ML19121A600

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LLC - Supplemental Response to NRC Request for Additional Information No. 202 (Erai No. 8911) on Design Certification Application
ML19121A600
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Issue date: 05/01/2019
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RAIO-0419-65386
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RAIO-0419-65386 May 1, 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. 202 (eRAI No. 8911) on the NuScale Design Certification Application

REFERENCES:

1. U.S. Nuclear Regulatory Commission, "Request for Additional Information No. 202 (eRAI No. 8911)," dated August 25, 2017
2. NuScale Power, LLC Response to NRC "Request for Additional Information No. 202 (eRAI No.8911)," dated December 21, 2018
3. NuScale Power, LLC Response to NRC "Request for Additional Information No. 202 (eRAI No. 8911)," dated April 9, 2019 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. 8911:

03.09.02-18 is the proprietary version of the NuScale Supplemental Response to NRC RAI No.

202 (eRAI No. 8911). 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 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0419-65386 Distribution: Gregory Cranston, NRC, OWFN-8H12 Samuel Lee, NRC, OWFN-8H12 Marieliz Vera, NRC, OWFN-8H12 : NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 8911, proprietary : NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 8911, nonproprietary : Affidavit of Zackary W. Rad, AF-0419-65387 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0419-65386 :

NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 8911, 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-0419-65386 :

NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 8911, 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 eRAI No.: 8911 Date of RAI Issue: 08/25/2017 NRC Question No.: 03.09.02-18 10 CFR 52.47 requires the design certification applicant to include a description and analysis of the structures, systems, and components (SSCs) sufficient to permit understanding of the system designs. TR-0916-51502-P, Rev. 0, NuScale Power Module Seismic Analysis describes the methodologies and structural models that are used to analyze the dynamic structural response due to seismic loads acting on the NuScale Power Module (NPM). The description is insufficient for staff to reach a safety finding. Specifically, the report does not provide the seismic and LOCA stress results. Please provide the seismic analysis details and stress results under Service Level D condition for the following reactor internals components.

Include the requested information in the NPM Seismic Report or in separate reports.

core support assembly (core barrel, lower core plate, reflector, upper core plate, upper core support) lower riser assembly upper riser assembly (upper riser, upper riser hanger support) control rod assembly guide tube, control rod assembly guide tube support, control rod assembly card, control rod drive shaft, and control rod drive shaft support steam generator tubes and tube supports control rod assembly guide tubes The component analysis should include a brief description of the component structure modelling, input motion (time history or in-structure response spectrum), major assumptions, acceptance criteria under Service Level D condition including stress and deflection limits, fluid modelling, mass distribution, damping values, gap considerations, dominant modes and frequencies, and seismic and LOCA stress results and ASME B&PV Code Section III stress evaluation under Service Level D condition.

NuScale Nonproprietary

NuScale Response:

The initial response to RAI 8911 Question 03.09.02-18 was submitted by NuScale letter RAIO-1218-63980, dated December 21, 2018. In a subsequent follow-up public meeting with NRC on January 22, 2019, additional questions were asked specific to the Reactor Vessel Internals (RVI) portion of this response.

Several of the followup 8911 Q18 (RVI) questions were discussed and acceptably resolved in the January 22, 2019 meeting. Those questions and responses are not repeated herein. The remaining 8911 Q18 (RVI) questions, that required additional action and/or previous response revision or supplemental information, are addressed below.

The following information addresses follow-up NRC 8911 Q18 (RVI) questions, and supersedes the original response under the subsection 'Reactor Vessel Internals (RVI)' in its entirety. Note that question numbering reflects the remaining open questions only.

Question RVI 1 - ASME Section III Appendix F-1321.3 requires consideration of gaps between part of the structures. CRDS and CRAGT have diametric gap as below.

CRDS CRAGT Diametric Gap (in) ((2(a),(c) Data from (( 

                }}2(a),(c)

Describe the boundary conditions at the diametric gaps (fixed or free) of CRDS and CRAGT and provide justification for not considering the gaps. NuScale response - Evaluation of the gap effect is currently in progress. The response to this question will be provided in another supplemental RAI response. Question RVI 2 - Provide FE mesh, dominant frequencies, mode shapes of CRDS. NuScale response - The FE mesh for the CRD shafts is provided in the attached Reactor Vessel Internals (RVI) Figure 12. The first four dominant frequencies and mode shapes were added in Figure 18. Note that although only one shaft is shown in Figure 18, the 16 shafts behave similarly. NuScale Nonproprietary

Question RVI 10 - The requirements of F-1335.4, Minimum Edge Distance in Line of Load are missing in the Table 'Threaded Structural Fastener.' Provide justification. NuScale response - From a review of the fasteners in the RVI, not all of the ASME criteria used in previous bolted joint qualifications are applicable. Fasteners evaluated in this calculation are the Upper Alignment Hanger Threaded Structural Fastener and Socket Head Cap Screw, which are classified as Internal Structure and Core Support Structure, respectively, in the NPM design drawings. Per the Design Specification, the Internal Structure is designed using NG-3000, which is the criteria for Core Support Structures. Therefore, all fasteners in this calculation are qualified using the rules for Core Support Structures. Since the ultimate strength of these threaded structural fasteners is less than 100 ksi, per ASME Code F-1440(d), the requirements F-1331.4, and therefore the rules of F-1335, are not applicable, and the stress limits are determined in accordance with either F-1331 or F-1341. Thus, the stress limits for the threaded structural fasteners analyzed in this calculation are determined in accordance with F-1331.1. Specifically, general primary membrane stress intensity is evaluated in accordance with F-1331.1(a) and the average primary shear stress across a section loaded in pure shear is evaluated in accordance with F-1331.1(d). The Pm+Pb criteria in F-1331.1(c) is not applicable because the bending moments on these fasteners are insignificant due to their arrangement. Table 8 Allowable Stress Limits for Level D, summarizes the updated applicable stress limits. This information has been included in the attached Reactor Vessel Internals (RVI) text, Acceptance criteria. Updated results are provided in Table 10. Question RVI 11 - In the Table, ASME BPVC compliance - components and the Table, ASME BPVC compliance - welds, list the location of the components where stress ratio is greater than 0.8. NuScale response - The locations where the stress ratio are greater than 0.8 have been summarized in Table 11 and Table 13 for components and welds, respectively. Question RVI 12 - Provide stress ratio for combined tensile and shear stress for Socket Head Cap Screw (i.e., bolted joint) of the core support block assembly in the Table, ASME BPVC compliance - components. Provide the stress ratio of shear pin, welds, and top plate and gusset plate (i.e., Plate and Shell Type Supports according to Table F-1200-1) of the core support block assembly. NuScale Nonproprietary

