ML19088A327

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

ML19088A327
Person / Time
Issue date:	03/07/2019
From:	Lawrence Burkhart Advisory Committee on Reactor Safeguards
To:
Burkhart L
References
NRC-0206
Download: ML19088A327 (105)

Text

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

Date:Thursday, March 7, 2019Work Order No.:NRC-0206 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 661ST MEETING 4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 (ACRS)6+ + + + +7 THURSDAY 8 MARCH 7, 2019 9+ + + + +10 ROCKVILLE, MARYLAND 11+ + + + +12 The Advisory Committee met at the Nuclear 13 Regulatory Commission, Two White Flint North, Room 14 T3D50, 11545 Rockville Pike, at 8:30 a.m., Peter C.

15 Riccardella, Chairman, presiding.

16 COMMITTEE MEMBERS:

17 PETER RICCARDELLA, Chairman 18 MATTHEW W. SUNSERI, Vice Chairman 19 JOY L. REMPE, Member-at-Large 20 RONALD G. BALLINGER, Member 21 DENNIS C. BLEY, Member 22 CHARLES H. BROWN, JR. Member 23 MARGARET SZE-TAI Y. CHU, Member 24 MICHAEL L. CORRADINI, Member 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 VESNA B. DIMITRIJEVIC, Member 1 WALTER L. KIRCHNER, Member 2 JOSE A. MARCH-LEUBA, Member 3 HAROLD B. RAY, Member 4 GORDON R. SKILLMAN, Member 5 6 DESIGNATED FEDERAL OFFICIAL:

7 MICHAEL SNODDERLY 8 9 ALSO PRESENT:

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

13 MIKE MILTON, NuScale 14 LAUREN NIST, NRR*

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

17 TIM TOVAR, NuScale*

18 19 20*Present via telephone 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 TABLE OF CONTENTS 1 Page 2 I. Opening Remarks 3 Peter Riccardella.............4 4 Mike Corradini..............6 5 II. Safety Evaluation with Open Items 6 Chapter 13: Conduct of Operations 7 Prosanta Chowdhury............7 8 IV. Safety Evaluation with Open Items 9 Chapter 18: Human Factors 10 Engineering 11 Prosanta Chowdhury............44 12 Brian Green................45 13 Public Comment 14 Marvin Lewis...............80 15 Adjourn 16 Peter Riccardella.............90 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 8:32 a.m.2CHAIRMAN RICCARDELLA: The meeting will 3 now come to order, please.

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

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

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

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

23Written comments are also welcome. Mr.

24 Mike Snodderly is the designated federal official for 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 the initial portion of this meeting.

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

7The ACRS Section of the U.S. NRC public 8 website provides our charter, by-laws, letter reports, 9and full transcripts of all full and subcommittee 10 meetings, including all slides presented at the 11 meetings.12 We have received no written comments or 13 requests to make oral statements from members of the 14public regarding today's sessions. There will be a 15 phone bridge line but to preclude interruption of the 16 meeting, the phone will be placed on a listen-in mode 17 only during the presentations and committee 18 discussion.

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

24 Please silence your cell phones or other 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 items that could make noise and disrupt the meeting.

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

3MEMBER CORRADINI: I'm going to wait until 4 the public line is open, okay?

5 CHAIRMAN RICCARDELLA: Yes.

6MEMBER CORRADINI: I think that's 7 important.

8 May we begin? Okay.

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

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

24 I'm going to leave it to Dr. Chowdhury 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 7 discipline us if we ask something that should be in 1 closed session. We have about 45 minutes to an hour 2scheduled at the end of the morning for a closed 3 session, if need be. Okay?

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

5Chowdhury. I remind all the members the mics are 6 always live.

7DR. CHOWDHURY: Thank you. Good morning.

8My name is Prosanta Chowdhury. I am a project manager 9 in NRO, Officer of New Reactors of the U.S. Nuclear 10 Regulatory Commission.

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

18 So what I plan to do today is briefly 19 cover the presentations that the staff already 20 presented at the subcommittee meeting on Chapter 13 on 21January 23, 2019. So I am just going to briefly 22 summarize what the staff covered. And I should have 23 Ms. Maurin Scheetz on the phone to answer questions on 24Section 13.1, 13.2, and 13.5. I have Ms. Amanda 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 Marshall in the audience to answer questions on 13.3.

1 And 13.4 is just a COL item.

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

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

11So 13.1, that is one of the sections 12Maurin Scheetz is the lead reviewer for. And the 13 scope of the review was the organizational structure.

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

24 And the staff reviewed those COL items 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 9 found them acceptable and there are no open items for 1 this section of the SE, safety evaluation.

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

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

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

22 These two are connected?

23 DR. CHOWDHURY: If you are talking about 24 the Process Sampling System, 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 10 MEMBER BALLINGER: Right.

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

4MEMBER BALLINGER: All right, I got it.

5 All right, thanks.

6DR. CHOWDHURY: So here we are at 13.3, 7Emergency Planning. So the focus areas were the 8 Technical Support Center, Emergency Response Data 9 System, Technical Support Center Engineering 10 Workstations, Decontamination Facilities, Process 11 Sampling System, Operations Support Center, Emergency 12 Operations Facility, and Emergency Plan and Emergency 13 Planning ITAAC.

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

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

24 The staff presented the interface 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 interactions on January 23rd and if there are any 1 other questions related to that, Amanda Marshall is in 2 the audience to answer the questions.

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

9 13.3, there is no requirement for 10 operational programs for a DC applicant, however, 11 there is a requirement in 10 CFR 52.79 for COL 12 applicants to describe operational programs.

13 There is a COL information item provided 14 by the applicant, which is 13.4-1 and the staff 15 reviewed it consistent with the Standard Review Plan, 16 Section 13.4 Draft Revision, which was in September of 172018, I believe. And the staff found it to be 18 acceptable, comprehensive, and there are no open items 19 in this section.

20MEMBER SKILLMAN: Dr. Chowdhury, let me 21 ask a question here and it's either in 13.4 or 13.5 22 that I will ask it again in 18.

23 What is unique about this plant is heavy 24 load lifting. And heavy load lifting is going 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 12 a constant activity on a 12-module plant, 24-month 1fuel cycle. There will be heavy lifting including 2 module shield blocks, and other paraphernalia 3 constantly.

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

10DR. CHOWDHURY: Okay, if I understand 11 correctly, there is a lot of module movement in --

12MEMBER SKILLMAN: Well, let me be very 13clear. In my view, this is a subcommittee meeting --

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

21 Even while those operating reactors are 22 functioning, there is going to be another crew 23 completely independent moving very heavy loads 24adjacent to those live cores. And I assert that 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 13 activity demands as much attention as keeping watch on 1 the operating cores.

2So my question is:

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

9DR. CHOWDHURY: Right. Yes, I understand 10 that and I also reviewed the transcript that has your 11 comments and questions about it.

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

16So beyond that, the staff looked at all 17 these on the organizational aspect of the reactor 18operation. So I will defer it if Maurin Scheetz is on 19 the line or Brian Green is in the audience that maybe 20 you can supplement our answer to this question.

21 So Brian is going to come.

22MEMBER CORRADINI: If I might just jump 23in. I think what Member Skillman is wondering, it 24appears here but it's also connected to 18. It's 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 14connected to Chapter 9. So they are all connected.

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

3DR. CHOWDHURY: Oh, yes. No, it is 4because, as Brian is going to probably cover -- add 5 also is that we had extensive interactions and 6 communications between Chapter 18, 13, Chapter 19, and 7 Chapter 15, and also part of Chapter 7.

8 So, Brian.

9DR. GREEN: Hi, it's Brian Green, Chapter 1018 reviewer. I don't think that maybe the discussion 11 in the subcommittee meeting maybe got as deep into 12 this as we probably should have.

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

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

22 it's still in process.

23 So in one sense, the Chapter 19 reviewers 24are working to have this discussion. They've been 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 aware of it and they don't have the final solution to 1 it yet.2 As far as -- maybe I should save this for 3 Chapter 18 in a little bit. We have a process where 4 we go back and reconcile to make sure that if there 5 are new insights from the PRA, let's say that you know 6 your question -- maybe what you're saying is something 7that needs to be done. If that becomes a part of the 8NuScale operations, we would go back through our 9 design implementation process to make sure that the 10 appropriate tests are done or that there are valid 11 analyses that help to help us make a conclusion.

