ML24089A212

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LLC, Response to NRC Request for Additional Information No. 002 (RAI-10107-R1) on the NuScale Standard Design Approval Application
ML24089A212
Person / Time
Site: 05200050, 99902078
Issue date: 03/29/2024
From: Fosaaen C
NuScale
To:
Office of Nuclear Reactor Regulation, Document Control Desk
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ML24089A211 List:
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RAIO-163033
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RAIO-163033 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com Docket No. 052-050 March 29, 2024 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738

SUBJECT:

NuScale Power, LLC Response to NRC Request for Additional Information No. 002 (RAI-10107-R1) on the NuScale Standard Design Approval Application

REFERENCE:

NRC Letter to NuScale, Request for Additional Information No. 002 (RAI-10107-R1), dated October 13, 2023 The purpose of this letter is to provide the NuScale Power, LLC (NuScale) response to the referenced letter, the NRC Request for Additional Information (RAI) for Chapter 19, Probabilistic Risk Assessment and Severe Accident Evaluation.

The enclosures to this letter contain NuScale's responses to the RAI questions from NRC RAI-10107-R1, as follows:

19.5-1

19.5-2

19.5-3

19.5-4

19.5-5

19.5-6

19.5-7 is the proprietary version of the NuScale responses to NRC RAI-10107-R1.

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. As Enclosure 1 contains Security-Related Information (SRI), NuScale requests that it also be withheld from public disclosure in accordance with the requirements of 10 CFR § 2.390. Enclosure 2 is the nonproprietary version of the NuScale responses.

This letter makes no regulatory commitments and no revisions to any existing regulatory commitments.

RAIO-163033 Page 2 of 2 03/29/2024 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com If you have any questions, please contact Thomas Griffith at 541-452-7813 or at tgriffith@nuscalepower.com.

I declare under penalty of perjury that the foregoing is true and correct. Executed on March 29, 2024.

Sincerely, Carrie Fosaaen Vice President, Regulatory Affairs NuScale Power, LLC Distribution:

Mahmoud Jardaneh, NRC Getachew Tesfaye, NRC Alina Schiller, NRC : NuScale Response to NRC Request for Additional Information RAI-10107-R1, proprietary version : NuScale Response to NRC Request for Additional Information RAI-10107-R1, nonproprietary version : Affidavit of Carrie Fosaaen, AF-163034

RAIO-163033 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com :

NuScale Response to NRC Request for Additional Information RAI-10107-R1, proprietary version

RAIO-163033 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com :

NuScale Response to NRC Request for Additional Information RAI-10107-R1, nonproprietary version

NuScale Nonproprietary NuScale Nonproprietary Response to Request for Additional Information Docket: 052000050 RAI No.: 10107 Date of RAI Issue: 10/13/2023 NRC Question No.: 19.5-1 Regulatory Basis Title 10 of the Code of Federal Regulations Section 50.150(b) requires the applicant to include the following descriptions in the final safety analysis report: (1) The design features and functional capabilities identified in paragraph (a)(1) of 10 CFR 50.150; and (2) How the design features and functional capabilities identified in paragraph (a)(1) of 10 CFR 50.150 meet the assessment requirements in paragraph (a)(1) of 10 CFR 50.150.

Issue Section 19.5.1 states that the design-specific aircraft impact assessment of the Reactor Building (RXB) follows guidelines in NEI 07-13, Revision 8, Methodology for Performing Aircraft Impact Assessments for New Plant Designs with no exceptions. The RXB external steel-plate composite (SC) wall design uses a steel-concrete modular construction that is different from a reinforced concrete wall construction used in the NuScale DCA. Empirical formulas in NEI 07-13, Revision 8 are not applicable for assessing local damages to the external SC walls of the RXB. In Section 2.4.1 (4) of NEI 07-13, Revision 8, it acknowledges that past experience with aircraft impact analysis of nuclear power plant structures has not been all inclusive, and new plant designs may contain design features for which experimental and analytical experience is lacking. NEI 07-13, Revision 8 makes it clear that that these new design features may be subject to failure modes that are outside the existing experience base and may require experimentally verified analytical evaluations.

The application does not make clear whether an analytical evaluation and experimental verification has been performed for the RXB external SC walls subjected to the aircraft impact loading. The application also does not make clear whether there are exceptions taken to NEI 07-13, Revision 8.

NuScale Nonproprietary NuScale Nonproprietary Information Requested

1. Clarify whether the design-specific aircraft impact assessment of the RXB considers the recommendation set forth in Section 2.4.1(4) of NEI 07-13, Revision 8, and clarify whether the design-specific aircraft impact assessment of the RXB includes an analytical evaluation and experimental verification of the RXB external SC walls subjected to the aircraft impact loading.
2. Clarify whether exceptions are taken to methodology in NEI 07-13, Revision 8 and provide the justification to explain why exceptions are taken.
3. Update the FSAR accordingly based on the responses above.

