with Hydrology and NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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113 1 Meteorological Section and she is present in the 2 audience.
3 Gerry Stirewalt is the Branch Chief of 4 RGS, which is Geology and Seismology branch. And Mike 5 Dudek, I don't believe he is in the audience, but he 6 is with RPAC.
7 And once again, I am Prosanta Chowdhury, 8 Project Manager.
9 With that, we are going to go into Section 10 2.1 and 2.2 and Rao Tammara will cover that.
11 MR. TAMMARA: Good afternoon. My name is 12 Rao Tammara. I have 45 years of experience, out of 13 this 22 with a consulting company doing the similar 14 work preparing the FSAR, EA, and the EIS sections for 15 utilities and government agencies. And for the past 16 18 years I am with the NRC doing FSAR and SSER 17 Chapters 2.1, 2.2 and also aircraft hazards, covering 18 the COLs and the ESP applications and design 19 certifications.
20 Next, this application I am the lead 21 reviewer for the Chapter 2 Site Characterizations 22 covering the Sections 2.1 and 2.2. Next slide, please 23 -- previous slide.
24 This Section 2.1 contains -- I mean 25 addresses the geography and demography. Section 2.2 NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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114 1 addresses the nearby industrial, transportation, and 2 the military facilities. Next slide, please.
3 Section 2.1, Geography and Demography 4 covers the areas addressing site location and the 5 description, exclusion area authority and control, and 6 population distribution. Since all this information 7 is site-specific, the DC will not have the information 8 to review; however, to see where the applicant 9 referencing the NuScale Power design is to provide 10 this site-specific information as a part of COL 11 information item 2.1-1 in the COL application.
12 Next slide, please.
13 Section 2.2 covering the nearby 14 industrial, transportation, and military facilities 15 will address the locations and the routes of all the 16 facilities within five miles of the site, descriptions 17 of the products, and manufacturing products, and also 18 evaluation of those facilities that may have a 19 potential on the proposed facility. Manmade hazards 20 these are all.
21 Since this is a design-specification or 22 design certification application, the site-specific 23 information is not addressed for this application.
24 Therefore, the applicant, COL applicant referencing 25 the NuScale Power design is to provide the site-NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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115 1 specific information as a part of COL Information Item 2 2.2-1 in the COL application.
3 So, all the site-specific information will 4 be provided at the COL stage.
5 That is my presentation.
6 MEMBER SKILLMAN: I'd like to ask a 7 question here. And it is Section 2.2.1 and among your 8 safety evaluation at page 2-12, and here is the text.
9 And the reference for my question is this: The ACRS 10 is looking at the Clinch River site as a potential 11 location for a NuScale plant.
12 MR. TAMMARA: That is a potential, yes.
13 MEMBER SKILLMAN: Yes, okay. And it has 14 a neighbor that's called Oak Ridge National 15 Laboratory.
16 MR. TAMMARA: That's correct.
17 MEMBER SKILLMAN: So here's the COL item:
18 A COL applicant that refers the NuScale Power Plant 19 certification will describe nearby industrial, 20 transportation, and military facilities. The COL 21 applicant's information should describe the primary 22 function of each facility and the nature of the 23 hazards that it presents. This information for each 24 facility should include the facility's primary 25 function, major products, number of employees, NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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116 1 materials regularly manufactured, stored, used, or 2 transported near the site and the hazards that could 3 result from accidents at each facility.
4 How is a COL applicant going to respond to 5 this if its neighbor is Oak Ridge National Laboratory?
6 MR. TAMMARA: It is the COL application.
7 If you take a look at the COL application the Clinch 8 River it has been assessed. I mean I assess it in the 9 sense the nearby facility has been addressed in the 10 Clinch River application.
11 MEMBER SKILLMAN: Okay, thank you.
12 MR. TAMMARA: Because it is not a design 13 basis but the facility is addressed. That is correct.
14 MR. CHOWDHURY: Anything else on 2.1 and 15 2.2, before we move on to 2.3?
16 MR. TAMMARA: I will turn it over to Mike 17 Mazaika to cover the site meteorology.
18 MR. MAZAIKA: Everybody hear okay? Okay.
19 Good afternoon, folks. My name is Mike 20 Mazaika. I'm one of several meteorologists in NRO and 21 have been on staff for just over ten years. Before 22 that, I spent 30 years in the engineering consulting 23 and air pollution research industries.
24 MEMBER MARCH-LEUBA: Mike, talk into the 25 microphone because there is people on the phone line.
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117 1 MR. MAZAIKA: Okay. Better?
2 Okay, before that I spent 30 years in the 3 engineering consulting and air pollution research 4 industry, including support for nuclear and fossil 5 projects. Next slide, please.
6 My presentation will cover the review of 7 2.3.1 through 2.3.3 of Revision 1 of the FSAR. My 8 colleague, Jason White will present the review of FSAR 9 Section 2.3.4 and 2.3.5 10 The last bullet on this slide which was 11 brought up earlier points out potential plant site 12 locations include all 50 states in the U.S., Alaska, 13 and Hawaii but that the DCA is silent on U.S.
14 Territories. That was brought up in an RAI question 15 for clarification.
16 Next slide, please.
17 This slides indicates that the applicant 18 postulated site parameters for various climatic 19 extremes, and for design basis accident, and routine 20 release atmospheric dispersion and deposition factors.
21 The staff performed its review in accordance with 22 applicable standard review plan sections, associated 23 regulatory guidance, and related data resources.
24 Finally, we note that eventual COL 25 applicants will need to compare their site NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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118 1 characteristics to the site parameter values 2 postulated for the NuScale design. Next slide, 3 please.
4 This slide covers site parameters related 5 to extreme rainfall. The postulated site parameters, 6 which you've seen before, are related are 19.4 inches 7 per hour and 6.3 inches in five minutes. The values 8 are used, in part, in determining roof loading, which 9 is reviewed under Chapter 3.
10 In Section 2.3.1 we evaluate the site 11 parameters themselves. The postulated site parameter 12 values are consistent with most of the previously 13 submitted DCAs and on that basis, the staff considers 14 these site parameter values representative of a 15 reasonable number of locations in the contiguous U.S.
16 and for the State of Alaska.
17 Next slide, please.
18 This slide addresses winter precipitation.
19 The applicant site parameters for normal and extreme 20 winter precipitation events, they are 50 and 75 pounds 21 per square foot. They represent roof loads only.
22 Based on Interim Staff Guidance 007 and the SRP, 23 Section 2.3.1 is looking for the basic data as ground 24 snow loads. Conversion to roof loads is handled in 25 Chapter 3.
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119 1 The applicant did not specify the return 2 period for its postulated values. The guidance in the 3 ISG and the SRP calls for a return period of 100 4 years. Staff performed its review on that base, using 5 the 50-year ground snow load data and conversion 6 factors for other return periods in ASCE/SEI 7-10.
7 The staff focused on the snow load data 8 and the ASCE/SEI document, although the ISG also 9 considers rain on top of snow in the form of probable 10 maximum winter precipitation. The reactor and control 11 building roofs limit accumulation of liquid 12 precipitation so that frozen winter precipitation 13 events should be controlling.
14 The staff considers the site parameter 15 values postulated as roof loads to be representative 16 of a reasonable number of locations in the continental 17 U.S., including some portions of Alaska. Next slide, 18 please.
19 The next two slides summarize the staff's 20 review of the site parameters for design basis winds.
21 One hundred-year return period severe wind speed value 22 on this slide and tornado and hurricane-related 23 extreme winds on the next slide, which have much 24 longer return periods.
25 Severe wind speeds are represented by a NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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120 1 three-second gust, as opposed to a sustained wind 2 speed. Consistent with several other design 3 submittals, this site parameter value, which is 145 4 miles per hour, when multiplied by a designated 5 importance factor shown in Chapter 3, represents a 6 100-year return period. According to the FSAR, this 7 value is applied to the reactor control and 8 radioactive waste buildings.
9 The staff performed its review using the 10 50-year basic wind speed values and 50- to 100-year 11 conversion factors presented in ASCE/SEI 7-05. The 12 staff considers that the site parameter value and 13 related characteristics are representative of a 14 reasonable number of locations in the contiguous U.S.,
15 Alaska, and Hawaii.
16 Next slide, please.
17 The next wind-related slides summarizes 18 the staff's review of design basis tornado parameters, 19 which include a maximum three-second gust wind speed 20 of 230 miles per hour and design-related 21 characteristics, for example, pressure drop and rate 22 of pressure decrease.
23 On the design-basis hurricane wind speed, 24 also a three-second gust but of 290 miles per hour.
25 Each of these design conditions is associated with an NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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121 1 exceedance frequency of ten to the minus seven per 2 year.
3 The staff found that the tornado site 4 parameters are based on the current version of Reg 5 Guide 1.76 for Region 1, which is the highest tornado 6 intensity region in the contiguous U.S.
7 The staff also found that the three-second 8 gust for hurricane wind speed is based on the current 9 version of Reg Guide 1.221. The postulated value, 290 10 miles per hour is the most conservative among those 11 indicated for hurricane prone site locations in the 12 contiguous U.S., along the Gulf of Mexico, and 13 Atlantic coastlines. The staff confirmed that these 14 values are consistent with the NRC regulatory guidance 15 and, on that basis, considers that the postulated 16 tornado and hurricane site parameters are 17 representative of a reasonable number of locations in 18 the contiguous U.S.
19 Next slide, please.
20 This next slide deals with the staff's 21 review of the dry- and wet-bulb temperatures 22 postulated for the NuScale design. For our review, 23 there are three key takeaways on this slide.
24 First, like other design certification 25 applicants, these temperatures are referenced to the NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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122 1 ERPI Utility Requirements Document or the URD. The 2 applicant cites Revision 13 of the URD issued in 2014, 3 which was updated to include small modular reactors.
4 Second, the staff determined that the 5 numerical values for these design-basis temperatures 6 have not changed since at least Revision 8 of the URD, 7 which was issued in 1999.
8 Third, the coincident wet-bulb 9 temperatures in the EPRI URD represent mean values; 10 whereas, the coincident wet-bulb temperatures 11 postulated for the design are said to represent 12 maximum values and that turns out to be a somewhat 13 important distinction.
14 Next slide, please.
15 MEMBER SKILLMAN: If you please, Mike. A 16 picky comment. This is on your Safety Evaluation page 17 220. You write: Zero percent exceedance 18 maximum/minimum amount for design dry-bulb 19 temperatures 46.1 Celsius, 115 Fahrenheit, and 40 20 degrees Centigrade minus 40 degrees Fahrenheit. You 21 actually show 40 and I think you mean minus 40 C.
22 MR. MAZAIKA: If that's a typo then we'll 23 --
24 MEMBER SKILLMAN: It's a typo. You need 25 a minus.
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123 1 MR. MAZAIKA: Okay. Part of that was a 2 constraint from the editors that we had to put the 3 metric units of measure before these English units.
4 And the site parameters are expressed in English units 5 of measure. So we'll correct that typo.
6 MEMBER SKILLMAN: I'm just saying that 7 there is a minus absent from the 40.
8 MR. MAZAIKA: Okay.
9 MEMBER SKILLMAN: Not a problem.
10 MR. MAZAIKA: Thank you.
11 CO-CHAIRMAN RICCARDELLA: Could you give 12 a little more explanation on that last bullet? You 13 said it was a significant difference. I'd like to 14 understand that a little better if I could.
15 MR. MAZAIKA: Regarding coincident wet-16 bulb temperatures?
17 CO-CHAIRMAN RICCARDELLA: Well maximum 18 versus mean.
19 MR. MAZAIKA: That was the subject of an 20 RAI question. It is partially addressed in Revision 21 2 of the document and we are only reviewing through 22 Revision 1.
23 The applicant cites the EPRI URD. So 24 that's an inconsistency or an explanation that has to 25 be resolved in a subsequent revision of the document.
