ML25058A423
| ML25058A423 | |
| Person / Time | |
|---|---|
| Site: | 05200050 |
| Issue date: | 02/27/2025 |
| From: | Shaver M NuScale |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML25058A422 | List: |
| References | |
| RAIO-179797 | |
| Download: ML25058A423 (1) | |
Text
RAIO-179797 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com February 27, 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-50 is the proprietary version of the NuScale Response to NRC RAI No. 032 (RAI-10297 R1, Question NonLOCA.LTR-50). 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 27, 2025.
Sincerely, Mark W. Shaver Director, Regulatory Affairs NuScale Power, LLC
RAIO-179797 Page 2 of 2 02/27/2025 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-50, Proprietary Version : NuScale Response to NRC Request for Additional Information RAI-10297 R1, Question NonLOCA.LTR-50, Nonproprietary Version : Affidavit of Mark W. Shaver, AF-179798
RAIO-179797 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-50, Proprietary Version
RAIO-179797 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-50, 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-50 Issue By letter dated January 6, 2023 (ML23011A012), NuScale submitted NRELAP5 files via DVD to support review of the Non-LOCA LTR and other LTRs that support the SDAA. NuScale informed NRC in February 2024, that a code error was found. Subsequently, NuScale informed NRC that a new code version, NRELAP5 v1.7, was being released and would be used for the SDAA and supporting topical reports. By letter dated August 6, 2024 (ML24228A242), NuScale submitted (( 2(a),(c). Information Requested In order for the staff to complete its technical review of the analytical approach and base its findings on submitted information relevant to the version of the code utilized in developing the EM, NuScale is requested to: a) Re-submit any of the remaining files impacted by this code version change. All files affected by the revision to v1.7, ((
}}
2(a),(c), need to be resubmitted to provide a complete submittal package for all four of these LTRs. ((
}}
2(a),(c). Note that similar requests are being made for all four LTRs, and responses can reference each other. NuScale Nonproprietary NuScale Nonproprietary
b) The markup to Non-LOCA LTR draft revision 5 that the staff audited states "testing associated with the release of the Reference 31 version of NRELAP5 confirmed no impact on the Non-LOCA EM." Make available for staff audit the documentation of the completed testing. c) Make available for audit an evaluation of the new version of the NRELAP5 code with all code qualification and design basis event analyses where the choked flow is involved to demonstrate impact on the current calculations. Provide LTR markups with updates to describe choked flow modeling changes and add or replace all evaluations in the LTR that are impacted. NuScale Response: Part a NuScale previously submitted (( }}2(a),(c) NRELAP5 version 1.7 (v1.7) in the following letter: NuScale letter to NRC, LO-172700, NuScale Power, LLC Submittal of Supplemental Information in Support of Review of TR-131981-P, Methodology for the Determination of the Onset of Density Wave Oscillations (DWO), Revision 1 Audit Question A-DWO.LTR-127, dated August 6, 2024. In addition, NuScale previously submitted supporting information for NRELAP5 version 1.7 (v1.7) (( }}2(a),(c) in the following letter: NuScale letter to NRC, LO-175108, NuScale Power, LLC Submittal of Supplemental Information in Support of NRC Review of NuScale Topical Reports Associated with the Standard Design Approval Application, dated October 17, 2024. The October 17, 2024 letter contained the files shown in Table 1 below. NuScale Nonproprietary NuScale Nonproprietary
Table 1: Files Contained in October 17, 2024 NuScale Letter to NRC (( }}2(a),(c) In response to a clarification call with the NRC on November 25, 2024, NuScale submitted NRELAP5 input files in the following letter: NuScale letter to NRC, LO-176112, NuScale Power, LLC Submittal of Supplemental Information in Support of NRC Review of NuScale Topical Reports Associated with the Standard Design Approval Application, dated December 2, 2024. The December 2, 2024 letter contained the files shown in Table 2 below. Collectively, the submittals provide the information requested by this part. NuScale Nonproprietary NuScale Nonproprietary
Table 2: Files Contained in the December 2, 2024 NuScale Letter to NRC (( }}2(a),(c) Part b The document supporting the quoted statement is SwTR-0304-17153, Revision 9, NRELAP5 Software Test Report. The document SwTR-0304-17153 was previously provided to the NRC for audit as requested by this part. SwTR-0304-17153 also includes an attachment that is very large (i.e., several thousand pages). As discussed during a clarification call with the NRC on August 15, 2024, only the relevant portions of the attachment to SwTR-0304-17153 were provided to the NRC for audit. In the response to audit question A-NonLOCA.LTR-50, NuScale provided a roadmap to identify the information in the attachment that was most relevant. ((
