ML25042A063

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LLC, Response to NRC Request for Additional Information No. 032 (RAI-10297 R1) on the NuScale Standard Design Approval Application
ML25042A063
Person / Time
Site: 05200050
Issue date: 02/11/2025
From: Shaver M
NuScale
To:
Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML25042A062 List:
References
RAIO-179388
Download: ML25042A063 (1)
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Text

RAIO-179388 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com February 11, 2025 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 Response to NRC Request for Additional Information No. 032 (RAI-10297 R1) on the NuScale Standard Design Approval Application

REFERENCE:

NRC Letter to NuScale, Request for Additional Information No. 032 (RAI-10297 R1), dated October 31, 2024 The purpose of this letter is to provide the NuScale Power, LLC (NuScale) response to the referenced NRC Request for Additional Information (RAI).

The enclosure to this letter contains the NuScale response to the following RAI question from NRC RAI-10297 R1:

NonLOCA.LTR-3, 9, 18, 19, 20, 21, 69 is the proprietary version of the NuScale Response to NRC RAI No. 032 (RAI-10297 R1, Question NonLOCA.LTR-3, 9, 18, 19, 20, 21, 69). 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. Enclosure 2 is the nonproprietary version of the NuScale response.

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

If you have any questions, please contact Amanda Bode at 541-452-7971 or at abode@nuscalepower.com.

I declare under penalty of perjury that the foregoing is true and correct. Executed on February 11, 2025.

Sincerely, Mark W. Shaver Director, Regulatory Affairs NuScale Power, LLC

RAIO-179388 Page 2 of 2 02/11/2025 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 Thomas Hayden, Project Manager, NRC

NuScale Response to NRC Request for Additional Information RAI-10297 R1, Question NonLOCA.LTR-3, 9, 18, 19, 20, 21, 69, Proprietary Version : NuScale Response to NRC Request for Additional Information RAI-10297 R1, Question NonLOCA.LTR-3, 9, 18, 19, 20, 21, 69, Nonproprietary Version : Affidavit of Mark W. Shaver, AF-179389

RAIO-179388 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-10297 R1, Question NonLOCA.LTR-3, 9, 18, 19, 20, 21, 69, Proprietary Version

RAIO-179388 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-10297 R1, Question NonLOCA.LTR-3, 9, 18, 19, 20, 21, 69, Nonproprietary Version

Response to Request for Additional Information Docket: 052000050 RAI No.: 10297 Date of RAI Issue: 10/31/2024 NRC Question No.: NonLOCA.LTR-3, 9, 18, 19, 20, 21, 69 Issues The methodology in NuScale topical report "Loss-of-Coolant Accident Evaluation Model," TR-0516-49422-P, Revision 3 (ML23008A001) (LOCA LTR) and the Non-LOCA LTR does not contain sufficient scaling analysis updates with the NIST-2 testing facility to capture higher power operations of the NPM-20 RCS, containment, and cooling pool. Between the LOCA LTR and Non-LOCALTR there is missing justification to extend the similarity of the NPM-160/NIST-1 to the NPM-20/NIST-2 in terms of the distortion analysis of important phenomena. This scaling analysis is discussed in the justification for applicability of the NRELAP5 code but not provided in the submission adequately.

  • Code validation for predicting DHRS performance The Non-LOCA LTR presents a validation of the NRELAP5 code using the NIST-2 test data.

The code validation is extended to applications of the code for LOCA events (( 2(a),(c).

  • Similarities (or distortion) of NIST-2 tests for code validation NuScale Nonproprietary NuScale Nonproprietary

Distortion analysis is missing in the Non-LOCA LTR for validation of the NRELAP5 code based on the NIST-2 test for analyses of Non-LOCA and LOCA events. A distortion analysis must be performed to identify the necessary correction factor in the code and models because comparison between the NIST-2 test facility and the NPM-20 design shows significant dissimilarities. Integral and separate effects tests are used to justify the development and applicability of an evaluation model to a given design. Since test facilities are not typically full-scale, distortions exist that can affect local and global elements of the analysis when compared to the full-scale plant. Therefore, a scaling analysis needs to be performed that identifies important non-dimensional parameters related to geometry and key phenomena and scaling distortions and their impact on the code assessment must be identified and evaluated.

  • Applicability of the NIST-2 tests for validating code for analyzing events In the Non-LOCA LTR, the applicability of the NRELAP5 DHRS modeling capability is extended to the LOCA LTR ((

}} 2(a),(c).

  • DHRS condensate flow oscillations and nodalization

(( 

}}

2(a),(c) NuScale Nonproprietary NuScale Nonproprietary

(( }} 2(a),(c).

