ML19088A327

Transcript of Advisory Committee on Reactor Safeguards 661st Full Committee Meeting - March 7, 2019, Pages 1-105

ML19088A327
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Issue date:	03/07/2019
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Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION

Title:

Advisory Committee on Reactor Safeguards Docket Number: (n/a)

Location: Rockville, Maryland Date: Thursday, March 7, 2019 Work Order No.: NRC-0206 Pages 1-105 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 661ST MEETING 5 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 6 (ACRS) 7 + + + + +

8 THURSDAY 9 MARCH 7, 2019 10 + + + + +

11 ROCKVILLE, MARYLAND 12 + + + + +

13 The Advisory Committee met at the Nuclear 14 Regulatory Commission, Two White Flint North, Room 15 T3D50, 11545 Rockville Pike, at 8:30 a.m., Peter C.

16 Riccardella, Chairman, presiding.

17 COMMITTEE MEMBERS:

18 PETER RICCARDELLA, Chairman 19 MATTHEW W. SUNSERI, Vice Chairman 20 JOY L. REMPE, Member-at-Large 21 RONALD G. BALLINGER, Member 22 DENNIS C. BLEY, Member 23 CHARLES H. BROWN, JR. Member 24 MARGARET SZE-TAI Y. CHU, Member 25 MICHAEL L. CORRADINI, Member NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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2 1 VESNA B. DIMITRIJEVIC, Member 2 WALTER L. KIRCHNER, Member 3 JOSE A. MARCH-LEUBA, Member 4 HAROLD B. RAY, Member 5 GORDON R. SKILLMAN, Member 6

7 DESIGNATED FEDERAL OFFICIAL:

8 MICHAEL SNODDERLY 9

10 ALSO PRESENT:

11 PROSANTA CHOWDHURY, NRO 12 BRIAN GREEN, NRR 13 MARVIN LEWIS*

14 MIKE MILTON, NuScale 15 LAUREN NIST, NRR*

16 MARIE A. POHIDA, NRO 17 MAURIN SCHEETZ, NRR*

18 TIM TOVAR, NuScale*

19 20 21 *Present via telephone 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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3 1 TABLE OF CONTENTS 2 Page 3 I. Opening Remarks 4 Peter Riccardella . . . . . . . . . . . . . 4 5 Mike Corradini . . . . . . . . . . . . . . 6 6 II. Safety Evaluation with Open Items 7 Chapter 13: Conduct of Operations 8 Prosanta Chowdhury . . . . . . . . . . . . 7 9 IV. Safety Evaluation with Open Items 10 Chapter 18: Human Factors 11 Engineering 12 Prosanta Chowdhury . . . . . . . . . . . . 44 13 Brian Green . . . . . . . . . . . . . . . . 45 14 Public Comment 15 Marvin Lewis . . . . . . . . . . . . . . . 80 16 Adjourn 17 Peter Riccardella . . . . . . . . . . . . . 90 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 8:32 a.m.

3 CHAIRMAN RICCARDELLA: The meeting will 4 now come to order, please.

5 This is the first day of the 661st meeting 6 of the Advisory Committee on Reactor Safeguards.

7 During today's meeting, the committee will consider 8 the following: NuScale Safety Evaluation Report with 9 open items for Chapters 13 and 18 and preparation of 10 ACR reports.

11 The ACRS was established by statute and is 12 governed by Federal Advisory Committee, FACA. As 13 such, this meeting will be conducted in accordance 14 with the provisions of FACA. This means that the 15 committee can only speak through its published letter 16 reports. We hold meetings to gather information and 17 support deliberations.

18 Interested parties who wish to provide 19 comments can contact our office regarding time after 20 the Federal Register Notice describing the meeting is 21 published. That said, we set aside ten minutes for 22 spur of the moment comments from members of the public 23 attending or listening to our meeting.

24 Written comments are also welcome. Mr.

25 Mike Snodderly is the designated federal official for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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5 1 the initial portion of this meeting.

2 Portions of the session on NuScale 3 Chapters and 13 and 18 may be closed in order to 4 discuss protected information designated as 5 proprietary. The repeat discussion portion of this 6 meeting will also be closed because we will be 7 discussing sensitive internal information.

8 The ACRS Section of the U.S. NRC public 9 website provides our charter, by-laws, letter reports, 10 and full transcripts of all full and subcommittee 11 meetings, including all slides presented at the 12 meetings.

13 We have received no written comments or 14 requests to make oral statements from members of the 15 public regarding today's sessions. There will be a 16 phone bridge line but to preclude interruption of the 17 meeting, the phone will be placed on a listen-in mode 18 only during the presentations and committee 19 discussion.

20 A transcript of portions of the meeting is 21 being kept and it is requested that the speakers use 22 one of the microphones, identify themselves, and speak 23 with sufficient clarity and volume so that they can be 24 readily heard.

25 Please silence your cell phones or other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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6 1 items that could make noise and disrupt the meeting.

2 With that, I will turn the meeting over to 3 Mike Corradini, who is chairman of the subcommittee.

4 MEMBER CORRADINI: I'm going to wait until 5 the public line is open, okay?

6 CHAIRMAN RICCARDELLA: Yes.

7 MEMBER CORRADINI: I think that's 8 important.

9 May we begin? Okay.

10 So for the members, this is our third full 11 committee meeting, where we are going through some of 12 the chapters of the DCA. This session we are going to 13 be looking at Chapter 13, Conduct of Operations, and 14 Chapter 18, Human Factors Engineering. We had a 15 subcommittee meeting on this in January and I think we 16 had most of the members here. We were missing I think 17 two or three. So most of you have gone through this 18 discussion but I think it is important we go through 19 it all now.

20 Dr. Chowdhury will lead us off with the 21 staff. NuScale doesn't have a formal presentation but 22 they have people in the room and on the phone line 23 that can answer our questions if we want to break in 24 with questions.

25 I'm going to leave it to Dr. Chowdhury to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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7 1 discipline us if we ask something that should be in 2 closed session. We have about 45 minutes to an hour 3 scheduled at the end of the morning for a closed 4 session, if need be. Okay?

5 So with that, I will turn it over to Dr.

6 Chowdhury. I remind all the members the mics are 7 always live.

8 DR. CHOWDHURY: Thank you. Good morning.

9 My name is Prosanta Chowdhury. I am a project manager 10 in NRO, Officer of New Reactors of the U.S. Nuclear 11 Regulatory Commission.

12 I joined the agency in 2005 and I joined 13 NRO in 2008 as a project manager. Prior to joining 14 the NRC, I worked for 18 years at the State of 15 Louisiana as a radiation specialist. So I have a 16 master's degree in nuclear engineering and also a 17 master's degree in electrical engineering. That's my 18 educational background.

19 So what I plan to do today is briefly 20 cover the presentations that the staff already 21 presented at the subcommittee meeting on Chapter 13 on 22 January 23, 2019. So I am just going to briefly 23 summarize what the staff covered. And I should have 24 Ms. Maurin Scheetz on the phone to answer questions on 25 Section 13.1, 13.2, and 13.5. I have Ms. Amanda NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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8 1 Marshall in the audience to answer questions on 13.3.

2 And 13.4 is just a COL item.

3 So with that, the three technical staff 4 who presented on January 23rd are listed on this 5 slide, including myself and the lead project manager 6 for this NuScale Design Certification Application 7 review is Mr. Greg Cranston.

8 I would like to remind everyone that this 9 review that was presented on January 23, 2019 is based 10 on Revision 1 of the Design Certification Application 11 that NuScale submitted.

12 So 13.1, that is one of the sections 13 Maurin Scheetz is the lead reviewer for. And the 14 scope of the review was the organizational structure.

15 Essentially, the COL applicant will have the 16 necessarily managerial and technical resources to 17 support the plant staff in construction, operation, 18 maintenance, and in the event of an emergency. And 19 there were two -- sorry -- three COL action 20 information items provided in Chapter 13.1 of the DCA 21 Part 2, Tier 2. Those COL items are 13.1-1, 13.1-2, 22 and 13.1-3 that describe the corporate level 23 management and technical support organization and the 24 on-site operating organization.

25 And the staff reviewed those COL items and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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9 1 found them acceptable and there are no open items for 2 this section of the SE, safety evaluation.

3 Likewise for 13.2, which is training, the 4 purpose of this section is to provide assurance that 5 the applicant has established acceptable COL 6 information items pertaining to a description and 7 schedule for the licensed operator training program 8 for reactor operators and senior reactor operators, 9 including the licensed operation requalification 10 program, and number two, the training program for the 11 non-licensed plant staff.

12 Again, there were two COL items, 13.2-1 13 and 13.2-2 that were presented in DCA Part 2, Tier 2, 14 Section 13.2 by NuScale. The staff reviewed those and 15 found them acceptable and there are no open items in 16 this section of the SE.

17 MEMBER BALLINGER: I have a question. I 18 was going through Chapter 9, and there is an open item 19 in Chapter 9, and it is related to the sampling 20 system, and it's related to shielding. At least one 21 of them is related to shielding and things like that 22 for the sampling system.

23 These two are connected?

24 DR. CHOWDHURY: If you are talking about 25 the Process Sampling System, right?

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10 1 MEMBER BALLINGER: Right.

2 DR. CHOWDHURY: That has -- Chapter 13.3 3 has an open item related to that. So I will get to 4 that soon.

5 MEMBER BALLINGER: All right, I got it.

6 All right, thanks.

7 DR. CHOWDHURY: So here we are at 13.3, 8 Emergency Planning. So the focus areas were the 9 Technical Support Center, Emergency Response Data 10 System, Technical Support Center Engineering 11 Workstations, Decontamination Facilities, Process 12 Sampling System, Operations Support Center, Emergency 13 Operations Facility, and Emergency Plan and Emergency 14 Planning ITAAC.

15 So there is an open item, as you just 16 mentioned. The open item here in Chapter 13 is 17 designated as 13.3-1. The capability to obtain a 18 post-accident sample is an interface item between 13.3 19 and 9.3.2. That's the one that we just talked about.

20 So if this Process Sampling System is 21 determined to be acceptable as a means for obtaining 22 a post-accident sample in accordance with the 23 definition cited here, 10 CFR 50.34(f)(2)(vii) and 24 (viii), then this open item will be resolved.

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11 1 interactions on January 23rd and if there are any 2 other questions related to that, Amanda Marshall is in 3 the audience to answer the questions.

4 So with the exception of this open item, 5 the staff concluded for 13.3 that on the basis of its 6 review of the NRC EP design-related features included 7 in the Design Certification Application, that the 8 applicant has met the applicable regulatory 9 requirements.

10 13.3, there is no requirement for 11 operational programs for a DC applicant, however, 12 there is a requirement in 10 CFR 52.79 for COL 13 applicants to describe operational programs.

14 There is a COL information item provided 15 by the applicant, which is 13.4-1 and the staff 16 reviewed it consistent with the Standard Review Plan, 17 Section 13.4 Draft Revision, which was in September of 18 2018, I believe. And the staff found it to be 19 acceptable, comprehensive, and there are no open items 20 in this section.

21 MEMBER SKILLMAN: Dr. Chowdhury, let me 22 ask a question here and it's either in 13.4 or 13.5 23 that I will ask it again in 18.

24 What is unique about this plant is heavy 25 load lifting. And heavy load lifting is going to be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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12 1 a constant activity on a 12-module plant, 24-month 2 fuel cycle. There will be heavy lifting including 3 module shield blocks, and other paraphernalia 4 constantly.

5 Is there a basis for a special review of 6 a special organization dedicated to handling the 7 modules, the shield curtains, all of the heavy lifting 8 gear associated with the heavy lifts to ensure that 9 those are conducted in a manner that does not present 10 disproportionate risk to the then-operating modules?

11 DR. CHOWDHURY: Okay, if I understand 12 correctly, there is a lot of module movement in --

13 MEMBER SKILLMAN: Well, let me be very 14 clear. In my view, this is a subcommittee meeting --

15 this is a full committee meeting but it is one 16 member's view -- you will have three reactor operators 17 and three senior operators. Their focus is going to 18 be on live cores. There is going to be a dominant 19 leader that is assigned watching the plant and two 20 additional supporting that individual. At any one 21 time, one person is in charge.

22 Even while those operating reactors are 23 functioning, there is going to be another crew 24 completely independent moving very heavy loads 25 adjacent to those live cores. And I assert that that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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13 1 activity demands as much attention as keeping watch on 2 the operating cores.

3 So my question is: Because of the 4 uniqueness of the NuScale design, is there a 5 requirement in the organization for dedicated focus to 6 what we would have called fuel handlers but they are 7 really module and heavy load handlers? And the reason 8 I ask that question is because they're doing this 9 alongside of live cores.

