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Public Meeting - NuScale Incorporated by Reference (Ibr) Slides
	ML19340B591
Person / Time
Site:	NuScale
Issue date:	12/06/2019
From:	; NuScale
To:	; NRC/NRR/DNRL
	Chowdhury P / 415-1647
References
	Download: ML19340B591 (12)
	v • d • e

NuScale Nonproprietary Incorporated by Reference (IBR)

Public Meeting December 9, 2019 1

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Purpose To achieve alignment on implementation of Incorporated by Reference in NuScale FSAR.

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Introduction

NuScale seeks to reduce the amount of reports that are incorporated by reference by the DCA.

NuScale believes it will also benefit the Rulemaking process and burden.

Two separate but related concepts at issue:

- Reducing amount of reports incorporated by reference in the DCD* (DCD-IBR), and

- Reducing the amount of reports approved for incorporation by reference by the Office of Federal Register (OFR-IBR).

Note: For simplicity, use of term DCD herein refers to the Generic DCD as traditionally defined (Tier 1, Tier 2, and Generic Tech Specs) 3 PM-MMYY-XXXX-P Revision: Copyright 2019 by NuScale Power, LLC.

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Scope of IBR

- DCD-IBR:

Used by applicants to incorporate reports into the DCD; equivalent to including directly in the DCD. For NuScale listed in Tier 2 Tables 1.6-1 and 1.6-2.

Traditionally used in Part 50 applications to adopt approved Topical Reports.

Additional function is to incorporate SUNSI and SGI that cannot be included in the DCD directly.

Afforded issue resolution and finality by the DC Rule. Becomes necessary for a COL applicant to include or IBR the same reports.

- OFR-IBR:

A subset of DCD-IBR: public reports that are DCD-IBR.

Formally approved for IBR by the OFR. Directly included in the scope the DC rule in the same manner as the DCD itself.

First used in the ESBWR DC:

>> ESBWR DCD Rev. 10 includes 70 reports that are DCD-IBR (Tables 1.6-1 and 1.6-2) and 48 reports that are additional references (Table 1.6-3).

>> 20 of the DCD-IBR reports are public documents and were approved for IBR by the OFR, in addition to the DCD itself.

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Reducing IBR

- DCD-IBR:

Primarily SUNSI/SGI reports (including nonprop versions of proprietary reports).

Problem: may expand licensing basis beyond what is intended or necessary; potential burden on NuScale and COL applicants/licensees.

- OFR-IBR:

Subset of DCD-IBR: Fully public documents that are IBRd for expediency.

Problem: for clarity to NRC and third parties, these reports should be references only (pre-ESBWR approach).

- First flowchart shared with NRC (Slide 6) aimed at what could be done to reduce DCD-IBR. Included some implicit assumptions that reflected that purpose.

- New flowchart (Slide 7) attempts to simplify DCD-IBR and OFR-IBR issues, and recognizes feasibility of DCA/SER changes at this stage.

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Original IBR logic 6

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Simplified IBR logic Is information in the report Are the requirements intended as a requirement? severable from the report?

Necessary to meet 10CFR52.47 YES

Can be readily distinguished required information AND from non-requirement

Forward-looking: necessary for a information COL applicant to comply with Potential SDA improvements YES Can the requirements be NO captured in the DCD* directly?

Are the requirements

Information intended as requirements is not SUNSI/SGI, already captured in DCD?

and

I.e., the information intended

Its practical to reproduce directly as requirements is in DCD.

NO redundant to equivalent Is the full report public?

information in the DCD

Not SUNSI or SGI NO YES

E.g., there arent separate Prop and Nonprop versions YES Incorporate requirements in DCD, corresponding NO YES changes to SER.

Report becomes a reference only.

Report is incorporated by Report is a reference Report IBRd in the reference in the DCD only (additional DCD and will be (Prop and NP versions); *DCD isnt a term applicable to the information that approved for IBR by SDA, but it is used for simplicity here.

accorded issue resolution supports DCD) the OFR and finality by DC Rule 7

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Simplifying Table 1.6-1-Topical Reports Topical Report FSAR FSAR Changes Topical Report Title IBR disposition Notes SER Ref.

