ML19203A342

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LLC Supplemental Response to NRC Request for Additional Information No. 154 (Erai No. 8938) on the NuScale Design Certification Application
ML19203A342
Person / Time
Site: NuScale
Issue date: 07/22/2019
From: Rad Z
NuScale
To:
Document Control Desk, Office of New Reactors
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ML19203A341 List:
References
RAIO-0716-66374
Download: ML19203A342 (48)
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RAIO-0716-66374 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. 154 (eRAI No. 8938) on the NuScale Design Certification Application

REFERENCES:

1. U.S. Nuclear Regulatory Commission, "Request for Additional Information No. 154 (eRAI No. 8938)," dated August 07, 2017
2. NuScale Power, LLC Response to NRC "Request for Additional Information No. 154 (eRAI No.8938)," dated December 05, 2018
3. NuScale Power, LLC Supplemental Response to NRC "Request for Additional Information No. 154 (eRAI No. 8938)," dated January 24, 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. 8938:

  • 03.12-1 Enclosure 1 is the proprietary version of the NuScale Supplemental Response to NRC RAI No.

154 (eRAI No. 8938). 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-0716-66374 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. 8938, proprietary : NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 8938, nonproprietary : Affidavit of Zackary W. Rad, AF-0719-66375 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com

RAIO-0716-66374 :

NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 8938, 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-0716-66374 :

NuScale Supplemental Response to NRC Request for Additional Information eRAI No. 8938, 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.: 8938 Date of RAI Issue: 08/07/2017 NRC Question No.: 03.12-1 SECY-90-377 and the NRC white paper on piping level of detail for design certification (ML14065A067) discuss the design information that is required at design certification without the need for design acceptance criteria (DAC) for the NRC staff to be able to make a final safety determination on piping issues at the design certification stage that meets the applicable requirements of 10 CFR 52. Specific to FSAR Tier 2, Section 3.12, provide the following information to support the staffs safety determination.

1. To demonstrate that the piping, which has been structurally evaluated based on the graded approach described in FSAR Tier 2, Section 14.3.2.3, conforms to the requirements of ASME Boiler and Pressure Vessel Code (BPV Code)Section III, mandated by 10 CFR 50.55a, provide the following information in response to this request. The information need not be included in the FSAR unless the applicant chooses to do so.

a) A tabulated, quantitative summary of the calculated maximum stresses and fatigue usage factors (if applicable) with a comparison to ASME BPV Code allowable stress values for each code equation. Include only maximum stresses and data at critical locations, including anchors, flued head anchor penetrations, nozzles, penetrations, flanged connections, valve and relief valve connections, branching pipe connections and pipe supports. List all applicable loads in load combination cases for each service level and code equation.

b) For equipment nozzles, a tabulated quantitative summary of the calculated reaction loads compared to specific nozzle allowable values.

NuScale Nonproprietary

c) For containment penetrations, quantitative maximum calculated results compared to allowable values from the penetration structural qualifications which include loads from both sides of the penetration.

NuScale Response:

The original response to this question was submitted by NuScale letter RAIO-1218-63709 on December 5, 2018, providing the stress analysis results for the Reactor Coolant System (RCS) discharge line and for the main steam (MS) and feedwater (FW) lines, inside and outside of the containment vessel (CNV). This response was later supplemented with stress analysis results for the MS piping in the area above containment, by NuScale letter RAIO-0119-64288 dated January 24, 2019.

This supplement provides final stress analysis results, reflecting the completion of the detailed piping evaluations for the high-energy systems inside and outside of the CNV. This information supersedes the original and Supplement 1 responses in their entirety.

NuScale has utilized a 'graded level of detail approach' for evaluation of the NPM piping. As part of this approach, detailed stress analyses were performed for representative systems: the RCS discharge line, the main steam lines, and the feedwater lines.

A description of the requested piping stress analysis and a quantitative summary of the analysis results is provided below.

