ML17252B631

2017/09/09 Nuscale SMR DC RAI - Request for Additional Information No. 219, RAI 8998 (13.6.2)

ML17252B631
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Site:	NuScale
Issue date:	09/09/2017
From:	NRC
To:	NRC/NRO/DNRL/LB1
References
Download: ML17252B631 (20)

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NuScaleDCRaisPEm Resource From: Cranston, Gregory Sent: Saturday, September 09, 2017 5:35 PM To: RAI@nuscalepower.com Cc: NuScaleDCRaisPEm Resource; Lee, Samuel; Chowdhury, Prosanta; Rivera, Alison; Lee, Pete

Subject:

Request for Additional Information No. 219, RAI 8998 (13.6.2)

Attachments: Request for Additional Information No. 219 (eRAI No. 8998).pdf Attached please find NRC staffs request for additional information concerning review of the NuScale Design Certification Application.

Please submit your technically correct and complete response within 60 days of the date of this RAI to the NRC Document Control Desk.

If you have any questions, please contact me.

Thank you.

Gregory Cranston, Senior Project Manager Licensing Branch 1 (NuScale)

Division of New Reactor Licensing Office of New Reactors U.S. Nuclear Regulatory Commission 301-415-0546 1

Hearing Identifier: NuScale_SMR_DC_RAI_Public Email Number: 242 Mail Envelope Properties (4d22692f3e6c44eb9c00da8fa320438c)

Subject:

Request for Additional Information No. 219, RAI 8998 (13.6.2)

Sent Date: 9/9/2017 5:34:34 PM Received Date: 9/9/2017 5:34:41 PM From: Cranston, Gregory Created By: Gregory.Cranston@nrc.gov Recipients:

"NuScaleDCRaisPEm Resource" <NuScaleDCRaisPEm.Resource@nrc.gov>

Tracking Status: None "Lee, Samuel" <Samuel.Lee@nrc.gov>

Tracking Status: None "Chowdhury, Prosanta" <Prosanta.Chowdhury@nrc.gov>

Tracking Status: None "Rivera, Alison" <Alison.Rivera@nrc.gov>

Tracking Status: None "Lee, Pete" <Pete.Lee@nrc.gov>

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

Tracking Status: None Post Office: R4PWMSMRS04.nrc.gov Files Size Date & Time MESSAGE 561 9/9/2017 5:34:41 PM Request for Additional Information No. 219 (eRAI No. 8998).pdf 197765 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

Request for Additional Information No. 219 (eRAI No. 8998)

Issue Date: 09/09/2017 Application Title: NuScale Standard Design Certification 048 Operating Company: NuScale Power, LLC Docket No.52-048 Review Section: 13.06.02 - Physical Security - Design Certification Application Section: Tier 1 Sections 3.16 and Tier 2 Sections 13.6; Technical Report TR-0416-48929, NuScale Design of Physical Security Systems QUESTIONS 13.06.02-1 Design Certification Application (DCA), Final Safety Analysis Report (FSAR) Tier 2, Section 13.6.1, Physical Security, (Page 13.6-1) and TR-0416-48929, NuScale Design of Physical Security Systems, Revision 0 (Pages i through vi)

Regulatory Basis: Subpart B of 10 CFR 52, § 52.47, requires that information submitted for a design certification must include performance requirements and design information sufficiently detailed to permit the preparation of acceptance and inspection requirements by the NRC, and procurement specifications and construction and installation specifications by an applicant. Title 10 CFR 52.48 requires the applications filed will be reviewed for compliance with the standards set out in 10 CFR Part 73. Title 10 CFR 52.47(b)(1) requires that the application must contain proposed inspections, tests, analyses, and acceptance criteria that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance crite ria met, a facility that incorporates the design certification has been constructed and will be operated in conformity with the design certification, the provisions of the Act, and the Commission's rules and regulations. Title 10 CFR 52.6 requires information provided to the Commission by an applicant for a standard design certification shall be complete and accurate in all material respects.

In DCA, FSAR Tier 2, Section 13.6.1, the applicant states, in part: [the NuScale Power Plant physical security design provides the capabilities to detect, assess, impede, and delay threats up to and including the design basis threat, and to provide for defense-in-depth through the integration of systems, technologies, and equipment. The design of physical security systems within the nuclear island and structures is described in Technical Report TR-0416-48929 (Reference 13.6-1), which is incorporated by reference to this FSAR.

The TR-0416-48929 is currently labeled as Licensing Topical Report. A topical report is reviewed and results documented in a safety evaluation report that is separate from the DCA review. A technical report, on the other hand, can be incorporated by reference into an FSAR.

The staff requests that the applicant revise the identification of TR-0416-48929 from Licensing Topical Report to Technical Report as indicated in DCA, FSAR Tier 2, Section 13.6.1.

13.06.02-2 TR-0416-48929, Section 3, Security by Design, Items No. 1, No. 3, and No. 8 (Pages 5 through 7) and Section 7, Figure 7 (Page 56) and Figure 8 (Page 57)

Regulatory Basis: Subpart B of 10 CFR 52, § 52.47, requires that information submitted for a design certification must include performance requirements and design information sufficiently detailed to permit the preparation of

acceptance and inspection requirements by the NRC, and procurement specifications and construction and installation specifications by an applicant. Title 10 CFR 52.48 requires the applications filed will be reviewed for compliance with the standards set out in 10 CFR Part 73. Title 10 CFR 52.47(b)(1) requires that the application must contain proposed inspections, tests, analyses, and acceptance criteria that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, a facility that incorporates the design certification has been constructed and will be operated in conformity with the design certification, the provisions of the Act, and the Commission's rules and regulations. The level of detail supporting design descriptions for how physical security systems will be designed should conform to RG 1.206, Figure 1, Combined License Application Referencing a Certified Design, showing acceptable level of detail based on design completions for design certification finality.

In TR-0416-48929, Section 3.0, Security by Design, the applicant states, in part: [t]he combination of enhanced security-by-design features described below [Section 3] provide for defense-in-depth through the integration of systems, technologies, and equipment. The applicant concludes or asserts that the NuScale design of the reactor and plant configurations (i.e., SSC) provides certain security functions. The descriptions or narrative of design features providing security functions in Section 3 did not provide references to security assessments, analyses, and/or calculations for which the applicant may have prepared and established the technical bases supporting various assertions made in Section 3.