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124 1 Typically, ASHRAE, the air conditioning 2 industry defines their coincident wet-bulb 3 temperatures as mean values, which is why I confirmed 4 it with the folks at EPRI.
5 The applicant can choose to do that.
6 Statistically, it makes it more difficult to comply 7 with both parameters, if you have a dry and a wet-bulb 8 temperature pair or as an individual wet-bulb value.
9 But that's the current definition that the applicant 10 has in their document. So that's something that we 11 have to resolve with them.
12 CO-CHAIRMAN RICCARDELLA: Okay.
13 MR. MAZAIKA: Okay? All right, next 14 slide, please.
15 The staff looked at a climatological 16 database compiled by ASHRAE, which is cited in SRP 17 231, which I mentioned, for the contiguous U.S. and 18 Hawaii. We used our professional judgment for 19 evaluating temperature conditions in Alaska.
20 Acceptability of these site parameters from an 21 engineering standpoint is evaluated under Chapter 9.
22 The maximum design dry-bulb temperatures 23 at the zero, one, and five percent exceedance levels 24 are 115, 100, and 95 degrees Fahrenheit. Postulated 25 minimum dry-bulb temperatures are minus 40, minus 10, NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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125 1 and minus 5 degrees Fahrenheit. These maximum and 2 minimum value are considered to be acceptable at a 3 reasonable number of locations.
4 The postulated one percent exceedance non-5 coincident wet-bulb temperature is 80 degrees 6 Fahrenheit. It should also be acceptable at a 7 reasonable number of sites in the contiguous U.S.,
8 Hawaii, and, based on our judgment, in Alaska.
9 Next slide, please.
10 The last temperature-related slide deals 11 with our observations on wet-bulb temperatures in 12 previous COL and ESP application submittals and 13 information in the ASHRAE database. That is that 14 these site parameters in the NuScale DCA may be 15 exceeded in many locations. A similar issue was 16 discussed during the ACRS presentations for the 17 APR1400 application review.
18 The applicant's wet-bulb temperature site 19 parameter values apply to non-safety-related HVAC 20 systems and the cooling towers. And I refer you to 21 Tier 2, Table 3.2-1 in the DCA. Therefore, the 22 applicant considers it a business decision not to 23 change the proposed wet-bulb values.
24 Given that position and the applicant's 25 defining coincident wet-bulb temperatures as maximum NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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126 1 rather than mean values, the second bulleted item 2 indicates that the dry-bulb temperatures in those 3 pairs appear to be acceptable at a reasonable number 4 of locations. On the other hand, the ASHRAE database 5 suggests that the coincident wet-bulb values are 6 likely to be exceeded in much of the contiguous United 7 States and Hawaii.
8 The last bulleted item indicates, based on 9 the staff's review, that there is a reasonable 10 expectation of the need for potential COL applicants 11 to request a departure from the postulated zero 12 percent non-coincident or the zero, one, or five 13 percent maximum coincident wet-bulb temperatures, 14 depending on site characteristics.
15 MEMBER BROWN: Question?
16 MR. MAZAIKA: Yes.
17 MEMBER BROWN: In your SER, you didn't use 18 the word much of the contiguous. You said most of the 19 contiguous U.S. Was there a -- I'm just reading from 20 page 39. The ASHRAE data suggests that postulated 21 temperature is likely to be exceeded in multiple -- in 22 most of the contiguous United States. That's a nuance 23 but it's a different word.
24 MR. MAZAIKA: True or not. So you're on 25 page 2-39? I have a different numbering system, so I NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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127 1 must have it --
2 MEMBER BROWN: It's right above -- it's 3 the paragraph above 2.3.1.5 that's the next to the 4 last paragraph right above the next section.
5 MR. MAZAIKA: I do not know the answer to 6 that right now. That may be a transcription error 7 between the text of the document and the slides.
8 MEMBER BROWN: Okay, I just -- it's a 9 nuance work. It's a different word. Much is 10 different than most.
11 MR. MAZAIKA: Agreed. Agreed. I'll take 12 a look at that.
13 MEMBER BROWN: All right, thanks.
14 MEMBER SKILLMAN: Michael, a question just 15 for clarification, not challenge.
16 You said it was a business decision to use 17 the zero, one, and five maximum coincident. And then 18 you identified your third bullet with the potential 19 need for departures for the maximum coincident wet-20 bulb.
21 It seems to me what that really is getting 22 to is the size of your condensers for your turbines 23 and your decay heat removal systems, heat exchanger 24 size. Is there anything else besides turbine 25 condenser and decay heat removal heat exchangers that NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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128 1 is an economic consideration?
2 MR. MAZAIKA: I can't answer that question 3 directly because I'm not an engineer. I'm a 4 meteorologist. So I would defer that to somebody 5 under Chapter 3.
6 The systems that were identified were 7 based on RAI responses and conversations back and 8 forth with the applicant.
9 MEMBER SKILLMAN: Okay.
10 MR. MAZAIKA: So that's the best I can do 11 right now.
12 MEMBER SKILLMAN: That's fair enough.
13 Thank you.
14 MEMBER CORRADINI: I think we'd have to 15 ask NuScale but my immediate guess is control room 16 habitability issues are going to be affected by this.
17 Otherwise, you'd have to make modifications because in 18 APR1400, when we brought up -- the most recent one 19 when we brought up APR1400, it was relative to that.
20 MR. HOUGHTON: This is Zack Houghton. I'm 21 a mechanical design engineering manager with NuScale.
22 This would apply to the control room 23 ventilation system, not the control room habitability 24 system.
25 MEMBER CORRADINI: I'm sorry. I'm sorry.
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129 1 MR. HOUGHTON: It would apply to the 2 turbine condensers but it would not apply to the DHR 3 condensers. Those are located directly in the reactor 4 building pool, which is the ultimate heat sink which 5 also isn't affected by ambient conditions.
6 So these ambient conditions don't affect 7 any of our safety-related systems.
8 MEMBER SKILLMAN: So it's really the 9 turbine condensers and the HVAC for the control room, 10 those two.
11 MR. HOUGHTON: Correct, turbine condensers 12 and your air conditioning units is what will be sized 13 by this information.
14 MEMBER SKILLMAN: Yes, okay. Thank you 15 very much.
16 MR. MAZAIKA: Did that answer your 17 question?
18 MEMBER SKILLMAN: Yes.
19 MR. MAZAIKA: Okay. All right that will 20 wrap up 2.3.1, unless there are any other questions.
21 And then I'll go to 2.3.2 and 2.3.3 on the next slide, 22 since they represent site-specific conditions, the COL 23 applicant will have to address local meteorology and 24 the on-site met monitoring program and the staff 25 agrees with that position.
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130 1 With that, if there are no more questions, 2 I'll turn it over to my colleague, Jason White.
3 MR. WHITE: Thank you, Mike. Good 4 afternoon. As Mike stated, my name is Jason White.
5 And I am also a meteorologist in the Office of New 6 Reactors. I've been a member of the NRC staff for 7 just under 10 years and have served as a technical 8 reviewer in both the Office of Nuclear Reactor 9 Regulation and Office of New Reactors.
10 Today I will be discussing the review of 11 Sections 2.3.4 and 2.3.5 of the application.
12 This slide addresses Section 2.3.4, which 13 discusses the short-term atmospheric dispersion site 14 parameters for accident releases. The exclusion area 15 boundary, or EAB, an out of boundary of the low 16 population zone, or LPZ, offsite atmospheric 17 dispersion X/Q value site parameters are used in DCA 18 Tier 2, Chapter 15, to help demonstrate that the 19 offsite radiological consequences of accidents need to 20 specify radiation dose guidelines as specified in 10 21 CFR 52.47.
22 The applicant stated in the application 23 that Topical Report TR-0915-17565 describes their 24 methodology for calculating the accident X/Q values at 25 the EAB and LPZ.
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131 1 Staff performed an independent 2 verification of the applicant's off flight X/Q site 3 parameter values postulated for EAB and LPZ. Staff 4 used a portion of the NuScale methodology to calculate 5 X/Q values based on meteorological data collected at 6 six nuclear power plant sites.
7 Staff found that only one of these six 8 sites had X/Q values that are bounded by all of the 9 postulated NuScale site parameter values. Therefore, 10 if a COL applicant references a NuScale design and 11 finds that its actual site characteristic X/Q values 12 do not fall within the corresponding site parameters 13 postulated in the DCA, the COL applicant will need to 14 provide sufficient justification that the proposed 15 facility is still acceptable at the proposed site.
16 MEMBER CORRADINI: Let me clarify, make 17 sure I understand you. So one out of six passed based 18 on this. But I could move the boundary out and things 19 would change.
20 MR. WHITE: Yes.
21 MEMBER CORRADINI: Okay, fine.
22 MEMBER KIRCHNER: This was nominally the 23 -- NuScale presented a conceptual design where the EAB 24 and the LPZ were coincident. It's the same box.
25 MR. WHITE: Yes.
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132 1 MEMBER KIRCHNER: So what are you saying 2 here? The 400 foot distance that they show as the 3 minimum distance that only one out of the six sites.
4 MR. WHITE: Yes. According to our 5 independent verification, yes.
6 MEMBER KIRCHNER: Right. Okay. So in 7 practical terms, what does this mean? That either the 8 LPZ is moved out or you don't site it here?
9 MR. WHITE: Well, the COL applicant would 10 have to provide a justification of why it could be 11 sited there.
12 MEMBER KIRCHNER: Okay.
13 MEMBER MARCH-LEUBA: Now, I haven't seen 14 the numbers, but my suspicion is that NuScale is 15 saying it can be 400 feet because it's much, much 16 smaller than that and they have sufficient margin, 17 meaning that if a COL applicant does not meet the 18 parameters that they use, they may still meet the 400 19 feet most likely. So they have a little more wind or 20 something than assumed. They probably still need the 21 400 feet.
22 MEMBER KIRCHNER: Well, the LPZ is based 23 on dose not on X/Q, indirectly on the source term. So 24 --
25 MEMBER MARCH-LEUBA: What I'm saying is --
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133 1 MEMBER KIRCHNER: -- and EAB is a 2 different definition.
3 MEMBER MARCH-LEUBA: -- I haven't seen the 4 numbers. But the fact that NuScale is putting their 5 money on 400 feet, it means that they believe it is 10 6 feet.
7 MEMBER KIRCHNER: Okay.
8 MEMBER MARCH-LEUBA: Or actually zero 9 because they probably want to tell us the source time 10 is zero.
11 MR. WHITE: Well, they're saying that 12 their minimum distance will be 400 feet.
13 Next slide. The staff is currently 14 reviewing the topical report to determine if the 15 NuScale methodology is acceptable for calculating the 16 design basis accident offsite X/Q values at the EAB 17 and LPZ in relation to the NuScale design and in a COL 18 application that references the NuScale design.
19 This review is going to track as Open Item 20 2.3.4-1. Subject to resolution of the staff's 21 evaluation of the Topical Report, the staff concludes 22 that the applicant has appropriately provided short-23 term accident release X/Q site parameter values.
24 Next slide. This slide discusses the 25 onsite main control room, or MCR, and technical NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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134 1 supports in our TSC X/Q site parameter values. The 2 staff performed an independent verification of the 3 applicant's postulated onsite X/Q site parameter 4 values of the MCR and TSC doors and at the HVAC 5 intake.
6 The staff generated X/Q values using the 7 Reg Guide 1.194 endorsed ARCON96 computer code with 8 the source to receive the information presented in the 9 DCA.
10 On the basis of this evaluation, the staff 11 found that the applicant provided onsite X/Q site 12 parameter values of the MCR and TSC doors and the HVAC 13 intake that are representative of a reasonable number 14 of locations that may be considered for a COL 15 application.
16 Next slide. This slide addresses Section 17 2.3.5, which discusses the long-term atmospheric 18 dispersion site parameters for routine releases.
