ML25069A742
| ML25069A742 | |
| Person / Time | |
|---|---|
| Site: | 05200050 |
| Issue date: | 03/10/2025 |
| From: | Shaver M NuScale |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML25069A741 | List: |
| References | |
| LO-180203 | |
| Download: ML25069A742 (1) | |
Text
LO-180203 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com March 10, 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 Submittal of Supplemental Information for Response to NRC Request for Additional Information No. 032 (RAI-10297 R1) on the NuScale Standard Design Approval Application
REFERENCE:
NuScale letter to NRC, NuScale Power, LLC Response to NRC Request for Additional Information No. 032 (RAI-10297 R1) on the NuScale Standard Design Approval Application, dated February 27, 2025 (ML25058A423)
NuScale Power, LLC (NuScale) hereby submits Supplemental Information for Response to NRC Request for Additional Information No. 032 (RAI-10297 R1), referenced above, on the NuScale Standard Design Approval Application. is the proprietary version of the Supplemental Information for 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. is the nonproprietary version of the Supplemental Information for 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 March 10, 2025.
Sincerely, Mark W. Shaver Director, Regulatory Affairs NuScale Power, LLC
LO-180203 Page 2 of 2 03/10/2025 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
- Supplemental Information for NuScale Response to NRC Request for Additional Information RAI-10297 R1, Question NonLOCA.LTR-50, Proprietary Version : Supplemental Information for NuScale Response to NRC Request for Additional Information RAI-10297 R1, Question NonLOCA.LTR-50, Nonproprietary Version : Affidavit of Mark W. Shaver, AF-180204
LO-180203 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com Supplemental Information for NuScale Response to NRC Request for Additional Information RAI-10297 R1, Question NonLOCA.LTR-50, Proprietary Version Note this supplemental information 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.
LO-180203 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com Supplemental Information for NuScale Response to NRC Request for Additional Information RAI-10297 R1, Question NonLOCA.LTR-50, Nonproprietary Version
Loss-of-Coolant Accident Evaluation Model TR-0516-49422-NP Draft Revision 5 76
© Copyright 2025 by NuScale Power, LLC TR-154300 Draft Revision 2 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)
LO-180203 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-180204
AF-180204 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 supplemental information 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 Supplemental Information for Response to NRC Request for Additional Information No. 032 (RAI-10297 R1) on the NuScale Standard Design Approval Application. 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-180204 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 10, 2025. Mark W. Shaver}}