The physical structure (an SSC for safety of operations) identified and discussed in Items No. 1, No. 3, and No. 9, that is described in the narrative to provide resistance to force entry (i.e., delay function) to access vital equipment, does not provide a continuous physical barrier system that prevents the bypass without using force. For the assertions that the design of the physical structure provides delay to force entry, the applicant did not provide references to the applicants assessment or analysis examining various tasks and time associated with mechanical, explosive, or combination of breaching methods to penetrate the physical structure. A summary description of bounding delay times for method of breaching was not included to support that the physical structure may be credited by a COL applicant for security delay function. The assertions did not compare task time for using equipment available for normal plant operations to remove the physical structure or the task time to bypass the structures through openings, to indicate viable alternative methods to using force entry. Figures in Section 7 and the NuScale standard design of nuclear reactor modules do not show that the physical structure credited for delay functions forms a continuous barrier and is subject to bypass.

Additional information is needed on technical references that supports the applicants narratives in Section 3 that assert that NuScale design of reactor and safety structures, systems and components also provide security functions or protect against the Design Basis Threat (DBT). The applicant did not address the limitations of security functions or enhancement to security operations and provide the design and technical bases for crediting various safety structures, systems and components and their configuration to perform security or enhance implementation of physical security to protect against the DBT for radiological sabotage as described in 10 CFR 73.1. The descriptions provided is not sufficient to support the credibility of various safety structures, systems and components that may be considered by a COL applicant in the design of a physical protection system for protecting and operating the referenced NuScale power reactor.

The staff requests that the applicant provide the following additional information on the design and technical bases of NuScale standard design of safety structures, systems, and components (SSC) and plant configurations that are credited, not only to provide safety or operations, but to also provide security functions for the implementation of physical protection or security operations:

a. Indicate the technical references (i.e., analyses, assessments, calculations, etc.) that document and establish the technical bases supporting the assertions of performances, conditions, or results for security functions provided by the design of the specific physical structure [intentionally not stated, identified in the last sentences of the first paragraph on Page 6] of the NuScale nuclear power reactor modules, as described in Section 3, Items No. 1, No. 3, and No. 9.

b. Describe the technical basis for the assertions stated in Items No. 1, No. 3, and No. 9 that the specific physical structure provides or can be relied on for delay functions for security response. The technical basis should address the following:

(1) In Items No. 1 and No. 3 (Pages 6 and 7), the applicant asserts that a specific physical structure

[intentionally not stated, identified in the last sentences of the first paragraph on Page 6] as designed is capable of resistance to forced entry to gain access, to vital equipment. Provide the technical basis for how the configuration provides a barrier is capable of providing delay of access to vital equipment. Include in the descriptions the following: (a) the design basis, from applicants technical assessments or analyses, including task analysis, for mechanical, explosive, or a combination of mechanical and explosive breaching methods that support the assertion that the physical structure can be credited for resisting force entry; (b) the bounding minimum delay times for different breaching methods analyzed and describe how design and material construction of the physical structures can be credited to achieve delay functions; and (c) how the physical structures provide additional protection of decay heat removal system, as stated in Item No. 9. Also, describe the normal operational requirements for removing a portion of the physical structure and the minimum time and equipment needed to remove the fastening component of the physical structure without using force.

(2) In Items No. 1 and No. 3 (Pages 5 and 6), the applicant made assertions in the narrative on security-by-design that the physical structure [intentionally not stated, identified in the last sentences of the first paragraph on Page 6] can be credited to prevent the bypass of the physical structures for access to vital equipment. Describe the technical basis supporting this assertion on how the physical structure forms a continuous physical barrier and the rationale that force entry (mechanical, explosive, or a combination) by a DBT adversary (as described in 10 CFR 73.1) is necessary in lieu of bypassing the physical structures. Include any technical basis from applicants assessment or analysis, on the task and time needed to bypass the physical structure to access vital equipment without using force.

c. Confirm whether the physical structure [intentionally not stated, identified in the last sentences of the first paragraph on Page 6], as shown in Figure 7 (Page 56), and Figure 8 (Page 57), are additional designated vital area barriers for delay and controlling access to vital equipment. Clarify whether the physical structure shown to be within physical barriers already identified and designated as a vital area barrier is intended to be an additional third barrier to the two barriers, or is accounting for the protected area barrier to be designed by the COL applicant, designed to meet the requirements of 10 CFR 73.55(e)(9). If these physical structures are designated as one of two barriers required for meeting 10 CFR 73.55(e)(9) for protecting access to vital equipment, provide the section views, along with the plan views shown in Figures 7 and 8, of the typical configuration of how the physical structure(s) combined to form the vital area boundaries and describe how the design will address the additional requirements to the physical barriers in 10 CFR 73.55(e)(9).

13.06.02-3 TR-0416-48929, Section 3.0, Security by Design, Item No. 2 (Page 6)

Regulatory Basis: Subpart B of 10 CFR 52, § 52.47, requires that information submitted for a design certification must include performance requirements and design information sufficiently detailed to permit the preparation of acceptance and inspection requirements by the NRC, and procurement specifications and construction and installation specifications by an applicant. Title 10 CFR 52.48 requires the applications filed will be reviewed for compliance with the standards set out in 10 CFR Part 73. Title 10 CFR 52.47(b)(1) requires that the application must

contain proposed inspections, tests, analyses, and acceptance criteria that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, a facility that incorporates the design certification has been constructed and will be operated in conformity with the design certification, the provisions of the Act, and the Commission's rules and regulations. Title 10 CFR 52.6 requires information provided to the Commission by an applicant for a standard design certification shall be complete and accurate in all material respects.

In Section 3, Item No. 2, the applicants narrative of the NuScale reactor design references the NRCs study conducted by the Department of Navy, Naval Surface Weapon Center - Carderock, Technical Report NSWCCD TR-2012/023. The study is a limited scoping study that examined possible underwater explosive effects on the outer containment vessel of the NuScale reactor, based on design specifications of 2012 and using explosives in a bulk configuration at select locations. The result of the limited scoping study cannot be broadly applied to be bounding of a maximum underwater explosive effect based on the DBT hand-carried explosives. The NRC study did not address other methods and quantities of explosives that are within the attributes of the DBT and did not analyze the potential explosive effects on the inner vessel, piping, valves, other safety-related equipment (bio-shield above the pool), the surrounding structures within effected underwater blast areas or the impact on storage of spent fuel. The NRC study cannot be referenced as the only source that contains the technical basis supporting or justifying the robustness of NuScale CNV as stated in Item No. 2. Additional information is needed on references, along with supporting the technical bases for the assertion stated in the narrative in Section 3, Item No. 2.

The staff requests that the applicant provide the following:

a. Indicate the technical references (i.e., analyses, engineering assessment or modeling of explosive effects) that NuScale has performed to support the assertion or conclusion stated that . . . thus, this study [Technical Report NSWCCD-66-TR-2012/023] confirms the robustness of NuScales CNV design, in Item No. 2 (Page 6).

b. Describe the technical and design bases for the following to support the applicants determination and conclusion of the robustness of the CNV to withstand explosive effects:

(1) how the design of the CNV (containment vessel) is capable of withstanding the explosive effects of the quantity of hand carried explosive, up to the maximum of the DBT, using other than the method and configurations that was considered and modeled in the study.

