ML18143B667

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Summary Report for the Environmental Audit of Part 3 of the NuScale Design Certification Application
ML18143B667
Person / Time
Site: NuScale
Issue date: 06/13/2018
From: Mallecia Sutton
NRC/NRO/DNRL
To: Jennivine Rankin
NRC/NRO/DNRL
Sutton M
References
Download: ML18143B667 (28)
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Text

May 8, 2018 MEMORANDUM TO: Jennivine Rankin, Acting Chief Licensing Branch 3 Division of Licensing, Siting, and Environmental Assessment Office of New Reactors FROM: Mallecia A. Sutton, Project Manager /RA/

Licensing Branch 3 Division of Licensing, Siting, and Environmental Assessment Office of New Reactors

SUBJECT:

SUMMARY

REPORT FOR THE ENVIRONMENTAL AUDIT OF PART 3 OF THE NUSCALE DESIGN CERTIFICATION APPLICATION By letter dated December 31, 2016, NuScale Power, LLC (NuScale) submitted its Design Certification Application (DCA) to the U. S. Nuclear Regulatory Commission (NRC) for review (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17013A229). On March 15, 2017, the NRC staff accepted the DCA for docketing and initiated its technical review.

As part of the NRC review, the staff conducted an audit of the documentation supporting DCA Part 3, containing Applicants Environmental Report - Standard Design Certification, herein denoted as the Environmental Report (ER). The staff also audited the methodology, models, assumptions, and calculation packages in support of the ER. An audit plan was used to support these interactions which is located in NRCs ADAMS under Accession No. ML17179A287.

The audit began August 14, 2017, and ended on February 28, 2018. The audit summary report is enclosed.

Docket No.: 52-048

Enclosures:

As stated CONTACT: Mallecia A. Sutton, NRO/DNRL 301-415-0673 cc w/encl.: NuScale DC ListServ

ML18143B667 *via e-mail NRO-002 OFFICE NRO/DNRL/LB3:PM NRO/DNRL/LB3:LA NRO/DNRL/LB3:BC NRO/DSEA/RPAC:BC NAME MSutton SGreen J Rankin (Acting) MDudek DATE 06/13/2018 05/29/2018 06/08/2018 5/21/2018

SUMMARY

NUSCALE ENVIRONMENTAL AUDIT REPORT AUGUST 14, 2017 TO FEBRUARY 28, 2018

1.0 BACKGROUND

AND PURPOSE By letter dated December 31, 2016, NuScale Power, LLC (NuScale) submitted its Design Certification Application (DCA) to the U. S. Nuclear Regulatory Commission (NRC) for review (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17013A229). On March 15, 2017, the staff accepted the DCA for docketing and initiated its technical review.

The staff identified a need for an environmental audit of NuScales design and severe accident mitigation design alternatives (SAMDA). In doing so, the NRC staff audited the supporting information presented in the environmental report (ER), including non-docketed supporting documents. The NRC staff also determined an audit would be needed in identifying and resolving specific information needs to support the staffs independent evaluation and confirmatory analysis for the regulatory findings required under Title 10 of the Code of Federal Regulations (10 CFR), Part 51 (see Appendix B for the list of information needs).

This environmental audit was coordinated with the Design Control Document (DCD) Chapter 19, Probabilistic Risk Assessment, safety review. As such, some of the documents that were reviewed as part of this audit was reviewed as part of the DCD Tier 2 Chapter 19 safety audit.

This was beneficial because these shared documents contain information from the Level 1 and Level 2 Probabilistic Risk Assessment (PRA) being applied as part of the environmental analysis used to support the SAMDA determination.

2.0 AUDIT REGULATORY BASES A regulatory audit is a planned, license or regulation-related activity, that includes the examination and evaluation of primarily non-docketed information. A regulatory audit is conducted with the intent to gain an understanding, verify information, and/or identify information that will require docketing to support the basis of the licensing or regulatory decision. The NRC staff conducted an environmental audit of the non-docketed and proprietary offsite consequence analyses, SAMDA evaluation, and supporting information to assist in the review of the environmental impacts related to the NuScale DCA to support the staffs obligations under the National Environmental Policy Act of 1969 (NEPA), as amended.

Specifically, this regulatory audit is based on the following:

  • NUREG 1555, Environmental Standard Review Plan, Section 7.2, Severe Accidents, and Section 7.3, Severe Accident Mitigation Alternatives
  • Title 10 of the Code of Federal Regulations (10 CFR) 51.55, Environmental report standard design certification
  • 10 CFR 52.47, Contents of Applications; Technical Information, subpart (b)(2)

Enclosure 1

3.0 AUDIT OBJECTIVES The NRC staffs objective in conducting this environmental audit was to gather information on the applicants bases for the SAMDA evaluation, including the methodology and analyses based on publicly available information and supporting non-docketed offsite consequences calculations, computer code input/output files, and related analyses that support the information contained in the ER, with the following goals:

  • Obtain sufficient information with appropriate documentation from the applicant to support the staffs environmental review.
  • Examine and evaluate non-docketed information such as sources of information, methodology, assumptions, calculations, analysis worksheets, and computer code input/output files.
  • Gain a clear understanding of NuScales cost-benefit analysis of SAMDAs contained in Part 3 of the application in the document entitled Applicants Environmental Report -

Standard Design Certification, namely the NuScale ER (ADAMS Accession No. ML17013A296).

