Text

LLC - Transmittal of Response to NRC Request for Additional Information No. 392 (Erai No. 9318) on the NuScale Design Certification Application
	ML18141A866
Person / Time
Site:	NuScale
Issue date:	05/21/2018
From:	Rad Z; NuScale
To:	; Document Control Desk, Office of New Reactors
Shared Package
ML18141A864	List: ML18141A866;
References
	AF-0518-60074, RAIO-0518-60073
	Download: ML18141A866 (44)
	v • d • e

RAIO-0518-60073 May , 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.

392 (eRAI No. 9318) on the NuScale Design Certification Application

REFERENCE:

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

392 (eRAI No. 9318)," dated March 20, 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 Enclosures to this letter contain NuScale's response to the following RAI Questions from NRC eRAI No. 9318:

18-26 18-27 18-28 18-29 18-30 18-31 18-32 18-33 is the proprietary version of the NuScale Response to NRC RAI No. 392 (eRAI No.

9318). NuScale requests that the proprietary version be withheld from public disclosure in accordance with the requirements of 10 CFR § 2.390. The proprietary enclosures have been deemed to contain Export Controlled Information. This information must be protected from disclosure per the requirements of 10 CFR § 810. The enclosed affidavit (Enclosure 3) supports this request. Enclosure 2 is the nonproprietary version of the NuScale response.

This letter and the enclosed responses make no new regulatory commitments and no revisions to any existing regulatory commitments.

NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0518-60073 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 Zackary Z

Director, Regulatory Affairs Director NuScale Power, LLC Distribution: Gregory Cranston, NRC, OWFN-8G9A Samuel Lee, NRC, OWFN-8G9A : NuScale Response to NRC Request for Additional Information eRAI No. 9318, proprietary : NuScale Response to NRC Request for Additional Information eRAI No. 9318, nonproprietary : Affidavit of Zackary W. Rad, AF-0518-60074 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0518-60073 :

NuScale Response to NRC Request for Additional Information eRAI No. 9318, proprietary NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0518-60073 :

NuScale Response to NRC Request for Additional Information eRAI No. 9318, nonproprietary 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.: 9318 Date of RAI Issue: 03/20/2018 NRC Question No.: 18-26 Regulations in 10CFR 50.34(f)(2)(v) require automatic indication of the bypassed and inoperable status of safety systems. Chapter 18, Human Factors Engineering, of NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, lists NUREG-0711, "Human Factors Engineering Program Review Model, and NUREG-0700, Human-System Interface Design Review Guidelines, as the sources of acceptance criteria the staff uses to evaluate whether an applicant meets the regulation. NUREG-0711, Criterion 8.4.4.2(2), describes an acceptable method for complying with the regulation for bypassed and inoperable status indication (BISI).

Provide a description for the following items and revise the submittal as necessary:

1. The staff could not find a description of the provisions for allowing the operations staff to confirm that a bypassed safety function was properly returned to service, which is addressed in the third bullet in NUREG-0711, Criterion 8.4.4.2(2).

2. The staff could not find how the application addresses the following, which is addressed by the sixth bullet of NUREG-0711, Criterion 8.4.4.2(2): Bypass and inoperable status indicators should be arranged such that personnel can determine whether it is permissible to continue operating the reactor.

NuScale Response:

RP-0316-17619, Human-System Interface Design Result Summary Report (HSI Design RSR),

was revised to update Section 4.6.2.2. to include information on how the NuScale HSI provides the operator with the provisions to confirm a bypassed safety function is properly returned to service and how personnel can determine whether it is permissible to continue operating the reactor.

Impact on DCA:

Human-System Interface Design Results Summary Report, RP-0316-17619, has been revised as described in the response above and as shown in the markup provided with this response.

NuScale Nonproprietary

Human Factors Engineering Human-System Interface Design Results Summary Report RP-0316-17619-NP Draft Rev. 21

2. Bypassed and Inoperable Status Indication The NuScale HSI design addresses the bypassed or inoperable status indication (BISI) function 10 CFR 50.34(f)(2)(v) requirement to provide for automatic indication of the bypassed and operable status of safety systems as discussed below.

The HSI continuously monitors the operability and position status of the components supporting the plant safety related functions. The HSI updates the information on the appropriate system display pages and for the SDCV locations. ((2(a),(c) © Copyright 20187 by NuScale Power, LLC 94

Human Factors Engineering Human-System Interface Design Results Summary Report RP-0316-17619-NP Draft Rev. 21 ((

                                                                              }}2(a),(c)

3. Relief and Safety Valve Position Monitoring The NuScale HSI design addresses the 10 CFR 50.34(f)(2)(xi) requirement to provide direct indication of relief and safety valve position (open or closed) in the control room as discussed below.

((

                                                                                    }}2(a),(c)

4. Manual Feedwater Control 10 CFR 50.34(f)(2)(xii) refers to a safety-related auxiliary feedwater system that is not applicable in the NuScale plant.

