ML24346A131
| ML24346A131 | |
| Person / Time | |
|---|---|
| Site: | 05200050 |
| Issue date: | 12/11/2024 |
| From: | Shaver M NuScale |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML24346A130 | List:
|
| References | |
| LO-175762 | |
| Download: ML24346A131 (1) | |
Text
LO-175762 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com December 11, 2024 Docket No. 052-050 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 the NRCs Request for Docketing of Resolved Audit Responses
REFERENCE:
NRC Letter to NuScale Power entitled, Audit Status - The Staff Review of the NuScale Power, LLC Standard Design Approval Application - NuScale US460, Dated October 24, 2024 (ML24269A008)
The purpose of this letter is to provide NuScale's response to the NRCs request to docket certain audit responses, noted in the reference above. The responses to the individual audit items are provided in the attachments.
This letter contains NuScale's responses to the following audit questions from the NRC:
Chapter 1
- 1. Information related to FSAR Section 1.6, Material Referenced.
One Item:
A-1.6-1 (Nonproprietary)
Chapter 2
- 1. Information related to FSAR Section 2.5.4, Stability of Subsurface Materials and Foundations.
Four Items:
A-2.5.4-1 (Nonproprietary)
A-2.5.4-1S (Nonproprietary)
A-2.5.4-7 (Nonproprietary)
A-2.5.4-8 (Nonproprietary)
Chapter 3
- 1. Information related to FSAR Section 3.5.1, Missile Selection and Description.
One Item:
A-3.5.1.3-2 (Nonproprietary)
- 2. Information related to FSAR Section 3.7.2, Seismic System Analysis.
One Item:
A-3.7.2-32 (Proprietary and Nonproprietary)
LO-175762 Page 2 of 9 12/11/2024 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com
- 3. Information related to FSAR Section 3.8.5, Foundations.
One Item:
A-3.8.5-8 (Nonproprietary)
- 4. Information related to FSAR Section 3.9.2, Dynamic Testing and Analysis of Systems, Components, and Equipment.
Six Items:
A-3.9.2-24 (Nonproprietary)
A-3.9.2-26 (Proprietary and Nonproprietary)
A-3.9.2-26-F (Proprietary and Nonproprietary)
A-3.9.2-28 (Proprietary and Nonproprietary)
A-3.9.2-34 (Proprietary and Nonproprietary)
A-3.9.2-35 (Proprietary and Nonproprietary)
- 5. Information related to FSAR Section 3.11, Environmental Qualification of Mechanical and Electrical Equipment.
One Item:
A-3.11-7 (Proprietary and Nonproprietary)
Chapter 4
- 1. Information related to FSAR Section 4.2, Fuel System Design.
Two Items:
A-4.2-5 (Proprietary and Nonproprietary)
A-4.2-9 (Proprietary and Nonproprietary)
- 2. Information related to FSAR Section 4.3, Nuclear Design.
Seven Items:
A-4.3-10 (Proprietary and Nonproprietary)
A-4.3-25 (Nonproprietary)
A-4.3-29 (Nonproprietary)
A-4.3-30 (Nonproprietary)
A-4.3-31 (Nonproprietary)
A-4.3-32 (Nonproprietary)
A-4.3-33 (Proprietary and Nonproprietary)
- 3. Information related to FSAR Section 4.4, Thermal and Hydraulic Design Two Items:
A-4.4-1 (Proprietary and Nonproprietary)
A-4.4-3 (Proprietary and Nonproprietary)
- 4. Information related to FSAR Section 4.5.2, Reactor Internals and Core Support Structure Materials.
One Item:
A-4.5.2-4 (Nonproprietary)
LO-175762 Page 3 of 9 12/11/2024 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com
- 5. Information related to Licensing Technical Report, NuFuel-HTP2TM Fuel and Control Rod Assembly Designs.
Three Items:
A-4.FuelCR.TeR-3 (Proprietary and Nonproprietary)
A-4.FuelCR.TeR-6 (Proprietary and Nonproprietary)
A-4.FuelCR.TeR-10 (Proprietary and Nonproprietary)
Chapter 5
- 1. Information related to FSAR Section 5.2.4.1, Inservice Inspection and Testing Program.
One Item:
A-5.2.4.1-2 (Proprietary and Nonproprietary)
- 2. Information related to FSAR Section 5.2.5, Reactor Coolant Pressure Boundary Leakage Detection.
