ML19088A292

Transcript of the Advisory Committee on Reactor Safeguards Nuscale Subcommittee Meeting - March 20, 2019

ML19088A292
Person / Time
Issue date:	03/20/2019
From:	Snodderly M R Advisory Committee on Reactor Safeguards
To:
Snodderly M R
References
NRC-0218
Download: ML19088A292 (312)

Text

Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION Title: Advisory Committee on Reactor Safeguards NuScale SubcommitteeDocket Number:(n/a)Location:Rockville, Maryland

Date:Wednesday, March 20, 2019Work Order No.:NRC-0218 Pages 1-NEAL R. GROSS AND CO., INC.

Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.

Washington, D.C. 20005(202)234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005

-3701 www.nealrgross.com 1 1 2 3 DISCLAIMER 4 5 6 UNITED STATES NUCLEAR REGULATORY COMMISSION'S 7 ADVISORY COMMITTE E ON REACTOR SAFEGUARDS 8 9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.

15 16 This t ranscript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.

19 20 21 22 23 1 UNITED STATES OF AMERICA 1 NUCLEAR REGULATORY COMMISSION 2+ + + + +3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4 (ACRS)5+ + + + +6 NuSCALE SUBCOMMITTEE 7+ + + + +8 WEDNESDAY 9 MARCH 20, 2019 10+ + + + +11 ROCKVILLE, MARYLAND 12+ + + + +13 The Subcommittee met at the Nuclear 14 Regulatory Commission, Two White Flint North, Room 15 T3B50, 11545 Rockville Pike, at 8:30 a.m., Joy L.

16 Rempe and Gordon R. Skillman, Co-Chairs, presiding.

17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 2 COMMITTEE MEMBERS:

1 JOY L. REMPE, Co-Chair 2 GORDON R. SKILLMAN, Co-Chair 3 RONALD G. BALLINGER, Member 4 DENNIS BLEY, Member 5 CHARLES H. BROWN, JR., Member 6 MICHAEL L. CORRADINI, Member 7 VESNA B. DIMITRIJEVIC, Member 8 WALTER L. KIRCHNER, Member 9 JOSE MARCH-LEUBA, Member 10 HAROLD B. RAY, Member 11 PETER RICCARDELLA, Member 12 MATTHEW W. SUNSERI, Member 13 14 ACRS CONSULTANT:

15 STEPHEN SCHULTZ 16 17 DESIGNATED FEDERAL OFFICIAL:

18 MIKE SNODDERLY 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 3 CONTENTS 1 Opening Remarks.................4 2 Overview of Chapter 9, "Auxiliary Systems," 3 NuScale Design Certification Application....10 4 Chapter 9, "Auxiliary Systems," 5 Safety Evaluation with Open Items........87 6 Overview of Chapter 16, "Technical Specifications" 7NuScale Design Certification Application...117 8 Chapter 16, "Technical Specifications" 9 Safety Evaluation with Open Items.......151 10 Adjourn....................187 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 4 P R O C E E D I N G S 1 8:30 a.m.2CO-CHAIR REMPE: Good morning, this 3meeting will now come to order. This is a meeting of 4 NuScale Subcommittee of the Advisory Committee on 5Reactor Safeguards. I'm Joy Rempe, and I'll be co-6 chairing the Subcommittee with Dick Skillman and Mike 7 Corradini.

8 Members in attendance today are Vesna 9 Dimitrijevic, Charlie Brown, let's see, I guess Ron 10 Ballinger, Jose -- sometimes known as Roland -- Jose 11 March-Leuba, Harold Ray, Dick Skillman, Mike 12 Corradini, Dennis Bley, and Walter Kirchner.

13 In addition, we're joined by our 14consultant, Steven -- oh, excuse me. Matt Sunseri and 15 Pete Riccardella. I forgot my colleagues up here at 16the front table. We also today joined by our 17 consultant, Steven Schultz. And we may be expecting 18 to be joined later today by Margaret Chu.

19 Mike Snodderly is the Designated Federal 20Official for this meeting. And today the Subcommittee 21 will review the staff's evaluation of Chapter 9, 22 Auxiliary Systems, and Chapter 16, Technical 23 Specifications of the NuScale Design Certification 24 Application.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 5 We also expect to hear from members of the 1 NRC staff, as well as representatives from NuScale.

2 They'll be briefing our subcommittee.

3 The ACRS was established by statute and is 4governed by the Federal Advisory Committees Act. The 5 rules for preparing today's meetings were announced in 6the Federal Register on March 18, 2019. It will be an 7 open, and possibly then a closed, meeting, as we will, 8 may close the meeting after the open portion to 9 discuss proprietary material.

10 And presenters can defer questions that 11 should not be answered in the public session to that 12time. And I'm going to ask for NuScale's help if some 13 of our questions during the open session do go beyond 14 what they should be and to just tell us you'd prefer 15 to wait.16 No written statement or request for making 17 an oral sta tement to the Subcommittee has been 18received by the public concerning this meeting. A 19 transcript of the meeting is being kept and will be 20 made available, as stated in the Federal Register 21 notice. 22 Therefore, we request that participants in 23 this meeting use the microphone that is located at the 24front of the public seating area. And they need to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 6 first identify themselves, as well as speak with 1 sufficient clarity and volume so that they can be 2 readily heard when they do make comments.

3 We have a bridge line that's been 4 established for the public to listen to this meeting.

5 And to minimize disturbance, that line is being kept 6in a listen-in only mode. To avoid disturbances, I 7 also want to request that attendees at this meeting 8 either turn off or mute their electronic devices.

9 And we're now going to proceed with this 10 meeting, and I'm going to call upon Scott Harris of 11 NuScale to start us off. Scott.

12 MR. HARRIS: Thank you. It's a pleasure 13 to be here today and present Chapter 9 on behalf of 14NuScale. My name is Scott Harris, I'm a supervisor 15 for the Mechanical Systems Group.

16 Just to give background on myself, I 17 graduated from Kansas State University with a degree 18in mechanical engineering. I started off my career as 19 a field engineer at Fort Calhoun Nuclear Station for 20 two years, and then transitioned to NuScale in 2012, 21 where I've been a member of the Mechanical Systems 22 Group ever since.

23 DR. NICHOL: My name is Corrie Nichol, I 24 have a PhD in mechanical engineering from Penn State.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 7 I spent 11 years as a research engineer at the Idaho 1 National Laboratory designing, among other things, 2 some of the remote handling equipment for the Yucca 3 Mountain Waste Package Welding Project. And now I'm 4 working for NuScale in the Remote Handling Group.

5MS. FOSAAEN: Good morning, Carrie 6 Fosaaen, I'm a supervisor of licensing at NuScale 7Power. I've been there for about three and a half 8years. Involved in Chapter 9 ever since I joined the 9 company. I graduated from Perdue University in 2008 10 with a nuclear engineering degree, and then in 2010 11 with a masters in health physics.

12MR. FIELDS: Good morning, I'm John 13Fields. I'm a nuclear nomad. I've been all over the 14 industry for 35 years here, so I'm not going to go 15into my degree and all that stuff. But all of that in 16 engineering and licensing.

17 MR. HARRIS: Just a high level review of 18 Chapter 9. It includes fuel storage handling, water 19 systems, HVAC, fire protection and other fire hazard 20 analysis.21 DR. NICHOL: So we're going to start off 22 by talking about spent fuel storage and handling, then 23 we'll talk about new fuel storage, spent fuel pool 24 cleanup and cooling system, the fuel handling 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 8 equipment, and the overhead heavy load handling.

1 So to start off the spent fuel racks, the 2design of the NuScale spent fuel racks prevents 3 criticality without regard to loading patterns or 4zones. The spent fuel pool itself is connected to the 5 ultimate heat sink, the operating pool of the 6 facility, which essentially means the volume is large.

7 The reason that's important is it prevents undetected 8 boron dilution in the pool.

9 Fuel management is controlled by 10 procedures, fuel storage and that sort of thing.

11 There are a couple tech specs related to fuel storage.

12 Tech spec 4.3 is fuel storage, tech spec 5.5.12 talks 13 about the neutron absorber monitoring program.

14 And there is a combined license item 15 related to this regarding the programs for fuel 16 movement and the programs and procedures that govern 17 that.18CO-CHAIR SKILLMAN: I'd like to ask a 19question, please. In this seven million gallon pool, 20 you've got a number of fluid systems that feed to it.

21 What ensures homogeneity in the boron concentration in 22 that pool among the 12 module spaces, the refueling 23 space, and the maintenance bay?

24 You've got a whole bunch of different 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 9 areas, and you've got a number of systems that touch 1that water. What makes sure the boron concentration, 2 and I'm going to assume it's approximately 2,000 ppm 3 throughout, what makes sure it's homogeneous?

4 MR. HARRIS: So I can speak to that. So 5 there's two --

6MEMBER CORRADINI: If I might just 7interject. If we're saying things that are 8 proprietary, stop us.

9 MR. HARRIS: Okay, understood.

10MEMBER CORRADINI: We can go and hold for 11 the, but sorry.

12MR. HARRIS: Okay, so there's two main 13 systems that service the ultimate heat sink as far as 14cooling is concerned, the spent fuel pool cooling 15 system and the reactor pool cooling system. Between 16 those two systems, they have a number of suction and 17 discharge points.

18 Suction points are taken off the spent 19 fuel pool and refueling pool then discharged back into 20 each individual operating bay. So that helps ensure 21 homogeneity.

22 CO-CHAIR SKILLMAN: Thank you.

23DR. NICHOL: One of the unique features of 24 our plant, we don't have specific new fuel storage.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 10 The new fuel is brought in and stored in the spent 1 fuel racks. The racks, the pool liner, and the pool 2 itself are seismic category I, and they are protected 3 from non-seismic category I structures, systems, and 4 components.

5 There are a couple combined license items 6related to this. The first one talks about the dry 7cask. We haven't specified that, that's something 8 that the applicant will choose which model of dry 9 cask, and that will then be spelled out in a combined 10 license item.

11 There's also a combined license item for 12 the site-specific rack designs.

13CO-CHAIR REMPE: So before you go on to 14 the next slide, on the prior slide, I know you've put 15 off to the COL applicant to do the criticality 16 evaluation, but in the staff's review, they noted that 17 some of the information you prepared that there were 18 some errors in some dimensions in that documentation, 19 which you've corrected.

20But I guess what I'm asking about is 21 something that I saw a couple other places in the 22 staff's SER, where there were some errors that I would 23 have thought a QA program should have detected.

24 And although you've fixed the errors the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 11 staff identified, did you stop and think that there 1 might some sort of underlying root cause that might be 2 leading to such errors, and have you addressed those 3 errors with some sort of fixes to your QA program to 4 make sure that similar errors aren't existing that the 5 staff might have missed?

6MR. HARRIS: I'm not familiar with the 7 particular errors, but I would say if they are 8 identified, they would have been put into our CAP 9 program, and depending on the severity, no matter the 10 severity, would have had a condition evaluation 11 performed.

12CO-CHAIR REMPE: Okay, so as we go through 13 today's presentation I'll bring up some other cases 14 where the staff identified some things that I thought 15 that the QA program would have detected or should 16 detect and we'll see if you can, till I kind of get an 17 idea that you really have thought about hey, we don't 18have those kind of things continuing to occur. Okay?

19 MR. HARRIS: Okay.

20 MS. FOSAAEN: And if I may just correct, 21 so we did present a criticality analysis in there.

22 The COL item is to confirm that it's still applicable 23 with the site-specific conditions.

24CO-CHAIR REMPE: And in that analysis the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 12 staff found some errors, right?

1 MS. FOSAAEN: Yes.

2CO-CHAIR REMPE: And so you understand 3 where I'm coming from, and yeah, okay, we all make 4mistakes, but are there other mistakes? And should 5 the QA program have detected that?

6MS. FOSAAEN: Yeah, I understand the 7question. And like Scott said, we did enter all of 8 that into our corrective action system for evaluation, 9 but I'm not familiar with the outcome of those actions 10 and what actions we took, other than correcting the 11 errors identified.

12 CO-CHAIR REMPE: Okay, thank you.

13MR. HARRIS: And since we're talking about 14 the --15MEMBER BLEY: Before you go ahead, I'd 16like to follow up on Dick's question. Put on that 17next slide, please. Yeah, thanks. There are a lot of 18separate areas here. It makes sense the answer you 19gave about why it ought to be mixed. But sometimes 20 things that make sense don't turn out to be right.

21 Where is the concentration monitored and 22where will it be sampled and kind of how often? I 23mean, have you played with this? Do we know for sure 24 that it's well mixed?

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 13 MR. HARRIS: Well, I can't --

1MEMBER BLEY: Or will we know for sure 2 when the plants operate?

3 MR. HARRIS: I can't speak to where it's 4sampled specifically. I imagine it's sampled on 5 several different areas, in the spent fuel pool, 6 refuel pool, and each individual operating bay.

7MEMBER BLEY: I didn't see where that's 8 spelled out. That's not part of the design. That's 9 going to be left to the --

10MR. HARRIS: That'll be part of an 11 operating procedure.

12MEMBER BLEY: Operating folks to figure 13 out where to sample.

14 CO-CHAIR REMPE: And how will they --

15MEMBER CORRADINI: Is that an item that's 16 identified for the operator?

17 PARTICIPANT: No.

18 MR. FIELDS: Each applicant will have to 19 develop their own operating and maintenance 20 procedures. That's a COL item.

21 MEMBER BLEY: But there's nothing in COL 22 items that tells them, that speaks to this issue of --

23MR. FIELDS: Not specifically to that, 24 your question, sir, no.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 14 MEMBER MARCH-LEUBA: Generally if you're 1 familiar with the criticality of the spent fuel pool 2for what you said. Do we take credit for the boron in 3the water, or are we not taking credit for it? For 4the spent fuel pool criticality calculation. Did you 5 rely exclusively on the solid racks, or did you take 6 credit for the soluble boron?

7DR. NICHOL: So I believe we did take 8 credit for the boron concentration.

9 MEMBER MARCH-LEUBA: In the water?

10 DR. NICHOL: For criticality control.

11MEMBER MARCH-LEUBA: Okay, then these 12questions are really relevant. It should not be left 13 over to the QA or the staff.

14MS. FOSAAEN: Actually, we have someone in 15 the audience we're going to have help us out here real 16 quick with this question, if you're all right with 17 that.18MR. SHAVER: Good morning, my name is Mark 19 Shaver, I'm a supervisor of the Radiological 20Engineering Group at NuScale Power. In our crit 21 safety analysis, the spent fuel pool is 1800 ppm of 22 boron, but we only take credit in the criticality 23safety analysis for 800 ppm boron. And so that gives 24 us 1000 ppm margin.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 15 And also, the limits we work to is K 1 effective value of .95 at the 100 ppm, and then under 21.0 without boron. So we do it both with and without 3 boron, but the boron we do credit is conservative.

4MEMBER MARCH-LEUBA: Do you take credit 5 for burnup, burnup credit?

6MR. SHAVER: No, we do not take any burnup 7 credit.8MEMBER BLEY: All of this sounds pretty 9 good, but, you know, I've spent a little time around 10 the chemical process industry, and you sometimes see 11 very surprising results in tanks that are assumed to 12 be well mixed when you sample in different places.

13 MEMBER MARCH-LEUBA: Especially when you 14 have thermogradients. The spent fuel pool is likely 15 to need a hotter source -- to be insulated. And so 16 whenever you have thermogradients in such a large 17 pool, you have to worry about those things.

18MR. HARRIS: Okay, so as we're talking 19 about the spent fuel pool, I'll just lay out the 20ultimate heat sink configurations. So the ultimate 21 heat sink consists of the spent fuel pool, our 22refueling pool, and the reactor pool. And they all 23 freely translate with each other.

24 And we also have the dry dock, which we 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 16 use to put our module in for maintenance operations 1 during refueling.

2DR. SCHULTZ: Excuse me, a question. What 3 latitude are you providing to the COL applicant with 4 regard to the spent fuel pool racks, and what are they 5 working to achieve when they do their own spent fuel 6 pool criticality calculations?

7MR. HARRIS: Do you want to speak to that?

8 DR. NICHOL: Sure, so if you actually go 9back one slide, this is spelled out. The COL 10 applicant is responsible for submitting vendor-11 specific design that includes the seismic analysis, 12 the criticality analysis, and those sorts of things.

13 Does that?

14DR. SCHULTZ: So they have the opportunity 15 to change rack design different than what you're 16 proposing at this point?

17MS. FOSAAEN: Yes, they could change 18 design, but that would require a reevaluation by the 19staff at the COLA stage. The COL item as represented 20 here is really intended to look at the seismic 21 structural aspect and ensure that the site seismic 22 characteristics are, you know, adequately evaluated.

23 And as part of that, we recognize that it could affect 24 the other characteristics.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 17 So this COL applicant item was really 1intended to be relative to the seismic aspect. And 2 then if there was a change that wasn't bounded by what 3 was already performed, we recognized they would need 4 to look at these other things, and it could result in 5 changes that would need to be evaluated.

6 And the standard review plan 384 spells 7 out the criteria that they have to do this re-analysis 8for. So the applicant would need to use that guidance 9 to ensure that they're appropriately selecting racks 10 if they were changing design.

11DR. SCHULTZ: And is NuScale also 12 providing guidance based upon your analysis and your 13 approach that would help the COL applicant to 14 determine what they need to accomplish in those 15 analyses?16MS. FOSAAEN: So we've spelled out certain 17 criteria in the application that would need to be 18 confirmed against, yes.

19DR. SCHULTZ: Okay, thank you. So this 20 really starts with things like external events that 21 would not be considered in the normal design practice, 22based upon what you've assumed. And you've got racks 23 that are seismic one and you've got criteria that 24 match up with that.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 18 MS. FOSAAEN: Yes.

1 DR. SCHULTZ: Thank you.

2 MR. HARRIS: So as previously mentioned, 3there's two systems which provide cooling for the 4 ultimate heat sink, that's the spent fuel pool cooling 5and the reactor pool cooling systems. Both these 6 systems are not safety-related.

7 In addition to cooling, they also maintain 8 ultimate heat sink water level and provide a means for 9 chemistry control and also provide reactor pool 10 temperature information signals for post-exit 11 monitoring.

12 In addition to the ultimate heat sink 13 cooling systems, we have the pool cleanup system.

14Again, non-safety related. This is specifically used 15for removing impurities to reduce dose rates and 16 maintain both chemistry and clarity.

17 We also have the pool surge control 18 system, which is our system used to drain the dry dock 19 during refueling operations.

20 The pool leakage detection system is used 21 to monitor any leakage from the pool liner. It uses 22 a series of channels to flow any leakage to our sumps 23 within the reactor building for operator evaluation.

24MEMBER CORRADINI: And does that, the way 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 19 that's situated, does that determine the location or 1 just gross loss?

2 MR. HARRIS: So you can isolate specific 3 channels to help identify the approximate area within 4the reactor pool. And then from there you can use 5 borescopes to go up and down the channels and identify 6 any wet spots.

7And those are my last two points there.

8 Fuel handling.

9DR. NICHOL: So the fuel handling 10 equipment, essentially we're talking about equipment 11 that handles receipt of new fuel, refueling 12 operations, and loading of spent fuel into a dry cask.

13 Some of the design considerations, these pieces of 14 equipment are designed to the appropriate design 15 standards, including ASME and ANSI design standards.

16 Essentially the goal is to reduce the risk 17 of a drop or a criticality event or exposure to 18radiation. The equipment is also designed to support 19 inspection of the equipment itself.

20 This is an illustration of the spent fuel 21 pool and the fuel handling equipment.

You can see 22 starting on the left there is the new fuel jib crane.

23 The area of hook coverage with a new fuel jib crane is 24 illustrated there with a wedge cut out of the side of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 20 it that essentially prevents it from, by interlock, 1 prevents it from carrying loads over the spent fuel 2 racks.3MEMBER BLEY: Have you designed or 4 specified what kind of interlock that's going to be?

5 I mean, some interlocks are like a micro switch or 6something sensing where it's moved. And if you got a 7 bad signal, it'll keep going. Other ones are actual 8 physical interlocks, so you just can't move.

9 DR. NICHOL: So it is not designed.

10MEMBER BLEY: Is it specified? If not, 11 when will it be specified?

12 DR. NICHOL: That's a good question.

13 MEMBER BLEY: Thank you.

14 CO-CHAIR REMPE: So some background, for 15some background information, the fact that you put 16 this interlock in was in result to the staff's review, 17 right?18 MS. FOSAAEN: That's correct.

19DR. NICHOL: So I would think at the 20 latest certainly at the time that the equipment is 21 designed it will be specified. It's a specification 22 to the equipment.

23CO-CHAIR SKILLMAN: What is the 24 distinction on the medium left of this image and the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 21far right in this image where there is the green 1 crosshatching, and on the far right, the blue 2 crosshatching, and the combined crosshatching right in 3the middle? What is the left green crosshatching 4 communicating to us?

5DR. NICHOL: So there's a key at the 6 bottom of the image. The green crosshatching is the 7 coverage area that the fuel handling machine mast can 8access. You can see that covers all of the storage 9 locations in the spent fuel racks, as well as a small 10 portion of the refuel pool, which gives it access to 11 the fuel when it's in the lower reactor pressure 12 vessel during refueling.

13 The blue crosshatching is the auxiliary 14 hoist, which is a piece of equipment on the fuel 15handling machine. And that's used for various 16 operations, including handling control rod assemblies, 17 that sort of thing. So it's physically located in a 18 different spot on the fuel handling machine, so its 19 coverage area is different.

20CO-CHAIR SKILLMAN: Is there a safety-21 related connotation to this crosshatching image?

22 DR. NICHOL: No.

23CO-CHAIR SKILLMAN: No. This is just, 24 hey, this is where the equipment can reach, this is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 22 where the bridge and trolley are able to operate.

1 DR. NICHOL: Right.

2 CO-CHAIR SKILLMAN: It's simply that?

3 DR. NICHOL: Right.

4 CO-CHAIR SKILLMAN: Okay, thank you.

5DR. NICHOL: The only other piece of 6 equipment that I haven't mentioned is the new fuel 7elevator. You can see that illustrated there. The 8 new fuel jib crane of course brings new fuel 9 assemblies to the elevator. They're brought down to 10 the level that the fuel handling machine can them 11 access them and place them in racks.

12 The COL items associated with the fuel 13 handling equipment, there are procedures that need to 14 be developed related to transferring fuel to a spent 15 fuel cask, and also one regarding the inspection of 16 the, and periodic testing of the fuel handling 17 equipment itself.

18 The overhead heavy load handling system.

19 The main components of this system include the reactor 20 building crane, the nuclear power module, the NuScale 21 power module lifting fixture, which is the physical 22structural elements that attach to the lift tabs. And 23 then the diagonal braces that attach to the module 24 itself.25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 23 There's a module lifting adapter that 1 interfaces essentially between the reactor building 2 crane and the NuScale power module lifting fixture.

3 And there's a wet hoist, which is used for any of the 4 lifting operations that take place under water.

5 The reactor building crane specifically is 6 designed to be a single failure-proof piece of 7equipment. It's designed to ASME NOG-1 Type 1 8 standards, that's the highest NOG-1 qualification, 9 highest NOG-1 design standard.

10 The movement of that system is controlled 11 via interlocks, and the path and the maximum lift 12 height are limited to prevent or to maintain shielding 13when moving reactor modules. And there's a 14 communication system between the operator of the 15 reactor building crane and the Control Room.

16MEMBER CORRADINI: What is the lift height 17 normally?18 DR. NICHOL: The lift height of?

19 MEMBER BLEY: In other words maximum.

20MEMBER CORRADINI: But normal, well, I 21guess maybe both. When you move a module, it's how 22 far off the floor of the ultimate heat sink floor.

23 DR. NICHOL: A foot off the floor.

24MEMBER CORRADINI: And then I guess Dennis 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 24 is asking the maximum height?

1 DR. NICHOL: Correct.

2 MEMBER CORRADINI: What is that?

3DR. NICHOL: The maximum height of the, so 4I have the numbers in my head. The maximum hook 5 height is --

6 MEMBER CORRADINI: Assuming you can tell 7 us.8DR. NICHOL: Yeah, it's 145 foot off the, 9 I mean, that's the site elevation, which puts the --

10MEMBER BLEY: You said there was a limiter 11 on how high it can lift. Where is that limiter set?

12DR. NICHOL: Oh, so the lift height limit 13 is going to be based on the load that's being picked 14up. So when a reactor module is being handled by the 15 crane, there'll be a limit imposed on how high it's 16 lifted.17MEMBER BLEY: So this is something an 18 operator will have to manually set.

19DR. NICHOL: No, it will be handled by an 20 automatic system.

21MEMBER BLEY: How does the automatic 22 system know what it's going to lift?

23DR. NICHOL: The system looks at the load 24 that the crane is lifting and limits the maximum lift 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 25 height.1 MEMBER BLEY: By, just by the weight.

2CO-CHAIR SKILLMAN: What is the quality 3 level of that control system?

4 DR. NICHOL: That's a good question.

5 CO-CHAIR SKILLMAN: Yes, it is.

6 DR. NICHOL: So --

7CO-CHAIR SKILLMAN: Okay, so I've got a 8740-ton module I'm hoisting. I'm at 11 inches, I pass 9through 12, now I'm at 13, now I'm at 14. You have no 10 module drop accident analyzed, and this control system 11 has not stopped hoist. What do you do?

12DR. NICHOL: So as an operator what do you 13 do?14 CO-CHAIR SKILLMAN: Yeah.

15DR. NICHOL: So the operator will be 16 informed of what is appropriate --

17CO-CHAIR SKILLMAN: Now I'm at 14 inches.

18DR. NICHOL: And the operator has the 19 opportunity to hit a stop button.

20CO-CHAIR SKILLMAN: How does he know to do 21 that?22 DR. NICHOL: He monitors the operations.

23 CO-CHAIR SKILLMAN: Okay. But he had an 24 automatic system that he was or she was depending on 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 26to stop the hoist. So what's the quality of the 1 control system? Let's just leave it at that.

2DR. NICHOL: Let me get back to you on 3 that.4CO-CHAIR SKILLMAN: Get back to us on 5 that.6 DR. NICHOL: Back to all of you.

7 CO-CHAIR SKILLMAN: Thank you.

8MEMBER MARCH-LEUBA: I'd like to follow up 9 on that because it's in the news all last week, all 10 these computer controls with single switches cause a 11lot of problems. It really begs the question of what 12 else we have single input computer controlled for an 13 operation that could become dangerous if it runs away.

14 And that is not the responsibility of ACRS 15 or the responsibility of the staff, it's your 16responsibility to find it. And we'll review what 17you've done. You cannot rely on the staff or ACRS to 18 find all those problems.

19 It was on the news this morning that 20 another plane, well, that like here, the condition of 21the crash was like there was another pilot. A day 22 before the crash, that he went to the crash the day 23before because he knew how to handle it. And then the 24 day after, that guy was not flying, so it crashed.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 27 So having a crane handling one of these 1 modules, I'm saying, well, the operator will push the 2 red button.

3MEMBER BALLINGER: So you say that it's 4 load control, so it's a set round number 700-ton 5 module. Most load cells 0.1% error, so that's about 6 7 tons. So what's the next heaviest device that the 7 crane would have to lift?

8Is it way beyond the uncertainty of the 9load system? In other words, is there something that 10 close, that's within the 7 tons error that you could 11 lift and make a mistake?

12DR. NICHOL: No, no. I think the next 13 lightest component is well below 400 tons.

14 MEMBER BALLINGER: Okay.

15MEMBER CORRADINI: I was going to just, 16 can I just generalize the question and then you can 17think about it. Operational procedures of the crew so 18 that they know what's going on, even though they may 19or may not believe the computer control I think is 20 kind of where we're going.

21 And so I'm curious, is there a, maybe 22 that's not in this chapter, but I think it's related 23to the module. That's where we were a month ago, 24 talking to another group of the NuScale folks about 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 28these topics. So I think that's the sense of what 1 you're hearing from some of the members.

2MS. FOSAAEN: Right, and we do have a COL 3 item that identifies the need to develop procedures 4 and operator training specifically for the crane in 5 915. 6 And if I may follow up on the question 7 related to instrumentation, our software control will 8 follow Reg Guide 1.168, and that's described in 7.2.

9 So the crane has been identified, the crane operating 10 software has been identified as needing to follow that 11 information.

12MEMBER RAY: Well, there's something I 13 guess was implicit in something Dick said earlier.

14 We've done a lot of heavy lifting in this business, 15 and it's not a unique or first-time event. But when 16 we did heavy lifting in the past, up until now as far 17 as I know, that could result in core damage, we always 18off-loaded the core first. The exception of course is 19 the removal of a head.

20 But this is different, because you are 21moving the core, basically. And so the questions 22 about the quality of the specified requirements, let's 23 put it that way, what are we certifying in this design 24is the question. If we're just certifying that oh, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 29 you have to come up with a crane that'll move a heavy 1 load reliably, but that's the responsibility of each 2 COL holder to do that individually, that's one thing.

3 But if there are more requirements that 4 are placed in the design certification for this part 5 of the system, we'd like to know what it is 6 specifically.

7 DR. NICHOL: So I would actually like to 8speak to that. So in a standard operator system where 9 the, you mentioned the core is offloaded before heavy 10 loads are handled over the top of the core, what we do 11is different, and we recognize that. And we have 12 spent a good deal of time analyzing the potential for 13 core damage based on load drop scenarios.

14 Seen, though, from another viewpoint, it 15 is not uncommon to move containers containing spent 16 fuel in an operating reactor, in the operating reactor 17fleet. So seen from that angle, essentially what 18 we're moving is a very large spent fuel container.

19 As I said, that doesn't mean that we're 20 dismissing the importance of this, and we have done a 21 lot of analysis looking at potential core damage 22frequency and those sorts of things. But we are 23 essentially moving a large container of spent fuel.

24 MEMBER RAY: Well, I would disagree, but 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 30this is not the place to debate that. It's not going 1 to sit there for five years before you load the spent 2fuel cask. There are many reasons why I wouldn't 3 agree, but this is not the place to have that debate.

4 The question I'm trying to ask very 5 clearly is are you just going to tell the COL holder 6 they need to address this, or are you going to, is the 7 design certification going to provide specific 8requirements that must be met by the COL holder. And 9that extends over many, many issues from quality 10 requirements for the control system to operator 11 requirements and so on.

12 Because that has to do then with what is 13 the scope of the design certification. Okay?

14CO-CHAIR SKILLMAN: I do want to go on 15 record and push this a little bit, because I find your 16argument flawed. I concur, an 840-ton cask or an 850-17or 870-ton module can be safely moved. Happens all 18 the time, big loads, shipyards, other parts of 19 industry move large loads safely.

20 What's different is you are moving a, the 21 current design moves a core that has abundant decay 22 heat generation, and it is being moved adjacent to 23 potentially 11 live cores. That's different.

