ML20296A161

SDA-720 - Request for Additional Information No. 0001 (Erai No. 9789)

ML20296A161
Person / Time
Site:	99902078
Issue date:	10/21/2020
From:	NRC
To:	NRC/NRR/DNRL/NRLB
References
Download: ML20296A161 (13)

Text

From:

Tesfaye, Getachew Sent:

Wednesday, October 21, 2020 8:33 PM To:

RAI@nuscalepower.com Cc:

Dudek, Michael; Scheetz, Maurin; Nist, Lauren; Seymour, Jesse; Green, Brian; Cowdrey, Christian; NuScale-SDA-720RAIsPEm Resource

Subject:

Request for Additional Information No. 0001 (eRAI No. 9789)

Attachments:

Request for Additional Information No. 0001 (eRAI No. 9789).pdf Attached please find NRC staffs request for additional information (RAI) concerning the review of Licensing Topical Report TR-0420-69456, Revision 0, "NuScale Control Room Staffing Plan" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20163A556).

Please submit your technically correct and complete response by the agreed upon date to the NRC Document Control Desk.

If you have any questions, please do not hesitate to contact me.

Thank you.

Getachew Tesfaye, Senior Project Manager New Reactor Licensing Branch (NRLB)

Division of New and Renewed Licenses (DNRL)

Office of Nuclear Reactor Regulation (NRR)

U.S. Nuclear Regulatory Commission 301-415-8013

Hearing Identifier:

NuScale_SDA720_RAI_Public Email Number:

2 Mail Envelope Properties (MN2PR09MB4924DF93476B5384BFC106908C1D0)

Subject:

Request for Additional Information No. 0001 (eRAI No. 9789)

Sent Date:

10/21/2020 8:33:00 PM Received Date:

10/21/2020 8:33:04 PM From:

Tesfaye, Getachew Created By:

Getachew.Tesfaye@nrc.gov Recipients:

"Dudek, Michael" <Michael.Dudek@nrc.gov>

Tracking Status: None "Scheetz, Maurin" <Maurin.Scheetz@nrc.gov>

Tracking Status: None "Nist, Lauren" <lauren.nist@nrc.gov>

Tracking Status: None "Seymour, Jesse" <Jesse.Seymour@nrc.gov>

Tracking Status: None "Green, Brian" <Brian.Green@nrc.gov>

Tracking Status: None "Cowdrey, Christian" <Christian.Cowdrey@nrc.gov>

Tracking Status: None "NuScale-SDA-720RAIsPEm Resource" <NuScale-SDA-720RAIsPEm.Resource@nrc.gov>

Tracking Status: None "RAI@nuscalepower.com" <RAI@nuscalepower.com>

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MN2PR09MB4924.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 730 10/21/2020 8:33:04 PM Request for Additional Information No. 0001 (eRAI No. 9789).pdf 242254 Options Priority:

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Request for Additional Information No. 0001 (eRAI No. 9789)

Issue Date: 10/21/2020 Application

Title:

Pre-Application Activities for NuScale SDA Application Operating Company: NuScale Docket No. 99902078 Review Section: NTR - NuScale Topical Report for SDA 720 Application Section: TR-0420-69456, Revision 0 QUESTIONS NTR-1 Background and Regulatory basis:

By letter dated June 11, 2020, NuScale Power, LLC (NuScale) submitted licensing topical report TR-0420-69456, Revision 0, "NuScale Control Room Staffing Plan" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20163A556), for NRC review and approval. The topical report is designed to be used by a NuScale licensee to support exemption requests from the staffing requirements in 10 CFR 50.54(m) or other alternative control room staffing regulations, such as those included in the NuScale design certification rule, and from the requirement in 10 CFR 50.120(b)(2)(iii) to provide training and qualifications for the STA.

The NRC staff reviews such exemption requests and must determine whether the staffing proposals provide adequate assurance that public health and safety will be maintained at a level that is comparable to that afforded by compliance with the current regulations. NUREG-1791, "Guidance for Assessing Exemption Requests from the Nuclear Power Plant Licensed Operator Staffing Requirements Specified in 10 CFR 50.54(m)," provides a process for systematically reviewing and assessing alternatives to licensed operator staffing requirements. NUREG-0711, "Human Factors Engineering Program Review Model," contains guidance the staff uses to evaluate the methodology and results of human factors and staffing plan validation testing.

On August 17-27, 2020, the staff conducted a regulatory audit (audit plan ADAMS Accession No. ML20210M065) in support of the staff's review of the topical report. During the audit, the staff identified information that will require docketing to allow the staff to make conclusion on the whether the staffing proposal will adequately protect the public health and safety. Therefore, the NRC staff requests that NuScale provide additional information regarding the following topics.

Request for Additional Information:

The proposed revised minimum staffing level for a 12-module NuScale plant is shown in the topical report, Table 6-1, "Minimum Licensed Operator Staffing," as one licensed reactor operator and two licensed senior reactor operators. During the audit, the NRC staff discussed revisions that need to be made to the table and its notes in the topical report, Section 6.1, "Facility Staff," to improve clarity and ensure the plan can be implemented by a licensee.

1.

Please revise Table 6-1 to specify the number of units for which the staffing level applies (e.g., 1-12 units operated from one control room).