10 DR. CHOWDHURY: Right. Yes, I understand 11 that and I also reviewed the transcript that has your 12 comments and questions about it.

13 I believe NuScale provided a response to 14 this inquiry before, stating that they had dedicated 15 procedures in place and organization in place to 16 handle it outside of operating the plant.

17 So beyond that, the staff looked at all 18 these on the organizational aspect of the reactor 19 operation. So I will defer it if Maurin Scheetz is on 20 the line or Brian Green is in the audience that maybe 21 you can supplement our answer to this question.

22 So Brian is going to come.

23 MEMBER CORRADINI: If I might just jump 24 in. I think what Member Skillman is wondering, it 25 appears here but it's also connected to 18. It's also NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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14 1 connected to Chapter 9. So they are all connected.

2 He just wants to make sure it's not lost in the 3 connection.

4 DR. CHOWDHURY: Oh, yes. No, it is 5 because, as Brian is going to probably cover -- add 6 also is that we had extensive interactions and 7 communications between Chapter 18, 13, Chapter 19, and 8 Chapter 15, and also part of Chapter 7.

9 So, Brian.

10 DR. GREEN: Hi, it's Brian Green, Chapter 11 18 reviewer. I don't think that maybe the discussion 12 in the subcommittee meeting maybe got as deep into 13 this as we probably should have.

14 Chapter 19 reviewers have been looking at 15 this and I don't know if they've had a chance to bring 16 their SER to you yet. There was an RAI issued by the 17 Chapter 19 reviewers that addresses precisely your 18 concern. It is currently, I believe the status is 19 closed, unresolved in there. They issued some 20 additional RAIs in the last few weeks that are going 21 into many of the concerns that you have brought up.

22 So they've seen the transcripts but this is still --

23 it's still in process.

24 So in one sense, the Chapter 19 reviewers 25 are working to have this discussion. They've been NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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15 1 aware of it and they don't have the final solution to 2 it yet.

3 As far as -- maybe I should save this for 4 Chapter 18 in a little bit. We have a process where 5 we go back and reconcile to make sure that if there 6 are new insights from the PRA, let's say that you know 7 your question -- maybe what you're saying is something 8 that needs to be done. If that becomes a part of the 9 NuScale operations, we would go back through our 10 design implementation process to make sure that the 11 appropriate tests are done or that there are valid 12 analyses that help to help us make a conclusion.

13 This way this helps to prevent any new 14 sorts of important actions like this from slipping 15 through the cracks.

16 MEMBER BLEY: Please don't leave yet.

17 DR. GREEN: Okay.

18 MEMBER BLEY: I was going to wait for 19 Chapter 18 but I think this is the right time.

20 Just a quick summary because these things 21 that cover multiple chapters are easy to lose track 22 of.

23 DR. GREEN: Yes, it spans a bunch of them.

24 MEMBER BLEY: Chapter 19 with the PRA 25 looked at seismic event impact on the crane. I have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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16 1 to go back and look more carefully at the regular part 2 of the PRA and see if they looked at crane drop 3 accidents there and they should have.

4 In Chapter 18, the staff had asked the 5 applicant about the HSI for the crane and, at least by 6 implication, any human errors associated with that.

7 The applicant came back and said the crane vendor is 8 going to supply that information.

9 I'm personally, well other than being a 10 little uncomfortable with that, what I would like to 11 hear from the staff is how, once the crane vendor 12 gives their information on the HSI and any associated 13 human actions with these lifts, that NuScale will 14 actually own that part of the analysis and the staff 15 will have reviewed it, if not for their design cert, 16 certainly I think for the COL. It's really kind of 17 crucial.

18 And the PRA, given the kinds of things 19 that have happened in crane drops in the past, the PRA 20 ought to be looking at human errors in rating the 21 crane, such that things get dropped. That's kind of 22 the most commonplace, other than breakage of some of 23 the small components, the lifting the components 24 themselves, rather than the crane.

25 Is there anything more you can say about NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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17 1 that?

2 DR. GREEN: I can say that there have been 3 some RAIs issued in Chapter 9 space to try and find 4 out what those words of futures would be so they could 5 be included in specs but I would not be the person to 6 answer further details on it.

7 The Chapter 19 reviewer is planning on 8 showing it for the Chapter 18 discussion. So she may 9 be able to provide the level of detail you are looking 10 for but I --

11 MEMBER CORRADINI: I think the essence of 12 what Dennis is asking, and I don't know maybe if this 13 is an easy yes or no, is that as we understood it from 14 the subcommittee meeting, staff identified this as a 15 risk. Staff has asked NuScale. NuScale has said 16 their vendors are going to take care of it.

17 We want to make sure the circuit is 18 completed so that the vendor comes back to NuScale, 19 and NuScale owns the plan, and staff has reviewed the 20 plan.

21 DR. GREEN: Understood. I think where 22 we're seeing it right now is these are essentially 23 screening criteria that would screen this into the HFE 24 review and I don't think that that answer is solved 25 yet.

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18 1 So the Chapter 19 review might say you 2 need to provide this, you need to provide some sort of 3 testing on the front end, rather than to delay it. So 4 the results of the Chapter 19 about how this ranks in 5 the risk may bring this more forward in the human 6 factors space, or it may go more to the lower end.

7 MEMBER BLEY: Okay. Well --

8 DR. GREEN: That screening question is 9 still where it is still under some dispute.

10 MEMBER DIMITRIJEVIC: All right, so I'm 11 familiar with those two RAIs which are issued on the 12 movement of the modules and they are related to the 13 numerous operator action related to that. Some of 14 them are action of Commission which are not even 15 modulating the Chapter 19.

16 So if those actions are part of that 17 initial to give in frequencies, they will never show 18 up in the ranking. Obviously, this is the most 19 important event in actually in the PRA. If they are 20 separated, they will show as important.

21 Well we will discuss that maybe more in 22 the Chapter 18. However, what I think Dick is 23 bringing, and this is how I feel, what is really 24 specific for this design is this module movement. It 25 is not -- I mean the other plants have the crane drop NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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19 1 during shutdown you know damaging but this is 2 completely different. This is the module movement 3 which can damage operating modules and misplace module 4 -- I mean you know disposition module in position 5 where it cannot be cooled.

6 So therefore, this has to be identified 7 somehow, not the details which we are waiting from 8 this RAI but this is some type of safety function.

9 Because the critical safety functions identified in 10 the Chapter 18 are just typical, you know the 11 reactivity control, if removal. This is something 12 very design-specific and has to be stated somewhere 13 independently of the results, which I think is going 14 to bring importance of those events in. But that 15 should be stated as very design-specific function to 16 be considered in operation -- module movement.

17 DR. GREEN: I understand that there is 18 potential for this and this is something that we are 19 still working on. I know Maurin is on the line.

20 She's been doing some thinking on this but I don't 21 believe there is a decision made about what that 22 critical -- if there should be another critical safety 23 function.

24 I believe NuScale's position is three is 25 enough but the staff is still --

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20 1 MEMBER DIMITRIJEVIC: Well, it doesn't 2 have to be core critical safety function because it's 3 something we use for yes, so the staff to change some 4 of its mind, but it has to be identified as an 5 important function of something you know. At least 6 the function it has to show somewhere in both 7 chapters.

8 DR. GREEN: Understood.

9 MEMBER RAY: Dennis, you referred to 10 NuScale in the context of the crane vendor, I believe.

11 MEMBER BLEY: But NuScale's response has 12 said that the crane vendor would supply this 13 information.

14 MEMBER RAY: Understand but I thought 15 there was some element of oversight review, approval, 16 or whatever of what the crane vendor did. I'm not 17 sure that wouldn't be the COL.

18 MEMBER BLEY: I'm not sure either but I 19 think it ought to be before the COL is completed.

20 MEMBER RAY: Right.

21 MEMBER BLEY: Because it could be a major 22 crumble.

23 MEMBER RAY: Yes, but it could vary from 24 plant to plant in terms of who the vendor was, how 25 they approached the problem, and so on and so forth, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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21 1 as far as I can tell.

2 DR. GREEN: I believe they've selected a 3 vendor. I'm not sure how they plan -- if they plan on 4 using the same one throughout the process.

5 MEMBER RAY: I don't think when you look 6 over the potential for many plants that have the 7 NuScale reactor that we should assume that all of this 8 is going to be supplied by NuScale, unless they've 9 said so. It would be something procured, I would 10 imagine under normal circumstances, by the COL holder.

11 So what --

12 MEMBER BLEY: I'm sorry. NuScale did say 13 that they would be including requirements about this 14 in their request for proposal or whatever it is from 15 the crane vendor.

16 DR. GREEN: The procurement vendor.

17 MEMBER BLEY: So they were saying that 18 they would own it.

19 MEMBER RAY: Okay, so you're satisfied 20 then that that's been addressed.

21 MEMBER BLEY: I'm satisfied that they are 22 going to do it.

23 Now, if you come along and buy one of 24 these things, you might put in an exception to switch 25 the crane vendor but then it ought to be covered at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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22 1 the COL stage.

2 That's my opinion.

3 DR. GREEN: And the human factors process 4 has a portion that starts after the Integrated System 5 Validation which occurred in the summer of last year 6 that aims to ensure that any human actions -- that new 7 human actions may arise between now and startup get 8 analyzed and potentially tested, if they rise to that.

9 And one of the criteria that's in that is that they 10 need to go back to the conclusions of the Integrated 11 System Validation and ensure that these changes do not 12 invalidate those conclusions.

13 The crane was not tested in the Integrated 14 System Validation that was conducted. So some 15 assessment would have to be done and potentially new 16 testing if this were to become new critical safety 17 functions or new operator actions involved.

18 Now, we do have an open item in our 19 review. We don't have an agreed upon process at this 20 point for how this is all going to be managed. That 21 is one of our outstanding open items but the 22 collection mechanism for new actions to come up 23 between now and then is addressed in that.

24 MEMBER SKILLMAN: Let me thank you for 25 your response and it gives me confidence that the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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23 1 concern that I have is going to be addressed.

2 Just for the record, let me explain how I 3 arrived at my questions. I started in Chapter 18 4 looking at human factors and I said there is going to 5 be a constant lift activity necessarily because of the 6 way this plant is designed. Where are the human 7 actions covered? Well, in 18 there is a statement 8 that says we're going to cover the human actions in 9 Chapter 9.

10 So I went into 9 and dug through 9 and I 11 concluded, first of all, the vendor is going to 12 provide the information, as Dr. Bley says, and the 13 owner, NuScale, are going to have to make sure that 14 the vendor information is appropriate for the number 15 of those types of lifts, the traffic in the tunnel 16 that separates five active and six active cores.

17 And I said well what's going to be lifted.

18 Well, it turns out it's just not the module, 734 tons.

19 To get to the module, you have to lift a 75-ton shield 20 block and stack it on the shield block of a live 21 reactor. So okay, now I've got to undo, latch, stack, 22 grab, disconnect, move. I've got six live here, five 23 live here. What do I know about everything that is 24 below the main hook?

25 That led me back to 19, to Dr.

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24 1 Dimitrijevic's comment. If you look at 19, 19 says 2 module handling is the greatest core safety risk in 3 the plant. And I figured well, what does Chapter 15 4 communicate? And I got to Chapter 15 and Chapter 15 5 communicates neither cask drop nor module drop are 6 examined because of the crane being a single failure.

7 And I said to myself, boy, that just lets 8 the air out of all my tires. I don't understand. So 9 I accept accountability for lighting this fire but I 10 think it deserves enough attention so that when this 11 application is finally reviewed, we can say with 12 confidence we have a solid grip on heavy load 13 handling. And it's not just the module. It's a 14 module. It's everything associated with the module.

15 It's everything associated with the fixtures into 16 which the module fits for disassembly and refueling, 17 reassembly and transport back to its home. These need 18 to be pulled together and we need to be comfortable 19 that they really have been integrated.

20 DR. GREEN: Understood.

21 MEMBER SKILLMAN: Thank you.

22 DR. GREEN: Thank you.

23 MEMBER REMPE: Before you leave, excuse 24 me. When you did the review, and I read the 25 transcript -- I missed the meeting -- but it looks NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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25 1 like, and I know NuScale wants it to be, for where all 2 12 modules are installed and operating. But in 3 Chapter 18, they explicitly say in the open document 4 that it is anticipated that you might have some 5 modules up and running while you are still installing 6 other modules.

7 Where do the modules come in? Do they 8 come in over the spent fuel pool? What end of the 9 building do they come in at?

