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LLC Submittal of Human Factors Engineering Program Management Plan, RP-0914-8534, Revision 5
	ML19119A342
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Site:	NuScale
Issue date:	04/29/2019
From:	Bergman T; NuScale
To:	; Document Control Desk, Office of New Reactors
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ML19119A341	List: ML19119A342;
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	LO-0219-64511 RP-0914-8534-NP, Rev. 5
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LO-0219-64511 April 29, 2019 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 Submittal of "Human Factors Engineering Program Management Plan," RP-0914-8534, Revision 5

REFERENCE:

Letter from NuScale Power, LLC to U.S. Nuclear Regulatory Commission, "NuScale Power, LLC Submittal of First Set of Human Factors Engineering Documentation for Design Certification Application", Dated December 29, 2016 (ML17004A222)

NuScale Power, LLC (NuScale) submitted Revision 3 of the Human Factors Engineering Program Management Plan, RP-0914-8534, to the NRC (Reference). The purpose of this letter is to submit Revision 5 of the Human Factors Engineering Program Management Plan to the NRC. Revision 4 of the Human Factors Engineering Program Management Plan was not submitted to the NRC. contains the proprietary version of the report entitled "Human Factors Engineering Program Management Plan," RP-0914-8534, Revision 5. 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 contains the nonproprietary version of the report entitled"Human Factors Engineering Program Management Plan," RP-0914-8534, Revision 5.

This letter makes no regulatory commitments and no revisions to any existing regulatory commitments.

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

Sincerely, Distribution: Gregory Cranston, NRC, OWFN-8H12 Samuel Lee, NRC, OWFN-8H12 Prosanta Chowdhury, NRC, OWFN-8H12 : "Human Factors Engineering Program Management Plan," RP-0914-8534-P, Revision 5, proprietary version : "Human Factors Engineering Program Management Plan," RP-0914-8534-NP, Revision 5 nonproprietary version : Affidavit of Thomas A. Bergman, AF-0219-54512 NuScale Power, LLC 1100 NE Circle Blvd , Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com

LO-0219-64511 :

"Human Factors Engineering Program Management Plan," RP-0914-8534-P, Revision 5, proprietary version NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com

LO-0219-64511 :

"Human Factors Engineering Program Management Plan," RP-0914-8534-NP, Revision 5, nonproprietary version NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 Human Factors Engineering Program Management Plan April 2019 Revision 5 Docket: 52-048 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 www.nuscalepower.com

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 COPYRIGHT NOTICE This document bears a NuScale Power, LLC, copyright notice. No right to disclose, use, or copy any of the information in this document, other than by the U.S. Nuclear Regulatory Commission (NRC), is authorized without the express, written permission of NuScale Power, LLC.

The NRC is permitted to make the number of copies of the information contained in these reports needed for its internal use in connection with generic and plant-specific reviews and approvals, as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by NuScale Power, LLC, copyright protection notwithstanding. Regarding nonproprietary versions of these reports, the NRC is permitted to make the number of additional copies necessary to provide copies for public viewing in appropriate docket files in public document rooms in Washington, DC, and elsewhere as may be required by NRC regulations. Copies made by the NRC must include this copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 Department of Energy Acknowledgement and Disclaimer This material is based upon work supported by the Department of Energy under Award Number DE-NE0008820.

This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, nor any of their employees, makes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately owned rights. Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United States Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the United States Government or any agency thereof.

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 CONTENTS 1.0 Purpose ............................................................................................................................ 3 2.0 Human Factors Engineering Program Goals and Scope ............................................ 4 2.1 Program Goals ...................................................................................................... 4 2.2 Program Scope ..................................................................................................... 4 2.2.1 Assumptions and Constraints ................................................................................ 4 2.2.2 HFE Program Duration .......................................................................................... 6 2.2.3 Applicable Facilities ............................................................................................... 6 2.2.4 Applicable Human-System Interfaces, Procedures, and Training ......................... 6 2.2.5 Applicable Personnel ............................................................................................. 7 2.2.6 Effects of Modifications on Personnel Performance .............................................. 7 2.3 Abbreviations and Definitions ................................................................................ 8 3.0 Human Factors Engineering Team, Qualifications, and Organization ..................... 10 3.1 Responsibility ...................................................................................................... 10 3.2 Organizational Placement and Authority ............................................................. 10 3.3 Composition ........................................................................................................ 11 3.4 Team Staffing....................................................................................................... 13 4.0 Human Factors Engineering Processes and Procedures ......................................... 15 4.1 General Process Procedures .............................................................................. 15 4.1.1 Human Factors Engineering Team Assignment .................................................. 15 4.1.2 Internal Management of the HFE Team............................................................... 15 4.1.3 Making Decisions on Management of the HFE Program .................................... 15 4.1.4 Making HFE Design Decisions ............................................................................ 15 4.1.5 Controlling Changes in Design of Equipment ...................................................... 15 4.1.6 Review of Human Factors Engineering Products ................................................ 16 4.2 Process Management Tools ................................................................................ 16 4.3 Integration of Human Factors Engineering and Other Plant Design Activities .............................................................................................................. 17 4.4 Human Factors Engineering Program Milestones ............................................... 17 4.5 Human Factors Engineering Documentation....................................................... 18 4.6 Subcontractor HFE Efforts................................................................................... 20 5.0 Human Factors Engineering Issue Tracking System................................................. 21 5.1 Availability of Human Factors Engineering Issue Tracking System ..................... 21 5.2 Human Factors Engineering Issues Tracking Methodology ................................ 21

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 5.3 Human Factors Engineering Issues Tracking Documentation............................. 22 5.4 Human Factors Engineering Issues Tracking Responsibilities ............................ 22 5.4.1 Supervisor, Human Factors Engineering Team ................................................... 22 5.4.2 Human Factors Engineering Issue Tracking System Team Lead ........................ 22 5.4.3 Human Factors Engineering Issues Tracking System Administrator ................... 23 5.4.4 HFE Team Member Issue Evaluator.................................................................... 23 5.4.5 Issue Owner ........................................................................................................ 23 5.4.6 HFEITS Review Committee................................................................................. 24 5.4.7 Human Engineering Discrepancy Resolution ...................................................... 25 5.4.8 HED Process Flow .............................................................................................. 26 6.0 Human Factors Engineering Technical Program Elements ...................................... 28 6.1 Operating Experience Review ............................................................................. 28 6.2 Functional Requirements Analysis and Function Allocation ................................ 29 6.3 Task Analysis ....................................................................................................... 30 6.4 Staffing and Qualifications ................................................................................... 31 6.5 Treatment of Important Human Actions ............................................................... 31 6.6 Human-System Interface Design ........................................................................ 32 6.7 Procedure Development ...................................................................................... 33 6.8 Training Program Development ........................................................................... 33 6.9 Human Factors Verification and Validation .......................................................... 33 6.10 Design Implementation ........................................................................................ 33 6.11 Human Performance Monitoring.......................................................................... 34 7.0 NUREG-0711 Conformance Evaluation ....................................................................... 35 8.0 References ..................................................................................................................... 40 8.1 Source Documents .............................................................................................. 40 8.2 Referenced Documents ....................................................................................... 40 Appendix A. NuScale HFE Program Design Integration ...................................................... 42

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 TABLES Table 2-1. Abbreviations ......................................................................................................... 8 Table 2-2. Definitions .............................................................................................................. 9 Table 3-1. Human Factors Engineering team member qualifications ................................... 12 Table 3-2. Human Factors Engineering team participant primary responsibilities................ 14 Table 4-1. Human factors engineering program and design activity milestones .................. 17 Table 4-2. Human factors engineering element documentation ........................................... 19 Table 7-1. Conformance with NUREG-0711......................................................................... 35 FIGURES Figure 5-1. Human factors engineering issues system process ............................................ 25 Figure 5-2. Human engineering discrepancy resolution process ........................................... 27 Figure A-1. NuScale and human factors engineering program design integration................. 42 Figure A-2. Human factors engineering program process ..................................................... 44

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 Abstract NuScale Power, LLC (NuScale) has developed a human factors engineering (HFE) program for the NuScale Power plant utilizing proven HFE technology and incorporating accepted HFE principles, standards, and guidelines. The overall HFE program incorporates twelve HFE elements under four general activities including planning and analysis, design, verification and validation, and implementation and operation. The planning and analysis activity includes an HFE program management element for the management of the overall HFE program to ensure that the HFE program is properly developed, executed, overseen, and documented. This program management plan (PMP) describes the HFE program management element, and is consistent with the applicable guidelines of Section 2 of NUREG-0711, Revision 3 (Reference 8.1.1).