NuScale response - The socket head cap screw is part of the upper core plate joint and not part of the core support block joint. The fastener in the core support block assembly is a hex head cap screw. The requirements for the socket head cap screw are F-1331.1(a) and F-1331(d) (see the response to Question RVI 10 above and the updated Table 8 (following)). The combined tensile and shear stress criteria in F-1335.3(a) is not applicable to the socket head cap screw. The hex head cap screw, shear pin, welds, top plate and gusset plate of the core support block assembly were not initially in the scope of RVI. A change of the classification of these items from RPV to RVI is in progress. When the classification change is updated in the Design Specification, these RVI items will be included in the updated RVI calculation, and updated stress ratios provided in a supplemental RAI response (when seismic loads are finalized), as discussed with NRC in the January 22, 2019 public meeting (see response to RVI 20 following). Question RVI 13 - Describe how Pm, Pm + Pb are determined for all components modeled by solid element. Do they involve SCL (stress classification line)? If, yes, describe locations of the SCL. NuScale response - Whether or not path lines are used depends upon the stress results. If the maximum total stress intensity for a component is less than the Pm, the maximum total stress intensity is conservatively used for both Pm and (Pm+Pb) qualifications. Otherwise, path lines are assigned to calculate and print linearized stresses. Path lines were assigned in Lower Core Plate (LCP) and upper riser hanger ring models. Figure 19 has been added to the attached 'Reactor Vessels Internals (RVI)' text and shows the resulting stress intensity for the LCP model. Four path lines, shown in Figure 20, were created near the maximum stress intensity location. The path lines #1 and #2 are through the thickness of the plate, while the path lines #3 and #4 are through the radial ligament of the holes. For the upper riser hanger ring model, the resulting stress intensity for the analysis is shown in Figure

21. A total of 16 path lines (two for each hole), shown in Figure 22, are created near the highest stress locations.

The above discussions were added to the attached Reactor Vessel Internals (RVI) text Results 2. Stress results. Question RVI 15 - Provide modeling description and FE figures of CRD shaft, CRDS supports in upper riser, core barrel, reflector and lower riser. Lower Riser model is not described in the RAI response. NuScale Nonproprietary

NuScale response - The Core Barrel, Reflector, and Lower Riser are not analyzed using the FE method. They were analyzed using category 1 methodology (closed form equations). The CRD shaft and CRDS supports are in the Upper Riser Assembly (URA) model (see Figure 9). The FE figures for the CRD shaft and CRDS supports have been added in Figure 12 and Figure 13, respectively. The element types used in the model are listed in Table 4. The entire URA is constructed of type 304/304L stainless steel material, except for the CRD shafts which use type 410 stainless steel. As described in the attached Reactor Vessel Internals (RVI) text Component structural modeling 6. Upper riser assembly Item b, steel density was adjusted to account for fluid. Mass was added to account for the mass of the control rod assemblies. Constraints and coupling information are provided in Figure 11. Question RVI 16 - Provide element types for all the RVI components in Table 4 such as UCP, LCP, etc. NuScale response - Other than the URA model, five FE models were used in the RVI analyses. Their element types have been added in Table 5 through Table 7. Note the Upper Core Plate (UCP), LCP, and CRA Guide Tube Support Plate models use the same element types so they are grouped into one table. Question RVI 18 - Provide updated stress ratios when seismic loads in the NPM seismic analysis report Rev. 2 are available. NuScale response - Stress ratios will be finalized with updated seismic loads when available. These tables will be provided in a supplemental RAI response (when seismic loads are finalized), as discussed with NRC in the January 22, 2019 public meeting (see response to RVI 20 following). Question RVI 20 - Add Table 1, Analysis Methodology of Components, Table 2, Analysis Methodology of Welds, Table 3, Required Load Combination, Table 8, Allowable Stress limits in Level D, and Table 10, (Maximum Stress Ratio of Components), Table 12, (Maximum Stress Ratio of Welds), and Table 14, Maximum CRD Shaft Grid Relative Displacement to the seismic report. NuScale response - These tables will be finalized with updated seismic loads, as applicable, in a supplemental RAI response (when seismic loads are finalized), as discussed with NRC in the January 22, 2019 public meeting. NuScale Nonproprietary

Reactor Vessel Internals (RVI) Detailed stress analysis for the reactor vessel internals (RVI) under Service Level D conditions was performed in accordance with the American Society for Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPVC). Analysis details and stress results are summarized below. The components and welds included in this evaluation are listed in Table 1 and Table 2 below. Depending on whether seismic and loss of coolant accident (LOCA) forces and moments are available for a component under analysis, one of two major methodologies is used in this calculation. In the category 1 methodology, forces and moments are applied at the bounding cross section of the components and associated welds. For components with simple geometries, primary stresses are calculated using closed form equations. In the case of more complicated geometry, forces and moments are applied to a finite element (FE) model of the component and stresses are derived using a static FE analysis. The category 2 methodology is used when seismic and LOCA forces and moments are not available. In this case, response spectra are defined at the item supports and stresses are derived from the FE analysis. The applicable methodology for each component and weld included in this analysis is provided in Table 1 and Table 2. Assumptions

1. Applicable loss of coolant accident (LOCA) time history data: It is assumed that the LOCA loads obtained at the top of the upper riser and on the RPV at the bottom of the SG are bounding. The loads from locations along the length of the upper riser are not used because the upper riser in the blowdown model is not supported in the radial direction in the blowdown calculation. Actually, the upper riser is coupled to the RPV shell in the radial direction via the stacks of SG tube supports. Therefore, due to this coupling, it is assumed that the loads on the RPV are representative of the loads at corresponding elevations on the upper riser.
2. Bellows concentric plate dimensions: The dimensions of the URVI bellows concentric plates are not yet finalized as the component details are to be provided by the supplier.

