ML23318A016

Readiness Assessment Summary Observation Report for the Carbon Free Power Project Draft Combined License Application

ML23318A016
Person / Time
Site:	99902052
Issue date:	11/30/2023
From:	Beverly Smith, Tabatabai-Yazdi O NRC/NRR/DNRL/NRLB
To:	Volkoff J NuScale
References
Download: ML23318A016 (32)

Text

Mr. John Volkoff Manager, Combined License Applications NuScale Power, LLC 1100 Circle Boulevard, Suite 200 Corvallis, OR 97330

SUBJECT:

READINESS ASSESSMENT REPORT FOR THE CARBON FREE POWER PROJECT DRAFT COMBINED LICENSE APPLICATION

Dear Mr. Volkoff:

In a letter dated November 10, 2023, Carbon Free Power Project, LLC (CFPP) and NuScale Power, LLC (NuScale), informed the Nuclear Regulatory Commission (NRC) staff that the CFPP project has been terminated and requested to withdraw its limited work authorization, the exemption request, and topical reports associated with the CFPP combined license application (COLA)1. In a followup letter, dated November 16, 2023, NuScale requested the NRC staff to suspend the review of Cybersecurity Methodology white paper and proceed with providing the readiness assessment closure letter with a summary of the NRC staffs observations and feedback2. The purpose of this letter is to provide you with the NRC staffs final closure report for the readiness assessment review of the draft CFPP COLA.

In a letter dated May 24, 2023, NuScale requested the NRC staff to conduct a phased readiness assessment review of the CFPP COLA3. On June 5, 2023, the NRC staff issued a readiness assessment review plan4 and began its review via NuScales Electronic Reading Room. The NRC staff performed its readiness assessment review in six Phases as CFPP and NuScale made select portions of the COLAs final safety analysis report (FSAR) and the associated Environmental Report (ER) available to the staff for its review5. Enclosure 1 to this letter provides the NRC staffs Observations and Comments for the FSAR, and Enclosure 2 provides the NRC staffs Observations from the review of CFPPs ER. The NRC staff notes that the summary report does not include any observations or feedback on the COLA Parts, Chapters, or supporting documents, such as licensing topical reports, that were excluded from the staffs readiness assessment review.

The NRC staffs Observations signify missing technical information or gaps in the information that is required to be included in the COLA to demonstrate compliance with the applicable regulations. Observations could also include issues involving policy matters currently before the Commission for decision. The NRC staffs Comments are items that the staff has identified for the applicant to further explain, clarify, or otherwise make consistent with other parts of the COLA, e.g., revision numbers for the referenced documents.

1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML23317A110.

2 ADAMS ML23320A094 3 ADAMS ML23144A332.

4 ADAMS ML23151A072.

5 ADAMS ML23258A173.

November 30, 2023

J. Volkoff 2

The staff also notes that because a significant portion of the draft COLA incorporated by reference the NuScales US460 standard design approval application (SDAA), it is incumbent upon the COLA applicant to address any applicable regulatory compliance issues that will not be resolved as part of the SDAA review or deferred to a future COLA applicant.

The NRC staff encourages the COLA applicant to address the NRC staffs Observations before submitting the COLA. Addressing the NRC staffs Comments would also substantially improve the efficiency of the staffs review when the COLA is submitted. As part of the preapplication engagement, the NRC staff is available to answer any questions you might have or provide additional clarifications on the readiness assessment report Observations and Comments.

If you have any questions, please contact Omid Tabatabai, Senior Project Manager, at (301) 415-6616 or Omid.Tabatabai@nrc.gov.

Sincerely, ture:

Brian W. Smith, Division Director Division of New and Renewed Licenses Office of Nuclear Reactor Regulation Docket No. 99902052

Enclosure:

1. NRC Staffs Observations of CFPPs Final Safety Analysis Report

2. NRC Staffs Observations of CFPPs Environmental Report cc: CFPP Listserv Lee, Samuel signing on behalf of Smith, Brian on 11/30/23

ML23318A016

• via email NRR-106 OFFICE DNRL/NRLB: PM NMSS/REFS/ERNRB:PM DNRL/NLIB: LA NAME OTabatabai DBarnhurst SGreen DATE 11/14/2023 11/14/23 11/14/2023 OFFICE DNRL/NRLB: BC NMSS/REFS/ERNRB:BC DNRL:DD NAME MJardaneh PDoub BSmith: Slee for DATE 11/14/2023 11/14/2023 Item Applicable Section(s)

Regulatory Basis NRC Staffs Observations on FSAR 1

Sections 10.3; 10.4.3; 10.4.4; 10.4.6; 10.4.7 10 CFR 52.79(a)

As part of its review of the NuScale design certification application (DCA), Final Safety Evaluation Report (FSER) Chapter 10 (page 41), the staff only reviewed the design aspects of the water hammer prevention. A combined license (COL) applicant needs to include information related to the site-specific and procedures to prevent a water hammer event.

2 10.4.1 10 CFR 52.79 (a) (41);

GDC 60 For the air-cooled condensers system (ACCS), the COLA is missing information on: (1) design specifications, and (2) site-specific information. Specifically, provide the functional requirements of the ACCS, as well as the effects of adverse environmental occurrences (e.g., extreme summer heat, frigid winter conditions), and abnormal operational conditions, anticipated operational occurrences, and accident conditions. The applicant needs to provide the missing information.

3 6.2 GDC 50, GDC 16, GDC 38 The staff approved COL Item1 6.2-3 in the NuScale DCA for the COL applicant to use the as-built considerations for the containment free volume in the bounding containment safety analyses, and to include margin to address the complex shapes of containment internal structures and components and manufacturing processes. The staff is working with NuScale (via SDAA Audit Question Number: A-6.2-2) to add the DCA COL Item 6.2-3 in the SDAA Chapter 6, or add an appropriate ITAAC, to verify its as-built containment free volume to perform conservative containment design-basis accident analyses to demonstrate conformance to the bounding pressure and temperature design requirements of GDC 50, GDC 16, and GDC 38.

1 Unless otherwise identified in this report, a COL item refers to items that must be addressed by a COL applicant referencing NuScales US460 SDA or SDAA.

4 6.4 Section 6.4.4.3 Control Room Envelope (CRE)

As stated in NuScale DCA Part 2, Tier 2, Table 1.9 2, aspects of Regulatory Guide (RG) 1.196, Control Room Habitability at Light Water Nuclear Power Reactors, related to control room habitability design are applicable to the NuScale design. As stated in DCA Part 2, Tier 2, Section 6.4.5, the Control Room Envelope (CRE) periodic testing conforms to RG 1.197, Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors. DCA COL Item 6.4.5 directs a COL applicant to specify testing and inspection requirements for the CRHS, including CRE integrity testing. The CFPP COLA needs to address DCA COL Item 6.4.5. Also, the CFPP COLA needs to establish the periodicity (after initial preoperational testing and ITACC completion) of CRE testing consistent with the intent RG 1.196 and RG 1.197.

5 6.4 GDC 4 The applicant needs to demonstrate that the CFPP site is bounded by the environment bases for SDAA Table 6.4-2 table. Currently, it is not clear how, Main Control Room Temperature under Passive Cooling Conditions, is bounded (e.g., to all new PP construction within contiguous 48 states).