19 These site parameters are an offsite dose location 20 atmospheric dispersion X/Q and atmospheric deposition 21 D/Q values. The staff performed an independent 22 evaluation of the applicant's postulated offsite X/Q 23 and D/Q values.
24 Staff generated X/Q and D/Q values using 25 the XOQDOQ computer code, which implements portions of NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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135 1 the Reg Guide at 1.111, the meteorological data from 2 various nuclear power plant sites and the release and 3 receptor information presented in the DCA.
4 On the basis of this evaluation, the staff 5 found that the long-term routine release atmospheric 6 dispersion and deposition site parameter values 7 selected by the applicant are representative of a 8 reasonable number of sites that have been or may be 9 considered for a COL application.
10 Next slide. This concludes the staff's 11 presentation on Section 2.3. If there are no 12 questions, Yuan Cheng will now present Section 2.4 13 MR. CHENG: Thank you, Jason. My name is 14 Yuan Cheng. I am an NRC technical reviewer for the 15 NuScale DCA Part 2, Tier 2, Section 2.4, hydrologic 16 engineering.
17 I hold a professional engineer's license 18 in several states including Maryland, Pennsylvania and 19 Ohio. I have worked for the NRC for approximately 20 five years as a hydrologist.
21 Prior to joining the agency, I have worked 22 in the private sector for approximately 35 years.
23 Recently, I completed the technical review on 24 hydrologic engineering for the Clinch River Early Site 25 permit applications.
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136 1 Next slide, please. Regarding applicant's 2 site parameters, the staff reviewed and conferred to 3 NuScale's three parameters related to Section 2.4, 4 hydrologic engineering. They are described in the DCA 5 Part 2, Tier 2, Section 2.0 and Table 2.0-1.
6 The first parameter is the maximum flood 7 level including wind induced wave run-up to be one 8 foot below the baseline to plant elevations.
9 The second is the maximum groundwater 10 level to be 2 feet below the site grade.
11 The third is the maximum precipitation 12 rate 19.4 inches in one hour and 6.3 inches in five 13 minutes.
14 MEMBER CORRADINI: So can I get a 15 clarification on the one foot below plant baseline, 16 plant elevation? What does that mean? So if the 17 ultimate heat sink swimming pool is so high, that's 18 one foot below the top of the swimming pool? But I 19 don't understand what one foot below baseline plant 20 elevation means.
21 MR. CHENG: Excuse me. Here it is talking 22 about the flood hazards. It's not talking about 23 interior tank failures.
24 MEMBER CORRADINI: So I'm looking for a 25 way to identify what that location is. Is that --
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137 1 MR. CHENG: External flood.
2 MEMBER CORRADINI: But I mean, is it one 3 foot below -- what's the baseline elevation? Is it a 4 piece of equipment or is the control room at baseline 5 elevation? What is baseline elevation?
6 MR. CHENG: Okay. The base plant 7 elevation is the finished floor elevations, finished 8 floor.
9 MEMBER CORRADINI: Okay. Thank you.
10 MR. CHENG: The concrete, the top of the 11 concrete.
12 MEMBER CORRADINI: Okay.
13 MEMBER MARCH-LEUBA: On a related 14 question, we recently reviewed the Turkey Point 15 application. And they actually considered climate 16 change for the sea level change, for really for 60 17 years. If NuScale was to be located close to a body 18 of water, would they need to consider climate change, 19 sea level changes?
20 MR. CHENG: Based on the standard review 21 plan and the current skylines and regulations, the 22 climate change is not included in the design.
23 MEMBER MARCH-LEUBA: But it was in this 24 particular application that we're reviewing.
25 MR. CHENG: Yes. But the ongoing change, NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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138 1 like climate change, have sometimes impact on the sea 2 level rise, which deals with monitors and that kind of 3 documents and research.
4 If they truly have some negative impact or 5 adverse impact, we will re-evaluate the flood.
6 MEMBER MARCH-LEUBA: Is that going to be 7 part of your Chapter 2 contributions?
8 MR. CHENG: No, no. That is not part of 9 the NuScale's review. Climate change is not.
10 MEMBER MARCH-LEUBA: You're saying that 11 whatever the flood level is, you'd better be one foot 12 above it, right? And then we'll determine what the 13 flood level is on your site?
14 MR. CHENG: Yes. Based on this, it's one 15 foot below.
16 MEMBER MARCH-LEUBA: I mean, that's an 17 iffy way out.
18 MR. CHENG: Yes.
19 MEMBER MARCH-LEUBA: But okay.
20 MR. CHENG: The next slide. Reviewing the 21 applicant's Section 2.4, hydrology engineering, the 22 staff confirmed the hydrological conditions are site 23 specific and they will be evaluated in the COL stage.
24 The staff confirmed that in the COL stage, 25 the Section 2.4.1 through 2.4.14 with the exceptions NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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139 1 of Sections 2.4.8 and 2.4.10 will be evaluated as they 2 are related to site specific hydrologic conditions.
3 The applicant provides the COL information 4 items 2.4.1 to defer the site specific analysis on 5 those sections.
6 Next slide. The staff confirmed that 7 cooling water canals and the reservoirs, Section 8 2.4.8, are not required as a safety-related made out 9 water sources for the other heat sink for the NuScale 10 design. The other heat sink design does not rely on 11 external water supply for at least 30 days.
12 Staff confirmed that flood protection 13 requirements, Section 2.4.10, are not applicable since 14 the baseline plant elevation is one foot above the 15 maximum flood level. Therefore, the staff confirmed 16 the COL stage, Section 2.4.8 and 2.4.10 are excluded 17 from the COL information, 2.4-1.
18 Next slide. The applicant provides the 19 COL information items, 2.4-1, and states as follows.
20 It combined licensed COL applicants that reference the 21 NuScale power plant design certification. We'll 22 investigate and describe the site specific 23 hydrological characteristics for the Section 2.4.1 24 through 2.4.14, except Section 2.4 and 2.4.10.
25 Next slide. Conclusions. The staff NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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140 1 confirmed that the NuScale DCA site parameters meet 2 the requirements of 10 CFR Part 100.
3 The staff concludes that all regulatory 4 requirements have been satisfied with no open items.
5 Three confirmatory items remain in the staff's safety 6 evaluation report and will be confirmed with the 7 applicant's Revision 2 of NuScale's DCA Part 2, Tier 8 2, Section 2.4, hydrologic engineering.
9 This concludes my presentation, and I will 10 now pass the presentation to Dr. Weijun Wang for 11 Section 2.5.
12 MR. WANG: Okay. If there is no question 13 regarding 2.4, I will present the summary of the staff 14 review on the Section 2.5.
15 I'm Weijun Wang. I'm a senior 16 geotechnical engineer with the NRO. I have a PhD 17 degree in geotechnical engineering and am a licensed 18 professional engineer in Virginia.
19 I have been working in geotechnical 20 engineering and the related field for over 38 years, 21 including 12 years in accounting at the NRC and 13 22 years at the Federal Highway Administration.
23 I am one of the technical reviewers of the 24 Section 2.5, geologist, seismology and geotechnical 25 engineering.
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141 1 So this section includes the topics, like, 2 basics geological and the seismic information 3 vibratory ground motion surface faulting and basically 4 we are talking about seismic information here so the 5 stability of the subsurface materials and the 6 foundations on the slope stability.
7 Next slide please. This section, the 8 Section 2.5, the application established the site 9 parameters for the NuScale design and for the site 10 suitability determination. So this slide, just the 11 list related to site parameters because the applicant 12 already presents the details and values. So I just, 13 okay, with the list here.
14 Next slide please. The Section 2.5 and 15 2.5.3 defined geology related site parameters such as 16 no fault displacement potential under the plant 17 structures at the site. And they also specified in 18 COL information item that the site specific basic 19 regional and site geologic information to be addressed 20 by COL applicant.
21 By the way, because of the site 22 parameters, especially in 2.5, it's not site specific.
23 Therefore for the any site parameters here, it has to 24 be addressed by the COL applicant.
25 Next slide, please. The Section 2.5.2 NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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142 1 defined the certified seismic design by spectra. And 2 in this design it also defined another CSDRS at a high 3 frequency is best specified for the hot rock site 4 which is chute for the most central east U.S.
5 This tool, CSDRS, seismic loading design 6 bases and it in turn covers most of the south in the 7 U.S.
8 This section also defines as the COL for 9 main items to specify the site specific basic regional 10 and the seismic information with local vibratory 11 ground motion and site safe shutdown earthquake to be 12 addressed by the COL applicant.
13 Next slide, please. This slide shows the 14 example of the certified seismic design response 15 spectra to include the basic one and another one for 16 the high frequency.
17 Next slide, please. Sections 2.5.4 and 18 2.5.5 did not reveal the stuff usual, the RAIs.
19 CO-CHAIRMAN RICCARDELLA: Can I ask you a 20 question?
21 MR. WANG: Yes.
22 CO-CHAIRMAN RICCARDELLA: Go back to the 23 previous slide.
24 MR. WANG: Okay.
25 CO-CHAIRMAN RICCARDELLA: You have the NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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143 1 design specification spectra and you have two other 2 spectras. Are those just shown there for reference?
3 The lower ones.
4 MR. WANG: Okay. The first one on the 5 chart on the left side one is also showed the 6 reference. That's the spectra response. That 7 response spectra it came in the Regulatory Guide at 8 1.60. It just gives the comparison, which we show 9 that for the NuScale design the certified -- the 10 seismic design of one spectra actually is envelope the 11 Regulatory Guide, the spectra.
12 CO-CHAIRMAN RICCARDELLA: Okay.
13 MR. WANG: I will continue. Okay. So in 14 the RAI for Section 2.5.4, the issues involved the 15 site subsurface material uniformity. And also about 16 some of the static and the dynamic parameters of the 17 subsurface material whether those parameters apply to 18 all the subsurface material, including the backfill 19 material and also related to the limits of the total 20 and the differential settlement for safety related 21 structures and the lateral earth pressure evaluation.
22 The applicant adequately addressed all of 23 the RAI issues and the specified pertinent items to be 24 addressed by COL applicants.
25 Next slide, please.
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144 1 MEMBER SKILLMAN: No, would you stay 2 there, please, on that slide.
3 MR. WANG: Okay.
4 MEMBER SKILLMAN: I'm looking at your 5 safety evaluation and unfortunately the portion of the 6 safety evaluation is protected information. Would you 7 speak a little bit about differential settlement?
8 You state on your third bullet limits of 9 total and differential settlements for safety related 10 structures. And it appears as though you have some 11 settlement details in the safety evaluation that are 12 unlimited. Would you speak to that please?
13 MR. WANG: Okay. The initial application 14 of the NuScale design for the set of parameters 15 regarding the total settlement initially it's a state.
16 There's no limit on the total settlement.
17 But our concern was it's normally for any 18 structures. If you have large the total settlement, 19 normally it's associated with larger differential 20 settlement.
21 Think about that. If a structure that's 22 uniformed, that settled and there's no connection to 23 other structures, it normally won't affect its normal 24 operation although it may cause some problems. For 25 example, if a building settled too much and your door NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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145 1 probably will settle into the ground, you probably 2 will have hard time to get in and out.
3 So if you see anything like that, there's 4 no limit on the total settlement, then it will raise 5 a question. It's really you don't have any limit on 6 the total settlement. So that's one question we ask 7 in our RAI.
8 And finally the applicant responded to us 9 and said, yes, there is a limit. It's a limit of 10 total settlement of four inches. So that's a 11 reasonable value here.
12 MEMBER KIRCHNER: This is a good time to 13 ask a question. Since most of these site parameters 14 that you evaluated, I think NuScale used suggested 15 every industry kind of nominal values. I know we're 16 going to hear about actual evaluation against these 17 site characteristics when we get to Chapter 3 and 15 18 and other places, 15 like the meteorology factors 19 being used for accident analysis.
20 But is there anything that you 21 collectively, all of you found that was unique about 22 this design that would place more demands on the 23 siting characteristics than nominal values that they 24 have taken from EPRI. See what I'm saying?