The analysis performed on this component is based on a computer aided design (CAD) model.

3. Control rod drive mechanism (CRDM) SCRAM loads: A mechanical SCRAM load of

(( }}2(a),(c) per CRA is assumed in the analysis based on pre-test CRA drop test analysis. NuScale Nonproprietary

Input loading The load combinations applicable to this analysis are provided in Table 3. Each of the loads provided in Table 3 is discussed, below.

1. Operating pressure difference (PD): The operating pressure difference across the internals does not vary significantly for different power levels. Therefore, this load is not included in the analysis.
2. Deadweight (DW): For the category 1 methodology, DW is applied as reaction forces and moments. For the category 2 methodology, DW is added as a separate load step in the analysis.
3. Buoyancy (B): The reaction forces and moments (category 1 methodology) used for DW include buoyancy effects. For the category 2 methodology, buoyancy is not included and therefore the full DW is considered. This provides minimal conservatism as the full DW contributes a small amount of stress to the final stress as compared to other applicable Level D loads.
4. Mechanical Loads such as RVI support reactions, fuel assembly weight, SCRAM Loads (EXT): A mechanical SCRAM load of (( }}2(a),(c) per CRA is included in the analysis where applicable (see Assumption 3 above). Note that fuel assembly weight is included in the DW loading. RVI support reactions are captured in DW, LOCA, and SSE loads.
5. Rod ejection accident (REA): REA is not applicable.
6. Main steam pipe break/feedwater pipe break/design basis pipe break (MSPB/FWPB/LOCA): MSPB and FWPB loads are not applicable to the components analyzed in this evaluation. LOCA loads (i.e. design basis loss of coolant accident (LOCA) loads) are applied as reaction forces and moments or as accelerations in static analysis.
7. SSE (Safe Shutdown Earthquake): Reaction forces and moments, ISRS, or time histories are used. A constant composite structural damping ratio of 4% is used for the multi-point response spectrum analysis.

Based on the loading information provided above, the loads applicable to the lower core plate (LCP) analysis are DW + SCRAM +/- SRSS (SSE + LOCA). For other components, the required loads are DW +/- SRSS (SSE + LOCA). Component structural modeling Modeling details are provided below for components analyzed via FE analysis. NuScale Nonproprietary

1. Upper core plate (UCP)

Figure 1 shows the model of the UCP. The element types are provided in Table 5. Note the model was created based on a previous configuration of the bolt holes rather than the configuration currently documented in the NuScale Power Module (NPM) design drawings. This is acceptable because the boundary conditions are applied at the circumference of the UCP and no loads is applied on the bolt holes, so the bolt hole configuration has no effect on the analysis of the plate. (The stress evaluation of the UCP tabs is performed using the current configuration of the tab and closed form equations.) A static analysis is performed for the UCP. The applicable loads are the DW, SSE, and LOCA forces and moments (category 1 methodology) provided at the lower riser-UCP interface (( }}2(a),(c). The combined loads are applied to a single pilot node at the center of the UCP. This pilot node is connected to 36 slave nodes, as shown in Figure 1, where each slave node is created at the fuel assembly location. Each slave node is tied to each of the fuel pin holes using contact pairs. Therefore, the load is transferred from the pilot node to the slave nodes and then to the pin holes. This distributes the load across the entire plate for a realistic distribution of forces. The boundary conditions are applied at the circumference of the UCP. Here, all six degrees of freedom (DOF) are constrained as shown in Figure 1.

2. Lower core plate (LCP)

Figure 2 shows the model of the LCP. The element types are provided in Table 5. Some of the holes in the LCP are shifted or excluded from the FE model. The effect of these shifts or exclusions is negligible because the highest stresses in the LCP are in the grids (fuel assembly locations) and not near these holes. Therefore, using this FE model for stress analysis is acceptable. A static analysis is performed for the LCP. The applicable loads are the SCRAM vertical force and the DW, SSE, and LOCA forces and moments (category 1 methodology) provided at the reflector-LCP-core barrel interface (( }}2(a),(c). The combined loads are applied to a single pilot node at the center of the LCP. This pilot node was connected to 36 slave nodes, as shown in Figure 2, where each slave node is created at the fuel assembly location. Each slave node is tied to each of the fuel pin hole using contact pairs. Therefore, the load is transferred from the pilot node to the slave NuScale Nonproprietary

nodes and then to the pin holes. This distributes the load across the entire plate for a realistic distribution of forces. The boundary conditions are applied at the circumference of the LCP. Here, the six DOFs are constrained as shown in Figure 2.

3. Upper riser hanger ring Figure 3 shows the model of the upper riser hanger ring. The element types are provided in Table 6. This model was created based on a previous configuration of the hanger ring rather than the configuration currently documented in the NPM design drawings.