  • Prediction of the impact of coolant inventory on DHRS performance During audit discussions, NuScale presented information that showed performance degradation in certain DHRS loop inventory ranges. The SG-DHRS loop inventory is determined when the SG-DHRS loop is isolated for DHRS operation. In various Chapter 15 events, the loop isolation timing varies depending on the event progression and plant response.

In reviewing the NRELAP assessment, NuScale identified the influence of DHRS loop inventory on heat removal. NuScale made available for staff audit (ML23067A300) several studies to address the staffs concern regarding the similarity between NIST-2 and the NPM-20. (( }} 2(a),(c).

  • NRELAP5 modeling of secondary-side mass inventory NuScale Nonproprietary NuScale Nonproprietary

(( }} 2(a),(c). Information Requested a) Provide NRELAP5 DHRS model validation for LOCA events (( }} 2(a),(c). b) (( }} 2(a),(c). Provide the bounding uncertainty of the DHRS methodology in LOCA until long-term cooling is established with or without ECCS operation. c) (( }} 2(a),(c). d) (( }} 2(a),(c). NuScale Nonproprietary NuScale Nonproprietary

e) Explain the impact of (( }} 2(a),(c) the scaling analysis in the Non-LOCA tests and the scalability to NPM-20. f) (( }} 2(a),(c). If not, provide a most-limiting SG-DHRS loop inventory analysis for applicable Chapter 15 events to ensure sufficient DHRS heat removal capacity. NuScale Response: Executive Summary A response is provided to each part of the request for additional information (RAI) in the sections below. Overall, the response identifies that the decay heat removal system (DHRS) remains effective during loss-of-coolant accident (LOCA) events, including during uncovery of steam generator (SG) tubes prior to or after emergency core cooling system (ECCS) actuation and up until the point at which long-term cooling is established. There is no evidence to suggest that there is significant uncertainty in the NRELAP5 predictions of DHRS performance. Even if there were uncertainty, sensitivity study results provided in this response (and others previously provided) demonstrate (( 

}}2(a),(c) has no impact on figures of merit (FOM) relevant to LOCA. Sensitivity study results also show that

(( 

}}2(a),(c) has no impact on LOCA event FOM margins. NRELAP5 predictions of DHRS performance are reasonable when compared to NuScale Integral System Test Facility (NIST)-2 test data. (( 
}}2(a),(c) The NRC also expressed concern with a modeling approach used in NRELAP5 (( 
}}2(a),(c) The response provides sensitivity studies that demonstrate that (( 
}}2(a),(c) there is no significant impact on overall DHRS performance. (( 
}}2(a),(c)

NuScale Nonproprietary NuScale Nonproprietary

(( 

}}2(a),(c) These sensitivity studies provide further evidence that DHRS performance is effective and can be reasonably modeled by NRELAP5.

As a further reassurance that DHRS will be effective during NuScale Power Module (NPM)-20 operation, the Final Safety Analysis Report (FSAR) Table 14.2-41 includes a DHRS system level test that is required to be performed for the first NPM tested. The test will verify that DHRS removes heat from the reactor coolant system (RCS). The cooldown rate of the test will be compared to the code of record (i.e., NRELAP5). The test will validate both the effectiveness of DHRS in actual performance as well as the ability of the NRELAP5 code to predict performance. Part a This part of the RAI requests validation of the NRELAP5 DHRS model for LOCA events (( 

}}2(a),(c)

(( 

}}2(a),(c)

NuScale Nonproprietary NuScale Nonproprietary

(( 

}}2(a),(c)

The above information was added to TR-0516-49422, Loss-of-Coolant Accident Evaluation Model, as shown in the markups provided with the response to RAI 10296 question LOCA.LTR-4, 45, 47. Part b This part of the RAI requests a bounding uncertainty of the DHRS methodology in LOCA until long-term cooling is established with or without ECCS operation. (( 

}}2(a),(c).