2.

Please revise Table 6-1 (e.g., in the title) to state that the staffing is onsite staffing.

NTR-2 Background and Regulatory basis:

By letter dated June 11, 2020, NuScale Power, LLC (NuScale) submitted licensing topical report TR-0420-69456, Revision 0, "NuScale Control Room Staffing Plan" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20163A556), for NRC review and approval. The topical report is designed to be used by a NuScale licensee to support exemption requests from the staffing requirements in 10 CFR 50.54(m) or other alternative control room staffing regulations, such as those included in the NuScale design certification rule, and from the requirement in 10 CFR 50.120(b)(2)(iii) to provide training and qualifications for the STA.

The NRC staff reviews such exemption requests and must determine whether the staffing proposals provide adequate assurance that public health and safety will be maintained at a level that is comparable to that afforded by compliance with the current regulations. NUREG-1791, "Guidance for Assessing Exemption Requests from the Nuclear Power Plant Licensed Operator Staffing Requirements Specified in 10 CFR 50.54(m)," provides a process for systematically reviewing and assessing alternatives to licensed operator staffing requirements. NUREG-0711, "Human Factors Engineering Program Review Model," contains guidance the staff uses to evaluate the methodology and results of human factors and staffing plan validation testing.

On August 17-27, 2020, the staff conducted a regulatory audit (audit plan ADAMS Accession No. ML20210M065) in support of the staff's review of the topical report. During the audit, the staff identified information that will require docketing to allow the staff to make conclusion on the whether the staffing proposal will adequately protect the public health and safety. Therefore, the NRC staff requests that NuScale provide additional information regarding the following topics. Request for Additional Information:

1.

Topical Report, Section 4.0, "Additional Staffing Considerations," states, "[t]he three-person crew staffing complement is intended to identify the minimum crew size to support safe plant operations. An additional requirement is added for at least two of the crew members to have senior operator licenses so that the CRS could leave while the second senior license holder remained in the control room." However, Table 6-1, Note b says, in part (underline added for emphasis), "A person holding a senior reactor operator license shall be in the control room complex at all times." Absent a definition of "control room complex," it is not clear whether Note b is consistent with the topical report, Section 4.0. Please either (1) revise Note b to delete "complex," or (2) provide a definition of "control room complex" and, if the complex includes area outside the control room, explain how control room supervisors at a NuScale plant could adhere to the guidance of Regulatory Guide (RG) 1.114 or why an alternative to RG 1.114 would be acceptable for a NuScale plant.

2.

Please clarify when the licensee is required to establish the staffing discussed in Note b (e.g., when any unit is fueled, a licensed reactor operator or senior operator shall be present at the controls at all times).

NTR-3 Background and Regulatory basis:

By letter dated June 11, 2020, NuScale Power, LLC (NuScale) submitted licensing topical report TR-0420-69456, Revision 0, "NuScale Control Room Staffing Plan" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20163A556), for NRC review and approval. The topical report is designed to be used by a NuScale licensee to support exemption requests from the staffing requirements in 10 CFR 50.54(m) or other alternative control room staffing regulations, such as those included in the NuScale design certification rule, and from the requirement in 10 CFR 50.120(b)(2)(iii) to provide training and qualifications for the STA.

The NRC staff reviews such exemption requests and must determine whether the staffing proposals provide adequate assurance that public health and safety will be maintained at a level that is comparable to that afforded by compliance with the current regulations. NUREG-1791, "Guidance for Assessing Exemption Requests from the Nuclear Power Plant Licensed Operator Staffing Requirements Specified in 10 CFR 50.54(m)," provides a process for systematically reviewing and assessing alternatives to licensed operator staffing requirements. NUREG-0711, "Human Factors Engineering Program Review Model," contains guidance the staff uses to evaluate the methodology and results of human factors and staffing plan validation testing.

On August 17-27, 2020, the staff conducted a regulatory audit (audit plan ADAMS Accession No. ML20210M065) in support of the staff's review of the topical report. During the audit, the staff identified information that will require docketing to allow the staff to make conclusion on the whether the staffing proposal will adequately protect the public health and safety. Therefore, the NRC staff requests that NuScale provide additional information regarding the following topics. Request for Additional Information:

The topical report, Section 4.0 Additional Staffing Considerations, states in part, "An additional senior license holder is required to support refueling operations." Table 6-1, Note d, states, "Each licensee shall have present, during alteration or movement of the core of a nuclear power unit (including fuel loading, fuel transfer, or movement of a module that contains fuel), a person holding a senior operator license or a senior operator license limited to fuel handling to directly supervise the activity and, during this time, the licensee shall not assign other duties to this person." Please revise Note d to clarify that the senior operator assigned to supervise alteration or movement of the core of a nuclear power unit is in addition to the two senior operators identified in Table 6-1.

NTR-4 Background and Regulatory basis:

By letter dated June 11, 2020, NuScale Power, LLC (NuScale) submitted licensing topical report TR-0420-69456, Revision 0, "NuScale Control Room Staffing Plan" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20163A556), for NRC review and approval. The topical report is designed to be used by a NuScale licensee to support exemption requests from the staffing requirements in 10 CFR 50.54(m) or other alternative control room staffing regulations, such as those included in the NuScale design certification rule, and from the requirement in 10 CFR 50.120(b)(2)(iii) to provide training and qualifications for the STA.

