ML25153A551

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LLC, Supplemental Response to NRC Request for Additional Information No. 001 (RAI-10502 R1) on the NuScale Topical Report TR-145417
ML25153A551
Person / Time
Site: 05200050
Issue date: 06/02/2025
From: Shaver M
NuScale
To:
Office of Nuclear Reactor Regulation, Document Control Desk
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RAIO-182565
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RAIO-182565 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com June 02, 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 Supplemental 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 supplements to the NuScale Power, LLC (NuScale) response to the referenced NRC Request for Additional Information (RAI).

The enclosure to this letter contains supplements to the NuScale response to the following RAI questions from NRC RAI-10502 R1:

FSR.LTR-1S1 FSR.LTR-48S1 is the proprietary version of the NuScale Respone to NRC RAI No. 001 (RAI-10502 R1, Question FSR.LTR-48S1). NuScale requests that the proprietary version be withheld from public disclosure in accordance with the requirements of 10 CFR § 2.390. The enclosed affidavits (Enclosure 4 and 5) support this request. pertains to the NuScale proprietary information, denoted by double braces (i.e., ((). Enclosure 5 pertains to the Framatome Inc. proprietary information, denoted by brackets (i.e., [ ]). Enclosures 1 and 3 are the nonproprietary versions 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-182565 Page 2 of 2 06/02/2025 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 June 02, 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-1S1, Nonproprietary Version : NuScale Response to NRC Request for Additional Information RAI-10502 R1, Question FSR.LTR-48S1, Proprietary Version : NuScale Response to NRC Request for Additional Information RAI-10502 R1, Question FSR.LTR-48S1, Nonproprietary Version : Affidavit of Mark W. Shaver, AF-182566 : Affidavit of Morris Byram, Framatome Inc.

RAIO-182565 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-1S1, 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-1S1 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 The applicants criticality safety analysis in NuScale US460 Fuel Storage Rack Design Topical Report, TR-145417-P, Revision 0, used TRITON/ORIGEN-S as the depletion code to estimate the post irradiated isotopic content of the fuel for utilization of burnup credit. To validate the depletion code, the applicant used 5% of the reactivity change from fresh unpoisoned fuel to the burnup of interest as the uncertainty, citing NEI 12-16, Guidance for Performing Criticality Analyses of Fuel Storage at Light-Water Reactor Power Plants, Revision 4 (ML19269E069), Section 4.2.3 as justification. NRC Regulatory Guide 1.240, Fresh and Spent Fuel Pool Criticality Analyses, (ML20356A127) endorses, with limitations and conditions, NEI 12-16. Section 4.2.3 of NEI 12-16 states, in part, In lieu of a formal lattice depletion validation, the licensee may apply an uncertainty equal to 5% of the reactivity decrement, if the licensee uses the lattice depletion code in a manner that is consistent with nuclear design calculations previously performed for commercial power reactor licensing. This ensures that the depletion code will produce reliable and predictable results for the intended application. The information provided by the applicant does not appear to demonstrate its use of TRITON/ORIGEN-S as the depletion code consistent with nuclear design calculations previously performed for commercial power reactor licensing. Typically, this is done by using an established code in commercial power reactor licensing or via an NRC approved NuScale Nonproprietary NuScale Nonproprietary

topical report that establishes that the code has been benchmarked to appropriate data and produces reliable and predictable results when used with the established methodology within the prescribed limitations and conditions. There is no NRC approved topical report that establishes TRITON/ORIGIN-S as an approved code for use nor is the code in active use for commercial power reactor licensing. Information Requested NuScale is requested to provide equivalent justification for using the uncertainty equal to 5% of the reactivity decrement for its depletion uncertainty. Otherwise, NuScale can validate TRITON/ORIGEN-S in an alternate manner such as those described in NUREG-2215, Standard Review Plan for Spent Fuel Dry Storage Systems and Facility - Final Report, (ML20121A190) and NUREG-2216, Standard Review Plan for Transportation Packages for Spent Fuel and Radioactive Material: Final Report, (ML20234A651). NuScale Response: NuScale is supplementing its response to RAI 10502, Question FSR.LTR-1 that was originally transmitted in letter RAIO-179614 dated February 20, 2025. The TRITON input files were developed using the guidance contained in the following documents:

NEI 12-16, Revision 4, Guidance for Performing Criticality Analyses of Fuel Storage at Light-Water Reactor Power Plants

NUREG/CR-7104, SCALE/TRITON Primer: A Primer for Light Water Reactor Lattice Physics Calculations

SCALE Users Manual (Version 6.2.4), Section 3: Reactor Physics o https://www.ornl.gov/file/scale-62-manual/display o W. A. Wieselquist, R. A. Lefebvre, M.A. Jessee, Eds., SCALE 6.2.4 User Manual, ORNL/TM-2005/39, UT-Battelle, Oak Ridge National Laboratory (April 2020)

