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Category:Legal-Affidavit
MONTHYEARML20150E1772020-05-29029 May 2020 LLC - Submittal of Presentation Materials Entitled ACRS Full Committee Presentation: NuScale Topic - Extended Dhrs Operation and RCS Boron Redistribution (Closed Session), PM-0620-70243, Revision 0 ML20141L8082020-05-20020 May 2020 LLC Submittal of Containment Response Analysis Methodology Technical Report, TR-0516-49084, Revision 3 ML20133K0882020-05-12012 May 2020 LLC, Submittal of Presentation Materials Entitled Public Meeting Presentation: Topic - Emergency Core Cooling System (ECCS) Boron Distribution (Closed Session), PM-0420-69512, Revision 0 RAIO-0420-69855, LLC, Submittal of Corrected Response to NRC Request for Additional Information No. 284 (Erai No. 9225) on the NuScale Design Certification2020-04-30030 April 2020 LLC, Submittal of Corrected Response to NRC Request for Additional Information No. 284 (Erai No. 9225) on the NuScale Design Certification ML20066H1812020-02-28028 February 2020 LLC, Submittal of Presentation Materials Entitled ACRS Subcommittee Presentation: NuScale FSAR Chapter 19 - Probabilistic Risk Assessment Area of Focus, PM-0220-69046, Revision 0 ML20066H1842020-02-28028 February 2020 LLC Submittal of Presentation Materials Entitled ACRS Subcommittee Presentation: NuScale FSAR Topic-Resolution of Chapter 15 Phase 2 Open Items (Closed Session), PM-0220-69063, Revision 0 ML20054A4112020-02-17017 February 2020 LLC - Submittal of Presentation Materials Entitled ACRS Subcommittee Presentation: NuScale Topical Report - Loss-of-Coolant Accident Evaluation Model (Closed Session), PM-0220-68914, Revision 0 ML20054A9652020-02-17017 February 2020 LLC, Submittal of Presentation Materials Entitled ACRS Subcommittee Presentation: NuScale Topical Report - Rod Ejection Accident Methodology (Closed Session), PM-1019-67366, Revision 0 ML20054A9692020-02-17017 February 2020 LLC Submittal of Presentation Materials Entitled ACRS Subcommittee Presentation: NuScale Topical Report- Non-Loss-of-Coolant Accident (Closed Session), PM-0220-68851, Revision 0 ML19353A7192019-12-19019 December 2019 LLC, Submittal of NuFuel-HTP2 Fuel and Control Rod Assembly Designs, TR-0816-51127, Revision 3 ML19352G6972019-12-18018 December 2019 LLC Submittal of Long-Term Cooling Methodology, TR-0916-51299, Revision 2 ML19338E9482019-12-0404 December 2019 LLC Submittal of Human-System Interface Style Guide, ES-0304-1381, Revision 4 ML19337B4472019-12-0202 December 2019 LLC - Submittal of Changes to Long-Term Cooling Methodology, TR-0916-51299, Revision 1 ML19332A1202019-11-27027 November 2019 LLC Supplemental Response to NRC Request for Additional Information No. 484 (Erai No. 8930) on the NuScale Design Certification Application ML19304B4712019-10-31031 October 2019 LLC Supplemental Response to NRC Request for Additional Information No. 466 (Erai No. 9482) on the NuScale Design Certification Application ML19238A3092019-08-26026 August 2019 LLC - Submittal Nuscale'S Proposed Closure Plan to Address Impacts of the Adjusted Iab Operations Range ML19238A3662019-08-23023 August 2019 LLC - Response to NRC Request for Additional Information No. 523 (Erai No. 9682) on the NuScale Design Certification Application ML19218A1472019-08-0505 August 2019 LLC - Submittal of Long-Term Cooling Methodology, TR-0916-51299, Revision 1 ML19215A0062019-08-0202 August 2019 LLC - Supplemental Response to NRC Request for Additional Information No. 441 (Erai No. 9485) on the NuScale Design Certification Application ML19215A0032019-08-0202 August 2019 LLC - Supplemental Response to NRC Request for Additional Information No. 202 (Erai No. 8911) on the NuScale Design Certification