NuScale Response:

Item (1):

Bruhl, et.al. methodology can be used to compute the minimum required steel plate thickness for steel-composite (SC) walls to prevent perforation due to missile impact. This is also supported by AISC N690 which references Bruhl, et.al. for designing SC walls for other missile impact.

Both global and local assessments use experimental data to benchmark the methodology and results.

Existing experimental data is used to verify the analytical structural aircraft impact assessments, which meets NEI 07-13, Revision 8, section 2.4.1(4) recommendations. The structural aircraft impact assessment is performed using LS-DYNA finite element analysis software. The methodology and software are bench-marked against existing physical experimental data for reinforced concrete and steel-composite specimens. Investigated modeling components include: material constitutive models for concrete and steel, element connectivity, contacts, and hourglass formation. The material damage leading to failure is consistent with NEI 07-13 methodology.

Local damage behavior of steel-plate composite walls subject to missile impacts is evaluated based on methodologies verified by experimental data from Bruhl, J. C., et al, Design of composite SC Walls to Prevent Perforation from Missile Impact, International Journal of Impact Engineering, (2015): 75-87.

NuScale Nonproprietary NuScale Nonproprietary Item (2):

The US460 Standard Design Approval Application (SDAA) does not take exception to NEI 07-13, Revision 8. As described above, experimental data is used to verify the design features including software validation, verification, and benchmarking.

Item (3): Proposed US460 SDAA Section 19.5 markups are included in this response.

Impact on US460 SDA:

FSAR Section 19.5 has been revised as described in the response above and as shown in the markup provided with this response.

NuScale Final Safety Analysis Report Adequacy of Design Features and Functional Capabilities Identified and Described for Withstanding Aircraft Impacts NuScale US460 SDAA 19.5-3 Draft Revision 2 19.5.4 Assessment Results 19.5.4.1 Physical Damage Audit Question A-19.5-4S RAI 10107-R1 19.5-2, 19.5-3, 19.5-4, 19.5-5 The RXB external walls resist physical damage from postulated aircraft strikes.

The design of the RXB as described in Section 3B.2 is a key design feature. The design of the RXB equipment door as described in this section is a key design feature for protecting core cooling equipment from impacts through the RWB trolley bay. The RXB equipment door consists of two doors (Figure 19.5-1). The outer door (impact door) serves as a barrier for aircraft impact and other design basis conditions. (( An inner door (blast door) serves primarily for security, airtightness, blast, fire, flood, and other design-basis conditions. The impact door is designed to be wider on each side of the blast door framing to support bearing on the SC walls. Procedural controls minimize the amount of time the RBED is open to ensure a low likelihood of exposure to an aircraft impact. Local reinforcement is provided as required at the wall to slab connection at the 146 ft 6 in. elevation.Additional concrete slab reinforcement is provided as required to strengthen the wall to slab connection at the 146 ft 6 in. elevation and the 187 ft 6 in. elevation. The slab reinforcing dowels into the SC walls on column lines RX-B and RX-D to fully develop the reinforcing strength at the RC slab to SC wall connection during an aircraft impact strike. The walls on RX-B and RX-D are the walls that separate HVAC equipment rooms 704 and 701 from the RXB pool area. The reinforcement prevents structural perforations that could allow physical damage and fire into portions of the RXB where safety-related equipment is housed. This is a key design featureThe reinforcing of the steel-composite (SC) wall to reinforced concrete (RC) slab connections are a key design feature at RXB 146 ft 6 in. elevation and 187 ft 6 in. Local detailing in the wall to wall connection region as required using ties is a key design feature.(( }}. Local detailing with tie rods spaced horizontally and vertically in SC wall to SC wall connection region as required at postulated aircraft strike locations is a key design feature. The ties are required above the 100 ft elevation of the RXB. The structural beam seat connections of roof beams on 187 ft elevation are key design features.The structural steel beam seat connections that connect the roof beams to the SC walls on column lines RX-B and RX-D on 187 ft elevation are key design features. The beam seats support the steel beams from the bottom of the beams.