Stress results are summarized by listing the locations with the highest stress ratio for each code equation. However, in order to provide a clearer picture of the overall stress state in the system, reporting the results for nodes that are in close proximity or similar locations is avoided.

Examples are provided for clarification.

  • Example 1: If the branch side of a tee joint has the highest stress, then the connecting branch pipe joint adjacent to the tee is not chosen as the second highest stress location.

These are considered one location.

  • Example 2: In the case of the main steam lines, Line 1 and Line 2 have similar geometries. If one of the four RPV nozzle locations has the highest stress, the other three RPV nozzle locations having similarly high stress are not chosen as the next highest stress location. These are all considered to represent one location.

NuScale Nonproprietary

Loads acting on the nozzles of the RPV and CNV are also listed; however, they are not compared to allowable loads. Instead, these loads are used as inputs to the the RPV and CNV stress analyses. Piping sizes in the NuScale design are relatively small compared to traditional PWRs and the CNV penetrations robust. Therefore, nozzle loads for the NuScale NPM are not a limiting design consideration. Other notes are provided below for clarification.

1. The loads applicable to each loading combination are provided in FSAR Table 3.12-1 for Class 1 piping and FSAR Table 3.12-2 for Class 2 piping.
2. Global Coordinate System: The Y-axis is vertical and is coincident with the centerline of the CNV, with the location of zero elevation at the base. The positive X-axis is horizontal and along the CNV 90 degree axis. The positive Z-axis (in accordance with the right-hand-rule) is orthogonal to the X-axis and is along the CNV 180 degree axis. For nozzle loading, some tables present reaction forces whereas others present member forces. This results in the sign being flipped for the reaction forces. Dynamic loads should be taken as occurring in both directions

(+/-) regardless of the sign shown.

3. DFL = Dynamic Fluid Loads (time-history analysis of valve opening/closing transients, water hammer, and pipe break cases). Note that where applicable, the maximum pipe break loads and water hammer loads are listed separately, as these loads are applied concurrently.

RCS Discharge Line The RCS discharge line was analyzed from the reactor pressure vessel nozzle connection to the first anchor (i.e., restraint in six degrees of freedom) on the outboard side of the reactor bay wall. Inside containment, this line is classified as ASME Class 1, while outside containment, it is classified as B31.1 with limited portions classified as Class 1 and Class 3.

The stress analysis of this line is split into two separate analysis models, for inside the CNV and outside the CNV, because the CNV penetration acts as an anchor. The analysis model for the Class 1 line inside the CNV is shown in Figure 1 through Figure 3, with the stress results and nozzle loads shown in Table 1 through Table 3.

The analysis model for the RCS discharge line outside the CNV is shown in Figure 4 and Figure 5, with the stress results and nozzle loads shown in Table 4 and Table 5. This analysis model includes the RCS injection line and the PZR spray line because they are connected to the RCS discharge line and cannot be decoupled from the analysis. Although the stress results for these other lines are not listed here, they also pass applicable ASME Code criteria. The weld between NuScale Nonproprietary

the CIV and the CNV nozzle safe-end is classified as ASME Class 1 piping and is evaluated in a separate calculation using NB-3200 methods, as allowed by NB-3630(b).

NuScale Nonproprietary

((2(a),(c) Figure 1 - RCS Discharge Line Inside the CNV - Entire Model NuScale Nonproprietary

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                                                              }}2(a),(c)

Figure 2 - RCS Discharge Line Inside the CNV -Upper Portion NuScale Nonproprietary

(( 

                                                            }}2(a),(c)

Figure 3 - RCS Discharge Line Inside the CNV - Lower Portion NuScale Nonproprietary

