ML19038A016
| ML19038A016 | |
| Person / Time | |
|---|---|
| Issue date: | 01/23/2019 |
| From: | Michael Snodderly Advisory Committee on Reactor Safeguards |
| To: | |
| Snodderly M, ACRS | |
| References | |
| NRC-0091 | |
| Download: ML19038A016 (260) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards NuScale Subcommittee: Open Session Docket Number: (n/a)
Location: Rockville, Maryland Date: Wednesday, January 23, 2019 Work Order No.: NRC-0091 Pages 1-193 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 (ACRS) 6 + + + + +
7 NUSCALE SUBCOMMITTEE 8 + + + + +
9 OPEN SESSION 10 + + + + +
11 WEDNESDAY 12 JANUARY 23, 2019 13 + + + + +
14 ROCKVILLE, MARYLAND 15 + + + + +
16 The Subcommittee met at the Nuclear 17 Regulatory Commission, Two White Flint North, Room 18 3D50, 11545 Rockville Pike, at 10:46 a.m., Dennis Bley 19 and Harold Ray, Co-Chairs, presiding.
20 COMMITTEE MEMBERS:
21 DENNIS BLEY, Co-Chair 22 HAROLD RAY, Co-Chair*
23 RONALD G. BALLINGER, Member 24 CHARLES H. BROWN, JR., Member 25 MARGARET SZE-TAI Y. CHU, Member NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 MICHAEL CORRADINI, Member 2 VESNA B. DIMITRIJEVIC, Member*
3 JOSE MARCH-LEUBA, Member 4 GORDON R. SKILLMAN, Member 5
6 DESIGNATED FEDERAL OFFICIAL:
9 ALSO PRESENT:
10 DOUG BOWMAN, NuScale 11 PROSANTA CHOWDHURY, NRO 12 AMY D'AGOSTINO, RES 13 RYAN FLAMAND, NuScale 14 CARRIE FOSAAEN, NuScale 15 BRIAN GREEN, NRR 16 AMANDA MARSHALL, NSIR 17 LAUREN NIST, NRR 18 STEVE POPE, NuScale 19 MAURIN SCHEETZ, NRR 20 TIM TOVAR, NuScale 21 22 23 24 *Present via telephone NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 1 CONTENTS 2 Call to Order and Opening Remarks . . . . . . . . 4 3 NuScale Presentation . . . . . . . . . . . . . . 9 4 Staff Presentation on Chapter 13 . . . . . . . . 52 5 Staff presentation on Chapter 18 . . . . . . . . 86 6 Opportunity for Public Comment . . . . . . . . 192 7 (None) 8 Adjourn . . . . . . . . . . . . . . . . . . . . 193 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 P R O C E E D I N G S 2 10:46 a.m.
3 CO-CHAIR BLEY: The meeting will now come 4 to order.
5 This is a meeting of the Advisory 6 Committee on Reactor Safeguards, the NuScale 7 Subcommittee. I'm Dennis Bley, Chairman for today's 8 Subcommittee meeting.
9 Members in attendance are Ron Ballinger, 10 Dick Skillman, Charlie Brown, Jose March-Leuba, 11 Margaret Chu, Mike Corradini. On the phone line we 12 have Harold Ray, and we are expecting Vesna 13 Dimitrijevic.
14 Mike Snodderly is the Designated Federal 15 Official for this meeting.
16 The Subcommittee will review the staff 17 Safety Evaluation Report with Open Items on Chapter 18 13, Conduct of Operations, and Chapter 18, Human 19 Factors Engineering, to the NuScale design 20 certification application. Today we have members of 21 the NRC staff and NuScale to brief the Subcommittee.
22 The ACRS was established by a statute and 23 is governed by the Federal Advisory Committee Act, 24 FACA. That means that the Committee can only speak 25 through its published letter reports. We hold NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 1 meetings to gather information to support our 2 deliberations.
3 Interested parties who wish to provide 4 comments can contact our office requesting time after 5 the meeting announcement is published in The Federal 6 Register. We also set aside 10 minutes at the end of 7 the day for members of the public who wish to make a 8 comment. Written comments are also welcome.
9 The ACRS section of the U.S. NRC public 10 website provides our Charter, Bylaws, letter reports, 11 and transcripts of all full and subcommittee meetings, 12 including the slides presented there.
13 This meeting was not noticed in The 14 Federal Register because of the closure of the federal 15 government. But we are here today. The meeting has 16 been noticed on the NRC public website, and some 17 members of the public have been notified of this 18 meeting directly. The meeting was announced as an 19 open/closed meeting. And let me take a break right 20 here and mention how we're going to do that. It's a 21 little different than shown in the agenda.
22 At some time during the first session this 23 morning, we will reach a point where NuScale will go 24 into a proprietary briefing. At that point, we'll 25 close the meeting and turn off the public phone line.
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6 1 We expect to be back following lunch at 12:45. It 2 might be as late as 1:00. But, at that time, the 3 public phone line will be open again, and it will be 4 an open meeting. And there will be another closed 5 session at the end of the day today. But, before we 6 go into that closed session, we'll ask if there are 7 comments from members of the public.
8 No written statement or request for making 9 an oral statement to the Subcommittee has been 10 received from the public concerning this meeting.
11 A transcript of the meeting is being kept 12 and will be made available. Therefore, we request 13 that participants in this meeting use the microphones 14 located throughout the meeting room when addressing 15 the Subcommittee. Participants should first identify 16 themselves and speak with sufficient clarity and 17 volume so they can be heard.
18 And for you guys who have never been here 19 before, today in this room the mics never shut off.
20 So, you'll always be on.
21 We have a bridge line established for the 22 public to listen to the meeting. To minimize 23 disturbance, the public line is kept in a listen-in 24 mode until we invite comments.
25 To avoid disturbance, I request that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 1 attendees put their electronic devices in the off or 2 noise-free mode.
3 We'll now proceed with the meeting. But, 4 before I turn it over to NuScale, there are a couple 5 of things I want to mention.
6 I received some notes from members of the 7 Committee, trying to read through the DCD and the SERs 8 on this work. From there, some things aren't 9 completely clear.
10 I'll just mention to everybody, only three 11 or four of us who are now on the Committee were on the 12 Committee in July of 2015, when we visited the plant.
13 And I think only two of those three or four actually 14 went there.
15 We saw some things that you can't find in 16 the DCD or the SER. If you read a little further, 17 like the report we were provided on staffing, you'll 18 find another reference to another report called 19 "Conduct of Operations," which, unlike Chapter 13, 20 really tells us how you operate the plant inside the 21 control room.
22 The one thing that was quite confusing to 23 many of us was, with six operators, kind of who does 24 what? And NuScale and the staff will touch on this 25 today, but they might not go quite as far. So, I want NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 to get this out for all of you at this point.
2 There are six SROs. Three of them 3 function much like in other plants. The shift 4 manager, the control room supervisor, and the STA, 5 pretty much the same as we're used to seeing. There 6 are three ROs, and those reactor operators, one of 7 them -- they designate him RO1 in that report I 8 mentioned. It's RP-0215-10815, "Concept of 9 Operations". It tells you how it works the way we saw 10 it.
11 And how it works is that that first 12 operator, RO1, runs all 12 plants. You don't divvy 13 the reactors up among all six operators. One person 14 runs all 12.
15 When you read the SER, you'll see a lot of 16 "We meet the criteria laid out in this NUREG" and in 17 this B&O report, but you don't see anything of the 18 sort that, when I was there, gave me some confidence 19 in this approach.
20 And the two things that really anchor this 21 are kind of the cleverness of the main control panel 22 with different colors, different flashing signals. I 23 don't remember about the sounds. But it made it very 24 easy for the one operator who's running all 12 to 25 identify problems in any of the 12 units and sort of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 1 have an initial ranking of what could be most 2 important. That lets them do what they want to do and 3 focus properly.
4 The second thing is, the philosophy tends 5 to be, if things get busy, because you can with this 6 plant, you throw a switch and you go into the passage 7 shutdown mode, passive cooling. And then, the 8 operator can pretty much ignore that unit while they 9 work on others. So, if they get an accident on one 10 unit, the one guy takes it. If it gets too confusing 11 or they get something on another unit, he hands it 12 off. And when it reaches the point that there's more 13 than people can do, they put them into the safe mode.
14 And you don't find that anywhere in the 15 stuff we've read. I'm curious as to why not. I'm 16 going to ask the staff about that when we get to 17 Chapter 18, because it seems to be the key to making 18 this thing work properly.
19 All of that said, it gives you some 20 perspective for when we get to Chapter 18. And at 21 this point, we're back to Chapter 13.
22 And I'm going to turn it over to Doug 23 Bowman, who will do our first presentation.
24 Doug?
25 MR. BOWMAN: Good morning. My name is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 1 Doug Bowman. I'm the Supervisor of Plant Operations 2 at NuScale Power.
3 Dr. Bley, I appreciate all your questions, 4 and I think we'll answer some of them in this 5 presentation. But, of course, if we don't, we know 6 we'll get questions from you.
7 And we will go into the background and 8 history of how, a little bit about how we arrived at 9 the conduct of operations that you guys observed in 10 2015.
11 A little bit about me. I have been at 12 NuScale for nearly five years now, working either as 13 an individual contributor performing human factors 14 engineering and operations work or now in my role as 15 the Supervisor, Plant Operations. Prior to that, I 16 worked on the commercial side of the nuclear industry 17 for 24 years. I was Senior Reactor Operator licensed 18 at both D.C. Cook and Byron, held many different 19 positions at both plants from engineering through 20 operations, work control, training, a wide variety of 21 positions, and took the opportunity in 2014 to come to 22 NuScale and work.
23 Also with me today is Ryan Flamand. Ryan, 24 you want to talk a little bit about yourself?
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11 1 Flamand. I work with Doug in plant operations, have 2 done a lot of the work on HNB as an individual 3 contributor.
4 Specific to Chapter 13, I was involved in 5 the development of conduct of operations, which will 6 be part of what the question I think we might be able 7 to answer today or help answer; and also, a generic 8 technical guidance, which is the basis for the 9 emergency operating procedures.
10 Previous to that, similarly to Doug, I 11 have 15 years commercial operating experience as a 12 Senior Reactor Operator licensed at Palisades. I also 13 was a reactor operator and also an equipment operator 14 for a period of time.
15 Previous to that, I was six years in the 16 Navy, a reactor operator on the USS California.
17 So, that's it.
18 MR. TOVAR: Good morning. My name is Tim 19 Tovar. I'm the Manager of Plant Operations at NuScale 20 Power.
21 I've been with the company for about six 22 and a half years now. My background, I started with 23 a mechanical engineering degree from RPI. I want into 24 the Navy to help pay for that, actually. Seven years 25 in the Navy as a submarine officer, was a radcon NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 1 officer on a tender during my shore tour for a couple 2 of years.
3 Then, went into civilian nuclear power, 4 licensed at Robinson Nuclear Power or Robinson Nuclear 5 Plant as a Senior Reactor Operator. Held the 6 positions of Operations Manager and Radiation 7 Protection Manager there. Went to First Energy and 8 was the Fleet Outage Manager for three years there, 9 and then, came to NuScale.
10 So, I've got a C7, 14, and 3, and six and 11 half years' worth of nuclear experience.
12 MS. FOSAAEN: Hi. Good morning. Carrie 13 Fosaaen. I am a Licensing Supervisor with NuScale.
14 I've been there for three and a half years now.
15 Prior to that, I was in commercial nuclear 16 as a licensing individual at Monticello Nuclear 17 Generating Plant. And previous to that, I did a year 18 in decommissioning.
19 My bachelor's is in nuclear engineering 20 and a master's in health physics.
21 And I've been involved with this team for 22 about the last year.
23 MR. BOWMAN: So, I'll go a little bit more 24 into our operational staff --
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13 1 ahead --
2 MR. BOWMAN: Sure.
3 CO-CHAIR BLEY: -- if we raise any 4 questions that your answers would move into the 5 proprietary area, it's up to you to say we'll pick 6 that up in the closed session. Okay?
7 MR. BOWMAN: Sure. Absolutely. We'll 8 protect our proprietary. Thank you.
9 I went through the introductions. I'd 10 like to go through a few more introductions. I 11 believe we're a little different than a typical 12 nuclear vendor. So, right now on staff, the group 13 that did the work, we have 18 previous licensing 14 director operators. We've held licenses at a wide 15 variety of plants covering three different vendors.
16 So, you can see the list up there on the board. In 17 total, we have 569 years of nuclear experience and 16 18 former Navy nuclear veterans.
19 So, our background I believe is a little 20 unique compared to the typical vendor. We have a lot 21 of operations background, and operations was brought 22 in very early to the NuScale design, recognizing the 23 unique challenges that were going to be placed by the 24 fact that we believe we needed fewer operators to 25 operate these plants.
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14 1 A little on logistics. So, "Conduct of 2 Operations," Chapter 13, is primarily a collection of 3 combined operating license holder actions to describe 4 the structure of the organizations and programs that 5 support plant operations. It also gets into 6 qualifications and training of the individuals in the 7 organizations.
8 So, as Dr. Bley mentioned, this 9 presentation is in two parts. There will be a non-10 proprietary portion first, which will be actually 11 relatively short, and then, we have a proprietary 12 version, which really goes deeper into the details of 13 the Generic Technical Guidelines.
14 And the Security and Fitness for Duty 15 Programs will not be covered as part of this.
16 Although they are a part of Chapter 13, we are not 17 covering them in this presentation.
18 All right. So, organizational structure.
19 Section 13.1 included "See all actions to describe the 20 corporate or home office management and technical 21 support organizations, onsite operations 22 organizations," and then, the qualifications for each 23 management -- all the positions that are listed there.
24 13.2 lists all the training programs. So, 25 this includes the initial and continuing License NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 1 Training Program for the Reactor Operators and Senior 2 Reactor Operators. And then, there's a list of 3 programs that are required for initial and periodic 4 retraining in qualifications. This is the list from 5 10 CFR 51.20, the list of training programs that are 6 required.
7 Section 13.3 covers the emergency plan.
8 It does include some description that comes out of the 9 standard plant design. And that really is regarding 10 the Technical Support Center. So, it provides 11 descriptions for the ventilation systems for the 12 Technical Support Center, communication systems, the 13 TSC workstations, the emergency response data systems.
14 And then, there are three COL actions contained in 15 there to develop the Operation Support Center, the 16 emergency offsite facility, and the overall emergency 17 plan.
18 MEMBER CORRADINI: I had a question, but 19 I'm not sure if -- are you done with 13.3 now --
20 MR. BOWMAN: Yes.
21 MEMBER CORRADINI: -- and you're about to 22 go to 4?
23 MR. BOWMAN: I'm going to move on.
24 MEMBER CORRADINI: Okay. So, you have a 25 plethora of acronyms. Explain to me what an "ISV" is, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 and when is it done? Because that connects to the 2 open item in this section.
3 MR. BOWMAN: Correct. So, Integrated 4 System Validation is the final test of the Human 5 Factors Engineering Program. Integrated System 6 Validation is a test of the procedures, the human-7 system interface, and the operators, to ensure that 8 they can safely operate the plant under the conditions 9 we've set. So, that is an open item because we 10 completed testing in September of this year, and we 11 are currently working through completing the report of 12 that testing effort.
13 MEMBER CORRADINI: Oh, so on your 14 simulator, or what I remember to be the thing, it has 15 already been done? You just have yet to document it 16 and show it to the staff?
17 MR. BOWMAN: That's correct. We've 18 completed all the testing required for ISV.
19 MEMBER CORRADINI: Okay. Okay. Somehow 20 that escaped me.
21 MR. BOWMAN: Okay.
22 CO-CHAIR BLEY: Well, it's not in what we 23 read.
24 (Laughter.)
25 MR. BOWMAN: It isn't. It is an open NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 1 item.
2 MEMBER CORRADINI: Okay. You helped me.
3 Thank you.
4 CO-CHAIR BLEY: So, this -- and we'll ask 5 the staff about this -- if this is complete, when you 6 respond finally to the staff, that hits an awful lot 7 of the open items that are in the SER.
8 MR. BOWMAN: That's correct.
9 CO-CHAIR BLEY: Maybe 80 percent of them.
10 I'm just guessing off the top.
11 MR. BOWMAN: And I actually have a slide 12 at the end that I'll go through and --
13 CO-CHAIR BLEY: Oh, okay.
14 MR. BOWMAN: -- delineate each open item, 15 how we believe it's going to be closed.
16 CO-CHAIR BLEY: We had a question from one 17 of the members who's not actually here and a couple 18 from other members. They pointed to this section.
19 So, I think that's a place to bring it up.
20 Here it speaks of the fact that the number 21 of modules is up to 12. The question was, is this the 22 place that's actually set or is it set somewhere in 23 other parts of the DCD?
24 MR. TOVAR: The --
25 CO-CHAIR BLEY: Yes, go ahead.
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18 1 MR. TOVAR: To answer your question, the 2 design certification application is written around 12 3 modules. And our staffing was geared towards 4 operating up to 12 modules.
5 CO-CHAIR BLEY: And if you operate less 6 than 12 modules, if somebody puts in less than 12, two 7 questions came up. One is -- well, three questions 8 maybe -- one is, do you operate the way you planned to 9 operate with 12 with a fewer number, if there's only 10 one or two or three? The same staffing? Or would 11 that be a COL thing that somebody might want to 12 change?
13 MR. TOVAR: For the licensed operator 14 staffing --
15 CO-CHAIR BLEY: Yes.
16 MR. TOVAR: -- what we have written is up 17 to 12 operating --
18 CO-CHAIR BLEY: So, 1 to 12 --
19 MR. TOVAR: Correct.
20 CO-CHAIR BLEY: -- it applies?
21 MR. TOVAR: If there's any operating 22 units, then, currently, we have the requirement for 23 six licensed operators.
24 CO-CHAIR BLEY: Another question that came 25 up was, if a utility decides to build one of these NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 1 with less than 12 modules -- say they're going to do 2 three at first -- are all of the common systems going 3 to be installed at that time? Or could there be 4 something less than what we see for the supporting 5 systems?
6 MR. TOVAR: I would say that we don't have 7 any official like written documentation for this, but 8 the reactor building and all the common systems 9 associated with that would have to be built and, 10 essentially, installed. The option to only build --
11 CO-CHAIR BLEY: As described, all of them?
12 MR. TOVAR: As described. There may be 13 some components that may be installed at a later date, 14 but, essentially, all the piping and everything that 15 goes through the walls, all that would have to be 16 really laid out.
17 The option, if we only had six or less 18 modules to only build one of the turbine buildings, 19 and then, build the second turbine building at a later 20 date, would be a possibility. But, again, this is --
21 CO-CHAIR BLEY: Is that something that 22 would require an amendment to the -- well, I forget 23 how you describe it -- that would come up during the 24 COL, and it would be an exception to the design cert?
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20 1 to be a bit of engineering work if there was plans to 2 build like a two-unit, four-unit, six-unit NuScale 3 plant. Because there would be some impacts, if 4 nothing else, from the seismic aspect of it. If you 5 only built one building, it may have some impact.
6 But, again, I'm getting out of my area of 7 expertise, and we don't have anything written down as 8 far as this goes. The design certification 9 application is for 12 units, and the understanding is 10 that, to make it cost-effective, the customer is going 11 to install over a period of time the 12 units.
12 CO-CHAIR BLEY: The 12 units? Well, we'll 13 take this to the staff, too, because it seems to me, 14 if you did something less, it would mean an exception 15 to the design cert, a change to the rule at the COL 16 stage. So, we'll see what they have to say about 17 that.
18 And the other question I remember people 19 passing around was: suppose you built three, and 20 then, you're going to add another three. Nobody was 21 able to find anything that described, if you're doing, 22 essentially, construction work while you're operating 23 three units, three modules, what kind of controls need 24 to be in place to allow that construction work to go 25 ahead? And we didn't see anything written about that, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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21 1 or at least I didn't.
2 MR. TOVAR: Correct. We have COL action 3 items that describe generating the procedures that 4 would control those activities. So, we don't 5 currently have any of those procedural guidance, any 6 of that procedural guidance --
7 MEMBER CORRADINI: So, that falls to the 8 owner/operator of the plant --
9 MR. TOVAR: Correct.
10 MEMBER CORRADINI: -- to define how they 11 would modify or even stop operation, commercial 12 operation of a plant as certain construction 13 operations are taking place? They would have to 14 develop the procedures to decide what turns on and 15 what turns off, et cetera?
16 MR. TOVAR: Correct. In our construction 17 plans, it's always been envisioned that we would have 18 the facility built. We'd install a module, and while 19 modules were being installed, subsequently, that we 20 could start up and operate the modules that were ready 21 to be operated. So that we could, basically, be 22 commercially generating power and a revenue stream as 23 the rest of the plant was built out.
24 CO-CHAIR BLEY: So, as you see it, this is 25 an item for the COL to deal with?
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22 1 MR. TOVAR: Yes, as far as the specific 2 procedures --
3 CO-CHAIR BLEY: Because construction work 4 could be threat to the operating.
5 MR. TOVAR: Correct, but --
6 CO-CHAIR BLEY: And it's dependent on how 7 it's done.
8 MR. TOVAR: If you look at the actual what 9 it takes to install a module, it's very similar, 10 essentially, to a refueling actually.
11 CO-CHAIR BLEY: A refueling, yes.
12 MR. TOVAR: And you're limited to moving 13 one module at a time, just due to the equipment to 14 assemble those modules. So, it really is no different 15 from the refueling activities that would take place.
16 And you could have up to 11 modules operating when 17 you're moving the module to do the refueling 18 activities.
19 MEMBER SKILLMAN: I have a bunch of 20 questions, but every question I have is from 21 documentation that is marked confidential. So, I'm 22 going to wait until the end for that confidential 23 period. But let me ask one or two questions.
24 A hundred and sixty megawatt reactor, 25 small by comparison. NuCore's are up to 4,000 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 1 megawatts. You were at Cook and Byron. Byron is a 2 big plant, real big. And you were at Palisades, 3 medium size. And you were at Brunswick.
4 MR. TOVAR: No, I was at Robinson.
5 MEMBER SKILLMAN: Robinson.
6 MR. TOVAR: Yes.
7 MEMBER SKILLMAN: Medium big.
8 MR. TOVAR: Right. I also spent time as 9 a Fleet Outage Manager at Perry, Davis-Besse, and 10 Beaver Valley.
11 MEMBER SKILLMAN: Well, big, middle, and 12 small.
13 (Laughter.)
14 I was on the Oversight Board for FENOC for 15 a long time.
16 But here's where I'm going with my 17 question. Please stick with me. A hundred and sixty 18 megawatt reactor. Between the three of you, you've 19 got some significant PWR experience with big machines.
20 What is it in the FENOC -- excuse me -- in the NuScale 21 training that is going to make sure that the one 22 reactor operator that might be looking at 12 plants on 23 the indications that Dr. Bley was talking about isn't 24 complacent in thinking he or she is looking at process 25 heating units versus a live core reactor that has real NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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24 1 consequences for an accident?
2 I ask this question based on the No. 1 3 lesson we learned out at TMI-2, and that's respect for 4 the technology. I think we're so comfortable with no 5 scrams. We operate 24-month fuel cycles. We go 6 almost breaker to breaker. We have crews on watch 7 right now that have never experienced a trip. So, 8 it's easy to get lulled into believing an accident 9 can't happen, a trip won't happen, and when it does 10 happen, all the automatic systems are going to take 11 over.
12 Here is a man or a woman looking at one, 13 two, three, six, maybe 11 units, with a module being 14 moved. What makes sure that individual really 15 understands that this is not just a little process 16 heating unit, 160 megawatts, but this is a live core 17 plant that can have a loss-of-coolant accident, even 18 though it's very, very improbable and you only have 19 these two high-impact human factors items? What keeps 20 them focused?
21 MR. TOVAR: A couple of things. One is, 22 I think one of the things that we did bring to NuScale 23 is the operating experience. Now the 18 licensed 24 operators, previously licensed operators, that we saw 25 is just the people that are currently on staff and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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25 1 currently within the operations group. That doesn't 2 take into account Dale Atkinson, who was the Chief 3 Nuclear Officer up at Energy Northwest. It doesn't 4 take into account other folks that are scattered 5 throughout the organization with their operating 6 experience. And it doesn't take into account the 7 people that have cycled through our organization that 8 have had tons of operating experience and input into 9 this.
10 So, one of the things that we're very 11 proud of is that operating experience, that we have 12 baked in a lot of the human factors into the human-13 system interface that helps as far as reducing human 14 errors and, basically, ensures that the operator is 15 less likely to make mistakes.
16 So, we do those things, but in Chapter 13 17 it's training. Now there is a COL action item to 18 develop that. I certainly would expect that we carry 19 on the current culture in the nuclear industry in 20 training our operators to understand that nuclear is 21 special. Reactivity, radiation, residual heat, and 22 that they fully understand and internalize that, the 23 special nature of that.
24 I think the operating experience that we 25 have with Fukushima, with TMI, with Chernobyl, and the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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26 1 realization that an event like Fukushima can happen 2 and whole countries can shut down their entire nuclear 3 industry, essentially. You know, Germany is an 4 amazing example of that, where they have taken and 5 said that they're going to shut down all their nuclear 6 power plants. It's incredible.
7 So, we have the use of OE that we have 8 also incorporated into our design and we'll 9 incorporate into our training, to make sure that folks 10 understand those important aspects of nuclear power.
11 Then, of course, we have the regulator 12 that essentially enforces that, to make sure that we 13 have programs that do incorporate operating experience 14 and the training programs are accredited, and we have 15 the operators who are licensed and have to go through 16 that process. So, there's a lot of checks and 17 balances to make sure that, as NuScale grows up and 18 actually starts to operate, that we do incorporate the 19 respect for nuclear and make sure that we don't become 20 complacent.
21 The fact that we have six licensed 22 operators and the oversight from a shift technical 23 advisor, the concurrence advisor, shift manager, all 24 in the control room watching these folks as they 25 control the reactors also is very similar to a current NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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27 1 control room. And I'm sure we'll carry on that 2 "nuclear is special and deserves respect" mentality.
3 MEMBER SKILLMAN: I appreciate the 4 explanation. Let me kind of hang onto this topic and 5 pull one more string. And I don't think this is 6 proprietary. If it is, then I'll wait for later.
7 It appears as though the whole conduct of 8 operations is designed around three critical safety 9 functions: reactivity, decay heat removal, protection 10 of the containment, those three. Is there room for 11 any others? If I look at your PRA, if I look at your 12 Chapter 15, if I look at your Chapter 18 and your 13 Chapter 13, my view is there's something missing.
14 And here's what I think it is: if you 15 have knowledge of Millstone, what got Millstone into 16 trouble was that they were moving fuel before 96 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />. Remember that? They had not allowed that fuel 18 to decay.
19 I know of no other facility where you can 20 have a live reactor and you can be moving 36 21 assemblies 25 or 30 feet away from that live reactor.
22 And you do that with a 734-ton module. You can be 23 actually emplacing a new one that's fresh or removing 24 one that is decaying to your maintenance stand.
25 Doesn't that create a different type of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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28 1 safety function independent of your Chapter 19 that 2 says it can't happen? Isn't that a different, a 3 fundamentally different environment?
4 Think about it. You're on watch at Byron.
5 When you move fuel, the head's off or the head's on.
6 The fuel is in the pool. And you're back to Ops.
7 That fuel is being handled by someone else. It's not 8 your operators. Or, if it is, they're not on shift 9 for the reactor. They are working with maintenance or 10 they're working with other crews.
11 Here you're actually moving a module 12 adjacent to one, two, five live modules. Is there 13 another critical safety function beyond reactivity, 14 decay heat removal, and containment that deserves a 15 different level of attention and perhaps a different 16 piece of staffing?