6 9.1.2 GDC 2 The FSAR does not include an assessment of non-seismic SSCs located in the vicinity of the spent fuel pool (SFP) to demonstrate that in the event of a seismic event, no SCC will fall into the SFP and damage any of the stored fuel. The applicant needs to assess the impact of a seismic event on non-seismic SSCs located in the vicinity of SFP and describe the results in the application.

7 9.2.9 GDC 60, 64 SDAA Section 9.2.9.2 indicates that the The source of water for the utility water system (UWS) and the required chemical treatment is site-specific. The draft COL application is missing information on UWS site-specific water source.

8 9.5 RG 1.189 CFPP COLA, Section 9.5.1, Table 9.5.1-2R, lists the COL applicant assigned fire protection items to be submitted in a COL application. Table 9.5.1-2R, did not provide detailed discussion on COL applicant assigned items as described in RG 1.189. Provide the information per RG 1.189 in the COLA.

9 5.3 GDC 14, 15, 31 COL Item 5.3-1 directs applicants to develop procedures to ensure transients will not be more severe than those for which the design adequacy has been demonstrated. The COL item direction is to base procedures on material properties of the as-built vessel is in addition to this. Draft COLA information only appears to address material properties aspect of COL item. The applicant needs to also describe the specifics of the actions to be taken by the operators, the verification of as-built transients being not more severe than for which design adequacy has been demonstrated, and the necessary limitations.

10 7.0.4.5 GDC 10, 13 Any design aspects of the density wave oscillations (DWO) issues that are not resolved as part of the SDAA review are within the scope of the COLA and will need to be incorporated into the COLA applicant. The applicant needs to provide the applicable control system details related to DWO. For instance, currently, COL Item 7.0-1 does not resolve the undetermined magnitude and frequency concerns using module control system algorithm.

11 13.2.1.1.1.1 and 13.2.7.3.1 Commission Policy Statement on Education for Senior Reactor Operators and Shift Supervisors at Nuclear Power Plants The staff may need to inform the Commission about a change in the degree requirements for senior reactor operator (SRO) applicants that do not have experience as a reactor operator at the facility (i.e., SRO-instants or direct SROs). The staff's review and approval of the NuScale Topical Report NuScale Control Room Staffing Plan, (ML21012A363) for staffing was based on current education requirements for SRO-instant applicants. This is a policy issue that may impact COLA review. This is not a gap in the application; however, the staff is flagging this item to inform the applicant that depending on the timing for submitting the application and a potential change in the Commission Policy affecting this regulatory area, the applicant may need to supplement its application to conform to the latest requirements.

12 3.9.5 50.55a COL Item 3.9.6 states: An applicant that references the NuScale Power Plant US460 standard design will develop a reactor Vessel Internals Reliability Program to address industry identified aging degradation mechanism issues. It appears that CFPP plans to address this COL item (i.e., develop the program) before the commercial operations start. The applicant needs to submit the program for the staff's review as part of the COLA.

13 3.9.5 50.55a COL 3.9-7 states: An applicant that references the NuScale Power Plant will provide a summary of reactor core support structure service level stresses, deformation, and cumulative usage factor values for each component and each operating condition in conformance with ASME BPV Code Section III, Subsection NG. It appears that CFPP plans to address this COL item before the fuel load. The applicant needs to complete the design stress report and provide it to the staff for review as part of the COLA.

14 2.3.4 GDC 19, 52.47a CFPP Section 2.3.4 states that site-specific short-term atmospheric dispersion estimates were made. The applicant needs to list the new site-specific dispersion values and provide the formatted site-specific meteorological data, inputs, and assumptions used to calculate those atmospheric dispersion values.

15 2.3.5 50.34a In Section 2.3.5 CFPP states that it calculated annual average atmospheric dispersion factors using the XOQDOQ model and lists the main input parameters in Table 2.3.5-201. The applicant needs to provide the site-specific meteorological data and the Joint Frequency Distributions formatted for use with the XOQDOQ model.

16 2.3.5 50.34a Section 2.3.5.2 states that there is only one year of validated site-specific meteorological data, from December 4, 2021, to December 3, 2022, to support the normal effluent dispersion and deposition assessment. The applicant needs to update the atmospheric dispersion analysis and the short-term dispersion analysis with the additional data from December 4, 2022, to December 3, 2023, and submit it with the COLA.

17 3.9.4 SRP 3.9.4 (area of review 4)

The COL Item 3.9-5 requires a summary of the testing program and a summary of the results. These need not be submitted at the same time - it may be beneficial to review the testing program early to allow for corrections of insufficiencies.

18 3.5.1.3 10 CFR Part 50, Appendix A, GDC 4 COL Item 3.5-1 states that this COL item will be replaced with The US460 standard design turbine parameters in Section 3.5.1.3.2 bound the site-specific turbine missile parameters." However, Section 3.5.1.3.2 only considers rotor and blade material, and the turbine rotor design, but does not consider the parameters for geometry and number of blades, the final design of the reactor building (RXB) exterior wall, and location of the turbines with respect to the RXB and Control Building specified as part of COL Item 3.5-1. Therefore, include these parameters as part of the evaluation of COL Item 3.5-1 to demonstrate the site-specific turbine missile parameters are bounded by the standard design analysis.

19 Part 5, Emergency Planning RG 1.242, Revision 0; NuScale DCA Section 6.4.4.6.5; and NuScale DCA FSER Chapter 6 (ML20205L406)

NuScale DCA FSER Chapter 6, Section 6.4.4.6.5, reads in part "Because the TSC is not served by the CRHS, for the case where the CRVS is not available or capable of providing acceptable air and pressurization, the TSC is uninhabitable and the TSC function is transferred to another location in accordance with the emergency plan." The draft COLA does not contain information that satisfies this NRCs FSER expectation. Emergency Plan II.H.2 in Technical Support Center is discussed. However, there is no mention of the need to establish an alternate TSC in the event the TSC becomes uninhabitable. Refer to RG 1.242 "C: Staff Regulatory Guidance Onsite Planning Activities #7d and Offsite Planning Activities #8e.

20 Part 04, Technical Specifications Introduction, Table 1-1:

Index to TS Annotations 52.79(a)(30); 50.36 pertaining to US460 COL Item 16.1-1, CFPP Chapter 16, and CFPP Part 04 TS Introduction COL Item 16.1-1 states, "An applicant that references the NuScale Power Plant US460 standard design will provide the final plant-specific information identified by [ ] in the generic Technical Specifications [GTS] and generic Technical Specification Bases." CFPP Part 4 - Technical Specifications Introduction (Table 1-1) addresses the "placeholder" information identified by brackets ("[ ]") in the US460 SDAA GTS and GTS Bases. NuScale SDAA GTS Bases page B 3.5.2-5 has bracketed information (related to SR 3.5.2.3) that does not appear to be presented in CFPP Table 1-1. The enumeration of individual instances of bracketed information may need review. The applicant needs to also review that the SDAA GTS Bases bracketed items are clearly included in an enumerated item that may encompass multiple instances of associated bracketed information.

21 Part 04 Technical, Specifications Introduction, Table 1-1:

Index to TS Annotations 52.79(a)(30); 50.36 pertaining to US460 COL Item 16.1-1 and COL 16.1-3, CFPP Chapter 16, and CFPP Part 04 TS Introduction NuScale US460 SDAA GTS Bases page B 3.3.1-58 has bracketed information that states, [Allocations for sensor response times may be obtained from records of test results, vendor test data, or vendor engineering specifications.]