5. Containment Monitoring The NuScale HSI design addresses the 10 CFR 50.34(f)(2)(xvii) requirement to provide instrumentation to measure, record and readout in the control room: (A) containment pressure, (B) containment water level, (C) containment hydrogen concentration, (D) containment radiation intensity (high level), and (E) noble gas effluents at all potential, accident release points as discussed below.

Response to Request for Additional Information Docket No. 52-048 eRAI No.: 9318 Date of RAI Issue: 03/20/2018 NRC Question No.: 18-27 Regulations in 10 CFR 50.34(f)(2)(xi) require direct indication of relief and safety valve position (open or closed) in the control room. NUREG-0711, Criterion 8.4.4.2(3) states that the applicant should describe how the HSI indicates the position of the relief and safety valves (open or closed) in the control room. DCD Tier 2, Section 6.3.1, Emergency Core Cooling- Design Basis, addresses the 10 CFR 50.34(f)(2)(xi) requirement and states that valve position indication is provided in the main control room for the ECCS valves, trip and reset actuator valves and the reactor safety valves (RSVs). HSI RSR Section 4.6.2(3) Relief and Safety Valve Position Monitoring, describes which HSI displays will contain this information and HSI RSR Section 7.0 contains examples of the HSI described in Section 4.6.2(3). However, the staff observed that the examples do not show the information that HSI RSR Section 4.6.2(3) says will be displayed on those HSIs.

1. Please explain whether the examples in the HSI RSR Section 7.0 are representative of the HSI that is designed to comply with 10 CFR 50.34(f)(2)(xi), and please explain whether the HSI will need to be updated to comply with 10 CFR 50.34(f)(2)(xi). Revise the submittal as necessary.

2. It is not clear to the staff if Reactor Pressure Vessel relief valves are the same as the Reactor Safety Valves (RSVs). Please clarify. Revise the submittal as necessary.

NuScale Response: 18-27 Question 1: RP-0316-17619, Human Factors Engineering Human-System Interface Design Results Summary Report (HSI RSR), Section 4.6.2.3 states: ((

                                                                                          }}2(a),(c)

NuScale Nonproprietary

((

                                                                           }}2(a),(c)

As noted above, the lack of reactor safety valve (RSV) (also known as reactor pressure vessel relief valve) position indication is a known deficiency that is tracked in the HFEITS database. ES-0304-1381, Human-System Interface Style Guide, Figures 4-12 and F-1, and RP-0316-17619, Human Factors Engineering Human-System Interface Design Results Summary Report, Figure 7-3, have been revised to include the 10 CFR 50.34(f)(2)(xi) compliant HSI display pages. 18-27 Question 2: Reactor pressure vessel relief valves are discussed in Section 4.6.2.3 of the HSI RSR and are the same as the reactor safety valves (RSVs) discussed in FSAR Section 5.1.3.5. FSAR Section 5.2.2.4.1 states, "Each RSV is a pilot operated relief valve designed in accordance with the requirements of ASME BPVC, Section III, Sub-article NB-7520." "Reactor safety valve" and "reactor pressure vessel relief valve" are synonymous. Nevertheless, the HSI RSR Section 4.6.2.3 has been revised to replace "reactor pressure vessel relief valve" with "reactor safety valve" for consistency. Impact on DCA: RP-0316-17619, Human Factors Engineering Human-System Interface Result Summary Report and ES-0304-1381, Human-System Interface Style Guide have been revised as described in the response above and as shown in the markup provided with this response. NuScale Nonproprietary

Human Factors Engineering Human-System Interface Design Results Summary Report RP-0316-17619-NP Draft Rev. 21 ((

                                                                              }}2(a),(c)

3. Relief and Safety Valve Position Monitoring The NuScale HSI design addresses the 10 CFR 50.34(f)(2)(xi) requirement to provide direct indication of relief and safety valve position (open or closed) in the control room as discussed below.

((

                                                                                    }}2(a),(c)

4. Manual Feedwater Control 10 CFR 50.34(f)(2)(xii) refers to a safety-related auxiliary feedwater system that is not applicable in the NuScale plant.

5. Containment Monitoring The NuScale HSI design addresses the 10 CFR 50.34(f)(2)(xvii) requirement to provide instrumentation to measure, record and readout in the control room: (A) containment pressure, (B) containment water level, (C) containment hydrogen concentration, (D) containment radiation intensity (high level), and (E) noble gas effluents at all potential, accident release points as discussed below.

Human Factors Engineering Human-System Interface Design Results Summary Report RP-0316-17619-NP Draft Rev. 21 ((

                                                                                                      }}2(a),(c),ECI Figure 7-3.        SDI pages

Human-System Interface Style Guide ES-0304-1381-NP Draft Rev. 32 4.11.2 Display Pages ((

                                                                                }}2(a),(c),ECI Figure 4-12.       Safety Display and Indication (SDI) - E014
© Copyright 20187 by NuScale Power, LLC 542