17 MR. TOVAR: I believe I understand your 18 question. I think the answer is, no, that there's not 19 another critical safety function. I think it's an 20 important aspect of our design that needs to be 21 understood and controlled. I think that any 22 technology has risks associated with it. When you are 23 refueling a reactor and lifting the head over that 24 vessel, there's inherent risks that go with that.
25 MEMBER SKILLMAN: But you're not lifting NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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29 1 over a vessel here. You've got four or five or six or 2 11 living, breathing, 160-megawatt plants, cores, and 3 you're moving a 734-ton machine 25-30 feet away. And 4 the protection for that is your crane, your super 5 single-failure-proof crane.
6 MR. TOVAR: Well, we have training, 7 qualifications, and our NAV1 crane.
8 MEMBER SKILLMAN: And I'll bet if one of 9 you had been at ANO-1, you might be thinking twice 10 about the answer to my question. I think the crane 11 issue and module handling may have a requirement for 12 a CSF, in addition to the three upon which you have 13 your staffing. Let me ask you to consider that before 14 you reject it.
15 MR. TOVAR: I struggle to differentiate 16 too much between a current operating plant and the 17 actions that they take when refueling and lifting a 18 heavy load over the core, and certainly we've had --
19 MEMBER SKILLMAN: Is that core at power?
20 MR. TOVAR: No, sir.
21 MEMBER SKILLMAN: I didn't think so.
22 MR. FLAMAND: I think it's a great 23 question and it's very thought-provoking. One thing 24 I would say is, to put it in perspective as well, 25 those three safety functions -- and maybe this doesn't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 1 apply to the question -- do apply to each of the 2 individual operating units. So, it's not that there's 3 three safety functions as a site. So, if something 4 were to happen and that crane affected one of the 5 other units, those have independent three safety 6 functions. So, if it affected containment or if it 7 affected reactivity, that would be shown for that 8 unit's safety function.
9 The other piece I guess I'd like to just 10 bring up is, because we've had discussions on how to 11 generate three -- again, that's different from other 12 designs. Some aspects of what would be traditional 13 safety functions have been incorporated.
14 So, for instance, what came to mind when 15 you were talking about refueling is water level and 16 how much water is there while I'm doing this refueling 17 activity, so that I have shielding for the folks 18 above, and all that. There's tech specs for that 19 ultimate heat sink level. And the ultimate heat sink 20 is incorporated into the core heat removal safety 21 function.
22 So, sometimes our simplification of three 23 safety functions -- and I don't know how much you've 24 had a chance to look at it, but it might include 25 things that might traditionally be -- like at my NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 1 plant, it would have been an ultimate heat sink kind 2 of safety function on its own, where that's part of 3 heat removal for us. I don't know if that helps.
4 MEMBER SKILLMAN: No, I agree with you.
5 The CSFs are applied to each core. I got that. I'm 6 kind of saying, what happens when your crane doesn't 7 perform the way it should and you end up with a 8 dropped module that might affect two or three 9 operating modules? That's where I'm really going with 10 this.
11 Let me stop here because all my homework 12 is really kind of peeling back on this one issue, not 13 to give you the raspberries, but just to raise this 14 one issue. The NuScale design is unique in the whole 15 world because you're moving a 734-ton machine near 16 operating cores contemporaneously. And I don't think 17 there's anything fundamentally wrong with that, but I 18 believe that that develops perhaps some scenarios that 19 have not been addressed in staffing, have not been 20 addressed in Chapter 18.
21 So, I'm raising it here on Chapter 13 22 because you might say, as head of Ops, you know what, 23 we might peel out special teams to do those movements, 24 and we might consider the single-failure-proof crane 25 from a different perspective. It might have some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 1 safety functions that the NUREGs really might not have 2 explored for operating plants.
3 I can tell you for a fact the TMI-2 4 cleanup was stopped for three months because we 5 couldn't get the crane qualified. I can tell you for 6 a fact that TMI-1 refueling was halted because the 7 brakes didn't set on the puller crane and it was 8 inching down one inch at a time, and we didn't have a 9 safe place to put that head, 160 tons.
10 So, I've been through a number of these 11 events at Three Mile and in the consulting that I did 12 for 10 years at other plants. It's almost as if the 13 crane issues are kind of aux operators take care of 14 that; contractors take care of that.
15 But, in the NuScale design, the crane is 16 front and center of the operating units. And I 17 believe that's different, and it might require a 18 thicker magnifying glass as you put together your 19 staffing plan and as you look at Chapter 18.
20 MR. TOVAR: One thing I will mention is 21 that NuScale does envision having a dedicated 22 refueling team assigned to it with a licensed operator 23 on that team.
24 MR. BOWMAN: That was going to be my 25 mention, too. We right now in our staffing plan NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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33 1 envision a Senior Reactor Operator, either fully 2 licensed or a limited fuel handling license, in charge 3 of any module movement. So, indeed, Operations will 4 be, at a minimum, supervising that activity.
5 In the current fleet, if they did an 6 activity like that -- and I don't believe this would 7 change for us -- you would put together a team to do 8 that activity. They would be briefed. They would be 9 high-level to management oversight to ensure that that 10 activity went properly and that appropriate 11 contingency actions were put in place.
12 But it is a normal activity to happen.
13 But all those pieces have to be in place for that to 14 go on. So, there's a great deal of oversight that I 15 would anticipate in place for any module movement that 16 went on at a NuScale plant.
17 MEMBER SKILLMAN: But let me make my final 18 point. And that is, what's different here is you're 19 moving adjacent to live cores at power. When we did 20 it, the reactor was shut down. We would be on decay 21 heat for two weeks. We had all of the protections and 22 all of the admin that you just mentioned, Doug. So, 23 I fully understand that.
24 What I'm saying is, in this design, there 25 is a unique feature that may need a different level of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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34 1 attention. It isn't going to be normal ops when 2 you've got 11 machines that are at power and you're 3 dragging this 734-ton machine 25 feet away from all 11 4 of them.
5 So, let's pick it up in the proprietary 6 session when I can refer to the documents. But I 7 really challenge you on that.
8 Thank you.
9 MR. TOVAR: Thank you.
10 MEMBER MARCH-LEUBA: Don't go so fast.
11 Mr. Chairman, I noticed he has some 12 questions for the closed session. I have some 13 questions for the closed session. And I noticed that 14 we have half an hour scheduled for the whole thing.
15 So, we may want to be flexible.
16 CO-CHAIR BLEY: We have to control things 17 a bit. So, let's see what happens.
18 MEMBER MARCH-LEUBA: Well, I mean, I think 19 the closed session would probably be more important 20 than the open session.
21 CO-CHAIR BLEY: Thank you.
22 MEMBER MARCH-LEUBA: But, that said, I 23 have an open session question, too.
24 CO-CHAIR BLEY: He's only got like two 25 more slides for the open session.
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35 1 Go ahead.
2 MEMBER MARCH-LEUBA: So, don't get me 3 wrong, I'm a computer guy. I love computer 4 procedures. Data cycles is something I admire. I 5 mean, once I was in a 767 flight simulator in the 6 lounge in the Rome Airport, and they let you go and 7 play with it. And they let me land the 767 on the 8 Venice Airport, and I accomplished it. All you have 9 to do is push one button and extend the flaps. That's 10 all you have to do to land a 767. And I messed up 50 11 percent of the thing; I pulled the flaps too fast.
12 (Laughter.)
13 But, with that said, in your training, the 14 problem I'm having is these computer procedures are 15 great, but we claim, I think, to minus 25 failure 16 probability, which is really currently low. And when 17 you claim those low probabilities, you have to worry 18 about -- and I'm going to raise Charlie's blood 19 pressure right here -- you're letting the computer run 20 your facility. They exercise a computer that knows 21 all the signals, knows all the procedures, and tells 22 you what to do.
23 In the training, who gets precedent, the 24 computer or the pilot or the operator and the paper 25 procedures? If the operator with the paper procedures NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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36 1 sees, hey, the computer is telling me something is 2 wrong, and I don't believe you, when you're training 3 who takes precedent?
4 MR. BOWMAN: So, I can try to answer part 5 of that. In the Generic Technical Guidelines, we 6 have, obviously, the -- I'm going to be careful here 7 not to pass into the proprietary realm -- the HSI 8 evaluates the critical safety functions we've 9 discussed and determines if one is being challenged, 10 and provides the operator with that information. And 11 then, he has to go take action.
12 Also, he's basing all that information 13 off of our best qualified instrumentation; the 14 computer is. And then, right now, right now the role 15 of the STA is the STA backs that up. So, it provides 16 an independent, the STA provides an independent check 17 of the human-system interface to ensure that the 18 correct decision is being made within the EOPs.
19 So, he is independently looking at his 20 best indications in a different manner than how the 21 HSI is looking at them to back it up. And that's one 22 example I can give you where we have the human built 23 in to back up the computer in this case.
24 MEMBER MARCH-LEUBA: But is that part of 25 the training?
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37 1 MR. BOWMAN: Yes.
2 MEMBER MARCH-LEUBA: Do you emphasize, 3 "Don't believe the computer; rely on it, but don't 4 believe it."?
5 MR. BOWMAN: Correct. So, any training 6 program I've been involved with, you have to believe 7 your indications, unless you can be shown that they 8 are wrong. But you have to question your indications 9 all the time to ensure they're working properly.
10 MEMBER MARCH-LEUBA: It's different to 11 read a needle with what the pressure is and having a 12 complex computer algorithm --
13 MR. BOWMAN: Right.
14 MEMBER MARCH-LEUBA: -- running on God 15 knows what platform, that can be on a blue screen of 16 death anytime. If you claim only 10 to the minus 3 17 probability of failure, I'll give you that, but when 18 you claim 10 to the minus 25, nothing has that 19 probability of failure.
20 And while you're thinking, let me give you 21 an example of that Air France flight that was going 22 over there in the Atlantic. And they were going at 23 40,000 feet and 600 miles per hour. And the computer 24 decided that they were stalling. And the computer and 25 the pilot, they started fighting with each other, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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38 1 at the end the plane ended up on the bottom of the 2 Atlantic.
3 MR. BOWMAN: So, I'll go back. I'll try 4 to do a better explanation. What the STA is looking 5 at is, physically, not a computer per se; it is part 6 of our fuel programmable gate array system, part of 7 our safety system. He's looking at those indications 8 that are the best qualification that he can see in the 9 control room. The computer algorithm is taking that 10 information separately and doing an assessment.
11 MEMBER MARCH-LEUBA: But the problem I'm 12 having --
13 MR. BOWMAN: But that's the safety, that's 14 the safety aspect of it.
15 MEMBER MARCH-LEUBA: For the last 15 16 years, I've been an operator in this plant, and the 17 computer has always been right. And suddenly, the 18 computer gets a wrong indication because a mouse chews 19 through a cable, or something.
20 MR. BOWMAN: Sure.
21 MEMBER MARCH-LEUBA: That's going to be 22 part of the training. Say, "Rely on the computer, but 23 always verify." And I get the idea that maybe we have 24 too much overreliance on the computer.
25 MR. TOVAR: I'll say that Chapter 13 has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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39 1 COL action items for the development of the training 2 program. But, because we completed the Integrated 3 System Validation, we had the opportunity to develop 4 quite extensive training for the Integrated System 5 Validation operators. We hired 22 contract operators 6 and put them through a training class that was, 7 roughly, seven months long -- five and a half months 8 long. Trained them on the NuScale design. They had, 9 most of them, all except for two had no background in 10 the NuScale design. So, we trained those folks.
11 And one of the things that the NRC staff 12 expressed during our pre-application engagements was 13 exactly that, a concern over failure of the I&C 14 system, and so forth. So, during that training, we 15 did train them on failures of the I&C system. And we 16 understand the importance of the operators to be able 17 to function and keep the core safe, even in the worse-18 case I&C failures. And in some cases, we took, 19 essentially, the entire control room and took that 20 out.
21 To me, it's very confusing, as an 22 operator, to have those displays up and displaying, 23 but you know that the system has failed. And what 24 it's showing you is a frozen screen from 10 minutes 25 ago. So, to me, that's very disorienting, as an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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40 1 operator.
2 But the crews that we put through that, 3 the training and the actual testing performed those 4 actions well.
5 CO-CHAIR BLEY: Let me follow that up just 6 a second. I'll get right back to you.
7 If you fail the whole computer system all 8 at once and it goes black, that's really not the worst 9 thing.
10 MR. TOVAR: Yes.
11 CO-CHAIR BLEY: The worst thing is when 12 you get something in between. Some things are right; 13 some things are wrong.
14 MR. TOVAR: Sure.
15 CO-CHAIR BLEY: Did you do any of that 16 kind of testing?
17 MR. FLAMAND: So, we did do -- and I don't 18 know if we're going to talk about this in one of the 19 slides -- but you might back up a little bit. The 20 control room has multiple different computer systems.
21 That's the first time I've heard the low probability 22 number and it's pretty good. But it's probably 23 because each unit has what's called module control, a 24 non-safety computer system with redundant components 25 within it and redundant servers. So, there is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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41 1 failover and redundancy there.
2 To get to your question, during this ISV 3 testing and previous staffing testing, we did do where 4 we took a workstation down or we took one of the 5 servers down to see what would happen. The effect and 6 how we showed it wasn't much because it goes over to 7 the failover. And then, we also showed, if you take 8 everything down, and that, basically, as you kind of 9 alluded to, isn't as hard.
10 We also showed -- and I think this was 11 just probably from not the official OE, but just 12 operator daily OE. I'm used to, hey, this valve 13 didn't move because it's been in the same position for 14 the last year, and now it gets a demand signal. So, 15 we tried to show those kinds of failures. So, hey, if 16 an automation expects a valve to respond when it 17 didn't, you know, there's ways of timing, or whatnot, 18 that the automation can help the operator.
19 And then, if you're out of bounds, again, 20 these computer-based procedures are non-safety, and 21 the safety systems are separate and --
22 MEMBER MARCH-LEUBA: The problem I'm 23 having is that software has ways of taking you and 24 failing in the most unusual ways. Really, with 25 software, my car-driving software, I mean, it's great.
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42 1 But --
2 MR. BOWMAN: But, you know, highlights of 3 the system that the STA is verifying is not software-4 based. It does not use software. The system that the 5 STA is using to verify the indications is not 6 software-based. It is programmable gate arrays. So, 7 they do not run software. They're really running a 8 logic network. It's a very different technology than 9 a software-based computer.
10 MEMBER MARCH-LEUBA: If PGAs are software, 11 they cannot even modify this thing.
12 MR. BOWMAN: Right, but they're burnt in 13 and they can't be subject to code. They can't be 14 modified once they've been tested and verified.
15 MEMBER MARCH-LEUBA: Yes, but there is a 16 combination of variables that makes the logic give you 17 the wrong answer.
18 MR. BOWMAN: Right. But, again, I can't 19 overstate the fact that the STA is independently 20 assessing those variables and looking at them in an 21 entirely different way than the software is.
22 MEMBER MARCH-LEUBA: And to the 10 to the 23 minus 3, I'll give you that anytime. We don't even 24 have to justify it. But 10 to the minus 25, no.
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43 1 somebody on your staff get a hold of a book called The 2 Glass Cage.
3 CO-CHAIR BLEY: Either way, just for the 4 Committee members, Jose was right; this meeting might 5 go to 8:00 or 9:00 tonight.
6 (Laughter.)
7 At least, let's not be repetitive, if we 8 can help it.
9 MEMBER MARCH-LEUBA: We haven't started 10 the tricky questions.
11 MR. BOWMAN: Ready to go on? Okay.
12 All right. So, Section 13.4 establishes 13 the operational programs necessary to safely support 14 the plant. There's a long list of those programs that 15 have been built in the current fleet, and this is our 16 COL action item to have the COL build those programs, 17 a large range of things from pre-in-service testing 18 down to the road to fire protection, security, and et 19 cetera. So, that list is in front of you.
20 And then, plant procedures and --
21 CO-CHAIR BLEY: Can I interrupt you as you 22 begin?
23 MR. BOWMAN: Sure.
24 CO-CHAIR BLEY: This one really bothers 25 me. As you've said, you've now got 18 formally-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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44 1 licensed operators. You've spent a lot of time with 2 trying to come up with a display that would really 3 allow the operators to follow the 12 reactors well.
4 You did a lot of training. You've experimented with 5 procedures. You've tried different kinds of manning 6 things. And finally come up with something you think 7 is pretty good.
8 And then, instead of getting a set of 9 operating procedures that match exactly what you've 10 been doing, you put this on the COL applicant who's 11 never seen a plant like this before. That bothers me.
12 I don't know why the EOPs should be a COL action item.
13 Have you got EOPs you're going to give them?
14 MR. BOWMAN: Yes.
15 CO-CHAIR BLEY: And they might modify 16 them?
17 MR. BOWMAN: Well, we have Generic 18 Technical Guidelines, just like the existing industry 19 uses, you know, Westinghouse, ERG, or GERG. So, we 20 have the basis for the procedures, and we'll provide 21 them a writer's guide on how they'll be developed.
22 CO-CHAIR BLEY: You don't actually have 23 procedures your operators have been using?
24 MR. BOWMAN: Yes, and I will get into 25 that --
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45 1 CO-CHAIR BLEY: Yes, you don't, or, yes, 2 you do?
3 MR. BOWMAN: Yes, we do. Yes, 4 absolutely --
5 CO-CHAIR BLEY: Okay. I'll wait for 6 closed session. That's good.
7 MR. BOWMAN: Yes, I would say that's a 8 good closed session question. We answer some of that 9 in the closed session.
10 CO-CHAIR BLEY: Okay. Because I didn't 11 find much help in most of what I read.
12 Go ahead.
13 MR. BOWMAN: Okay. So, there we go.
14 Okay.
15 So, part of Section 13.5 includes the COL 16 action item to ensure plant-specific emergency 17 operating procedures are developed. And the staff, 18 during the review of that, requested that we provide 19 them a set of Generic Technical Guidelines as part of 20 the DCA.
21 So, our goals for development of these 22 were that we provide an entirely symptom-based set of 23 procedures, unlike some of the current industry which 24 uses a mix of event-based and symptom-based 25 procedures. We wanted the status to be easily NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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46 1 assessed by the operator. Given the number of units 2 they had to look at, we needed a quick assessment 3 capability. And we wanted the OPs to be fully 4 integrated in the human-system interface. And I will 5 show you that in the closed session. I think we do 6 that in the closed session.
7 And also, we wanted a single set of 8 procedures that would address all post-accident 9 actions. So, our Generic Technical Guidelines that 10 we've developed cover the legacy emergency operating 11 procedures, severe accident management guidelines, 12 LOLA or loss of large area, extended loss of AC power, 13 and extensive damage mitigation guidelines in the 14 current procedure set, which are typically broken out 15 in separate procedure sets that the operator has to 16 transition between based on conditions.
17 So, how did we start work on the 18 development of the Generic Technical Guidelines?
19 There are several pieces to this. One of them was the 20 critical safety functions that Mr. Skillman alluded 21 to. Another piece of it was, we had to go and find 22 all the actions that we had committed to in the DCA.
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47 1 they were being worked on as part of the DCA.
2 So, PRA, if they were proposing an action, 3 they would come and talk to us about what they thought 4 we should do, and we would provide a discussion and 5 some guidance on how to build that.
6 Anyway, so the places we went and looked 7 are Chapter 7, which Chapter 7 is the I&C failure 8 section where the defense-in-depth analysis is 9 contained. And there are no credited actions there.
10 FSAR Chapter 15, which is the plant design 11 basis for the design-basis events, and there are no 12 actions in there.
13 Chapter 18, human factors engineering task 14 analysis and associated reference. One of the things 15 that people probably don't highlight enough is Chapter 16 18 actually asks our subject matter experts to develop 17 actions to see if they believe there are actions that 18 need to be taken. So, we used our SMEs as well.
19 However, there are no credited actions there. We did 20 develop actions there.
21 CO-CHAIR BLEY: I'm sorry, I was saving 22 this until later. Between Chapter 13 and Chapter 18, 23 and maybe more in the SERs, if it weren't for the I&C 24 guys, I would say these reports were the most 25 cluttered with acronyms I've ever tried to find.
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48 1 (Laughter.)
2 So, what was that last acronym you said?
3 S-E --
4 MR. BOWMAN: Subject matter experts, SMEs.
5 So, in our case, our subject matter 6 experts were the people I alluded to at the beginning 7 of the presentation, the 18 operators, former licensed 8 operators we had which developed our Chapter 18 task 9 analysis, which you can say task analysis and 10 procedures in the same breath for us. They're one and 11 the same to us.
12 So, FSAR Chapter 19, which is the PRA 13 actions, those actions assumed in beyond-design-basis 14 events. In that case, there are seven actions there.
15 And then, Chapter 20, which are the --
16 again, it is called beyond design basis, but Chapter 17 19 is the PRA evaluation; Chapter 20 is the chapter 18 where we have taken those -- for example, ELAP, 19 extended loss of AC power, and extensive damage 20 mitigation guideline actions are in there. So, 21 there's two actions in there.
22 Chapter 21 is the multi-unit design 23 considerations, and there are none. And then, system 24 requirements and limitations, as defined in the system 25 description documents, which is our own engineering NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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49 1 documents. We also found --
2 MEMBER SKILLMAN: Let me just offer an 3 insight here. And neither of these two citations that 4 I will make are proprietary.
5 From your Chapter 19, it is 19.1.6.2 on 6 page 19.1-102. "Key insights. Key insights from 7 LPSD, low power shutdown events. Module drop 8 accidents are the dominant contributors to core 9 damage."
10 Then, you write, "The calculated 11 probability of such events is low, and a large release 12 does not occur from a dropped module, even if the 13 containment is damaged due to radionuclide scrubbing 14 by the pool." That's dandy as long as your pool 15 hasn't been damaged by the module drop.
16 The second citation from your Chapter 15, 17 and this is what really got me going on this question.
18 "NuScale Power Module Drop Accident is 15.7.6 in your 19 Chapter 15. "The use of this single-failure-proof 20 crane precludes the need to perform low drop 21 evaluations. As a result, no design basis accident 22 analysis has been performed to assess the radiological 23 consequences of a nuclear power module drop accident."
24 So, at least as I see it, your critical 25 safety functions screen out this whole topic because NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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50 1 of the dependence on that single-failure-proof crane, 2 or the reliability, your assumed reliability of that 3 crane, and the assumption that you'll get enough 4 scrubbing that, even if you drop the module, it's not 5 a problem.
6 But the real issue for me is not just a 7 dropped module; it's the consequence. If that crane 8 fails or if the reeving fails or the brakes fail, you 9 can have a module, 734 tons, bump into one, two, or 10 three other modules. And it seems to me that that 11 raises the bar. I think that's a different deal, and 12 I think we ought to be talking about it. I think your 13 own documentation, if you weave it together a little 14 differently than the way you have woven it together, 15 you might come to that same conclusion.
16 So, let me stop there until we get to the 17 proprietary session.
18 MR. BOWMAN: Right. So, that's a great 19 segue because the next thing we're going to do is 20 -- my presentation for the open part is done. And we 21 give a list of acronyms as our last slide.
22 CO-CHAIR BLEY: Okay. We don't have your 23 slides for the closed session yet. How many slides 24 are there and how long were you expecting it to take?
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51 1 slides. Only five or six slides, right?
2 MR. BOWMAN: Yes. I don't think there's 3 even 25 in the closed session.
4 So, the closed session is not on this 5 computer right now?
6 MEMBER CORRADINI: We're going to have to 7 make sure.
8 MR. BOWMAN: Okay. Really, the discussion 9 will go into more detail about the Generic Technical 10 Guidelines, is what the closed session discussion is 11 about.
12 CO-CHAIR BLEY: Maybe that will help us 13 later.
14 Mike, let's set up for the closed session.
15 We're going to go well beyond where we thought we 16 would in time.
17 MR. SNODDERLY: Okay. I think that's a 18 good idea.
19 CO-CHAIR BLEY: And maybe you can talk 20 with the staff and the NuScale folks --
21 MR. SNODDERLY: Yes.
22 CO-CHAIR BLEY: -- in between about us 23 hanging around later tonight.
24 MR. SNODDERLY: Yes. Okay. So, what I'd 25 like to do is to ask Prosanta and Steven Pope to look NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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52 1 around the room, and if you identify anyone that 2 doesn't have a need to know -- all members of the 3 public or anyone from the staff that doesn't have a 4 need to know, I need you to leave the room.
5 MEMBER MARCH-LEUBA: Are we on the record 6 still? You should close the open session.
7 (Whereupon, at 11:46 a.m., the foregoing 8 matter recessed from open session and went into closed 9 session until 1:15 p.m.)
10 CO-CHAIR BLEY: The meeting will come back 11 to order and at this time we'll hear from the staff 12 about Chapter 13.
13 Prosanta, are you going to start?
14 MR. CHOWDHURY: Yes. Good afternoon. My 15 name is Prosanta Chowdhury. I'm the project manager 16 for Chapter 13 of the NuScale design certification 17 application review by the staff, by the NRC staff.
18 And with me I have Amanda Marshall for Nuclear 19 Security and Incident Response Office, and also Maurin 20 Scheetz from Nuclear Reactor Regulation Office.
21 As for my credentials I have been a 22 project manager at NRO since 2008 and I have gone 23 through several projects including an site permit in 24 2015. I have also been as a PM involved in the review 25 of EPR design certification application in the past.
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53 1 So as part of my background I have a 2 nuclear engineering master's degree and also a 3 master's degree in electrical engineering. I have in 4 the past worked for the Louisiana State government for 5 18 years as a radiation protection specialist. I have 6 joined the NRC in 2005.
7 And Amanda and Maurin will talk about 8 their credentials.
9 MS. MARSHALL: Yes, good afternoon. My 10 name is Amanda Marshall. As Prosanta said, I work in 11 the Office of Nuclear Security and Incident Response 12 as an emergency preparedness specialist. I reviewed 13 Section 13.3 of the NuScale design certification 14 application. I've been with the NRC for 13 years 15 working in emergency planning for the past 5 or years.
16 And prior to that I was on the security side of NSIR 17 focused on law enforcement response to nuclear power 18 plants.
19 MS. SCHEETZ: All right. Good afternoon.
20 My name is Maurin Scheetz. I have been with the NRC 21 for the past five years predominantly in operator 22 licensing as an examiner, and I've also done some time 23 in the Office of New Reactors as part of this review.
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54 1 predominantly in operator licensing.
2 Before my time at the NRC I did work in 3 re-qualification training at the San Onofre Generating 4 Station. And prior to that I was in the Nuclear Navy 5 as an officer on an aircraft carrier.
6 So I -- as far as Chapter 13 goes, I 7 looked at the organizational structure, the training 8 and the procedure sections of Chapter 13. So I'm 9 going to roll right into that.
10 MR. CHOWDHURY: Yes.
11 MS. SCHEETZ: So next --
12 MR. CHOWDHURY: One second. So the staff 13 is going to present Chapter 13 to the members of the 14 Committee. And also this is the agenda we have. The 15 staff -- I already introduced the review team. The 16 purpose and scope will be covered, review activities 17 and timeline, focus areas, open items and conclusions.
18 So as far as project managers go, Greg 19 Cranston is the lead project manager in LB1, Licensing 20 Branch 1 in NRO.
21 So with that I think we're going to --
22 overview of Chapter 13 we have these sections that 23 will be covered: 13.1, 13.2, 13.3, 13.4 and 13.5.
24 You already heard 13.6, Security, and we are not 25 presenting that. However, based on a comment from one NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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55 1 of the members is that the staff indeed reviewed 13.6.
2 Staff indeed issued a request for additional 3 information, received responses and disposition 4 responses. Staff also had an audit conducted, a demi 5 -- half-audit conducted back in December 2017.
