ML18274A400

LLC Response to NRC Request for Additional Information No. 377 (Erai No. 9380) on the NuScale Design Certification Application

ML18274A400
Person / Time
Site:	NuScale
Issue date:	10/01/2018
From:	Rad Z NuScale
To:	Document Control Desk, Office of New Reactors
Shared Package
ML18274A399	List: ML18274A400
References
AF-1018-62010, RAIO-1018-62009
Download: ML18274A400 (30)

Text

RAIO-1018-62009 October 01, 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 Response to NRC Request for Additional Information No.

377 (eRAI No. 9380) on the NuScale Design Certification Application

REFERENCES:

1. U.S. Nuclear Regulatory Commission, "Request for Additional Information No. 377 (eRAI No. 9380)," dated March 02, 2018

2. NuScale Power, LLC Supplemental Response to "NRC Request for Additional Information No. 377 (eRAI No. 9380)" dated September 13, 2018 The purpose of this letter is to provide the NuScale Power, LLC (NuScale) response to the referenced NRC Request for Additional Information (RAI).

The Enclosures to this letter contain NuScale's response to the following RAI Question from NRC eRAI No. 9380:

• 06.02.01 .01 .A-7 The response to RAI Questions 06.02.01 .01 .A-6 was previously provided in Reference 2. The response to question 06.02.01 .01 .A-5 will be provided by October 17, 2018.

Enclosure 1 is the proprietary version of the NuScale Response to NRC RAI No. 377 (eRAI No.

9380). NuScale requests that the proprietary version be withheld from public disclosure in accordance with the requirements of 10 CFR § 2.390. The proprietary enclosures have been deemed to contain Export Controlled Information. This information must be protected from disclosure per the requirements of 10 CFR § 810. The enclosed affidavit (Enclosure 3) supports this request. Enclosure 2 is the non proprietary 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 Paul lnfanger at 541-452-7351 or at pinfanger@nuscalepower.com.

Sincerely,

~ ~

/Zackary W. Rad Director, Regulatory 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-1018-62009 Distribution: Gregory Cranston, NRC, OWFN-8G9A Omid Tabatabai, NRC, OWFN-8G9A Samuel Lee, NRC, OWFN-8G9A : NuScale Response to NRC Request for Additional Information eRAI No. 9380, proprietary : NuScale Response to NRC Request for Additional Information eRAI No. 9380, nonproprietary : Affidavit of Zackary W. Rad, AF-1018-62010 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-1018-62009 :

NuScale Response to NRC Request for Additional Information eRAI No. 9380, 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-1018-62009 :

NuScale Response to NRC Request for Additional Information eRAI No. 9380, 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.: 9380 Date of RAI Issue: 03/02/2018 NRC Question No.: 06.02.01.01.A-7 Provide a discussion of the NIST-1 HP-06 tests results including an evaluation of the impact of preheating of the NIST-1 containment with regards to the ability of this test to show the impact of CNV liquid temperature stratification. Evaluate the NIST-1 HP-06 test data to show how the NRELAP5 code correctly calculates the temperature, enthalpy and mass fraction of vapor and liquid as the containment pressure increases with time.

NuScale Response:

The HP-06 test series are integral effects tests used to assess the capability of NRELAP5 to predict the integral response of the NIST-1 facility to a single-ended discharge line break inside containment. The test series includes the HP-06 and HP-06b test, where HP-06b is a repeat of HP-06 with a higher decay heat. The overall progressions of the tests are similar, as described in the LOCA topical report TR-0516-49422 Section 7.5.6.6. The HP-06b test assessment is most recent and is used in response to this RAI.

The response is broken into three parts:

• Part 1 is a discussion of the impact of preheating of the CNV walls on thermal stratification phenomenon in the CNV.

• Part 2 is an analysis of the impact of pool condensation on the prediction of CNV peak pressure.

• Part 3 provides an assessment of HP-06b relative to prediction of containment liquid and vapor temperature, enthalpy, and CNV liquid/vapor mass as the containment pressure increases.

NuScale Nonproprietary

Part 1 - Impact of CNV Wall Preheating on CNV Thermal Stratification The configuration of the containment vessel (CNV) and cooling pool vessel (CPV) and the purpose of preheating are discussed in detail in the response to eRAI 8777, Question 15.06.05-1, transmitted by NuScale letter RAIO-0917-56266, dated September 17, 2017. In summary, the heat transfer plate (HTP) between the CNV and CPV is scaled to capture the heat transfer behavior of the NuScale containment wall. Heat transfer to the CNV shell wall causes distortion of the results, relative to what is expected in the NuScale plant. Thus preheating of the shell wall is used to reduce heat transfer to the CNV shell wall during a LOCA test and increase the relative amount of heat transfer through the HTP to better capture the heat transfer behavior expected in the plant response.

In the HP-06b experiment, ((2(a),(b),(c),ECI NuScale Nonproprietary

((

                                                                          }}2(a),(b),(c),ECI Figure 1 - Containment experimental level and temperatures In Figure 1, ((
                                                   }}2(a),(b),(c),ECI NuScale Nonproprietary

((

                                                                        }}2(a),(b),(c),ECI Part 2 - Impact of Pool Condensation on CNV Pressure Response In order to evaluate whether the NRELAP5 model nodalization for the CNV is acceptable in terms of capturing pool condensation phenomenon, qualitative and quantitative methods, described below, were used to evaluate how much impact pool condensation has on system pressure in the HP-06b test.