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 Executive Summary The HFE program incorporates 12 HFE elements under four general activities in accordance with the guidance of NUREG-0711:

planning and analysis HFE program management operating experience review functional requirements analysis and function allocation task analysis staffing and qualifications treatment of important human actions

design human-system interface design procedure development training program development

verification and validation human factors verification and validation

implementation and operation design implementation human performance monitoring The HFE program management element falls under the planning and analysis activity, and its purpose is to ensure that the HFE program is properly developed, executed, overseen, and documented. This PMP describes NuScales overall plan to accomplish this goal. Consistent with the guidance of NUREG-0711, the topics of discussions in this PMP include the HFE program scope, team, processes and procedures, and tracking of HFE issues.

This PMP also provides a summary of the remaining eleven HFE elements, and identifies the elements that are beyond the scope of design certification. Specifically, activities associated with procedures development, training program development, and human performance monitoring elements are the responsibility of a combined license applicant. More details on the implementation methodology and the results of analyses for the applicable HFE elements are contained in the associated implementation plans and/or the results summary reports.

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 1.0 Purpose This NuScale Power human factors engineering (HFE) program management plan (PMP) describes how HFE is effectively incorporated into the design of human-system interfaces (HSI), procedures, and training. HFE is also applied to aspects of the overall plant design as described in Section 2.2.1. As part of the operations organization, the HFE team ensures that the processes detailed in this plan are integrated into the analysis, development, design, and operation of the NuScale plant design.

The purpose of this HFE PMP is to describe the following:

HFE program goals and scope

HFE team, qualifications, and organization

HFE processes and procedures

HFE Issues Tracking System (HFEITS)

HFE technical program elements The scope of this HFE PMP is consistent with the applicable guidance of Section 2 of NUREG-0711, Revision 3.

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 2.0 Human Factors Engineering Program Goals and Scope 2.1 Program Goals The goal of this PMP is to describe how the overall NuScale HFE program implementation is conducted to comply with regulatory requirements 10 CFR 50.34(f)(2)(iii) (Reference 8.2.1) and 10 CFR 52.47(a)(8) (Reference 8.2.2 regarding the use of state-of-the-art human factors principles).

The primary goal of the NuScale HFE program is to provide the NuScale design a human-centered approach for plant operators and technicians to control plant processes and equipment safely and reliably so that the

tasks can be accomplished by personnel within the required time frame and according to defined performance criteria (e.g., HSI navigation and system response time, human-human interaction).

human-system interface (HSI), procedures, staffing and qualifications (S&Q),

training, management, and organizational arrangements support optimum performance and situation awareness.

design supports personnel in maintaining vigilance over plant operations and provides acceptable workload levels (i.e., minimize periods of under- and over-load).

design of the HSI serves to minimize personnel errors and supports error detection and recovery capability.

As the program develops, the program goals are further defined and used as a basis for HFE tests and evaluations.

2.2 Program Scope 2.2.1 Assumptions and Constraints The following assumptions and constraints shape the HFE program.

Passive Features The NuScale plant is designed with passive features to make it inherently safer and to reduce the need for operator interaction.

Nuclear steam supply system is integrated in the reactor vessel to eliminate large bore piping, and reactor coolant flow is circulated without the use of reactor coolant pumps (i.e., natural circulation).

Safety systems are designed with passive and fail-safe features.

Decay heat is removed to the containment pool without the use of pumps or the need for electric power.

No operator actions are necessary for a minimum of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following a design basis event.

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 Modular Design The NuScale plant is a 50 MWe plant intended to be scalable up to 12 units at a site.

The NuScale plant is considered a modular design because

operation of the first unit can begin before successive units are complete.

refueling of individual units can occur with others on line.

systems such as reactor pool cooling, spent fuel pool cooling, instrument air, various ventilation, rad waste, and component cooling water systems, fire protection system, and the AC electrical system are shared across up to 12 units.

all 12 units are controlled from a single main control room (MCR).

High Degree of Automation The NuScale plant is highly automated to reduce the need for operator actions and allow for monitoring multiple units simultaneously.

Steady state routine operating tasks are automated to the extent that human interactions to start, stop, or suspend automated sequences do not distract the operator.

HSIs support operator monitoring and management of automated actions and sequences. Within limits, automated actions and sequences may be altered or suspended by the operator. Automated actions or sequences initiated in response to off-normal conditions or emergencies also make available to the operator information on why the actions were required and what actions have been or will be performed.

((2(a),(c)
Computer-based procedures for normal, abnormal, and emergency operations and alarm response are text-based.

Main Control Room Operators The staffing evaluations are based on activities performed by licensed control room operators. Staffing analysis for maintenance or refueling activities, activities completed by craft/technical personnel (i.e., mechanical, electrical, or instrumentation and controls © Copyright 2019 by NuScale Power, LLC 5

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 (I&C) maintenance; health physics; chemistry; engineering; or information technology), or activities associated with the technical support center (TSC), emergency operations facility (EOF), operations support center (OSC), or any other emergency response facilities are included only if they are determined to impact licensed operator workload. When licensed operator workload is impacted, then the area of concern is analyzed to a degree sufficient to quantify the impact to licensed operator workload or staffing, and develop any human-system interface (HSI) or staffing adjustments required to address the specific task and associated staffing requirements. The numbers and qualifications of nonlicensed operator personnel, including technicians and maintenance staff, are the responsibility of a NuScale plant licensee, and are not analyzed by the NuScale plant HFE program. Reference 8.2.11 provides more information on the methodology and results of staffing evaluations. 2.2.2 HFE Program Duration The NuScale HFE program is applicable from the start of conceptual design through completion of plant startup testing. After plant turnover to the owner, an established human performance monitoring program maintains the NuScale HFE program design data and appropriate processes. 2.2.3 Applicable Facilities The scope of the NuScale HFE program includes the alarms, controls, indications, and procedures applicable to the main control room (MCR) and the remote shutdown station (RSS). The HSI at the RSS are derived from the HSI in the MCR. The HSI of the TSC, the EOF, and local control stations (LCS) are also included implicitly since their HSI are derivatives of the MCR HSI. The EOF and the technical support center (TSC) will comply with the guidance of NUREG-0696, Functional Criteria for Emergency Response Facilities. The HSI in the TSC and EOF are derivatives of the MCR HSI and comply with the HSI style guide; however, these HSI are for information display only. No control functions are provided in any of the emergency response facilities. For these facilities, the program scope is limited to defining the plant data. 2.2.4 Applicable Human-System Interfaces, Procedures, and Training The HSI design process represents the translation of function, allocation, and task requirements into HSI characteristics and implementation strategies. HSI design inputs include the following:

operating experience review (OER)
functional requirements analysis and function allocation (FRA/FA)
task analysis (TA)
staffing and qualifications (S&Q)
treatment of important human actions (TIHA)

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5

concept of operations
I&C systems design
system requirements
HSI style guide The HFE program supports procedure and training program development for normal operating, abnormal operating, emergency operating, alarm response, and accident management activities performed or supervised by licensed operators.

In addition, the program provides appropriate inputs to the training programs for the personnel identified in 10 CFR 50.120 (Reference 8.2.3), including

I&C technicians.
electrical and mechanical maintenance personnel.
radiological protection personnel.
chemistry technicians.
engineering support personnel.
any other personnel who perform tasks directly related to plant safety, such as information technology technicians who troubleshoot and maintain support systems and their HSIs.

2.2.5 Applicable Personnel The number and qualifications of operators including licensed control room operators as defined in 10 CFR 55 (Reference 8.2.4), the shift supervisor, and shift technical advisor are analyzed and defined by the NuScale HFE program as described in Section 6.4. 2.2.6 Effects of Modifications on Personnel Performance The HFE design process described in program elements up to and including design implementation (DI) evaluates the effect on personnel performance for any modifications in the plant design performed prior to completion of startup testing that affect HSI design, procedures, or training. These evaluations occur directly or through the resolution of human engineering discrepancies (HED). After completion of startup testing and provisional turnover, the licensee institutes a human performance monitoring (HPM) program to continuously evaluate impacts on human performance going forward. The HPM program is described in Section 6.11. Separate from HPM, licensees conduct plant modifications in accordance with regulatory requirements such as 10 CFR 50.59, Changes, Tests, and Experiments. These requirements invoke additional HFE analysis or testing as deemed necessary by the licensees site-specific HFE team. The plant modification process is outside the scope of HPM. © Copyright 2019 by NuScale Power, LLC 7

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 2.3 Abbreviations and Definitions Table 2-1. Abbreviations Term Definition CFR U.S. Code of Federal Regulations COL combined license D3 diversity and defense-in-depth DI design implementation DIHA deterministically important human actions EOF emergency operations facility FRA/FA functional requirements analysis and function allocation HED human engineering discrepancy HFE human factors engineering HFEITS Human Factors Engineering Issues Tracking System HPM human performance monitoring HRA human reliability analysis HSI human-system interface I&C instrumentation and control IP implementation plan ISV integrated system validation ITAAC inspections, tests, analyses, and acceptance criteria LCS local control stations MCR main control room NRC U.S. Nuclear Regulatory Commission OE operating experience OER operating experience review OSC operations support center PMP program management plan PRA probabilistic risk analysis QAPD quality assurance program description QMP quality management plan RIHA risk-important human actions © Copyright 2019 by NuScale Power, LLC 8