NuScale Final Safety Analysis Report Adequacy of Design Features and Functional Capabilities Identified and Described for Withstanding Aircraft Impacts NuScale US460 SDAA 19.5-4 Draft Revision 2 RAI 10107-R1 19.5-6 The design of the Reactor Building penetration and piping protections are key design features for preventing physical damage and fire from entering the RXB. The exterior wall penetration protection (awning) is designed and constructed to provide strength to prevent perforation due to a direct aircraft strike. The exterior wall penetration protections are constructed of 7000 psi concrete with two

  1. 11 bars at 12 inches on each face of the awning and each way (horizontal and vertical directions). In addition, the awning protection has #5 shear ties at 12 inches on center. The pipe penetration protections are located at exterior wall penetrations above grade, primarily where main steam and feedwater pipes exit the RXB. Figure 1.2-17 shows the RXB north and south section view.

The NEI 07-13 criteria (Reference 19.5-1) are used to minimize physical damage from strikes to external openings in the RXB external walls. Doors and penetrations leading into SC-I portions of the RXB are protected to prevent physical damage and fire from an aircraft impact from entering SC-I portions of the RXB. RAI 19.5-7 The trolley on the Reactor Building crane (RBC) cannot be struck and dislodged, because there is no perforation of the RXB outer wall. The design of the RBC, as described in Section 9.1.5, is a key design feature for ensuring that impact loads from an aircraft impact on the exterior wall of the RXB do not result in the crane falling into the reactor pool area and damaging the NPMs or damaging the RXB structure containing the UHS. The design and location of the RBC as described in Section 9.1.5 is a key design feature for protecting the NPMs. 19.5.4.2 Shock Damage The impact of a commercial aircraft on the RXB structure causes a short duration, high acceleration, high frequency vibration. Shock damage distances are measured from the center of the initial impact along a structural pathway to affected equipment. Shock effects do not affect the spent fuel pool structure nor the ability to retain the pool water inventory. The NPMs are shut down by operator action before impact, and core cooling is provided by passive systems (e.g., the decay heat removal system (DHRS)). There are no SSC susceptible to shock (sensitive electronics or active components) on the NPMs that interrupt or prevent successful core cooling once the reactor is tripped, the DHRS is actuated, and containment is isolated. There is no impact of concern below the 55-ft elevation. The SFP cooling equipment is located on elevation 55 ft and 70 ft of the RXB. Other affected equipment at the 55 ft, 70 ft, 85 ft, 100 ft, 126 ft, and 146 ft 6 in. elevations is not required to maintain core cooling or spent fuel cooling.

NuScale Final Safety Analysis Report Adequacy of Design Features and Functional Capabilities Identified and Described for Withstanding Aircraft Impacts NuScale US460 SDAA 19.5-7 Draft Revision 2 19.5.5.3 Spent Fuel Pool Integrity RAI 10107-R1 19.5-7 The east, west, and south SFP walls are constructed as described in Section 3B.2. The design uses SC interior and exterior walls and RC basemat and slabs. The foundation of the SFP is constructed as described in Section 3.8.5. The reinforced concrete floor has a stainless steel liner as described in Section 3.8.4. The SFP is integrated into the RXB structure and is located below grade. Because the SFP is completely below grade, an aircraft impact cannot strike the pool or the pool liner. Thus, the pool liner is not a key design feature. Because there is no damage to the pool structure, there is no loss of water level and SFP integrity is maintained. The location of the SFP, as described in Section 9.1.2 and shown on Figure 1.2-8 through Figure 1.2-15, is a key design feature for maintaining SFP integrity from a direct aircraft impact. There are multiple hoist systems inside the RXB that can be operated over the SFP area: the fuel handling machine, the new fuel jib crane, and the new fuel elevator. The reactor building crane is designed to the ASME standards specified in Table 9.1.5-1. There are seismic restraints on the RBC, as shown on Figure 9.1.5-1. Because the exterior wall of the RXB is not perforated, the trolleys cannot be dislodged to fall into the reactor pool. Additionally, there are seismic restraints on the fuel handling machine, as described in Section 9.1.4. The design and location of the fuel handing equipment and reactor building crane, are key design features for ensuring the hoists remain intact and cannot fall into the SFP. 19.5.5.4 Spent Fuel Pool Cooling Spent fuel pool cooling is not maintained for the postulated strike locations due to shock or to loss of power. However, as described in Section 19.5.5.3, SFP integrity is maintained, and SFP cooling is not required for beyond the mission time, even with the loss of forced SFP cooling. The SFP is part of the ultimate heat sink, which provides water inventory and ensures an adequate water level is maintained above the spent fuel assemblies. 19.5.5.5 Plant Monitoring and Control For the postulated aircraft impact event, required operator actions occur before the aircraft impact, upon notification of the threat. Operators trip the individual NPMs and initiate containment isolation and decay heat removal systems. Following the aircraft impact event, monitoring functions are expected to remain available. However, in the event that post-aircraft impact monitoring is determined to be unavailable, mitigating strategies for the loss of large area (LOLA) beyond-design-basis event are invoked. The actions taken by the operators before the aircraft impact ensure that the reactor core and spent fuel remains cooled, containment remains intact, and spent fuel pool integrity is maintained.