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

15 MEMBER BLEY: Please don't leave yet.

16 DR. GREEN: Okay.

17MEMBER BLEY: I was going to wait for 18 Chapter 18 but I think this is the right time.

19 Just a quick summary because these things 20 that cover multiple chapters are easy to lose track 21 of.22DR. GREEN: Yes, it spans a bunch of them.

23MEMBER BLEY: Chapter 19 with the PRA 24 looked at seismic event impact on the crane. 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 16 to go back and look more carefully at the regular part 1 of the PRA and see if they looked at crane drop 2 accidents there and they should have.

3In Chapter 18, the staff had asked the 4 applicant about the HSI for the crane and, at least by 5 implication, any human errors associated with that.

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

8 I'm personally, well other than being a 9 little uncomfortable with that, what I would like to 10 hear from the staff is how, once the crane vendor 11 gives their information on the HSI and any associated 12human actions with these lifts, that NuScale will 13 actually own that part of the analysis and the staff 14 will have reviewed it, if not for their design cert, 15certainly I think for the COL. It's really kind of 16 crucial.17And the PRA, given the kinds of things 18 that have happened in crane drops in the past, the PRA 19 ought to be looking at human errors in rating the 20 crane, such that things get dropped. That's kind of 21 the most commonplace, other than breakage of some of 22 the small components, the lifting the components 23 themselves, rather than the crane.

24 Is there anything more you can say 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 17 that?1DR. GREEN: I can say that there have been 2 some RAIs issued in Chapter 9 space to try and find 3 out what those words of futures would be so they could 4 be included in specs but I would not be the person to 5 answer further details on it.

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

10MEMBER CORRADINI: I think the essence of 11 what Dennis is asking, and I don't know maybe if this 12 is an easy yes or no, is that as we understood it from 13 the subcommittee meeting, staff identified this as a 14risk. Staff has asked NuScale. NuScale has said 15 their vendors are going to take care of it.

16 We want to make sure the circuit is 17 completed so that the vendor comes back to NuScale, 18 and NuScale owns the plan, and staff has reviewed the 19 plan.20DR. GREEN: Understood. I think where 21 we're seeing it right now is these are essentially 22 screening criteria that would screen this into the HFE 23 review and I don't think that that answer is solved 24 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 18 So the Chapter 19 review might say you 1 need to provide this, you need to provide some sort of 2testing on the front end, rather than to delay it. So 3 the results of the Chapter 19 about how this ranks in 4 the risk may bring this more forward in the human 5 factors space, or it may go more to the lower end.

6 MEMBER BLEY: Okay. Well --

7DR. GREEN: That screening question is 8 still where it is still under some dispute.

9MEMBER DIMITRIJEVIC: All right, so I'm 10 familiar with those two RAIs which are issued on the 11movement of the modules and they are related to the 12numerous operator action related to that. Some of 13 them are action of Commission which are not even 14 modulating the Chapter 19.

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

20 Well we will discuss that maybe more in 21the Chapter 18. However, what I think Dick is 22 bringing, and this is how I feel, what is really 23specific for this design is this module movement. It 24 is not -- I mean the other plants have the crane 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 19 during shutdown you know damaging but this is 1completely different. This is the module movement 2 which can damage operating modules and misplace module 3-- I mean you know disposition module in position 4 where it cannot be cooled.

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

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

16DR. GREEN: I understand that there is 17 potential for this and this is something that we are 18still working on. I know Maurin is on the line.

19 She's been doing some thinking on this but I don't 20 believe there is a decision made about what that 21 critical -- if there should be another critical safety 22 function.23 I believe NuScale's position is three is 24 enough but the staff is 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 20MEMBER DIMITRIJEVIC: Well, it doesn't 1 have to be core critical safety function because it's 2 something we use for yes, so the staff to change some 3 of its mind, but it has to be identified as an 4important function of something you know. At least 5 the function it has to show somewhere in both 6 chapters.7 DR. GREEN: Understood.

8MEMBER RAY: Dennis, you referred to 9 NuScale in the context of the crane vendor, I believe.

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

13MEMBER RAY: Understand but I thought 14 there was some element of oversight review, approval, 15or whatever of what the crane vendor did. I'm not 16 sure that wouldn't be the COL.

17MEMBER BLEY: I'm not sure either but I 18 think it ought to be before the COL is completed.

19 MEMBER RAY: Right.

20MEMBER BLEY: Because it could be a major 21 crumble.22 MEMBER RAY: Yes, but it could vary from 23 plant to plant in terms of who the vendor was, how 24 they approached the problem, and so on and so forth, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 21 as far as I can tell.

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

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

10 So what --

11MEMBER BLEY: I'm sorry. NuScale did say 12 that they would be including requirements about this 13 in their request for proposal or whatever it is from 14 the crane vendor.

15 DR. GREEN: The procurement vendor.

16MEMBER BLEY: So they were saying that 17 they would own it.

18MEMBER RAY: Okay, so you're satisfied 19 then that that's been addressed.

20MEMBER BLEY: I'm satisfied that they are 21 going to do it.

22 Now, if you come along and buy one of 23 these things, you might put in an exception to switch 24 the crane vendor but then it ought to be covered 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 22 the COL stage.

1 That's my opinion.

2DR. GREEN: And the human factors process 3 has a portion that starts after the Integrated System 4 Validation which occurred in the summer of last year 5 that aims to ensure that any human actions -- that new 6 human actions may arise between now and startup get 7 analyzed and potentially tested, if they rise to that.

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

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

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

23MEMBER SKILLMAN: Let me thank you for 24 your response and it gives me confidence that 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 23 concern that I have is going to be addressed.

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

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

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

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

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

24That led me back to 19, to Dr.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 24Dimitrijevic's comment. If you look at 19, 19 says 1 module handling is the greatest core safety risk in 2 the plant. And I figured well, what does Chapter 15 3 communicate? And I got to Chapter 15 and Chapter 15 4 communicates neither cask drop nor module drop are 5 examined because of the crane being a single failure.

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

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

19 DR. GREEN: Understood.

20 MEMBER SKILLMAN: Thank you.

21 DR. GREEN: Thank you.

22MEMBER REMPE: Before you leave, excuse 23me. When you did the review, and I read the 24 transcript -- I missed the meeting -- but it looks 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 like, and I know NuScale wants it to be, for where all 112 modules are installed and operating. But in 2 Chapter 18, they explicitly say in the open document 3 that it is anticipated that you might have some 4 modules up and running while you are still installing 5 other modules.

6Where do the modules come in? Do they 7 come in over the spent fuel pool? What end of the 8 building do they come in at?

9DR. GREEN: Lauren, do you have the answer 10 for that off the top of your head? I don't remember 11specifically. I know that installing the new modules 12 is quite similar in activity to the refueling module 13 but I don't remember --

14 MEMBER REMPE: Well okay.

15 DR. GREEN: -- when the new module comes 16 in.17MEMBER REMPE: It's not -- it may not be.

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

24 And you're saying no, they can bring it 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 26 from the outside world.

1DR. GREEN: I believe that was one of the 2 assumptions but I don't remember off the top of my 3 head.4MEMBER REMPE: Okay then I'd like to know 5 how -- if you --

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

7MS. NIST: Yes, I'm on the line. So I 8 also have to do some research to answer that question 9 with accuracy.

10MEMBER REMPE: Because I am curious 11because in Chapter 9, with the staff interactions, 12 they actually had NuScale change the DCA to day don't 13 bring in a new fuel assembly over the existing fuel 14assemblies. And if we don't know how they're bringing 15in the module, I think that some attention might be 16 warranted to make sure that the DCA explicitly states 17 how this is going to happen.

18 DR. GREEN: We can look into that.

19 MEMBER REMPE: Okay, thank you.

20MEMBER MARCH-LEUBA: Joy, I am looking at 21 one of the cartoons, the pictures of NuScale, and the 22 module seems to be coming horizontally into the 23refueling machine. So the new module will come 24 horizontally and then drop into the -- above the fuel 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 pool.1 MEMBER REMPE: So it does --

2MEMBER MARCH-LEUBA: I can show you in the 3 picture.4MEMBER REMPE: So it is coming in over the 5 spent fuel pools.

6 MEMBER MARCH-LEUBA: Over the fuel pool, 7 yes.8MEMBER REMPE: It's interesting, since 9 we're not supposed to be bringing a fuel assembly in 10 over the existing fuel elements but they have the 11 modules coming in over the spent fuel elements.