Application ML19212A3752019-07-31031 July 2019 LLC Supplemental Response to NRC Request for Additional Information No. 483 (Erai No. 9516) on the NuScale Design Certification Application ML19212A7992019-07-31031 July 2019 LLC Supplemental Response to NRC Request for Additional Information No. 427 (Erai No. 9408) on the NuScale Design Certification Application ML19211D4112019-07-30030 July 2019 LLC Submittal of NuScale Power Module Short-Term Transient Analysis, TR-1016-51669, Revision 1 ML19207B3812019-07-26026 July 2019 LLC - Response to NRC Request for Additional Information No. 427 (Erai No. 9408) on the NuScale Design Certification Application ML19199A1172019-07-18018 July 2019 LLC - Supplemental Response to NRC Request for Additional Information No. 484 (Erai No. 8930) on the NuScale Design Certification Application ML19192A1602019-07-0909 July 2019 LLC Submittal of Presentation Materials Entitled ACRS Full Committee Presentation: NuScale Topical Report-Evaluation Methodology for Stability Analysis of the NuScale Power Module, PM-0719-66244, Revision 0 ML19184A6152019-07-0303 July 2019 LLC Supplemental Response to NRC Request for Additional Information No. 386 (Erai No. 9316) on the NuScale Design Certification Application ML19183A4852019-07-0202 July 2019 LLC - Submittal of Fluence Calculation Methodology and Results, TR-0116-20781, Revision 1 ML19182A0462019-06-27027 June 2019 LLC - Submittal of Presentation Materials Titled TF-3 Modal Demonstration Testing and Siet Tour, PM-0619-66058-P, Revision 0 ML19176A5802019-06-25025 June 2019 LLC Supplemental Response to NRC Request for Additional Information No. 232 (Erai No. 9113) on the NuScale Design Certification Application ML19172A1012019-06-17017 June 2019 LLC - Submittal of Presentation Materials Entitled ACRS Subcommittee Presentation, NuScale FSAR Chapter 15, Transient and Accident Analyses, and Chapter 6.2.1, Containment Functional Design, PM-0619-65992-P, Revision 0 ML19164A1452019-06-13013 June 2019 LLC - Submittal of Containment Response Analysis Methodology Technical Report, TR-0516 -49 08 4, Revision 1 ML19158A3822019-06-0707 June 2019 LLC - Submittal of Containment Vessel Ultimate Pressure Integrity, TR-0917-56119, Revision 1 ML19157A3262019-06-0606 June 2019 LLC - Supplemental Response to NRC Request for Additional Information No. 232 (Erai No. 9113) on the NuScale Design Certification Application ML19154A6222019-06-0303 June 2019 LLC Supplemental Response to NRC Request for Additional Information No. 202 (Erai No. 8911) on the NuScale Design Certification Application ML19154A6052019-06-0303 June 2019 LLC Response to NRC Request for Additional Information No. 514 (Erai No. 9645) on the NuScale Design Certification Application ML19151A8102019-05-31031 May 2019 LLC Submittal of Technical Report NuScale Generic Technical Guidelines, TR-1117-57216, Revision 1 ML19151A8372019-05-31031 May 2019 LLC - Supplemental Response to NRC Request for Additional Information No. 377 (Erai No. 9380) on the NuScale Design Certification Application ML19151A8342019-05-31031 May 2019 LLC - Submittal of Turbine Missile Barrier Design Closure Plan Actions (Final Safety Analysis Report, Tier 2, Section 3.5.1.3) ML19149A2982019-05-28028 May 2019 LLC Submittal of NuScale Containment Leakage Integrity Assurance, TR-1116-51962, Revision 1 ML19137A3612019-05-17017 May 2019 LLC - Submittal of Nuclear Steam Supply System Advanced Sensor Technical Report, TR-0316-22048, Revision 2 ML19119A3982019-04-29029 April 2019 LLC - Submittal of Human-System Interface Design Results Summary Report, RP-0316-17619, Revision 2 ML19119A3422019-04-29029 April 2019 LLC Submittal of Human Factors Engineering Program Management