24And in the analysis, in Chapter 15, in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 31 Chapter 19, module drop accident is not considered.

1 And so I find the combination of your response, it's 2 just a heavy load, kind of like a cask, combined with 3 the absence of a module drop accident, to be 4problematic. I think NuScale has to own the notion 5 they're moving a very heavy load adjacent to live 6 cores.7Let me go one step further. I was 8 involved in moving a heavy load repeatedly over a dead 9live core. And at TMI-2, we dropped equipment into 10 the open reactor vessel in which there was destroyed 11fuel. So to the very best of our intention to have 12 the single failure-proof crane, guess what, a load got 13 away from us. It simply happens.

14 And so I guess I've got that orientation 15 that I'll never let go of that a crane accident can be 16a very big problem. And the people at Arkansas 17Nuclear 1 will verify that. This is a heavy load, and 18 it can have heavy consequences, and it's adjacent to 19 other live cores.

20MS. FOSAAEN: If I may, we did not 21 evaluate it in Chapter 15 because of the guidance that 22 says if we design to single failure-proof. However, 23 we did evaluate model drop within our action with 24nearby modules in Chapter 19. And there is an 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 32analysis that does look at that under PRA, with the 1 consequences.

2MEMBER BLEY: There's one thing that kind 3 of bothers me, and I don't expect you to answer this 4now. And I'm kind of guarding the staff, I'm going to 5ask them as well. It came up in one of my earlier 6 questions about exactly what kind of limit device 7 would be on the jib crane.

8 In Chapter 18, NuScale responded to the 9 staff that details about the human system interface 10 and essentially potential operator errors is being 11 left to the designer of the crane, who will design to 12your specification. I assume some of these other 13 issues are also in that ballpark. I don't know when 14 they get looked at, and I'm going to ask the staff 15 that when they come up.

16 If you've negotiated this and know about 17 that, that'd be great. But some of these issues are 18 potentially important, and putting it off on the 19 designer of the crane at the time the crane's going to 20 be built, I'm not sure where that fits in the review 21 process by the NRC. And will it be reviewed?

22 Or is it just, I mean, they're not even 23 right now reviewing your specification because they 24 don't think you have it yet.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 33MEMBER CORRADINI: Can I ask Dennis's 1question a little bit differently? If it's as he 2 said, is there an ITAAC then that has to come and be 3 cleared, such that the specifications have been 4 designated, met, and then checked by the staff? And 5 we can hold off and ask the staff this, but I'm just 6 kind of curious from your standpoint, because I think 7 he makes a valid point.

8MS. FOSAAEN: So I can check, but I'm 9 quite sure that we actually do have an ITAAC for the 10crane specifically. I don't recall off the top of my 11 head the specifics, but we can get back to that.

12 MEMBER CORRADINI: We'll come back.

13CO-CHAIR REMPE: But I think Harold's 14 point was that did you at least give guidance on what 15 would be done? Not just have an ITAAC, but is there 16 some high level guidance of what is expected is where 17 I am at.18MS. FOSAAEN:

We do have guidance in 19 Chapter 14 that helps understand what's required to 20close the ITAAC. So there is guidance in 14 that 21 specifies what should be done to help resolve the 22 ITAAC.23 CO-CHAIR REMPE: Thank you.

24MEMBER BALLINGER: I couldn't find this in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 34 Chapter 9, but maybe I should look in other chapters.

1 And I'm quite familiar with the interaction between 2 electromechanical and electrohydraulic systems, 3 computer controls, and what happens when things can go 4 wrong and all of a sudden you get very high 5 temperature steam out into the laboratory.

6 And the way we solved the problem, invent 7stuff. The way we solved the problem was to put a 8 mechanical limiter, mechanical limiter, in the system 9that made it virtually impossible. The crane 10 operator, the computer guy could be stoned and try to 11 move something, and it hits a mechanical stop and it 12 just can't go any further.

13 Is there something like that with this 14 crane? I couldn't find it, but it's so easy to do.

15MEMBER BLEY: They told me earlier that's 16 not specified.

17MEMBER BALLINGER: I mean, that solves the 18 problem, or largely solves the problem.

19DR. NICHOL: So there are no physical, I'm 20 trying to understand, you're saying, you're asking if 21 there's like a physical?

22 MEMBER BALLINGER: Module a foot, right.

23But then somebody asked how high could you lift it.

24 You said 100 --

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 35DR. NICHOL: No, no, that's the top of 1 the.2MEMBER BALLINGER: Yeah, but how high can 3 you, you know, what limits how high you can actually 4 go?5MEMBER BLEY: Ron's point, you know, this 6could be done by software. Looking at ovations and 7 positions, it could be done by something like limit 8 switches, electrical devices, or it could be done by 9 physical devices --

10 PARTICIPANT: We had all three.

11 MEMBER BLEY: To keep it from moving and 12 one works a whole lot more often than the other two.

13 Is successful, the whole.

14 MEMBER BALLINGER: And it's simple.

15MEMBER KIRCHNER: So what is the range of 16 operation of the crane for other purposes? Isn't it 17 used for shielding?

18DR. NICHOL: Maybe we can get into that 19in, I have a figure coming up. I don't think it's the 20 next one, but we'll get back to the range of operation 21 of the crane. And that may answer some of the other 22 questions about limits of where the crane can operate.

23MEMBER RICCARDELLA: Before we go on, 24 Corrie, you mentioned an ASME standard that I'm not 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 36familiar with. Could you tell us a little about that?

1DR. NICHOL: I believe that was NOG-1, 2 nuclear --

3 MEMBER RICCARDELLA: NOG, N-O-G?

4DR. NICHOL: Yeah, nuclear overhead 5 gantry, N-O-G-1.

6 MEMBER RICCARDELLA: Oh, okay.

7MEMBER BALLINGER: But none of those 8documents mention a live core. 550 whatever it is, is 9 two NUREGs and everything, there's nothing in there 10 that says this is for a live core. So that's what 11 makes it different, and I presume that your PRA, 12 you're getting around it by having it a very low 13 probability event in the PRA.

14CO-CHAIR SKILLMAN: Well, no, the way they 15get around it is they communicate this is a single 16 failure-proof crane and it won't happen.

17 MEMBER BALLINGER: Right, right, but the 18 NUREGs don't have anything in there that says if 19 you're lifting a live core, you got to do something 20 different. It's just --

21MEMBER BLEY: Lifting over a live, 22 adjacent to it, lifting over a live core.

23 DR. NICHOL: If I could clarify, though, 24 that we do, in Chapter 19, we do consider module drop 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 37accidents that would include core damage. We do look 1 at that.2MEMBER MARCH-LEUBA: Yeah, and I'm looking 3at it. I'm not sure if it's proprietary or not, so I 4 won't mention numbers, but they are ludicrous.

5MEMBER DIMITRIJEVIC: Well, in your 6 Chapter 19, that's the most important event from the 7point of core damage. How you go around is that it's 8 crap and it's not going to be released and it's not 9 considered as a safety measure. And so there is not 10 really detailed analysis otherwise, as you tried to 11 mention.

12 This is an estimate of probability of this 13 happening, which is the low in ten to minus eight.

14 But it's still the most important event because this 15 is very safe plan. So this mostly, it seems this is 16 happening in the big pool, in the scrapping there is 17 no releases. That's what your estimate is that.

18 However, from the point of the importance 19 of the thing, even things will just to lead to core 20 damage without leading to releases should be 21 considered important.

22 MEMBER BROWN: I've got one question.

23MEMBER BALLINGER: I'll say it again, a 24 mechanical stop cuts the head off of this snake.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 38 MEMBER BROWN: But let me ask a question 1relative to that. Obviously if you've got a computer-2 controlled crane, you've got a processor of some kind 3 in it, right.

4 DR. NICHOL: Correct.

5MEMBER BROWN: A microprocessor or 6something. How do you handle a circumstance where the 7processor locks up? You call it single failure-proof, 8but what does that mean relative to the software? Do 9 you have redundant software that runs this that has to 10 be compared? Do you specify for that?

11DR. NICHOL: So single failure-proof 12 refers to the portions of the crane responsible for 13 handling the load such that it isn't dropped.

14MEMBER BROWN: Okay, well is that 15 software-controlled?

16DR. NICHOL: The single failure-proof 17 portions of the crane are physical.

18 MEMBER BROWN: Are what?

19DR. NICHOL: Physical. They're hardware, 20 they're redundant ropes and those sorts of things.

21MEMBER BROWN: So the answer is no. Well, 22 what makes it move?

23MEMBER MARCH-LEUBA: No, the answer is 24 digital means. Digital means, software.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 39 MEMBER BROWN: Software.

1 DR. NICHOL: Right.

2MEMBER BROWN: So what, if it's moving, 3 what prevents it from failing if the software locks 4 up?5DR. NICHOL: So there will need to be a 6 redundant system that monitors the operation of the 7 existing software to ensure essentially that that 8 doesn't happen.

9MEMBER BROWN: Well, I know, but you just 10 commented that the mechanical parts are designed to be 11 backed up so that you don't have it, it's a single 12 failure-proof.

13 DR. NICHOL: Right.

14MEMBER BROWN: But you don't make any 15 comment about the software being backed up, the single 16 failure-proof.

17 DR. NICHOL: Right.

18MEMBER BROWN: You kind of limited it 19 between the software-based systems and the mechanical-20based systems. And if anything we've ever learned, 21 software locks up. It'll do it unexpectedly, you're 22 moving your mouse and all of a sudden it doesn't move 23 anymore, just randomly.

24 And the processes that you use, whether, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 40 are they going to use custom software, is it going to 1 be commercially dedicated software with all kinds?

2 You're going to get locked up if you don't provide 3 some safeguards, I don't, safeguard's the wrong word, 4 requirements to provide monitoring and/or backup 5 and/or prevent lockup of that software, and have that 6 lockup result in something that stops everything so 7 that you can take manual control.

8 If you don't tell them to do that, how do 9you do it? Right now, it seems like there's a 10division of responsibility right now. Here all these 11 things are going to be redundant and single failure-12 proof, but the software is just fine because it's not 13a problem. It's kind of a hard, that's a hard nut to 14follow. And I just throw that on the table and let 15 you deal with it.

16 DR. NICHOL: Okay.

17 MEMBER CORRADINI: My thought is we need 18 to move on, but I think you get the sense of it is 19 specifications that are given by NuScale, go to the 20 vendor, come back, are checked by NuScale and are 21 inspected by the staff might be what I'll call a 22 consensus opinion of the members.

23 So to make sure that you essentially come 24 back all the way full circle so you have what you want 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 41 in terms of your system design.

1MEMBER KIRCHNER: It goes back to Harold's 2 question, what are we certifying here, just a single 3module? Or what's unique about this plant is the idea 4 of having multi modules and yet, the amount of detail 5 that's being provided for critical functions is scant 6in this particular case. And yet, this is at the crux 7of multi-mode operation. I just find it deficient.

8 That's one person's opinion.

9MEMBER BROWN: You've really got to think 10 about a fail-safe circumstance for the software-based 11 systems, and that doesn't seem to be addressed based 12on the conversations I've heard. I'll stop at this 13 point.14C0-CHAIR REMPE: So I think we've made our 15point. And maybe if we haven't, we'll come back with 16-- just let's go ahead. Unless you have some 17 clarifying thing like oh, you should look at chapter 18 such and such and you can see this, I think you need 19 to move on, but you can understand there's some 20 concern.21 DR. NICHOL: Yes, let's move on.

22 C0-CHAIR REMPE: Okay.

23CO-CHAIR SKILLMAN: Corrie, let me ask one 24 other question before we move on.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 42 DR. NICHOL: Okay.

1CO-CHAIR SKILLMAN: I searched the word 2 buoyancy and I find that intriguing because the way 3 the documents are written, it seems to identify that 4 buoyancy might be variable from one place to another.

5And I would just assert that if you're taking an 6 imaginary one cubic foot of something to the 7 Challenger Deep in the Marianas Trench or you put that 8 same cubic foot of imaginary in your bathtub, it's 9 still about 62.4 pounds of buoyant upward through the 10 centroid of that mass.

11Why is buoyancy a concern here? And what 12 relationship would buoyancy have to the load-lifting 13capability of the crane, if any? My thought is none, 14 but I'm asking the question because I searched on 15 buoyancy and it shows up a couple of places.

16DR. NICHOL: So we credit the buoyancy of 17 the module when we assign a name plate capacity for 18 the crane.

19CO-CHAIR SKILLMAN: And so you consider 20 the whole module voided?

21DR. NICHOL: No. The condition that we 22 analyze is the condition that it will be in in 23 refueling which includes water in ECCS system and as 24--25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 43CO-CHAIR SKILLMAN: So the containment is 1 flooded?2 DR. NICHOL: Right.

3CO-CHAIR SKILLMAN: So what would be 4 buoyant?5DR. NICHOL: We displace water with the 6steel that makes up the reactor module. And we don't 7 flood the entire space in the containment vessel.

8MEMBER CORRADINI: Is there a -- I figured 9you were going to say that. Is there a reason for 10 that?11DR. NICHOL: To keep the -- I don't know, 12 is that proprietary?

13 MEMBER CORRADINI: We can hold off.

14CO-CHAIR SKILLMAN: Let's talk about that.

15I'm just curious because what is unique here is, if 16 you will, a buoyancy discussion for a module you don't 17 find that when you're refueling any other reactor.

18 DR. NICHOL: Right.

19MEMBER CORRADINI: Let's talk about it in 20 the proprietary section, please.

21 DR. NICHOL: Right.

22 MEMBER CORRADINI: Thank you.

23MS. FOSAAEN: We recognize the importance 24 of that as well and you'll find that that's reflected 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 44 in the full-level bases as an important function.

1 MEMBER CORRADINI: I know. That's why I 2asked the question. That's where I went searching.

3 Thank you.

4 DR. NICHOL: Okay, so briefly, I want to 5 talk about the actual operating bay. In this image, 6 you can see the safe-load paths are illustrated so 7 maybe I can just talk through bringing a module in and 8 then refueling operations will, of course, be the 9 reverse of that.

10So when a module is brought into the 11plant, it's on its side. It's brought in where the 12pointer is in the top left of the figure. It's 13brought in horizontally. It's brought in and then 14 upended in the inspection rack.

15C0-CHAIR REMPE: Is the crane used at this 16 point or is something else used?

17 DR. NICHOL: Once the module is upended, 18 the crane then picks up the upper module to move it to 19 the next station.

20C0-CHAIR REMPE: So at this point it's 21horizontal. It's not upended. So how are you 22 bringing it in is what I'm asking?

23DR. NICHOL: It's brought in horizontally 24 and then upended.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 45 C0-CHAIR REMPE: By not the crane.

1 DR. NICHOL: Correct.

2 C0-CHAIR REMPE: By other devices.

3 DR. NICHOL: Correct.

4 C0-CHAIR REMPE: A tractor or something, 5 I don't know. And then a crane helps it upend?

6DR. NICHOL: No, there's a piece of 7 equipment that's the module upender.

8C0-CHAIR REMPE: Okay. It's brought in or 9 it always stays in there?

10DR. NICHOL: It's a part of the refuel --

11 C0-CHAIR REMPE: Okay.

12 DR. NICHOL: Or the inspection rack.

13C0-CHAIR REMPE: Okay. I didn't see this 14 in Chapter 9. Maybe I missed it. But it's there?

15MS. FOSAAEN: The upender is described in 16 3.17 C0-CHAIR REMPE: Three. Okay.

18 DR. NICHOL: So once the module, the top 19 portion of the module is brought in, I guess I should 20preface this, the lower reactor pressure vessel and 21 the lower containment vessel are brought in separately 22and upended separately and placed in the reactor 23 flange tool and the containment flange tool by means 24 of the wet hoist.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 46 Once the module is brought in and upended, 1 the reactor building crane picks it up and brings it 2 to the reactor flange tool where it's assembled to the 3 lower reactor pressure vessel. Then the assembly is 4 picked up and moved to the containment flange tool 5 where it's assembled to the lower containment vessel 6 and then it's moved to the appropriate operating bay.

7 The safe load paths are illustrated there.

8 They're the fairly narrow darker bands that 9 illustrates essentially where the module can be moved 10by the crane. The other cross-hatched area is the 11 area of coverage for other operations that include wet 12 hoist operations and other auxiliary hoist operations 13 in the pool.

14 And I'll also point out there is a heavy 15 load exclusion zone where the reactor building crane 16 is prevented by interlock from the trolley traversing 17 over that space where the spent fuel racks are in the 18 spent fuel pool.

19 This is a chart that describes the design 20 codes that are applicable to different pieces of 21equipment. You can see the reactor building crane 22main hoist. I mentioned ASME NOG-1, Type I. That's 23 also the code that's used for the auxiliary hoist.

24 The module-lifting adapter and the NuScale power 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 47 module lift fixture are both designed to ANSI N14.6 1 which covers below the hook-lifting devices.

2 The wet hoist is an NOG-1 hoist and the 3 jib crane is designed to the ASME NUM-1, Type II 4standard. NUM stands for Nuclear Underhung Monorail.

5 So it's a different configuration crane, so it's 6 covered by a different standard.

7 Also, noted on the chart are the seismic 8 category, the different pieces of equipment and the 9 maximum traverse and hoist speeds of the different 10 equipment.

11 I would mention there are a few COL items 12on the crane. The first covers the process for 13 handling receipt of critical loads including the 14module. The second one talks about spent fuel cask 15 handling equipment including the procedures for safe 16handling of the spent fuel casks. The last one talks 17about the governing procedures. We mentioned this, 18 the training and governing procedures that will be 19 required for operation of the heavy load handling 20 systems.21DR. SCHULTZ: It's these areas where I 22 find it -- I'll call it strange or surprising that 23you're putting this to the COL applicant. I just have 24 to believe you'd want to provide very specific 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 48 instructions associated with these types of things.

1 Project that you've got five NuScale facilities or 2you've got 10 or 100 NuScale facilities, to have COL 3 applicants doing different things at different places, 4 I just don't quite understand why you wouldn't want to 5 have very specific instructions, training programs, 6procedures and so forth. These are very important 7 things. 8 You may be able to survive an accident or 9 a mishap associated with movement of a module, but if 10 that happens and it will be significant for the 11NuScale industry, you don't want it to happen. So I'm 12 surprised that if you don't have them, you would put 13 off to a COL stage something that would be that 14significant and be totally involved in the process 15 rather than have a COL applicant come up with this at 16 that stage of the process.

17MS. FOSAAEN: And I would agree. We at 18NuScale, we do intend to have a lot of services 19 available at future times. At this point, the focus 20 was on the design and we do have development in-house.

21 And so those would be services we would intend on 22 offering a future applicant.

23 And I think one thing that's important 24 here is that you mentioned five potential reactors.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 49 So there would be an advantage to standardization and 1 something we didn't really mention is that for us 2 refueling, I know you've said would be a frequent 3 evolution. So the advantage to that is we'll have a 4lot of operating experience. We'll have crews that 5 are very familiar, as they'll be constantly performing 6 these evolutions, whereas in a traditional plant 7you're only doing a refuel 18 months or 2 years. And 8 our cranes are always accessible as a result of not 9being inside a locked containment. So there are some 10advantages to our design. And I agree with the 11 points. And thank you for that.

12MEMBER BALLINGER: I guess I didn't notice 13 this, but the last item on that slide, detailed 14 description of the safe load paths for movement of 15heavy loads. I find that astounding because one of 16 your previous slides showed the safe load paths.

17 MS. FOSAAEN: Right.

18 MEMBER BALLINGER: That's got to be tied 19 to the PRA and every other thing.

20MEMBER KIRCHNER: It has to be well 21 specified.

22MEMBER BALLINGER: Has to be specified 23 just doesn't make any sense to me at all.

24MS. FOSAAEN: So we did analyze and do 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 50 have specified safe-load paths. That item was added 1 specifically in response to a staff question.

2DR. SCHULTZ: Right. It was an RAI 3response. I appreciate what you're saying, but you 4say we can provide this as an offering to a COL. I 5 just think it's too important to NuScale to leave it 6 to the COLs.

7 I know the hubris of the industry is such 8that oh, we can do this. We don't have to have 9 commonality, but think of the history of the industry 10 and at some point we determined that we needed a PWR 11 owners group and a PWR owners group activity in many, 12 many different areas.

13 It would be nice if we didn't have to do 14 that later, but if we did it now, and make it easier 15 for the first COL applicant and those that follow to 16 get this done.

17MEMBER RAY: Not only that, Steve, but you 18 know, we're focused here on the certified design of 19 the scope and the content of that. The intentions 20 that exist for providing information, help assistance, 21 guidance and so on down the road, that's not part of 22the certification. It's not something we can credit.

23It just can't be because it's certified design. It 24 has value as a certified design, regardless of what 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 51 the holder of that design may ultimately do years in 1the future. And so we're just trying to get into the 2 certified design, the things that we think are 3essential. Crediting what the present intentions are 4 in the future just can't be part of that process.

5C0-CHAIR REMPE: I think we made our 6 point. Let's keep going. Thank you.

7MR. HARRIS: Okay, on to 9.2 which is the 8wire systems. This includes station service water is 9 not in NuScale design, but 9.2 includes reactor 10 component cooling water systems, demin water system, 11 potable and sanitary water, the ultimate heat sink, 12 condensate storage, site cooling water, chilled water 13 and utility water.

14 The majority of these systems are a 15 typical industry design, so in the interest of time 16 I'm going to only focus on 9.2.5, the ultimate heat 17 sink. Otherwise, the remainder of those systems are 18 non-safety related and non-risk significant.

19C0-CHAIR REMPE: I'm going to stop you 20 here though since I think that means you don't plan to 21 talk about the reactor component cooling water system.

22 Is that a true assumption?

23MR. HARRIS: I can talk about it if you'd 24 like.25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 52 C0-CHAIR REMPE: I'd like it.

1 MR. HARRIS: Okay.

2C0-CHAIR REMPE: Just briefly, at the last 3 month's meeting, I was told because of whatever, the 4 multi-module chapter that you have said clearly you're 5 going to install what's needed for when you have a 6 less than 12 modules.

7 So in this component cooling water system, 8 if you had 12 modules, you'd have 3 systems of 2 9identical systems that each supports 6 modules and 10 then you have a third system that's a backup. So in 11 this case, even though I didn't see it clearly stated 12 in the DCA, I would assume you will do the backup and 13 the one system for whenever you even have one module 14 installed. Is that true?

15 MR. HARRIS: I can't speak to particular 16 construction activities about what, if you'd install 17 one or both reactor component cooling water systems.

18 I believe there's only -- should be only two reactor 19 component cooling water subsystems, one for each side, 20 north and south of the reactor cooling.

21CO-CHAIR REMPE: Right, to the six, but 22there's a backup. When I have module number 1 that 23 means I should have one of these two systems installed 24 and the backup, right?

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 53MR. HARRIS: I'm not sure what you're 1 referring to as a backup. It's a non-safety system.

2 There's no -- we have redundant pumps.

3C0-CHAIR REMPE: The power train is not in 4 operation, but it's kept in stand by and started, if 5needed. I'm quoting from the open DCA, okay? And so 6 to me, that means clearly that I've got to have the 7 backup as well as one of these systems installed from 8 day one if I have one module. And that's all I'm 9 asking because I mean that's what I think we read 10according to this multi-module chapter that you do, 11and I just am asking for clarification. Because 12 sometimes there's a system that supports like three or 13four modules. Sometimes there's one that supports 14six. But then there's like sometimes a backup system 15 and I'm just asking can we assume that, because we are 16 certifying a very -- sometimes fuzzy -- DCA.

17 So I'm getting into another question of 18what are we certifying here, but just an example. And 19 I would have expected you have said immediately, oh, 20 of course, we'll have that back-up system when we --

21 before we start one of these modules up.

22MS. FOSAAEN: I think it was just the 23terminology that was confusing. The system would need 24to have its basic functions. So if it was credited to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 54 have all three pumps installed, even for one module, 1 that would be required.

2C0-CHAIR REMPE: I can assume, and this is 3 on the record, that again, before you start one 4 module, we'll have one RCCWS and its backup.

5 MS. FOSAAEN: And by backup, we mean the 6 full suite of pumps that would be in there.

7 C0-CHAIR REMPE: Okay. Okay. Go ahead, 8 now. Sorry.

9MR. HARRIS: And so I think like Carrie 10 said, it's a difference in terminology, I think.

11 C0-CHAIR REMPE: Okay.

12MR. HARRIS: So other than the ultimate 13 heat sink, none of these systems are an essential 14 source of water, nor are they required during or after 15a natural phenomenon event. And anything in proximity 16 to a Seismic Category 1 component is designated 17 Seismic Category 2.

18On to the ultimate heat sink. Like I 19 mentioned previously, the ultimate heat sink consists 20 of the reactor pool -- refueling pool and spent fuel 21pool. It is a stainless steel lined reinforced 22 concrete pool filled with borated water.

23CO-CHAIR SKILLMAN: Scott, can you tell us 24 about how thick that, if you will, the floor liner is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 55 under what will be the controlled load path for the 1 module? Is it a one inch, two inch, a --

2 MR. HARRIS: It's less than one inch. I 3 can't speak specifically --

4CO-CHAIR SKILLMAN: It's less than an 5 inch?6 MR. HARRIS: Not off the top of my head.

7CO-CHAIR SKILLMAN: Is it puncture proof, 8 if that module gets away from the -- from your main 9 hook?10MR. HARRIS: I wouldn't expect -- so -- I 11 just want to clarify, the pool liner is non-safety 12related. So the safety-related structure is the 13 reactor building.

14 CO-CHAIR SKILLMAN: So it's the concrete 15 underneath.

16 MR. HARRIS: Right.

17CO-CHAIR SKILLMAN: Got that. So now I've 18 got a 740 ton and I drop it, do I puncture that less 19 than one inch pool liner?

20MR. HARRIS: I would expect if you dropped 21 a 900-ton load, it would puncture steel less than an 22 inch.23CO-CHAIR SKILLMAN: That's what I would 24expect. So is there going to be some armor plating 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 56 under that safe-load path or something to make sure 1 that no matter what, that pool liner cannot be 2punctured? Just think about it. You don't have to 3 answer.4 MR. HARRIS: Okay. Thank you.

5 CO-CHAIR SKILLMAN: Thank you.

6MR. HARRIS: The ultimate heat sink 7 consists of approximately seven million gallons of 8 water, so it's sized such that active cooling systems 9are not required for accident conditions. And that 10 combined volume of water provides sufficient coolant 11 for greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> without additional make up.

12 The ultimate heat sink is also provided 13 with a seismically qualified make up line that can be 14 connected external to the reactor building if 15 additional water were to be added.

16 And during normal operations, spent fuel 17 pool cooling and reactor cooling system services this 18 body of water and in a design basis event involving 19 loss of AC power decay heat removed from the modules 20 and into the ultimate heat sink.

21MEMBER CORRADINI: So let me ask just a 22quick question. So is there a procedure as to the 23 replenishment after -- if there's change in level?

24 There was a note made and the number is not important, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 57 but so many days before replenishment.

1 Is there a procedure for replenishment in 2 terms of at some point at some level?

3MR. HARRIS: So the level is covered by 4tech specs. So I believe the tech spec level is 5 greater than 68 feet, normal level, so anything below 6 that would trigger actions per the tech specs.

7 MEMBER CORRADINI: Thank you.

8MR. HARRIS: And a number of COL items for 9 chemicals used, sanitary waste disposal, corrosion, et 10 cetera.11On to process auxiliaries. This consists 12 of the compressed-air system, process sampling, 13 equipment and floor drain system, chemical and volume 14control system, stand by liquid control is not 15applicable to our design, and also the containment 16 evacuation system and containment drain system for 17 9.3.6.18 Similar to the other water systems, I'm 19 only going to focus on the items unique to our design 20 so with the exception of chemical and volume control 21system. These are non-safety related, non-risk 22 significant systems.

23 In any structures which could adversely 24 affect Seismic Category 1 or designated Seismic 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 58 Category 2, and we have two COL items, leakage control 1 program and post-accident sampling.

2 With the chemical and volume control 3 system --4C0-CHAIR REMPE: I guess before you go 5 there, just for the record, apparently, the sampling 6 system, there's an issue about -- it's on hold because 7 of the source term issue, right?

8MS. FOSAAEN: That's correct. There is an 9 open item from the staff in the review relative to 10that. And NuScale recently did submit an exemption in 11 relation to that that is affecting that review.

12C0-CHAIR REMPE: So you've requested an 13 exemption, submitted all the documentation and the 14 staff is reviewing it at this time.

15 MS. FOSAAEN: That's correct.

16C0-CHAIR REMPE: And that's where the hold 17 is right now. Thank you.

18MR. HARRIS: All right, on to the chemical 19and volume control system. It's used to purify 20 reactor coolant, maintain chemistry including boron 21concentration. Also provides for make up and let down 22 and supplies pressurizer spray flow and also provides 23 a de-gas operation.

24 There's one chemical and volume control 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 59 system per module and during start up is used in 1 conjunction with the module heat system to raise the 2 reactor coolant temperature to generate natural 3circulation. And also, it's used in conjunction with 4 the boron addition system which is a shared system for 5 all 12 modules.

6MEMBER MARCH-LEUBA: Don't move. This 7 system, the CVCS is dear to all of us, we tend to 8think about. Let's make sure I understood because 9 typically I am the one that nobody understands when he 10 speaks, but the acoustics in this room is so terrible 11 that I don't understand you.

12 MR. HARRIS: Okay.

13MEMBER MARCH-LEUBA: You have to speak 14more clearly. There is one CVCS system for the whole 15 plant. Is that correct?

16MR. HARRIS: No. There's one per 17 operating module.

18MEMBER MARCH-LEUBA: There's one CVCS 19 system --20 MR. HARRIS: So there's 12 total.

21 MEMBER MARCH-LEUBA: So there is one BAS 22 system per module?

23MR. HARRIS: No. One BAS per all 12 24 modules and --

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 60MEMBER MARCH-LEUBA: It doesn't appear on 1 the drawings. So each module has its own CVCS?

2 MR. HARRIS: Correct.

3MEMBER MARCH-LEUBA: And they are not ---

4 other than to the BAS system, they're not cross tied?

5MR. HARRIS: BAS is just -- so correct, 6 within the CVCS, they're not cross tied.

7MEMBER MARCH-LEUBA: Completely 8 independent. So if one fails, you cannot bring --

9 MR. HARRIS: It will not impact.

10C0-CHAIR REMPE: But there's a backup 11 power supply system, right, that includes -- there's 12 two -- the backup power supply system, I guess, 13 includes two redundant diesel generators and one 14 auxiliary alternating current power source.

15 How much of that is installed when you 16 have the first unit and six units and seven units, et 17cetera? Is all of that installed from day one?