Table 1. ASME Class 1 RCS Discharge Line Inside the CNV ASME Combination Joint Component Stress(psi) Allowable Ratio Code Stress(psi) Level Design ASME Eq. (9) A00 Pipe to RPV12 Nozzle (( Connection A03 Bend A04 Bend A-B-C ASME Eq. (10) A03 Bend A04 Bend A25 Bend A-B-C ASME Eq. (12) A18 Bend A23 Bend A03 Bend A-B-C ASME Eq. (13) A03 Bend A00 Pipe to RPV12 Nozzle Connection A18 Bend A-B Thermal Stress All All Ratchet A-B-C ASME NB- A00 Pipe to RPV12 Nozzle 3653.5 Connection Cumulative A18 Bend Damage (In-Air Fatigue) A03 Bend A-B-C Cumulative A00 Pipe to RPV12 Nozzle Damage Connection Considering A18 Bend Environmental Effects A03 Bend B ASME Eq. (9) A03 Bend A00 Pipe to RPV12 Nozzle Connection A07 Bend C ASME Eq. (9) A00 Pipe to RPV12 Nozzle Connection A03 Bend A15 Straight Pipe at Support Guide D ASME Eq. (9) A00 Pipe to RPV12 Nozzle Connection A03 Bend A15 Straight Pipe at Support Guide D ASME NB- A00 Pipe to RPV12 Nozzle 3656(b) Connection (2)Sustained A03 Bend Stress Due to A04 Bend }}2(a),(c) Weight NuScale Nonproprietary

D ASME NB- A15 Straight Pipe at Support (( 3656(b) Guide (3)Pressure A03 Bend 

               + Weight          A00    Pipe to RPV12 Nozzle
              + Reversing                     Connection Dynamic (SSE Inertia)

D ASME NB- A01 Bend 3656(b) A29 Pipe to CNV13 Nozzle (4)SAM Connection Bending A26 Bend D ASME NB- A25- Bend 3656(b) A26 (4)SAM Axial A22- Bend A23 A17- Bend }}2(a),(c) A19 Table 2. RCS Discharge Line Inside the CNV - RPV Nozzle Loads Joint A00 - RPV12 Load FX FY FZ MX MY MZ (lbf) (lbf) (lbf) (ft-lbf) (ft-lbf) (ft-lbf) Gravity (( Max Thermal SSE (Inertia) SSE (SAM) Max Level A DFL Max Level B DFL(1) Max Level C DFL(2) Max Level D DFL(2) }}2(a),(c)

1. Max of Time History Cases 1, 2, 4, 5
2. Max of Time History Cases 3, 6 NuScale Nonproprietary

Table 3. RCS Discharge Line Inside the CNV - CNV Nozzle Loads Joint A29 - CNV13 Load FX FY FZ MX MY MZ (lbf) (lbf) (lbf) (ft-lbf) (ft-lbf) (ft-lbf) Gravity (( Max Thermal SSE (Inertia) SSE (SAM) Max Level A DFL Max Level B DFL(1) Max Level C DFL(2) Max Level D DFL(2) }}2(a),(c)

1. Max of Time History Cases 1, 2, 4, 5
2. Max of Time History Cases 3, 6 NuScale Nonproprietary

(( 

                                                                                   }}2(a),(c)

Figure 4. CVCS Discharge, Injection, and PZR Spray Outside the CNV - Entire Model NuScale Nonproprietary

(( 

                                                                                    }}2(a),(c)

Figure 5. CVCS Discharge Line Outside the CNV - ASME Class 3 Portion Highlighted in Red - Other Lines Hidden for Clarity NuScale Nonproprietary

Table 4. ASME Class 3 RCS Discharge Line Outside the CNV ASME Combination Joint Component Stress (psi) Allowable Stress Ratio Code (psi) Level Design ASME Eq. H03 Drain Branch (( (8) Connection A23 Straight Pipe A49 Straight Pipe to Valve Connection at Class 3 Boundary A ASME Eq. H03 Drain Branch (9a) Connection A23 Straight Pipe A49 Straight Pipe to Valve Connection at Class 3 Boundary A ASME Eq. A08- Straight Pipe to (11a) A09 Check Valve to CIV Weld A10 Bend A41 Reducer B ASME Eq. H03 Drain Branch (9a) Connection A49 Straight Pipe to Valve Connection at Class 3 Boundary A16 Straight Pipe B ASME Eq. A08- Straight Pipe to (11a) A09 Check Valve to CIV Weld A10 Bend A41 Reducer C ASME Eq. A14 Straight Pipe (9a) H03 Drain Branch Connection A13 Tee D ASME Eq. A14 Straight Pipe (9a) A12** Straight Pipe with Lug Attachment at Support Location H03 Drain Branch Connection D ND-3655(b)(2) A23 Straight Pipe Sustained Stress A16- Straight Pipe-Weight A21 Bend A13 Tee D ND-3655(b) A33 Bend (4) A34 Bend SAM Bending A39 Bend 0.441 }}2(a),(c) NuScale Nonproprietary