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 Term Definition RSS remote shutdown station RSR results summary report S&Q staffing and qualifications SME subject matter expert SRO senior reactor operator TA task analysis TIHA treatment of important human actions TSC technical support center V&V verification and validation Table 2-2. Definitions Term Definition Simulator Review Board The Simulator Review Board reviews the results of simulator testing and compares them to analysis and engineering calculations to certify that the simulator reflects the plant design. This board consists of representatives from Safety Analysis, probabilistic risk analysis (PRA), Engineering, and Operations. Their review is focused on realism to the operator and model validity. HFE Design team The HFE Design Team reviews HEDs and determines the appropriate design changes to the HSI or plant design to resolve the HED. This group consists of members of the HFE team. © Copyright 2019 by NuScale Power, LLC 9

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 3.0 Human Factors Engineering Team, Qualifications, and Organization 3.1 Responsibility The NuScale HFE team is the primary organization that is responsible for the overall HFE program. Specifically, the HFE team is responsible for

developing HFE implementation plans (IP), procedures, and results summary reports (RSR), and ensuring HFE activities compliance with the HFE plans and procedures.
scheduling and overseeing HFE activities in HFE design, development, test, and evaluation as appropriate, and verifying that the teams recommendations are implemented.
HFE reviews of documents produced by other engineering disciplines.
initiating, evaluating, resolving or ensuring resolution of, and maintaining tracking records for HFE issues noted during design activities for all engineering disciplines (see Section 5.0, Human Factors Engineering Issue Tracking System [HFEITS]).

3.2 Organizational Placement and Authority The HFE team is made up of two groups. The core group comprises those members who report directly to the HFE supervisor. The other group is not a specific organization. This group includes various members of the design engineering organization such as system engineering, probabilistic risk assessment, safety analysis, and mechanical engineering. These members do not report directly to the HFE supervisor from a functional organizational perspective; rather, they are distributed throughout the design organization and represent expertise available to the core HFE team on an as-needed basis. Although these personnel do not directly report to the HFE supervisor, they are part of the HFE team, and take direction from the HFE supervisor while performing HFE activities. Accordingly, the HFE supervisor exercises sufficient authority and control over these personnel to reasonably assure that all HFE tasks assigned to them are completed. The list and qualifications of the HFE team members are discussed in Section 3.3. The HFE team members that report directly to the HFE supervisor are a diverse group that includes

human factors engineers that have received formal HFE training.
simulator engineers with backgrounds in computer science and nuclear engineering who participate in the design and selection of controls and displays.
experienced operators that have held NRC-issued reactor operator and senior reactor operator licenses with numerous varying backgrounds in areas such as training, engineering, maintenance, and licensing.

NuScale has integrated the human factors engineers, operators, and simulator engineers into a single group that comprise the core HFE team reporting to the HFE supervisor. This supervisor reports to an operations manager who in turn reports directly © Copyright 2019 by NuScale Power, LLC 10

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 to a vice president of operations. The result is a diverse team with common interests that have significant authority to influence, establish design standards, and advise design engineers. This ensures the integration of systems into an operationally safe design. The size, makeup, and number of supervisors change as the design progresses, depending on what phase of HFE work is beginning or completing. The HFE supervisor has ultimate responsibility for scheduling and oversight of the various HFE activities and is the owner of the HFEITS database. The HFE supervisor or other members of the HFE team elevate issues within the management chain as necessary utilizing appropriate NuScale programs and tools. The HFE program is applicable from the start of conceptual design through completion of plant startup testing. Changes to the HFE organization and responsibilities may occur during construction and startup. A combined license (COL) applicant/holder is responsible for ensuring that any transitions between responsible organizations are made as necessary and appropriate. 3.3 Composition As discussed in Section 3.2, the HFE team includes personnel that report directly to the HFE supervisor, and various other personnel distributed throughout the design organization who do not directly report to the HFE supervisor. The HFE team incorporates, at a minimum, the expertise described in the appendix of NUREG-0711, Revision 3 (see Table 3-1). The experience and education levels of the members of the core HFE team meet many of the requirements listed in Table 3-1; however, both the core HFE team and the HFE team members distributed throughout the organization taken together meet all the required experience and qualifications as listed in Table 3-1. © Copyright 2019 by NuScale Power, LLC 11

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 Table 3-1. Human Factors Engineering team member qualifications Technical Discipline Minimum Qualifications Technical Project

Bachelor's degree Management
5 years of experience in nuclear power plant design or operations
3 years of management experience Systems Engineering
Bachelor of Science degree
4 years of cumulative experience in at least three of the following areas of systems engineering: design, development, integration, operation, and test and evaluation Nuclear Engineering
Bachelor of Science degree
4 years of nuclear design, development, test, or operations experience HSI/I&C Engineering
Bachelor of Science degree
4 years of experience in design of hardware and software aspects of process control systems
Experience in at least one of the following areas of engineering: design, power plant operations, and test and evaluation
Familiarity with the theory and practice of software quality assurance and control Architect Engineering
Bachelor of Science degree
4 years of experience in design of power plant control rooms HFE
Bachelor's degree in HFE, engineering psychology, or related science
4 years of cumulative experience related to the human factors aspects of human-computer interfaces. Qualifying experience should include at least the following activities within the context of large-scale human-machine systems (e.g., process control): design, development, and test and evaluation
4 years of cumulative experience related to the human factors aspects of workplace design. Qualifying experience should include at least two of the following activities: design, development, and test and evaluation.

Plant Operations

Has, or has held, an SRO license
2 years of experience in relevant nuclear power plant operations Computer
Bachelor's degree in electrical engineering or computer science, or graduate System/Simulator degree in another engineering discipline (e.g., mechanical engineering or Engineering chemical engineering)
4 years of experience in the design of digital computer systems and real-time systems applications
Familiarity with the theory and practice of software quality assurance and control

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 Technical Discipline Minimum Qualifications Plant Procedure

Bachelor's degree Development
4 years of experience in developing nuclear power plant operating procedures Personnel Training
Bachelor's degree
4 years of experience in the development of personnel training programs for power plants
Experience in the application of systematic training development methods Systems Safety
Bachelor of Science degree Engineering
4 years of experience in system safety engineering Maintainability/
Bachelor of Science degree Inspectability
4 years of cumulative experience in at least two of the following areas of Engineering power plant maintainability and inspectability engineering activity: design, development, integration, and test and evaluation
Experience in analyzing and resolving plant system and/or equipment-related maintenance problems Reliability/Availability
Bachelor's degree Engineering
4 years of cumulative experience in at least two of the following areas of power plant reliability engineering activity: design, development, integration, and test and evaluation
knowledge of computer-based, human-interface systems 3.4 Team Staffing The HFE supervisor assigns members of the HFE team (including personnel from outside the Plant Operations organization) to HFE activities to ensure that needed expertise is applied in performing those activities. Members of the core HFE team are assigned as leads and owners of various HFE related areas. For example, each core HFE team member is assigned a group of systems and is the primary interface and representative with engineering for that system. Additionally, this person is responsible for completing all the work in support of functional requirements analysis and function allocation (FRA/FA), TA, HSI, procedures, and training development for the systems assigned. This person also performs all system design document and functional specification reviews for the assigned group of systems. Members of the core HFE team are also assigned as functional leads for nonsystem areas such as probabilistic risk analysis (PRA), emergency planning, and simulator design.

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 Table 3-2. Human Factors Engineering team participant primary responsibilities HSI Other OER FRA/FA TA S&Q TIHA Procedures Training V&V DI HPM Design Duties Technical Project 1, 2, 3 Management Systems X X X X X 4 Engineering Nuclear X X X 4 Engineering I&C Engineering X X X X X X X X X 4 Architect X X X 4 Engineering Human Factors X X X X X X X X X X X 4, 5 Engineering Plant Operations X X X X X X X X X X X 4, 5 Computer Systems X X X X 4 Engineering Plant Procedure X X X X X 4 Development Personnel X X X X X X X 4 Training Systems Safety X 4 Engineering Maintainability/ Inspection X X X X X X X 4 Engineering Reliability/ Availability X X X 4 Engineering Other Duties:

1. Develop project and element technical reports.

2. Develop and maintain HFE design schedule.

3. Manage the HFE analysis, design, V&V, implementation, and problem resolution.

4. Perform the duties of HFEITS evaluator and owner as assigned.

5. Perform the duties of HFE element leader as assigned.

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 4.0 Human Factors Engineering Processes and Procedures 4.1 General Process Procedures 4.1.1 Human Factors Engineering Team Assignment The HFE supervisor assigns personnel from throughout the organization so that the needed expertise, knowledge, and experience are applied to each HFE activity (see Table 3-2). IPs and RSRs describe the expertise utilized for each activity within the HFE program element. 4.1.2 Internal Management of the HFE Team The HFE supervisor assigns members of the HFE team (within the Plant Operations organization, Design Engineering, and other organizations) and supervises them during performance of HFE tasks. 4.1.3 Making Decisions on Management of the HFE Program The HFE supervisor has ultimate responsibility for scheduling and oversight of the various HFE activities. 4.1.4 Making HFE Design Decisions The HFE supervisor has primary authority to make management decisions for HFE activities. Where design decisions require input from multiple organizations, the HFE supervisor may elevate issues within the management chain utilizing NuScale tools and programs including HFEITS, the applicable NuScale internal procedures, design review boards (who perform design reviews as part of design), and the corrective action program. Any member of the HFE team may identify problems and propose solutions using the HFEITS tool. The HFE supervisor has authority to make decisions regarding resolution of HFEITS items (including HEDs). 4.1.5 Controlling Changes in Design of Equipment The HFE supervisor is responsible for the design of MCR equipment and controls any changes. Design Engineering is responsible for the design of HSIs throughout the plant. Design changes to HSI and other equipment that have major input from HFE are governed through a design change process. As discussed in Section 3.4, the HFE team members perform reviews of the assigned system design documents and have the authority to approve the documents. They also participate in key meetings such as system design phase reviews. This ensures that the HFE team members have the authority to influence and control design changes. © Copyright 2019 by NuScale Power, LLC 15

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 4.1.6 Review of Human Factors Engineering Products The HFE supervisor has ultimate responsibility for scheduling and oversight of the various HFE activities including reviews of HFE team products. Where independent reviews (outside the overall HFE team) are necessary, the HFE supervisor retains approval authority for HFE team products. 4.2 Process Management Tools HFE, like other NuScale engineering discipline activities, is conducted in accordance with the NuScale Quality Management Plan (QMP) (Reference 8.2.5) and subordinate plans and procedures, including the design control process (Reference 8.2.6). The QMP establishes controls to ensure that all provisions and commitments contained in NuScale Quality Assurance Program Description (QAPD) have been implemented appropriately The design process includes provisions to control design inputs, outputs, changes, interfaces, records, and organizational interfaces within NuScale and with suppliers. These provisions ensure that design inputs (such as design bases and the performance, regulatory, quality, and quality verification requirements) are correctly translated into design outputs (such as analyses, specifications, drawings, procedures, and instructions). This translation ensures that the final design output can be related to the design input in sufficient detail to permit verification. Design change processes and the division of responsibilities for design-related activities are detailed in NuScale and supplier procedures. The design control program includes interface controls necessary to control the development, verification, approval, release, status, distribution, and revision of design inputs and outputs. Design changes and disposition of nonconforming documents are reviewed and approved by the NuScale design organization or by other organizations so authorized by NuScale. HFE program tools and techniques used to fulfill responsibilities are also available to support the HFE elements. Specific tools and techniques used for each HFE element are described in the respective RSRs. ((

                                                                                  }}2(a),(c)

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 4.3 Integration of Human Factors Engineering and Other Plant Design Activities Appendix A describes the HFE team integration into the iterative design process through the design review process. 4.4 Human Factors Engineering Program Milestones Table 4-1 shows the relationship of HFE program element design activities to the activity milestones. The IP and RSR shown parenthetically in the activities column represent the type of submittal associated with a given activity or HFE element. An HFE relative project schedule with milestones is integrated into the project design development schedule and is available for review. Table 4-1. Human factors engineering program and design activity milestones HFE and Design Activities Activity Milestones Combined License (COL) Activity Type of Design Control (Prior to Fuel Activities Activities Document Load) Operating Experience Review (RSR) X Functional Requirements Analysis and Function X Allocation (RSR) Task Analysis (RSR) X Staffing & Qualifications (RSR) X Treatment of Important Human Actions (RSR) X Human-System interface Design (RSR) X HFE Element Procedure Development X Evaluation Training Program Development X Verification & Validation (IP) NOTE: The verification and validation RSR will be submitted prior to start of Phase 4 of the NRCs X review of the design certification application, in accordance with Reference 8.2.14. Design Implementation X Human Performance Monitoring X (ongoing) PRA - Chapter 19 Level I & II PRA (all modes/all X hazards) Plant Design Chapter 15 Safety Analyses X Activities Physical Plant Layout X X (site specific) Simulator Development X (Sufficient to X (ANSI 3.5) support S&Q © Copyright 2019 by NuScale Power, LLC 17

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 HFE and Design Activities Activity Milestones RSR) SSC Design X X SSC Testing X 4.5 Human Factors Engineering Documentation HFE documents that support design are quality records and retained in accordance with the NuScale QMP (Reference 8.2.5). All such documentation is available for review upon request. HFE documentation includes design verification checklists, HFEITS records, documentation identified in the HFE element technical reports (e.g., RSRs, guides, and training programs), and information stored in the HFE database. Table 4-2 provides a tabulation of the IPs and the RSRs submitted. The methodologies of the HFE activities described in each elements implementation plan are summarized in the associated RSR, with the exception of the V&V RSR. In addition to results of the analyses, the RSRs (References 8.2.8 through 8.2.13) contain the latest methodology used in the analysis, and supersede the methodology described in the associated IPs that had been previously submitted. Since the human factors verification and validation RSR will be completed after the initial DCA submittal, the human factors verification and validation IP will remain a standalone document. As a result, the human factors verification and validation RSR will not contain a methodology section but will simply reference the IP. Unless otherwise noted, the contents of the RSRs are in accordance with the applicable guidance of NUREG-0711. © Copyright 2019 by NuScale Power, LLC 18

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 Table 4-2. Human factors engineering element documentation Results Implementation HFE Element Summary Notes Plan Report The RSR contains results and the latest Operating Experience X X methodology, and supersedes the Review implementation plan Functional The RSR contains results and the latest Requirements Analysis X X methodology, and supersedes the and Functional implementation plan Allocation The RSR contains results and the latest Task Analysis X X methodology, and supersedes the implementation plan The RSR contains results and the latest Staffing and X X methodology, and supersedes the Qualifications implementation plan The RSR contains results and the latest Treatment of Important X X methodology, and supersedes the Human Actions implementation plan The RSR contains results and the latest Human-System X X methodology, and supersedes the Interface Design implementation plan Procedure development is the responsibility of a COL applicant. Procedure development activities Procedure within the NuScale HFE program are limited to Development writers guides and integration with the computer-based procedure HSI. Training program development is the responsibility of a COL applicant. Training Training Program program activities within the NuScale HFE Development program are limited to operator qualifications to support V&V activities in the simulator. Human Factors The RSR is submitted prior to the start of Phase Verification and X X 4 of the NRCs review of the design certification Validation application. No RSR is required for this element since conformance of the as-built design to the verified Design X and validated design is confirmed by an Implementation inspections, tests, analyses, and acceptance criteria (ITAAC) item. Human performance monitoring is the Human Performance responsibility of a COL applicant. No Monitoring implementation plan or RSR is submitted as part of design certification application. © Copyright 2019 by NuScale Power, LLC 19

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 4.6 Subcontractor HFE Efforts If a subcontractor is involved in HFE activities, the HFE team verifies that the subcontractor is properly trained and complies with the NuScale QMP (Reference 8.2.5) and subordinate plans and procedures. The QMP establishes controls to assure that all provisions and commitments contained in NuScales Quality Assurance Program Description (QAPD) have been implemented appropriately. The QAPD requires that NuScale subcontractors establish a qualification program that is applied to individuals performing quality inspections regardless of the functional group where they are assigned. The NuScale QA organization verifies that the subcontractors conduct work in accordance with the NuScale QMP or the subcontractors quality assurance program as contracted. © Copyright 2019 by NuScale Power, LLC 20

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 5.0 Human Factors Engineering Issue Tracking System 5.1 Availability of Human Factors Engineering Issue Tracking System HFE issues are identified and tracked in the HFEITS database. A Human Factors Engineering issue is any issue that has not been resolved in the NuScale HFE program process. Issues are those items that need to be addressed at some later date and thus need to be tracked to provide reasonable assurance that they are not overlooked. The HFEITS database is available to any member of the HFE team and identification of issues is part of the NuScale corporate culture. HFE issues may include

recognized industry HFE issues.
issues identified throughout the life cycle of the HFE project.
human engineering discrepancies found during HFE design.
deficiencies with operating procedures
discrepancies noted with the HSI
simulator modeling issues
simulator (control room) ergonomics The HFEITS database is maintained until fuel load. The HFEITS process is depicted in Figure 5-1.

