ML18101B398

LLC Response to NRC Request for Additional Information No. 390 (Erai No. 9371) on the NuScale Design Certification Application

ML18101B398
Person / Time
Site:	NuScale
Issue date:	04/11/2018
From:	Rad Z NuScale
To:	Document Control Desk, Office of New Reactors
References
RAIO-0418-59516
Download: ML18101B398 (5)

Text

RAIO-0418-59516 April 11, 2018 Docket No.52-048 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738

SUBJECT:

NuScale Power, LLC Response to NRC Request for Additional Information No.

390 (eRAI No. 9371) on the NuScale Design Certification Application

REFERENCE:

U.S. Nuclear Regulatory Commission, "Request for Additional Information No.

390 (eRAI No. 9371)," dated March 19, 2018 The purpose of this letter is to provide the NuScale Power, LLC (NuScale) response to the referenced NRC Request for Additional Information (RAI).

The Enclosure to this letter contains NuScale's response to the following RAI Question from NRC eRAI No. 9371:

18-24 This letter and the enclosed response make no new regulatory commitments and no revisions to any existing regulatory commitments.

If you have any questions on this response, please contact Steven Mirsky at 240-833-3001 or at smirsky@nuscalepower.com.

Sincerely, Zackary W. Rad Director Regulatory Affairs

Director, NuScale Power, LLC Distribution: Samuel Lee, NRC, OWFN-8G9A Prosanta Chowdhury NRC, OWFN-8G9A Demetrius Murray, NRC, OWFN-8G9A : NuScale Response to NRC Request for Additional Information eRAI No. 9371 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0418-59516 :

NuScale Response to NRC Request for Additional Information eRAI No. 9371 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9371 Date of RAI Issue: 03/19/2018 NRC Question No.: 18-24 Title 10 of the Code of Federal Regulations (10 CFR) Section 52.47(a)(8) requires an applicant for a design certification to provide a final safety analysis report (FSAR) that must include the information necessary to demonstrate compliance with any technically relevant portions of the Three Mile Island requirements set forth in 10 CFR 50.34(f), except paragraphs (f)(1)(xii),

(f)(2)(ix), and (f)(3)(v). Section 10 CFR 50.34(f)(2)(iii) requires an applicant to "Provide, for Commission review, a control room design that reflects state-of-the-art human factor principles prior to committing to fabrication or revision of fabricated control room panels and layouts.

Chapter 18, Human Factors Engineering, of NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, and NUREG-0711, "Human Factors Engineering Program Review Model, identify criteria the staff uses to evaluate whether an applicant meets the regulation. The applicant stated in the FSAR, Tier 2, Section 18.0, "Human Factors Engineering - Overview," that its human factors engineering (HFE) program incorporates accepted HFE standards and guidelines including the applicable guidance provided in NUREG-0711, Revision 3.

Criterion 11.4.3.4 (1) states, Participants in the applicants validation tests should be representative of plant personnel who will interact with the HSI (e.g., licensed operators, rather than training personnel or engineers). In addition 11.4.3.4 (4) states, The applicant should prevent bias in the sample of participants by avoiding the use of participants who:

are members of the design organization participated in prior evaluations were selected for some specific characteristic, such as crews identified as good performers or more experienced The Human Factors Verification and Validation Implementation Plan, Section 4.4, Individual operating crews participating in the ISV may be previously licensed commercial reactor or senior reactor operators, operators with Navy nuclear experience, or design engineering staff members familiar with the NuScale Power plant design.

As members of the design engineering staff are cited as potential ISV participants, please clarify how they are representative of the anticipated plant personnel who will interact with the HSI and explain how bias is prevented. Also, please clarify whether ISV participants have participated in NuScale Nonproprietary

prior evaluations (e.g. staffing plan validation, etc).

NuScale Response:

Twenty two individuals have been selected to perform as plant personnel in the Integrated System Validation (ISV) testing. The selected individuals are categorized into three groups based on their previous experience.

Previously licensed commercial nuclear power plant operators (either SRO or RO) (nine individuals)

Previously non-licensed commercial nuclear power plant operators or Navy nuclear plant operators (eight individuals)

Engineering degree with no previous operating experience (five individuals)

This is representative of the pool of plant personnel expected to operate in a NuScale control

room and is consistent with the types of operators currently found in the existing nuclear

industry (reference ACAD 10-001, Guidelines for Initial Training and Qualification of Licensed

Operators). The three paths to control room licensed operator qualification in the existing

industry are:

Previously licensed commercial nuclear power plant operators (either SRO or RO)

Non-licensed commercial nuclear power plant operators that have been selected as a candidate for license class training Individuals with engineering degrees that have been selected as direct SRO candidates The NuScale ISV plant personnel have been specifically selected to represent the types of

candidates that are currently selected to enter commercial nuclear license classes.

Two of the twenty two ISV plant personnel have had previous involvement with NuScale.

One is a NuScale employee that has worked for the Probabilistic Risk Assessment (PRA)

group in the Engineering Department. This individual has never been involved with the

HSI or control room design and has no HFE design organization experience. This

individual does have significant knowledge in regards to the physical plant design and

PRA methodology and sequences.

One was a former participant in the staffing plan validation conducted in August of 2016.

This individual also worked as an operator at the NuScale Integrated System Test (NIST)

facility and participated in initial screening and applicability review of Operating

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NuScale Nonproprietary

Overall, the selected ISV plant personnel are a diverse yet representative sample of operators who are anticipated to interact with the NuScale HSI.

Impact on DCA:

There are no impacts to the DCA as a result of this response.

NuScale Nonproprietary