18 Because that is needed for the CVCS and I assume it's 19 given credit for it.

20 MR. HARRIS: So any system, whether it's 21-- if it's shared or not, required for a module 22 operation will be installed and as you bring other 23 modules on line, module-specific systems would be 24installed for those modules. So for your example, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 61 backup diesel generator, that would be installed to 1 support that initial first module coming on line.

2C0-CHAIR REMPE: So the two -- for modules 3 less than six, would you have one diesel generator, 4but you'd have the alternating current power source 5installed? Or would you put both diesel generators in 6 from day one?

7MR. HARRIS: I'm not sure of the specifics 8 of the backup diesel generator, if there's one or two.

9C0-CHAIR REMPE: Maybe it's an unfair 10 question to ask you, but do you think it's documented 11 in the DCA somewhere other than a vague statement?

12MEMBER CORRADINI: Your question is where 13 is it documented?

14 MS. FOSAAEN: I know that 20.1 discusses 15 at a high level the multi-module in bringing 16 additional modules on line, but I don't believe the 17 level of detail you're requesting is specified in the 18 DCA.19C0-CHAIR REMPE: So I'm just kind of 20 wondering when they start building this, and I know, 21 the economic case depends on being able to produce 22 power with a few modules while you're still bringing 23 in the other modules. But to make sure that they've 24 appropriately done DCA, it seems to me some sort -- I 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 62 think we've looked at that test in chapter -- was it 120, 21, whatever it was you said. And it's very high 2 level and it kind of commits, yes, we're going to 3 bring in everything that's needed for the modules.

4 Okay, I might have accepted when you said well, we'll 5 put one of the diesel generators, but that back up 6 system, it seems like it's got to be there.

7 Somehow or other, I'd like to see a plan 8 that provides some guidance on how it's going to be 9 added on because we get a lot of single units sites in 10the U.S. where they've got a concrete pad and it's 11 like the second unit never got installed.

12CO-CHAIR SKILLMAN: Let me raise an issue 13here on CVCS. When I review, let's back up. CVCS 14 provides the ability to maintain the chemistry of the 15reactor coolant system. It's a back up for adding 16boric acid to your seven million gallon pool. It 17 serves a host of key functions.

18 If I'm an operator and I wish to add boric 19 acid to the reactor coolant system, I would have to 20 light off my boric acid system. I've got to work my 21 way through a bunch of valves, find my way to the 22 make-up pump, and at the make-up pump increase the 23pressure from 152 psi up to 2200. And only then do I 24 get that boron, boric acid, into the core.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 63 From Table 3.2-1, everything in CVCS is 1quality group D. It's 2 Bravo, excuse me, Bravo 2 out 2 of .69 and it's all Seismic Category 3 for both CVCS 3 and boric acid.

4 My point is a system upon which I very 5 significantly depend is basically commercial grade, no 6 augmented QA equipment. Why should I be comfortable 7 with that? It's a key system.

8MR. HARRIS: I agree. It's a key system.

9 I do want to clarify a point. There are two safety 10 related demineralized water isolation valves which are 11 safety-related.

12CO-CHAIR SKILLMAN: That's great. I'm not 13 for putting in un-borated water. I agree with that.

14 MR. HARRIS: I agree.

15 MS. FOSAAEN: I think the key point --

16CO-CHAIR SKILLMAN: I want a lot of boron 17 and I want it now.

18 MS. FOSAAEN: Right. And our Chapter 15 19 analysis does not credit CVCS for any boron addition.

20CO-CHAIR SKILLMAN: I know. Isn't that 21 great. I want boron. I'm an operator. I want shut 22down. I want as much as negative reactivity as I can 23throw at that core for whatever reason. And I have no 24 way to do it unless I go through a daisy chain.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 64Doesn't that spark a little bit of uncomfort? I would 1 think it would to those who are people who have held 2reactor operator licenses. And every other 3 application, you push a button, you get copious boric 4acid. And on the Bs (phonetic) you've got slick. And 5on this plant, I don't have that capacity. Is that 6 something that ought to be looked at more thoroughly?

7MR. HARRIS: I'd also like to add that 8 there are redundant make-up pumps, redundant 9 recirculation pumps, so there's redundancy within the 10 system if an event a pump failed.

11 CO-CHAIR SKILLMAN: I still have a daisy 12 chain to get boric acid to my core. I'll just leave 13 it at that, okay?

14 MR. HARRIS: Okay.

15MEMBER MARCH-LEUBA: And I want to second 16 that opinion.

17 MR. HARRIS: Thank you.

18MEMBER MARCH-LEUBA: We will see in 19 Chapter 15. Thank you.

20MR. HARRIS: So the chemical and volume 21 control system is also the only system with 22connections to the reactor coolant system. The piping 23 runs outside containment, so it is the total scope of 24 the inner system LOCAs for consideration in NuScale 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 65 design.1 The containment isolation function for 2CVCS is also part of the containment system which is 3 covered in Section 6-2.

4 As I mentioned, CVC is equipped with two 5 automatic safety related fail closed demineralized 6 isolation valves to ensure no inadvertent boron 7dilution concentration. Those are covered by Tech 8 Spec 346 for containment isolation valves.

9 Section 936 is the containment evacuation 10 system and containment flooding and drain system.

11 These systems are used to transfer liquids and gases 12 between the containment vessel free volume and other 13 plant systems.

14 The containment evacuation system 15 establishes and maintains a vacuum in the containment 16 vessel by a moving water vapor and non-condensable 17 gases in the CNV. It also has a function to perform 18 leakage detection for a reactor coolant system.

19 The containment flooding and drain system 20 is used to flood the containment vessel with borated 21 water after shutdown in preparation to removing -- to 22 moving the module and it's also used to drain the 23 module prior to start up.

24 And the containment flooding and drain 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 66 system also has a function to provide borated cooling 1 inventory to the containment vessel during a beyond 2 design basis event.

3 The isolation function, containment 4 isolation function is covered in Section 6-2 and in 5 tech specs for these systems are 347, 349, and 373.

6 And here's just diagrams of the 7containment evacuation system. It consists of two 8redundant vacuum pumps. These pumps are operating 9continuously. Any liquid that's removed from the 10 vessel is condensed and collected and quantified in 11 the sample vessel and the non-condensable gases are 12 sent to either the reactor ventilation system or 13 gaseous rad waste system.

14 And the containment flood and drain system 15consists of two redundant pumps. There's one 16 containment flood and drain system per six modules, 17 north and south of the reactor building, so they each 18 serve six modules apiece.

19 On to 9.4 which is air conditioning, 20heating and cooling, and ventilation system. This 21covers control room area ventilation, reactor venting 22 and ventilation in the spent fuel pool, ventilation 23 radiative waste building ventilation, turbine building 24ventilation. Section 945 engineering, continuous 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 67 safety-feature ventilation system is not applicable to 1 the NuScale design.

2 A common element to these systems are they 3 are non-safety related or risk significant, not 4 credited for public dose mitigation. Any components 5which could adversely affect Seismic Category 1 are 6 designated Seismic Category 2 and we had a COL item to 7 specify periodic testing inspection program 8 requirements.

9CO-CHAIR SKILLMAN: Let me ask this on the 10 ventilation systems, one characteristic that people in 11the plant and the plants know real well is that 12ventilation systems are systems where you don't get 13wet and you don't get irradiated. And so most of all, 14 you ignore them and they sit there and they turn away 15 until the force draft fan of the blower breaks an axle 16 and starts making noise, if the maintenance doesn't 17 put some grease like they should. So it's squeaking 18 and you say something needs to be fixed.

19 But the ventilation systems provide the 20 negative pressure barriers and the contours for 21 ventilation to make sure that the operators are safe.

22 So here are these ventilation systems that are almost 23 not too different than a ventilation system in an 24 airplane hangar in this application.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 68 What makes sure that these ventilation 1 systems are performing the way they're supposed to?

2 Because they actually do perform -- you might not call 3 it a safety function, but it's certainly an important 4 function for the operators.

5MR. HARRIS: There's a number of assurance 6 that you would use to ensure system performance flow, 7pressure, pressure across filter banks. And you're 8 going to be continuously monitoring those systems and 9 even non-safety alarms tied to anything that would 10 identify improper performance.

11 CO-CHAIR SKILLMAN: Thank you. Right?

12MR. HARRIS: On to 9.5. It includes 13 communication system, lighting system, fire protection 14program, and fire hazards analysis. So the 15 communication system includes components for inter-16plant and plant off-site communication. This includes 17 private branch exchange, public address, general alarm 18 system, sound power telephones, distributed antenna, 19 and radios for point-to-point communication. Serves 20no safety-related risk significant functions. It's 21 not credited for design basis accidents or safe 22shutdown. And there are two COL items attached to the 23 system.24CO-CHAIR SKILLMAN: Let's back up. 9.5.1 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 69is your fire protection program. Chapter 9 is void of 1any description of your firefighting system. No 2identification of plumbing. I don't know how many 3 diesel driven fire pumps or electrically driven fire 4pumps you have. I don't know where your fire mains 5 are. You do communicate in Chapter 3.2 or Table 3.2 6 item 1. It's all non-safety and it's not seismic.

7 Fire protection is probably one of the 8 most important systems you have in the plant. But 9 there isn't anything in the design cert. application 10that points to this. What it does communicate is that 11some fire piping is likely Seismic II over I. And in 12that case, it won't be Seismic III. It will be 13 something else. But that's a real loose requirement 14 for what is at least in my judgment a critical system 15 in this design.

16 Why isn't there any treatment of the fire 17 system in Chapter 9?

18MR. HARRIS: So the fire protection system 19is described in 9.5.1. We'll be getting to that. We 20 kind of just reversed order so we could do the fire 21 hazards analysis together in this presentation.

22 CO-CHAIR SKILLMAN: I would suggest that 23 it's mighty sparse.

24MR. HARRIS: There's a large matrix table 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 70of compliance with Reg. Guide 1.189. And there's 1 where you get all of the specifications for how much 2water to be delivered to given areas. How many stand 3 pipes, what the yard configuration is, the separation 4 of the yard piping, and all that kind of stuff. All 5 that is included in the compliance to Reg. Guide 1.189 6 table in Section 9.5.1.

7 MEMBER BLEY: It sounds as if the system 8 is not designed yet. Is that right?

9MR. FIELDS: I don't know how -- what full 10 extent it's designed.

11MR. HARRIS: It's designed to the point 12 necessary for DCA.

13 MEMBER CORRADINI: Say that again?

14MEMBER BLEY: There's no schematic.

15 There's no --

16MS. FOSAAEN: There is, in 9.5.1, there's 17Figure 9.5.1-1 and it shows the pumps, the tanks. So 18 there are high-level schematics in 9.5.1 at the tail 19 end.20MEMBER MARCH-LEUBA: Can you say again 21 what table?

22 MS. FOSAAEN: 9.5.1-1 and 9.5.1-2.

23MEMBER CORRADINI: But you made a point 24 and maybe I didn't understand it. You said it's not 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 71 required for DCA?

1MR. HARRIS: I'm not saying that. I'm 2 just saying that it's designed up to the point 3 required for design specification application. It's 4 not in detailed design.

5 MEMBER CORRADINI: Thank you.

6C0-CHAIR REMPE: So I didn't come back and 7 give you examples where I found the QA program might 8have a problem. I think that they throughout the 9 staff's review, they noticed the seismic categories 10were incorrectly identified. There were plant layout 11 drawings that had been updated and not reflected in 12 the DCA.

13 I'm just kind of wondering again when you 14 have something that's only designed up to a certain 15 extent, is there going to be a good process in place 16 that will say oh, I need to change something because 17 of the fire protection system design, a wall needs to 18 be thicker and you'll have noted it there, but it 19won't get updated other places in the DCA. And I'm 20 bringing this up not to pick on you, but we've 21 actually had examples for a certified design had not 22 been updated and it's a real costly endeavor to change 23a certified design. And so that's why I'm wondering, 24 do you have confidence you've improved your QA system 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 72 that you'll be able to track requiremen ts from 1 different systems that if that's the actual plant 2 design and say oh, I need to change it here, too, 3 because whatever system?

4 I mean how -- we noticed some problems and 5 say oh, yeah, we need to fix it and we have done that 6 or you just don't think it's a problem yet?

7MR. FIELDS: Yes, we've gone through a 8 very painstaking process over the last year to ensure 9 that the DCA is under configuration control and we've 10 captured changes that we had missed in previous 11 changes --

12 C0-CHAIR REMPE: That's the answer I was 13 looking for.

14MR. FIELDS: Yes, we've been going through 15 that process to go ensure that and as we grow and as 16 we change into customers and other applications, we're 17 setting up systems to capture that so that it doesn't 18 cross pollinate or doesn't cross boundary lines for 19 one design versus another.

20 C0-CHAIR REMPE: Thank you.

21MEMBER BROWN: I would presume the COMS 22 systems that you talk about in your first paragraph 23 there include general alarm systems, branch, public 24 address, and it's intra-plant as well as plant to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 73 offsite.

1 Is there any definition of how those 2 communication systems are ensured that they don't 3 provide false information to plant people since your 4external to internal plant information? For instance, 5 a general alarm could be sounded based on a cyber-6attack that comes in and turns on the alarm and 7 everybody puts their hair on fire, or is that say, you 8 don't specify anything relative to that through the 9 COL anywhere?

10 Are you putting it off or are you trying 11 to isolate critical functions that could provide 12 general alarms throughout the plant, so as to not 13 inadvertently done by hacking. I'm sure your system 14 is computer controlled. They're all done that way.

15MR. HARRIS: Yes, if I may, I'd like to 16 Jeff Ehlers, our electrical supervisor, who is on the 17 phone?18 MEMBER BROWN: Your who?

19MR. HARRIS: Jeff Ehlers. He is our 20 electrical supervisor on the phone address that 21 question.22MEMBER CORRADINI: Jeff, are you out 23 there?24 MR. EHLERS: Yes, I'm sorry, we just got 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 74off a minute. So yes, I would figure any software, 1 any software that we use for our communication system 2 will have to be under the software QA program and meet 3 the same requirements as all the other software in the 4 plant for cyber security.

5 And other than that, communication systems 6 are all specified to be encrypted to add another layer 7 of protection there.

8 MEMBER BROWN: By encrypted, what do you 9mean? It sounds good, but I'm -- encryption means if 10 I send something somewhere, you have to have a fancy 11algorithm on the other end to decrypt it. And you 12have to encrypt it to start with. I presume -- I'm 13 not a designer, but I assume that's the right thought 14 process.15MR. EHLERS: Yes. I believe you're 16correct. We have not specifically made -- stated any 17 specifics about that encryption, but there is a 18 requirement in the DCA for all communications to be 19 encrypted.

20MEMBER BLEY: I've got a question. I 21 spent time in the Navy and we used sound powered 22phones all the time. I don't usually see them in a 23 commercial plant. Will they be throughout the plant 24 to be used when the other com systems don't work well?

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 75MR. HARRIS: Jeff, can you answer that 1 one?2 MR. EHLERS: Sorry, the beginning of the 3 question --

4 MEMBER BLEY: Yes. I haven't seen sound 5 powered phones in commercial plants. Of course, the 6 Navy has had them forever.

7Two questions about it. One, are they 8 rigged throughout the plant so operators can use them 9 when other communication systems are down? And two, 10 all the ones I'm familiar with have really hideous 11 frequency response and the first time you use them, it 12just sounds like gobbledy-gook and you have to 13 practice for a week or more and pretty much routinely 14 to be able to understand people. You can understand 15 perfectly well when you're used to them.

16 And is there anything about training 17 people on using these sound powered phones or maybe 18 they're better than they used to be.

19MR. EHLERS: Well, I think your first 20question is about the industry. They're already used 21in the industry. They were used at my Houston plant.

22MEMBER BLEY: Oh, okay. I haven't seen 23 them, but go ahead.

24MR. EHLERS: Yes, they do have in the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 76nuclear industry. They do use them. There are 1 designed -- they are jacks installed in various 2 locations to be able to plug one in and use -- as long 3 as you have a proper path that you can be able to use 4 it.5MEMBER BLEY: Okay, so the jacks are 6 around the plants such that you could use them for any 7 operations you need to do?

8MR. EHLERS: Correct. If you lose all the 9 other battery pack communication systems, either 10 wireless, fiber optic, or whatever, then yes, you have 11 the sound powered to use.

12MEMBER BLEY: Okay. What about legibility 13 and practice on them?

14 MR. EHLERS: Legibility and practice?

15 MEMBER BLEY: Yes, the ones I'm used to, 16 if you don't use them regularly, you can't understand 17what anybody is saying. You have to practice kind of 18 routinely to be able to understand. Frequency 19 response, or at least used to be horrible on them.

20MR. EHLERS: We don't have any 21 specification for, you know, how they would practice, 22 but I'm assuming would be in their ERO drills and 23 stuff like that where they would practice that kind of 24 drill where they have to go to their sound powered 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 77 phones. I know we have.

1 MEMBER BLEY: Okay, so that's left up to 2 whoever is going to operate the plant?

3MR. EHLERS: Yes, it's part of the 4 emergency preparations they do.

5 MEMBER BLEY: Okay.

6MR. HARRIS: On to 9.5.3, our lighting 7 system, plant lighting system provides artificial 8 illumination for buildings, room spaces, and outdoor 9areas of the plant. The functions include normal 10 plant lighting, emergency plant lighting, normal and 11emergency main control room lighting. It's in 12accordance with NUREG post-700. We have emergency 13 lighting fed from our DC power system for a minimum of 14 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and a battery pack for one and a half hours 15 for egress or exiting in accordance with NFPA 804.

16 And the plant lighting system also 17 provides emergency lighting with battery pack for 18 eight hours for post-fire, safe shutdown activities 19 outside of the main control room.

20 Line 5.1 is our fire protection program.

21 The objective of our fire protection program is to use 22 defense in depth to achieve the required degree of 23 reactor safety. Our safe shutdown relies on passive 24 fire protection and redundant safe shutdown of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 78 equipment is separated by three-hour fire barriers.

1 So part of that defense in depth is prevent fires from 2 starting, to rapidly detect, control, and extinguish 3 fires that do occur, and provide protection to 4 components important to safety.

59.a, fire hazards analysis. Our fire 6 hazard analysis demonstrates that the plant maintains 7 the ability to perform its safe shutdown functions and 8 minimize radioactive material release in the event of 9a fire. So our hazard analysis considers in-situ and 10 transient fire hazards, determines the effect of any 11 fire -- of a fire in any location in the plant and its 12ability to safely shut down the reactor. Also 13 specifies measures for fire protection prevention, 14 detection, and suppression.

15 Within 9.a, our special cases are a main 16control room fire area. We have switches that provide 17 back-up control of systems, automatically controlled 18 by module protection system.

19 In the event of a main control room fire, 20 we have manual switches associated with module 21 protection functions to isolate those actuations.

22 Those switches are located outside the main control 23 room. 24 For containment fire area, it's highly 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 79 unlikely due to our containment is held at a vacuum.

1 Our electrical conductors are made of noncombustible 2 material and a lot of the conduit is inaccessible 3during normal operation. And also during shutdown, we 4 flood our containment which also helps prevent 5 ignition or the spread of fire.

6For the top of module fire area, also 7considered highly unlikely. It's enclosed in our bio 8 shield and cabling under the bio shield is in a 9conduit or three hour rated cable. This top of module 10 area is inaccessible during normal power operations.

11 The hydraulic hood used in our containment isolation 12 valves is specified to be noncombustible.

13 For our containment isolation valves and 14 decay heat removal system actuation valves, these 15 valves move to their safe position using stored 16 pressurized nitrogen accumulators.

17 And between modules, there is a three hour 18 fire barrier with the exception of the bio shield 19 while facing the reactor pool.

20 And during shutdown, the bio shields are 21 moved and administrative controls placed on that area 22 for combustible -- for transient combustibles.

23 CO-CHAIR SKILLMAN: Where are the valves 24 that are hydraulically actuated located?

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 80MR. HARRIS: All of our containment 1 isolation valves are hydraulically actuated and heat 2 removal actuation valves are also hydraulically 3actuated. They're all located on top of the actual 4 module.5CO-CHAIR SKILLMAN:

So if you had a 6 hydraulic leak, where would the hydraulic fluid leak 7 to?8MR. HARRIS: Assuming it's gravity 9 draining, just leak on top of the module and into the 10 pool.11CO-CHAIR SKILLMAN: Into the pool. And 12what is the fluid? What is the hydraulic fluid? Is 13 that like automatic transmission fluid?

14MR. HARRIS: I can't speak to the 15specifics of the hydraulic fluid. It is 16 noncombustible.

17CO-CHAIR SKILLMAN: But it is a 18 hydrocarbon.

19 MR. HARRIS: Again, I can't speak to the 20 specifics of it.

21MR. FIELDS: I don't know if it's been 22specified fully at this point. It's just that it's 23 noncombustible 24MEMBER CORRADINI: Do you specify it this 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 81 way?1MR. FIELDS: I don't believe it's fully 2 specified what we're going to use, but it's just a 3 noncombustible hydraulic fluid.

4MR. HARRIS: And just to reiterate, to go 5 to the safe position for all these valves I mentioned 6 does not require any hydraulic fluid. It's all done 7 by nitrogen spring.

8 So there's a vessel on top or connected to 9 each containment isolation valve and to actuate the 10 valve you actually remove, you vent that hydraulic 11 path and it has that hydraulic path vents during 12 nitrogen spring -- moves the valve to the safe 13 position.14CO-CHAIR SKILLMAN: At what pressure is 15 the hydraulic fluid?

16MR. HARRIS: I'm not prepared to answer 17 that question.

18 CO-CHAIR SKILLMAN: I suggest you take a 19look at the operating experience from TMI II. We 20 leaked hydraulic fluid and we ended up with leafy 21 green vegetables because whatever is in that water 22 that may be organic will go after that hydraulic fluid 23 and it will grow.

24MR. HARRIS: And there are instruments in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 82 place to identify if hydraulic pressure is reducing 1 and thus identifying a leak.

2CO-CHAIR SKILLMAN: I didn't realize there 3was hydraulic fluid over the pool water. So I'll 4 leave that with you. Thank you.

5MEMBER MARCH-LEUBA: Let's continue on 6 that. I'm looking at this figure 9.5.1-1 and what I 7 see here about it, fire protection system is two big 8 water tanks and three pools that spray water into 9whatever is inside the plant, right? So am I to 10 assume that you are spraying water on top of all of 11 the control room computers and control system and the 12operators? Or is there a second fire protection 13 system for the control room and the controllers?

14 What it specifies here is that you're 15 going to be spraying water inside the control room and 16 obviously, make it completely inhabitable and 17 nonworking.

18MR. FIELDS: If Ed Siener's on the line we 19 could have him answer that question for you.

20MR. SIENER: Could you repeat the 21 question, please?

22MEMBER MARCH-LEUBA: What type of fire 23 suppression system do you have in the control room and 24 all the controllers, computers, electrical system?

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 83MR. SIENER: In the control room 1 specifically, there's no automatic water suppression.

2 It's a continuously operated control room so we rely 3on detection and manual suppression in the control 4 room.5 In electric rooms, it's somewhat similar 6depending on the fire loading. I would say generally 7 in an electrical room, there is not automatic 8suppression. There's detection with manual 9 suppression located per code.

10MEMBER MARCH-LEUBA: Is that specified in 11 the CVA somewhere or it's a COL item?

12MR. SIENER: Well, one place it is located 13in is the 9A where we have every fire area in the 14 plant and it says specifically whether it does or does 15 not have automatic suppression.

16MEMBER MARCH-LEUBA: Okay, I'll look it up 17 now that I know where to look.

18Second related question, when you look at 19 the drawing of the plant, most of it is underground 20 and most of it -- well, one would consider it water-21tight rooms, for example, the battery room. It's 22underground and fairly water tight. When you turn on 23 all those sprinklers in the event of a fire, what 24 happens to the water that accumulates on the floor?

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 84 Because it's underground, so the only way you can 1drain that water is with an active pump system. Does 2 nothing exist or do you just want to make a swimming 3 pool of the battery room?

4MR. SIENER: No, the NFPA code 5 specifically address drainage and any of those rooms 6 with automatic water suppression would have drainage 7that would not allow de-pooling of water. Most 8 electrical equipment, other important equipment would 9 probably be elevated so that we could deal with small 10puddling on the floor. But the drainage would take 11 care of any buildup of water.

12MEMBER MARCH-LEUBA: These are underground 13rooms, so it would have to be active draining. You 14 have to have power and you have to have a pump 15working. But the point that mostly Dick is making 16 which he has a lot of experience on this is that fire 17protection is probably the most important thing you 18 can do in this plant for safety and it looks a little 19 light on the CVA.

20MR. SIENER: A huge advantage NuScale has 21 is compartmentalization. There's a lot of rooms and 22 we're able to separate all the safe shutdown 23equipment. We're using three hour fire barriers 24except where notified in those special cases. So our 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 85 suppression -- we assure safe shutdown by separation 1 of the equipment, so the suppression is really more 2 for defense in depth and human safety.

3CO-CHAIR SKILLMAN: But just remember, 4 Browns Ferry was designed with that same, if you will, 5mental framework. TVA intended for those plants to be 6 extremely safe and they underwent a terrible fire.

7 And my point would be that sometimes fires 8 happen and they get away from you and they're 9 insidious because they actually have a mind of their 10own. You can think you're going to drive that fire 11 and the fire will drive you and you've got a couple of 12choices. You can prevent it from happening by having 13 no combustibles or you can make the compartments so 14 small that there is no real threat to the rest of 15 plant, but now you are confined basically like a rat 16 in a cage. You can't get to it.

17 And so the whole issue of firefighting is 18 one that warrants a kind of a front lobe attack at the 19 design stage to make certain that the fire cannot get 20 to where it shouldn't get to. And where it's really 21 problematical is in the control room and your switch 22 gear and particularly where your cable spreading 23occurs. You don't need the sermon, but just recognize 24 again it happened at Browns Ferry and those of us who 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 86 have had maritime experience, the worst thing that can 1 happen is that you're so compartmentalized you can't 2 get to it which means you have to have ample either 3carbon dioxide or Cardox or wintergreen or whatever 4 you're going to have or at Browns Ferry copious 5 amounts of water readily available which means your 6 headers and your hoses have to be ready to go.

7C0-CHAIR REMPE: Colleagues, we're already 8 like 30 minutes behind, so let's let them go through 9 and then we need to decide whether we're going to 10bring the staff up or have a break before. But we are 11 way behind, okay?

12 Go ahead.13MR. HARRIS: This is our last slide, just 14 listing out our COL items, or no COL items for fire 15 protection, no unique COL items for fire protection.

16 We have generic items for fire protection program 17 development, procedure development, implementation, QA 18program, training. And no unique COL items for the 19 fire hazards analysis, just COL items to provide site 20 specific fire hazards analysis and that's it.

21C0-CHAIR REMPE: Do we want to have a 22quick break and come back? So let's do that and it's 23 10:16 by my clock, so let's get back here by 10:25, 24okay? And that will give us staff time, but I didn't 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 87 want to cut into the chapter 16.

1 (Whereupon, the above-ent itled matter went 2 off the record at 10:16 a.m. and resumed at 10:25 3 a.m.)4CO-CHAIR REMPE: Okay. We're back. It's 510:25 and I'm going to bang the gavel. So, please sit 6down if you're in the near area. And the rest of the 7 members will come as they can.

8So let's restart. And I'm not sure which 9 of the staff is beginning, but okay, please start.

10 MR. TESFAYE: Good morning everyone. My 11name is Getachew Tesfaye.

I am the NRC Project 12 Manager. Can you all hear me?

13 I'm the Project Manager for Chapter 9 of 14 Auxiliary System. The staff has completed the Phase 15 Two safety evaluation for the open items and submitted 16 it to ACRS.

17This report contains four one items. And 18 one of them, one of the open items has since been 19closed. And the remaining open items will be 20 addressed in Phase Four of this review.

21 Chapter 9 comprised of five major areas, 22review areas and 26 sections. And our presentation 23 slides have 41 slides, but due to time limitation, 24 we'll focus our presentation on Section that have open 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 88 items and areas where we believe there is ACRS 1 interest.2 Those who are presented are -- who are 3presenting are sitting here with me. And the rest of 4 the technical staff is up in the audience.

5 With that, I'll ask the presenters to 6 first introduce themselves.

7MS. SIWY: Alex Siwy, NRO Reactor Systems.

8MR. STUTZCAGE: Ed Stutzcage, Radiation 9 Protection Reviewer.

10 MR. NOLAN: Ryan Nolan, Reactor Systems.

11MS. SACKO: Fanta Sacko, Electrical 12 Engineering Branch in NRR.

13MR. TESFAYE: And the rest of the 14 contributors to this 41 slide package are Alissa 15 Neuhausen, Raul Hernandez, Hanry Wagage, Chang Li, 16 Angelo Stubbs, Bob Vettori, Tony Gardner, Alexander 17 Chereskin, Andrew Yesnick, Nan Chien, and Dawnmathews 18 Kalathivettil.

19 So, with that, if it's okay, we'll do the staff 20 observation.

21MS. SIWY: Thanks Getachew. Again, my 22name is Alex Siwy. And I'll walk you through the 23 staff's review of Section 911.

24 The main objective of the review of this 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 89 Section is to verify that fuel will remain sub-1 critical during all credible storage and handling 2 conditions in accordance with 10 CFR 50.68 and GDC 62.

3 The main guidance that the staff used for 4its review is SRP Section 911. And there are several 5topics in this review area as are listed on this 6 slide.7 As a result of the staff's review, the 8 staff finds that the applicant's criticality 9 calculation methodology is acceptable and adequately 10 benchmarked. And the applicant's criticality models 11 correctly incorporate design information and use 12 appropriate assumptions.

13There is an open item related to the 14analysis. And that is that the applicant is making 15 the structural analysis of the racks, a COL item.

16 The implications of this COL item on the 17criticality analysis is that a COL applicant would 18 have to show that any rack deformation or relocation 19 due to a seismic event or a fuel assembly drop would 20 be bounded by the existing criticality analysis.

21 And if it weren't, then the COL applicant 22 would have to re-analyze. Right now this is an open 23 item pretty much because the staff is working with the 24 applicant and OGC on the wording of the COL item.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 90 Other than that, the staff generally 1 accepts the approach.

2 So, other than the analyses that are 3 related to that COL information item, the staff finds 4 that the applicant's criticality analyses do comply 5 with 10 CFR 50.68 and GDC 62.

6CO-CHAIR SKILLMAN: Alex, let me ask this 7 question, please.

8 MS. SIWY: Sure.

9CO-CHAIR SKILLMAN: On the safety 10 evaluation on page 12, the safety evaluation 11 communicates about two thousand PTM.

12 And then on page 13 is the statement, DCA 13 Part Two, tier two, section 911 states that the large 14 volume of water, about seven million gallons by the --

15 in the UHS prevents an undetected boron dilution 16 accident from the normal -- I think it's nominal, 17 nominal boring concentration of about 18 hundred to 18 below eight hundred.

