ML18288A396

LLC - Supplemental Response to NRC Request for Additional Information No. 232 (Erai No. 9113) on the NuScale Design Certification Application

ML18288A396
Person / Time
Site:	NuScale
Issue date:	10/15/2018
From:	Rad Z NuScale
To:	Document Control Desk, Office of New Reactors
Shared Package
ML18288A395	List: ML18288A396
References
AF-1018-62136, RAIO-1018-62135
Download: ML18288A396 (16)

Text

RAIO-1018-62135 October 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. 232 (eRAI No. 9113) on the NuScale Design Certification Application

REFERENCES:

1. U.S. Nuclear Regulatory Commission, "Request for Additional Information No. 232 (eRAI No. 9113)," dated September 21, 2017

2. NuScale Power, LLC Response to NRC "Request for Additional Information No. 232 (eRAI No.9113)," dated July 23, 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. 9113:

• 03.06.03-9 is the proprietary version of the NuScale Supplemental Response to NRC RAI No.

232 (eRAI No. 9113). 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, Zackary W. Rad Director, Regulatory Affairs NuScale Power, LLC Distribution: Gregory Cranston, NRC, OWFN-8G9A Samuel Lee, NRC, OWFN-8G9A Marieliz Vera, NRC, OWFN-8G9A NuScale Power, LLC 1100 NE Circle Blvd. , Suite 200 Corvalis, Oregon 97330 , Office: 541.360.0500 , Fax: 541.207.3928 www.nuscalepower.com

RAIO-1018-62135 : NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9113, proprietary : NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9113, nonproprietary : Affidavit of Zackary W. Rad, AF-1018-62136 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-1018-62135 :

NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9113, 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-1018-62135 :

NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9113, 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.: 9113 Date of RAI Issue: 09/21/2017 NRC Question No.: 03.06.03-9S1 The equations presented in FSAR Section 3.6.3.3 have been used to generate the SBAC Figures referenced in FSAR Section 3.6.3.4 showing normal operating (N) and maximum (N+SSE) stresses for LBB locations. Many of these graphs presented in Figures 3.6-23 through 3.6-32 are unusual in that the maximum (N+SSE) stresses are lower than the normal stresses for some cases. To assist the staff in understanding these graphs, please provide the following; Provide a table of stresses or forces and moments at the girth weld (node points) from the piping stress analysis and indicate which of these locations are used in the LBB analysis. In these tables, also identify the different stress components, i.e., thermal expansion, pressure, dead-weight, seismic/inertial, seismic/anchor motion, etc.

The normal stress versus maximum stress plots shown Figure 3.6-23 to Figure 3.6-32 for various segments for MS and FW system show that there were some data points below 1:1 line indicating that N+SSE stresses are lower than normal stress. Please explain.

NuScale Response:

In a follow-up public meeting with NRC on August 23, 2018, the staff requested the following additional information.

In order to proceed with confirmatory analyses, additional data, i.e., all three component values (Mx, My, and Mz) of resultant moment for each loading condition (i.e., DW, TH, PR, SSE, and SAM) at 36 weld locations are required - as resultant moment alone is not sufficient. NuScale is requested to provide this additional data so that confirmatory analyses can proceed as planned.

NuScale Nonproprietary

The data that NuScale provided in the initial RAI 9113 Question 03.06.03-9 response were from new piping loads, based on new seismic loads and pipe routing. These data are not the same set of data that were used in calculating the stress points in Figure 3.6-23 through Figure 3.6-32 in the FSAR Section 3.6. The differences between the FSAR piping and the new piping include load magnitudes and number of welds. The new piping has 36 welds while the FSAR piping has 40 welds.

The forces and moments for the 40 welds used in the FSAR Section 3.6 are provided in Tables 1 through 4 below. In these tables, the loads are calculated based on a local Cartesian coordinate system at each weld location. Fa is axial force while Mx, My, and Mz are moments about axial and two transverse directions.

An example computation of a stress point is provided after the Table 4, showing how the normal and maximum stresses are determined.

NuScale Nonproprietary

Table 1: MS line 1 weld location forces and moments MS1 Load Fa Mx My Mz Point Combination (lbf) (ft-lbf) (ft-lbf) (ft-lbf)

A00 Dead Weight ((

Therm. Exp.(1)

Pressure SAM(2)

Seismic(4)

A03A Dead Weight Therm. Exp.

Pressure SAM Seismic A06N-(3) Dead Weight Therm. Exp.

Pressure SAM Seismic A06N+(3) Dead Weight Therm. Exp.

Pressure SAM Seismic A06F-(3) Dead Weight Therm. Exp.

