ML25073A241

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LLC - Response to NRC Request for Additional Information No. 001 (RAI-10502 Ri) on the Nuacale Topical Report TR-145417
ML25073A241
Person / Time
Site: 05200050
Issue date: 03/14/2025
From: Shaver M
NuScale
To:
Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML25073A240 List:
References
RAIO-180352
Download: ML25073A241 (1)
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RAIO-180352 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com March 14, 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. 001 (RAI-10502 R1) on the NuScale Topical Report TR-145417

REFERENCE:

NRC Letter to NuScale, Request for Additional Information No. 001 (RAI-10502 R1), dated February 13, 2025 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-10502 R1:

FSR.LTR-31, 32, 33, 34, 35 is the proprietary version of the NuScale Response to NRC RAI No. 001 (RAI-10502 R1, Question FSR.LTR-31, 32, 33, 34, 35). NuScale requests that the proprietary version be withheld from public disclosure in accordance with the requirements of 10 CFR § 2.390. The enclosed affidavits (Enclosures 3 and 4) support this request. pertains to the NuScale proprietary information, denoted by double braces (i.e.,((). Enclosure 4 pertains to the Framatome Inc. proprietary information, denoted by brackets (i.e., [ ]). 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 Kris Cummings at 240-833-3003 or at kcummings@nuscalepower.com.

RAIO-180352 Page 2 of 2 03/14/2025 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com I declare under penalty of perjury that the foregoing is true and correct. Executed on March 14, 2025. Sincerely, Mark W. Shaver Director, Regulatory Affairs NuScale Power, LLC Distribution: Mahmoud Jardaneh, Chief New Reactor Licensing Branch, NRC Getachew Tesfaye, Senior Project Manager, NRC River Rohrman, Project Manager, NRC : NuScale Response to NRC Request for Additional Information RAI-10502 R1, Question FSR.LTR-31, 32, 33, 34, 35, Proprietary Version : NuScale Response to NRC Request for Additional Information RAI-10502 R1, Question FSR.LTR-31, 32, 33, 34, 35, Nonproprietary Version : Affidavit of Mark W. Shaver, AF-180353 : Affidavit of Morris Byram, Framatome Inc.

RAIO-180352 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-10502 R1, Question FSR.LTR-31, 32, 33, 34, 35, Proprietary Version

RAIO-180352 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-10502 R1, Question FSR.LTR-31, 32, 33, 34, 35, Nonproprietary Version

Response to Request for Additional Information Docket: 052000050 RAI No.: 10502 Date of RAI Issue: 02/13/2025 NRC Question No.: FSR.LTR-31, 32, 33, 34, 35 Regulatory Basis

  • 10 CFR 50.68(b) provides the requirements that are necessary to prevent criticality accidents in fuel storage in lieu of a monitoring system.
  • General Design Criterion (GDC) 62 requires criticality in the fuel storage and handling system to be prevented by physical systems or processes, preferably by use of geometrically safe configurations.

Issue Description NuScale US460 Fuel Storage Rack Design Topical Report, TR-145417-P, Revision 0, Section 6.5.1, Fuel Storage System Tolerance Analysis discusses the fuel assembly and storage rack tolerances that are being evaluated. NRC Regulatory Guide 1.240 discusses the importance of the fuel assembly and storage rack tolerances effect on the estimation of keff. However, it is not clear what fuel assembly and storage rack tolerances are being evaluated, how they are being determined, and how they are included into the estimation of the spent fuel pool (SFP) keff. Information Requested NuScale is requested to provide the following additional information: a) What fuel assembly and storage rack tolerances are being evaluated, b) How they are being determined, and c) How they are included in the estimation of the SFP keff. NuScale Nonproprietary NuScale Nonproprietary