NuScale disagrees with the premise that there is a lack of information regarding DHRS performance during LOCA. As described in the response to part a above, DHRS remains highly effective during LOCA conditions. To support the previous NRC approval of TR-0516-49416-P-A, Revision 3, Non-Loss-of-Coolant Accident Analysis Methodology, NuScale performed sensitivity analyses considering the impact of a 30 percent uncertainty in DHRS performance. Consistent with the prior approach to addressing NRC concerns regarding DHRS uncertainty during non-LOCAs, NuScale has similarly performed sensitivity analyses considering an even larger uncertainty in DHRS performance as described below. NuScale has previously provided a sensitivity study considering DHRS uncertainty in the response to RAI 10359 question 6.2.1-1. (( 

}}2(a),(c)

NuScale Nonproprietary NuScale Nonproprietary

(( }}2(a),(c) NuScale Nonproprietary NuScale Nonproprietary

(( }}2(a),(c) NuScale has not identified any information that would suggest the uncertainty in DHRS performance is that large; NuScale believes the uncertainty to be minimal. Therefore, explicit quantification of the uncertainty is not required. Part c This part of the RAI requests several different items. For clarity, each item of the request is listed in indented, italicized text, followed by the NuScale response. (( }}2(a),(c) NuScale Nonproprietary NuScale Nonproprietary

(( }}2(a),(c) (( }}2(a),(c (( }}2(a),(c) (( }}2(a),(c NuScale Nonproprietary NuScale Nonproprietary

(( }}2(a),(c) (( 

}}2(a),(c)

(( 

}}2(a),(c NuScale Nonproprietary NuScale Nonproprietary

(( }}2(a),(c) (( 

}}2(a),(c)

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(( 

}}2(a),(c As a further reassurance that DHRS will be effective during NPM-20 operation, the FSAR Table 14.2-41 includes a DHRS system level test that is required to be performed for the first NPM tested. The test will verify that DHRS removes heat from the RCS. The cooldown rate of the test will be compared to the code of record (i.e., NRELAP5). The test will validate both the effectiveness of DHRS in actual performance as well as the ability of the NRELAP5 code to predict performance.

Part d (( 

}}2(a),(c)

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(( 

}}2(a),(c)

(( 

}}2(a),(c)

(( 

}}2(a),(b),(c)

NuScale Nonproprietary NuScale Nonproprietary

(( 

}}2(a),(c)

(( 

}}2(a),(b),(c)

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(( 

}}2(a),(b),(c)

(( 

}}2(a),(b),(c)

(( 

}}2(a),(c)

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(( }}2(a),(c) Figure 1: NIST-2 Run 1 Steam Generator and Decay Heat Removal System Active Loop Inventory Comparison (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 2: NIST-2 Run 1 Primary Pressure Comparison (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 3: NIST-2 Run 1 Secondary Pressure Comparison (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 4: NIST-2 Run 1 Primary Flow Rate Comparison (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 5: NIST-2 Run 1 Condensate Flow Rate Comparison (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 6: NIST-2 Run 1 Decay Heat Removal System Heat Exchanger Inlet and Outlet Temperature Comparison (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 7: NIST-2 Run 1 Steam Generator Secondary Side Inlet and Outlet Temperature Comparison (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 8: NIST-2 Run 1 Steam Generator Primary Side Inlet and Outlet Temperature Comparison (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 9: NIST-2 Run 1 Decay Heat Removal System Level Comparison (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 10: NIST-2 Run 1 Steam Generator Level Comparison (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 11: NIST-2 Run 1 Decay Heat Removal System Heat Exchanger Power Comparison (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 12: NIST-2 Run 2 Steam Generator and Decay Heat Removal System Active Loop Inventory Comparison (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 13: NIST-2 Run 2 Primary Pressure Comparison (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 14: NIST-2 Run 2 Secondary Pressure Comparison (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 15: NIST-2 Run 2 Primary Flow Rate Comparison (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 16: NIST-2 Run 2 Condensate Flow Rate Comparison (with Running Average) (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 17: NIST-2 Run 2 Decay Heat Removal System Heat Exchanger Inlet and Outlet Temperature Comparison (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 18: NIST-2 Run 2 Steam Generator Secondary Side Inlet and Outlet Temperature Comparison (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 19: NIST-2 Run 2 Steam Generator Secondary Side Inlet and Outlet Temperature Comparison (Alternate Feedwater Location) (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 20: NIST-2 Run 2 Steam Generator Primary Side Inlet and Outlet Temperature Comparison (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 21: NIST-2 Run 2 Decay Heat Removal System Level Comparison (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 22: NIST-2 Run 2 Steam Generator Level Comparison (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 23: NIST-2 Run 2 Decay Heat Removal System Heat Exchanger Power Comparison (with Running Average) (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 24: NIST-2 Run 2 Steam Line Orifice Differential Pressure (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Part e (( 

}}2(a),(c)

NuScale Nonproprietary NuScale Nonproprietary

(( }}2(a),(c) NuScale Nonproprietary NuScale Nonproprietary

(( }}2(a),(c) Table 1: NIST-2 Non-LOCA Run 1 Integral Energy Comparison (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 25: NIST-2 Mass Sensitivity Run 1 Base Case Energy Rate Comparison (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 26: NIST-2 Mass Sensitivity Run 1 Base Case Integral Energy Comparison (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

