ML18135A050

Hfe Audit Report (Jul 25-2017 - Feb 14-2018)

ML18135A050
Person / Time
Site:	NuScale
Issue date:	05/24/2018
From:	Demetrius Murray NRC/NRO/DNRL/LB1
To:	Samson Lee NRC/NRO/DNRL/LB1
Chowdhury P/415-1647
Shared Package
ML18135A049	List: ML18135A050
References
Download: ML18135A050 (5)

Text

May 24, 2018 MEMORANDUM TO: Samuel S. Lee, Chief Licensing Branch 1 Division of New Reactor Licensing Office of New Reactors FROM: Demetrius Murray, Project Manager /RA Prosanta Chowdhury for:/

Licensing Branch 1 Division of New Reactor Licensing Office of New Reactors

SUBJECT:

AUDIT REPORT

SUMMARY

FOR THE REGULATORY AUDIT OF NUSCALE POWER, LLC DESIGN CERTIFICATION APPLICATION HUMAN FACTOR ENGINEERING From July 25, 2017, through February 14, 2018, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a regulatory audit of NuScale Power, LLC (NuScale) Design Certification Application (DCA) Human Factors Engineering (HFE) Topics.

The purpose of the audit was to: (1) review non-docketed information related to verification and validation methods to evaluate conformance with regulatory guidance and (2) identify information that will require docketing to support the basis of the licensing or regulatory decision. The NRC staff conducted the audit at NuScales offices in Rockville, Maryland and also reviewed documents in the NuScale electronic reading room.

The NRC staffs audit plan, dated July 25, 2017, can be accessed via the NRCs Agencywide Documents Access and Management System under Accession No. ML17205A465. The NRC staff conducted the audit in accordance with the Office of New Reactors (NRO) Office Instruction NRO-REG-108, Regulatory Audits.

The objectives of the audit, based upon the purpose stated above, were met during or shortly after the audit. The enclosed report summarizes the NRC staffs activities and conclusions involving the audit.

Docket No.52-048

Enclosure:

1. Audit Summary Report CONTACT: Prosanta Chowdhury, NRO/DNRL 301-415-1947

ML18135A049 - Pkg *via Email NRO- 002 OFFICE NRO/DNRL/LB1: PM NRO/DNRL/LB1: LA NRO/DCIP/HOIB: BC NRO/DNRL/LB1: PM NAME DMurray* MMoore* LKent* PChowdhury*

DATE 05/10/2018 05/16/2018 05/14/2018 05/24/2018 U.S. NUCLEAR REGULATORY COMMISSION NUSCALE POWER, LLC DESIGN CERTIFICATION APPLICATION - HUMAN FACTORS ENGINEERING AUDIT

SUMMARY

REPORT Audit Team Members

• Lauren Kent

• Amy DAgostino

• Maurin Scheetz

• Brian Green Background and Audit Bases By letter dated December 31, 2016, NuScale submitted a design certification application (DCA) for review (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17013A229). The DCA includes Final Safety Analysis Report (FSAR) Tier 2, Chapter 18, Human Factors Engineering, which describes the human factors engineering (HFE) program for the NuScale Standard Design Power Plant (ADAMS Accession No. ML17013A289).

Consistent with NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, Chapter 18, Human Factors Engineering, the NRC staff is using the review criteria in NUREG-0711, Human Factors Engineering Program Review Model, Revision 3, to determine whether the NuScale design complies with HFE-related NRC regulatory requirements. The HFE Program Review Model described in NUREG-0711 consists of 12 elements (refer to Figure 1-1, Elements of the HFE programs review model, of NUREG-0711 for additional information).

The FSAR Tier 2, Section 18.0, Human Factors Engineering - Overview, states the NuScale HFE program incorporates accepted HFE standards and guidelines including the applicable guidance provided in NUREG-0711. NuScale submitted two types of technical reports to address the 12 elements in NUREG-0711, Implementation Plans and Results Summary Reports. NUREG-0711, Section 1.2.2, Review Elements, explains that implementation plans describe processes and methods for performing HFE activities and results summary reports describe the results of performing those activities.

NuScale submitted, Human Factors Verification and Validation Implementation Plan (V&V IP),

Revision 2, with the DCA. In a letter dated April 8, 2016, from Mr. Thomas Bergman, NuScale, Vice-President, Regulatory Affairs to Mr. Frank Akstulewicz, Director, Division of New Reactor Licensing, NRC (ADAMS Accession No. ML16099A270), NuScale stated that NuScale would submit the V&V Results Summary Report (RSR) prior to Phase 4 of the NRCs review of the NuScale DCA.

As described in NUREG-0711, Section 11.1, Background, a significant V&V activity is the integrated system validation (ISV) test. The V&V IP, Section 4.6, Test Design, says, Upon approval, the ISV scenarios and test plan will be available for review or audit by the NRC Enclosure

sufficiently before the conduct of ISV so that comments or concerns can be adequately addressed prior to commencing ISV.

In May 2017, the NRC staff conducted an audit consistent with the audit plan dated April 25, 2017 (ADAMS Accession No. ML17110A254). The audit included a review of the ISV Test Plan and scenario bases documents to verify the V&V scenarios and ISV test methods conform to selected review criteria in NUREG-0711, Section 11.4, Review Criteria. The results of the audit are documented in the audit summary report dated July 17, 2017 (ADAMS Accession No. ML17181A415).

Audit Activities The NRC staff commenced a follow-up audit on July 24, 2017 as discussed in the audit plan dated July 25, 2017 (ADAMS Accession No. ML17205A465). The objective of the audit was to verify the V&V methodology conforms to the review criteria in NUREG-0711, Section 11.4, that was not assessed as part of the previous audit and to identify information that will require docketing to support the basis of the licensing or regulatory decision. This objective is identified as Objective 1 in the audit plan. The audit plan includes Objectives 2, 3, 4, and 5, which were not assessed during this audit because the NRC staff determined they could be verified during subsequent audit(s) that will be more appropriately timed to coincide with the activities discussed in the response from NuScale to the NRC staffs request for additional information (RAI) 9123, Question 18-12 (ADAMS Accession No. ML18002A554).

The NRC staff reviewed the following documents in NuScales Electronic Reading Room (ERR):

• The V&V IP, Revision 4,

• Integrated Systems Validation Test Plan, Revision 0,

• ISV Scenario Basis Documents, Original Revision,

• Human System Interface Design and Validation Process, Revision 1, and

• Design verification test plan, Original Revision.

Additionally, the NRC staff held discussions with the NuScale staff1 about the proposed V&V methods and the scope of information to be included in the application.

Audit Results The NRC staff began reviewing non-docketed information on July 24, 2017, via NuScales ERR and concluded the audit on February 14, 2018. The NRC staff issued the following RAIs as a result of this audit: RAI Nos. 8805, 9394, 9371, 9395, 9396, 9397, 9398, 9399, and 9414.

Conclusion The NRC staff conducted an audit exit call with NuScale staff on February 14, 2018. The NRC 1

The NuScale staff members who participated in substantive conversations include Timothy Tovar, Manager, Plant Operations; Doug Bowman, Supervisor, Plant Operations; and Ryan Flamand, Operations Engineer.

2

staff stated they were able to accomplish the audit objective, and was able to identify areas where RAIs were warranted.

3