NuScale Final Safety Analysis Report Adequacy of Design Features and Functional Capabilities Identified and Described for Withstanding Aircraft Impacts NuScale US460 SDAA 19.5-8 Draft Revision 2 19.5.6 Conclusion The aircraft impact assessment concludes that the NuScale Power Plant US460 design and functional capabilities provide adequate protection of public health and safety in the event of an impact of the NRC-defined large commercial aircraft. Containment intact, core cooling capability, and spent fuel pool integrity are not impaired as a result of the postulated aircraft impacts. 19.5.7 References 19.5-1 Nuclear Energy Institute, Methodology for Performing Aircraft Impact Assessments for New Plant Designs, NEI 07-13, Revision 8, Washington, DC, April 2011. RAI 10107-R1 19.5-1 19.5-2 Bruhl, J. C., et al, Design of composite SC Walls to Prevent Perforation from Missile Impact,, International Journal of Impact Engineering, (2015): 75-87.

NuScale Final Safety Analysis Report Adequacy of Design Features and Functional Capabilities Identified and Described for Withstanding Aircraft Impacts NuScale US460 SDAA Draft Revision 2 19.5-9 RAI 10107-R1 19.5-2 Figure 19.5-1: General Arrangement Reactor Building Equipment Door ^^ }`

NuScale Nonproprietary NuScale Nonproprietary Response to Request for Additional Information Docket: 052000050 RAI No.: 10107 Date of RAI Issue: 10/13/2023 NRC Question No.: 19.5-2 Regulatory Basis Title 10 of the Code of Federal Regulations Section 50.150(b) requires the applicant to include the following descriptions in the final safety analysis report: (1) The design features and functional capabilities identified in paragraph (a)(1) of 10 CFR 50.150; and (2) How the design features and functional capabilities identified in paragraph (a)(1) of 10 CFR 50.150 meet the assessment requirements in paragraph (a)(1) of 10 CFR 50.150. Issue NuScale SDAA Section 19.5.4.1 states that the design of the RXB equipment door, as described in this section, is a key design feature for protecting core cooling equipment from impacts through the Radioactive Waste Building (RWB) trolley bay. The RXB equipment door consists of two doors (Figure 19.5-1). The outer door (impact door) serves as a barrier for aircraft impact and other design basis conditions. Section 19.5.3.2 states that no credit is taken for the RWB, Control Building (CRB) or the Turbine Generator Building (TGB) as intervening structures. All RXB elevations and faces above grade are vulnerable. NuScale DCA Part 2, Tier 2, Section 19.5.3.2 states that the location of the RWB in relation to the RXB is a key design feature that limits potential strike locations to the west end of the RXB. The design of the exterior walls of the RWB, as described in Section 3.5.3.1.1, is a key design feature for crediting the RWB as an intervening structure. The application does not make clear what the thickness and construction of the RXB equipment door is. Since the applicant does not credit the RWB as an intervening structure, the application does not make clear whether the applicant has performed a design-specific aircraft impact assessment to resist physical damage from all postulated aircraft strikes for protecting core cooling equipment from impacts through the RWB trolley bay when the RXB equipment door is open. Figure 19.5-1 is very schematic, and it does not reflect realistic conditions of the RXB external SC wall and the construction of the RXB equipment door.

NuScale Nonproprietary NuScale Nonproprietary Information Requested

1. Describe the thickness and construction of the RXB equipment door.
2. Update Figure 19.5-1 to reflect realistic conditions of the RXB external SC wall and the RXB equipment door.
3. Clarify (a) whether a design-specific aircraft impact assessment has been performed to resist physical damage from all postulated aircraft strikes in order to protect core cooling equipment from impacts through the RWB trolley bay when the RXB equipment door is open; or (b) the RWB could be credited as an intervening structure in the design-specific aircraft impact assessment of the RXB; or (c) provide justification based on expected frequency and duration of when the door will be open, including the administrative controls in place, that the RXB equipment door when open has sufficiently low likelihood to be subjected to aircraft impact.
4. Update the FSAR accordingly based on the responses above.