D ND-3655(b)(4) A39- Bend - Straight (( SAM Axial A38A* Pipe A10 Bend A11 Bend 

--        Appendix Y-    A12     Straight Pipe 5410(c) Eq. (5)            with Lug Attachment at Support Location A38A    Straight Pipe with Lug Attachment at Support Location A33A    Straight Pipe with Lug Attachment at Support Location
--        Appendix Y-    A12     Straight Pipe 5410(c) Eq. (6)            with Lug Attachment at Support Location A38A    Straight Pipe with Lug Attachment at Support Location A33A    Straight Pipe                                  }}2(a),(c) with Lug Attachment at Support Location Note: **Joints A12, A33A, and A38A are locations having a welded attachment and also analyzed using the requirements in Nonmandatory Appendix Y, Article Y-5000.

NuScale Nonproprietary

Table 5. RCS Discharge Line Outside the CNV - CNV Nozzle Loads in Local Coordinates Joint A03 - Discharge Line CNV Nozzle Load FX FY FZ MX MY MZ (lbf) (lbf) (lbf) (ft-lbf) (ft-lbf) (ft-lbf) Gravity (( Max Thermal SSE (Inertia) SSE (SAM) Max Level A DFL Max Level B DFL Max Level C DFL Max Level C Pipe Break Max Level D DFL Max Level D Pipe Break }}2(a),(c) NuScale Nonproprietary

Feedwater Lines The two feedwater lines were analyzed from the reactor pressure vessel nozzle connection to anchor supports on the outboard side of the reactor bay wall. Inside containment, these lines are classified as ASME Class 2, while outside containment, the majority of this piping is classified as B31.1 with a limited portion classified as Class 2. The stress analysis of these lines is split into three separate analysis models. There are two models for the feedwater lines inside the CNV, one for each train of the the feedwater system. The analysis model for feedwater line 1 inside the CNV is shown in Figure 6 through Figure 9, with the stress results and nozzle loads shown in Table 6 through Table 9. The analysis model for feedwater line 2 inside the CNV is shown in Figure 10 through Figure 12, with the stress results and nozzle loads shown in Table 10 through Table 13. The analysis model for the feedwater lines outside the CNV is shown in Figure 13, with the stress results and nozzle loads shown in Table 14 and Table 15. In this case, only one model is necessary to qualify both trains of the feedwater system because the physical layout of the piping is symmetrical about the z-y plane. Stress results are only provided for the ASME Class 2 piping weld between the CIV and the CNV nozzle safe-end as other piping is B31.1. Although the stress results for the B31.1 portion are not listed here, they also pass applicable ASME Code criteria as required by the design specification (i.e., meets level D stress limits for the SSE). NuScale Nonproprietary

(( 

                                                           }}2(a),(c)

Figure 6. Feedwater Line 1 Inside the CNV - Entire Model NuScale Nonproprietary

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                                                            }}2(a),(c)

Figure 7. Feedwater Line 1 Inside the CNV - Upper Portion NuScale Nonproprietary

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                                                             }}2(a),(c)

Figure 8. Feedwater Line 1 Inside the CNV - Middle Portion NuScale Nonproprietary

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                                                            }}2(a),(c)

