RAIO-1218-63980, LLC Response to NRC Request for Additional Information No. 202 (Erai No. 8911) on the NuScale Design Certification Application

LLC Response to NRC Request for Additional Information No. 202 (Erai No. 8911) on the NuScale Design Certification Application

ML18355B029
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Site:	NuScale
Issue date:	12/21/2018
From:	Rad Z NuScale
To:	Document Control Desk, Office of New Reactors
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ML18355B028	List: RAIO-1218-63980, LLC Response to NRC Request for Additional Information No. 202 (Erai No. 8911) on the NuScale Design Certification Application
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RAIO-1218-63980 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com December 21, 2018 Docket No.52-048 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.

202 (eRAI No. 8911) on the NuScale Design Certification Application

REFERENCE:

U.S. Nuclear Regulatory Commission, "Request for Additional Information No.

202 (eRAI No. 8911)," dated August 25, 2017 The purpose of this letter is to provide the NuScale Power, LLC (NuScale) response to the referenced NRC Request for Additional Information (RAI).

The Enclosures to this letter contain NuScale's response to the following RAI Question from NRC eRAI No. 8911:

03.09.02-18 is the proprietary version of the NuScale Response to NRC RAI No. 202 (eRAI No.

8911). 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 and the enclosed responses make no new regulatory commitments and no revisions to any existing regulatory commitments.

If you have any questions on this response, please contact Marty Bryan at 541-452-7172 or at mbryan@nuscalepower.com.

Sincerely, Zackary W. Rad Director, Regulatory Affairs NuScale Power, LLC Distribution:

Gregory Cranston, NRC, OWFN-8G9A Samuel Lee, NRC, OWFN-8G9A Marieliz Vera, NRC, OWFN-8G9A

RAIO-1218-63980 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com : NuScale Response to NRC Request for Additional Information eRAI No. 8911, nonproprietary : Affidavit of Zackary W. Rad, AF-1218-63981 : NuScale Response to NRC Request for Additional Information eRAI No. 8911, proprietary

RAIO-1218-63980 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com :

NuScale Response to NRC Request for Additional Information eRAI No. 8911, proprietary

RAIO-1218-63980 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com :

NuScale Response to NRC Request for Additional Information eRAI No. 8911, nonproprietary

Response to Request for Additional Information Docket No.52-048 eRAI No.: 8911 Date of RAI Issue: 08/25/2017 NRC Question No.: 03.09.02-18 10 CFR 52.47 requires the design certification applicant to include a description and analysis of the structures, systems, and components (SSCs) sufficient to permit understanding of the system designs. TR-0916-51502-P, Rev. 0, NuScale Power Module Seismic Analysis describes the methodologies and structural models that are used to analyze the dynamic structural response due to seismic loads acting on the NuScale Power Module (NPM). The description is insufficient for staff to reach a safety finding. Specifically, the report does not provide the seismic and LOCA stress results. Please provide the seismic analysis details and stress results under Service Level D condition for the following reactor internals components.

Include the requested information in the NPM Seismic Report or in separate reports.

core support assembly (core barrel, lower core plate, reflector, upper core plate, upper core support)

lower riser assembly

upper riser assembly (upper riser, upper riser hanger support)

control rod assembly guide tube, control rod assembly guide tube support, control rod assembly card, control rod drive shaft, and control rod drive shaft support

steam generator tubes and tube supports

control rod assembly guide tubes The component analysis should include a brief description of the component structure modelling, input motion (time history or in-structure response spectrum), major assumptions, acceptance criteria under Service Level D condition including stress and deflection limits, fluid modelling, mass distribution, damping values, gap considerations, dominant modes and frequencies, and seismic and LOCA stress results and ASME B&PV Code Section III stress evaluation under Service Level D condition.

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NuScale Response:

Detailed stress analyses for the steam generator (SG) assembly and the reactor vessel internals (RVI) under Service Level D conditions were performed in accordance with the American Society for Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPVC).

Analysis details and stress results are summarized below.

SG Assembly The components and welds included in the SG assembly evaluation are:

1. SG tubes

2. SG tube support column assemblies

3. Upper SG supports & associated weld

4. Lower SG supports & associated weld In this evaluation, a 3D ANSYS model of the SG assembly, reactor pressure vessel (RPV), and the upper riser is used. A modal analysis is performed up to a minimum of 100 Hz to capture the dynamic effect due to seismic events and is followed by mode superposition spectrum analysis to calculate the seismic response. The loss of coolant accident (LOCA) acceleration, dead weight, and pressure are analyzed using static analysis.