SCALE Users Manual (Version 6.3.2), Section 3: Reactor Physics o https://scale-manual.ornl.gov/ o W. A. Wieselquist, R. A. Lefebvre, Eds., SCALE 6.3.2 User Manual, ORNL/TM-2024/3386, UT-Battelle, Oak Ridge National Laboratory (February 2024) NuScale Nonproprietary NuScale Nonproprietary

One key aspect of the depletion from these guidance documents is the materials chosen for depletion, including all fissile nuclei and burnable absorbers. Since gadolinium is conservatively neglected, burnable absorbers are not included in the depletion. Structural materials and moderator are not depleted, in accordance with the SCALE Primer. A second key aspect is the length of the depletion step. As described in Section 6.3.3 of TR-145417, burnup steps are no larger than 0.25 GWD/MTU. This depletion step size is in accordance with the guidance in Section 6.2 of the SCALE Primer and Section 3.1.2 of NEI 12-16. The inputs to the depletion code are chosen in accordance with Section 4.2.1 of NEI 12-16:

A limited set of nuclides is included for transfer to the criticality code.

Power density, fuel temperature, moderator temperature, moderator density and core soluble boron are biased in the direction that maximizes reactivity.

Gadolinium is the only burnable absorber, which is conservatively neglected.

The NPM-20 is designed for baseload operation; therefore, no rodded operation is included.

No cooling time is credited. Impact on Topical Report: There are no impacts to Topical Report TR-145417, NuScale US460 Fuel Storage Rack Design Topical Report, as a result of this response. NuScale Nonproprietary NuScale Nonproprietary

RAIO-182565 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-48S1, Proprietary Version

RAIO-182565 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-48S1, 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-48S1 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 The applicants criticality safety analysis in TR-145417-P, Revision 0, Section 6.5.11, Multiple Misloaded Fuel Assemblies (( 

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2(a),(c) During the audit, the applicant cited NEI 12-16, Revision 4 Section 6.3.5 as a reference for its approach. NEI 12-16, Revision 4 Section 6.3.5, states that it is important to have a multi-tier defense-in-depth program to prevent or mitigate a multiple fuel misload scenario. The applicant does not explicitly define the administrative controls that will prevent multiple fuel misload. Information Requested Provide an explanation of the administrative controls that would prevent multiple fuel misload. Otherwise, provide an explanation and justification for not modeling multiple fresh fuel assemblies misloaded into Zone 1. The discussion should be detailed and use NEI 12-16, Revision 4 Section 6.3.5 as guidance. Include all requirements that future combined license applicants will have to adopt to be consistent with TR-145417-P, Revision 0. NuScale Nonproprietary NuScale Nonproprietary

NuScale Response: NuScale is supplementing its response to RAI 10502, Question FSR.LTR-48 that was originally transmitted in letter RAIO-179614 dated February 20, 2025. Although NuScale believes that misloading new fuel assemblies into the interior Zone 1 locations can be prevented with administrative controls, such as fuel handler training and instructions that new fuel assemblies are only allowed in an exterior row of a storage rack, it is beyond the scope of this topical report to demonstrate those administrative tools. Consequently, NuScale has added to the topical report a multiple misload analysis that bounds all new fuel assembly misload scenarios. Section 6.5.11.1 describes the analysis of loading new fuel assemblies in all cells of the storage rack. Using assumptions similar to those of the other multiple misload configurations, the analysis concludes that a minimum boron concentration of 2380 ppm ensures k95/95 maintains the same margin to the target value of 0.95 that is established in Section 6.5.5 for the nominal, zero boron case and its target value of 1.0. Impact on Topical Report: There are no impacts to Topical Report TR-145417, NuScale US460 Fuel Storage Rack Design Topical Report, as a result of this response. Additional Information: While the topical report contains export controlled information and is marked as such, none of the attached markup pages contain export controlled information. NuScale Nonproprietary NuScale Nonproprietary

NuScale US460 Fuel Storage Rack Design Topical Report TR-145417-NP Draft Revision 1 © Copyright 2025 by NuScale Power, LLC 174 6.5.4 Fuel Storage Configurations and Assembly Eccentric Positioning Scenarios The allowable fuel storage configurations for the FSRs are shown in Figure 6-6. Any assembly with a nominal enrichment up to 4.95 wt.% 235U may be placed in a Zone 2 location. An assembly must meet the enrichment and burnup requirements of Table 6-15 prior to being placed in a Zone 1 location. Fuel loading maps for a single misloaded FA are shown in Figure 6-16 through Figure 6-22. RAI FSR.LTR-48 A fuel loading map to analyze one configuration of multiple misloaded new FAs is shown in Figure 6-23. A fuel loading map to analyze FSR motion due to a seismic event is shown in Figure 6-24. The analysis evaluates 5 different scenarios of FA eccentric positioning within individual storage locations. Sensitivity studies are performed to determine the most reactive eccentric positioning scenario.