4.0 SCOPE OF THE AUDIT AND AUDIT ACTIVITIES The audit was conducted August 14, 2017, through March 1, 2018, by reviewing appropriate documents available in NuScales electronic reading room (eRR). In addition, the staff met with NuScale staff during a two day meeting beginning on August 28, 2018, to gain an overview of the audited information, and for further clarification on the information presented in the ER via information needs. The NRC staff conducted the audit in accordance with the Office of New Reactors (NRO) Office Instruction NRO-REG-108, Regulatory Audits (Reference 1).

Members of the audit team, listed below, were selected based on their detailed knowledge of radiological consequence assessment, PRAs and severe accident consequence assessment; their experience supporting previous design certification reviews; their knowledge of the regulatory framework regarding design certification; and their knowledge regarding implementation of the review framework for small modular reactors. Audit team members included:

  • Michelle Hart, Sr. Reactor Engineer (NRO/DSEA/RPAC)
  • Marie Pohida, Sr. Reliability and Risk Analyst (NRO/DSRA/SPRA)

The documents reviewed by the staff either via an eRR or at NuScales Rockville office during the audit are listed below:

1. ER-P010-3782_R0_Steam_Generator_Tube_Failure PRA
2. ER-P012-7022_R0_Internal Fires Notebook
3. ER-P020-3536_R0_Analysis_In-Vessel_Retention_Reactor_Pressure_Vessel
4. ER-P030-3751_R1_SAMDA Value Max Risk Calc
5. ER-P050-3815_R1_PRA for Reactor Building Crane
6. ER-P050-7030_R1_Low_Power_Shutdown_PRA
7. ER-P060-7085_R1_Dropped Module Conseq_Analysis
8. ER_P000-7200_R0_NuScale SAPHIRE Probabilistic Risk Assessment Base Model
9. ER_P02_3779_R1_Probabilistic_Analysis_of_Emergency_Core_Cooling_Valve_

Reliability

10. ER_P013_7020_R0_Reactor_Coolant_System_PRA_Notebook
11. ER_P013_7023_R0_Internal Floods Notebook
12. ER_P020_7024_R0_Level_2_Probabilistic_Risk_Assessment_Notebook
13. ER_P030_3753_01_SAMDA_Identification_and Screening
14. ER_P030_4113_R0_MELCOR_Accident_Consequence_Code_System_MACCS_

Base_Model

15. ER_P030_4524_R0_SAMDA_Release_Cat_2_Isolated_CVCS_LOCA_Outside_

Contain_Offsite_Consq

16. ER_P030_4525_R0_SAMDA_Release_Cat_1_CVCS_LOCA_Inside_Contain_

Offsite_Consq

17. ER_P030_4526_R0_SAMDA_Release_Cat_3_Unisolated_CVCS_LOCA_Outside_

Contain_Offsite_Consq 3

18. ER_P030_4527_R0_SAMDA_Release_Cat_4_ECCS_Spurious_Actuation_Offsite_

Conseq

19. ER_P030_4528_R1_SAMDA_Release_Cat_5_Unisolated_Steam_Generator_Tube_

Failure_Offsite_Conseq

20. ER_P030_4529_R0_SAMDA_Release_Cat_6_General_Transient_with_RSV_Stuck_

Open_Offsite_Conseq

21. ER_P030_4530_R0_SAMDA_Release_Cat_7_General_Transient_with_No_RSVs_

Offsite_Conseq

22. ER_P040_4281_R0_Seismic_Core_Damage_Freq_Eval_for_Peach_Bottom_Surry_

Sites

23. ER_P040_7026_R0_Seismic_Margin_Assessment_Notebook
24. ER_P040_7027_R0_Other_External_Events_Notebook
25. ER_P040_7028_R0_High_Winds_Notebook
26. ER_P040_7029_R0_External_Floods_Notebook
27. TR-0515-13952-NP-A Risk Significant Determination Approved Version
28. ECN-P050-4846, Probabilistic Risk Assessment for Reactor Building Crane
29. NuScale WinMACCS Input and Output files for each release category with baseline case and sensitivity runs provided at the NuScale Rockville Office
30. NuScales Maximum Benefit Calculation Excel spreadsheets provided at the NuScale Rockville Office During the audit, the staff went to NuScales Rockville office to review non-docketed documents, such as MELCOR Accident Consequence Code System (MACCS) project folders, MACCS input files, related MACCS output files and maximum benefit calculation Excel spreadsheets.