(2) how the designs of other structural components (e.g., piping, valves, etc.) were analyzed and their capabilities to withstand explosive effects to maintain the integrity of the CNV and continued required safety functions.

(3) how the internal design pressure of CNV, as stated in Item No. 2, is relevant to protecting the CNV against external explosive pressures and describe the significance of the loss of integrity of the CNV on maintaining core cooling.

13.06.02-4 TR-0416-48929, Section 3, Security by Design (Pages 6 through 8)

Regulatory Basis: Subpart B of 10 CFR 52, § 52.47, requires that information submitted for a design certification must include performance requirements and design information sufficiently detailed to permit the preparation of acceptance and inspection requirements by the NRC, and procurement specifications and construction and installation specifications by an applicant. Title 10 CFR 52.48 requires the applications filed will be reviewed for compliance with the standards set out in 10 CFR Part 73. Title 10 CFR 52.47(b)(1) requires that the application must contain proposed inspections, tests, analyses, and acceptance criteria that are necessary and sufficient to provide

reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, a facility that incorporates the design certification has been constructed and will be operated in conformity with the design certification, the provisions of the Act, and the Commission's rules and regulations. Title 10 CFR 52.6 requires information provided to the Commission by an applicant for a standard design certification shall be complete and accurate in all material respects.

In TR-0416-48929, Section 3.0, Security by Design, the applicant states, in part: [t]he combination of enhanced security-by-design features described below [Section 3] provide for defense-in-depth through the integration of systems, technologies, and equipment. The applicants narrative in Section 3 made assertions that the design of the reactor and plant can be credited for security functions. The descriptions in Section 3 did not provide references to security assessments, analyses, and/or calculations for which the applicant may have prepared to establish the technical bases supporting the assertions stated.

Additional information is requested on the references that document the technical and design bases that support the applicants narratives in Section 3, "Security-by-Design," that safety structures, systems and components of the NuScale standard plant can be credited or capable, as asserted in Items No. 4, No. 5, No. 6, No. 7, No. 8, No. 9, No.

12, No. 13, and No. 14, of performing security functions. The technical and design bases, along with limitations of enhancements to implementing security functions, are needed for establishing credibility of the safety design features to perform security functions (i.e., security by design) that may be applied by a COL applicant that references the NuScale standard design.

The staff requests that the applicant provide the following:

Indicate the references (e.g., assessment, analysis, calculations, etc.) that document the technical bases for the following assertions in narratives found in Section 3, for capabilities, performances, conditions, or conclusions that the design of the NuScale safety structures, systems and components and plant configurations provide security functions that limit impacts, effects, or consequences from the DBT for radiological sabotage, which enhance physical protection and implementation of security requirements. For the selected items below, describe the technical and design bases supporting the assertions stated:

a. In Item No. 4 (Pages 6 and 7), the applicant asserts that The smaller fission product inventory, in additio n to the NPM [nuclear power module] being located within the UHS [ultimate heat sink] . . . with fewer accessible vital equipment increases the complexity of actions that an adversary team would have to take to be successful in achieving significant core damage or spent fuel sabotage. Provide the technical basis for the following:

(1) How fewer vital equipment increases adversary tasks or complexity of tasks.

(2) How physical features of the NuScale standard design are being credited for delaying the access to the vital equipment.

b. In Item No. 5 (Page 7), the applicant asserts that the equilibrium water level and calculations support the durations for core and spent fuel cooling indicated in Item No. 12. Describe the technical basis for the following:

(1) How intentional acts (i.e., the DBT and its attributes and capabilities) are considered in determining the equilibrium water level required. Include descriptions of what parameters, assumptions, and plant and systems configurations credited for the durations indicated and how they are bounding of DBT scenarios to allow continued core and spent fuel cooling.

(2) How the durations indicated in Item No. 12, are bounding for intentional acts that prevent safety systems and components from performing their intended functions, such as intentional acts that would change system configuraton needed for core cooling.

c. In Items No. 7, No. 13, and No. 14 (Pages 7 and 8), the applicant asserts that: the fuel and reactor located below grade reduces or eliminate the postulated impact from DBT vehicle bomb attack; the Reactor

Building structural design is capable to withstand the blast effects of DBT vehicle bombs and preclude the use of DBT hand carried explosives; and the configurations of the NuScale reactor modules, with the fuel and core component located below grade level, result in the reduction or elimination of postulated impacts from the DBT vehicle bomb attacks.

(1) Describe the technical bases for the following to support the assertions stated:

(a) For Item No. 7, how the NuScale standard plant designs (i.e., structural and construction material) and configurations of structures are credited to protect against explosive blast effects of the quantities of DBT vehicle bombs. Specifically describe how the explosive effects on the underground portion of the Reactor Building were analyzed, including the methods, assumptions, structural design and material construction that are credited to support that its design, with fuel and reactor components, located below grade level results in the reduction or elimination of postulated impacts. . . from vehicle bomb attacks. Indicate the reference of the analysis that documents the technical basis characterized the explosive effects on the underground structure of the NuScale standard plant that support the assertion stated in Items No. 7 and No. 14.

(b) For Item No. 13, how the blast analyses or calculations support the narrative assertion that adjacent plant structures above grade provides shielding of the Reactor Building from explosive effects.

(c) For item No. 14, how the NuScale Power Plant designed in accordance with 10 CFR 50.150, aircraft impact, provides for designing a robust Reactor Building that is resistant to effects of explosives associated with DBT vehicle bombs.

(2) Provide the design descriptions and configurations, in Section 4 and Section 7 of the TR-0416-48929, respectively, for the NuScale standard design features stated in Item No. 14 that preclude the use of hand carried explosive . . . .

d. In Items No. 8 and No. 9 (Page 7), the applicant asserts capabilities for long term core or spent fuel cooling without secondary power supply and that the design effectively eliminates an adversary capability to prevent decay heat removal. Provide the technical basis that the equipment identified as vital in TR-0416-48929, Section 4.8, are capable of performing their intended functions without primary or secondary electrical power. Describe the technical basis supporting the assertion that the NuScale design effectively eliminates specific DBT adversary capabilities, and indicate in what context and limitations of this assertion. Also address how the NuScale reactor design, with location of reactors vessel underwater, effectively eliminates the DBT adversary from impacting safety-related systems identified vital in Section 4.8, Design Element No. 8.

e. In Item No. 12 (Page 7), the applicant asserts that the NuScale design provides a volume of water in the UHS for core and spent fuel cooling for two specific durations (i.e., a worst case and a more re alistic boil off) based on calculations. Indicate the reference calculations that support the assertions stated. Describe the key parameters and assumptions of the supporting calculations and indicate whether these calculations of worst or best case addresses the attributes of the DBT. Indicate how the assumptions of availability and reliability of safety related equipment and safety analysis scenarios (e.g., accident sequence) are effected by the DBT (i.e., intentional acts), which have not been previously analyzed. Clarify whether the durations indicated in Item No. 12 represent a plant configuration that circulates water flow through the CNV under accident conditions previously analyzed and whether those durations consider plant configurations or conditions without water flow through the CNV.

f. In Items No. 14 (Page 8), the applicant asserts that the Reactor Building is designed in accordance with 10 CFR 50.150. Provide the technical basis that supports that the design of the structure of the reactor building meeting the requirements of 10 CFR 50.150 can be credited for meeting security functions, such as the resisting or delay of forced entry using explosives and/or mechanical tools. Indicate whether the

design descriptions in TR-0416-48929, such as doors, access portals, or other protection of openings of the reactor building, are also being credited to withstand aircraft impact, for meeting 10 CFR 50.150.