Human-System Interface Style Guide ES-0304-1381-NP Draft Rev. 32 ((

                                                               }}2(a),(c),ECI Figure F-1. SDI display pages

Response to Request for Additional Information Docket No. 52-048 eRAI No.: 9318 Date of RAI Issue: 03/20/2018 NRC Question No.: 18-28 Regulations in 10 CFR 50.34(f)(2)(xvii) require instrumentation to measure, record and readout in the control room: (A) containment pressure; (B) containment water level; (C) containment hydrogen concentration; (D) containment radiation intensity (high level); and (E) noble gas effluents for all potential, accident release points. NUREG-0711, Criterion 8.4.4.2(5) states that the applicant should describe how the control rooms HSIs (alarms and displays) inform personnel about: (A) containment pressure; (B) containment water level; (C) containment hydrogen concentration; (D) containment radiation intensity (high level); and (E) noble gas effluents for all potential, accident release points. (C) containment hydrogen concentration In HSI RSR Section 4.6.2(5) Containment Monitoring, NuScale states that they are seeking an exemption from supplying containment hydrogen concentration parameters; however, DCD Part 7, Exemptions, does not contain an exemption for either 10 CFR 50.44(c)(4) or 10 CFR 50.34(f)(2)(xvii)(C). Furthermore, DCD Tier 2 Chapter 7.2.13 Displays and Monitoring, states that consistent with 10 CFR 50.34(f)(2)(xvii)(C) and 10 CFR 50.44(c)(4), the containment Process Sampling System (PSS) includes non-safety related oxygen and hydrogen analyzers to continuously monitor the concentrations of these elements in the containment environment during operation and beyond design-basis conditions. The hydrogen analyzer output signal is sent to the MCS, which can provide readout in the main control room. Align the information in DCD Tier 2 Chapter 7, the HSI RSR and DCD Part 7. Revise the submittal as necessary. (D) containment radiation intensity (high level) Information provided in HSI RSR Section 4.6.2(5), Containment Monitoring, for radiation monitoring contradicts information provided in DCD Tier 2 Chapter 12.3.4, Area Radiation and Airborne Radioactivity Monitoring Instrumentation, which states that the area and airborne radiological monitoring equipment is designed to provide monitoring of containment radiation levels, conforming to 10 CFR 50.34(f)(2)(xvii). Align the information in DCD Tier 2 Chapter 12 and the HSI RSR. Revise the submittal as necessary. NuScale Nonproprietary

(E) noble gas effluents for all potential, accident release points Information provided in HSI RSR Section 4.6.2(5), Containment Monitoring, for noble gas effluent monitoring contradicts information in Tier 2 Chapter 11.5 Process and Effluent Radiation Monitoring Instrumentation and Sampling System which states that monitoring and sampling equipment has been designed to provide monitoring and sampling instrumentation for measuring and recording noble gas radiological data at release points. The system also provides continuous monitoring and sampling of radioactive iodine and particulates in gaseous effluents from accident release points in accordance with the requirements of 10 CFR 50.34(f)(2)(xvii) . Align the information in DCD Tier 2 Chapter 11 and the HSI RSR. Explain how the control rooms HSIs (alarms and displays) inform personnel about noble gas effluents for all potential, accident release points. Revise the submittal as necessary. NuScale Response: RP-0316-17619, Human-System Interface Design Result Summary Report (HSI RSR), Section 4.6.2 (5) was revised to update information consistent with FSAR Chapters 7, 11, and 12 and the DCA Part 7. The NuScale HSI monitors noble gas effluents using information from radiation monitors installed at each potential effluent point. The HSI will alarm when the noble gas release rate, for each release point, exceeds the rate that would result in an emergency declaration. There will also be additional notifications, for each release point, set at a rate below the emergency declaration release rate. These additional notifications provide the operator with situational awareness cues of changing radiological conditions and that an effluent parameter is trending toward an emergency declaration. Impact on DCA: RP-0316-17619, Human-System Interface Design Results Summary Report, has been revised as described in the response above and as shown in the markup provided with this response. NuScale Nonproprietary

Human Factors Engineering Human-System Interface Design Results Summary Report RP-0316-17619-NP Draft Rev. 21 ((

                                                                              }}2(a),(c)

3. Relief and Safety Valve Position Monitoring The NuScale HSI design addresses the 10 CFR 50.34(f)(2)(xi) requirement to provide direct indication of relief and safety valve position (open or closed) in the control room as discussed below.

((

                                                                                    }}2(a),(c)

4. Manual Feedwater Control 10 CFR 50.34(f)(2)(xii) refers to a safety-related auxiliary feedwater system that is not applicable in the NuScale plant.

5. Containment Monitoring The NuScale HSI design addresses the 10 CFR 50.34(f)(2)(xvii) requirement to provide instrumentation to measure, record and readout in the control room: (A) containment pressure, (B) containment water level, (C) containment hydrogen concentration, (D) containment radiation intensity (high level), and (E) noble gas effluents at all potential, accident release points as discussed below.

Human Factors Engineering Human-System Interface Design Results Summary Report RP-0316-17619-NP Draft Rev. 21 ((

                                                                                                        }}2(a),(c)

Note: The underlying purpose of the containment hydrogen monitoring requirements of 10 CFR 50.44(c)(4), and 10 CFR 50.34(f)(2)(xvii)(C) is to:

1) identify and assess core damage during and following an accident, and

2) assess containment combustible gas conditions to determine if mitigating actions are required.