NuScale Response: The aircraft impact assessment (AIA) of the Reactor Building (RXB) follows the guidelines in NEI 07-13 Revision 8 Section 2.4.1(4) with no exceptions. NuScales AIA strategy is to keep physical damage and fire from an aircraft impact out of the RXB with the exception of the stairwells. The AIA considers protecting openings or penetrations smaller than a personnel door (approximately 3 ft by 7 ft) small enough that physical damage will not get through the opening. Item (1): The reactor building equipment door (RBED) is located at a single wall opening on the west end of the 100 ft elevation of the RXB, on column line RX-1, between column lines RX-B and RX-C. There are two separate doors at this one wall opening to meet the functional requirements to stop physical damage and fire. RBED consists of two doors. One is a steel-composite (SC) with similar structural properties as RXB walls, which stops physical damage. A second door inside of the SC door prevents pressurized fire from entering the RXB. The RBED meets the design requirements provided in RG 1.76.

NuScale Nonproprietary NuScale Nonproprietary (( }} Item (2): US460 Standard Design Approval Application (SDAA) Figure 19.5-1 is revised as shown by SDAA 19.5 markups. Item (3a): Similar to approved US600 Design Certification Application (DCA), the AIA assumes advanced warning of a postulate aircraft impact. Upon notification of the aircraft threat, operators trip the individual NuScale Power Module (NPM) and initiate containment isolation and the decay heat removal systems. If the RBED is open at time of an advanced warning, then the RBED will be closed prior to impact. Therefore, the AIA does not evaluate a postulated aircraft impact when the RBED is open. As noted in the US600 DCA and US460 SDAA, the actions taken by the operators before the aircraft impact ensure that the reactor core and spent fuel remains cooled, containment remains intact, and spent fuel pool integrity is maintained. Design features are automatic or can be initiated and operated from the control room or an alternate location, and require minimal or no, further operator intervention to maintain the core cooling function. Item (3b): The RWB is not credited as an intervening structure on the west side of the RXB. The west wall of the RXB at elevations above grade and the RBED that aligns with the RWB trolley bay are assessed for physical damage of a postulated aircraft impact strikes. Item (3c): The RBED is designed to resist the physical, shock, and fire effects of an aircraft impact. The RBED shall prevent penetration and fire entry into the RXB to protect against physical damage of components within the RXB. As noted in US460 SDAA Section 19.5.5.5, for the postulated aircraft impact event, required operator actions occur before the aircraft impact, upon notification of the potential threat. The actions taken by the operators before the aircraft impact ensure that the reactor core and spent fuel remains cooled, containment remains intact, and spent fuel pool integrity is maintained.

NuScale Nonproprietary NuScale Nonproprietary (( }} As for administrative controls, the RBED follows plant procedures utilized by the operating organization to ensure that routine operating, off-normal, and emergency activities are conducted in a safe manner as noted in US460 SDAA Section 13.5. Item (4): US460 SDAA Section 19.5 is revised as shown by markups. Impact on US460 SDA: FSAR Section 19.5 has been revised as described in the response above and as shown in the markup provided below and those provided in the response to Question 19.5-1.

NuScale Final Safety Analysis Report Conformance with Regulatory Criteria NuScale US460 SDAA 1.9-29 Draft Revision 2 1.210 Qualification of Safety-Related Battery Chargers and Inverters for Nuclear Power Plants 0 Not Applicable The design does not use safety-related battery chargers or inverters. Not Applicable 1.211 Qualification of Safety-Related Cables and Field Splices for Nuclear Power Plants 0 Conforms None. 3.11 1.212 Sizing of Large Lead-Acid Stor-age Batteries 1 Not Applicable This guidance is written in the context of a safety-related standby battery system and endorses IEEE Std. 485-2010. The nonsafety-related normal DC power system and EDAS batteries are sized in accor-dance with IEEE Std. 485-2020. Not Applicable 1.213 Qualification of Safety-Related Motor Control Centers for Nuclear Power Plants 0 Not Applicable The electrical system design does not use safety-related motor control centers. Not Applicable 1.214 Response Strategies for Poten-tial Aircraft Threats 1 Conforms Not Applicable None.This guidance is pertinent to 10 CFR 50.54(hh)(1), which is applicable for downstream licensees. There-fore, conformance with this guidance is the responsibility of downstream applicants or licensees. Not Applicable19.5 1.215 Guidance for ITAAC Closure Under 10 CFR Part 52 2 Not Applicable This guidance describes acceptable methods of comply-ing with the requirements of 10 CFR 52.99, which is applicable to applicants and licensees. Not Applicable 1.216 Containment Structural Integrity Evaluation for Internal Pressure Loadings Above Design-Basis Pressure 0 Conforms None. 3.8.2 6.2 1.217 Guidance for the Assessment of Beyond-Design-Basis Aircraft Impacts 0 Conforms None. 19.5 1.218 Condition-Monitoring Tech-niques for Electric Cables Used in Nuclear Power Plants 0 Not Applicable The applicant determines whether a cable is subject to condition monitoring during the development of the maintenance rule (10 CFR 50.65) program. Cables that meet the criteria for inclusion in the program are subject to the guidance of RG 1.218. Not Applicable 1.219 Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors 1 Not Applicable This guidance is applicable to operating reactor licens-ees, including applicants. Not Applicable Table 1.9-2: Conformance with Regulatory Guides (Continued) RG Title Rev. Conformance Status Comments Section