13.06.02-5 TR-0416-48929, Section 3, Security by Design (Page 8, 3 rd paragraph)

Regulatory Basis: Subpart B of 10 CFR 52, § 52.47, requires that information submitted for a design certification must include performance requirements and design information sufficiently detailed to permit the preparation of acceptance and inspection requirements by the NRC, and procurement specifications and construction and installation specifications by an applicant. Title 10 CFR 52.48 requires the applications filed will be reviewed for compliance with the standards set out in 10 CFR Part 73. Title 10 CFR 52.47(b)(1) requires that the application must contain proposed inspections, tests, analyses, and acceptance criteria that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, a facility that incorporates the design certification has been constructed and will be operated in conformity with the design certification, the provisions of the Act, and the Commission's rules and regulations. Title 10 CFR 52.6 requires information provided to the Commission by an applicant for a standard design certification shall be complete and accurate in all material respects.

10 CFR 73.1(a)(1), Radiological sabotage states the following:

(i) A determined violent external assault, attack by stealth, or deceptive actions, including diversionary actions, by an adversary force capable of operating in each of the following modes: A single group attacking through one entry point, multiple groups attacking through multiple entry points, a combination of one or more groups and one or more individuals attacking through multiple entry points, or individuals attacking through separate entry points, with the following attributes, assistance and equipment: (A) Well -

trained (including military training and skills) and dedicated individuals, willing to kill or be killed, with sufficient knowledge to identify specific equipment or locations necessary for a successful attack; (B)

Active (e.g., facilitate entrance and exit, disable alarms and communications, participate in violent attack) or passive (e.g., provide information), or both, knowledgeable inside assistance; (C) Suitable weapons, including handheld automatic weapons, equipped with silencers and having effective long range accuracy; (D) Hand-carried equipment, including incapacitating agents and explosives for use as tools of entry or for otherwise destroying reactor, facility, transporter, or container integrity or features of the safeguards system; and (E) Land and water vehicles, which could be used for transporting personnel and their hand-carried equipment to the proximity of vital areas; and (ii) An internal threat; and (iii) A land vehicle bomb assault, which may be coordinated with an external assault; and (iv) A waterborne vehicle bomb assault, which may be coordinated with an external assault; and (v) A cyber attack.

The regulation explicitly include an and and does not restrict the methods of attacks as independent of each other and standalone.

The staff requests that the applicant correct the bullets identifying methods (or modes) indicated in Section 3 to reflect the requirements of 10 CFR 73.1 to correctly characterize methods for radiological sabotage. Specifically, the five general attack modes indicated in Section 3 requires an and to represent accurately the requirement of 10 CFR 73.1(a)(1), which establish that the methods of attack for radiological sabotage are not independent of each other or considered stand-alone.

13.06.02-6

TR-0416-48929, Section 4.2, Design Element No. 2 (Page 13, paragraphs No. 3 and No. 4)

Regulatory Basis: Subpart B of 10 CFR 52, § 52.47, requires that information submitted for a design certification must include performance requirements and design information sufficiently detailed to permit the preparation of acceptance and inspection requirements by the NRC, and procurement specifications and construction and installation specifications by an applicant. Title 10 CFR 52.48 requires the applications filed will be reviewed for compliance with the standards set out in 10 CFR Part 73. Title 10 CFR 52.47(b)(1) re quires that the application must contain proposed inspections, tests, analyses, and acceptance criteria that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, a facility that incorporates the design certification has been constructed and will be operated in conformity with the design certification, the provisions of the Act, and the Commission's rules and regulations. The level of detail supporting design descriptions for how physical security systems will be designed should conform to RG 1.206, Figure 1, Combined License Application Referencing a Certified Design, showing acceptable level of detail based on design completions for design certification finality.

In Section 4.2, Design Element No. 2, the applicant did not describe the minimum design requirements (performance and acceptance criteria) for the physical security system and hardware for protecting openings, which are capable of blast and ballistic protection and force entry resistant delay. Section 4.2, Design Element No. 2, the applicant did not describe the minimum design requirements (performance and acceptance criteria) for the physical security system and hardware for protecting openings, which are capable of blast and ballistic protection and force entry resistant delay. Additional information is requested on the design description and how the physical security system and hardware were considered in the analysis or calculations determining the MSSD shown in Table 4-1 in Section 4.11, Design Element No. 11. The description for the capability to withstand ballistics did not specify minimum design requirements or standards for the design of the security system and hardware to achieve a specific minimum level of bullet-resistant.

The staff requests that the applicant provide the following:

Describe the minimum design requirements (i.e., performance and acceptance criteria) and standards for the blast/ballistic protection and force entry resistant delay for the systems and hardware [intentionally not stated]

described in paragraphs No. 3 and No. 4 on Page 13. For the design capabilities for blast resistant, indicate how these security system and hardware are included in the calculations determining the Reactor Building minimum safe standoff distance (MSSD) shown in Section 4.11.2, Table 4.1 for Design Element No. 11. Specifically, indicate how these system and hardware are considered in the analysis or calculations for determining the MSSD for the overall structure. Describe the minimum ballistic protection that is required for the physical security system and hardware. Describe the design basis and the minimum delay time that is expected based on the design and material construction requirements for blast and ballistic protection. Indicate on the drawings (notes, door schedule, etc.) in Figure 7 and Figure 21, the physical security system and hardware described in paragraph No. 3 and No. 4.

