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| number = ML18058A807 | | number = ML18058A807 | ||
| issue date = 03/27/2018 | | issue date = 03/27/2018 | ||
| title = Public Meeting Summary | | title = Public Meeting Summary NuScale Conference Call November 29, 2017 | ||
| author name = Vera M | | author name = Vera M | ||
| author affiliation = NRC/NRO/DNRL/LB1 | | author affiliation = NRC/NRO/DNRL/LB1 | ||
| addressee name = Lee | | addressee name = Lee S | ||
| addressee affiliation = NRC/NRO/DNRL/LB1 | | addressee affiliation = NRC/NRO/DNRL/LB1 | ||
| docket = 05200048 | | docket = 05200048 | ||
Line 15: | Line 15: | ||
=Text= | =Text= | ||
{{#Wiki_filter:March 27, 2018 | {{#Wiki_filter:March 27, 2018 MEMORANDUM TO: Samuel S. Lee, Chief Licensing Branch 1 Division of New Reactor Licensing Office of New Reactors FROM: Marieliz Vera, Project Manager /RA/ | ||
Licensing Branch 1 Division of New Reactor Licensing Office of New Reactors | |||
MEMORANDUM TO: | |||
FROM: Marieliz Vera, Project Manager | |||
==SUBJECT:== | ==SUBJECT:== | ||
==SUMMARY== | ==SUMMARY== | ||
OF THE NOVEMBER 29, 2017, CATEGORY 1 PUBLIC TELECONFERENCE WITH NUSCALE POWER, LLC DESIGN CERTIFICATION APPLICATION REQUEST FOR ADDITIONAL INFORMATION NOS. 8979, 8981, 8983, 8971, 8973, AND 8974 RESPONSES FOR CHAPTER 3, | OF THE NOVEMBER 29, 2017, CATEGORY 1 PUBLIC TELECONFERENCE WITH NUSCALE POWER, LLC DESIGN CERTIFICATION APPLICATION REQUEST FOR ADDITIONAL INFORMATION NOS. 8979, 8981, 8983, 8971, 8973, AND 8974 RESPONSES FOR CHAPTER 3, DESIGN OF STRUCTURES, SYSTEMS, COMPONENTS AND EQUIPMENT The U.S. Nuclear Regulatory Commission (NRC) held a Category 1 public teleconference on November 29, 2017, to discuss NuScale Power, LLCs (NuScale) Design Certification, responses to Request for Additional Information (RAI) Nos. 8979, 8981, 8983, 8971, 8973, and 8974 Chapter 3, Design of Structures, Systems, Components, and Equipment. Participants included personnel from NuScale and no members of the public. | ||
The public meeting notice can be found in the Agencywide Documents Access and Management Systems (ADAMS) under Accession No. ML17320A099. This meeting notice was also posted on the NRC public Website. | |||
The U.S. Nuclear Regulatory Commission (NRC) held a Category 1 public teleconference on November 29, 2017, to discuss NuScale Power, | |||
8974 Chapter 3, | |||
Participants included personnel from NuScale and no members of the public. | |||
The public meeting notice can be found in the Agencywide Documents Access and Management Systems (ADAMS) under Accession No. ML17320A099. This meeting notice was also posted on the NRC public Website. | |||
The meeting agenda and list of participants can be found in Enclosures 1 and 2, respectively. | The meeting agenda and list of participants can be found in Enclosures 1 and 2, respectively. | ||
The technical issues discussed are included in Enclosure 3. | The technical issues discussed are included in Enclosure 3. | ||
CONTACT: Marieliz Vera, NRO/DNRL 301-415-5861 | |||
S. Lee 2 Summary: | |||
The purpose of this meeting was to discuss the RAI responses for RAI Nos. 8979; 8981; 8983; 8971, Question No. 3.8.4-12; 8973, Question No. 3.8.4-18; and RAI 8974, Question Nos. 3.8.4-21 and 3.8.4-23 (ADAMS Accession Nos. ML17272A119, ML17272A411, ML17268A251, ML17276B170, and ML17276B887 respectively). The comments presented by the NRC staff (Enclosure 3) for RAI Nos. 8979, 8981, and 8983 were discussed with NuScale staff. Response comments will be addressed by NuScale supplementing the RAI response. On RAI No. 8979 question 03.03.01-2 NuScale clarified the Seismic Category II portion of the control building was analyzed along with the Seismic Category I portion of the structure. They also identified that the information is stated on RAI 8975, Question 03.08.04-25 (ML17297B940) therefore that question does not need to be supplemented. The second half of the meeting the NRC staff discussed the feedback for RAI Nos. 8971, 8973, and 8974. The feedback will be addressed by NuScale supplementing the RAI responses, with a supplement for Question 3.8.4-12, taking longer than 30 days. | |||