Assumptions

1. MSPB and FWPB loads are bounded by design bases LOCA loads: This evaluation assumes that the main steam pipe break (MSPB) and feedwater pipe break (FWPB) Service Level D loads defined in the Design Specification are bounded by the design bases LOCA loads. The MSPB and FWPB Service Level D loads acting on the internal secondary side of the tubing are not available. However, because the SG tube external pressure is ((2(a),

(c) psia and the internal pressure is (( }}2(a),(c) psia under normal operating conditions, it is assumed that the SG tube differential pressure generated from a MSPB or FWPB is bounded by the maximum total Level D pressure, (( }}2(a),(c) psi, applied in this analysis (see Input 1, below). In addition, the reaction forces at the SG tube supports and the upper and lower SG supports due to MSPB and FWPB do not affect the conclusions of the analysis since the stress ratios at these supports are not controlling (see the Results section, below). This assumption is tracked by a NuScale open design item and the MSLB and FWLB loads will be evaluated in order to close this open item. NuScale Nonproprietary

2. LOCA Loads: It is assumed that the LOCA loads obtained on the RPV at the top and bottom of the SG are bounding. The loads from locations on the upper riser are not used because the upper riser in the blowdown model is not supported in the radial direction in the blowdown calculation. Actually, the upper riser is coupled to the RPV shell in the radial direction via the stacks of SG tube supports. Therefore, due to this coupling, it is assumed that the loads on the RPV are representative of the loads at corresponding elevations on the upper riser.

Input loading The load combinations applicable to this analysis are provided in Table 1. Each of the loads provided in Table 1 is discussed below.

1. Pressure (P): Per the Design Specification, the maximum primary/secondary side pressure is ((

}}2(a),(c) psia. This maximum pressure is added to the maximum acoustic time history pressure of (( }}2(a),(c) psia (determined from LOCA loading, below) such that a total Level D pressure applied is (( }}2(a),(c) psia.

2. Deadweight (DW): The deadweight of the SG items, identified within the scope of this calculation, is captured by applying a specifying linear acceleration of 386.09 in/s2 in the positive vertical direction to simulate the downward effect of gravity.

3. Buoyancy (B): Buoyancy is not included and therefore the full DW is considered. This provides minimal conservatism as the full DW contributes a small amount of stress to the final stress as compared to other applicable Level D loads.

4. External mechanical loads (EXT): The only applicable EXT loads are the reaction forces at RPV-RVI interfaces. These are captured via model boundary conditions and connections (see Boundary conditions information under the Component structural modeling description).

5. Piping mechanical or thermal loads (M): There are no applicable M loads for the SG model.

6. Rod ejection accident (REA): REA is not applicable to the SG model.

7. MSPB/FWPB: See discussion in Assumption 1 above.

8. SCRAM (SCR): SCRAM loads due to the drop of the CRD shaft and the control rod assembly (CRA) do not affect the SG stress analysis.

9. Safe-shutdown earthquake (SSE): SSE response spectra for the SG assembly are obtained at locations on the upper riser and at the top and bottom of the SG. Bounding spectra from locations on the upper riser are developed for the lower riser end. The broadened enveloped in-structure response spectra (ISRS) with 4% damping at the applicable locations is utilized to generate bounding spectra for application within this analysis. Figure 1 through Figure 3 present the seismic response spectra used in this evaluation.

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10.LOCA: In-structure LOCA acceleration time histories are obtained at the top and bottom of the SG (see Assumption 2 above). In-structure spectra are developed using the acceleration time histories with 4% damping ratio. The maximum spectrum acceleration is (( }}2(a),(c) in the horizontal direction and (( }}2(a),(c) in the vertical direction. These values are applied statically in the LOCA evaluation portion with a factor of 1.5. LOCA acoustic pressure time histories are obtained along the RPV }}2(a),(c), at the lower riser (( }}2(a),(c), and at the core barrel }}2(a),(c). For these locations, a maximum acoustic pressure of (( }}2(a),(c) psia is identified. This value was multiplied by a factor of 1.5 to obtain a maximum acoustic pressure of (( }}2(a),(c) is used in this evaluation). This pressure was added to the Level D maximum pressure identified above and applied statically in the LOCA evaluation. Thus, the total Level D pressure applied is (( }}2(a),(c) psia. This evaluation considers the following Service Level D load combination for the primary stress qualification: lP+DWl+SRSS(SSE,LOCA) where SRSS is the square root sum of the squares. Component structural modeling

1. Overview A 3D ANSYS model was created wherein the SG tubes are modeled as BEAM188 elements. The element type was modified to PIPE288 in order to apply appropriate tube pressure. The model consists of 21 SG tube columns and 21 x 8 SG tube support column assemblies. Tube columns 1, 11, and 21 are explicitly modeled while the other tube columns are modeled with each bundle of tubes being represented by a super element (ANSYS Matrix50 element). Super element use for the tube models is necessary due to the large number of degrees of freedom. The RPV and the upper riser are partially modeled to provide proper boundary conditions to the SG model. Due to the large number of degrees of freedom in the RPV and upper riser model, the RPV and upper riser model was converted to a super element, with the nodes interfacing with SG tube supports selected as master nodes. The remote points corresponding to the SG top section, the SG bottom section, the lower end of the upper riser, the upper SG supports, and the lower SG supports are also NuScale Nonproprietary

selected as master nodes to apply boundary conditions and connections. The SG model and the adjacent upper riser and RPV are illustrated in Figure 4.