13.06.02-7 TR-0416-48929, Section 4.3, Design Element No. 3 (Page 16, [intentionally not stated] Barrier, paragraph No. 4)

Regulatory Basis: Subpart B of 10 CFR 52, § 52.47, requires that information submitted for a design certification must include performance requirements and design information sufficiently detailed to permit the preparation of acceptance and inspection requirements by the NRC, and procurement specifications and construction and installation specifications by an applicant. Title 10 CFR 52.48 requires the applications filed will be reviewed for compliance with the standards set out in 10 CFR Part 73. Title 10 CFR 52.47(b)(1) re quires that the application must contain proposed inspections, tests, analyses, and acceptance criteria that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, a facility that incorporates the design certification has been constructed and will be operated in conformity with the

design certification, the provisions of the Act, and the Commission's rules and regulations. The level of detail supporting design descriptions for how physical security systems will be designed should conform to RG 1.206, Figure 1, Combined License Application Referencing a Certified Design, showing acceptable level of detail based on design completions for design certification finality.

In TR-0416-48929, Section 4.3, design element for physical barriers, the applicants design basis, credit a minimum thickness and material construction of reactor building walls, including the ceiling and floors did not address the technical basis for how bullet-resistant is met. The applicant refers to an engineering calculation that determined a certain thickness of walls can provide abullet resistant design basis, but did not indicate information on the referenced engineered calculation or describe a summary of design parameters, assumptions, or the capabilities for bullet-resistant for the design basis that certain building structures can be credited for performing security functions for meeting security design requirements.

The staff requests that the applicant provide the following for the design descriptions provided in Design Element No. 3:

a. Indicate the reference calculation in the statement that [a] NuScale engineering calculation determined that a concrete wall of [intentionally not stated] thickness is required in order to be classified as bullet-resistant. Identify this engineering calculation reference, and any other technical references - engineering calculations, assessments, or analyses, that establish the design and technical bases for crediting the safety structures, systems and components of the building relied on for security functions in Section 6.

b. Describe the design and technical bases supporting the minimum thickness indicated in Section 4.3 fo r achieving bullet-resistant. Include in the summary descriptions any limitations or conditions, such as whether the technical basis that the minimum thickness for bullet-resistant is bounding of the expected maximum hand carried weapon attributes (e.g., projectiles, velocities, mass, numbers of rounds, etc.) of the DBT and reference standard applied to determined minimum thickness and material construction required for achieving intended bullet-resistant functions.

13.06.02-8 TR-0416-48929, Section 4.4, Design Element No. 4 (Page 17)

Regulatory Basis: Subpart B of 10 CFR 52, § 52.47, requires that information submitted for a design certification must include performance requirements and design information sufficiently detailed to permit the preparation of acceptance and inspection requirements by the NRC, and procurement specifications and construction and installation specifications by an applicant. Title 10 CFR 52.48 requires the applications filed will be reviewed for compliance with the standards set out in 10 CFR Part 73. Title 10 CFR 52.47(b)(1) re quires that the application must contain proposed inspections, tests, analyses, and acceptance criteria that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, a facility that incorporates the design certification has been constructed and will be operated in conformity with the design certification, the provisions of the Act, and the Commission's rules and regulations. The level of detail supporting design descriptions for how physical security systems will be designed should conform to RG 1.206, Figure 1, Combined License Application Referencing a Certified Design, showing acceptable level of detail based on design completions for design certification finality.

Section 4.4.2 provides design descriptions of physical security systems that are part of the NuScale standard design for barriers, access control, locking, and assessment with references to Figures 1 through 21. Some figures, drawings with door schedules, such as Figure 17 shows a specific type of door (i.e., Note 8) discussed in Design Element No. 4. However, the design descriptions or information on drawings does not show other types of doors and delay barriers, and associated controls and interfaces, discussed in Section 4.4. Additional information is

requested on how the design element described in Section 4.4 are designed and configured in the drawings shown in Section 7.

The applicant, in Section 4.4.2, indicates that physical barriers or features (e.g., vault doors, security hardened doors, other features, etc.) and fighting positions fall under Criterion 3(b) as being independent from the construction of the nuclear island and structures. Other than fighting positions that are mobile, not permanently installed to the structure of a building, the design and installation of physical barriers or features (e.g., vault or security hardened doors, other features, etc.) are a permanent part of the building structure, and are considered integral to the structural integrity of the Reactor Building or Control Building. Inconsistent with the note indicated in Section 4.4, the applicant has described physical barriers and other features that are integral to the NuScale standard design.

The staff requests that the applicant -

a. provide configurations of physical barriers (e.g., vault doors, security hardened doors, other features, etc.)

and any fixed fighting positions for physical security systems discussed in Section 4.4.2 on the appropriate drawings in Section 7 of the TR-0416-48929. Identify the types of doors (e.g., vault, security hardened, or others) in the door schedules provided on drawings in Section 7 (i.e., Figures No. 5, No. 6, No. No. 7, No. 8, No. 10, No. 15, No. 16, No. 17, No. 18, No. 20, and No. 21). Include any design requirements for locks, alarms, access controls and detection and assessment system interfaces.

b. show the typical design for physical barriers (i.e., section views) along with plan views. Describe for the design specifications for controlling mechanism and capabilities to lock or to unlock doors and gates for deployment to meet security delay or protection functions. Describe the design and material constructions of these barriers and associated minimum delay functions.

c. confirm whether the note that [d]escriptions need not be included if Criterion 3(a) or 3(b) and the discussions of Criterion (3) in Section 4.4.2 are applicable for this design element.

13.06.02-9 TR-0416-48929, Section 4.6, Design Element No. 6 (Page 20)

Regulatory Basis: Subpart B of 10 CFR 52, § 52.47, requires that information submitted for a design certification must include performance requirements and design information sufficiently detailed to permit the preparation of acceptance and inspection requirements by the NRC, and procurement specifications and construction and installation specifications by an applicant. Title 10 CFR 52.48 requires the applications filed will be reviewed for compliance with the standards set out in 10 CFR Part 73. Title 10 CFR 52.47(b)(1) re quires that the application must contain proposed inspections, tests, analyses, and acceptance criteria that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, a facility that incorporates the design certification has been constructed and will be operated in conformity with the design certification, the provisions of the Act, and the Commission's rules and regulations. The level of detail supporting design descriptions for how physical security systems will be designed should conform to RG 1.206, Figure 1, Combined License Application Referencing a Certified Design, showing acceptable level of detail based on design completions for design certification finality.

The physical security structure, system and components for the portal described in Section 4.6, Design Element No.

6, are not shown on figures found in Section 7. The design requirements and acceptance criteria for minimum blast and bullet resistant are not specified in the TR-0146-48929.

The staff requests that the applicant indicate the typical design of the portals, described in Section 4.6.2.1, on the appropriate design drawings in Section 7. Indicate whether vault doors are used to meet the performance stated to protect the openings. Provide the design basis for the barriers blast and forced-entry resistant capabilities stated, and describe the design and material construction requirements and associated capabilities for delaying unauthor ized entry.