12MEMBER MARCH-LEUBA: Yes, we don't have 13 enough detail to know if it might be a little to the 14 left or to the right.

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

17MEMBER MARCH-LEUBA: I'm going to look at 18 it.19 MEMBER REMPE: Yes.

20MR. MILTON: Mike Milton with NuScale.

21And we have a team on the phone that can help. It 22 does not come in over the spent fuel pool.

23MEMBER REMPE: And that is actually stated 24 somewhere in the DCA?

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 28 MR. MILTON: I will check on that.

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

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

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

12 Someone is on the phone.

13MEMBER CORRADINI: Can you guys please 14speak up? We can barely hear you. You've got to get 15 close to a mike or get off the speaker phone. Still 16 too low. Louder.

17 MEMBER REMPE: We're old.

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

19I apologize for that. But it is not typically 20 possible to bring a module in over the spent fuel 21pool. There is no equipment to life a module over.

22It comes to the side of the spent fuel pit and then 23enters the pool. It is then, I think people are 24 familiar with the travel path going to the -- from 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 29 dry dock basically in the pool submerged -- partially 1 submerged, to the operating bay, and to the 2 disassembly equipment.

3MEMBER REMPE: Where is this documented in 4 the DCA, what chapter?

5PARTICIPANT: Yes, I don't have that 6information right now. We're looking but I just 7 wanted to mention it is not physically possible to 8 lift it up over the spent fuel pool. There is no 9equipment above it that would be able to hoist any 10 portion of the module up over the spent fuel pool.

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

13I'm just trying to figure this out. And if you could 14 point me somewhere into the available documentation we 15have, whether it's proprietary or not. And you can do 16this later, give it to Mike Snodderly. But I would be 17 curious in understanding how it gets in -- a new 18 module would get into the building when you've got 19 modules up and running.

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

23MR. MILTON: This is Mike Milton. Yes, we 24 will.25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 30 MEMBER REMPE: Thank you.

1 MEMBER CORRADINI: Go ahead.

2DR. CHOWDHURY: My last slide on plant 3procedures, 13.5. There are open items -- there is 4one open item. In 13.5 there is one. So the NuScale 5 submitted a Generic Technical Guideline Document, Rev.

6 0. The staff reviewed it.

7 The staff had extensive interactions with 8NuScale on this document. We had two public closed 9meetings. I think one in February of 2018 -- February 109th and February 15. We had two really extensive 11meetings and I was part of it. There were feedback 12 from the staff, extensive feedback provided to NuScale 13 on what they had identified as their concerns.

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

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

24MEMBER BLEY: Prosanta, can I ask you 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 31 couple of questions about this?

1 DR. CHOWDHURY: Yes.

2MEMBER BLEY: I know you haven't finished 3 your review but the GTGs are called out in Chapter 13 4for developing procedures as a reference. They aren't 5 called out in Chapter 18 but some of the citations in 6 Chapter 18 use them as a secondary reference, which is 7 truly important over there as well.

8 In the development of procedures -- well 9 this question is one you can save until later until 10 you've finished your review of GTGs -- but there is a 11 section on symptom-based procedures and there's a 12 section on -- I lost it here -- I turn pages too 13 quickly -- on essentially how you use the GTGs to 14develop procedures. And those aren't -- to me, are 15 not fully transparent. So after you've finished the 16 review, we want to ask a number of questions about 17 those.18 There are places where it sounds like the 19automated version of the GTGs are almost procedures 20 and there's really no clear indication of how 21 procedures will be developed from them. You know if 22 one looks at those flow charts as what we'd call ESDs 23 in doing risk assessment, they certainly aren't 24complete. If they are tools for developing 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 32 procedures, it's important to really understand how 1 they're going to be used.

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

4 DR. CHOWDHURY: Okay.

5MEMBER BLEY: For Chapter 13, those are my 6 main concerns right now.

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

10MEMBER BLEY: Since the whole document is 11 proprietary, yes, probably.

12 DR. CHOWDHURY: Okay.

13MEMBER BLEY: And I don't think we need to 14do it today. I think that's something -- unless 15 you've finished your review or it's almost done and 16 you're ready to address it.

17 DR. CHOWDHURY: No.

18 MEMBER BLEY: Okay.

19MEMBER CORRADINI: I didn't think so.

20 Okay.21DR. CHOWDHURY: Okay so there are several 22 COL items for this section of the SE, 13.5-1 through 23 13.5-5 and then 13.5-7 and 13.5-8 for plant 24 procedures. Those the staff found to be appropriate 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 33 and acceptable.

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

4 I believe Maurin she is on the line.

5 Maurin, are you on the line?

6MS. SCHEETZ: Yes, good morning. This is 7 Maurin Scheetz.

8DR. CHOWDHURY: Okay. So thank you for 9joining. And Maurin, is the key reviewer for this 10 section of the DCD. So if you have any questions in 11 the public discussion time, then she can answer.

12MEMBER CORRADINI: Any further questions.

13 DR. CHOWDHURY: Any further questions.

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

19 DR. CHOWDHURY: Okay.

20MEMBER BLEY: Those were the ones I had 21 seen. They're hard to track.

22 And I was looking at the one.

23 DR. CHOWDHURY: Okay.

24MEMBER MARCH-LEUBA: I don'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 34question. I have a comment that I wanted to follow-up 1 in the subcommittee meeting. Is now the time?

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

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

12So I imagine if somebody is moving a 13 module in the middle with a crane and you have a big 14 seismic event, so I need the whole attention of the 15 operator who is going to be on the module that will be 16 moved. And he will quickly glance around and see 11 17 green lights, saying I don't have worry about those 18 guys. Let me worry about this one.

19 One concern I have is there is too much 20 over-reliance on computer-aided procedures and 21 computer-aided green lights. When we discussed this 22 in the subcommittee, NuScale told us that they trained 23 their operators when the screen goes black how to go 24 and use the backup information, the tablet, 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 35 possibly on paper.

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

5And so one of my recommendations and I 6believe the committee can follow up on that is that 7 there should be some recommendations to have some 8 training for the operators where the computer lies to 9them. It makes a green light show green when it 10should be yellow or red. And they should have an 11 emphasis on don't believe the green light completely.

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

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

16 DR. CHOWDHURY: Thank you.

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

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

19MEMBER CORRADINI: Okay, so we can move on 20 to Chapter 18.

21 DR. CHOWDHURY: Okay.

22 MEMBER BROWN: While they're doing that, 23 I'd just make one observation relative to your green 24 lights. Like you say, it's a software and computer-25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 36 generated safety indication, which seems to go against 1 the old dictum that you believe your instrumentation 2 and the operators look at their instrumentation, not 3 an amalgam of a bunch of algorithms to tell you don't 4 bother with all the instrumentations, I've telling you 5everything's okay. I am just not comfortable with 6that. Like you, I'm not comfortable with that thought 7process. Too many screens and not enough people to 8 look at them.

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

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

12MEMBER BROWN: But still, somebody has got 13 to design the pathway for that information to get 14 through, whether it's a microprocessor or FPGA.

15MEMBER MARCH-LEUBA: Maybe the probability 16of failure is lower. Maybe it's a little more 17 deterministic but still probability of failure exists.

18MEMBER BLEY: Before we leave that little 19 side discussion, I'd like to join in.

20 Well, I don't disagree at all. The 21 instruments can give you misleading signals. On the 22 other hand, there are some kinds of activities that, 23 and quite a few of them, especially the routine 24 checking of many things, for which computers are much 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 37 more reliable than people.

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

5MEMBER MARCH-LEUBA: My recommendation is 6to have the best of both worlds. Have a computer use 7 them but train the operator to check the computer.

8 MEMBER BLEY: No, I agree.

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

11I said this in the subcommittee. Chapter 12 18 is sparse on detail. It tells what they're going 13 to do and it doesn't report back all of the human 14 events, and human actions, and all of those things.

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

17 As we go through this discussion, I'd be 18 happy if the staff would tell us how they gain 19 confidence that this set of human actions is complete, 20 is reasonable, or needed, given they have to go 21 through this whole chain of documents to track it 22 down.23 The GTGs seem to be the main source where 24 one would develop human actions to be examined both 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 for developing procedures, for understanding 1 operations, and truly to support the PRA, although 2 they imply that they get their source of human actions 3from many different places, including the PRA. And 4 that goes both ways. That's a little reasonable.

