ML19098B620

LLC - Supplemental Response to NRC Request for Additional Information No. 465 (Erai No. 9494) on the NuScale Design Certification Application

ML19098B620
Person / Time
Site:	NuScale
Issue date:	04/08/2019
From:	Rad Z NuScale
To:	Document Control Desk, Office of New Reactors
Shared Package
ML19098B619	List: ML19098B620
References
RAIO-0419-65122
Download: ML19098B620 (13)

Text

RAIO-0419-65122 April 08, 2019 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. 465 (eRAI No. 9494) on the NuScale Design Certification Application

REFERENCES:

1. U.S. Nuclear Regulatory Commission, "Request for Additional Information No. 465 (eRAI No. 9494)," dated May 04, 2018

2. NuScale Power, LLC Response to NRC "Request for Additional Information No. 465 (eRAI No.9494)," dated April 08, 2019

3. NuScale Technical Report Containment Response Analysis Methodology, dated January 2017, TR-0516-49084 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. 9494:

• 06.02.01.01.A-17 is the proprietary version of the NuScale Supplemental Response to NRC RAI No.

465 (eRAI No. 9494). 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 Rebecca Norris at 541-452-7539 or at rnorris@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-0419-65122 Distribution: Gregory Cranston, NRC, OWFN-8H12 Omid Tabatabai, NRC, OWFN-8H12 Samuel Lee, NRC, OWFN-8H12 : NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9494, proprietary : NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9494, nonproprietary : Affidavit of Zackary W. Rad, AF-0419-65123 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0419-65122 :

NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9494, 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-0419-65122 :

NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9494, 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.: 9494 Date of RAI Issue: 05/04/2018 NRC Question No.: 06.02.01.01.A-17 The "Containment Response Analysis Methodology" Technical Report (CRAM TeR) (TR-0516-49084-P Rev. 0), in Section 2.0, states that the qualification of the LOCA and non-LOCA methodologies presented in both LOCA and Non-LOCA topical reports (TR-0516-49422- P, Rev. 0, and TR-0516-49416-P, Rev. 0, respectively) and in particular the comparisons to separate effects tests and integral effects tests, are applicable for the containment response analysis methodology. It appears to the staff that NuScale is relying on the qualification documented in these two topical reports as part of its containment response analysis methodology (CRAM). However, the LOCA topical report (TR) states that "NuScale is requesting Nuclear Regulatory Commission (NRC) review and approval to use the LOCA evaluation model (EM) described in this report for analyses of design-basis LOCA events in the NPM." Therefore, the staff is concerned about the applicability of the NIST-1 separate/integral effects tests results, validation, and distortion analysis presented in the LOCA TR, to the NRELAP5 safety analysis models used in the CRAM TeR to evaluate containment peak pressure/temperature for the design-basis events. The staff has the same concern about the stated scope for the non-LOCA TR and its applicability to the CRAM. Likewise, the scaling distortion report (Calculations to Support NIST-1 Distortion Analysis and Modeling of Containment and Pool heat Transfer, ((2(a),(c)) that is used to analyze the scaling distortions of the NIST-1 testing for both LOCA EM and CRAM, is only discussed in the LOCA TR. Sections 4.1.1 and 4.1.2 of the CRAM TeR state that no additional qualification activities were performed for the LOCA and non-LOCA models relative to applicability to the CRAM, and that these qualification activities were adequate. However, a clear and complete basis for that conclusion was not provided. NuScale is therefore requested to address the following questions, and update the FSAR and the reports involved, accordingly:

a. Clarify the intended applicability of the LOCA and non-LOCA TRs to the CRAM, including NuScale Nonproprietary

specification of the portions of those two TRs considered applicable to the CRAM,

b. Make any necessary associated changes to the scope of the LOCA TR and the non-LOCA TR, and

c. Demonstrate the applicability of those portions of the LOCA and non-LOCA TRs to the CRAM, and justify that the qualification activities in those TRs were adequate.

NuScale Response: During a January 16, 2019 public call, NuScale indicated that they would perform sensitivity analyses that evaluate the impact of using the (( }}2(a),(c) within the NRELAP5, on containment peak pressure. These sensitivity analyses were completed and provided for audit. During a subsequent February 22, 2019 meeting in the NuScale Rockville office, the staff requested the results of the sensitivity analyses, in a docketed RAI supplementary response. The following provides the information satisfying this request. As discussed in the response to eRAI 8990, transmitted by NuScale letter RAIO-1117-57291, dated November 20, 2017, NRELAP5 utilizes the newest published version of the ((

                   }}2(a),(c)

NuScale Nonproprietary

Two additional condensation models were incorporated in a version of NRELAP5, as heat transfer options so that sensitivity calculations could be performed, providing additional information to confirm the conclusions made by the response to eRAI 8990. The first additional condensation model ((

                                                                                   }}2(a),(c)

NuScale Nonproprietary

((

                                                                                           }}2(a),(c)

Model sensitivity results are provided by comparing results from the following three cases: ((

                                               }}2(a),(c)

NuScale Nonproprietary

((

                                                            }} 2(a),(c) No changes to the NuScale evaluation models are required.

Reference 1: Bejan, A. 2003. "Convection Heat Transfer", Third Edition, John Wiley and Sons, Inc. NuScale Nonproprietary

Table 1 NRELAP5 containment pressure response for limiting P&T case ((

                                                                              }}2(a),(c)

Figure 1. NRELAP5 NPM Containment Pressure Response for Limiting Pressure Case Impact on DCA: There are no impacts to the DCA as a result of this response. NuScale Nonproprietary

RAIO-0419-65122 : Affidavit of Zackary W. Rad, AF-0419-65123 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 develops its containment response analysis.

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-0419-65123

4. The information sought to be withheld is in the enclosed response to NRC Request for Additional Information No. 465, eRAI No.9494. 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 April 8, 2019. Zackary W. Rad AF-0419-65123}}