25 I think settlement might be one because of NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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146 1 the overall weight, mass and hence bearing pressure of 2 a very large building filled with water with 12 3 modules. Anything else like that unique that would 4 say that nominal values taken from an industry 5 recommended standard needs further investigation.
6 It seems like this RAI, for example, 7 focused on something that would be rather unique for 8 a NuScale module for the plant.
9 MR. WANG: Okay. I can only speak from 10 the geologist site module and the geotechnical 11 engineering area and regarding, like, the climate and 12 hydraulic. Probably my colleague can answer that.
13 And based on our review, I did not find 14 like anything really out of the normal run-off the 15 actual standard. Like, for example, if there's a 16 differential settlement, like the tool, it's like a 1 17 over the 600 to 1,200 and the half inch of 18 differential settlement, that's all the normal run-off 19 of the industry standard for the larger structures and 20 so forth.
21 Yes, if you are talking about the unit, 22 the loading for this design, this unit loading 23 actually is greater than, like, 81,000.
24 MEMBER KIRCHNER: Right.
25 MR. WANG: Yes. However, because the NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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147 1 requirement for the bin capacity and the settlement 2 limit is always in the normal standard requirement.
3 So, therefore, at least in our section, we did not 4 identify anything abnormal.
5 MEMBER KIRCHNER: Thank you.
6 MEMBER SKILLMAN: Is the four inches that 7 you just mentioned a change to the safety evaluation?
8 Is there a new safety evaluation that identifies that 9 four inches and its acceptability?
10 MR. WANG: Yes. You know, it's for the 11 four inch in total settlement is not -- if you think 12 of four inches, probably this much, and you probably 13 sort of maybe too much actually for this type of 14 structure. Four inches of total settlement won't 15 cause any problem.
16 The only concern is the total settlement 17 is for -- was building. It doesn't matter. You know, 18 you also need to consider another issue is the so-19 called another type of differential settlement which 20 is the settlement between two buildings because --
21 MEMBER SKILLMAN: We fully understand 22 that. We are, in your safety evaluation, we are 23 looking at the words of the document that we were 24 asked to review. And we are seeing text that would 25 suggest to us that there is no limit. And you are now NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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148 1 saying there is a limit. It's four. The four is 2 acceptable. It's been evaluated. And it's a 3 differential settlement.
4 And you're also saying it's acceptable 5 because, I guess, you're thinking that the buildings 6 will settle at the same rate and at the same 7 displacement. We understand, at least I understand, 8 that's what you're saying.
9 MR. WANG: Okay.
10 MEMBER SKILLMAN: Thank you.
11 MR. WANG: You're welcome. Next one.
12 Okay. The conclusion --
13 MEMBER SKILLMAN: Is the FSR going to be 14 revised? How is that four inches going to be codified 15 in your safety evaluation? Will there be a revision 16 one?
17 MR. WANG: Okay. That's a number we will 18 be presenting in the, I believe, Revision 2 of the 19 FSR. We'll specify all the change. And by the way, 20 that's two confirmatory items we're tracking here.
21 MEMBER SKILLMAN: Okay. Thank you. Thank 22 you, sir. Thank you.
23 MR. WANG: So the conclusion is there is 24 no open items. And the applicant adequately specified 25 the site parameters related to geology and the NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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149 1 seismology on the geotechnical engineering.
2 And also if the applicant probably 3 identified the site specific information to be 4 addressed in the COL application and it describes such 5 information in the COL open items. So, again, there 6 are two confirmatory items we are currently tracking.
7 I believe that will be my presentation. Any other 8 questions?
9 MEMBER CORRADINI: Other questions by the 10 committee? Should we go around -- why don't we first 11 hear comments from the -- can we open the line to the 12 outside world? The phone line -- she's working on it.
13 Is there any comments from members in the audience?
14 Is the phone line open?
15 MEMBER BLEY: You mean, like, members?
16 MEMBER CORRADINI: Well, Dennis, you're 17 more than welcome to -- but we have a separate public 18 line that's open that I'm also looking for members of 19 the public. We'll come back to the ACRS members after 20 we get the public.
21 PARTICIPANT: It's open.
22 MEMBER CORRADINI: Is any member of the 23 public going to make a comment? Okay. Going once.
24 All right. Why don't we close the line?
25 Okay. Dennis, why don't we start with NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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150 1 you. Any comments you'd like to make about Chapter 2?
2 MEMBER BLEY: I have no extra comments 3 about Chapter 2. Thanks, Mike.
4 MEMBER CORRADINI: Let me ask another 5 question since we're not going to be coming back into 6 session until full committee when this is presented.
7 Do you have anything relative to an interim letter 8 that you want to emphasize, assuming the committee 9 wants to write it in a letter?
10 MEMBER BLEY: Hmm.
11 MEMBER CORRADINI: Is that a hmm or a yes?
12 MEMBER BLEY: That was a hmm. Personally, 13 I don't have anything. There was a lot of discussion, 14 not on Chapter 2 earlier, but you might want something 15 in there. But personally I don't have anything I 16 would feel obliged to call to your attention at this 17 point.
18 MEMBER CORRADINI: Okay. Thank you, 19 Dennis. So let me go around. We'll start with Walt 20 and go around the room.
21 MEMBER KIRCHNER: No further comments.
22 Thank you.
23 MEMBER CORRADINI: Let me make you, 24 though, talk about the opportunity for an interim 25 letter and if so, what things would be in it?
NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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151 1 MEMBER KIRCHNER: In my opinion, it's some 2 of the issues we debated with regard to Chapter 17.
3 MEMBER CORRADINI: Deserves to be 4 mentioned in an interim letter.
5 MEMBER KIRCHNER: In some manner this 6 expression, clarification on -- pardon me, 7 sufficiently closed on the ODIs to make a reasonable 8 assurance determination.
9 MEMBER CORRADINI: Okay. Thank you. I 10 actually forgot. Margaret, I assume, is still out 11 there. Margaret, are you still out there? No, 12 different line. Okay. She must have left us. Pete?
13 CO-CHAIRMAN RICCARDELLA: No. We have 14 some comments from our consultant, Steve Shultz, that 15 I think we'll have to take into account in our letter 16 writing.
17 MEMBER CORRADINI: Okay. But nothing from 18 you?
19 CO-CHAIRMAN RICCARDELLA: Nothing from me.
20 MEMBER CORRADINI: Okay.
21 MEMBER SKILLMAN: Yes. I would like to 22 ask the staff -- this is on Section 2.3 and this has 23 to do with identification of missiles more energetic 24 than design basis missiles defining FSR Tier 2, 25 Section 3.5.14. This is a coal item.
NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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152 1 And the question I wanted to ask when we 2 were going through this portion is what are these 3 missiles and what are their sources? And I'm 4 wondering if someone from the staff can respond to 5 that.
6 And I'll cite the SER location here in 7 just a second. I'm going through this as quickly as 8 my computer will allow. Please come back to me. Keep 9 on going and come back to me so I can be accurate when 10 I identify the issue. Matt, go ahead.
11 MEMBER SUNSERI: I don't have anything 12 else to add.
13 MEMBER CORRADINI: Jose?
14 MEMBER MARCH-LEUBA: Yes. I am a little 15 slow today because I have to confess I have not 16 prepared for these two chapters because I have been 17 occupied with other topical reports.
18 But during -- and this is not the worst 19 thing, but a favor I want to ask during the full 20 committee. I would like for, especially NuScale to 21 talk a little bit more about the low population some, 22 the LPZ methodology. Because I buy the Bellefonte 23 site and build a reactor there, I will be required to 24 have a 10 mile radius.
25 So obviously for some reason you are NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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153 1 asking for an exception from the rule. All I hear is 2 that your LPZ must be larger than 400 feet. But I 3 have no idea how you plan to calculate it.
4 So if you could shed some light on what 5 you plan to do with LPZ, I mean, obviously, there's 6 going to be some cut of frequencies that you will not 7 --
8 MR. BERGMAN: I think those were probably 9 addressed better when you look at the EPZ methodology 10 report, which is separate from the DCA. It's not part 11 of our DCA application.
12 MEMBER MARCH-LEUBA: So this is not this 13 topic even though you included many --
14 MR. BERGMAN: We'll look to see if there's 15 a related question. But if it's specific about the 16 EPZ methodology, that is not part of the DCA.
17 MEMBER MARCH-LEUBA: We'll see that later?
18 MEMBER CORRADINI: We'll see that not as 19 part of the DCA. Not as part of the DCA. It's 20 separate from the DCA.
21 MEMBER MARCH-LEUBA: Will we see that 22 before summer?
23 MR. BERGMAN: I'll have to ask the staff 24 on their schedule.
25 MEMBER CORRADINI: I think, Jose, if I NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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154 1 might, it's going to be part of the source term 2 discussion. The source term will be one of the 3 inputs. But the EPZ determination is a separate 4 entity than from the DCD.
5 MEMBER MARCH-LEUBA: Okay. If we don't 6 have it under CPI on the records, you are excluding 7 them out.
8 MR. CHOWDHURY: We do not have a schedule 9 for the EPZ Topical Report yet.
10 MR. SHAVER: So right now it's tentative 11 but we're going to --
12 MEMBER CORRADINI: Is it on?
13 MR. SHAVER: Thank you. So right now we 14 made the decision that we were going to focus on the 15 SER with open items. And that should be wrapping up 16 in July.
17 So right now we've tentatively scheduled 18 the emergency planning zone topical to have a 19 subcommittee meeting on October 22. And that means we 20 would need the staff's evaluation by September 22.
21 That's the current plan.
22 MEMBER MARCH-LEUBA: All I'm telling the 23 staff, until NTR is reviewed and approved, this 24 crucial zone is certainly larger than 400 feet because 25 it is 10 miles.
NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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155 1 MEMBER CORRADINI: Now you're getting 2 confused about emergency planning zone and LPZ.
3 MEMBER MARCH-LEUBA: LPZ.
4 MEMBER CORRADINI: The emergency planning 5 zone is 10 and 50 by rule.
6 MEMBER MARCH-LEUBA: Yes.
7 MEMBER CORRADINI: But that's not the EAB 8 and the LPZ. It's a different calculation.
9 MEMBER MARCH-LEUBA: Mm-hmm.
10 MEMBER CORRADINI: One is a siting 11 calculation and one is an emergency planning zone 12 calculation. Different --
13 MEMBER KIRCHNER: EAB, that's a different 14 definition. These are different terms, Jose. So EAB 15 is the terminology where the owner of the site 16 controls that boundary.
17 MEMBER MARCH-LEUBA: That's my fence.
18 MEMBER KIRCHNER: LPZ is a dose-based 19 designation for distance.
20 MEMBER MARCH-LEUBA: Which we just went 21 through the methodology for calculating for Clinch 22 River.
23 MEMBER KIRCHNER: And the EPZs are 24 currently 10 and 50. But these are different.
25 They're all different. They're all defined NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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156 1 differently. And so just be careful. I think you 2 were confusing --
3 MEMBER CORRADINI: But I think, Jose's 4 point is when are we going to get to it? The answer 5 is probably not until late '19.
6 MEMBER MARCH-LEUBA: Okay. Until such 7 time as the staff gets it, the EPZ, and I think the 8 LPZ, too, is too much. I mean all around the LPZ --
9 MEMBER CORRADINI: I think you're 10 incorrect about the LPZ. You are correct about the 11 EPZ.
12 MEMBER MARCH-LEUBA: Okay. For sure the 13 EPZ.
14 CO-CHAIRMAN RICCARDELLA: Except for 15 Clinch River TVA requests an exemption to the ten 16 mile.
17 MEMBER KIRCHNER: Because the rule-making 18 is in process, what TVA chose to do was to, in their 19 early site permit, ask for two exemptions, which the 20 staff reviewed. And so it's through exemptions that 21 they're looking for a different definition of the EPZ 22 for the plume exposure pathway.
