ML18135A123

LLC - Supplemental Response to NRC Request for Additional Information No. 221 (Erai No. 9114) on the NuScale Design Certification Application

ML18135A123
Person / Time
Site:	NuScale
Issue date:	05/15/2018
From:	Rad Z NuScale
To:	Document Control Desk, Office of New Reactors
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ML18135A122	List: ML18135A123
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RAIO-0518-59976
Download: ML18135A123 (13)

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RAIO-0518-59976 May 15, 2018 Docket No.52-048 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738

SUBJECT:

NuScale Power, LLC Supplemental Response to NRC Request for Additional Information No. 221 (eRAI No. 9114) on the NuScale Design Certification Application

REFERENCES:

1. U.S. Nuclear Regulatory Commission, "Request for Additional Information No. 221 (eRAI No. 9114)," dated September 12, 2017

2. NuScale Power, LLC Response to NRC "Request for Additional Information No. 221 (eRAI No.9114)," dated November 13, 2017

3. NuScale Power, LLC Supplemental Response to "NRC Request for Additional Information No. 221 (eRAI No. 9114)" dated February 21, 2018 The purpose of this letter is to provide the NuScale Power, LLC (NuScale) supplemental

response to the referenced NRC Request for Additional Information (RAI).

The Enclosures to this letter contain NuScale's supplemental response to the following RAI

Question from NRC eRAI No. 9114:

03.07.02-31 is the proprietary version of the NuScale Supplemental Response to NRC RAI No.

221 (eRAI No. 9114). NuScale requests that the proprietary version be withheld from public

disclosure in accordance with the requirements of 10 CFR § 2.390. The enclosed affidavit (Enclosure 3) supports this request. Enclosure 2 is the nonproprietary version of the NuScale

response.

This letter and the enclosed responses make no new regulatory commitments and no revisions

to any existing regulatory commitments.

If you have any questions on this response, please contact Marty Bryan at 541-452-7172 or at

mbryan@nuscalepower.com.

Sincerely, Za Z ckary W. Rad Zackary Di t Regulatory Director, R l t Aff i Affairs NuScale Power, LLC NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0518-59976 Distribution: Omid Tabatabai, NRC, OWFN-8G9A Samuel Lee, NRC, OWFN-8G9A Prosanta Chowdhury NRC, OWFN-8G9A : NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9114, proprietary : NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9114, nonproprietary : Affidavit of Zackary W. Rad, AF-0518-59977 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0518-59976 :

NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9114, proprietary NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0518-59976 :

NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9114, nonproprietary NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

Response to Request for Additional Information Docket No.52-048 eRAI No.: 9114 Date of RAI Issue: 09/12/2017 NRC Question No.: 03.07.02-31 10 CFR 52.47(a)(20) requires that an application for Design Certification must include the

information necessary to demonstrate that the standard plant complies with the earthquake

engineering criteria in 10 CFR 50, Appendix S. 10 CFR 50 Appendix S requires that the safety

functions of structures, systems, and components (SSCs) must be assured during and after the

vibratory ground motion associated with the Safe Shutdown Earthquake (SSE) through design,

testing, or qualification methods.

FSAR Tier 2, Section 3A.1 states the seismic analysis of the NuScale Power Module (NPM) is

provided in technical report, TR-0916-51502, NuScale Power Module Seismic Analysis. In

TR-0916-51502, Section 3.1, the applicant indicates that NPM simplified beam models

developed in ANSYS are incorporated into the RXB system model used in SAP2000 and

SASSI2010 analyses. In TR-0916-51502, Section 6.0, the applicant discusses how NPM

simplified beam models were derived from the corresponding NPM detailed 3D models in

ANSYS. However, the staff notes that the NPM beam models depicted in Figure 6- 1 (dry) and

Figure 6-13 (wet) in TR-0916-51502 appear to be different than the model shown in FSAR

Figure 3.7.2-28, which FSAR Section 3.7.2.1.2.2 states represents the SASSI2010 NPM beam

model.