The containment hydrogen level parameter is not needed for assessing core damage because the NuScale design uses the under Bioshield Radiation monitors to provide core damage assessment capabilities. The containment hydrogen level parameter is used for assessment of containment combustible gas conditions during and following a design bases event or beyond design bases event. Because the containment sampling system equipment is located outside of the containment, the continuous monitoring of hydrogen level for the combustible gas control is unavailable when the containment is isolated during an accident scenario. However, containment hydrogen monitoring immediately after an event is not necessary as hydrogen combustion scenarios occurring within 72 hours following an event initiation have no adverse effect on containment integrity or plant safety functions. The analysis of combustion events in the NuScale containment demonstrates that no compensatory measures or mitigating actions are required for any scenario, within the first 72 hours of an event. Accumulation of combustible gases beyond 72 hours can be managed by licensee implementation of severe accident management guidelines because after 72 hours, sufficient time is available to implement mitigating actions. Containment gas sampling and the monitoring of flow paths can be re-established when the plant conditions are amenable to perform post-accident sampling. The NuScale HSI displays noble gas effluents using information from radiation monitors installed at each potential effluent point. The HSI will alarm when the noble gas release rate, for each release point, exceeds the rate that would result in an emergency declaration. There will also be additional notifications, for each release point, set at a rate below the emergency declaration release rate. These additional notifications provide the operator with situational awareness cues of changing radiological conditions and that an effluent parameter is trending toward an emergency declaration. NuScale is seeking an exemption from supplying this parameter based on:

3) This parameter is not needed because the NuScale design is relying on the under Bioshield Radiation monitors to provide core damage assessment capabilities

Human Factors Engineering Human-System Interface Design Results Summary Report RP-0316-17619-NP Draft Rev. 21

4) Due to the fact that the possibility of damage to a subatmospheric containment from hydrogen is remote

5) With the NuScale design there is abundant time to assess and mitigate hydrogen generation if required

6) The NuScale design provides alternate means of indirectly measuring containment hydrogen

6. Core Cooling The NuScale HSI design addresses the CFR 50.34(f)(2)(xviii) requirement to provide unambiguous indication of inadequate core cooling, such as primary coolant saturation meters in pressurized water reactors (PWR), and a suitable combination of signals from indicators of coolant level in the reactor vessel and in-core thermocouples as discussed below.

((

                      }}2(a),(c)

7. Post-accident Monitoring The NuScale HSI design addresses the CFR 50.34(f)(2)(xix) requirement to ensure the monitoring of plant and environmental conditions following an accident that includes core damage as discussed below.

The HSI provides indication of plant conditions following an accident including core damage on the appropriate SDI display VDU in the MCR. Refer to the Safety Display and Indication System (Item 1 above) for more detail on the type of information displayed at this location.

8. Leakage Control The NuScale HSI design addresses the 10 CFR 50.34(f)(2)(xxvi) requirement to provide for leakage control and detection in the design of systems outside containment that contain (or might contain) accident-source-term radioactive materials following an accident as discussed below.

During accident conditions, the CVC is isolated from the RCS by the containment isolation valves and is not needed to circulate primary coolant outside of containment. In addition, there are no safety systems that circulate reactor coolant outside of containment. However, in order to support post-accident sampling by the PSS, the CVC is capable of being unisolated from the RCS, when conditions permit, to establish the © Copyright 20187 by NuScale Power, LLC 97

Response to Request for Additional Information Docket No. 52-048 eRAI No.: 9318 Date of RAI Issue: 03/20/2018 NRC Question No.: 18-29 Regulations in 10 CFR 50.34(f)(2)(xviii) require unambiguous indication of inadequate core cooling (ICC). NUREG-0711, Criterion 8.4.4.2(6) states than an applicant should describe how the HSI provides unambiguous indication of inadequate core cooling, such as with primary coolant saturation meters in PWRs, and a suitable combination of signals from indicators of coolant level in the reactor vessel and in-core thermocouples in PWRs and BWRs As described in DCD Tier 2, Section 7.2.13.6, Three Mile Island Action Items, the following parameters are used to monitor inadequate core cooling (ICC) in the control room and satisfy the requirements of 10 CFR 50.34(f)(2)(xviii): core exit temperature, wide range reactor coolant pressure, degrees of subcooling, wide range reactor coolant hot temperature, Reactor Pressure Vessel (RPV) water level and containment water level. HSI RSR, Section 4.6.2(6), Core Cooling, contains information about how the HSI addresses 10 CFR 50.34(f)(2)(xviii). HSI RSR Section 7.0, Figure 7-1 contains an example of one HSI described in Section 4.6.2(6). However, the staff observed that the example does not provide indication of the information that DCD Tier 2, Section 7.2.13.6 says will be displayed in the Main Control Room. Align the information in DCD Tier 2 Section 7.2.13 and the information in HSI RSR Figure 7-1, Safety Function Monitoring Page. Revise the submittal as necessary. NuScale Response: RP-0316-17619, Human-System Interface Design Results Summary Report (HSI RSR), Figure 7-1 "Safety Function Monitoring Page" is not the page NuScale created to monitor inadequate core cooling (ICC) in the main control room (MCR). Figure 7-3, "SDI Page" was intended to fulfill that function. As discussed in FSAR Section 7.2.13.2, post-accident monitoring variables are displayed in the MCR on the SDIS, MCS, and PCS via the SDI display page. Figure 7-3, SDI Pages, has been revised to contain the complete list of variables for unit-specific and common SDI pages that are described in FSAR Section 7.2.13.6, Three Mile Island Action Items. NuScale Nonproprietary