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

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

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

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

7DR. GREEN: This is probably the more 8 appropriate time to address it but I will mention that 9there was an RAI -- this goes way back. I don't 10remember. I'll have to get you that -- but where 11 NuScale had credited some analysis that kind of goes 12into what you're looking for, errors of commission 13that may happen. We would have to find that for you.

14 MEMBER BLEY: Okay.

15DR. GREEN: It was in a related topic but 16 it was not specifically addressed to find that.

17MEMBER BLEY: So you didn't find it in the 18 document. You only got it in response.

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

20MEMBER BLEY: Interesting. It seems to me 21 if they really did something like that, there ought to 22be a document. That's just stuff I'm concerned about 23 in that area.

24DR. GREEN: Do you want a closed session?

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

3DR. GREEN: I think getting you the RAI 4 would be more appropriate but it's been quite a while 5since I've looked at that. I would rather get that to 6 you than just say something untrue.

7MEMBER BLEY: Is the staff comfortable 8 that the applicant did a thorough job of searching for 9 errors of commission that they say they've looked for?

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

12 DR. GREEN: I agree.

13MEMBER BLEY: You won't see them in a 14 test.15DR. GREEN: It would not be likely to show 16 up in the types of tests that we run because they 17 happen so infrequently and with the number of 18 scenarios and the number of trials we do, you would 19 have to run hundreds, maybe thousands of tests to 20 maybe catch one.

21 MEMBER BLEY: Maybe.

22DR. GREEN: Yes, I agree that would not 23 the best --

24 MEMBER BLEY: And you're not going to 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 41 that.1DR. GREEN: Right. That's not within the 2 scope of what we do.

3MEMBER DIMITRIJEVIC: But a couple of 4 errors of commission identified during module 5movement. I know you look in seismic but there is 6 actually module movement regular operation, not 7 seismic related where there is I think three errors of 8 commission identified the operator can actually make 9 that are in error.

10 MEMBER BLEY: In Chapter 19.

11MEMBER DIMITRIJEVIC: IN the RAI for 12 Chapter 19.

13 MEMBER BLEY: Oh, okay.

14MEMBER DIMITRIJEVIC: I will give you 15 connection to this.

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

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

23 And that's just one event.

24 MEMBER BLEY: That's one, yes.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 42MEMBER DIMITRIJEVIC: Yes, and we don't 1 see what is inside.

2MEMBER BLEY: And it's an amalgam of stuff 3 from everywhere.

4MEMBER DIMITRIJEVIC: Right. However, 5 there is the technical report which describes those 6 errors of commission and also errors of omission also 7 related to the module drop. That technical report I 8 hope to see when we go to visit.

9 MEMBER BLEY: Okay, yes, I would like to 10 see that.11 Also, until they really get a crane, 12 they're going to have to revisit this --

13 DR. GREEN: That's true.

14MEMBER BLEY: -- because those sorts of 15 things are very dependent on the design that they've 16 actually done.

17DR. GREEN: Our Chapter 19 reviewer is 18here. If you'd like, we could ask Marie Pohida to 19 perhaps discuss some of where the -- what the 20discussions are. I know she's issued some RAIs 21 recently.22MEMBER BLEY: Well I think the seismic 23 part we'll wait because we haven't had any meetings on 24 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 43 It would be delightful to hear from her.

1MS. POHIDA: Good morning. I'm Marie 2 Pohida from the PRA Group in NRO and I am the tech 3 reviewer for Chapter 19 on module drop.

4 So are there any questions that I need to 5 answer?6 MEMBER SKILLMAN: Well, I would ask one.

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

12 MS. POHIDA: Uh-huh.

13MEMBER SKILLMAN: So it's called stacking.

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

19MS. POHIDA: Okay. We looked at all 20 movements of the module you know from the operating 21 bay all the way up to the lift at the reactor 22 internals with the upper portions of the CNV and the 23 upper portions of the RPV when they're loading onto 24 their fueling deck for inspection. We looked at 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 44 entire path of the crane.

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

5 MEMBER SKILLMAN: Thank you.

6 MS. POHIDA: Does that help?

7 MEMBER SKILLMAN: Yes, thank you.

8 MS. POHIDA: Thank you.

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

12 DR. CHOWDHURY: Let me go first.

13 DR. GREEN: Sure.

14DR. CHOWDHURY: So this is Chapter 18 and, 15 again, I am the project manager.

16 And Chapter 18 --

17MEMBER CORRADINI: Is there slides for 18?

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

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

23 And the technical staff involved are Dr.

24 Amy D'Agostino from Research, Dr. Brian Green who 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 45 here to cover the next slides, Ms. Lauren Nist, she is 1 on the phone, and Maurin Scheetz is on the phone as 2 well. Greg Cranston is the lead project manager.

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

4 Brian Green to cover the following subsequent slides.

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

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

21 To provide technical justification for 22 this proposed operator staffing requirements, the 23 applicant conducted a Staffing Plan Validation test or 24 SPV, as we've often used too many acronyms here. 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 46 apologies for that.

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

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

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

14 MEMBER BLEY: It is complete?

15DR. GREEN: That one is complete. The 16 Integrated System Validation is not complete.

17 MEMBER BLEY: Okay.

18MEMBER CORRADINI: But you have -- because 19 in January we were under the impression something has 20 been submitted.

21DR. GREEN: It has not been submitted yet.

22 MEMBER CORRADINI: Oh.

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

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

2DR. GREEN: Yes, the testing was conducted 3 in August and September and they've been using the 4 last few months to analyze and generate the report.

5MEMBER BLEY: And your SER did not include 6the SPV reports, did it? I thought they were still to 7 come.8 DR. GREEN: I believe the qualifications 9 chapter discusses it.

10MEMBER BLEY: I'll have to go back and 11 look but I thought it showed --

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

13 I don't remember.

14MEMBER BLEY: You still have to review it 15 I think is what it said but I'll take a look.

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

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

21 MEMBER BLEY: Thank you.

22 DR. GREEN: Shall I continue? Okay.

23 I just want to take this opportunity to 24 remind us that many of the specific details of 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 48 applicant's test methods and results are proprietary.

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

3 To conduct our review and develop the 4 safety evaluation, we reviewed the following parts of 5the application: The DCA Tier 2, Chapter 18, which 6summarizes the more detailed parts of the many 7 technical reports that were submitted with the 8 application; we reviewed many of the technical 9 reports, which include a description of methods the 10 applicant uses for various analyses; and a summary of 11 the results of the testing that was conducted for 12 those.13As you mentioned, the ISV is not yet 14complete. So that's where many of our open items are 15in that area. But most of the rest of the HFE process 16 is complete at this time.

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

20 We reviewed the concept of operations, 21 which describes the rolls and responsibilities of the 22 control room operators and how they are expected to 23 interact with each other and use the HSIs to operate 24 the 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 49 We reviewed a description of the methods 1 the applicant used to conduct the Staffing Plan 2 Validation and the results. And we've also reviewed 3 a description of the methods the applicant used to 4 conduct the Integrated System Validation test, 5 including things like reviewing the types of scenarios 6 that were going to be implemented, the types of 7 methods, data collection methods and whatnot.

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

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

15 We also reviewed the information in Tier 162, Section 3.15. The Tier 1 information in this 17 section includes an ITAAC for HFE.

18 Chapter 14 of the staff's Safety 19 Evaluation Report also documents the staff's review of 20 HFE ITAAC and there is some overlap in Chapter 18 of 21 this SER.22And perhaps I think one of the more 23 important parts we did is the staff conducted a series 24 of audits to review the applicant's human factors 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 50analyses and design activities. Staff confirmed that 1 the applicant conducted these activities consistent 2 with applicable guidance and that appropriate 3 considerations unique to small modular reactors were 4 included.5 In addition, the staff performed audits of 6 the Staffing Plan Validation and the Integrated System 7 Validation tests, both of which provide performance-8 based evidence suggesting the plant could be safely 9 operated using the NuScale human system interfaces and 10 staffing levels described in the application.

11 Next slide, please.

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

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

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

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

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

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

19 MEMBER REMPE: Excuse me.

20 DR. GREEN: Yes.

21MEMBER REMPE: So I, unfortunately, missed 22the January subcommittee meeting but I know Member 23 Bley brought up some of my concerns about shared 24 systems during this interim period before all 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 52 modules are installed.