23 MEMBER BLEY: But that's irrelevant for 24 the devices. It's true. But it's irrelevant for the 25 devices.
NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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157 1 MEMBER CORRADINI: You have to get closer, 2 Dennis. We can't hear you. You're a bit muffled.
3 MEMBER BLEY: I'm screaming into my phone 4 at the top of my voice. Never mind.
5 MEMBER MARCH-LEUBA: Okay. Given the 6 extent of the discussion, during the full committee if 7 we can have a slide on it, on the concept, so I can 8 understand what we're talking about. I will not 9 proceed. Next.
10 MEMBER BALLINGER: No further comment.
11 MEMBER CORRADINI: Charlie?
12 MEMBER BROWN: No further comment.
13 CO-CHAIRMAN RAY: I don't have a comment 14 on two. Were you asking about 17 also? That's what 15 I thought. I don't know. Were you responding, Matt, 16 for example, on 17?
17 MEMBER SUNSERI: I was deferring to you 18 actually.
19 CO-CHAIRMAN RAY: Okay. I don't expect I 20 would recommend, but I need to think about it some 21 more so everything is tentative here.
22 On recommended comments, Mike, directed 23 toward NuScale, I think that comments may be 24 appropriate in terms of how we look at the process 25 ourselves. And I just need to discuss that among the NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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158 1 members a little further. I've sent an email to you.
2 MEMBER CORRADINI: I'm not following you, 3 I'm sorry.
4 CO-CHAIRMAN RAY: I don't see anything in 5 what NuScale has presented that tells me we need to 6 comment about what they're doing or their program or 7 whatnot.
8 MEMBER CORRADINI: In terms of an interim 9 letter?
10 CO-CHAIRMAN RAY: Correct.
11 MEMBER CORRADINI: Okay. I missed that.
12 CO-CHAIRMAN RAY: But what I am saying is 13 that with regard to how we, the agency, are dealing 14 with it, there may be a comment that we should make.
15 MEMBER CORRADINI: Okay.
16 CO-CHAIRMAN RAY: Because it's related to 17 our process not their process.
18 MEMBER CORRADINI: But let me just get to 19 it though. I mean, my sense of it is though that from 20 your original comments on 17, if we do an interim 21 letter, there are going to be some comments to the 22 staff about the SER that we might want to make 23 relative to, we'll call it, finding reasonable 24 assurance for closure of these ODIs.
25 CO-CHAIRMAN RAY: Well, that's one aspect NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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159 1 of it. There are others as well --
2 MEMBER CORRADINI: Okay.
3 CO-CHAIRMAN RAY: -- having to do with how 4 the status is monitored post-design certification for 5 example.
6 MEMBER CORRADINI: Okay.
7 CO-CHAIRMAN RAY: But it needs some more 8 discussion because we're into a process space here 9 where we need to make sure we understand what the 10 intent is of the design certification relative to what 11 happens before, what happens afterward and so on.
12 But in terms of the program that NuScale 13 presented, I don't --
14 MEMBER CORRADINI: You don't see a need.
15 CO-CHAIRMAN RAY: Personally, right now, 16 I don't see a need. It may evolve --
17 MEMBER CORRADINI: Okay.
18 CO-CHAIRMAN RAY: -- out of further 19 discussion. But that's the way I see it.
20 MEMBER CORRADINI: Okay. Let me go back 21 to Dick. We skipped over Dick.
22 MEMBER SKILLMAN: Thank you. This is a 23 2.2.4 in the safety evaluation. It is on Page 217.
24 And here's the text. NuScale is saying the applicant 25 stated -- or the NRC is communicating what NuScale NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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160 1 communicated. The applicant stated the following 2 principal types of hazards will be considered with 3 respect to each of the above areas of review if they 4 have a probability of occurrence greater than ten to 5 the core minus seven per year. I got it.
6 This is more energetic than tornado 7 missile spectra. I understand that this becomes the, 8 if you will, the applicant's accountability. But I'm 9 just wondering what the NRC was thinking when they 10 wrote missiles more energetic than tornado missile 11 spectra or if that was just, if you will, a statement 12 to establish an envelope for which the safety 13 evaluation is applicable. It's Section 2.2.2.
14 MR. TAMMARA: I think hurricane missiles 15 might be a little bit higher than that one, but that 16 will be looked at by the COL applicant. That's what 17 the intent was.
18 MEMBER KIRCHNER: Dick, I remember --
19 MR. TAMMARA: Because we went through, and 20 the question arose at the PSEG application or 21 whatever. And we discussed it, too, and we discussed 22 this aspect a little bit at that time.
23 And the new regulatory aspect of whatever 24 it is it was proposed it is higher than the --
25 MEMBER SKILLMAN: I think it was the NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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161 1 hurricane straight line winds and the potential for 2 the higher wind field to lift a vehicle or a fairly 3 large component.
4 MEMBER KIRCHNER: Normally the tornado 5 missile dominates. But there were certain sites where 6 it appears. And we saw one that was at the Turkey 7 Point, right, in Florida, where the hurricane 8 generated missile actually was dominant. And so I 9 suspected, the way I interpreted it, is normally it's 10 going to be -- I forget the reg guys. You all live 11 and die --
12 (Simultaneous speaking.)
13 MEMBER KIRCHNER: There was a more recent 14 reg guy for hurricanes.
15 MEMBER SKILLMAN: It's 1.22.1.
16 MR. TAMMARA: The COL applicant will 17 calculate that probability and show that it might be 18 less than ten to the core minus seven.
19 MEMBER SKILLMAN: Thank you. That was the 20 item that was tugging at me. And, Mike, the other 21 item is I think, you know, one man's opinion. This 22 plant is a heavyweight. It's a dense plant. It is a 23 large footprint with a large volume and mass of water 24 in 12 modules.
25 And I understand soil bearing requirement.
NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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162 1 But I'm thinking, as large and strong as this building 2 is, it's still an eggshell. And there are some 3 demands on the structure of the reactor building that 4 are different from any, at least that I've seen, in my 5 career. And I'm not sure that that's highlighted as 6 prominently as it needs to be. And that's all I want 7 to say. Thanks.
8 MEMBER CORRADINI: Anything else from any 9 of the members? Okay. With that, we'll adjourn.
10 Happy holidays.
11 (Whereupon, the above-entitled matter went 12 off the record at 4:59 p.m.)
13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS C O U R T R E P O R T E R S A N D T R A N S C R IB E R S 1 3 2 3 R H O D E IS L A N D A V E ., N .W .
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NuScale Nonproprietary ACRS Presentation Chapter 17 -
Quality Assurance and Reliability Assurance Patrick Conley Engineering Programs Paul Infanger Licensing Project Manager December 18, 2018 1
PM-1218-63732 Revision: 0 Copyright 2018 by NuScale Power, LLC.
Template #: 0000-21727-F01 R4
Purpose
- Provide FSAR Chapter 17 overview
- Quality Assurance Program (QAP)
- Design Reliability Assurance Program (D-RAP) 2 PM-1218-63732 Revision: 0 Copyright 2018 by NuScale Power, LLC.
Template #: 0000-21727-F01 R4
Quality Assurance Program
- Established in accordance with 10 CFR 50 App B and ASME NQA-1-2008 with NQA-1a-2009 addenda as endorsed by RG 1.28, Rev. 4
- Consistent with guidance in NUREG-0800 and NEI 11-04A Rev. 0 QAPD template
- Consists of
- Approved TR-1010-859-NP-A, Quality Assurance Program Description for the NuScale Power Plant, Rev. 3
- Quality Management Plan (QMP) - identifies requirements fully implemented and requirements not within scope of design phase, but may be implemented in future
- Implementing procedures listed in QMP 3
PM-1218-63732 Revision: 0 Copyright 2018 by NuScale Power, LLC.
Template #: 0000-21727-F01 R4
QAP (contd)
Section No. Description Remarks 17.1 Quality Assurance during the Design Phase Described in 17.5 17.2 Quality Assurance during the Construction and Not applicable to design Operation Phase certification Item COL 17.5-1 17.3 Quality Assurance Program Description Section 17.5 17.5 Quality Assurance Program Description - Does not address Design Certification, Early Site Permits, and construction and design QA New License Applicants activities that begin once construction begins 4
PM-1218-63732 Revision: 0 Copyright 2018 by NuScale Power, LLC.
Template #: 0000-21727-F01 R4
COL Items
- 17.4-1 Describe RAP to be conducted during operations
- 17.4-3 Identify QA controls for RAP SSC during site-specific design, procurement, fabrication, construction, and preoperational testing
- 17.5-1 Describe QAP applicable to site-specific design, construction, and operation
- 17.6-1 Describe 10 CFR 50.65 maintenance effectiveness monitoring program 5
PM-1218-63732 Revision: 0 Copyright 2018 by NuScale Power, LLC.
Template #: 0000-21727-F01 R4
- Only three RAIs on Ch 17
- RAI 8879 17.04-1 (chemical and volume control system)
- RAI 8879 17.04-2 (expert panel)
- RAI 8909 17.04-3 (backup power)
- All three are Resolved-Closed 6
PM-1218-63732 Revision: 0 Copyright 2018 by NuScale Power, LLC.
Template #: 0000-21727-F01 R4
D-RAP Process
- Complies with NUREG-0800, Section 17.4
- Process controlled by procedure
- Expert panel consists of Design Engineering, Operations, PRA, and Safety Analysis
- Licensing is a non-mandatory member 7
PM-1218-63732 Revision: 0 Copyright 2018 by NuScale Power, LLC.
Template #: 0000-21727-F01 R4
D-RAP Process (contd)
- PRA input based on approved TR-0515-13952-NP-A Risk Significance Determination, Rev. 0
- Default classification is risk-significant for safety-related functions, unless PRA specifically determines SSC functionality is not risk-significant
- Engineering Change Control process determines if expert panel review is required 8
PM-1218-63732 Revision: 0 Copyright 2018 by NuScale Power, LLC.
Template #: 0000-21727-F01 R4
RTNSS
- FSAR 17.4.3.3 states the process for evaluating SSC for the regulatory treatment of non-safety systems (RTNSS) program is described in FSAR 19.3
- No RTNSS criterion met
- No RTNSS SSCs in design 9
PM-1218-63732 Revision: 0 Copyright 2018 by NuScale Power, LLC.
Template #: 0000-21727-F01 R4
10 PM-1218-63732 Revision: 0 Copyright 2018 by NuScale Power, LLC.
Template #: 0000-21727-F01 R4
Risk Significance Determination (RSD)
- Key conditions and limitations in RSD topical report SER
- Only applicable to NuScale
- Risk-informed applications include consideration of risk-significant SSCs with other concepts (e.g., defense in depth)
- Technically adequate PRA that addresses all hazards and all modes
- NuScale met all conditions and limitations 11 PM-1218-63732 Revision: 0 Copyright 2018 by NuScale Power, LLC.