10 DR. GREEN: Lauren, do you have the answer 11 for that off the top of your head? I don't remember 12 specifically. I know that installing the new modules 13 is quite similar in activity to the refueling module 14 but I don't remember --

15 MEMBER REMPE: Well okay.

16 DR. GREEN: -- when the new module comes 17 in.

18 MEMBER REMPE: It's not -- it may not be.

19 And I guess because you are still bringing in a module 20 for the outside world, I guess, unless they have a 21 requirement which I didn't see in what I reviewed, to 22 say even though we may not have them all up and 23 running, we've got to bring in all the vessels into 24 the building before we start up.

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26 1 from the outside world.

2 DR. GREEN: I believe that was one of the 3 assumptions but I don't remember off the top of my 4 head.

5 MEMBER REMPE: Okay then I'd like to know 6 how -- if you --

7 DR. GREEN: Lauren, are you on the line?

8 MS. NIST: Yes, I'm on the line. So I 9 also have to do some research to answer that question 10 with accuracy.

11 MEMBER REMPE: Because I am curious 12 because in Chapter 9, with the staff interactions, 13 they actually had NuScale change the DCA to day don't 14 bring in a new fuel assembly over the existing fuel 15 assemblies. And if we don't know how they're bringing 16 in the module, I think that some attention might be 17 warranted to make sure that the DCA explicitly states 18 how this is going to happen.

19 DR. GREEN: We can look into that.

20 MEMBER REMPE: Okay, thank you.

21 MEMBER MARCH-LEUBA: Joy, I am looking at 22 one of the cartoons, the pictures of NuScale, and the 23 module seems to be coming horizontally into the 24 refueling machine. So the new module will come 25 horizontally and then drop into the -- above the fuel NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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27 1 pool.

2 MEMBER REMPE: So it does --

3 MEMBER MARCH-LEUBA: I can show you in the 4 picture.

5 MEMBER REMPE: So it is coming in over the 6 spent fuel pools.

7 MEMBER MARCH-LEUBA: Over the fuel pool, 8 yes.

9 MEMBER REMPE: It's interesting, since 10 we're not supposed to be bringing a fuel assembly in 11 over the existing fuel elements but they have the 12 modules coming in over the spent fuel elements.

13 MEMBER MARCH-LEUBA: Yes, we don't have 14 enough detail to know if it might be a little to the 15 left or to the right.

16 MEMBER REMPE: Yes, okay, so the cartoon 17 isn't explicit.

18 MEMBER MARCH-LEUBA: I'm going to look at 19 it.

20 MEMBER REMPE: Yes.

21 MR. MILTON: Mike Milton with NuScale.

22 And we have a team on the phone that can help. It 23 does not come in over the spent fuel pool.

24 MEMBER REMPE: And that is actually stated 25 somewhere in the DCA?

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28 1 MR. MILTON: I will check on that.

2 MEMBER REMPE: Because, again, the staff 3 had some interactions and say I want to know where --

4 you know there ought to be something in here that 5 precludes and allows a safe pathway. And you may have 6 plans but it ought to be somewhere in the 7 documentation.

8 MR. MILTON: Right. It's definitely not 9 over the pool and we'll check on the words. It does 10 come in through the railway bay and that's located 11 there.

12 MEMBER REMPE: Okay, thank you.

13 Someone is on the phone.

14 MEMBER CORRADINI: Can you guys please 15 speak up? We can barely hear you. You've got to get 16 close to a mike or get off the speaker phone. Still 17 too low. Louder.

18 MEMBER REMPE: We're old.

19 PARTICIPANT: I'm as close as I can get.

20 I apologize for that. But it is not typically 21 possible to bring a module in over the spent fuel 22 pool. There is no equipment to life a module over.

23 It comes to the side of the spent fuel pit and then 24 enters the pool. It is then, I think people are 25 familiar with the travel path going to the -- from the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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29 1 dry dock basically in the pool submerged -- partially 2 submerged, to the operating bay, and to the 3 disassembly equipment.

4 MEMBER REMPE: Where is this documented in 5 the DCA, what chapter?

6 PARTICIPANT: Yes, I don't have that 7 information right now. We're looking but I just 8 wanted to mention it is not physically possible to 9 lift it up over the spent fuel pool. There is no 10 equipment above it that would be able to hoist any 11 portion of the module up over the spent fuel pool.

12 MEMBER REMPE: So is there like some big 13 large overhead door where it comes in the building?

14 I'm just trying to figure this out. And if you could 15 point me somewhere into the available documentation we 16 have, whether it's proprietary or not. And you can do 17 this later, give it to Mike Snodderly. But I would be 18 curious in understanding how it gets in -- a new 19 module would get into the building when you've got 20 modules up and running.

21 And so can you provide us some sort of 22 detailed response on that or something or point us to 23 where we should be looking for it?

24 MR. MILTON: This is Mike Milton. Yes, we 25 will.

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30 1 MEMBER REMPE: Thank you.

2 MEMBER CORRADINI: Go ahead.

3 DR. CHOWDHURY: My last slide on plant 4 procedures, 13.5. There are open items -- there is 5 one open item. In 13.5 there is one. So the NuScale 6 submitted a Generic Technical Guideline Document, Rev.

7 0. The staff reviewed it.

8 The staff had extensive interactions with 9 NuScale on this document. We had two public closed 10 meetings. I think one in February of 2018 -- February 11 9th and February 15. We had two really extensive 12 meetings and I was part of it. There were feedback 13 from the staff, extensive feedback provided to NuScale 14 on what they had identified as their concerns.

15 And also staff issued six RAIs with 17 16 questions on this matter regarding the Generic 17 Technical Guidelines. And NuScale responded to those 18 and NuScale provided Revision 1 draft of the Generic 19 Technical Guidance and the staff has seen that.

20 And the staff still has an open item 21 because I think based on the ISV, Integrated System 22 Validation testing and other validation activities, 23 the GTGs may be revised, updated as necessary. So 24 this is an open item that the staff is tracking.

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31 1 couple of questions about this?

2 DR. CHOWDHURY: Yes.

3 MEMBER BLEY: I know you haven't finished 4 your review but the GTGs are called out in Chapter 13 5 for developing procedures as a reference. They aren't 6 called out in Chapter 18 but some of the citations in 7 Chapter 18 use them as a secondary reference, which is 8 truly important over there as well.

9 In the development of procedures -- well 10 this question is one you can save until later until 11 you've finished your review of GTGs -- but there is a 12 section on symptom-based procedures and there's a 13 section on -- I lost it here -- I turn pages too 14 quickly -- on essentially how you use the GTGs to 15 develop procedures. And those aren't -- to me, are 16 not fully transparent. So after you've finished the 17 review, we want to ask a number of questions about 18 those.

19 There are places where it sounds like the 20 automated version of the GTGs are almost procedures 21 and there's really no clear indication of how 22 procedures will be developed from them. You know if 23 one looks at those flow charts as what we'd call ESDs 24 in doing risk assessment, they certainly aren't 25 complete. If they are tools for developing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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32 1 procedures, it's important to really understand how 2 they're going to be used.

3 I'm going to come back to these with a 4 couple more questions when we get to Chapter 18.

5 DR. CHOWDHURY: Okay.

6 MEMBER BLEY: For Chapter 13, those are my 7 main concerns right now.

8 DR. CHOWDHURY: Okay. Do you think that 9 we have to go into proprietary discussion in answering 10 those questions?

11 MEMBER BLEY: Since the whole document is 12 proprietary, yes, probably.

13 DR. CHOWDHURY: Okay.

14 MEMBER BLEY: And I don't think we need to 15 do it today. I think that's something -- unless 16 you've finished your review or it's almost done and 17 you're ready to address it.

18 DR. CHOWDHURY: No.

19 MEMBER BLEY: Okay.

20 MEMBER CORRADINI: I didn't think so.

21 Okay.

22 DR. CHOWDHURY: Okay so there are several 23 COL items for this section of the SE, 13.5-1 through 24 13.5-5 and then 13.5-7 and 13.5-8 for plant 25 procedures. Those the staff found to be appropriate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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33 1 and acceptable.

2 So the staff will make a conclusion on the 3 GTGs at a later time after they review the -- complete 4 their review.

5 I believe Maurin she is on the line.

6 Maurin, are you on the line?

7 MS. SCHEETZ: Yes, good morning. This is 8 Maurin Scheetz.

9 DR. CHOWDHURY: Okay. So thank you for 10 joining. And Maurin, is the key reviewer for this 11 section of the DCD. So if you have any questions in 12 the public discussion time, then she can answer.

13 MEMBER CORRADINI: Any further questions.

14 DR. CHOWDHURY: Any further questions.

15 MEMBER BLEY: Oh, when I said I couldn't 16 find the section I was looking for, the two sections 17 are 4.1 symptom-based procedures and 4.3 structure and 18 use. I had actually used these to develop the 19 procedures.

20 DR. CHOWDHURY: Okay.

21 MEMBER BLEY: Those were the ones I had 22 seen. They're hard to track.

23 And I was looking at the one.

24 DR. CHOWDHURY: Okay.

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34 1 question. I have a comment that I wanted to follow-up 2 in the subcommittee meeting. Is now the time?

3 Well first, ACRS is going to have a 4 meeting in the facility where we are going to see the 5 control room. And I am eagerly awaiting to see the 6 whole thing but I've seen pictures of it.

7 And the way I envision it is there are 8 going to be 12 big screen displays, one for each 9 module. And each of those is driven by some logic, 10 you can call it software or not. There is a logic 11 implemented in there that gives you a green light and 12 tells you this module is okay.

13 So I imagine if somebody is moving a 14 module in the middle with a crane and you have a big 15 seismic event, so I need the whole attention of the 16 operator who is going to be on the module that will be 17 moved. And he will quickly glance around and see 11 18 green lights, saying I don't have worry about those 19 guys. Let me worry about this one.

20 One concern I have is there is too much 21 over-reliance on computer-aided procedures and 22 computer-aided green lights. When we discussed this 23 in the subcommittee, NuScale told us that they trained 24 their operators when the screen goes black how to go 25 and use the backup information, the tablet, or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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35 1 possibly on paper.

2 But I write software for a living and I've 3 never written software that produces a green light 4 when it should be red. I mean often. That happens 5 very often.

6 And so one of my recommendations and I 7 believe the committee can follow up on that is that 8 there should be some recommendations to have some 9 training for the operators where the computer lies to 10 them. It makes a green light show green when it 11 should be yellow or red. And they should have an 12 emphasis on don't believe the green light completely.

13 Use it to your advantage but go and check yourself all 14 of them during this special event.

15 That is just a comment I wanted to put on 16 the record.

17 DR. CHOWDHURY: Thank you.

18 MEMBER CORRADINI: Why don't we move on?

19 DR. CHOWDHURY: That's all I have.

20 MEMBER CORRADINI: Okay, so we can move on 21 to Chapter 18.

22 DR. CHOWDHURY: Okay.

23 MEMBER BROWN: While they're doing that, 24 I'd just make one observation relative to your green 25 lights. Like you say, it's a software and computer-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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36 1 generated safety indication, which seems to go against 2 the old dictum that you believe your instrumentation 3 and the operators look at their instrumentation, not 4 an amalgam of a bunch of algorithms to tell you don't 5 bother with all the instrumentations, I've telling you 6 everything's okay. I am just not comfortable with 7 that. Like you, I'm not comfortable with that thought 8 process. Too many screens and not enough people to 9 look at them.

10 MEMBER MARCH-LEUBA: Yes. And they will 11 tell you it is not a computer. It's not software.

12 It's an FPGA-based logic but it does the same thing.

13 MEMBER BROWN: But still, somebody has got 14 to design the pathway for that information to get 15 through, whether it's a microprocessor or FPGA.

16 MEMBER MARCH-LEUBA: Maybe the probability 17 of failure is lower. Maybe it's a little more 18 deterministic but still probability of failure exists.

19 MEMBER BLEY: Before we leave that little 20 side discussion, I'd like to join in.

21 Well, I don't disagree at all. The 22 instruments can give you misleading signals. On the 23 other hand, there are some kinds of activities that, 24 and quite a few of them, especially the routine 25 checking of many things, for which computers are much NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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37 1 more reliable than people.

2 So it's not that we're going to be 3 recommending that these things run in manual but being 4 aware of what can go wrong and how to survive that 5 situation, I certainly agree with.

6 MEMBER MARCH-LEUBA: My recommendation is 7 to have the best of both worlds. Have a computer use 8 them but train the operator to check the computer.