13.06.02-10 TR-0416-48929, Section 7, Figure 22, [intentionally not stated] Building (Page 71)

Regulatory Basis: Subpart B of 10 CFR 52, § 52.47, requires that information submitted for a design certification must include performance requirements and design information sufficiently detailed to permit the preparation of acceptance and inspection requirements by the NRC, and procurement specifications and construction and installation specifications by an applicant. Title 10 CFR 52.48 requires the applications filed will be reviewed for compliance with the standards set out in 10 CFR Part 73. Title 10 CFR 52.47(b)(1) re quires that the application must contain proposed inspections, tests, analyses, and acceptance criteria that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, a facility that incorporates the design certification has been constructed and will be operated in conformity with the design certification, the provisions of the Act, and the Commission's rules and regulations. The level of detail supporting design descriptions for how physical security systems will be designed should conform to RG 1.206, Figure 1, Combined License Application Referencing a Certified Design, showing acceptable level of detail based on design completions for design certification finality.

Figures 22 provides plan views for the design of the building, which is not included in the scope of the NuScale standard design. Also, Figure 22 shows a physical barrier near Door No. [intentionally not stated], which appears to be a barrier protecting the opening into the structure, but it is not described in Section 4 of TR-0416-48929 or identified on the door schedule on the drawing in Figure 22.

The staff requests that the applicant confirm whether the physical security systems and features shown in Figure 22 are within the scope of the NuScale standard design. If so, provide the design descriptions, including section views, for the physical barrier between column lines [intentionally not stated], shown near Door No. [intentionally not stated] on Figure 22. The barrier shown is not described in design elements found in Section 4 of TR-0416-48929.

13.06.02-11 TR-0416-48929, Section 4.8, Vital Areas and Equipment (Element 8) (Pages 22-23)

Regulatory Basis: Subpart B of 10 CFR 52, § 52.47, requires that information submitted for a design certification must include performance requirements and design information sufficiently detailed to permit the preparation of acceptance and inspection requirements by the NRC, and procurement specifications and construction and installation specifications by an applicant. Title 10 CFR 52.48 requires the applications filed will be reviewed for compliance with the standards set out in 10 CFR Part 73. Title 10 CFR 52.47(b)(1) re quires that the application must contain proposed inspections, tests, analyses, and acceptance criteria that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, a facility that incorporates the design certification has been constructed and will be operated in conformity with the design certification, the provisions of the Act, and the Commission's rules and regulations.

The regulations in 10 CFR 73.2 state that Vital equipment means any equipment, system, device, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by

exposure to radiation. Equipment or systems which would be required to function to protect public health and safety following such failure, destruction, or release are also considered to be vital.

The applicant indicated that an interdisciplinary team evaluated and identified all vital equipment for the NuScale standard design in accordance with 10 CFR 73.2 definition of vital equipment, and subsequently provided design of physical security systems in the scope of a standard design for meeting regulatory requirements of 10 CFR 73.55(e)(9)(i) - vital equipment must be located only within vital areas. The descriptions of the process for identifying vital equipment establish how the applicant evaluate and determine structures, systems and components of the NuScale standard design meet the definition of 10 CFR 73.2, to establish a reasonable, complete, and an accurate list of vital equipment for which designation of vital areas and physical security systems are designed to meet the requirements 10 CFR 73.55 for controlling access to protect vital equipment.

The staff requests that the applicant -

a. describe the process applied to evaluate and determine which structures, systems and components of the NuScale standard design are vital.

(1) Describe the following in the process established to identify vital equipment:

(a) How the process applies and complies with the definition of vital equipment in 10 CFR 73.2.

(b) Criteria and assumptions used to identify vital equipment.

(c) Criteria applied to exclude SSC as vital equipment.

(d) How the designations of SSC as safety-related and the risk-significance of SSC were considered in the process of identifying vital equipment.

(e) Source documents (e.g., safety analyses, design documents, technical reports, analyses, etc.) used to identify vital equipment.

b. describe the specific PRA insights used in the process to develop and identify vital equipment, to include whether flood and fire PRA were used to inform the team. Also, describe how the PRA was used to develop the insights, including quantitative and qualitative techniques. The descriptions of the process applied should include the following:

(1) Discuss how systems' piping is addressed in identifying vital equipment for the NuScale standard design. In addition, describe how such safety systems components, including those associated with control systems (e.g., communications signals) relied on for operations of safety systems, are being evaluated for identifying vital equipment.

(2) Discuss how the cables (i.e., power, control, instrument) supporting the vital equipment were addressed in identifying vital equipment.

(3) Describe how single failure criterion is used in the identification of vital equipment.

(4) Describe the operator assumptions used in the identification of vital equipment, including any credited actions that were used to screen equipment from the vital equipment list.

c. describe the process for how the identified list of vital equipment will be updated to reflect changes to plant systems, configurations, and/or the NuScale standard design. Specifically, how the vital equipment list in TR-0416-48929 will be updated to reflect subsequent information developed in topical or technical repo rts, updates to PRA information or insights, and the updates to the FSAR that could determine or affect both the identification/completeness and the locations of vital equipment.

d. describe, in Section 4.8.2, any structures, systems, and components in the building that would be considered vital, based on the process applied to identify vital equipment and how structures, systems and components were excluded.

13.06.02-12 TR-0416-48929, Section 4.7, Design Element No. 7 (Page 21) and Section 4.10, Design Element No. 10 (Page 25)

Regulatory Basis: Subpart B of 10 CFR 52, § 52.47, requires that information submitted for a design certification must include performance requirements and design information sufficiently detailed to permit the preparation of acceptance and inspection requirements by the NRC, and procurement specifications and construction and installation specifications by an applicant. Title 10 CFR 52.48 requires the applications filed will be reviewed for compliance with the standards set out in 10 CFR Part 73. Title 10 CFR 52.47(b)(1) re quires that the application must contain proposed inspections, tests, analyses, and acceptance criteria that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, a facility that incorporates the design certification has been constructed and will be operated in conformity with the design certification, the provisions of the Act, and the Commission's rules and regulations. Title 10 CFR 52.6 requires information provided to the Commission by an applicant for a standard design certification shall be complete and accurate in all material respects.

For Design Element No. 7, the applicant describes the design for bullet-resistant barriers and protection of openings for physical security (e.g., 10 CFR 73.55(e)). Figures provided in Section 7 show the doors and walls, etc. along with other physical barriers. The walls, doors, and windows are integral to the design of the building structural design. The SRP 13.6.2 Criterion 3(a) or Criterion 3(b) do not apply in these cases and the note is inconsistent with the information provided.

For Design Element No. 10, the note only applies to the statement in Section 4.10.2, Items No. 3 and No. 5 that address the Secondary Alarm Station and secondary power supply, which are not within the scope of the NuScale standard plant. The note only applies to the design of the secondary alarm station (SAS), which Section 4.10.2, Item No. 3, indicates that its location and design will be addressed by a COL applicant. The remaining discussions of design elements in this section address security systems and features for the MCR and CAS, which are within the scope of the NuScale standard design, and their design configurations are shown in Figure 21 (Page 70).

