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Category:Legal-Affidavit
MONTHYEARML24222A5282024-08-0909 August 2024 LLC, Submittal of NuScale Comprehensive Vibration Assessment Program Measurement and Inspection Plan Technical Report, TR-121354, Revision 1 ML24205A1562024-07-23023 July 2024 LLC, Response to NRC Request for Additional Information No. 14 (RAI-10131 R1, Question 3.9.4-8) on the NuScale Standard Design Approval Application ML24205A2112024-07-23023 July 2024 LLC, Response to NRC Request for Additional Information No. 022 (RAI-10157 R1) on the NuScale Standard Design Approval Application ML24135A2942024-04-25025 April 2024 LLC Resubmittal of Supplemental Information in Support of NRC Review of Topical Report TR-124587-P, Extended Passive Cooling and Reactivity Control Methodology, Revision O (A-XPC.LTR-8 Resubmittal) ML24067A0622024-03-0707 March 2024 LLC, Submittal of Supplemental Information for NuScale Letter LO-130201 ML24047A2522024-02-16016 February 2024 LLC, Response to NRC Request for Additional Information No. 10115 (RAI No. 10115) on the NuScale Standard Design Approval Application ML24024A0552024-01-19019 January 2024 LLC Submittal of Information in Support of NRC Review of Sdaa Chapter 3 ML23361A0992023-12-27027 December 2023 LLC, Response to NRC Request for Additional Information (RAI 10083) on the NuScale Standard Design Approval Application ML23310A1222023-11-0606 November 2023 LLC, Submittal of Supplemental Topical Report Entitled Statistical Subchannel Analysis Methodology, Supplement 1 to TR-0915-17564-P-A, Revision 2, Subchannel Analysis Methodology, TR-108601-P, Revision 4 ML23306A2742023-11-0202 November 2023 LLC, Submittal of Additional Information with the NuScale Standard Design Approval Application, Revision 1 ML23304A3162023-10-31031 October 2023 LLC, Submittal of Revision 1 to Standard Design Approval Application ML23285A3412023-10-12012 October 2023 LLC Submittal of Supplemental Topical Report Entitled Statistical Subchannel Analysis Methodology, Supplement 1 to TR-0915-17564-P-A, Revision 2, Subchannel Analysis Methodology, TR-108601-P, Revision 3 ML23283A3362023-10-0909 October 2023 LLC Submittal of Topical Report Entitled NuScale US460 Fuel Storage Rack Design Topical Report, TR-145417-P, Revision 0 ML23270B1192023-09-20020 September 2023 LLC, Submittal of Information in Support of NRC Review of Chapter 15, Transient and Accident Analyses, Revision 0, NRC Audit Item A-15.0.2-1 ML23263A0252023-09-12012 September 2023 Nu Scale Power, LLC, Submittal of Supplemental Information in Support of Nrg Review of Topical Report TR-124587-P, Extended Passive Cooling and Reactivity Control Methodology, Revision O (Item A-XPC.LTR-4) ML23229A5452023-08-17017 August 2023 LLC, Submittal of Presentation Materials Entitled US460 Fuel Storage Rack Topical Report, TR-145417-P, PM-148607 Revision 0 (Closed Session) ML23205A2172023-07-24024 July 2023 LLC Submittal of the Nrc'S Request for Docketing of Resolved Audit Responses ML23214A2112023-07-18018 July 2023 LLC, Submittal of the NRCs Request for Docketing of Resolved Audit Response A-LOCA L TR-3 ML23198A2442023-07-17017 July 2023 LLC Submittal of Topical Report Methodology for the Determination of the Onset of Density Wave Oscillations (Dwo), TR-131981, Revision 1 ML23195A0922023-07-14014 July 2023 LLC Submittal of Responses to NRC Rsis on Topical Report, Methodology for the Determination of the Onset of Density Wave Oscillations (Dwo), TR-131981, Revision 0 ML23145A0582023-05-18018 May 2023 LLC Submittal of Supplemental Information in Support of Acceptance of TR-131981-P, Methodology for the Determination of the Onset of