However, since the previous configuration has less total material and since the holes are larger in this configuration, the stresses and deformation calculated from the previous configuration is larger and thus more conservative. On the other hand, the new configuration adds approximately 650 lbm. This added mass has negligible effect on the upper riser hanger ring stress as compared to the other applicable loads. Therefore, it is acceptable to use the previous configuration for analysis. A static analysis is performed for the upper riser hanger ring. The applicable loads are the DW and SSE forces and moments (category 1 methodology) provided at each hanger brace and the LOCA loads provided at the center of the upper riser hanger ring. The combined loads are applied at the hanger brace attachment points in the local coordinate systems for the braces (note that the reactions at the hanger brace locations due to the LOCA loads at the center of the hanger ring are determined before the loads are combined). The ring is constrained in the Y translation DOF at the 8 bolt holes which attach the hanger ring to the baffle plate. The horizontal translational DOFs at these locations are not constrained because the horizontal loads are not carried by these threaded fasteners. Instead, the horizontal constraints are applied to a side surface of the ring to represent the confinement below the Upper Riser Hanger Braces. This is shown in Figure 3.

4. Control rod assembly (CRA) guide tube assembly
a. Overview The CRA guide tube assembly is composed of four components: CRA guide tube, CRA cards, CRD shaft alignment cone, and CRA lower flange. There are no available loads in form of forces and moments for the CRA guide tube assembly. Loads acting NuScale Nonproprietary

on the assembly are generated by performing a response spectra analysis for SSE loads and a static analysis of LOCA accelerations (category 2 methodology). Prior to the SSE response spectrum analysis, a modal analysis is performed. The modal analysis is run for 100 modes to capture the dynamic effect due to seismic events. Considering the control rod assembly in a variety of parking positions (see Fluid modeling and mass distribution information, below), three ANSYS analyses are performed. Figure 4 shows the basic geometry and mesh of the CRA guide tube assembly model. The element types are provided in Table 7. Figure 5 shows pilot nodes at which the response spectra are applied. This figure also shows the simulated constraints with the guide tube support plate (GTSP) and the UCP. These constraints are realized through multi-point constraint (MPC), as shown in Figure 6. CRA cards, the alignment cone, and the lower flange are also attached to the tube via bonded contact elements as shown in the same figure.

b. Fluid modeling and mass distribution To account for added mass of water inside the CRA guide tube assembly, the mass density of the CRA tube is adjusted by adding the mass of water contained inside the CRA guide tube assembly.

Interaction (parking) of the control rod is also accounted for. The control rod may be in a variety of positions - from rod completely inserted into fuel to fully elevated. In case of fully inserted control rods, only the alignment cone supports part of the CRD shaft. In the case of the control rods in the fully elevated position, the entire CRA guide tube assembly provides support for the CRD shaft. The interaction of the control rods is simulated using mass elements. For conservatism, the entire mass of the control rods is imposed on the alignment cone for the case of the rod completely elevated. Similarly, for the cases where the rod is partially elevated, the entire mass of the control rod is distributed to two of the longest fingers of the top card and then, in a separate run, the entire mass of the control rod is distributed to the second card from top of the CRA guide tube. The added mass locations for these three cases are illustrated in Figure 7.

5. CRA guide tube support plate (GTSP)

NuScale Nonproprietary

The CRA GTSP supports the top of the CRA. Static analysis is performed on the CRA GTSP. Loads acting on the CRA GTSP are extracted from the CRA analysis documented above (category 1 methodology). There are 16 CRAs supported by the CRA GTSP. The 16 locations are loaded through pilot nodes that distribute loads into the interface of the plate with the CRAs. Figure 8 shows the CRA GTSP model and boundary conditions. The element types are provided in Table 5. Connection of the CRA GTSP to the lower riser spacer is not modeled. Nodes at the CRA GTSP-spacer interface are instead constrained in all degrees of freedom. This simplification has negligible impact on stresses and is therefore acceptable.

6. Upper riser assembly
a. Overview The Upper Riser Assembly (URA) is composed of upper CRD shaft supports, upper riser transition, upper riser section, upper riser hanger ring, upper riser hanger braces, and upper riser bellows. The 16 CRD shafts are also included in the structural model.

The entire URA is made of type 304/304L stainless steel material, except for the CRD shafts which use type 410 stainless steel. There are no available loads in form of forces and moments for the URA, with the exception of the interface loads at the top of the upper riser hangers. Loads acting on the URA have are generated by performing a response spectra analysis for SSE loads and static analyses of LOCA accelerations (category 2 methodology). Prior to the SSE response spectrum analysis, the modal analysis was run for 2000 modes in order to capture an effective mass of at least 80 percent. Figure 9 depicts the basic geometry and mesh of the URA model. The element types used in the model are listed in Table 4. The contacts are bonded except bellows lateral restraints as shown in Figure 10. Constraints of the model are illustrated in Figure 11. The FE meshes for the CRD shaft and CRDS supports are shown in Figure 12 and Figure 13, respectively.

b. Fluid modeling and mass distribution To account for added mass of water inside the URA, the mass density of the URA is adjusted by adding the mass of water contained inside the URA assembly. A similar approach is taken for the drive shafts; the total mass is evenly distributed in PIPE288 elements. MASS21 elements are added to the ends of the drive shafts to account for the mass of the control rod assemblies.

NuScale Nonproprietary

Acceptance criteria Per paragraph NG-3225 of Section III, Subsection NG, the rules of ASME BPVC Appendix F are to be used for Level D conditions. In addition, when the special stress limits of NG-3227 are applicable for Level D Limits, the calculated stresses shall not exceed twice the stress limits given in NG-3227 as applied for Level A and Level B Service Limits. The applicable qualification criteria from ASME BPVC Table F-1200-1 and paragraph NG-3227 are summarized as follows:

1. F-1331.1 for general primary membrane stresses, local primary membrane stresses, general or local membrane plus bending primary stresses for components.
2. NG-3227.1(a) for bearing stress for components. Note that F-1331.3 is bounded by NG-3227.1(a).
3. F-1331.1(d) and NG-3227.2(a) for average primary pure shear stress of components.
4. F-1334.3 and F-1334.5 for buckling of components.
5. F-1331.1(a) for allowable tensile stress of threaded structural fasteners.
6. F-1331.1(d) for allowable shear stress of threaded structural fasteners.