19My question, is it two thousand or 18 20 hundred?21MS. SIWY: I'd have to double check the 22 table in the DCA. I think --

23 CO-CHAIR SKILLMAN: I thought it was two 24 thousand.25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 91 MS. SIWY: Yeah. I think they're aiming 1 for two thousand. But I think there is one table in 2 the DCA, in chapter 9 that says at least 18 hundred.

3CO-CHAIR SKILLMAN: Thank you. All right.

4 Thanks.5MS. SIWY: Okay. Yes, next slide. So, 6 the staff also conducted an independent confirmatory 7 analysis that support the applicant's conclusions with 8 regards to the acceptance criteria.

9 The staff also notes that the tier one 10 information is complete and consistent with tier two.

11 And that the Tech Specs related to fuel storage 12 adequately protect the assumptions in the criticality 13 analysis.14 With regard to materials for fuel storage, 15 the staff notes that NuScale has not specified a 16neutron absorbing material. And there is a related 17 open item in which the staff requested additional 18 details on the impacts of manufacturing on neutron 19 attenuation, materials qualifications for the spent 20 fuel pool environment, and manufacturing process 21 controls.22 The staff and applicant recently agreed on 23 a path forward for this open item by creating a COL 24 item to address the staff's concerns. And like with 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 92 the other open item, the staff and the applicant are 1 working on wording of this right now.

2 The staff also notes that the applicant is 3 implementing a neutron absorber monitoring program 4that's consistent with TSTF-577, Revision 1. And 5 utilizes the staff approved NEI 16-03 guidance for 6 monitoring a fixed neutron absorber and spent fuel 7 pools.8 And this provides the staff reasonable 9 assurance that degradation of neutron absorbing 10 material can be adequately detected so that the 11 neutron absorber continues to provide the credit 12 criticality control.

13That concludes my presentation. Are there 14 any questions?

15MR. TESFAYE: Thank you Alex. And Section 16 9.1.2, new spent fuel storage, there was one open item 17related to the fuel gage protection system. The 18information we received was provided by NuScale. And 19 we have since closed that open item.

20 And for the next sections, we don't have 21any open items. The slides are presented. If you 22 have any questions, we'll be glad to address them.

23No open items in water system either. So, 24the next open item is in Section 9.32. If it's okay, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 93 I would like to jump to that slide.

1MEMBER CORRADINI: No. I think you're 2 going the wrong direction.

3MEMBER BLEY: On 9.1.2-1, RAI response, 4you say that one's closed now. Did you investigate 5 how they ensure they have mixing in the -- in fuel 6 pool so the boron concentration is the same 7 everywhere?

8MR. TESFAYE: Okay. Raul, would you 9 please address that question?

10MEMBER BLEY: And hot just the pumping, 11 but how they do sampling to make sure it really is 12 mixed.13MR. HERNANDEZ: This open item is not 14related to the boron solution issue. The open item in 15 front of us is related to leakage detection.

16 And the spent fuel pool and the ultimate 17 heat sink having an adequate leakage channel behind 18the walls to detect leakage. And the latest response 19 they added.

20 For the boron solution issue, I don't have 21the exact location of the sampling point. So I cannot 22 talk about that.

23I can mention that the suction in the 24 returns from the cooling systems are located at 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 94 different points on the pool that would allow the flow 1 of water to increase mixing and help prevent having 2 stagnant areas of water.

3 MEMBER BLEY: How are you convinced they 4 don't have any stagnant areas?

5 I've seen lots of tanks where people were 6 surprised when they finally sampled at a different 7 place then they'd been sampling and found very 8 different concentrations.

9MR. HERNANDEZ: Based on the drawings and 10-- I have not -- I don't expect there to be one. I 11 don't have any specific details to give you right now 12 at this moment.

13MEMBER BLEY: So you don't know of really 14 having mixing.

15MR. HERNANDEZ: At this moment I cannot 16 answer the question specifically.

17 MEMBER BLEY: Okay.

18 MEMBER CORRADINI: Is there --

19 MEMBER BLEY: I'm sorry.

20 MEMBER CORRADINI: Oh.

21 MEMBER BLEY: Go ahead Mike.

22MEMBER CORRADINI: Well, I just wanted to 23ask, there's a COL information item, 9.1-1. I guess, 24 and it was about procedures relevant to handling of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 95 storage of spent and new assemblies and criticality 1 control.2This isn't related. But in some sense, 3 their leak -- as I understood when we were asking 4 NuScale, they're leaving it to the operator to develop 5 procedures to determine that they have good sampling.

6 And it is homogeneous.

7 That's how I interpreted.

8MEMBER BLEY: I didn't hear them say that.

9 They said, yeah, the operator will have to figure out 10 where they're going to sample.

11 But, nothing about we have been mixing, we 12have checked for stagnant areas. We make sure you've 13 got the uniform solution.

14 I didn't hear anybody say that that was a 15 requirement that was laid out.

16 MEMBER MARCH-LEUBA: I guess my question 17 is more for Alexander who is the technicality person.

18 Is there any place in the UHS where we make ready for 19 the boron other than the fuel suppression at the spent 20 fuel pool?

21 MS. SIWY: I specifically focused on the 22spent fuel pool part. The other instance I could 23 think of is during refueling.

24 MEMBER MARCH-LEUBA: Yeah. I don't -- I 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 96 don't think there is any transient that results in 1 water around the pool that inside the vessel.

2 And the containment is always intact.

3 MS. SIWY: Um-hum.

4MEMBER MARCH-LEUBA: So, just a 5 recommendation, if I were going to sample it, I would 6sample it in the spent fuel pool drain line, the 7suppression line. That's where I would make sure that 8 the boron is within specs, because that's where it's 9 needed.10 But that's my opinion.

11CO-CHAIR REMPE: I believe there's someone 12 from the audience who had a comment? Oh, okay.

13 Sorry.14MR. TESFAYE: Okay. Are we ready to move 15 on?16CO-CHAIR SKILLMAN: Getachew, what 17 challenge, if any, did the staff raise about the 18 adequacy of the thickness of the pool liner floor?

19MR. TESFAYE: Yes. We have that question 20 for. Raul, do you have the answer to that?

21MEMBER BLEY: If we speak more directly in 22the microphones, everybody can hear you better. It's 23 surprising how bad the acoustics are.

24 MR. TESFAYE: Yes. Okay, I'm sorry.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 97MR. HERNANDEZ: Can you repeat the 1 question, please?

2MR. TESFAYE: That how confident are we --

3CO-CHAIR SKILLMAN: The question is, what 4 consideration did the staff give to the adequacy of 5 the thickness of the pool liner floor?

6 There's a stainless steel liner down 7there. It sounds like it's a quarter of an inch, 8maybe half an inch. And there are going to be 9 multiple 730 ton loads --

10 MR. HERNANDEZ: Okay, --

11CO-CHAIR SKILLMAN: Transported over or 12 dragged over that very thin membrane.

13 MR. TESFAYE: Okay.

14MR. YESHNIK: This is Andrew Yeshnik. I'm 15 a materials engineer in the Office of New Reactors.

16 CO-CHAIR REMPE: Speak up.

17MR. YESNICK: Closer? Oh, sorry. That 18was not credited. The liner itself is not credited 19 with any sort of structural function in the case of a 20 drop.21 The drop is precluded so it's not part of 22 the design.

23MEMBER MARCH-LEUBA: So if it drops, it 24breaks? Or it has a high probability of breaking? Or 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 98 at some point --

1MR. YESHNIK: It will probably deform, 2 yeah.3 MEMBER MARCH-LEUBA: Huh?

4 MR. YESHNIK: I mean, it's a very heavy 5 load.6 MEMBER MARCH-LEUBA: The difference --

7MR. YESHNIK: I have not seen the analysis 8 of what that load specifically is, but.

9MEMBER MARCH-LEUBA: I heard you say 10earlier something I liked very much. There is a leak 11 detection system.

12 MR. YESHNIK: Um-hum.

13MEMBER MARCH-LEUBA: I'm pretty sure there 14is one on the spent fuel pool. But is there one on 15 the UHS?16 MR. YESHNIK: Yes.

17MEMBER MARCH-LEUBA: So there are channels 18 underneath, if it breaks we will see it before the 19 pool starts dropping?

20MR. YESHNIK: No. Those channels are 21designed to detect any leakage of the wells. Not the 22 entirety of the UHS.

23MEMBER MARCH-LEUBA: Oh, so it's not an 24 out leakage for this in use?

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 99 MR. YESHNIK: Um --

1 MEMBER MARCH-LEUBA: Ignore me.

2MEMBER CORRADINI: If the well is cracked, 3 it's swept along the weld line.

4 MR. YESHNIK: That's correct.

5MR. HERNANDEZ: I just wanted to add that 6 and this is not unique to this design. There are in 7 other designs, the liner itself, it doesn't have the 8 function of retaining the water.

9 The function is basically to protect the 10 concrete. The concrete structure is the one that is 11 holding the water and is designed to maintain the 12 integrity.

13 We do monitor the wells between the plates 14 to ensure that there is no long term degradation of 15 the concrete because of all known leakage.

16 But, like Andrew just said, the liner is 17 not credited to retain the water. It's the concrete 18 structure.

19CO-CHAIR SKILLMAN: I assure you my 20 question was not aimed at suggesting the liner has any 21 structural component whatever. The liner is nothing 22 more than a membrane.

23 But if that membrane is injured because of 24 whatever reason, that is a common mode failure for 12 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 100 live core reactors.

1Now let me say that again. If you tear 2 that liner, if you drop a module, if you drop a fuel 3 assembly, if you drop a fixture, if you drop a reading 4 device onto a one-quarter inch thick membrane that is 5 well supported, I suspect that there will be a 6 puncture wound.

7 And you will have to do something to 8 repair that liner. And that's a common mode failure 9 on a single pool that's cooling potentially 12 live, 10 160 megawatt reactors.

11That's a problem. And that means that 12 floor liner should probably be more then a one-quarter 13 inch membrane.

14 It should be either armored for the load 15path. Or otherwise precluded from sustaining a 16 puncture wound.

17 One man's opinion.

18MR. TESFAYE: I think we've taken a note.

19 So we'll look into that.

20CO-CHAIR SKILLMAN: So the answer to my 21 question is, the staff did not consider beyond a 22 quarter of an inch or whatever that membrane thickness 23 is.24And that was not challenged. I believe 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 101 the answer is no.

1 MR. TESFAYE: No.

2 CO-CHAIR SKILLMAN: Okay. Thank you.

3MR. TESFAYE: Thank you. Any other 4 questions on this?

5 (No response) 6MR. TESFAYE: If there are no questions on 7 the next Section 9.1.3 spent fuel pool cooling and 8 clean up system and light load handling and systems, 9 I'd like to move on to the next section that has an 10 open item.

11We have no open items on water systems.

12 Okay. Ed, let's move onto.

13MR. STUTZCAGE: Hi, I'm Ed Stutzcage.

14I'll be present 9.3.2. Which is process and post-15 accident sampling systems.

16 The purpose of the process imposed 17 accident sampling system is similar to other designs.

18 It is to collect and analyze the chemical and 19 radiochemical conditions from the primary and 20 secondary systems and other systems including the 21 containment atmosphere. Next slide, please.

22 There's no dedicated post-accident process 23sampling system used in the NuScale design. The 24 normal process sampling system is used during post-25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 102 accident conditions.

1 I'll be focusing mostly on post-accident 2 sampling, because we had no open items for normal 3 sampling.4 For post-accident sampling, we actually 5had seven open quest -- open items in Chapter 9. And 6 nine open questions in Chapter 12.

7 They're all related to the post-accident 8 sampling process, which is unique to NuScale's design.

9 And you can go to the next slide, please.

10 So in NuScale's design to collect liquid 11 samples during an accident, you'd have to un-isolate 12 containment, and send the fluid through the chemical 13and volume control system. Through the sampling line 14 where it would, you know, it would be sent through the 15 sampling point and collected.

16 For gaseous samples, it would also have to 17-- the containment would have to be un-isolated.

18 Liquid would have to be sent through the containment 19 evacuation system to the sampling system and then 20 returned to the containment through the containment 21 flood and drain system.

22 There were numerous staff concerns related 23to this. Particularly related to the dose, to workers 24 taking the samples and also the system operation and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 103 so on and so forth.

1 NuScale has recently requested an 2 exemption from the requirements of 10 CFR 3 50.34(f)(2)(8), which are requirements to take post-4 accident samples and within specific dose limits.

5 Instead they would -- they're requesting 6 to rely on continuously planning to take samples if 7 they needed to.

8 And part of their basis for this is, they 9 have other means of providing the inf -- of getting 10 the information that sampling would provide, such as 11 under the bio shield radiation monitors for 12 radiochemical conditions, they have hydrogen monitors.

13 However, NuScale's hydrogen monitors are 14on their sample lines. So they'd have to use a 15 similar process of opening the containment evacuation 16 system to monitor for hydrogen.

17 The exemption request is somewhat similar 18 to relaxations applied to the operating fleet in 19 several topical reports. But like I said, there are 20 some unique features in the NuScale design that are 21 being considered.

22 So, we're still evaluating the exemption 23 requests.24MEMBER CORRADINI: So, can I clarify this 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 104one? Because I didn't understand it. It's because 1 you're operating at low pressure within the 2 containment, and that creates an issue of how to take 3 the sample?

4MR. STUTZCAGE: There's different 5 challenges depending on what the conditions are inside 6containment. There's a possibility and my 7understanding that you would have to send nitrogen 8 into the system to push the gaseous fluid through.

9 And there's also potential challenges of 10liquids. If the water in the containment is too low, 11 depending on where you're at in the accident, and what 12 the accident is, you may have to do things to raise 13 the water level.

14 So, there's -- like I said, there's -- it 15 kind of depends on the situation and conditions.

16 MEMBER CORRADINI: So, their contingency 17-- would you help me out here? I should have asked 18 them and I forgot.

19 Their contingency is to do what in terms 20of sampling? Or is it yet to be determined because 21 we're in the middle of the RAI and the open items?

22MR. STUTZCAGE: NuScale's approach is that 23 they have other means to detect the information that 24sampling could provide them. However, if they really 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 105 needed to, and they chose, it would be beneficial to 1 take a sample.

2 They can, you know, they have the 3capability to do it. It's just they're only going to 4 rely on it if they determine it was, you know, 5 completely -- if they determine it to be beneficial.

6 They don't want to have a requirement to 7 have to be able to do it within, you know, a short 8 amount of time following an accident.

9MEMBER CORRADINI: But this is -- this RAI 10 is still going to remain open. This is --

11 MR. STUTZCAGE: Yeah --

12 MEMBER CORRADINI: Is 90.44.

13MR. STUTZCAGE: All of the -- yes. All of 14 the -- right. All of those questions remain open as 15 we evaluate the exemption request.

16 And then yeah, we make a determination on 17 that -- determination on that and we'll figure out 18 what to do with that RAI.

19 MEMBER CORRADINI: Thank you.

20DR. SCHULTZ: Is there a schedule for that 21 Ed?22MR. STUTZCAGE: I can't say we have a 23 definitive schedule at this point. Yeah, it came in 24 at the very end of January and we've -- yeah.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 106 DR. SCHULTZ: Got you. Thank you.

1 MR. STUTZCAGE: Any other questions?

2 (No response) 3MR. TESFAYE: Okay. Thank you. Next 4slide is on CVCS. Ryan Nolan will be presenting that.

5 MR. NOLAN: Yes. My name is Ryan Nolan.

6 I was one of the reviewers for the CVCS system.

7 And we don't have any open items in this 8 review area. However, there is an exemption request 9 that I'll spend a little bit of time discussing, as 10 well as some previous ACRS questions that we received.

11 I'll discuss some of those as well. So if you go to 12 the next slide.

13 So NuScale requested an exemption to GDC 14 33 which requires having a reactor coolant makeup 15 system to address for small breaks in reactor coolant 16 pressure boundary.

17 And NuScale's design doesn't rely on any 18 injection of ECCS from external tanks for adding 19inventory to the RCS. Instead, they rely on isolation 20 of the system, inventory retention.

21 And then the ECCS and the containment 22 vessels maintain the core coolability to meet the 23 SAFDLs. And the way the staff approached this is we 24 looked at it from both normal operation 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 107 considerations, as well as off normal.

1 And so for normal operations, we would 2 assume that CVCS is available to control inventory.

3 And then for off normal considerations NuScale relies 4 on the safety actuation isolation signals that would 5isolate CVCS as well as potentially containment. And 6 then rely on ECCS and containment to meet the SAFDL 7 requirements.

8 That's the finding we made on the 9 exemption to 33.

10MEMBER CORRADINI: If -- this is a kind of 11an off question. If they chose to un-isolate 12 containment and they isolate a wait use list, is that 13 selective?

14 Or is it un-isolated in all valves such 15 that if they wanted to operate ECC -- CVCS selectively 16 open the valves in there.

17MR. NOLAN: I'm not as familiar in like 18 recovery operation aspects of how they would actually 19do that. I would have to go back and look at the 20 design.21MEMBER CORRADINI: Yeah. But it's not in 22 the plan of how they want to address any sort of 23 accident situation. They go to isolation and --

24 MR. NOLAN: Correct. And rely on --

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 108MEMBER CORRADINI: To delay the high 1 pressures and low pressure ECCS.

2MR. NOLAN: Yes. And rely on ECCS for the 3 long term cooling requirements.

4MEMBER MARCH-LEUBA: Yeah, we -- we would 5 look at these events during Chapter 15 review a little 6 more. Because Chapter 15 is missing a few events.

7 MR. NOLAN: Um-hum.

8MEMBER MARCH-LEUBA: One of them is normal 9shutdown. And under normal shutdown, without CVCS 10 completely isolated, the reactor will start cooling 11 down by itself. And it will start shrinking.

12 MR. NOLAN: Um-hum.

13MEMBER MARCH-LEUBA: The water level will 14drop to 63 percent of volume. And I would like to see 15 what happens then.

16 I mean, during normal operation they will 17 have CVCS maintain the inventory in the vessel. And 18 the vessel is going to drop significantly in liquid.

19 And I have not seen that analysis to 20 ensure that it is acceptable.

21MR. NOLAN: Well, we'll go to the next 22 slide. We've received some questions --

23 MEMBER MARCH-LEUBA: Um-hum.

24MR. NOLAN: About mixing phenomena. A low 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 109 flow boron mixing phenomenon that we've seen in 1 boiling water reactors.

2 And I guess the phenomenon is at really 3 low flows, when you put boron into the lower vessel, 4 the boron has a tendency to settle out and not make 5 its way into the core.

6 And so in this drawing, what I'm trying to 7 illustrate here is that the CVCS injection line is 8actually above the core. It injects eight feet above 9 the core.10 And so if there is a phenomenon of low 11 flow or boron potentially setting, it actually has to 12 go into the core first before.

13 And this is just sort of teeing up a 14discussion in Chapter 15. This is a thermal hydraulic 15 phenomenon that we're currently looking at.

16 Boron dilution in long term, that's 17evaluated in Chapter 15. And then the mixing 18 methodology that NuScale has used for the dilution 19 events is evaluated in 15.4.6.

20MEMBER MARCH-LEUBA: My point is, of 21 course the vessel will never reach the temperature on 22 the UHS. But, it might get close.

23 Because after, a mounting there eventually 24will reach. If you start at 1850 psi, the density of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 110the vessel is 0.63 grams persistent. At the end of 1 the operation, this is 1.

2 So if you have complete isolation of 3 containment the water level will drop about 63 percent 4of what it was inside the vessel. So the operator 5 will start CVCS eventually. And they will put a lot 6 of water.7 And that water better not be un-borated.

8 And I don't see anywhere that that event is described.

9 I don't see any event in Chapter 15 or Chapter 19.

10 Maybe it is in Chapter 19.

11 I'm just putting it on the record, that 12there are events that I have not seen anywhere. Thank 13 you.14MR. NOLAN: One more point I wanted to 15make. Member Skillman, you mentioned earlier this 16 morning about -- you questioned the capability of 17 putting boron into the core and why is CVCS not safety 18 related, or questioning the pedigree.

19 And I'll just point out that that's a --

20the staff looks at that as part of GDC 26 and 27. And 21that's eval -- GDC 26 is evaluated in Chapter 4. So, 22 we'll have more discussions on that.

23More or less the answer is, there's two 24 elements of GDC 26 that requires independent means of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 111 using diverse principals for controlling reactivity.

1 First is control rods, which are safety related.

2 And then the second one is for controlling 3 rate of reactivity changes. And that's for our plan 4 in normal operations.

5 And so in this case, CVCS could be 6credited for meeting that portion of the GDC. It 7 doesn't specify that it has to be safety related.

8And then GDC 27, NuScale is seeking an 9 exemption for that. And that's evaluated in Chapter 10 15.11 CO-CHAIR SKILLMAN: Yeah. And what kind 12 of drove my comment this morning is my recognition 13 that you -- that NuScale is seeking an exemption from 14 GDC 27 and 33.

15 And those are basically key structural 16components for PWRs in terms of shutdown. And so here 17we have a proposed new design where the designer is 18 saying, I really don't need that boron.

19 And guess what, I really don't need a make 20 up system for a small break. I don't need the boron 21 because I've got another way to shut it down. And I 22 don't need Generalized Design Criteria 33 because the 23 only small breaks I'm going to have are in the steam 24 system.25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 112And I'm choking on that. It would seem to 1 me that a responsible reactor operator would say, I 2don't care what those words are. I want a backup 3shutdown system. And I want a pump that's going to 4 put that boron in there when I tell it to go in there.

5 It would just seem to me that that would 6have been the construct for a passive design. And the 7 addition of the boron does not need to be high volume.

8 It just needs a little bit.

9 That's why we have the slip. That's why 10 the newer reactor designs have direct vessel 11 injection.

12 Well, to me it's just counterintuitive.

13 And it seems like a very simple adjustment to what is 14 a relatively robust design. Thank you.

15MR. NOLAN: I understand. A lot of the 16 long term review areas, that's something that we look 17 at in Chapter 15.

18 And so, I'm sure we'll have lots of 19 discussions on that in the near future.

20 CO-CHAIR SKILLMAN: Thank you.

21 MR. TESFAYE: Okay. Any other questions 22 to Ryan?23 (No response) 24MR. TESFAYE: Thank you Ryan. And again, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 113 we don't have any other open items in the rest of 1Section 9.3. And Section 9.4 HESE, we don't have any 2 open items.

3So, if you don't have any questions on 4 those sections, I'd like to move onto the next section 5that has open items. Which is in Section 9.5.3, 6 lighting. Fanta?

7MS. SACKO: Okay. My name is Fanta Sacko, 8 and I'll be discussing Section 9.5.3, lighting 9 systems.10 The NuScale design plan lighting system is 11 a non-class one system that is not safety significant.

12 Not risk significant and non-safety related.

13 And it includes normal pin lighting, 14 emergency can lighting, normal and emergency main 15 control lighting.

16 The normal pin lighting provides 17illumination on the plant site and for plain 18buildings. The emergency plan lighting provides 19 illumination outside the control room or for loss of 20 normal lighting.

21 The normal and emergency main control room 22 lighting provides illumination under all operating 23 MENs testing and emergency conditions in the MCR.

24 Staff reviewed the FSAR to determine 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 114 whether the plan levels are adequate in all ten areas.

1 And whether the PLS can operate without adversely 2 impacting the operational control and maintenance of 3 FSCs.4 We conducted these reviews in accordance 5with SRP Section 9.5.3 and NUREG 0700. In summary, we 6 had one open item related to Reg Guide 175, which is 7 the physical separation between non-safety related 8 lighting circuits and safety-related circuits.

9And we had one confirmatory item. So the 10 completion of the staff's review of the plain lighting 11 system is awaiting the completion of Chapter 8 open 12 item regarding GDC 17 and 18 exemptions.

13 So, like I said, the open item in this 14 section relates to the physical separation between the 15 non-safety lighting and the safety-related circuits.

16 Regarding the staff verifying that the 17 design does not require a safety-related power. The 18 confirmatory item of plan illumination levels will be 19 addressed in phase four of the FSAR.

20 This concludes this slide presentation.

21MR. TESFAYE: Thank you Fanta. Any 22 questions to Fanta on lighting systems?

23 (No response) 24MR. TESFAYE: Okay. That completes our 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 115presentation. But I'd like to add a couple of things 1on schedule. There was a question on when are we 2 going to be completing the pass exemption requests.

3 Pass exemptions as all the other 4 exemptions, are reviewed in the Chapter that it's in.

5 And it's a phase four activity.

6 And phase four has begun for this chapter, 7 of it will be completed in accordance to the Chapter 8 9 schedule, Chapter 9/Chapter 12 schedule for phase 9 four. We do have a schedule.

10CO-CHAIR REMPE: Thank you. And thank you 11for a very succinct presentation. Because we're back 12 on schedule. I hadn't expected that.

13MEMBER MARCH-LEUBA: I wanted to make one 14 question. Just to put it on the record, because you 15 don't know the answer of this.

16 I am looking at the design diagram of the 17CVCS. Which is Figure -- it's on page 9.3. That's 1884, Figure 9.3.4-1. Which is a diagram of the 19 chemical boron control system.

20 And it shows that there is a continuous 21 sampling line on the discharge that comes from the 22vessel. So, we know what the concentration is in the 23 vessel by measuring this.

24 But, it does not show a sampling line on 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 116 the injection line, unless it's one of these heating 1 ones that isn't a sample.

2MR. NOLAN: It's just downstream of the 3 regen heat exchanger. It's a normally closed.

4 MEMBER MARCH-LEUBA: The one for PSS?

5 MR. NOLAN: Yeah.

6MEMBER MARCH-LEUBA: Okay. I take it 7 back.8CO-CHAIR REMPE: Thank you. If there 9 aren't any other questions, let's invite NuScale to 10 come back and discuss Chapter 16.

11 (Off mic comments) 12CO-CHAIR REMPE: So Ross, are you ready to 13 begin?14 MR. SNUGGERUD: Yes. All right. Hello, 15good afternoon. My name is Ross Snuggerud. I have a 16 Master's degree in Nuclear Engineering.

17 I have been in the industry for 25 years.

18I spent 15 of those at a PWR in Michigan. And I've 19 spent the last almost 11 years at NuScale.

20 MR. GROSS: My name is Carl Gross. I've 21 been in the industry for 39 years now, including old 22 licensing under Part 50 at Palo Verde.

23 I've worked in the operations and 24 licensing.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 117CO-CHAIR REMPE: Carl, you're going to 1 have to get closer.

2MR. GROSS: Worked in operations and 3licensing out there. And have been mostly in 4 licensing and operating programs since then.

5 Worked at about 25 commercial reactors and 6 five or six DOE sites in nuclear safety and then TSR 7 development there.

8MEMBER BLEY: Please try to stay closer to 9 the mic.10 MR. GROSS: Sorry.

11MEMBER BLEY: Because you disappear as 12 soon as you back off a little.

13MS. FOSAAEN: Again, Carrie Fosaaen, 14 NuScale Licensing Supervisor for Chapter 16.

15MR. SNUGGERUD: All right. So today we 16 are going to talk about NuScale's Chapter 16. Which 17 generally relates to the development of the technical 18 specifications that will be used by the COLA applicant 19 to submit specific technical specification for their 20 facility.21 The technical specifications -- who runs 22the slides? Do I? The technical specifications that 23 we've built are designed to support individual 24 modules.25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 118So, the tech specs will behave for the 1 operator much like they do in the current industry.

2 There would actually technically be 12 copies of the 3technical specifications. Our intent would be that 4 they are all the same.

5 But they deal with the technical 6specifications on a module by module basis. Shared 7 systems like the pool would potentially cause 8 actuations of the technical specifications across 9multiple modules. But they would be addressed 10 individually.

11 Some of the things that are unique about 12 the development of technical specifications for the 13 NuScale design are the fact that we have a simpler, 14 natural circulation design without the primary coolant 15 pumps.16We have passive cooling systems. Both the 17ECCS and the DHR system. We have a completely digital 18 module protection system.

19 We don't require any safety related AC 20power or any need for offsite power which has an 21impact on the tech specs. We don't have any credited 22 HVAC systems and no active support systems.

23 And we do move the reactor when we refuel.

24 So, all of those things impacted the execution of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 119 developing the tech specs.

1 Because the design is simpler and because 2 we have fewer systems that are incorporated in the 3 technical specifications, the ultimate document that 4 we generated is roughly half the size of the typical 5 set of instructions for a more conventional PWR 6 design.7In developing the technical 8 specifications, we used the criteria of 50 -- 10 CFR 950.36 to evaluate all the plant designs. Which was 10 largely a review of Chapter 15.

11 And we developed a topical report that 12 went through our evaluation of all of the designs.

13 This was unique for us because NuScale doesn't have a 14 predecessor plant.

15So we didn't have a predecessor set of 16tech specs that we could start and work to modify. We 17 started with a blank piece of paper.

18 So, we did a complete evaluation of the 19plant. We used the existing NUREGs for the base 20 designs, both PWRs and BWRs as source input where 21 appropriate.

22 And we used an operations group that 23 incorporates -- I want to make sure I get the numbers 24 right, but we have 18 previously licensed SROs with 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 120over 560 years of experience in operating nuclear 1 facilities.

2 And that experience went into helping both 3the development of the technical report and the 4 reviews of the technical specifications.

5 In addition, we followed the guidance of 6the standard tech spec writer's guide. And we 7 monitored industry actions.

8 So, in addition to the standard NUREGs 9 that exist, we also followed tech spec task force 10work. Both approved travelers and upcoming work that 11 is available to the public.

12 And evaluated whether or not those changes 13 were appropriate to the NuScale technical 14specifications. And incorporated what was appropriate 15 to our design where that occurred.

16 One thing I didn't mention on the slide, 17 but there were -- there's four criteria for 50.36.

18 The fourth one is a criteria that's used because it's 19 assumed to be prudent, not because it necessarily 20 meets any of the prescribed requirements.

21 And there are two features of the NuScale 22design that we included for prudency. That's the 23 manual actuation function and the remote shut down 24 function.25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 121 I mentioned earlier, and the committee is 1 clearly aware that we do move the module during our 2refueling process. And so that did change the way we 3 went about developing our mode definitions.

4 Sometimes the mode definitions get 5 confused because they're used very heavily in plant 6operations. But, the reality is, the mode definitions 7 are chosen to make applicability of the Section Three 8 tech specs easier for the operator to apply.

9 So you want to pick transition points that 10 logically follow the plant design, and make it easier 11 for the operator to know which sets of technical 12 specifics apply to any given mode of operation.

13 As a result, we got rid of the classic 14 mode two. Which is the low power hot mode. Because 15 at NuScale there were no unique requirements that only 16 applied to that mode of operation. So that mode was 17 removed.18 We added the mode transition which applies 19 to the reactor module while it's being moved and prior 20 to decoupling any of the bolts associated with the 21 lower portion of the reactor vessel.