Therefore, the applicant is requested to explain how the NPM beam models included in the

SAP2000/SASSI2010 RXB models were developed and validated (e.g., comparison of dynamic

characteristics between the detailed and simplified models).

NuScale Response:

As discussed, in a meeting on April 17, 2018, a supplement to NuScale's original response to RAI 9114 03.07.02-31 is provided.

The NuScale Power Module (NPM) beam models used in the soil-structure interaction (SSI) and load combinations for the building models in SASSI2010 and SAP2000, are different from those presented in the NuScale Power Module Analysis Technical Report, TR-0916-51502. The beam models from TR-0916-51502 are more refined models which better represent the dynamic NuScale Nonproprietary

behavior of the detailed 3D model and are more appropriate for the NPM specific analyses.

The NPM beam model shown in FSAR Tier 2, Figure 3.7.2-28, and described in Section 3.7.2.1.2.2, was designed to have similar dynamic characteristics as the 3D model at the time of development. To validate the NPM beam model, a modal analysis in three directions was performed in order to tune the simplified model to match the detailed 3D model response. The frequencies for the most significant modes are presented in Table 1. The simplified beam model captures the overall dynamic behavior of the 3D NPM model required for the building response analyses used in the SASSI2010 and SAP2000 models. Additional clarification has been added to the FSAR Tier 2, Section 3.7.2.1.2.2 to describe the approach used to develop and verify the NPM beam model.

NuScale Nonproprietary

Table 1: Mode comparisons between simplified NPM beam model and 3D model for development.

((2(a),(c) Impact on DCA: FSAR Tier 2, Section 3.7.2 has been revised as described in the response above and as shown in the markup provided with this response. NuScale Nonproprietary

NuScale Final Safety Analysis Report Seismic Design The rigid springs have a zero length and have a stiffness value large enough to simulate rigid connection. The large stiffness used is arbitrarily chosen to be ten billion lbs per inch, or 1010 lbs/inch, in the three global directions. The model dimensions, the quantities of elements and masses, and structural damping ratios used for the SASSI2010 model are summarized in Table 3.7.2-1. The NPMs and the Reactor Building crane (RBC) are included in the RXB model as beam models. These two subsystems are discussed in the following sections. 3.7.2.1.2.2 NuScale Power Modules Up to twelve NPMs will be inside the RXB. The modules are partially immersed in the reactor pool. The NPMs are not permanently bolted or welded to the pool floor or walls. Instead they are geometrically supported and constrained at four locations. The geometrical constraints are designed to keep each NPM in its location before, during, and after a seismic event. The base support is a steel skirt that rests outside a permanently installed ring plate attached at the bottom of the reactor pool. The other three geometrical supports are steel lug restraints located on the walls of each bay at approximately the midpoint of the module (~EL. 75). The NPM has lugs that align with a slot in the restraint. Each restraint prevents movement in the direction parallel to the wall and allows the NPM to move freely in the upward direction. In other words, the lug and restraint provides only horizontal restraint in the in-plane direction for the supporting wall. The lug and lug restraint combination is shown in Figure 3.7.2-22. Figure 3.7.2-23 shows the top view of a restrained NPM. The placement of the twelve NPMs in the model of the RXB is shown in Figure 3.7.2-24. An enlarged view of the NPM pool region is shown in Figure 3.7.2-25. Figure 3.7.2-26 shows a view of the RXB model with twelve NPMs within the support walls. The lug restraints can be seen near the mid-height of the NPMs in the figure. Figure 3.7.2-27 shows a single NPM. In this figure, the lug restraint can be seen at the upper part of the NPM and the support skirt can be seen at the base of the NPM. NuScale Power Module Model Included in the Reactor Building SASSI2010 Model RAI 03.07.02-20, RAI 03.07.02-20S1, RAI 03.07.02-31S1, RAI 03.07.02-31S2 Within the SASSI2010 building model, the NPM is represented by a beam model as shown in Figure 3.7.2-28. The beam model was developed to have similar dynamic characteristics as a 3-D ANSYS model of a single NPM bay. To validate the NPM beam model, a modal analysis in three directions was performed in order to tune the simplified model to match the detailed 3-D model response, shown in Table 3.7.2-38. The skirt support at the base of the containment restricts horizontal and vertical movements. Eight rigid beams Tier 2 3.7-116 Draft Revision 2