The NRC staff reviews such exemption requests and must determine whether the staffing proposals provide adequate assurance that public health and safety will be maintained at a level that is comparable to that afforded by compliance with the current regulations. NUREG-1791, "Guidance for Assessing Exemption Requests from the Nuclear Power Plant Licensed Operator Staffing Requirements Specified in 10 CFR 50.54(m)," provides a process for systematically reviewing and assessing alternatives to licensed operator staffing requirements. NUREG-0711, "Human Factors Engineering Program Review Model," contains guidance the staff uses to evaluate the methodology and results of human factors and staffing plan validation testing.

On August 17-27, 2020, the staff conducted a regulatory audit (audit plan ADAMS Accession No. ML20210M065) in support of the staff's review of the topical report. During the audit, the staff identified information that will require docketing to allow the staff to make conclusion on the whether the staffing proposal will adequately protect the public health and safety. Therefore, the NRC staff requests that NuScale provide additional information regarding the following topics.

Request for Additional Information:

NUREG-1791, Section 2.0, lists the type of information that is considered part of the concept of operations. In addition to the number of personnel who will have plant monitoring and operational control responsibilities on each shift, it also includes their individual roles and responsibilities; the interaction of control personnel with automated systems; other mechanisms that enable or support control personnel responsibilities for monitoring, disturbance detection, situation assessment, response planning, response execution, and the management of transitions between automatic and manual control; the interactions of control personnel with each other and with people not directly responsible for the control and safe operation of the plant; and multi-unit operations. Although a major goal of a staffing plan validation test is to confirm that the proposed minimum number of licensed operators on each shift is acceptable, the other elements of the concept of operations are also validated and assessed during a staffing plan test since they govern the ways in which the operators perform their function to operate the plant safely. As such, the staff considers the other elements of the concept of operations to be an important element of the staffing plan.

Reference 8.2.10 in the references section of the topical report is, "Concept of Operations," RP-0215-10815, Revision 3. Revision 3 is for a crew of at least six licensed operators, and it is incorporated by reference in Tier 2 of the NuScale standard design certification document for the 600 MWe, 12 small modular reactor plant design. The information in Revision 3 about the roles and responsibilities of the six-person crew is not applicable to the revised staffing plan. During the August 2020 audit, the staff reviewed draft Revision 4 of the "Concept of Operations,"

which NuScale revised to account for changes to the concept of operations for the revised staffing plan.

Please either submit Revision 4 of the "Concept of Operations" document or revise the topical report to include the changes to the concept of operations for the revised staffing plan.

NTR-5 Background and Regulatory basis:

By letter dated June 11, 2020, NuScale Power, LLC (NuScale) submitted licensing topical report TR-0420-69456, Revision 0, "NuScale Control Room Staffing Plan" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20163A556), for NRC review and approval. The topical report is designed to be used by a NuScale licensee to support exemption requests from the staffing requirements in 10 CFR 50.54(m) or other alternative control room staffing regulations, such as those included in the NuScale design certification rule, and from the requirement in 10 CFR 50.120(b)(2)(iii) to provide training and qualifications for the STA.

The NRC staff reviews such exemption requests and must determine whether the staffing proposals provide adequate assurance that public health and safety will be maintained at a level that is comparable to that afforded by compliance with the current regulations. NUREG-1791, "Guidance for Assessing Exemption Requests from the Nuclear Power Plant Licensed Operator Staffing Requirements Specified in 10 CFR 50.54(m)," provides a process for systematically reviewing and assessing alternatives to licensed operator staffing requirements. NUREG-0711, "Human Factors Engineering Program Review Model," contains guidance the staff uses to evaluate the methodology and results of human factors and staffing plan validation testing.

On August 17-27, 2020, the staff conducted a regulatory audit (audit plan ADAMS Accession No. ML20210M065) in support of the staff's review of the topical report. During the audit, the staff identified information that will require docketing to allow the staff to make conclusion on the whether the staffing proposal will adequately protect the public health and safety. Therefore, the NRC staff requests that NuScale provide additional information regarding the following topics.

Request for Additional Information:

NuScale measured workload of the test participants during the revised staffing plan validation test using the NASA TLX methodology. When using NASA TLX method, it is acceptable to either apply weighting factors to the measurements or to not apply them. The topical report, Section 5.1, "Staffing Plan Validation Methodology Overview," refers to the "streamlined use" of workload weighting factors. Please clarify what is meant by "streamlined use" of weighting factors.

NTR-6 By letter dated June 11, 2020, NuScale Power, LLC (NuScale) submitted licensing topical report TR-0420-69456, Revision 0, "NuScale Control Room Staffing Plan" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20163A556), for NRC review and approval. The topical report is designed to be used by a NuScale licensee to support exemption requests from the staffing requirements in 10 CFR 50.54(m) or other alternative control room staffing regulations, such as those included in the NuScale design certification rule, and from the requirement in 10 CFR 50.120(b)(2)(iii) to provide training and qualifications for the STA.