9 MEMBER BLEY: No, I agree.

10 And before we get started, let me ask my 11 question about Chapter 18 at this point.

12 I said this in the subcommittee. Chapter 13 18 is sparse on detail. It tells what they're going 14 to do and it doesn't report back all of the human 15 events, and human actions, and all of those things.

16 They are all in subsidiary documents that are cited in 17 Chapter 18.

18 As we go through this discussion, I'd be 19 happy if the staff would tell us how they gain 20 confidence that this set of human actions is complete, 21 is reasonable, or needed, given they have to go 22 through this whole chain of documents to track it 23 down.

24 The GTGs seem to be the main source where 25 one would develop human actions to be examined both NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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38 1 for developing procedures, for understanding 2 operations, and truly to support the PRA, although 3 they imply that they get their source of human actions 4 from many different places, including the PRA. And 5 that goes both ways. That's a little reasonable.

6 They're very particular in saying that 7 both errors of commission and errors of omission, 8 which are really analyst terms, they are not the 9 operators always commit something but we know what we 10 are meaning by errors of omission and commission.

11 On the other hand, when you go through the 12 details of the actions that get identified and used in 13 the PRA, and I just simply identified, I find no 14 errors of commission in that list. My experience is 15 if you want to look for errors of commission, you 16 don't run a couple of tests. You have to really come 17 up with some carefully thought out search schemes, 18 kind of like a HazOp in the chemical business. And 19 that can be based on the set of event trees and 20 scenarios that are in the PRA. It can be based on 21 knowledge of the functions of all the systems. To 22 come up with a list of things people might do that are 23 errors of commission, that might be the problem. I 24 think the crane is a place where certainly they ought 25 to come up.

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39 1 I don't see any of the results of a search 2 like that or definition of such a search and I 3 certainly don't see any errors of commission, although 4 they say they're covered.

5 So I don't know what you guys have done 6 about that and if getting into the details of that 7 would require us to be in closed session or not.

8 DR. GREEN: This is probably the more 9 appropriate time to address it but I will mention that 10 there was an RAI -- this goes way back. I don't 11 remember. I'll have to get you that -- but where 12 NuScale had credited some analysis that kind of goes 13 into what you're looking for, errors of commission 14 that may happen. We would have to find that for you.

15 MEMBER BLEY: Okay.

16 DR. GREEN: It was in a related topic but 17 it was not specifically addressed to find that.

18 MEMBER BLEY: So you didn't find it in the 19 document. You only got it in response.

20 DR. GREEN: It was in an RAI response.

21 MEMBER BLEY: Interesting. It seems to me 22 if they really did something like that, there ought to 23 be a document. That's just stuff I'm concerned about 24 in that area.

25 DR. GREEN: Do you want a closed session?

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40 1 MEMBER BLEY: If there is anything to be 2 said in closed session. Otherwise, if you can just 3 get us the RAI.

4 DR. GREEN: I think getting you the RAI 5 would be more appropriate but it's been quite a while 6 since I've looked at that. I would rather get that to 7 you than just say something untrue.

8 MEMBER BLEY: Is the staff comfortable 9 that the applicant did a thorough job of searching for 10 errors of commission that they say they've looked for?

11 And I don't think you can just run an 12 experiment, a test to find them because they're rare.

13 DR. GREEN: I agree.

14 MEMBER BLEY: You won't see them in a 15 test.

16 DR. GREEN: It would not be likely to show 17 up in the types of tests that we run because they 18 happen so infrequently and with the number of 19 scenarios and the number of trials we do, you would 20 have to run hundreds, maybe thousands of tests to 21 maybe catch one.

22 MEMBER BLEY: Maybe.

23 DR. GREEN: Yes, I agree that would not 24 the best --

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41 1 that.

2 DR. GREEN: Right. That's not within the 3 scope of what we do.

4 MEMBER DIMITRIJEVIC: But a couple of 5 errors of commission identified during module 6 movement. I know you look in seismic but there is 7 actually module movement regular operation, not 8 seismic related where there is I think three errors of 9 commission identified the operator can actually make 10 that are in error.

11 MEMBER BLEY: In Chapter 19.

12 MEMBER DIMITRIJEVIC: IN the RAI for 13 Chapter 19.

14 MEMBER BLEY: Oh, okay.

15 MEMBER DIMITRIJEVIC: I will give you 16 connection to this.

17 Those three are actions are related that 18 actually operator can make mistake without the module 19 drop. And those are extremely important, actually, 20 errors of commission.

21 However, we don't see them in the PRA and, 22 when we go to visit, I will look in this document 23 because they are part of the module drop frequency.

24 And that's just one event.

25 MEMBER BLEY: That's one, yes.

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42 1 MEMBER DIMITRIJEVIC: Yes, and we don't 2 see what is inside.

3 MEMBER BLEY: And it's an amalgam of stuff 4 from everywhere.

5 MEMBER DIMITRIJEVIC: Right. However, 6 there is the technical report which describes those 7 errors of commission and also errors of omission also 8 related to the module drop. That technical report I 9 hope to see when we go to visit.

10 MEMBER BLEY: Okay, yes, I would like to 11 see that.

12 Also, until they really get a crane, 13 they're going to have to revisit this --

14 DR. GREEN: That's true.

15 MEMBER BLEY: -- because those sorts of 16 things are very dependent on the design that they've 17 actually done.

18 DR. GREEN: Our Chapter 19 reviewer is 19 here. If you'd like, we could ask Marie Pohida to 20 perhaps discuss some of where the -- what the 21 discussions are. I know she's issued some RAIs 22 recently.

23 MEMBER BLEY: Well I think the seismic 24 part we'll wait because we haven't had any meetings on 25 that.

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43 1 It would be delightful to hear from her.

2 MS. POHIDA: Good morning. I'm Marie 3 Pohida from the PRA Group in NRO and I am the tech 4 reviewer for Chapter 19 on module drop.

5 So are there any questions that I need to 6 answer?

7 MEMBER SKILLMAN: Well, I would ask one.

8 Module drop, to me, is code word for heavy lift. So 9 does your review go beyond just module? For instance, 10 to refuel module, one must remove the 75-ton shield 11 ledge and emplace it on an adjacent heavy lift over a 12 live module.

13 MS. POHIDA: Uh-huh.

14 MEMBER SKILLMAN: So it's called stacking.

15 So in your review, maybe yes or no is an 16 appropriate type of question, have you looked beyond 17 just the module lift and looked at all of the other, 18 if you will, subordinate lifts that are essential in 19 order for the module lift to be successful.

20 MS. POHIDA: Okay. We looked at all 21 movements of the module you know from the operating 22 bay all the way up to the lift at the reactor 23 internals with the upper portions of the CNV and the 24 upper portions of the RPV when they're loading onto 25 their fueling deck for inspection. We looked at the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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44 1 entire path of the crane.

2 In Chapter 19, the impact of putting the 3 bioshield on top of another operating bay for 4 refueling, that has been looked at and we do have one 5 open item on multi-module drop in Chapter 19.

6 MEMBER SKILLMAN: Thank you.

7 MS. POHIDA: Does that help?

8 MEMBER SKILLMAN: Yes, thank you.

9 MS. POHIDA: Thank you.

10 DR. GREEN: Well, thanks. I guess we've 11 covered a lot of what I thought we might get to. So 12 my next presentation is already half done for me.

13 DR. CHOWDHURY: Let me go first.

14 DR. GREEN: Sure.

15 DR. CHOWDHURY: So this is Chapter 18 and, 16 again, I am the project manager.

17 And Chapter 18 --

18 MEMBER CORRADINI: Is there slides for 18?

19 DR. CHOWDHURY: Chapter 18, a review of 20 Safety Evaluation Report once again is based on 21 Revision 1 of the Design Certification Application.

22 I just want to make sure it's clear that's what was 23 presented on January 23rd.

24 And the technical staff involved are Dr.

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45 1 here to cover the next slides, Ms. Lauren Nist, she is 2 on the phone, and Maurin Scheetz is on the phone as 3 well. Greg Cranston is the lead project manager.

4 So with that, I will turn it over to Dr.

5 Brian Green to cover the following subsequent slides.

6 DR. GREEN: Thank you. Today my plan is 7 to summarize the progress of the human factors review 8 that we've completed thus far and discussed certain 9 areas of interest during the review, describe the 10 activities we plan to complete in the near term, and 11 to address the open items that remain in the review.

12 The purpose of the review is to determine 13 whether human factors engineering design of the 14 NuScale standard plant control room supports operators 15 in the safe operation of the plant. In addition, the 16 applicant requested the minimum license operator 17 staffing requirement specific to the NuScale power 18 plant design. It adopted as requirements applicable 19 to licensees referencing the NuScale power plant 20 design certification in lieu of the requirements 21 stated in 10 CFR 50.54.

22 To provide technical justification for 23 this proposed operator staffing requirements, the 24 applicant conducted a Staffing Plan Validation test or 25 SPV, as we've often used too many acronyms here. My NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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46 1 apologies for that.

2 This test used personnel trained on 3 NuScale operations to perform a set of challenging and 4 high workload situation scenarios in the 12-unit main 5 control room simulator. In addition, an Integrated 6 System Validation has been conducted, or ISV, in 7 September of 2018, which provided performance-based 8 data of operators performing, in this case, a wide 9 variety of tasks throughout a range of normal and 10 accident conditions.

11 MEMBER BLEY: So as I understand it, you 12 have not completed your review of these tests.

13 DR. GREEN: The Staffing Plan Validation 14 is complete.

15 MEMBER BLEY: It is complete?

16 DR. GREEN: That one is complete. The 17 Integrated System Validation is not complete.

18 MEMBER BLEY: Okay.

19 MEMBER CORRADINI: But you have -- because 20 in January we were under the impression something has 21 been submitted.

22 DR. GREEN: It has not been submitted yet.

23 MEMBER CORRADINI: Oh.

24 DR. GREEN: I believe we're expecting it 25 at the end of the month.

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47 1 MEMBER CORRADINI: Oh, okay. All right, 2 so it still has not been submitted.

3 DR. GREEN: Yes, the testing was conducted 4 in August and September and they've been using the 5 last few months to analyze and generate the report.

6 MEMBER BLEY: And your SER did not include 7 the SPV reports, did it? I thought they were still to 8 come.

9 DR. GREEN: I believe the qualifications 10 chapter discusses it.

11 MEMBER BLEY: I'll have to go back and 12 look but I thought it showed --

13 DR. GREEN: I'm not sure to what degree.

14 I don't remember.

15 MEMBER BLEY: You still have to review it 16 I think is what it said but I'll take a look.

17 MS. NIST: Good morning. This is Lauren 18 Nist. I would point to chapter -- I'm sorry --

19 Section 18.5 the Chapter 18 of the Evaluation Report 20 provides an analysis of our review of the applicant's 21 Staffing Plan Validation results.

22 MEMBER BLEY: Thank you.

23 DR. GREEN: Shall I continue? Okay.

24 I just want to take this opportunity to 25 remind us that many of the specific details of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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48 1 applicant's test methods and results are proprietary.

2 Therefore, if we have questions about those, we should 3 hold those for the closed session.

4 To conduct our review and develop the 5 safety evaluation, we reviewed the following parts of 6 the application: The DCA Tier 2, Chapter 18, which 7 summarizes the more detailed parts of the many 8 technical reports that were submitted with the 9 application; we reviewed many of the technical 10 reports, which include a description of methods the 11 applicant uses for various analyses; and a summary of 12 the results of the testing that was conducted for 13 those.

14 As you mentioned, the ISV is not yet 15 complete. So that's where many of our open items are 16 in that area. But most of the rest of the HFE process 17 is complete at this time.

18 The technical reports also contain a 19 description of the HSIs or the human system interfaces 20 available to operators on the main control room.

21 We reviewed the concept of operations, 22 which describes the rolls and responsibilities of the 23 control room operators and how they are expected to 24 interact with each other and use the HSIs to operate 25 the plant.

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49 1 We reviewed a description of the methods 2 the applicant used to conduct the Staffing Plan 3 Validation and the results. And we've also reviewed 4 a description of the methods the applicant used to 5 conduct the Integrated System Validation test, 6 including things like reviewing the types of scenarios 7 that were going to be implemented, the types of 8 methods, data collection methods and whatnot.

9 We also conducted an audit of the testing 10 and we will be looking at the results as well.

11 As we have already done so today, the 12 staff referred to parts of Tier 2, Chapters 7, 15, and 13 19 that were related to human factors engineering 14 topics. The insights from those chapters are used to 15 risk-inform the human factors review.

16 We also reviewed the information in Tier 17 2, Section 3.15. The Tier 1 information in this 18 section includes an ITAAC for HFE.