6 So with that I'll turn it over to Maurin 7 to cover 13.1 and 13.2.
8 MS. SCHEETZ: Thank you, Prosanta.
9 Regulations require a COL applicant referencing a 10 standard design to describe their corporate level 11 management and technical support organization and the 12 on-site operating organization. Therefore, we 13 reviewed the application Section 13.1, Organizational 14 Structure, for acceptable COL information items for 15 the COL applicant to provide descriptions of the 16 corporate-level management, technical support 17 organization and on-site operating organization to 18 include a description of the training and 19 qualification requirements for personnel in these 20 organizations.
21 The staff finds that the three COL items 22 that -- provided in this section of the application 23 addressed the applicable requirements for these 24 descriptions of the COL's organizational structure.
25 That's all I have for this section.
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56 1 Next slide, please? The COL applicant is 2 also responsible for describing the training programs 3 and to provide a schedule for training plant staff.
4 The staff reviewed the application section 13.2, 5 Training, to verify COL information items exist for 6 descriptions of the training programs for licensed 7 operator initial and re-qualification training and 8 non-licensed operator -- or correction, non-licensed 9 plant staff initial training and periodic retraining.
10 The staff also verified COL information 11 items include information about the qualifications for 12 non-licensed staff enrolled in these training 13 programs. For example, that would be non-licensed 14 operators, STAs, instrument and control technicians, 15 chemistry technicians, maintenance technicians and 16 other engineering support staff.
17 The staff finds that the two COL 18 information items provided by the applicant address 19 the training program description requirements and 20 therefore are acceptable.
21 CO-CHAIR BLEY: You didn't say STA, did 22 you?
23 MS. SCHEETZ: I did say STA. So --
24 CO-CHAIR BLEY: They're licensed SROs.
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57 1 model they intend them to be licensed SROs. They 2 don't -- regulations don't require for them to hold an 3 SRO license, though most of the fleet -- or most of 4 the operating plants do that.
5 CO-CHAIR BLEY: Yes.
6 MS. SCHEETZ: Yes.
7 MEMBER SKILLMAN: Maurin, what attention 8 did you give to training of those who will handle the 9 modules?
10 MS. SCHEETZ: Do you mean fuel handling?
11 Is that what you mean?
12 MEMBER SKILLMAN: Well, I'm afraid if I 13 say yes to that, it narrows the question I'm really 14 asking.
15 (Laughter.)
16 MEMBER SKILLMAN: You know, a fuel 17 assembly weighs as much as a Volkswagen. These are 18 half-size. So they weigh as much as a Fiat. Okay?
19 The modules are 732 tons. This is not a trivial load.
20 Is there any specific attention given to handling 21 those modules, training-wise?
22 MS. SCHEETZ: So I hear what you're 23 saying. I understand the question. So for our 24 review, because we looked at COL information items, 25 because that's what's required at this stage for the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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58 1 design certification application, we didn't look at 2 the details of what the training program -- the 3 content of the training program. That would be looked 4 at when the COL application comes in, to look into the 5 actual topics and how it's organized. Is that going 6 to be a licensed operator training program requirement 7 or is that going to fall into a different training 8 program for anomalies and stuff on those.
9 MEMBER SKILLMAN: Fair enough. Thank you.
10 MEMBER MARCH-LEUBA: Since we're on the 11 training, you heard us this morning talking about the 12 training, about HSI, human system interface failures 13 due to software or computer hardware. Did you 14 consider any of those in your review?
15 MS. SCHEETZ: So your question is did we 16 look at where HSI training would come into a training 17 program?
18 MEMBER MARCH-LEUBA: Yes.
19 MS. SCHEETZ: Did we review that?
20 MEMBER MARCH-LEUBA: Assuming that 21 software fails most of the time, maybe once every 100 22 years, but it does fail.
23 MS. SCHEETZ: So for this review again we 24 looked at COL information items, so I would expect the 25 NRC staff to review HSI degradations or malfunctions NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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59 1 and how operators in the control room and outside the 2 control room are trained on that in the FSCOLCs.
3 MEMBER MARCH-LEUBA: And for the record I 4 love HSI approach, I love computer-aided procedures.
5 I -- in the example I gave this morning I love being 6 able to land a 767 without any training. Okay? But 7 the operator must have a healthy respect for failures 8 and there is over-reliance. The computer is telling 9 me there's been an issue. It will be okay. You 10 should always look at the other two. And that's part 11 of training and part of the philosophy of doing 12 things. Thank you.
13 MS. SCHEETZ: I agree. I totally agree.
14 And I could say that from an operator licensing 15 standpoint in Part 55 we have requirements that would 16 essentially require that kind of training for operator 17 staff. So that's where I would -- from a regulator I 18 would expect to see it in the Part 55 sections.
19 Any other questions?
20 (No audible response.)
21 MS. SCHEETZ: Okay. So now I'm going to 22 pass it to Amanda Marshall.
23 MS. MARSHALL: Yes, good afternoon. For 24 a design certification review Section 13.3 is intended 25 to address those design features, facilities, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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60 1 functions and equipment that are technically relevant 2 to the design that are not site-specific and that 3 affect some aspect of emergency planning or the 4 capability of a licensee to cope with plant 5 emergencies.
6 The applicant may choose the extent to 7 which the application includes EP information to be 8 reviewed as part of the design certification and 9 there's no minimum amount of information that they 10 must include.
11 NuScale chose to include in the DCA and 12 the staff reviewed emergency planning design 13 information related to a technical support center, 14 emergency response data system, TSC engineering work 15 stations, decontamination facilities, the process 16 sampling system, specifically the post-accident 17 sampling function of which there's an associated open 18 item, and four COL information items related to the 19 operation support center, an emergency operations 20 facility, a comprehensive emergency plan and EP ITAAC, 21 which is actually in Chapter 14.
22 MEMBER MARCH-LEUBA: So you addressed the 23 emergency procedures, how the evacuation would be 24 done, things like that, but did not address the 25 emergency planning zone, the size of these zones.
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61 1 MS. MARSHALL: That's correct.
2 MEMBER MARCH-LEUBA: That's correct?
3 MS. MARSHALL: That's outside the scope of 4 this particular review.
5 MEMBER MARCH-LEUBA: Because we keep 6 saying that we really to see the -- how the source 7 terms are calculated.
8 MEMBER CORRADINI: The source term is 9 going to be used for multiple things, but I think the 10 staff's point is that the emergency planning zone is 11 not part of the DCA.
12 MS. MARSHALL: That's correct.
13 MEMBER MARCH-LEUBA: It's not on any DCAs?
14 MEMBER CORRADINI: Not any DCA. Not just 15 this one. Not any DCA.
16 MEMBER MARCH-LEUBA: But last -- in 17 December we had some kind of talk about the LPZ, the 18 low population zone. They said at a minimum it has to 19 be the size of the exclusion ridge.
20 MEMBER CORRADINI: That's for accident --
21 I'm --
22 MEMBER MARCH-LEUBA: Okay.
23 MEMBER CORRADINI: -- not sure exactly 24 what you're talking about, but --
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62 1 EPZ as --
2 (Simultaneous speaking.)
3 MS. MARSHALL: Yes, that's correct, sir.
4 You may be referring -- there's a few technical 5 reports out as well as an SMR rulemaking, which are a 6 little more focused on the EPZ size.
7 MEMBER MARCH-LEUBA: Now remind me again; 8 I mean, in the Clinch River Breeder reactor site where 9 we have licensed or have an approval --
10 MEMBER CORRADINI: That was the ESP that 11 we looked at. That's unrelated to whatever technology 12 is there.
13 MEMBER MARCH-LEUBA: Correct. The early 14 site permit. But they do have some recommendations 15 from NuScale about the size of their emergency 16 planning zone, if I remember correctly.
17 MEMBER CORRADINI: Well, they used --
18 we're a little off topic, but just to be clear, they 19 used four different potential SMRs that would fit, and 20 then when they decided the size of their emergency 21 planning -- when they made the recommendation for the 22 acceptability of the emergency planning zone, they 23 used an 800-megawatt thermal machine --
24 MEMBER MARCH-LEUBA: Yes.
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63 1 scale source term for 800 megawatts.
2 MEMBER MARCH-LEUBA: Okay. But my 3 impression is that they were using some numbers 4 directly from the NuScale report. That's what I 5 thought they said.
6 MEMBER CORRADINI: I think not.
7 MEMBER MARCH-LEUBA: Okay.
8 MEMBER CORRADINI: I think they scaled 9 everything to a canonical 800-megawatt thermal. Which 10 is in the open session, so we can talk about that?
11 CO-CHAIR BLEY: Yes.
12 MEMBER CORRADINI: Okay.
13 MS. MARSHALL: Okay. NUREG-0800 14 identifies various emergency planning reviewer 15 interface areas which support the review of Section 16 13.3 which are not the specific focus of this meeting 17 nor of the staff's evaluation contained in SER Section 18 13.3.
19 Primary SER interface areas for EP 20 include: SER Section 6.4, which provides information 21 regarding the protection of main control room 22 personnel during an emergency; SER Section 7.2.13.7, 23 which provides information related to TSC data 24 retrieval capabilities; SER Section 9.3.2, which 25 provides information pertaining to the process NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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64 1 sampling system; SER Section 9.4.1, which provides the 2 staff's determination of the acceptability of the HVAC 3 system that supplies the main control room and the 4 TSC; SER Section 9.5.2, which discusses voice and data 5 communications equipment; SER Section 12.1.2.3, which 6 provides the staff's determination of the 7 acceptability of the on-site decontamination 8 facilities proposed by the applicant; and finally SER 9 Section 15.3, which contains information related to 10 TSC radiological habitability. So as you can see, 11 there's a lot of tentacles to other SER sections.
12 Next slide, please? This slide identifies 13 that there is one open item associated with Section 14 13.3 EP review related to the post-accident sampling 15 function of the process sampling system. And the DCA 16 itself, DCA Part 2, Tier 2, Section 9.3.2 states that 17 the function of the process sampling system, or PSS, 18 is to provide the means to obtain representative 19 liquid and gaseous samples from various primary and 20 secondary process streams and components for 21 monitoring and analyzing the chemical and 22 radiochemical conditions. The PSS capability is used 23 during normal plant operations and following accident 24 conditions without the need for a dedicated post-25 accident sampling system.
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65 1 As I mentioned earlier, the capability to 2 obtain a post-accident sample is an interface item 3 with Section 9.3.2. And in EP space Planning Standard 4 B-9 of 10 CFR 50.47 requires adequate method systems 5 and equipment for assessing and monitoring actual 6 potential off-site consequences of a radiological 7 emergency condition are in use. And the guidance in 8 NUREG-0654, Evaluation Criteria, (I)(2) identifies a 9 post-accident sampling capability as an acceptable 10 means of meeting this requirement.
11 As you see on the slide the resolution of 12 this open item is ongoing, and if the process sampling 13 system is determined to be acceptable as a means for 14 obtaining a post-accident sample in accordance with 10 15 CFR 50.34(f)(2)(D)(ii) and (B)(iii), then this open 16 item will be resolved.
17 And that's all I have. Oh, excuse me.
18 Except for my conclusion.
19 With the exception of that open item 20 concerning the capability to obtain a post-accident 21 sample, the staff concluded on the basis of its review 22 that the EP design-related features included in the 23 DCA that the applicant met the applicable regulatory 24 requirements. When the process sampling system review 25 is complete the NRC staff will update its conclusion NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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66 1 to reflect the disposition of this open item.
2 That's all I have. Thank you.
3 MR. CHOWDHURY: Section 13.4, Operational 4 Programs. This is a COL item. The COL applicants 5 are required by 10 CFR 52.79 to describe operational 6 programs, but similar requirements do not exist for 7 DCAs.
8 NuScale did provide COL Item 13.4-1 9 stating that a COL applicant that references the 10 NuScale design certification will provide site-11 specific information including an implementation 12 schedule, operation programs -- operational programs.
13 So the staff has reviewed this COL item 14 and then compared with the Standard Review Plan 15 Section 13.4, Draft Revision 4, September 2018, and 16 find it to be acceptable.
17 MS. SCHEETZ: Section 13.5 is Plant 18 Procedures. Plant procedures include administrative 19 procedures, operating procedures, emergency operating 20 procedures, as well as maintenance and other 21 procedures for safety-related activities. COL 22 applicants are required to develop these type of 23 procedures that are plant-specific, thus the staff 24 reviewed the COL information items in Application 25 Section 13.5, Plant Procedures, for a COL to provide NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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67 1 procedure description and information about procedure 2 program development and implementation.
3 CO-CHAIR BLEY: You actually review the 4 procedures or just --
5 MS. SCHEETZ: Just --
6 CO-CHAIR BLEY: -- review the plan?
7 MS. SCHEETZ: We review that the 8 application, the design certification application has 9 COL information items that would then have a 10 description of these --
11 (Simultaneous speaking.)
12 CO-CHAIR BLEY: When the COL comes up and 13 they have their procedure, do you review the 14 procedures or just ensure they have procedures?
15 MS. MARSHALL: The COL applicant review 16 stage, descriptions of the procedures, and then I do 17 think the SRP does into procedure review, especially 18 for --
19 (Simultaneous speaking.)
20 CO-CHAIR BLEY: The reason I'm asking 21 is --
22 MR. CHOWDHURY: Maybe for fuel loading.
23 Maybe.
24 MS. SCHEETZ: Yes, as part of operational 25 programs for fuel.
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68 1 CO-CHAIR BLEY: I couldn't hear, Prosanta.
2 MS. SCHEETZ: I'm saying it may be right 3 before fuel loading that the actual procedures would 4 be looked at, but I'm not sure about that.
5 CO-CHAIR BLEY: Who would know?
6 MS. SCHEETZ: It's in our SRP. I thought 7 you --
8 MR. CHOWDHURY: I don't have --
9 MS. SCHEETZ: We can get back to you on 10 that.
11 CO-CHAIR BLEY: I'd like to know. And, I 12 don't know, were you here all morning?
13 MS. SCHEETZ: I was here all morning.
14 CO-CHAIR BLEY: NuScale has prepared 15 guidelines that are essentially the emergency 16 procedures that are going to be used and I don't know 17 why you're not looking at those now.
18 MS. SCHEETZ: So I am, and I'm going to 19 get into that. That's --
20 CO-CHAIR BLEY: Where? Okay.
21 MS. SCHEETZ: In this section. So this 22 section has essentially two parts because there are 23 COL information items to actually provide descriptions 24 of these procedures in the implementation program.
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69 1 generic technical guidelines which are reviewed at 2 this stage. And so that was part of my review in this 3 section. So I'll get into that.
4 The seven COL information items provided 5 we found to be acceptable because they addressed the 6 requirements for procedures. And then additionally 7 the staff reviewed the applicant's generic technical 8 guidelines, or GTGs, and those are used by the COL 9 applicant to develop plant-specific technical 10 guidelines that then form the basis for plant-specific 11 emergency operating procedures. The GTGs are the 12 responsibility of the DC applicant and NuScale 13 provided them as part of the application.
14 As a reminder, a lot of the detail in the 15 50 --
16 CO-CHAIR BLEY: I'm sorry. If you 17 reviewed them, do they look like guidelines or do they 18 look like actual procedures that you'll work from?
19 MS. SCHEETZ: They -- the GTGs themselves 20 is a -- it's a large package of both. I would say you 21 could use those as procedures right now, but they also 22 have a lot of basis information and implementation 23 strategy and other stuff. And they do contain a lot 24 of proprietary information, so I think a lot of the 25 discussion on the GTGs we might have to hold off for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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70 1 the closed session. I just want to caution that.
2 CO-CHAIR BLEY: I understand that. So we 3 might revisit this section in the Chapter 18 closed 4 session, if I remember. Go ahead.
5 MS. SCHEETZ: Yes, I think we can 6 definitely cover -- I'll be here for the closed 7 session for Chapter 18.
8 CO-CHAIR BLEY: Okay. Good.
9 MS. SCHEETZ: So, but I'm --
10 MEMBER MARCH-LEUBA: This morning, I don't 11 know if it was the open or the closed session, I don't 12 remember, but we were shown some graphic diagram of 13 decision making. There are five or six of those and 14 the GTGs, which are basically the procedures, but 15 they're not written as a procedure. It's a graphical 16 procedure. Yes, a flow chart.
17 CO-CHAIR BLEY: Well, that was in the 18 closed session.
19 MEMBER MARCH-LEUBA: Oh, was it?
20 MS. SCHEETZ: Yes.
21 MEMBER MARCH-LEUBA: Okay. So we 22 didn't --
23 (Simultaneous speaking.)
24 CO-CHAIR BLEY: -- closed session.
25 (Simultaneous speaking.)
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71 1 MEMBER MARCH-LEUBA: -- that's in it?
2 CO-CHAIR BLEY: And as I understand it, 3 those are part of the general guideline document you 4 talked about --
5 MEMBER MARCH-LEUBA: That is correct.
6 CO-CHAIR BLEY: -- that's now on our 7 SharePoint site.
8 MEMBER MARCH-LEUBA: That is correct.
9 CO-CHAIR BLEY: Members can access that.
10 MEMBER MARCH-LEUBA: And they're actually 11 full PDF. You can blow up those charts and you 12 actually read what it says, whereas the slide we saw 13 this morning you cannot. It's a big chart.
14 CO-CHAIR BLEY: I'm sorry for the 15 diversion. Go ahead.
16 MS. SCHEETZ: That's okay. I can speak 17 about the staff's review of the GTGs. So the NuScale 18 GTGs contain generic guidance for procedure writers to 19 develop procedures that will be used by plant 20 operators to ensure plant safety during an accident.
21 The guidance covers the content for emergency 22 operating procedures, severe accident management 23 guidelines, and guidance for extended loss of AC power 24 and loss or large-area events.
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72 1 of the NuScale GTGs to determine if they are 2 acceptable for use in the development of a COL 3 applicant's plant-specific technical guidelines. In 4 our review the staff focused on three areas: We 5 looked at the design-specific critical safety 6 functions that the applicant identified and described, 7 we looked at what methods the applicant used to 8 identify operator actions, and the operator actions 9 necessary to assess and maintain the critical safety 10 functions including the basis for this information.
11 Also, as part of this review we looked at 12 the use of type B post-accident monitoring variables 13 in the GTGs. Type B post-accident monitoring 14 variables are defined as variables that provide 15 primary information to control room operators to 16 assess critical safety functions during an accident.
17 The applicant provided a list of the type B post-18 accident monitoring variables in the application. The 19 staff found some differences between the type B post-20 accident monitoring variables in the application and 21 those presented in the GTGs for operators to use for 22 assessing the critical safety functions.
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73 1 the GTGs using the Human Factors Engineering 2 Integrated System or ISV testing and validation 3 methods and then make changes to the GTGs.
4 Therefore, there's one open item in this 5 SER for the applicant to provide updated GTGs as 6 necessary and to resolve the PAM -- post-accident 7 monitoring variable inconsistencies and account for 8 any necessary changes resulting from those 9 validations.
10 MEMBER CORRADINI: So just to -- in short, 11 when they submit their report for their ISV, whatever 12 that is --
13 MS. SCHEETZ: Yes.
14 MEMBER CORRADINI: -- that's what you will 15 review to make sure this open item is satisfied?
16 MS. MARSHALL: I would expect either if it 17 comes in the Integrated System Validation Report or 18 another way of NuScale informing the staff that 19 they've completed the validation activities of the 20 generic technical guidelines, and then I guess a new 21 revision of the GTGs.
22 CO-CHAIR BLEY: And --
23 MS. SCHEETZ: I'm sure NuScale can answer 24 how --
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74 1 gave up using acronyms.
2 MS. SCHEETZ: Okay. I can, yes.
3 CO-CHAIR BLEY: GTG is?
4 MS. SCHEETZ: GTG, PAM. I can use --
5 CO-CHAIR BLEY: No.
6 MEMBER CORRADINI: No, I think he wants --
7 MS. SCHEETZ: Do you want me to --
8 MEMBER CORRADINI: -- you to say it out 9 loud.
10 MS. SCHEETZ: Okay.
11 CO-CHAIR BLEY: Say what the words are.
12 MS. SCHEETZ: So you want me to say 13 generic technical guidelines?
14 CO-CHAIR BLEY: I do. Thank you.
15 MS. SCHEETZ: I will.
16 (Laughter.)
17 MR. BOWMAN: Dennis?
18 MS. SCHEETZ: Doug, did you want to --
19 MR. BOWMAN: Hey, Dennis? One comment.
20 We will be submitting a revised set of generic 21 technical guidelines once we have completed the work 22 associating with getting -- we have to get the ISV 23 Report done.
24 CO-CHAIR BLEY: That will be before the 25 design cert is complete?
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75 1 MR. BOWMAN: Yes.
2 CO-CHAIR BLEY: Okay. So we'll see you 3 again on this when there are no open items remaining.
4 MR. BOWMAN: Yes.
5 MS. SCHEETZ: That's correct.
6 MEMBER MARCH-LEUBA: And --
7 MEMBER SKILLMAN: Maurin, what 8 challenge --
9 CO-CHAIR BLEY: Thanks.
10 MEMBER SKILLMAN: did you give -- I'm 11 sorry, Jose.
12 MEMBER MARCH-LEUBA: Oh, no. Go ahead.
13 MEMBER SKILLMAN: Maurin, what challenge 14 did the staff give to the adequacy of the critical 15 safety function? There are only three and they become 16 the -- they have become the foundation for almost 17 everything. What consideration did the staff give to 18 challenging whether or not something has been 19 orphaned, something has been overlooked?
20 MS. SCHEETZ: Okay. So we did challenge 21 the applicant on the critical safety functions.
22 There's not -- in the SRP there's not clear, hey, this 23 is how you review critical safety functions. We had 24 to go into a lot of the background information of TMI 25 action plan items and look at where these critical NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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76 1 safety functions came from in the beginning and the 2 background information for them and kind of come up 3 with a plan of what -- how we would do this review.
4 So the first thing we did was -- you know, 5 what do the other PWRs have for critical safety 6 functions? So we did a comparison of NuScale critical 7 safety functions to traditional -- or large light 8 water reactor critical safety functions for PWR. And 9 when we found -- okay, why don't they have several of 10 those safety functions? Then we issued a request for 11 additional information to NuScale asking about --
12 asking more information about why these critical 13 safety functions and not these other ones.
14 So, and NuScale did provide a response 15 which we found acceptable basically explaining that 16 those other safety function -- critical safety 17 functions that we're used to seeing are inherent to 18 the three critical safety functions that they present, 19 which we found acceptable. We agreed with them on 20 that.
21 MEMBER SKILLMAN: Would you give 22 consideration to taking one more look recognizing that 23 the critical safety functions that have been developed 24 are common for PWRs? And they certainly address fuel 25 in terms of reactivity, decay heat and containment, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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77 1 but they don't look at the unique features of this 2 plant independent from the fact that there are 12 3 smaller-sized pressurized water reactors. There are 4 other features of this plant I think that need -- that 5 deserve to be at least challenged in terms of whether 6 those unique features might in fact constitute the 7 basis for an additional or different safety function 8 in addition to the three that are focused on the fuel.
9 MS. SCHEETZ: I agree. So I can also say 10 that because of -- in part of the Chapter 18 human 11 factors engineering review we've also incorporated --
12 okay, what are the important human actions? We've 13 looked at that part of the review to understand what 14 is known about the NuScale design at this time and how 15 that factors into plant safety functions, safety 16 functions and critical safety functions. So that is 17 part of the human factors engineering process the 18 staff does, and we'll -- I think we'll get into this 19 in Chapter 18.
20 We do have some questions on fuel 21 operations for NuScale, and I do believe we have an 22 open item in Chapter 18 reserved for what important 23 human actions might come out of what we know at a 24 later time about fuel handling and module movement.
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78 1 information would get fed back into the process and 2 the staff would have an opportunity to assess plant 3 safety functions and understand if there is something 4 missing there.
5 MEMBER SKILLMAN: Thank you.
6 MEMBER MARCH-LEUBA: Don't go too fast.
7 He stole my time.
8 NuScale has finally learned how -- they're 9 trying to implement what we've always been saying, 10 that you should have a generic design and then make 11 cookie cutter reactors, make them all the same. And 12 I applaud them for that. This is what everybody has 13 been trying to do, which means that these generic 14 guidelines, the GTGs, are not really generic. They're 15 plant-specific because all plant are the same. And 16 that's what I believe NuScale intends.
17 So I sense a little gap on the review.
18 You're reviewing the point of view of the operator 19 actions. I missed the Chapter 15 reviewer's reviewing 20 them for technical contents. Is this operator action 21 the appropriate one to do at this condition, or is it 22 a better one, or is it a bad one? And I've reserved 23 some time for the closed session to give you some 24 examples about that.
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79 1 part of this review we did interface with the Chapter 2 15 technical reviewers, Chapter 19 technical 3 reviewers, 20 and 21 to understand what operator 4 actions were or were not required and how they -- if 5 they appeared in the generic technical guidelines. So 6 that's -- when I talk about we looked at the 7 methodology that NuScale used to identify operator 8 actions, we looked at across other chapters.
9 MEMBER MARCH-LEUBA: Before we close open 10 item 13.5-1 -- I will not just review a document that 11 NuScale sent. I would love to see all technical 12 experts from all branches in NRR and NRO get together 13 and look at -- there are not many. There is only five 14 screens with some flow charts. I mean, there aren't 15 that many. And you can review them in an afternoon.
16 If I was the king of the world and I was organizing 17 this, I would make a workshop, internal workshop in 18 NRO, say everybody come here, we're going to go 19 through the procedures for NuScale. Let's see what 20 you think. And that would be very valuable. As I 21 say, I reserve some examples that are proprietary for 22 later on.
23 MS. SCHEETZ: Okay. Thank you.
24 CO-CHAIR RAY: Dennis?
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80 1 Harold.
2 CO-CHAIR RAY: I understood that you were 3 advised we will revisit this area after the two items 4 are closed in the exchange you had a few minutes ago.
5 CO-CHAIR BLEY: That's right.
6 CO-CHAIR RAY: I just wanted us to see if 7 we make note, either our staff or somehow, that will 8 bring it back to our attention so we don't miss that.
9 I think --
10 MEMBER CORRADINI: Well, we're 11 automatically going to see it, Harold, when they close 12 the open items. We have to make sure we're satisfied 13 with it.
14 CO-CHAIR BLEY: We'll have an open --
15 we'll have meetings on I believe each chapter again 16 with no open items.
17 MEMBER CORRADINI: In Phase 5.
18 CO-CHAIR BLEY: Phase 5.
19 CO-CHAIR RAY: I just -- I didn't want it 20 to go past us somehow because we didn't recognize it.
21 That's all.
22 CO-CHAIR BLEY: We'll have to remember we 23 want to look for it, though. Keep a note.
24 CO-CHAIR RAY: Help me do that, will you?
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81 1 ask.
2 CO-CHAIR RAY: Well, I'll ask --
3 MEMBER CORRADINI: I'll -- we'll remember.
4 CO-CHAIR RAY: Mr. Snodderly can take note 5 of it. That's fine.
6 CO-CHAIR BLEY: Mike Snodderly's got it.
7 MEMBER MARCH-LEUBA: We're on Chapter --
8 Section 13.5. I will address this in the closed 9 session with more detail, but there is a section under 10 reactivity control, 13.5.4.17 -- pardon me, that has 11 all that number -- in which you quote verbatim what 12 NuScale said about the ATWS transit. So have you seen 13 this ATWS transit? Have they documented the ATWS 14 transit? Has the staff seen this document anywhere, 15 because Chapter 15 says we don't need to give you an 16 ATWS result because we're so good that we don't need 17 one.