NuScale Final Safety Analysis Report Seismic Design arranged like the legs of a spider are modeled to connect the NPM model containment skirt to nodes in the building model located at the interface of the skirt and pool floor. The RXB analysis produces local acceleration time histories that are used as input to the NPM seismic analysis. The seismic analysis of the NPM is discussed in Appendix 3A. Table 3.7.2-36 and Table 3.7.2-37 outline the NPM beam model to RXB model interface boundary conditions for the SASSI2010 and ANSYS models, respectively. 3.7.2.1.2.3 Reactor Building Crane The RBC is a bridge crane used to transport modules between the operating locations and the refueling and disassembly area and the drydock. The RBC travels on rails on the top of the reactor pool walls at EL. 145'-6". When not in use, the RBC is parked over the refueling pool with the trolley at the north end near the dry dock gate. In this position, the RBC is not above either the SFP or the NPMs. The RBC is described in Section 9.1.5. Reactor Building Crane Model Included in the Reactor Building SASSI2010 Model RAI 03.07.03-1 Figure 3.7.2-29 shows the beam and spring model used to represent the RBC. For the analysis of the RXB, the RBC is unloaded (i.e., no suspended NPM) and located in the middle of the reactor pool area as shown in Figure 3.7.2-24. The RXB analysis produces in-structure response spectra (ISRS) that are used as input to the RBC seismic analysis. 3.7.2.1.2.4 Ultimate Heat Sink Pool The UHS pool contributes a large amount of weight to the global mass of the RXB. This fluid impacts the dynamic characteristics of the building. Figure 3.7.2-30 provides a visualization of the hydrodynamic structural system (building and UHS pools). Figure 3.7.2-31 provides a similar view, but eliminates the structure and shows only the pool water. In the RXB SAP2000 model, the hydrodynamic load generated due to the pool water mass during a seismic event is addressed by assigning lumped masses on the pool walls and foundation nodes that are in contact with the pool water. These lumped nodal masses are multiplied by the nodal accelerations during the dynamic analyses and introduce equivalent dynamic pressures on the walls and foundation as impulsive pressures. All of the pool water mass is assigned as lumped nodal masses in the two horizontal and vertical directions separately. Neither the SAP2000 nor SASSI2010 computer programs have an explicit fluid element formulation to accurately calculate the hydrodynamic effects due to all three directional components of earthquake input motions. To develop a correction factor, a fluid structure interaction (FSI) model was created in ANSYS and used to develop fluid loads. These results were compared to the SASSI2010 dynamic results and a correction factor established. Tier 2 3.7-117 Draft Revision 2

NuScale Final Safety Analysis Report Seismic Design RAI 03.07.02-31S1, RAI 03.07.02-31S2 Table 3.7.2-38: Major Mode Comparisons Between Simplified NuScale Power Module Beam Model and 3-D ModelNot Used Simplified Beam Model 3-D Model X-Freq. X-Eff. Mass X-Freq. (Hz) (lbfs2/in.) (Hz) 6.9 3999 5.83 12.85 2395 11.16 17.14 284 17.45 Simplified Beam Model 3-D Model Y-Freq. Y-Eff. Mass Z-Freq. (Hz) (lbfs2/in.) (Hz) 9.23 1989 8.89 14.29 3304 12.59 19.28 1399 15.12 Simplified Beam Model 3-D Model Z-Freq. Z-Eff. Mass Y-Freq. (Hz) (lbfs2/in.) (Hz) 14.18 2456 13.94 19.4 2227 16.41 42.67 191 42.9 Tier 2 3.7-232 Draft Revision 2

RAIO-0518-59976 : Affidavit of Zackary W. Rad, AF-0518-59977 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

NuScale Power, LLC AFFIDAVIT of Zackary W. Rad I, Zackary W. Rad, state as follows:

1. I am the Director, Regulatory Affairs of NuScale Power, LLC (NuScale), and as such, I have been specifically delegated the function of reviewing the information described in this Affidavit that NuScale seeks to have withheld from public disclosure, and am authorized to apply for its withholding on behalf of NuScale.