19 Chapter 14 of the staff's Safety 20 Evaluation Report also documents the staff's review of 21 HFE ITAAC and there is some overlap in Chapter 18 of 22 this SER.

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50 1 analyses and design activities. Staff confirmed that 2 the applicant conducted these activities consistent 3 with applicable guidance and that appropriate 4 considerations unique to small modular reactors were 5 included.

6 In addition, the staff performed audits of 7 the Staffing Plan Validation and the Integrated System 8 Validation tests, both of which provide performance-9 based evidence suggesting the plant could be safely 10 operated using the NuScale human system interfaces and 11 staffing levels described in the application.

12 Next slide, please.

13 In preparation for the review of small 14 modular reactor designs, the staff developed two 15 guidance documents that identify potential human 16 performance issues that are uniquely related to small 17 modular reactors. These include NUREG/CR-7126, Human 18 Performance Issues Related to the Design and Operation 19 of Small Modular Reactors, and NUREG/CR-7202, NRC 20 Reviewer Aid for Evaluating the Human Performance 21 Aspects Related to the Design and Operation of Small 22 Modular Reactors.

23 Staff used audits to confirm that these 24 issues identified in these NUREGs were adequately 25 addressed by the applicant's human factors program.

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51 1 Staff confirmed that the various databases used by the 2 applicant during the human factors activity have 3 adequately addressed these concerns and that these 4 considerations were ultimately used to influence the 5 HSI design. I'll get to an example of how that works 6 in a moment.

7 In addition, the staff reviewed the 8 methodologies associated with the Integrated System 9 Validation and audited portions of that testing.

10 Staff observed an ISV test that was consistent with 11 NUREG-0711, which contains guidance for conducting 12 valid and reliable HFE tests.

13 So far the preliminary test results have 14 been -- that have been shared with us have been 15 positive, suggesting that the HSI design is sufficient 16 to support safe operation. Staff plans to review the 17 final ISV results when they are complete later this 18 month to confirm that the data do in fact support 19 these conclusions.

20 MEMBER REMPE: Excuse me.

21 DR. GREEN: Yes.

22 MEMBER REMPE: So I, unfortunately, missed 23 the January subcommittee meeting but I know Member 24 Bley brought up some of my concerns about shared 25 systems during this interim period before all the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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52 1 modules are installed.

2 Did your review look at some of these 3 human actions during this interim period? For 4 example, when they did install a new module coming in, 5 it seems like you'd have to be lowering the water 6 level of the pool as you put this big volume in. If 7 there is shared systems, such as the backup diesel 8 generators, and they may not all be installed from day 9 one, what shared systems need to be considered and did 10 their -- what they submitted, did it consider that 11 interim period prior to all this being there or do 12 they assume all shared systems like the backup diesel 13 generators, et cetera, are there from day one when a 14 module is operational?

15 I know they said the operators -- six 16 have to be there if you only have one module but I 17 didn't see anywhere where they identified when all the 18 shared systems have to be installed.

19 DR. GREEN: I can't say I have the answer 20 for that. I know that much of the refueling work has 21 been scoped out because of the way the risk-informing 22 process works. So much of it is not included within 23 the HFE review currently.

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53 1 and retest them.

2 MEMBER REMPE: This is not refueling.

3 This is basically interim period during startup of all 4 12 modules, when you have a couple in the pool and 5 your bringing more in. And then when do you have to 6 add the backup diesel generators?

7 And I thought during the transcripts, I 8 reviewed it before this meeting, that NuScale answered 9 and said no, we haven't documented anywhere what has 10 to be -- when you have to put those shared systems in.

11 DR. GREEN: I don't know the answer to it 12 so I would have to look but I can't recall.

13 MEMBER REMPE: Is anyone on the line from 14 NuScale who can provide some sort of information?

15 MEMBER BLEY: Someone's here.

16 MEMBER REMPE: Or if someone from NuScale 17 could answer those kinds of questions for me because 18 I am concerned about that interim period. We have a 19 lot of plants that never built some of the units that 20 were originally proposed.

21 MR. MILTON: Sure, it's Mike Milton. I'll 22 open up to the NuScale team if they'd like to answer 23 that question about the pool level. I believe the 24 pool level does not change.

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54 1 the pool level. I think what Member Rempe is asking 2 is, to put it as I -- do shared systems get installed, 3 whether it's one or ten, or one or n, and two, the 4 activities occurring during the operation of less than 5 --

6 MEMBER REMPE: Interim.

7 MEMBER CORRADINI: -- the interim period.

8 MEMBER REMPE: Yes and that's true. It's 9 more than just dropping -- that's one example that 10 came to my mind. But I'm just wondering has someone 11 from NuScale been thinking about this.

12 MR. MILTON: Sure. I'll give Corvallis a 13 chance to comment. If not, we'll take it away and 14 come back.

15 MEMBER REMPE: Did we lose them?

16 MEMBER CORRADINI: Anybody out there?

17 MR. TOVAR: This is Tim Tovar, NuScale 18 Power. The answer to that question is yes, we have 19 looked at that but we don't have the expertise in the 20 room to answer it in detail.

21 MEMBER REMPE: So this is a multi-chapter 22 question. And so can you provide some information so 23 that we can look at that because it is of interest to 24 me? And again, the transcript says no -- again, maybe 25 it was just the guy up on the podium, and it was a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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55 1 person from NuScale and I don't remember his name, but 2 said no, it's not documented anywhere.

3 But the other part of the question is to 4 the staff, which I don't think Member Bley ever got 5 around to during the meeting was you have not reviewed 6 that probably yet. It's not been part of your review.

7 DR. GREEN: I don't recall it. I'm not 8 sure if one of the other reviewers might have looked 9 at that at some level. Lauren or Maurin, do you have 10 anything to add on this? We may need to get back to 11 you on that.

12 MEMBER REMPE: Okay, thank you.

13 DR. CHOWDHURY: One thing -- this is 14 Prosanta Chowdhury -- I would like to mention is that 15 not to the details that you may be looking for but 16 some concept has been provided in Chapter 21, Multi-17 Module Design Considerations while they are talking 18 about construction and operation phase how modules are 19 placed and what shared systems are installed at what 20 point.

21 MEMBER REMPE: Chapter 21 --

22 DR. CHOWDHURY: Chapter 21.

23 MEMBER REMPE: -- explicitly says when the 24 shared --

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56 1 information in there.

2 MEMBER REMPE: I will look at that before 3 we get to our review coming up in Chapter 9.

4 DR. CHOWDHURY: This is unique NuScale 5 design certification application has Chapter 21 and it 6 is Multi-Module Design Considerations.

7 MEMBER REMPE: Okay. Well, I will look at 8 it and anything NuScale can provide before this mid-9 March meeting I think would be helpful in our 10 discussion. Thank you.

11 DR. GREEN: Let's see, are we on the right 12 slide? Next slide, please.

13 All right, before I go into the open items 14 I would like to take a moment to illustrate how 15 potential HFE issues associated with small modular 16 reactors was considered by the staff throughout the 17 HFE process.

18 One unique feature of this design is that 19 it allows for operation of all 12 units from a single 20 operator workstation. Therefore, we were interested 21 to see what kinds of design features would help to 22 prevent operators from taking actions intended for one 23 unit on a different unit or we might refer to these as 24 wrong unit type of errors.

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57 1 HFE analyses. One of these would be the operating 2 experience review. NuScale has a database where 3 they've collected information related to these sorts 4 of errors and other sorts of issues that were 5 identified in NUREG/CR-7126 and NUREG/CR-7202, where 6 they have done analyses of different industries, 7 nuclear and non-nuclear, because many of the sorts of 8 operating experiences that we might see, these wrong 9 unit sorts of errors, would come from military 10 applications or from medical applications where you 11 might have one person monitoring many patients using 12 teleoperative medicine and whatnot.

13 And so they looked, performed an analysis 14 to see what they could learn from other similar 15 industries where these wrong unit sorts of errors 16 might be possible.

17 MEMBER BLEY: Did the Navy share 18 information with you on this topic?

19 DR. GREEN: I don't know if the Navy did 20 but there are publishable articles out there about 21 these sorts of issues. The UAVs were one particular 22 area.

23 MEMBER BLEY: Okay. When you said the 24 military, I assumed you were talking about the Nuclear 25 Navy.

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58 1 DR. GREEN: No, no.

2 MEMBER BLEY: I'd be surprised if they 3 shared.

4 DR. GREEN: I would not ask NuScale to 5 discuss all of their sources but this is a common 6 human factors problem that has been in our industry 7 for quite some time. UAVs being one that's quite 8 publishable, where the thought was always that one 9 operator would fly a fleet of UAVs and that was very 10 challenging at first because of the many sorts of 11 mission-related things. So it turned out they needed 12 many operators.

13 And then they were approved on the designs 14 and now I believe they are applying this. But it 15 didn't get there quickly so there are sorts of 16 analytical research papers and things that NuScale had 17 reviewed in this process.

18 The staff audited their database, where 19 they collected these sorts of insights and found that 20 it was consistent with NUREG-0711 Chapter 3, which is 21 related to our practices for 0711 -- for human factors 22 operating experiencing review and that it consisted of 23 the sorts of things that we would expect from 24 NUREG/CR-7202.

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59 1 human factors process we looked at the HSI design and 2 looked for features that would help to prevent these 3 sorts of errors from occurring. These are some of the 4 observations that we had:

5 The applicant used consistent and clear 6 schemes for unit labeling on the HSI displays that 7 were used for monitoring and control as a means to 8 reduce the probability of wrong unit type errors.

9 Also the concept of operations defines the 10 roles and responsibilities for each of the control 11 room operators. The operators have different 12 responsibilities for different units, which may help 13 to prevent some of the errors.

14 Although the HSIs at the operator 15 workstations can be used to operate safety-related 16 components, the operator must first deliberately 17 operate the enabled non-safety control switch. No 18 automatic or manual safety actuation signals can be 19 present. Operation of the enabled non-safety control 20 switch to allow operation of the safety-related 21 components from the operator workstations is only 22 necessary under a limited set of conditions.

23 Also, it is an action that is intended to 24 be controlled by procedures, which gives us some more 25 confidence, and because it occurs in the control room NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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60 1 within sight of the control room supervisor's 2 workstation, it can be overseen by the control room 3 supervisor.

4 Additionally, if an event occurs, given 5 that the unit requires actuation of a protection 6 signal from the module protection system, the module 7 protection system will position the safety equipment, 8 if necessary, regardless of the position of the 9 enabled non-safety control switch or the safety-10 related components, giving us extra confidence.

11 So we kind of took these sorts of HSI 12 design features and found that they are building a 13 case to show that there are protections to help 14 prevent these sorts of wrong unit errors.

15 And then to go one step further, we 16 observed the Integrated System Validation testing, 17 which is where we might see some of these sorts of 18 errors. This is where the operators go into the 19 control room and perform various scenarios under lots 20 of different conditions.

21 The staff observed good data collection 22 practices that would likely identify any of these 23 errors, if they had occurred. And the staff is 24 awaiting the results to see if we see any of these, 25 and if they had safety consequences, and if there are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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61 1 any changes to the NuScale design at this point to 2 prevent -- to further prevent or mitigate these types 3 of errors.

4 MEMBER BLEY: I'm curious. You observed 5 those tests.

6 DR. GREEN: We observed portions during 7 the seven weeks.

8 MEMBER BLEY: The crews being tested 9 actually have procedures? Did they use those GTGs to 10 guide them through? What did they --

11 DR. GREEN: They did have procedures.

12 MEMBER BLEY: They did have procedures.

13 DR. GREEN: They have a computer-based 14 procedure system.

15 MEMBER BLEY: Okay.

16 In your review, did you go through the 17 GTGs and look at how they would be used to develop 18 procedures?

19 DR. GREEN: I did not. That's typically 20 --

21 MEMBER BLEY: Did anybody on the staff do 22 that?

23 DR. GREEN: Maurin Scheetz is both on the 24 Chapter 13 and 18. So she would be the person to 25 answer that question about the GTGs. She should be on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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62 1 the line.

2 MEMBER BLEY: Okay.

3 MS. SCHEETZ: Yes, this is Maurin. I'm on 4 the line. And I did use -- I looked at how the GTGs 5 were used to develop procedures. They are basically 6 there as a basis for COL applicant procedures.