Figure 9. Feedwater Line 1 Inside the CNV - Lower Portion NuScale Nonproprietary

Table 6. ASME Class 2 - Feedwater Line 1 Inside the CNV ASME Combination Joint Component Stress (psi) Allowable Ratio Code Stress (psi) Level Design ASME Eq. (8) A04- Reducer (( A05 A15 Bend A16 Bend A&B ASME Eq. (9a) D02 Weldolet to Weld Neck Connection at Relief Valve A06- Straight Pipe to A07 Bend A00 Straight Pipe A&B ASME Eq. A27 Bend (10a) A47 Tee at Relief Valve A25 Bend A&B ASME Eq. (11) A27 Bend A47 Tee at Relief Valve A25 Bend D ASME Eq. (9a) A26 Support with weld on NPS 5 piping D02 Weldolet to Weld Neck Connection at Relief Valve A27 Bend }}2(a),(c) Table 7. Feedwater Line 1 Inside the CNV - CNV Nozzle Loads Joint A29 - CNV1 Load FX FY FZ MX MY MZ (lbf) (lbf) (lbf) (ft-lbf) (ft-lbf) (ft-lbf) Gravity (( Max Thermal SSE (Inertia) SSE (SAM) Max Level A DFL Max Level B DFL Max Level C DFL Max Level C Pipe Break Max Level D DFL Max Level D Pipe Break }}2(a),(c) NuScale Nonproprietary

Table 8. Feedwater Line 1 Inside the CNV - RPV Nozzle Loads Joint A00 - RPV3 Load FX FY FZ MX MY MZ (lbf) (lbf) (lbf) (ft-lbf) (ft-lbf) (ft-lbf) Gravity (( Max Thermal SSE (Inertia) SSE (SAM) Max Level A DFL Max Level B DFL Max Level C DFL Max Level C Pipe Break Max Level D DFL Max Level D Pipe Break }}2(a),(c) Table 9. Feedwater Line 1 Inside the CNV - RPV Nozzle Loads Joint A06 - RPV5 Load FX FY FZ MX MY MZ (lbf) (lbf) (lbf) (ft-lbf) (ft-lbf) (ft-lbf) Gravity (( Max Thermal SSE (Inertia) SSE (SAM) Max Level A DFL Max Level B DFL Max Level C DFL Max Level C Pipe Break Max Level D DFL Max Level D Pipe Break }}2(a),(c) NuScale Nonproprietary

(( 

                                                        }}2(a),(c)

Figure 10. Feedwater Line 2 Inside CNV - Entire Model NuScale Nonproprietary

(( 

                                                             }}2(a),(c)

Figure 11. Feedwater Line 2 Inside the CNV - Upper Portion NuScale Nonproprietary

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                                                             }}2(a),(c)

Figure 12. Feedwater Line 2 Inside the CNV - Lower Portion NuScale Nonproprietary

Table 10. ASME Class 2 - Feedwater Line 2 Inside the CNV ASME Combination Joint Component Stress (psi) Allowable Ratio Code Stress (psi) Level Design ASME Eq. (8) B04- Reducer (( B05 B27- Bend B28 B10 Tee A&B ASME Eq. (9a) B46 Tee at Relief Valve D02 Weldolet to Weld Neck Connection at Relief Valve B00 Straight Pipe A&B ASME Eq. (10a) B46 Reducer B20 Support with weld on NPS 5 piping B12 Reducer at DHRS Condensate A&B ASME Eq. (11) B46 Reducer B20 Support with weld on NPS 5 piping B12 Reducer at DHRS Condensate D ASME Eq. (9a) B46 Reducer B20 Support with weld on NPS 5 piping D02 Weldolet to Weld Neck }}2(a),(c) Connection at Relief Valve NuScale Nonproprietary