Plan, RP-0914-8534, Revision 5 ML19119A3932019-04-29029 April 2019 LLC - Submittal of Human Factors Engineering Task Analysis Results Summary Report, RP-0316-17616 Revision 2. (Non-Proprietary Version) ML19105B0772019-04-15015 April 2019 LLC - Supplemental Response to NRC Request for Additional Information No. 478 (Erai No. 9470) on the NuScale Design Certification Application ML19101A4412019-04-11011 April 2019 LLC Response to NRC Request for Additional Information No. 386 (Erai No. 9316) on the NuScale Design Certification Application ML19099A4732019-04-0909 April 2019 LLC - Supplemental Response to NRC Request for Additional Information No. 202 (Erai No. 8911) on the NuScale Design Certification Application ML19098B6202019-04-0808 April 2019 LLC - Supplemental Response to NRC Request for Additional Information No. 465 (Erai No. 9494) on the NuScale Design Certification Application ML19093B8502019-04-0303 April 2019 LLC - Submittal of Technical Report TR-0916-51502, NuScale Power Module Seismic Analysis, Revision 2 ML19087A2882019-03-28028 March 2019 LLC Updates to Final Safety Analysis Report, Section 1.6,Materials Referenced, Section 3.6, Protection Against Dynamic Effects Associated with Postulated Rupture of Piping, and the Pipe Rupture Hazards Analysis, TR-0818-61384 2020-05-29
[Table view] Category:Letter
MONTHYEARML23180A1512023-06-29029 June 2023 LLC, Request for Exemption to the Reporting Requirements of 10 CFR 50.46(a)(3) ML21102A3072021-04-15015 April 2021 OEDO-21-00155 - Lessons-Learned from the Design Certification Review of the NuScale Power, LLC, Small Modular Reactor ML21050A4312021-02-19019 February 2021 LLC - Lessons-Learned from the Design Certification Review of the NuScale Power, LLC Small Modular Reactor ML20247J5642020-09-11011 September 2020 Standard Design Approval for the NuScale Power Plant Based on the NuScale 600 Standard Plant Design Certification Application ML20231A8042020-08-28028 August 2020 Final Safety Evaluation Report for the NuScale Standard Plant Design ML20224A4602020-08-25025 August 2020 OEDO-20-00292-Response to the Advisory Committee on Reactor Safeguards Letter on NuScale Power, LLC, Report on the Safety Aspects of the NuScale Small Modular Reactor ML20231A5982020-08-25025 August 2020 OEDO-20-00285_NuScale Area of Focus - Boron Redistribution ML20210M8902020-07-29029 July 2020 Area of Focus - Boron Redistribution ML20195A5872020-07-13013 July 2020 LLC - Submittal of Draft Operator Licensing and Examination Standard for NuScale Small Modular Reactors ML20195C7662020-07-13013 July 2020 LLC Request for Standard Design Approval Based on the NuScale Standard Plant Design Certification Application ML20192A3262020-07-10010 July 2020 LLC, Submittal of Environmental Report: Revision Status ML20198M3932020-07-0202 July 2020 LLC Submittal of Revised Packing Slip for Submittal of the NuScale Standard Plant Design Certification Application, Revision 4.1, Dated June 19, 2020 ML20174A3472020-07-0101 July 2020 OEDO-20-00220 - Area of Focus - Probabilistic Risk Assessment and Emergency Core Cooling System Valve Performance ML20184A2872020-07-0101 July 2020 LLC Submittal of Presentation Materials Entitled ACRS Full Committee Presentation: NuScale Topic - Boron Redistribution and General Design Criterion 33, PM-0720-70785, Revision 0 ML20181A4322020-06-22022 June 2020 Final SER for NuScale TR-0516-49416 NON-Loss-of-Coolant Analysis Model, Rev 3 (Letter) ML20181A2702020-06-22022 June 2020 Final SER for NuScale TR-0516-49422 Loss-of-Coolant Analysis Model, Rev 2 (Letter) ML20198M3922020-06-19019 June 2020 LLC - Submittal of the NuScale Standard Plant Design Certification Application, Revision 4.1 ML20171A7312020-06-19019 June 2020 