Density Wave Oscillations, Revision 0, NRC Request for Supplement Information Item RSl-1 ML23132A3242023-05-12012 May 2023 LLC Submittal of White Paper, Edas Supplemental White Paper, Revision 0 ML23045A0992023-02-14014 February 2023 LLC Submittal of Presentation Materials Entitled US460 Design and Sdaa Overview Update, PM-135237, Revision 0 (Closed Session) ML23026A3612023-01-26026 January 2023 LLC Submittal of Presentation Materials Entitled Sdaa Presentation, Treatment of DC Power in Safety Analysis, PM-134581-P, (Closed Session) ML23027A2262023-01-26026 January 2023 LLC, Submittal of Presentation Materials Entitled, Methodology for Determination of Onset of Density Wave Oscillations Post-Application Presentation, PM-134372, Revision 0 (Closed Session) ML23008A0022023-01-0808 January 2023 LLC, Submittal of Topical Report Loss-of-Coolant Accident Evaluation Model, TR-0516-49422, Revision 3 ML23011A0132023-01-0606 January 2023 LLC Submittal of Supplemental Information in Support of NRC Review of Topical Report Entitled, Statistical Subchannel Analysis Methodology, Supplement 1 to TR-0915-17564-P-A, Revision 2, TR-108601, Revision 2 ML23011A0122023-01-0606 January 2023 LLC Submittal of Supplemental Information in Support of NuScale Topical Reports ML23005A3082023-01-0505 January 2023 LLC, Submittal of Topical Report Extended Passive Cooling and Reactivity Control Methodology, TR-124587, Revision 0 ML23005A3052023-01-0505 January 2023 LLC Submittal of Topical Report Non-Loss-of-Coolant Accident Analysis Methodology, TR-0516-49416, Revision 4 ML23001A0022022-12-31031 December 2022 LLC Submittal of the Technical Report, Pipe Rupture Hazards Analysis, TR-121516, Revision 0 ML22365A0132022-12-31031 December 2022 LLC, Submittal of the NuScale Standard Design Approval Application Part 2 - Final Safety Analysis Report, Chapter 18, Human Factors Engineering, Revision 0 ML23001A0182022-12-31031 December 2022 LLC, Submittal of the Technical Report, NuScale Power Module Short-Term Transient Analysis, TR-121517, Revision 0 ML23001A0212022-12-31031 December 2022 LLC Submittal, NuScale Comprehensive Vibration Assessment Program Analysis Technical Report, TR-121353, Revision 0 ML22362A0792022-12-28028 December 2022 LLC Submittal of the NuScale Standard Design Approval Application Part 2 - Final Safety Analysis Report, Chapter 4, Reactor, Revision 0 2024-08-09
[Table view] Category:Letter
MONTHYEARML24222A5282024-08-0909 August 2024 LLC, Submittal of NuScale Comprehensive Vibration Assessment Program Measurement and Inspection Plan Technical Report, TR-121354, Revision 1 ML24205A2112024-07-23023 July 2024 LLC, Response to NRC Request for Additional Information No. 022 (RAI-10157 R1) on the NuScale Standard Design Approval Application ML24205A1562024-07-23023 July 2024 LLC, Response to NRC Request for Additional Information No. 14 (RAI-10131 R1, Question 3.9.4-8) on the NuScale Standard Design Approval Application ML24155A0702024-06-0505 June 2024 Nuscale Power, LLC - Acknowledgement of Disputed Notice of Violation - Nuclear Regulatory Commission Inspection Report 05200050/2024-201 ML24138A2002024-05-24024 May 2024 Audit Status May 2024 - the Staff Review of the Nuscale Power, LLC Standard Design Approval Application - NuScale US460 ML24145A1062024-05-24024 May 2024 LLC Response to NRC Request for Additional Information No. 019 (RAI-10146-R1) on the NuScale Standard Design Approval Application ML24131A1532024-05-10010 May 2024 LLC Reply to a Notice of Violation Noted in IR 05200050/2024-201 ML24122C6122024-05-0101 May 2024 LLC Response to NRC Request for Additional Information No. 009 (RAI-10106) on the NuScale