Draft CFPP Part 4 (Table 1-1) description and justifications for page B 3.3.1-58 states in part, This requirement remains preliminary, to resolve after COL issuance. Plant-specific TS and Bases for a COL license may have no bracketed items of preliminary or pending information. In other words, the TS &

Bases must be usable upon COL issuance. The applicant needs to update Part 4 accordingly.

22 19.1.5 52.79(c)(1)

Draft COLA Section 19.1.5 addresses COL Item 19.1-7 and states that, Section 3.7, Seismic Design, describes the site-specific seismic results were not all frequencies for the US460 in-structure response spectra are bounded for the Control Building. A subsequent design analysis and PRA assessment have determined that this does not impact the site-specific PRA conclusions. Draft COLA Figures 3.7.2-215 and 216 show CFPP in-structure response spectra (ISRS) at a few CRB floors that are not fully bounded by those of the US460 SDAA. While the level of exceedance appears to be rather limited, the COLA needs to include justification about the impact of the exceedance in ISRS for the CRB floors and any other SSCs on the site-specific PRA and its insights, especially insights that are different from the SDAA FSAR.

23 19.1.5 52.79(c)(1)

The external hazards bounding screening criteria in the SDAA follows guidance in DC/COL-ISG-028. COLA Table 19.1-30R (External Events Screening Criteria) modifies the bounding external event screening criteria for a and b by eliminating the "less than 10% of the internal events mean CDF" term from the criteria. This elimination will constitute a deviation from the SDAA, and the COLA needs to provide a detailed technical justification for the deviation, including changes to the results of the screening.

24 19.1.5 and Table 19.1-31R 52.79(c)(1)

In Table 19.1-31R, the description for External Flooding points to an evaluation in 19.1.5.4 and the description for High Winds (Tornadoes and Hurricanes) points to an evaluation in 19.1.5.5. Neither of these sections includes information on the site-specific evaluation of the hazard and how it is bounded by the hazard assumed in the SDAA. SRP 19.0 states, where the DC included generic analysis of external events, the COLA may demonstrate that the relevant parameters of the generic analysis bound the corresponding site-specific parameters." The applicant needs to include the site-specific parameters in the COLA.

25 19.1 52.79(c)(1)

SDAA Section 19.1.5.1.1, "Seismic Risk Evaluation," states, "the seismic margin assessment (SMA) for the nuclear power module (NPM) is performed in accordance with NRC guidance from Section 19.0 of NUREG-0800, Revision 3 and the applicable SMA guidance in Part 5 of ASME/ANS RA-Sa-2009 as endorsed by Regulatory Guide 1.200." SRP 19.0 states, "DC/COL-ISG-020 discusses post-DC activities to update the PRA-based SMA throughout the licensing process of new reactors, including COL action items and post-licensing activities." Since DC/COL-ISG-20, not SRP 19.0, covers post-DC activities, the applicant needs to follow DC/COL-ISG-20 for the PRA-based SMA for the COLA in addition to SRP 19.0.

26 19.1 52.79(c)(1)

SRP 19.0 states that the NRC expects COL applicants to describe their approach for maintaining and periodically upgrading the PRA in accordance with RG 1.206 and RG 1.200. Also, the NRC staff should confirm that the PRA maintenance process provides that the PRA performed in support of a COL application be updated to reflect plant modifications if there are changes to the design during the design, construction, and operation of the facility. The applicant needs to provide information related to the maintenance and upgrade program, and PRA configuration control in the application.

Item Applicable Section(s)

Basis NRC Staffs Comments on FSAR 1

10.3.6.3.1 thru 10.3.6.3.7 Clarity on intended use in the COLA The term "repair" is used. Is there a distinction made in either the SDAA or COLA between the term "repair' vs. "rework" (i.e., definition of both)?

Is "repair" the correct term being invoked?

2 10.4.8 Completeness of information for an SDAA departure According to CFPP DEP 10.4-1 in Section 10.4.8, the FWTS also provides chemicals to the Auxiliary Boiler System (ABS). Provide drawings of the CFPP FWTS to show the main components and how the system interfaces with the ABS and CFS. In addition, CFPP should discuss the effects, if any, of this design change on US460 FSAR Figure 10.1-1.

3 10.3.6.3 Basis for susceptibility assessment Section 10.3.6.3 should specify the material, such as 1-1/4 Chromium-Molybdenum alloy steel, that will be used for the steam and feedwater system to assess the susceptibility of the piping and components.

4 10.3.6.3.6 Requirement for implementation of program The FAC program implementation schedule, including construction phase activities, should be included in Section 10.3.6.3.6 as an operational program consistent with SECY-05-0197, Review of Operational Programs in a Combined License Application and Generic Emergency Planning Inspection, Tests, Analyses, and Acceptance Criteria to verify the implementation of the program including preservice baseline examinations.

5 10 Site-specific information and considerations The SDAA only provides high-level and generic information about the ABS. The applicant should also provide site-specific, or interface information about the ABS that is not in the SDAA.

6 12.2.1.14 Description of radiation sources Section 12.2.1.14, Other Contained Sources, provides information on additional radiation sources for the CFPP facility. Section 12.2.1.14 states that the contained radioactive source material to be received, possessed, or used does not involve uranium hexafluoride in excess of 50 kilograms in a single container or 1000 kilograms total. The applicant cites these specific quantity limits of uranium hexafluoride as they are values associated with the potential need for an emergency plan in 10 CFR 40.31(j). However, the application should appropriately describe the types and quantities of radioactive material to be possessed.

Uranium hexafluoride is used in the enrichment process and normally does not normally have any purpose associated with reactor operation.

If uranium hexafluoride is to be used by CFPP, the use of uranium hexafluoride should be described in the application and its intended use should be evaluated against applicable requirements. Alternatively, Section 12.2.1.14 should be revised to clarify that CFPP will not be receiving, possessing, or using uranium hexafluoride.

7 17.6 RG 1.160, Revision 4 The draft COLA Section 17.6 states implementation of the Maintenance Rule Program will be consistent with RG 1.160 and that RG references in NEI 07-02A will be updated to FSAR Chapter 1.9 versions.

NEI 07-2A, Revision 0 (corrected), November 2010, references RG 1.160, Revision 2. The current, endorsed RG 1.160 is Revision 4 (ML18220B281). Additional limitations and conditions are contained in the Revision 4 version as compared to the Revision 2 version.

NEI 07-2A, Revision 0 (corrected), November 2010, Section 17.X.6, Reference 3 will need to be updated to the current RG 1.160 Revision 4, if used.

8 17.6 RG 1.160, Revision 4 The NEI 07-2A, Revision 0 (corrected), November 2010, references NUMARC 93-01, Revision 2. Current RG 1.160, Revision 4 (ML18220B281) endorses NUMARC 93-01, Revision 4F (ML18120A069). The information in the first paragraph of NEI 07-2A, Revision (corrected), November 2010, Section 17.X.1, became obsolete with the current endorsed versions of RG 1.160 and NUMARC 93-01.

The referenced RG 1.182 has been withdrawn and is no longer in effect (see Federal Register Vol. 77, No. 228, November 27, 2012, 70846-70847). NEI 07-2A, Revision 0 (corrected), November 2010, Section 17.X.6, Reference 5, will need to be deleted since RG 1.182 has been withdrawn. Section 17.X.6, Reference 4 is now the same reference as Reference 2.