Docket No. 52-048 | |||
==Enclosures:== | |||
: 1. Meeting Agenda | |||
: 2. List of Attendees | |||
: 3. Comments presented by NRC staff cc w/encl.: DC NuScale Power, LLC Listserv | |||
ML18058A807 *via email NRC002 OFFICE NRO/DNRL/LB1: PM NRO/DNRL/LB1: LA NRO/DNRL/LB1: PM NAME MVera MMoore MVera DATE 2/26/2018 3/01/2018 3/27/2018 U.S. NUCLEAR REGULATORY COMMISSION CATEGORY 1 PUBLIC TELECONFERENCE WITH NUSCALE POWER, LLC DESIGN CERTIFICATION APPLICATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION 8979, 8981, 8983, 8971, 8973, AND 8974 CHAPTER 3, DESIGN OF STRUCTURES, SYSTEMS, COMPONENTS AND EQUIPMENT November 29, 2017 1:00 p.m. - 3:00 p.m. | |||
: 1. Meeting | AGENDA Public Meeting 1:00-1:10 Introductions and identification of topics 1:10-2:30 Discussion of the Responses to RAIs 8979, 8981, 8983, 8971, 8973 and 8974 2:30-2:45 Public comments 2:45-3:00 Closed portion Enclosure 1 | ||
: 2 | |||
: 3 | |||
U.S. NUCLEAR REGULATORY COMMISSION CATEGORY 1 PUBLIC TELECONFERENCE WITH NUSCALE POWER, LLC DESIGN CERTIFICATION APPLICATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION 8979, 8981, 8983, 8971, 8973, AND 8974 CHAPTER 3, DESIGN OF STRUCTURES, SYSTEMS, COMPONENTS AND EQUIPMENT LIST OF ATTENDEES November 29, 2017 NAME AFFILIATION Marieliz Vera U.S. Nuclear regulatory Commission (NRC) | |||
Manas Chakravorty NRC Robert Roche NRC Timothy Lupold NRC George Wang NRC John Ma NRC Marty Bryan NuScale Power, LLC (NuScale) | |||
Kyra Perkins NuScale Josh Parker NuScale Craig Harwood NuScale Andre LEplattenier NuScale Wayne Massie NuScale Tom Ryan NuScale Basheer Sweidan NuScale Hadi Razavi NuScale Jeremy Aartun NuScale Enclosure 2 | |||
U.S. NUCLEAR REGULATORY COMMISSION CATEGORY 1 PUBLIC TELECONFERENCE WITH NUSCALE POWER, LLC DESIGN CERTIFICATION APPLICATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION 8979, 8981, 8983, 8971, 8973, AND 8974 CHAPTER 3, DESIGN OF STRUCTURES, SYSTEMS, COMPONENTS, AND EQUIPMENT Request for Additional Information No. 8979, Question 03.03.01-1: | |||
: a. Acceptable. | |||
: a. Acceptable. b. Acceptable. c. Editorial comment: | : b. Acceptable. | ||
: c. Editorial comment: final safety analysis report (FSAR) Sections 3.3.1.2 and 3.3.2.2 define the gust-effect factor to be 0.85 or greater. The staff requests the applicant to delete wording or greater in FSAR to be consistent with the Request for Additional Information (RAI) response. | |||
: d. Acceptable. | |||
RAI 8979, Question 03.03.01-2: | RAI 8979, Question 03.03.01-2: | ||
Editorial comment: | Editorial comment: The applicants response is acceptable to the staff. The staff requests the applicant to include using the same methodology as the Seismic Category I portions of the CRB for the Seismic Category II portions of the CRB in FSAR Section 3.7.2.8. | ||
RAI 8981, Question 03.04.02-1: | RAI 8981, Question 03.04.02-1: | ||
: a. Editorial comment: | : a. Editorial comment: The applicants response is acceptable to the staff. The staff requests the applicant to include these analysis procedures into the FSAR Section 3.4.2. | ||
RAI 8983, Question 03.05.03-2: | : b. Acceptable. | ||
: a. Acceptable. b. Acceptable. c. Based on the recommendation of Equation 2-8 in the Bechtel Topical Report, BC-TOP-9A, Rev. 2 and precedent application review, 25 percent increase shall also apply to the steel target thickness determined by the Stanford Formula. The NRC staff requests the applicant to evaluate and provide 25 percent increase for the steel target thickness determined by the Stanford Formula in FSAR otherwise the justification shall be | RAI 8983, Question 03.05.03-2: | ||
: a. Acceptable. | |||
: b. Acceptable. | |||