22 So basically from the time you complete 23 your shutdown and prepare the module for movement, 24 until the time that you start manipulating bolts 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 122 associated with the reactor flange, that's the 1 transition mode.

2 And then finally, we have a refueling 3 mode. Which is not unlike the existing industry.

4 Just for clarity, the CRA is a control rod 5 assembly, see --

6MEMBER RAY: Wait a minute. You have a 7 refueling load that's not unlike existing industry?

8 MR. SNUGGERUD: At the point that --

9MEMBER RAY: What do you mean by unlike --

10MR. SNUGGERUD: At the point that we're in 11 refueling, the primary things that the tech specs are 12 concerned about, are monitoring for reactivity changes 13 in the core.

14 MEMBER RAY: Just tell me what you meant 15 by that statement.

16MR. SNUGGERUD: So, the kinds of things 17 that are required in our Mode Five, look a lot like 18 the kinds of things that are required in a refueling 19 Mode Five for other plants.

20 Obviously, ours is compressed. But it's 21 talking about the same types that evolutions is 22 talking about, picking up and moving fuel inside a 23core. And what's necessary to ensure that that's a 24 safe activity.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 123 I understand that my choice of words may 1 not have been appropriate.

2MEMBER RAY: Those words were not 3 appropriate. Period.

4MR. SNUGGERUD: From what basis? Help me 5 understand why you feel that strongly.

6MEMBER RAY: Well, you've done refuelings 7before. You're moving fuel elements one at a time in 8 and out.9 This is moving an entire core and a 10 reactor and its vessel with a core, you know, the 11entire core inside of it. That's in and of itself 12 completely different.

13 MR. SNUGGERUD: I agree. And that's the 14transition mode. Which is unique and new to NuScale.

15 I transitioned from the transition mode, 16 which incorporates all those activities you just 17 talked about, to the refueling mode, which looks much 18 more --19 MEMBER RAY: Oh, after you get this --

20 MR. SNUGGERUD: Yes.

21 MEMBER RAY: I apologize. My fault.

22 MR. SNUGGERUD: I just want to make sure 23 we are talking trans --

24MEMBER RAY: I thought you were still 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 124 moving the reactor vessel when you said that.

1 MR. SNUGGERUD: Yeah. I'm sorry.

2 MEMBER RAY: Okay.

3MR. SNUGGERUD: The transition mode is 4 completely unique to NuScale.

5 MEMBER RAY: Okay.

6CO-CHAIR SKILLMAN: Far right column.

7 Indicated reactor coolant temperature, you reach 8 Fahrenheit.

9 What is the distinction between all versus 10 any? What do those words mean, please?

11MR. SNUGGERUD: So, there is clarification 12in the basis document. We're talking about all safety 13 related T colds and T hots.

14 Or any safety related T cold or T hot 15 since you can't always guarantee that the hots will be 16 hotter then the colds.

17 CO-CHAIR SKILLMAN: Okay. Thank you.

18 MEMBER MARCH-LEUBA: And mostly you said 19 that any temperature indicated that this is less than 20 420? Is that --

21 MR. SNUGGERUD: All temperatures have to 22 be less the 420 in order for you to be in Mode Three.

23 MEMBER MARCH-LEUBA: Okay.

24MR. SNUGGERUD: Because there are certain 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 125pieces of equipment that are no longer required. But 1 you have to prove that you've reduced the energy to 2below 420 at all locations. All operable indications.

3MEMBER MARCH-LEUBA: And do you also have 4 to guarantee that you -- the effect is .99? Because 5 when you get really, really cold, you may not satisfy 6.99.7 MR. SNUGGERUD: So, the --

8MEMBER MARCH-LEUBA: How do you know where 9you are? Because what I'm saying is, I'm an operator 10 and would like to know what temperature would be a 11 threshold that would make me unsafe.

12MR. SNUGGERUD: So we would have a 13 guidance document not unlike what the PWR that's used 14in the industry that would tell the operators for a 15 given temperature what the required boron 16 concentration is.

17 It is demonstratable that under most cases 18 the boron concentration necessary to meet this 19 requirement is consistent with the operating boron 20concentration. Assuming that all of the control rods 21 have fully inserted.

22 For refueling though, obviously we haven't 23--24 MEMBER MARCH-LEUBA: At any temperature?

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 126MR. SNUGGERUD: Right. You can go to a 1 much lower temperature. And our expectation is that 2 there would be the addition of boron to the system to 3 do a normal plant shutdown to meet that requirement.

4MEMBER MARCH-LEUBA: I got that impression 5 too.6 MR. SNUGGERUD: Yeah.

7MEMBER MARCH-LEUBA: What we're concerned 8 is, what equipment are you going to use to accomplish 9 it?10MR. SNUGGERUD: We will be using the CVCS 11 system.12MEMBER MARCH-LEUBA: A non-safety related 13 CVCS?14 MR. SNUGGERUD: Yes. Just like existing 15 facilities.

16MEMBER MARCH-LEUBA: You might want to put 17 that on the record.

18 MEMBER KIRCHNER: I'm just puzzled. Why 19do you say our expectation? Why isn't this more 20 definitive?

21 You could be at the end of a burn up cycle 22 of a module and down to, if I remember right from 23 Chapter Four, somewhere close to 10 ppm when you 24 finish that cycle.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 127 So, I would say that boron injection is 1required, not expected. Because your -- beyond the 2 criteria --

3MR. SNUGGERUD: The design is designed 4 such that when all the rods insert, we maintain 5 shutdown margin at all temperatures.

6 But, there are specific cases, and if you 7 assume a rod missing and those types of things, where 8 you would need slightly more margin.

9 In addition, our refueling process will 10involve removing control assemblies. And some of 11 those assemblies will have control rods.

12 So the process includes margin for that 13 boron. And because we want to ensure that the boron 14 at the bottom of the vessel meets the boron 15 requirements for the refueling operations, we would be 16adding boron during the shutdown process to ensure 17 that.18 I'm trying to be a little bit careful 19 because the reactivity --

20MEMBER KIRCHNER: But we asked -- where 21 there --22MR. SNUGGERUD: That's where the 23 expectation comes in. Because technically --

24MEMBER KIRCHNER: I think it's a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 128requirement to do it safely. It's not an expectation.

1 MR. SNUGGERUD: I understand your point.

2 MEMBER KIRCHNER: Yeah. And therefore I 3 would ex -- there I would use the word expected to be 4 specifically clear either in tech spec space or 5 procedures. Preferably tech spec.

6MR. SNUGGERUD: The tech specs do provide 7 requirements for concentrations of boron in shutdown 8 modes.9 MEMBER KIRCHNER: Right.

10MR. SNUGGERUD: And what the required 11margins are. So if those couldn't be demonstrated 12 with the boron concentration that had been exemplified 13 during operation, additional boron would need to be 14 added.15 And we have the capability of doing that 16 using the chemical volume control system.

17MEMBER KIRCHNER: By using tech spec 18 space.19MR. SNUGGERUD: It is in tech spec space.

20MEMBER KIRCHNER: So there's no longer an 21 expectation, it's defined.

22MR. SNUGGERUD: Fair enough. Yes. The --

23 I mean, the mode definition is a piece of that. The 24 boron requirements within tech spec are an additional 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 129 piece of that.

1MEMBER MARCH-LEUBA: We will review and --

2 we will be reviewing Chapter Four next month, I 3 believe.4 And I'm just giving you something -- maybe 5you could use some feedback to your colleagues. We 6hear that there will be a lot of questions about 7 certain margins.

8 And it would be nice if they have some 9backup calculations that we can see. So, some actual 10 numbers and actual calculations with actual 11 assumptions. Not just statements of expectation.

12MR. SNUGGERUD: Understood. You'd be more 13 interested in what those numbers look like under 14 different circumstances with different assumptions.

15MEMBER MARCH-LEUBA: Not just the numbers, 16but how you arrived at those numbers. Because 17 shutdown margin is the most important thing in a 18 nuclear reactor.

19 I guess being an operator, you know that.

20Right? It cannot be an expectation. And it has to be 21 well analyzed, very --

and how with uncertainty 22 determination for it.

23MR. SNUGGERUD: All true. Any other 24 questions about the mode definition table that I have 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 130 up there?1I was just going to clarify that CRA 2stands for control rod assembly. CVCS you probably 3recognize as chemical volume control system. And CFDS 4 is the containment flood and drain system.

5Part of what those are touching on are 6 things that could potentially change the concentration 7 of the water inside the module after you've 8 established the boron concentration you intended to 9 have in place for transition.

10CO-CHAIR SKILLMAN: Is there a need --

11this is an open question. And I don't -- I don't have 12 an expectation for an answer.

13 But, is there a -- should there be an 14 additional mode for NuScale where one of the modules 15 or several are somehow compromised or in casualty?

16These are operating modes. Most of us who 17 have been around the industry kind of recognize this.

18 But, in this plant with 12 live cores, is 19 there another mode that is -- ought to have its own 20 unique name tag so that the leadership of the plant 21 and the operators, the men and women that are working 22 there, recognize this is different.

23 Different rules may apply. Or there may 24 be some different ingress, egress, load handling, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 131 ventilation. Some other kind of requirement.

1 This is not a norm -- that's not the right 2word. This is so different. Does it deserve some 3 kind of a moniker where you say, you know, this one's 4-- it's not in mode one, two, three, four, or five.

5 This is in mode 12. And mode 12 means special rules 6 apply.7MR. SNUGGERUD: So for the unaffected 8 modules, the answer is no.

9CO-CHAIR SKILLMAN: And I agree with that.

10 Yeah.11MR. SNUGGERUD: So, for the affected 12 module, and this is true for existing facilities, when 13 you're in an accident, then you're in your emergency 14 procedures and you're following your emergency 15 procedures.

16 The technical specifications are designed 17 to ensure that the plant started prior to the accident 18 in a condition that allowed it to be in an analyzed 19 position for the accident that occurred.

20 To the extent they can, operators will 21 continue to try and maintain the plant within the 22 requirements of technical specifications.

23But, once you get into an accident, the 24 function of the technical specifications to some 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 132 extent, has been met.

1CO-CHAIR SKILLMAN: But accident has a 2 unique meaning also.

3 MR. SNUGGERUD: Absolutely.

4CO-CHAIR SKILLMAN: So, maybe it's not an 5accident. Maybe you've got a module that's stuck.

6 Your cable's failed.

7 Where the module is located is precluding 8some other operation. Or it's over in one of the 9 storage stands. Your cable's unreaved.

10 You've got six of a number of bolts or 11 detention. So, it isn't a full casualty. You don't 12have an accident. You might not be leaking 13 radioisotopes.

14 But there is an alert in the plant where 15folks say, things are not right right now. We've got 16to get this situation modified. But it's none of 17 these modes.

18 Don't answer.

19 MR. SNUGGERUD: You have a --

20 CO-CHAIR SKILLMAN: I'm just --

21MR. SNUGGERUD: I've kind of given what I 22 can answer.

23CO-CHAIR SKILLMAN: Yeah. There's a --

24 you're in a different world in this plant.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 133MR. GROSS: Yeah. The role of tech specs 1 though is not off normal conditions such as that.

2 It's to keep the plant, as he mentioned, aligned with 3 the assumptions before the event occurs and so that it 4 will respond as appropriate if it hap -- if something 5 occurs.6 There is one different one, and that's of 7 course to identify leakage from the RCS system. The 8-- those, the conditions you're describing would be 9 off normal emergency procedures.

10 By definition if it affected the tech --

11 if it affected the safety analysis, we would have to 12 take action under the emergency plan of procedures.

13 If a module is just not movable, it really 14doesn't have an effect. There's no special actions to 15 take before we began moving or entering or changing 16 conditions, all the other modules would have to comply 17 with their tech specs.

18 And for example, the shutdown margin, the 19 mode four transition definition, there --

20 MEMBER KIRCHNER: I think there might be 21a -- I don't know if you were thinking this. But, I'm 22 thinking that if you build your plant and say install 23 half the module, so you have six.

24Now you're bring six more in. Or you put 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 134four in. There are a few instances where you do have 1shared systems. Boron addition comes to mind and 2 such.3 So, where you have special requirements in 4terms of isolation as you tap into those systems. So 5--6 MR. GROSS: I don't believe any of those 7 systems other then UHS are credited.

8 MEMBER KIRCHNER: Um-hum.

9MR. GROSS: So, as long as we maintain 10 water in the pool with the appropriate boron and the 11 right temperatures, we've met our requirements for our 12 safety analysis, which is what Chapter -- or what tech 13 specs are driven to protect.

14CO-CHAIR REMPE: Well, which mode is when 15 you add another module? Is it transition?

16 Where am I when I'm bringing in a new one?

17MR. SNUGGERUD: Yeah. So when you're 18 bringing in a new module, it's not fueled yet.

19 So, it wouldn't technically be in 20technical specifications at that point. Once you put 21 the lower pieces into the plant, and assuming you had 22 completed whatever hot -- or start up testing and 23 validation you had completed.

24 And you started loading in fuel, you would 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 135 be in refueling.

1 CO-CHAIR REMPE: So, the other -- you've 2 divided it up. And I've forgotten the term you had.

3MR. SNUGGERUD: It's in the inspection 4 station. Yeah.

5CO-CHAIR REMPE: And then you put the fuel 6 in there and --

7 MR. SNUGGERUD: No.

8CO-CHAIR REMPE: Then bring it down. Are 9 you bring -- what --

10 MR. SNUGGERUD: So, when you bring a new 11 module in, obviously there's some testing that we're 12going to do before we ever put any fuel in it. Right?

13 We're going to do some training work and 14those kinds of things. But you get to the sixth, 15 seventh module, you bring the components in.

16 You bring the lower containment vessel in.

17 Low lower reactor vessel in, and then the upper 18 reactor vessel and the upper containment.

19 The lower reactor vessel goes in its tool.

20The lower containment goes in its tool. At that 21 point, with the upper module in the inspection bay, 22 there's no difference between that and a refueling.

23 And as soon as you load that first bundle 24into the bottom of the reactor vessel, you would be 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 136 entering mode five for refueling. And the equipment 1 required to support refueling activity would have to 2 be operable.

3 CO-CHAIR REMPE: And then you transition 4it back to its station. But -- and you hook things up 5 just like you would the others.

6 MR. SNUGGERUD: And then before you left 7 mode three, the required equipment would have to be 8 available to support hot shutdown and so on.

9 CO-CHAIR REMPE: Okay. Thank you.

10MEMBER SUNSERI: So the way you -- the way 11 you have that mode five defined up there, it is 12 equivalent to at least in my view, what plants call at 13 all times right now.

14 Is that what was your intention?

15MR. GROSS: Yeah. I believe it's slightly 16different. At all times is whether there's fuel in 17 the core or not.

18 MEMBER SUNSERI: But that says less than 19 one bolt fully tension.

20 MR. GROSS: So he's --

21 MEMBER SUNSERI: You might look at that.

22 MR. GROSS: I'll take a -- thanks. I'll 23 take that back.

24 MR. SNUGGERUD: It's a good --

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 137MEMBER BLEY: Karl said something that I'm 1not sure I read anywhere. And I'm not sure I heard 2 you correctly.

3 But I think you were saying, if you have 4 a module that's in a -- some kind of failed condition, 5 that before you do anything with that module, all the 6 others have to be meeting their tech specs.

7 Is that what you said?

8MR. GROSS: All the others will meet their 9 tech specs contin -- they need to -- everything needs 10 to stay within its tech spec bound limits all the 11 time.12 MEMBER BLEY: Yeah.

13MR. GROSS: If there's fuel in the pot 14basically. The -- if there's an upset module, it's by 15 definition outside a -- pretty much outside of tech 16 specs.17Not all -- that's not always true. But in 18 general, that's where it is. And not fully out 19 necessarily, but.

20MR. SNUGGERUD: But the operators continue 21 to apply tech specs to the --

22 MR. GROSS: That's right. Exactly.

23MR. SNUGGERUD: Other parts of the plant.

24 I think again, maybe part of your question goes to the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 138 mode definitions are for the applicability of the 1 technical specifications.

2 They're not intended to describe all 3potential plant conditions. They're described --

4 intended to describe the required equipment in given 5 plant conditions.

6 So, if I was in the condition where I had 7 un-tensioned some bolts and six bolts I couldn't get 8un-tensioned, I know where I'm at on this table. The 9 plant might be in some unique configuration that would 10 require response of the operations organization and 11 the maintenance organization.

12 But, I have defined where I'm at in the 13table. And that tells the operators what equipment is 14 required under those conditions.

15 And then you get the multi-module issue, 16which you kind of hinted at as well. But now the 17 other modules can't get to the refueling station 18 because I have a module in the refueling station.

19 Those types of recovery plans are things 20 that we're talking about in the design and development 21 of our recover -- of our refueling equipment to make 22 sure that the challenges to the other plants aren't 23 experienced.

24 But, knowing that you can't refuel would 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 139preclude you from wanting to get into transition. So 1 you would stay in your safe shutdown condition.

2 And that would define the requirements for 3 that unit while it was sitting in its module space 4 waiting for the other issue to be resolved.

5 CO-CHAIR SKILLMAN: I was just thinking 6 back to what we got into when we started refueling at 7 TMI-2, and we thought we had it all sewed up nice and 8 clean, nice and tidy, and every time we turned around, 9 we were in a new situation, trying to figure out where 10 to go from here.

11 And a lot of the stuff, we were doing on 12the fly. We were writing procedures, we were writing 13 stuff like this, trying to navigate our way through a 14 safe and defendable path.

15 And then, here we are at the front end of 16 this unique design, maybe a little more effort would 17 stave off what would be really a complex situation in 18 the future.

19 MR. SNUGGERUD: And it is our intent and 20 our hope that the effort that we've put into this, 21 I've been working on tech specs, at least part time, 22 for all ten years I've been at NuScale, would, to a 23large extent, do that. I can't claim that we have 24 thought of everything, because that would be a false 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 140 claim.1 But I did try and bring out the fact that 2 we do have a substantial staff of previously licensed 3operators, and we have a very competent technical 4staff in the Licensing Department. It won't catch 5 everything, but we have made a very big effort.

6 Like I said, we didn't just go through the 7 PWR tech specs, we looked at the BWR tech specs, we 8 looked at foreign types of things, to get input to 9 make sure that we were evaluating this new design in 10 as many ways as we could.

11 CO-CHAIR SKILLMAN: Thank you.

12 MR. SNUGGERUD: Let me get back into my 13presentation here. So, this is going into the 14 sections of the technical specification that actually 15hold the limiting conditions of operation. Section 16 3.1 and 3.2 are not terribly different from things 17 that you would normally see, so we have left those 18 out, and I've jumped to Instrumentation.

19 I mentioned in my opening that we have a 20 completely digital module protection system. And as 21 a result, that changed, to some extent, the way we've 22 organized the Instrumentation section of our technical 23 specifications.

24 The manual actuation function is there, at 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 1413.3.4. That was one that we don't credit in our 1 Chapter 15 analysis, but as an operator, and our 2 operating staff, we agreed that the operators need to 3 have a way that's independent of the digital system to 4 affect the actuation of the engineered safety features 5and the reactor trip system. I don't know if there's 6 anything else you want to add on this slide?

7 Passive Core Cooling is another section 8 that is unique to NuScale, in that our cooling systems 9don't involve the pumps. So, we have the emergency 10 core cooling system, the decay heat removal system, 11 and we put the ultimate heat sink under passive 12 cooling because it obviously supports those two 13systems. There are elements of the ultimate heat sink 14 that also support refueling operations, but they're 15 covered under 3.5.

16 Containment Systems, again, is a little 17bit different. You're not going to find personnel 18 hatch controls for our technical specifications.

19 We're largely looking at the containment itself, its 20 function as an isolation vessel, and then, the valves 21 associated with isolating the containment.

22 Plant Systems, again, a smaller set. We 23 have main steam and main feed water, because the 24 isolation of the steam generators is important to the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 142 function of DHR and for the mitigation of steam 1 generator tube ruptures.

2 And then, we have the in-containment 3 secondary piping leakages, which is a specification 4 that we added after working with the staff to ensure 5 that the assumptions of our leak-before-break 6 methodology are in place during normal operations.

73.8 typically is Electrical. For NuScale, 8we don't have that section. What we do have is 9 Refueling Operations, which is normally 3.9.

10 MEMBER CORRADINI: So, is 3.8 then the 11 transitional and refueling?

12 MR. SNUGGERUD: So, it's --

13 MEMBER CORRADINI: I'm trying to understand 14 where movement fits into this and limiting conditions 15--16 MR. SNUGGERUD: The movement is mostly 17 controlled by the early technical specification on 18Reactivity Requirements. So, when we're moving the 19 module, we ensure, prior to disconnection, that 20 adequate boron is in place, and we ensure that 21 adequate decay time, which is in 3.8, is in place.

22 And we ensure that the module temperature 23 and systems are aligned as designed, to ensure passive 24cooling during transition. But in transition, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 143 specifically, there aren't any technical 1 specifications, beyond ensuring that those things that 2 were set up aren't changed.

3 MEMBER CORRADINI: And the conditions you 4 want?5 MR. SNUGGERUD: Yes, correct.

6 MEMBER MARCH-LEUBA: So, is the nuclear 7instrumentation live instrumentation? I mean, you 8 have a cable pulled in for the incore detectors?

9 MR. SNUGGERUD: So, the incore detectors 10 are only meaningful at power. So --

11 MEMBER MARCH-LEUBA: But that's better than 12 not having nothing?

13 MR. SNUGGERUD: The types of self-powered 14 incore detectors that we are using would not provide 15 any indication.

16 MEMBER MARCH-LEUBA: So, do you add 17 transition source level detectors?

18 MR. SNUGGERUD: So, we have source level 19 detectors at the operating position and at the 20refueling position. Between those two, it is our 21 position that reactivity changes are precluded.

22MEMBER MARCH-LEUBA: Okay. So, the nuclear 23 instrumentation specs don't say any -- say you don't 24 need anything --

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 144 MR. SNUGGERUD: That's correct.

1 MEMBER MARCH-LEUBA: -- during transition?

2 CO-CHAIR SKILLMAN: Do the tech specs 3 require that the reactor be borated to the 1,800 or 4 2,000 PPM before it is disconnected and then moved?

5 I mean, clearly, you're depending on the rods to be 6 bottomed, but are you depending on full-load boron as 7 the preventative, so that you do not need neutron 8 monitoring during module movement?

9 MR. SNUGGERUD: So, there is no means of 10 changing out the fuel during the transition.

11 CO-CHAIR SKILLMAN: Oh, I understand that.

12 MR. SNUGGERUD: There is advantageous to 13 have the boron concentration at the bottom of the 14 vessel, at full boron concentration, prior to starting 15 refueling activities, if your intent is to load new 16fuel, which requires the 1,800 PPM. The fuel that 17 you're taking out, doesn't.

18 The current tech specs would require that 19 you know that you have 1,800 PPM borated water in the 20lower reactor vessel. It doesn't currently specify 21 the details of how you do that.

22 The easy one, which would be consistent 23with the current industry, would be to set up those 24 conditions prior to taking it apart. Another option 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 145 would be to find a way to ensure that you had flushed 1 that vessel prior to moving anything and taking 2 samples appropriately.

3 We haven't specified that level of detail 4in the tech specs, other than to ensure that the 5 requirements for the new core would be met prior to 6 the new core being inserted into the lower reactor 7 vessel.8 CO-CHAIR SKILLMAN: So, you're basically 9 allowing credit for burnup, as reactivity depletion --

10 MR. SNUGGERUD: Yes.

11 CO-CHAIR SKILLMAN: -- and not necessarily 12 requiring full-load boron before you move the module?

13MR. SNUGGERUD: That's correct. And the 14existing fleet could do the same. Again, they know 15 they're going to put fuel back in their modules and 16 they don't want their cold legs sitting there with 17 boron concentrations that don't meet the refueling 18 boron concentrations for the new core.

19 So, they borate to refueling 20 concentrations, not because the core they're taking 21 out needs them to, but because the core they're 22putting in requires it. Same thing applies to 23NuScale. And the NuScale facility will have the same 24 expectations that the existing facilities have.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 146 CO-CHAIR SKILLMAN: Yes, except that you 1 borate it up before you take the head off, and so, 2 you're fully borated before you touch your first fuel 3 assembly.4MR. SNUGGERUD: That's correct. At our 5 plant, when you take the head off, you're going to be 6 exposing it to a seven million gallon pool that meets 7 all boron concentration requirements.

8 MEMBER MARCH-LEUBA: And in the operating 9 fleet, they have pumps that they can kind of mix the 10 boron.11 MR. SNUGGERUD: Yes, but the pumps don't 12 hit all portions of the shutdown plant, depending on 13 the plant's design. Which, again, is why typically, 14 and at the plant that I operated at, we borated to the 15 new core's boron concentration before starting 16 refueling processes.

17 MEMBER MARCH-LEUBA: But I've been reading 18 in-between lines that you expect the boron 19concentration in the vessel to be non-uniform. And --

20 MR. SNUGGERUD: That's not what I'm saying.

21 MEMBER MARCH-LEUBA: -- how do you know 22 what you --

23 MR. SNUGGERUD: What I'm saying --

24 MEMBER MARCH-LEUBA: -- do you say the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 147 bottom of the vessels or --

1 MR. SNUGGERUD: The easy way to do it would 2 be to do the same thing at NuScale, right? It would 3 be to borate the module to 1,800 PPM on the way over.

4 As you had pointed out, during shutdown, 5 there's going to be ample space made during the 6 cooling process, that you could add as much boron as 7you chose to. I don't want to tell you that that's 8 what they're going to do, because the tech specs don't 9 force them to do that, and technically, it isn't 10 required.11 What is required is, before they touch a 12 bundle and start putting new fuel into the reactor, 13 that they ensure that that lower pole of the reactor 14 that's sitting in the pool is at the boron 15 concentration that they intended.

16 MEMBER MARCH-LEUBA: How they do that if 17 instrument is on the discharge line of the CVCS?

18 MR. SNUGGERUD: So, as I suggested, the 19 easy way to do that would be to borate the entire 20 module prior to ever doing it.

21 MEMBER MARCH-LEUBA: That was my --

22 MR. SNUGGERUD: But there are other ways of 23 doing it --

24 MEMBER MARCH-LEUBA: That was my 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 148 expectation --

1 MR. SNUGGERUD: -- and the tech spec --

2 MEMBER MARCH-LEUBA: -- before you started 3 talking.4MR. SNUGGERUD: Yes. The tech specs don't 5 tell them how they have to do that, they tell them 6what they have to do. I would agree with you, that 7 would be the easy way.

8 MEMBER MARCH-LEUBA: Yes, if you don't have 9 a sensor up there, that's the only way.

10 MR. SNUGGERUD: I can envision means by 11 which you could ensure turnover of that lower module.

12 It's not a very big space, you have hot fuel in it.

13 It's going to be pulling water down the down comer and 14 pushing it up through the core, just because of the 15 flow design of that module.

16 I don't want to tell you that somebody in 17 the future won't do the calculations to make that 18 argument and do the demonstrations to prove that 19 that's appropriate, but I haven't done them.

20 MEMBER MARCH-LEUBA: I have a running 21 concern with the staff about how well the boron mixes 22 when you don't have any flow, and indeed, experiments 23 for BWR show the boron does not mix and it goes all to 24 the bottom of the vessel. And this will have to be 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 149 addressed somewhere --

1 MR. SNUGGERUD: Yes.

2 MEMBER MARCH-LEUBA: -- I expect Chapter 3 15.4 MR. SNUGGERUD: And I've heard your 5 concerns and I know NuScale is aware of them.

6 So, this is just a brief, the staff will 7 cover this in more detail, but we have received 8approximately 60 Chapter 16 RAIs. A significant 9number of them have been responded to. We do have 10 some outstanding and we do have some that were 11 recently provided.

12 I will also mention that the number of 13 RAIs isn't exactly the same as the number of 14 questions, because one example up there, a single RAI 15 had 80 subparts. So, we have more than 60 questions 16about the tech specs. The staff has -- well, I guess 17 I have another slide that kind of covers some of the 18 high level things.

19 There were a lot of discussions about how 20 we chose to implement standard tech spec content into 21our design. And so, there were some formatting and 22 some deliberations about the most appropriate way to 23 do that, to ensure that the understanding is 24 consistent with the existing fleet.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 150 We got a number of questions related to 1 instrumentation, which makes sense, again, as NuScale 2 has a unique and newly designed module protection 3system, which is the subject of a Topical Report. And 4 that spawned additional questions related to response 5 time testing, because the barriers or the designations 6 between where you do your t esting are a little bit 7 different for our design.

8We discussed leak rate monitoring. Our 9 containment is different, it's dry, it's in a vacuum.

10 So, what are we going to use to give us evidence and 11 make the operators aware of any leakage before it 12becomes a problem? We had discussions about that 13 system.14 And then, we added the RCS-specific 15 activity limit that addresses dose rates for 16operators, which is something that the staff asked 17 for.18And then, lastly, we added a tech spec, 19 most recently, related to any containment secondary 20 piping leakage that supports our leak-before-break 21 methodology.

22 So, in conclusion for my side, NuScale has 23spent a lot of time to develop technical 24 specifications and bases that reflect our design and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 151 the analysis and the operations as we envision them.

1 We've tried to ensure the safety in 2 licensing basis will be implemented as designed, 3aligned with the standards that the industry uses, 4 take into account industry experience, and prepare a 5 document that will be easy for the COLA applicant to 6 finalize, consistent with the intent of both the staff 7 and NuScale.

8 CO-CHAIR REMPE: If there aren't any more 9questions, we're again running behind, and so, I'm 10 going to ask the staff to come up.

11 MR. SNUGGERUD: Okay.

12 CO-CHAIR REMPE: Thank you.

13 MR. TESFAYE: Good morning. I'm also the 14Chapter 16 PM. Good morning, again. Craig Harbuck is 15 my to my right and he's the technical reviewer, as you 16 may all know. Greg's not here, he's our lead PM.

17 Staff has completed a Safety Evaluation 18Report and submitted it about a month ago. This 19 report contains several open items when it was issued, 20 but a good portion of the open items have since been 21 closed.22 The remaining open items will be addressed 23in Phase 4 of the review. Craig will discuss in 24 detail the open items that have been closed and the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 152 remaining issues that will be addressed in Phase 4 and 1 his overall technical findings.

2 Now, at this time, Craig has asked me, if 3 it is okay with Committee, he would like to go through 4 the presentation and then, the Q&A, if that's okay 5 with you, in the interest of time.

6 CO-CHAIR REMPE: Thank you.

7 MR. TESFAYE: Okay.

8 MR. HARBUCK: I'll be discussing open items 9 that are still open.

10CO-CHAIR REMPE: Okay. So, please scoot 11 very close to the mic.