}}2(a),(c) Based on discussions with the NRC during a clarification call associated with the advanced draft RAI on September 21, 2024, the NRC clarified that additional comparisons between NRELAP5 version 1.6 (v1.6) and v1.7 for the NPM-20 design-basis events were needed to answer this question. Specifically, the NRC expressed interest in NRELAP5 v1.6 and v1.7 comparisons for the following non-loss-of-coolant NuScale Nonproprietary NuScale Nonproprietary
accident (non-LOCA) NPM-20 analyses: (( }}2(a),(c) NuScale performed comparisons of NRELAP5 v1.6 to v1.7 in EE-175345, Revision 0, Comparison Study of NRELAP5 version 1.6 and 1.7. The document EE-175345 is provided for NRC audit with this response. The relevant sections of EE-175345 for the non-LOCA events identified above are indicated in the list below. (( }}2(a),(c) NuScale Nonproprietary NuScale Nonproprietary
((
}}2(a),(c)
The comparisons previously provided in SwTR-0304-17153 and the supplemental comparisons provided in EE-175345 with this response are adequate to demonstrate that NRELAP5 v1.7 is performing as expected and NPM non-LOCA transient results are not affected by the version change. Part c NuScale reviewed TR-0516-49416-P, Revision 4, Non-Loss-of-Coolant Accident Analysis Methodology regarding choked flow modeling. ((
}}2(a),(c) Therefore, the NRELAP5 v1.7 changes do not impact the choked flow model discussions in TR-0516-49416-P, Revision 4. The only impacts to TR-0516-49416-P, Revision 4, because of the NRELAP5 v1.7 changes are those previously identified in the markups provided with the responses (original and supplement) to audit question A-NonLOCA.LTR-50.
Impact on US460 SDAA: There are no impacts to Topical Report TR-0516-49416, Non-Loss-of-Coolant Accident Analysis Methodology, as a result of this response. A minor clarification to Topical Report TR-0516-49422, Loss-of-Coolant Accident Evaluation Model, is made based on NRC feedback, and is shown in the attached pages. Note this response references a proprietary version of the topical report that is marked as containing export controlled information (ECI). However, the extracted pages of the topical report that are attached to this response do not contain ECI as submitted herein. Notwithstanding, any proprietary information included in the response and the attachment hereto shall be withheld per 10 CFR 2.390. NuScale Nonproprietary NuScale Nonproprietary
Loss-of-Coolant Accident Evaluation Model TR-0516-49422-NP Draft Revision 4 © Copyright 2025 by NuScale Power, LLC 76 TR-154300 Revision 1 5.1.2 Reactor Coolant System The RCS model is composed of the LP, reactor core, riser (lower, transition, and upper sections), riser plenum, downcomer (upper section containing the helical coil SGs and lower section), and pressurizer. 5.1.2.1 Lower Plenum (( }}2(a),(c) 5.1.2.2 Reactor Core 5.1.2.2.1 General Model The reactor core assembly is modeled with (( }}2(a),(c)
Loss-of-Coolant Accident Evaluation Model TR-0516-49422-NP Draft Revision 4 © Copyright 2025 by NuScale Power, LLC 734 TR-154300 Revision 1 111 U.S. Nuclear Regulatory Commission, "Design-Specific Review Standard for NuScale SMR Design," Chapter 6, Section 6.2.1.1.A, Rev. 0, June 2016. 112 U.S. Nuclear Regulatory Commission, "Design-Specific Review Standard for NuScale SMR Design," Chapter 6, Section 6.2.1.3, Rev. 0, June 2016. 113 U.S. Nuclear Regulatory Commission, "Design-Specific Review Standard for NuScale SMR Design," Chapter 6, Section 6.2.1.4, Rev. 0, June 2016. 114 NuScale Power, LLC, Topical Report "Non-LOCA Transient Analysis Methodology," TR 0516-49416-P, Rev. 3. 115 NuScale Power, LLC, Topical Report, "NuScale Power Critical Heat Flux Correlations," TR-0116-21012-P-A, Revision 1. 116 Tong, L.S., Currin H.B., et. al., "Influence of axially non-uniform heat flux on DNB," AIChE Chemical Engineering Progress Symposium Series, Vol. 62, No. 64. 117 U.S. Nuclear Regulatory Commission, "Applying Statistics," NUREG-1475, Rev. 1. 118 NuScale Power, LLC, Statistical Subchannel Analysis Methodology, Supplement 1 to TR-0915-17564-P-A, Revision 2, TR-108601-P-A, Revision 4.
RAIO-179797 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-179798
AF-179798 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-50) 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-50. 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-179798 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 27, 2025. Mark W. Shaver}}