: c. Based on the recommendation of Equation 2-8 in the Bechtel Topical Report, BC-TOP-9A, Rev. 2 and precedent application review, 25 percent increase shall also apply to the steel target thickness determined by the Stanford Formula. The NRC staff requests the applicant to evaluate and provide 25 percent increase for the steel target thickness determined by the Stanford Formula in FSAR otherwise the justification shall be | |||
provided. The staff also request the applicant to confirm if the larger thickness resulting from the use of either the BRL or Stanford formula will be used in the design. | |||
: d. Acceptable. | |||
RAI 8971, Question 3.8.4-12: | |||
In its response, the applicant clarified that the jet impingement, pipe break reaction, and missile impact loads are to be addressed by the combined license (COL) applicant as per COL items 3.6-2 and COL item 3.6-3. However, it is not clear to the staff how it is ensured that the design demands considered in the standard plant Reactor Building (RXB) bound the aforementioned loads when combined with other loads as per Load Combinations 13 and 17 in FSAR Tables 3.8.4-1 Concrete Design Load Combinations and 3.8.4-2 Steel Design Load Combinations, respectively. Therefore, the staff request the applicant to provide the technical basis that demonstrate the adequacy of the RXB to withstand the demands from Load Combinations 13 and 17. Additionally, the NRC staff requests the applicant to clarify the locations in the structures where these loads are expected to occur and clarify whether the COL applicant is to combine the jet impingement, pipe break reaction, and missile impact loads with the standard design seismic demand or the site-specific seismic demand. Further, the NRC staff requests the applicant to address the comparison of the site-specific loadings (as per load combinations 13 and 17) with the standard design loadings in the existing COL item 3.8-2 or a new COL item. | |||
Based on the review above, RAI 8971, Question 3.8.4-12 will be tracked as an Open Item. | |||
RAI 8973, Question 3.8.4-18: | |||
Per the August 17, 2017, public meeting, the applicant committed to provide a description of the seismic input, analysis, and design process for partition walls. The NRC staff request applicant to address the aforementioned aspects in their response. | |||
Based on the review above, RAI 8973, Question 3.8.4-18 will be tracked as an Open Item. | |||
RAI 8974, Question 3.8.4-21: | |||
In its response and respective proposed FSAR markups the applicant indicated that the capacity of the lug restraint system is 4,600 kips. The staff request the applicant to clarify in their response and respective FSAR markups, how the 4,600 is kips is calculated. | |||
Based on the review above, RAI 8974, Question 3.8.4-21 will be tracked as an Open Item. | |||
RAI 8974, Question 3.8.4-23: | |||
The staff could not verify the markups associated with the in-structure response spectra (ISRS) figures in RAI response against the respective ISRS figures in FSAR, Revision 0. Please clarify whether the ISRS Figure numbers in FSAR, Revision 0 have changed and if so provide the ISRS figures as part of the RAI response. | |||
Additionally, the applicant did not augment the COL item 3.8-2 to address comparison of seismic forces and moments, deformations, and seismic stability of the structures. As per COL item 3.8-2, the comparison of ISRS may be used as a surrogate for comparison of forces and moments. However the reliance on the ISRS comparison only is not acceptable to the staff. As | |||
shown in the response to RAI 8900, Question 3.7.1-1, the ISRS and structural demands are obtained from different sets of analysis cases. As per the response to RAI 8900 - Question 3.7.1-1, the cases used to calculate the ISRS are based on OBE damping (i.e. 4 percent damping) and the cases used to calculate the structural demands are based on SSE damping (i.e. 7 percent damping). Therefore, the staff request the applicant to augment the COL item 3.8-2 to address comparison of seismic forces and moments, deformations, and seismic stability of the structures. | |||