9 17.6 RG 1.160, Revision 4 NEI 07-2A, Revision 0 (corrected), November 2010, references NUMARC 93-01, Revision 2. Current RG 1.160, Revision 4 (ML18220B281) endorses NUMARC 93-01, Revision 4F (ML18120A069). Additional guidance is contained in the Revision 4F version as compared to the Revision 2 version. NEI 07-2A, Revision 0 (corrected), November 2010, Section 17.X.6, Reference 2 will need to be updated to the current NUMARC 93-01 Revision 4F, if used.

10 17.6 RG 1.206, Revision 1 NEI 07-2A, Revision 0 (corrected), November 2010, Section 17.X.6, Reference 6, RG 1.206, Revision 0. RG 1.206 has been revised to Revision 1 (ML18131A181).

11 17.6 NRC SER endorsing NEI 07-02A, Rev. 0, March 2008 ML080910149/ML103410542 NEI 07-2A, Revision 0 (corrected), November 2010, Section 17.X.1.1.b, references FSAR Section 17.Y. This reference will need to be updated to match the COLA FSAR.

12 6.3 GDC 27 The US460 design added the ECCS supplemental boron system (ESB).

CFPP COLA needs to provide the description or elements of a procedure for loading the boron oxide pellets into the dissolver baskets in the application. Additionally, any design aspect of the ESB that is not addressed as part of the SDAA review, must be addressed by the CFPP.

13 17.5 SRP 17.5 The 17.5 section states that "at time of submission, it does not describe the controls for operational programs." The applicant should clarify if this statement is referring to the CFPP QAPD and to the operations phase instead of operational program.

14 6.2.5 10 CFR 50.44(c)

The US460 design added a passive autocatalytic recombiner (PAR) to the design as described in Section 6.2.5, Combustible Gas Control.

CFPP will need to address any design aspects of the PAR that are not resolved through the SDAA review.

15 9 and 14 Associated GDC Chapters 9 and 14 incorporate by reference the SDAA. Therefore, the review of those areas for the COLA will rely on the staff review of the SDAA.

16 13.7, 3rd paragraph Clarification CFPP stated that the FFD program would be consistent with NEI 06-06 as endorsed by the NRC in RG 5.84. Does CFPP intend to commit to RG 5.84, Revision 0, July 2015, which endorsed NEI 06-06, Revision 6, April 2013?

17 13.7, 2nd bullet CFPP statement would require an exemption from 10 CFR 26.4.

CFPP stated that "Construction workers and first line supervisors are covered by the construction FFD program (elements Subpart K), except when escorted by a construction escort." 10 CFR 26.4 and the requirements in Subpart K do not allow licensees and other entities to escort the two categories of individuals identified by CFPP. Does CFPP desire to seek an exemption from 10 CFR 26.4(f)? Vogtle Units 3 and 4 implemented a similar provision, which required an exemption that was issued on June 12, 2019 (Federal Register Notice 84 FR 27364).

18 13.7, 3rd bullet Clarification CFPP stated that "Personnel contracted for construction management and oversight are covered by the construction FFD program (elements Subparts A - H, N and O)." Would licensee employees (i.e.,

management and oversight (QA?)) also be covered?

19 13.7, 7th bullet, and 13.4-201, Item 15(i)

Clarification Draft CFPP COLA stated in Section 13.7, 7th bullet, that "Personnel required to physically report to the Technical Support Center when that requirement is in effect are covered by the operational FFD Program (elements Subparts A - I, N, and O, except 10 CFR 26.205 - 209)."

Confirm that there is no Emergency Operations Facility (same question for Table 13.4-201, Item 15(i)).

20 6.4 RG 1.78 COL 6.4-1 states in part, "There are no off-site chemical hazards that pose an impact to control room habitability." Without a staff review of the Chapter 2 CFPP site characteristics, this statement has no value.

Suggest modifying the wording to tie this conclusion back to the CFPP SAR Chapter 2 site characteristics review.

21 9.3.2.1 Clarification The first sentence of Section 9.3.2.1 states, "the initial testing of systems outside containment that contain (or might contain) accident source terms following an accident are addressed in Section 14.2." It is unclear what systems and/or tests are being referred to?

22 13.6.4 Clarification Section 13.6.4 References includes the following:

"13.6-201 Nuclear Energy Institute, Nuclear Power Plant Access Authorization," the staff notes that NEI 03-01, Revision 4, June 2014. NEI 03-01, Revision 4, June 2014, is not the current NRC-endorsed version of NEI 03-01. RG 5.66, Access Authorization Program for Nuclear Power Plants, endorsed NEI 03-01, Revision 3, May 2009. (ML112060028). The staff notes that NEI rescinded the request for NRC endorsement of NEI 03-01, Revision 4, in a letter to the NRC dated July 25, 2019 (ML19266A446). Does CFPP seek to reference the NRC-endorsed version of NEI 03-01?

23 5.3 GDC 14, 15, 31 SDAA Section 5.3.2.1 notes that the pressure-temperature limits in the application do not include location correction or instrument uncertainty.

These should be accounted for when addressing COL Item 5.3-1.

24 5.4.1.6 GDC 32 The following elements of the Steam Generator Program in response to COL Item 5.4-1 do not reference corresponding FSAR section numbers:

Loose parts management, Contractor oversight, Self-assessment, and Reporting. Discuss where and how these program elements are addressed in the FSAR.

25 5.4.1.6 GDC 32 The response to COL Item 5.4-1 references FSAR Section 6.3, Emergency Core Cooling System, for the foreign material exclusion element of the Steam Generator Program. The staff notes that COL Item 6.3-1 covers foreign material exclusion controls for the containment. Discuss why FSAR Section 6.3 was referenced for the foreign material exclusion element of the Steam Generator Program.

26 5.4.1.6 GDC 32 The response to COL Item 5.4-1 in FSAR Section 5.4.1.6 states, The SG program development, scope, and implementation follow relevant guidance within the Electric Power Research Institute SG guidelines (Reference 5.4-201) and revision 3 of the Nuclear Energy Institute NEI 97-06 (Reference 5.4-1). However, COL Item 5.4-1 in FSAR Section 5.4.1.6 in the SDAA states, The Steam Generator Program will be based on the latest revision of Nuclear Energy Institute NEI 97-06, "Steam Generator Program Guidelines," and applicable Electric Power Research Institute steam generator guidelines at the time of the application. The response to COL Item 5.4-1 states follow relevant guidance while COL Item 5.4-1 in the SDAA states based on. It is unclear whether follow relevant guidance means some guidance in NEI 97-06 and the EPRI guidelines will not be followed. Therefore, clarification is needed on the wording follow relevant guidance in this context.

The staff notes that FSAR Section 5.4 does not identify or provide justification for portions of NEI 97-06 or the EPRI guidelines that will not be followed. In addition, the response to COL Item 5.4-1 references only the SG EPRI SG Examination Guidelines (Reference 5.4-201), while COL Item 5.4-1 in the SDAA does not reference a specific EPRI SG guideline. The staff notes that EPRI SG guidelines other than the Examination Guidelines are applicable to the Steam Generator Program, as indicated in COL Item 5.4-1. Therefore, CFPP needs to describe why only the EPRI SG Examination Guidelines are referenced in response to COL Item 5.4-1.