Impact on DCA: Figure 7-3 of RP-0316-17619, Human-System Interface Design Results Summary Report, has been revised as described in the response above and as shown in the markup provided with this response. NuScale Nonproprietary

Human Factors Engineering Human-System Interface Design Results Summary Report RP-0316-17619-NP Draft Rev. 21 ((

                                                                                                      }}2(a),(c),ECI Figure 7-3.        SDI pages

Response to Request for Additional Information Docket No. 52-048 eRAI No.: 9318 Date of RAI Issue: 03/20/2018 NRC Question No.: 18-30 Regulations in 10 CFR 50.34(f)(2)(xix) require an applicant to provide instrumentation adequate for monitoring plant conditions following an accident that includes core damage. NUREG-0711, Criterion 8.4.4.2(7) states than an applicant should describe how the HSI assures monitoring of plant and environmental conditions following an accident including core damage. Regulatory Guide 1.97 is one method that the NRC staff finds acceptable for complying with the agencys regulations with respect to satisfying criteria for accident monitoring instrumentation at nuclear power plants. This RG 1.97, Rev. 4 endorses IEEE-497-2002, IEEE Standard for Accident Monitoring Instrumentation for Nuclear Power Generating Stations, subject to several regulatory positions. According to DCD Tier 2 Section 7.2.13.2, System Status Indication, the Post Accident Monitoring (PAM) variables are displayed in the MCR on the Safety Display Indication System (SDIS), Module Control System (MCS) and Plant Control System (PCS). The SDIS displays continuous real time Type B, C and D PAM variables and meets the display criteria of IEEE-497-2002. PAM variables displayed on the SDIS are also displayed on MCS or PCS. Type E PAM variables are only displayed on MCS and PCS. There are 15 Type E PAM variables listed in DCD Tier 2 Section 7.2.13. The application does not describe how these are displayed. The staff compared the PAM variables listed in DCD Tier 2 Section 7.2.13 with the SDIS sample display page in HSI RSR Figure 7-3. For Type D PAM variables, only 18 out of 27 identified Type D variables are located on the SDI sample page in HSI RSR Figure 7-3. Contrary to DCD Tier 2 Section 7.2.13.2, System Status Indication, nine Type D variables are not displayed on the SDIS. Explain why some Type D variables listed in DCD Tier 2 Section 7 have been omitted from the SDIS display. Align the information in DCD Tier 2 Section 7.2.13 and the information in HSI RSR, Section 4.6.2(7), Post-accident Monitoring. Clarify how Type E PAM variables are displayed in the MCR. Revise the submittal as necessary. NuScale Nonproprietary

NuScale Response: RP-0316-17619, Human-System Interface Design Results Summary Report (HSI RSR), Figure 7-3, SDI Pages, has been revised to show SDI system pages that contain a complete list of Type A, B, C, and D variables consistent with those described in FSAR Table 7.1-7, Summary of Type A, B, C, D, and E Variables. Type E variables are not required to be displayed on the SDI displays. Type E variables are displayed through either the module control system (MCS) or plant control system (PCS) interfaces. The MCS and PCS compose the bulk of the controls and indications in the control room. The operator workstations in the main control room are part of the PCS. Impact on DCA: Figure 7-3 of RP-0316-17619, Human-System Interface Design Results Summary Report, has been revised as described in the response above and as shown in the markup provided with this response. NuScale Nonproprietary

Human Factors Engineering Human-System Interface Design Results Summary Report RP-0316-17619-NP Draft Rev. 21 ((

                                                                                                      }}2(a),(c),ECI Figure 7-3.        SDI pages

Response to Request for Additional Information Docket No. 52-048 eRAI No.: 9318 Date of RAI Issue: 03/20/2018 NRC Question No.: 18-31 Regulations in 10 CFR 50.34(f)(2)(xxvi) require an applicant to provide for leakage control and detection in the design of systems outside containment that contain or might contain radioactive materials. NUREG-0711, Criterion 8.4.4.2(10) states that an applicant should describe how the HSI provides for leakage control and detection in the design of systems outside containment that contain (or might contain) accident-source-term radioactive materials after an accident. The staff reviewed HSI RSR Figure 7-3, SDI Page, and observed that it does not include leakage control and detection parameters for systems outside containment as stated in HSI RSR Section 4.6.2(8), Leakage Control. Explain why the information in HSI RSR Figure 7-3 is not consistent with information provided in HSI RSR Section 4.6.2(8). Explain how the HSI provides for leakage control and detection in the design of systems outside containment that contain (or might contain) accident-source-term radioactive materials after an accident. NuScale Response: RP-0316-17619, Human-System Interface Design Results Summary Report, Section 4.6.2.8. and Figure 7-3 were revised to be consistent with each other and to provide clarification on how the HSI provides for leakage control and detection in the design of systems outside containment that contain (or might contain) accident-source-term radioactive materials after an accident. Impact on DCA: RP-0316-17619, Human-System Interface Design Results Summary Report, has been revised as described in the response above and as shown in the markup provided with this response. NuScale Nonproprietary