Response to Request for Additional Information Docket: 052000050 RAI No.: 10107 Date of RAI Issue:10/13/2023 NRC Question No.: 19.5-3 Regulatory Basis Title 10 of the Code of Federal Regulations Section 50.150(b) requires the applicant to include the following descriptions in the final safety analysis report: (1) The design features and functional capabilities identified in paragraph (a)(1) of 10 CFR 50.150; and (2) How the design features and functional capabilities identified in paragraph (a)(1) of 10 CFR 50.150 meet the assessment requirements in paragraph (a)(1) of 10 CFR 50.150. Issue Section 19.5.4.1 states that local reinforcement provided as required at the wall-to-slab connection at the 146 feet 6-inch elevation is a key design feature. The staff reviewed Figures 1.2-16 and 1.2-17 for the Reactor Building Section Views. The wall-to-slab connections at the 146 feet 6 inch elevation could be perimeter external SC wall-to-slab connections or interior SC wall-to-slab connections. In addition, the application does not make clear how the local reinforcing bars are configured, including their sizes, spacing and lengths. Information Requested

1. Clarify locations of the wall-to-slab connections at the 146 feet 6 inch elevation which are applicable to this key design feature.
2. Provide detailed section views to show configurations of local reinforcing bars, their sizes, spacing and lengths.
3. Clarify whether this key design feature is applicable to the wall-to-slab connections at other elevations.
4. Update the FSAR accordingly based on the responses above.

NuScale Nonproprietary NuScale Nonproprietary

NuScale Response: Item (1): The reinforcing of the steel-composite (SC) wall to reinforced concrete (RC) slab connections are a key design feature at Reactor Building (RXB) 146 ft 6 in. elevation. (( }}2(a),(c) The reinforced slab areas on the 146 ft 6 in. elevation are above two fire areas as shown on US460 Standard Design Approval Application (SDAA) Figure 1.2-14 elevation 126 ft. Item (2): The connection between the SC wall and the RC slab at elevation 146 ft 6 in. is strengthened by using additional reinforcement as illustrated in Figure 1. (( }}2(a),(c) The rebar reinforcement is shown in the section view in Figure 2. Item (3): This key design feature is at the 146 ft 6 in. elevation. Reinforcing is required to strengthen the RXB for an aircraft impact strike to the walls on the slabs near grids RX-B and RX-D. The reinforcement prevents structural perforations that could allow physical damage and fire into portions of the RXB where safety-related equipment is housed. Item (4): Proposed US460 SDAA Section 19.5 markups are shown in this response. NuScale Nonproprietary NuScale Nonproprietary

(( }} NuScale Nonproprietary NuScale Nonproprietary

(( }} Impact on US460 SDA: FSAR Section 19.5 has been revised as described in the response above and as shown in the markups associated with the response to Question 19.5-1. NuScale Nonproprietary NuScale Nonproprietary

NuScale Nonproprietary NuScale Nonproprietary Response to Request for Additional Information Docket: 052000050 RAI No.: 10107 Date of RAI Issue: 10/13/2023 NRC Question No.: 19.5-4 Regulatory Basis Title 10 of the Code of Federal Regulations Section 50.150(b) requires the applicant to include the following descriptions in the final safety analysis report: (1) The design features and functional capabilities identified in paragraph (a)(1) of 10 CFR 50.150; and (2) How the design features and functional capabilities identified in paragraph (a)(1) of 10 CFR 50.150 meet the assessment requirements in paragraph (a)(1) of 10 CFR 50.150. Issue Section 19.5.4.1 states that local detailing in the wall-to-wall connection region as required using ties is a key design feature. The application does not make clear where these wall-to-wall connections are located on plans and elevations, and the configurations of local reinforcing bars, including their sizes, spacing and lengths. Information Requested

1. Clarify the locations of the wall-to-wall connections on plans and elevations.
2. Provide detailed section views to show reinforcing ties including their configurations, sizes, spacing and lengths between the 100 feet and 146 feet 6 inch elevations and above the 146 feet 6 inch elevation.
3. Update the FSAR accordingly based on the responses above.