18 MS. SCHEETZ: So, no, I have not looked at 19 the specific documentation for ATWS.
20 MEMBER MARCH-LEUBA: We'll go into a 21 little more detail later on this afternoon, but I am 22 convinced that if you give me the ATWS transit I can 23 make that thing go straight widely on flow, and I will 24 read from NuScale's own report that says so. So I 25 would please ask you to -- even if we don't resolve NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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82 1 it, that don't have that quote on the SER on page 13 2 of 34.
3 MS. SCHEETZ: I know what -- yes.
4 MEMBER MARCH-LEUBA: Because it feels like 5 an implicit approval of what they're saying. And I 6 don't think we have reviewed it aggressively enough.
7 MS. SCHEETZ: Okay. So what I can say 8 about the generic technical guidelines is that so far 9 we believe that they are logically structured, they 10 appropriately have prioritized safety and defense-in-11 depth functions, they adequately describe initial and 12 follow-up evaluation when critical safety functions 13 are challenged or not met, they can be practically 14 implemented and they provide adequate design-specific 15 information for a COL applicant to use in the 16 development of plant-specific guidelines, and then the 17 b subsequently emergency operating procedures.
18 The staff plans to review the results of 19 generic technical guideline validation to understand 20 if operators were successful in using the generic 21 technical guidelines during simulated accident 22 scenarios and to understand what if any changes the 23 applicant has identified for the generic technical 24 guidelines or the application.
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83 1 ask a specific question. This is in the Safety 2 Evaluation, Chapter 13. It is in Section 13.5.4.2.1, 3 13,5.4.2.1, Critical Safety Functions. And the text 4 is describing the low temperature over-pressurization 5 protection system. And there's one statement here:
6 "The NuScale reactor pressure vessel is designed to 7 withstand the maximum passive system cool-down rate."
8 And you will find that on PDF page 13-29.
9 And my question is has that -- has the 10 staff verified the accuracy of that statement? And 11 this is important because when the plant goes into 12 ECCS mode, they actually add cool water to the reactor 13 vessel. So I -- the reason I'm raising this is part 14 of the TMI accident was the operators' fear of over-15 pressurizing. If you talk to those operators, they 16 were afraid of fracturing the reactor coolant system.
17 So I'm really asking have you verified, has staff 18 verified the NuScale statement?
19 MS. SCHEETZ: So a predecessor did this 20 specific part of the review before I took it over, so 21 I'd have to check with him about who in Chapter 15 you 22 talked about -- he talked to you about this. My 23 understanding was that Chapter 15 was a large 24 interface in this review as far as verifying these 25 requests for additional information responses from the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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84 1 applicant. So I believe that we have verified that 2 through Chapter 15 and all.
3 MEMBER SKILLMAN: This is in Chapter 13, 4 the statements in Chapter 13.
5 MS. SCHEETZ: The Chapter -- the statement 6 is in Chapter 13 because we were explaining about why 7 other critical safety functions didn't need to be 8 specified because they were inherent to the critical 9 safety functions that NuScale had outlined, so this 10 kind of explains that basis for that decision.
11 MEMBER SKILLMAN: Thank you.
12 MS. SCHEETZ: That's all I have.
13 CO-CHAIR BLEY: Yes, we are. That's it.
14 I'm just curious; and I don't know if you can answer 15 this, given that you have reviewed the guidelines at 16 this point, when a COL -- should a COL come forward 17 and they say we have no changes with respect to the 18 design cert, what will you be looking for them to do 19 on this COL item, 13.5-2 through 7? Will you expect 20 anything or will you just say, well, if you use those 21 as your procedures, that's great? We've already --
22 MS. SCHEETZ: No, I think we would -- I 23 would expect that the staff would do a new review of 24 the design-specific emergency operating procedures, 25 whether or not they --
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85 1 CO-CHAIR BLEY: Even if they're the same?
2 MS. SCHEETZ: Even if they're the same, 3 yes.
4 CO-CHAIR BLEY: Thank you.
5 MS. SCHEETZ: We would follow our review 6 procedures.
7 MEMBER MARCH-LEUBA: Yes, but I think it 8 would be more efficient if we do it once instead of 9 every time a new module gets built. I mean, if you 10 have 12 modules, you just pick 12 reviews of the GTGs?
11 I mean, every time you put a new --
12 CO-CHAIR BLEY: Well, wait.
13 MEMBER MARCH-LEUBA: -- module into 14 effect, will you expect it to --
15 CO-CHAIR BLEY: The procedures will not 16 change dependent on whether there's 1, 2, 3 or 12 17 modules, I don't think.
18 MEMBER MARCH-LEUBA: They're not going to 19 change with respect to the GTGs that already exist.
20 CO-CHAIR BLEY: Yes.
21 MEMBER MARCH-LEUBA: It would be more 22 efficient to do it once and --
23 (Simultaneous speaking.)
24 CO-CHAIR BLEY: Well, the way it was just 25 explained it would be done once on the first COLA.
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86 1 The rest of the COLAs could refer to that one. But I 2 don't know why it couldn't be done now myself, which 3 is why I was asking it, too. I agree with you.
4 Anything from the Committee?
5 (No audible response.)
6 CO-CHAIR BLEY: All right. At this time 7 -- no, we're going to go to Chapter 18, open session.
8 Thank you so much. The same people will 9 be back for Chapter 18?
10 MR. CHOWDHURY: Correct.
11 CO-CHAIR BLEY: Okay. Thanks, Prosanta.
12 MR. CHOWDHURY: Well, we have more people.
13 CO-CHAIR BLEY: And more? Okay.
14 (Laughter.)
15 CO-CHAIR BLEY: Let's stand them up in the 16 center of this dome.
17 (Pause.)
18 CO-CHAIR BLEY: All right. Is there any 19 reason for us to delay or can we go ahead?
20 Okay. Dough, you're up.
21 MR. BOWMAN: All right. Good afternoon, 22 everybody. We're going to present on Chapter 18 now.
23 NuScale recognizes some unique goals in 24 Chapter 18. We went through a little bit of this in 25 Chapter 13. But given the unique nature of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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87 1 control room in terms of -- especially U.S. plants, 2 with 12 units being operated from a single control 3 room, this was our vision. We knew -- and the fact 4 that the design was so simple, we knew there were some 5 unique things that we were going to be faced with.
6 So we set some goals early on. We wanted 7 to integrate human factors engineering into the 8 development, design and evaluation of the plant. And 9 what that really resulted in is deliberate elimination 10 of operator actions in the design-basis. We as 11 operators certainly were staunch advocates of that 12 position. We also wanted to provide an HFE design 13 that facilitated safe and reliable operation, 14 maintenance testing, inspections around the plant.
15 Really what resulted from that was we wanted to allow 16 an operator to be able to quickly assess the status of 17 all 12 units. We're going to show you some examples 18 of the human system interface that we designed to 19 allow that to happen.
20 And we wanted to provide a state-of-the-21 art human factors design that satisfied the regulatory 22 requirements, and out of that we really wanted to 23 expand the use of automation. I know we've talked 24 about this extensively in 13. For routine normal 25 tasks to limit operator workload really do the things NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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88 1 that computers are doing now.
2 So in light of that I'm going to -- this 3 presentation is going to -- I'm not going to walk 4 through every single section of Chapter 18, but I'm 5 going to walk through the areas that we felt were very 6 important to our development, and we're going to talk 7 about how we developed our Concept of Operations, and 8 really that Concept of Operations leads up to the 9 staffing plan validation for the first major event we 10 did in human factors engineering. So we'll discuss 11 that. We'll follow that up with the integrated system 12 validation and how all of those two items flange 13 together. And that's really what this presentation is 14 going to be about.
15 So we did an extensive operating 16 experience review. It is the first area I'm going to 17 talk about. And we reviewed the operating experience 18 in the following industries: Currently operating 19 nuclear power plants; that was an obvious choice for 20 us, nuclear facilities that do not produce power, non-21 nuclear power plants, a U.S. military platform. And 22 we also went into the health care industry. We looked 23 at a neonatal care intensive unit where they monitor 24 multiple babies over the course of -- or children as 25 part of that exercise. Electrical distribution and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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89 1 the airline industry. And our purpose was to review 2 -- was to identify human factors engineering safety 3 issues and incorporate identified positive features in 4 the NuScale plant design.
5 CO-CHAIR BLEY: When you said "non-6 nuclear," that could be almost anything in the world.
7 What kind of things are you talking about?
8 MR. BOWMAN: Well, in this case it was a 9 non-nuclear power plant, right?
10 CO-CHAIR BLEY: Oh, it was a power plant?
11 MR. BOWMAN: So we are -- I'm going to 12 talk about the specific -- because that's one very 13 specific -- we --
14 (Simultaneous speaking.)
15 CO-CHAIR BLEY: But not chemical 16 processing plants, that kind of stuff?
17 MR. BOWMAN: I don't believe we did any 18 chemical plants at all.
19 CO-CHAIR BLEY: Okay. Just curious.
20 MR. BOWMAN: So the things we were worried 21 about. From the current industry inside of a nuclear 22 -- inside of the current commercial nuclear area we 23 were worried about alarm avalanche. That idea that at 24 the time that an event occurs, especially a reactor 25 trip or a major accident, the operator is inundated NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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90 1 with alarms. And many of these alarms are essentially 2 not applicable to the situation he's looking at. He 3 has to know what alarms are just normal that are going 4 to come into the situation, then he has to look for 5 those alarms that are actually pertinent to his 6 situation.
7 So we established a tiered alarm system.
8 Now this isn't unusual to use a tiered alarm system.
9 Ours is set up with three levels of alarm 10 notification: alarm, caution and notice. And I will 11 provide you at least some visual examples of how we'd 12 do that, but a brief explanation. Alarm -- go ahead.
13 CO-CHAIR BLEY: Before you do that, you 14 now have 18 former licensed operators with you. How 15 many did you have back when you were doing this work?
16 Were there operators involved in deciding how these 17 alarms ought to be displayed?
18 MR. BOWMAN: There's been other people 19 involved despite the ones the we have now. I couldn't 20 tell you exactly how many, but yes, we've had other 21 people who've come and gone out of our project.
22 CO-CHAIR BLEY: Not just people, but 23 operators?
24 MR. BOWMAN: Operators, yes. Absolutely.
25 CO-CHAIR BLEY: Go ahead.
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91 1 MR. BOWMAN: All right. So a tiered alarm 2 system. The alarm is -- operates as we're all used 3 to. There's a continuous alarm sound and a flashing 4 indication that stays in until you acknowledge the 5 alarm. And we expect those alarms to be used on a 6 very limited basis for those things that actually 7 require an operator to take action in our safety 8 concern.
9 The caution behaves differently. It comes 10 in. It provides a single tone to the operator and 11 then it stops. There's no continuous alarm function.
12 On the human system interface you can see how many 13 cautions you have in at a given time. There's a 14 yellow icon that shows you how many cautions you have 15 in.
16 And then the final one is a notice, and 17 the notice is essentially kind of like getting an 18 email. Essentially it's a way for the human system 19 interface to provide the operator with information 20 that's not critical in nature, but he needs to provide 21 the operator that information. There's a lot of 22 alarms today in the industry that are like that that 23 are currently -- they're all one tier and you don't 24 know the difference.
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92 1 an automation that covers -- that monitors all 12 2 units and looks for whether or not a dilution needs to 3 be performed. And if that automation decides that 4 it's ready for a dilution, it will provide a notice to 5 the operator that it wants to dilute for example Unit 6 8. Then the operator would go and review that 7 information and decide whether or not he wanted to 8 allow that automation to continue. That's an example 9 of a notice.
10 CO-CHAIR BLEY: Does a notice tell him 11 why?
12 MR. BOWMAN: Yes, absolutely. When he 13 brings up that screen, it's going to show him all the 14 parameters on that unit and why it thinks it's time 15 for it to go dilute. And he can review all that and 16 decide if he wants to move on with that or not.
17 And again, a dilution is not a time-critical --
18 there's nothing critical about the operator performing 19 a dilution. It's a thing to maintain your power is 20 all it really is. So that's one piece of what we did.
21 Operating multiple units from a single 22 control room. Obviously given the lack of information 23 about that in the industry, we -- especially the 24 American industry, we started looking outside of the 25 American industry. So obviously we started with our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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93 1 on subject matter experts and they provided us some 2 initial ideas about what our staffing level should be 3 and what our basis should be.
4 But then we went to Bruce Power, and Bruce 5 Power, the Canadian plants, they operate four units 6 from a single control room. And from this 7 benchmarking trip we took a concept they use where 8 they have a control room supervisor -- although we've 9 kind of talked about him as being in a traditional 10 role, and he does serve that traditional role. He is 11 a bit step-backed in his oversight because he's much 12 more of a resource manager in the control room than he 13 is direct oversight of a reactor operator performing 14 a duty. So we took that idea from Bruce Power.
15 And also at Bruce Power they'll have 16 operators who are operating at the controls, but they 17 also have additional operators in the control room 18 that are basically resources for those operators at 19 the controls to perform various activities. So we 20 also took that concept, and that's a part of how we 21 got to our operations concept.
22 Then the other major one was -- we did 23 benchmarking at the T.H. Wharton Gas Turbine 24 Generating Station. So this -- at this plant they 25 have a total of 17 different turbines operating, both NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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94 1 gas generation and steam turbine units, and they both 2 operate in both simple and combined cycle and they're 3 all operated by a single operator in a single control 4 room. So 17 individual units. One operator is 5 monitoring them all. Different designs, different 6 design features, different eras. So there's a wide 7 variety of what he has to take in.
8 CO-CHAIR BLEY: Were you able to see 9 anything about their operating history and what kind 10 of problems occurred?
11 MR. BOWMAN: Some. We did use some of it.
12 I didn't personally go on this trip, but I can tell 13 you that for example they had a lot of problems where 14 they didn't understand --
15 CO-CHAIR BLEY: "They" being the 16 operators?
17 MR. BOWMAN: The operators at this gas 18 plant didn't understand their I&C system well enough.
19 So they didn't understand the effects of failures. So 20 we within our design certainly looked at that. We 21 provide the operators with backup control stations.
22 We have a procedure built already -- a draft 23 procedure; we don't have real procedures yet for this 24 kind of thing -- a draft procedure that describes what 25 the operator does in various failure states on the I&C NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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95 1 system, depending on which portion of the system is 2 broken or failed. So we've developed some of that 3 work already.
4 But also the concept of a single operator 5 operating multiple units evolved. So what we wound up 6 with for the three reactor operators that you talked 7 a little bit about earlier is we have RO-1 as 8 described. He is operator at controls for 12 units.
9 He's monitoring 12 units. And he has two other 10 operators that are resources for him to use depending 11 on what's going on, are resources for him to help.
12 And that allows the maximum amount of flexibility with 13 addressing problems as they come up for that crew.
14 Instead of for example having an operator 15 -- three operators each describing -- covering four 16 units, they can only cover those four units and how 17 much further can they extend their use? For the 18 single operator, he's in passive control, what we term 19 passive control, as the plants are operating in normal 20 conditions.
21 CO-CHAIR BLEY: Can I ask you a question?
22 MR. BOWMAN: Sure.
23 CO-CHAIR BLEY: I had to take -- I saw it 24 there five, six -- four years ago, whenever that was, 25 but I read through the DCD, I read through the SER.
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96 1 I didn't find anything. I went to the staffing and 2 whatever it is final report. Didn't find anything 3 there except a reference to the Concept of Operations 4 report where I found either specific details or at 5 least close-to-specific details with hints of the rest 6 of what you've described.
7 I think this material is very important to 8 support your philosophy of how to operate these 9 plants, yet from a regulatory point of view; at least 10 my regulatory point of view, it's in a tertiary 11 document. I don't know why you didn't recommend and 12 the staff didn't say that that document ought to be --
13 I forget the words they used -- picked up by 14 reference --
15 MR. BOWMAN: So the --
16 CO-CHAIR BLEY: -- for the design.
17 MEMBER SKILLMAN: Incorporated by 18 reference.
19 CO-CHAIR BLEY: Incorporated by reference.
20 MEMBER SKILLMAN: IBR.
21 MR. BOWMAN: So the Concept of Operations 22 is actually required by NUREG-1711 and is submitted 23 and on the docket as part of our application.
24 MR. TOVAR: There's two different 25 documents that we have: One is the Concept of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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97 1 Operations, which is a higher-level document that 2 describes at a high level roles and responsibilities 3 and the staffing. We have a Conduct of Operations, 4 which I think your -- is really where your interest 5 lies -- is a much more detailed document that 6 describes the conduct of the operators within the 7 control room, different human error prevention 8 techniques and so forth, what is the requirements for 9 peer checking and so forth. That was not incorporated 10 by reference or docketed. As they are not in 11 commercial plants today it doesn't make sense to have 12 that type of controls on a document like that because 13 that makes it much more difficult for --
14 MEMBER CORRADINI: Was the overview 15 document explained, the process that we observed back 16 in -- when we were physically there, because you guys 17 took us through at least -- I can't remember who else 18 in the room was there.
19 CO-CHAIR BLEY: Just me, I think.
20 MEMBER CORRADINI: No, you and I.
21 CO-CHAIR BLEY: Of the people who were 22 still on -- were you there, Ron?
23 MEMBER BALLINGER: Oh, yes, I was there.
24 CO-CHAIR BLEY: Okay.
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98 1 through the what-ifs about if one plant went to some 2 sort of --
3 CO-CHAIR BLEY: Well, they actually ran a 4 drill --
5 (Simultaneous speaking.)
6 MEMBER CORRADINI: They ran the drill.
7 CO-CHAIR BLEY: I need to come back. The 8 document I'm looking at is -- wow, that's a different 9 number than -- oh, no. RP0215-10815-P, and it's 10 called Concepts, with an S, of Operations.
11 MR. BOWMAN: But that does describe the 12 role of --
13 (Simultaneous speaking.)
14 CO-CHAIR BLEY: It does.
15 MR. BOWMAN: Yes.
16 CO-CHAIR BLEY: It does. And that's the 17 one I was talking about. The other one I haven't 18 seen, so I'm going to have to go look for that.
19 (Laughter.)
20 CO-CHAIR BLEY: Conduct of Operations.
21 MR. BOWMAN: So the Concept of Operations, 22 the document you referenced, is incorporated by 23 reference and was --
24 (Simultaneous speaking.)
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99 1 saw in either the DCD or the SER. If it is, please 2 show us. Not this instant, but fill us in. That one 3 I would like -- I think that would be a good idea.
4 The Conduct of Operations one, if you can give us a 5 report on that, that would be of interest, because I 6 didn't see that referenced anywhere.
7 MR. BOWMAN: But to echo Tim's comment, I 8 don't believe the Conduct of Operations is 9 appropriate. I mean, mind you, we're reviewing it, 10 obviously. I don't believe it's appropriate to bring 11 into a DCA application, but --
12 CO-CHAIR BLEY: Well, that might be. It's 13 the other one that I was --
14 MR. BOWMAN: Right.
15 CO-CHAIR BLEY: -- thinking should be.
16 MR. BOWMAN: Okay.
17 CO-CHAIR BLEY: Because I didn't see 18 anywhere else where this was addressed.
19 MR. BOWMAN: Sure.
20 MR. TOVAR: And I just checked Chapter 18 21 of the design certification application and it is not 22 referenced directly, but if you --
23 CO-CHAIR BLEY: Yes.
24 MR. TOVAR: -- look into --
25 CO-CHAIR BLEY: It's true.
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100 1 MR. TOVAR: -- I want to say the Staffing 2 and Qualification Results Summary Report --
3 CO-CHAIR BLEY: It references it.
4 MR. TOVAR: -- it will be referenced --
5 (Simultaneous speaking.)
6 CO-CHAIR BLEY: That is true. That's why 7 I called it a tertiary --
8 (Simultaneous speaking.)
9 MEMBER CORRADINI: That's how he found it.
10 MR. TOVAR: Right.
11 CO-CHAIR BLEY: That's how I found it. I 12 didn't --
13 MR. TOVAR: Okay.
14 CO-CHAIR BLEY: -- find it until like 15 Friday and didn't get a copy of it to look at until 16 Sunday.
17 MEMBER SKILLMAN: Doug, let me ask this 18 question: When I look at my RO license and my SRO 19 license, there's a blank. It gives my name and I'm 20 authorized to operate reactor with facility 21 designation, and there's the facility designation.
22 And for both my licenses there's just one reactor.
23 What is the vision that NuScale has and what is the 24 NRC's vision for how your reactor -- how the NuScale 25 reactor operators' licenses will be identified, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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101 1 because one of the key facets of, at least the 2 licenses that most of us have held, is the issue of 3 accountability. If you are the OAC and you fail to 4 operate in accordance with procedure, you own it.
5 MR. BOWMAN: So --
6 MEMBER SKILLMAN: So here you are, an 7 individual perhaps with a license to operate sub 1, 8 sub 2, sub 3, sub 4, sub 5, sub 6, and it's good old 9 sub 7 that goes belly up in the night. You say, well, 10 really, I was just monitoring it. I wasn't operating.
11 He was operating.
12 MR. BOWMAN: So I'll try to answer that in 13 two parts. So I'll start off with -- both of my 14 licenses have two facilities on them because I was 15 licensed --
16 (Simultaneous speaking.)
17 MEMBER SKILLMAN: On both? Okay.
18 MR. BOWMAN: So we envision that first 19 part of that question to be answered with the docket.
20 I believe we're going to have individual dockets for 21 the units. So therefore, an operator would be 22 licensed on those 12 units.
23 No. 2, our -- I don't know how far I can 24 go in open session with this one in terms of 25 discretion of --
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102 1 PARTICIPANT: If it's displayed in a non-2 proprietary simulator presentation, it's --
3 (Simultaneous speaking.)
4 MR. BOWMAN: Yes, we can do that. Okay.
5 We use a concept called passive and active control in 6 the Concept -- in the Conduct of Operations. So if 7 the Operator 1 -- I say one guy is in charge, RO-1, 8 and one person is -- he -- that person is monitoring 9 those 12 units and there's nothing displayed on the 10 HSI. So when somebody wants to go take action on the 11 unit, we go into a mode we call active control.
12 So if it's going to be RO-1, which on 13 certain cases, limited cases we roll out and take very 14 small actions, he would actually change the HSI to 15 show that he is in active control of that unit. And 16 that's a symbol that -- an icon that shows up. If he 17 were to do a bigger -- a bigger task needed to be 18 done, then for example RO-2 might do it. Well, when 19 RO-2 took over control of that unit, you would put his 20 icon up there and show that he's in control.
21 So our Concept of Operations; we like to 22 use this term a lot, is baked into our human system 23 interface. We have a very clear set of roles and 24 responsibilities. We know who's in charge of all the 25 units all the time and it's displayed for anybody who NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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103 1 walks into the control room to see.
2 MEMBER SKILLMAN: Thank you.
3 MR. BOWMAN: All right. So I'll move onto 4 task analysis. I'm leading up to -- to get back to 5 our summary, I'm leading up to the staffing plan 6 validation. We talked about operating experience and 7 how we developed our Concept of Operations. I'm going 8 to talk about task analysis.
9 This is really a brief slide, but task 10 analysis was important to us because much like the 11 question about the generic technical guidelines, the 12 task analysis we did for human factors engineering.
13 When you look at it, it looks like a procedure. I 14 mean, that's the way we wound up using it. We 15 developed task analysis to look like procedures.
16 This was done by our subject matter 17 experts, the 18-plus people, SROs, we've had working 18 on this project for four-plus years. More than that.
19 The five years I've been around. We actually put this 20 task analysis into the database that almost the entire 21 industry uses for training. That allows us to use 22 that task analysis as a training basis, too, in the 23 systematic approach to training. So our intention is 24 to build the entire operations program forward 25 starting with human factors engineering and keep NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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104 1 developing the project as we move on.
2 Next slide. Treatment of Important Human 3 Actions. So we've talked about this in Chapter 13 a 4 bit, but we have two risk-important human actions. We 5 talked about the other seven actions we identified 6 during GTG -- or generic technical guideline 7 development, but these are the two important ones.
8 And we've discussed them before. We're adding water 9 to the reactor coolant system with a chemical and 10 volume control system and adding water to containment 11 with the containment flood and drain system.
12 We needed to develop these to know what 13 our staffing plan validation test was going to look 14 like. We had to understand them well. And recognize 15 there are no deterministic important human actions 16 identified in -- by transient max analysis or by the 17 diversity or defense-in-depth coping analysis.
18 CO-CHAIR BLEY: I don't know quite what 19 that means, but --
20 MR. BOWMAN: So I'll talk about it by 21 chapter then.
22 CO-CHAIR BLEY: Okay. That's fine.
23 MR. BOWMAN: We found our important human 24 actions in Chapter 19 like we discussed. These other 25 two, the major areas were the human factors NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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105 1 engineering regulations tell you to look is in Chapter 2 7 in your diversity and defense-in-depth analysis, and 3 in Chapter 15 under your accident analysis to look for 4 operator actions.
5 CO-CHAIR BLEY: And we haven't reviewed 6 that yet. Chapter 15 --
7 MR. BOWMAN: Seven you've reviewed.
8 CO-CHAIR BLEY: -- we haven't. Seven we 9 have.
10 MR. BOWMAN: Yes.
11 MEMBER SKILLMAN: Doug, isn't that -- that 12 second bullet on that slide, the deterministic 13 important human actions were identified, so on and so 14 forth, based on your critical safety functions.
15 Because the real root of this and of these two highly 16 important actions come out of your critical safety 17 functions. They're driven by the CSFs.
18 MR. BOWMAN: Well, they're certainly 19 categorized under CSFs and put in that way, but we 20 were always looking for places where people were 21 trying to specify actions for operators. When I went 22 back to that early statement where I said we were a 23 staunch defenders of the position that we didn't want 24 any operators -- operator actions in the design. So 25 Chapter 15 and Chapter 7 we were -- I don't know how NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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106 1 best to put it -- we defended that position strongly.
2 Any time somebody brought up -- an 3 engineer might bring up a solution to a problem we 4 were having with a design, they might say, yes, we can 5 put an operator action here. It's common in the 6 industry. We came back with, no, we need to come up 7 with a solution that doesn't require an operator 8 action.
9 MEMBER SKILLMAN: Okay.
10 CO-CHAIR BLEY: Okay. And this was in 11 Chapter 18 you talk about this for the important 12 actions. Or no, for the deficiencies? You looked 13 for --
14 MR. BOWMAN: No, no, no. This is back in 15 the design stage.
16 MEMBER SKILLMAN: This is your overall --
17 MR. BOWMAN: I'm sorry. I'm going back, 18 way back --
19 (Simultaneous speaking.)
20 MEMBER SKILLMAN: Yes, this is your 21 overarching design?
22 MR. BOWMAN: Right, this is how we -- this 23 is our design philosophy. We were strong about not 24 wanting operator action.
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107 1 with you that that is the appropriate overarching 2 design intent, and I think you fulfilled that by and 3 large by being faithful to your CSFs. And I just 4 think there may be one or two more that need to be 5 elevated to CSF category, because I think they are so 6 important that they need attention. So I would 7 suggest that -- generally I agree with you, but I 8 think the lens needs to be opened a little wider.
9 MR. TOVAR: So I think that we've heard 10 that message very clearly --
11 MEMBER SKILLMAN: Yes, okay.
12 MR. TOVAR: -- and we need to go back and 13 make sure that we --
14 MEMBER SKILLMAN: I'll stop.
15 MR. TOVAR: -- take a look at that.
16 MEMBER SKILLMAN: I'll stop. It's just 17 really a chapter 18, but it's also a Chapter 13 issue.
18 MR. TOVAR: Sure, and I'm not asking --
19 CO-CHAIR BLEY: Can I put a little onus on 20 you?
21 MR. TOVAR: Sure.
22 CO-CHAIR BLEY: Earlier when you followed 23 this line you gave them at least the example of the 24 crane moving loads while the other plants are 25 operating. I didn't hear another one you offered NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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108 1 them. Did you have another one? I don't think so.