Human Factors Engineering Human-System Interface Design Results Summary Report RP-0316-17619-NP Draft Rev. 21

4) Due to the fact that the possibility of damage to a subatmospheric containment from hydrogen is remote

5) With the NuScale design there is abundant time to assess and mitigate hydrogen generation if required

6) The NuScale design provides alternate means of indirectly measuring containment hydrogen

6. Core Cooling The NuScale HSI design addresses the CFR 50.34(f)(2)(xviii) requirement to provide unambiguous indication of inadequate core cooling, such as primary coolant saturation meters in pressurized water reactors (PWR), and a suitable combination of signals from indicators of coolant level in the reactor vessel and in-core thermocouples as discussed below.

((

                      }}2(a),(c)

7. Post-accident Monitoring The NuScale HSI design addresses the CFR 50.34(f)(2)(xix) requirement to ensure the monitoring of plant and environmental conditions following an accident that includes core damage as discussed below.

The HSI provides indication of plant conditions following an accident including core damage on the appropriate SDI display VDU in the MCR. Refer to the Safety Display and Indication System (Item 1 above) for more detail on the type of information displayed at this location.

8. Leakage Control The NuScale HSI design addresses the 10 CFR 50.34(f)(2)(xxvi) requirement to provide for leakage control and detection in the design of systems outside containment that contain (or might contain) accident-source-term radioactive materials following an accident as discussed below.

During accident conditions, the CVC is isolated from the RCS by the containment isolation valves and is not needed to circulate primary coolant outside of containment. In addition, there are no safety systems that circulate reactor coolant outside of containment. However, in order to support post-accident sampling by the PSS, the CVC is capable of being unisolated from the RCS, when conditions permit, to establish the © Copyright 20187 by NuScale Power, LLC 97

Human Factors Engineering Human-System Interface Design Results Summary Report RP-0316-17619-NP Draft Rev. 21 sample flow path from the CVC discharge piping upstream of the Regenerative Heat Exchanger. The leakage control and detection parameters for systems outside containment are provided on the display pages that are available on the workstation VDUs in the MCR. These parameters include flows, pressures, tank levels, radiation levels, and alarms generated from these indications.The leakage control and detection parameters for systems outside containment are displayed on the SDI, Plant Overview and Containment Evacuation display pages and are available on the workstation VDUs in the MCR.

9. Radiation Monitoring The NuScale HSI design addresses the 10 CFR 50.34(f)(2)(xxvii) requirement to provide appropriate monitoring of in-plant radiation and airborne radioactivity for a broad range of routine and accident conditions as discussed below.

Radiation monitoring for the NuScale plant is a shared unit system. Thus, the monitoring and display of in-plant radiation and airborne radioactivity for the range of routine and accident conditions is on the common systems panel VDU in the MCR. In addition, the Feed and Condensate and Containment Evacuation display pages contain trends to display system radiation levels.

10. Manual Initiation of Protective Actions As required by Regulatory Guide 1.62, safety system automation override and manual initiation of safety functions during unanalyzed conditions is provided ((

                                                        }}2(a),(c)

Human Factors Engineering Human-System Interface Design Results Summary Report RP-0316-17619-NP Draft Rev. 21 ((

                                                                                                      }}2(a),(c),ECI Figure 7-3.        SDI pages

Response to Request for Additional Information Docket No. 52-048 eRAI No.: 9318 Date of RAI Issue: 03/20/2018 NRC Question No.: 18-32 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 FSAR, Tier 2, Section 18.0, "Human Factors Engineering - Overview," indicates that the HFE program incorporates the applicable guidance provided in NUREG-0711, Revision 3. NUREG-0711, Rev. 3, "Human Factors Engineering Program Review Model," Criterion 8.4.4.2(12), Manual Initiation of Protective Actions, states that the applicant should describe how the HSI supports the manual initiation of protective actions at the system level for safety systems otherwise initiated automatically. The staff reviewed DCD Tier 2 Section 7.2.12.2, Manual Control, and Human Systems Interface Design Results Summary Report, RP-0316-17619-P, Revision 0 Section 4.6.2(10), Manual Initiation of Protective Actions, and found that the list for manual actuation of protective actions in Section 7 does not match the HSI for manual action of protection actions provided in HSR RSR Section 4.6.2(10) and Figure 4-51. The staff does not have information about how the HSI supports manual initiation of all the protective actions described in Section 7. Align the information in the HSI RSR with the information in DCD Tier 2 Section 7.2.12.2. Revise the submittal as necessary. Explain how the HSI supports manual initiation of all protective actions for safety systems otherwise initiated automatically. NuScale Nonproprietary