2. I am knowledgeable of the criteria and procedures used by NuScale in designating information as a trade secret, privileged, or as confidential commercial or financial information. This request to withhold information from public disclosure is driven by one or more of the following:

a. The information requested to be withheld reveals distinguishing aspects of a process (or component, structure, tool, method, etc.) whose use by NuScale competitors, without a license from NuScale, would constitute a competitive economic disadvantage to NuScale.

b. The information requested to be withheld consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), and the application of the data secures a competitive economic advantage, as described more fully in paragraph 3 of this Affidavit.

c. Use by a competitor of the information requested to be withheld would reduce the competitor's expenditure of resources, or improve its competitive position, in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.

d. The information requested to be withheld reveals cost or price information, production capabilities, budget levels, or commercial strategies of NuScale.

e. The information requested to be withheld consists of patentable ideas.

3. Public disclosure of the information sought to be withheld is likely to cause substantial harm to NuScale's competitive position and foreclose or reduce the availability of profit-making opportunities. The accompanying Request for Additional Information response reveals distinguishing aspects about the methodology by which NuScale develops its reactor building models used in the soil-structure interaction (SSI) and load combinations for the building models.

NuScale has performed significant research and evaluation to develop a basis for this methodology and has invested significant resources, including the expenditure of a considerable sum of money. The precise financial value of the information is difficult to quantify, but it is a key element of the design basis for a NuScale plant and, therefore, has substantial value to NuScale. If the information were disclosed to the public, NuScale's competitors would have access to the information without purchasing the right to use it or having been required to undertake a similar expenditure of resources. Such disclosure would constitute a misappropriation of NuScale's intellectual property, and would deprive NuScale of the opportunity to exercise AF-0518-59977

its competitive advantage to seek an adequate return on its investment.

4. The information sought to be withheld is in the enclosed response to NRC Request for Additional Information No. 221, eRAI 9114. The enclosure contains the designation "Proprietary" at the top of each page containing proprietary information. The information considered by NuScale to be proprietary is identified within double braces, "(( }}" in the document.

5. The basis for proposing that the information be withheld is that NuScale treats the information as a trade secret, privileged, or as confidential commercial or financial information. NuScale relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC § 552(b)(4), as well as exemptions applicable to the NRC under 10 CFR §§ 2.390(a)(4) and 9.17(a)(4).

6. Pursuant to the provisions set forth in 10 CFR § 2.390(b)(4), the following is provided for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld:

a. The information sought to be withheld is owned and has been held in confidence by NuScale.

b. The information is of a sort customarily held in confidence by NuScale and, to the best of my knowledge and belief, consistently has been held in confidence by NuScale.

The procedure for approval of external release of such information typically requires review by the staff manager, project manager, chief technology officer or other equivalent authority, or the manager of the cognizant marketing function (or his delegate), for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside NuScale are limited to regulatory bodies, customers and potential customers and their agents, suppliers, licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or contractual agreements to maintain confidentiality.

c. The information is being transmitted to and received by the NRC in confidence.

d. No public disclosure of the information has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or contractual agreements that provide for maintenance of the information in confidence.

e. Public disclosure of the information is likely to cause substantial harm to the competitive position of NuScale, taking into account the value of the information to NuScale, the amount of effort and money expended by NuScale in developing the information, and the difficulty others would have in acquiring or duplicating the information. The information sought to be withheld is part of NuScale's technology that provides NuScale with a competitive advantage over other firms in the industry.

NuScale has invested significant human and financial capital in developing this technology and NuScale believes it would be difficult for others to duplicate the technology without access to the information sought to be withheld. I declare under penalty of perjuryy that the foregoing g g is true and correct. Executed on 5/15/2018. Zackary WW. Rad AF-0518-59977}}