An audit exit meeting was held February 28, 2018, by telephone to discuss feedback from the audit and to outline the staffs next review steps. The staffs summary of observations given below is based on the notes taken by the NRC staff during the audit. The NRC staff did not acquire any documents during the audit.

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5.0

SUMMARY

OF OBSERVATIONS Based on the NRC staffs environmental audit of the applicants documentation, the staff observed the following:

1. Through review of the proprietary NuScale calculation packages in the eRR, the staff was able to understand more fully the inputs, assumptions and methodology used in for the assessment of severe accidents for the NuScale design via Level 1 PRA, Level 2 PRA, and offsite consequences (i.e., a Level 3 PRA) for the various hazard and accident release categories. This is important since the number and type of release categories is different between the PRA presented in DCD Chapter 19 and the PRA information applied in the ER.
2. There were 26 information needs presented and discussed during the audit meeting (see Appendix B). Three of these items were addressed and resolved as a result of audit discussions. Three information needs will need to be resolved in a subsequent audit. For the remaining 20 items, NuScale understood the information needs and will work with the staff for revising the ER with necessary text and references. The staff will review the revised ER to determine if these information needs can be closed.
3. The staff reviewed the MACCS computer code package analysis and associated Excel spreadsheets. The staff observed that NuScale obtained the majority of the MACCS site input parameter values and modeling guidance from NRCs State-of-the-Art Reactor Consequence Analyses study.

Due to other critical, high priority work, the staff was not able to complete the audit. Thus, the decision was made to close this phase of the audit and to establish a subsequent audit when the staffs workload could support the completion of the environmental audit. Additionally, with a revised NuScale ER, the staff will incorporate questions and information needs based on the new information provided by the applicant to potentially close out the open information needs from this audit.

6.0 REFERENCES

1. NRO Office Instruction, NRO-REG-108, Regulatory Audits, Revision 0, April 2009.

NuScale Power LLC, Applicants Environmental Report - Standard Design Certification, Revision 0, December 2016, ADAMS Accession No. ML17013A296.

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APPENDIX A: ENVIRONMENTAL AUDIT AGENDA AUGUST 14, 2017 TO FEBRUARY 28, 2018 DISCUSSION OF STAFFS INFORMATION NEEDS Location: NuScale Power, LLC Rockville Office 11333 Woodglen Ave., Suite 205 Rockville, Maryland 20852 Date: Monday, August 28, 2017 8:30 a.m. Audit Meeting Opens 8:45 a.m. Introductions and Safety Briefing 9:00 a.m. Audit Meeting Begins 12:00 p.m. Lunch 1:00 p.m. Team Continues Audit 4:30 p.m. Team Debrief 5:00 p.m. Audit Meeting Adjourns for the Day Date: Tuesday, August 29, 2017 8:30 a.m. Audit Meeting Resumes 12:00 p.m. Lunch 1:00 p.m. Team Continues Audit 4:30 p.m. Team Debrief 5:00 p.m. Audit Meeting Adjourns for the Day REVIEW OF ELECTRONIC READING ROOM FILES AND MACCS INPUT & OUTPUT FILES Dates: August 14, 2017 to December 29, 2017

  • Audit of calculation files provided via the NuScale electronic reading room
  • Review of MACCS input and output material at the NuScales Rockville Office Enclosure 2

Appendix B: NuScale Environmental Information Needs and Status Serial ER Section Page No. Information Need Status No.

ER-01 --- --- Provide access to NRC staff on the NuScale NuScale provided the various files electronic reading room (eRR) for the NuScale (about 27 electronic files) via their eRR documents as they relate to off-site consequence for the NRC staff to audit.

and risk including the following topic areas:

ACTION: Staff will review Revision 1

  • Low power shutdown analyses of ER.
  • Dropped module consequence analyses
  • All transients resulting in offsite OPEN consequences
  • SAMDA maximum risk
  • SAMDA identification and screening process
  • Base case and sensitivity calculations using WinMACCS
  • The seismic evaluations for the Surry and Peach Bottom sites
  • PRA and analysis documentation for Reactor Building Crane failures
  • Unisolated accident analyses
  • Other PRA documents which support the analysis in the ER.

This information is needed since there is no specific listing or referencing in the ER of technical reports or other documents developed by NuScale regarding the technical information applied in support of the ER.

Enclosure 3

Serial ER Section Page No. Information Need Status No.

ER-02 --- --- Provide a Digital Versatile Disc (DVD) which NuScale provided access at the contains WinMACCS input and output files in NuScale Rockville Maryland office to native format which were applied for the base case the NRC staff to the DVD with their at the Surry site and the sensitivity case at the WinMACCS and related calculation Peach Bottom site. files.

This proprietary DVD will be used by the staff ACTION: NRC staff will need access during the on-site portions of the audit. to relevant files once audit is reopened.