7 MEMBER BLEY: Could you say that last one 8 again?

9 MS. SCHEETZ: We'll have another 10 opportunity to review --

11 MEMBER CORRADINI: You're breaking up.

12 Could you say that again, please?

13 MS. SCHEETZ: Okay. There's like 14 considerable feedback when I talk so it's very 15 confusing.

16 DR. GREEN: Maurin, they're asking for you 17 to repeat your comments. We couldn't hear you the 18 last time through.

19 MS. SCHEETZ: So I did look at how the 20 GTGs would be used for a COL procedure in the future.

21 The GTGs are a basis, a starting point. We will have 22 another opportunity when there is a COL to look at the 23 actual emergency operating procedures, severe 24 mitigation guidelines, et cetera.

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63 1 over. As I'm trying to say, this is a basis and we 2 believe that these are an adequate basis, a starting 3 point for future procedures.

4 MEMBER BLEY: Since you have the open item 5 in Chapter 13, I assume the final SER on 13 will go 6 into the GTGs and what you found there and your 7 conclusions about them. Is that true?

8 MS. SCHEETZ: The open item is related to 9 NuScale's validation of the GTGs. So we are waiting 10 for information back from NuScale on the results of 11 that validation before we make our final decision on 12 the GTGs, which the purpose of the GTGs is a basis for 13 plant-specific technical guidelines.

14 MEMBER BLEY: I may have understood that.

15 Go ahead.

16 MEMBER CORRADINI: I heard that as a yes.

17 MS. SCHEETZ: Yes, we have an open item.

18 Yes.

19 MEMBER CORRADINI: And it will be 20 discussed -- let me just make sure. What Member Bley 21 was asking, it will be discussed as you resolve it in 22 Chapter 13, assuming --

23 MS. SCHEETZ: The resolution of our open 24 item will be discussed in Chapter 13, yes.

25 MEMBER CORRADINI: Thank you.

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64 1 DR. GREEN: Okay, so now we're onto our 2 open items.

3 The Phase 2 SER currently contains 23 open 4 items for the following topics. Nineteen of those are 5 associated -- I guess we're using a different acronym 6 here. I should have caught that -- V&V is a set of 7 tests that includes the Integrated System Validation.

8 So for the sake of consistency, let's say they're 9 there. So these will be items that we should be able 10 to close when we get the Integrated System Validation 11 RSR later this month. And those are primarily 12 involved with making sure that the results that are 13 provided, and they are consistent with what we had 14 seen and good analytic practice and whatnot. So you 15 might bundle those into one open item but there are 16 several RAIs that are there to mark that.

17 Other than that, there are four unique 18 open items that are not related to the outstanding ISV 19 analyses. One open item is about how we can ensure 20 that there will be sufficient verification and 21 documentation of the human factors activities that a 22 NuScale licensee should perform. For example, there 23 should be a viable mechanism we can rely on to ensure 24 that any new or modified important human actions will 25 be confirmed to be feasible and reliable.

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65 1 And this -- the intent of this is to go 2 back to make sure that if things change so that if the 3 crane becomes elevated to a point where it needs 4 additional analyses or testing, this would be a 5 mechanism to help make sure that that focuses us into 6 the human factors process at that point.

7 So this basically helps to ensure that 8 just because the Integrated System Validation is done 9 doesn't mean that human factors is a foregone 10 conclusion.

11 There is one open item related to a topic 12 that is also under review in Chapter 7. It's for the 13 applicant to clarify how the design satisfies remote 14 shutdown capabilities discussed in GDC 19. This issue 15 was previously discussed at a Chapter 7 ACRS meeting.

16 We'll need to update our SER to be consistent with 17 Chapter 7 as that issue is resolved, depending on 18 what, if any, changes are made to the design of the 19 HSIs in the remote shutdown station.

20 There is an open item to confirm that the 21 information in the Chapter 18 SER about the treatment 22 of important human actions is consistent with the 23 results of the Chapter 7, 15, and 19 reviews. This 24 will help us to ensure that any changes in these 25 analyses are adequately addressed within the human NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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66 1 factors process.

2 And this really has to do with the fact 3 that those reviews are being conducted concurrently 4 with ours and they also help us scope our reviews. So 5 if something happens that broadens the scope, we need 6 to go back and continually check with them. So we 7 meet with them periodically to make sure there's no --

8 nothing on the horizon that is going to surprise us.

9 Is there a question?

10 MEMBER RAY: Well, I was waiting to ask 11 one when you stopped. But I was going to ask, Mike, 12 do you know when or if we see the ITAAC, for example, 13 on the HFE, at a time when we comment or is that, the 14 ITAAC, set after we're done?

15 MEMBER CORRADINI: I thought we were going 16 to come to those later, yes?

17 MEMBER RAY: You know what the ITAAC says 18 on this subject is somewhat important to --

19 MEMBER BLEY: Yes, I don't know the answer 20 to that. Do we have a session set up for looking at 21 all the ITAAC?

22 MEMBER SKILLMAN: Well we do for Chapter 23 14.

24 MEMBER CORRADINI: That's what I thought.

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67 1 as mature as Harold wants it. But it's a great 2 question.

3 MEMBER RAY: Well, it seems really vague, 4 at this point, what the ITAAC rule contains --

5 MEMBER SKILLMAN: For HFE.

6 MEMBER RAY: Yes.

7 DR. GREEN: It is still somewhat under --

8 there is one related to the remote shutdown 9 workstation. There was a public call on this 10 recently. So there are some changes coming in that 11 way.

12 And we do have kind of an outstanding 13 issue, potentially, with the design implementation 14 part of human factors that is -- it's undetermined 15 whether or not ITAAC is necessary. So we're still 16 working on that one as well.

17 But my understanding is I believe you 18 would hear that under Chapter 14 and see the full set 19 of them there.

20 MEMBER MARCH-LEUBA: Okay. With respect 21 to when you were talking about continuing the 22 conclusions with Chapter 15 and 19 --

23 DR. GREEN: Yes.

24 MEMBER MARCH-LEUBA: -- how are you going 25 to interface with it? You were now closing Chapter 13 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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68 1 and 18. If something happens in Chapter 15 that 2 affects it, you will then redraw Chapters 13 and 14?

3 DR. GREEN: Well if something were to 4 happen in Chapter 15, say that there were now suddenly 5 a deterministic human action that was really very 6 important, this could potentially be a really 7 challenging situation for us. So we may have to go 8 back to the applicant and see you know do you have 9 testing that supports the operators can do that.

10 Perhaps they may have already tested it.

11 In fact NuScale, when they put together the Integrated 12 System Validation testing, used -- they had the 13 Chapter 19 actions that are prioritized, they included 14 more than what they thought they needed because you 15 need to have scenarios that are useful. You can't 16 just say there are these two actions that are 17 important, let's go prove those. You need to put it 18 into a context so that they don't know what's coming.

19 And my understanding is that many of the other actions 20 that were in there were the next ones that might raise 21 to the level, if this sort of thing were to happen.

22 So there is a reasonable chance that these 23 sort of actions that -- and I don't necessarily think 24 there are going to be new actions in the control room, 25 but if there were, there's a reasonable chance they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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69 1 would have been included in the testing we've done and 2 we could go back and analyze those.

3 MEMBER MARCH-LEUBA: So I am going to 4 branch a little bit because you just said something.

5 During this testing, were they using the final 6 procedures? Do those procedures exist?

7 DR. GREEN: I'm not sure. Maurin, these 8 are still considered a draft at this point, I believe, 9 but I would ask Maurin to confirm that. There may 10 still be some changes to those procedures but they 11 would expected to be validated.

12 But I'll let Maurin answer.

13 MS. SCHEETZ: Okay, this is Maurin. I 14 just want to make sure we're distinguishing between 15 computer-based procedures that NuScale uses versus the 16 GTGs. I think the question before dealt with the 17 Generic Technical Guidelines that might have been 18 about computer-based procedures.

19 In Chapter 13 space, we review the Generic 20 Technical Guidelines to make sure that they are 21 adequate as a basis for plant-specific technical 22 guidelines. They are specifically more closely 23 aligned with emergency operating procedures and the 24 severe accident mitigation guidelines.

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70 1 computer-based procedures to make sure that from a 2 human factors standpoint that they are adequate.

3 So the ones that are in draft are the 4 Generic Technical Guidelines.

5 MEMBER MARCH-LEUBA: Yes but my question 6 was are you confident that -- are you satisfied in 7 this validation test that they just performed last 8 month that we're using procedures that are 9 representative of what they will really be at the end?

10 DR. GREEN: We believe that they are.

11 There are some -- some of our criteria that we look 12 at, I'll give you some examples of some of the things, 13 we wouldn't want them to put together a skeleton crew 14 of procedures that only address the issues that 15 they're expected to see. Because if they were to take 16 the wrong path, they'd say oh geez, we don't have a 17 procedure; we must be doing something wrong. It would 18 tip operators off.

19 So there is a robust set of procedures.

20 They do work through the processes that are there. I 21 don't know that we would expect them to look exactly 22 the same. Certainly, things are going to change in 23 them between now and then but the normal validation 24 procedures would be used to make those corrections.

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71 1 NuScale, when they finally have final procedures, to 2 make a 50.59-type evaluation that says yes, what we 3 tested is similar to what we have.

4 DR. GREEN: Yes, I'm not sure what the 5 practice is for that, for the validation of those 6 changes at that point but I believe there is a process 7 in place for that.

8 MEMBER MARCH-LEUBA: Okay, going back to 9 my original.

10 DR. GREEN: Okay.

11 MEMBER MARCH-LEUBA: I was going to wait 12 until the end of the presentation but I wanted to put 13 something else on the record.

14 DR. GREEN: Sure.

15 MEMBER MARCH-LEUBA: And it is related to 16 this relationship in Chapters 15 and 19 and is, in 17 particular, ATWS, anticipated transients without 18 scram. They sprinkle, the references sprinkle all 19 over the SERs for 13 and 18 that says ATWS is okay and 20 does not require any operator action.

21 And in particular, Chapter 13 has a 22 paragraph which is a direct quote from an RAI 23 response, which I particularly find offensive because 24 I don't believe it's true.

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72 1 little heavy, I have been trying to find those adverse 2 calculations before the subcommittee and after the 3 subcommittee and I have to confess that I have not 4 been able to find them. I am convinced by now that 5 they don't exist and all these statements that you 6 have in the SER is a figment of somebody's imagination 7 because I have not seen those calculations.

8 The calculations that the staff has showed 9 me a cover page of a report that hasn't been issued 10 and that really added to my problem.

11 Let me put it on the record, yes to put it 12 on the record I want them to explain in detail what 13 happens. But I am worried that an isolation ATWS, 14 that you have containment isolation, you have an ATWS 15 and it's the beginning of cycle, when the moderator 16 temperature coefficient is zero, which you are allowed 17 to have. Therefore, you don't have any water 18 reactivity feedback. All your feedback is only 19 Doppler.

20 I ran some interim calculations and the 21 few numbers I have been able to find from FSAR Topical 22 Reports and there is not enough reactivity in the core 23 to shut it down. Indeed, if we start saying numbers, 24 we will have to go into closed session so I won't say 25 it in this session but the reactor will not shutdown NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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73 1 where there is significantly high power. And I don't 2 mean ten percent. Significantly higher power and we 3 start boiling off the whole inventory. And it will 4 die out and it will melt.

5 So I know that when we do the real 6 calculations there will be other effects like boron 7 concentration or things like that that saves us but 8 right now I have a scenario that directly contradicts 9 what they said in Chapter 13 and what they said in 10 Chapter 19, and what they said in Chapter 15.

11 So I wanted to put that on the record and 12 whenever we get in June to see Chapter 15, we'll have 13 a lot of fun with this. There will be a calculation 14 for us.

15 DR. GREEN: Understood. We did coordinate 16 with the project manager for Chapter 15. So we've 17 passed on the transcripts from the last meeting and 18 we'll do the same so that your concern will be noted 19 and I'll let them defend the position that they have.

20 MEMBER MARCH-LEUBA: I'm giving you -- you 21 notice that when we finalize the review of Chapter 15 22 you may have to change some of the language.

23 DR. GREEN: We understand that that's a 24 possibility and that's built into our process here.

25 So that's why the design implementation element is --

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74 1 it's the catchall in case something comes out there.

2 And you know I don't think anybody wants to have to go 3 back and do that retesting but if that's what's 4 necessary, we can have that discussion at that time.

5 MEMBER MARCH-LEUBA: It probably wouldn't 6 affect the human factors. I would only affect the 7 language of the SER.

8 DR. GREEN: Well that would be -- I think 9 NuScale be happy for us to rewrite the SE than to have 10 to --

11 MEMBER MARCH-LEUBA: Well maybe not. I 12 mean if everything, if all the planets align in the 13 wrong way and my scenario turns out to be a core 14 damage, it will be the dominant factor in the whole 15 plant by three or four orders of magnitude.