The NRC staff reviews such exemption requests and must determine whether the staffing proposals provide adequate assurance that public health and safety will be maintained at a level that is comparable to that afforded by compliance with the current regulations. NUREG-1791, "Guidance for Assessing Exemption Requests from the Nuclear Power Plant Licensed Operator Staffing Requirements Specified in 10 CFR 50.54(m)," provides a process for systematically reviewing and assessing alternatives to licensed operator staffing requirements. NUREG-0711, "Human Factors Engineering Program Review Model," contains guidance the staff uses to evaluate the methodology and results of human factors and staffing plan validation testing.

On August 17-27, 2020, the staff conducted a regulatory audit (audit plan ADAMS Accession No. ML20210M065) in support of the staff's review of the topical report. During the audit, the staff identified information that will require docketing to allow the staff to make conclusion on the whether the staffing proposal will adequately protect the public health and safety. Therefore, the NRC staff requests that NuScale provide additional information regarding the following topics.

Request for Additional Information:

During the audit, the staff observed video recordings of the scenario trials. The staff noticed that at the beginning of all of the scenarios, all three operators were in the control room simulator. However, in accordance with Table 6-1, all three operators may not be in or near the control room at the same time. Please explain whether there is any impact on the results of the RSPV test by not simulating that one of the three crew members could be elsewhere onsite at the start of a potentially challenging, high workload situation.

NTR-7 Background and Regulatory basis:

By letter dated June 11, 2020, NuScale Power, LLC (NuScale) submitted licensing topical report TR-0420-69456, Revision 0, "NuScale Control Room Staffing Plan" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20163A556), for NRC review and approval. The topical report is designed to be used by a NuScale licensee to support exemption requests from the staffing requirements in 10 CFR 50.54(m) or other

alternative control room staffing regulations, such as those included in the NuScale design certification rule, and from the requirement in 10 CFR 50.120(b)(2)(iii) to provide training and qualifications for the STA.

The NRC staff reviews such exemption requests and must determine whether the staffing proposals provide adequate assurance that public health and safety will be maintained at a level that is comparable to that afforded by compliance with the current regulations. NUREG-1791, "Guidance for Assessing Exemption Requests from the Nuclear Power Plant Licensed Operator Staffing Requirements Specified in 10 CFR 50.54(m)," provides a process for systematically reviewing and assessing alternatives to licensed operator staffing requirements. NUREG-0711, "Human Factors Engineering Program Review Model," contains guidance the staff uses to evaluate the methodology and results of human factors and staffing plan validation testing.

On August 17-27, 2020, the staff conducted a regulatory audit (audit plan ADAMS Accession No. ML20210M065) in support of the staff's review of the topical report. During the audit, the staff identified information that will require docketing to allow the staff to make conclusion on the whether the staffing proposal will adequately protect the public health and safety. Therefore, the NRC staff requests that NuScale provide additional information regarding the following topics.

Request for Additional Information:

NUREG-1791, Section 3, "Review the Operational Conditions," says the staff reviews the operational conditions selected for the staffing plan validation to "ensure that the operational conditions which present the greatest potential challenges to the effective and safe performance of control personnel, under the conditions of the requested exemption, were analyzed by the applicant and support the exemption request." The topical report, Section 5.1, states, "There is reasonable assurance that the workload during each of the scenarios bounds the anticipated workload conditions." Please explain how the scenarios selected for the RSPV bound the anticipated workload conditions at a NuScale plant.

NTR-8 Background and Regulatory basis:

By letter dated June 11, 2020, NuScale Power, LLC (NuScale) submitted licensing topical report TR-0420-69456, Revision 0, "NuScale Control Room Staffing Plan" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20163A556), for NRC review and approval. The topical report is designed to be used by a NuScale licensee to support exemption requests from the staffing requirements in 10 CFR 50.54(m) or other alternative control room staffing regulations, such as those included in the NuScale design certification rule, and from the requirement in 10 CFR 50.120(b)(2)(iii) to provide training and qualifications for the STA.

The NRC staff reviews such exemption requests and must determine whether the staffing proposals provide adequate assurance that public health and safety will be maintained at a level that is comparable to that afforded by compliance with the current regulations. NUREG-1791, "Guidance for Assessing Exemption Requests from the Nuclear Power Plant Licensed Operator Staffing Requirements Specified in 10 CFR 50.54(m)," provides a process for systematically reviewing and assessing alternatives to licensed operator staffing requirements. NUREG-0711, "Human Factors Engineering Program Review Model," contains guidance the staff uses to evaluate the methodology and results of human factors and staffing plan validation testing.

On August 17-27, 2020, the staff conducted a regulatory audit (audit plan ADAMS Accession No. ML20210M065) in support of the staff's review of the topical report. During the audit, the staff identified information that will require docketing to allow the staff to make conclusion on the whether the staffing proposal will adequately protect the public health and safety. Therefore, the NRC staff requests that NuScale provide additional information regarding the following topics.

Request for Additional Information:

During the audit, the staff reviewed a list of scenario assumptions in the RSPV Test Report, Section 3.3. In some cases, these scenario assumptions provide limitations and constraints on the activities that may be assigned to the control room crew. The staff recognizes that it was necessary for NuScale to make staffing assumptions in the absence of a facility licensee, who will be responsible for finalizing the decisions addressed by the staffing assumptions, in order to perform the RSPV test.