This information is needed per 10 CFR 51.41 and 10 CFR 51.45(c). OPEN ER-03 --- --- Provide knowledgeable experts to discuss the The NRC and NuScale staff discussed systems, structures, and components (SSCs) of whether such non-safety SSCs were the NuScale design to discuss the potential able to have a risk significant impact.

applications of SSCs classified non-safety systems for possible consideration as severe accident ACTION: NuScale would consider mitigation design alternatives. For example: adding text to reference information found in DCA Final Safety Analysis

  • Non-safety systems which can inject Report (FSAR) Section 19.2.6, additional water into the containment or Consideration of Potential Design reactor vessel module Improvements Under 10 CFR
  • Non-safety monitoring systems which could 50.34(f).

assist in assessing accident progression

  • Non-safety systems which could assist the ACTION: Staff will review Revision 1 mitigation of a release of ER.

This information was not provided in the ER and is OPEN needed to support the staffs regulatory environmental finding per 10 CFR 51.55(a) with respect to the bases for not incorporating severe accident mitigation design alternatives in the design to be certified.

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Serial ER Section Page No. Information Need Status No.

ER-04 --- --- Provide knowledgeable experts to discuss the NuScales 8 release categories based technical information from the NuScale Level 1 and more on common initiators or Level 2 PRA applied in the analysis of off-site equipment failures under 6 risk consequences, including: significant events (or hazard groups).

These hazard groups are: internal

  • Determination of PRA scenarios leading to a low power and shutdown, external radiological offsite release (i.e., release flooding, and high winds.

categories)

  • Determination of release source terms and There was discussion between NRC plume-related information for each release and NuScale staff as to the level of category (e.g., release fractions for each detail needs to be in the ER for this chemical group, number of plume segments, information versus what is resolved durations) and documented via an audit process.
  • Determination of event timing, for example:

the declaration of a general emergency and ACTION: Staff will review Revision 1 the start of the initial release of ER.

Specific information in regards to the above was OPEN not provided in the ER. Environmental Standard Review Plan, NUREG-1555, Section 7.2 under Review Interfaces states the reviewer of severe accidents should coordinate with the DCD Tier 2, Chapter 19 reviewer to ensure consistency with the severe-accident analyses given by the applicant in the ER. See NUREG-1555, Section 7.2, Subsection III, Review Procedures, under item (2) for additional guidance if the application references a design undergoing certification.

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Serial ER Section Page No. Information Need Status No.

ER-05 --- --- Provide knowledge experts to discuss the updated NuScale discussed the updating of Table B-18 submitted to the NRC in NuScale Table B-18. This table was more for transmittal dated July 7, 2017 (ADAMS Accession information and the updated version No. ML17188A452). Specifically, to discuss with did not affect the information provided the staff the effect on the analysis and on other in Table B-19.

tables in the ER where the values were derived from the information presented in Table B-18. ACTION: CLOSED ER-06 --- --- Provide knowledgeable experts to discuss results The NRC and NuScale staff discussed from the DCD Chapter 19 PRA safety audit which the need for when PRA information carry over into the analysis that supports the ER. relied upon in the ER is changed, revised, or updated that the ER be Environmental Standard Review Plan, NUREG- appropriately updated also.

1555, Section 7.2 under Review Interfaces states the reviewer of severe accidents should coordinate ACTION: Staff will review Revision 1 with the safety reviewer for DCD Tier 2, Chapter of ER.

19 to ensure consistency with the severe-accident analyses given by the applicant in the ER. Also CLOSED FOR AUDIT.

see NUREG-1555, Section 7.2, Subsection III, Review Procedures, under item (2) for additional guidance if the application references a design undergoing certification.

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Serial ER Section Page No. Information Need Status No.

ER-07 --- --- Provide knowledgeable experts to discuss the use NRC and NuScale staff discuss the of references throughout the ER and in particularly issue in that NuScale presents for: information or provides technical statements that cannot be verified

  • Tables in the ER, in particular for tables because the source is not referenced.

presenting information from other parts of the The NRC staff provided numerous application (e.g., from Chapter 19 of Part 2 of examples.

the DCA)

  • PRA-related information, for example the low ACTION: Staff will review Revision 1 power and shutdown PRA analysis of ER.
  • MACCS calculations and results including cases applied in the sensitivity study OPEN
  • The seismic CDFs for the Surry and Peach Bottom sites
  • Appendix B The degree of detail provided by the applicant in their Environmental Report should satisfy Regulatory Guide (RG) 4.2, Revision 2, Preparation of Environmental Reports for Nuclear Power Stations, Section A.7.c, Presentation of Information, (see RG 4.2, Revision 2, page x under ADAMS Accession No. ML003739519).

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Serial ER Section Page No. Information Need Status No.