Other subsections of Section 4 should be reviewed to confirm whether the note accurately reflects the descriptions provided for various design elements to appropriately characterize descriptions provided that contradicts the note that descriptions of design were not provided using the SRP 13.6.2 Criterion 3(a) or Criterion 3(b).

The staff requests that the applicant review the applicability of the Note: Descriptions need not be included if Criterion 3(a) or 3(b) criterion is applicable for design elements addressed in Sections 4.7 and 4.10. Also verify whether this note is applicable for the descriptions provided in the following Sections:

• Section 4.17, Design Element No. 17 (Page 34)

• Section 4.18, Design Element No. 18 (Page 35)

• Section 4.19, Design Element No. 19 (Page 36)

• Section 4.20, Design Element No. 20 (Page 37)

• Section 4.21, Design Element No. 21 (Page 38) 13.06.02-13

TR-0416-48929, Section 4.11, Design Element No. 11 (Page 26-27) and Table 4-1, Minimum Standoff Distances (Page 26)

Regulatory Basis: Subpart B of 10 CFR 52, § 52.47, requires that information submitted for a design certification must include performance requirements and design information sufficiently detailed to permit the preparation of acceptance and inspection requirements by the NRC, and procurement specifications and construction and installation specifications by an applicant. Title 10 CFR 52.48 requires the applications filed will be reviewed for compliance with the standards set out in 10 CFR Part 73. Title 10 CFR 52.47(b)(1) requires that the application must contain proposed inspections, tests, analyses, and acceptance criteria that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, a facility that incorporates the design certification has been constructed and will be operated in conformity with the design certification, the provisions of the Act, and the Commission's rules and regulations. The level of detail supporting design descriptions and basis for how physical security systems will be designed should conform to RG 1.206, Figure 1, Combined License Application Referencing a Certified Design, showing acceptable level of detail based on design completions for design certification finality.

The MSSD shown in Table 4-1 are based on calculations and applied methods described in Section 4.11.

The applicant did not identify references that establish the design and technical basis for the results shown in Table 4-1. The discussion did not provide sufficient descriptions of what methods were applied, design parameters, assumptions, criteria and damage severities for establishing that the MSSD are adequate to protect structures, systems, and components against the DBT vehicle bombs. Additional information is needed in the TR-0416-4892 on the design and technical bases that the MSSD shown in Table 4-1 are reasonable and adequate to protect the structures, systems and components identified and may be referenced by the COL as a basis for design of a physical protection system meeting the requirements of 10 CFR 73.55.

The staff requests that the applicant provide the following for Design Element No. 11 that provides the minimum safe standoff distances for the NuScale standard design:

a. Indicate the references documenting the analyses or engineering calculations that determined the minimum safe standoff distances (MSSD) shown in Table 4-1. In addition to indicating references, provide a summary of how the MSSDs were determined, including structural design parameters, assumptions, and criteria (pressures and severity of damage) for determining that at the MSSD indicated the structures identified are protected against explosive effects of the DBT vehicle bombs. Include which specific method listed in Section 4.11 were applied in determining each of the MSSD shown in Table 4.1 and what level of protection were designated as criteria for calculating the MSSD indicated.

b. For the MSSD results shown in Table 4-1, provide descriptions to address the following:

(1) For the building MSSD, describe how the calculations address NUREG/CR-6190, Appendix B, Section B-3 guidance on explosive blast effects (e.g., blast induced ground shock, cratering, fragments, and thermal radiation). Describe the analytical methods applied to evaluate blast wavefront, ground motions, and subsurface pressures in analyzing the blast effect on the buried structure, including the method applied to evaluate potential crater dimensions for the detonation of the vehicle bombs at the MSSD indicated in Table 4-1.

(2) Describe how AT-Blast was used, in conjunction with SBEDS for determining blast loading.

(3) For the building that is not included, provide the technical basis for why this structure within the scope of the NuScale standard plant design is not included in Table 4-1.

(4) For the structures, systems, or components that are not within the scope of the NuScale standard design (i.e., Secondary Alarm Station and BRE), but are identified in Table 4-1, provide clarification of the purpose of providing their MSSD. Also, as appropriate, provide summary of

key design basis, including the descriptions of the structural design and construction requirements that would be expected for a COL applicant to meet for applying the MSSD indicated in Table 4-1.

(5) For the MSSD shown for the CAS, indicate whether the MSSD is for the outer boundaries of the building which the CAS is located within or whether the MSSD is from the boundaries of the CAS, inside the building.

(6) Confirm whether it is necessary to indicate MSSD for person in open and person in non-hardened enclosure, for the security design features addressed in the NuScale design certification. If these MSSD are appropriate and are to be included for information only, describe the criteria for human fragility used for determining MSSD shown for the determination that security personnel will not be incapacitated to prevent the continuing performance of required security functions (e.g., capabilities to assess, communicate, and perform security response to interdict or neutralize).

(7) For the MSSD provided for stiffened steel security door, describe how this relates to the doors described in design elements in Section 4 and the door schedules shown in drawings found in Section 7 (e.g., the design and material construction requirements and locations of where such doors will be installed). Indicate the design requirements and configurations for the security stiffened steel security doors and how the design can be credited in determining the MSSD that protects the reactor building from the explosive effects of the DBT vehicle bombs.

(8) Indicate the reference engineering calculations or blast analyses supporting the MSSD for the blast resistant enclosure (BRE), for the design basis that establish the bounding MSSD where a vehicle barrier system must be installed to protect plant operation. Describe how calculations considered and applied criteria for human fragility for maximum overpressure that would expect a person will not be impaired and will be able to continue performing security functions at the blast pressures shown with the MSSD in Table 4-1.

13.06.02-14 TR-0416-4892, Section 4.23, Design Element No. 23 (Page 40)

Regulatory Basis: Subpart B of 10 CFR 52, § 52.47, requires that information submitted for a design certification must include performance requirements and design information sufficiently detailed to permit the preparation of acceptance and inspection requirements by the NRC, and procurement specifications and construction and installation specifications by an applicant. Title 10 CFR 52.48 requires the applications filed will be reviewed for compliance with the standards set out in 10 CFR Part 73. Title 10 CFR 52.47(b)(1) requires that the application must contain proposed inspections, tests, analyses, and acceptance criteria that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, a facility that incorporates the design certification has been constructed and will be operated in conformity with the design certification, the provisions of the Act, and the Commission's rules and regulations. Title 10 CFR 52.6 requires information provided to the Commission by an applicant for a standard design certification shall be complete and accurate in all material respects. The level of detail supporting design descriptions and basis for how physical security systems will be designed should conform to RG 1.206, Figure 1, Combined License Application Referencing a Certified Design, showing acceptable level of detail based on design completions for design certification finality.