The fasteners evaluated in this calculation are the Upper Alignment Hanger Threaded Structural Fastener and Socket Head Cap Screw. These are classified as Internal Structure and Core Support Structure, respectively, in the NPM design drawings. Per the Design Specification, the Internal Structure is designed using NG-3000, which defines the criteria for Core Support Structures. Therefore, the fasteners in this calculation are qualified using the rules for Core Support Structures. Since the ultimate strength of these threaded structural fasteners is less than 100 ksi, per ASME BPVC F-1440(d), the requirements F-1331.4, and therefore the rules of F-1335, are not applicable. Additionally, the special stress limits defined in NG-3227 are not applicable to threaded structural fasteners. Thus, the stress limits for the threaded structural fasteners analyzed in this calculation are determined in accordance with F-1331.1. Specifically, general primary membrane stress intensity is evaluated in accordance with F-1331.1(a) and the average primary shear stress across a section loaded in pure shear is evaluated in accordance with F-1331.1(d). The Pm+Pb criteria in F-1331.1(c) is not needed because the bending moments on these fasteners are insignificant due to their arrangement. Table 8 summarizes the applicable stress limits. NuScale Nonproprietary

The qualification criterion for welds is provided in ASME BPVC paragraph NG-3352 and is noted below: The quality factor is used by multiplying the allowable stress limit for primary and secondary categories times the quality factor in evaluating the design. The use of weld quality factor n is for static, not fatigue applications. Therefore, the allowable stresses for welds are the stress limits in Table 8 multiplied by a quality factor n, where n is provided in ASME BPVC Table NG-3352-1. Table 9 summarizes weld types and their applicable quality factors. Relative displacements between adjacent the control rod drive (CRD) shaft grids are evaluated. Note that there are no specific limits for the displacements and results are provided for information only. Results

1. Modal results
a. CRA guide tube assembly The modal results from CRA_1 analysis are shown in Figure 14, indicating the major horizontal modes are at (( }}2(a),(c) Hz and major vertical mode at (( }}2(a),(c) Hz.

Figure 15 shows the modal shape of the first horizontal major mode. The results for CRA_2 and CRA_3 are in a similar trend except that the major horizontal modes for CRA_2 and CRA_3 are (( }}2(a),(c) Hz and (( }}2(a),(c) Hz, respectively.

b. Upper riser assembly The modal results are shown in Figure 16 and Figure 17, indicating the major horizontal mode at (( }}2(a),(c) Hz and major vertical mode at (( }}2(a),(c) Hz. The first four dominant frequencies and mode shapes for the CRD shaft are shown in Figure
18. Note that while only one shaft is illustrated, all 16 shafts behave the same.
2. Stress results Stress results are compared to ASME BPVC requirements in Table 10 and Table 12 for components and welds, respectively. The locations where the stress ratio are greater NuScale Nonproprietary

than 0.8 are summarized in Table 11 and Table 13 for components and welds, respectively. Whether or not path lines are used is dependent upon the stress results. If the maximum total stress intensity for a component is less than the Pm, the maximum total stress intensity is conservatively used for both Pm and (Pm+Pb) qualifications. Otherwise, path lines are assigned to calculate and print linearized stresses. Path lines were assigned in LCP and upper riser hanger ring. For the LCP model, the resulting stress intensity for the analysis is shown in Figure 19. Four path lines, shown in Figure 20, were created near the maximum stress intensity location. The path lines #1 and #2 are through the thickness of the plate, while the path lines #3 and #4 are through the radial ligament of the holes. For the upper riser hanger ring model, the resulting stress intensity for the analysis is shown in Figure 21. A total of 16 path lines (two for each hole), shown in Figure 22, are created near the highest stress locations.

3. Deflections Maximum relative displacements between adjacent CRD shaft grids are provided in Table 14. Since the maximum value ((( }}2(a),(c)) is insignificant, it is concluded that the CRD shafts do not experience excessive displacements.

Conclusions The analysis described above demonstrates that the design of the RVI satisfies the structural requirements of the ASME BPVC for Service Level D loads. NuScale Nonproprietary

Table 1. Components Item Part Number Methodology Upper Riser Transition A023.300 1 Upper Riser Section A023.301 2 Upper CRD Shaft Support A023.305 2 Top CRD Shaft Support A023.312 2 Upper Riser Hanger Ring A023.306 1 Upper Riser Hanger Brace A023.307 1 Upper Alignment Hanger Threaded Structural A023.309 1 Fastener Upper Riser Bellows A023.310 2 Upper Core Plate (UCP) A023.200 1 Lower Riser Section A023.201 1 Lower Riser Transition A023.202 1 Lower Riser Spacer A023.203 1 In-core Instrument Guide Tube (ICIGT) Support A023.210 2 CRA Guide Tube Support Plate (GTSP) A023.230 1 CRA Guide Tube A023.231 2 CRD Shaft Alignment Cone A023.232 2 CRA Card A023.233 2 CRA Lower Flange A023.234 2 Fuel Pin Cap A023.250 1 Fuel Pin A023.251 1 A023.061 1 Core Barrel A023.009 1 Reflector Block A023.044-046 1 Upper Support Block A023.047-048 1 Reflector Block Alignment Pin A023.049 1 Lower Core Plate (LCP) A023.008 1 Socket Head Cap Screw A011.043 1 Control Rod Drive Shaft 01D4484H01, 2 01D4485H01, 01D4486H01, (Drive Shaft Sections) NuScale Nonproprietary