ER-08 4.0 4-13 Provide knowledgeable experts to discuss the NRC and NuScale staff discussed the relationships the SAMDA analysis and DCD issue. DCA FSAR Chapter 20 did not Chapter 19 may have with respect to DCD influence the SAMDAs in the ER to Chapter 20, Mitigation of Beyond-Design-Basis improve severe accident response Events and in particular as related to the screening beyond 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Essentially, the of potential SAMDA candidates. required actions for MBDBEE results in them not becoming a consideration Environmental Standard Review Plan, under SAMDAs.

NUREG-1555, Section 7.3 under Data and Information Needs, presents the type of data and ACTION: CLOSED FOR AUDIT information needed from the applicant will be affected by various factors including a description and list of any alternatives that have been or will be implemented to prevent or mitigate severe accidents or reduce the risk of a severe accident.

DCD Chapter 20 discusses mitigating strategies that address an extended loss of alternating current power and loss of normal access to the ultimate heat sink resulting from severe accidents (i.e., beyond design basis external events).

Therefore, efforts by NuScale to mitigate severe accidents as discussed in DCD Chapter 20 could have an impact as to the SAMDAs considered in the ER.

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Serial ER Section Page No. Information Need Status No.

ER-09 4.0 14-23 Provide knowledgeable experts to discuss the The NRC and NuScale staff discussed process for creating NuScale specific SAMDAs as the need for completeness in the ER described in Section 4.1.1 through Section 4.1.13. for describing the process for One specific item for discussion is the reactor developing SAMDAs. NuScale building crane failure being the significant risk understands the need for cross-scenario and the consideration of SAMDAs to referencing back to other parts of the address this risk. DCD for system descriptions and where the basic events applied for Environmental Standard Review Plan, SAMDAs were derived from.

NUREG-1555, Section 7.3 under Subsection II, Acceptance Criteria, presents the following ACTION: NuScale will revise the ER acceptance criteria is used: Completeness and to include this information. Staff will reasonableness, also with respect to the following: review Revision 1 of ER.

(1) the identification of SAMAs applicable to the plant or design under consideration. Therefore the OPEN staff must understand the process NuScale followed in identifying specific SAMDAs for consideration.

ER-10 4.0 4-13 Provide knowledgeable experts to discuss the NRC and NuScale staff discussed the PRA insights from DCD Chapter 19 (see the text need to provide in the ER more on pages 4 and 5 of the ER) that were applied in information about what was passed or Section 4. relied upon from DCA FSAR Chapter 19 and how this was applied Specific PRA insight information from DCD in the various sections of the ER.

Chapter 19 was not provided in the ER.

Environmental Standard Review Plan, NUREG- ACTION: NuScale will revise the ER 1555, Section 7.2 under Review Interfaces, to include this information. Staff will states the reviewer of severe accidents should review Revision 1 of ER.

coordinate with the safety reviewer of DCD Tier 2, Chapter 19 to ensure consistency with the severe- OPEN accident analyses given by the applicant in the ER.

This is also stated in the corresponding Section 7.3 under Review Interfaces.

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Serial ER Section Page No. Information Need Status No.

ER-11 4.1 14-23 Provide knowledgeable experts to discuss the NRC and NuScale staff discussed the source of information from Part 2 DCA sections for topic and NuScale understands the the various NuScale SSCs that are described in issue.

Section 4.1 of the ER.

ACTION: NuScale will revise the ER This information was not provided in the ER. to reference the appropriate sections Environmental Standard Review Plan, of the FSAR for the information NUREG-1555, Section 7.3 under Data and provided in ER Section 4.1. Staff will Information Needs states the following information review Revision 1 of ER.

should be obtained from the ER: The methodology, process, and rationale used by the OPEN applicant to identify, screen, and select design alternatives and procedural modifications.

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Serial ER Section Page No. Information Need Status No.

ER-12 4.0, 6.1.5, A 6-13; 38 to 39; Provide knowledgeable experts to discuss in detail NRC and NuScale staff discussed the A-21 to A-27 the development and screening of NuScale topic and NuScale understands the design-specific SAMDAs from the discussion issue. Not all SAMDAs provided in provided in Section 4 and Table 4-2, to the Table 4-2 are listed under the discussion in Section 6.1.5 and Tables 6-1 and 6-2 respective system in Section 4.1 which and to the final disposition of each NuScale is then passed to Section 6 and to design-specific SAMDA (Table A-1). Appendix A.

Environmental Standard Review Plan, ACTION: NuScale to revise the ER to NUREG-1555, Section 7.3 under Subsection III, ensure all basic events are tied to Review Procedures, item (2) states for the staff to Section 4.1, Section 6 and evaluate the applicants methods for identifying the Appendix A. Staff will review potential mitigation alternatives such that: Revision 1 of ER.

(a) Determine if this set of potential design OPEN alternatives and procedural modifications represents a reasonable range of preventive and mitigative alternatives.