The NRC staff also observed that the Conduct of Operations document, Revision 1, Section 3.11, includes a staffing assumption about availability of additional personnel. During the audit, the staff observed during some scenario trials that the control room supervisor/shift manager was heavily involved in phone communications, and the reactor operators were engaged in operations. During situations where multiple units are in a transient, and the reactor operators are engaged in tasks as directed by the plant procedures, the CRS will need to limit the amount of time he or she spends engaged in external communications to ensure he or she maintains the role of providing effective command and control of the shift activities. The staffing assumption in Section 3.11 of the Conduct of Operations document addresses a way for the CRS to manage external communications to ensure he or she can maintain the command and control function in the control room. Additionally, Section 4.0 of the Conduct of Operations document states an expectation for how long it will take the third operator to return to the control room if he or she is outside of the control room (and is still onsite).

Given the topical report is to be used by facility licensee applicants, the facility licensee should confirm that these assumptions remain accurate for its facility, and if not, it should describe the deviations and any impacts to the staffing plan.

1.

Please revise the topical report to include a summary of the scenario and staffing assumptions in Section 3.3 of the RSPV Test Report, Bullets 4 and 5, and Sections 3.11 and 4.0 of the Conduct of Operations document.

2.

Additionally, in the conditions of applicability section, add that a COL applicant will either verify these assumptions remain valid for its facility or identify and address impacts of any deviations.

NTR-9 Background and Regulatory basis:

By letter dated June 11, 2020, NuScale Power, LLC (NuScale) submitted licensing topical report TR-0420-69456, Revision 0, "NuScale Control Room Staffing Plan" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20163A556), for NRC review and approval. The topical report is designed to be used by a NuScale licensee to support exemption requests from the staffing requirements in 10 CFR 50.54(m) or other alternative control room staffing regulations, such as those included in the NuScale design certification rule, and from the requirement in 10 CFR 50.120(b)(2)(iii) to provide training and qualifications for the STA.

The NRC staff reviews such exemption requests and must determine whether the staffing proposals provide adequate assurance that public health and safety will be maintained at a level that is comparable to that afforded by compliance with the current regulations. NUREG-1791, "Guidance for Assessing Exemption Requests from the Nuclear Power Plant Licensed Operator Staffing Requirements Specified in 10 CFR 50.54(m)," provides a process for systematically reviewing and assessing alternatives to licensed operator staffing requirements. NUREG-0711, "Human Factors Engineering Program Review Model," contains guidance the staff uses to evaluate the methodology and results of human factors and staffing plan validation testing.

On August 17-27, 2020, the staff conducted a regulatory audit (audit plan ADAMS Accession No. ML20210M065) in support of the staff's review of the topical report. During the audit, the staff identified information that will require docketing to allow the staff to make conclusion on the whether the staffing proposal will adequately protect the public health and safety. Therefore, the NRC staff requests that NuScale provide additional information regarding the following topics.

Request for Additional Information:

NUREG-0711, Section 11.4.3.3(2) states that "[t]he testbed's HSIs and procedures should be represented with high physical fidelity to the reference design, including the presentation of alarms, displays, controls, job aids, procedures, communications equipment, interface management tools, layout, and spatial relationships." The staff previously assessed the simulator used for ISV and determined it had sufficient fidelity to the plant design for validation testing. The topical report, Section 5.3.3, states that participant training for the RSPV included classroom training on simulator differences from the ISV. During the audit, the staff reviewed two simulator release notes that document changes to the simulator that occurred following ISV. However, neither the topical report nor the test report discuss whether simulator changes that occurred between the ISV and RSPV were based on plant design changes and, furthermore, whether they improved the fidelity of the simulator to the as-designed HSI (e.g., whether the changes to the simulator following ISV were implemented to ensure the simulator reflected changes to the as-designed control room and HSI).

Additionally, during the audit, the staff reviewed the RSPV Test Report, which describes the simulator testing NuScale conducted prior to the RSPV test to validate the fidelity of the simulator to the plant design. The staff also reviewed documentation of simulator testing that was conducted to verify the scenarios used for the RSPV would perform as planned.

1.

Please revise the topical report to state that NuScale conducted simulator performance testing prior to the RSPV to verify the fidelity of the simulator to the plant design, the type of testing that was performed, and whether the results confirmed the simulator for RSPV had adequate fidelity to the as-designed MCR HSI.

2.

Please explain whether simulator changes that occurred between the ISV and RSPV were based on plant design changes and whether they improved the fidelity of the simulator to the as-designed HSI.

NTR-10 Background and Regulatory basis:

By letter dated June 11, 2020, NuScale Power, LLC (NuScale) submitted licensing topical report TR-0420-69456, Revision 0, "NuScale Control Room Staffing Plan" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20163A556), for NRC review and approval. The topical report is designed to be used by a NuScale licensee to support exemption requests from the staffing requirements in 10 CFR 50.54(m) or other alternative control room staffing regulations, such as those included in the NuScale design certification rule, and from the requirement in 10 CFR 50.120(b)(2)(iii) to provide training and qualifications for the STA.