NuScale Nonproprietary NuScale Nonproprietary NuScale Response: Item (1): The wall to wall connection requiring ties is a key design feature for the Reactor Building (RXB). Only steel-composite (SC) wall to wall connections requiring tie reinforcing are key design features. (( }}2(a),(c). The ties are required above the 100 ft elevation of the RXB. Item (2): Figure 1 shows details of wall to wall connections at the building corners, and Figure 2 shows wall to wall intersections. Item (3): Proposed US460 Standard Design Approval Application (SDAA) Section 19.5 markups are shown in this response.

NuScale Nonproprietary NuScale Nonproprietary (( }}

NuScale Nonproprietary NuScale Nonproprietary (( }} Impact on US460 SDA: FSAR Section 19.5 has been revised as described in the response above and as shown in the markups associated with the response to Question 19.5-1.

NuScale Nonproprietary NuScale Nonproprietary Response to Request for Additional Information Docket: 052000050 RAI No.: 10107 Date of RAI Issue: 10/13/2023 NRC Question No.: 19.5-5 Regulatory Basis Title 10 of the Code of Federal Regulations Section 50.150(b) requires the applicant to include the following descriptions in the final safety analysis report: (1) The design features and functional capabilities identified in paragraph (a)(1) of 10 CFR 50.150; and (2) How the design features and functional capabilities identified in paragraph (a)(1) of 10 CFR 50.150 meet the assessment requirements in paragraph (a)(1) of 10 CFR 50.150. Issue Section 19.5.4.1 states that the structural beam seat connections of roof beams on the 187 feet elevation are key design features. The application does not make clear where the structural beam seat connections of roof beams on the 187 feet elevation are located and what are the details of the structural beam seat connections. The application also does not make clear whether the wall-to-slab connection on the 187 feet elevation is a key design feature. Information Requested

1. Clarify where the structural beam seat connections of roof beams on the 187 ft elevation are located.
2. Provide section views and reinforcing details of the structural beam seat connections of roof beams and the wall-to-slab connections on the 187 ft elevation.
3. Explain why the structural beam seat connections of roof beams on the 187 ft elevation are key design features.
4. Clarify whether the wall-to-slab connections on the 187 ft elevation are key design features and clarify where they are located.
5. Update the FSAR accordingly based on the responses above.

NuScale Nonproprietary NuScale Nonproprietary NuScale Response: Item (1): This beam seat connection is a key design feature in the reactor building (RXB). The beams in question are steel beams that support the concrete slab at 187 ft elevation of the RXB. The beam seats are the connections to the walls at both ends of the beams on grids RX-B and RX-D. The walls on RX-B and RX-D are the walls that separate HVAC equipment rooms 704 and 701 from the RXB pool area a shown in US460 Standard Design Approval Application (SDAA) Figure 1.2-15. Item (2): (( }}2(a),(c) Item (3): These beam seats are required to support the beams during and after an aircraft impact. In addition, the beam seats prevent the beams from falling from the roof elevation 187 ft. Item (4): The wall-to-slab connections on the 187 ft elevation are key design features. This connection occurs on the north and south sides of the roof slab on the 187 ft elevation where the slab connects to the SC wall below the slab. Item (5): Proposed US460 SDAA Section 19.5 markups are shown in this response.

NuScale Nonproprietary NuScale Nonproprietary (( }} Impact on US460 SDA: FSAR Section 19.5 has been revised as described in the response above and as shown in the markups associated with the response to Question 19.5-1.

NuScale Nonproprietary NuScale Nonproprietary Response to Request for Additional Information Docket: 052000050 RAI No.: 10107 Date of RAI Issue: 10/13/2023 NRC Question No.: 19.5-6 Regulatory Basis Title 10 of the Code of Federal Regulations Section 50.150(b) requires the applicant to include the following descriptions in the final safety analysis report: (1) The design features and functional capabilities identified in paragraph (a)(1) of 10 CFR 50.150; and (2) How the design features and functional capabilities identified in paragraph (a)(1) of 10 CFR 50.150 meet the assessment requirements in paragraph (a)(1) of 10 CFR 50.150. Issue Section 19.5.4.1 states that the design of the RXB penetration and piping protections are key design features for preventing physical damage and fire from entering the RXB. The exterior wall penetration protection (awning) is designed and constructed to provide strength to prevent perforation due to a direct aircraft strike. The exterior wall penetration protections are constructed of 7000 psi concrete with two #11 bars at 12 inches on each face of the awning and each way (horizontal and vertical directions). In addition, the awning protection has #5 shear ties at 12 inches on center. The application does not make clear where these exterior wall penetrations (awnings) and piping protections are located and how they are constructed with the RXB external SC walls. Information Requested

1. Provide detailed reinforcing drawings of the RXB penetration protections (awnings) and piping protections connecting with the RXB external SC walls.
2. Describe where the exterior wall penetration protections (awnings) and piping protections are located.
3. Update the FSAR accordingly based on the responses above.