Pressure SAM Seismic A06F+(3) Dead Weight Therm. Exp.

Pressure SAM Seismic A10 Dead Weight Therm. Exp.

Pressure SAM Seismic A09A Dead Weight Therm. Exp.

Pressure SAM Seismic B03A Dead Weight Therm. Exp.

Pressure SAM Seismic B07 Dead Weight Therm. Exp.

Pressure SAM Seismic2(a),(c) (1) Note  : Thermal Expansion (2)

Seismic Anchor Motion (3)

Straight pipe side of the data: F+ and N-; bent pipe side: F- and N+

(4)

Seismic data are the SRSS results of the SSE loads applied in three directions of x, y, and z NuScale Nonproprietary

Table 2: MS line 2 weld location forces and moments MS2 Load Fa Mx My Mz Point Combination (lbf) (ft-lbf) (ft-lbf) (ft-lbf) A00 Dead Weight (( Therm. Exp. Pressure SAM Seismic A03A Dead Weight Therm. Exp. - Pressure SAM Seismic A06N- Dead Weight Therm. Exp. Pressure SAM Seismic A06N+ Dead Weight Therm. Exp. Pressure SAM Seismic A06F- Dead Weight Therm. Exp. Pressure SAM Seismic A06F+ Dead Weight Therm. Exp. Pressure SAM Seismic A10 Dead Weight Therm. Exp. Pressure SAM Seismic A09A Dead Weight Therm. Exp. Pressure SAM Seismic B03A Dead Weight Therm. Exp. Pressure SAM Seismic B07 Dead Weight Therm. Exp. Pressure SAM Seismic }}2(a),(c) NuScale Nonproprietary

Table 3: FW line 1 weld location forces and moments FW1 Load Fa Mx My Mz Point Combination (lbf) (ft-lbf) (ft-lbf) (ft-lbf) A00 Dead Weight (( Therm. Exp. Pressure SAM Seismic A05- Dead Weight Therm. Exp. Pressure SAM Seismic A05+ Dead Weight Therm. Exp. Pressure SAM Seismic A09 Dead Weight Therm. Exp. Pressure SAM Seismic A11 Dead Weight Therm. Exp. Pressure SAM Seismic A13 Dead Weight Therm. Exp. Pressure SAM Seismic A18 Dead Weight Therm. Exp. Pressure SAM Seismic A17 Dead Weight Therm. Exp. Pressure SAM Seismic B01 Dead Weight Therm. Exp. Pressure SAM Seismic B04 Dead Weight Therm. Exp. Pressure SAM Seismic }}2(a),(c) NuScale Nonproprietary

Table 4: FW line 2 weld location forces and moments FW2 Load Fa Mx My Mz Point Combination (lbf) (ft-lbf) (ft-lbf) (ft-lbf) A00 Dead Weight (( Therm. Exp. Pressure SAM Seismic A26 Dead Weight Therm. Exp. Pressure SAM Seismic A27 Dead Weight Therm. Exp. Pressure SAM Seismic A12 Dead Weight Therm. Exp. Pressure SAM Seismic A14 Dead Weight Therm. Exp. Pressure SAM Seismic A16 Dead Weight Therm. Exp. Pressure SAM Seismic A19 Dead Weight Therm. Exp. Pressure SAM Seismic A25 Dead Weight Therm. Exp. Pressure SAM Seismic B01 Dead Weight Therm. Exp. Pressure SAM Seismic B04 Dead Weight Therm. Exp. Pressure SAM Seismic }}2(a),(c) NuScale Nonproprietary

Example: Take the B03A weld in Table 1 as an example, its normal and maximum loads are calculated using FSAR equations 3.6-7 to 3.6-10 as: This weld is located in a NPS8 pipe, as indicated in Figure 1. With the normal operating and maximum internal pressures in MS as 500 and 650 psi respectively, the end cap forces are, Then, the normal and maximum stresses are, This pair of stresses corresponds to the stress point indicated in Figure 2. NuScale Nonproprietary

Figure 1: MS line 1 weld B03A location Figure 2: Location B03A stress point in FSAR Figure 3.6-24 NuScale Nonproprietary

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

RAIO-1018-62135 : Affidavit of Zackary W. Rad, AF-1018-62136 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 method by which NuScale evaluates it power module systems.

NuScale has performed significant research and evaluation to develop a basis for this method 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-1018-62136

4. The information sought to be withheld is in the enclosed response to NRC Request for Additional Information No. 232, eRAI No. 9113. 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 15,2018.

                                /          Zackary W. Rad AF-1018-62136}}