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LLC, Submittal of Presentation Materials Entitled US460 Fuel Storage Rack Topical Report, TR-145417-P, PM-148607 Revision 0 (Closed Session)
	ML23229A545
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Site:	99902078, 05200050
Issue date:	08/17/2023
From:	Fosaaen C; NuScale
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
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ML23229A544	List: ML23229A545;
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	LO-148618 PM-148607, Rev 0
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LO-148618 August 17, 2023 Docket No.52-050 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 US460 Fuel Storage Rack Topical Report, TR-145417-P, PM-148607 Revision 0 (Closed Session)

NuScale Power, LLC (NuScale) has requested a meeting with the NRC technical staff on August 22, 2023, to discuss US460 Fuel Storage Rack Topical Report. NuScale requested a closed meeting due to the proprietary nature of the information that will be presented and discussed.

The purpose of this submittal is to provide presentation materials to the NRC for use during this meeting. is the proprietary version of the presentation entitled US460 Fuel Storage Rack Topical Report. NuScale requests that the proprietary version be withheld from public disclosure in accordance with the requirements of 10 CFR § 2.390. The enclosed affidavits support this request (Enclosures 3 and 4). Enclosure 3 pertains to the NuScale proprietary information, denoted by double braces (i.e., ((). Enclosure 4 pertains to the Framatome Inc. (formally AREVA Inc.) proprietary information, denoted by brackets (i.e., [ ]). is the nonproprietary version. This letter makes no regulatory commitments and no revisions to any existing regulatory commitments. If you have any questions, please contact Wren Fowler at 541-452-7183 or at sfowler@nuscalepower.com. Sincerely, Carrie Fosaaen Vice President, Regulatory Affairs NuScale Power, LLC Distribution: Matthew Mitchell, NRC Getachew Tesfaye, NRC David Drucker, NRC Stacy Joseph, NRC NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com

LO-148618 Page 2 of 2 08/17/2023 Enclosure 1: US460 Fuel Storage Rack Topical Report, TR-145417-P, PM-148607-P Revision 0 (Closed Session), proprietary version Enclosure 2: US460 Fuel Storage Rack Topical Report, TR-145417-P, PM-148607-NP Revision 0 (Closed Session), nonproprietary version Enclosure 3: Affidavit of Carrie Fosaaen AF-148611 Enclosure 4: Affidavit of Morris Byram, Framatome NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com

LO-148618 : US460 Fuel Storage Rack Topical Report, TR-145417-P, PM-148607-P Revision 0 (Closed Session), proprietary version NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com

LO-148618 : US460 Fuel Storage Rack Topical Report, TR-145417-P, PM-148607-NP Revision 0 (Closed Sesion), nonproprietary version NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com

NuScale Nonproprietary 1 Pre-Application Presentation US460 Fuel Storage Rack Topical Report, TR-145417-P August 2023 Closed Session PM-148607-NP Rev. 0 Copyright © 2023 NuScale Power, LLC. Template #: 0000-21727-F01 R10

NuScale Nonproprietary 2 Copyright and Trademarks Various images, text, or other works included in this material are copyright © 2007 or later by NuScale Power, LLC. All rights reserved. The works owned by NuScale Power, LLC may not be copied or used to create derivative works without NuScales express permission. NuScales trademarks, logos, service marks, trade dress (NuScale Trademarks) are registered or common law trademarks of NuScale Power, LLC. The NuScale Trademarks are owned by NuScale Power, LLC may not be used without NuScales express written permission. Various trademarks, logos, service marks, trade dress are registered or common law trademarks of its registrants, owners, or licensors, and may not be used without express written permission of the registrants, owners, or licensors. PM-148607-NP Rev. 0 Copyright © 2023 NuScale Power, LLC. Template #: 0000-21727-F01 R10

NuScale Nonproprietary 3 Acknowledgement and Disclaimer This material is based upon work supported by the Department of Energy under Award Number DE-NE0008928. This presentation was prepared as an account of work sponsored by an agency of the United States (U.S.) Government. Neither the U.S. Government nor any agency thereof, nor any of their employees, makes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately owned rights. Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, recommendation, or favoring by the U.S. Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the U.S. Government or any agency thereof. PM-148607-NP Rev. 0 Copyright © 2023 NuScale Power, LLC. Template #: 0000-21727-F01 R10

NuScale Nonproprietary 4 Agenda

Closed Session o Scope of Review o Applicable Regulatory Criteria o Regulatory and Industry Guidance o General Description of Fuel Storage Racks o Applied Software o Structural Analysis o Thermal Hydraulic Analysis o Materials Assessment o Criticality Analysis o Manufacturing and Operation o Projected Review Schedule o Questions PM-148607-NP Rev. 0 Copyright © 2023 NuScale Power, LLC. Template #: 0000-21727-F01 R10