12 MR. HARBUCK: Okay. Can you hear me now?

13 CO-CHAIR REMPE: Yes.

14MR. HARBUCK: It's good? Okay. My name is 15Craig Harbuck. I'm in the Technical Specifications 16 Branch and have been for a long time. Next -- no, 17 previous slide. Previous slide.

18 This is the people who I was able to 19 identify that were participating in supporting this 20 review. If I've left anyone out, I apologize. Next 21 slide.22 The outline of this presentation, it 23 consists of an overview of the tech specs and then, a 24 number of technical topics that are mostly related to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 153 open items.

1 A brief overview of the tech spec chapter, 2sections, and subsections. This outline shows that 3the tech spec chapters and sections are mostly 4 organized consistent with a PWR STS NUREG.

5 Notice that the NuScale tech specs are 6 missing the LCO that allows operation for a limited 7 period of time with an inoperable piping support 8 snubber. That's normally LCO 308, but since they're 9 not having that one, that's what it will be.

10 Also, NuScale tech specs do not have a 11 Chapter 3 section for electrical power, for reasons we 12 all know. Next slide.

13 This slide lists the Chapter 3 LCO 14 subsections that were the result of applying the LCO 15Selection Criteria 50.36. NuScale's evaluation of its 16 design and safety analyses against the LCO Selection 17 Criteria is described in their report entitled 18 Technical Specifications Regulatory Conformance and 19Development. Currently, we're up to Revision 1 on 20 that report.

21 There's two LCOs that satisfy both 22Criterion 2 and Criterion 3. That would be boron 23 dilution control and the ultimate heat sink.

24 I would also point out that LCO 3.4.1 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 154 differs from the equivalent STS LCO by only including 1 verification of reactor coolant system flow resistance 2 within limits at the beginning of each operating 3 cycle, right after refueling.

4 And this is due to the use of natural 5 circulation, where coolant flow is a function of core 6 power, and therefore, we don't include a 12-hour 7 surveillance that you typically have for verifying RCS 8 flow.9 Also, as mentioned previously in NuScale's 10 presentation, they're using a leak-before-break 11 evaluation, to ensure an in-containment secondary 12 system line break is essentially precluded from 13occurring. To ensure this remains valid, LCO 3.7.3 is 14 established, to specify a limit on the rate of 15 secondary leakage into containment. Next slide.

16 This slide lists the sections and 17 subsections of Chapter 4, Design Features, and Chapter 18 5, Administrative Controls.

19 In the Procedures Section, that's 5.4.1, 20 NuScale agreed to add a requirement for procedures to 21 control the availability and reliability of systems 22 covered by the Owner Control Requirements Manual, 23 because these systems are not covered by the Reg Guide 24 1.33 required procedures or the Quality Assurance Plan 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 155 procedures.

1 And examples of systems that we would 2 expect to see covered by the OCDM are control room 3 habitability, ventilation, the CVCS system, 4 demineralized water system, electrical power, the 5 containment evacuation system, the core flood and 6 drain system, and a number of others.

7We'd also like to point out that the 8 NuScale tech specs include a surveillance frequency 9 control program, which is Risk-informed Tech Spec 10 Initiative 5B, which is implemented using Traveler 11 TSTF-425. Next slide.

12 CO-CHAIR SKILLMAN: Craig, if I could 13 please, on that same slide.

14 MR. HARBUCK: Okay.

15 CO-CHAIR SKILLMAN: Under the procedures 16 that you just enumerated, which is 5.4.1, Frank, F, 17 would you also expect the procedures for the operation 18of the heavy load handling system, the crane, to be 19 binned in that same category?

20 MR. HARBUCK: I'm not sure, that's not 21 normally included in the procedures that are required.

22 Well, let me put it this way, if that equipment was 23deemed to be safety-related, perhaps it would be 24 covered already by --

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 156 CO-CHAIR SKILLMAN: Do you think it's 1 safety-related?

2 MR. HARBUCK: -- Reg Guide 1.33.

3 CO-CHAIR SKILLMAN: Do you think it's 4 safety-related? The crane?

5 MR. HARBUCK: Oh, I do think so, yes.

6 CO-CHAIR SKILLMAN: So, do you think the 7 procedures --

8 MR. HARBUCK: But --

9 CO-CHAIR SKILLMAN: -- may be in here?

10 MR. HARBUCK: Well, everything they do at 11the plant should have procedures. What I'm concerned 12 about in the tech spec arena is to ensure the things 13 that we've normally included in tech specs, but that 14 are not being called out as meeting any of the 15 criteria, that there be some means of -- I mean, a 16tech spec requirement for there to be procedures.

17 Otherwise, it's hard to know what level of control 18 we're going to have, since none of these things fall 19 within the other non-tech spec controls.

20 CO-CHAIR SKILLMAN: Okay, I'll leave it 21 there. Thanks.

22 MR. HARBUCK: Okay.

23 MEMBER BLEY: I need a little help, I'm not 24well-versed here. Your Slide 5 is the Chapter 16 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 157 sections, yes?

1 MR. HARBUCK: Yes, that's correct.

2 MEMBER BLEY: And the last two slides you 3showed, your 6 and 7, are from Part 4, which as I 4 think I understand it is going with the Generic Tech 5Specs in the NUREG and seeing which ones apply, is 6 that right?

7 MR. HARBUCK: Well, what Slide 6 does, it 8 lists the LCOs that were identified as meeting the 9 criteria and one that doesn't, in 50.36(c)(2)(ii).

10MEMBER BLEY: And if all these meet the 11 criteria, except for one, shouldn't they all be in 5?

12 I'm just a little confused about the relationship 13 between --

14 MR. HARBUCK: Oh, the --

15 MEMBER BLEY: -- Part 4 and Chapter 16.

16MR. HARBUCK: We refer to tech specs as 17 having chapters, sections, and subsections.

18 MEMBER BLEY: Yes.

19 MR. HARBUCK: On Slide 5, I've gone down to 20 the section level.

21MEMBER BLEY: Okay. So, you've gone a 22 layer deeper?

23 MR. HARBUCK: That's right.

24 MEMBER BLEY: You also said there's no 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 158 electric power?

1 MR. HARBUCK: There are no LCOs for 2 electrical power, except for the Class 1E isolation 3 devices to protect the MPS instrumentation.

4 MEMBER BLEY: And the reason there's not?

5 I mean, there's something in here on CVCS --

6 MR. HARBUCK: It is --

7 MEMBER BLEY: -- is non-safety.

8MR. HARBUCK: Well, that had to do with 9 NuScale agreeing to add another provision for 10 procedures --

11 MEMBER BLEY: Okay.

12 MR. HARBUCK: -- so we would have something 13 to point to.

14 MEMBER BLEY: I'm linking back to things 15 that aren't --

16 MR. HARBUCK: Yes.

17 MEMBER BLEY: -- in your area here, but --

18 MR. HARBUCK: Okay.

19 MEMBER BLEY: -- when we reviewed the 20 chapter on electric power, they, for several reasons, 21decided not to have 1E electric power system and to 22 have a highly reliable electric power system.

23 MR. HARBUCK: Yes, DC power.

24 MEMBER BLEY: That would imply to me that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 159 there ought to be something like a tech spec 1 requirement on it.

2 MR. HARBUCK: The conclusions, I believe, 3 on Chapter 8, were that there were no safety-related 4electrical systems. No electrical power is required, 5 since everything that actuates in accidents does so by 6removing electrical power. So, it's my understanding 7 that none of the criteria have been satisfied by the 8 electrical power.

9 MEMBER BLEY: So, with this highly reliable 10 electric power system, they could have it shut down 11 and it would not affect the tech specs? It could be 12 turned off?

13 MR. HARBUCK: Well, they might have a hard 14 time operating if they didn't have that.

15 MEMBER BLEY: Yes, they might.

16 MR. HARBUCK: I had a thought --

17MEMBER BLEY: Go ahead. Chapter 8 isn't 18 finished, by the way, there were a lot of outstanding 19 things.20MR. HARBUCK: Okay. Anyway, this reflects 21 our understanding of the current status of Chapter 8 22 and its role in the safety analysis.

23MEMBER MARCH-LEUBA: Chapter 8? I've been 24 saying Page 8.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 160 MEMBER BLEY: Sorry.

1MR. HARBUCK: Okay. That's the end of the 2overview. Now, we're going to start on the technical 3topics. And before I begin, just let me follow up on 4 something from the previous presentation.

5 The mode definition for Mode 4, that 6 transition mode, requires shutdown margin to be 7 whatever the reactivity condition, k-effective less 8 than 0.95, which is going to dictate what your boron 9 concentration is going to have to be set at before you 10 start moving the module.

11 And then, when you disassemble the module, 12 the requirements on the pool boron concentration in 13 3.5.3 would dictate the reactivity condition to 14 maintain that requirement.

15 MEMBER MARCH-LEUBA: Do tech specs say you 16have to have a value for k-effective? Or do they say 17--18 MR. HARBUCK: No, it says k-effective, I 19 think that's --

20 MEMBER MARCH-LEUBA: Which you cannot 21 measure during operation.

22 MR. HARBUCK: It's correlated with -- it's 23calculated. You know what the boron concentration is, 24 you estimate --

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 161 MEMBER MARCH-LEUBA: It's --

1 MR. HARBUCK: -- how long since you shut 2 down and --

3 MEMBER MARCH-LEUBA: I wanted to save it 4 for the end, but she will make me shut up, because 5 we'll run out of time.

6 MR. HARBUCK: Okay.

7 MEMBER MARCH-LEUBA: First principles, if 8 you insert all rods, at any point in the cycle, but 9 mostly towards the end of the cycle, when boron 10 concentration is very low and the monitored 11 temperature coefficient is very negative, you will 12 have a temperature, a relationship between boron 13 concentration and core temperature, which you regain 14 criticality. So, for every boron concentration, you 15 have a temperature you become critical again.

16Why is this not on tech specs? There 17 should be a three-dimension table that tells me 18 temperature below which I cannot go, as function of 19boron concentration and burnup. And the statement, it 20 says, you cannot reach is.

21 Tell me what it is and put it in tech 22 specs, because the operator doe sn't know what k-23 effective is, if he can measure the temperature.

24 MR. HARBUCK: Well, at the moment, these 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 162 values are not in the tech specs, they're in the Core 1 Operating Limits Report, which we haven't seen.

2 MEMBER MARCH-LEUBA: Which you have not 3 seen?4 MEMBER CORRADINI: Because that's typical 5 of most PWRs?

6 MR. HARBUCK: That has been the case since 7 the 1990s, since we adopted this Core Operating Limits 8 Report.9 MEMBER MARCH-LEUBA: When will be able to 10 see the COLR?

11 MR. HARBUCK: I would have to let NuScale 12 answer that.

13 MEMBER MARCH-LEUBA: So, it's --

14 MR. HARBUCK: It's probably not something 15 that's part of the DCA.

16 MEMBER MARCH-LEUBA: But do we know -- can 17 we specify that something like this must exist in the 18 COLR?19 MR. HARBUCK: Yes, because the tech spec on 20 shutdown margin says, you have to meet the values that 21are in the COLR. And then, there's a definition of 22 shutdown margin, which provides the other assumptions 23 you have to make in calculating what your shutdown 24 margin is.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 163MEMBER MARCH-LEUBA: Okay. We'll talk 1 about this at some point.

2MR. HARBUCK: Okay. All right. So, enough 3 of that.4 Last thing I wanted to say was, the 5 definition of mode also includes a phrase that says 6there's got to be fuel in the vessel. So, when you 7 remove all your fuel, you're not in a mode. Okay.

8 I'll now discuss several topics of 9 interest for which the staff and NuScale have not yet 10reached resolution. And first up are several defined 11 terms.12 The sentence that NuScale proposes to add 13 to the pressure boundary leakage definition, it's 14 indicated by the blue underlined text there, matches 15 an STS change previously proposed by industry that the 16 staff did not accept.

17 We do not believe that this relaxation, to 18 permit leakage through an isolation device of a fault 19 in the reactor coolant pressure boundary, is 20 warranted. We are also not convinced that there are 21 locations in the NuScale reactor coolant pressure 22 boundary where this allowance could even be used.

23 Next slide.

24 MEMBER CORRADINI: Can you -- I want to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 164 understand that a little better.

1 MR. HARBUCK: Okay.

2 MEMBER CORRADINI: Okay, thank you.

3 CO-CHAIR REMPE: We can go on, Mike, or do 4 you have a question?

5 MEMBER CORRADINI: No, I just was trying to 6 catch up.7 MR. HARBUCK: The next one is operability.

8 And we believe that the indicated changes of the STS 9 operability definition are appropriate for NuScale.

10 This is a markup of the STS definition.

11 The most noteworthy difference with the 12 STS definition is the removal of the phrase normal or 13emergency to describe electrical power. This makes 14 sense, because, as we've previously mentioned, NuScale 15 has no safety-related emergency electrical power 16 sources and, thus, no LCO section for electrical power 17 systems.18 Also, notice this definition includes two 19lists of the various ways tech specs refer to a 20redundant part of a supported system. These lists 21 should match, and I've added some markup to do that.

22 The second list should include the term 23 Separation Group, as does the first list, it's a 24NuScale term. And then, both lists should include 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 165 Channel and Division, because the MPS instrumentation 1 has four channels and the MPS RTS and ESFAS actuation 2 logic functions have two divisions. Next slide.

3 NuScale proposed to admit the STS 4 definitions for reactor trip system response time and 5 engineer safety feature response time, because the 6 digital portion of the MPS will contribute a 7 conservatively allocated response time to the total 8 ESF and RTS response times, and NuScale thereby 9 concludes that these STS definitions are not needed to 10 effectively state the Surveillance Requirements for 11 verifying the I&C response times are within limits, as 12 explained in the bases of the following Surveillance 13 Requirements.

14 SR 3.3.1.3 is MPS implementation response 15time measurement. This surveillance verifies for each 16 instrumentation function the response time of each 17 channel from when the process variable exceeds its set 18 point until the output from the channel analog logic 19 reaches the input of the MPS digital logic. So, the 20 response time for this surveillance is just handling 21 the input to the digital system.

22 And then, SR 3.3.2.3 verifies for each 23 reactor trip system actuation logic division, that the 24 division response time from the output of equipment 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 166 interface module until the reactor trip breakers are 1opened. So, it goes to the other end of the 2instrument loop and handles the output from the 3 digital system.

4 And again, the digital system, they 5 provide a conservative allocated time in calculating 6 the total response time. Next slide.

7 MEMBER BROWN: Go backwards a minute.

8 MR. HARBUCK: Slide 11?

9 MEMBER BROWN: Is the stuff in blue 10 replacing the lines above it or --

11 MR. HARBUCK: No --

12 MEMBER BROWN: -- is that just an 13 explanation --

14 MR. HARBUCK: Well, what --

15 MEMBER BROWN: -- that we're going to get 16 rid of the RTS and ESF terms?

17 MR. HARBUCK: Well, what this is meant to 18indicate, what I'll get to on the next slide, these 19 are quotes from the bases and they are meant to 20 indicate some material that was taken from the defined 21 terms, the definitions, that have been put into the 22 bases now. And I had a point to make about that.

23 CO-CHAIR REMPE: Let's let him get to the 24 next slide, okay? I think it explains it.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 167MR. HARBUCK: Okay. Now, SR 3.3.3.2 1 verifies, and this is kind of interesting, so listen 2 carefully, it verifies the pressurizer heater trip 3 ESFAS function logic and actuation division response 4 time, from the output of the equipment interface 5 module to the loss of voltage at the output of the 6 pressurizer heater breaker.

7 MEMBER BROWN: Can you -- that's on the 8 previous slide?

9 MR. HARBUCK: That's on Slide --

10 MEMBER BROWN: You said SR --

11 MR. HARBUCK: That's on Slide 11, 3.3.3 --

12 MEMBER BROWN: 2 was on Slide 10.

13 MR. HARBUCK: Did I mix -- well, 3.3 --

14 CO-CHAIR REMPE: Well, if I can --

15 MR. HARBUCK: -- I believe it's 3.3.3.2, it 16 might be 3.3.3.3, I could have -- anyways, the 17 Surveillance Requirement number is not so important, 18 but the response time surveillance for the ESFAS 19 functions in the Instrumentation section only 20 explicitly addresses the pressurizer heater trip.

21 Now, the surveillances for the other ESFAS 22 functions, logic and actuation functions, that opens 23 or closes valves are included in each associated 24 system's LCO subsection.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 168 Now, the reason for the blue highlighted 1 text is because, unlike the Section 3.3 bases for 2 response time surveillances, the bases of the 3 surveillances to verify valve actuation time in LCO 4 subsections of affected systems do not include 5 descriptive language, which is consistent with the 6omitted STS response time definitions. And in the 7 absence of those definitions, we are suggesting that 8 the applicant add such language to the bases for those 9 surveillances. Next slide.

10 CO-CHAIR REMPE: You okay, Charlie?

11 MEMBER BROWN: I'm still having trouble 12 with that. Somebody else understands it better than 13I do. It seems to me, you've added -- the blue is not 14 part of the overall STS? I'm not real familiar --

15 MR. HARBUCK: The quotations are taken from 16 the bases, for that surveillance.

17 MEMBER BROWN: I'm trying to figure out 18 what the intent of the blue part is. I mean --

19 MR. HARBUCK: It would --

20 MEMBER BROWN: -- maximum response time --

21 MR. HARBUCK: That phrase, that sentence is 22 a phrase that's verbatim out of the definitions in the 23 Standard Tech Specs.

24MEMBER BROWN: Okay. Go back to Slide 10, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 169 I might --

1 MR. HARBUCK: Okay.

2 MEMBER BROWN: -- be able to understand 3that one better, 3.3.2. The Standard says, the 4 maximum digital response time is described in the 5 FSAR. Okay.

6 The SR encompasses the response time from 7 the output of the equipment interface until the trip 8 breakers open. Now, the next statement says, to me, 9 that you can do it piecemeal or overall. Is that --

10 MR. HARBUCK: That's true. And the total 11 response time there is referring not just --

12 MEMBER BROWN: Is that --

13 MR. HARBUCK: -- to what that surveillance 14 is --15 MEMBER BROWN: -- in the Standard right 16 now?17 MR. HARBUCK: Yes.

18 MEMBER BROWN: So, that's not an addition?

19 MR. HARBUCK: That's not an addition or 20 anything, I'm just point out that --

21 MEMBER BROWN: Okay. I thought --

22 MR. HARBUCK: -- in compensating --

23 MEMBER BROWN: I'm sorry, I thought they 24 were modifying the Standard.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 170 MR. HARBUCK: No.

1 MEMBER BROWN: I thought they were 2 modifying the Standard. I understand --

3 MR. HARBUCK: They were beefing up the 4 bases --5 MEMBER BROWN: -- whether I agree with that 6or not, that's another thing. But that's what's been 7 used in the past?

8 MR. HARBUCK: Right, yes.

9 MEMBER BROWN: Okay, thank you.

10 MR. HARBUCK: Okay.

11 MEMBER BROWN: Jose, you were on the same 12 page I was? Okay.

13 CO-CHAIR REMPE: We're a bit behind, so 14 let's go ahead, okay? We're good now.

15MEMBER BROWN: Yes, I got it. I got it, 16 we're okay.

17MR. HARBUCK: Slide 12. Okay. All right.

18So, very briefly here. Some other defined 19 Surveillance Requirements.

20 The MPS, module protection system, 21 continuously conducts automatic self-testing to verify 22 channel and division operability between the channel 23 calibrations and actuation logic test.

24 And this feature of the MPS is more 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 171 effective than performing the STS channel operational 1test every 92 days and the STS actuation logic test 2 every 24 months, for verifying proper operation of the 3 MPS instrumentation and the RTS and ESFAS logic and 4 actuation divisions.

5 This is a reminder that in the Standard 6 Tech Specs, the circuits are typically analog and so, 7 these tests involve injecting a signal and seeing what 8 happens to the logic and doing the various 9 combinations.

10 MEMBER BROWN: Okay. If I understand --

11 MR. HARBUCK: And they don't --

12 MEMBER BROWN: -- this one --

13 MR. HARBUCK: And they don't do that one.

14 Okay.15 MEMBER BROWN: And if I understand --

16 MR. HARBUCK: All right.

17 MEMBER BROWN: -- in the old days, with the 18 analog stuff, you had a periodic test that you had to 19 do, where you input stuff.

20 MR. HARBUCK: That's right.

21 MEMBER BROWN: Since we've got self-22 testing, that's performed and the only check of the 23 self-testing is on a two-year basis. That's the way 24--25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 172 MR. HARBUCK: The --

1MEMBER BROWN: -- I'm reading it. They go 2-- that's how I'm reading this is that they have to do 3 something to verify that the self-testing is actually 4 self-testing.

5 MR. HARBUCK: That particular point in the 6 Branch Technical Position that addresses the self-7 testing of digital systems would have to be addressed 8by Instrumentation reviewers. My understanding is 9 that testing of the tester has been addressed in that 10 discussion of that chapter.

11 MEMBER BROWN: Yes, I don't remember.

12 MR. HARBUCK: But I'm not in a position to 13--14 MEMBER BROWN: It's been a while.

15 MR. HARBUCK: -- question that at this 16 point. Okay.

17 Now, the STS actuation logic test 18 definition has been revised for NuScale, since the 19NuScale actuation logic test has a reduced scope. It 20 goes from the equipment --

21 MEMBER BROWN: Well, I'm reading the --

22 MR. HARBUCK: -- interface --

23 MEMBER BROWN: I'm reading the first 24 paragraph, which says, you depend on self-testing and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 173 division operability between channel calibrations and 1 actuation logic tests, which are on 24.

2 So, I think that reads, the way I'm 3 reading it, am I missing -- Jose, do you see that the 4same way? They're relying two years on self-tests.

5 Every two years, there's going to be an operability of 6 the channel calibrations.

7 MEMBER MARCH-LEUBA: I understand what 8 you're saying, I don't understand what they're saying.

9 I think we're on the same page.

10 MEMBER BROWN: Yes, Page 12. Okay.

11 MR. HARBUCK: Okay. So, as I was saying, 12 the actuation logic test in NuScale verifies the 13 analog actuation priority logic in the equipment 14 interface module and the various manual switches which 15 have no automatic self-test features.

16 Now, the STS channel check definition is 17 also revised, as shown by the markup on this slide, to 18 account for the operation of the self-testing feature 19of the digital platform. So, they've kept the 20 surveillance and they've kept essentially the same 21 frequency, but how it's performed is a bit different 22 than in typical plant. Okay.

23 Electrical Power Su rveillance Requirements 24 is a bit of misnomer, but I wanted to say it to make 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 174the point. NuScale protects the MPS from faults in 1 the non-safety-related electrical power system by use 2 of Class 1E isolation devices that automatically 3 separate the MPS from its electrical power upon 4 detecting an under voltage or overcurrent condition.

5 LCOs for the MPS reactor trip system and 6 ESFAS include, for the associated Class 1E isolation 7 devices, a Channel Calibration Surveillance 8 Requirement, which verifies operability of each 9 device.10 They don't include such a surveillance for 11 the manual actuation and we've asked them to consider 12 whether that's appropriate.

13 Given the importance of maintaining water 14 inventory in the decay heat removal system following 15 its actuation, the main steam isolation and feed water 16 isolation valves must not leak more than the leakage 17 rate that will support decay heat removal system 18operation for the time period needed following an 19 event that relies on the decay heat removal system for 20 core cooling.

21 NuScale has not provided values as part of 22 its application for these leakage limits, which are 23 the acceptance criteria for the leak rate verification 24 surveillances for the MSIVs and the feed water 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 175 isolation valves.

1 We are still evaluating NuScale's position 2 that these acceptance criteria will be established 3 when the in-service test program is put in place by 4the COL applicant. NuScale has concluded, therefore, 5 that these values do not need to be provided as part 6 of the DCA.

7 CO-CHAIR REMPE: So, we're really running 8 behind, can you highlight key points on the remaining 9 slides, please?

10MR. HARBUCK: Okay. In the next two 11 slides, I'll just briefly put it -- make it very 12 brief.13 They've proposed, again, a provision 14 that's in an unapproved industry Change Traveler to 15 the STS that would allow Surveillance Requirements to 16 be suspended and not required to be met if the 17 isolation device or valve is put in its actuated 18position. And we're not convinced that this is needed 19or warranted. And so, we have open item related to 20 that. Okay.

21Now, Slide 17. The next six slides 22 involve a listing of our open items, several of which 23 have been discussed, as indicated by the blue color on 24 their number.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 17616-30D, at the bottom of the page, is 1 related to their adoption of a surveillance frequency 2control program. We asked them to provide, in the 3 DCA, the initial frequencies and the bases for those 4 frequencies, which is necessary in order for a COL 5applicant to actually implement that program. And 6they put this in a table in FSAR Section 16.1. And 7 that table needs to be updated and so, this item is 8 simply tracking that.

9MEMBER BLEY: On this long list of open 10 items, are there any on which you're really divided or 11 is it on most of them or are you getting pretty close 12 to agreement on how these are going to settle out?

13MR. HARBUCK: I'll point that out, if I 14 mention one --

15 MEMBER BLEY: Okay.

16 MR. HARBUCK: -- if there's a -- I'm not 17 going to really talk about the ones that we've -- I 18 mean, I guess, one would be on Slide 18, the one about 19 providing the Surveillance Requirement acceptance 20 criteria for the valve leakage in the steam and feed 21systems. That would be one where we'd perhaps are in 22 disagreement.

23 MEMBER CORRADINI: And again, a little bit 24 louder, that's the one that you're still in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 177 discussions with?

1MR. HARBUCK: Right. On the -- Question 2 16-59 has to do with apparent disconnect on the 3 applicability of this instrument function, which 4 initiates the decay heat removal system, but there's 5 going to be a design change coming that we've been 6 made aware of that's going to alter their response to 7that question. They haven't, as a result, they 8 haven't responded to that one yet and that's why it's 9 open.10 And on the next slide, we have some issues 11about the applicability of the LCO 3.1.9, we made a 12 suggestion.

13 And the Mode 3 applicability for LCO 14 3.3.1, what's interesting there is that there's an 15 interlock, which blocks it or bypasses it, and yet, 16the applicability goes beyond, goes to a lower 17 temperature than at the point at which it's blocked, 18 so that's a question here.

19 And finally, there was some confusion in 20 an Action Requirement, which said, decrease power 21 below this interlock, the interlock refers to 15 22 percent rated power and the question was, which 23 interlock is the appropriate one to refer to?

24 On the Slide 21, these are -- we just 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 178 recently provided six new questions to NuScale in this 1 RAI 9642.2 And I'll just mention briefly that we have 3 a concern about the design of their system to prevent 4 putting water into containment when the reactor 5 coolant system is at too high a temperature.

6 There's going to be in the PTLR a 7 temperature limit and the way they preclude it now is 8 that they have an interlock based on that temperature 9 on a control valve, a non-safety control valve in the 10core flood and drain system. And we're asking, well, 11 why didn't they put an interlock on the containment 12 isolation valves, which are a higher level of safety 13 grade?14 And then, lastly, we're asking them to add 15 some additional methodology references to the Core 16 Operating Limits Report Specification 5.6.3.

17 The last one refers back to the leak-18 before-break, where we're still reviewing the limit 19 they've proposed in LCO 3.7.3 of 1.5 gallons per hour.

20 And we're still reviewing their supplemental response.

21 And we're also, we think we're waiting for some 22 additional input, that may be incorrect, but that's 23 our understanding right now.

24 And then, the last thing doesn't have a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 179 number, but the COL item list or the sub-item list, as 1 it's been called, are all the places where information 2 is bracketed in the tech specs and bases, where we 3 want that list to be definitive as part of the design 4 cert, so that the COL applicant knows exactly what 5 they need to do to complete the tech specs.

6 CO-CHAIR REMPE: So, we have like one 7 minute to finish this.

8 MR. HARBUCK: Okay.

9 CO-CHAIR REMPE: We've got --

10 MR. HARBUCK: I'm --

11 CO-CHAIR REMPE: -- another meeting, so 12 maybe summarize.

13 MR. HARBUCK: Yes, I'm -- okay. The next 14slide is just your -- okay. Slide 23 is just for your 15 information, to say we've got some more work to do, 16 because they made some design changes.

17 And then, there's some general issues.

18 One, I just mentioned, completing the COL item list.

19 Also, we have some issues related to their adopting 20Travelers that aren't approved. And then, there's a 21 bunch of administrative items that need to be cleaned 22 up.23 And so, we've done a pretty thorough 24 review of the tech specs and we have a number of items 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 180that need to be resolved. I wouldn't say any of them 1 are show-stoppers or very significant, in and of 2 themselves.

3 And the Technical Branches listed will be 4 providing some support for us in completing those.

5 And when those are done, we'll be done with the tech 6 specs. That concludes the presentation.

7CO-CHAIR REMPE: Okay, thank you. I 8 apologize for other people's sessions going longer.

9 MR. HARBUCK: I understand.

10 CO-CHAIR REMPE: Before we decide about 11 having public comment, I want to have the members say 12 whether they think we need to have a closed meeting to 13 address, for example, your buoyancy question, Dick.

14 Do you want to explore that further today?

15 So, any members see a need to have a closed meeting?

16 Mike, did you have a comment before I start asking for 17 public comments? Okay.

18 Do we have anyone on the phone line? Is 19it open? Yes, it's open? Okay. Do we need to verify 20 that someone's out there or do we just --

21 MR. SNODDERLY: Is there anyone on the 22 public phone line?

23 MR. LEWIS: Marvin Lewis, public --

24 MS. FIELDS: Sarah Fields.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 181CO-CHAIR REMPE: Okay. Do either of you 1 have a comment you'd like to make at this time?

2 MR. LEWIS: Yes, I do.

3 CO-CHAIR REMPE: Please go forward.

4 MR. LEWIS: Well, let me put it this way, 5 I've been listening to the ACRS since they went on the 6 telephone and I've been attending ACRS meetings as a 7 member of the public well before then, back to the 81970s. And I have to admit, today blew me away. I've 9 heard better questions from the ACRS membership than 10 I have ever heard before. And I thank you.

11 CO-CHAIR REMPE: Thank you for your 12comment. Are there any other comments? So, with 13 that, I need to go around to each --

14 MS. FIELDS: Yes.

15 CO-CHAIR REMPE: Oh, sorry.

16MS. FIELDS: This is Sarah Fields. I'd 17like to make a comment. Yes, I also believe that 18 there were some very good questions, which I hope will 19 be answered down the line.

20 Going back to the Chapter 9 presentation, 21 9.1-2, the slide indicated that the COL applicant will 22 demonstrate that an NRC licensed cask can be lowered 23into the dry dock and used to remove spent fuel 24assemblies from the plant. And then, 9.1-3, they also 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 182 reference the fuel being transferred to a cask.

1 And I found that there seems to be 2confusion between the term canister and cask. My 3 understanding is that fuel first goes into a metal 4 canister and is later transferred into a thicker 5 containment cask.