The NRC staff reviews such exemption requests and must determine whether the staffing proposals provide adequate assurance that public health and safety will be maintained at a level that is comparable to that afforded by compliance with the current regulations. NUREG-1791, "Guidance for Assessing Exemption Requests from the Nuclear Power Plant Licensed Operator Staffing Requirements Specified in 10 CFR 50.54(m)," provides a process for systematically reviewing and assessing alternatives to licensed operator staffing requirements. NUREG-0711, "Human Factors Engineering Program Review Model," contains guidance the staff uses to evaluate the methodology and results of human factors and staffing plan validation testing.

On August 17-27, 2020, the staff conducted a regulatory audit (audit plan ADAMS Accession No. ML20210M065) in support of the staff's review of the topical report. During the audit, the staff identified information that will require docketing to allow the staff to make conclusion on the whether the staffing proposal will adequately protect the public health and safety. Therefore, the NRC staff requests that NuScale provide additional information regarding the following topics. Request for Additional Information:

The topical report, Section 1.5, contains the conditions of applicability that are associated with the topical report. This section of the topical report lists several features and states that "an applicant can show the proposed design complies with the conditions of applicability by performing an evaluation or demonstration of their design to these attributes." The staff understands NuScale intends to submit a standard design approval application for the NuScale 720MWe plant design. During the audit, NuScale explained that the simulator used for the RSPV test was based on the NuScale plant design as described in the design certification application (i.e., the 600MWe plant).

1.

Please provide the rationale for the conditions and limitations contained in the topical report and explain why additional conditions and limitations are not needed for COL applicants referencing the NuScale 720 standard design.

2.

Given the level of automation in the plant design helps minimize operator workload by performing more tasks, please explain why it was not listed with the other HSI design features listed in the topical report, Section 1.5, "Conditions of Applicability."

NTR-11 Background and Regulatory basis:

By letter dated June 11, 2020, NuScale Power, LLC (NuScale) submitted licensing topical report TR-0420-69456, Revision 0, "NuScale Control Room Staffing Plan" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20163A556), for NRC review and approval. The topical report is designed to be used by a NuScale licensee to support exemption requests from the staffing requirements in 10 CFR 50.54(m) or other alternative control room staffing regulations, such as those included in the NuScale design certification rule, and from the requirement in 10 CFR 50.120(b)(2)(iii) to provide training and qualifications for the STA.

The NRC staff reviews such exemption requests and must determine whether the staffing proposals provide adequate assurance that public health and safety will be maintained at a level that is comparable to that afforded by compliance with the current regulations. NUREG-1791, "Guidance for Assessing Exemption Requests from the Nuclear Power Plant Licensed Operator Staffing Requirements Specified in 10 CFR 50.54(m)," provides a process for systematically reviewing and assessing alternatives to licensed operator staffing requirements. NUREG-0711, "Human Factors Engineering Program Review Model," contains guidance the staff uses to evaluate the methodology and results of human factors and staffing plan validation testing.

On August 17-27, 2020, the staff conducted a regulatory audit (audit plan ADAMS Accession No. ML20210M065) in support of the staff's review of the topical report. During the audit, the staff identified information that will require docketing to allow the staff to make conclusion on the whether the staffing proposal will adequately protect the public health and safety. Therefore, the NRC staff requests that NuScale provide additional information regarding the following topics.

Request for Additional Information:

The topical report, Section 5.3.2, "Participants in Second Validation Trials," states that RSPV test participants were chosen based on previous experience as crew members during the ISV. NUREG-0711, Section 11.4.3.4, "Plant Personnel," says there should be variation in age, skill/experience, and qualifications among test personnel, and test participants should not be selected for specific characteristics, such as good performers. Also, test participants should not have access to the test scenarios prior to testing in order to avoid biasing the test results.

1.

Please explain the other criteria NuScale used to select the RSPV test participants in order to avoid selecting for specific characteristics such as good performance.

2.

Please state whether the test participants had access to the scenario contents prior to the RSPV test.

NTR-12 Background and Regulatory basis:

By letter dated June 11, 2020, NuScale Power, LLC (NuScale) submitted licensing topical report TR-0420-69456, Revision 0, "NuScale Control Room Staffing Plan" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20163A556), for NRC review and approval. The topical report is designed to be used by a NuScale licensee to support exemption requests from the staffing requirements in 10 CFR 50.54(m) or other alternative control room staffing regulations, such as those included in the NuScale design certification rule, and from the requirement in 10 CFR 50.120(b)(2)(iii) to provide training and qualifications for the STA.

The NRC staff reviews such exemption requests and must determine whether the staffing proposals provide adequate assurance that public health and safety will be maintained at a level that is comparable to that afforded by compliance with the current regulations. NUREG-1791, "Guidance for Assessing Exemption Requests from the Nuclear Power Plant Licensed Operator Staffing Requirements Specified in 10 CFR 50.54(m)," provides a process for systematically reviewing and assessing alternatives to licensed operator staffing requirements. NUREG-0711, "Human Factors Engineering Program Review Model," contains guidance the staff uses to evaluate the methodology and results of human factors and staffing plan validation testing.

On August 17-27, 2020, the staff conducted a regulatory audit (audit plan ADAMS Accession No. ML20210M065) in support of the staff's review of the topical report. During the audit, the staff identified information that will require docketing to allow the staff to make conclusion on the whether the staffing proposal will adequately protect the public health and safety. Therefore, the NRC staff requests that NuScale provide additional information regarding the following topics.