Table. 11 Feedwater Line 2 Inside the CNV - CNV Nozzle Loads Joint B30 - CNV2 Load FX FY FZ MX MY MZ (lbf) (lbf) (lbf) (ft-lbf) (ft-lbf) (ft-lbf) Gravity (( Max Thermal SSE (Inertia) SSE (SAM) Max Level A DFL Max Level B DFL Max Level C DFL Max Level C Pipe Break Max Level D DFL Max Level D Pipe Break }}2(a),(c) Table. 12 Feedwater Line 2 Inside the CNV - RPV Nozzle Loads Joint B00 - RPV4 Load FX FY FZ MX MY MZ (lbf) (lbf) (lbf) (ft-lbf) (ft-lbf) (ft-lbf) Gravity (( Max Thermal SSE (Inertia) SSE (SAM) Max Level A DFL Max Level B DFL Max Level C DFL Max Level C Pipe Break Max Level D DFL Max Level D Pipe Break }}2(a),(c) NuScale Nonproprietary

Table. 13 Feedwater Line 2 Inside the CNV - RPV Nozzle Loads Joint B06 - RPV6 Load FX FY FZ MX MY MZ (lbf) (lbf) (lbf) (ft-lbf) (ft-lbf) (ft-lbf) Gravity (( Max Thermal SSE (Inertia) SSE (SAM) Max Level A DFL Max Level B DFL Max Level C DFL Max Level C Pipe Break Max Level D DFL Max Level D Pipe Break }}2(a),(c) NuScale Nonproprietary

(( 

                                                                   }}2(a),(c)

Figure 13. Feedwater Line 1 and 2 Outside the CNV - Entire Model NuScale Nonproprietary

Table 14. ASME Class 2 Feedwater Lines 1 & 2 Outside the CNV ASME Combination Joint Component Stress (psi) Allowable Stress Ratio Code (psi) Level Design ASME Eq. (8) C00 CNV Nozzle Safe- End (( to CIV Weld A&B ASME Eq. (9a) C00 CNV Nozzle Safe- End to CIV Weld A&B ASME Eq. C00 CNV Nozzle Safe- End (10a) to CIV Weld C ASME Eq. (9a) C00 CNV Nozzle Safe- End to CIV Weld D ASME Eq. (9a) C00 CNV Nozzle Safe- End (Pipe Break to CIV Weld Only) D ASME Eq. (9a) C00 CNV Nozzle Safe- End (Pipe Break + to CIV Weld SSE) D NC-3655(b) C00 CNV Nozzle Safe- End (4)SAM to CIV Weld Bending D NC-3655(b) C00 CNV Nozzle Safe- End }}2(a),(c) (4)SAM Axial to CIV Weld (Note: Stress results provided for the only joint in the model classified as ASME Class 2. All other piping is B31.1) Table 15. Feedwater Lines 1 & 2 Outside the CNV - CNV Nozzle Loads Joint C00 - CNV1 and CNV2 Load FX FY FZ MX MY MZ (lbf) (lbf) (lbf) (ft-lbf) (ft-lbf) (ft-lbf) Gravity (( Max Thermal SSE (Inertia) SSE (SAM) Max Level A DFL Max Level B DFL Max Level C DFL Max Level D DFL }}2(a),(c) NuScale Nonproprietary

Main Steam Lines The two main steam lines were analyzed inside containment from the reactor pressure vessel nozzle connection to the containment vessel nozzle connection. These lines are classified as ASME Class 2. The stress analysis of these lines is contained in a single analysis model shown in Figure 14. The stress results and nozzle loads are shown in Table 16 through Table 22. The two trains of the main steam system are included in the same analysis model, but do not interact and are not physically connected. NuScale Nonproprietary

(( 

                                                                 }}2(a),(c)

Figure 14. Main Steam Line 1 & 2 Inside the CNV - Entire Model NuScale Nonproprietary