6 So, I think that that should be clarified, 7 whether fuel within the containment vessel is going to 8 be transferred to a metal canister and then, possibly, 9 later going into a cask.

10 That should be clarified, because a lot of 11 discussions in other dimensions related to spent fuel, 12 these fuels are confused and they should really be 13 specifically defined.

14 CO-CHAIR REMPE: Thank you for your 15comment. Are there any other comments, individuals on 16the line? And I'm not seeing anyone in the room that 17 has comments.

18 And so, we're going to go around and ask 19 the members for comments. In particular, if there's 20 some issues that rise to being mentioned in the 21 progress or interim letter we're going to be writing, 22 please emphasize those as we go around the room.

23 I heard several topics discussed today 24 that I think might warrant being mentioned in this 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 183 interim letter, but it would be good for you to 1highlight them if I've missed them. And I'm going to 2 start with Walt.

3 MEMBER KIRCHNER: For this section, where 4 I have questions, I think, on tech specs, I will take 5 note and bring them up in Chapter 4 and 5 and 6, which 6we haven't yet reviewed. Issues like leak-before-7 break and breaks within containment.

8 And, here, we have things like leakage 9 rates into the containment, but there's the more 10 fundamental aspect of design, before you get to the 11 leak, that is something that we can take up with the 12 applicant and the staff when we get to Chapters 4, 5, 13 and 6. Thank you.

14 CO-CHAIR REMPE: Thank you. Dennis?

15 MEMBER BLEY: Nothing to add.

16 CO-CHAIR REMPE: Mike?

17 MEMBER CORRADINI: Nothing to add at this 18 time.19 CO-CHAIR REMPE: Dick?

20 CO-CHAIR SKILLMAN: Nothing further, it's 21 already on the record and --

22CO-CHAIR REMPE: Okay. So, you've 23 mentioned several points and you don't have any 24 requests that you'd like to have emphasized in the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 184full committee meeting? Because if we're going to 1 have anything documented in the letter, this would be 2 a good time to summarize some of those points.

3 CO-CHAIR SKILLMAN: Well, I'm going to pull 4 those points out of the record when I see it.

5 CO-CHAIR REMPE: Okay.

6 CO-CHAIR SKILLMAN: I've identified them 7 contemporaneously, my concern with homogeneity, the 8 crane, the floor, the structure, not the strength of 9the floor, but the membrane vulnerability to load 10drop, and several others such as those. And those are 11 already in the record --

12 CO-CHAIR REMPE: Okay.

13 CO-CHAIR SKILLMAN: -- so I'll pluck those 14 from the record.

15 CO-CHAIR REMPE: Okay, thank you.

16 CO-CHAIR SKILLMAN: Thank you.

17 CO-CHAIR REMPE: Harold?

18 MEMBER RAY: Our last staff presentation 19 included the excellent comment that the COL applicant 20 needs to know exactly what they need to do. And I 21 just have some concern on the larger areas covered and 22 I think with regard to tech specs, that's being 23 addressed, it seems, from what we've heard.

24 But we need to underscore, I think, that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 185 where a design certification credits an assumption, 1 that a COL applicant will comply with requirements 2 which are yet to be identified and will be provided 3 later by the certificate holder, then that needs to be 4 explicit.5 We can't answer all their questions at the 6 time of certification, but the fact that things are 7 going to be provided later, requirements are going to 8 be imposed on the COL applicant later, or provided to 9the COL applicant later, needs to be identified. And 10 that's all I want to say at this point.

11 CO-CHAIR REMPE: Thank you. Jose?

12 MEMBER MARCH-LEUBA: Same as Dick, my 13 comments are on the record and I will provide you with 14 some comments for the letter later, when we can review 15 them.16 CO-CHAIR REMPE: Okay. Ron?

17 MEMBER BALLINGER: No further comment.

18 CO-CHAIR REMPE: Charlie?

19 MEMBER BROWN: No further comment.

20 CO-CHAIR REMPE: Vesna?

21 MEMBER DIMITRIJEVIC: No further comment.

22 CO-CHAIR REMPE: Before I get to Steve, 23 what about Matt?

24 MEMBER SUNSERI: I don't have any comments, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 186 thanks, Joy.

1 CO-CHAIR REMPE: Pete?

2 MEMBER RICCARDELLA: I don't have any 3comments at this time, but I will bring out some 4 thoughts and concerns I have at the letter writing, 5 during the letter writing.

6CO-CHAIR REMPE: Okay. So, let me hear 7 from Steve, but hold that thought, I want to make a 8 comment, but go ahead, Steve?

9 DR. SCHULTZ: No further comments that 10 aren't on the record.

11CO-CHAIR REMPE: Okay. So, we will be 12 having an interim letter and waiting until that letter 13is always a little difficult. So, I know, Jose and 14 Dick and Harold, if you'll send, and you also, Pete, 15 some draft comments, it'll make it easier.

16 And I think Matt's going to combine this 17with the letter for 10, 11, and 12. So, copy me, but 18also send them to Matt, okay? Is that your 19 understanding, the process, Mike, that you'd 20 envisioned, that he would be leading --

21 MEMBER CORRADINI: I would appreciate it if 22 I got to know what the members want.

23 CO-CHAIR REMPE: That would be true, too.

24 Yes, copy Mike, Matt, and me.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 187 MEMBER CORRADINI: But from the standpoint 1 that we have, I think, on the full committee, we have 2 the morning Thursday for the staff and the applicant 3 to present.

4 So, to the extent that there are certain 5 things we want to put in the letter, because again, my 6 personal view is, if it's something that's 7 significant, we want to issue it. If it's something 8 that is a matter of discussion, we can enter it, but 9 I'm looking for things significant that deviate from 10 the open items, that we want or the staff wants.

11 CO-CHAIR REMPE: So, I think, Dick and 12 Harold and Jose have emphasized those, about how you 13 check about the boron mixing and different things like 14 that, they've emphasized today, and that's why I 15 wanted to have them bring it up again as we went 16around the circle. Is there anything else I've 17 forgotten, Mike Snodderly?

18 MR. SNODDERLY: No, I'll just remind the 19 Committee of the bylaws on letter writing and that 20 when these comments are circulated, it should not 21 involve more than the majority, no more than -- it has 22 to be a less than a minority. Or then, you should 23 wait until the open letter writing session for further 24 discussions.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 188 CO-CHAIR REMPE: Well, yes, we are just 1 supposed to have it go to the Subcommittee, but the 2 draft letter should be a product of the Subcommittee, 3 so it is fine to have it sent to us that way. Okay?

4 So, thank you and with that, we're going to adjourn.

5 (Whereupon, the above-entitled matter went 6 off the record at 12:29 p.m.)

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com

1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com

March 20, 2019

Portland Office6650 SW Redwood Lane, Suite 210 Portland, OR 97224

971.371.1592Corvallis Office1100 NE Circle Blvd., Suite 200 Corvallis, OR 97330

541.360.0500Rockville Office11333 WoodglenAve., Suite 205 Rockville, MD 20852

301.770.0472Charlotte Office2815 Coliseum Centre Drive, Suite 230 Charlotte, NC 28217

980.349.4804Richland Office 1933 JadwinAve., Suite 130 Richland, WA 99354

541.360.0500Arlington Office2300 Clarendon Blvd., Suite 1110 Arlington, VA 22201London Office 1 st Floor Portland HouseBressendenPlace London SW1E 5BH

United Kingdom

+44 (0) 2079 321700http://www.nuscalepower.comTwitter: @NuScale_Power Presentation to the ACRS SubcommitteeNuScale Power, LLC (NuScale)Design Certification Application ReviewSafety Evaluation with Open Items: Chapter 9AUXILIARY SYSTEMSMarch 20, 2019 Technical Reviewers:Alexandra Siwy

-NRO/DSRA/SRSBAlissa Neuhausen -NRO/DEI/SEBRyan Nolan

-NRO/DSRA/SRSBRaul Hernandez

-NRO/DSRA/SCPBHanry Wagage

-NRO/DSRA/SCPBChang Li -NRO/DSRA/SCPBAngelo Stubbs

-NRO/DSRA/SCPBBob Vettori

-NRO/DSRA/SPRAEdward Stutzcage

-NRO/DLSE/RGRBTony Gardner

-NRR/DMLR/MCCBAlexander Chereskin

-NRR/DMLR/MCCBFanta Sacko

-NRR/DE/EENBAndrew Yeshnik

-NRO/DEI/MCBNan Chien

-NRO/DSRA/SCPBDawnmathews Kalathiveettil

-NRR/DE/EICAProject Managers

Greg Cranston

-Lead Project ManagerGetachew Tesfaye

-Chapter 9 Project ManagerMarch 20, 2019 Chapter 9, Auxiliary Systems 2

Technical Reviewers:Chapter 9: Auxiliary SystemsSection 9.1

-Fuel Storage and HandlingAlexandra Siwy -SRSBRaul Hernandez -SPSBAlissa Neuhausen -SEBAndrew Yeshnik

-MCBSection 9.2

-Water SystemsChang Li-SCPBAngelo Stubbs -SCPBNan Chien -SCPBBob Vettori -SPRASection 9.3

-Process AuxiliariesRaul Hernandez-SCPBTony Gardner

-MCCBEdward Stutzcage

-RGRBBob Vettori -SPRAHanry Wagage -SCPBRyan Nolan -SRSBSection 9.4

-Air Conditioning, Heating, Cooling, and Ventilation SystemsNan Chien -SCPBSection 9.5

-Other Auxiliary SystemsRobert Vettori -SPRADawnmathews Kalathiveettil

-EICAFanta Sacko-EENBNan Chien -SCPBMarch 20, 2019 Chapter 9, Auxiliary Systems 3

Section 9.1: Fuel Storage andHandlingSubsections:9.1.1 -Criticality Safety of New and Spent Fuel Storage9.1.2 -Fuel Storage System9.1.3 -Spent Fuel Pool Cooling and Cleanup System9.1.4 -Light and Heavy Systems and Heavy Load Handling SystemMarch 20, 2019 Chapter 9, Auxiliary Systems 4

9.1.1 -Criticality Safety of New and Spent Fuel Storage (1/2)Review objective: verify that fuel will remain subcritical during storage and handling in accordance with 10 CFR 50.68 and GDC 62

• Review guidance: SRP Section 9.1.1, Revision 3

• Review areas: computational methods and validation, scope of conditions analyzed, analysis models and assumptions, handling of bias and uncertainty, analysis results, storage rack materialsStaff Review and Findings:

• Criticality calculation methodology is acceptable and adequately

benchmarked *Criticality models correctly incorporate design information and use

appropriate assumptions

• Open Item 9.1.1

-2: Applicant is making the structural analysis of the racks a COL item, which the staff will evaluate in Phase 4March 20, 2019 Chapter 9, Auxiliary Systems 5

9.1.1 -Criticality Safety of New and Spent Fuel Storage (2/2)Staff Review and Findings, continued

• Except for analyses related to Open Item 9.1.1

-2, applicant's criticality analyses comply with 10 CFR 50.68 and GDC 62

• Staff confirmatory analyses support the applicant's results

• Tier 1 information complete and consistent with Tier 2 information

• Technical Specifications adequately protect the assumptions in the criticality analysis

• NuScale has not specified a Neutron Absorbing material.Open item 9.1.1

-1: Request additional details on the impacts of manufacturing on the neutron attenuation, materials qualification for the SFP environment, and manufacturing process controls.

• The applicant is implementing a neutron absorber monitoring program that is consistent with TSTF

-577, Rev. 1, and utilizes NEI 16-03, "Guidance for Monitoring of Fixed Neutron Absorbers in Spent Fuel Pools."March 20, 2019 Chapter 9, Auxiliary Systems 6

9.1.2 -New and Spent Fuel Storage (1/1)Review Objective

• The SFP has the necessary design features unique to fuel storage during initial receipt, refueling operations, and accident conditions, including maintaining cooling and limiting offsite exposure in the event of a fuel handling accident. Items of major interest

• Staff reviewed the SFP in accordance with the guidance of SRP 9.1.2

• SFP is integral part of the UHS

• Shared system between all 12 modulesOpen Items

• 9.1.2-1 -Related to the pool leakage detection system capability to monitor the UHS liner integrity

-Based on latest RAI response and proposed DCA changes, the staff finds this Open Item Closed

.*Staff finds that the SFP conforms with the guidance of SRP 9.1.2March 20, 2019 Chapter 9, Auxiliary Systems 7

9.1.3 -Spent Fuel Pool Cooling and Cleanup System (1/1)Review Objective

• Ensure the safety

-related Spent Fuel Pool Cooling System is capable of maintaining the spent fuel assemblies cooled and covered with water during all storage conditions.Items of major interest

• Staff reviewed SFPCCS in accordance with the guidance in SRP 9.1.3

• Ensure system configuration ensures adequate water inventory in the SFP

• Evaluate all key assumptions of the thermal analyses

• Cooling capability during accident scenarios addressed in Section 9.2.5

UHS*RAI responses found acceptable and proposed changes to DCD are being

tracked as Confirmatory Items

• Staff finds that the SFPCS conforms with the guidance of SRP 9.1.3March 20, 2019 Chapter 9, Auxiliary Systems 8

9.1.4 and 9.1.5

-Light Load Handling Systems (Related to Refueling) (1/1)Review ObjectiveTo ensure the design and operation of the load handling systems can prevent or minimize the likelihood of an event that could cause a release of radioactivity, a criticality accident, or an inability to cool fuel within the reactor vessel or spent fuel pool; or could prevent the safe shutdown of the reactor.Items of major interest

• Responses of load handling equipment to a safe shutdown earthquake

(SSE) event consistent with guidance in SRPs 9.1.4 and 9.1.5.

• Design criteria for single

-failure-proof load handling components consistent

with guidelines of NUREG

-0554*Procedures for safe load handling operations consistent with guidelines of

NURE G-0612*ALL RAI responses and DCA changes are found acceptable.

Staff finds that the light and heavy load handling conforms with the guidance of SRPs 9.1.4 and 9.1.5.March 20, 2019 Chapter 9, Auxiliary Systems 9

Section 9.2

-Water SystemsSubsections:9.2.1 -Station Service Water System9.2.2 -Component Cooling Water System9.2.3 -Demineralized Water System9.2.4 -Potable and Sanitary Water Systems9.2.5 -Ultimate Heat Sink9.2.6 -Condensate Storage Facilities9.2.7 -Site Cooling Water System9.2.8 -Chilled Water Systems9.2.9 -Utility Water SystemsMarch 20, 2019 Chapter 9, Auxiliary Systems10 9.2.1 -Station Service Water System (1/1)Key Design Features and Considerations

• The NuScalepassive design does not rely on active systems such as a service water system to provide cooling to essential equipment.

• The NuScalePower Modules are partially submerged in the reactor pool portion of the plant UHS.

• This design configuration ensures passive heat transfer from essential systems and components directly to the UHS, with no intermediate heat transfer loop such as that provided by a typical LWR essential service water system.Staff's Review and Evaluation Results

• The staff reviewed the NuScalesystem design and confirmed the above statements.

• The UHS, reviewed in Section9.2.5 of this SER, performs the safety function of decay heat removal, which the service water system usually performs in LWR active designs.

• The site cooling water system (SCWS), reviewed in Section9.2.7 of this SER, performs the heat removal function for the nonsafety-related systems, which the service water system usually performs in LWR designs.March 20, 2019 Chapter 9, Auxiliary Systems 11 9.2.2 -Component Cooling WaterSystem (1/1)Key Design Features and Considerations

• RCCWS is a closed loop cooling system comprised of two identical subsystems each supporting up to six reactor modules.

• RCCWS provides cooling to the CVCS non-regenerative heat exchanger, CES condenser and pumps, the PSS coolers and analyzer control units and the CRDMs electromagnetic coils housing .

• RCCWS is not safety-related, however the CVCS, CES, and PSS components cooled by the RCCWS are located in the RXB, the CRDM electromagnetic coils, are located inside containment and outside of the reactor vessel. Staff's Review and Evaluation Results

• Staff reviewed CCWS in accordance with SRP 9.2.2. Since the system is not credited for

performing any safety related function the review focused on system design that ensures system failure would not impact important to safety SSCs.

• The system was found to be in compliance with GDCs 2 and 4 based on the RCCWS SSCs

inside the reactor building and containment having appropriate seismic classifications and having appropriate environmental qualifications . The staff also found the system to be in compliance with GDCs 60 , 64.March 20, 2019 Chapter 9, Auxiliary Systems12 9.2.3 -Demineralized WaterSystem (1/1)Key Design Features and Considerations

• The DWS is designed to treat the water from the utility water system (UWS) and provide and distribute high-quality demineralized water to the plant.

• The DWS provides plant support during abnormal conditions by providing additional

makeup water to the SFPCS to compensate for inventory loss, and to the condenser for emergency fill.

• The DWS is not safety

-related and is not required for any DBE.Staff's Review and Evaluation Results

• Staff reviewed the systems in accordance with SRP 9.2.3

• The staff found the design to be in accordance with the guidance in SRP 9.2.3, and in

compliance with GDCs 2, 5, 60 and 10CFR 20.1406. March 20, 2019 Chapter 9, Auxiliary Systems13 9.2.4 -Potable and Sanitary Water Systems (1/1)Key Design Features and Considerations

• Systems provide potable water for domestic use and human consumption and collects and transfers site sanitary waste for treatment and discharge.

• The PWS piping in the control building penetrating the control room envelope and

habitability boundary.

• Systems are site specific therefore only conceptual design information, interface

requirements and design features to prevent radioactive contamination of the system is included in the application.Staff's Review and Evaluation Results

• Staff reviewed the systems in accordance with SRP 9.2.4

• The staff found the conceptual design information and the interface requirements in

the DCD to be in accordance with 10 CFR 52.47(a)

• Design provision made to prevent inadvertent contamination of the domestic water and

sanitary systems with radioactive material was found to be acceptable and the design is in compliance with GDC 60.

• PWS uses passive design feature (loop seal) instead of isolation valves to ensure

integrity of CR envelope.March 20, 2019 Chapter 9, Auxiliary Systems14 9.2.5 -Ultimate Heat Sink (1/1)Key Design Features and Considerations

• The NuScale UHS is a set of safety

-related pools of borated water that consists of the combined water volume of the reactor pool, RFP, and SFP.

• Up to 12 NPMs are located in the reactor pool and share the combined volume of water.

• During accident scenarios, the NuScale design credits the safety

-related water inventory stored in the UHS to passively remove the decay heat.

• The applicant considered GDCs 2, 4, 5, 45, 46, 61, and PDC 44 in the

design.Staff's Review and Evaluation Results

• The staff evaluates the safety

-related UHS function in this section of the SER.*The staff's review confirmed that the UHS has sufficient water inventory for

30 days to remove the decay heat from the NPM and the stored fuel from the pool through boiling and evaporation, removing enough heat to maintain the spent fuel and fuel in the NPMs sufficiently cool to prevent fuel damage.March 20, 2019 Chapter 9, Auxiliary Systems15 9.2.6 -Condensate StorageFacilities (1/1)Key Design Features and Considerations

• The CST provides a volume for makeup and rejection of condensate to and from the condenser hotwell based on hotwell level.

• The CST does not serve a safety function, and it does not interface with

other systems that could adversely affect safety

-related or augmented equipment.

• In the event of failure of non

-seismic CSF storage tanks, site grading and

drainage will ensure SSCs important to safety will not be adversely affected Staff's Review and Evaluation Results

• Staff reviewed CSF in accordance with SRP 9.2.6.

• The system was found to be in compliance with GDCs 2 and 60 and

10 CFR 20.1406.

• GDCs 5, 44, 45, and 46 were found not applicable because system is not

safety-related and not credited for supporting safety

-related systems.March 20, 2019 Chapter 9, Auxiliary Systems16 9.2.7 -Site Cooling WaterSystem (1/1)Key Design Features and Considerations

• Transfer heat from plant auxiliary systems to the SCWS cooling towers.

• Service loads for the SCWS include equipment in the RXB, Central Utility Building, North and South TGB, and Auxiliary Boiler Building.

• SCWS does not provide cooling to safety

-related or risk

-significant SSCs, and is not credited for performing any safety

-related functions.Staff's Review and Evaluation Results

• The staff reviewed the SCWS to determine if system failures could potentially

impact import to safety SSCs (GDCs 2, 4 & 5) or result in the release of radiation to environment (GDC 60).

• Staff concluded that the SCWS complies with GDC 2, 4, 5 and 60 as well as 10 CFR 20.1406. March 20, 2019 Chapter 9, Auxiliary Systems17 9.2.8 -Chilled WaterSystem (1/1)Key Design Features and Considerations

• Primary CHWS provides cooling for the normal CRVS, RWBVS, RBVS, and other equipment in the radioactive waste processing systems.

• Standby CHWS is dedicated only to the CRVS in the event of a loss of

normal ac power.Staff's Review and Evaluation Results

• Staff reviewed CHWS in accordance with SRP 9.2.7.

• The CHWS has the heat removal capacity to provide, during plant normal

operation, a heat sink for various air handling units and cooling loads in the radioactive waste processing systems

• The CHWS design complies with GDCs 1, 2, 4, 5, 44, 10 CFR 20.1406, and 10CFR52.47(b)(1)March 20, 2019 Chapter 9, Auxiliary Systems18 9.2.9 -Utility WaterSystems (1/1)Area of Review

• Staff reviewed the Utility Water System in accordance with the applicable guidance in SRP 9.2.4.

• Staff reviewed to ensure compliance with GDC 5, 60, 64, and 10CFR

20.1406. *RAIs issued, all closed/resolved. No open items.Staff's Findings

• The Utility Water System is in accordance with the applicable guidance in

SRP 9.2.4 and is in compliance with GDC 5, 60, 64 and 10CFR 20.1406.March 20, 2019 Chapter 9, Auxiliary Systems19 Section 9.3: Process AuxiliariesSubsections:

• 9.3.1 -Compressed Air Systems

• 9.3.2 -Process and Post

-Accident Sampling Systems

• 9.3.3-Equipment and Floor Drain Systems

• 9.3.4 -Chemical and Volume Control System

• 9.3.5 -Not Applicable

• 9.3.6 -Containment Evacuation System and Containment Flooding and Drain SystemMarch 20, 2019 Chapter 9, Auxiliary Systems20 9.3.1 -Compressed Air Systems (1/1)Review Objective

• Ensure the quality of air does not prevent the safety

-related air operated valves from performing their safety functionItems of major interest

• Staff reviewed compressed air and gas systems in accordance with the guidance in SRP 9.3.1.

• CAS has no safety function, but the system follows the guidance that

ensures high quality air is available.

• The CAS is shared between 12 modules simultaneously.

• Staff finds that the compress air and gas systems conforms with the

guidance of SRP 9.3.1March 20, 2019 Chapter 9, Auxiliary Systems21 9.3.2 -Process and Post

-Accident Sampling Systems (1/3)System DescriptionThe function of the process sampling system (PSS) is to provide the means to obtain representative liquid and gaseous samples from various primary and secondary process streams and components for monitoring and analyzing the chemical and radiochemical conditions.Scope of Review

• Sampling locations and capabilities

• Detection and control of leakage outside containment

• Containment isolationMarch 20, 2019 Chapter 9, Auxiliary Systems22 9.3.2 -Process and Post

-Accident Sampling Systems (2/3)Conclusions

• No dedicated post-accident PSS used. Normal PSS is used during post-accident conditions.

• There are sample points for collecting and analyzing liquid and gaseous samples from the primary coolant, secondary coolant, containment air, spent fuel pool, and other sources

• Includes the sampling locations in the SRP acceptance criteria, and other locations

• COL applicant will -.

• Develop operational procedures and maintenance program for leak detection and

contamination control

• Develop post

-accident sampling contingency plans for using the process sampling system and the containment evacuation system off-line radiation monitor to obtain reactor coolant and containment atmosphere samples. March 20, 2019 Chapter 9, Auxiliary Systems23 9.3.2 -Process and Post

-Accident Sampling Systems (3/3)Conclusions (continued)

• The process of collecting liquid post

-accident samples involves opening containment isolation valves and routing liquid to the CVCS system to the sampling lines for liquid samples.*The process of collecting gaseous post-accident samples involves opening containment isolation valves and routing gases through the containment evacuation system to the sample lines and back to containment through the containment flood and drain system. Staff has several open questions related to the post

-accident sampling process, including radiological concerns related to post-accident sampling and the dose to operators when taking samples, in accordance with 10 CFR 50.34(f)(2)(viii).

However, NuScalehas recently proposed an exemption from 10 CFR 50.34(f)(2)(viii), which is currently being evaluated by staff. The staff will re

-

assess the status of the open questions following the review of the exemption. March 20, 2019 Chapter 9, Auxiliary Systems24 9.3.3 -Equipment and Floor Drain Systems (1/1)Area of Review

• The EFDS is comprised of two separate, unconnected systems, the radioactive waste drain system (RWDS,) and the balance

-of-plant drain system (BPDS).

• Staff reviewed the EFDS is accordance with the guidance in SRP 9.3.3.

• Staff reviewed to ensure compliance with GDC 2, 4, 5, 60, 64, and 10CFR

20.1406.*RAIs issued, all closed/resolved. No open items.Staff Findings

• The EFDS conforms with the guidance of SRP 9.3.3 and is compliance with

GDC 2, 4, 5, 60, 64, and 10CFR 20.1406.March 20, 2019 Chapter 9, Auxiliary Systems25 9.3.4 -Chemical and Volume Control System (1/3)Findings*Design Basis Only safety

-related functions of the CVCS are containment and demineralized water isolation.

• Functionality

• System functional design to include all components necessary for RCS chemical and volume control

• Components, instrumentation and controls appropriate

• Adequate chemistry/purity control

• Utilized to establish natural circulation flow to support startup operations

• Protection

• Protection against boric acid precipitation adequate

• Appropriate seismic classification completed for CVCS

• Purifying equipment appropriately protected

• CVCS leakage control adequate to minimize contaminationMarch 20, 2019 Chapter 9, Auxiliary Systems26 9.3.4 -Chemical and Volume Control System (2/3) GDC 33 Exemption Request

• Not applicable to NuScale

-RCS makeup from CVCS is not relied on to meet SAFDLs

• Underlying purpose of GDC 33 is met by:CVCS isolation capability CNV and ECCS capability to maintain RCS inventory and core coolabilityto meet the SAFDLsMarch 20, 2019 Chapter 9, Auxiliary Systems27 9.3.4 -Chemical and Volume Control System (3/3)

• CVCS injects into the lower riser 8 feet above the core.*Dilution mixing

methodology during startup is reviewed in Section 15.4.6.

• T-H phenomena for boron dilution in the long term is reviewed in Section 15.0.6.March 20, 2019 Chapter 9, Auxiliary Systems28 9.3.6 -Containment Evacuation System and Containment Flooding and Drain System (1/1)Area of Review

• Staff reviewed the CES and CFDS design function of transferring liquids

and gases between the containment vessel free volume and other plant systemsStaff Findings

• In response to staff RAIs the applicant clarified and updated NuScale FSAR

for the following:CFDS and CVCS systems provide single failure proof capability to cool the nuclear power module from normal operating conditions to conditions equivalent to cold shutdown in a conventional plantWith the discharge line isolated, the radioactive gases are left in the CFDS to

decay until the level is below the limit for release through the RBVS plant exhaust stackExemption from 10 CFR 50.34(f)(2)(xiv)(E) as applied to the CES is described in

Part 7, Chapter 13

• The CES and CFDS conforms with the guidance of DSRS 9.3.6 March 20, 2019 Chapter 9, Auxiliary Systems29 Section 9.4: Heating, Ventilation and Air Conditioning SystemsSubsections:9.4.1 -Control Room Area Ventilation System9.4.2 -Reactor Building and Spent Fuel Pool Area Ventilation System9.4.3 -Radioactive Waste Building Ventilation System9.4.4 -Turbine Building Ventilation SystemMarch 20, 2019 Chapter 9, Auxiliary Systems30 9.4.1-Control Room Area Ventilation System (1/1)Area of Review

• Staff reviewed the CRVS design to determine whether it is capable of maintaining suitable environmental conditions for personnel under normal conditions. Staff Findings

• NuScale does not credit operator actions to mitigate DBEs.

• CRVS is not credited to be operational during design

-basis accidents.Staff Conclusion

• Staff concluded that the CRVS complies with GDC 2, 4, 5, 19 and 60 as well as with 10 CFR 20.1406, 10 CFR 50.63 and 10 CFR 52.47(b)(1). March 20, 2019 Chapter 9, Auxiliary Systems31 9.4.2 -Reactor Building and Spent Fuel Pool Area Ventilation System (1/1)Area of Review

• The capability of maintaining acceptable ambient conditions in the Reactor Building to support personnel and equipment. *The ability of controlling airborne radioactivity in the area during normal operation and fuel handling accident.Staff Findings

• RBVS spent fuel pool exhaust ductwork provides a protective function for the safety-related, Seismic Category I Reactor Building

• NuScale did not take credit to meet offsite dose limit due to leakage from the Reactor Building in case of a HELB event.Staff ConclusionStaff concluded that the RBVS complies with GDC 2, 5, 60, 61 and 64 as well as with 10 CFR 20.1406 and 10 CFR 52.47(b)(1). . March 20, 2019 Chapter 9, Auxiliary Systems32 9.4.3 -Radioactive Waste Building Ventilation System (1/1)Area of Review

• The capability to support personnel access and equipment functions by maintaining a suitable operating environment in the RWB.

• The ability to support the control of radioactive contamination by

maintaining airflow from areas of lesser potential contamination to areas of greater potential contamination, maintaining the RWB at a negative pressure with respect to the outside atmosphere, and collecting potentially contaminated discharges vented from equipment in the RWB.Staff Findings

• Staff finds that the RWBVS conforms with the guidance of SRP 9.4.3.Staff ConclusionStaff concluded that the RBVS complies with GDC 2, 5, and 60 as well as with 10 CFR 20.1406 and10 CFR 52.47(b)(1).March 20, 2019 Chapter 9, Auxiliary Systems33 9.4.4 -Turbine Building VentilationSystem (TBVS) (1/1)Area of Review

• Capability to maintain a suitable environment for all equipment and personnel in the TGB during startup, shutdown, and normal plant operation.Staff Findings

• Staff finds that the TBVS conforms with the guidance of SRP 9.4.4.Staff Conclusion

• Staff concluded that the TBVS complies with GDC 2, 5, and 60 as well as with 10 CFR 52.47(b)(1). . March 20, 2019 Chapter 9, Auxiliary Systems34 Section 9.5: Other Auxiliary SystemsSubsections:9.5.1 -Fire Protection Program9.5.2 -Communication Systems9.5.3 -Lighting Systems9.5.4 -Emergency Diesel Engine (Backup Diesel Generators) Support SystemsMarch 20, 2019 Chapter 9, Auxiliary Systems35 9.5.1 -Fire Protection Program (1/1)Review Objectives

• Staff reviewed the Fire Protection Program and Fire Hazard Analysis in accordance with the applicable guidance in SRP 9.5.1.1, SECY 90

-016, "Evolutionary Light Water Reactor (LWR) Certification Issues and Their Relationship to Current Regulatory Requirements." and Regulatory Guide 1.189, "Fire Protection for Nuclear Power Plants."