(b) Verify that the applicants list of potential SAMAs includes a reasonable range of applicable SAMAs derived from consideration of previous analyses and based on insights from the Level 1 and Level 2 portions of the applicants PRA or IPE/IPEEE.

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Serial ER Section Page No. Information Need Status No.

ER-13 5.2, 5.3 25-27 Provide knowledgeable experts to discuss the NRC and NuScale staff discussed the MACCS calculations supporting the offsite issue. For example:

consequences for population dose and economic costs.

  • Site data (meteorology, population distribution, economic information, The information provided on these pages of the etc.) came from the NRCs ER does not provide a source for the development SOARCA study for the Surry and of the offsite impacts (e.g., Appendix B). Peach Bottom sites.

Environmental Standard Review Plan,

  • Population data was not based on NUREG-1555, Section 7.2 under Subsection III, SECPOP-calculations.

Review Procedures, states [t]he environmental

  • Adjusted ER Table B-2 for inflation consequences of severe accidents are estimated (CPI ratio).

using acceptable methodology (such as the

  • Emergency cohorts were not based MACCS2 code package and the staff should on a 10-mi inhalation EPZ per determine if the method (computer code) used current regulations to evaluate the environmental consequences is appropriate and that it evaluates the ACTION: Staff will review Revision 1 consequences to a distance of 80 km (50 mi). of ER.

Therefore, the staff needs to understand whether the application of the MACCS code package with OPEN related inputs, outputs, and results for the various analyses conducted under Part 3 of the DCA are appropriate and reasonable.

10

Serial ER Section Page No. Information Need Status No.

ER-14 5.2, 5.3, B 24 to 27, Provide knowledgeable experts to discuss the NRC and NuScale staff discussed the B-34 and B-35 absolute results for the offsite risks with the issue and further actions for this WinMACC code package. Make available to the Information Needs are also covered NRC staff the internal calculation files and under Information Needs ER-01 and technical support documentation for these results ER-02.

and the conversion to risk values presented in ER Tables 5-1, 5-2, and B-19. ACTION: Staff will review Revision 1 of ER.

Specific information was not provided in the ER.

Environmental Standard Review Plan, OPEN NUREG-1555, Section 7.2 under Subsection III, Review Procedures, states in item (3) determine if the method (computer code) used to evaluate the environmental consequences is appropriate and that it evaluates consequences to a distance of 80 km (50 mi). Therefore, the staff needs to understand if results for the various analyses conducted under Part 3 of the DCA are appropriate and reasonable.

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Serial ER Section Page No. Information Need Status No.

ER-15 5.2, 5.8, B.1.6 25, 35 to 37, B-5 Provide knowledgeable experts to discuss in detail NRC and NuScale discussed the the SOARCA site data for Surry and Peach Bottom issue. See Environmental Information applied for the analysis presented in the ER. This Needs ER-01 and ER-02 for actions would include discussing sources of the that would affect resolution of this information with subsequent use as a reference in issue. NuScale request further the ER, the rationale for selecting the respective clarification from the NRC staff via the SOARCA site data given that the SOARCA study request for addition information (RAI) was not intended to evaluate economic impacts process.

(see page C-14 of NUREG-1935, Volume 2, ADAMS Accession No. ML12332A058), specific ACTION: Per NuScale e-mail request changes or modifications made to this site data for dated February 12, 2018, none of the factors such as current year or other adjustments ER audit issues should become RAIs.

(see page 63 of NUREG-1935, Volume 1, ADAMS Staff will review Revision 1 of ER.

Accession No. ML12332A057).

OPEN This information was not provided in the ER.

Environmental Standard Review Plan, NUREG-1555, Section 7.2 under Subsection III, Review Procedures, in items (4) through (10) provides staff guidance for determining if the various data inputs to the consequence assessment methodology used to support the ER severe accident analysis is appropriate.

Therefore, the staff needs to understand in detail the SOARCA site data for Surry and Peach Bottom being applied for the analysis 12

Serial ER Section Page No. Information Need Status No.

ER-16 5.4, 5.5, 5.6 27-33 Provide knowledgeable experts to discuss the NRC and NuScale discussed the analytical process for determining the various issue. NuScale request further averted cost components. clarification from the NRC staff via the RAI process.

Environmental Standard Review Plan, NUREG-1555, Section 7.3 under Subsection III, Review ACTION: Per NuScale email request Procedures, in items (4) and (5) has the staff dated February 12, 2018, none of the assessing whether the applicants cost estimates ER audit issues should become RAIs.

for the SAMDAs and the benefit-cost comparison Staff will review Revision 1 of ER.

are reasonable.

OPEN ER-17 5.7, 5.8 33-37 Provide knowledgeable experts to discuss the NRC and NuScale staff discuss the maximum benefit and the maximum benefit issue. See Environmental Information sensitivity results. Needs ER-01 and ER-02 for actions that would affect resolution of this Environmental Standard Review Plan, issue.