Number Section (beyond §1.6 tables)

NP-TR-1010-859- NuScale Topical Report: Maintain as DCD-IBR; Nonproprietary document. Includes forward-looking requirements for None.

NP, Rev 4 Quality Assurance 17 Will be OFR-IBR. future QA.

Program Description for the NuScale Power Plant TR-0515-13952- Risk Significance 17, 19 Delete from IBR; Nonproprietary document. Provides methodology that is required for None. Ch. 17 A, Rev 0 Determination FSAR but no forward-looking requirements.

Maintain as reference.

§17.4 uses as methodology reference.

Table 19.1-19: Criteria for Risk Significance provides the criteria. TR-0515-13952-A is a reference.

TR-0815-16497- Safety Classification of 8, 15 Delete from IBR; Proprietary report with necessary information for safety evaluation in None. Ch. 5, P-A, Rev 1 Passive Nuclear Power FSAR Maintain as reference. Ch. 6, Plant Electrical Systems

§8.3 references the methodology provided in the TR.

Ch. 8, Part 7 and SER reference to support GDC 17, 18 exemptions.

Ch. 13, Ch. 15 TR-1015-18653- Design of the Highly 7, 15 Maintain as DCD-IBR; Proprietary report (nonproprietary version provided). The TR provides None Ch. 7, P-A, Rev 2 Integrated Protection non-severable requirements for system design:

Will not be OFR-IBR. Ch. 16 System Platform Topical §7.0.4.1 points to the TR for design detail (The MPS is built on Report the highly integrated protection system platform (See TR-1015-18653-P-A),

§7.1.1 states The safety-related module protection system (MPS) uses the highly integrated protection system (HIPS) platform described in topical report NuScale Power, LLC, TR-1015-18653-P-A,

§7.2.15.3 states More detail on the MPS diagnostics functions are provided in TR-1015-18653-P-A.

Other uses:

§15.8 lists as a reference Part 4 (B.3.3) lists as validation source Part 7 reference to support 10 CFR 50.62(c)(1) ATWS exemption.

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Simplifying Table 1.6-2-Technical Reports Report Technical Report FSAR IBR disposition Notes FSAR Changes SER Ref.

Number Title Section TR-0716- Comprehensive 3.9, 14.2 Maintain as DCD-IBR; Proprietary report. The TR provides forward-looking requirements, e.g., None Ch. 3, 50439 Vibration Assessment Ch. 4, Will not be OFR-IBR. §14.2.3.3 The program is implemented consistent with the requirements of TR-0716-50439, Program (CVAP)

Ch. 5 Technical Report TR- §14.2.11 Vibration testing is performed in accordance to the requirements of the NuScale CVAP as described 0716-50439 in TR-0716-50439 Also: §13.9 COL Item 3.9-10: The methodology contained in.TR-0716-50439 is acceptable.

TR-0816- Fuel Storage Rack 3.7, 3.8, Maintain as DCD-IBR; Proprietary report. The TR provides forward-looking requirements specified in §9.1.2: A COL applicant will provide a None Ch. 9 49833 Analysis 9.1 neutron absorber material qualification report which demonstrates that the neutron absorber material can meet the Will not be OFR-IBR.

neutron attenuation and environmental compatibility design functions described in Technical Report TR-0816-49833.

Also:

§3.7.3: The design of the racks is discussed in Section 9.1.2 and the details of the seismic analysis are provided in technical report"§3.8.4: The fuel storage racks are described in Section 9.1 and Technical Report.

§9.1.5: Uses as a validation source (i.e., RH margin)

§9.1.3: The maximum keff remains below the applicable limits in the regulations and no abnormal condition would cause an inadvertent criticality

Table 3.7.2-35 uses as reference TR-0816- Loss of Large Areas 20.2 Delete from IBR; None Proprietary report. LOLA requirements defined by regulation and design features described in FSAR. Report provides 50796 Due to Explosions and Maintain as reference. details of evaluation that was performed but doesnt contain forward-looking requirements.