NuScale Nonproprietary

Part 2.1 - Methodology for Assessing Impact of Pool Condensation As described in the RAI, the CNV pool temperature stratification phenomenon is of interest primarily because it impacts condensation rates at the pool surface and thus has the potential to impact the CNV pressure response, which is a safety analysis figure of merit. Thermal stratification of the pool occurs as condensate collects at the bottom of the CNV during a period of pressure increase. As the containment pressure increases, the condensed water that collects on the surface of the pool will be hotter than the liquid below due to the increase in saturation temperature with increase of pressure. Physically, the thermal stratification of the CNV pool has the effect of limiting surface condensation, particularly during the phase when the containment pressure is increasing. Because NRELAP5 is a finite volume code that discretizes the liquid temperature profile according to the spatial nodalization, the ability to model thermal stratification is affected by the nodalization. Given that the liquid temperature of a cell is the average liquid temperature rather than the (hotter during pressurization) surface temperature, ((

                                           }}2(a),(b),(c),ECI NuScale Nonproprietary

Part 2.2 - Qualitative Analysis The period of interest for pool stratification phenomena is the time over which the pressure is increasing. For the HP-06b test data, ((

                                                        }}2(a),(b),(c),ECI NuScale Nonproprietary

((

          }}2(a),(b),(c),ECI Part 2.3 - Quantitative Analysis

((

                                                       }}2(a),(b),(c),ECI NuScale Nonproprietary

((

                  }}2(a),(b),(c),ECI, the nodalization is deemed to be acceptable for purposes of modeling pool condensation.

Part 3 - Assessment of NRELAP5 Prediction of Parameters of Interest Finally, results from the HP-06b assessment are presented to demonstrate that NRELAP5 reasonably predicts CNV liquid and vapor temperature, enthalpy, and CNV liquid/vapor mass as the CNV pressure increases. From the pressure response shown in Figure 2, ((

                                                                                         }}2(a),(b),(c),ECI Part 3.1 - CNV Liquid and Vapor Temperature

((

                                                         }}2(a),(b),(c),ECI NuScale Nonproprietary

Table 1 - Containment temperature comparison ((

                                               }}2(a),(b),(c),ECI NuScale Nonproprietary

As indicated in Table 1, ((

                                                  }}2(a),(b),(c),ECI NuScale Nonproprietary

Part 3.2 - CNV Liquid Mass ((

                                                   }}2(a),(b),(c),ECI Overall, NRELAP5 provides a reasonable to excellent prediction of the CNV liquid mass.

Part 3.3 - CNV Liquid Enthalpy ((

                                    }}2(a),(b),(c),ECI The low temperature at the bottom of the CNV and the slightly low level suggest that the total CNV liquid enthalpy is slightly low overall, but agreement with data is reasonable to excellent.

NuScale Nonproprietary

Part 3.4 - CNV Vapor Mass ((

                                    }}2(a),(b),(c),ECI However, both predictions show reasonable to excellent agreement with data, so the CNV vapor mass is judged to be in reasonable to excellent agreement.

Part 3.5 - Vapor Enthalpy ((

                                                                               }}2(a),(b),(c),ECI Thus vapor enthalpy overall is judged to be reasonable. Note that a primary reason that the vapor enthalpy is of interest is the connection this has to CNV pressure and temperature, which were evaluated independently.

NuScale Nonproprietary

((

                                                           }}2(a),(b),(c),ECI Figure 2 - NRELAP5 Pressure versus Experimental Pressure Response NuScale Nonproprietary

((

                                                                }}2(a),(b),(c),ECI Figure 3 - Break and RRV Vapor Flow vs. CNV Condensation Rate NuScale Nonproprietary

((

                                                                }}2(a),(b),(c),ECI Figure 4 - Total Condensation Rate and Pool Condensation Rate NuScale Nonproprietary

((

                                           }}2(a),(b),(c),ECI Figure 5 - Lower CNV liquid temperatures NuScale Nonproprietary

((

                                                 }}2(a),(b),(c),ECI Figure 6 - Lower-middle CNV liquid temperature NuScale Nonproprietary

((

                                             }}2(a),(b),(c),ECI Figure 7 - Lower-middle vapor temperatures NuScale Nonproprietary

((

                                            }}2(a),(b),(c),ECI Figure 8 - Middle CNV vapor temperatures\

NuScale Nonproprietary

((

                                          }}2(a),(b),(c),ECI Figure 9 - Upper CNV vapor temperatures NuScale Nonproprietary

((

                         }}2(a),(b),(c),ECI Figure 10 - CNV level NuScale Nonproprietary

((

                                }}2(a),(b),(c),ECI Figure 11 - Pressurizer level NuScale Nonproprietary

((

                                                             }}2(a),(b),(c),ECI Figure 12 - RPV level Impact on DCA:

There are no impacts to the DCA as a result of this response. NuScale Nonproprietary

RAIO-1018-62009 : Affidavit of Zackary W. Rad, AF-1018-62010 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 distinguishing aspects by which NuScale develops its NIST-1 HP-02 testing.

NuScale has performed significant research and evaluation to develop a basis for this distinguishing aspects 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 its competitive advantage to seek an adequate return on its investment. AF-1018-62010

4. The information sought to be withheld is in the enclosed response to NRC Request for Additional Information No. 377, eRAI 9380. 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 perjury that the foregoing is true and correct. Executed on October 1, 2018. ~ 7 Zackary W. Rad AF-1018-62010}}