27 5.4.1.6 GDC 32 The applicants response to COL Item 5.4-1 lists elements of the Steam Generator Program with a corresponding FSAR section number (e.g.,

Assessment of degradation (Section 5.4)). The staff notes that these numbers refer to sections with numerous pages and subsections, so it can be difficult to find the information. It would be helpful to provide the most specific section number appropriate for the topic (e.g., Section 10.3.5 instead of 10.3 for primary and secondary water chemistry control). (2) Tube integrity assessment does not reference FSAR Section 5.2, which addresses reactor coolant boundary integrity. (3)

Primary and secondary side water chemistry does not reference FSAR Sections 10.4.5 and 10.4.8, which address condensate polisher skid and resign regeneration system and the feedwater treatment system.

28 Chapter 13 10 CFR 50.55a Table 13.4-201, Operational Programs Required by Nuclear Regulatory Commission Regulations, addresses COL Item 13.4-1. This table references FSAR Sections 5.4.1.1 and 5.4.1.6 for the SG ISI and FSAR Section 5.4.1.4 for the SG PSI. The staff notes that FSAR Sections 5.4.1.2 and 5.4.1.4 in the SDAA also address SG ISI and FSAR Section 5.4.1.1 in the SDAA also addresses SG PSI; however, these sections are not referenced in Table 13.4-201. In addition, the staff notes that FSAR Section 5.4 does not reference Table 13.4-201 for the SG PSI and ISI operational programs.

29 14.3.5.3.1 10 CFR 52.97(b)

Section 14.3.5.3.1 identifies requirements of 10 CFR 73.55 that are considered top-level design features and those that are not considered top-level design features. Clarify if the applicant intends to provide a site-specific ITAAC for design features that are not considered top-level.

30 9.1.1 10 CFR 50.68; GDC 2; GDC 62 Where does CFPP plan to address the seismic response of the fuel when in the operating bay, refueling flange tool, and spent fuel racks?

31 9.1.1 10 CFR 50.68; GDC 62 Does CFPP intend to incorporate by reference the Spent Fuel Pool Storage Rack Analysis Topical Report, TR-145417?

32 13.2 10 CFR 50.54(m)

Clarification is needed regarding CFPP plan to seek exemption from 50.54m. CFPP COLA points to a topical report and not the SDA. The staff seeks to understand if (1) a future COL holder can use the justification provided in the SDA as the basis for an exemption from 50.54(m), or (2) a future COL holder can use the topical report as the basis for the exemption.

33 18 question The changes that staff sees in C.18 imply that there will not be an EOF.

Was the EOF from the SDAA removed in the COLA?

34 18 question Will any Human Factors element RSRs be provided with the COLA?

35 Chapters 3, 5, 7, 15 comment The staff is currently reviewing the potential for DWO as part of the NuScale SDAA. Any design and analysis aspects related to the potential for DWO that are not resolved through the SDAA review or are within the scope of the COLA, including but not limited to control system design, will need to be incorporated into the COL FSAR.

36 Section 2.1.1 10 CFR Part 100.3 and 100.20(b)

Section 2.1.1 does not contain a site area map with reactor and associated plant structures to determine distance to exclusion area, etc.

Provide this information, or a map, based on the CALC package showing the details of Exclusion Area Boundary (EAB) and Low Population Zone (LPZ).

37 Section 2.1.3 10 CFR Part 100.20 and 100.21 Provide the projected population at the start of operation of the first module and at 10 years interval.

38 Sections 2.2.1-2.2.2 10 CFR Part 100.20 Provide the CALC package for aircraft hazard assessment from all potential sources giving details of the assumptions made, data used, and the results. The assessment must consider the effects of both impact and fire associated with an aircraft crash. In addition, the assessment must contain the details to estimate the core damage frequency and likelihood of radiological release. NUREG-0800, Section 3.5.1.6 states that the annual aircraft crash hazard is the cumulative from all sources, not only General Aviation aircraft and therefore the NuScale annual aircraft crash hazard shall include the cumulative from all sources.

39 2.2.1 10 CFR Part 100.20 Figure 2.2-201 does not provide airway information for Airway V269.

This Airway is identified in the "Identification of Hazards in Site Vicinity" within 1 mile of the CFPP site as a "Hazard Source.

40 2.2.3 10 CFR Part 100.20 Provide the CALC package for: (1) hydrocarbon explosion(s) nearby and (2) propane truck and tank explosion(s) taking into consideration dispersion of propane given the local worst-case atmospheric conditions. Provide to the NRC staff early in the audit after application submission and acceptance the CALC package giving details of the control room habitability assessment and natural fires.

41 3.7.1.1.3.2.1 10 CFR Part 50, Appendix A, GDC 2 Chi-Chi earthquake is MMS 7.6, not 6.2.

42 3.7.1.1.3.2.3 10 CFR Part 50, Appendix A, GDC 2 Table 3.7.1-203 gives correlation coefficient for FIRS compatible time histories, not GMRS-compatible.

43 3.7.1.3.3 10 CFR Part 50, Appendix A, GDC 2 Table 3.7.1-210 gives shear wave velocity, damping, and unit weight; not shear wave velocity, unit weight, and Poisson's ratio.

44 3.7.2 10 CFR Part 50, Appendix A, GDC 2 The applicant will need to provide the ISRS analysis package and harmonic analysis package from which the description has been extracted.

45 3.7.2.5.2 10 CFR Part 50, Appendix A, GDC 2 Describe how the probabilistic seismic hazard analysis accounts for the effects of non-vertically propagating seismic waves.

46 3.7.2.8 10 CFR Part 50, Appendix A, GDC 2 Explain why seismic Category I portion of the RXB would not be affected by the collapse of the RWB during Safe Shutdown Earthquake.

47 3.7.2.16.1 10 CFR Part 50, Appendix A, GDC 2 Clarify Figures 3.7.2-202 and others, e.g., proper labeling, description of different representation, etc. to be meaningful and usable. Describe the results of harmonic analysis with appropriate figures.

48 3.7.2.16.1.1 10 CFR Part 50, Appendix A, GDC 2 Describe the scenario with appropriate figures for each case analyzed and discuss under what circumstances the results would be appropriate to use in structural design.

49 3.7.2.16.1.1 10 CFR Part 50, Appendix A, GDC 2 Describe details of the model used in each scenario and discuss how the results would be used in structural design.

50 3.7.2.16.1.1 10 CFR Part 50, Appendix A, GDC 2 Describe the methodology used including appropriate references to material properties and structural damping. Describe the codes and standards used/referred to select the property values.

51 3.7.2.16.1.1 10 CFR Part 50, Appendix A, GDC 2 Describe how the rock bolts would be used to support the excavation walls and how it was modeled in the Double Building model. Label the rock bolts in Figures 3.7.2-204 and 205.

52 3.7.2.16.1.1 10 CFR Part 50, Appendix A, GDC 2 Discuss the scenario in soil separation case. Describe how the interaction between the RXB and the surrounding but separated engineered backfill has been accounted for.

53 3.7.2.16.1.1 10 CFR Part 50, Appendix A, GDC 2 Describe whether any of the walls are constructed of steel-plated concrete (SC), and if, yes, include the material properties used in the analysis.

54 3.7.2.16.1.1 10 CFR Part 50, Appendix A, GDC 2 Describe how the properties of the controlled low-strength material (CLSM) were generated, as given in Table 3.7.2-201. It is not clear how the Poisson's ration 0.31 is related to the CLSM properties.

55 3.7.2.16.1.1 10 CFR Part 50, Appendix A, GDC 2 There is no discussion on the effective modal mass participation versus frequency of the Double Building model in each case analyzed.