Standard Design Approval Application ML24122C6152024-05-0101 May 2024 LLC, Response to NRC Request for Additional Information No. 005 (RAI-10089-R1) on the NuScale Standard Design Approval Application ML24135A2942024-04-25025 April 2024 LLC Resubmittal of Supplemental Information in Support of NRC Review of Topical Report TR-124587-P, Extended Passive Cooling and Reactivity Control Methodology, Revision O (A-XPC.LTR-8 Resubmittal) ML24108A1222024-04-17017 April 2024 LLC Response to NRC Request for Additional Information No. 10105 (RAI-10105) on the NuScale Standard Design Approval Application ML24099A1292024-04-12012 April 2024 Sdaa QAP Implementation Inspection Report 05200050/2024201 and NOV ML24093A3192024-04-0202 April 2024 LLC - Supplemental Response to NRC Request for Additional Information No. 10083 (RAI-10083) on the NuScale Standard Design Approval Application ML24088A3092024-03-28028 March 2024 LLC, Submittal of Human Factors Engineering Task Analysis Implementation Plan, TR-130413, Revision 1 ML24088A3162024-03-28028 March 2024 LLC, Submittal of Human Factors Engineering Verification and Validation Implementation Plan, TR-130415, Revision 1 ML24075A3232024-03-15015 March 2024 LLC Submittal of Presentation Material Entitled “Acrs Subcommittee Meeting (Open Session) Chapters 2, 10, 11, 13, and 17,” PM-157982, Revision 1 ML24074A4732024-03-14014 March 2024 LLC, Submittal of Presentation Material Entitled “Acrs Subcommittee Meeting (Open Session) Chapters 2, 10, 11, 13, 17, and 18,” PM-157982, Revision 0 ML24067A0622024-03-0707 March 2024 LLC, Submittal of Supplemental Information for NuScale Letter LO-130201 ML24047A2522024-02-16016 February 2024 LLC, Response to NRC Request for Additional Information No. 10115 (RAI No. 10115) on the NuScale Standard Design Approval Application ML24037A1342024-02-0606 February 2024 LLC Response to NRC Request for Additional Information (RAI No. 10101) on the NuScale Standard Design Approval Application ML24025A1462024-01-25025 January 2024 LLC, Submittal of Presentation Materials Entitled Statistical Subchannel Analysis Methodology and Rod Ejection Accident Methodology Topical Reports, ACRS Closed Session, PM-154737, Revision 0 (Closed Session) ML24025A1442024-01-25025 January 2024 LLC Submittal of Presentation Materials Entitled “Statistical Subchannel Analysis Methodology and Rod Ejection Accident Methodology Topical Reports, ACRS Open Session,” PM-154736, Revision 0 (Open Session) ML24024A0552024-01-19019 January 2024 LLC Submittal of Information in Support of NRC Review of Sdaa Chapter 3 ML23361A0992023-12-27027 December 2023 LLC, Response to NRC Request for Additional Information (RAI 10083) on the NuScale Standard Design Approval Application ML23348A2832023-12-13013 December 2023 LLC Submittal of Supplemental Information in Support of Review of Methodology for the Determination of the Onset of Density Wave Oscillations (Dwo), TR-131981-P, Revision 1, Audit Question A-DWO.LTR-11 ML23331A2752023-11-29029 November 2023 Response Request to Reopen the NuScale Standard Design Approval Application Comment Period ML23310A1222023-11-0606 November 2023 LLC, Submittal of Supplemental Topical Report Entitled Statistical Subchannel Analysis Methodology, Supplement 1 to TR-0915-17564-P-A, Revision 2, Subchannel Analysis Methodology, TR-108601-P, Revision 4 ML23306A2742023-11-0202 November 2023 LLC, Submittal of Additional Information with the NuScale Standard Design Approval Application, Revision 1 ML23304A3162023-10-31031 October 2023 LLC, Submittal of Revision 1 to Standard Design Approval Application ML23331A2742023-10-30030 October 2023 Request to Reopen the Nuscale