NuScale Response: a) Section 6.5.1 of the NuScale US460 Fuel Storage Rack Design Topical Report, Fuel Storage System Tolerance Analysis describes the tolerance factors evaluated with a single storage cell, infinite array KENO V.a model. The magnitude of the manufacturing tolerances is contained in Table 6-2 for the fuel assemblies and Table 6-4 for the fuel storage rack. NuScale has added the tolerance for fuel stack axial position, described as Bottom of Fuel Assembly to Bottom of Fuel Column, to Table 6-2. Section 6.5.1.1, Uncertainty Factors Dependent on Enrichment and Not Burnup, describes the tolerance factors that are determined as a function of enrichment and boron concentration. The tolerances of those factors are as follows:

pin pitch: [ ]

fuel clad outside diameter (OD): [ ]

guide tube and instrument tube inside diameter (ID) and OD: [ ]

storage cell width: [ ]

storage cell pitch: [ ]

absorber plate width (while preserving the areal density of B10): [ ] Section 6.5.1.2, Uncertainty Factors Dependent on Enrichment and Burnup, describes the tolerance factors as a function of enrichment, boron concentration, and burnup. NuScale has added details about the calculation of the fuel pellet loading tolerance to Section 6.5.1.2. The tolerances of those factors are as follows:

fuel pellet loading: [ ]

fuel enrichment: [ ]

depletion (delta relativity from zero burnup): 5% of reactivity decrement

reactor record burnup (due to uncertainty in the value of burnup): 5% Section 6.5.1.3, Uncertainty Factors Dependent on Fuel Storage Rack Configuration, describes the tolerance factors as a function of enrichment, boron concentration, and a single burnup for each enrichment. The tolerances of those factors are as follows:

fuel pellet stack height: [ ]

fuel stack axial position: [ ] NuScale Nonproprietary NuScale Nonproprietary

Additionally, the uncertainty analysis includes bias factors, as described in Section 6.5.3, System Bias for Modeling Parameters.

the presence of moderator inside the instrument and guide tubes, as a function of boron concentration

the effect of thermal expansion in the depletion code, as a function of enrichment, boron concentration, and burnup

the loss of cladding integrity, as a function of enrichment, boron concentration, and a single burnup for each enrichment

spacer grid growth during irradiation, as a function of enrichment, boron concentration, and a single burnup for each enrichment The spacing between fuel storage racks does not include an uncertainty. Section 3.1, Description of Spent Fuel Pool and Pertinent Fuel Parameters, [ ] The whole pool KENO V.a model, however, conservatively places adjacent racks with [ 

] nearly touching, as described in Section 6.3.4, KENO-V.a Criticality Model.

b) Uncertainty factors that are determined as a function of enrichment, boron concentration, and burnup are computed with the single storage cell KENO V.a model. Section 6.5.1 of the topical report discusses the KENO V.a model is run with only the individual tolerance factor being investigated perturbed. Both the perturbed and unperturbed models are run with both the flat and distributed axial burnup profiles. For both the perturbed and unperturbed cases, the values of keff are curve fit to a cubic polynomial as a function of burnup. The cubic polynomial curve fits of k-effective versus burnup for each tolerance factor represent the k-effective data well, with the correlation coefficient (r2) no smaller than 0.9989 and the standard deviation of the curve fit residuals no larger than 0.00182, per the criticality safety evaluation. The uncertainty factor is then calculated as the difference between the curve fits. Section 6.5.1.2 contains additional details on the calculation of each uncertainty factor. Uncertainty factors that are a function of enrichment and boron concentration are also computed with the single storage cell KENO V.a model. Section 6.5.1.1 contains details on the calculation of these uncertainty factors. The criticality safety evaluation includes relevant sensitivity studies for pin pitch and fuel clad outside diameter. Uncertainty factors that are a function of enrichment, boron concentration, and a single burnup for each enrichment are computed with the whole pool KENO V.a model, as discussed in Section 6.5.1.3. NuScale Nonproprietary NuScale Nonproprietary

The bias factors discussed in part a) are computed with the same methodology as the uncertainty factors. c) For convenience, the uncertainty factors are combined prior to the calculation of k95/95. The uncertainty factors that are a function of enrichment and boron concentration are combined as discussed in Section 6.5.1.1. The uncertainty factors that are a function of enrichment, boron concentration, and burnup are combined as discussed in Section 6.5.1.2. The bias factors are selected and interpolated (as needed) to the correct burnup, then are summed and included as the ksys term in Equation 6-1 in Section 6.1.3. The standard deviations of the bias factors are squared and summed and included as 2 The uncertainty factors are selected and interpolated (as needed) to the correct burnup, then squared and summed and included as the 2 factor in Equation 6-1. The standard deviations of the uncertainty factors are squared and summed and included as the 2 factor. Table 1 provides a summary of the calculation of the k95/95 for the enrichment and burnup points shown in Table 6-15. As shown in the tables, tolerance and bias factors are computed with both a flat axial burnup shape and with a conservative distributed axial burnup shape. The maximum value of the tolerance or bias factor from the two axial burnup distributions is chosen. The standard deviation of the maximum tolerance factor is chosen. The spent fuel storage rack identifies two types of fuel assemblies, classified as individual zones. [ 