NuScale Nonproprietary 5 Scope of Review

NRC approval for o Design of the fuel storage racks o Appropriateness of the inputs, assumptions, single application of methods, and results of the analyses o Acceptability of the use of the fuel storage racks with the US460 NPM design
Generic approval of the analytical methodologies is not requested PM-148607-NP Rev. 0 Copyright © 2023 NuScale Power, LLC. Template #: 0000-21727-F01 R10

NuScale Nonproprietary 6 Applicable Regulatory Criteria ((

10 CFR Part 50 o Appendix A, General Design Criteria 1, Quality Standards and Records 2, Design Bases for Protection Against Natural Phenomena 4, Environmental and Dynamic Effects Design Bases 5, Sharing of Structures, Systems, and Components 61, Fuel Storage and Handling and Radioactivity Control 62, Prevention of Criticality in Fuel Storage and Handling o Appendix B, Quality Assurance o 50.68, Criticality Accident Requirements

                                                                                                                       }}2(a),(c)

NuScale Nonproprietary 7 Regulatory and Industry Guidance

US NRC Regulatory Guide o 1.29, Revision 6 o 1.61, Revision 1 o 1.183, Revision 0 o 1.240, Revision 0
Standard Review Plan / Design Specific Review Standards o DSRS 3.7.1 o DSRS 3.8.4 o SRP 9.1.1 o DSRS 9.1.2
NUREG Publications o NUREG/CR-6361 o NUREG/CR-6665 o NUREG/CR-6698 o NUREG/CR-7109
NEI 12-16, Revision 4
NEI 16-03A, Revision 0 PM-148607-NP Rev. 0 Copyright © 2023 NuScale Power, LLC. Template #: 0000-21727-F01 R10

NuScale Nonproprietary 8 General Description of Fuel Storage Racks

Non-safety related; ASME NQA-1 augmented quality requirements
Seismic Category I (([
Six [ ] fuel racks provide storage for 10 years of operation
[ ]
[ ]
MAXUS metal matrix composite neutron absorber plates o Located on all four sides of each storage tube o Extend above and below active fuel height o Gaps between adjacent plates considered in criticality analysis model
Fuel parameters: NuFuel-HTP2' o 17x17 array o Maximum enrichment of 4.95 weight percent U235 o 94 inches overall length

                                                                                                                   ]}}2(a),(c)

NuScale Nonproprietary 9 Applied Software

ANSYS - commercially available finite element analysis (FEA) software o Mechanical Version 19.2: used to define finite element model (FEM) of FSR and perform structural analysis o LS-DYNA Version R10.1: used for dynamic analysis of FSR in SFP under load drop and seismic conditions o FLUENT Version 2021/R2: computational fluid dynamic software used to predict fluid temperatures in SFP
SCALE Version 6.2.4 - modeling and simulation software for nuclear design and analysis o KENO V.a: three-dimensional Monte Carlo criticality code used for criticality analysis o TRITON/ORIGEN-S: code module of SCALE used for depletion calculations PM-148607-NP Rev. 0 Copyright © 2023 NuScale Power, LLC. Template #: 0000-21727-F01 R10

NuScale Nonproprietary 10 (([ Structural Analysis

Defines and validates mechanical finite element model
Load drop analysis o [ ] shallow drops

[

o [ ] deep drops [

                                            ]
                                                                                             ]}}2(a),(c) o     Acceptance criteria

[

NuScale Nonproprietary 11 Structural Analysis (continued)

Seismic response time-history analysis consistent with US460 standard design
[

o o o o ]

Whole pool analysis - examines forces during safe shutdown earthquake o Fuel storage rack component stresses - ASME Level A, B, and D criteria Plate and shell support types for all members except support legs Linear support type for support legs o Maximum forces acting on fuel assembly grids Lower than allowable grid loads o Margin to overturning of FSR o Margin to sliding of FSR PM-148607-NP Rev. 0 Copyright © 2023 NuScale Power, LLC. Template #: 0000-21727-F01 R10

NuScale Nonproprietary 12 Thermal Hydraulic Analysis (([

Maximum bulk water temperature o Two trains of cooling available o One train of cooling available
Time to boil with no cooling
Maximum fuel cladding temperature
[

Acceptance criteria o [ ] degrees F or less with two trains of cooling o [ ] degrees F or less with one train of cooling

                                                                                                                     ]}}2(a),(c)

NuScale Nonproprietary 13 Materials Assessment Structural components are [ ]

Extensively used in operating plant components
Meets [ ]
Design lifetime of 80 years MAXUS metal matrix composite neutron absorber
Uniformly distributed boron loading of (([ ]}}2(a),(c)
99.7% pure AA 1070 aluminum matrix
AA 5000 series aluminum cladding
In use in industry (ML15336A084)