One Item:
A-5.2.5-6 (Nonproprietary)
- 3. Information related to FSAR Section 5.3.2.2, Operating Procedures.
One Item:
A-5.3.2.2-1 (Nonproprietary)
- 4. Information related to FSAR Section 5.4.3, Decay Heat Removal System.
Three Items:
A-5.4.3-3 (Nonproprietary)
A-5.4.3-5 (Proprietary and Nonproprietary)
A-5.4.3-7 (Nonproprietary)
- 5. Information related to FSAR Section 5.4.5, Pressurizer One Item:
A-5.4.5-1 (Proprietary and Nonproprietary)
- 6. Information related to FSAR Section 5.4, Reactor Coolant System Component and Subsystem Design.
Two Items:
A-5.4-9 (Nonproprietary)
A-5.4-10 (Proprietary and Nonproprietary)
LO-175762 Page 4 of 9 12/11/2024 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com Chapter 6
- 1. Information related to FSAR Section 6.1, Engineered Safety Feature Materials.
Five Items:
A-6.1.1-2 (Proprietary and Nonproprietary)
A-6.1.1-3 (Proprietary and Nonproprietary)
A-6.1.1-4 (Proprietary and Nonproprietary)
A-6.1.1-5 (Nonproprietary)
A-6.1.1-6 (Nonproprietary)
- 2. Information related to FSAR Section 6.2, Containment Structure.
Two Item:
A-6.2.1-7 (Proprietary and Nonproprietary)
A-6.2.5-1 (Proprietary and Nonproprietary)
- 3. Information related to FSAR Section 6.3, Emergency Core Cooling System.
Five Items:
A-6.3.2.2.1-1 (Proprietary and Nonproprietary)
A-6.3-5 (Nonproprietary)
A-6.3-6 (Proprietary and Nonproprietary)
A-6.3-8 (Proprietary and Nonproprietary)
A-6.3-12 (Nonproprietary)
- 4. Information related to FSAR Section 6.4, Control Room Habitability.
One Item:
A-6.4-1 (Nonproprietary)
Chapter 8
- 1. Information related to FSAR Section 8.3, Onsite Power Systems.
Nine Items:
A-EDAS Audit Meeting Action Item 1 Submitted August 02, 2024, ML24215A001 / (Audit Response)
ML24215A144 A-EDAS Audit Meeting Action Item 2 Submitted August 02, 2024, ML24215A001 / (Audit Response)
ML24215A145 / ML24215A146 A-EDAS Audit Meeting Action Item 3 Submitted August 02, 2024, ML24215A001 / (Audit Response)
ML24215A147 A-EDAS Audit Meeting Action Item 4 Submitted August 02, 2024, ML24215A001 / (Audit Response)
ML24215A148 A-EDAS Audit Meeting Action Item 5 Submitted August 02, 2024, ML24215A001 / (Audit Response)
LO-175762 Page 5 of 9 12/11/2024 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com A-EDAS Audit Meeting Action Item 6 Submitted August 02, 2024, ML24215A001 / (Audit Response)
ML24215A150 A-EDAS Audit Meeting Action Item 9 Submitted August 02, 2024, ML24215A001 / (Audit Response)
ML24215A151 A-EDAS Audit Meeting Action Item 14 Submitted August 02, 2024, ML24215A001 / (Audit Response)
ML24215A152 A-8.3-16 (Nonproprietary): includes requested FSAR markups in CP-3915 Chapter 8 and 15 incorp. DC Power TR-102621 Chapter 9
- 1. Information related to FSAR Chapter 9 Fuel Storage and Handling.
One Item:
A-9.1.5-8 Submitted August 29, 2024, (ML23004A396) / (Audit Response)
ML24242A213 Chapter 15
One Item:
A-15-2 (Proprietary and Nonproprietary)
- 2. Information related to FSAR Section 15.0.3 Design Basis Accident Radiological Consequence Analyses for Advanced Light Water.
One Item:
A-15.0.3.7-2 (Nonproprietary)
- 3. Information related to FSAR Section 15.0.4 Safe, Stabilized Condition.
One Item:
A-15.0.4-1 (Nonproprietary)
- 4. Information related to FSAR Section 15.0.5 Extended Passive Cooling for Decay and Residual Heat Removal.