2. Fluid modeling and mass distribution

a. Secondary water in SG tubes: The SG tubes are modeled assuming that the tubes are filled with half liquid secondary water and half steam. In reality, the portions are not 50/50 and the density is not uniform. However, the overall modal response of the SG is not sensitive to the distribution of the mass of the secondary side water, just that the total mass of water in the secondary side is close to the actual value. The 50/50 mix is a reasonable assumption as it captures the appropriate mass of the structure and a reasonable distribution of mass in the tubes.

b. Simplified representation of RCS water: The RCS water in the annulus between the upper riser and the RPV shell is represented by Fourier nodes for the elevation between

(( }}2(a),(c). The RCS water inside the upper riser is calculated by the total volume, neglecting any components inside the upper riser, and is distributed onto the upper riser using point masses.

3. Gap considerations

a. Innermost column unconstrained circumferentially by riser: The SG assembly was modeled assuming that the riser backing strips do not provide circumferential constraint to the tube support tabs for the innermost column. The backing strips are designed to provide radial support to the innermost bar. The gap between the tabs and the backing strips allows the bar to have small circumferential motion.

b. Tube support-to-tube support force distribution to tabs: At each support location, the tube support-to-tube support radial force is carried by the support tabs, not the tubes. A large force on the tab is required to close the diametric gaps and distribute load to the SG tubes. The force on the tab due to Level D loading is significantly lower than the force required to close the gaps. Thus, the radial force at the tube support is only distributed to the tabs, not to the tubes.

4. Boundary conditions The super element for the RPV and upper riser, the 18 super elements for SG tubes in Columns 2-10 and 12-20, the support bars, and the three tube columns are combined to form the final model using ANSYS parametric design language (APDL). The following connections and boundary conditions are applied to the combined model:

a. SG tubes at the feedwater plenum are constrained in Ux, Uy, Uz, ROTx, ROTy, and ROTz directions to simulate the interface between the SG tube and the RPV feedwater plenum. Refer to Figure 5 and Figure 6 for additional details.

b. SG tubes at steam plenum are constrained in Ux, Uy, and Uz, ROTx, ROTy, and ROTz to simulate the interface between the SG tube and the steam plenum of the PZR. Refer to Figure 7 and Figure 8 for additional details.

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c. SG inner tube support column 1 is coupled to the master nodes in the RPV and upper riser model super element to simulate the interfacing between the SG column tabs and riser OD in Ux (radial direction in the cylindrical coordinate systems) and ROTz, as shown in Figure 9. Note that the backing strips on the riser are not designed to constrain the circumferential displacement of the tab tips. The gap between the tabs and the backing strips allows the bar to have small circumferential motion.

d. SG outer tube support column 21 is coupled to the master nodes in the RPV and upper riser model super element to simulate the interfacing between the SG column bars and the RPV ID in Ux (radial direction in the cylindrical coordinate systems) and ROTz, as shown in Figure 10.

e. SG tubes are coupled to support tabs middle nodes for UX, UY, and UZ in the local coordinate systems shown in Figure 11. SG tube nodes ROTy and ROTz (local coordinate system) are coupled to support tabs root nodes ROTz and ROTy (cylindrical coordinate system), respectively.

f. Between any two adjacent columns, the tab tip nodes are coupled to the bar back nodes in Ux and Uy in the cylindrical coordinate system. The ROTz is also constrained.

g. SG tube support bar upper ends are coupled to the upper SG supports in Uy and Uz directions, as illustrated in Figure 12.

h. SG tube support bar lower ends are coupled to the lower SG supports in Uy direction in the cylindrical CS, as illustrated in Figure 13.

Acceptance criteria Per ASME BPVC, Section III, Paragraph NB-3225 and NG-3225, the rules in Section III Non-mandatory Appendix F may be used in evaluating Service Level D (Faulted Condition) loads. Therefore, Appendix F, Paragraph F-1331, Criteria for Components is used in the evaluation. The material design stress intensity, Sm, the material yield strength, Sy, and the material ultimate strength, Su, are taken from ASME BPVC, Section II, Part D at a temperature of 600°F. The following qualification criteria are applicable:

1. F-1331.1 for general primary membrane stresses, local primary membrane stresses, general or local membrane plus bending primary stresses and average primary pure shear stress.