56 3.7.2.16.1.1 10 CFR Part 50, Appendix A, GDC 2 There is no discussion of seismic gap among the RXB, RWB, and CRB buildings.

57 3.7.2.16.1.2 10 CFR Part 50, Appendix A, GDC 2 Explain what is meant by " soil libraries have an excavation depth of 6.56 ft "

58 3.7.2.16.2 10 CFR Part 50, Appendix A, GDC 2 Explain in Figure 3.7.2-209 the significance of three elevation of RXB Floor. Never discussed a RXB elevation of EL 126 ft before.

59 3.7.2.16.3 10 CFR Part 50, Appendix A, GDC 2 Describe how the In-Structure Response Spectra was assessed including design of a particular structural member.

60 3.7.2.16.3 10 CFR Part 50, Appendix A, GDC 2 Figure 3.7.2-214 does not show the rock bolts.

61 3.7.2.16.3 10 CFR Part 50, Appendix A, GDC 2 What is hybrid CRB model? How the properties of the structural members (both uncracked and cracked) in this model were determined?

Explain whether a structural member is cracked or not is determined?

62 3.8.5.3.3 10 CFR Part 50, Appendix A, GDC 2 Model description is missing.

63 3.8.5.3.3 10 CFR Part 50, Appendix A, GDC 2 Discuss how local stiff and soft points on the foundation soil will be identified and accounted for.

64 3.8.5.5.2.2 10 CFR Part 50, Appendix A, GDC 2 CFPP needs to provide the analysis package for NRC review.

65 3.8.5.5.2.2 10 CFR Part 50, Appendix A, GDC 2 Describe what is/are the transient load(s) analyzed.

66 3.8.5.5.2.2 10 CFR Part 50, Appendix A, GDC 2 Describe the model along with the material properties and assumptions taken.

67 3.8.5.5.2.2 10 CFR Part 50, Appendix A, GDC 2 Describe why under Factor of Safety FOS<1, the CRB design would still be acceptable.

68 3.2 50.55a, GDC 1 Section 3.2 is incorporated by reference. Are there any site-specific SSCs that are not included in the incorporated content?

69 3.6 52.80(a)

COL Item 3.6-1 references ITAAC 2.1-1, Item 4 for the reconciliation for pipe rupture hazards analysis for piping outside the reactor pool bay in the RXB. This ITAAC is NPM-specific. Would it be more appropriate to consider ITAAC #8 in Table 3.11-1 as a reference?

70 CFPP Part 4 Technical Specifications Introduction 52.79(a)(30); 50.36 pertaining to COL Item 16.1-1, CFPP Chapter 16, and CFPP Part 04 TS Introduction CFPP Part 4, Technical Specifications Introduction, Table 1-1 (top entry on page 6 of 7) lists OI-0116 in the left column with no apparent discussion about what this identifier means. CFPP needs to describe OI-0116.

71 CFPP Part 5 Emergency Plan 50.160(b)(3), Emergency Planning ZonesSection I.C.2, Emergency Planning Zone, states that the CFPP facilitys EPZ will be entirely within the CFPP facility boundary. Figure I.A-1, CFPP Facility Map, does not clearly identify what is considered the CFPP facility boundary. Provide (1) the definition of CFPP facility boundary, and (2) graphical display and figure symbol identification of CFPP facility boundary. Additionally, ensure "CFPP facility boundary" definition is consistent throughout all COL application descriptions and figures.

72 11.2.1 20.1301, 20.1302 and 50.34a(d)

In Section 11.2.1, the applicant states that 20.1301, 20.1302, Part 20 Appendix B, Part 50, Appendix I and 40 CFR 190 will not apply to the LRWS because the LRWS does not discharge effluent to the environment. The regulations above do not apply to systems but to the conduct of licensee operations and thus are always applicable.

Therefore, Clarify if the applicant intends to pursue exemption from the abovementioned regulations. If an exemption is not sought, Clarify the language. For example, if the applicant does not expect to emit liquid effluents during operations; State explicitly in the application that the contribution of liquid effluents to public doses is expected to be little to none.

73 11.2.2 and re-numbered 11.2.2.5 50.34a(d)

In Section 11.2.2 - the applicant states that they intend to replace the last para of SDAA Section 11.2.2 with the following, "Section 11.2.2.5 describes how the LRWS wastewater is treated before recycling within the plant." SDAA Section 11.2.2.4 - Detergent Waste Subsystem was renumbered as CFPP Section 11.2.2.5. SDAA Section 11.2.2.4 does not provide a full description of how LRWS wastewater is treated. Also, SDAA Section 11.2.2.4 refers to discharges (e.g., wastes are then discharged through a cartridge filter if the sample results indicate that...

requirements are met.) Clarify if this discharge is offsite.

74 11.2.2.3 50.34a(d)

Section 11.2.2.3 refers to discharging liquid effluents, should this be removed to be consistent with other references to liquid discharge?

75 11.2.2.5 50.34a(d)

Is the intent to add the text that references Table 11.2-2R? (other sections have said that the following text will be added to the section).

76 11.3.3.1 50.34a(d)

Not clear where Table 2.0-203 is located. Per COL Item 11.3-3, the COL applicant will perform an analysis in accordance with BTP 11-5 using site specific parameters. The applicant needs to provide such an analysis (i.e., inputs, assumptions, description of model and results) per the COL item.

77 Section 19.4.2 and Table 19.1-31R 52.79(c)(1)

The COLA should evaluate the Volcanic Hazards Assessment once it's complete and include any mitigating SSCs and key assumptions in the PRA and the description of PRA. Mitigating SSCs should also be evaluated for inclusion in D-RAP.

78 19.1 52.79(c)(1)

In Table 19.1-31R, for the Aircraft Impact Hazard, the description of the screening criteria includes the statement that at least two trains of mitigating systems are available to prevent core damage. Because an aircraft crash can damage multiple trains of mitigating systems, the applicant should provide additional context for this screening criterion justifying its applicability to aircraft impact.

79 17.4 SECY-95-132 SRP 17.4 states that "the application should propose a process for integrating the RAP into operational programs" and the application should cite the specific sections or chapters of the application where applicable operational programs are described." Further, the SRP states, "one acceptable method for integrating the RAP into operational programs is by implementation of the following operational programs:

(1) maintenance rule program consistent with RG 1.160, with all RAP SSCs being included in the scope of maintenance rule and categorized as HSS, (2) QA program for safety-related SSCs established through Appendix B to 10 CFR Part 50 requirements, (3) QA controls for non-safety-related RAP SSCs established in accordance with Part V of SRP Section 17.5 and (4) inservice inspection, inservice testing, surveillance testing, and maintenance programs for the RAP SSCs to maintain equipment performance consistent with risk insights and key assumptions and to address dominant failure modes. The COL application should describe the programs that are used to integrate the RAP into operational programs, such as the quality assurance program, inservice testing, surveillance testing, etc.

80 19.1.5 STD COL 19.1-7 52.79(c)(1)

NuScale SDAA Table 19.1-21 includes a key assumption for site-specific and soil dependent seismic hazards. This assumption is a component of COL Item 19.1-7: An applicant that references the NuScale Power Plant US460 standard design will evaluate site-specific external event hazards (e.g., liquefaction, slope failure), screen those for risk-significance, and evaluate the risk associated with external hazards that are not bounded by the standard design. There is no discussion of the analysis (or a pointer to Chapter 3 with the analysis) that concludes that the site-specific design meets the seismic requirements of 167% for sliding and overturning. The inclusion of landslides in Table 19.1-31R addresses slope failure. There is no mention of liquefaction in Table 19.1-31R.