Regarding the response to item (c), for the spent fuel storage racks, topical report (TR)-0816-49833 refers to ISRS at multiple elevations (i.e. El 24 ft and El 50 ft) which are enveloped for use as loading for the spent fuel rack analyses. Further, TR-0816-49833 indicates that the ISRS are obtained from the SSI analyses performed for the CSDRS and CSDRS-HF. The response to Questions 3.8.4-23 refers to the ISRS at El 25 ft (i.e. Figure 3.7.2-108 in the RAI response) as addressing the location for the spent fuel storage racks. The staff request the applicant to clarify whether the ISRS in Figure 3.7.2-108 is the top of concrete/liner ISRS used as input to the analyses documented in TR-0816-49833. If not, the NRC staff request the applicant to augment the COL item 3.8-2 to include the top of concrete/liner ISRS thats used as input to the TR-0816-49833 analyses. | |||
Based on the review above, RAI 8974, Question 3.8.4-23 will be tracked as an Open Item.}} | Based on the review above, RAI 8974, Question 3.8.4-23 will be tracked as an Open Item.}} |
Latest revision as of 12:14, 3 February 2020
ML18058A807 | |
Person / Time | |
---|---|
Site: | NuScale |
Issue date: | 03/27/2018 |
From: | Vera M NRC/NRO/DNRL/LB1 |
To: | Samson Lee NRC/NRO/DNRL/LB1 |
Vera M | |
References | |
Download: ML18058A807 (8) | |
Text
March 27, 2018 MEMORANDUM TO: Samuel S. Lee, Chief Licensing Branch 1 Division of New Reactor Licensing Office of New Reactors FROM: Marieliz Vera, Project Manager /RA/
Licensing Branch 1 Division of New Reactor Licensing Office of New Reactors
SUBJECT:
SUMMARY
OF THE NOVEMBER 29, 2017, CATEGORY 1 PUBLIC TELECONFERENCE WITH NUSCALE POWER, LLC DESIGN CERTIFICATION APPLICATION REQUEST FOR ADDITIONAL INFORMATION NOS. 8979, 8981, 8983, 8971, 8973, AND 8974 RESPONSES FOR CHAPTER 3, DESIGN OF STRUCTURES, SYSTEMS, COMPONENTS AND EQUIPMENT The U.S. Nuclear Regulatory Commission (NRC) held a Category 1 public teleconference on November 29, 2017, to discuss NuScale Power, LLCs (NuScale) Design Certification, responses to Request for Additional Information (RAI) Nos. 8979, 8981, 8983, 8971, 8973, and 8974 Chapter 3, Design of Structures, Systems, Components, and Equipment. Participants included personnel from NuScale and no members of the public.
The public meeting notice can be found in the Agencywide Documents Access and Management Systems (ADAMS) under Accession No. ML17320A099. This meeting notice was also posted on the NRC public Website.
The meeting agenda and list of participants can be found in Enclosures 1 and 2, respectively.
The technical issues discussed are included in Enclosure 3.
CONTACT: Marieliz Vera, NRO/DNRL 301-415-5861
S. Lee 2 Summary:
The purpose of this meeting was to discuss the RAI responses for RAI Nos. 8979; 8981; 8983; 8971, Question No. 3.8.4-12; 8973, Question No. 3.8.4-18; and RAI 8974, Question Nos. 3.8.4-21 and 3.8.4-23 (ADAMS Accession Nos. ML17272A119, ML17272A411, ML17268A251, ML17276B170, and ML17276B887 respectively). The comments presented by the NRC staff (Enclosure 3) for RAI Nos. 8979, 8981, and 8983 were discussed with NuScale staff. Response comments will be addressed by NuScale supplementing the RAI response. On RAI No. 8979 question 03.03.01-2 NuScale clarified the Seismic Category II portion of the control building was analyzed along with the Seismic Category I portion of the structure. They also identified that the information is stated on RAI 8975, Question 03.08.04-25 (ML17297B940) therefore that question does not need to be supplemented. The second half of the meeting the NRC staff discussed the feedback for RAI Nos. 8971, 8973, and 8974. The feedback will be addressed by NuScale supplementing the RAI responses, with a supplement for Question 3.8.4-12, taking longer than 30 days.