2 MEMBER SKILLMAN: I -- well --
3 CO-CHAIR BLEY: I think it was just that 4 one.
5 MEMBER SKILLMAN: Only to the extent that 6 it's woven between Chapter 15 --
7 CO-CHAIR BLEY: Yes, but if --
8 MR. TOVAR: -- and 18.
9 CO-CHAIR BLEY: -- there are two or three 10 more important safety functions --
11 MEMBER SKILLMAN: No, I --
12 CO-CHAIR BLEY: -- we know about, we ought 13 to tell them why we think that's --
14 MEMBER SKILLMAN: I do not have --
15 CO-CHAIR BLEY: -- I kind of suspect I 16 could throw a couple in, but almost all of them could 17 be reduced to what they have except for the thing you 18 were talking about.
19 MEMBER SKILLMAN: Yes. No, I don't have 20 one beyond that, Dennis.
21 CO-CHAIR BLEY: Okay.
22 MEMBER SKILLMAN: Yes, I agree. I agree.
23 CO-CHAIR BLEY: I just didn't want to 24 leave them with an assignment that had no answer.
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109 1 to give --
2 CO-CHAIR BLEY: Not that we can give you 3 assignments --
4 (Simultaneous speaking.)
5 MEMBER SKILLMAN: Yes. No, but I'm not 6 trying to give them raspberries, either. I'm not 7 trying to hassle them. I am --
8 CO-CHAIR BLEY: No, I was just trying to 9 be --
10 (Simultaneous speaking.)
11 MEMBER SKILLMAN: Very sensitive to the 12 module and the crane, that coupling. Okay.
13 MR. BOWMAN: All right. So a little bit 14 of background about the important human actions.
15 We've talked about what they are, but I'm going to 16 tell you when we use them. This is a bit of a 17 simplification, but I'm an operator; I like simpler 18 answers better than more complex ones.
19 We categorized the important human actions 20 of the three major design -- beyond-design-basis 21 accident events. The first is a containment bypass 22 event, which is -- could either be a LOCA outside of 23 containment, un-isolable in either -- on CVCS, for 24 example, would be a great example, or you could have 25 a steam generator tube failure in combination with an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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110 1 un-isolable stem break, which would also force you to 2 lose inventory out of the -- outside of the module.
3 That's really what a containment bypass event is. And 4 in that case we need to add water using the CVCS 5 system to the reactor coolant system in order to 6 address that. Again, beyond-design-basis.
7 The second is a failure of ECCS where 8 either all of the reactor vent valves or all of the 9 reactor re-cert valves fail to open. So this isn't a 10 normal single-failure ECCS failure. This is a -- all 11 three -- there's three vent valves on top of the 12 system that are on top of the reactor coolant system 13 that are part of the ECCS system. All three of those 14 have to fail to open in this case.
15 MEMBER CORRADINI: And either that or --
16 (Simultaneous speaking.)
17 MR. BOWMAN: Or the reactor re-cert valve 18 -- both reactor re-cert valves have to fail. Again, 19 beyond-design-basis failure ECCS.
20 And the third is a complete failure of the 21 decay heat removal system. That means the whole 22 system, all trains are failed and both reactor safety 23 valves failed to open. In this case you have no way 24 to remove heat. So in that case you actually -- you 25 just use the containment flood system to add water NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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111 1 outside of containment in order to provide a coupling 2 of the reactor coolant system with the open heat sync 3 to cool down the reactor.
4 So what's important about that --
5 MEMBER CORRADINI: Sorry, but for all 6 three of these you require -- back to the -- my 7 question about the two actions, either CFDS or CVCS 8 must be actuated to satisfy --
9 MR. BOWMAN: Right.
10 MEMBER CORRADINI: -- to get around it?
11 MR. BOWMAN: I'll go back to that. So 12 when -- and if you would bypass on that, you can 13 actually use either the containment flood action or 14 the CVCS action to address it.
15 In the ECCS failure the only thing that's 16 successful --
17 MEMBER CORRADINI: Is CVCS?
18 MR. BOWMAN: -- is the CVCS. And in the 19 last one I talked about, the failure of decay heat 20 removal and the reactor safety valves, only the 21 containment flood system is accessible.
22 So both of those important human actions 23 were sampled by the staffing plan validation. I'll 24 talk a little bit more about what staffing plan 25 validation was in a minute.
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112 1 And then all of the human actions that 2 were performed from the main control room assumed in 3 the PRA were sampled during the integrative system 4 validation. That's the later testing which was 5 completed. We looked at all seven of those actions 6 and did those -- not all seven. We didn't do the 7 local action. All the one from the control room were 8 sampled during the integrated system validation.
9 CO-CHAIR BLEY: I want to ask you a 10 question because it wasn't transparent to me either in 11 the DCD or in the SER. To me. It might be clear to 12 everyone else. The ISV, the integrated system 13 validation, and the SPV, the staffing plan validation, 14 both seem to be key to many open items that I saw.
15 Can you explain the difference between those two?
16 MR. BOWMAN: I will get into those in just 17 a minute. Hopefully that will explain your -- answer 18 your question. In fact, we'll talk about it now.
19 So talking about staffing and 20 qualification --
21 MEMBER BROWN: If I could interrupt for a 22 second. Go back. Go back a page. You say the IHAs 23 are utilized in three major beyond-design-basis 24 accident conditions, yet in -- and I'm trying to 25 correlate this with some words in Chapter 18 that says NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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113 1 you only have two IHAs.
2 MR. BOWMAN: Correct.
3 MEMBER BROWN: Two risk-important. And 4 that is relative to the un-isolate and initiate 5 injection of the inventory of the vessel using CVS --
6 CVCS system. The second one is to un-isolate and 7 initiate injection of inventory to the containment.
8 MR. BOWMAN: Correct.
9 MEMBER BROWN: And yet --
10 MR. BOWMAN: Two actions will cover these 11 three beyond-design-basis --
12 MEMBER BROWN: Is that --
13 MR. BOWMAN: So I'll walk --
14 MEMBER BROWN: I'm trying to get -- that's 15 what I'm trying to get is what's the --
16 (Simultaneous speaking.)
17 MR. BOWMAN: All go through it again. So 18 the containment bypass event can be addressed by 19 either using the -- adding water to the reactor 20 coolant system with CVCS or by using the CFDS. Either 21 one of those will work, because in these cases the 22 ECCS valves are open and your -- the water can come in 23 either from containment or into the reactor coolant 24 system.
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114 1 have to put water into the reactor coolant system.
2 The containment flood and drain system is not 3 effective in this case to prevent core damage. So you 4 have to put containment -- CVCS into the reactor 5 coolant system to mitigate this event.
6 And the third one, the complete failure of 7 decay heat removal, basically all of your heat removal 8 systems, you have to put water outside of -- outside 9 of the reactor coolant system in the containment 10 vessel in order to couple the core -- reactor coolant 11 system to the ultimate heat sink to address it.
12 So there are three events and there are 13 two actions we use to address all of them, just in 14 different combinations depending on the event.
15 MEMBER BROWN: Okay.
16 MR. BOWMAN: And then if you go back and 17 look at the GTGs, we have direction that gives the 18 operator which one to use under which event. So 19 although they're not event-based, they are symptom-20 based.
21 MEMBER BROWN: Okay. Thanks for the 22 connection.
23 MR. BOWMAN: Does that --
24 MEMBER BROWN: Yes. Yes. No, I --
25 MR. BOWMAN: Okay.
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115 1 MEMBER BROWN: -- I've been listening.
2 That's what I have read and all of a sudden I -- my --
3 I had two and just with -- burned it in my brain, 4 which is a very small brain these days.
5 MR. BOWMAN: All right. So staffing 6 qualification, again our staffing qualification was 7 based on the fact that we have no operator actions 8 required for design-basis events. The HSI provides 9 at-a-glance assessment of the plant conditions and 10 facilitates protection of the creating conditions and 11 one operator can have primary focus on maintaining and 12 monitoring a role during normal, abnormal and 13 emergency conditions. And that's the role described 14 in the Concept of Operations for RO-1.
15 So the results of SPV, I'll start with.
16 SPV verified that a NuScale plant can be operated --
17 CO-CHAIR BLEY: Say the words.
18 MR. BOWMAN: Staffing Plan Validation --
19 CO-CHAIR BLEY: Thank you.
20 MR. BOWMAN: -- verified the NuScale plant 21 can be operated safely and reliably from a single 22 control room by a contingent of three reactor 23 operators, three licensed reactor operators and three 24 licensed senior reactor operators. We do have a COL 25 action item that will determine the non-licensed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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116 1 operator staffing requirement.
2 CO-CHAIR BLEY: Okay. How are you going 3 at that?
4 MR. BOWMAN: We did model -- in both 5 staffing plan validation and integrated system 6 validation we modeled four non-licensed operators just 7 to allow those events to go on. We need to do a 8 separate assessment of some kind to determine how many 9 operators that will be, but that is a COL action. I 10 mean, they may ask us to do that for them, but --
11 CO-CHAIR BLEY: Okay.
12 MR. BOWMAN: -- that's something the need 13 to determine.
14 So our staffing plant validation was 15 performed in August of 2016. This -- I'm going to 16 talk about scope. This event, this staffing plan 17 validation consisted of two crews of five NuScale 18 operations staff. This is not a separate group. This 19 is a group of people we pulled from inside of our 20 organization, 10 people total. They were trained to 21 perform the tasks necessary to complete staffing plan 22 validation and they did not know the content or 23 sequence of any of the scenarios.
24 So the scenario tasks for staffing plan 25 validation were samples from the task analysis, which NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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117 1 is why I talked about it earlier, based on the 2 following attributes: We did task analysis and then 3 we evaluated them using human factors engineering 4 tools. So these are the attributes that we looked for 5 and sampled from. So it would be a high-risk task, 6 high-stress task. You can see the list there.
7 What we're after is -- a large workload 8 under a high-risk or high-stress condition is what we 9 were looking for when we did the sampling for staffing 10 plan validation.
11 CO-CHAIR BLEY: Just an aside, because I 12 was a little concerned about the human reliability 13 analysis so far down in the PRA. I'm trying to think 14 of when you did these different things. Did the 15 people doing the human reliability analysis in the PRA 16 have access to the thinking about what's high-stress, 17 all of the items on this list, as they did that work?
18 And if they didn't, I'm wondering if they shouldn't go 19 back and make sure they picked up things that the rest 20 of you thought of.
21 MR. BOWMAN: I'm not sure if one of our 22 PRA members are the line or not, but my understanding 23 of the HRA was -- consisted of is a very simple 24 model --
25 CO-CHAIR BLEY: Very simple?
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118 1 MR. BOWMAN: -- that allows -- that says 2 the first time an action appears in an event tree, 3 there would be a one in a thousand chance the operator 4 would fail. And then it goes down to one in a hundred 5 for two and it progresses down until you always fail 6 them.
7 CO-CHAIR BLEY: Okay. So I don't -- I 8 didn't need an answer to this, but if somebody from 9 the PRA group is on the line, one day maybe when we 10 come back with no open items, you can tell me how this 11 is going to be done in a less-simplistic way for the 12 final PRA before fuel load. And I hope that won't 13 just be saying that's up to the COL applicant.
14 Go ahead.
15 MEMBER SKILLMAN: I've got to --
16 CO-CHAIR BLEY: It's a separate thing. I 17 don't think we need to talk about it.
18 MEMBER SKILLMAN: I got to ask this 19 question: High-stress. I operated with a guy who 20 when things were really coming apart at the seams, he 21 was so lazy his automatic watch would stop.
22 (Laughter.)
23 MEMBER SKILLMAN: He did not get stressed 24 under any circumstances. And his DNA was just flat-25 lined. But he was a great operator. He never missed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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119 1 a beat, but he did not stress.
2 CO-CHAIR BLEY: You may have worked with 3 a guy like one I worked with. When it was as simplest 4 thing like a startup, he was completely stressed, 5 right?
6 MEMBER SKILLMAN: But my only point is --
7 CO-CHAIR BLEY: You have both kinds.
8 MEMBER SKILLMAN: -- what might be very 9 high-stress for me might be a non-item for Dr.
10 Ballinger. How do you identify what's high-stress?
11 MR. BOWMAN: Well, for this juncture where 12 we were at in the design, it was the subject matter 13 expert's job to identify if he thought the task was 14 high-risk.
15 MEMBER SKILLMAN: Fair enough. Okay.
16 MR. BOWMAN: And that's really what we do.
17 CO-CHAIR BLEY: Did he do any checking --
18 MR. BOWMAN: I have a story for you about 19 a person --
20 (Simultaneous speaking.)
21 MR. BOWMAN: Yes, we found also during 22 ISV, integrated system validation --
23 (Simultaneous speaking.)
24 CO-CHAIR BLEY: Did you see any change to 25 that during your simulator exercises that might say we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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120 1 didn't think this was high-stress, but everybody's 2 having trouble with it, or vice-versa?
3 MR. BOWMAN: It was actually probably 4 likely more towards the other -- what -- so what we 5 traditionally felt was high-stress, for example 6 accident mitigation, especially within the design, is 7 essentially not really all that stressful in the 8 NuScale design. Not so much the other way.
9 I mean, so the tasks that we sampled are 10 fairly obvious to you. Major accidents, beyond-11 design-basis accidents, fires. And the other side of 12 this is it wasn't just this sampling. They also had 13 to be not -- something you couldn't drop, right?
14 Something you couldn't stop doing. So you have to 15 respond to the fire. I can't stop responding to the 16 fire. A surveillance that's going on I might be able 17 to stop and move onto something else. So that really 18 shouldn't be part of our workload concerns. So we 19 look for fires. Medical conditions. A medical issue 20 in the plant. We sampled that.
21 CO-CHAIR BLEY: But that shouldn't be part 22 of our workload concern, but when you read lots of 23 incident reports --
24 MR. BOWMAN: Sure.
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121 1 that sort of routine stuff and don't come around in 2 time sometimes.
3 MR. BOWMAN: I have personal experience, 4 so that was why we --
5 (Laughter.)
6 CO-CHAIR BLEY: Don't we all? Okay. So 7 you do have it? Okay.
8 MR. BOWMAN: Absolutely.
9 MEMBER CORRADINI: So must to make sure I 10 understand. So you went through all the Chapter 15 11 accidents at least --
12 MR. BOWMAN: Yes.
13 MEMBER CORRADINI: -- and see how they 14 kind of fell out relative to these attributes?
15 MR. BOWMAN: Correct. And we sampled 16 quite a few Chapter 15 accidents during the staffing 17 plan validation.
18 MEMBER CORRADINI: Okay. That's fine.
19 My next question is since this is an area 20 that we've been talking about that I have -- I am 21 learning; I'm not -- I can't criticize or ask 22 questions about that much -- I'm curious about how did 23 you -- for the analysis or -- for the simulation of 24 the Chapter 15 accidents you were using RELAP and 25 NRELAP?
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122 1 MR. BOWMAN: Correct.
2 MEMBER CORRADINI: Okay.
3 MR. BOWMAN: The simulator model, as you 4 -- so this was after you guys visited, so it would 5 have been a more developed version of the same 6 simulator that you guys saw.
7 MEMBER CORRADINI: Okay. Fine. Thank 8 you.
9 MR. BOWMAN: Okay. So these tasks, we 10 took the sampling of tasks, we grouped them into three 11 very challenging scenarios and each crew, these two 12 crews performed all three scenarios. So these 13 scenarios -- I would have some examples for you what 14 we put into them, but there was -- if any of you are 15 familiar with the initial license training exam, it 16 would look two or three of them stacked together at 17 times and how much was going on in these scenarios.
18 We intended them to be very challenging high-workload 19 scenarios to prove that the design could be operated 20 with the operators we had.
21 MEMBER CORRADINI: And so I'm sorry to ask 22 this question. So let me make sure I understand. So 23 you had the dozen units, modules, whatever you call 24 them, and something would happen here and something --
25 okay. That's what I wanted to check.
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123 1 MR. BOWMAN: Right. We would have 2 multiple events on multiple units in a single 3 scenario.
4 MEMBER CORRADINI: Okay.
5 MR. BOWMAN: Scenarios generally lasted 6 about less than two hours and they would run across --
7 for example, they might run across a Chapter 15 event 8 and a design-basis event and then maybe a multi-unit 9 event as well.
10 MEMBER CORRADINI: Thank you.
11 MR. BOWMAN: So our testing methodology 12 was based on what we anticipated doing for integrated 13 system validation testing, so that meant that we took 14 -- we had observers in the room. We collected their 15 feedback. We collected feedback from the operators 16 themselves. We collected task times, which means if 17 there was a timed task within that evolution, we would 18 take a stopwatch and watch the guy from start to 19 finish and see how long it took him. And our SPV 20 again successfully demonstrated that NuScale design 21 could be safely operated by the proposed staff.
22 So after SPV we did some more work on 23 human system interface design. Just a little bit of 24 background about it. We have a multi-faceted team, so 25 we -- I talked a lot about the operators we used. We NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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124 1 also have human factors engineers that do work for us, 2 too. So we're -- their input is important, but we are 3 led by the operations group in terms of doing this 4 human factors engineering work. It sounds a little 5 strange, but that's the way we did it.
6 MEMBER CORRADINI: Doesn't sound strange 7 to me.
8 MR. BOWMAN: I mean, my background, I 9 don't have any human factors engineering background 10 and I'm in charge of our human factors engineers. But 11 they've been a great resource and they've been a great 12 fantastic input to us.
13 So we went through and --
14 MEMBER SKILLMAN: Let me ask this: The 15 two groups of five you chose, two groups of five --
16 MR. BOWMAN: Yes.
17 MEMBER SKILLMAN: -- what gives you 18 confidence that those individuals are representative 19 of a future licensee's individuals?
20 MR. TOVAR: So that wasn't really the 21 intent of the staffing plan validation. That was more 22 the intent of the integrated system validation, which 23 is a more comprehensive test. For this we wanted to 24 show that a crew of competent licensed operators; and 25 that's what they simulated, would be capable of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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125 1 operating the plant in a very challenging high-2 workload situation.
3 MEMBER SKILLMAN: This is kind of a proof 4 of principle as opposed to --
5 MR. TOVAR: Exactly.
6 MEMBER SKILLMAN: -- checking out a future 7 licensee? Understand.
8 MR. TOVAR: Okay.
9 MR. BOWMAN: Okay. Yes, thanks.
10 MR. BOWMAN: Okay. So here's an example 11 screen we have up. And this is actually what we 12 termed the process library, so when you ask about your 13 electronic procedures, this is the screen that does 14 our electronic procedures for us.
15 On the left-hand side you can see a column 16 with a menu list of various procedures that you're 17 allowed to go access. On the very right-hand column 18 you have a progress bar and that progress bar shows 19 you all the active procedures anywhere in all 12 units 20 at any time. So anybody in the control room can 21 access that information on the right-hand bar and tell 22 every activity that's going on in the control room at 23 the time. And he can also go click on it, select it 24 and it will pull up into his process library and he 25 can see live where that person is at.
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126 1 CO-CHAIR BLEY: Any time they hit a point 2 where they trip the unit and put it in its safe mode, 3 does this disappear or are they still in the middle of 4 those procedures?
5 MR. BOWMAN: So I show you this as a 6 single example. It would probably be good to have a 7 layout. You've seen the layout. But we have three 8 work stations --
9 CO-CHAIR BLEY: It's been a long time.
10 MR. BOWMAN: -- we have three work 11 stations. There's four screens in front of the 12 operator. Each operator is at their work station.
13 There's also a large horseshoe that has all 12 units 14 mimicked up in front of it. So when a unit does for 15 example a reactor trip there's many indications that 16 come in to tell the operator this has happened.
17 One is there's a large overview screen 18 that provides an indication that the reactor is 19 tripped and whether or not that trip has been 20 successful or not. There's a series of four screens 21 below it in the horseshoe that also come out of sleep 22 mode and wake up and show the status of for example 23 our critical safety functions and -- but there's lots 24 of ways for him to know that has happened. This stays 25 up and available at all times. Or I shouldn't say at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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127 1 all times, but it doesn't change status because of 2 that --
3 CO-CHAIR BLEY: Okay.
4 MR. BOWMAN: -- change in the status of 5 the unit.
6 MEMBER BROWN: If a screen pops up, how 7 long before it disappears?
8 MR. BOWMAN: As long as there is an 9 actuated safety function those screens stay up, right?
10 PARTICIPANT: Right.
11 MEMBER BROWN: But if something else 12 happens and you need it -- so it disappears and 13 something else comes in in its place?
14 CO-CHAIR BLEY: Or they stack up?
15 MR. FLAMAND: So the critical safety 16 function display isn't meant to be moved. It's pretty 17 much got an area so that way the operator always know 18 to go look there. At the work station you're able to 19 maneuver your screens however the user wants them.
20 And so --
21 MEMBER BROWN: But they don't change 22 without you changing them?
23 MR. FLAMAND: Not at your work station.
24 MR. BOWMAN: Correct.
25 MEMBER BROWN: Let me give you a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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128 1 frustration. How many times have I been doing 2 something, had to go pull something else up and I have 3 to make it so small I can't read it or you cover up 4 what you're doing, you can't remember what you read on 5 the other page and you're snapping back and forth, and 6 by that time, when you're my age, you've forgotten 7 what you're looking for in the first place.
8 MEMBER CORRADINI: They're not that --
9 MEMBER BROWN: Huh?
10 MEMBER CORRADINI: They're not going 11 through --
12 (Laughter.)
13 MR. FLAMAND: That's my answer.
14 MR. BOWMAN: We've addressed many of those 15 things. For example, the font sizes are limited based 16 on the screen, a human factors engineering principle.
17 You can't actually -- they have to be a certain size 18 to be readable at all times. We don't shrink down 19 into windows for any screens or fall full screen 20 systems, but you can go through and select what 21 screens you want up. And operators, as we went 22 through the integrated system validation, found they 23 wanted certain sequences of screens up, and that's 24 what they like, depending on what work they were 25 doing.
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129 1 MEMBER CORRADINI: Are some of these back 2 up on paper, pull up paper? I think they asked the 3 same question about --
4 MR. BOWMAN: Some of the procedures you 5 have paper backup when appropriate.
6 MEMBER MARCH-LEUBA: Some or all?
7 MR. BOWMAN: Some. Not all.
8 CO-CHAIR BLEY: They're --
9 MR. BOWMAN: You got to --
10 CO-CHAIR BLEY: The DCA says some.
11 MR. BOWMAN: Yes, so the -- go ahead.
12 MR. FLAMAND: I was just going to say one 13 of the things that we showed -- because we did have 14 operators use backup procedure sets. And they were 15 still electronic. They were just on tablets. So then 16 we could have whole sets of procedures on an 17 electronic tablet. And the nice thing about that is 18 then the same feel and look at the operator would see 19 in an interface is what they see on the tablet, same 20 place keeping, same -- so that way it wasn't a 21 jarring. They moved from one --
22 (Simultaneous speaking.)
23 MEMBER CORRADINI: -- a three-ring binder 24 is a tablet, an external --
25 (Simultaneous speaking.)
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130 1 MR. FLAMAND: Correct. Yes. And now you 2 can have 10 of those and have your entire procedure 3 set.
4 MEMBER MARCH-LEUBA: The failure that 5 happens here is reproduced on the tablet? That's what 6 you're saying?
7 MR. FLAMAND: Say that again, please?
8 MEMBER MARCH-LEUBA: The same failure of 9 your software that is happening on this screen is 10 reproduced on the tablet?
11 MR. FLAMAND; Well, the tablet is not 12 connected to the HSI. They're separate.
13 MEMBER MARCH-LEUBA: But it's a logic 14 failure where the programmers messed up?
15 MR. BOWMAN: Well, we do have --
16 CO-CHAIR BLEY: I mean, if they have the 17 procedure -- and if it's a procedure, it can be in 18 black and white or it can --
19 (Simultaneous speaking.)
20 MEMBER MARCH-LEUBA: No, it's a failure to 21 implement it. I mean, it's a quality control --
22 MR. BOWMAN: But for example -- I'll give 23 you an example: We do have a paper procedure 24 available. The paper procedure is the loss of I&C, 25 because if you lose that, you don't have access to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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131 1 this. So where appropriate we do have paper backup 2 procedures.
3 MEMBER MARCH-LEUBA: Why not have them 4 all on paper? It's just been too -- a little 5 obstinate.
6 MEMBER BROWN: What did you call these?
7 The tablets, whatever the latest winkle is for these 8 little doohickeys?
9 MR. FLAMAND: Yes.
10 MEMBER BROWN: You can tell I don't have 11 one. They're not really paper?
12 MEMBER MARCH-LEUBA: Similar to your 13 phone.
14 MEMBER BROWN: 2002 cell phone. It works.
15 They're not paper? There's no paper is what you're 16 telling me. They're written in tablets?
17 MR. BOWMAN: No, no. There is some paper 18 where appropriate.
19 MEMBER BROWN: Oh, okay. All right.
20 MR. BOWMAN: For example, the loss of 21 I&C --
22 MEMBER BROWN: I got lost in that 23 iteration back and forth here with the --
24 MR. BOWMAN: For example, the loss of I&C 25 procedure is on paper because when you lose I&C, you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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132 1 don't have access to these procedures in the HSI 2 anymore. So it's then appropriate to have --
3 MEMBER BROWN: Yes, but you've got the 4 tablet.
5 MR. BOWMAN: We could use the tablet, but 6 in this case it might be easier just to turn around 7 and grab the paper procedure.
8 MEMBER BROWN: It's much easier to look at 9 pages than turning back and forth.
10 CO-CHAIR BLEY: Depends your generation, 11 right?
12 MR. FLAMAND: Depends on your generation.
13 CO-CHAIR BLEY: But when you go to the 14 tablet wherein the big board, the normal system it 15 says as the following three functions achieved and it 16 will tell you yes, they are. You don't have that on 17 the tablet, correct? You have to go find it yourself?
18 MR. FLAMAND: You're not communicating 19 with the HSI, so you --
20 CO-CHAIR BLEY: At all?
21 MR. FLAMAND: So for instance; and Doug 22 talked about this earlier, one of the reasons of the 23 STA to go look for things separate was, one, to try to 24 address the issue of a problem on the HSI, a software 25 problem. That's another backup. Another could be if NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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133 1 all the -- if the system's gone, I have a way to still 2 address the critical safety functions manually. And 3 then of course there is a paper version of the 4 critical safety -- of the emergency operating 5 procedures. So that would be one of the few set of 6 paper procedures available.
7 CO-CHAIR BLEY: in your test programs have 8 you run at least some kind of simulation on every 9 emergency operating procedure?
10 MR. BOWMAN: We have gone through -- we 11 did not get through every branch in the simulator. We 12 have on tabletops on everything in the emergency ops.
13 Every branch --
14 CO-CHAIR BLEY: Have you exercised them 15 all? The reason I ask is, out in the operating fleet, 16 we've done a pretty good job of that. Somewhere 17 people have exercised all of them. And then, we came 18 up with the shutdown emergency procedures and thought 19 we were really smart. And I was doing some work with 20 one of the plants that had done that, and we started 21 running events, and procedures had all kinds of dead-22 ends in them that the guy who wrote them never thought 23 of. If you don't exercise them, you don't know 24 they're going to work, even for the things you've 25 thought of, let alone the things that we talked about.