Fires Assessment

§20.2: TR-0816-50796documentsresponse to a LOLA event using the guidance in.NEI 06-12 defines LOLA criteria and identifies the design features that meet those criteria and COL applicant requirements COL Item 20.2-1: A COL applicant that references the NuScale Power Plant design certification will develop enhanced firefighting capabilities in accordance with 10 CFR 50.155(b)(2). The enhanced firefighting capabilities should address the expectation elements listed in Section 4.1.3 of the Technical Report TR-0816-50796 (Reference 20.2-1).

COL Item 20.2-2: A COL applicant that references the NuScale Power Plant design certification will provide a means for water spray scrubbing using fog nozzles and the availability of water sources, and address runoff water containment issues (sandbags, portable dikes, etc.) as an attenuation measure for mitigating radiation releases outside containment.

RP-0914- Human Factors 18.11 Maintain as DCD-IBR; Non-proprietary report: None Ch. 18 8544 Engineering Design Will be OFR-IBR.

Contains the requirements that a COL must meet to verify conformance of the as-built design to the planned design.

Implementation Implementation Plan

Describes how ownership of the HFE program is transferred from NuScale to a licensee and what actions a licensee must complete in order to close the HFE ITAAC.

RP-1215- Control Room Staffing 18.5 Delete from IBR; Proprietary report: None Ch. 18 20253 Plan Validation Maintain as reference.

Provides a systematic method to perform staffing validations and testing with focus on high workload situations Methodology

Describes the methodology used to evaluate licensed operator workload in a control room environment

A workload assessment will verify the physical and cognitive demands associated with operating a 12-unit facility with the staffing plan to ensure that the staff workload is within limits.

ES-0304- Human-System 18.10 Maintain as DCD-IBR; Proprietary report: None Ch. 18 9

1381 Interface Style Guide Will not be in OFR-IBR. Ensures the implementation of human factors engineering and human system interface principles in the PM-MMYY-XXXX-P development of user interface display pages, work locations, and work stations.

Documents all of the information, requirements, and functional specifications of the human system interface.Template #: 0000-21727-F01 R5

Interpretations of Tables 1.6-1, 1.6-2

Is use in a DCA part other than Part 2 a reason for IBR?

- Yes, e.g., Part 4 (Tech Specs); Part 7 (Exemptions) cannot be.

Is reference in RAI response, by itself, a reason for IBR?

- No. Only reports with information intended as requirements will be IBR.

Does SER statement referencing report as supporting a safety finding require in FSAR 1.6 tables?

- No. Only reports with information intended as requirements will be IBR.

Does an SER statement that report is IBR require inclusion in FSAR 1.6 tables?

- No, although SER wording may need to be revised.

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Implementation

Actions to get to agreement on what can be removed from NuScale FSAR IBR content

Timeline for DCA update

Implications for SER updates

Other thoughts or questions?

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Portland Office Richland Office 6650 SW Redwood Lane, 1933 Jadwin Ave., Suite 130 Suite 210 Richland, WA 99354 Portland, OR 97224 541.360.0500 971.371.1592 Arlington Office Corvallis Office 2300 Clarendon Blvd., Suite 1110 1100 NE Circle Blvd., Suite 200 Arlington, VA 22201 Corvallis, OR 97330 541.360.0500 London Office 1st Floor Portland House Rockville Office Bressenden Place 11333 Woodglen Ave., Suite 205 London SW1E 5BH Rockville, MD 20852 United Kingdom 301.770.0472 +44 (0) 2079 321700 Charlotte Office 2815 Coliseum Centre Drive, Suite 230 Charlotte, NC 28217 980.349.4804 http://www.nuscalepower.com Twitter: @NuScale_Power 12 PM-MMYY-XXXX-P Revision: Copyright 2019 by NuScale Power, LLC.

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ML19340B591

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