Request for Additional Information:

The topical report, Section 7.0, "Summary and Conclusions," states in part that "a preponderance of evidence shows that individuals, and the crew as a whole, experienced acceptable levels of workload." During the August 2020 audit, the staff reviewed the NASA TLX workload data for each crew member in each of the scenario trials. The staff also reviewed the results of the situation awareness questionnaires administered to each test participant.

Please revise the topical report to include the following:

1.

the range of the average workload for each crew member (i.e., lowest average workload and the highest average workload),

2.

the maximum workload measured during all trials and the reason(s) why the workload was high in the specific scenario(s),

3.

a statement about the situation awareness results as described in the RSPV Test Report, Section 10.2.2, "Situation Awareness."

NTR-13 Background and Regulatory basis:

By letter dated June 11, 2020, NuScale Power, LLC (NuScale) submitted licensing topical report TR-0420-69456, Revision 0, "NuScale Control Room Staffing Plan" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20163A556), for NRC review and approval. The topical report is designed to be used by a NuScale licensee to support exemption requests from the staffing requirements in 10 CFR 50.54(m) or other alternative control room staffing regulations, such as those included in the NuScale design certification rule, and from the requirement in 10 CFR 50.120(b)(2)(iii) to provide training and qualifications for the STA.

The NRC staff reviews such exemption requests and must determine whether the staffing proposals provide adequate assurance that public health and safety will be maintained at a level that is comparable to that afforded by compliance with the current regulations. NUREG-1791, "Guidance for Assessing Exemption Requests from the Nuclear Power Plant Licensed Operator Staffing Requirements Specified in 10 CFR 50.54(m)," provides a process for systematically reviewing and assessing alternatives to licensed operator staffing requirements. NUREG-0711, "Human Factors Engineering Program Review Model," contains guidance the staff uses to evaluate the methodology and results of human factors and staffing plan validation testing.

On August 17-27, 2020, the staff conducted a regulatory audit (audit plan ADAMS Accession No. ML20210M065) in support of the staff's review of the topical report. During the audit, the staff identified information that will require docketing to allow the staff to make conclusion on the whether the staffing proposal will adequately protect the public health and safety. Therefore, the NRC staff requests that NuScale provide additional information regarding the following topics. Request for Additional Information:

The RSPV Test Report, Appendix D, says that a readiness assessment was performed prior to RSPV, which used the same scenarios from the 2016 SPV test and the RSPV test participants. It also says all acceptance criteria were met; these included criteria for successful task performance. During the August 2020 audit, NuScale explained that the readiness assessment used the same test protocol and data collection methods as the RSPV test. The scenario events are included in the SPV Results Technical Report, which is a document that can be accessed by NuScale employees. Thus, NuScale stated it could not guarantee that the RSPV test participants had not reviewed the scenarios prior to the readiness assessment. However, NuScale said it had a high level of confidence that the RSPV participants had not reviewed the scenarios. Although the reviewed documentation indicates that access to the readiness assessment scenarios were not controlled as strictly as the RSPV test scenarios prior to the readiness assessment, the NRC staff believe that there is some confidence that the participants did not have prior knowledge of the readiness assessment scenarios prior to the assessment. As such, reviewing this data provides the staff a reasonable "apples-to-apples" comparison between the SPV and the RSPV that provides support for NuScale's staffing plan.

Please include a description of the RSPV readiness assessment, including a summary of the task performance, workload and situation awareness results and how they compare to the results from the initial SPV test, and why it is unlikely that the test participants reviewed the scenario contents prior to the readiness assessment.

NTR-14 Background and Regulatory basis:

By letter dated June 11, 2020, NuScale Power, LLC (NuScale) submitted licensing topical report TR-0420-69456, Revision 0, "NuScale Control Room Staffing Plan" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20163A556), for NRC review and approval. The topical report is designed to be used by a NuScale licensee to support exemption requests from the staffing requirements in 10 CFR 50.54(m) or other alternative control room staffing regulations, such as those included in the NuScale design certification rule, and from the requirement in 10 CFR 50.120(b)(2)(iii) to provide training and qualifications for the STA.

The NRC staff reviews such exemption requests and must determine whether the staffing proposals provide adequate assurance that public health and safety will be maintained at a level that is comparable to that afforded by compliance with the current regulations. NUREG-1791, "Guidance for Assessing Exemption Requests from the Nuclear Power Plant Licensed Operator Staffing Requirements Specified in 10 CFR 50.54(m)," provides a process for systematically reviewing and assessing alternatives to licensed operator staffing requirements. NUREG-0711, "Human Factors Engineering Program Review Model," contains guidance the staff uses to evaluate the methodology and results of human factors and staffing plan validation testing.

On August 17-27, 2020, the staff conducted a regulatory audit (audit plan ADAMS Accession No. ML20210M065) in support of the staff's review of the topical report. During the audit, the staff identified information that will require docketing to allow the staff to make conclusion on the whether the staffing proposal will adequately protect the public health and safety. Therefore, the NRC staff requests that NuScale provide additional information regarding the following topics.