16 DR. GREEN: Okay.

17 MEMBER MARCH-LEUBA: So yes, it could.

18 DR. GREEN: So it's on our radar and we 19 will continue to coordinate with Chapter 15 in these 20 other areas to make sure we don't miss anything.

21 And then finally, there is one other open 22 item that is administrative in nature, which is to 23 verify that the human factors reports, such as the V&V 24 result summary report are incorporated by reference to 25 make sure that they end up in the final application.

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75 1 Next slide, please.

2 In conclusion, I'd like to summarize what 3 we've determined thus far about the applicant's human 4 factors design in the proposed staffing plan. Results 5 of the applicant's Staffing Plan Validation test 6 demonstrate that the applicant's proposed staffing 7 plan can be used to safely operate the plant.

8 And based on our own observations of the 9 Integrated System Validation test, we expect that the 10 results will provide additional evidence that the 11 human factors design supports plant personnel in the 12 safe operation of the plant. However, we will be 13 reviewing these ISV results to verify that they either 14 confirm the proposed staffing plan or that the 15 applicant makes any necessary changes in order to 16 support the safe operation plan.

17 The open items identified in the safety 18 evaluation need to be resolved during the Phase 4 19 review for us to find that the HFE design complies 20 with all NRC requirements related to human factors and 21 thus, the human factors design supports personnel in 22 the safe operation of the plant.

23 That concludes our prepared remarks. I'm 24 happy to take any more questions you may have.

25 MEMBER CORRADINI: Members?

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76 1 MEMBER SKILLMAN: Let me ask one and I 2 want to build on Dr. Rempe's question on shared 3 systems.

4 Is there a commissioning sequence that one 5 could review that would identify which systems must be 6 operable when -- as the build out continues? For 7 instance, I imagining that the base plan would be the 8 concrete, the liner, testing the liner, installation 9 of the crane because no heavy lift is going to come 10 without that crane, closure of the containment 11 building, filling the ultimate heat sink, bringing in 12 the first module. The first module is going to 13 require CVCS, CFDS, boric acid addition, demineralized 14 water, vacuum system, a couple more. So there's a 15 logical sequence and that's where Joy's question comes 16 out in how many multiples do you need.

17 For instance, there is one CVCS per 18 module, boric acid is shared among six. You're not 19 going to use a module until you can dump heat. So you 20 need at least one turbine. You need a condenser. You 21 need a vacuum. You need circ water. You need 22 chemistry control in the secondary on the primary.

23 So there must be -- and I'm confident that 24 the NuScale team is a smart team. They probably put 25 something like this together that would allow Joy's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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77 1 question to be answered on shared systems. Is there 2 such a thing?

3 DR. GREEN: I don't have it for NuScale.

4 I am unaware of it.

5 MEMBER SKILLMAN: I've just been chewing 6 on it since I kind of got the gist of it.

7 VICE CHAIRMAN SUNSERI: If I could jump 8 in, in the DCD there is a Chapter 21 that talks about 9 multi-module design consideration and it describes the 10 things that you're talking about.

11 MEMBER REMPE: Well it does, but I 12 actually looked at that because it was brought up 13 earlier by the staff, but it doesn't have a lot of 14 detail. And then what I don't know and maybe Vesna 15 and Dennis can help with the PRA is when they did 16 their analysis did they ever assume any cross ties.

17 Because yes, it does in say 21, as well as 9, that 18 sometimes the shared system is needed for six modules, 19 sometimes the shared system is needed for four.

20 So clearly, they've been thinking about it 21 but then do they ever say well, okay, as a backup, 22 that one that is shared by the first six or the first 23 four isn't going to work until I put a cross tie 24 between the other one that's there. And the backup 25 diesel generators are one that come to mind because NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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78 1 it's one of the important actions that is in Chapter 2 13 identified at the operator startup. And I think 3 there's two backup diesel generators. Are both of 4 those installed from day one or is it like the turbine 5 generator building where they say no, you only need it 6 for the first six?

7 MEMBER CORRADINI: I think we're going to 8 have to wait.

9 MEMBER REMPE: Yes, well I think so but I 10 think it's something that we ought to maybe, again, we 11 can discuss when we do letter writing that we ought to 12 mention, hey, we're interested in this unless the PRA 13 folks can tell me no, they never did any cross ties or 14 something like that.

15 And it's just something that when I was 16 reading through that I was curious about and I was 17 curious if the staff had thought about it, too.

18 MEMBER DIMITRIJEVIC: Well, we can discuss 19 usually the 19. See all this, where the shared 20 systems are considered when there is an initiator 21 which will challenge all units like loss of offsite 22 power, you know the side, all the units will require 23 the use of generators. When it comes to the active 24 feature, you need specifics like the ability the LOCA 25 will happen in multiple units is very small so, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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79 1 therefore, those shared systems are not as important 2 as the ones which were credited for the carbon 3 emission.

4 So and it's not also -- there is not also 5 -- it is not clear, actually, and we will discuss this 6 in Chapter 19 how those actions are considered with 7 the multiple units. I am very curious about that 8 myself.

9 Also, it is not clear from the operator 10 actions when he has to tend to multiple units are the 11 stress or are the difference in the evolution of the 12 human actions.

13 MEMBER REMPE: Again, we can discuss it 14 more but I think it might be -- again, I don't think 15 it is a high level recommendation or conclusion. It 16 is just a point that is something that we are curious 17 about and we ought to keep in our minds.

18 MEMBER CORRADINI: Well I think -- I 19 definitely think the staff and NuScale are aware of 20 the fact we're interested in this and we'll keep on 21 asking until we get an answer.

22 Okay, other questions by the members?

23 We have time for a closed session. What 24 I would prefer to do is to get any more members' 25 comments, go to public comments, and then essentially NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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80 1 go to break as we get organized for any questions in 2 closed session.

3 Okay, so can we -- is there anyone from 4 the general public who wants to make a comment that 5 are in the room?

6 Hearing none, can we open the public line 7 to see if anybody wants to make a comment that is on 8 the phone? We'll wait until the powers that be turn 9 it on.

10 MR. LEWIS: My name is Marvin Lewis.

11 MEMBER CORRADINI: You're going to have to 12 speak louder, sir. I can't hear.

13 MR. LEWIS: My name is Marvin Lewis.

14 MEMBER CORRADINI: Mr. Lewis, go ahead.

15 MR. LEWIS: I have a comment about the 16 crane stuff. While you are stacking, may I 17 respectfully suggest you also look at the floor 18 underneath where it drops?

19 In ANO, Arkansas Nuclear One, the drop 20 wound up on a floor that gave way to a ceiling in the 21 switchgear room, which led to no water addition to the 22 fuel pools for 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />. A few more hours and we 23 would have had a nice shamrock type fire in the fuel 24 pools.

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81 1 whatever you're stacking. You look at the floor 2 underneath. Will it give way? Will there be a 3 switchgear room underneath? Will the switchgear, when 4 it blows, be able to somehow get water into the fuel 5 pools?

6 Thank you.

7 MEMBER CORRADINI: Thank you.

8 Is there anybody else online that wants to 9 make a comment, please?

10 Okay, hearing none, can we close the 11 public line and we'll take a break -- or sorry. I'll 12 turn it back over to the chairman. We'll take a 13 break, if that's allowed and then we'll come back to 14 closed session.

15 CHAIRMAN RICCARDELLA: Yes, I mean it's 16 10:07.

17 MEMBER CORRADINI: Well if I might just 18 ask, I assumed we needed a closed session. Do the 19 members have other questions? Otherwise, we're just 20 going to be concluding the session completely.

21 MEMBER BLEY: I'm sorry, was there more of 22 an answer to the question earlier about GTGs that you 23 want to cover in closed session?

24 DR. GREEN: I didn't have anything more.

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82 1 discuss about GTGs in the closed session?

2 MS. SCHEETZ: I don't have anything for 3 the closed session. I just want to clarify we're 4 talking about two different things here and I didn't 5 do a good job of saying this earlier.

6 For the Generic Technical Guidelines, the 7 scope of our review was about the content of the 8 Generic Technical Guidelines being adequate. That's 9 -- the design of computer-based procedures so that 10 they were adequate for use by operators in the control 11 room. And I just wanted to differentiate those two 12 things.

13 We're waiting on the results of the 14 Integrated System Validation to confirm if the Generic 15 Technical Guidelines were able to be implemented in 16 that scope in Chapter 13.

17 MEMBER BLEY: Thank you. I think we got 18 that. So I don't think we need a closed session.

19 MEMBER CORRADINI: Okay, so I'm hearing 20 that -- yes, Charlie?

21 MEMBER BROWN: I just wanted -- throughout 22 the earlier conversation relative to the crane, and it 23 seems the crane is a key ingredient or a key element 24 in terms of the all the module transfers, multiple 25 modules, taking them out and moving them from one NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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83 1 place to the other. And I don't remember who said it, 2 since I'm not as familiar with this type of a system 3 in my past experience, it seemed like all of the 4 requirements were being deferred to the vendor of the 5 crane is going to satisfy the requirements. What 6 requirements they are or why is the crane 7 manufacturer, he's not a plant guy, how is going to be 8 able to understand what he needs to provide in safety 9 in the backups, the multiple whatever it is that makes 10 that crane satisfactory.

11 MEMBER CORRADINI: Is that a question to 12 NuScale?

13 MEMBER BROWN: Yes, it sounds to me like 14 they're -- I just don't understand. It sounds like 15 NuScale, to me, should be providing what safety 16 requirements do we need to be imposing on the crane 17 manufacturer, not the crane manufacturer is going to 18 tell us well that's okay.

19 MEMBER SKILLMAN: My --

20 MEMBER BROWN: Did I get that -- do I 21 understand that point?

22 MEMBER SKILLMAN: Charlie, I think the 23 question is appropriate. I'm not going to try to 24 answer the question because it really is a NuScale 25 answer but it appears to me in the safety evaluation NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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84 1 that entire topic has been, quote, offloaded to the 2 notion it's a single failure-proof crane.

3 We had single failure-proof cranes to do 4 the defueling at TMI2 and we dropped parts of the 5 defueling equipment into the reactor vessel on top of 6 the pebble bed of fuel.

7 So I'm not convinced with a single failure 8 crane everything is going to be fine, which is one of 9 the reasons that I've got a fire on this. I think 10 there needs to be as much focus and accountability on 11 the design of that crane, in the operation of the 12 crane, and the training of the people that operate 13 that crane as we have on the men and women that are 14 going to operate the cores.

15 Operating the crane on this plant, heavy 16 load lifting on this plant is going to be a 24/7 job.

17 If there are 12 modules, there's going to be a module 18 change-out each two months. And if you look at the 19 module change-out, that's what Marvin Lewis just 20 mentioned, when you're stacking, where you're putting 21 this stuff, whatever load has, how is all of that 22 coordinated so that there is no risk to what could be 23 15 operating modules at 160 megawatts each.

24 So I think it's appropriate that you raise 25 it. The lens through which I am looking at this is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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85 1 the safety evaluation in Chapter 19 says it's a single 2 failure-proof crane. If you look in Chapter 15, cask 3 drop and module drop are excluded because of the 4 single failure-proof crane. And I'm just not -- I'm 5 not convinced that that is sufficient for the issues 6 that we need to deal with.

7 MEMBER BROWN: Is the crane or the rails 8 of the crane, is that part of the crane assembly?

9 MEMBER SKILLMAN: Yes.

10 MEMBER BROWN: He provided that as well?

11 MEMBER SKILLMAN: And to the credit of 12 NuScale, the crane is a massive crane. It is 13 encapsulated so it can't fall. It rides on rails 14 overhead. It's qualified for 130 percent of its 15 maximum load. Its maximum load is the 734-ton module.

16 I understand all of that.

17 There's still the notion that a single 18 failure-proof crane under NUREG-0554 and under heavy 19 lifting, which is NUREG-0612. I'm not sure that 20 that's a sufficient argument to say we're not going to 21 do cask drop, we're not going to do module drop, and 22 everything is going to be fine.

23 MEMBER BLEY: And we are coming to this in 24 Chapters 9, and 15, and 19.

25 MEMBER SKILLMAN: And 6 and 9, yes, sir.

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86 1 MEMBER BLEY: Yes.

2 MEMBER CORRADINI: Dennis, did you want to 3 --

4 MEMBER BROWN: Thank you, I just wanted to 5 make sure that I understood.

6 MEMBER BLEY: I did. Harold, you asked 7 about human factors engineering and ITAAC. Chapter 14 8 doesn't do human factors engineering but Tier 1 has 9 one ITAAC and that ITAAC is to ensure that the as-10 built configuration of the main control room HSI 11 matches the design HSI and that's the only one.