• Staff reviewed to ensure compliance with 10CFR 50.48, "Fire Protection,"

GDC 3, 5, 19, and 23.

• RAIs issued, all closed/resolved. No open items. Staff's Findings

• The Fire Protection Program and Fire Hazard Analysis are in accordance

with the applicable guidance in SRP 9.5.1.1, SECY 90

-016, Regulatory Guide 1.189, and are in compliance with 10CFR 50.48, GDC 3, 5, 19, and

23.March 20, 2019 Chapter 9, Auxiliary Systems36 9.5.2 -Communication Systems (1/1)

• The stafffindsthattheCOMSdesignsareacceptableandmeettheapplicablerequirementsof10CFRPart50

,and10CFRPart 52.*Noopen items.*TheNRC staff ispresent toaddressanyquestionsorcommentsfromtheCommitteemembers

.March 20, 2019 Chapter 9, Auxiliary Systems37 9.5.3 -Lighting Systems (1/2)NuScale Design:The plant lighting system includes normal plant lighting, emergency plant lighting, and normal and emergency main control room lighting. Normal plant lighting provides illumination on the plant site and for plant buildingsEmergency plant lighting provides illumination outside the control room upon loss of normal lightingNormal and Emergency Main Control Room lighting provides illumination under all

operating, maintenance, testing, and emergency conditionsStaff Review:Staff reviewed the capability of the plant lighting levels to provide adequate illumination in all plant areas during all plant operating conditions, and to operate without adversely impacting the operation, control, and maintenance of structure, system and components.March 20, 2019 Chapter 9, Auxiliary Systems38 9.5.3 -Lighting Systems (2/2)Open Item:The open item in this section is related to RG 1.75 and the physical separation between nonsafety

-related lighting circuits and safety

-related circuits, and GDC 17 and 18 exemptions. The completion of the staff's review of plant lighting system is awaiting the completion of Chapter 8 open item, regarding the GDC 17 and 18 exemptions.Confirmatory Item:The confirmatory item will be addressed in our Phase 4 SER.March 20, 2019 Chapter 9, Auxiliary Systems39 9.5.4 -Emergency Diesel Engine (Backup Diesel Generators) Support Systems (1/1)

• The applicant did not provide any physical or functional description for these

systems in FSAR Section 9.5.

• In response to the staff's RAI, the applicant stated that the backup diesel

generators (BDGs) are described in FSAR Section 8.3.1.1.2 as stand

-alone, skid-based installations including support features such as lubrication and cooling. These support features are not assigned to discrete systems similar to those used for traditional large LWR safety

-related diesel applications as presupposed by the guidance in SRP 9.5.4 through 9.5.8. Hence no need to include these SRP sections in the FSAR.

• The staff agrees with the applicant determination that the EDESS are

nonsafety, non-risk-significant.

• No open items.

• The NRC staff is present to address any questions or comments from the

Committee members.March 20, 2019 Chapter 9, Auxiliary Systems40 ACRONYMSBDG -backup diesel generatorRCCWS -reactor component cooling water systemCDI -conceptual design informationCOL -combined license CSF -condensate storage facilityCST -condensate storage tankCVCS -chemical and volume control systemCWS -chilled water systemDBA -design basis accident DCD -design control documentEDG -emergency diesel generatorEFDS -equipment and floor drainage systemsGDC -general design criterionRAI -request for additional informationRCS -reactor coolant systemSAFDL -specified acceptable fuel design limit SFP -spent fuel poolSFPCS -spent fuel pool cooling systemSFPCCS -spent fuel pool cooling and cleanup systemSRP -standard review planSSC -structure, system and componentSSE -safe shutdown earthquakeITAAC -inspections, tests, analyses, and acceptance criteriaTBVS -turbine building ventilation systemUHS -ultimate heat sinkMarch 20, 2019 Chapter 9, Auxiliary Systems41 LO-0319-64764 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360

-0500 Fax 541.207.3928 www.nuscalepower.com March 7, 2019 Docket No.52-048 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852

-2738

SUBJECT:

NuScale Power , LLC Sub mittal of Presentati on Materials E ntitl ed "AC RS Presentation:

NuScal e Techni al pecifications FSAR Chapter 16 a nd DCA Part 4," PM-03 19-64 414, Revisi on 0 T he purpos e of this submittal is t o provid e presentati on materials t o t he NRC for use duri ng the upcomi ng Advisory Committ ee on Reactor Safegurards (ACRS) NuScal e Subcommitt ee meeti ng on Marc h 20, 2019. T he materials support NuScale's presentati on of Chapter 16 a nd Desig n Certification Applicatio n (DCA) Part 4, "Technical Specifications."

Enclosur e 1 is t he nonproprietary versio n of t he presentati on entitled "AC R S Presentation:

NuScale Techni al pecifications FSAR Chapter 1 6 and DCA Part 4," PM-03 19-64 414, Revisi on 0. This letter makes no regulatory commitments an d no revisions t o any existin g regulatory commitments.

If y ou hav e any questions, pleas e contact Carri e Fosaaen at 541-452-7126 or at cfosaaen@nuscalepower.com. Sincerely, Zackar y W. Rad Director, Regulatory Affairs NuScale Power, LLC Distribution:

Robert Taylor, NRC, OWFN , 8H12 Michael Snodderly, NRC, TWFN-2E26 Gregory Cranston. NRC, 8H12 Samuel Lee, NRC, 8H12 Getachew Tesfaye, NRC, 8H12 Enclosure 1: "ACRS Presentation:

NuScal e Techni al pecifications FSAR Chapter 16 an d DCA Part 4," PM-0319-64414, Revision 0 LO-0319-64764 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360

-0500 Fax 541.207.3928 www.nuscalepower.com Enclosure 1:

"ACRS Presentation:

NuScal e Techni al pecifications FSAR Chapter 16 an d DCA Part 4," PM-0 319-6 4414, Revisi on 0 March 20, 2019

(AP1000 approx. 350 pages)(AP1000 approx. 670 pages)

Portland Office6650 SW Redwood Lane, Suite 210 Portland, OR 97224

971.371.1592Corvallis Office1100 NE Circle Blvd., Suite 200 Corvallis, OR 97330

541.360.0500Rockville Office11333 WoodglenAve., Suite 205 Rockville, MD 20852

301.770.0472Charlotte Office2815 Coliseum Centre Drive, Suite 230 Charlotte, NC 28217

980.349.4804Richland Office 1933 JadwinAve., Suite 130 Richland, WA 99354

541.360.0500Arlington Office2300 Clarendon Blvd., Suite 1110 Arlington, VA 22201London Office 1 st Floor Portland HouseBressendenPlace London SW1E 5BH

United Kingdom

+44 (0) 2079 321700http://www.nuscalepower.comTwitter: @NuScale_Power Presentation to the ACRS SubcommitteeNuScale Power, LLCNuScale Design Certification Application ReviewSafety Evaluation with Open Items: Chapter 16 GENERIC TECHNICAL SPECIFICATIONS AND BASESMARCH 20, 2019 March 20, 2019 Chapter 16 Generic Technical Specifications and Bases 2*Technical Staff PresenterCraig Harbuck

• Project Managers Gregory Cranston

-Lead Project Manager Getachew Tesfaye

-Chapter 16 Project Manager Staff Review TeamMarch 20, 2019 Chapter 16 Generic Technical Specifications and Bases 3Primary ReviewersTechnical Specifications Branch*........................Craig Harbuck, Bob Tjader

• Secondary ReviewersContainment and Ventilation Branch............................................................. -----------------.Nan Chien, Syed Haider, Boyce TravisMechanical Engineering Branch .......................................................Tuan LeRadiation Protection and Accident Consequences Branch -------------......................................................Lavera, Ronald, Michelle HartReactor Systems, Nuclear Performance, and Code Review Branch ...................................................Matt Thomas, Timothy Drzewiecki, Alexandra BurjaInstrumentation, Controls, and Electrical Engineering Branch (ICE) .......... ............................... Dawnmathews Kalathiveettil, Dinesh Taneja, Joe Ashcraft Plant Systems Branch ............................................Angelo Stubbs, Chang LiProbabilistic Risk Assessment Branch ....Anne-Marie Grady, Marie PohidaElectrical Engineering Branch**............................................... Fanta SackoMaterials & Chemical Engineering Branch ...........Leslie Terry, Greg Makar* Center of expertise NRR/DSS/STSB** Center of expertise NRR/DE/EENB March 20, 2019 Chapter 16 Generic Technical Specifications and Bases 4*OutlineOverview of Chapter 16Technical Topics

• Defined Terms

• RTS and ESFAS Surveillance Requirements

• Electrical Power Surveillance Requirements

• Allowed Leakage for Main Steam and Feedwater Isolation Valves

• Exceptions to Meeting Surveillances

• Open Item Listing

• Pending MPS design changes

• General IssuesReview Status Summary March 20, 2019 Chapter 16 Generic Technical Specifications and Bases 5Overview ofDesign Certification Application (DCA) Part 2, Chapter 16; and Part 4 1.0USE AND APPLICATION1.1Definitions 1.2Logical Connectors1.3Completion Times1.4Frequency 2.0SAFETY LIMITS (SLs)2.1SLs2.1.1Reactor Core SLs2.1.2RCS Pressure SL2.2SL Violations 3.0LCO APPLICABILITYLCO 3.0.1LCO 3.0.2 LCO 3.0.3 LCO 3.0.4 LCO 3.0.5 LCO 3.0.6 LCO 3.0.7 LCO 3.0.83.0 SR APPLICABILITYSR 3.0.1 SR 3.0.2 SR 3.0.3 SR 3.0.4 3.0LCO AND SR (#) -number of LCO subsections3.1REACTIVITY CONTROL SYSTEMS (9)3.2CORE OPERATING LIMITS (2)3.3INSTRUMENTATION (5)3.4REACTOR COOLANT SYSTEM (RCS) (10)3.5PASSIVE CORE COOLING SYSTEMS (PCCS) (3)3.6CONTAINMENT SYSTEMS (2)3.7PLANT SYSTEMS (3)3.8REFUELING OPERATIONS (2) 4.0DESIGN FEATURES (3 sections) 5.0ADMINISTRATIVE CONTROLS (7 sections)

March 20, 2019 Chapter 16 Generic Technical Specifications and Bases 6Overview of DCA Part 4LCO selection criteria resultsCriterion 13.4.7, RCS Leakage Detection InstrumentationCriterion 23.1.1SHUTDOWN MARGIN (SDM)3.1.2Core Reactivity3.1.3Moderator Temperature Coefficient (MTC)3.1.4 Rod Group Alignment Limits3.1.5 Shutdown Bank Insertion Limits3.1.6 Regulating Bank Insertion Limits3.1.7 Rod Position Indication3.1.9 Boron Dilution Control (Boric Acid supply boron concentration; demineralized water makeup flow rate)3.2.1Enthalpy Rise Hot Channel Factor (FH)3.2.2AXIAL OFFSET (AO)3.4.1RCS Pressure, Temperature, and Flow Resistance Critical Heat Flux Limits3.4.2RCS Minimum Temperature for Criticality3.4.3RCS Pressure and Temperature (P/T) Limits3.4.5RCS Operational LEAKAGE3.4.8RCS Specific Activity3.4.9Steam Generator (SG) Tube Integrity3.5.3Ultimate Heat Sink3.7.3In-Containment Secondary Piping Leakage3.8.2Decay TimeCriterion 33.1.9Boron Dilution Control (Chemical and Volume Control System (CVCS)) demineralized water isolation valves)3.3.1Module Protection System Instrumentation3.3.2Reactor Trip System (RTS) Logic and Actuation3.3.3Engineered Safety Features Actuation System (ESFAS) Logic and Actuation3.4.4Reactor Safety Valves (RSVs)3.4.6CVCS Isolation Valves3.4.10Low Temperature Overpressure Protection (LTOP) Valves3.5.1Emergency Core Cooling System (ECCS)3.5.2Decay Heat Removal System (DHRS)3.5.3Ultimate Heat Sink3.6.1Containment3.6.2Containment Isolation Valves3.7.1Main Steam Isolation Valves (MSIVs)3.7.2Feedwater Isolation 3.8.1Nuclear Instrumentation (refueling neutron flux channels)Criterion 43.3.4Manual Actuation Functions3.3.5Remote Shutdown Station (RSS)No Criterion3.1.8PHYSICS TESTS Exceptions March 20, 2019 Chapter 16 Generic Technical Specifications and Bases 7Overview of DCA Part 44.0DESIGN FEATURES4.1Site Location4.1.1Site and Exclusion Boundaries4.1.2Low Population Zone (LPZ)4.2Reactor Core4.3 Fuel Storage4.2.1Fuel Assemblies4.3.1 Criticality4.2.2Control Rod Assemblies4.3.2 Drainage4.3.3 Capacity5.0ADMINISTRATIVE CONTROLS5.1Responsibility5.1.1[plant manager]5.1.2[shift manager]5.2 Organization5.2.1 Onsite and Offsite Organizations5.2.2 Facility Staff5.3 Facility Staff Qualifications5.3.1facility staff5.3.2licensed SRO and licensed RO5.4Procedures5.4.1Written procedures shall be -

a.Regulatory Guide 1.33 b.Emergency Operating Procedures c.QA and Environmental Monitoring d.Fire Protection Program e.Section 5.5 programs f.availability and reliability controls for SSCs in owner-controlled requirements manual5.5Programs and Manuals5.5.1Offsite Dose Calculation Manual5.5.2Radioactive Effluent Control Program5.5.3Component Cyclic or Transient Limit5.5.4Steam Generator Program5.5.5Secondary Water Chemistry Program5.5.6Explosive Gas and Storage Tank Radioactivity Monitoring Program5.5.7TS Bases Control Program5.5.8Safety Function Determination Program5.5.9Containment Leakage Rate Testing Program5.5.10Setpoint Program (SP)5.5.11Surveillance Frequency Control Program (FSAR Table 16.1

-1)5.5.12Spent Fuel Storage Rack Neutron Absorber Monitoring Program5.6Reports5.6.1Annual Radiological Environmental Operating Report5.6.2Radiological Effluent Release Report5.6.3Core Operating Limits Report (COLR)5.6.4RCS Pressure and Temperature Limits Report (PTLR)5.6.5Steam Generator Tube Inspection Report5.7High Radiation Area5.7.15.7.2 March 20, 2019 Chapter 16 Generic Technical Specifications and Bases 8Technical TopicsDefined Terms

• LEAKAGE*Mark up of STS definition of "Pressure Boundary LEAKAGE

":"LEAKAGE (except primary to secondary SG LEAKAGE) through a nonisolable fault in a RCS component body, pipe wall, or vessel wall. A fault in an RCS component body, pipe wall, or vessel wall is isolated if LEAKAGE through the isolation device limit of 5 gpm.

"*Based on traveler TSTF

-534, "Clarify Application of Pressure Boundary Leakage Definition" Revision 0, rejected by the staff in 2012

• Unclear where in NuScale reactor coolant pressure boundary this provision could be used, much less would be beneficial to unit operation or a safety enhancement

• Open Item under RAI 9031, Question 16.2, Subquestion f (Supplemental response pending)

March 20, 2019 Chapter 16 Generic Technical Specifications and Bases 9Technical TopicsDefined Terms (continued)

• OPERABLE-OPERABILITY

• Mark up of STS definition plus staff-suggested changes for consistency with NuScale instrumentation design:"A system, subsystem, separation group, channel, division, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, separation group, channel, division, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s)."

• Open Item under RAI 9031, Question 16.2, Subquestion f (Supplemental response pending)

March 20, 2019 Chapter 16 Generic Technical Specifications and Bases 10Technical TopicsDefined Terms (continued)

• RTS RESPONSE TIME and ESF RESPONSE TIME

• The applicant has proposed to omit these defined terms, and just use "response time" in the corresponding surveillances. Digital response time assumes an allocated value.

• Bases for each surveillance explains the response time:3.3.1 MPS instrumentation Functions -channel actuation response time; B 3.3.1:"-the time from when the process variable exceeds its setpoint until the output from the channel analog logic reaches the input of the MPS digital logic."

"Response time may be verified by any series of sequential, overlapping or total channel measurements, including allocated sensor response time, such that the response time is verified.

"3.3.2 RTS Logic and Actuation -RTS division response time; B 3.3.2:"The maximum digital time response is described in the FSAR. This SR encompasses the response time of the RTS division from the output of the equipment interface modules (EIM) until the RTBs are open."

"Total response time may be verified by any series of sequential, overlapping, or total channel measurements

."

March 20, 2019 Chapter 16 Generic Technical Specifications and Bases 11Technical TopicsDefined Terms (continued)

• RTS RESPONSE TIME and ESF RESPONSE TIME (continued)3.3.3 ESFAS Logic and Actuation -only addresses response time for opening of pressurizer heater breakers; B 3.3.3:"-The maximum digital time response is described in the FSAR. This SR encompasses the response time of the ESFAS from the output of the EIM to the loss of voltage at the output of the pressurizer heater breaker." "Total response time may be verified by any series of sequential, overlapping, or total channel measurements

.""The response time of valves actuated by the ESFAS are verified in accordance with the IST program" (and associated SRs in Subsections 3.4.6, 3.4.10, 3.5.1, 3.5.2, 3.6.2, 3.7.1, 3.7.2; Bases do not include languageabout response time, as provided in Section 3.3 Bases -subject of RAI 9642, Question 16-65)Example: SR 3.6.2.3 -verify isolation time of each automatic containment isolation valve in accordance with the INSERVICE TESTING PROGRAM; B 3.6.2:"Isolation time is measured from output of the MPS EIM until the valves are isolated."

• Open Item under RAI 9614, Question 16

-50 (ICE evaluating response)

March 20, 2019 Chapter 16 Generic Technical Specifications and Bases 12Technical TopicsRTS and ESFAS Surveillance Requirements

• MPS digital logic channels, RTS digital actuation logic divisions, and ESFAS digital actuation logic divisions rely on self

-testing features to verify channel and division OPERABILITY between CHANNEL CALIBRATIONS and ACTUATION LOGIC TESTS (24 month frequencies)CHANNEL OPERATIONAL TEST (92 day frequency) retained only for RCS leak detection monitors implemented in Module Control System(containment evacuation system (CES) gaseous radioactivity monitor channel, and CES condensate channels.)ACTUATION LOGIC TEST verifies (B 3.3.2/B 3.3.3) "actuation and priority logic (APL) on all RTS/ESFAS EIMs, the enable nonsafety control switches, the main control room isolation switches, the [ESFAS] override switches, and the operating bypass switches.

The ACTUATION LOGIC TEST includes a review of any alarms or failures reported by the self-testing features."CHANNEL CHECK definitionis revised as shown in markup of STS definition:A CHANNEL CHECK shall be the qualitative assessment, by observation, of verification through the absence of alarms from the automatic analog and binary process signal monitoring features used to monitor channel behavior during operation. Deviation beyond the established acceptance criteria is alarmed to allow appropriate action to be taken.This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.This determination can be made using computer software or be performed manually.

March 20, 2019 Chapter 16 Generic Technical Specifications and Bases 13Technical TopicsElectrical Power Surveillance Requirements

• No LCOs included for electrical power systems, which are all nonsafety

-related*Module Protection System is protected from faults in the nonsafety

-related electrical power system by use of Class 1E isolation devices

• Open on undervoltage or overcurrent

• Details of design of Class 1E isolation devices not included in DCA Part 2, Chapters 7 and 8

• Isolation settings are determined in accordance with the Setpoint Program

• OPERABILITY verified by CHANNEL CALIBRATION surveillance requirements in Subsections 3.3.1, MPS Instrumentation; 3.3.2, RTS Logic and Actuation; 3.3.3, ESFAS Logic and Actuationsupport OPERABILITY of MPS Instrumentation Functions, RTS Logic and Actuation Functions, and ESFAS Logic and Actuation FunctionsOpen Item under RAI 9051, Question 16

-28, regarding whether Class 1E isolation device CHANNEL CALIBRATION surveillance is needed for Manual RTS and ESFAS Functions of Subsection 3.3.4 March 20, 2019 Chapter 16 Generic Technical Specifications and Bases 14Technical TopicsAllowed Leakage for Main Steam and Feedwater Isolation Valves

• Verifying secondary system isolation valve leakage is within limits is required by SR 3.7.1.3 (main steam isolation valves (MSIVs)) and SR 3.7.2.3 (feedwater isolation valves (FWIVs), feedwater regulating valves (FWRVs), and feedwater check valves (FWCVs) in accordance with the Inservice Testing Program.Leakage limit ensures decay heat removal system (DHRS) maintains sufficient inventory to remain OPERABLE following events that credit DHRS actuation.Applicant's response to RAI 9614, Question 16

-58, says that Surveillance acceptance criteria values for main steam and feedwater isolation valve leakage would be provided by a COL applicant to complete COL Item 3.9

-5, by establishing "an Inservice Testing program in accordance with ASME OM Code and 10 CFR 50.55a."

• Open Item under RAI 9614, Question 16

-58, to track completion of the staff's ongoing evaluation of the response.

March 20, 2019 Chapter 16 Generic Technical Specifications and Bases 15Technical TopicsExceptions to Meeting Surveillances

• While the unit is operating under an exception, operational impact may be reduced by allowing repositioning of the valve, breaker, or device under administrative control

.RTBs:Not required to be met for RTBs that are open.Class 1E Electrical Isolation Devices:Not required to be met for Class 1E isolation devices that have isolated 1E circuits from non

-1E power.Pressurizer Heater Breakers:Not required to be met for pressurizer heater breakers that are open or closed under administrative control.CVCS Isolation ValvesNot required to be met for valves that are closed or open under administrative controls.

Verify each automatic CVCS valve - actuates to the isolation position on an - actuation signal except for valves that are open under administrative controls.

March 20, 2019 Chapter 16 Generic Technical Specifications and Bases 16Technical TopicsExceptions to Meeting Surveillances (continued)Reactor Vent Valves and Recirculation Valves:Not required to be met for valves that are open.Containment Isolation Valves,Verify the isolation time - is within limits except for valves that are open under administrative controls

.Verify each automatic containment isolation valve - actuates to the isolation position on an - actuation signal except for valves that are open under administrative controls

.Revision 2 of DCA Part 4 does not include such exceptions forDHRS Actuation ValvesMSIVs, MSIV Bypass ValvesFWIVs, FWRVs

• Open Item under RAI 9051, Question 16

-28, because there are no apparent scenarios in which administrative control of an automatic valve, breaker, or device provides a safety benefit over entering the LCO action requirements. SR 3.0.1 already states that surveillances do not have to be performed on inoperable equipment.

March 20, 2019 Chapter 16 Generic Technical Specifications and Bases 17Technical TopicsOpen Item Listing (1 of 6)RAI #ActionIssue 9033 16-2.fNuScaleDefinition of RCS Pressure Boundary LEAKAGE 9051 16-27NuScaleAdditional information about locations in FSAR that describe contents of Owner Controlled Requirements Manual (Note that creation of this document is the subject of COL Item 16.1

-2)9051 16-28NuScaleAppend the phrase "in accordance with the Setpoint Program" to Channel Calibration Surveillance statement 9051 16-28NuScaleInclude a Channel Calibration Surveillance for Class 1E electrical isolation devices in LCO 3.3.4, Manual RTS and ESF Functions 9051 16-28 9642 16-64NuScaleExceptions to meeting Surveillances and use of administrative controls while using an exception 9034 16-30.dNuScaleUpdate FSAR Table 16.1

-1, "Surveillance Frequency Control Program Base Frequencies" March 20, 2019 Chapter 16 Generic Technical Specifications and Bases 18Technical Topics Open Item Listing (2 of 6)RAI #ActionIssue 9614 16-50 9642 16-65StaffNuScaleOmission of the Response Time definitions and defined terms, and the adequacy of the proposed response time verification Surveillances 9614 16-54NuScale(editorial) SR 3.7.2.1 should not contain "required" because both FWIVs are required OPERABLE by LCO 3.7.2, and the SR only applies to valves with pressurized gas accumulators 9614 16-54NuScale(editorial) Phrasing of surveillance statements to verify accumulator pressure for valves with the NuScale-specific actuator design 9614 16-58StaffDefer providing values for INSERVICE TESTING PROGRAM Surveillance acceptance criteria for main steam and feedwater isolation valve leakage limits March 20, 2019 Chapter 16 Generic Technical Specifications and Bases 19Technical TopicsOpen Item Listing (3 of 6)RAI #ActionIssue 9614 16-59NuScaleApplicability of LCO 3.3.1, MPS Function 22b, DHRS actuation on High Narrow Range Containment Pressure in MODE 3 9634 16-60NuScaleEditorial comments on SR 3.1.7.1, SR 3.1.9.1, SR 3.2.1.1, SR 3.3.2.3, SR 3.3.3.3, SR 3.4.10.4, and SR 3.5.1.4.

9634 16-60.2NuScaleClarify whether 'Low Pressurizer Level' or 'Low Low Pressurizer Level' initiates 'secondary system isolation (SSI)' actuation.

9614 16-52 9634 16-60.34 9634 16-60.63NuScale& Staff(editorial) Conformance to Improved TS writer's guide section 4.1.3.b. Remove unnecessary instances of the words "inoperable" and "required" in Condition, Required Action, and Surveillance statements; and also Action Notes on separate Condition entry.

March 20, 2019 Chapter 16 Generic Technical Specifications and Bases 20Technical TopicsOpen Item Listing (4 of 6)RAI #ActionIssue 9634 16-60.37.1NuScaleLCO 3.1.9, "Boron Dilution Control," Action B, requires isolating the dilution source, which completes the safety function of the DWSI makeup isolation valves.

It appears that the Applicability of LCO 3.1.9 for these valves would be more accurate by stating: "MODES 1, 2, and 3 with any CVCS demineralized water isolation valve open

."9634 16-60.37.3NuScaleCorrect reference to interlock (either N

-2H or N-2L) in LCO 3.3.1, Required Action E.1 ("Reduce THERMAL POWER to below the N

-2L interlock. l 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />"). The affected MPS Functions (2a, 18a, 18b, 18c) are applicable in MODE 1 above the

N-2H interlock (15% RTP) 9634 16-60.70NuScaleClarify rationale for Applicability not including MODE 3 for MPS Low Low Pressurizer Pressure Functions 9.b, DHRS, 9.c, CVCSI, and 9.d, PHT, of LCO 3.3.1, between 350°F and 420° F.

March 20, 2019 Chapter 16 Generic Technical Specifications and Bases 21Technical Topics Open Item Listing (5 of 6)RAI #ActionIssue 9642 16-61NuScaleWhat are the appropriate means of addressing prevention and mitigation of the postulated inadvertent actuation of the containment flood and drain system (CFDS) to flood the containment vessel with RCS temperature above the RCS temperature limit in the PTLR? Why not use safety-grade interlock on CFDS CIVs to protect RPV from higher than analyzed thermal stress?

9642 16-62NuScaleClarify in the Subsection 3.3.1 Bases the relationship of the MPS Instrumentation Functions, and their bypassing or enabling interlocks and permissives, to the SP controls and Channel Calibration Surveillances.

9642 16-63NuScale(editorial) Clarify Bases for LCO 3.0.4 and SR 3.0.4. Should initiating and terminating PASSIVELY COOLED be treated as a MODE transition within MODE 3?

9642 16-66NuScaleRequest for adding two additional references to the Specification 5.6.3 COLR methodology list, LOCA analyses for LCO 3.1.6, LCO 3.2.2, and LCO 3.4.1.

March 20, 2019 Chapter 16 Generic Technical Specifications and Bases 22Technical Topics Open Item Listing (6 of 6)RAI #ActionIssue9201 5.2.5

-7StaffAcceptability of 1.5 gallons per hour leak-before-break (LBB) limit on in

-containment secondary system piping leakage, specified by LCO 3.7.3. The staff is reviewing March 5, 2019, supplemental response and may request additional edits to Subsection B 3.7.3.9201 5.2.5

-7NuScaleRevised LBB analysis

-related additional information in preparation.NoneNuScaleCompletion of COL sub-itemlisting under COL Item 16.1

-1 March 20, 2019 Chapter 16 Generic Technical Specifications and Bases 23Technical TopicsPending MPS design change

• 13 DHRS-initiating MPS instrumentation Functions to support new ESFAS Function of "Secondary System Isolation (SSI)"SSI closes isolation valves in main steam lines and feedwater lines without an unnecessary cooldown from DHRS actuationAssociated SSI operating bypass based on FWIV position indication, which is upgraded to safety

-related to support bypass logicJust 4 of these 13 MPS instrumentation Functions will initiate DHRS:

• High Pressurizer Pressure (7.b)

• High Steam Pressure (17.b)

• High Narrow Range RCS Hot Temperature (13.b)

• Low AC Voltage to ELVS Battery Chargers (25.b)

• Remove uncredited ECCS actuation on RPV riser level; The safety analysis credited ECCS actuation on High Containment Water Level (23.a) is adequate to initiate ECCS by opening RVVs and RRVs March 21-22, 2017 Chapter 16 Generic Technical Specifications and Bases 24Technical TopicsGeneral Issues

• Combined License (COL) sub

-item determination

-Open Item

• Disposition of NRC

-approved technical specifications task force (TSTF) traveler changes

-adapted or not adaptedwhich have been incorporated in NUREG

-1432 (digital), Revision 4; or approved since issuance of NUREG

-1432 (digital), Revision 4.Open Items under RAI Questions 16

-2f and 16-28*Administrative Changes

-Open Items as listed aboveCorrection of grammatical and typographical errorsReplacement of inapplicable content taken from STS BasesAddition of missing content to the BasesClarification of submitted content in the BasesConformance to STS style, punctuation, phrasing, formatting conventionsResolution of inconsistencies, both within DCA Part 4 and DCA Part 2 March 20, 2019 Chapter 16 Generic Technical Specifications and Bases 25Chapter 16 Review Status

SUMMARY

• The NuScale Generic Technical Specifications are based upon Standard Technical Specifications; differences are a result of design differences with plant designs considered in the STS

• A thorough review of the NuScale GTS has been conducted resulting in a safety evaluation chapter that includes open items in the following areas:

• New and Revised Defined Terms and revised definitions *MPS instrumentation Function Applicability inconsistencies*I&C surveillance requirements & testing

• Response time testing

• Application of LCO selection criteria, TSTF disposition & COL action items

• Administrative and editorial issues

• Resolution of the Open Items will be accomplished with the assistance of the technical branches (i.e., ICE, SRSB, SPRA, SCVB, and SPSB)