81 19.1 52.79(c)(1)

Address whether the PRA supports any regulatory oversight processes (e.g., the Mitigating Systems Performance Index (MSPI) and the significance determination process (SDP)). These examples were provided in Revision 0 of RG 1.206.

82 19.1.5 and Table 19.1-31R 52.79(c)(1)

Section 16 (Industrial or military facility accident), Section 25 (Release of chemicals from onsite storage), Section 33 (Toxic gas release),

Section 34 (Transportation accidents), Section 39 (Grass fires), and Section 44 (Radiation) say that these could result in control room habitability concerns, but screens them out because they cant cause a reactor trip nor affect any SSC credited for safe shutdown. These external events dont expand on the control room habitability issue so there needs to be more detail on how these events don't affect control room habitability.

83 19.1.5 and Table 19.1-31R 52.79(c)(1)

Section 31 (Soil shrink or swell) discusses clay expansion and contraction due to changes in moisture content, but says that it does not result in plant trip or affect any SSC credited for safe shutdown. There needs to be more detail on why clay expansion and contraction would not affect the site.

84 19.1.5 and Table 19.1-31R 52.79(c)(1)

Section 41 discusses sinkholes, but says that it does not result in plant trip or affect any SSC credited for safe shutdown rather than the likelihood of the event and if it were to occur at the plant that there would be SSCs affected, or a reactor trip so there needs to be more detail on this event.

85 19.2.6.7 52.79(c)(1)

Regarding the first sentence in Section 19.2.6.7, it is not clear why information should be added to SDAA 19.2.6.7 regarding CCFP site-specific evaluations as stated in COLA Section 19.2.6.7.

86 5.2.6, 5.4.6 GDC 32 The staff noted an apparent discrepancy in the references in COLA Chapter 5. According to STD COL 5.4-1, Reference 5.4-2, Revision 7 (2007) of the EPRI PWR Steam Generator Examination Guidelines, was deleted. As part of COL 5.4-1, Reference 5.4-201 was added, referencing Revision 8 (2016) of the same guidelines. However, since there are not corresponding changes in COLA Section 5.2, Reference 5.2-7 references Revision 7 of the guidelines. Consequently, COLA Sections 5.2 and 5.4 reference different revisions of the Steam Generator Examination Guidelines.

87 10.4.8 GDC 14 COL Item 10.4-1 states, An applicant that references the NuScale Power Plant US460 standard design will provide a secondary water chemistry analysis. This analysis must show that the size, materials, and capacity of the feedwater treatment system equipment and components satisfies the water quality requirements of the Secondary Water Chemistry Control Program described in Section 10.3.5, and it is compatible with the chemicals used. (emphasis added). The COLA addresses COL 10.4-1 with a paragraph containing statements about the secondary water chemistry analyses, such as, A hydraulic and equipment sizing analysis demonstrates. A metallurgical analysis specifies The COLA does not appear to provide a secondary water chemistry analysis as described in the SDAA COL 10.4-1. The staff needs this information to review the size, materials, capacity, and chemical compatibility as they relate to the system meeting the secondary water chemistry requirements.

88 19.1 52.79(c)(1)

In Section, 19.1.1.3.1, Use of PRA in support of programs, and in Section 19.1.1.3.2, Risk Informed Applications, it is not clear what the Construction Phase means. Clarify whether CFPP means Combined License Applicant or not until fuel load?

89 19 52.79(c)(2)

CFPP draft COLA states that the COLA will use Revision 1 of the SDAA FSAR for Items in Chapter 19 not currently in the SDAA FSAR. The staff notes that in accordance with 10CFR52.79(C)(2), CFPP COLA must demonstrate that all terms and conditions that have been included in the design approval will be satisfied by the date of issuance of the combined license.

90 3.11 50.49 COL Item 3.11-1 states that the applicant will submit milestones and completion dates for program implementation. However, the resolution of COL Item 3.11-1 does not include any milestones or completion dates and is addressed in the resolution of COL Item 3.11-3. For COL Item 3.11-3, it states that Table 13.4-201 establishes the milestones for the implementation of the environmental qualification program. The applicant should address the milestones for program implementation in COL Item 3.11-3 for completeness and clarity.

91 18.5.1 STD COL 18.5-1/SRP 13.1.2 operating organization The COLA addresses non licensed operator minimum staffing as a "recommendation" ("minimum staff size of three is recommended for operation"). The staff is not familiar with how to treat recommendations in FSARs. Chapter 13.1 is not available during the readiness assessment to understand staffing numbers.

92 3.9.6.3.2 10 CFR 50.55a Draft CFPP COLA FSAR (page 3.9-4) removes the current language in COL Item 3.9-10, and includes a new paragraph that references Appendix IV to the ASME OM Code for test procedures to monitor the performance of ECCS valves. The new paragraph states that Table 3.9-17 identifies ECCS valves needing a "deferred" valve test. The reference to a deferred valve test should be clarified. With additional provisions described in Section 3.9.6.4.4, the NuScale SDAA FSAR specifies that the ASME OM Code, Appendix IV, as incorporated by reference in 10 CFR 50.55a, will be used for ECCS valve testing, including the determination of appropriate diagnostic test intervals based on the evaluation of valve test data and margin within the maximum performance assessment test interval allowed in Appendix IV.

93 19.1 52.79(c)(1)

There is no discussion in the draft FSAR Section 19.1 whether risk-significant SSCs in the scope of the D-RAP program are scoped into the Maintenance Rule program.

NRC Staffs Observation of CFPPs Environmental Report Item Applicable Section(s)

Regulatory Basis NRC Staffs Observations on Environmental Report 1

5.3 ESRP 5.6.1 On page 5.3-8, there is a high-level description of vegetation maintenance activities, but no details are provided, or references cited.

In addition, there is no mention of monitoring or controlling for invasives.

2 5.3 ESRP 5.6.1 There is some discussion of sage-grouse and little brown myotis conservation efforts, but details are not provided regarding USFWS management requirements for these species. What species will not be monitored and why?

3 5.8.2 ESRP 5.3.4 The text has discussion of the ACCS and the Site Cooling Water System (SCWS), but Table 5.8-203 also includes a line item for air cooled condenser fan, and it is unclear if this fan is part of the ACCS or a separate system. Recommend clarifying to enhance consistency between the text and table.

4 5.6.1 ESRP 5.1.3 36 CFR 800 The COL references that same 2325-acre APE that is listed in the LWA ER but does not appear to include the transmission line as previously indicated.

5 5.6.1 ESRP 5.1.3 36 CFR 800 Regarding the use of the LWA information, if the APE is the red polygon, what additional steps will be taken to identify historic properties in the areas not covered by previous surveys? When could we expect results from field investigations?

6 5.6.1.2 ESRP 5.1.3 36 CFR 800 The section does not provide impact assessments to the historic buildings mentioned. Describe what the potential impacts of the undertaking would be to the historic buildings.

7 5.6 ESRP 5.1.3 36 CFR 800 There is no discussion of training for workers and visitors related to cultural resources. Provide this information.