1Did your review look at some of these 2 human actions during this interim period? For 3 example, when they did install a new module coming in, 4 it seems like you'd have to be lowering the water 5 level of the pool as you put this big volume in. If 6 there is shared systems, such as the backup diesel 7 generators, and they may not all be installed from day 8 one, what shared systems need to be considered and did 9 their -- what they submitted, did it consider that 10 interim period prior to all this being there or do 11 they assume all shared systems like the backup diesel 12 generators, et cetera, are there from day one when a 13 module is operational?

14I know they said the operators -- six 15 have to be there if you only have one module but I 16 didn't see anywhere where they identified when all the 17 shared systems have to be installed.

18DR. GREEN: I can't say I have the answer 19for that. I know that much of the refueling work has 20 been scoped out because of the way the risk-informing 21 process works. So much of it is not included within 22 the HFE review currently.

23 If it gets scoped in by changes to Chapter 24 19, 15, or Chapter 7, then we would have to go back 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 53 and retest them.

1MEMBER REMPE: This is not refueling.

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

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

10DR. GREEN: I don't know the answer to it 11 so I would have to look but I can't recall.

12MEMBER REMPE: Is anyone on the line from 13 NuScale who can provide some sort of information?

14 MEMBER BLEY: Someone's here.

15MEMBER REMPE: Or if someone from NuScale 16 could answer those kinds of questions for me because 17 I am concerned about that interim period. We have a 18 lot of plants that never built some of the units that 19 were originally proposed.

20MR. MILTON: Sure, it's Mike Milton. I'll 21 open up to the NuScale team if they'd like to answer 22 that question about the pool level. I believe the 23 pool level does not change.

24MEMBER CORRADINI: I think it's more than 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 the pool level. I think what Member Rempe is asking 1 is, to put it as I -- do shared systems get installed, 2 whether it's one or ten, or one or n, and two, the 3 activities occurring during the operation of less than 4--5 MEMBER REMPE: Interim.

6MEMBER CORRADINI: -- the interim period.

7MEMBER REMPE: Yes and that's true. It's 8 more than just dropping -- that's one example that 9 came to my mind. But I'm just wondering has someone 10 from NuScale been thinking about this.

11MR. MILTON: Sure. I'll give Corvallis a 12chance to comment. If not, we'll take it away and 13 come back.

14 MEMBER REMPE: Did we lose them?

15 MEMBER CORRADINI: Anybody out there?

16MR. TOVAR: This is Tim Tovar, NuScale 17Power. The answer to that question is yes, we have 18 looked at that but we don't have the expertise in the 19 room to answer it in detail.

20MEMBER REMPE: So this is a multi-chapter 21question. And so can you provide some information so 22 that we can look at that because it is of interest to 23me? And again, the transcript says no -- again, maybe 24 it was just the guy up on the podium, and it was 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 55 person from NuScale and I don't remember his name, but 1 said no, it's not documented anywhere.

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

6DR. GREEN: I don't recall it. I'm not 7 sure if one of the other reviewers might have looked 8at that at some level. Lauren or Maurin, do you have 9 anything to add on this? We may need to get back to 10 you on that.

11 MEMBER REMPE: Okay, thank you.

12DR. CHOWDHURY: One thing -- this is 13 Prosanta Chowdhury -- I would like to mention is that 14 not to the details that you may be looking for but 15 some concept has been provided in Chapter 21, Multi-16 Module Design Considerations while they are talking 17 about construction and operation phase how modules are 18 placed and what shared systems are installed at what 19 point.20 MEMBER REMPE: Chapter 21 --

21 DR. CHOWDHURY: Chapter 21.

22MEMBER REMPE: -- explicitly says when the 23 shared --24DR. CHOWDHURY: They have some high level 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 information in there.

1MEMBER REMPE: I will look at that before 2 we get to our review coming up in Chapter 9.

3DR. CHOWDHURY: This is unique NuScale 4 design certification application has Chapter 21 and it 5 is Multi-Module Design Considerations.

6MEMBER REMPE: Okay. Well, I will look at 7 it and anything NuScale can provide before this mid-8 March meeting I think would be helpful in our 9 discussion. Thank you.

10DR. GREEN: Let's see, are we on the right 11 slide? Next slide, please.

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

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

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

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

16MEMBER BLEY: Did the Navy share 17 information with you on this topic?

18 DR. GREEN: I don't know if the Navy did 19 but there are publishable articles out there about 20 these sorts of issues. The UAVs were one particular 21 area.22MEMBER BLEY: Okay. When you said the 23 military, I assumed you were talking about the Nuclear 24 Navy.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 DR. GREEN: No, no.

1MEMBER BLEY: I'd be surprised if they 2 shared.3DR. GREEN: I would not ask NuScale to 4 discuss all of their sources but this is a common 5 human factors problem that has been in our industry 6for quite some time. UAVs being one that's quite 7publishable, where the thought was always that one 8 operator would fly a fleet of UAVs and that was very 9 challenging at first because of the many sorts of 10mission-related things. So it turned out they needed 11 many operators.

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

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

24 If we move a little bit further into 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 59 human factors process we looked at the HSI design and 1 looked for features that would help to prevent these 2sorts of errors from occurring. These are some of the 3 observations that we had:

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

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

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

22 Also, it is an action that is intended to 23 be controlled by procedures, which gives us some more 24 confidence, and because it occurs in the control room 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 60 within sight of the control room supervisor's 1 workstation, it can be overseen by the control room 2 supervisor.

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

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

14And then to go one step further, we 15 observed the Integrated System Validation testing, 16 which is where we might see some of these sorts of 17errors. This is where the operators go into the 18 control room and perform various scenarios under lots 19 of different conditions.

20 The staff observed good data collection 21 practices that would likely identify any of these 22errors, if they had occurred. And the staff is 23 awaiting the results to see if we see any of these, 24 and if they had safety consequences, and if there are 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 any changes to the NuScale design at this point to 1 prevent -- to further prevent or mitigate these types 2 of errors.

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

5DR. GREEN: We observed portions during 6 the seven weeks.

7MEMBER BLEY: The crews being tested 8actually have procedures? Did they use those GTGs to 9 guide them through? What did they --

10 DR. GREEN: They did have procedures.

11 MEMBER BLEY: They did have procedures.

12DR. GREEN: They have a computer-based 13 procedure system.

14 MEMBER BLEY: Okay.

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

18 DR. GREEN: I did not. That's typically 19--20MEMBER BLEY: Did anybody on the staff do 21 that?22DR. GREEN: Maurin Scheetz is both on the 23Chapter 13 and 18. So she would be the person to 24answer that question about the GTGs. She should be 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 62 the line.1 MEMBER BLEY: Okay.

2MS. SCHEETZ: Yes, this is Maurin. I'm on 3 the line. And I did use -- I looked at how the GTGs 4 were used to develop procedures. They are basically 5 there as a basis for COL applicant procedures.

6MEMBER BLEY: Could you say that last one 7 again?8MS. SCHEETZ: We'll have another 9 opportunity to review --

10MEMBER CORRADINI: You're breaking up.

11 Could you say that again, please?

12MS. SCHEETZ: Okay. There's like 13 considerable feedback when I talk so it's very 14 confusing.

15DR. GREEN: Maurin, they're asking for you 16to repeat your comments.

We couldn't hear you the 17 last time through.

18MS. SCHEETZ: So I did look at how the 19 GTGs would be used for a COL procedure in the future.

20The GTGs are a basis, a starting point. We will have 21 another opportunity when there is a COL to look at the 22 actual emergency operating procedures, severe 23 mitigation guidelines, et cetera.

24 So this isn't the end of it. 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 63over. As I'm trying to say, this is a basis and we 1 believe that these are an adequate basis, a starting 2 point for future procedures.

3MEMBER BLEY: Since you have the open item 4in Chapter 13, I assume the final SER on 13 will go 5 into the GTGs and what you found there and your 6 conclusions about them. Is that true?

7MS. SCHEETZ: The open item is related to 8 NuScale's validation of the GTGs. So we are waiting 9 for information back from NuScale on the results of 10 that validation before we make our final decision on 11 the GTGs, which the purpose of the GTGs is a basis for 12 plant-specific technical guidelines.

13MEMBER BLEY: I may have understood that.

14 Go ahead.15MEMBER CORRADINI: I heard that as a yes.

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

17 Yes.18MEMBER CORRADINI: And it will be 19discussed -- let me just make sure. What Member Bley 20 was asking, it will be discussed as you resolve it in 21 Chapter 13, assuming --

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

24 MEMBER CORRADINI: Thank you.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 64DR. GREEN: Okay, so now we're onto our 1 open items.

