ML18249A421

LLC - Supplemental Response to NRC Request for Additional Information No. 399 (Erai No. 9399) on the NuScale Design Certification Application

ML18249A421
Person / Time
Site:	NuScale
Issue date:	09/06/2018
From:	Rad Z NuScale
To:	Document Control Desk, Office of New Reactors
Shared Package
ML18249A420	List: ML18249A421
References
RAIO-0918-61681
Download: ML18249A421 (13)

Text

RAIO-0918-61681 September 06, 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 Supplemental Response to NRC Request for Additional Information No. 399 (eRAI No. 9399) on the NuScale Design Certification Application

REFERENCES:

1. U.S. Nuclear Regulatory Commission, "Request for Additional Information No. 399 (eRAI No. 9399)," dated March 23, 2018

2. NuScale Power, LLC Response to NRC "Request for Additional Information No. 399 (eRAI No.9399)," dated May 17, 2018 The purpose of this letter is to provide the NuScale Power, LLC (NuScale) supplemental response to the referenced NRC Request for Additional Information (RAI).

The Enclosures to this letter contain NuScale's supplemental response to the following RAI Question from NRC eRAI No. 9399:

18-35 is the proprietary version of the NuScale Supplemental Response to NRC RAI No.

399 (eRAI No. 9399). NuScale requests that the proprietary version be withheld from public disclosure in accordance with the requirements of 10 CFR § 2.390. 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.

If you have any questions on this response, please contact Carrie Fosaaen at 541-452-7126 or at cfosaaen@nuscalepower.com.

Sincerely, Zackary W. Rad Director, Regulatory Affairs NuScale Power, LLC Distribution: Gregory Cranston, NRC, OWFN-8G9A Samuel Lee, NRC, OWFN-8G9A Prosanta Chowdhury NRC, OWFN-8G9A NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0918-61681 : NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9399, proprietary : NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9399, nonproprietary : Affidavit of Zackary W. Rad, AF-0918-61682 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0918-61681 :

NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9399, 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-0918-61681 :

NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9399, 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.: 9399 Date of RAI Issue: 03/23/2018 NRC Question No.: 18-35 Title 10 of the Code of Federal Regulations (10 CFR) Section 52.47(a)(8) requires an applicant for a design certification to provide a final safety analysis report (FSAR) that must include the information necessary to demonstrate compliance with any technically relevant portions of the Three Mile Island requirements set forth in 10 CFR 50.34(f), except paragraphs (f)(1)(xii), (f)(2)

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

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

Criteria in Section 11.4.3.7 (1-7), of NUREG-0711 addresses Data Analysis and HED Identification. The staff requests that NuScale provide clarification in the following areas:

1. Criterion 2 states that, The applicant should discuss the method by which data is analyzed across trials, and include the criteria used to determine successful performance for a given scenario. In Section 4.7 of the V&V IP, the applicant states, Data are analyzed for each scenario across multiple trials. The method of analysis, consistency of measure assessing performance, and criteria used to determine successful performance for a given scenario is determined by the HFE Design Team. While the applicant commits to analyzing data across trials, no information regarding the methodology is provided.

Please describe the method(s) that will be used to analyze data across trials and the criteria that will be used to determine successful performance.

2. Criterion 4 states, When interpreting test results, the applicant should allow a margin of error to reflect the fact that actual performance may be slightly more variable than observed validation-test performance. In the FSAR, Section 18.10.2.3.7, the applicant states, Expert judgment is employed to infer a margin of error from the observed NuScale Nonproprietary

performance or data analysis. This allows for the possibility that actual performance may be slightly more variable than ISV test results. Please clarify the following:

Identify the qualifications of the personnel who will be providing the expert judgment Discuss the process by which the expert judgment is derived (e.g. what information is considered) and how it is used in interpreting test results

3. Criterion 5 states, The applicant should verify the correctness of the analyses of the data.

This verification should be done by individuals or groups other than those who performed the original analysis, but may be from the same organization. In the FSAR, Section 18.10.2.3.7, the applicant states, Integrated system validation data analysis is reviewed to verify the correctness of the analyses of the data. Data and data-analysis tools (e.g.,

equations, measures, spreadsheets, expert opinions, resulting HEDs) are documented and available for review and subsequent audit and application during HFE program elements design integration or human performance monitoring.

Please clarify the individual(s) or group(s) that will carry out this verification and how they are independent from those who conducted the original analysis.

NuScale Response:

This response supplements NuScale's previous response to eRAI 9399, Question 18-35, sub-question 1 (ML18137A583). During an August 7, 2018 teleconference call, NRC Staff asked NuScale to provide additional information regarding how data collected during the integrated systems validation is analyzed across trials. Based on the NRC feedback, Section 4.7 of RP-0914-8543, Human Factors Verification and Validation Implementation Plan has been revised.

