ML18288A545

SMR DC Docs - NuScales Proposed Supplemental Response to RAI 9415

ML18288A545
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Site:	NuScale
Issue date:	10/15/2018
From:	NRC
To:	NRC/NRO/DLSE/LB1
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1 NuScaleDCDocsPEm Resource From:

Chowdhury, Prosanta Sent:

Monday, October 15, 2018 3:07 PM To:

NuScaleDCDocsPEm Resource

Subject:

NuScale's proposed supplemental response to RAI 9415 Attachments:

RAI 9415 ITAAC 3.15-1 Revisions_Public Meeting on 10-17-2018.docx NuScales proposed supplemental response to RAI 9415 - for discussion at the October 17, 2018, public meeting. NuScale confirmed via email (Monday, October 01, 2018, 9:19 PM) that the attached document can be made publicly available, i.e., the document does not contains proprietary or sensitive information.

Prosanta Chowdhury Project Manager Office of New Reactors U.S. Nuclear Regulatory Commission 301-415-1647

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NuScale's proposed supplemental response to RAI 9415 Sent Date:

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1. NuScale to evaluate the language in ITAAC 3.15-1 and propose new language (Proposed new ITAAC language in Tier 1 Table 3.15-1, ITAAC No. 1 and associated Tier 2, Table 14.3-2 ITAAC Discussion - red line strikeout, blue bold additions)

Tier 1, Table 3.15-1 No.

Design Commitment Inspections, Tests, and Analyses Acceptance Criteria 1

The as-built main control room HSI is consistent with the final verified and validated HFE design.

specifications validated by the integrated system validation test.

An inspection will be performed of the as-built configuration of MCR HSI.

The as-built configuration of main control room HSI is consistent with the final as-designed HSI configuration. of main control room HSI as modified by the Integrated System Validation Report.

Tier 2, Table 14.3-2 ITAAC No.

System Discussion DBA Internal/

External Hazard Radiological PRA &

Severe Accident FP 03.15.01 HFE Section 18.11, Design Implementation, describes the implementation of HFE aspects of the plant design.

The design implementation activities verify that the final main control room design is consistent with the verified and validated design resulting from the HFE design process. An ITAAC inspection is performed to verify that the as-built configuration of main control room HSI is consistent with the final as-designed HSI configuration. As used here, the final as-designed HSI configuration is the COL holders configuration-controlled design, which includes changes made by

the COL holder subsequent to design certification approval under the COL holders configuration control process.

configuration of main control room HSI as modified by the Integrated System Validation Report.

2. Follow-up on COL action item FSAR Section 18.11, Design Implementation, will not include a new COL Item directing completion of a Design Implementation (DI) Results Summary Report. Concerns were identified with how a COL action item would accomplish the staffs intentions as characterized in our follow-up communications. Staff feedback indicated that a DI Results Summary Report (RSR) is needed to adequately determine that design and PRA changes made post-ISV have been analyzed to ensure that they will introduce no new human performance issues.

When the design certification is approved, it is incorporated by reference in the 10 CFR 52 design certification specific appendix. Subsequent COL applications must conform to the design certification (e.g., Appendix D to Part 52, paragraph III.B) as modified by the applicants departures or exemptions (e.g., Appendix D to Part 52, paragraph IV.A.2.a). Consequently, any design or PRA changes affecting the design certification approved configuration would be addressed in the COL application as a departure or exemption, and subject to NRC review and, in some cases, approval (e.g., Appendix D to Part 52, section VIII). This review would render redundant the NRCs stated purpose for reviewing a COL information item requiring an RSR.

Additionally, any post-COL modifications from the design certification approved configuration would be subject to the requirements for departures or exemptions, and departures would continue to be reported (e.g., Appendix D to Part 52, paragraph X.B). A DI RSR would either be submitted as part of the COL application or would have to be addressed under Reg.

Guide1.206, section C.III.4.3 as a COL information item that cannot be resolved before the issuance of a license. Again, either action seems redundant to the requirements of the design certification rule.

With one exception described in item 4 below, NuScale believes that an RSR for the design implementation element of NUREG-0711 is redundant to regulation and unnecessary. The basis for not including a COL action item directing completion of a DI RSR in our supplementary response is summarized below:

1. NUREG-0711, section 12.3: document the applicants verification and concluding statement that the as-built plant conforms to the approved, validated design

Verification that the as-built plant is consistent with the approved, validated design is accomplished by the revised ITAAC provided above.

Prior to COL issuance, design and PRA changes affecting the design certification approved design are required to be documented in COL applications.

Following COL issuance, changes affecting the design certification approved design are required to be processed as departures or exemptions. Changes affecting the COL approved design are subject to the requirements of 10 CFR 50.59.

2. NUREG-0711, section 12.3: corroborate that all HEDs have been satisfactorily resolved Open HEDs are tracked in the NuScale and the COL holders corrective action process and are subject to verification of satisfactory closure. Because the NuScale HFE design is submitted at a Results Summary Report level, closure of HEDs affecting safety are reported in the NuScale design certification.

3. NUREG-0711, section 12.3: delineate how the HFE program addressed each important Human Action Because the NuScale HFE design is being submitted at a Results Summary Report level, the NuScale design certification delineates how the HFE program addresses each important human action (IHA). It is also pointed out that the NuScale design provides for a safe response to all design basis events without operator action and the NuScale IHAs are limited to beyond design basis events with a probability of occurrence on the order of 10-11. This effectively establishes a new standard for what constitutes an IHA that merits less regulatory scrutiny.

4. The exception is with regards to NUREG-0711, section 12.3: explain how all aspects of the design that were not addressed during the V&V activities were covered in implementing the design The DI Implementation Plan directs assessments of these aspects of the design and, while a requirement exists in the approved design certification for the COL applicant to complete the assessments, there is no regulation requiring a report explaining how this action is completed. However, a licensees completion of design implementation activities, required by the FSAR, will be performed under the licensees QA program and subject to NRC inspection. NuScale believes the FSAR requirement is sufficient and completion of the assessments does not merit additional reporting.