12 MEMBER RAY: Well and I understood there 13 is a consideration still that may be concluding that 14 no ITAAC are required.

15 I think one of the things that is perhaps 16 more common than not is the fact that although we are 17 not in a position where we can perhaps expect more 18 than we're being given, how we satisfy that, the 19 assurance needed going forward without ITAAC to cover 20 the things that we simply can't expect to understand 21 fully now is an open issue in a lot of places for me 22 here.

23 We keep saying well, we probably don't 24 need ITAAC here; we don't need it there. And yet 25 there's things that are left open that are to be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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87 1 validated down the road. And I just -- since we don't 2 know the criteria against which it will be validated 3 in the absence of ITAAC, it's a problematic issue in 4 general.

5 DR. GREEN: And this is related to one of 6 our open items. For the ITAAC that was just read, 7 some of the wording of that we believe needs to be 8 changed. There are RAIs that have gone out on that.

9 So there is some negotiating on that to make sure 10 we've got the correct scope of activities that are 11 included underneath that.

12 There has been discussion of a second 13 ITAAC but I believe we're moving away from that at 14 this point regarding the remote shutdown station. But 15 we've just got some -- we're waiting for some new 16 information on that. That would be more appropriate 17 to discuss later.

18 MEMBER RAY: It's a generic issue that 19 really goes to the question of what are we doing in a 20 design certification. And to the extent that we are 21 postponing, or necessarily -- and again, I don't mean 22 it to be a negative comment, other than to say well, 23 we're certifying a design and yet there's stuff to go 24 that we don't know how it's going to be answered.

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88 1 that covers it, fine; that puts it to bed because it's 2 part of the certification. But if you just say well 3 we're going to get to it later and we'll look at it 4 then, I'm troubled by that.

5 DR. GREEN: There's something I don't know 6 that I've made this clear throughout the presentation 7 but when we look at previous design certifications, 8 they've all relied on DAC previously. So at that 9 point, they submitted implementation plans. They said 10 this is how we will one day fill all these blanks.

11 That's not what NuScale did. They've designed their 12 control room and it is done and tested at this point.

13 So in one very big sense, we have a lot 14 more than we've ever seen before at this point.

15 MEMBER RAY: Okay.

16 DR. GREEN: Now, there are still some gaps 17 to be addressed and our intent is that these open 18 items should give us some regulatory assurance to make 19 sure we're covering the right sorts of things.

20 MEMBER RAY: Well, I did, as many of the 21 others of us did, but I chaired the subcommittee on 22 the last design certification. We did Amendment 6 to 23 AP1000. And I'm just -- it's different.

24 DR. GREEN: It is.

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89 1 mind around that.

2 DR. GREEN: Yes, no I understand. It took 3 us a while to wrap our head around it, too, because 4 when we reviewed the previous ones, we had the -- you 5 know we were looking at, essentially, IOUs. This is 6 how we will one day conduct this analysis. And that's 7 wonderful and you need a lot of details to make sure 8 that works.

9 But now we have both the methodology or 10 how they were conducting it and we were able to go an 11 audit as we went. So in that very real sense, we have 12 an awful lot more confidence that the outcomes of 13 these processes are what we hoped they would be.

14 So it's been -- you know obviously an 15 applicant picks their strategy but this one has been 16 easier for us to oversee in that respect.

17 MEMBER RAY: Well we probably should --

18 MEMBER CORRADINI: I think we should move 19 on.

20 MEMBER RAY: -- yes, move on. We just 21 need to bear in mind that understanding what was just 22 exchanged better on a generic basis is probably 23 something that would be useful.

24 DR. GREEN: Understood.

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90 1 not going to have a closed session. I'll turn it back 2 to the chairman. We'll go into break and go from 3 there.

4 Chairman, it's back to you with no closed 5 session.

6 CHAIRMAN RICCARDELLA: Yes, with no closed 7 session. So I guess we will adjourn this portion of 8 the meeting and take a break until 10:45. And after 9 that, we'll start letter writing.

10 MEMBER CORRADINI: We have a draft.

11 CHAIRMAN RICCARDELLA: We have a draft.

12 MEMBER REMPE: So we don't need a 13 transcriber for that, right? We're done.

14 MEMBER CORRADINI: We have it as one of 15 the things in the schedule before lunch.

16 CHAIRMAN RICCARDELLA: I understand.

17 MEMBER CORRADINI: Okay.

18 CHAIRMAN RICCARDELLA: But the question is 19 we don't need any more transcription.

20 MEMBER CORRADINI: No, not that I'm aware 21 of.

22 (Whereupon, the above-entitled matter went 23 off the record at 10:19 a.m.)

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Safety Evaluation with Open Items:

Ch 13, Conduct of Operations NuScale Design Certification Application Review ACRS Full Committee Meeting March 7, 2019

NRC Staff Review Team

• Technical Staff Presenters Maurin Scheetz, NRR - DCA Sections 13.1, 13.2, 13.5 Amanda Marshall, NSIR - DCA Section 13.3 Prosanta Chowdhury, NRO - DCA Section 13.4

• Project Managers Greg Cranston - Lead Project Manager Prosanta Chowdhury - Chapter 13 Project Manager

• Staff presented SER with Open Items to ACRS subcommittee on January 23, 2019 Note: Review is based on revision 1 of the DCA March 7, 2019 Chapter 13 Conduct of Operations 2

Technical Topics Section 13.1 - Organizational Structure Scope of Review

• The purpose of this section is to provide assurance that the applicant has established acceptable COL Information Items pertaining to the corporate-level management, technical support and onsite operating organizations necessary for the safe design, construction, testing and operation of the nuclear plant, including training and qualification requirements. That is, the COL applicant will have the necessary managerial and technical resources to support the plant staff in construction, operation, maintenance, and in the event of an emergency.

Conclusion

• The staff has reviewed DCA Part 2, Tier 2, Section 13.1, Organization Structure, and determined that applicants approach for COL Items 13.1-1 through 13.1-3 describing the corporate-level management and technical support organization, and the onsite operating organization, is acceptable to meet all applicable requirements. There are no Open Items.

March 7, 2019 Chapter 13 Conduct of Operations 3

Technical Topics Section 13.2 - Training Scope of Review

• The purpose of this section is to provide assurance that the applicant has established acceptable COL Information Items pertaining to a description of, and schedule for, (1) the licensed operator training program for reactor operators and senior reactor operators, including the licensed operator requalification program, and (2) the training program for the nonlicensed plant staff.

Conclusion

• The staff has reviewed DCA Part 2, Tier 2, Section 13.2, Training, and determined that applicants approach for COL Items 13.2-1 and COL 13.2-2 pertaining to a description and schedule of training programs for licensed and non-licensed staff is acceptable. There are no Open Items.

March 7, 2019 Chapter 13 Conduct of Operations 4

Technical Topics Section 13.3 - Emergency Planning Scope of Review

• The purpose of this section is to address those design features, facilities, functions, and equipment that are technically relevant to the design, that are not site specific, and that affect some aspect of emergency planning (EP) or the capability of a licensee to cope with plant emergencies. The applicant may choose the extent to which the application includes EP features to be reviewed as part of the design certification.

Focus Areas

• Technical Support Center (TSC); Emergency Response Data System; TSC Engineering Workstations; Decontamination Facilities; Process Sampling System (Post-Accident Sampling function); Operations Support Center (COL Item 13.3-1); Emergency Operations Facility (COL Item 13.3-2); Emergency Plan (COL Item 13.3-3); EP ITAAC (COL Item 14.3-1)

Open Item 13.3 Process Sampling System (PSS)

• The capability to obtain a post-accident sample is an interface item between SRP Section 9.3.2, Process Sampling Systems, and SRP Section 13.3. If the PSS is determined to be acceptable as a means for obtaining a post-accident sample in accordance with 10 CFR 50.34(f)(2)(vii) and (viii), then this open item will be resolved.

Conclusion

• With the exception of Open Item 13.3-1, the staff concludes, on the basis of its review of the EP design-related features included in the DCA, that the applicant has met the applicable regulatory requirements.

March 7, 2019 Chapter 13 Conduct of Operations 5

Technical Topics Section 13.4 - Operational Programs Scope of Review

• COL applicants are required by 10 CFR 52.79 to describe operational programs, but similar requirements do not exist for DCAs.

• The applicant provided COL Item 13.4-1 stating that a COL applicant that references the NuScale Power Plant design certification will provide site-specific information, including implementation schedule, for operational programs.

Conclusion

• The staff has reviewed DCA Part 2 Tier 2, Section 13.4, Operational Programs, and determined that COL Item 13.4-1 is acceptable because the applicant appropriately directs the COL applicant to develop operational programs, consistent with the list in SRP Section 13.4, draft Rev. 4. There are no Open Items.

March 7, 2019 Chapter 13 Conduct of Operations 6

Technical Topics Section 13.5 - Plant Procedures Scope of Review

• The purpose of this section is for the NRC staff to review the acceptability of COL information items for descriptions of plant procedures and the establishment of a program for development and implementation of plant procedures. The staff also reviewed the technical adequacy of the NuScale Generic Technical Guidelines (GTGs) for use as a basis for development of COL applicant Plant Specific Technical Guidelines (P-STGs).

Open Items

• The acceptability of the NuScale GTGs for use as a basis for the development of COL applicant P-STGs is contingent upon the achievement of satisfactory results from Integrated System Validation (ISV) testing and validation activities and the subsequent incorporation of any necessary changes to the GTGs and the associated Post Accident Monitoring (PAM) variables. This is being tracked as Open Item 13.5-1.

Conclusion

• The staff has reviewed DCA Part 2, Tier 2, Section 13.5, Plant Procedures, and determined that the COL Items 13.5-1 through 13.5-5, 13.5-7, and 13.5-8 for plant procedures are appropriate and acceptable. The staff will make a conclusion on the GTGs at a later time.

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Safety Evaluation with Open Items:

Ch 18, Human Factors Engineering NuScale Design Certification Application Review ACRS Full Committee Meeting March 7, 2019

NRC Staff Review Team

• Technical Staff Dr. Amy DAgostino, RES Dr. Brian Green, NRR Lauren Nist, NRR Maurin Scheetz, NRR

• Project Managers Greg Cranston - Lead Project Manager Prosanta Chowdhury - Chapter 18 Project Manager

• Staff presented SER with Open Items to ACRS subcommittee on January 23, 2019 Note: Review is based on revision 1 of the DCA March 7, 2019 Chapter 18 Human Factors Engineering 2

Purpose and Scope

• Purpose

• Verify that the Human Factors Engineering (HFE) design of the NuScale Standard Plant control room supports operators in the safe operation of the plant

• Verify there is sufficient technical justification for a new, design-specific staffing regulation

• Scope

• DCA Part 2, Tier 2, Ch 18 as well as parts of Ch 7, 15, and 19

• HFE technical reports

• DCA Part 2, Tier 1, Section 3.15

• Audits of HFE analyses, SPV testing, and ISV testing March 7, 2019 Chapter 18 Human Factors Engineering 3

Areas of Interest

• Potential human performance issues specific to SMRs are identified in NUREG/CR-7126 and NUREG/CR-7202

• The staff considered the effects of the following on human performance and safe plant operation:

• Multi-unit operation from a single operator workstation and from a single control room

• Relatively higher amount of automation

• Novel Human-System Interface (HSI) design features March 7, 2019 Chapter 18 Human Factors Engineering 4

Open Items

• The Phase 2 SER contains 23 open items for the following topics:

• Review of the applicants V&V results (19 open items)

• Scope of the HFE ITAAC and documentation of the HFE activities to be performed by the licensee (1 open item)

• Evaluate whether changes to Ch 7 related to remote shutdown affect Ch 18 and verify accuracy of the SER (1 open item)

• Confirm conclusions in SER Chapters 7, 15 and 19 about the treatment of important human actions are consistent with those in Ch 18 (1 open item)

• Ensure that HFE reports are incorporated by reference into Tier 2 (1 open item)

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Conclusion

• The results of the Staffing Plan Validation (SPV) testing support the applicants proposed staffing plan. The staff will confirm the Integrated System Validation (ISV) results also support the staffing plan or that any changes have been made if needed.

• Based on the staffs observations of the ISV test, the staff expects that the ISV results will provide evidence that the HFE design adequately supports plant personnel in safely operating the plant.

• The open items identified in the safety evaluation need to be resolved for the staff to find that the HFE design complies with all NRC requirements related to HFE and thus that the HFE design supports personnel in the safe operation of the plant.

March 7, 2019 Chapter 18 Human Factors Engineering 6