[ ] Table 6-24 System Bias for Pin Pitch Growth Soluble Boron (ppm) Enrichment (wt.% 235U) Assembly Average Burnup (GWD/MTU) Bias for Grid Growth Standard Deviation 0 [ ] 0 [ ] 0 [ ] 0 [ ] 0 [ ] 1450 [ ] 1450 [ ] 1450 [ ] 1450 [ ] 1450 [ ]

NuScale US460 Fuel Storage Rack Design Topical Report TR-145417-NP Draft Revision 1 © Copyright 2025 by NuScale Power, LLC 204 6.5.10 Single Misloaded Assembly A single misloaded FA is analyzed in one of seven potential locations as shown in Figure 6-16 through Figure 6-22. The Zone 1 fuel is modeled with [ ] The misloaded assembly analysis is performed with the uniform axial burnup distribution as this burnup distribution was shown to be conservative in Section 6.5.5. The Zone 2 fuel as well as the misloaded assembly is modeled with 4.95 wt.% 235U enrichment and no burnup. Eccentric positioning option 3, shown in Figure 6-7 is used for this analysis. Section 6.5.4 demonstrates that this is the most conservative option for a nominal fuel loading. The seven misloaded FA locations ensure that the most conservative misloaded fuel assembly configuration is analyzed. RAI FSR.LTR-48 The fuel compositions are calculated with TRITON/ORIGEN-S including the presence of a neutron source assembly. The results are shown in Table 6-27. The highest value of k95/95 at a boron concentration of 1450 ppm [ ] 6.5.11 Multiple Misloaded Fuel Assemblies RAI FSR.LTR-48 [ ] The fuel loading map shown in Figure 6-23 is used for the first configuration. The Zone 1 fuel is modeled with the limiting enrichment and burnup as shown in Table 6-15. A uniform axial burnup shape is used as well as the conservative axial burnup shape at [ ] GWD/MTU as shown in Table 6-6. Table 6-27 Single Misloaded Fuel Assembly Results Map # Boron (ppm) keff k k95/95 Map 6 1450 [ ] Map 7 1450 [ ] Map 8 1450 [ ] Map 9 1450 [ ] Map 10 1450 [ ] Map 11 1450 [ ] Map 12 1450 [ ]

NuScale US460 Fuel Storage Rack Design Topical Report TR-145417-NP Draft Revision 1 © Copyright 2025 by NuScale Power, LLC 205 The nominal loading map, shown in Figure 6-6, is used for the second configuration where the Zone 1 fuel is modeled at [ ] burnup. A uniform axial burnup shape is used as well as the conservative axial burnup shape at [ ] GWD/MTU as shown in Table 6-6. Both configurations are modeled with the eccentric fuel positioning scenarios 1 through 4, as shown in Figure 6-25, Figure 6-26, Figure 6-7, and Figure 6-27. Both multiple misload configurations use fuel composition data from TRITON/ORIGEN-S that assume the presence of a neutron source assembly. The multiple misload accident is the most reactive accident and determines the minimum boron concentration in the spent fuel pool. To facilitate the determination of the minimum boron concentration, calculations are performed at soluble boron amounts of 0, 800, 1200, 1600, and 2000 ppm, as well as the final chosen minimum value of 1450 ppm. Plots of keff versus soluble boron concentration are shown in Figure 6-42 and Figure 6-43. Results of k95/95 at the minimum soluble boron concentration of 1450 ppm are shown in Table 6-28. The table shows that at a boron concentration of 1450 ppm the largest value of k95/95 is [ ] RAI FSR.LTR-48 6.5.11.1 Multiple Misloaded Fuel Assemblies, Bounding Case RAI FSR.LTR-48 A third configuration uses a fuel loading map with Zone 2 fuel in all storage cells. Although a licensee is not expected to store more new fuel assemblies than are required for upcoming refueling activities, this configuration bounds any multiple misload scenario involving Zone 2 fuel assemblies. [ ] The bounding configuration is modeled with the eccentric fuel positioning scenarios 1 through 4, as shown in Figure 6-25, Figure 6-26, Figure 6-7, and Figure 6-27, respectively. RAI FSR.LTR-48 Calculations are performed at soluble boron concentrations of 0, 1450, 1600, 1800, 2200, 2400, and 2600 ppm. Table 6-28a shows the results of k95/95 at 2200, 2400, and 2600 ppm. The results of these calculations show that to maintain k95/95 less than the target value of 0.95 with a margin equal to the margin of [ ] determined in Section 6.5.5 requires a minimum boron concentration of 2380 ppm.

