ML19203A321

LLC Supplemental Response to NRC Request for Additional Information No. 333 (Erai No. 9282) on the NuScale Design Certification Application

ML19203A321
Person / Time
Site:	NuScale
Issue date:	07/22/2019
From:	Rad Z NuScale
To:	Document Control Desk, Office of New Reactors
Shared Package
ML19203A320	List: ML19203A321
References
RAIO-0719-66386
Download: ML19203A321 (11)

Text

RAIO-0719-66386 July 22, 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. 333 (eRAI No. 9282) on the NuScale Design Certification Application

REFERENCES:

1. U.S. Nuclear Regulatory Commission, "Request for Additional Information No. 333 (eRAI No. 9282)," dated January 09, 2018

2. NuScale Power, LLC Response to NRC "Request for Additional Information No. 333 (eRAI No.9282)," dated March 08, 2018

3. NuScale Power, LLC Supplemental Response to NRC "Request for Additional Information No. 333 (eRAI No. 9282)," dated December 18, 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. 9282:

03.11-17 is the proprietary version of the NuScale Supplemental Response to NRC RAI No.

333 (eRAI No. 9282). 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 Carrie Fosaaen at 541-452-7126 or at cfosaaen@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-0719-66386 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. 9282, proprietary : NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9282, nonproprietary : Affidavit of Zackary W. Rad, AF-0719-66387 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0719-66386 :

NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9282, 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-0719-66386 :

NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 9282, 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.: 9282 Date of RAI Issue: 01/09/2018 NRC Question No.: 03.11-17 Regulatory Basis 10 CFR 52.47(a)(5) requires applicants to identify the kinds and quantities of radioactive materials expected to be produced in the operation and the means for controlling and limiting radiation exposures within the limits of 10 CFR Part 20. 10 CFR 50.49(e)(4) requires applicants to identify the type of radiation and the total dose expected during normal operation over the installed life of the equipment. Appendix A to Part 50General Design Criteria (GDC) for Nuclear Power Plants, Criterion 61Fuel storage and handling and radioactivity control, requires systems which may contain radioactivity to be designed with suitable shielding for radiation protection and with appropriate containment, confinement, and filtering systems. GDC 4 requires applicants to ensure that structures, systems, and components important to safety are designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operation. 10 CFR Part 20 requires the use of engineering features to control and minimize the amount of radiation exposure to occupational workers, from both internal and external sources. NuScale DSRS 12.2 DSRS and DSRS 3.11 Acceptance Criteria states that the applicant should describe the radiation fields in sufficient detail for evaluating the inputs to shielding codes, and determination of radiation dose to electrical equipment important to safety as described in 10 CFR 50.49, and GDC 4.

Background

NuScale DCD, Tier 2 Revision 0, Table 3C-6: Normal Operating Environmental Conditions, states that the 60 Years Integrated N Dose (Rads) for the area outside of the top of the Pressurizer is 6.00E7 rads (120 rads/hour). NuScale DCD, Tier 2, Revision 0, Chapter 12.2 Table 12.2-1: Core and Coolant Source Information, only provides the fission neutron source strength and the fission neutron spectrum, without specifying the neutron energy spectrum in NuScale Nonproprietary

areas such as above the pressurizer. NuScale Technical Report TR-0116-20781-P Rev. 0 Fluence Calculation Methodology and Results, Table 5-1 Best estimate of fluence expected to be experienced in various NuScale Power Module components and locations, describes the neutron fluence to the reactor vessel and containment vessel, in the vicinity of the core, but does not provide any neutron flux and spectrum information for the area above the pressurizer.

The Control Rod Drive Mechanisms (CRDM) are located in the area above the pressurizer and inside the containment vessel. DCD Tier 2, Revision 0, Table 4.5-1, Control Rod Drive Mechanism Materials, states that Stellite 6 may be used for Hard facing for latch arm tips, and the control rod remote disconnect expansion plugs use Haynes Alloy 25. Industry material specification data shows that for Stellite 6 Haynes Alloy 25, over 50% of the base metal consist of cobalt. Industry literature also shows that Alloy X-750 (UNS N07750) the cobalt impurity is limited to 1%. The CRDM springs use springs use Alloy X-750 (UNS N07750). Due to the relatively high neutron absorption cross section of cobalt, the relatively high resultant specific radioactivity and the quantity and energy of the emitted photons when cobalt 60 (Co-60) decays, the resultant gamma dose rates, the neutron spectrum and flux where cobalt is present, are important aspects of the DSRS 12.2 and DSRS 3.11 reviews.

The neutron spectrum and flux information evaluated during the staff review under NuScale DSRS 12.2, are used in the evaluation performed by the staff for NuScale DSRS 12.3-12.4 and DSRS 3.11, related to the acceptability of the shielding design, the establishment of radiation zones, the impact on systems, structures and components, and the activation of material.

NuScale DSRS 12.2 Acceptance Criteria, states that the source descriptions should include all pertinent information required for input to shielding codes used in the design process, establishment of related facility design features, and determination of radiation dose to electrical equipment important to safety as described in 10 CFR 50.49, and GDC 4, as well as the controlling radiation exposure to workers, consistent with 10 CFR 20 and GDC 61. DSRS 12.2 also states that unless described within other sections of the FSAR, source descriptions should include the methods, models, and assumptions used as the bases for all values provided in FSAR Section 12.2. These acceptance criteria are consistent with the relevant requirements of 10 CFR Part 50 and 10 CFR Part 52.

Key Issue: The neutron flux and energy spectrum are not well-defined nor is the derivation of these values. The staff needs to know the neutron flux, energy spectrum and appropriate supporting information to evaluate the impact on materials and components located inside of the containment vessel and above the reactor core. This information is needed to evaluate the environmental qualification of components, to assess the generation of activated corrosion NuScale Nonproprietary

products, and to confirm direct occupational radiation exposure of workers during refueling evolutions. Based on information made available to the staff during the RPAC Chapter 12 Audit, the staff was not able to characterize the neutron radiation fields in the aforementioned areas.

Question To facilitate staff understanding of the application information sufficient to make appropriate regulatory conclusions, the staff requests that the applicant:

Identify and describe the methods, models and assumptions used to calculate the neutron spectrum and flux above the top of the pressurizer, inside the containment vessel.

Provide data in NuScale DCD, Tier 2, Revision 0, Section 12.2 describing the neutron spectra and flux, at the area identified above, and the assumptions and input parameters used.

OR Provide the specific alternative approaches used and the associated justification.

NuScale Response:

This response supplements the previous responses to RAI 9282. During a teleconference meeting on June 25, 2019, NuScale agreed to provide the neutron flux spectra at the inner surface of the top of the CNV, to facilitate the closure of RAI 9282 and the related SER open item # 12.03-26. The neutron flux spectra is a result of the design basis shielding MCNP calculation of an operating NPM, providing neutron energy spectra for neutrons at the inner surface of the containment vessel head. ((2(a),(c) NuScale Nonproprietary

((

                                                          }} 2(a),(c)

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

RAIO-0719-66386 : Affidavit of Zackary W. Rad, AF-0719-66387 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 process by which NuScale develops its containment neutron doses.

NuScale has performed significant research and evaluation to develop a basis for this process 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-0719-66387

4. The information sought to be withheld is in the enclosed response to NRC Request for Additional Information No. 333, eRAI No. 9282. 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 July 22, 2019. Zackary W. Rad AF-0719-66387}}