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134 1 MR. BOWMAN: So, my background was you had 2 to go through every branch of the procedure to 3 validate it. So, that effort, the open item in 4 Chapter 13 about validation of the GTGs --
5 CO-CHAIR BLEY: So, you will do that?
6 MR. BOWMAN: Yes.
7 MEMBER CORRADINI: What open item is that?
8 MR. BOWMAN: The Chapter 13 one about the 9 validation of --
10 MEMBER CORRADINI: The 13.5.1?
11 MR. BOWMAN: -- the Generic Technical 12 Guidelines. I think it's 13.5.1, yes.
13 MEMBER CORRADINI: Okay, fine.
14 MR. BOWMAN: Yes.
15 MEMBER CORRADINI: All right. Thank you.
16 Thanks.
17 MR. BOWMAN: That's what we need to do.
18 CO-CHAIR BLEY: Okay. And that part of 19 testing you have not done?
20 MR. BOWMAN: We've actually completed it.
21 We just haven't written the report on it yet.
22 CO-CHAIR BLEY: Oh, okay. So, that's --
23 MR. BOWMAN: So, in Integrated System 24 Validation, we were able to complete a large majority 25 of that work of getting through the emergency NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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135 1 operating procedures. So, we took credit for that.
2 CO-CHAIR BLEY: And then, you had a few 3 more?
4 MR. BOWMAN: We had a few more that we had 5 to clean up.
6 CO-CHAIR BLEY: Okay.
7 MR. BOWMAN: Okay. So, human factors 8 verification and validation. This is where we get 9 into that Integrated System Validation. We all talk 10 about Integrated System Validation as V&V, but there's 11 several other elements to V&V and human factors 12 engineering design.
13 Design verification would be one of those.
14 So, those activities were conducted between August of 15 2017 and July of 2018. And then, we did actual 16 Integrated System Validation testing performed with 17 the crews from July 23rd, 2018 through September 6th, 18 2018.
19 So, we had three crews of operators. They 20 were selected to participate in the training program 21 to qualify them as ISV Certified Training Operators.
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136 1 training was done for the operators. These people 2 were brought in mostly from outside of our company and 3 were independent from our HSI design group.
4 MR. FLAMAND: I'd just like to make one 5 point since we're talking about this topic. One of 6 the specific things we were looking for, when we 7 brought this group of people in, is who would be the 8 operators, what would be the dynamics of operators at 9 a future NuScale plant. So, there was a large cross-10 section of experience, you know, younger experience.
11 And that was on purpose, so that we could get a wide 12 range of who we thought -- you know, they might get a 13 license operator upgrade or you might get someone 14 through the Navy. And we had all of those kind of 15 backgrounds involved.
16 MR. BOWMAN: Yes, we had people directly 17 from engineering school, directly out of the Navy.
18 Some had been non-licensed operators at other 19 facilities. Some had been licensed operators at other 20 facilities. So, we had a mix of just everybody we 21 thought would be in a program.
22 MEMBER SKILLMAN: Was there a proportion 23 of those that washed out?
24 MR. BOWMAN: We did not wash anybody out.
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137 1 staff, and in some cases some chose to take other jobs 2 along the way.
3 MEMBER SKILLMAN: Okay.
4 MR. TOVAR: I'll correct that. We did --
5 MR. BOWMAN: Oh, I'm sorry, yes.
6 MR. TOVAR: We did terminate two 7 individuals, and then, we had additional individuals 8 that left on their own choice.
9 MEMBER SKILLMAN: Thank you.
10 MR. TOVAR: Yes.
11 MR. BOWMAN: So, the overall conclusion of 12 Integrated System Validation testing, although this is 13 staff a draft topic, is that NuScale's control and 14 design staffing plan supports safe operation of a 15 NuScale plant.
16 So, the V&V RSR is an open item from the 17 Chapter 18 SER. It's more than one open item. It's 18 many open items in Chapter 18.
19 The V&V RSR, Results Summary Report, will 20 be submitted by the end of March 2019. We completed 21 two trials for 12 scenarios. So, we had three 22 different crews, and we cycled those crews through 23 these two different trials. So, we rotated them 24 through, and all the crews saw some portion of the 25 testing.
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138 1 During those 24 total scenarios, we 2 collected 8,000 total data points. We created and 3 wrote 32 human engineering discrepancies. We have 4 three categories. We had no Priority 1s, nine 5 Priority 2s, and 23 Priority 3s.
6 I'll let Ryan talk quickly about 7 priorities.
8 MR. FLAMAND: Yes, what does that mean to 9 us? A Priority 1 would be a safety-significant-type 10 action. So, if we found something that potentially an 11 important action couldn't be performed, that would 12 probably fall under that priority. Priority 2 is more 13 operation of the plant or operability of equipment.
14 Priority 3 is basically, hey, it doesn't fall into 15 safety, it doesn't really fall into operation of the 16 plant.
17 So, you can see we had a lot of Priority 18 3s. Those are things that were typically we saw 19 performance that could be better, but it wouldn't have 20 affected the plant safety or operations.
21 CO-CHAIR BLEY: So, the HEDs, the human 22 engineering discrepancies, they are things, when you 23 did the testing, you said, "That isn't what we 24 expected," or something like that?
25 MR. FLAMAND: Right.
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139 1 CO-CHAIR BLEY: Is that where they came 2 from? I didn't see that well laid out, where they 3 came from.
4 MR. BOWMAN: And you probably really won't 5 see them until the Results Summary Report come out.
6 Yes, most of our stuff was, most of the 7 items were gathered as -- would have started out 8 potentially as feedback from the operators or from the 9 observers.
10 CO-CHAIR BLEY: Okay. So, maybe not the 11 testing itself, but the operator said, "This is 12 something that was" --
13 MR. BOWMAN: It could have been a testing 14 problem as well.
15 CO-CHAIR BLEY: Okay.
16 MR. BOWMAN: But, yes, most of what we 17 wrote up as human engineering discrepancies are: this 18 procedure step doesn't work the way I like it to work.
19 CO-CHAIR BLEY: Okay. So, they were kind 20 of reports from the people trying to use them?
21 MR. BOWMAN: Or this human-system 22 interface, I don't like the way this is laid out. I'd 23 rather have it laid out this way.
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140 1 MR. BOWMAN: We had to fix before we 2 finished the RSR.
3 CO-CHAIR BLEY: Okay. And fixing was a 4 design change usually or --
5 MR. BOWMAN: Results Summary Report.
6 It could be a design change. It could be 7 a procedure change. It could be a human-system 8 interface change.
9 CO-CHAIR BLEY: Okay. If the procedure 10 wasn't working right, yes. Okay.
11 MR. BOWMAN: You could have even 12 potentially addressed it as a training item.
13 CO-CHAIR BLEY: So, when we see -- is it 14 the report on the ISV --
15 MR. BOWMAN: Yes.
16 CO-CHAIR BLEY: -- where we'll see these 17 delineated --
18 MR. BOWMAN: That's correct.
19 CO-CHAIR BLEY: -- and what you did about 20 them?
21 MR. BOWMAN: Yes.
22 CO-CHAIR BLEY: Okay. And that will all 23 be reviewed by the staff by the time we get back 24 together on this. Okay. Thank you.
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141 1 on the primary side or on the secondary side?
2 MR. FLAMAND: I don't know if I really 3 categorize them primary or secondary.
4 MEMBER SKILLMAN: If they were over on the 5 reactor side or over on the steam plant auxiliary side 6 shooting a bogus signal into the primary?
7 MR. FLAMAND: No, they weren't really -- I 8 wouldn't categorize them quite that way. It was more, 9 a good example might be someone is using a startup 10 procedure. And this is just an example. But they had 11 maybe a wording issue or there was some clarification 12 that the crew got through the scenario, but it just 13 wasn't --
14 MEMBER SKILLMAN: Crisp?
15 MR. FLAMAND: -- efficient and crisp and 16 clean. So, it's definitely something we wanted to 17 fix. So, at the end of the day, the crew was able to 18 get through startup, and then, we showed that, but 19 there might be a piece to that that there was 20 discussion on, or whatever.
21 And so, I do want to say, too, during this 22 testing there is acceptance criteria. So, there's 23 clean acceptance criteria as part of the test, and 24 then, there's what we called performance measures.
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142 1 performance measure. That could have been a way an 2 HED is generated.
3 The participants get asked certain 4 questions. They might say, "Hey, my workload is 5 really high, and that might have triggered us." So, 6 maybe we saw nothing, you know, like it didn't really 7 happen. I would say we pretty much saw everything.
8 But, potentially, they could have reported a high 9 workload, which, then, generated us to figure out, 10 okay, why did that happen; where did that come up?
11 Maybe it was because this procedure wasn't written 12 well, and that's how we're going to fix it.
13 MEMBER SKILLMAN: I asked the question 14 because it's hard to be operating at, say, 85 percent 15 of power unless your secondary plant is absorbing 85 16 percent power by the reactor. So, sometimes you say 17 the plant is not functioning, and the question is, 18 which part of the plant is not functioning? Is it on 19 the reactor side or condensate feedwater, or, you 20 know, the turbine? What's going on over there? So, 21 it takes the two.
22 MR. TOVAR: Yes, I think most of the human 23 engineering deficiencies that we saw --
24 MEMBER SKILLMAN: Over on the primary side 25 probably?
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143 1 MR. TOVAR: Well, like were related to the 2 human-system interface. Like, for example, the 3 notification system for the alarms, cautions, and 4 notifications. So, that would cross boundaries. If 5 a caution came in and we didn't have an audio sound 6 that was supposed to be there, or it was inconsistent, 7 that may be like a human engineering deficiency, but 8 it would cross boundaries, depending on where the 9 caution came from. But it was part of the human-10 system interface and not really a plant-generated 11 issue.
12 MEMBER SKILLMAN: Okay. Thank you.
13 MR. TOVAR: I did want to just throw out 14 a couple items here. Cleanup. We said NRELAP was 15 used in the simulator. It is actually RELAP. So, I 16 just wanted to do that correction. We used RELAP5-3D, 17 Studsvik S3R, Jay TOP, Merit, and Jay ELECTRIC as our 18 modeling software.
19 One other thing we talked about was having 20 data lost to the operators and getting confusing. In 21 the Integrated System Validation, we didn't run into 22 that as an issue with the operators losing data. If 23 you had an overhead view of what the operator station 24 looked like, they have four separate computer screens 25 that they can put data on. And so, they became very NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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144 1 proficient at putting data up and accessing the data 2 that they needed.
3 That was it.
4 MR. BOWMAN: A point on this slide, the 5 important human actions integrated with some 6 validation were completed with 70 percent margin of 7 the time allowed; i.e., it took us 25 percent of the 8 required time to complete the action on average.
9 MEMBER CORRADINI: So, these are the seven 10 actions, five --
11 MR. BOWMAN: Only the two important human 12 actions.
13 MEMBER CORRADINI: Oh, oh, oh, excuse me.
14 The two that would solve the three -- okay.
15 MR. BOWMAN: That's correct.
16 Okay. Design implementation --
17 MEMBER SKILLMAN: Wait, wait, wait.
18 MR. BOWMAN: Go ahead.
19 MEMBER SKILLMAN: When you communicate 20 that, that the operators completed those actions 21 within 25 percent of 100 percent of the time that was 22 necessary or required, is that telling you something 23 about your design other than there's a lot of margin 24 in the time that is allowed for the operator actions?
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145 1 listened to?
2 MR. BOWMAN: That's all we're trying to 3 communicate, is the fact that we have lots of time to 4 complete those important human actions as well.
5 MEMBER SKILLMAN: Okay. Thank you.
6 CO-CHAIR BLEY: Can you be specific about 7 margin to what? Your expectation or margin to damage 8 or?
9 MR. BOWMAN: So, our PRA group did 10 analysis for us that shows how long from the time the 11 operator sees the queue to take that action until he 12 needs to be done to be successful.
13 MEMBER CORRADINI: But I think what he's 14 asking is, what state variable goes awry that creates 15 the end time? In other words, if the time is two 16 minutes, is it to get to, essentially, the fuel design 17 criteria?
18 MR. BOWMAN: The best thing to do would be 19 to walk you through an example. So, in a bypass LOCA, 20 containment bypass LOCA, you have 90 minutes to get 21 CVCS in service. That starts at a time whenever the 22 operator --
23 MEMBER CORRADINI: We can do it later.
24 MR. BOWMAN: We can do it later. Sorry.
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146 1 remember that for the closed session.
2 MR. BOWMAN: We'll answer your question 3 later. I hope this will answer your question.
4 MEMBER SKILLMAN: You said "minutes," not 5 "seconds," right?
6 CO-CHAIR BLEY: We'll wait for the closed 7 session.
8 MR. BOWMAN: I said -- no, I might have 9 said "seconds". I don't know.
10 (Laughter.)
11 MEMBER CORRADINI: He didn't say anything.
12 MEMBER SKILLMAN: He didn't say that.
13 (Laughter.)
14 MR. BOWMAN: All right. We're pretty 15 close anyway. So, let's finish this up.
16 Design implementation. So, this is an 17 activity that happens in the future, right? Design 18 implementation takes the design. Once we're done, we 19 have a DCA-committed design, an approved design, and 20 this will track the changes that are done to the 21 design between what we did and what the COL eventually 22 implements. And there is ITAAC that will confirm 23 that.
24 So, COL items, there are three COL items 25 in Chapter 18, one for the human performance NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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147 1 monitoring program, which is essentially a program 2 that looks at how the operators are functioning within 3 the HSI and reports on their performance, then takes 4 corrective actions.
5 Also, one we already discussed about the 6 non-licensed operator staffing.
7 And then, the training program and 8 procedure development for the COL are addressed in 9 Chapter 13, which we have previously covered.
10 Open items. So, there are a total of 23 11 open items in the SER. And as you asked earlier, 19 12 of those we believe will be closed by the submission 13 of the V&V Results Summary Report. One will be closed 14 when we complete a revision to the Human-System 15 Interface Style Guide after the RSR is completed, the 16 Results Summary Report is completed. One will be 17 closed by the completion of the Chapter 7, 15, and 19 18 SERs. So, we're tied into those three chapters.
19 And then, the closure of the remaining two 20 items are actively being pursued between the NRC and 21 NuScale staff. One of them is related to the main 22 control room and human-system interface ITAAC and its 23 method of closure, and the second one is related to 24 the remote shutdown station ITAAC.
25 And that's all I've got to discuss. Any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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148 1 other questions?
2 CO-CHAIR BLEY: Nothing from the 3 Committee?
4 MEMBER BROWN: Yes.
5 CO-CHAIR BLEY: Well, talk.
6 MEMBER BROWN: No, I thought you had 7 something.
8 CO-CHAIR BLEY: I was going to send us on 9 a break. Are you interfering with our break?
10 (Laughter.)
11 MEMBER BROWN: Do you want me to ask my 12 question before the break?
13 CO-CHAIR BLEY: If you want to ask it.
14 MEMBER BROWN: Oh, okay. I just wanted to 15 backtrack to the alarm avalanche routine where you 16 talk about your alarms, cautions, and notices. And I 17 went back through Chapter 7, and it talks about 18 they're generated by the MCS and, then, presented to 19 the operators in the main control room and remote 20 shutdown station.
21 But there's nothing in either of the 22 chapters which talks about how they're aggregated, 23 what alarms. You talked about you all did an analysis 24 of the alarms, but you didn't want -- unimportant 25 alarms, but they're all important -- but critical NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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149 1 alarms to be masked by what I would call the trip-2 less-important or less-critical alarms. But there's 3 nothing listing it. Who is going to develop that list 4 and where is it? Are they specified now? Are they 5 delineated or required by the DCA? It didn't sound 6 like -- I could find no listing in any chapter of 7 alarm aggregation. I only looked at three, the ones 8 that had instrumentation in them.
9 MR. BOWMAN: We did do that alarm 10 aggregation for the Integrated System Validation. So, 11 we have those set of alarms that we built for 12 Integrated System Validation, based off of those 13 design documents. You know, what was put as an alarm, 14 what was put as a caution, what was put as a notice 15 within that model, meaning the control --
16 MEMBER BROWN: But how are they displayed 17 for aggregation purposes? I mean, are the critical 18 alarms displayed so the guy can see them, and the ones 19 that are yellow are on some other panel somewhere 20 where he doesn't have to look at them?
21 MR. BOWMAN: Every screen, if you look at 22 this, the top of the screen --
23 MEMBER BROWN: My God, that's terrible.
24 (Laughter.)
25 You just lost it right there.
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150 1 MR. BOWMAN: So, up at the top there's a 2 red stop sign at the top left.
3 MEMBER BROWN: I can see the little red 4 thing up in the upper right-hand corner.
5 MR. BOWMAN: Yes, but hold on.
6 MEMBER BROWN: I got it.
7 MR. BOWMAN: So, this one is on every 8 screen. This top bar is on every screen. So, no 9 matter what screen you have up, you always have an 10 indication of how many alarms are happening. And 11 again, the alarm --
12 MEMBER BROWN: That tells you how many?
13 MR. BOWMAN: That tells you how many also, 14 yes.
15 CO-CHAIR BLEY: Well, that's very 16 intelligible. I'm not cutting any slack here.
17 MR. TOVAR: It would be much, much more 18 clear when you get into the actual control room to see 19 this. It's displayed in multiple locations, but it's 20 very clear to the operations individuals how many 21 alarms they have, how many have cleared.
22 CO-CHAIR BLEY: If you want to talk about 23 this more, let's wait until later.
24 MEMBER BROWN: This is for the closed 25 session?
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151 1 CO-CHAIR BLEY: Yes, there's some things 2 I want to tell you, too, in the closed session.
3 MEMBER MARCH-LEUBA: Give me 20 seconds.
4 I talk very fast.
5 CO-CHAIR BLEY: We know that.
6 (Laughter.)
7 MEMBER MARCH-LEUBA: Is it fair to say 8 that your validation of your human operations is based 9 on this alarm aggregation? And if you change the 10 aggregation, you will have to rerun it?
11 MR. BOWMAN: We would have to evaluate it.
12 I don't know that we would have to rerun it. It would 13 depend on whether or not it impacted the results of 14 ISV.
15 MEMBER MARCH-LEUBA: Okay. So, you plan 16 to use it to validate?
17 MR. BOWMAN: Yes.
18 MEMBER MARCH-LEUBA: Just as well as you 19 did with the hours?
20 (Laughter.)
21 CO-CHAIR BLEY: Okay. At this point --
22 MEMBER BROWN: Just one observation, so 23 they can think about it while we break.
24 CO-CHAIR BLEY: You bet.
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152 1 who are nuclear operators, we spent a lot of time 2 trying to make sure that there was nothing showing up 3 red that didn't have to be paid attention to 4 immediately. And the warnings were pretty much 5 sublimated. They were kind of -- I won't say "out of 6 mind," but they were out of -- we paid a lot of 7 attention to that. And that's why I asked the 8 question. I just look for some way, a visual way for 9 the operators not to be distracted; that's all.
10 CO-CHAIR BLEY: We can come back and --
11 MEMBER BROWN: That's my thought process.
12 That's all I wanted to get across during the break.
13 CO-CHAIR BLEY: That was a hammer. We're 14 on break until 3:20.
15 (Whereupon, the foregoing matter went off 16 the record at 3:03 p.m. and went back on the record at 17 3:21 p.m.)
18 CO-CHAIR BLEY: This SER feels to me like 19 it's all process, meeting criteria from this NUREG, 20 that NUREG. And it becomes very repetitious. It's 21 really hard to read. And the technical meat is hidden 22 under those things and never gets really brought out.
23 For example, there's no words that really 24 explain to a reader, or a regulator I would think, how 25 do the minimum staff actually control 12 reactors, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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153 1 why does it work? How does it work? Does it really 2 work?
3 So, we're meeting lots of criteria, but I 4 didn't see anything that really talked to the 5 technical issues. But I look forward to your 6 presentations, and we'll probably have some questions 7 as you go forward.
8 Prosanta, I'll turn it over to you.
9 MEMBER SKILLMAN: Dennis?
10 CO-CHAIR BLEY: Yes?
11 MEMBER SKILLMAN: Just an issue of admin 12 here. My version of the SE has "Official Use Only -
13 Proprietary Information" at the top of each page. So, 14 I'm wondering what environment we are in in this 15 meeting as we, if you will, dig into this issue. Is 16 this a proprietary session?
17 MR. SNODDERLY: This is Mike Snodderly 18 from the staff.
19 So, Dick, that's partly my fault. When 20 the staff first provides us the SE in a timely manner, 21 they also send it to NuScale for them to do their 22 proprietary designation. So, prior to that 23 designation, we call it "proprietary". So, that's why 24 it's labeled the way it is.
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154 1 with your question, and then, we'll ask NuScale or the 2 staff to step in if they feel like you're going into 3 an area, and we'll do it during the closed session.
4 Does that sound fair?
5 CO-CHAIR BLEY: Yes, as long as it's okay 6 with NuScale.
7 MR. SNODDERLY: Right. That's what I'm 8 saying. I think they'll stop us from saying anything 9 that --
10 CO-CHAIR BLEY: So, interrupt us if 11 anything --
12 MR. SNODDERLY: Say, "Let's cover this in 13 a closed session."
14 CO-CHAIR BLEY: I don't know where you 15 stand on this.
16 MR. SNODDERLY: That's the version you 17 have. That's the version that you guys --
18 CO-CHAIR BLEY: And it's proprietary 19 because at this point it hadn't been reviewed to 20 ensure --
21 MR. SNODDERLY: We're asking you to treat 22 it as such until the staff --
23 CO-CHAIR BLEY: -- that it's not 24 proprietary?
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155 1 chime-in here.
2 Again, let me introduce myself once again.
3 I'm Prosanta Chowdhury. I'm the Project Manager for 4 Chapter 18, the NuScale design certification 5 application review.
6 And the staff will present the Chapter 18 7 Safety Evaluation at this meeting. And this is the 8 phase 2 SER with Open Items.
9 To go back to your initial comment about 10 the voluminous SE, this SE will be streamlined. The 11 staff needed to document. We recognize the issue that 12 you brought up. The staff documented everything that 13 they needed to, so that they can go into the phase 14 with no open items to clean it up. So, in phase 5 15 you'll see --
16 CO-CHAIR BLEY: I look forward to phase 5.
17 MR. CHOWDHURY: Yes. So, I want to 18 clarify that.
19 Then, regarding the proprietary version, 20 we initially provide any SE to the applicant as 21 proprietary pending their verification of proprietary 22 information and any factual errors. Once we receive 23 confirmation that there is no proprietary, we list it 24 publicly, or if there is proprietary, redact it and 25 release it for the public.
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156 1 For Chapter 18 SE, a redacted version has 2 been released to the public. So, that portion does 3 not have proprietary marking on any page at all. And 4 both the ML numbers have been provided to ACRS staff.
5 So, maybe it's the timing issue that you 6 didn't get to have that in your system, but we do have 7 a redacted version for the purpose of this meeting.
8 In the proprietary version, we do have proprietary 9 information bracketed with bold paired brackets. So, 10 please be aware of those.
11 CO-CHAIR BLEY: And if we should wander 12 into that or ask you questions, please say, "That's 13 proprietary. We can't go into it." But we'll have a 14 closed session at the end --
15 MR. CHOWDHURY: We will.
16 CO-CHAIR BLEY: -- to cover both Chapter 17 13 and 18, if there are additional questions for the 18 staff.
19 MR. CHOWDHURY: Sure.
20 CO-CHAIR BLEY: Thanks, Prosanta. Please 21 go ahead.
22 MR. CHOWDHURY: Sure.
23 The technical staff we have today is 24 Lauren Nist, next to me. And then, next to her is Dr.
25 Brian Green, and then, Maurin Scheetz, and Dr. Amy NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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157 1 D'Agostino. And the lead Project Manager for this 2 project is Greg Cranston. I wanted to recognize him.
3 With that, I'll turn it over to Lauren.
4 She will be the key presenter, and then, the others 5 will assist her in fulfilling. And they will provide 6 you their credentials as well as the sections of the 7 application that they have individually reviewed and 8 coordinated.
9 Lauren?
10 MS. NIST: Good afternoon. As Prosanta 11 said, I'm Lauren Nist, and I have been at the NRC 12 -- can everyone hear me, by the way, or should I turn 13 this microphone?
14 CO-CHAIR BLEY: Turn it towards you, 15 please.
16 MS. NIST: Thank you.
17 CO-CHAIR BLEY: We have to have a good 18 record.
19 MS. NIST: Thank you.
20 So, I've been working here now at the NRC 21 for about four and a half years as a Human Factors 22 Engineering Technical Reviewer and, also, as an 23 Operator Licensing Examiner. Prior to joining the NRC 24 staff, I worked also with Maurin at San Onofre Nuclear 25 Generating Station in license operator requalification NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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158 1 training. And prior to that, I was also in the 2 nuclear Navy, also on a target, the USS Nimitz, for 3 about two and a half years and non-nuclear Navy prior 4 to that on a destroyer.
5 So, that's my background, and introduce 6 Brian Green.
7 MR. GREEN: Hi. I'm Brian Green. I've 8 been with the NRC almost nine years now, almost all of 9 it doing human factors work, both in NRO and in NRR.
10 Prior to that, I was at the University of Buffalo 11 where I studied trust in automation and human factors 12 associated with aviation maintenance tasks.
13 MS. D'AGOSTINO: Hi. I'm Dr. Amy 14 D'Agostino. I've been with the NRC since 2009. So, 15 I'm coming up on 10 years. I work in the Office of 16 Research, but I did a year-long rotation to NRO to 17 help with this review. I'm a Human Factors Analyst.
18 My background is I have my PhD in organizational and 19 human factors psychology from the University of 20 Connecticut.
21 MS. NIST: So, today we will discuss the 22 purpose and scope of our review, the review activities 23 that we've conducted thus far, the activities that we 24 plan to complete in the near-term, areas of interest 25 specific to our review, the status of the open items NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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159 1 discussed in our Safety Evaluation Report, and our 2 plans for closing them.
3 Additionally, some of our colleagues who 4 are reviewing Chapter 7, Instrumentation and Controls, 5 of the application shared with us that there were some 6 human factors-related questions that were raised 7 during the Subcommittee meeting back in August. And 8 so, we tried to address those questions in this 9 presentation as well.
10 Also, before we move on, I'd like --
11 MEMBER BROWN: Will you highlight those?
12 MS. NIST: I can do that.
13 MEMBER BROWN: When you get there.
14 MS. NIST: Sure.
15 Before we move on, I'd actually like to 16 address two of the questions that came up in the 17 previous session. So, the first question I'd like to 18 address has to do with the concept of ops, Concept of 19 Operations Technical Report, and clarification of what 20 it means for a document to be incorporated by 21 reference and where you will find that information.
22 So, the concept of operations document 23 that talks about the roles and responsibilities of the 24 operators, methods of control, that document is 25 incorporated by reference into DCD Tier 2. That means NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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160 1 it is essentially, even though it's in literally a 2 separate paper, it is treated as the DCD Tier 2 --
3 CO-CHAIR BLEY: Where does it say that?
4 Sometimes I see it spelled out. I didn't see it 5 spelled out for this one.
6 MS. NIST: You know what is incorporated 7 by reference by looking at Chapter 1. There's a 8 section of Tier 2, Table 1.6-2, which shows you the 9 technical reports that are part of the DCA.
10 CO-CHAIR BLEY: Thank you.
11 MS. NIST: And then, the Topical Reports 12 are in Table 1.6-1.
13 That is different than going to Chapter 18 14 of the DCD and looking at the individual sections and 15 seeing references listed. Those are just references.
16 That does not mean --
17 CO-CHAIR BLEY: Yes, but somewhere in 18 Chapter 18 one of the other reports actually is 19 labeled "incorporated by reference".
20 MS. NIST: Well --
21 CO-CHAIR BLEY: There you go.
22 MS. NIST: You have to go to Chapter 1 to 23 see what is actually incorporated and treated as part 24 of the DCD.
25 The second question --
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161 1 CO-CHAIR BLEY: And concepts of 2 operations, RP-2015, or whatever it is, is 3 incorporated by reference?