(( }}2(a),(c) Table 2: Mass Sensitivity Time-Averaged Energy Pseudo-Pi Group (Equation 1) (( }}2(a),(b),(c) Table 3: Mass Sensitivity Time-Averaged Mass Pseudo-Pi Group (Equation 2) (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 27: DHRS Mass Boundary Energy Pi Group (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 28: Original Post-Test DHRS Energy Pi Groups (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 29: DHRS Mass Boundary Mass Pi Group (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Figure 30: Original Post-Test DHRS Mass Pi Group (( }}2(a),(b),(c) NuScale Nonproprietary NuScale Nonproprietary

Part f (( 

}}2(a),(c)

The analysis of the increase in feedwater flow event in FSAR Section 15.1.2 includes consideration of the impact of high SG-DHRS inventory on DHRS performance. The analysis of the main steam line break event in FSAR Section 15.1.5 includes consideration of the impact on DHRS performance from a loss of one train of DHRS due to the break location and high SG-DHRS inventory in the intact train of DHRS. Given the discussion in parts d and e of this response, NuScale concludes that the FSAR Section 15.1.2 and FSAR Section 15.1.5 analyses are not impacted by the particular active inventory modeling approach used in the NIST-2 test assessments. Therefore, the FSAR Section 15.1.2 and FSAR Section 15.1.5 analyses remain valid. The analyses demonstrate that the DHRS adequately removes decay heat during limiting high SG-DHRS inventory conditions. Unrelated to this RAI, the FSAR Section 15.1.2 analysis was revised as described in the response to RAI 10297 Question NonLOCA.LTR-60. The supporting document, EC-0000-8328, Revision 1, Increase in Feedwater Flow Transient Analysis, was made available for the NRC staff as part of the response to that RAI question. Additional Information The current NRELAP5 model for DHRS includes consideration of the heat transfer that occurs in the portion of the DHRS steam line piping that is below the level of the ultimate heat sink as well as the DHRS condenser headers. The modeling of heat transfer in these components is not described in TR-0516-49416, Revision 4. Therefore, TR-0516-49416, Revision 4, is revised as indicated in the attached markups to identify that these components may be considered in the heat transfer and identify the heat transfer boundary condition types used in NRELAP5 when modeling the heat transfer from these components. NuScale Nonproprietary NuScale Nonproprietary

Impact on Topical Report: Topical Report TR-0516-49416, Non-Loss-of-Coolant Accident Analysis Methodology, has been revised as described in the response above and as shown in the markup provided in this response. NuScale Nonproprietary NuScale Nonproprietary

Non-Loss-of-Coolant Accident Analysis Methodology TR-0516-49416-NP Draft Revision 5 © Copyright 2024 by NuScale Power, LLC 499 6.1.5 Decay Heat Removal System Audit Question A-NonLOCA.LTR-63 RAI 10297 Question NonLOCA.LTR-3, 9, 18, 19, 20, 21, 69 An NPM incorporates two separate DHRSs that are treated individually in the NRELAP5 model. (( }}2(a),(c) Figure 6-13 shows the typical nodalization for DHRS loop 1 (( }}2(a),(c). Loop 2 is modeled similarly. While each DHRS line in an NPM features two parallel actuation valves, (( }}2(a),(c) Audit Question A-NonLOCA.LTR-63 The number of hydrodynamic volumes in the DHRS condenser piping and HX regions are based on results from NRELAP5 assessments using data from the NIST-1 facility (Section 5.3.2). (( }}2(a),(c) RAI 10297 Question NonLOCA.LTR-3, 9, 18, 19, 20, 21, 69 In addition to the DHRS condenser piping and HX regions, heat removal occurs in the DHRS steam line piping below the level of the reactor cooling pool and from the DHRS condenser headers. (( }}2(a),(c) Audit Question A-NonLOCA.LTR-63 In an actual NPM, the DHRS heat exchanger iscondensers are located in the reactor cooling pool. (( }}2(a),(c) The long-term use of DHRS is addressed separately in Reference 26.

RAIO-179388 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-179389

AF-179389 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 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 No. 10297 R1, Question NonLOCA.LTR-3, 9, 18, 19, 20, 21, 69) 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 is in the enclosed response to NRC Request for Additional Information RAI 10297 R1, Question NonLOCA.LTR-3, 9, 18, 19, 20, 21, 69. 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-179389 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 February 11, 2025. Mark W. Shaver}}

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