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

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

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

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 65And this -- the intent of this is to go 1 back to make sure that if things change so that if the 2 crane becomes elevated to a point where it needs 3 additional analyses or testing, this would be a 4 mechanism to help make sure that that focuses us into 5 the human factors process at that point.

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

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

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

19 There is an open item to confirm that the 20 information in the Chapter 18 SER about the treatment 21 of important human actions is consistent with the 22results of the Chapter 7, 15, and 19 reviews. This 23 will help us to ensure that any changes in these 24 analyses are adequately addressed within the human 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 factors process.

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

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

8 Is there a question?

9MEMBER RAY: Well, I was waiting to ask 10 one when you stopped. But I was going to ask, Mike, 11 do you know when or if we see the ITAAC, for example, 12 on the HFE, at a time when we comment or is that, the 13 ITAAC, set after we're done?

14MEMBER CORRADINI: I thought we were going 15 to come to those later, yes?

16MEMBER RAY: You know what the ITAAC says 17 on this subject is somewhat important to --

18MEMBER BLEY: Yes, I don't know the answer 19 to that. Do we have a session set up for looking at 20 all the ITAAC?

21 MEMBER SKILLMAN: Well we do for Chapter 22 14.23MEMBER CORRADINI: That's what I thought.

24 MEMBER SKILLMAN: But I'm not sure it 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 67as mature as Harold wants it. But it's a great 1 question.2MEMBER RAY: Well, it seems really vague, 3 at this point, what the ITAAC rule contains --

4 MEMBER SKILLMAN: For HFE.

5 MEMBER RAY: Yes.

6DR. GREEN: It is still somewhat under --

7there is one related to the remote shutdown 8workstation. There was a public call on this 9recently. So there are some changes coming in that 10 way.11And we do have kind of an outstanding 12 issue, potentially, with the design implementation 13 part of human factors that is -- it's undetermined 14 whether or not ITAAC is necessary.

So we're still 15 working on that one as well.

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

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

22 DR. GREEN: Yes.

23MEMBER MARCH-LEUBA: -- how are you going 24to interface with it? You were now closing Chapter 13 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 68and 18. If something happens in Chapter 15 that 1 affects it, you will then redraw Chapters 13 and 14?

2DR. GREEN: Well if something were to 3 happen in Chapter 15, say that there were now suddenly 4 a deterministic human action that was really very 5 important, this could potentially be a really 6challenging situation for us. So we may have to go 7 back to the applicant and see you know do you have 8 testing that supports the operators can do that.

9 Perhaps they may have already tested it.

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

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

21 So there is a reasonable chance that these 22 sort of actions that -- and I don't necessarily think 23 there are going to be new actions in the control room, 24 but if there were, there's a reasonable chance they 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 69 would have been included in the testing we've done and 1 we could go back and analyze those.

2MEMBER MARCH-LEUBA: So I am going to 3 branch a little bit because you just said something.

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

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

11 But I'll let Maurin answer.

12MS. SCHEETZ: Okay, this is Maurin. I 13 just want to make sure we're distinguishing between 14 computer-based procedures that NuScale uses versus the 15GTGs. I think the question before dealt with the 16 Generic Technical Guidelines that might have been 17 about computer-based procedures.

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

24In Chapter 18 space, we looked at 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 70 computer-based procedures to make sure that from a 1 human factors standpoint that they are adequate.

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

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

9DR. GREEN: We believe that they are.

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

18 So there is a robust set of procedures.

19They do work through the processes that are there. I 20 don't know that we would expect them to look exactly 21the same. Certainly, things are going to change in 22 them between now and then but the normal validation 23 procedures would be used to make those corrections.

24MEMBER MARCH-LEUBA: And you would expect 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 NuScale, when they finally have final procedures, to 1 make a 50.59-type evaluation that says yes, what we 2 tested is similar to what we have.

3DR. GREEN: Yes, I'm not sure what the 4 practice is for that, for the validation of those 5 changes at that point but I believe there is a process 6 in place for that.

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

9 DR. GREEN: Okay.

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

13 DR. GREEN: Sure.

14MEMBER MARCH-LEUBA: And it is related to 15this relationship in Chapters 15 and 19 and is, in 16 particular, ATWS, anticipated transients without 17scram. They sprinkle, the references sprinkle all 18 over the SERs for 13 and 18 that says ATWS is okay and 19 does not require any operator action.

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

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

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

10 Let me put it on the record, yes to put it 11 on the record I want them to explain in detail what 12happens. But I am worried that an isolation ATWS, 13 that you have containment isolation, you have an ATWS 14 and it's the beginning of cycle, when the moderator 15 temperature coefficient is zero, which you are allowed 16to have. Therefore, you don't have any water 17reactivity feedback. All your feedback is only 18 Doppler.19 I ran some interim calculations and the 20 few numbers I have been able to find from FSAR Topical 21 Reports and there is not enough reactivity in the core 22to shut it down. Indeed, if we start saying numbers, 23 we will have to go into closed session so I won't say 24 it in this session but the reactor will not shutdown 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 73where there is significantly high power. And I don't 1 mean ten percent. Significantly higher power and we 2start boiling off the whole inventory. And it will 3 die out and it will melt.

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

10 So I wanted to put that on the record and 11 whenever we get in June to see Chapter 15, we'll have 12 a lot of fun with this. There will be a calculation 13 for us.14DR. GREEN: Understood. We did coordinate 15 with the project manager for Chapter 15. So we've 16 passed on the transcripts from the last meeting and 17 we'll do the same so that your concern will be noted 18 and I'll let them defend the position that they have.

19MEMBER MARCH-LEUBA: I'm giving you -- you 20 notice that when we finalize the review of Chapter 15 21 you may have to change some of the language.

22DR. GREEN: We understand that that's a 23 possibility and that's built into our process here.

24 So that's why the design implementation element 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 74 it's the catchall in case something comes out there.

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

4MEMBER MARCH-LEUBA: It probably wouldn't 5affect the human factors.

I would only affect the 6 language of the SER.

7DR. GREEN: Well that would be -- I think 8 NuScale be happy for us to rewrite the SE than to have 9 to --10MEMBER MARCH-LEUBA: Well maybe not. I 11mean if everything, if all the planets align in the 12 wrong way and my scenario turns out to be a core 13damage, it will be the dominant factor in the whole 14 plant by three or four orders of magnitude.

15 DR. GREEN: Okay.

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

17DR. GREEN: So it's on our radar and we 18 will continue to coordinate with Chapter 15 in these 19 other areas to make sure we don't miss anything.

20 And then finally, there is one other open 21 item that is administrative in nature, which is to 22 verify that the human factors reports, such as the V&V 23 result summary report are incorporated by reference to 24 make sure that they end up in the final 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 75 Next slide, please.

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

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

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

22That concludes our prepared remarks. I'm 23 happy to take any more questions you may have.

24 MEMBER CORRADINI: Members?

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 76MEMBER SKILLMAN: Let me ask one and I 1 want to build on Dr. Rempe's question on shared 2 systems.3 Is there a commissioning sequence that one 4 could review that would identify which systems must be 5operable when -- as the build out continues? For 6 instance, I imagining that the base plan would be the 7 concrete, the liner, testing the liner, installation 8 of the crane because no heavy lift is going to come 9 without that crane, closure of the containment 10 building, filling the ultimate heat sink, bringing in 11the first module. The first module is going to 12 require CVCS, CFDS, boric acid addition, demineralized 13water, vacuum system, a couple more. So there's a 14 logical sequence and that's where Joy's question comes 15 out in how many multiples do you need.

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

22 So there must be -- and I'm confident that 23 the NuScale team is a smart team. They probably put 24 something like this together that would allow Joy's 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 question to be answered on shared systems. Is there 1 such a thing?

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

3 I am unaware of it.

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

6VICE CHAIRMAN SUNSERI: If I could jump 7 in, in the DCD there is a Chapter 21 that talks about 8 multi-module design consideration and it describes the 9 things that you're talking about.

10MEMBER REMPE: Well it does, but I 11 actually looked at that because it was brought up 12 earlier by the staff, but it doesn't have a lot of 13detail. And then what I don't know and maybe Vesna 14 and Dennis can help with the PRA is when they did 15 their analysis did they ever assume any cross ties.

