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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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L0-0220-69047 February 28, 2020 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 of Presentation Materials Entitled "ACRS Subcommittee Presentation: NuScale FSAR Chapter 19 - Probabilistic Risk Assessment Area of Focus," PM-0220-69046, Revision 0
\
The purpose of this submittal is to provide presentation materials to the NRG for use during the upcoming Advisory Committee on Reactor Safeguards (ACRS) Subcommittee Meeting on March 3, 2020. The materials support NuScale's presentation of the Chapter 19, probabilistic
. risk assessment area of focus.
Enclosure 1 is the proprietary presentation entitled "ACRS Subcommittee Presentation:
NuScale FSAR Chapter 19- Probabilistic Risk Assessment Area of Focus," PM-0220-69046, Revision 0. 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 2) supports this request.
This letter makes no regulatory commitments and no revisions to any existing regulatory commitments.
If you have any questions, please contact Rebecca Norris at 541-602-1260 or at RNorris@nuscalepower.com.
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/i:::a;;~. Rad Director, Regulatory Affairs NuScale Power, LLC Distribution: Robert Taylor, NRC, OWFN-8H12 Michael Snodderly, NRG, OWFN-8H12 Christopher Brown, NRC, OWFN-8H12 Gregory Cranston, NRG, OWFN-8H12 Michael Dudek, NRC, OWFN-8H12 Rani Franovich, NRG, OWFN-8H12 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com
L0-0220-69047 Page2of2 02/28/2020 Enclosure 1: "ACRS Subcommittee Presentation: NuScale FSAR Chapter 19 - Probabilistic Risk Assessment Area of Focus," PM-0220-69046-P, Revision 0 Enclosure 2: Affidavit of Zackary W. Rad, AF-0220-69048 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com
L0-0220-69047 :
Affidavit of Zackary W. Rad, AF-0220-69048 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 ha\ie 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 behalfof 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 dri\ien by one or more of the following:
(a) The information requested to be withheld re\ieals distinguishing aspects of a process (or component, structure, tool, method, etc.) whose use by NuScale competitors, without a license from NuScale, would constitute a compeMi\ie economic disadvantage to NuScale.
(b) The information requested to be withheld consists of supporting data, including test data, relati\ie to a process (or component, structure, tool, method, etc.}, and the application of the data secures a competiti\ie 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 impro\ie 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 re\ieals cost or price information, production capabilities, budget le\iels, 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 competiti\ie position and foreclose or reduce the availability of profit-making opportunities. The accompanying presentation re\ieals distinguishing aspects about the method by which NuScale de\ielops its probabilistic risk assessment (PRA).
NuScale has performed significant research and evaluation to de\ielop the PRA methodology and has in\iested 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 ha\ie 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 depri\ie NuScale of the opportunity to exercise its competiti\e advantage to seek an adequate return on its im.estment.
(4) The information sought to be withheld is in the enclosed presentation entitled "ACRS Subcommittee Presentation: NuScale FSAR Chapter 19 - Probabilistic Risk Assessment Area of Focus," PM-0220-69046, Revision 0. The enclosure contains the designation "Proprietary" at the top of each page containing proprietary information.
(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 § AF-0220-69048 Page 1 of2
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 Nu Scale.
(b) The information is ofa sort customarily held in confidence by NuScale and, to the best ofmy 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 competiti\e 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 pe~ury that the foregoing is true and correct. Executed on February 28, 2020.
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