Two Items:
A-15.0.5-1 (part a) (Proprietary and Nonproprietary)
A-15.0.5-3 (Proprietary and Nonproprietary)
Two Items:
A-15.1.1-3 (Proprietary and Nonproprietary)
A-15.1.1-9 (Proprietary and Nonproprietary)
LO-175762 Page 6 of 9 12/11/2024 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com
Two Items:
A-15.1.2-1 (Proprietary and Nonproprietary)
A-15.1.2-3 (Nonproprietary)
- 7. Information related to FSAR Section 15.1.3 Increase in Steam Flow.
One Item:
A-15.1.3-2 (Nonproprietary)
- 8. Information related to FSAR Section 15.1.5 Steam Piping Failures Inside and Outside of Containment.
One Item:
A-15.1.5-1 (Proprietary and Nonproprietary)
- 9. Information related to FSAR Section 15.1.6 Loss of Containment Vacuum and Containment Flooding.
One Item:
A-15.1.6-2 (Nonproprietary)
- 10. Information related to FSAR Section 15.2.4 Closure of Main Steam Isolation Valve(s).
One Item:
A-15.2.4-1 (Nonproprietary)
One Item:
A-15.2.7-1 Submitted on August 02, 2024, ML24215A001 / (Audit Response)
- 12. Information related to FSAR Section 15.4.1 Uncontrolled Control Rod Assembly Withdrawal from a Subcritical or Low Power Startup Condition.
Three Items:
A-15.4.1-1S (Proprietary and Nonproprietary)
A-15.4.1-2 (Nonproprietary)
A-15.4.1-2S (Nonproprietary)
- 13. Information related to FSAR Section 15.4.3 Control Rod Misoperation (System Malfunction or Operator Error).
Two Item:
A-15.4.3-3 (Proprietary and Nonproprietary)
A-15.4.3-5 (Nonproprietary)
- 14. Information related to FSAR Section 15.4.7 Inadvertent Loading and Operation of a Fuel Assembly in an Improper Position.
Two Items:
A-15.4.7-1 (Proprietary and Nonproprietary)
A-15.4.7-4S2 (Proprietary and Nonproprietary)
LO-175762 Page 7 of 9 12/11/2024 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com
- 15. Information related to FSAR Section 15.4.8 Spectrum of Rod Ejection Accidents.
Two Items:
A-15.4.8-5 (Nonproprietary)
A-15.4.8-6 (Proprietary and Nonproprietary)
- 16. Information related to FSAR Section 15.6.2 Failure of Small Lines Carrying Primary Coolant Outside Containment.
One Item:
A-15.6.2-2 (Proprietary and Nonproprietary)
- 17. Information related to FSAR Section 15.6.5 Loss-of-Coolant Accidents Resulting from Spectrum of Postulated Piping Breaks within the Reactor Coolant Pressure Boundary.
Two Items:
A-15.6.5-13 (Nonproprietary)
A-15.6.5-14 (Proprietary and Nonproprietary)
- 18. Information related to FSAR Section 15.9 Stability.
Two Items:
A-15.9-2 (Nonproprietary)
A-15.9-3 (Proprietary and Nonproprietary)
Chapter 19
- 1. Information related to FSAR Section 19.1, Probabilistic Risk Assessment.
Eleven Items:
A-19.1-5 (Proprietary and Nonproprietary)
A-19.1-37 (Proprietary and Nonproprietary)
A-19.1-52 (Proprietary and Nonproprietary)
A-19.1-53 (Proprietary and Nonproprietary)
A-19.1-55 (Proprietary and Nonproprietary)
A-19.1-61 (Nonproprietary)
A-19.1-62 (Proprietary and Nonproprietary)
A-19.1-63 (Proprietary and Nonproprietary)
A-19.1-64 (Nonproprietary)
A-19.1-65 (Proprietary and Nonproprietary)
A-19.1-66 (Proprietary and Nonproprietary)
- 2. Information related to FSAR Section 19.2, Severe Accident Evaluation.
Three Items:
A-19.2-32 (Proprietary and Nonproprietary)
A-19.2-33 (Proprietary and Nonproprietary)
A-19.2-34 (Proprietary and Nonproprietary)
LO-175762 Page 8 of 9 12/11/2024 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com XPC 1.