NuScale Response: RP-0316-17619, Human-System Interface Design Result Summary Report (HSI RSR), Section 4.2.2.1, Figure 4-2, Section 4.6.2.10. and Figures 4-51 and 4-52 were revised to be consistent with FSAR Chapter 7. ((

                 }}2(a),(c),ECI Impact on DCA:

RP-0316-17619, Human-System Interface Design Results Summary Report, has been revised as described in the response above and as shown in the markup provided with this response. NuScale Nonproprietary

Human Factors Engineering Human-System Interface Design Results Summary Report RP-0316-17619-NP Draft Rev. 21 4.2.2.1 Stand-Up Unit Workstations The MCR contains 12 stand-up unit workstations. Each stand-up workstation has five VDUs, a keyboard, a mouse, and manual switch backups for protection functions. The unit overview display VDU is a GVD that provides SDCV unit status information to MCR personnel. The unit overview display does not have navigation capabilities. The HSIs displayed on all four lower VDUs are navigable and contain the alarms, controls, indications, and procedures necessary to monitor and manage the corresponding unit during normal, abnormal, emergency, and shutdown operations. The function of the four lower VDUs may be accomplished by other means providing the operators utilizing the workstation can view four independent HSI display pages simultaneously. The GVD must remain independent and non-navigable. ((

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Human Factors Engineering Human-System Interface Design Results Summary Report RP-0316-17619-NP Draft Rev. 21 sample flow path from the CVC discharge piping upstream of the Regenerative Heat Exchanger. The leakage control and detection parameters for systems outside containment are provided on the display pages that are available on the workstation VDUs in the MCR. These parameters include flows, pressures, tank levels, radiation levels, and alarms generated from these indications.The leakage control and detection parameters for systems outside containment are displayed on the SDI, Plant Overview and Containment Evacuation display pages and are available on the workstation VDUs in the MCR.

9. Radiation Monitoring The NuScale HSI design addresses the 10 CFR 50.34(f)(2)(xxvii) requirement to provide appropriate monitoring of in-plant radiation and airborne radioactivity for a broad range of routine and accident conditions as discussed below.

Radiation monitoring for the NuScale plant is a shared unit system. Thus, the monitoring and display of in-plant radiation and airborne radioactivity for the range of routine and accident conditions is on the common systems panel VDU in the MCR. In addition, the Feed and Condensate and Containment Evacuation display pages contain trends to display system radiation levels.

10. Manual Initiation of Protective Actions As required by Regulatory Guide 1.62, safety system automation override and manual initiation of safety functions during unanalyzed conditions is provided ((

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Human Factors Engineering Human-System Interface Design Results Summary Report RP-0316-17619-NP Draft Rev. 21 ((

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Figure 4-51. Hard-wired manual actuation switches

11. Diversity and Defense-in-depth

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Human Factors Engineering Human-System Interface Design Results Summary Report RP-0316-17619-NP Draft Rev. 21 ((

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Figure 4-52. Hard-wired non-safety enable switch

12. Important Human Actions The NuScale HFE/HSI design minimizes the probability of error in the performance of IHAs and provides the opportunity to detect errors, should they occur. ((

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Response to Request for Additional Information Docket No. 52-048 eRAI No.: 9318 Date of RAI Issue: 03/20/2018 NRC Question No.: 18-33 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 FSAR, Tier 2, Section 18.0, "Human Factors Engineering - Overview," indicates that the HFE program incorporates the applicable guidance provided in NUREG-0711, Revision 3. NUREG-0711, Rev. 3, "Human Factors Engineering Program Review Model," Criterion 8.4.4.2(15), Computer-Based Procedure Platform, states that the applicants computer-based procedures should be consistent with the design review guidance in NUREG-0700, Section 8, Computer-Based Procedure System. The staff reviewed Human Systems Interface Design Results Summary Report, RP-0316-17619-P, Revision 0 and Human Factors Engineering Interface Style Guide, ES-034-1381-P, Revision 1 and found that the design of computer-based procedures is consistent with the guidance in NUREG-0700, Section 8 except for the following review criteria: 8.2.2-10 and 8.3.1-1. Please describe how the computer-based procedures are consistent with these review criteria or describe why these were not addressed. Revise the submittal as necessary. NUREG-0711, Criterion 8.4.4.2(15), Computer-Based Procedure Platform, states that the applicants computer-based procedures should be consistent with the design review guidance in DI&C-ISG-5, "Highly-Integrated Control Rooms - Human Factors issues (HICR - HF)," Section 1 (NRC, 2008). Human Systems Interface Design Results Summary Report, RP-0316-17619-P, Revision 0 NuScale Nonproprietary

states that NuScale computer-based procedures are designed in accordance with the guidance in Section 1 of DI&C ISG-05, 2008 however the staff cannot find this information in the application. Include a description of how the design of the computer-based procedures is consistent with the guidance in DI&C ISG-05, Section 1 or provide where this information can be found. Revise the submittal as necessary. NuScale Response: Response to Question 1: NUREG-0700 Section 8.2.2-10 states: "Users should make some form of acknowledgment of procedure steps and recommendations for terminations and transitions. Additional Information: As an example, users may acknowledge that a step is satisfied by depressing the "Return" key, or clicking on an onscreen acceptance button. Such acknowledgment helps the users to maintain awareness of the procedure's status." NUREG-0700 Section 8.3.1-1 states: "There should be an indication of whether or not a step was completed. Additional Information: The indication can be manual or automatic, depending on whether the CBP has the specific criteria and information to determine this." ((