Table 16. ASME Class 2 Main Steam Line 1 & 2 Inside the CNV ASME Combination Joint Component Stress (psi) Allowable Ratio Code Stress (psi) Level Design ASME Eq. (8) C10 Tee at Branch Connection (( D01 Tee at Branch Connection C09 Reducer A&B ASME Eq. (9a) C10 Tee D01 Tee at Branch Connection A00 Straight Pipe at RPV10 Nozzle A&B ASME Eq. (10a) C07 Bend C09 Reducer C05 Bend A&B ASME Eq. (11) C09 Reducer C07 Bend C05 Bend D ASME Eq. (9a) C07 Bend C10 Tee at Branch Connection C09 Reducer D ASME NC- A06 Bend 3655(b)(4) A11 Reducer SAM Bending C07 Bend D ASME NC- A03 Bend 3655(b)(4) A02 Bend SAM Axial B04 Bend 0.013}}2(a),(c) Table 17. Main Steam Line 1 Inside the CNV - RPV Nozzle Loads Joint A00 - RPV10 Load FX FY FZ MX MY MZ (lbf) (lbf) (lbf) (ft-lbf) (ft-lbf) (ft-lbf) Gravity (( Max Thermal SSE (Inertia) SSE (SAM) Max Level A DFL Max Level B DFL Max Level C DFL Max Level C Pipe Break Max Level D DFL Max Level D Pipe Break }}2(a),(c) NuScale Nonproprietary

Table 18. Main Steam Line 1 Inside the CNV - RPV Nozzle Loads Joint B07 - RPV8 Load FX FY FZ MX MY MZ (lbf) (lbf) (lbf) (ft-lbf) (ft-lbf) (ft-lbf) Gravity (( Max Thermal SSE (Inertia) SSE (SAM) Max Level A DFL Max Level B DFL Max Level C DFL Max Level C Pipe Break Max Level D DFL Max Level D Pipe Break }}2(a),(c) Table 19. Main Steam Line 1 Inside the CNV - CNV Nozzle Loads Joint A10 - CNV3 Load FX FY FZ MX MY MZ (lbf) (lbf) (lbf) (ft-lbf) (ft-lbf) (ft-lbf) Gravity (( Max Thermal SSE (Inertia) SSE (SAM) Max Level A DFL Max Level B DFL Max Level C DFL Max Level C Pipe Break Max Level D DFL Max Level D Pipe Break }}2(a),(c) NuScale Nonproprietary

Table 20. Main Steam Line 2 Inside the CNV - RPV Nozzle Loads Joint C00 - RPV9 Load FX FY FZ MX MY MZ (lbf) (lbf) (lbf) (ft-lbf) (ft-lbf) (ft-lbf) Gravity (( Max Thermal SSE (Inertia) SSE (SAM) Max Level A DFL Max Level B DFL Max Level C DFL Max Level C Pipe Break Max Level D DFL Max Level D Pipe Break }}2(a),(c) Table 21. Main Steam Line 2 Inside the CNV - RPV Nozzle Loads Joint D09 - RPV7 Load FX FY FZ MX MY MZ (lbf) (lbf) (lbf) (ft-lbf) (ft-lbf) (ft-lbf) Gravity (( Max Thermal SSE (Inertia) SSE (SAM) Max Level A DFL Max Level B DFL Max Level C DFL Max Level C Pipe Break Max Level D DFL Max Level D Pipe Break }}2(a),(c) NuScale Nonproprietary

Table 22. Main Steam Line 2 Inside the CNV - CNV Nozzle Loads Joint C11 - CNV4 Load FX FY FZ MX MY MZ (lbf) (lbf) (lbf) (ft-lbf) (ft-lbf) (ft-lbf) Gravity (( Max Thermal SSE (Inertia) SSE (SAM) Max Level A DFL Max Level B DFL Max Level C DFL Max Level C Pipe Break Max Level D DFL Max Level D Pipe Break }}2(a),(c) Main Steam Lines within the Break Exclusion Zone The two high-energy ASME Class 2 main steam lines were analyzed from the containment vessel nozzle connection to the first six-way anchor restraint beyond the reactor bay wall. The stress analysis of these lines is contained in a single representative analysis model (Train 2) shown in Figures 1 and 2. The single analysis is representative as the two lines are mirror images about the CNV z-axis. The two trains of the main steam system do not interact and are not physically connected. The stress results and nozzle loads are shown in Table 23 and Table 24. NuScale Nonproprietary