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

19 So clearly, they've been thinking about it 20 but then do they ever say well, okay, as a backup, 21 that one that is shared by the first six or the first 22 four isn't going to work until I put a cross tie 23between the other one that's there. And the backup 24 diesel generators are one that come to mind because 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 it's one of the important actions that is in Chapter 113 identified at the operator startup. And I think 2there's two backup diesel generators. Are both of 3 those installed from day one or is it like the turbine 4 generator building where they say no, you only need it 5 for the first six?

6MEMBER CORRADINI: I think we're going to 7 have to wait.

8MEMBER REMPE: Yes, well I think so but I 9 think it's something that we ought to maybe, again, we 10 can discuss when we do letter writing that we ought to 11 mention, hey, we're interested in this unless the PRA 12 folks can tell me no, they never did any cross ties or 13 something like that.

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

17MEMBER DIMITRIJEVIC: Well, we can discuss 18usually the 19. See all this, where the shared 19 systems are considered when there is an initiator 20 which will challenge all units like loss of offsite 21 power, you know the side, all the units will require 22the use of generators. When it comes to the active 23 feature, you need specifics like the ability the LOCA 24 will happen in multiple units is very small so, 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 therefore, those shared systems are not as important 1 as the ones which were credited for the carbon 2 emission.3 So and it's not also -- there is not also 4-- it is not clear, actually, and we will discuss this 5 in Chapter 19 how those actions are considered with 6the multiple units. I am very curious about that 7 myself.8 Also, it is not clear from the operator 9 actions when he has to tend to multiple units are the 10 stress or are the difference in the evolution of the 11 human actions.

12MEMBER REMPE: Again, we can discuss it 13 more but I think it might be -- again, I don't think 14 it is a high level recommendation or conclusion. It 15 is just a point that is something that we are curious 16 about and we ought to keep in our minds.

17MEMBER CORRADINI: Well I think -- I 18 definitely think the staff and NuScale are aware of 19 the fact we're interested in this and we'll keep on 20 asking until we get an answer.

21 Okay, other questions by the members?

22 We have time for a closed session. What 23 I would prefer to do is to get any more members' 24 comments, go to public comments, and then essentially 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 80 go to break as we get organized for any questions in 1 closed session.

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

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

10MEMBER CORRADINI: You're going to have to 11 speak louder, sir. I can't hear.

12 MR. LEWIS: My name is Marvin Lewis.

13 MEMBER CORRADINI: Mr. Lewis, go ahead.

14MR. LEWIS: I have a comment about the 15crane stuff. While you are stacking, may I 16respectfully suggest you also look at the floor 17 underneath where it drops?

18 In ANO, Arkansas Nuclear One, the drop 19 wound up on a floor that gave way to a ceiling in the 20 switchgear room, which led to no water addition to the 21fuel pools for 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />. A few more hours and we 22 would have had a nice shamrock type fire in the fuel 23 pools.24 So when you stack, don't just stack 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 81whatever you're stacking. You look at the floor 1underneath. Will it give way? Will there be a 2switchgear room underneath? Will the switchgear, when 3 it blows, be able to somehow get water into the fuel 4 pools?5 Thank you.

6 MEMBER CORRADINI: Thank you.

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

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

14CHAIRMAN RICCARDELLA: Yes, I mean it's 15 10:07.16MEMBER CORRADINI: Well if I might just 17ask, I assumed we needed a closed session. Do the 18 members have other questions? Otherwise, we're just 19 going to be concluding the session completely.

20MEMBER BLEY: I'm sorry, was there more of 21 an answer to the question earlier about GTGs that you 22 want to cover in closed session?

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

24 Maurin, did you have anything else that you wanted 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 82 discuss about GTGs in the closed session?

1MS. SCHEETZ: I don't have anything for 2the closed session. I just want to clarify we're 3 talking about two different things here and I didn't 4 do a good job of saying this earlier.

5 For the Generic Technical Guidelines, the 6 scope of our review was about the content of the 7 Generic Technical Guidelines being adequate. That's 8-- the design of computer-based procedures so that 9 they were adequate for use by operators in the control 10room. And I just wanted to differentiate those two 11 things.12 We're waiting on the results of the 13 Integrated System Validation to confirm if the Generic 14Technical Guidelines were able to be implemented in 15 that scope in Chapter 13.

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

18MEMBER CORRADINI: Okay, so I'm hearing 19 that -- yes, Charlie?

20MEMBER BROWN: I just wanted -- throughout 21 the earlier conversation relative to the crane, and it 22 seems the crane is a key ingredient or a key element 23 in terms of the all the module transfers, multiple 24 modules, taking them out and moving them from one 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 83place to the other. And I don't remember who said it, 1 since I'm not as familiar with this type of a system 2in my past experience, it seemed like all of the 3 requirements were being deferred to the vendor of the 4crane is going to satisfy the requirements. What 5 requirements they are or why is the crane 6 manufacturer, he's not a plant guy, how is going to be 7 able to understand what he needs to provide in safety 8 in the backups, the multiple whatever it is that makes 9 that crane satisfactory.

10 MEMBER CORRADINI: Is that a question to 11 NuScale?12 MEMBER BROWN: Yes, it sounds to me like 13they're -- I just don't understand. It sounds like 14 NuScale, to me, should be providing what safety 15 requirements do we need to be imposing on the crane 16 manufacturer, not the crane manufacturer is going to 17 tell us well that's okay.

18 MEMBER SKILLMAN: My --

19MEMBER BROWN: Did I get that -- do I 20 understand that point?

21MEMBER SKILLMAN: Charlie, I think the 22question is appropriate. I'm not going to try to 23 answer the question because it really is a NuScale 24 answer but it appears to me in the safety evaluation 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 that entire topic has been, quote, offloaded to the 1 notion it's a single failure-proof crane.

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

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

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

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

23 So I think it's appropriate that you raise 24it. The lens through which I am looking at 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 85 the safety evaluation in Chapter 19 says it's a single 1failure-proof crane. If you look in Chapter 15, cask 2 drop and module drop are excluded because of the 3 single failure-proof crane. And I'm just not -- I'm 4 not convinced that that is sufficient for the issues 5 that we need to deal with.

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

8 MEMBER SKILLMAN: Yes.

9 MEMBER BROWN: He provided that as well?

10MEMBER SKILLMAN: And to the credit of 11NuScale, the crane is a massive crane. It is 12encapsulated so it can't fall. It rides on rails 13overhead. It's qualified for 130 percent of its 14maximum load. Its maximum load is the 734-ton module.

15 I understand all of that.

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

22MEMBER BLEY: And we are coming to this in 23 Chapters 9, and 15, and 19.

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

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 MEMBER BLEY: Yes.

1MEMBER CORRADINI: Dennis, did you want to 2--3MEMBER BROWN: Thank you, I just wanted to 4 make sure that I understood.

5MEMBER BLEY: I did. Harold, you asked 6about human factors engineering and ITAAC. Chapter 14 7 doesn't do human factors engineering but Tier 1 has 8 one ITAAC and that ITAAC is to ensure that the as-9 built configuration of the main control room HSI 10 matches the design HSI and that's the only one.

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

14 I think one of the things that is perhaps 15 more common than not is the fact that although we are 16not in a position where we can perhaps expect more 17 than we're being given, how we satisfy that, the 18 assurance needed going forward without ITAAC to cover 19 the things that we simply can't expect to understand 20 fully now is an open issue in a lot of places for me 21 here.22 We keep saying well, we probably don't 23need ITAAC here; we don't need it there. And yet 24 there's things that are left open that are 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 87validated down the road. And I just -- since we don't 1 know the criteria against which it will be validated 2 in the absence of ITAAC, it's a problematic issue in 3 general.4DR. GREEN: And this is related to one of 5our open items. For the ITAAC that was just read, 6 some of the wording of that we believe needs to be 7 changed. There are RAIs that have gone out on that.

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

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

17MEMBER RAY: It's a generic issue that 18 really goes to the question of what are we doing in a 19 design certification. And to the extent that we are 20 postponing, or necessarily -- and again, I don't mean 21 it to be a negative comment, other than to say well, 22 we're certifying a design and yet there's stuff to go 23 that we don't know how it's going to be answered.

24 And if you don't have -- if you have ITAAC 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 that covers it, fine; that puts it to bed because it's 1 part of the certification. But if you just say well 2we're going to get to it later and we'll look at it 3 then, I'm troubled by that.

4DR. GREEN: There's something I don't know 5 that I've made this clear throughout the presentation 6but when we look at previous design certifications, 7they've all relied on DAC previously. So at that 8point, they submitted implementation plans. They said 9 this is how we will one day fill all these blanks.