Template #: 0000-21727-F01 R4
D-RAP PRA Candidates
- Systems
- module protection system
- Components
- ECCS reactor vent valves and reactor recirculation valves
- decay heat removal system actuation valves
- reactor safety valves
- containment system containment isolation valves (CIVs)
- chemical and volume control system CIVs
- containment evacuation system CIVs
- combustion turbine generator 12 PM-1218-63732 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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D-RAP PRA Candidates (contd)
- Other events and initiators (Fussel-Vesely FV>20%)
- Reactor Building crane
- LOCA inside containment
- LOCA outside containment
- loss of offsite power
- internal fires
- internal floods
- Human actions (FV>20%)
- chemical and volume control system actuation
- containment flooding and drain system actuation 13 PM-1218-63732 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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Final D-RAP Results
- Table 17.4-1: Risk-significant D-RAP SSC
- containment system
- steam generator system
- reactor core system
- control rod drive system
- emergency core cooling system
- decay heat removal system
- module protection system
- neutron monitoring system
- Reactor Building, Reactor Building crane, Control Building 14 PM-1218-63732 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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Portland Office Richland Office 6650 SW Redwood Lane, 1933 Jadwin Ave., Suite 130 Suite 210 Richland, WA 99354 Portland, OR 97224 541.360.0500 971.371.1592 Arlington Office Corvallis Office 2300 Clarendon Blvd., Suite 1110 1100 NE Circle Blvd., Suite 200 Arlington, VA 22201 Corvallis, OR 97330 541.360.0500 London Office 1st Floor Portland House Rockville Office Bressenden Place 11333 Woodglen Ave., Suite 205 London SW1E 5BH Rockville, MD 20852 United Kingdom 301.770.0472 +44 (0) 2079 321700 Charlotte Office 2815 Coliseum Centre Drive, Suite 230 Charlotte, NC 28217 980.349.4804 http://www.nuscalepower.com Twitter: @NuScale_Power 15 PM-1218-63732 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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Safety Evaluation with Open Items:
Chapter 17, Quality Assurance and Reliability Assurance NuScale Design Certification Application ACRS Subcommittee Meeting December 18, 2018
Agenda
- NRC Staff Review Team
- Summary of the NRC Staffs Review
- Quality Assurance
- FSAR Sections: 17.1, 17.2, 17.3, and 17.5
- Reliability Assurance
- FSAR Section: 17.4
NRC Staff Review Team
- Technical Staff
- Andrea Keim, NRO
- Mark Caruso, NRO (Retired)
- Project Management
- Omid Tabatabai, Senior Project Manager
- Greg Cranston, Lead Project Manager ACRS Subcommittee Presentation on December 18, 2018 3 NuScale DCA, FSAR, Chapter 17
Overview and Summary of Staffs Review
- DCA Rev. 0 submitted in Dec. 2016; Rev. 1 in Mar. 2018; and Rev. 2 in Oct. 2018. The Staffs SER is based on DCA, Rev 1
- Issued 2 RAIs (containing 3 questions) related to Section 17.4.
All RAI Questions are resolved-closed
- Conducted two regulatory audits related to Section 17.4 during April-August 2017 and March-April 2018
- Conducted one Quality Assurance Implementation Inspection in June 2017. A follow-up inspection is being planned
- The Staffs Chapter 17 SER contains two open items - details will be discussed in the subsequent slides
- There are no Confirmatory Items in the SER ACRS Subcommittee Presentation on December 18, 2018 4 NuScale DCA, FSAR, Chapter 17
Section 17.5 Quality Assurance ACRS Subcommittee Presentation on December 18, 2018 5 NuScale DCA, FSAR, Chapter 17
Regulatory Basis
- 10 CFR Part 50, Appendix A, GDC 1 requires that QA program be established and implemented
- 10 CFR Part 50, Appendix B specifies 18 quality criteria that the QA program description must address
- 10 CFR 52.47(a)(19) requires that a standard DC applicant include a QAPD that satisfies applicable portions of Appendix B to 10 CFR Part 50 ACRS Subcommittee Presentation on December 18, 2018 6 NuScale DCA, FSAR, Chapter 17
Topical Report Review
- NuScale submitted Topical Report NP-TR-1010-859-NP, Quality Assurance Program Description for the NuScale Power Plant, Revision 3 on March 24, 2016
- NuScale commits to NQA-1-2008 and NQA-1a-2009 addenda as endorsed by RG 1.28, Revision 4
- The NRC staff reviewed the QAPD using NUREG-0800 Section 17.5
- The NRC staff SER dated September 22, 2016 ACRS Subcommittee Presentation on December 18, 2018 7 NuScale DCA, FSAR, Chapter 17
Staffs Review of DCA, Section 17.5
- References Quality Assurance Program Description for the NuScale Power Plant, NP-TR-1010-859-NP-A, Revision 3
- COL Item 17.5-1: A COL applicant that references the NuScale Power Plant design certification will describe the quality assurance program applicable to the site-specific design activities and to the construction and operations phases.
- Open Item 17.5-1: Additional QA implementation inspection ACRS Subcommittee Presentation on December 18, 2018 8 NuScale DCA, FSAR, Chapter 17
QA Implementation Inspection
- June 5 - 9th, 2017
- NuScale Office Facility in Corvallis, Oregon
- Inspection Procedure 35017, Quality Assurance Implementation Inspection
- No findings of significance were identified
- QA Inspection Report is publicly available at (ML1720J382).
- Additional QA inspection is being scheduled and is listed in SER Open Item 17.5-1 ACRS Subcommittee Presentation on December 18, 2018 9 NuScale DCA, FSAR, Chapter 17
Section 17.4 Reliability Assurance Program (RAP)
ACRS Subcommittee Presentation on December 18, 2018 10 NuScale DCA, FSAR, Chapter 17
Reliability Assurance Program
- Staff evaluated NuScales reliability assurance program, including the design RAP (D-RAP) list in accordance with SRP Section 17.4, Rev. 1
- Staff found the RAP program sufficient in:
- Program description and implementation
- Programmatic controls
- SSC selection methodology
- Expert panel member requirements
- Determination of risk significant SSCs ACRS Subcommittee Presentation on December 18, 2018 11 NuScale DCA, FSAR, Chapter 17
Reliability Assurance Program
- Staff found:
- the D-RAP list was developed in accordance with its RAP methodology and the D-RAP list is comprehensive.
- NuScale adequately implemented the expert panel in developing the D-RAP list.
- COL items provide reasonable assurance that the RAP for a COL applicant which references the NuScale design will be adequate.
- Open Item: D-RAP ITAAC (SECY-18-0093)
ACRS Subcommittee Presentation on December 18, 2018 12 NuScale DCA, FSAR, Chapter 17
Abbreviations ACRS Advisory Committee on Reactor Safeguards COL Combined License DC Design Certification DCA Design Certification Application D-RAP Design Reliability Assurance Program FSAR Final Safety Analysis Report ITAAC Inspections, Tests, Analyses, and Acceptance Criteria NRO NRC Office of New Reactors QA Quality Assurance RAP Reliability Assurance Program SER Safety Evaluation Report SSC Structures, Systems, and Components ACRS Subcommittee Presentation on December 18, 2018 13 NuScale DCA, FSAR, Chapter 17
NuScale Nonproprietary ACRS Presentation Chapter 2 -
Site Characteristics and Site Parameters J. J. Arthur, P.E.
Manager, Structures and Design Analysis Paul Infanger Licensing Project Manager December 18, 2018 1
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Purpose
- Provide FSAR Chapter 2 overview
- Site characteristics and parameters
- RAIs
- SER open item 2
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Chapter 2 Overview
- Site parameters are generally consistent with past applicant precedents and 2014 EPRI Advanced LWR Utility Requirements Document 3
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Conceptual Site Layout 4
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Site Design Parameters
- Design assumes site parameters representative of a reasonable number of potential plant site locations in the U.S. A summary of the parameters is in FSAR Table 2.0-1 and provided in following slides.
- COL Item 2.0-1: demonstrate site-specific characteristics are bounded by design parameters specified in Table 2.0-1. If not bounded, demonstrate acceptability of site-specific values.
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2.1 Geography, Demography
- Minimum distance from EAB to nearest release point -
400 ft
- Minimum distance from LPZ outer boundary to nearest release point - 400 ft
- COL Item 2.1-1: describe site geographic and demographic characteristics 6
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2.2 Nearby Facilities
- No hazards from nearby industrial, transportation, or military facilities postulated
- No aircraft hazards postulated
- COL Item 2.2-1: describe nearby industrial, transportation, and military facilities; demonstrate design acceptability for each potential accident or provide site-specific design alternatives 7
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2.3 Meteorology
- 19.4 inches/hr (6.3 inches for 5 min period)
- normal / extreme 50 psf / 75 psf
- 100-yr return 3-sec wind gust (EPRI URD)
- 145 mph with importance factor of 1.15 for RXB, CRB, RWB
- Design basis tornado (RG 1.76)
- max wind speed 230 mph
- translational speed 46 mph
- max rotational speed 184 mph (radius 150 ft)
- pressure drop / rate 1.2 psi / 0.5 psi/sec 8
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2.3 Meteorology (contd)
- Tornado missile spectra (RG 1.76 R1, Table 2, Region 1)
- Design basis hurricane (RG 1.221)
- missile spectra (RG 1.221 R0, Tables 1 & 2)
- max wind speed 290 mph
- 0% exceedance values (historical limit excluding peaks
< 2 hr) used for CRVS design
- max outdoor design dry bulb temp 115oF
- min outdoor design dry bulb temp -40oF
- max coincident wet bulb temp 80oF
- max non-coincident wet bulb temp 81oF 9
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2.3 Meteorology (contd)
- max outdoor design dry bulb temp 100oF
- min outdoor design dry bulb temp -10oF
- max coincident wet bulb temp 77oF
- max non-coincident wet bulb temp 80oF
- 5% exceedance values used for TGB HVAC design
- max outdoor design dry bulb temp 95oF
- min outdoor design dry bulb temp -5oF
- max coincident wet bulb temp 77oF 10 PM-1218-63753 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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2.3 Meteorology (contd)
- Atmospheric dispersion X/Q methodology based on ARCON96
- NuScale site boundary (400 ft) vs traditional LWR
(~ 2,600 ft - 19,700 ft)
- NuScale applies ARCON96 methodology based on RG 1.194 for improved accuracy in predicting atmospheric dispersion for a short EAB/LPZ distance, as opposed to a PAVAN methodology based on RG 1.145, which was developed for longer distances
- Methodology described in Accident Source Term topical report Rev. 2 11 PM-1218-63753 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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2.3 Meteorology (contd)
- Accident release X/Q at EAB/LPZ boundary 2 hr 6.22E-04 s/m3 8 hr 5.27E-04 s/m3 24 hr 2.41E-04 s/m3 96 hr 2.51E-04 s/m3 720 hr 2.46E-04 s/m3
- Accident release X/Q at MCR/TSC door and HVAC intake 2 hr 6.50E-03 s/m3 8 hr 5.34E-03 s/m3 24 hr 2.32E-03 s/m3 4 days 2.37E-03 s/m3 30 days 2.14E-03 s/m3 12 PM-1218-63753 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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2.3 Meteorology (contd)
- Routine release X/Q and D/Q (bounding offsite dose)
- undepleted/no decay 1.44E-05 s/m3
- undepleted/2.26-day decay 1.44E-05 s/m3
- depleted/8.00-day decay 1.44E-05 s/m3
- D/Q 1.44E-07 l/m2
- COL Item 2.3-1: describe site-specific meteorological characteristics for Section 2.3.1 through Section 2.3.5 13 PM-1218-63753 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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2.4 Hydrology
- Max flood elevation (EPRI URD)
- 1 ft below baseline plant elevation
- Max groundwater elevation (EPRI URD)
- 2 ft below baseline plant elevation
- COL Item 2.4-1: investigate and describe site-specific hydrologic characteristics for Section 2.4.1 through Section 2.4.14 14 PM-1218-63753 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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2.5 Geology, Seismology
- Design uses geologic, seismologic, and geotechnical engineering parameters representative of a reasonable number of potential plant site locations in the U. S.
- Two DBEs: CSDRS and CSDRS-HF
- Spectra bound most of central and eastern U.S., and sites in less seismically active portions of western U.S.