The applicant states that [i]llumination within the Reactor Building and Control Building will be provided by the normal plant lighting and emergency lighting systems. The plant emergency lighting system provides illumination

during the loss of normal power. Additional information is needed on whether the design of plant emergency lighting system provides sufficient illumination needed for performing security functions and whether there would be a need for a dedicated emergency lighting for security functions.

The staff requests that the applicant describe the design requirements for minimum illumination for performing security functions in the general building areas within the buildings, within the scope of the design, outside of the CAS, and the minimum requirement for security alarm work stations located within the CAS. Indicate whether the plant emergency lighting system can be credited for providing the minimum required (or exceeds) illumination to perform security functions (e.g., intrusion assessment, surveillance, access controls, security response, identifying and acquiring targets for neutralization) in the event of loss of normal power.

13.06.02-15 TR-0416-4892, Section 4.21, Design Element No. 21 (Page 38) and Section 4.23, Design Element No. 23 (Page)

Regulatory Basis: Subpart B of 10 CFR 52, § 52.47, requires that information submitted for a design certification must include performance requirements and design information sufficiently detailed to permit the preparation of acceptance and inspection requirements by the NRC, and procurement specifications and construction and installation specifications by an applicant. Title 10 CFR 52.48 requires the applications filed will be reviewed for compliance with the standards set out in 10 CFR Part 73. Title 10 CFR 52.47(b)(1) requires that the application must contain proposed inspections, tests, analyses, and acceptance criteria that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, a facility that incorporates the design certification has been constructed and will be operated in conformity with the design certification, the provisions of the Act, and the Commission's rules and regulations. The level of detail supporting design descriptions for how physical security systems will be designed should conform to RG 1.206, Figure 1, Combined License Application Referencing a Certified Design, showing acceptable level of detail based on design completions for design certification finality.

The staff requests that the applicant provide design descriptions of the security assessment system described in Section 4.21 and shown in drawings in Section 7. Confirm whether the design descriptions for capability indicated in Section 4.23 (last paragraph of Section 4.23.2) is a design requirement of the assessment system described in Section 4.21.

13.06.02-16 TR-0416-4892, Section 7, Figure 23 (Page 72)

Regulatory Basis: Subpart B of 10 CFR 52, § 52.47, requires that information submitted for a design certification must include performance requirements and design information sufficiently detailed to permit the preparation of acceptance and inspection requirements by the NRC, and procurement specifications and construction and installation specifications by an applicant. Title 10 CFR 52.48 requires the applications filed will be reviewed for compliance with the standards set out in 10 CFR Part 73. Title 10 CFR 52.47(b)(1) requires that the application must contain proposed inspections, tests, analyses, and acceptance criteria that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, a facility that incorporates the design certification has been constructed and will be operated in conformity with the design certification, the provisions of the Act, and the Commission's rules and regulations. The level of detail supporting design descriptions for how physical security systems will be designed should conform to RG 1.206, Figure 1, Combined License Application Referencing a Certified Design, showing acceptable level of detail based on design completions for design certification finality.

The design of the petition shown in Section 7, Figure 23, is not described in design elements found in Section

4. Additional information requests the indication of design descriptions and basis for the physical security feature identified in Figure 23 in the appropriate design element in Section 4, and to clarify whether the partition is an additional barrier credited for meeting the requirement of 10 CFR 73.55(e) for bullet-resistant.

The staff requests the following:

Provide design basis and descriptions for the design of the physical partition shown inside the door to the room on the design drawing in Figure 23. Indicate which design element in Section 4 addresses this design of the physical partition. Describe the following on the design and technical bases and its application:

a. The intended design functions and any limitations, including the design parameters and criteria for how it achieves its intended functions (e.g., protecting the entire area of the room on the design drawing in Figure 23, protecting equipment, protecting the person and equipment in the separated room, material construction, level of bullet-resistant protection, etc.);

b. Confirm whether the partition is intended to provide redundancy of security function of that which is provided by the door and wall.

c. Describe any limitation of the design configuration shown to protect against possible travel of projectiles through the open areas between the top of partition and the ceiling above for the protection of the alarm orkstation, separated room, and any security equipment and components above the ceiling.

13.06.02-17 TR-0416-48929, Section 6, References (Pages 47-48)

Regulatory Basis: Subpart B of 10 CFR 52, § 52.47, requires that information submitted for a design certification must include performance requirements and design information sufficiently detailed to permit the preparation of acceptance and inspection requirements by the NRC, and procurement specifications and construction and installation specifications by an applicant. Title 10 CFR 52.48 requires the applications filed will be reviewed for compliance with the standards set out in 10 CFR Part 73. Title 10 CFR 52.47(b)(1) requires that the application must contain proposed inspections, tests, analyses, and acceptance criteria that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, a facility that incorporates the design certification has been constructed and will be operated in conformity with the design certification, the provisions of the Act, and the Commission's rules and regulations. Title 10 CFR 52.6 requires information provided to the Commission by an applicant for a standard design certification shall be complete and accurate in all material respects.

The staff requests that the applicant indicate, in Section 6, all engineering calculations, analyses, assessments, and other references that provide the design and technical basis for the summary descriptions of design, design basis, results, and conclusions presented in TR-0416-48929.

13.06.02-18 TR-0416-48929, Section 7, Figures (Pages 50 to 56)

Regulatory Basis: Subpart B of 10 CFR 52, § 52.47, requires that information submitted for a design certification must include performance requirements and design information sufficiently detailed to permit the preparation of acceptance and inspection requirements by the NRC, and procurement specifications and construction and installation specifications by an applicant. Title 10 CFR 52.48 requires the applications filed will be reviewed for compliance with the standards set out in 10 CFR Part 73. Title 10 CFR 52.47(b)(1) requires that the application must contain proposed inspections, tests, analyses, and acceptance criteria that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, a facility that incorporates the design certification has been constructed and will be operated in conformity with the design certification, the provisions of the Act, and the Commission's rules and regulations. The level of detail supporting design descriptions for how physical security systems will be designed should conform to RG 1.206, Figure 1, Combined License Application Referencing a Certified Design, showing acceptable level of detail based on design completions for design certification finality.

The figures in Section 7 identify vital areas (i.e., reactor control room and CAS) that are identified in 10 CFR 73.55(e)(9)(V)(A) and (V)(C). However, the drawings shown in Section 7 did not address the requirement of 10 CFR 73.55(e)(9)(V)(B) which requires that the spent fuel pool is designated as a vital area.

The staff requests that the applicant identify and show the boundaries of the spent fuel pool that are designated as vital area barriers on drawings in Section 7.