5.2 Human Factors Engineering Issues Tracking Methodology Because the HFE team is imbedded into the design engineering process, most potential HFE issues are able to be resolved immediately. This is accomplished through direct feedback to design engineers, at engineering design phase review meetings, and during design document review and comment resolution. If the issue cannot be immediately resolved, it is entered into the HFEITS database and is assigned a unique tracking number. Supporting documentation in electronic format is attached to the database item. The HFE issue is screened and evaluated to confirm potential degradation in human performance is identified. Issues found that do not degrade human performance are either closed or transferred to more appropriate corrective action processes. Proposed corrective action to resolve the HFE issue is identified and assigned as necessary. Due dates for resolution of the overall evaluation or for each corrective action are established by the HFEITS administrator. Issue close-out and transfer with proper documentation is approved by both the HFEITS administrator and the HFE supervisor. The HFE supervisor may obtain support from the HFE team to resolve and approve the closure of items in the HFEITS database. At HFE program milestones (completion of certain activities), the HFEITS database is reviewed for items to be resolved or closed. © Copyright 2019 by NuScale Power, LLC 21

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 5.3 Human Factors Engineering Issues Tracking Documentation For each HFE issue, the HFEITS documents the following:

issue date
any supporting information, such as attachments documenting the issue
assigned issue owner and evaluator
whether or not the issue involves a human engineering discrepancy Note: Management and closure of human engineering discrepancies are discussed in the various HFE program technical reports and RSRs (see Section 6.0).
proposed resolution
HFE team acceptance or rejection and detailed justification
actual resolutions (i.e., changes to design)

Note: Descriptions of resolutions are sufficiently detailed to provide traceability and promote third party review.

actions taken (i.e., any programmatic or administrative changes determined appropriate to address larger issue)
affected document(s) 5.4 Human Factors Engineering Issues Tracking Responsibilities All HFE team members are responsible for identifying, logging, evaluating, and tracking HFE issues to resolution.

5.4.1 Supervisor, Human Factors Engineering Team The HFE supervisor has overall responsibility for administering and managing the HFE Issue Tracking System team and review committee. 5.4.2 Human Factors Engineering Issue Tracking System Team Lead The HFEITS team lead is responsible for requesting resolution and verification resources from the responsible manager, in order to resolve open HFEITS issues. The responsibilities are to

provide oversight of HFE issue tracking.
coordinate appropriate resources across the company including operations SMEs, software developer SMEs, plant system SMEs to identify and implement resolution solution.
approve resolution of HFE issues with support from HFE team as needed.

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coordinate the HFEITS review committee.
coordinate with the software review board.
add and remove users authorized to modify the database.
negotiate initial issue evaluator and owner assignments.
negotiate initial resolution and corrective action due dates.
track the issue resolution and corrective action due dates.
approve issue evaluator and owner changes.
approve due date changes.

5.4.3 Human Factors Engineering Issues Tracking System Administrator The HFEITS administrator is assigned responsibility for managing the software component of the database. The administrator will not necessarily be a member of the HFE team; for example, an information technology specialist. The HFEITS administrators responsibilities are to

manage the integrity of the HFEITS database.
maintain hardware and software for optimum performance.
manage database security.

5.4.4 HFE Team Member Issue Evaluator An HFE team member issue evaluators responsibilities are to

evaluate issues.
identify the extent and significance of issues.
recommend issue owners.
recommend corrective actions.
recommend resolution due dates.

5.4.5 Issue Owner The issue owners responsibilities are to

resolve issues.
update HFEITS with proposed or completed actions.
update design documentation where appropriate.

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 5.4.6 HFEITS Review Committee A HFEITS review committee reviews all HFE issues and human engineering discrepancies (HEDs) submitted following an established internal NuScale procedure to evaluate designation, impact, priority, alignment with current development phases, and assignment to appropriate implementers. The HFE review committee is responsible for reviewing the full documentation to verify the resolution was completed on all HFEITS issues and HEDs for completeness before final closure. © Copyright 2019 by NuScale Power, LLC 24

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 ((

                                                                                                          }}2(a),(c)

Figure 5-1. Human factors engineering issues system process 5.4.7 Human Engineering Discrepancy Resolution A human engineering discrepancy (HED) is an issue usually discovered during the verification and validation phase of the HFE program and may require engineering changes and verification. HEDs are identified as personnel task requirements (as defined in the task analysis) that are not fully supported by the human system interface (HSI), and the presence of HSI components that may not be needed to support personnel tasks. HEDs are also identified if the design is inconsistent (does not accommodate human capabilities and limitations) with HFE guidelines, such as NUREG-0700 or any NuScale HSI style guides. © Copyright 2019 by NuScale Power, LLC 25

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 HEDs are identified, documented, and resolved throughout the verification and validation process. NuScale begins to record HEDs after the completion of Staffing Plan Validation. The HED resolution process involves evaluation of the HEDs to determine if they require correction, development and evaluation design solutions to address HEDs that must be corrected, and verification that the design solutions have been implemented. These topics are discussed in Reference 8.2.15. HEDs may not always be resolved; HEDs may be found acceptable after an evaluation in the context of the integrated design. The basis for a decision for accepting an HED without change in the integrated design is documented. It may be based on accepted HFE practices, current published HFE literature, trade-off studies, tests, or engineering evaluations. 5.4.8 HED Process Flow During ISV testing HEDs are analyzed by the HFEITS team for priority selection and design category placement (e.g., HSI or simulator). Once the HED has been received, a discrepancy entry is created in the HFEITS database and the HED is prioritized as Priority 1, Priority 2, or Priority 3 HEDs according to their importance as follows:

Priority 1 HEDs have a potential direct or indirect impact on plant safety and are resolved prior to submitting the V&V Results Summary Report. HEDs initiated as a result of a performance measure not being met (pass/fail performance measures) are priority 1 HEDs. Cross-cutting issues determined through HED analysis or performance measure analysis are priority 1 HEDs due to their global impact on the HSI design performance.
Priority 2 HEDs have a direct or indirect impact on plant performance and operability and are resolved before turning over HFE responsibilities to a licensee.
Priority 3 HEDs are those that do not fall into priority 1 or priority 2. Priority 3 HEDs are resolved in accordance with QA policy-related programs and processes.

The HED is then routed to the appropriate group for resolution. HEDs related to the HSI are sent to the HFE design team, and HEDs related to simulator modeling are sent to the simulator review board. It is possible for HEDs to be routed to both groups. The HED is then resolved, and the discrepancy entry closed. The HED resolution is reviewed for final closure in the HFEITS database by an HFE review committee. The HED resolution process is depicted in Figure 5-2. © Copyright 2019 by NuScale Power, LLC 26

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 6.0 Human Factors Engineering Technical Program Elements The NuScale HFE program comprises the elements described below. The elements and associated activities are included in the integrated project development schedule, and are available for NRC review. Each elements IP or RSR provides

description of the scope, inputs, analyses to be performed, outputs, and documentation.
description of the applicable methodology.
appropriate tools and facilities to be employed.
description of the review and documentation requirements for subordinate documents that support HFE products.

The following sections provide a summary of each HFE element. A more detailed discussion is contained in the associated IPs or RSRs. 6.1 Operating Experience Review The NuScale HFE program includes an operating experience review (OER). As shown in Table 4-2, the OER activity documentation consists of an RSR. The RSR (Reference 8.2.8) describes the OER process, methodology, and the findings from the OER. The RSR also documents the specific types of OER conducted and the incorporation of applicable findings into the NuScale design. The OER scope includes

review of recognized industry HFE issues contained in NUREG/CR-6400 (Reference 8.2.7).
review of recognized industry HFE issues identified since January 1996, one year before NUREG/CR-6400 was issued.
review of operating experience related to the proposed NuScale.
identification of HFE issues obtained through interviews with plant personnel.
identification of important human actions in the NuScale design.

The HFE team is responsible for conducting the operating experience review. The qualifications of the HFE team members supporting OER are specified in the OER RSR. The OER methodology includes the following considerations:

team and team lead responsibilities
OER information review criteria
OER database data entry
OER item analysis approval
results output to requisite NuScale engineering organizations

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OER database field descriptions
OER plant personnel interview criteria
coordination between the OER database and the HFE issues tracking database If an OER issue is determined to be applicable to NuScale and HFE, but cannot be resolved at the current point in the design, it becomes an HFE issue. HFE issues are tracked in the HFEITS database throughout the lifecycle of the HFE program for the NuScale design project. The HFEITS database is described in Section 5.0.

6.2 Functional Requirements Analysis and Function Allocation The NuScale HFE program includes an FRA/FA. As shown in Table 4-2, the FRA/FA activity documentation consists of an RSR. The RSR (Reference 8.2.9) describes the FRA/FA process, methodology, and the findings from the FRA/FA. For each plant function, the HFE team documents

purpose.
predecessor functions of systems.
relevant operating experience.
differences from predecessor functions or systems.
supporting sub-functions, processes, components, and systems.
safety and risk significance.

To support the functional analysis, the HFE team then documents

supported plant goal.
conditions that indicate the need for the function.
parameters that indicate the availability and operating status of each function, whether the function is achieving its purpose, and whether the operations of the function should be terminated.
alternative success paths for the function.