Table 23. ASME Class 2 - Containment System Main Steam Piping and Main Steam System Piping Outside the CNV ASME Combination Joint Component Stress (psi) Allowable Ratio Code Stress (psi) Level Design ASME Eq. (8) C00 Safe-end weld to (( }}2(a),(c) custom tee; uses SA-312 TP304 material allowable A ASME Eq. (9a) CO01 Branch connection (( }}2(a),(c) at 8" DHRSAV tee A ASME Eq. (10a) CN04 Weld at MSIV (( }}2(a),(c) B ASME Eq. (9a) CP01 8" Steam Piping Tee (( }}2(a),(c) C00 Safe-end weld to (( }}2(a),(c) custom tee; uses SA-312 TP304 material allowable B ASME Eq. (10a) CP01 8" Steam Piping Tee (( }}2(a),(c) CO01 8" Steam Piping Tee (( }}2(a),(c) C ASME Eq. (9a) CO01 Branch connection (( }}2(a),(c) at 8" DHRSAV tee CP01 8" Steam Piping Tee (( }}2(a),(c) CN03 Branch at DHRSAV (( }}2(a),(c) tee D ASME Eq. (9a) CN06 Straight Pipe at TSS (( }}2(a),(c) guide support CN05 Straight Pipe (( }}2(a),(c) Adjacent and Upstream of MSIV D ASME CN06 Straight Pipe at TSS (( }}2(a),(c) NC-3655(b)(4) guide support SAM Bending CN05 Straight Pipe (( }}2(a),(c) Adjacent and Upstream of MSIV D ASME CN05 Straight Pipe (( }}2(a),(c) NC-3655(b)(4) Adjacent and SAM Axial Upstream of MSIV Note: A portion of the main steam line piping is classified to ASME B31.1. The ASME Service Level D acceptance criteria is expanded to include this portion of ASME B31.1 piping and the results are included in this table. NuScale Nonproprietary

Table 24. Main Steam Piping Outside the CNV - Global Nozzle Loads Joint C00 (Nozzle Safe-End to Piping Connection) - CNV 3 and CNV4 Load FX FY FZ MX MY MZ (lbf) (lbf) (lbf) (ft-lbf) (ft-lbf) (ft-lbf) Max Gravity(1) (( }}2(a),(c) Max Thermal (( }}2(a),(c) SSE (Inertia) (( }}2(a),(c) SSE (SAM) (( }}2(a),(c) Max Level A DFL(2) (( }} 2(a),(c) Max Level B DFL(3) (( }}2(a),(c) Max Level C DFL(4) (( }}2(a),(c) Max Level D DFL(5) (( }}2(a),(c) Notes: (1) Gravity = Max of Operating DHRS vs. Non-Operating DHRS Conditions (2) Time History Case 8 (3) Max of Time History Cases 1, 5, 6, 8, 10, 11, 12 (4) Max of Time History Cases 2, 7, 9, 10, 11, and 12 (5) Max of Time History Cases 15, 17, 18, 19, 20, and 21 NuScale Nonproprietary

(( 

                                                                                 }}2(a),(c)

Figure 15. Containment System Main Steam Piping and Main Steam System Piping Outside the CNV - Overall Model NuScale Nonproprietary

(( 

                                                                                  }}2(a),(c)

Figure 16 - Containment System Main Steam Piping and Main Steam System Piping Outside the CNV - Detailed View near MSIV NuScale Nonproprietary

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

RAIO-0716-66374 : Affidavit of Zackary W. Rad, AF-0719-66375 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 and results by which NuScale develops its piping analyses.

NuScale has performed significant research and evaluation to develop a basis for this method and results 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-0719-66375

4. The information sought to be withheld is in the enclosed response to NRC Request for Additional Information No. 154, eRAI No. 8938. 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-0719-66375}}

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