NUREG-1555, Section 7.3 under Subsection III, Review Procedures, in items (4) and (5) has the ACTION: When audit is re-opened staff assessing whether the applicants cost staff will continue its review.

estimates for the SAMDAs and the benefit-cost comparison are reasonable. Additional guidance OPEN is provided in NEI 05-01A, Section 8 for sensitivity analysis (see NuScale reference 8.1-1).

13

Serial ER Section Page No. Information Need Status No.

ER-18 5.8 35-37 Provide knowledgeable experts to discuss the NRC and NuScale discussed the WinMACCS calculations for the sensitivity cases issue. NuScale request further discussed in ER Section 5.8, Maximum Benefit clarification from the NRC staff via the Sensitivity Study. Provide for NRC staff review the RAI process.

internal calculation files and technical support documentation for the cases applied in the ACTION: Per NuScale email request sensitivity study. dated February 12, 2018, none of the ER audit issues should become RAIs.

Environmental Standard Review Plan, Staff will review Revision 1 of ER.

NUREG-1555, Section 7.3 under Subsection III, Review Procedures, in items (4) and (5) has the OPEN staff assessing whether the applicants cost estimates for the SAMDAs and the benefit-cost comparison are reasonable. Additional guidance is provided in NEI 05-01A, Section 8 for sensitivity analysis (see NuScale reference 8.1-1).

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Serial ER Section Page No. Information Need Status No.

ER-19 5.8, 6.3, Table 35 to 37, 40, Provide knowledgeable experts to discuss the NRC and NuScale discussed the A-1 A A-27 assessment of potentially cost beneficial SAMDAs issue. The NRC staff is looking for a as presented in ER Section 6.3 based on the complete discussion of the maximum benefit sensitivity cases for the Peach determination of applying the 3 Bottom site (Case 6) and the real discount rate of percent discount rate in the ER.

three percent (Case 9) versus the SAMDAs in NuScale requests further clarification Table A-1 with cost of implementation less than the from the NRC staff via the RAI maximum benefit of Cases 6 and 9. process.

Severe Accident Mitigation Alternatives (SAMA) ACTION: Per NuScale e-mail request Analysis, NEI 05-01A, which is based on dated February 12, 2018, none of the Regulatory Analysis Guidelines of the U.S. Nuclear ER audit issues should become RAIs.

Regulatory Commission, NUREG/BR-0058, and Staff will review Revision 1 of ER.

Regulatory Analysis Technical Evaluation Handbook, NUREG/BR-0184, and is applied in the OPEN ER by NuScale, states in several parts of Section 8, Sensitivity Analysis, to [p]rovide pertinent results and discuss how they affect the conclusions of the SAMA analysis. If SAMAs appear cost-beneficial in the sensitivity results, discussion of conservatisms in the analysis, (e.g.,

conservatisms in cost estimates discussed in Section 7.2), and their impact on the results may be appropriate.

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ER-20 6.2 and 6.3 53-54 Provide knowledgeable experts to discuss the NRC and NuScale discussed the evaluation of potentially cost-beneficial SAMDAs issue. NuScale request further based on a comparison to the Maximum Benefit clarification from the NRC staff via the sensitivity calculations. RAI process. The NRC staff will also review files in the eRR for their Several of the SAMDAs screened out by NuScale relevance to this issue.

are potentially cost-beneficial based on several of the sensitivity calculations but further analysis as ACTION: Per NuScale e-mail request to why these could be screened out is not dated February 12, 2018, none of the discussed. As noted in ER-19, NEI 05-01A states ER audit issues should become RAIs.

that [i]f SAMAs appear cost-beneficial in the Staff will review Revision 1 of ER.

sensitivity results, discussion of conservatisms in the analysis, (e.g., conservatisms in cost estimates OPEN discussed in Section 7.2), and their impact on the results may be appropriate.

ER-21 Table A-1 A A-27 Provide knowledgeable experts to discuss the NRC and NuScale discussed the assessment of the SAMDAs in Table A-1 for each issue. For example:

of the Phase I screening categories with specific emphasis for excessive implementation cost and

  • excessive costs tied to above very low benefit screening categories. $100K
  • very low benefit could be linked to Per 10 CFR 51.41, the staff must be responsible PRA information (basic events or for the reliability of any information which it uses. cutsets?).

Therefore, the staff needs to understand how NuScale determined it was appropriate to bin ACTION: Staff will review Revision 1 individual SAMDAs into these categories. of ER.

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ER-22 B --- Provide knowledgeable experts to discuss the NRC and NuScale discussed the assumptions and sources of information for the issue. NuScale has placed into the setting of WinMACCS input parameter values eRR for NRC staff review what they including the relevant technical documents where consider to be the relevant documents.

the values were ascertained for the Surry and Additionally, NuScale staff will review Peach Bottom sites. Provide to the NRC staff at the Commissions order CLI-16-017 the start of the audit a list of the associated publicly and consider adding a sensitivity available and non-publicly available documents. analysis. NuScale request further clarification from the NRC staff via the This information was not provided in the ER. Per RAI process.