Docket No.52-048
Enclosures:
- 1. Meeting Agenda
- 2. List of Attendees
ML18058A807 *via email NRC002 OFFICE NRO/DNRL/LB1: PM NRO/DNRL/LB1: LA NRO/DNRL/LB1: PM NAME MVera MMoore MVera DATE 2/26/2018 3/01/2018 3/27/2018 U.S. NUCLEAR REGULATORY COMMISSION CATEGORY 1 PUBLIC TELECONFERENCE WITH NUSCALE POWER, LLC DESIGN CERTIFICATION APPLICATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION 8979, 8981, 8983, 8971, 8973, AND 8974 CHAPTER 3, DESIGN OF STRUCTURES, SYSTEMS, COMPONENTS AND EQUIPMENT November 29, 2017 1:00 p.m. - 3:00 p.m.
AGENDA Public Meeting 1:00-1:10 Introductions and identification of topics 1:10-2:30 Discussion of the Responses to RAIs 8979, 8981, 8983, 8971, 8973 and 8974 2:30-2:45 Public comments 2:45-3:00 Closed portion Enclosure 1
U.S. NUCLEAR REGULATORY COMMISSION CATEGORY 1 PUBLIC TELECONFERENCE WITH NUSCALE POWER, LLC DESIGN CERTIFICATION APPLICATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION 8979, 8981, 8983, 8971, 8973, AND 8974 CHAPTER 3, DESIGN OF STRUCTURES, SYSTEMS, COMPONENTS AND EQUIPMENT LIST OF ATTENDEES November 29, 2017 NAME AFFILIATION Marieliz Vera U.S. Nuclear regulatory Commission (NRC)
Manas Chakravorty NRC Robert Roche NRC Timothy Lupold NRC George Wang NRC John Ma NRC Marty Bryan NuScale Power, LLC (NuScale)
Kyra Perkins NuScale Josh Parker NuScale Craig Harwood NuScale Andre LEplattenier NuScale Wayne Massie NuScale Tom Ryan NuScale Basheer Sweidan NuScale Hadi Razavi NuScale Jeremy Aartun NuScale Enclosure 2
U.S. NUCLEAR REGULATORY COMMISSION CATEGORY 1 PUBLIC TELECONFERENCE WITH NUSCALE POWER, LLC DESIGN CERTIFICATION APPLICATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION 8979, 8981, 8983, 8971, 8973, AND 8974 CHAPTER 3, DESIGN OF STRUCTURES, SYSTEMS, COMPONENTS, AND EQUIPMENT Request for Additional Information No. 8979, Question 03.03.01-1:
- a. Acceptable.
- b. Acceptable.
- c. Editorial comment: final safety analysis report (FSAR) Sections 3.3.1.2 and 3.3.2.2 define the gust-effect factor to be 0.85 or greater. The staff requests the applicant to delete wording or greater in FSAR to be consistent with the Request for Additional Information (RAI) response.
- d. Acceptable.
RAI 8979, Question 03.03.01-2:
Editorial comment: The applicants response is acceptable to the staff. The staff requests the applicant to include using the same methodology as the Seismic Category I portions of the CRB for the Seismic Category II portions of the CRB in FSAR Section 3.7.2.8.
RAI 8981, Question 03.04.02-1:
- a. Editorial comment: The applicants response is acceptable to the staff. The staff requests the applicant to include these analysis procedures into the FSAR Section 3.4.2.
- b. Acceptable.
RAI 8983, Question 03.05.03-2:
- a. Acceptable.
- b. Acceptable.
- c. Based on the recommendation of Equation 2-8 in the Bechtel Topical Report, BC-TOP-9A, Rev. 2 and precedent application review, 25 percent increase shall also apply to the steel target thickness determined by the Stanford Formula. The NRC staff requests the applicant to evaluate and provide 25 percent increase for the steel target thickness determined by the Stanford Formula in FSAR otherwise the justification shall be
provided. The staff also request the applicant to confirm if the larger thickness resulting from the use of either the BRL or Stanford formula will be used in the design.