NuScale US460 Fuel Storage Rack Design Topical Report TR-145417-NP Draft Revision 1 © Copyright 2025 by NuScale Power, LLC 206 RAI FSR.LTR-48 Figure 6-42 Keff versus Boron Concentration for Multiple Misloaded New Fuel Assemblies (Map Option 13) [ ]

NuScale US460 Fuel Storage Rack Design Topical Report TR-145417-NP Draft Revision 1 © Copyright 2025 by NuScale Power, LLC 208 RAI FSR.LTR-48 RAI FSR.LTR-48 6.5.12 Fuel Storage System Seismic Event The mechanical analysis of the FSRs for a seismic event demonstrates that the FSRs may shift a few inches, [ ] Table 6-28 Multiple Misloaded Fuel Assembly Results Configuration1 Boron Concentration (ppm) keff k k95/95 Map=13, Shift=1, shape 1450 [ ] Map=13, Shift=2, shape 1450 [ ] Map=13, Shift=3, shape 1450 [ ] Map=13, Shift=4, shape 1450 [ ] Map=13, Shift=1, flat 1450 [ ] Map=13, Shift=2, flat 1450 [ ] Map=13, Shift=3, flat 1450 [ ] Map=13, Shift=4, flat 1450 [ ] Map=5, Shift=1, shape 1450 [ ] Map=5, Shift=2, shape 1450 [ ] Map=5, Shift=3, shape 1450 [ ] Map=5, Shift=4, shape 1450 [ ] Map=5, Shift=1, flat 1450 [ ] Map=5, Shift=2, flat 1450 [ ] Map=5, Shift=3, flat 1450 [ ] Map=5, Shift=4, flat 1450 [ ] 1The term Shift refers to the eccentric positioning scenario. Table 6-28a Multiple Misloaded New Fuel Assemblies (in All Storage Cells) Results Eccentric Positioning Scenario (Shift) Boron Concentration (ppm) keff k k95/95 1 2200 [ ] 2 2200 [ ] 3 2200 [ ] 4 2200 [ ] 1 2400 [ ] 2 2400 [ ] 3 2400 [ ] 4 2400 [ ] 1 2600 [ ] 2 2600 [ ] 3 2600 [ ] 4 2600 [ ]

NuScale US460 Fuel Storage Rack Design Topical Report TR-145417-NP Draft Revision 1 © Copyright 2025 by NuScale Power, LLC 220 [ ] [ ] The burnup limits for selected values of enrichment are shown in Table 6-15, reproduced here for convenience. 6.6.4 Abnormal and Accident Conditions 6.6.4.1 Multiple Misloaded Fuel Assemblies RAI FSR.LTR-48 ThreeTwo scenarios of multiple misloaded FAs are analyzed as discussed in Section 6.2. This is the most limiting event and sets the minimum soluble boron concentration at 1450 ppm. Disregarding the bounding case of new fuel assemblies in all cells, the minimum soluble boron concentration is 1450 ppm. For this condition the largest value of k95/95 is [ ] well below the limit of 0.95. Including the bounding case sets the minimum soluble boron concentration at 2380 ppm, with the largest k95/95 at [ ] 6.6.4.2 Single Misloaded Fuel Assembly The single misloaded FA is discussed in Section 6.5.10. The FSRs are fully loaded according to the storage map discussed in Section 6.6.3. The misloaded FA is placed in several locations to ensure the most reactive position is found. Credit is taken for the minimum boron concentration of 1450 ppm. The highest value of k95/95 provides significant margin to the limit of 0.95. 6.6.4.3 Fuel Assembly Dropped On the Fuel Storage Racks An FA dropped on top of the FSRs is separated from the fuel region of the FAs stored in the rack by more than [ ] This distance is sufficient that the dropped assembly is considered decoupled from the fuel stored in the rack. No further consideration is required. Table 6-35 Final Burnup versus Enrichment Limit for Zone 1 Enrichment (wt.% 235U) Burnup Limit (GWD/MTU) [ ] [ ] [ ] [ ] [ ] [ ] [ ]

RAIO-182565 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-182566

AF-182566 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 Supplemental Responses to NRC Request for Additional Information (RAI-10502 R1, Question FSR.LTR-48S1) 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 supplemental response to NRC Request for Additional Information RAI-10502 R1, Question FSR.LTR-48S1. 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-182566 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 June 02, 2025. Mark W. Shaver

RAIO-182565 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 2 (NuScale Response to NRC Request for Additional Information RAI-10502 R1, Question FSR.LTR-48S1) to the NuScale Power, LLC letter Number LO-182565, with subject NuScale Power, LLC Supplemental Response to NRC Request for Additional Information No. 001 (RAI-10502 R1) on the 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: (5/29/2025) (NAME) Email: morris.byram@framatome.com Phone: 434-221-1082 BYRAM Morris Digitally signed by BYRAM Morris Date: 2025.05.29 14:12:38 -07'00'}}

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