Table 2. Welds Weld Number Description Methodology A023.300.001 Upper Riser Transition Seam 1 A023.301.001 Upper Riser Section Seam 1 A023.305A-H.001 - Upper CRD Shaft Support 2 A023.305A-H.008 A023.307A-H.001 Brace to Upper Riser Hanger Ring 1 A023.307A-H.002 Brace to Upper Riser Section 1 A023.310.001 Upper Riser to Bellows 1 A023.310.002 Bellows to Upper Riser Transition 1 A023.200.001 Lower Riser to UCP 1 A023.201.001 Lower Riser Section 1 A023.202.001 Lower Riser Transition 1 A023.203.001 Lower Riser Spacer 1 A023.203.001A Lower Riser Spacer to Lower Riser Section 1 A023.203.002 Lower Riser Transition to Lower Riser Spacer 1 A023.210.001A-H ICIGT Support to Lower Riser Transition 1 A023.230.001A-D CRA GTSP to Lower Riser Spacer 1 A023.231.001A-P CRA Lower Flange to CRA Guide Tube 2 A023.231.002A-P - CRA Card to CRA Guide Tube 2 A023.231.009A-P A023.231.010A-P - CRDS Alignment Cone 2 A023.231.013A-P A023.009.001 - Upper Support Block 1 A023.009.004 A023.008.001 Core Barrel to LCP 1 Table 3. Required load combinations Plant Event Service Level Load Combination Allowable Limit Rod Ejection Accident D PD + DW + B + EXT + REA Level C Main Steam and Feedwater D PD + DW + B + EXT + MSPB- Level D Pipe Breaks FWPB SSE + DBPB-MSPB-FWPB D PD + DW + B + EXT +/- SRSS Level D (SSE + LOCA-MSPB-FWPB) Note: SRSS is the square root sum of the squares NuScale Nonproprietary

Table 4. Element types in URA model Item Element Type Control Rod Drive Shaft PIPE288 URVI Section SHELL181 Control Rod mass MASS21 contact pairs TARGE170, CONTA174, CONTA175 other components SOLID45 Table 5. Element types in UCP, LCP, and CRA Guide Tube Support Plate models Item Element Type Section SOLID45 contact pairs (for scoped pilot TARGE170, node to apply loads) CONTA174 NuScale Nonproprietary

Table 6. Element types in upper riser hanger ring model (ANSYS Workbench) Item Element Type Section SOLID187, SOLID186 contact pairs (for scoped pilot node to TARGE170, apply moment loads) CONTA174 Non-structural surface to apply pressure SURF154 (converted from force loads) Table 7. Element types in CRA Guide Tube Assembly model Item Element Type CRA Guide Tube (teal in Figure 4) SHELL181 Other components (purple in Figure 4) SOLID45 contact pairs (for scoped pilot node to apply TARGE170, loads and to bond Shell and Solid elements) CONTA174, CONTA175 Control Rod mass MASS21 NuScale Nonproprietary

Table 8. Allowable stress limits for Level D Stress Category Code Criterion Paragraph Component General primary membrane F-1331.1(a) lesser of 2.4Sm and 0.7Su stress, Pm Local primary membrane F-1331.1(b) 1.5Pm stress, Pl General or local primary F-1331.1(c)(1) 1.5Pm membrane plus bending stress, Pm+Pb Bearing stress NG-3227.1(a) 2Sy(1) Average primary pure shear F-1331.1(d), lesser of 0.42Su and 1.2Sm stress NG-3227.2(a) Compressive loads F-1334.3, Multiple criteria F-1334.5 Threaded Tensile stress F-1331.1(a) lesser of 2.4Sm and 0.7Su Structural Shear stress F-1331.1(d) 0.42Su Fastener(2) Notes:

1. This is for general bearing stress, which bounds the 2.1Su (F-1336 for pinned joints) and 3Sy (NG-3227.1(a) for bearing stress distance to free edge distance larger than distance over which the bearing load is applied).

Therefore, the 2Sy limit is conservatively used in this document.

2. See the Acceptance criteria section, 3rd through 5th paragraphs.

NuScale Nonproprietary

Table 9. Weld geometry summary Component 1 Component 2 Weld Geometry and Weld Category Quality Size and Type Factor n(1) Upper Riser Hanger Upper Riser Hanger (( Category E, 0.55(2) Brace (A023.307) Ring (A023.306) Type VI Upper Riser Hanger Upper Riser Section Category E, 0.35 Brace (A023.307) (A023.301) Type VI Upper CRDS Support Upper Riser Section Category E, 0.4 (A023.305) (A023.301) Type IV Upper Riser Bellows Upper Riser Category B, 0.5 (A023.310) Transition Type I (A023.300) ICIGT Support Lower Riser Category E, 0.4 (A023.210) Transition Type IV (A023.202) Lower Riser Spacer Lower Riser Section Category B, 0.5 (A023.203) (A023.201) Type II Lower Riser Section Upper Core Plate Category C, 0.5 (A023.201) (A023.200) Type III CRA GTSP Lower Riser Spacer Category E, 0.5 (A023.230) (A023.203) Type III CRA Guide Tube CRA Alignment Category E, 0.3 (A023.231) Cone (A023.232) Type VIII CRA Card (A023.233) CRA Guide Tube Category C, 0.5 (A023.231) Type III CRA Lower Flange CRA Guide Tube Category C, 0.5 (A023.234) (A023.231) Type III Upper Support Block Core Barrel Category E, 0.4 (A023.048) (A023.009) Type IV Core Barrel Lower Core Plate Category C, 0.5 (A023.009) (A023.008) Type III Upper Riser Section Upper Riser Bellows Category B, 0.5 (A023.301) (A023.310) Type I Lower Riser Lower Riser Spacer Category C, 0.5 2(a),(c) Transition (A023.202) (A023.203) }} Type III Notes:

1. Assuming using surface visual examination method except note (2).
2. Assuming using progressive UT examination method based on the geometry NuScale Nonproprietary