8 5.4.3.1 ESRP 5.4.3 Key impact modeling is still pending. An input-output model is expected to model the effects of operations activities on local employment and income and needs to be provided. Are the costs listed in Section 10.6.2 same as annual operational expenditures?

9 5.4.3.2 ESRP 5.4.3 Discussion of the tax consequences of operations activities of the proposed project is still pending but needs to be provided.

10 5.4.4.3 ESRP 5.4.4 There is no discussion about whether the in-migrating workforce would create upward pressure on the price of housing for the public.

11 3.2/3.4 ESRP 3.3.1 A water balance flow diagram is provided in COL ER Figure 3.4-201 for average plant water uses (all uses). Diagram/narrative does not provide maximum water use; any effects on water use from low water availability (e.g., whether water withdrawals are subject to curtailment in the event of a water rights call); average operational water use by month; and water use by operating mode/status. Production well locations and pond locations have placeholders for figures, but these are not currently (October 16, 2023) in the COL ER. Final COL ER should provide additional information.

12 3.2/3.4 ESRP 3.4.1 Operational mode information for the cooling system is not provided.

Final COL ER should provide additional information.

13 4.2 ESRP 4.2 No additional construction impacts for COL (beyond those identified in the LWA ER). Confirm whether that is the case. COL ER should refer to LWA ER for construction related information/impacts.

14 5.2 ESRP 5.2.1 Plant water use by operational mode not provided. Potential limitations on water use during low water availability periods not discussed, if relevant. Water rights not defined, including whether there are any potential legal limitations on water use, e.g., during low water availability periods. Final COL ER should provide additional information or provide a statement regarding status.

15 5.2 ESRP 5.2.2 Physical effects of groundwater use are stated qualitatively in COL ER 5.2.2.2. Technical basis for these alteration estimates not provided.

Water rights and potential groundwater use restrictions (e.g., during periods of low water availability) are not described. ESPA Groundwater Management Area designation not discussed for any potential impacts on water use. Final COL ER should provide the needed information.

16 5.2 ESRP 5.5.1 Confirm applicable permits for sanitary wastewater pond and requirements for construction/monitoring for NZLD ponds. Final COL ER should provide additional information.

17 5.2.1.2 ESRP 5.2.1 NZLD evaporation ponds are not clearly explained (or defined). A brief definition of NZLD evaporation ponds would be helpful.

18 5.2.1.2 ESRP 5.2.1 In the first paragraph, it mentions two stormwater retention ponds. In the following paragraph, it mentions stormwater detention ponds. In Section 3.2.5.1, they are again mentioned as detention ponds. Which one is correct? From the description, it's not clear whether they are retention or detention ponds. A confirmation is needed.

19 3.2.4.2 ESRP 5.2.1, 3.3.1 CFPP average water supply flow rate is mentioned to be 225 gpm in Section 3.2.4.2. In Section 5.2, it is mentioned to be 222 gpm. Which one is correct? A confirmation on the average water supply flowrate is needed.

20 5.11.1.1 ESRP 7.1 ESRP states to compare to SSAR/FSAR for EAB and LPZ consistency.

Obtaining the FSAR or SSAR is required to confirm this, and this is likely to be available by the ER submittal.

21 5.9 &

5.11.1 ESRP 5.4.2 ESRP 7.1 ESRP discusses meteorology that is not currently available for review.

Meteorological Data used for analysis is expected to be submitted as part of a complete ER.

22 5.11.2 ESRP 7.1/

RG 1.183 Calculation of dose discusses breathing rate but does not discuss changes in breathing rate.

23 ESRP 7.2 Cross-listed areas of meteorology, socioeconomics, land use, and hydrology, appear sufficient but additional sections are unavailable for review.

24 5.11.3 ESRP 7.2 Core damage frequencies are listed as having a low probability. Issue should be coordinated with Chapter 19 of the FSAR and verified in the final ER.

25 5.11.2 ESRP 7.2 There is no table of the severe accident source terms (i.e., the radionuclides released and quantities) being applied for the CFPP severe accident MACCS calculation. Provide in the ER or provide a referral to an FSAR section for this information.

26 5.11.2.2 ESRP 7.2 Provide whether the source term for RC 2b (RXB failure) is the same as for RC 2a (RXB intact).

27 5.11 ESRP 7.2 Is the appropriate reference for the release frequencies in ER Table 5.11-6 FSAR Chapter 19? If so, it needs provided.

28 5.11.3.2.5 ESRP 7.3 What is the rational for including both the US460 and CFPP SAMDA discussions in the COLA ER?

29 5.11.3.3.4 ESRP 7.3 Discuss whether values are reasonable to be used for all SAMDAs (*I.e.,

correcting in a control system to prevent human errors of co-mission) and provide a reference for given values.

30 5.11.3.2.2; 5.11.3.3.2 ESRP 7.3 A number of SAMDAs are screened out in Table 5.11.9 as Not applicable to the combined license application. However, there are several reasons for such a screening and no specific rationale is give in Table 5.11.9 when this screening criteria is applied. One such reason is design elements that are to be finalized in a later stage of the design process are outside of the scope of this analysis. This is especially important for SAMDA 197, Automate the NPM transport process to the extent permitted by the reactor building crane control system design for reduction in operator errors of Commission during NPM transport associated with the RXB crane. Without an appropriate SAMDA 197 with associated implementation cost, an environmental finding cannot be reached on SAMDAs for CFPP without consideration of a design alternative for addressing RXB crane errors of human Commission.

31 5.11.3.2.2; 5.11.3.3.2 ESRP 7.3 A number of SAMDAs are screened out in Table 5.11-9 as Excessive implementation cost. However, no SAMDA-specific cost value is provided for the staff to agree or allow the staff to disagree. This needs to be provided.

32 5.9 ESRP 5.4.1 The radial diagram of the area that is referenced in COLA ER Section 5.9.2.2. needs to be provided.

33 5.9 ESRP 5.4.1 A statement is needed regarding nearest known locations of and transit (or lack of transit) times of discharge for:

Drinking water Aquatic food Future shoreline 34 5.9 ESRP 5.4.2 ESRP 5.4.3 On the table of radial doses out to 50 m, summary MEI tables are listed, but more specificity may be needed.

35 5.9 ESRP 5.4.2 General comments are made that address or redirect to future drinking intakes, irrigation rates, and commercial fishing/invertebrates, unusual animals/plants/ag practices in relation to liquid effluents and recreational waters. A blanket statement of no release may not be sufficient with a coolant pond and evaporation system.

36 5.9 ESRP 5.4 Since tritium in the form of TOH has been a component of LWR liquid discharges, it is expected that tritium would be in the evaporated water from this evaporation system.

How does this add to the gaseous effluent quantity released annually?

To the surrounding human and non-human doses?

What is the discharge rate into the evaporation ponds?

What is the capacity of the evaporation ponds?

How well they will work over the winter?

From past reviews, evaporation ponds must be cleaned out periodically.

What will be the LLRW/Mixed Waste classification of the sludge removed from the liquid rad and non-rad evaporation ponds? And what is the expected quantity?

37 6.1 Cumulative Impacts (ESRP 4.7 proposed)

The COLA ER section is missing references to or listing of other activities that have or will occur in the region that may contribute to uranium fuel cycle impacts.

38 General General Due to the structure of the safety information, i.e., the SDA containing most of the safety information, is referenced by the FSAR, which is referenced by the ER. The cross referencing is confusing and information between documents appears incomplete.