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

12So in one very big sense, we have a lot 13 more than we've ever seen before at this point.

14 MEMBER RAY: Okay.

15DR. GREEN: Now, there are still some gaps 16 to be addressed and our intent is that these open 17 items should give us some regulatory assurance to make 18 sure we're covering the right sorts of things.

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

23 DR. GREEN: It is.

24MEMBER RAY: Okay and I'm trying to get 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 89 mind around that.

1DR. GREEN: Yes, no I understand. It took 2 us a while to wrap our head around it, too, because 3 when we reviewed the previous ones, we had the -- you 4 know we were looking at, essentially, IOUs. This is 5how we will one day conduct this analysis. And that's 6 wonderful and you need a lot of details to make sure 7 that works.

8But now we have both the methodology or 9 how they were conducting it and we were able to go an 10audit as we went. So in that very real sense, we have 11 an awful lot more confidence that the outcomes of 12 these processes are what we hoped they would be.

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

16 MEMBER RAY: Well we probably should --

17MEMBER CORRADINI: I think we should move 18 on.19MEMBER RAY: -- yes, move on. We just 20 need to bear in mind that understanding what was just 21 exchanged better on a generic basis is probably 22 something that would be useful.

23 DR. GREEN: Understood.

24MEMBER CORRADINI: So if I may then, we're 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 90not going to have a closed session. I'll turn it back 1to the chairman. We'll go into break and go from 2 there.3 Chairman, it's back to you with no closed 4 session.5CHAIRMAN RICCARDELLA: Yes, with no closed 6 session. So I guess we will adjourn this portion of 7 the meeting and take a break until 10:45. And after 8 that, we'll start letter writing.

9 MEMBER CORRADINI: We have a draft.

10 CHAIRMAN RICCARDELLA: We have a draft.

11MEMBER REMPE: So we don't need a 12 transcriber for that, right? We're done.

13MEMBER CORRADINI: We have it as one of 14 the things in the schedule before lunch.

15 CHAIRMAN RICCARDELLA: I understand.

16 MEMBER CORRADINI: Okay.

17CHAIRMAN RICCARDELLA: But the question is 18 we don't need any more transcription.

19MEMBER CORRADINI: No, not that I'm aware 20 of. 21 (Whereupon, the above-entitled matter went 22 off the record at 10:19 a.m.)

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 Safety Evaluation with Open Items: Ch 13, Conduct of OperationsNuScale Design Certification Application ReviewACRS Full Committee MeetingMarch 7, 2019 March 7, 2019Chapter 13 Conduct of Operations 2*Technical Staff PresentersMaurin Scheetz, NRR -DCA Sections 13.1, 13.2, 13.5Amanda Marshall, NSIR

-DCA Section 13.3Prosanta Chowdhury, NRO

-DCA Section 13.4

• Project Managers Greg Cranston

-Lead Project Manager Prosanta Chowdhury

-Chapter 13 Project Manager*Staff presented SER with Open Items to ACRS subcommittee on January 23, 2019Note:Review is based on revision 1 of the DCANRC Staff Review Team March 7, 2019Chapter 13 Conduct of Operations 3Technical TopicsSection 13.1

-Organizational StructureScope of Review

• The purpose of this section is to provide assurance that the applicant has established acceptable COL Information Items pertaining to the corporate

-level management, technical support and onsite operating organizations necessary for the safe design, construction, testing and operation of the nuclear plant, including training and qualification requirements. That is, the COL applicant will have the necessary managerial and technical resources to support the plant staff in construction, operation, maintenance, and in the event of an emergency.Conclusion

• The staff has reviewed DCA Part 2, Tier 2, Section 13.1, "Organization Structure," and determined that applicant's approach for COL Items 13.1

-1 through 13.1-3 describing the corporate

-level management and technical support organization, and the onsite operating organization, is acceptable to meet all applicable requirements. There are no Open Items

.

March 7, 2019Chapter 13 Conduct of Operations 4Technical TopicsSection 13.2

-TrainingScope of Review

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

.Conclusion

• The staff has reviewed DCA Part 2, Tier 2, Section 13.2, "Training," and determined that applicant's approach for COL Items 13.2-1 and COL 13.2

-2 pertaining to a description and schedule of training programs for licensed and non-licensed staff is acceptable.There are no Open Items

.

March 7, 2019Chapter 13 Conduct of Operations 5Technical TopicsSection 13.3

-Emergency PlanningScope of Review

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

• Technical Support Center (TSC); Emergency Response Data System; TSC Engineering Workstations; Decontamination Facilities; Process Sampling System (Post

-Accident Sampling function); Operations Support Center (COL Item 13.3

-1); Emergency Operations Facility (COL Item 13.3-2); Emergency Plan (COL Item 13.3

-3); EP ITAAC (COL Item 14.3

-1)Open Item 13.3 Process Sampling System (PSS)

• The capability to obtain a post

-accident sample is an interface item between SRP Section 9.3.2, "Process Sampling Systems," and SRP Section 13.3. If the PSS is determined to be acceptable as a means for obtaining a post

-accident sample in accordance with 10 CFR 50.34(f)(2)(vii) and (viii), then this open item will be resolved. Conclusion

• With the exception of Open Item 13.3

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

March 7, 2019Chapter 13 Conduct of Operations 6Technical TopicsSection 13.4

-Operational ProgramsScope of Review

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

.*The applicant provided COL Item 13.4

-1 stating that a COL applicant that references the NuScale Power Plant design certification will provide site

-specific information, including implementation schedule, for operational programs.Conclusion

• The staff has reviewed DCA Part 2 Tier 2, Section 13.4, "Operational Programs," and determined that COL Item 13.4

-1 is acceptable because the applicant appropriately directs the COL applicant to develop operational programs, consistent with the list in SRP Section 13.4, draft Rev. 4.There are no Open Items

.

March 7, 2019Chapter 13 Conduct of Operations 7Technical TopicsSection 13.5

-Plant ProceduresScope of Review

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

-STGs).Open Items

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

-1.Conclusion

• The staff has reviewed DCA Part 2, Tier 2, Section 13.5, "Plant Procedures," and determined that the COL Items 13.5-1 through 13.5

-5, 13.5-7, and 13.5

-8 for plant procedures are appropriate and acceptable. The staff will make a conclusion on the GTGs at a later time.

Safety Evaluation with Open Items: Ch 18, Human Factors EngineeringNuScale Design Certification Application ReviewACRS Full Committee MeetingMarch 7, 2019 March 7, 2019Chapter 18 Human Factors Engineering 2*Technical StaffDr. Amy D'Agostino, RESDr. Brian Green, NRRLauren Nist, NRRMaurin Scheetz, NRR

• Project Managers Greg Cranston

-Lead Project Manager Prosanta Chowdhury

-Chapter 18 Project Manager*Staff presented SER with Open Items to ACRS subcommittee on January 23, 2019Note:Review is based on revision 1 of the DCANRC Staff Review Team March 7, 2019Chapter 18 Human Factors Engineering 3*Purpose*Verify that the Human Factors Engineering (HFE) design of the NuScale Standard Plant control room supports operators in the safe operation of the plant*Verify there is sufficient technical justification for a new, design

-specific staffing regulation

• Scope*DCA Part 2, Tier 2, Ch 18 as well as parts of Ch 7, 15, and 19*HFE technical reports

• DCA Part 2, Tier 1, Section 3.15

• Audits of HFE analyses, SPV testing, and ISV testing Purpose and Scope March 7, 2019Chapter 18 Human Factors Engineering 4*Potential human performance issues specific to SMRs are identified in NUREG/CR

-7126 and NUREG/CR

-7202*The staff considered the effects of the following on human performance and safe plant operation:

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

• Relatively higher amount of automation

• Novel Human

-System Interface (HSI) design featuresAreas of Interest March 7, 2019Chapter 18 Human Factors Engineering 5*The Phase 2 SER contains 23 open items for the following topics:

• Review of the applicant's V&V results (19 open items)

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

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

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

• Ensure that HFE reports are incorporated by reference into Tier 2 (1 open item) Open Items March 7, 2019Chapter 18 Human Factors Engineering 6*The results of the Staffing Plan Validation (SPV) testing support the applicant's proposed staffing plan. The staff will confirm the Integrated System Validation (ISV) results also support the staffing plan or that any changes have been made if needed.

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

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