Request for Additional Information:

The topical report, Section 3.1, "Industry Upgrades to Qualifications of Shift Supervisors and Senior Operators,"

states, "Applicable engineering principles are now an integral part of any licensed operator training program." The topical report, Section 2.3, "Control Room Staff Level Based on Staffing and Qualification Analysis," also states, "Licensed operators are selected, trained, and qualified consistent with 'Guidelines for Initial Training and Qualification of Licensed Operators,' ACAD 10-001 (Reference 8.2.4)."

ACAD 10-001 is a proprietary document maintained by the Institute of Nuclear Power Operations (INPO) National Academy for Nuclear Training (NANT). Reference 8.2.4 is Revision 0, which has been superseded, and is expired. It is the facility licensee's responsibility to establish the training programs (i.e., training is an operational program and the development of the training program is a COL item). A facility licensee may not seek INPO/NANT accreditation, and therefore, may not have access to ACAD 10-001. Therefore, in addition to using a SAT-based process to develop the operator initial training program based on the tasks operators perform at the plant, the COL applicant should confirm that its initial training program does include the operator generic fundamentals that are relevant to operation of a NuScale power plant.

1.

Please revise the topical report to account for a facility licensee that may not use ACAD 10-001 and that the revision listed in Reference 8.2.4 is expired.

2.

Please revise the topical report to include a condition for the COL applicant's initial operator training program to be SAT-based and contain relevant generic fundamentals, including the math, physics, thermodynamics, and component design topics that are of specific relevance to the operation of a nuclear power plant.

NTR-15 Background and Regulatory basis:

By letter dated June 11, 2020, NuScale Power, LLC (NuScale) submitted licensing topical report TR-0420-69456, Revision 0, "NuScale Control Room Staffing Plan" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20163A556), for NRC review and approval. The topical report is designed to be used by a NuScale licensee to support exemption requests from the staffing requirements in 10 CFR 50.54(m) or other alternative control room staffing regulations, such as those included in the NuScale design certification rule, and from the requirement in 10 CFR 50.120(b)(2)(iii) to provide training and qualifications for the STA.

The NRC staff reviews such exemption requests and must determine whether the staffing proposals provide adequate assurance that public health and safety will be maintained at a level that is comparable to that afforded by compliance with the current regulations. NUREG-1791, "Guidance for Assessing Exemption Requests from the Nuclear Power Plant Licensed Operator Staffing Requirements Specified in 10 CFR 50.54(m)," provides a process for systematically reviewing and assessing alternatives to licensed operator staffing requirements. NUREG-0711, "Human Factors Engineering Program Review Model," contains guidance the staff uses to evaluate the methodology and results of human factors and staffing plan validation testing.

On August 17-27, 2020, the staff conducted a regulatory audit (audit plan ADAMS Accession No. ML20210M065) in support of the staff's review of the topical report. During the audit, the staff identified information that will require docketing to allow the staff to make conclusion on the whether the staffing proposal will adequately protect the public health and safety. Therefore, the NRC staff requests that NuScale provide additional information regarding the following topics.

Request for Additional Information:

The topical report, Executive Summary, states, "NUREG-0737 (Reference 8.1.6) states 'the need for the STA position may be eliminated when the qualification of the shift supervisors and senior operators have been upgraded and the man-machine interface in the control room has been acceptably upgraded.' These conditions have been met in the NuScale Power Plant, and the minimum operating crew of three operators does not include the STA role" Although the STA was initially intended to be an interim or short-term measure implemented following the accident at Three Mile Island, the Commission's Policy Statement on Engineering Expertise on Shift (50 FR 43621),

which was issued in October 1985 after NUREG-0737, states, "The STA has proven to be a worthwhile addition to the operating staff by providing an independent engineering and accident assessment capability, and we support continuation of this position."

NUREG-1791, Section 6.2, states that "[t]he task analysis data submitted in support of the exemption request should include the following, as applicable identification of tasks that may affect the roles, responsibilities, or qualifications for licensed control personnel." During the August 2020 audit, the staff reviewed the results of a task analysis that NuScale performed as part of assessment of eliminating the STA position. The task analysis listed all tasks that were previously assigned to the STA and how they have been dispositioned with the elimination of the STA.

During the audit, the staff observed that some tasks previously assigned to the STA that involve assisting and making recommendations to the CRS and/or SM about whether an emergency action level (EAL) has been exceeded and whether plant equipment included in Technical Specifications is operable were listed as having been consolidated with tasks assigned to the CRS position. In the revised staffing plan, the CRS and SM roles can be combined, and so the individual in the combined CRS/SM position cannot assist or make recommendations to him or herself. Additionally, the staff did not observe any HSI design features that provide recommendations to the CRS/SM that are comparable to an additional operator who has been trained on EALs and Technical Specifications. Ensuring equipment included in technical specifications is operable helps ensure important plant equipment will be available if needed in an emergency, and proper implementation of the emergency plan, including identification of the correct the correct EAL during an abnormal event, helps to protect public health and safety.

1.

In support of the proposal to eliminate the STA role, please revise the topical report to include a description of the task analysis NuScale conducted, including a summary of how NuScale dispositioned the tasks that were assigned to the STA, and NuScale's conclusions from the task analysis.

2.

Please explain why, when the CRS/SM position is combined, there is not a need for an additional individual who is trained on operability determinations and emergency action levels to provide independent assessment and advice to the CRS/SM.