Information related to NuScale Topical Report: "Extended Passive Cooling and Reactivity Control Methodology, Revision 0 (ADAMS Accession No. ML23005A308),"
TR-124587, Revision 0.
Nine Items:
A-XPC.LTR-14 (Proprietary and Nonproprietary)
A-XPC.LTR-15 (Proprietary and Nonproprietary)
A-XPC.LTR-20 (Proprietary and Nonproprietary)
A-XPC.LTR-22 (Proprietary and Nonproprietary)
A-XPC.LTR-25 (Proprietary and Nonproprietary)
A-XPC.LTR-26 (Proprietary and Nonproprietary)
A-XPC.LTR-27 (Proprietary and Nonproprietary)
A-XPC.LTR-29 (Proprietary and Nonproprietary)
A-XPC.LTR-30 (Proprietary and Nonproprietary)
A-XPC.LTR-32 (Proprietary and Nonproprietary)
A-XPC.LTR-33 (Proprietary and Nonproprietary)
The audit items specified above have been attached to the NRC EIE submittal. The responses that are labeled as proprietary include both proprietary and nonproprietary versions. The enclosed affidavits support this request. Some responses have also been determined to contain Export Controlled Information. This information must be protected from disclosure per the requirements of 10 CFR § 810.
This letter makes no regulatory commitments and no revisions to any existing regulatory commitments.
If you have any questions, please contact Thomas Griffith at 541-452-7813 or tgriffith@nuscalepower.com.
I declare under penalty of perjury that the foregoing is true and correct. Executed on December 11, 2024.
Sincerely, Mark W. Shaver Director, Regulatory Affairs NuScale Power, LLC
LO-175762 Page 9 of 9 12/11/2024 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com Distribution:
Mahmoud Jardaneh, Chief New Reactor Licensing Branch, NRC Getachew Tesfaye, Senior Project Manager, NRC Stacy Joseph, Senior Project Manager, NRC
LO-175762 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 Mark W. Shaver, AF-175763
AF-175763 Page 1 of 2
NuScale Power, LLC AFFIDAVIT of Mark W. Shaver I, Mark W. Shaver, state as follows:
(1)
I am the Director of Regulatory Affairs of NuScale Power, LLC (NuScale), and as such, I have been specifically delegated the function of reviewing the information described in this Affidavit that NuScale seeks to have withheld from public disclosure, and am authorized to apply for its withholding on behalf of NuScale (2)
I am knowledgeable of the criteria and procedures used by NuScale in designating information as a trade secret, privileged, or as confidential commercial or financial information. This request to withhold information from public disclosure is driven by one or more of the following:
(a)
The information requested to be withheld reveals distinguishing aspects of a process (or component, structure, tool, method, etc.) whose use by NuScale competitors, without a license from NuScale, would constitute a competitive economic disadvantage to NuScale.
(b)
The information requested to be withheld consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), and the application of the data secures a competitive economic advantage, as described more fully in paragraph 3 of this Affidavit.
(c)
Use by a competitor of the information requested to be withheld would reduce the competitors expenditure of resources, or improve its competitive position, in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.
(d)
The information requested to be withheld reveals cost or price information, production capabilities, budget levels, or commercial strategies of NuScale.
(e)
The information requested to be withheld consists of patentable ideas.
(3)
Public disclosure of the information sought to be withheld is likely to cause substantial harm to NuScales competitive position and foreclose or reduce the availability of profit-making opportunities. The accompanying response reveals distinguishing aspects about the process by which NuScale developed the Standard Design Approval Application for the US460 design.
NuScale has performed significant research and evaluation to develop a basis for this process 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 the NRCs Request for Docketing of Resolved Audit Responses. 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-175763 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 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 December 11, 2024. Mark W. Shaver
LO-175762 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 Morris Byram, Framatome Inc.
A F F I D A V I T
- 1.
My name is Morris Byram. I am Product 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 the NuScale Power, LLC letter Number LO-175762, with subject NuScale Power, LLC Submittal of the NRCs Request for Docketing of Resolved Audit Responses, 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), 6(d) and 6(e) 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: (12/09/2024) (NAME) Email: morris.byram@framatome.com Phone: 434-221-1082 BYRAM Morris Digitally signed by BYRAM Morris Date: 2024.12.09 15:58:34 -08'00'}}