] as shown in the header rows. At three separate points in the tables, the maximum value of the uncertainty or bias factor is chosen from Zone 1 or Zone 2 for each enrichment for use in the calculation of k95/95. The standard deviation (S.D.) of the maximum value is chosen.

NuScale Nonproprietary NuScale Nonproprietary

Table 1: Example Calculations of k95/95, 0 ppm Boron Concentration [ ] NuScale Nonproprietary NuScale Nonproprietary

Table 1: Example Calculations of k95/95, 0 ppm Boron Concentration (Continued) [ ] NuScale Nonproprietary NuScale Nonproprietary

Table 1: Example Calculations of k95/95, 0 ppm Boron Concentration (Continued) [ ] NuScale Nonproprietary NuScale Nonproprietary

Table 1: Example Calculations of k95/95, 0 ppm Boron Concentration (Continued) [ ] NuScale Nonproprietary NuScale Nonproprietary

[ ] NuScale Nonproprietary NuScale Nonproprietary

[ ] NuScale Nonproprietary NuScale Nonproprietary

[ ] Impact on Topical Report: Topical Report TR-145417, NuScale US460 Fuel Storage Rack Design Topical Report, has been revised as described in the response above and as shown in the markup provided in this response. NuScale Nonproprietary NuScale Nonproprietary

NuScale US460 Fuel Storage Rack Design Topical Report TR-145417-NP Draft Revision 1 © Copyright 2025 by NuScale Power, LLC 133 RAI FSR.LTR-31, 32, 33, 34, 35 Table 6-2 Fuel Assembly Specification for Criticality Analysis Description Nominal Value Tolerance Overall Size 8.426 in x 8.426 in Rod Array 17x17 Number of Fuel Rods 264 Number of Guide Tubes 24 Number of Instrument Tubes 1 Instrument Tube Inside Diameter (ID) 11.43 mm [ ] Instrument Tube Outside Diameter (OD) 12.24 mm [ ] Instrument Tube Material Zircaloy-4 Fuel Pellet Theoretical Density 96.5% [ ] Fuel Pellet Diameter 0.3195 in [ ] Fuel Pellet Length 0.400 in [ ] Fuel Pellet Dish Volume (( [ ] }}2(a),(c),ECI [ ] Fuel Pellet Chamfer and Shoulder Volume (( [ ] }}2(a),(c),ECI Fuel Pellet Total Void Fraction (( [ ] }}2(a),(c),ECI Fuel Rod Clad ID 0.326 in [ ] FuelFurl Rod Clad OD 0.374 in [ ] Fuel Active Length 78.74 in [ ] Bottom of Fuel Assembly to Bottom of Fuel Column [ ] [ ] Fuel Rod Pitch 0.496 in [ ] Fuel Rod Clad Material M5 Guide Tube ID 11.43 mm [ ] Guide Tube OD 12.24 mm [ ] Guide Tube Material [ ] HTP Spacer Grid Material [ ] HTP Spacer Grid Mass [ ] HMP Spacer Grid Material [ ] HMP Spacer Grid Mass [ ] HTP & HMP Grid Height 1.75 in Spacer Grid Elevation of Mid-Point from Bottom of Fuel HMP 2.365 in HTP 22.413 in HTP 42.477 in HTP 62.540 in Fuel Assembly Pitch (( [ ] }}2(a),(c),ECI

NuScale US460 Fuel Storage Rack Design Topical Report TR-145417-NP Draft Revision 1 © Copyright 2025 by NuScale Power, LLC 147 6.5.1.2 Uncertainty Factors Dependent on Enrichment and Burnup The uncertainty factors dependent on enrichment and burnup include the following:

Fuel pellet loading

Pellet enrichment

Reactivity change due to depletion

Burnup These uncertainty factors are evaluated with the burnup interpolation methodology discussed in Section 6.5.1. Uncertainty for Fuel Pellet Loading The fuel pellet loading factor accounts for the manufacturing tolerances that affect the amount of fuel in an assembly, including manufacturing tolerances for the [ ] as shown in Figure 6-1. The [ ] manufacturing tolerance is assumed to be independent of the [ ] manufacturing tolerances. RAI FSR.LTR-31, 32, 33, 34, 35 The nominal fuel void fraction is [ ] which is the total of the [ ] The minimum volume of the [ ] is computed with the worst combination of dimensions and manufacturing tolerances from Figure 6-1 along with the [ ] and manufacturing tolerances from Table 6-2. The minimum volumes of the [ ] gives a minimum fuel void fraction of [ ] The change in void fraction is statistically combined on a relative basis with the fuel density tolerance factor as: Table 6-10 Combined Uncertainty Factors versus Enrichment, 1450 ppm Boron [ ]

NuScale US460 Fuel Storage Rack Design Topical Report TR-145417-NP Draft Revision 1 © Copyright 2025 by NuScale Power, LLC 148 RAI FSR.LTR-31, 32, 33, 34, 35 [ ] RAI FSR.LTR-31, 32, 33, 34, 35 Statistically combining the minimum fuel void fraction with the fuel density tolerance of [ ] on a relative basis, gives a fuel loading tolerance of [ ] The uncertainty factor for fuel loading tolerance is evaluated by two different methods. In the first method, the fuel loading is increased by the fuel loading tolerance in the TRITON/ORIGEN-S cases that then provides fuel number densities to the KENO V.a model of a single storage cell location. In the second method the KENO V.a model of a single storage cell location uses fuel number densities from a nominal TRITON/ORIGEN-S cases that are increased by the fuel loading tolerance. In both methods the KENO V.a results from the perturbed cases are compared to KENO V.a nominal results. Fuel Enrichment Uncertainty Factor The uncertainty factor for fuel enrichment is evaluated by changing the enrichment in the TRITON/ORIGEN-S cases by 0.05 wt.% 235U. These cases then provide fuel number densities for the KENO V.a model of a single storage cell location. The uncertainty factor is computed by comparing the results from the perturbed KENO V.a cases to nominal results. Depletion Uncertainty Factor A depletion uncertainty of 5% of the reactivity decrement due to depletion as allowed by Section 4.2.3 of NEI 12-16 Revision 4 (Reference 10.10). The KENO V.a model of a single storage cell location is run with nominal nuclide concentrations from TRITON/ORIGEN-S cases. The reactivity uncertainty is computed as 5% of the keff difference from zero burnup to the burnup value of interest, using the same curve fit to determine both values of keff. The standard deviation of the uncertainty is conservatively taken as the statistical combination of the maximum standard deviation of the KENO V.a cases and the standard deviation of the curve fit residuals. Both standard deviations are taken twice in the statistical combination. Reactor Record Burnup Uncertainty Factor The burnup uncertainty factor is taken as the reactivity equivalent of 5% of the stated burnup value as discussed in Section 5.1.5 of NEI 12-16 Revision 4

RAIO-180352 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-180353

AF-180353 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 Responses to NRC Request for Additional Information (RAI-10502 R1, Question FSR.LTR-31, 32, 33, 34, 35) on the NuScale Topical Report TR-145417. 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-10502 R1, Question FSR.LTR-31, 32, 33, 34, 35. 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-180353 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 14, 2025. Mark W. Shaver

RAIO-180352 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 Enclosure 1 with title NuScale Response to NRC Request for Additional Information RAI-10502 R1, Question FSR.LTR-31,32,33,34,35, of NuScale Power, LLC letter Number RAIO -180352, with subject NuScale Power, LLC Response to NRC Request for Additional Information No. 001 (RAI-10052 R1) on NuScale Topical Report TR-145417, 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 paragraphs 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: (3/14/2025) (NAME) Email: morris.byram@framatome.com Phone: 434-221-1082 BYRAM Morris Digitally signed by BYRAM Morris Date: 2025.03.14 09:04:03 -07'00'}}

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