10 CFR 51.41, the staff must be responsible for the reliability of any information which it uses. ACTION: Per NuScale e-mail request Therefore, the staff needs to understand how dated February 12, 2018, none of the NuScale determined it was appropriate to apply ER audit issues should become RAIs.

the selected WinMACCS input parameter values Staff will review Revision 1 of ER.

for the analyses presented in the ER. For example, NUREG/BR-0184 in Section B.4.2, OPEN MACCS Input Parameter Assumptions, cites to NUREG/CR-4551, Volume 2, Revision 1, Part 7 (Sprung et al., 1990) as a source for MACCS input parameter values. While the Peach Bottom and Surry SOARCA integrated analysis documents (NUREG/CR-7110, Volume 1 and 2, respectively) in Appendix C provide the input parameters applied in SOARCA, the ER does not provide an explanation as to the basis for these values as well as the input parameters being appropriate for NuScales analyses. Please review the Commissions order CLI-16-07 (ADAMS Accession No. ML16125A150) and the note on page 47 the Commissions statement regarding being able to explain and make available underlying assumptions in our environmental analyses.

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ER-23 B B-34 Provide knowledgeable experts to discuss the NRC and NuScale staff discussed the rationale and methodology for establishing the need for the information in Table B-17 arrangement of the various hazard groups (i.e., to be referenced to a source document internal events, internal fires, internal flooding, low or further discussed in the ER since power and shutdown, external flooding, high this information is not discussed in winds, crane failure) to release Categories 1 DCA FSAR Chapter 19.

through 8 as shown in Table B-17 of the ER.

This information was not provided in the ER. ACTION: Staff will review Revision 1 Environmental Standard Review Plan, NUREG- of ER.

1555, Section 7.3 under Data and Information Needs, states the following data or information OPEN should be obtained:

  • A list of release sequences (accident classes) for severe accidents with their associated core damage frequencies and source terms (from the ER and the design certification probable risk assessment submittal).

Additionally, under Subsection III, Review Procedures, item (2)(a) ) states for the staff to determine if the information given in the ER on which the applicants analysis is based is appropriate (release sequences, core damage frequencies, and source terms).

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ER-24 B B B-34 Provide knowledgeable experts to discuss the NRC and NuScale discussed rationale and/or calculations that justify no plume NuScales rationale for not having to heat content (i.e., 0.0 watts) for 6 out of 8 release include the plume heat content for the categories. See ER Tables B-6, B-7, B-9, B-10, various release categories. NuScale B-12, B-13, B-14, and B-16. understand the issue and will consider how to address this information needs This information was not provided in the ER. Per in the ER.

10 CFR 51.41, the staff must be responsible for the reliability of any information which it uses. ACTION: Staff will review Revision 1 From the review of the ER, NuScale does not of ER.

provide a discussion for the how and why the plume heat content was set to the values provided OPEN in the cited Appendix B tables. Therefore, the staff needs to understand how NuScale determined it was appropriate to apply the selected values.

ER-25 B B-18, B-19, B Provide knowledgeable experts to discuss for Based on NRC and NuScale staff B-25 Release Categories 3 and 5 concerning the discussion, NuScale understands the release mechanisms and the lack of plume heat information needs. NuScale will add a content in regards to information in ER Tables B-9 summary for the two release and B-12 (e.g., flow rate and gas density). categories for the rationale for what is presented in the ER.

This information was not provided in the ER.

Environmental Standard Review Plan, ACTION: Staff will review Revision 1 NUREG-1555, Section 7.3 under Subsection III, of ER.

Review Procedures, item (2)(a) states determine if the information given in the ER on OPEN which the applicants analysis is based is appropriate (release sequences, core damage frequencies, and source terms).

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ER-26 B.2.9 B-34 Provide knowledgeable experts to discuss the NuScale explained for the ER they re-rationale for the two release categories identified in classified the release information from the Level 2 PRA that were further refined into eight their Level 2 PRA into 8 release release categories to more realistically estimate categories for the severe accident the offsite risks of severe accidents (see page 25 analysis. This was supposed to allow of the ER and Table B-17). a better fit for addressing SAMDAs (i.e., connecting release categories to This information was not provided in the ER. the affected SSCs and then to a Environmental Standard Review Plan, related SAMDA).

NUREG-1555, Section 7.2 under Subsection I in Review Interfaces, states the reviewer of severe ACTION: NuScale will consider how accidents should coordinate with the safety to address the information need.

reviewer of DCD Tier 2, Chapter 19 to ensure ACTION: Staff will review Revision 1 consistency with the severe-accident analyses of ER.

given by the applicant in the ER.

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