- Fault displacement potential none
- Min soil bearing capacity 75 ksf
- Lateral soil variability uniform (< 20o dip)
- Min internal friction soil angle 30o
- Min shear wave velocity > 1000 fps 15 PM-1218-63753 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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2.5 Geology, Seismology (contd)
- Liquefaction potential none
- Max settlement for RXB, CRB, RWB
- Total 4 inches
- Tilt 0.5 inch per 50 ft of building length or 1 inch total in any direction
- Differential 0.5 inch (RXB-CRB, RXB-RWB)
- Slope failure potential none
- COL Item 2.5-1: describe the site-specific geology, seismology, and geotechnical characteristics for Section 2.5.1 through Section 2.5.5 16 PM-1218-63753 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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RAIs FSAR Resolved Unresolved Suppl Resp
- RAIs Confirmatory Section Closed Closed In Eval 2.3 13 5 5 3 2.4 1 1 2.5 5 1 2 2
- Unresolved Closed issue involves analysis of accidental release of radioactive liquid effluents in groundwater and surface water using BTP 11-6 methodology and guidance (RAI 8750 Question 02.04.13-1) 17 PM-1218-63753 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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SER Open Item 02.03.04-1
- Acceptability of method for calculating accident offsite X/Q values for EAB and LPZ, which is the outer boundary from the AST topical report TR-0915-17565 18 PM-1218-63753 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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Abbreviations AST - accident source term COL - combined license CRB - Control Building CRVS - normal control room HVAC system CSDRS - certified seismic design response spectra CSDRS-HF - CSDRS - high frequency CWS - circulating water system DCD - Design Control Document EAB - exclusion area boundary EPRI - Electric Power Research Institute 19 PM-1218-63753 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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Abbreviations (contd)
FSAR - Final Safety Analysis Report HMR - Hydrometeorological Report HVAC - heating ventilation and air conditioning LPZ - low population zone LWR - light water reactor MCR - main control room NOAA - National Oceanic and Atmospheric Administration RAI - request for additional information RG - Regulatory Guide RWB - Radioactive Waste Building 20 PM-1218-63753 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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Abbreviations (contd)
RXB - Reactor Building SER - Safety Evaluation Report SCWS - site cooling water system TGB - Turbine Generator Building TSC - technical support center URD - Utility Requirements Document 21 PM-1218-63753 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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Portland Office Richland Office 6650 SW Redwood Lane, 1933 Jadwin Ave., Suite 130 Suite 210 Richland, WA 99354 Portland, OR 97224 541.360.0500 971.371.1592 Arlington Office Corvallis Office 2300 Clarendon Blvd., Suite 1110 1100 NE Circle Blvd., Suite 200 Arlington, VA 22201 Corvallis, OR 97330 541.360.0500 London Office 1st Floor Portland House Rockville Office Bressenden Place 11333 Woodglen Ave., Suite 205 London SW1E 5BH Rockville, MD 20852 United Kingdom 301.770.0472 +44 (0) 2079 321700 Charlotte Office 2815 Coliseum Centre Drive, Suite 230 Charlotte, NC 28217 980.349.4804 http://www.nuscalepower.com Twitter: @NuScale_Power 22 PM-1218-63753 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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Presentation to the ACRS Subcommittee NuScale Design Certification Application Review Safety Evaluation Report with Open Items Chapter 2: SITE CHARACTERISTICS Project Manager: Prosanta Chowdhury December 18, 2018
Technical Branch Presentations Radiation Protection and Accident Consequences Branch
- Section 2.1 Geography and Demography
- Section 2.2 Nearby Industrial, Transportation, and Military Facilities Hydrology & Meteorology Branch
- Section 2.3 Meteorology
- Section 2.4 Hydrologic Engineering Geoscience & Geotechnical Engineering Branch
- Section 2.5 Geology, Seismology, & Geothermal December 18, 2018 Chapter 2 - Site Characteristics 2
NRC Staff Interactions with NuScale Requests for Additional Information Section 2.3 - 10 questions; 4 Closed; 6 Confirmatory Action pending FSAR update; 1 Open Item Section 2.4 - 1 question; 1 Closed; 3 Confirmatory Action pending FSAR update Section 2.5 - 3 questions; 1 Closed; 2 Confirmatory Action pending FSAR update December 18, 2018 Chapter 2 - Site Characteristics 3
NRC Presenters Rao Tammara: NRO/DLSE/RPAC - Sections 2.1 & 2.2 Michael Mazaika: NRO/DLSE/RHM/RMET - Section 2.3.1 - 2.3.3 Jason White: NRO/DLSE/RHM/RMET - Sections 2.3.4 - 2.3.5 Yuan Cheng: NRO/DLSE/RHMB - Section 2.4 Weijun Wang: NRO/DLSE/RGS - Section 2.5 Stephanie Devlin-Gill: Branch Chief - NRO/DLSE/RHM Gerry Stirewalt: Branch Chief - NRO/DLSE/RGS Michael Dudek: Branch Chief - NRO/DLSE/RPAC Prosanta Chowdhury: Project Manager - NRO/DLSE/LB1 December 18, 2018 Chapter 2 - Site Characteristics 4
Presentation to the ACRS Subcommittee NuScale Design Certification Application Review Safety Evaluation Report with Open Items Section 2.1: GEOGRAPHY AND DEMOGRAPHY Section 2.2: NEARBY INDUSTRIAL, TRANSPORTATION, AND MILITARY FACILITIES December 18, 2018
Technical Topics of Interest Section 2.1 - Geography and Demography Section 2.1 - Geography and Demography
- The review involves the following sections of the NuScale Power DCD:
- 2.1.1 - Site Location and Description
- 2.1.2 - Exclusion Area Authority and Control
- 2.1.3 - Population Distribution The COL applicant that references the NuScale Power design certification will describe and address the site geographic and demographic characteristics as described above. The COL applicant is to provide this site specific information as part of COL information Item 2.1-1 in the COL application.
December 18, 2018 Chapter 2 - Site Characteristics 6
Technical Topics of Interest Section 2.2 - Nearby Industrial, Transportation, and Military Facilities Section 2.2 - Nearby Industrial, Transportation, and Military Facilities
- The review involves the following sections of the NuScale Power DCD:
- 2.2.1 - Locations and Routes
- 2.2.2 - Descriptions
- 2.2.3 - Evaluation of Potential Accidents The COL applicant that references the NuScale Power design certification will describe and address the nearby industrial, transportation, and military facilities. The COL applicant is to demonstrate that the design is acceptable for each potential accident or provide site-specific design alternatives. The COL applicant is to provide this site specific information as part of COL information Item 2.2-1 in the COL application.
December 18, 2018 Chapter 2 - Site Characteristics 7
Presentation to the ACRS Subcommittee NuScale Design Certification Application Review Safety Evaluation Report with Open Items Section 2.3: METEOROLOGY December 18, 2018
Overview of DCA FSAR Section 2.3 - Meteorology
- Review involves the following sections through Revision 1 of the NuScale DCA FSAR:
- 2.3.1 - Regional Climatology
- 2.3.2 - Local Meteorology
- 2.3.3 - Onsite Meteorological Measurements Programs
- 2.3.4 - Short-Term Atmospheric Dispersion Estimates for Accident Releases
- 2.3.5 - Long-term Atmospheric Dispersion Estimates for Routine Releases
- Potential plant site locations in U.S. including contiguous (lower 48) states, Alaska, and Hawaii. DCA is silent on potential deployment in U.S. Territories December 18, 2018 Chapter 2 - Site Characteristics 9
Section 2.3 - Meteorology Postulated Site Parameters
- Applicant postulated site parameters related to:
- Climatic Extremes (i.e., precipitation, winds, ambient temperatures)
- Atmospheric Dispersion and Deposition Factors (design-basis accident & routine (normal) releases)
- Staff reviewed Section 2.3 of the NuScale DCA FSAR in accordance with SRP Sections 2.3.1 through 2.3.5, associated regulatory guidance, and related data resources
- A COL applicant is required to compare its site characteristics to the site parameters postulated for the NuScale design December 18, 2018 Chapter 2 - Site Characteristics 10
Topics of Interest Section 2.3.1 - Regional Climatology Climate-related Site Parameters
- Maximum Precipitation (Rainfall) Rates for Roof Design
- Consistent with most of previously-submitted DCAs
- PMP values from HMR No. 52 (based on selected storms east of 105th Meridian in contiguous U.S.)
- Postulated site parameters representative of a reasonable number of locations in contiguous U.S.
December 18, 2018 Chapter 2 - Site Characteristics 11
Topics of Interest Section 2.3.1 - Regional Climatology Climate-related Site Parameters (Contd)
- Winter Precipitation Loads (for Roof Design)
- Site parameters only provided as normal and extreme roof snow loads.
Consistent with intent of DC/COL-ISG-007, Applicant revised Chapter 3 to allow back-calculation of ground loads (reported in Section 2.3.1)
- Design of RXB and CRB roofs limits accumulation of liquid precipitation such that frozen winter precipitation events should be controlling
- Staff evaluated 100-year return ground snow loads based on ASCE/SEI 7-10 for contiguous U.S. and Alaska
- Postulated site parameters are representative of a reasonable number of locations in continental U.S. (including some portions of Alaska)
December 18, 2018 Chapter 2 - Site Characteristics 12
Topics of Interest Section 2.3.1 - Regional Climatology Climate-related Site Parameters (Contd)
- Design-Basis Severe Wind Speed (100-Year 3-Second Gust)
- Also referred to as straight-line winds. Postulated design-basis severe wind speed (3-sec gust) based on ASCE/SEI 7-05 and is applicable to RXB, CRB, and RWB
- Staff evaluated 100-year return straight-line wind speed (3-sec gust) using ASCE/SEI 7-05 for contiguous U.S. and Alaska consistent with SRP Section 2.3.1
- Site parameter value and related characteristics representative of a reasonable number of locations in the contiguous U.S., Hawaii, and much of Alaska December 18, 2018 Chapter 2 - Site Characteristics 13
Topics of Interest Section 2.3.1 - Regional Climatology Climate-related Site Parameters (Contd)
- Design-Basis Tornado
- Postulated DBT wind speed (3-sec gust) and pressure parameters (with exceedance frequency of 1E-07 per year) based on RG 1.76 (Rev. 1) for Region 1 (highest tornado intensity region)
- Site parameters representative of a reasonable number of locations in contiguous U.S. DBT parameters not specified in RG 1.76 for Alaska or Hawaii. DCA does not address these locations
- Design-Basis Hurricane
- Postulated DBH wind speed (3-sec gust) with exceedance frequency of 1E-07 per year based on RG 1.221 represents highest 3-sec gust depicted in RG 1.221
- Site parameter representative of a reasonable number of locations, including hurricane-prone areas, of contiguous U.S. DBH wind speeds not specified in RG 1.221 for Pacific Coast of contiguous U.S. or Hawaii.