Once the FRA is complete, the FA is conducted. A set of automation criteria is developed to allocate each function to manual, automatic, or shared execution. The HFE team allocates each function to optimize relevant automation criteria as follows:

analyze predecessor function allocations and operating experience
analyze upstream, downstream, and related functions in the overall plant design to assess indirect consequences
evaluate relevant criteria impacting safety, reliability, situation awareness and cost effectiveness

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evaluate the aggregate impact to personnel considering all functions assigned to them
allocate the function to a discrete allocation criteria to improve overall design consistency Tools for the FRA/FA process include an FRA/FA database that produces a functional requirements hierarchy chart.

6.3 Task Analysis The NuScale HFE program includes a TA. As shown in Table 4-2, the TA activity documentation consists of an RSR. The RSR (Reference 8.2.10) describes the TA process, methodology, and the findings from the TA. All tasks, regardless of the importance, are analyzed so that the full extent of the work load can be determined. Examples of tasks to be analyzed include, but are not limited to, the following:

tasks that include important human actions as determined from safety analysis, probabilistic risk assessment (PRA), and diversity and defense-in-depth (D3) coping analysis for the instrumentation and control systems
tasks that, if performed incorrectly, could impact nuclear safety or power generation
tasks that are new or performed in a manner significantly different from similar tasks in the existing industry
tasks related to monitoring automated systems that are important to safety
tasks related to recognizing the failure or degradation of automated equipment and performance of associated tasks that implement backup responses
administrative tasks and support aids such as reference materials, hard copy graphs, and calculators that place a large burden on the control room personnel
maintenance or testing tasks that are important to safety
tasks with potential effects on personnel safety (such as maintenance tasks performed in the containment)

After identification, a task narrative is written to (1) describe the objectives of a specific systems operator tasks, and (2) provide an overview of the activities personnel are expected to accomplish to complete the task. Narrative descriptions of operator activities contain requisite detail for a reviewer to correlate the described task objectives to the results of the completed TA. The narrative is brief for simple tasks but has greater detail from more complex tasks. The detailed TA involves

decomposition of task elements.
preparation of the operational sequence diagram.

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determination of task attributes and completion of the task table.
identification of knowledge and abilities.
assignment of tasks to roles.
analysis of the feasibility and reliability for important human actions.

A database is used to capture data from the TA process. The database contains the results from the TA and can be used to facilitate searches and reviews of previous analyses. The database also contains a list of the tasks reviewed, the task attributes, and the knowledge and abilities identified for each task. 6.4 Staffing and Qualifications As discussed in Section 2.2.1, NuScales HFE program staffing and qualifications (S&Q) analysis addresses only the activities performed by licensed control room operators. The S&Q RSR describes the S&Q analysis process and includes the output documentation requirements. The S&Q RSR (Reference 8.2.11) describes the findings from the S&Q analysis. Operator staffing levels for the current operating plants are regulated by 10 CFR 50.54(m) for single or dual unit sites operated from a single control room or for sites with up to three units and up to three control rooms. The NuScale plant is designed to operate up to twelve modules from a single MCR, and this configuration is not specifically addressed in the regulation. NuScale proposes an alternate staffing solution and the associated technical basis for addressing staffing level requirements. The technical basis uses the existing guidance in NUREG-0800, NUREG-0711, and NUREG-1791, consistent with SECY-11-0098 and NUREG/CR-6838. Guidance of NUREG-1791, specifically Section 10 from the guidance, is incorporated into the S&Q analysis and the S&Q RSR. As described in Section 2.2.1, the NuScale plant uses passive safety systems and is highly automated to reduce the need for operator actions and allow for monitoring multiple units simultaneously. This level of automation impacts HSI design from the aspect of the number of physical interfaces, data processing, operating procedures, display screens, alarms, controls, and support aids needed to support the accomplishment of tasks. The acceptability of staffing levels for the NuScale operating concept for all modes and for the aggregate of tasks assigned to operating personnel is confirmed in the S&Q analysis. The S&Q analysis confirms that OER issues related to licensed operator staffing positions are adequately addressed despite any changes in staffing or qualifications for the NuScale design from current operating plants. The S&Q analysis also provides the staffing plan validation. 6.5 Treatment of Important Human Actions The NuScale HFE program includes provision for treatment of important human actions (TIHA). The TIHA RSR describes the process for determining and treatment of important © Copyright 2019 by NuScale Power, LLC 31

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 human actions and includes the output documentation requirements. The TIHA RSR (Reference 8.2.12) describes the findings from the analysis and resolutions. The TIHA analysis identifies risk-important human actions (RIHA) from the PRA. The TIHA IP describes the PRA methodology, the method for determining human error probability (HEP), and the method used to determine the risk significance of those potential errors. Other PRA activities are outside the scope of the HFE program. The TIHA analysis also describes the methodology used to extract deterministically important human actions (DIHA) from the transient and accident analyses and the D3 coping analysis. HFE personnel assess DIHAs to confirm with reasonable confidence that they can be carried out within the time available. An additional detailed quantitative analysis of workload and time constraints is performed for both RIHAs and DIHAs in the TA, the S&Q, and in a performance-based test, using the simulator, independent operating crews, and challenging scenarios. These IHAs are also included in integrated system validation (ISV) scenarios. 6.6 Human-System Interface Design The NuScale HFE program includes HSI design. An HSI design RSR (Reference 8.2.13) describes the HSI methodology and the outputs of the HSI design element. The HSI design element generates the MCR HSIs, MCR derivative HSIs, and LCS HSIs after translating HFE analysis outputs into the inventory of alarms, displays, controls, and operating procedures. A key output of the HSI design program element is a complete set of HSIs that are implemented in the control room simulator for subsequent verification and validation (V&V). The simulator includes all the functions of the MCR and MCR derivative HSIs used in the RSS, technical support center (TSC), and emergency operations facility (EOF). HSI design also generates the LCS HSI design and the requirements for their physical locations. OER identifies issues addressed by predecessor and similar HSI designs. Assessments are made by the HFE team at the time the OER is conducted. HSI design confirms that the OER issues remain adequately addressed despite any changes during plant design. The TIHA element identifies assumptions regarding the characteristics of the HSI used for RIHAs and DIHAs. HSI design element ensures these assumptions are implemented in the HSI (e.g., control accessibility from the MCR and/or spatially-dedicated continuously-visible HSI to reduce time required for human actions). HSI design uses the HSI inventory and characteristic outputs from TA to establish alarm priority and applicability logic, display and control designs, and procedure step acceptance criteria. HSI design also uses these TA outputs to establish the grouping of HSI inventory for task-based display screens. The S&Q analysis confirms the MCR operating staff numbers and qualifications for all plant modes. The HSI design includes layout of the operator workstations and displays for the MCR. The HSIs at the RSS and local facilities are derivatives of the MCR HSIs. © Copyright 2019 by NuScale Power, LLC 32

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 HSI design uses plant operating procedures developed as part of the plant design (i.e., procedure development is integrated with HFE activities but not considered HFE program scope) to generate computer-based procedures, which are necessary tools to support the ISV of the V&V program element. Other procedures (e.g., surveillance and test procedures) are also outside the scope of the HSI design element because they have their own development and V&V program. HFE issues generated during HSI design or from prior program elements are resolved during HSI design so that the final output is a complete HSI design suitable for V&V. 6.7 Procedure Development Procedure development is the responsibility of the COL applicant. Though there are procedure development activities integrated with the overall NuScale HFE program, no IP or RSR for procedures is produced as part of the NuScale HFE program. 6.8 Training Program Development Operators who support the human factors V&V program element are trained in accordance with the NuScale training program. The training program itself is not part of the HFE program. Training program development is the responsibility of the COL applicant. Though there are training program development activities integrated with the overall NuScale HFE program, no IP or RSR for training program is produced as part of the NuScale HFE program. 6.9 Human Factors Verification and Validation The NuScale HFE program includes human factors V&V. The V&V IP (Reference 8.2.15) describes the human factors V&V process and includes the output documentation requirements. Following V&V activities, an RSR will be prepared to describe the V&V methodology as well as the outputs of human factors V&V. Human factors V&V evaluations comprehensively determine that the HSIs, procedures, and training program conform to HFE design principles and that the HSIs enables plant personnel to successfully perform their tasks to achieve plant safety and other operational goals. Demonstrating conformance to the acceptance criteria defined in the human factors V&V IP for the ISV is the final design acceptance milestone for the HSIs. The scope of the human factors V&V activity includes the MCR, RSS, TSC, EOF (information requirements and communications), and LCSs as defined in Section 2.2.3. Human factors V&V of the EOF is outside the scope of the human factors V&V program. V&V is conducted using a control room simulator that reflects the output of HSI design, procedures, and training program. 6.10 Design Implementation The NuScale HFE program includes design implementation. The DI IP describes the DI process and includes the output documentation requirements. No RSR is required for © Copyright 2019 by NuScale Power, LLC 33

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 this element since conformance of the as-built design to the verified and validated design is confirmed by an ITAAC. DI demonstrates that the design that is implemented accurately reflects the design that has been verified and validated during human factors V&V. If the DI program element identifies differences such as site-specific aspects that were not included in V&V or design changes that occur after V&V, those differences are evaluated to determine any impact to the analysis results from all previous HFE program elements, including V&V. While successful ISV marks the end of human factors V&V, the HSI design continues to be challenged during the operator training program. Any Priority 3 HEDs generated during V&V that are determined to require resolution and any HEDs generated after completion of V&V are resolved during DI. 6.11 Human Performance Monitoring Human performance monitoring (HPM) begins after DI is completed and continues for the life of the plant. HPM is intended to detect degradation in operator performance compared to the performance observed during integrated system validation. Degradation may be due to many factors that occur over the life of the plant, including changes in personnel, changes in plant culture, changes in training methods, or changes in the HSI design itself. The HPM program includes

monitoring and investigating perceived or documented reduced human performance.
analyzing causes of reduced human performance.
developing corrective action plans for improvement.
maintaining a culture of continuous monitoring of human performance through operating experience review.
training and qualification.
change management (modification process, configuration management).
use of the plant simulator.
independent reviews and audits.