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NuScale Nonproprietary

Response to Question 2: DI&C ISG-05 Section 1, computer-based procedures, has 30 general review criteria. The Human-System Interface Design results summary report (HSI RSR) states that DI&C ISG-05 guidance was used during the design of computer-based procedures. The 30 review criteria were met in the NuScale computer-based procedure design as follows: ((

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NuScale Nonproprietary

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NuScale Nonproprietary

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NuScale Nonproprietary

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Impact on DCA: There are no impacts to the DCA as a result of this response. NuScale Nonproprietary

RAIO-0518-60073 : Affidavit of Zackary W. Rad, AF-0518-60074 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

NuScale Power, LLC AFFIDAVIT of Zackary W. Rad I, Zackary W. Rad, state as follows:

1. I am the Director, Regulatory Affairs of NuScale Power, LLC (NuScale), and as such, I have been specifically delegated the function of reviewing the information described in this Affidavit that NuScale seeks to have withheld from public disclosure, and am authorized to apply for its withholding on behalf of NuScale.

2. I am knowledgeable of the criteria and procedures used by NuScale in designating information as a trade secret, privileged, or as confidential commercial or financial information. This request to withhold information from public disclosure is driven by one or more of the following:

a. The information requested to be withheld reveals distinguishing aspects of a process (or component, structure, tool, method, etc.) whose use by NuScale competitors, without a license from NuScale, would constitute a competitive economic disadvantage to NuScale.

b. The information requested to be withheld consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), and the application of the data secures a competitive economic advantage, as described more fully in paragraph 3 of this Affidavit.

c. Use by a competitor of the information requested to be withheld would reduce the competitor's expenditure of resources, or improve its competitive position, in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.

d. The information requested to be withheld reveals cost or price information, production capabilities, budget levels, or commercial strategies of NuScale.

e. The information requested to be withheld consists of patentable ideas.

3. Public disclosure of the information sought to be withheld is likely to cause substantial harm to NuScale's competitive position and foreclose or reduce the availability of profit-making opportunities. The accompanying Request for Additional Information response reveals distinguishing aspects about the method by which NuScale develops its human factors verification and validation.

NuScale has performed significant research and evaluation to develop a basis for this method and has invested significant resources, including the expenditure of a considerable sum of money. The precise financial value of the information is difficult to quantify, but it is a key element of the design basis for a NuScale plant and, therefore, has substantial value to NuScale. If the information were disclosed to the public, NuScale's competitors would have access to the information without purchasing the right to use it or having been required to undertake a similar expenditure of resources. Such disclosure would constitute a misappropriation of NuScale's intellectual property, and would deprive NuScale of the opportunity to exercise its competitive advantage to seek an adequate return on its investment. AF-0518-60074

4. The information sought to be withheld is in the enclosed response to NRC Request for Additional Information No. 392, eRAI 9318. The enclosure contains the designation "Proprietary" at the top of each page containing proprietary information. The information considered by NuScale to be proprietary is identified within double braces, "(( }}" in the document.

5. The basis for proposing that the information be withheld is that NuScale treats the information as a trade secret, privileged, or as confidential commercial or financial information. NuScale relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC § 552(b)(4), as well as exemptions applicable to the NRC under 10 CFR §§ 2.390(a)(4) and 9.17(a)(4).

6. Pursuant to the provisions set forth in 10 CFR § 2.390(b)(4), the following is provided for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld:

a. The information sought to be withheld is owned and has been held in confidence by NuScale.

b. The information is of a sort customarily held in confidence by NuScale and, to the best of my knowledge and belief, consistently has been held in confidence by NuScale.

The procedure for approval of external release of such information typically requires review by the staff manager, project manager, chief technology officer or other equivalent authority, or the manager of the cognizant marketing function (or his delegate), for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside NuScale are limited to regulatory bodies, customers and potential customers and their agents, suppliers, licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or contractual agreements to maintain confidentiality.

c. The information is being transmitted to and received by the NRC in confidence.

d. No public disclosure of the information has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or contractual agreements that provide for maintenance of the information in confidence.

e. Public disclosure of the information is likely to cause substantial harm to the competitive position of NuScale, taking into account the value of the information to NuScale, the amount of effort and money expended by NuScale in developing the information, and the difficulty others would have in acquiring or duplicating the information. The information sought to be withheld is part of NuScale's technology that provides NuScale with a competitive advantage over other firms in the industry.

NuScale has invested significant human and financial capital in developing this technology and NuScale believes it would be difficult for others to duplicate the technology without access to the information sought to be withheld. I declare under penalty of perjury that the foregoing is true and correct. Executed on 5/2018. Zackary Z k W. R W Radd AF-0518-60074}}

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