4 MS. NIST: Yes, sir.
5 CO-CHAIR BLEY: Okay. That makes me more 6 comfortable.
7 MR. GREEN: I believe the acronym that's 8 used to describe this document is simply CONOPS, and 9 it's in the functional requirements analysis. There's 10 a reference to the document in there.
11 CO-CHAIR BLEY: As CONOPS?
12 MR. GREEN: But it may not have been clear.
13 CO-CHAIR BLEY: Chapter 13, right, is --
14 never mind. To me, this is the real concept of 15 operations. It's how you're going to operate the 16 machine --
17 MR. GREEN: There's an overlap between the 18 two.
19 CO-CHAIR BLEY: Yes.
20 MR. GREEN: It makes sense to consider it 21 in both.
22 CO-CHAIR BLEY: And lack of overlap, too, 23 yes.
24 Okay. Go ahead.
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162 1 was from the Chapter 13 session that I'm going to let 2 Maurin address, having to do with inspection of 3 operating procedures at a site.
4 MS. SCHEETZ: So, you asked about when or 5 how does the NRC staff review the plant-specific 6 technical review guidelines and the emergency 7 operating procedures.
8 So, the plant-specific technical review 9 guidelines are submitted with a COL applicant and 10 they're part of a procedure generation package. Those 11 would be reviewed at the COL application level by the 12 NRC staff using NUREG-0800, the Staff Review Plan.
13 CO-CHAIR BLEY: So, if another plant comes 14 along, they would reference that COL, yes?
15 MS. SCHEETZ: If another COL comes along, 16 they could submit their own plant-specific ones or --
17 CO-CHAIR BLEY: Or they could reference 18 this --
19 MS. SCHEETZ: But I think the thought that 20 they use NuScale's Generic Technical Guidelines to 21 create their own plant-specific. How plant-specific 22 that is depends on the COL.
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163 1 we get closer to fuel loading, so that EOPs, emergency 2 operating procedures, are expected to be very mature 3 at that point. And the inspectors will go in using 4 Inspection Procedure 42454, which is Part 52, 5 Emergency Operating Procedures, which has very clear 6 guidance for inspectors to look at the emergency 7 operating procedures.
8 CO-CHAIR BLEY: Yes, and most of our 9 existing plants, there's a wide range -- well, not a 10 wide range -- there's a lot of differences in 11 specifics, different set points, that sort of thing, 12 as you go through the EOPs from one unit to another of 13 the same general type. But, in most of those cases, 14 they didn't stick to the design cert. They've done 15 other things.
16 MS. SCHEETZ: I think when you talk about 17 the operating reactors, emergency operating procedures 18 came about at a later time, not --
19 CO-CHAIR BLEY: I wasn't talking about the 20 operating plants.
21 MS. SCHEETZ: Okay.
22 CO-CHAIR BLEY: I was talking about ones 23 that have come forward to get --
24 MS. SCHEETZ: To get design certifications?
25 CO-CHAIR BLEY: Yes.
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164 1 MS. SCHEETZ: I can't answer that. I'm 2 not --
3 CO-CHAIR BLEY: I told you what.
4 MS. SCHEETZ: Okay.
5 CO-CHAIR BLEY: Go ahead.
6 MS. SCHEETZ: I thought you were asking.
7 I'm sorry.
8 CO-CHAIR BLEY: So, in this case, people 9 come in and use the actual design, replicate it. And 10 then, one would expect that the procedures won't 11 change very much because the reason they changed in 12 the other cases was because there were design 13 differences actually within the same general design 14 cert.
15 Go ahead.
16 MS. SCHEETZ: That's all I have.
17 CO-CHAIR BLEY: So, when the applicant was 18 up, they talked that they kind of expect all these 19 plants to follow very closely. We see that. It could 20 be that only the -- let me turn my question around.
21 They have a document that lays out, it 22 has, essentially, a version of the procedures. If a 23 COL comes along and adopts those essentially as is, 24 would you have to review it again or would you just 25 point to the design cert and say that it's a match?
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165 1 Do you review them to the depth that you could say 2 you've actually reviewed the proposed EOPs?
3 MS. SCHEETZ: I don't see any way out of 4 not completing the inspection procedure for inspectors 5 to look at the emergency operating procedures. So, my 6 belief is that they would be reviewed by those 7 inspectors at the as-constructed plant.
8 And in that procedure there's a lot of 9 detail about how many of these procedures were 10 actually table-topped or simulated in the simulator 11 with the COL staff. So, not NuScale doing it as part 12 of a different validation, but the COL at that point 13 doing it.
14 CO-CHAIR BLEY: So, in the design cert, 15 what we're doing now, you haven't reviewed that 16 document that contains what might be the procedures 17 for the first COL?
18 MS. SCHEETZ: No. We've looked at what's 19 supposed to be used as generic technical information 20 for a COL to base their emergency operating procedures 21 on.
22 CO-CHAIR BLEY: I'm not saying this the 23 way I'm trying to. You've reviewed that as generic?
24 MS. SCHEETZ: Generic.
25 CO-CHAIR BLEY: If I come in with an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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166 1 application next year for a COL and say I'm going to 2 use that exactly as written, would there be an 3 additional review?
4 MS. SCHEETZ: Yes, there would be a review 5 during the construction program.
6 CO-CHAIR BLEY: Even if they're using the 7 same thing? Is that because you didn't review them at 8 the level one would review it at the COL stage?
9 MS. SCHEETZ: Yes, I think that they're 10 not going to be called -- I doubt that a COL -- I'm 11 speculating. I doubt that a COL would be operating 12 with generic technical guidelines. They'd be 13 operating with emergency operating procedures, which 14 are required in technical specifications. So, they're 15 going to be looked at through the Technical 16 Specifications Program, and then, the Construction 17 Inspection Program.
18 MS. NIST: So, if I might add, what has 19 been reviewed for within the scope of the design 20 certification is the design certification element 21 provided a document that can be used as the guidelines 22 for the development of their site-specifics 23 procedures.
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167 1 address the COL item provided in Section 13.5. And 2 so, part of our review criteria would be to look and 3 see if certain things have been provided and if they 4 have sufficient process to develop site-specific 5 emergency operating procedures.
6 Now what we're looking at here is 7 -- correct me if I'm wrong -- adequacy of these 8 guidelines as the basis for the development of the 9 site-specific procedures. So, there would be 10 additional review at the COL stage when the 11 application comes in.
12 CO-CHAIR BLEY: Okay.
13 MS. NIST: And then, there's the 14 inspection piece which happens prior to operation 15 after the license is issued.
16 CO-CHAIR BLEY: I apologize that I haven't 17 read the current document because I didn't know it was 18 there until today. I'll be reading it. But the way 19 it was described is that, although it's guidelines, 20 it's really essentially the procedures they expect a 21 plant would use, and if you adopted it verbatim, I'm 22 wondering why there would be another review. Is that 23 because we didn't review them as if they were 24 operating procedures today? Or is it something else?
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168 1 make sense, just say so.
2 MS. NIST: I think what's confusing is --
3 so, you're basically asking, why is there a COL item 4 if they're provided procedures, essentially?
5 CO-CHAIR BLEY: Well, I asked them that 6 earlier. I mean, you heard their answer, I suppose.
7 I don't know if you were here.
8 MS. NIST: I did hear the answer, and I 9 can tell you, you know, that we've reviewed what's on 10 the docket and what's been provided as generic 11 technical guidelines to meet the scope of the DC 12 review.
13 CO-CHAIR BLEY: Go ahead. Whoever is 14 next, go ahead.
15 MS. NIST: That would be me.
16 (Laughter.)
17 Next slide, please.
18 So, the purpose of our human factors 19 engineering review was to determine whether the human 20 factors engineering design of the NuScale standard 21 plant control room supports operators in the safe 22 operation of the plant. Additionally, the Applicant 23 requested that minimum licensed operator staffing 24 requirements specific to the NuScale power plant 25 design be adopted as requirements applicable to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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169 1 licensees, referencing the NuScale power plant design 2 certification in lieu of those stated in 3 10 CFR 50.54(m).
4 To provide a technical justification for 5 its proposed operator staffing requirements, the 6 Applicant conducted a staffing plan validation test, 7 which they discussed previously, using personnel 8 trained on NuScale operations to perform a set of 9 challenging high workload scenarios in the 12-unit 10 main control room simulator.
11 So, I'd also like to take this opportunity 12 just to remind us that many of the specific details of 13 the staffing plan validation tests were proprietary.
14 And so, if we have a specific discussion about that, 15 we will need to do that in the closed session.
16 To conduct our review and develop the 17 Safety Evaluation, we reviewed the following parts of 18 the application: we reviewed the application Tier 2, 19 Chapter 18, as well as parts of Chapter 7, 15, and 19 20 that were related to human factors engineering topics.
21 Chapter 18 of the DCD also summarizes the 22 numerous human factors engineering technical reports 23 that were included with the application. These 24 reports contain a description of the methods the 25 Applicant used to conduct the various human factors NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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170 1 analyses and summaries of those results; a description 2 of the human-system interfaces, or HSIs, available to 3 the operators; the concepts of operations, which 4 describes the roles and responsibilities of the 5 control room operators and how they will interact with 6 one another and use the HSIs to operate the plant; a 7 description of the methods that the Applicant used to 8 conduct and evaluate the staffing plan validation as 9 well as the results. They also provided a description 10 of the methods that they used to conduct the 11 Integrated System Validation test.
12 As previously mentioned, the Applicant 13 completed its Integrated System Validation testing in 14 September of 2018, and they have informed us that they 15 will provide us the results of that testing by the end 16 of this March.
17 Additionally, we reviewed the information 18 in Tier 1, Section 3.15, for human factors 19 engineering, which includes design description as well 20 as an ITAAC for human factors engineering.
21 Chapter 14 of the Safety Evaluation Report 22 documents our review of the human factors engineering 23 ITAAC. And there is some overlap with Chapter 18.
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171 1 in more detail what we did and what we observed and 2 when we did it.
3 As discussed in the Chapter 18 Safety 4 Evaluation Report, we used the guidance in NUREG-0711, 5 HFE Program Review Model, and NUREG-0700, Human System 6 Interface Design Review Guidelines, to evaluate the 7 Applicant's HFE design and make our findings; in our 8 Safety Evaluation documents, the current status of our 9 review and the conclusions that we've made so far, as 10 well as the open items.
11 Next slide, please.
12 So, one of the members asked that I point 13 out a question from the Subcommittee. I think we 14 attempted to address those here on that slide. But 15 one of the questions was whether the staffing plan had 16 been settled in the DCD or if it was a policy issue 17 before the Commission. And the answer is that this 18 particular issue is being addressed as part of this 19 design certification review activity. That is in 20 accordance with, this strategy is in accordance with 21 the plan that was set forth in SECY-11-0098, where we 22 informed the Commission that we would evaluate 23 staffing proposals on a case-by-case basis using some 24 of the guidance that had been developed specifically 25 for that purpose.
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172 1 CO-CHAIR BLEY: Did they issue an SER on 2 that SECY?
3 MS. NIST: An SRM?
4 CO-CHAIR BLEY: Yes. Sorry.
5 MS. NIST: No, sir. It was an information 6 paper.
7 CO-CHAIR BLEY: Okay.
8 MS. NIST: Also, someone had asked whether 9 the design of the human-system interfaces were fixed.
10 And the answer is basically yes, at the end of the 11 design certification review, the HED design for the 12 standard plant will be fixed by NuScale completing the 13 activities related to verification and validation.
14 CO-CHAIR BLEY: So, when we see the V&V, 15 verification and validation, report, we will see those 16 details of what the panel looks like, how it's used, 17 all the information?
18 MS. NIST: Well --
19 CO-CHAIR BLEY: I mean, I think this is 20 important because -- well, you guys had a visit out 21 there, right?
22 MS. NIST: Yes, at least one.
23 CO-CHAIR BLEY: Did you watch the 24 simulator?
25 MS. NIST: Yes, we did.
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173 1 CO-CHAIR BLEY: Did they run a whole 2 series of things on it?
3 I'm still stuck with the two things that 4 made that convincing to me, and those are not directly 5 addressed here. One is the way the panel was laid out 6 so that one person could really have an understanding 7 of what was going wrong in particular units, if that 8 started to happen, particular modules, and then, pass 9 it off to others.
10 The other piece was the ability to easily 11 put it into a safe state, so they didn't have to spend 12 time monitoring it.
13 There aren't any words about that in the 14 SER that I saw. To me, that's more convincing than 15 saying, "We met all the criteria in NUREG so-and-so 16 and the B&O report." And there's nothing there that 17 tells me that you really paid attention to that.
18 MS. NIST: So, I think what we can do, 19 because I think that we have that information there, 20 but, unfortunately, like you said earlier, I don't 21 think it's elevated in the document such that it's 22 blinking light, you know, getting your attention, 23 hoping to make a finding. So, we hear your feedback, 24 and we thank you for.
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174 1 we will be -- we need to recognize this is an interim 2 product. And so, our review strategy, as I said a 3 moment ago, we reviewed this guidance. And so, this 4 guidance has a lot of guidance related to the overall 5 HFE process. And so, we can talk about why we felt 6 that it was necessary to review the process activities 7 that ultimately led to the development of the HSI 8 design.
9 But, having said that, we do realize that 10 we need to, as we get the results, we need to tie that 11 together into a way that ultimately supports our 12 findings. And so, hearing your feedback is valuable 13 to us to make sure that we rely on the information, 14 and not only that we find it compelling from a process 15 standpoint, but our observations, which are 16 documented, maybe not necessarily in the SER, but in 17 some of the audit reports -- and we can go back and 18 look at that.
19 CO-CHAIR BLEY: Okay. I think that would 20 be useful.
21 Maybe at some point we'll talk about 22 schedule with the Applicant again. But there's a lot 23 of open items here, but they don't depend on many 24 sources. So, when you get a couple of these sources 25 back, you'll be able to deal with them.
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175 1 From what we've heard, they've done most 2 of the tests they plan to do. Can you give me a hint 3 of when you expect to hear from them and how long it's 4 going to take you to go through? I think this section 5 will be much more understandable once that work is 6 done. But I am curious, how does the time line up 7 with the time available?
8 MR. CHOWDHURY: Chapter 18 has identified 9 23 open items. I think 19 of them are related to the 10 V&V RSR that the Applicant informed us would be 11 submitted by March 31st.
12 CO-CHAIR BLEY: Okay.
13 MR. CHOWDHURY: So, here's what happens:
14 it is that two things will happen. One is that we 15 received Revision 2 of the design certification 16 application in October. By that time, the staff had 17 completed writing or drafting the SER. So, this SER 18 is consistent with Revision 1 of the application.
19 Changes that have been made as a result of 20 NuScale's own initiatives as well as in response to 21 certain RAIs, Requests for Additional Information, 22 those will be incorporated in the next version of the 23 SE.
24 CO-CHAIR BLEY: Well, Rev. 2 is already 25 posted on the NRC website.
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176 1 MR. CHOWDHURY: That is correct, Rev. 2 of 2 the application, the SE going into phase 5 --
3 CO-CHAIR BLEY: Ah, okay.
4 MR. CHOWDHURY: So, we think between this 5 phase 3 that we are going through now and phase 4 this 6 SE will be updated, revised, streamlined, as I 7 mentioned before. And then, a clean product will be 8 available by the end of the phase 4. I don't have the 9 date right now, but the schedule. You know, we have 10 a schedule of phase 4. I believe that's the end of 11 this year, but I have to make sure that's correct.
12 But, by phase 4, the SE will have no open items and be 13 clean.
14 CO-CHAIR BLEY: Okay.
15 MR. CHOWDHURY: So, right now, we know 16 that March 31st, the deadline that the Applicant wants 17 to submit the Results Summary Report, it is important 18 for us to meet the subsequent milestones of our SE.
19 CO-CHAIR BLEY: Okay.
20 MR. CHOWDHURY: So, we have not developed 21 internal milestones because we want to make sure that 22 we get that. And also, one RAI response is still 23 pending, the response to RAI 9415. We are expecting 24 it next week, also, or the end of this month. So, 25 based on all of --
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177 1 CO-CHAIR BLEY: So, it looks to be 2 tracking?
3 MR. CHOWDHURY: Yes.
4 CO-CHAIR BLEY: I guess just one more 5 comment on the SER. Since you based it on meeting the 6 criteria in at least two NUREGs and the BNL-NUREG/CR, 7 it's very repetitive. Because lots of those criteria 8 are repetitive, it would be easier for almost anyone 9 to read and understand if you could somehow merge 10 those kind of things that are the same into one place 11 and not repeat them many times.
12 MS. NIST: Right. So, we realize that, 13 and that is going to be something that we will be 14 paying attention to moving forward.
15 CO-CHAIR BLEY: What you said earlier, 16 yes.
17 MS. NIST: I think part of this is an 18 artifact of an intention to be very thorough in this 19 review and be transparent about what we reviewed, why 20 we looked at it. But, certainly, moving forward to 21 the final product, we'll definitely take that into 22 consideration and work for readability of the 23 document.
24 CO-CHAIR BLEY: Thank you.
25 Go ahead.
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178 1 MS. NIST: Okay. I think that actually we 2 can --
3 MR. CHOWDHURY: Let me make one comment.
4 On this slide, you will see the last bullet. It says, 5 "Phase 4 activities in progress." So, what it means 6 is that the staff has already started reconciling 7 information that came in response to RAIs.
8 CO-CHAIR BLEY: Okay. And Chapter 10 is 9 on V&V and is really loaded with them, yes.
10 MR. CHOWDHURY: Okay.
11 MS. NIST: Now I'd like to discuss the 12 activities that we've completed in the course of our 13 review of --
14 CO-CHAIR BLEY: I'm sorry?
15 MEMBER MARCH-LEUBA: Use the microphone.
16 MS. NIST: Okay. How's that? Okay.
17 Thank you.
18 So, I'd like to discuss the activities 19 that we've completed and what we're planning to do 20 moving forward. As part of pre-application activities 21 that started around the 2015 timeframe, we reviewed 22 the Applicant's Human Factors engineering 23 Implementation Plan which described their proposed 24 means of conducting human factors analyses, developing 25 the human-system interface design, and validating the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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179 1 effectiveness of that design.
2 As part of that, we also reviewed their 3 method for conducting the staffing plan validation, 4 and we observed one of two weeks of the staffing plan 5 validation testing. NuScale is the first applicant to 6 conduct a staffing plan validation, and we're 7 reviewing the staffing plan validation results for the 8 first time.
9 As we discussed previously, we used two 10 guidance documents to evaluate the Applicant's 11 staffing plan validation methods and results. So, the 12 first was NUREG-1791, Guidance for Assessing Exemption 13 Requests, and the nuclear power plant license operator 14 staffing requirements in 10 CFR 50.549(m). And the 15 second is Attachment B of Chapter 18 of the standard 16 review plan, "Methodology to Assess the Workload of 17 Challenging Operational Conditions in Support of 18 Minimum Staffing Level Reviews".
19 NUREG-1791 describes a process for 20 systematically reviewing and evaluating alternative 21 staffing plans. This process involves reviewing data 22 and analyses from validation exercises that are 23 performed to demonstrate the effectiveness and safety 24 of a proposed staffing plan.
25 And Attachment B, Chapter 18, of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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180 1 standard review plan is based on the technical report 2 that was prepared by Brookhaven National Laboratory.
3 Its main focus is to provide a methodology for 4 developing a sample of scenarios to be used 5 specifically for this kind of a test to simulate 6 challenging high workload scenarios. Key performance 7 measures for the staffing plan validation include 8 acceptable task performance, operator workload, and 9 situation awareness.
10 As discussed in Chapter 18 of the Safety 11 Evaluation Report, we concluded that the Applicant's 12 method for performing the validation was consistent 13 with this guidance. And, also, the results of the 14 staffing plan validation shows that, for each of the 15 scenarios, the operators completed all of the tasks 16 within any specified time limits while maintaining 17 workload and situation awareness within acceptable 18 levels.
19 Additionally, as I mentioned, we went to 20 observe one of the two weeks of testing. And we 21 observed that the operators were able to complete all 22 of the tasks in the scenarios. They maintained 23 adequate situation awareness, and it appeared that 24 their workload was very manageable.
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181 1 indications provided by the HSI to diagnose the 2 scenario events in a timely manner and take 3 appropriate actions. So, for example, one event 4 resulted in an increase in megawatts and reactor power 5 for one unit. The HSI or the displays and controls 6 for the affected unit showed an increase in megawatts 7 and reactor power. The operators identified the 8 change in these parameters for the affected unit 9 within seconds of the HSI providing the changes. And 10 during this event, the operators also used other 11 indications in the control room to confirm their 12 diagnosis.
13 So, ultimately, we have concluded that the 14 staffing plan validation results do validate the 15 proposed staffing plan.
16 Following docketing of the application and 17 the start of our review, we reviewed the Applicant's 18 human factors engineering analyses, as summarized in 19 the application. We also conducted two audits to 20 review the results of those analyses.
21 Specifically, we reviewed a sample of the 22 Applicant's operating experience review, their task 23 analyses, and their function allocation results. We 24 found that the Applicant completed those analyses that 25 were necessary to identify the inputs to the human-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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182 1 system interface design, and we found that those 2 analyses were acceptable.
3 So, we also conducted an audit to review 4 the Integrated System Validation Test Plan. And then, 5 we went out to observe two of the seven weeks of the 6 Integrated System Validation testing. We observed 7 that the preliminary scenario results showed that the 8 pass/fail criteria for the scenarios had been met and 9 issues were being identified and documented for 10 further analysis and evaluation by the Applicant.
11 Issues were identified and documented, but the staff 12 did not observe that there were any apparent 13 significant human performance degradations as a result 14 of the identified issued.
15 While we were observing the ISV testing, 16 we also assessed a sample of the control room HSIs to 17 confirm that the design complies with certain 18 regulatory requirements for human-system interfaces 19 and, also, that it conformed to their own design-20 specific human factors engineering design guidelines.
21 For example, we compared a sample of the computer-22 based procedures to the relevant guidance in 23 NUREG-0700 and found that they conformed to the 24 guidance with a few minor exceptions, and that there 25 was adequate justification for not conforming to all NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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183 1 of the guidelines.
2 We also observed the operators using the 3 safety display and indication system to complete 4 critical safety function checks following simulated 5 unit trips. And we saw that the crew could complete 6 those checks for all units in the time required by the 7 Applicant's procedure.
8 Finally, when we receive it, we will 9 review the Applicant's ISV and other validation 10 results and update the Safety Evaluation Report. And 11 in phase 4, we'll also be resolving the open items, 12 which we'll discuss in more detail later.
13 Next slide, please.
14 In preparation for review of small modular 15 reactor designs, the staff developed two guidance 16 documents that identified potential human performance 17 issues that were specific to small modular reactors.
18 These were NUREG/CR-7126, Human Performance Issues 19 Related to the Design and Operation of Small Modular 20 Reactors, and NUREG/CR-7202, NRC Reviewer Aid for 21 Evaluating the Human Performance Aspects Related to 22 the Design and Operation of Small Modular Reactors.
23 Some of the potential human performance 24 issues identified in these NUREGs were relevant to the 25 NuScale design. And so, we considered them during our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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184 1 review, and I'd like to share a few examples.
2 First, the design allows for operation of 3 all units from a single-operator workstation. So, we 4 were interested particularly to see what kinds of 5 design features would help to prevent operators from 6 taking actions intended for one unit on a different 7 unit, or otherwise referred to as wrong unit errors.
8 We observed that the Applicant has used 9 consistent and clear schemes for unit labeling on 10 their displays that are used for monitoring and 11 control. Also, the concept of operations defines the 12 roles and responsibilities of the control room 13 operators. The operators have different 14 responsibilities for the different units, which can 15 also help to prevent operating errors.
16 Additionally, although the human-systems 17 interfaces at the operator workstations can be used to 18 operate safety-related components, the operator must 19 first deliberately operate the enable non-safety 20 control switch and no automatic or manual safety 21 actuation signals can be present. Operation of the 22 enable non-safety control switch to allow operation of 23 safety-related components from these operator 24 workstations is only necessary under a limited set of 25 conditions. Also, it is an action that is intended to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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185 1 be controlled by procedures, and because it occurs in 2 the control room within sight of the control room 3 supervisor's workstation, it can also be overseen by 4 the control room supervisor.
5 Additionally, if an event occurs on a 6 given unit that requires actuation of a protective 7 signal from the module protection system, the module 8 protection system will position the safety equipment 9 as necessary, regardless of the position of the enable 10 non-safety control switch or the component.
11 Thus, we concluded that the HSI design 12 features, the concept of operations, and the module 13 protection system design features do help to minimize 14 opportunities for, and consequences of, significant 15 wrong unit errors.
16 We were also interested to see how the 17 crew could manage the operation of up to 12 units from 18 one single control room. For example, if multiple 19 alarms are received at once for one unit, the HSI 20 should help the operators identify the high-priority 21 alarms and determine what actions, if necessary, are 22 needed.
23 The NuScale Plant Notification System is 24 designed with multiple features that allow operators 25 to identify relatively higher-priority alarms and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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186 1 determine how to respond. During the ISV audit that 2 we conducted, we observed alarm prioritization, and we 3 did not observe any cascading alarm conditions that 4 impacted operator performance during those scenarios.
5 Additionally, as was discussed 6 previously --
7 CO-CHAIR BLEY: Was that because of the 8 nature of the drills you were watching or was it 9 because of some aspect of the design of these modules?
10 MS. NIST: So both. The design, as Doug 11 mentioned earlier, they've set up a tiered system to 12 help prioritize and display the important alarms and 13 priority to the operators. So, we observed, also, the 14 operators using that system, interacting with that 15 system. Of course, given the scenario, you would 16 expect to have more alarms, depending on how 17 significant the consequences are of that scenario 18 other than others.
19 But we did, just from a sampling 20 perspective, when we were trying to figure out when we 21 wanted to go observe, we were interested specifically 22 in observing scenarios where there would be relatively 23 more action happening, so that we could observe what 24 to us would be the more significant scenarios to see 25 how operators were interacting with the system.
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187 1 CO-CHAIR BLEY: I don't know if this kind 2 of information is appropriate for the SER. Is it 3 documented in a trip report or something? I don't see 4 anything referred to. You know, the things you're 5 telling me here are pretty important with the judgment 6 that you're making in the SER.
7 MS. NIST: Yes, we refer to the audit 8 report for the ISV audit.
9 CO-CHAIR BLEY: In the SER?
10 MS. NIST: Yes, we have.
11 CO-CHAIR BLEY: Which part?
12 MS. NIST: It would be --
13 CO-CHAIR BLEY: The staffing part?
14 MS. NIST: No. It would be in 18.10.
15 CO-CHAIR BLEY: 10, V&V. Okay.
16 MS. NIST: Yes. And the staffing plan 17 validation audit also has an audit report that is also 18 referenced in 18.5 of the SER.
19 Finally, the last point on this slide, 20 speaking to novel HSI design features, we've observed 21 that the Applicant has included novel HSIs in the 22 control room. For example, one of these control room 23 display designs, which is proprietary, is intended to 24 help operators detect changes in unit status. And we 25 were interested to see how operators use this display NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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188 1 during both the staffing plan validation and the 2 Integrated System Validation testing, and whether it 3 was effective. And we observed instances where this 4 particular display was an effective tool to alert the 5 operators promptly to changes in unit status.
6 Next slide, please.
7 We've talked to some extent today about 8 this, but, again, there are several open items. The 9 majority of those we expect to be able to close when 10 we get the results of the validation testing.
11 There's one open item related to adequacy 12 of the scope of the human factors engineering ITAAC, 13 and we are working with NuScale to resolve that issue.
14 There's also an open related to remote shutdown, as 15 it's described in Chapter 7, and we'll be tracking the 16 resolution of that issue to make sure that our SER is 17 consistent with the way that that issue is resolved.