LLC, Submittal of Riser Flow Hole Methodology and Associated Changes to Final Safety Analysis Report Incorporating Its Use ML20157A2232020-06-0303 June 2020 Letter to NuScale Requesting -A for TR-0716-50350 ML20150C5172020-05-29029 May 2020 LLC Submittal of Presentation Materials Entitled NRC Public Meeting Presentation: Boron Redistribution and Associated Design and DCA Changes, PM-0620-70336, Revision 0 ML20150E1772020-05-29029 May 2020 LLC - Submittal of Presentation Materials Entitled ACRS Full Committee Presentation: NuScale Topic - Extended Dhrs Operation and RCS Boron Redistribution (Closed Session), PM-0620-70243, Revision 0 ML20150C8812020-05-29029 May 2020 LLC Submittal of Presentation Materials Entitled ACRS Full Committee Presentation: NuScale Topic - Boron Redistribution and Associated Design and DCA Changes, PM-0620-70244, Revision 0 ML20149M1192020-05-28028 May 2020 LLC Summary of Impacts to Erai 8930 Response and Discussion on the Exemption from General Design Criterion 33 ML20141L8082020-05-20020 May 2020 LLC Submittal of Containment Response Analysis Methodology Technical Report, TR-0516-49084, Revision 3 ML20141N0122020-05-20020 May 2020 LLC Submittal of Changes to Final Safety Analysis Report, Section 6.2, Containment Systems, Section 6.3, Emergency Core Cooling System, and Technical Report TR-0516-49084, Containment Response Analysis Methodology Technical Report ML20141M7642020-05-20020 May 2020 LLC Submittal of Nuclear Steam Supply System Advanced Sensor Technical Report, TR-0316-22048, Revision 3 ML20141L7872020-05-20020 May 2020 LLC, Submittal of Second Updates to Standard Plant Design Certification Application, Revision 4 ML20141L8162020-05-20020 May 2020 LLC, Submittal of Long-Term Cooling Methodology, TR-0916-51299, Revision 3 ML20141M1142020-05-20020 May 2020 LLC Submittal of NuScale Instrument Setpoint Methodology Technical Report, TR-0616-49121, Revision 3 ML20141L8042020-05-20020 May 2020 LLC Submittal of Technical Specifications Regulatory Conformance and Development, TR-1116-52011, Revision 4 ML20128J3162020-05-18018 May 2020 OEDO-20-00167 - Response to the ACRS Letter on Combustible Gas Monitoring ML20133K0882020-05-12012 May 2020 LLC, Submittal of Presentation Materials Entitled Public Meeting Presentation: Topic - Emergency Core Cooling System (ECCS) Boron Distribution (Closed Session), PM-0420-69512, Revision 0 ML20133J9142020-05-11011 May 2020 LLC Submittal of Presentation Materials Entitled Public Meeting Presentation: Topic - Emergency Core Cooling System (ECCS) Boron Distribution, PM-0420-69511, Revision 0 ML20112F4552020-05-0101 May 2020 LLC, Design Certification Application Phases 5 and 6 Review Status ML20107F8492020-05-0101 May 2020 OEDO-2000140 - NuScale Area of Focus - Helical Tube Steam Generator Design ML20104A0792020-04-27027 April 2020 OEDO-20-00115 - Safety Evaluation Report for Topical Report TR-0516-49416, Revision 2, Non-Loss-of-Coolant Accident Analysis Methodology ML20099H0802020-04-0808 April 2020 LLC - Submittal of Presentation Materials Entitled NRC Public Meeting: Revisions to Nuscale'S EPZ Sizing Methodology Topical Report, PM-0420-69598, Revision 0 ML20098G2372020-04-0707 April 2020 Nuscale Power, LLC Submittal of Remaining Closure Items for the Emergency Core Cooling System Valve Failure Mode Effects Analysis Audit Items ML20097F1922020-04-0606 April 2020 Nuscale Power, LLC Submittal of Presentation Materials Entitled ACRS Full Committee Presentation: Nuscale Topic - Hydrogen/Oxygen Monitoring, PM-0420-69518, Revision 0 ML20094H6742020-04-0303 April 2020 LLC Submittal of Presentation Materials Entitled ACRS Full Committee Presentation NuScale Topic-Probabilistic Risk Assessment with a Focus