DCA does not address these locations December 18, 2018 Chapter 2 - Site Characteristics 14
Topics of Interest Section 2.3.1 - Regional Climatology Climate-related Site Parameters (Contd)
- Ambient Design Dry- and Wet-Bulb Temperatures
- Postulated site parameters for 0%, 1%, and 5% exceedance maximum and minimum dry-bulb temperatures, wet-bulb temperatures coincident with indicated maximum dry-bulb values, and 0% and 1% exceedance non-coincident wet-bulb temperatures
- Applicant referenced numerical values to Rev. 13 of EPRI URD (2014) and indicated (via RAI response) that values represent annual, rather than seasonal, exceedance probabilities. Staff determined that numerical values are same as in Rev. 8 of URD (1999)
- Coincident wet-bulb temperatures in EPRI URD represent mean values whereas coincident wet-bulb temperatures postulated in DCA represent (via RAI response) maximum values December 18, 2018 Chapter 2 - Site Characteristics 15
Topics of Interest Section 2.3.1 - Regional Climatology Climate-related Site Parameters (Contd)
- Ambient Design Dry- and Wet-Bulb Temperatures
- Staff evaluated postulated dry- and wet-bulb temperatures based on data summarized by ASHRAE for contiguous U.S. and Hawaii, and used professional judgement for temperature conditions in Alaska
- Maximum and minimum dry-bulb values for all exceedance levels acceptable at a reasonable number of locations in most of continental U.S. and Hawaii
- Postulated 1% non-coincident wet-bulb temperature acceptable at a reasonable number of locations in contiguous U.S., Hawaii, and, based on professional judgement, Alaska December 18, 2018 Chapter 2 - Site Characteristics 16
Topics of Interest Section 2.3.1 - Regional Climatology Climate-related Site Parameters (Contd)
- Ambient Design Dry- and Wet-Bulb Temperatures
- Applicant took position (via RAI response) that chosen wet-bulb temperature site parameters are for non-safety related HVAC systems and cooling towers (see Tier 2, Table 3.2-1). Therefore, it is a business decision not to change these values
- Postulated 0%, 1%, and 5% dry-bulb temperatures appear to be acceptable at a reasonable number of locations (except in desert southwest and drier portions of California). However, ASHRAE database suggests maximum coincident wet-bulb temperatures in those pairs likely to be exceeded in much of contiguous U.S. and Hawaii
- Based on Applicants position, it is reasonable to expect a need for potential COL applicants to request a departure from postulated 0%
non-coincident, or the 0%, 1% or 5% maximum coincident wet-bulb temperature(s) depending on site characteristics December 18, 2018 Chapter 2 - Site Characteristics 17
Topics of Interest
- Section 2.3.2 - Local Meteorology
- FSAR states that [l]ocal meteorology is site-specific and is addressed by the COL applicant. Staff agrees
- Section 2.3.3 - Onsite Meteorological Measurements Programs
- FSAR states that [o]nsite meteorological measurements programs are site-specific and addressed by COL applicant. Staff agrees December 18, 2018 Chapter 2 - Site Characteristics 18
Topics of Interest Section 2.3.4 - Short-Term Atmospheric Dispersion Site Parameters for Accident Releases Offsite EAB and LPZ X/Q Site Parameter Values
- Applicant stated that topical report, TR-0915-17565, describes the methodology for calculating accident X/Q values at EAB and LPZ
- Staff performed an independent verification of Applicants offsite X/Q site parameter values postulated for EAB and LPZ
- Staff used a portion of the NuScale methodology to calculate X/Q values based on meteorological data collected at six nuclear power plant sites
- Staff found that only one of these six sites had X/Q values that are bounded by all of the postulated NuScale site parameter values
- If a COL applicant references the NuScale design and finds its actual site characteristic X/Q values do not fall within corresponding site parameters postulated in the DCA, the COL applicant will need to provide sufficient justification that the proposed facility is still acceptable at the proposed site December 18, 2018 Chapter 2 - Site Characteristics 19
Topics of Interest Section 2.3.4 - Short-Term Atmospheric Dispersion Site Parameters for Accident Releases (Contd)
Offsite EAB and LPZ X/Q Site Parameter Values
- Open Item 2.3.4-1. Staff is currently evaluating TR-0915-17565 to determine if the NuScale methodology is acceptable for calculating DBA offsite X/Q values at EAB and LPZ in relation to NuScale design and in a COL application that references NuScale design
- Subject to resolution of the Staffs evaluation of TR-0915-17565, the Staff concludes that the Applicant has appropriately provided the short-term (accident release) X/Q site parameters December 18, 2018 Chapter 2 - Site Characteristics 20
Topics of Interest Section 2.3.4 - Short-Term Atmospheric Dispersion Site Parameters for Accident Releases (Contd)
Onsite MCR and TSC X/Q Site Parameter Values
- Staff performed an independent verification of Applicants postulated onsite X/Q site parameter values at the MCR and TSC doors and HVAC intake
- Staff generated X/Q values using the ARCON96 computer code with the source and receptor information presented in the DCA
- Staff found that the Applicant has provided onsite X/Q site parameter values at the MCR and TSC doors and HVAC intake that are representative of a reasonable number of locations that may be considered for a COL application December 18, 2018 Chapter 2 - Site Characteristics 21
Topics of Interest Section 2.3.5 - Long-Term Atmospheric Dispersion Site Parameters for Routine Releases Offsite Dose Location X/Q and D/Q Values
- Staff performed an independent evaluation of Applicants postulated offsite X/Q and D/Q site parameter values using the XOQDOQ computer code
- Staff found that the long-term (routine release) site parameter values selected by the Applicant are representative of a reasonable number of sites that have been or may be considered for a COL application December 18, 2018 Chapter 2 - Site Characteristics 22
Acronyms & Abbreviations Section 2.3 - Meteorology
- ASCE/SEI - American Society of Civil Engineers/Structural Engineering Institute
- ASHRAE - American Society of Heating, Refrigeration & Air Conditioning Engineers
- COL - Combined License
- CRB - Control Building
- DBA - Design-Basis Accident
- DBH - Design-Basis Hurricane
- DBT - Design-Basis Tornado
- DC - Design Certification
- DCA - Design Certification Application
- D/Q - Relative Deposition Factor (1/m2)
- EAB - Exclusion Area Boundary
- EPRI - Electric Power Research Institute
- FSAR - Final Safety Analysis Report
- HMR - Hydrometeorological Report
- HVAC - Heating, Ventilation, and Air Conditioning System December 18, 2018 Chapter 2 - Site Characteristics 23
Acronyms & Abbreviations Section 2.3 - Meteorology (Contd)
- ISG - Interim Staff Guidance
- LPZ - Outer Boundary of the Low Population Zone
- MCR - Main Control Room
- PMP - Probable Maximum Precipitation
- RAI - Request for Additional Information
- RG - Regulatory Guide
- RWB - Radioactive Waste Building
- RXB - Reactor Building
- SRP - Standard Review Plan
- TR - Topical Report
- URD - Utility Requirements Document
- X/Q - Atmospheric Dispersion Factor (sec/m3)
December 18, 2018 Chapter 2 - Site Characteristics 24
Presentation to the ACRS Subcommittee NuScale Design Certification Application Review Safety Evaluation Report with Open Items Section 2.4: HYDROLOGIC ENGINEERING December 18, 2018
Site Parameters For Hydrologic Engineering
- The applicant identified three site parameters related to hydrologic engineering: (Reference to DCA PART 2, Tier 2, Table 2.0-1)
- Maximum flood level, including wind-induced wave run-up, one foot below baseline plant elevation
- Groundwater level is a minimum of two feet below the site grade
- Maximum precipitation rates: 19.4 inches in one hour and 6.3 inches in 5 minutes December 18, 2018 Chapter 2 - Site Characteristics 26
Site-Specific Characteristics and COL Information Item 2.4-1
- DCA PART 2, Tier 2, Sections 2.4.1 through 2.4.14, except 2.4.8 and 2.4.10, should be evaluated in COL stage:
- Staff confirmed that DCA PART 2 Tier 2, Sections 2.4.1 through 2.4.14, except 2.4.8 and 2.4.10, are related to site-specific characteristics
- Characteristics include: local hydrology, local intense precipitation, probable maximum flood on stream and rivers, potential dam failures, probable maximum surge and seiche flooding, probable maximum tsunami hazards, ice effects, channel diversions, low water considerations, ground water, and a liquid effluent release to groundwater
- Those sections related to site-specific characteristics will be evaluated in COL stage by future applicant December 18, 2018 Chapter 2 - Site Characteristics 27
Site-Specific Characteristics and COL Information Item 2.4-1 (Continued)
- Staff confirmed that cooling water canals and reservoirs (Section 2.4.8) would not be designated as safety-related make-up water sources for NuScale design
- Staff confirmed that the NuScale ultimate heat sink design does not rely on an external water supply for at least 30 days (Section 9.2.5.4)
- Staff also confirmed that flood protection requirements (Section 2.4.10) are not applicable since the baseline plant elevation is one foot above the maximum flood level elevation December 18, 2018 Chapter 2 - Site Characteristics 28
Site-Specific Characteristics and COL Information Item 2.4-1 (Continued)
- COL Information Item 2.4-1:
A combined license (COL) applicant that references the NuScale Power Plant design certification (DC) will investigate and describe the site-specific hydrologic characteristics for Sections 2.4.1 through 2.4.14, except Sections 2.4.8 and 2.4.10
- COL Information Item 2.4-1 addresses the three site parameters.
December 18, 2018 Chapter 2 - Site Characteristics 29
Staff Conclusions
- NuScale DCA site parameters meets the requirements of 10 CFR Part 100, Reactor Site Criteria
- All regulatory requirements have been satisfied
- No open items
- Three confirmatory items December 18, 2018 Chapter 2 - Site Characteristics 30
Acronyms & Abbreviations Section 2.4 - Hydrologic Engineering CFR - Code of Federal Regulations COL - Combined License DC - Design Certification DCA - Design Certification Application NRC - U.S. Nuclear Regulatory Commission December 18, 2018 Chapter 2 - Site Characteristics 31
Presentation to the ACRS Subcommittee NuScale Design Certification Application Review Safety Evaluation Report with Open Items Section 2.5: GEOLOGY, SEISMOLOGY, AND GEOTECHNICAL ENGINEERING December 18, 2018
Technical Topics of Interest Section 2.5 - Geology, Seismology, and Geotechnical Engineering The review involved the following sections of the NuScale FSAR:
2.5.1 Basic Geologic and Seismic Information 2.5.2 Vibratory Ground Motion 2.5.3 Surface Faulting 2.5.4 Stability of Subsurface Materials and Foundations 2.5.5 Stability of Slopes December 18, 2018 Chapter 2 - Site Characteristics 33
Technical Topics of Interest Section 2.5 - Geology, Seismology, and Geotechnical Engineering Establishes site parameters as NuScale design basis or for a site suitable for the design, which include:
- no fault displacement potential under the plant structures
- certified seismic design response spectra (CSDRS)
- certified seismic design response spectra - high frequency (CSDRS-HF)
- minimum shear wave velocity of the subsurface material
- minimum ultimate bearing capacity
- uniformity of soil layers
- no potential for soil liquefaction
- minimum coefficient of static friction
- minimum soil angle of internal friction
- limits of foundation settlement December 18, 2018 Chapter 2 - Site Characteristics 34
Technical Topics of Interest Section 2.5 - Geology, Seismology, and Geotechnical Engineering Sections 2.5.1 and 2.5.3 findings:
- DCA defined geology related site parameters such as no fault displacement potential under the plant structures at a site
- DCA specified in COL Information item that site specific basic regional and site geologic information to be addressed by COL applicants December 18, 2018 Chapter 2 - Site Characteristics 35
Technical Topics of Interest Section 2.5 - Geology, Seismology, and Geotechnical Engineering Sections 2.5.2 findings:
- The DCA defined CSDRS and CSDRS-HF as its seismic loading design basis, and intended to cover sites at most of the central and eastern U.S., as well as sites in the western U.S.
- DCA specified in COL Information item that site specific basic regional and site seismic information, with local vibratory ground motion and site safe shutdown earthquake to be addressed by COL applicants December 18, 2018 Chapter 2 - Site Characteristics 36
NuScale Horizontal Certified Seismic Design Response Spectra at 5% Damping 10.000 10.00 CSDRS CSDRS RG 1.60 @ 0.3g RG 1.60 @ 0.1g CSDRS-HF 1.000 1.00 0.100 0.10 0.010 0.01 0.1 1.0 10.0 100.0 0.1 1.0 10.0 100.0 Frequency (Hz) Frequency (Hz)
CSDRS vs RG 1.60 CSDRS and CSDRS-HF December 18, 2018 Chapter 2 - Site Characteristics 37
Technical Topics of Interest Section 2.5 - Geology, Seismology, and Geotechnical Engineering Sections 2.5.4 and 2.5.5 findings:
- The staff RAIs focused on:
- site subsurface material uniformity requirements
- applicability of static and dynamic parameters of the subsurface materials, including the backfill materials
- limits of total and differential settlements for safety related structures
- lateral earth pressure evaluation
- The applicant adequately addressed all RAI issues, and specified pertinent items to be addressed by COL applicants December 18, 2018 Chapter 2 - Site Characteristics 38
Technical Topics of Interest Section 2.5 - Geology, Seismology, and Geotechnical Engineering Staff Conclusions
- No Open Items in Chapter 2.5
- The applicant adequately specified geologic, seismic and geotechnical engineering related site parameters for NuScale design and for site suitability determination