HPM is a catalyst for corrective actions over the life of the plant; the COL applicant manages its own corrective actions program. HPM is a responsibility of the COL applicant. No implementation plan or RSR is submitted as part of the design certification application. © Copyright 2019 by NuScale Power, LLC 34

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 7.0 NUREG-0711 Conformance Evaluation Table 7-1 provides a mapping of the sections in this program management plan (PMP) where each NUREG-0711, Revision 3 criterion is met. Table 7-1. Conformance with NUREG-0711 HFE PMP Review Criteria Section No. and paragraph 2.4.1 General HFE Program Goals and Scope Section 2.1, All (1) HFE Program Goals - The applicant should state the general objectives of the program in human-centered terms. As the HFE program develops, they should be further defined and used as a basis for HFE tests and evaluations. Additional Information: Generic human-centered HFE design goals include the following: personnel tasks can be accomplished within time and performance criteria the HSIs, procedures, staffing/qualifications, training, and management and organizational arrangements support personnel situation awareness the design will support personnel in maintaining vigilance over plant operations and provide acceptable workload levels, i.e., minimize periods of under- and over-load the HSIs will minimize personnel error and will support error detection and recovery capability (2) Assumptions and Constraints - The applicant should identify the design Section 2.2.1, All assumptions and constraints. Additional Information: An assumption or constraint is an aspect of the design, such as a specific staffing plan or a specific HSI technology that is an input to the HFE program rather than the result of HFE analyses and evaluations. (3) HFE Program Duration - The applicants HFE program should be in effect at Section 2.2.2, All least from the start of the design cycle through completion of initial plant startup test program. (4) Facilities - The applicants HFE program should cover the main control room Section 2.2.3, All (MCR), remote shutdown facility (RSF), technical support center (TSC), emergency operations facility (EOF), and local control stations (LCSs). The 12 HFE elements should be applied to each of them, unless otherwise noted for a specific HFE element. However, applicants may apply the elements of the HFE program in a graded fashion to facilities other than the MCR and RSF, providing justification in the HFE program plan. (5) HSIs, Procedures and Training - The applicants HFE program should Section 2.2.4, All address the design of HSIs and identify inputs to the development of procedures and training for all operations, accident management, maintenance, test, inspections, and surveillance tasks that operational personnel will perform or supervise. In addition, the HFE design process should identify training program input for the following personnel identified in 10 CFR 50.120: instrument and control technician, electrical maintenance personnel, mechanical maintenance personnel, radiological protection technician, chemistry technician, and engineering support personnel. In addition, any other personnel who perform tasks directly related to plant safety should be included, such as information technology technicians who troubleshoot and maintain support systems and their HSIs. (6) Personnel - The applicants HFE program should consider operations staffing Section 2.2.5, All and qualifications, including licensed control-room operators as defined in 10 CFR Part 55, and the following categories of personnel: non-licensed operators, shift supervisor, and shift technical advisor. © Copyright 2019 by NuScale Power, LLC 35

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 HFE PMP Review Criteria Section No. and paragraph (7) Additional Considerations for Reviewing the HFE Aspects of Plant Section 2.2.6, All Modifications - In addition to any of the criteria above that relate to the modification being reviewed, the applicant should address the following considerations: The goals of the applicants HFE program should address the potential effects of a modification on the performance of personnel. The transition from the existing plant configuration to the modified one can pose different demands on human performance than either the initial or the final configurations. Therefore, the modification and its implementation should be planned to minimize the effects of the change on personnel performance. The HFE program for the modification should consider: planning the installation to minimize disruptions to work coordinating changes in training and procedures when implementing the modification conducting training to maximize personnels knowledge and skill with the new design before implementing it The applicants HFE program should involve plant personnel to ensure that the following are considered from a users perspective in establishing the requirements for the modification, and evaluating the outputs of the design process: users understanding of how plant systems are structured and behave task demands and constraints of the existing work environment and work processes 2.4.2 HFE Team and Organization Section 3.1, All In this document, the term HFE team means the primary organization(s) responsible for the applicants HFE program. However, we do not assume that HFE is the responsibility of a single organizational unit, or that there is an organizational unit called the HFE team. Responsibility - The applicants team should be responsible for: developing all HFE plans and procedures overseeing and reviewing all activities in HFE design, development, test, and evaluation, including the initiation, recommendation, and provision of solutions through designated channels for problems identified in implementing the HFE work verifying that the teams recommendations are implemented assuring that all HFE activities comply with the HFE plans and procedures scheduling work and milestones Organizational Placement and Authority - The applicant should describe the primary Section 3.2, All HFE organization(s) or function(s) within the engineering organization designing the plant or modification. The organization should be illustrated to show organizational and functional relationships, reporting relationships, and lines of communication. The applicant also should address the following: When more than one organization is responsible for HFE, such as instrumentation and control (I&C) and operations, the lead organizational unit answerable for the HFE program plan should be identified. If organization changes are expected over time (e.g., from design through construction to startup) necessary transitions between responsible organizations should be described. The team should have the authority and organizational placement to reasonably assure that all its areas of responsibility are completed, and to identify problems in establishing the overall plan or modifying its design. The team should have the authority to control further processing, delivery, installation, or use of HFE products until the disposition of a nonconformance, deficiency, or unsatisfactory condition is resolved. Composition - The applicants HFE team should include the expertise described in Section 3.3, All the appendix to this report. Team Staffing - The applicant should describe team staffing in terms of job Section 3.4, All descriptions and assignments of team personnel. © Copyright 2019 by NuScale Power, LLC 36

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 HFE PMP Review Criteria Section No. and paragraph 2.4.3 HFE Process and Procedures Section 4.1, All (1) General Process Procedures - The applicant should identify the process through which the team will execute its responsibilities. It should include procedures for the following: assigning HFE activities to individual team members governing the internal management of the team making decisions on managing the HFE program making HFE design decisions controlling changes in design of equipment reviewing of HFE products (2) Process Management Tools - The applicant should identify the tools and Section 4.2, All techniques (e.g., review forms) the team uses to verify that they fulfilled their responsibilities. (3) Integration of HFE and Other Plant or Modification Design Activities - The Section 4.3, All applicant should describe the process for integrating the design activities (i.e., the inputs from other design work to the HFE program, and the outputs from the HFE program to other plant design activities). The applicant should also discuss the iterative aspects of the HFE design process. (4) HFE Program Milestones - The applicant should identify HFE milestones that Section 4.4, All show the relationship of the elements of the HFE program to the integrated plant design, development, and licensing schedule. A relative program schedule of HFE tasks should be available for the NRC staffs review showing relationships between the HFE elements and the activities, products, and reviews. Additional Information: A milestone might include, for example, the date when a simulator will be available for integrated system validation and operator training. HFE Documentation - The applicant should identify the HFE documentation items, Section 4.5, All such as RSRs and their supporting materials, and briefly describe them, along with the procedures for their retention and for making them available to the NRC staff for review. Subcontractor HFE Efforts - The applicant should include HFE requirements in each Section 4.6, All subcontract contributing to the HFE program. The applicant should periodically verify the subcontractor's compliance with HFE requirements. The HFE plan should describe milestones and the methods used for this verification. 2.4.4 Tracking HFE Issues Section 5.1, All (1) Availability - The applicant should have a tracking system to address human factors issues that are: known to the industry (defined in the Operating Experience Review element, see Section 3) identified throughout the life cycle of the HFE aspects of design, development, and evaluation deemed by the HFE program as human engineering discrepancies (HEDs) (see Section 11.4.4) Additional Information: Issues are those items that need to be addressed later, and hence must be tracked to assure that they are not overlooked. Establishing a new system to track HFE issues independent from the rest of the design effort is unnecessary; rather, an existing one can be adapted for this purpose (such as a plant's corrective-action program). (2) Method - The applicants method should: Section 5.2, All establish criteria for when issues are entered into the system track issues until the potential for negative effects on human performance is reduced to an acceptable level. © Copyright 2019 by NuScale Power, LLC 37