The following examples illustrate the trending techniques used for analysis:

((2(a),(c) NuScale Nonproprietary

((

                                                                                     }}2(a),(c)

Impact on DCA: RP-0914-8543, Human Factors Verification and Validation Implementation Plan has been revised as described in the response above and as shown in the markup provided with this response. NuScale Nonproprietary

Human Factors Verification and Validation Implementation Plan RP-0914-8543-NP Draft Rev. 54 CONTENTS 1.0 Introduction ..................................................................................................................... 3 1.1 Purpose ................................................................................................................. 3 1.2 Scope .................................................................................................................... 3 1.3 Abbreviations and Definitions ................................................................................ 4 2.0 Sampling of Operational Conditions and Scenario Development .............................. 7 2.1 Sampling Dimensions ............................................................................................ 7 2.2 Identification of Scenarios ..................................................................................... 7 2.3 Scenario Definition ................................................................................................ 8 3.0 Design Verification Methodology ................................................................................ 10 3.1 Human-System Interface Inventory and Characterization ................................... 11 3.2 Human-System Interface Task Support Verification ............................................ 12 3.3 Human Factors Engineering Design Verification ................................................. 14 4.0 Integrated System Validation ....................................................................................... 16 4.1 Validation Team ................................................................................................... 16 4.2 Test Objectives .................................................................................................... 17 4.3 Validation Test Beds ............................................................................................ 18 4.4 Plant Personnel ................................................................................................... 21 4.5 Performance Measurement ................................................................................. 22 4.6 Test Design .......................................................................................................... 28 4.7 Data Analysis ....................................................................................................... 31 4.8 Validation Conclusions ........................................................................................ 32 5.0 Human Engineering Discrepancy Resolution ............................................................ 34 5.1 HED Design Solution Implementation ................................................................. 34 5.2 Human Engineering Discrepancy Analysis .......................................................... 35 5.3 Design Solution Testing ....................................................................................... 37 6.0 Verification & Validation Results Summary Report ................................................... 38 7.0 NUREG-0711 Conformance Evaluation ....................................................................... 39 8.0 References ..................................................................................................................... 63 8.1 Source Documents .............................................................................................. 63 8.2 Referenced Documents ....................................................................................... 63 Appendix A. Performance Measure Characteristics ......................................................... 64 © Copyright 20187 by NuScale Power, LLC iv

Human Factors Verification and Validation Implementation Plan RP-0914-8543-NP Draft Rev. 54

• familiarity with HFE data collection tools and techniques
• familiarity with observation techniques, goals, and responsibilities specific to each observers role 4.6.4 Training Participants Test participants undergo training similar to that which plant operators receive including conduct of operations, plant systems, HSI, plant events, and operating procedures. Test participants are not trained specifically on the scenarios in which they will participate.

To assure near-asymptotic performance and a consistent level of proficiency between individuals making up the operating crews, only participants who have successfully completed the training program and have reached an acceptable level of proficiency are considered to be qualified for operating crew assignment. 4.6.5 Pilot Testing A test operating crew, which does not participate in ISV, conducts a pilot test (a pre-validation test) to

• assess the adequacy of test design, performance measures, and data-collection methods
• give the observers and administrators experience in running the test
• ensure that the ISV runs smoothly and correctly 4.7 Data Analysis and Human Engineering Discrepancy Identification Test data areis analyzed using both quantitative and qualitative methods. The analysis identifies the relationship between the observed and measured performance and the established acceptance criteria described in Section 4.5.2. Data are analyzed for each scenario across multiple trials. The method of analysis, consistency of measure assessing performance, and criteria used to determine successful performance for a given scenario is determined by the HFE Design Team.

Data is collected from multiple sources including crew debriefs, observer debriefs, NASA TLX questionnaires, Situational Awareness questionnaires, and management observations. The data is collected and added to a database where an HFE Subject Matter Expert (SME) and an Operations SME bin and code the performance data and then independently identify significant issues and trends within the data. This analysis compares and contrasts data sources, data across crews, data across trials, and data across scenarios. The HFE and Operations SMEs then collaborate on trending results and Human Engineering Discrepancy (HED) identification.HED identification and resolution details are discussed in Section 5.0 ((

                                                                                                       }}2(a),(c)

© Copyright 20187 by NuScale Power, LLC 31

Human Factors Verification and Validation Implementation Plan RP-0914-8543-NP Draft Rev. 54 ((

                                                                                    }}2(a),(c) 4.8      Validation Conclusions ISV conclusions are based on

• a comprehensive testing program performed by an independent ISV team using test procedures covering the scope described above
• a high-fidelity test platform representative of the actual system, model, and HSI in aspects important to the integrated systems performance; variable aspects of the integrated system are adequately sampled
• acceptance criteria are measurable, reflect good operational practices, and are representative of important aspects of performance
• test design minimizes bias or confounding effects so as not to affect the validity of the results
• statistical conclusions, where possible, are based on convergence of multiple measures

© Copyright 20187 by NuScale Power, LLC 32

RAIO-0918-61681 : Affidavit of Zackary W. Rad, AF-0918-61682 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-0918-61682

4. The information sought to be withheld is in the enclosed response to NRC Request for Additional Information No. 399, eRAI 9399. 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 September 6, 2018. Zackary W. Rad AF-0918-61682}}