18 Also, the reviews for Chapter 7, 15, and 19 19 are happening at the same time as this review.
20 Chapter 7 is much further along. But we will be 21 monitoring the progress of those reviews to make sure 22 that our conclusions are consistent with the 23 conclusions in those Safety Evaluation Reports as they 24 progress as well, since the information in those 25 sections feeds directly into Chapter 18 in some cases.
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189 1 And then, also, this is more of an 2 administrative item. It's just to ensure that the HFE 3 reports yet to be received are incorporated by 4 reference into Tier 2.
5 Next slide, please.
6 So, in conclusion, to speak to what we've 7 been able to determine thus far about the Applicant's 8 HFE design and the proposed staffing plan, there was 9 also the staffing plan validation testing does support 10 the Applicant's proposed staffing plan. And we'll 11 confirm if there were any staffing issues identified 12 during ISV, that they've made any changes to that 13 plan, if they were necessary.
14 Also, based on our observations of ISV 15 tests, we expect that the ISV results will provide 16 evidence that the HFE design adequately supports 17 personnel in the safe operation of the plant. But, 18 again, we do need to resolve the open items and 19 complete our review of the validation and verification 20 results prior to making our finding, which we will be 21 doing in phase 4.
22 CO-CHAIR BLEY: I have a minor request.
23 I guess we won't have another break. But, at some 24 point in time, if you can flag to where those audit 25 reports are referenced, it would be helpful.
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190 1 MS. NIST: Sure.
2 CO-CHAIR BLEY: The references aren't at 3 the end of every chapter. So, they must be scattered 4 through. That would be helpful.
5 MS. D'AGOSTINO: The ISV audit is, if you 6 look at page 18-142, the ML number is 1829A, or 7 298A189.
8 CO-CHAIR BLEY: There were more, though, 9 right?
10 MS. D'AGOSTINO: Yes. That was the ISV 11 audit, and there is the June 2018 audit as well.
12 CO-CHAIR BLEY: Oh, yes. Okay. And 13 they're in ADAMS, so we can find them.
14 MS. D'AGOSTINO: Yes.
15 CO-CHAIR BLEY: Okay. Thank you.
16 MS. D'AGOSTINO: ML18208A370.
17 MR. GREEN: Was that the staffing plan 18 validation? I think he was looking for that one as 19 well.
20 MS. D'AGOSTINO: No, they were just the 21 two ISVs.
22 MR. GREEN: Okay.
23 CO-CHAIR BLEY: Thanks, Lauren.
24 MS. NIST: Sure.
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191 1 any more.
2 MS. D'AGOSTINO: Okay.
3 CO-CHAIR BLEY: We can find them now.
4 MS. NIST: Thank you. That concludes our 5 prepared remarks.
6 CO-CHAIR BLEY: On everything?
7 (Laughter.)
8 MS. NIST: I wanted to make sure we had 9 plenty of time to address any questions.
10 CO-CHAIR BLEY: I guess I think I agree 11 with you, a lot of the confusion comes from trying to 12 get everything in here. Some of the judgments are 13 probably laid out in your audit reports. It would be 14 helpful to have some of that up in the SER, so you 15 understand the engineering basis for some of the 16 conclusions. I mean, it felt very checklist-oriented 17 to me. "We met criterion 3. We met criterion 4." I 18 find if the engineering judgments are in there, 19 they're so buried among the other stuff, I couldn't 20 find them or missed them.
21 MS. NIST: I understand.
22 CO-CHAIR BLEY: Anything from other 23 members in the open session?
24 (No audible response.)
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192 1 the closed session.
2 Okay. Were there other things that we 3 flagged for the closed session that you remember?
4 Okay. Oh, no, it's the open session. So, 5 yes, get the phone line open.
6 And while we're waiting for the phone 7 line, is there anybody in the room who would like to 8 make a comment? If so, please come to the podium over 9 here and state your name and who you represent, and 10 give us your comment.
11 Don't be shy.
12 Okay. Is the phone line open?
13 If anybody on the public line is there, 14 just say a word or two, so I can see if it's open, if 15 there is anybody. We don't know yet.
16 PARTICIPANT: NuScale Corvallis is here, 17 just so you know the line is open.
18 CO-CHAIR BLEY: Okay. So, NuScale's line 19 is open.
20 MR. SNODDERLY: Yes. Yes, the NuScale 21 line is always open.
22 CO-CHAIR BLEY: If there's anybody on the 23 public line who would like to make comment, please 24 give us your name and your comment.
25 (No audible response.)
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193 1 Going, going. I guess not. Thank you.
2 MR. SNODDERLY: So, please close that open 3 line. But keep the NuScale line open, but close the 4 public line.
5 CO-CHAIR BLEY: I'll wait until we finish 6 the closed session --
7 MR. SNODDERLY: And so, if the NuScale 8 person is on the open line, hold there to make sure it 9 is closed. If not, you'll tell us.
10 And then, as we go into closed session, I 11 need to ask anyone from the public or from the staff 12 that does not have a need to know to leave.
13 Prosanta and Steve, if you can help?
14 Okay. So, I think we're good.
15 All right. Once we verify the open line 16 is closed, I think, yes, we can go into closed 17 session.
18 CO-CHAIR BLEY: Okay. So, is the NuScale 19 person who was on the public line still there? If so, 20 say something very loud, so we can hear you.
21 (No audible response.)
22 I guess it's closed.
23 (Whereupon, at 4:09 p.m., the foregoing 24 matter recessed from open session and went into closed 25 session.)
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NuScale Nonproprietary ACRS Presentation Conduct of Operations Chapter 13 Overview January 23, 2019 Doug Bowman Supervisor Plant Operations 1
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Introductions
- Doug Bowman- Supervisor Plant Operations
- Ryan Flamand- Senior Reactor Operator 5 2
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Operations Staff
- 18 previously licensed SROs
- Licenses held at:
Byron Columbia DC Cook Limerick Nine Mile Point Palisades HB Robinson Seabrook
- 569 years of nuclear experience
- 16 Navy nuclear veterans 3
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Conduct of Operations - Chapter 13 Primarily a collection of action items for a Combined Operating License holder to describe the structure of the organizations and programs supporting plant operations, as well as the qualification of the individuals in the organizations.
Security and FFD programs covered separately.
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Organizational structure Section 13.1 includes COL actions to describe:
- corporate or home office management and technical support organization
- onsite operations organization
- qualification requirements for each management, operating, technical, and maintenance position described in the operating organization 5
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Training programs Section 13.2 includes COL actions for a description and schedule for:
- initial license training program for reactor operators and senior reactor operators
- licensed operator requalification program
- initial training, periodic retraining, and qualification(s):
- non-licensed operators
- shift supervisors
- shift technical advisors
- I&C technicians
- electrical maintenance personnel
- mechanical maintenance personnel
- radiological protection technicians
- chemistry technicians
- engineering support personnel 6
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Emergency Plan Section 13.3 describes the emergency facilities included in the standard plant design. This includes:
- TSC - including the following associated systems
- Ventilation systems
- Communications systems
- TSC workstations
- Emergency response data systems This section also includes 3 COL actions that require development of:
- 1) operations support center
- 2) emergency offsite facility
- 3) the overall emergency plan 7
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Operational programs Section 13.4 includes COL actions to provide site-specific information, including implementation schedule:
- Pre-service and In-service testing and inspection
- Environmental Qualification
- Fire protection
- Containment leak rate
- Process and Effluent monitoring and sampling
- Radiation protection
- Training
- Process control
- Emergency planning
- Security
- Quality Assurance
- Motor operated valve
- Maintenance Rule
- Initial test 8
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Plant Procedures Section 13.5 includes COL actions to provide a description of and a plan for the development, implementation and control of the following procedure areas:
- administrative procedures
- operations and maintenance procedures
- plant radiation protection procedures
- emergency preparedness procedures
- calibration and test procedures
- chemical-radiochemical control procedures
- radioactive waste management procedures
- maintenance and modification procedures
- material control procedures
- plant security procedures 9
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Plant Procedures - Generic Technical Guidance Section 13.5 also includes COL actions to ensure that plant specific emergency operating procedures are developed The staff requested that we provide a set of generic technical guidelines as part of the DCA Goals for development:
- Symptom based procedure
- Status easily assessed by the operator
- Fully integrated into the HSI
- A single procedure set addresses all post accident actions (covers the legacy emergency operating procedure, severe accident management, LOLA/ELAP/extensive damage mitigation) 10 PM-0119-64147 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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Plant Procedures - Generic Technical Guidance How did NuScale start development of the GTGs?
Source document Credited Actions FSAR Chapter 7 I&C failure defense in depth analysis 0 FSAR Chapter 15 plant design basis response to DBEs 0 FSAR Chapter 18 HFE task analysis and associated reference 0 FSAR Chapter 19 operator actions assumed in beyond-design-basis 7 PRA FSAR Chapter 20 operator actions assumed in beyond-design-basis 2 evaluations FSAR Chapter 21 multi-unit design considerations 0 System requirements and limitations as defined in system description 0 documents 11 PM-0119-64147 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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Acronyms CFDS- containment flooding and GTG- Generic Technical Guidelines drain system HFE- human factors engineering COL- combined license HSI- human system-interface CVCS- chemical and volume I&C- instrumentation and control control system IHA- important human action DCA- Design Certification Application LOLA- loss of large areas DBE- design basis event PRA-probabilistic risk assessment ECCS- emergency core cooling TSC- technical support center system SRO- Senior Reactor Operator ELAP- extended loss of AC power FFD- fitness-for-duty FSAR- Final Safety Analysis Report 12 PM-0119-64147 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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Portland Office Richland Office 6650 SW Redwood Lane, 1933 Jadwin Ave., Suite 130 Suite 210 Richland, WA 99354 Portland, OR 97224 541.360.0500 971.371.1592 Arlington Office Corvallis Office 2300 Clarendon Blvd., Suite 1110 1100 NE Circle Blvd., Suite 200 Arlington, VA 22201 Corvallis, OR 97330 541.360.0500 London Office 1st Floor Portland House Rockville Office Bressenden Place 11333 Woodglen Ave., Suite 205 London SW1E 5BH Rockville, MD 20852 United Kingdom 301.770.0472 +44 (0) 2079 321700 Charlotte Office 2815 Coliseum Centre Drive, Suite 230 Charlotte, NC 28217 980.349.4804 http://www.nuscalepower.com Twitter: @NuScale_Power 13 PM-0119-64147 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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Safety Evaluation with Open Items:
Ch 13, Conduct of Operations NuScale Design Certification Application Review ACRS Subcommittee Meeting January 23, 2019
Agenda
- NRC staff review team
- Purpose and scope
- Review activities and timeline
- Focus areas
- Open items
- Conclusion January 23, 2019 Chapter 13 Conduct of Operations 2
NRC Staff Review Team
- Technical Staff Presenters Maurin Scheetz, NRR - DCA Sections 13.1, 13.2, 13.5 Amanda Marshall, NSIR - DCA Section 13.3 Prosanta Chowdhury, NRO - DCA Section 13.4
- Project Managers Greg Cranston - Lead Project Manager Prosanta Chowdhury - Chapter 13 Project Manager January 23, 2019 Chapter 13 Conduct of Operations 3
Overview of Chapter 13 Section Description 13.1 Organizational Structure - contains COL items which require the COL applicant to develop the management and tech support organizational structure including design, construction, operating, and maintenance responsibilities. This includes the qualification requirements such as education, training, and experience for each position.
13.2 Training - contains COL items which require the COL applicant to develop the description and schedule of the training program for licensed reactor operators and non-licensed plant staff.
13.3 Emergency Planning - contains a description of design-related emergency planning features, such as the Technical Support Center, as well as COL Items pertaining to emergency planning.
13.4 Operational Programs - contains a COL item which requires a COL applicant to provide site-specific information, including implementation schedule, for operational programs.
13.5 Plant Procedures - contains COL items which require the COL applicant to describe the admin & operating procedures for all January 23, 2019 Chapter 13 Conduct of Operations 4 operational modes, and a schedule for preparing the procedures.
Technical Topics Section 13.1 - Organizational Structure Scope of Review
- The purpose of this section is to provide assurance that the applicant has established acceptable COL Information Items pertaining to the corporate-level management, technical support and onsite operating organizations necessary for the safe design, construction, testing and operation of the nuclear plant, including training and qualification requirements. That is, the COL applicant will have the necessary managerial and technical resources to support the plant staff in construction, operation, maintenance, and in the event of an emergency.
Focus Areas
- Three COL information items are provided, COL 13.1-1 through 13.1-3. Staff found that the COL information items appropriately identified and sufficiently addressed the required information.
Open Items
- None Conclusion
- The staff has reviewed DCA Part 2, Tier 2, Section 13.1, Organization Structure, and determined that the applicants approach for COL items describing the corporate-level management and technical support organization, and the onsite operating organization, is acceptable to meet all applicable requirements.
January 23, 2019 Chapter 13 Conduct of Operations 5
Technical Topics Section 13.2 - Training Scope of Review
- The purpose of this section is to provide assurance that the applicant has established acceptable COL Information Items pertaining to a description of, and schedule for, (1) the licensed operator training program for reactor operators and senior reactor operators, including the licensed operator requalification program, and (2) the training program for the nonlicensed plant staff.
Focus Areas
- Two COL information items COL 13.2-1 and COL 13.2-2 are provided pertaining to a description and schedule of training programs for licensed and non-licensed staff.
Open Items
- None Conclusion
- The staff has reviewed DCA Part 2, Tier 2, Section 13.2, Training, and determined that applicants approach for COL items for training programs is acceptable.
January 23, 2019 Chapter 13 Conduct of Operations 6
Technical Topics Section 13.3 - Emergency Planning Scope of Review
- The purpose of this section is to address those design features, facilities, functions, and equipment that are technically relevant to the design, that are not site specific, and that affect some aspect of emergency planning (EP) or the capability of a licensee to cope with plant emergencies. The applicant may choose the extent to which the application includes EP features to be reviewed as part of the design certification.
Focus Areas
- 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)
January 23, 2019 Chapter 13 Conduct of Operations 7
Technical Topics Section 13.3 - Emergency Planning Open Items
- Open Item 13.3 Process Sampling System o DCA Part 2, Tier 2, Section, 9.3.2, states that [t]he function of the process sampling system (PSS) is to provide the means to obtain representative liquid and gaseous samples from various primary and secondary process streams and components for monitoring and analyzing the chemical and radiochemical conditions. The PSS capability is used during normal plant operations and following accident conditions without the need for a dedicated post-accident sampling system.
o 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.
o Resolution is ongoing: If the process sampling system 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.
January 23, 2019 Chapter 13 Conduct of Operations 8
Technical Topics Section 13.4 - Operational Programs Scope of Review
- COL applicants are required by 10 CFR 52.79 to describe operational programs, but similar requirements do not exist for DCAs. Staff evaluated this section using Draft Revision 4 of SRP 13.4, which was published in September 2018, to ensure COL Information Item(s) include necessary requirements for COL applicants consistent with the SRP.
Focus Areas
- 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.
Open Items
- None Conclusion
- The staff has reviewed DCA Part 2 Tier 2, Section 13.4, Operational Programs, and determined that the COL Information Item 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.
January 23, 2019 Chapter 13 Conduct of Operations 9
Technical Topics Section 13.5 - Plant Procedures Scope of Review
- The purpose of this section is to 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).
Focus Areas
- Seven COL information items are provided, COL 13.5-1 through 13.5-5, 13.5-7, and 13.5-8 for plant procedures.
- The GTG review focused on (1) the three CSFs defined for the NuScale power plant, (2) the methodology used to identify operator actions, and (3) the CSF flowchart logic and operator actions necessary to assess and maintain the CSFs, including the bases.
Open Items
- The staff is unable to conclude that the NuScale GTGs are acceptable for use as a basis for the development of COL applicant P-STGs. This is contingent upon the achievement of satisfactory results from ISV testing and validation activities and the subsequent incorporation of any necessary changes to the GTGs and the associated 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 Information Items the applicant provided are appropriate and acceptable. The staff will make a conclusion on the GTGs at a later time.
January 23, 2019 Chapter 13 Conduct of Operations 10
Acronyms COL: Combined License CSF: Critical Safety Function DCA: Design Certification Application EP: Emergency Planning GTG: Generic Technical Guidelines ISV: Integrated System Validation ITAAC: inspections, tests, analyses, and acceptance criteria OER: operating experience review NRO: US NRC Office of New Reactors NRR: US NRC Office of Nuclear Reactor Regulation NSIR: US Office of Nuclear Security and Incident Response PAM: Post Accident Monitoring PSS: Process Sampling System RES: US NRC Office of Research TSC: Technical Support Center January 23, 2019 Chapter 13 Conduct of Operations 11
NuScale Nonproprietary ACRS Presentation Human Factor Engineering Chapter 18 Overview January 23, 2019 Doug Bowman Supervisor Plant Operations 1
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Human Factors Engineering - NuScale goals
- 1. Integrate HFE into the development, design, and evaluation of the plant
- Eliminate operator actions in the design basis
- 2. Provide an HFE design that facilitates the safe, efficient and reliable operation, maintenance, testing, inspection, and surveillance of the plant
- Ensure an operator is able to quickly assess the status off all 12 units
- 3. Provide a state-of-the-art human factors design that satisfies regulatory requirements
- Expand the use of automation for routine normal tasks to limit operator workload 2
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Operating Experience Review
- NuScale performed an extensive review of operating experience in the following industries and facilities:
Currently operating nuclear power plants Nuclear facilities that do not produce power Nonnuclear power plants A U.S. military platform The heath care, electrical distribution, airline industry
- The purpose of the review was to identify HFE-related safety issues and incorporate identified positive features in the NuScale plant design.
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Operating Experience Summary Current Industry concerns and benefits:
- Alarm avalanche in the control room and the need to prioritize and control them.
Tiered alarm system - Alarm, Caution and Notice
- Operating multiple units from a single control room SMEs with commercial plant experience from various disciplines at NuScale provided input to the initial staffing levels and bases.
Benchmarking at Bruce Power displayed the operation of four reactors in the same control room.
- From this benchmarking trip, the concept of the control room supervisor as a resource manager and providing additional operators as a resource to the at the controls operator evolved.
Benchmarking at T. H. Wharton Gas Turbine generating station (a total of 17 gas and steam turbine units operating in both simple and combined cycle) operated by a single operator from a single control room.
- From this benchmarking trip, the concept of a single operator in control of multiple units evolved.
- Providing the operators with back up control stations and a thorough understanding of various I&C system failures and effects was important.
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Task Analysis
- Performed by SMEs - former commercial licensed operators.
- Provided the foundation for all procedures developed for SPV testing required to operate the plant.
- TA was the cornerstone for cognitive and performance based operator training that is required for S&Q.
- TA was essential to the HSI development and the V&V process.
- Used a software database that the nuclear industry currently uses to manage operator training programs.
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Treatment of Important Human Actions Results Important Human Actions:
- The NuScale plant identified two risk-important human actions:
- 1) Add water to the Reactor Coolant system with the Chemical and Volume Control system
- 2) Add water to Containment with the Containment flood and drain system
- No deterministic-important human actions were identified by transient and accident analysis or by diversity and defense-in-depth coping analysis.
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Treatment of Important Human Actions Results
- The IHAs are utilized in three major beyond design basis accident conditions:
Containment Bypass event ECCS failure of either all Reactor Vent valves or all Reactor recirc valves to open Complete failure of the decay heat removal system and both reactor safety valves
- Both important human actions were sampled during staffing plan validation
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Staffing and Qualifications Summary
- S&Q activities were based on the following NuScale design attributes:
no operator actions are required for design basis events.
the HSI design provides at-a-glance assessment of plant conditions and facilitates early detection of degrading conditions.
one operator can have primary focus of maintaining a monitoring role during normal, abnormal, and emergency conditions.
- SPV verified that a NuScale power plant can be operated safely and reliably from a single control room by a contingent of:
three licensed reactor operators three licensed senior reactor operators
- Non-Licensed operators COL will address the staffing and qualifications of non-licensed operators.
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Staffing Plan Validation
- Performed August 2016
- Consisted of two crews of five NuScale Operations staff Trained to perform the tasks necessary to accomplish the validation Did not know the content or sequence of the scenarios 9
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Staffing Plan Validation Scenario Tasks were sampled from the task analysis based on the following attributes:
- High risk
- High stress
- High consequence of inaccurate performance
- High cognitive or physical work load
- Requires communication outside of operations
- Abnormal, transient or severe conditions
- High time pressure
- Also sampled tasks with a high frequency (once a day or more) 10 PM-0119-64207 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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Staffing Plan Validation
- These tasks were grouped into three very challenging scenarios and each crew performed all three scenarios
- Testing methodology was based on NuScales anticipated ISV testing methodology
- Observer and operator feedback was collected
- Task times were collected for those tasks that had time limits
- SPV successfully demonstrated that the NuScale design could be safely operated by the proposed staff.
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Human-System Interface Design Summary
- NuScales integrated HSI design was developed by a multi-faceted HSI design team that brought unique skills and knowledge to the effort.
- FRA/FA, TIHA and TA results, tabletop activities helped the team develop the layout and construct the MCR simulator.
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Human Factors Verification and Validation Summary
- Design verification activities were conducted between August 23, 2017 through July 23, 2018
- The NuScale ISV testing was performed from July 23, 2018 through September 6, 2018.
- Three crews of operators were selected to participate in a training program to qualify them as ISV-certified operators.
- This training primarily focused on technical design knowledge, but also stressed the importance of providing feedback during the ISV testing period.
- The overall conclusion of the testing is that the NuScale control room design and staffing plan support safe operation of the NuScale plant.
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Human Factors Verification and Validation Summary
- V&V RSR is an open item for the Chapter 18 SER.
- V&V RSR will be submitted by the end of March 2019
- Completed 2 trials for all 12 scenarios
~8000 total data points captured
- 32 HEDs no Priority 1 9 Priority 2 23 Priority 3
- IHA actions completed with 72% margin of the time allowed 15 PM-0119-64207 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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Design Implementation Summary
- Completion of design implementation activities is tracked and confirmed by an ITAAC.
- This ensures that the as-built design conforms to the verified and validated design resulting from the HFE design process.
- After completion of start-up testing and provisional turn over, a licensee institutes a HPM program to evaluate impacts on human performance going forward.
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COL items
- A COL applicant that references the NuScale Power Plant design certification will provide a description of the HPM program in accordance with applicable NUREG-0711 or equivalent criteria.
- A COL applicant that references the NuScale Power Plant design certification will address the S&Q of non-licensed operators.
- The training program and procedure development for the COL are addressed in Chapter 13.
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Open items
- Total of 23 open items in the SER
- 19 will be closed by the V&V RSR
- 1 will be closed by completion of revision to HSI Style Guide
- 1 will be closed by completion of the Chapter 7, 15 and 19 SERs Closure of the remaining 2 items are being actively being pursued between the NRC and NuScale staff
- RAI 9612 Remote Shutdown Station ITAAC 18 PM-0119-64207 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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- COL- combined license
- RSR- results summary report
- FA- functional analysis
- SER- safety evaluation report
- FRA- functional requirements analysis
- SME- subject matter expert
- HED- human engineering discrepancies
- SPV- staffing plan validation
- HFE- human factors engineering
- S&Q- staffing and qualification
- HPM- human performance monitoring
- TA- task analysis
- HSI- human system-interface
- TIHA- treatment of important human actions
- I&C- instrument and controls
- V&V- verification and validation
- IHA- important human action
- ISV- integrated system validation
- ITAAC- Inspections, Test, Analyses, and Acceptance Criteria
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Portland Office Richland Office 6650 SW Redwood Lane, 1933 Jadwin Ave., Suite 130 Suite 210 Richland, WA 99354 Portland, OR 97224 541.360.0500 971.371.1592 Arlington Office Corvallis Office 2300 Clarendon Blvd., Suite 1110 1100 NE Circle Blvd., Suite 200 Arlington, VA 22201 Corvallis, OR 97330 541.360.0500 London Office 1st Floor Portland House Rockville Office Bressenden Place 11333 Woodglen Ave., Suite 205 London SW1E 5BH Rockville, MD 20852 United Kingdom 301.770.0472 +44 (0) 2079 321700 Charlotte Office 2815 Coliseum Centre Drive, Suite 230 Charlotte, NC 28217 980.349.4804 http://www.nuscalepower.com Twitter: @NuScale_Power 20 PM-0119-64207 Revision: 0 Copyright 2018 by NuScale Power, LLC.
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Safety Evaluation with Open Items:
Ch 18, Human Factors Engineering NuScale Design Certification Application Review ACRS Subcommittee Meeting January 23, 2019
NRC Staff Review Team
- Technical Staff Dr. Amy DAgostino, RES Dr. Brian Green, NRR Lauren Nist, NRR Maurin Scheetz, NRR
- Project Managers Greg Cranston - Lead Project Manager Prosanta Chowdhury - Chapter 18 Project Manager January 23, 2019 Chapter 18 Human Factors Engineering 2
Agenda
- Purpose and scope
- Review activities and timeline
- Areas of interest
- Open items
- Conclusion January 23, 2019 Chapter 18 Human Factors Engineering 3
Purpose and Scope
- Purpose
- Verify that the 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
- Methods used to conduct HFE analyses and the results
- Description of the HSI design and the concept of operations
- SPV methods and results
- ISV methods (note: ISV results will be submitted no later than March 2019)
- DCA Part 2, Tier 1, Section 3.15
- Audits of HFE analyses, SPV testing, and ISV testing January 23, 2019 Chapter 18 Human Factors Engineering 4
Review Activities and Timeline
- Pre-application activities (complete)
- Reviewed HFE IPs
- Phase 1 and 2 activities (complete)
- Reviewed and conducted audit of results of HFE analyses
- Reviewed and conducted audit of ISV methods, ISV testing, and HSIs
- Phase 4 activities (in progress)
- Review the applicants V&V results and resolve open items January 23, 2019 Chapter 18 Human Factors Engineering 5
Areas of Interest
- Potential human performance issues specific to SMRs are identified in NUREG/CR-7126 and NUREG/CR-7202
- The staff considered the effects of the following on human performance and safe plant operation:
- Multi-unit operation from a single operator workstation and from a single control room
- Relatively higher amount of automation
- Novel HSI design features January 23, 2019 Chapter 18 Human Factors Engineering 6
Open Items
- The Phase 2 SER contains 23 open items for the following topics:
- Review of the applicants V&V results (19 open items)
- Scope of the HFE ITAAC and documentation of the HFE activities to be performed by the licensee (1 open item)
- Evaluate whether changes to Ch 7 related to remote shutdown affect Ch 18 and verify accuracy of the SER (1 open item)
- Confirm conclusions in SER Chapters 7, 15 and 19 about the treatment of important human actions are consistent with those in Ch 18 (1 open item)
- Ensure that HFE reports are incorporated by reference into Tier 2 (1 open item)
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Conclusion
- The results of the SPV testing support the applicants proposed staffing plan. The staff will confirm the ISV results also support the staffing plan or that any changes have been made if needed.
- Based on the staffs observations of the ISV test, the staff expects that the ISV results will provide evidence that the HFE design adequately supports plant personnel in safely operating the plant.
- The open items identified in the safety evaluation need to be resolved for the staff to find that the HFE design complies with all NRC requirements related to HFE and thus that the HFE design supports personnel in the safe operation of the plant.
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Acronyms FA: function allocation FRA: functional requirements analysis HFE: human factors engineering HSI: human-system interface IP: implementation plan ISV: integrated system validation ITAAC: inspections, tests, analyses, and acceptance criteria OER: operating experience review NRR: US NRC Office of Nuclear Reactor Regulation RES: US NRC Office of Research RSR: results summary report SER: safety evaluation report SPV: staffing plan validation TA: task analysis V&V: verification and validation January 23, 2019 Chapter 18 Human Factors Engineering 9