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 HFE PMP Review Criteria Section No. and paragraph (3) Documentation - The applicant should document the actions taken to Section 5.3, All address each issue in the system; if no action is required, this should be justified. Additional Information: The description of the final resolution of the issue should be sufficiently detailed so that a third party can understand how it was resolved. (4) Responsibility - After identifying an issue, the applicants tracking procedures Section 5.4, All should describe individual responsibilities for logging, tracking, and resolving it, along with the acceptance of the outcome. 2.4.5 Technical Program Section 6.0, All (1) The applicant should describe the applicability and status of each of the following HFE elements: Operating Experience Review Section 6.1 Functional Requirements Analysis and Function Allocation Section 6.2 Task Analysis Section 6.3 Staffing and Qualifications Section 6.4 Treatment of Important Human Actions Section 6.5 HSI Design Section 6.6 Procedure Development (Described in SRP, Chapter 13 submittal) Section 6.7 Training Program Development (Described SRP, Chapter 13 submittal) Section 6.8 Human Factors Verification and Validation Section 6.9 Design Implementation Section 6.10 Human Performance Monitoring Section 6.11 Additional Information: The applicant should identify each applicable element of the HFE program. If the applicant determines that an HFE element is not applicable to the HFE program, the applicant should give a rationale. For example, if an applicants HFE program involves modifying a control room HSI wherein the level of automation is not affected, then the Functional Requirements Analysis and Function Allocation element might not be included. The applicant should describe the status of each element in the HFE plan (i.e., will the element be enacted in the future, is it currently being performed, or is it completed). The applicant should clearly identify the use of past analyses that the NRC has not reviewed (i.e., analyses originally undertaken for another design) and justify their use in the current application. The criteria for the technical review of each element in the HFE program are presented in Sections 3 to 13 of this document. (2) The applicant should identify the approximate schedule for completing any Table 4-1 HFE activities that are unfinished at the time of the application. Additional Information: For example, if an applicant for design certification has not finished V&V, the applicant should give an approximate schedule for its completion. See Referenced (3) The applicants plan should identify and describe the standards and Documents, specifications that are sources of the HFE requirements. Section 8.2 (4) The applicants plan should specify HFE facilities, equipment, tools, and Section 4.2, techniques (such as laboratories, simulators, rapid prototyping software) that the HFE Associated IPs program will employ. and RSRs © Copyright 2019 by NuScale Power, LLC 38

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 HFE PMP Review Criteria Section No. and paragraph (5) Additional Considerations for Reviewing the HFE Aspects of Plant Not applicable for Modifications - The applicant should provide assurance that a modification to the DCA submittal control room or a change to risk-important human actions does not compromise HFE Program defense in depth in accordance with RG 1.174. The applicant should assure the following important aspects of defense in depth: A reasonable balance is preserved among prevention of core damage, prevention of containment failure, and consequence mitigation. There is no over-reliance on programmatic activities to compensate for weaknesses in plant design. This may be pertinent to changes in credited human actions (HAs). System redundancy, independence, and diversity are preserved commensurate with the expected frequency, consequences of challenges to the system, and uncertainties (e.g., no risk outliers). Defenses against potential common cause failures are preserved, and the potential for the introduction of new common cause failure mechanisms is assessed. Caution should be exercised in crediting new HAs to verify that the possibility of significant common cause errors is not created. Independence of barriers is not degraded. Defenses against human errors are preserved. For example, establish procedures for a second check or independent verification for risk-important HAs to determine that they have been performed correctly. The intent of the General Design Criteria (GDC) in Appendix A to 10 CFR Part 50 is maintained. GDC that may be relevant are: 3 - Fire Protection 13 - Instrumentation and Control 17 - Electric Power Systems 19 - Control Room 34 - Residual Heat Removal 35 - Emergency Core Cooling System 38 - Containment Heat Removal 44 - Cooling Water Safety margins often used in deterministic analyses to account for uncertainty and provide an added margin to provide adequate assurance that the various limits or criteria important to safety are not violated. Such safety margins are typically not related to HAs, but the reviewer should take note to see if there are any that may apply to the particular case under review. It is also possible to add a safety margin (if desired) to the HA by demonstrating that the action can be performed within some time interval (or margin) that is less than the time identified by the analysis. Additional Information: Defense in depth, described in RG 1.174, is one of the fundamental principles upon which a plant is designed and built. It uses multiple means to assure safety functions and to prevent the release of radioactive materials. Defense in depth is important in accounting for uncertainties in equipment and human performance, and for ensuring some protection remains, even in the face of significant breakdowns in particular areas, such as safety systems, training, and quality assurance. Whereas an applicant may change a specific defense in depth strategy, defense in depth must be maintained overall. These types of defense in depth evaluations may be done as part of the 10 CFR 50.59 evaluation for modifying the plant. © Copyright 2019 by NuScale Power, LLC 39

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 8.0 References 8.1 Source Documents 8.1.1 U.S. Nuclear Regulatory Commission, Human Factors Engineering Program Review Model, NUREG-0711, Rev. 3, November 2012. 8.1.2 U.S. Nuclear Regulatory Commission, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition - Human Factors Engineering (NUREG-0800, Chapter 18), Revision 3, March 2007. 8.2 Referenced Documents 8.2.1 U.S. Code of Federal Regulations, Contents of Applications; Technical Information, Section 50.34(f)(2)(iii), Part 50, Chapter I, Title 10, Energy, (10 CFR 50.34(f)(2)(iii)). 8.2.2 U.S. Code of Federal Regulations, Contents of Applications; Technical Information, Section 52.47(a)(8), Part 52, Chapter I, Title 10, Energy, (10 CFR 52.47(a)(8)). 8.2.3 U.S. Code of Federal Regulations, Training and Qualifications of Nuclear Power Plant Personnel, Section 50.120, Part 50, Chapter 1, Title 10 Energy, (10 CFR 50.120). 8.2.4 U.S. Code of Federal Regulations, Operators Licenses, Part 55, Chapter I, Title 10, Energy, (10 CFR 55). 8.2.5 NuScale Power, LLC, NuScale Quality Management Plan, PL-0202-10360. 8.2.6 NuScale Power, LLC, NuScale Design Control, NP-QP-0302-001. 8.2.7 U.S. Nuclear Regulatory Commission, Human Factors Engineering (HFE) Insights for Advanced Reactors Based Upon Operating Experience, NUREG/CR-6400, January 1997. 8.2.8 NuScale Power, LLC, Human Factors Engineering Operating Experience Review Results Summary Report, RP-0316-17614. 8.2.9 NuScale Power, LLC, Human Factors Engineering Functional Requirements Analysis and Function Allocation Results Summary Report, RP-0316-17615. 8.2.10 NuScale Power, LLC, Human Factors Engineering Task Analysis Results Summary Report, RP-0316-17616. 8.2.11 NuScale Power, LLC, Human Factors Engineering Staffing and Qualifications Results Summary Report, RP-0316-17617. © Copyright 2019 by NuScale Power, LLC 40

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 8.2.12 NuScale Power, LLC, Human Factors Engineering Treatment of Important Human Actions Results Summary Report, RP-0316-17618. 8.2.13 NuScale Power, LLC, Human-System Interface Design Results Summary Report, RP-0316-17619. 8.2.14 Table, HFE Documents for the NuScale DCD (sic) Application, U.S. Nuclear Regulatory Commission, April 11, 2016, Agencywide Documents Access and Management System Accession Number ML16034A181. 8.2.15 NuScale Power, LLC, Human Factors Verification and Validation Implementation Plan, RP-0914-8544. © Copyright 2019 by NuScale Power, LLC 41

Human Factors Engineering Program Management Plan RP-0914-8534-NP Rev. 5 Appendix A. NuScale HFE Program Design Integration As illustrated in Figure A-1, the HFE team is integrated into the iterative design process through the design review process. ((

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LO-0219-64511 : Affidavit of Thomas A. Bergman, AF-0219-64512 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com

NuScale Power, LLC AFFIDAVIT of Thomas A. Bergman I, Thomas A. Bergman, state as follows: (1) I am the Vice President of 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 competitors 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 NuScales competitive position and foreclose or reduce the availability of profit-making opportunities. The accompanying report reveals distinguishing aspects about the method by which NuScale develops its human factors engineering program management plan. 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. (4) The information sought to be withheld is in the enclosed report entitled "Human Factors Engineering Program Management Plan," RP-0914-8534-P, Revision 5. 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 AF-0219-64512 Page 1 of 2

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 Nu Scale, 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 Nu Scale 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 April 29, 2019 AF-0219-6451 2 Page 2 of 2}}

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