NuScale Nonproprietary 14 Criticality Analysis: Storage Configuration (([

                                                                                      ]}}2(a),(c)

NuScale Nonproprietary 15 Criticality Analysis (continued): Multiple Misload Scenarios (([

                                                                                       ]}}2(a),(c)

NuScale Nonproprietary 16 Criticality Analysis (continued)

Methodology o Adherence to RG 1.240 (endorsed NEI 12-16, Revision 4) o Calculations use ENDF/B-VII.1 library o Credit for burnup applied
Off-normal/Accident events o Fuel assembly dropped outside of FSR o Single and multiple fuel assemblies misload o Seismically induced fuel shifting in FSR o Eccentric positioning

[

Acceptance criteria - demonstrate at the 95 percent probability and 95 percent confidence level that o keff <1.0 when pool is flooded with unborated water o keff < 0.95 when pool is flooded with minimally borated water PM-148607-NP Rev. 0 Copyright © 2023 NuScale Power, LLC. Template #: 0000-21727-F01 R10

NuScale Nonproprietary 17 Manufacturing and Operation

Manufacturing in accordance with NQA-1-2008/2009a
No specific maintenance required other than monitoring
Monitoring of neutron absorbers in accordance with NEI 16-03A, Revision 0
Pool water chemistry controlled to minimize corrosion PM-148607-NP Rev. 0 Copyright © 2023 NuScale Power, LLC. Template #: 0000-21727-F01 R10

NuScale Nonproprietary 18 Projected Review Schedule

Submittal in Q4 2023
Target 1 year review duration

NuScale Nonproprietary 20 Acronyms ASME American Society of Mechanical Engineers COLA Combined Operating License Application DCA Design Certification Application DSRS design specific review standard FSAR Final Safety Analysis Report FSR fuel storage rack NEI Nuclear Energy Institute NPM NuScale Power Module SDAA Standard Design Approval Application SFP spent fuel pool SRP standard review plan US460 NPM design with 250 MWt per module US600 NPM design with 160 MWt per module PM-148607-NP Rev. 0 Copyright © 2023 NuScale Power, LLC. Template #: 0000-21727-F01 R10

LO-148618 : Affidavit of Carrie Fosaaen AF-148611 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 Carrie Fosaaen I, Carrie Fosaaen, state as follows: (1) I am the Vice President 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 NuScales competitive position and foreclose or reduce the availability of profit-making opportunities. The accompanying presentation reveals distinguishing aspects about the component design and analysis by which NuScale develops its US460 Fuel Storage Rack Topical Report, TR-145417-P. NuScale has performed significant research and evaluation to develop a basis for this component design and analysis 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. (4) The information sought to be withheld is in the enclosed presentation entitled US460 Fuel Storage Rack Topical Report, TR-145417-P. 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. AF-148611 Page 1 of 2

(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 8/17/23. Carrie Fosaaen AF-148611 Page 2 of 2

LO-148618 : Affidavit of Morris Byram, Framatome NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com

AFFIDAVIT

1. My name is Morris Byram. I am Manager, Licensing & Regulatory Affairs for Framatome Inc. (Framatome) and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by Framatome to determine whether certain Framatome information is proprietary. I am familiar with the policies established by Framatome to ensure the proper application of these criteria.

3. I am familiar with the Framatome information contained in enclosure 1 to NuScale letter LO-148618, entitled US460 Fuel Storage Rack Topical Report, TR-145417-P Revision 0 (Closed Session), dated August 2023, and referred to herein as Document.

Information contained in this Document has been classified by Framatome as proprietary in accordance with the policies established by Framatome for the control and protection of proprietary and confidential information.

4. This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by Framatome and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.

5. This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4) Trade secrets and commercial or financial information.

6. The following criteria are customarily applied by Framatome to determine whether information should be classified as proprietary:

(a) The information reveals details of Framatomes research and development plans and programs or their results. (b) Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service. (c) The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for Framatome. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for Framatome in product optimization or marketability. (e) The information is vital to a competitive advantage held by Framatome, would be helpful to competitors to Framatome, and would likely cause substantial harm to the competitive position of Framatome. The information in this Document is considered proprietary for the reasons set forth in paragraph 6(c) and 6(d) above.

7. In accordance with Framatomes policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside Framatome only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. Framatome policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.

9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.

I declare under penalty of perjury that the foregoing is true and correct. Executed on: (8/17/2023) Digitally signed by BYRAM BYRAM Morris Morris Date: 2023.08.17 13:18:53 -07'00' (NAME) morris.byram@framatome.com}}

ML23229A545

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