on Emergency Core Cooling System Analysis PM-0420-69559, Revision 0 ML20092L8992020-04-0101 April 2020 LLC - Submittal of Updates to Standard Plant Design Certification Application, Revision 4 ML20072M6682020-03-30030 March 2020 Response to NuScale Letter Dated February 24, 2020, on Planned SDA Application Content ML20072H3332020-03-0909 March 2020 LLC - Submittal of Presentation Materials Entitled Public Meeting Presentation: Topic - Emergency Core Cooling System (ECCS) Boron Distribution, PM-0320-69218, Revision 0 ML20057D9002020-03-0606 March 2020 Submittal of Errata to Final SE for NuScale Power, LLC TR-1010-859-NP-A, Quality Assurance Program Description for the NuScale Power Plant ML20062F7262020-03-0505 March 2020 Request for Withholding Information from Public Disclosure for Nuscale Power, LLC Letter Public ML20069A1572020-03-0404 March 2020 LLC - Submittal of Presentation Materials Entitled ACRS Full Committee Presentation: NuScale Topical Report-Rod Ejection Accident Methodology, PM-0320-69146, Revision 0 ML20069A1772020-03-0404 March 2020 LLC - Submittal of Presentation Materials Entitled ACRS Full Committee Presentation: NuScale Topical Report-Non-Loss-of-Coolant Accident, PM-0320-69141, Revision 0 ML20069A9632020-03-0404 March 2020 LLC Submittal of Presentation Materials Entitled ACRS Full Committee Presentation: NuScale Topical Report, Loss-of-Coolant Accident Evaluation Model, PM-0320-69138, Revision 0 ML20066G2802020-03-0303 March 2020 LLC, Submittal of Presentation Materials Entitled ACRS Subcommittee Presentation: NuScale Topic - Hydrogen Monitoring, PM-0220-69071, Revision 0 ML20066G2882020-02-28028 February 2020 LLC Submittal of Presentation Materials Titled ACRS Full Committee Presentation: NuScale - Steam Generator Design (Closed Session), PM-0220-69053, Revision 0 2023-06-29
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LO-0819-66702 August 26, 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 Submittal NuScales Proposed Closure Plan to Address Impacts of the Adjusted IAB Operations Range REF ER ENCES: 1. U.S. Nuclear Regulatory Commission Staff Report of Regulatory Audit Failure Modes and Affects Analysis and Other Supporting Documents for Emergency Core Cooling System Valves in the NuScale Power, LLC, Design Certification Application, dated August14, 2018 (ML18219B634)
- 2. NuScale Power, LLC Submittal of Resolution Plans and Classification for ECCS Valve FMEA Audit Follow-Up Items, dated September 21, 2018 (ML18264A312)
- 3. NuScale Power, LLC Submittal of Responses to ECCS Valve FMEA Audit Follow-Up Items, dated August 21, 2019 (ML19233A203)
During an August 15, 2019 public teleconference with Marieliz Vera, Timothy Lupold and Thomas Scarbrough of the NRC Staff, NuScale Power, LLC (NuScale) discussed a proposed path forward for resolution of follow-up items from the Reference 1 audit report. As a result of this discussion, NuScale submitted the proposed closure plan, Reference 2, for these follow-up items. An update on current the status of Reference 2 is given in Reference 3.
As part of the Reference 2 closure plan, NuScale proposed additional emergency core cooling system valve functional testing at fluid conditions up to the NuScale Power Module reactor operating pressure and temperature. The results of this additional testing required the need to adjust the inadvertent actuation block (IAB) mechanism operating range. The enclosed table provides NuScales proposed closure plan to address the impacts of the adjusted IAB operating range. is the proprietary version of NuScale Proposed Closure Plan to Address Impacts of the Adjusted IAB Operations Range. 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 document.