- d. Acceptable.
RAI 8971, Question 3.8.4-12:
In its response, the applicant clarified that the jet impingement, pipe break reaction, and missile impact loads are to be addressed by the combined license (COL) applicant as per COL items 3.6-2 and COL item 3.6-3. However, it is not clear to the staff how it is ensured that the design demands considered in the standard plant Reactor Building (RXB) bound the aforementioned loads when combined with other loads as per Load Combinations 13 and 17 in FSAR Tables 3.8.4-1 Concrete Design Load Combinations and 3.8.4-2 Steel Design Load Combinations, respectively. Therefore, the staff request the applicant to provide the technical basis that demonstrate the adequacy of the RXB to withstand the demands from Load Combinations 13 and 17. Additionally, the NRC staff requests the applicant to clarify the locations in the structures where these loads are expected to occur and clarify whether the COL applicant is to combine the jet impingement, pipe break reaction, and missile impact loads with the standard design seismic demand or the site-specific seismic demand. Further, the NRC staff requests the applicant to address the comparison of the site-specific loadings (as per load combinations 13 and 17) with the standard design loadings in the existing COL item 3.8-2 or a new COL item.
Based on the review above, RAI 8971, Question 3.8.4-12 will be tracked as an Open Item.
RAI 8973, Question 3.8.4-18:
Per the August 17, 2017, public meeting, the applicant committed to provide a description of the seismic input, analysis, and design process for partition walls. The NRC staff request applicant to address the aforementioned aspects in their response.
Based on the review above, RAI 8973, Question 3.8.4-18 will be tracked as an Open Item.
RAI 8974, Question 3.8.4-21:
In its response and respective proposed FSAR markups the applicant indicated that the capacity of the lug restraint system is 4,600 kips. The staff request the applicant to clarify in their response and respective FSAR markups, how the 4,600 is kips is calculated.
Based on the review above, RAI 8974, Question 3.8.4-21 will be tracked as an Open Item.
RAI 8974, Question 3.8.4-23:
The staff could not verify the markups associated with the in-structure response spectra (ISRS) figures in RAI response against the respective ISRS figures in FSAR, Revision 0. Please clarify whether the ISRS Figure numbers in FSAR, Revision 0 have changed and if so provide the ISRS figures as part of the RAI response.
Additionally, the applicant did not augment the COL item 3.8-2 to address comparison of seismic forces and moments, deformations, and seismic stability of the structures. As per COL item 3.8-2, the comparison of ISRS may be used as a surrogate for comparison of forces and moments. However the reliance on the ISRS comparison only is not acceptable to the staff. As
shown in the response to RAI 8900, Question 3.7.1-1, the ISRS and structural demands are obtained from different sets of analysis cases. As per the response to RAI 8900 - Question 3.7.1-1, the cases used to calculate the ISRS are based on OBE damping (i.e. 4 percent damping) and the cases used to calculate the structural demands are based on SSE damping (i.e. 7 percent damping). Therefore, the staff request the applicant to augment the COL item 3.8-2 to address comparison of seismic forces and moments, deformations, and seismic stability of the structures.
Regarding the response to item (c), for the spent fuel storage racks, topical report (TR)-0816-49833 refers to ISRS at multiple elevations (i.e. El 24 ft and El 50 ft) which are enveloped for use as loading for the spent fuel rack analyses. Further, TR-0816-49833 indicates that the ISRS are obtained from the SSI analyses performed for the CSDRS and CSDRS-HF. The response to Questions 3.8.4-23 refers to the ISRS at El 25 ft (i.e. Figure 3.7.2-108 in the RAI response) as addressing the location for the spent fuel storage racks. The staff request the applicant to clarify whether the ISRS in Figure 3.7.2-108 is the top of concrete/liner ISRS used as input to the analyses documented in TR-0816-49833. If not, the NRC staff request the applicant to augment the COL item 3.8-2 to include the top of concrete/liner ISRS thats used as input to the TR-0816-49833 analyses.
Based on the review above, RAI 8974, Question 3.8.4-23 will be tracked as an Open Item.