Table 10. ASME BPVC compliance - components Item (Part Number) Stress Type Stress Ratio Upper Riser Transition Pm (( }}2(a),(c) (A023.300) Pm+Pb (( }}2(a),(c) (( }}2(a),(c) Upper Riser Section Pm (( }}2(a),(c) (A023.301) Pm+Pb (( }}2(a),(c) Upper CRDS Support Pm (( }}2(a),(c) (A023.305) Pm+Pb (( }}2(a),(c) Upper Riser Hanger Ring Pm (( }}2(a),(c) (A023.306) Pm+Pb (( }}2(a),(c) Upper Riser Hanger Brace Pm (( }}2(a),(c) (A023.307) Pm+Pb (( }}2(a),(c) (( }}2(a),(c) Upper Alignment Hanger Tensile stress in stud, ns (( }}2(a),(c) Threaded Structural Fastener Shear stress in stud threads, s (( }}2(a),(c) (A023.309) Shear stress in hanger ring (( }}2(a),(c) threads, t Upper Riser Bellows Pm (( }}2(a),(c) (A023.310) Pm+Pb (( }}2(a),(c) Upper Core Plate (tabs) Pm (( }}2(a),(c) (A023.200) Pm+Pb (( }}2(a),(c) (( }}2(a),(c) bearing (( }}2(a),(c) Upper Core Plate (A023.200) Pm (( }}2(a),(c) Pm+Pb (( }}2(a),(c) Lower Riser Section Pm (( }}2(a),(c) (A023.201) Pm+Pb (( }}2(a),(c) (( }}2(a),(c) Compressive stress, bu_c (( }}2(a),(c) Combined axial compression and (( }}2(a),(c) bending, NF-3322.1(e)(1), eq. 20, bu_cs_20 Combined axial compression and (( }}2(a),(c) bending, NF-3322.1(e)(1), eq. 21, bu_cs_21 Combined axial compression and (( }}2(a),(c) bending, NF-3322.1(e)(1), eq. 22, bu_cs_22 Lower Riser Transition Pm (( }}2(a),(c) (A023.202) Pm+Pb (( }}2(a),(c) (( }}2(a),(c) NuScale Nonproprietary

Lower Riser Spacer Pm (( }}2(a),(c) (A023.203) Pm+Pb (( }}2(a),(c) (( }}2(a),(c) ICIGT Support (A023.210) N/A(1) N/A CRA Guide Tube Support Pm (( }}2(a),(c) Plate (A023.230) Pm+Pb (( }}2(a),(c) CRA Guide Tube (A023.231) Pm (( }}2(a),(c) CRDS Alignment Cone (A023.232) CRA Card (A023.233) Pm+Pb (( }}2(a),(c) CRA Lower Flange (A023.234) bearing (( }}2(a),(c) CRA Guide Tube (A023.231) Compressive stress, bu_c (( }}2(a),(c) Combined axial compression and (( }}2(a),(c) bending, NF-3322.1(e)(1), eq. 20, bu_cs_20 Combined axial compression and (( }}2(a),(c) bending, NF-3322.1(e)(1), eq. 21, bu_cs_21 Combined axial compression and (( }}2(a),(c) bending, NF-3322.1(e)(1), eq. 22, bu_cs_22 Fuel Pin and Cap (A023.250, Pm+Pb (( }}2(a),(c) A023.251, A023.061) (( }}2(a),(c) Core Barrel (A023.009) Pm (( }}2(a),(c) Pm+Pb (( }}2(a),(c) (( }}2(a),(c) Compressive stress, bu_c (( }}2(a),(c) Combined axial compression and (( }}2(a),(c) bending, NF-3322.1(e)(1), eq. 20, bu_cs_20 Combined axial compression and (( }}2(a),(c) bending, NF-3322.1(e)(1), eq. 21, bu_cs_21 Combined axial compression and (( }}2(a),(c) bending, NF-3322.1(e)(1), eq. 22, bu_cs_22 Reflector Block (A023.044, Pm (( }}2(a),(c) A023.045, A023.046) Pm+Pb (( }}2(a),(c) (( }}2(a),(c) bearing (( }}2(a),(c) Upper Support Block Pm (( }}2(a),(c) (A023.047) Pm+Pb (( }}2(a),(c) (( }}2(a),(c) NuScale Nonproprietary

Reflector Block Alignment Pin (( }}2(a),(c) (A023.049) bearing (( }}2(a),(c) Lower Core Plate (A023.008) Pm (( }}2(a),(c) Pm+Pb (( }}2(a),(c) Lower Core Plate (tabs) Pm (( }}2(a),(c) (A023.008) Pm+Pb (( }}2(a),(c) (( }}2(a),(c) bearing (( }}2(a),(c) Socket Head Cap Screw Tensile stress in screw, ns (( }}2(a),(c) (A011.043) Shear stress in screw threads, s (( }}2(a),(c) Shear stress in upper support block (( }}2(a),(c) threads, n Control Rod Drive Shaft (All Pm (( }}2(a),(c) Parts of Assembly) Pm+Pb (( }}2(a),(c) Note:

1. This component is similar in location and configuration to the lowest upper CRD shaft support. Thus, the evaluation of the CRD shaft support is used to determine acceptability of the ICIGT support.