NuScale Nonproprietary NuScale Nonproprietary NuScale Response: Item (1): The external awnings are attached to the North and South exterior structural composite (SC) walls of the reactor building (RXB). The reinforcement of the awnings are the key design feature for the piping and penetration protection as stated in US460 Standard Design Approval Application (SDAA) Section 19.5.4.1, not the connection to the SC wall. The key design feature is described as 7000 psi concrete with two #11 bars at 12 inches on each face of the awning and each way (horizontal and vertical direction). In addition, the awning protection has #5 shear ties at 12 inches on center. A visual representation of the reinforcement configuration is shown in Figure 1 details this key design feature. Item (2): The external awnings are attached to the North and South exterior structural composite walls with the top of concrete 27-0 above finished grade. The pipe penetration protections are located at exterior wall penetrations above grade, primarily where main steam and feedwater pipes exit the RXB. The US460 SDAA provides Figure 1.2-17 showing the RXB north-south section view. Item (3): Proposed US460 SDAA Section 19.5 markups are shown in this response.

NuScale Nonproprietary NuScale Nonproprietary (( }} Impact on US460 SDA: FSAR Section 19.5 has been revised as described in the response above and as shown in the markups associated with the response to Question 19.5-1.

NuScale Nonproprietary NuScale Nonproprietary Response to Request for Additional Information Docket: 052000050 RAI No.: 10107 Date of RAI Issue: 10/13/2023 NRC Question No.: 19.5-7 Regulatory Basis Title 10 of the Code of Federal Regulations Section 50.150(b) requires the applicant to include the following descriptions in the final safety analysis report: (1) The design features and functional capabilities identified in paragraph (a)(1) of 10 CFR 50.150; and (2) How the design features and functional capabilities identified in paragraph (a)(1) of 10 CFR 50.150 meet the assessment requirements in paragraph (a)(1) of 10 CFR 50.150. Issue NuScale SDAA Section 19.5.4.1 states that the design and location of the reactor building crane (RBC), as described in Section 9.1.5, is a key design feature for protecting the NPMs. NuScale DCA Part 2, Tier 2, Section 19.5.4.1 states that the design and location of the RBC, as described in Section 9.1.5, is a key design feature for protecting the NPMs and the reactor pool lining. The application does not make clear whether the reactor pool lining needs to be protected by the key design feature in NuScale SDAA. Information Requested

1. Clarify whether the reactor pool lining needs to be protected by the key design feature in NuScale SDAA. If the reactor pool lining needs to be protected in this key design feature, update the key design feature, otherwise provide the justification why the reactor pool lining does not need to be protected in this key design feature.
2. Update the FSAR accordingly based on the response above.

NuScale Nonproprietary NuScale Response: The design of the reactor building crane (RBC) is a key design feature for protecting the NuScale Power Module (NPM). The US460 Standard Design Approval Application (SDAA) Section 3.7.2 notes that the location of the RBC is selected to maximize the in-structure response spectra (ISRS) in the Reactor Building (RXB). US460 SDAA Section 9.1.5 states that RBC is designed to ensure it retains its load throughout a safe-shutdown earthquake (SSE) and not drop the load. Thus the location of the RBC is not a key design feature. Item (1): As noted in US460 SDAA Section 3.8.4, the spent fuel pool (SFP) is integrated into the RXB structure and is located below grade. Because the SFP is completely below grade, an aircraft impact cannot strike the pool or the pool liner. Both the SFP and pool liner are not subject to physical damage or fire effects from a postulated aircraft impact. Additionally, the pool liner does not serve as a safety function and thus the pool liner is not a key design feature. Item (2): Proposed US460 SDAA Section 19.5 markups are shown in this response. Impact on US460 SDA: FSAR Section 19.5 has been revised as described in the response above and as shown in the markups associated with the response to Question 19.5-1. NuScale Nonproprietary

RAIO-163033 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com : Affidavit of Carrie Fosaaen, AF-163034

AF-163034 Page 1 of 2 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 Request for Additional Information response reveals distinguishing aspects about the response by which NuScale develops its NuScale Power, LLC Response to NRC Request for Additional Information (RAI-10107-R1) on the NuScale Standard Design Approval Application. NuScale has performed significant research and evaluation to develop a basis for this response 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, NuScales 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 NuScales 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 are in the enclosed responses to NRC Request for Additional Information RAI-10107-R1, Chapter 19.5. 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-163034 Page 2 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 NuScales 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 March 29, 2024. Carrie Fosaaen}}

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