Standard Design Approval Application Comment Period - Request ML23285A3412023-10-12012 October 2023 LLC Submittal of Supplemental Topical Report Entitled Statistical Subchannel Analysis Methodology, Supplement 1 to TR-0915-17564-P-A, Revision 2, Subchannel Analysis Methodology, TR-108601-P, Revision 3 ML23283A3362023-10-0909 October 2023 LLC Submittal of Topical Report Entitled NuScale US460 Fuel Storage Rack Design Topical Report, TR-145417-P, Revision 0 ML23269A0622023-09-29029 September 2023 Audit Status - the Staff Review of the NuScale Power, LLC Standard Design Approval Application NuScale US460 ML23254A1922023-09-22022 September 2023 Resource Estimate Letter for NuScale US460 Standard Design Approval Application Review ML23270B1192023-09-20020 September 2023 LLC, Submittal of Information in Support of NRC Review of Chapter 15, Transient and Accident Analyses, Revision 0, NRC Audit Item A-15.0.2-1 ML23263A0252023-09-12012 September 2023 Nu Scale Power, LLC, Submittal of Supplemental Information in Support of Nrg Review of Topical Report TR-124587-P, Extended Passive Cooling and Reactivity Control Methodology, Revision O (Item A-XPC.LTR-4) ML23229A5452023-08-17017 August 2023 LLC, Submittal of Presentation Materials Entitled US460 Fuel Storage Rack Topical Report, TR-145417-P, PM-148607 Revision 0 (Closed Session) ML23229A5402023-08-17017 August 2023 LLC, Submittal of Presentation Materials Entitled US460 Fuel Storage Rack Topical Report, TR-145417-P, PM-148609 Revision 0 (Open Session) ML23198A1632023-07-31031 July 2023 Acceptance for Docketing of the NuScale US460 Standard Design Approval Application ML23205A2172023-07-24024 July 2023 LLC Submittal of the Nrc'S Request for Docketing of Resolved Audit Responses ML23214A2112023-07-18018 July 2023 LLC, Submittal of the NRCs Request for Docketing of Resolved Audit Response A-LOCA L TR-3 ML23198A2442023-07-17017 July 2023 LLC Submittal of Topical Report Methodology for the Determination of the Onset of Density Wave Oscillations (Dwo), TR-131981, Revision 1 ML23195A0922023-07-14014 July 2023 LLC Submittal of Responses to NRC Rsis on Topical Report, Methodology for the Determination of the Onset of Density Wave Oscillations (Dwo), TR-131981, Revision 0 ML23192A2802023-07-11011 July 2023 LLC, Submittal of Topical Report Quality Assurance Program Description, MN-122626, Revision 1 ML23151A1192023-06-20020 June 2023 Audit Status - the Staff Review of the NuScale Power, LLC Standard Design Approval Application - NuScale US460 ML23145A0582023-05-18018 May 2023 LLC Submittal of Supplemental Information in Support of Acceptance of TR-131981-P, Methodology for the Determination of the Onset of Density Wave Oscillations, Revision 0, NRC Request for Supplement Information Item RSl-1 ML23132A3242023-05-12012 May 2023 LLC Submittal of White Paper, Edas Supplemental White Paper, Revision 0 ML23045A0992023-02-14014 February 2023 LLC Submittal of Presentation Materials Entitled US460 Design and Sdaa Overview Update, PM-135237, Revision 0 (Closed Session) ML23045A0802023-02-14014 February 2023 LLC Submittal of Presentation Materials Entitled, US460 Design and Sdaa Overview Update, PM-135236, Rev. 0 (Open Session) ML23026A3582023-01-26026 January 2023 LLC, Submittal of Presentation Materials Entitled Sdaa Presentation, Treatment of DC Power in Safety Analysis, PM-134582-NP, (Open Session) 2024-08-09
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L0-151314 September 20, 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 Information in Support of NRC Review of Chapter 15, "Transient and Accident Analyses," Revision 0, NRC Audit Item A-15.0.2-1
REFERENCES:
- 1. NuScale Power, LLC, LO-130883, "NuScale Power, LLC Submittal of the NuScale Standard Design Approval Application Part 2 - Final Safety Analysis Report, Chapter 15, 'Transient and Accident Analyses,' Revision O," December 31, 2022 (ML22365A006)
- 2. United States Nuclear Regulatory Commission, "Audit Plan for the Staff Review of the NuScale Power, LLC Standard Design Approval Application-NuScale US460," March 22, 2023, (ML23067A300)
NuScale Power, LLC (NuScale) submitted Chapter 15, "Transient and Accident Analyses,"
Final Safety Analysis Report (FSAR) Revision O (Reference 1). During NRC audit of the chapter submittal, NuScale has agreed to provide additional data to support NRC review of the chapter. This letter provides a set of digital versatile disks (DVDs) of supplemental information to support NRC review containing the information requested by the NRC for review. One disk is being provided for the document control desk, and the other disk is being provided for the NRC reviewers.
Information on the DVDs is highly sensitive, considered NuScale Confidential, Proprietary Class 1, and is also Export Controlled Information. Accordingly, NuScale requests that the DVDs be withheld in their entirety from public disclosure in accordance with the requirements of 10 CFR § 2.390 and 10 CFR § 810. The enclosed affidavit (Enclosure 2) supports this request.
This letter makes no regulatory commitments and no revisions to any existing regulatory commitments.
NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com
L0-151314 Page 2 of2 0912012023 If you have any questions, please contact Thomas Griffith at 541-452-7813 or tgriffith@nuscalepower.com.
Sincerely,
- iA~w-,5~-
Mark W. Shaver Director, Regulatory Affairs NuScale Power, LLC Distribution: Matthew Mitchell, NRG Getachew Tesfaye, NRG David Drucker, N'Rc Stacy Joseph, NRG Enclosure 1: DVD for A-15.0.2-1 Enclosure 2: Affidavit of Carrie Fosaaen, AF-151317 NuScale Power, LLC 1100 NE Circle Blvd, Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com
L0-151314 :
DVD for A-15.0.2-1 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com
L0-151314 NuScale Power, LLC Submittal of Information in Support of NRC Review of Chapter 15, "Transl ent and Accident Analyses," Revision 0, NRC Audit Item A-16.0.2-1 NuScale Confidential, Restricted, Proprietary Class 1 This document contains export controlled information.
NuScale Power, LLC 1100 NE Circle Blvd.
Suite 200 Corvallis, OR 97330 541-360-0500 Nuclea~ Regulatory Commission Copy NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com
L0-151314 :
Affidavit of Carrie Foassen, AF-151317 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 procedur~s 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 response reveals distinguishing aspects about the method by which NuScale develops its Transient and Accident Analyses.
NuScale has performed significant research and evaluation to develop a basis for this method 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 response entitled NuScale Power, LLC Submittal of Information in Support of NRC Review of Chapter 15, "Transient and Accident Analyses," Revision 0, NRC Audit Item A-15.0.2-1.
(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-151317 Page 1 of2
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552(b)(4), as well as exemptions applicable to the NRG 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 NuS.cale. 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 NRG 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 NRG, 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 9/20/2023.
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