Table 11. Location of components where stress ratio is greater than 0.8 Item (Part Number) Location Upper Riser Section (A023.301) top of URA shell connecting to brace bottom Upper CRD Shaft Support (A023.305) the bottom CRDS support (grid 5) CRA Guide Tube Support Plate bottom of the support plate where a ring (A023.230) transitions to one of the four horizontal bars Table 12. ASME BPVC compliance - welds Item 1 (Part Number) Item 2 (Part Number) Stress Type Stress Ratio Upper Riser Hanger Upper Riser Hanger Pm (( }}2(a),(c) Brace (A023.307) Ring (A023.306) Pm+Pb (( }}2(a),(c) (( }}2(a),(c) Upper Riser Hanger Upper Riser Section Pm (( }}2(a),(c) Brace (A023.307) (A023.301) Pm+Pb (( }}2(a),(c) (( }}2(a),(c) Upper CRDS Support Upper Riser Section Pm (( }}2(a),(c) (A023.305) (A023.301) Pm+Pb (( }}2(a),(c) (( }}2(a),(c) Upper Riser Bellows Upper Riser Transition Pm (( }}2(a),(c) (A023.310) (A023.300) Pm+Pb (( }}2(a),(c) (( }}2(a),(c) NuScale Nonproprietary

ICIGT Support Lower Riser Transition N/A(1) N/A (A023.210) (A023.202) Lower Riser Spacer Lower Riser Section Pm (( }}2(a),(c) (A023.203) (A023.201) Pm+Pb (( }}2(a),(c) (( }}2(a),(c) Lower Riser Section Upper Core Plate Pm (( }}2(a),(c) (A023.201) (A023.200) Pm+Pb (( }}2(a),(c) (( }}2(a),(c) CRA GTSP (A023.230) Lower Riser Spacer Pm (( }}2(a),(c) (A023.203) Pm+Pb (( }}2(a),(c) (( }}2(a),(c) CRA Guide Tube CRA Alignment Cone (( }}2(a),(c) (A023.231) (A023.232) CRA Card (A023.233) CRA Guide Tube (( }}2(a),(c) (A023.231) CRA Lower Flange CRA Guide Tube (( }}2(a),(c) (A023.234) (A023.231) Upper Support Block Core Barrel (A023.009) Pm (( }}2(a),(c) (A023.048) Pm+Pb (( }}2(a),(c) (( }}2(a),(c) Core Barrel (A023.009) Lower Core Plate Pm (( }}2(a),(c) (A023.008) Pm+Pb (( }}2(a),(c) (( }}2(a),(c) Upper Riser Section Upper Riser Bellows N/A(2) N/A (A023.301) (A023.310) Lower Riser Transition Lower Riser Spacer Pm (( }}2(a),(c) (A023.202) (A023.203) Pm+Pb (( }}2(a),(c) (( }}2(a),(c) Notes:

1. The weld evaluation is bounded by the evaluation for the upper CRD shaft-upper riser section weld.
2. The weld evaluation is bounded by the evaluation for the upper riser bellows-upper riser transition weld.

NuScale Nonproprietary

Table 13. Location of welds where stress ratio is greater than 0.8 Item 1 (Part Number) Item 2 (Part Number) Location Upper Riser Hanger Upper Riser Hanger corner of the brace top, where a brace is Brace (A023.307) Ring (A023.306) welded to the upper riser hanger ring Upper CRD Shaft Upper Riser Section "foot" of the bottom CRDS support (grid 5) Support (A023.305) (A023.301) CRA GTSP Lower Riser Spacer corner (A023.230) (A023.203) Table 14. Maximum CRD shaft grid relative displacements (inch) X (Hori.) Y (Vert.) Z (Hori.) Horizontal Final Grid 1~2 (( Grid 2~3 Grid 3~4 Grid 4~5 }}2(a),(c) NuScale Nonproprietary

(( 

                                                           }}2(a),(c)

Figure 1. Upper core plate model and boundary conditions NuScale Nonproprietary

(( 

                                                 }}2(a),(c)

Figure 2. Lower core plate boundary conditions NuScale Nonproprietary

(( 

                                                        }}2(a),(c)

Figure 3. Upper riser hanger ring boundary conditions NuScale Nonproprietary

(( 

                                               }}2(a),(c)

Figure 4. CRA model (( 

                                               }}2(a),(c)

Figure 5. Location of pilot nodes NuScale Nonproprietary

(( 

                                            }}2(a),(c)

Figure 6. CRA bonded connections NuScale Nonproprietary

(( 

                                                       }}2(a),(c)

Figure 7. Control rod mass locations for three cases (( 

                                                       }}2(a),(c)

Figure 8. CRA GTSP model NuScale Nonproprietary

(( 

                                               }}2(a),(c)

Figure 9. Upper riser assembly model NuScale Nonproprietary

(( 

                                                     }}2(a),(c)

Figure 10. Bellows profile and constraint location NuScale Nonproprietary

(( 

                                              }}2(a),(c)

Figure 11. Constraints at URA NuScale Nonproprietary

(( 

                                              }}2(a),(c)

Figure 12. CRD shaft FE mesh NuScale Nonproprietary

(( 

                                            }}2(a),(c)

Figure 13. CRDS supports NuScale Nonproprietary

(( 

                                              }}2(a),(c)

Figure 14. Modal analysis results for CRA_1 NuScale Nonproprietary

(( 

                                               }}2(a),(c)

Figure 15. First major mode shape for CRA_1 NuScale Nonproprietary

(( 

                                             }}2(a),(c)

Figure 16. Modal analysis results for URA NuScale Nonproprietary

(( 

                                                    }}2(a),(c)

Figure 17. First major lateral mode shape for URA NuScale Nonproprietary

(( 

                                                   }}2(a),(c)

Figure 18. CRD shaft major modes and mode shapes NuScale Nonproprietary

(( 

                                              }}2(a),(c)

Figure 19. LCP stress intensity NuScale Nonproprietary

(( 

                                               }}2(a),(c)

Figure 20. Location of path lines for LCP NuScale Nonproprietary

(( 

                                                      }}2(a),(c)

Figure 21. Upper riser hanger ring stress intensity NuScale Nonproprietary

(( 

                                                                }}2(a),(c)

Figure 22. Location of path lines for upper riser hanger ring NuScale Nonproprietary

RAIO-0419-65386 : Affidavit of Zackary W. Rad, AF-0419-65387 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 power module seismic 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-0419-65387

4. The information sought to be withheld is in the enclosed response to NRC Request for Additional Information No. 202, eRAI No. 8911. 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 May 1, 2019. Zackary W. Rad AF-0419-65387}}

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