This letter makes no regulatory commitments and no revisions to any ex isting regulatory commitments.
NuScale Pow er, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com
LO-0819-66702 Page 2 of 2 08/26/19 If you have any questions, please contact Rebecca Norris at 541-602-1260 or at RNorris@nuscalepower.com.
Sincerely, Zackary W. Rad Director, Regulatory Affairs NuScale Power, LLC Distribution: Samuel Lee, NRC, OWFN-8H12 Gregory Cranston, NRC, OWFN-8H12 Timothy Lupold, NRC, OWFN-8H12 Marieliz Vera, NRC, OWFN-8H12 Thomas Scarbrough, NRC, OWFN-8H12 Enclosure 1: NuScale Proposed Closure Plan to Address Impacts of the Adjusted IAB Operations Range, proprietary version Enclosure 2: NuScale Proposed Closure Plan to Address Impacts of the Adjusted IAB Operations Range, nonproprietary version Enclosure 3: Affidavit of Zackary W. Rad, AF-0819-66761 NuScale Pow er, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com
LO-0819-66702 :
NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com
LO-0 19-66 :
NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com
LO-0819-66702 Enclosure Page 1 of 1 NuScale Proposed Closure Plan to Address Impacts of the Adjusted IAB Operations Range ACTION ITEMS:
Proposed NuScale Action Scheduled Issue Description Completion
- 1. NuScale proposes Design Provide proposed DCA and Technical Certification Application (DCA) and Report changes to NRC for their Technical Report changes to reduce consideration. ((
specific references to the IAB operating ranges
- 2. Issues and corresponding NuScale Submit a closure plan to the NRC to be actions resulting from the updated IAB discussed during a subsequent public setpoint range need to be presented call to the NRC staff
- 3. Reference 2 closure plan for follow-up Add Draft FMEA revision addressing the ECCS valve FMEA audit items follow-up items to the electronic reading identified numerous proposed room (eRR) updates to the ECCS valve Failure Modes and Effects Analysis (FMEA)
- 4. Reference 2 closure plan for follow-up Add Draft FTR to eRR ECCS valve FMEA audit items indicated NuScale will provide a ECCS Valve DCA Demonstration Test Final Test Report (FTR) for NRC review
- 5. Reference 2 closure plan for follow-up Internal vendor calculations supporting ECCS valve FMEA audit items closure of inadvertent actuation block indicated NuScale will finalize (IAB) partial opening issue will be preliminary vendor calculations completed and made available for NRC reviewed by the staff during the ECCS audit if needed Valve FMEAY audit activities at the vendors facility.
NuScale Chapter 6 and 15 analyses will be completed and added to the eRR for NRC review:
- 6. The revised IAB operating range a. Containment Pressure impacts FSAR Chapter 6 and 15 b. 15.6.5- LOCA analyses, which require update c. 15.6.6 - Inadvertent Operation of the Emergency Core Cooling System Request for additional information (RAI)
- 7. DCA updates are required to be updates transmitting DCA Change submitted to the staff reflecting the Packages (CPs) reflecting the revised2{d) results of the above analyses analyses will be submitted the NRC for review NuScale Nonproprietary
LO-0 19-66 :
Affidavit of , AF-0 19-66 6 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, 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 of 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 competitors 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. The accompanying submittal reveals confidential, preliminary and/or pre-decisional aspects of NuScales commercial strategy.
The precise financial value (loss) resulting from public disclosure of the information is difficult to quantify, but it is sensitive information related to NuScales commercial strategy and, therefore, has substantial value to NuScale.
(4) The information sought to be withheld is in the enclosed submittal entitled NuScale Proposed Closure Plan to Address Impacts of the Adjusted IAB Operations Range. 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).
AF-0819-66761 Page 1 of 2
(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 August 26, 2019.
Zackary W. Rad AF-0819-66761 Page 2 of 2}}