2. NB-3227 (SG tubes) & NG-3227 (SG supports) for special stress limits Applicable Service Level D stress limits are summarized in Table 2.

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The SG upper and lower tube support bars are welded to the RPV with a full penetration bevel weld. In accordance with the design specification, the welds between the upper and lower SG supports and the integral steam plenum and RPV shell are part of the RPV and constructed in accordance with ASME BPVC, Section III, Subsection NB, where no weld quality factors are required. The SG tube and SG tube support bar deflections in the cylindrical coordinate systems are extracted for the load cases. The maximum deflections are found for radial, circumferential and vertical directions. There are no specific limits for the deflections. Deflections are provided for information only. Results

1. Modal results The significant mode in each direction is listed in Table 3, and plotted in Figure 14 through Figure 16. Note that the total simulated mass participation ratios are ((

}}2(a),(c) for X, Y and Z directions, respectively. The low total ratios are due to the fact that the RPV has the majority of the mass }}2(a),(c)) which is not activated with significant effective mass at lower frequencies.

2. Stress results The maximum membrane stress intensity (Pm) and membrane plus bending stress intensity (Pm + PB) in the SG assembly components and associated welds are provided in Tables 4 through 9.

3. Deflections The deflections in the SG tubes and the SG tube support bars are provided in Tables 10 and 11, respectively.

Conclusions The analysis described above demonstrates that the design of the SG assemblyspecifically the SG tubes, the SG tube support column assembly, the upper and lower SG supports, and the SG support weldssatisfies the structural requirements of the ASME BPVC for Service Level D loads. NuScale Nonproprietary

Table 1. Service Level D load combinations Plant Event Service Level Load Combination Allowable Limit Rod Ejection Accident D P + DW + B +EXT + M + REA + SCR Level C Main Steam and Feedwater Pipe Breaks P + DW + B + EXT + M + MSPB/FWPB + SCR Level D SSE + DBPB-MSPB-FWPB P + DW + B + EXT + M + SCR +/-SRSS(SSE + DBPB-MSPB-FWPB) Level D Hydrogen Detonation with DDT P + DW + B + EXT + HDDT Level D Note: SRSS is the square root sum of the squares Table 2. Allowable stress limits for Service Level D ASME Stress Category ASME Code Paragraph ASME Criterion General Primary Membrane Stress Intensity, Pm F-1331.1(a) lesser of 2.4Sm and 0.7Su Local Primary Membrane Stress Intensity, Pl F-1331.1(b) 1.5 Pm General or Local Primary Membrane plus Bending Stress Intensity, Pm+Pb F-1331.1(c)(1) 1.5 Pm Compressive Loads (SG Tubes)Allowable External Pressure F-1331.5(b), Note 1 1.5 x (Pa) Average Primary Pure Shear Stress SG Tubes NB-3225, F-1331.1(d) SG Supports NG-3225, NG-3227, NG-3227.2 SG Tubes 0.42Su SG Supports 1.2Sm Note 1) Allowable external pressure (Pa) as calculated by NB-3133 is greater than or equal to the external pressure (P). Alternatively, the rules of ASME Code Case N-759-2 may be used. Table 3. Significant modes Direction Freq. (Hz) Effective Mass (Slug) Ratio Total simulated participation ratio X (( Y Z }}2(a),(c) NuScale Nonproprietary

Table 4. Bounding stresses in upper portion of SG tube support column Max Stress (psi) Allowable Stress (psi) Load Step Stress Ratio Passed Pm (( Yes Pm+Pb }}2(a),(c) Yes Table 5. Bounding stresses in lower portion of SG tube support column Max Stress (psi) Allowable Stress (psi) Load Step Stress Ratio Passed Pm (( Yes Pm+Pb }}2(a),(c) Yes Table 6. Bounding stresses in SG tube support bar tabs (a) Tabs providing radial supports Max Stress (psi) Allowable Stress (psi) Load Step Stress Ratio Passed Pm (( Yes Pm+Pb }}2(a),(c) Yes (b) Tabs providing circumferential supports Max Stress (psi) Allowable Stress (psi) Load Step Stress Ratio Passed Pm (( Yes Pm+Pb }}2(a),(c) Yes Table 7. Bounding stresses in SG tubes Max Stress (psi) Allowable Stress (psi) Load Step Stress Ratio Passed Col. 1 Pm (( Yes Pm+Pb Yes Col. 11 Pm Yes Pm+Pb Yes Col. 21 Pm Yes Pm+Pb }}2(a),(c) Yes NuScale Nonproprietary

Table 8. Bounding stresses in the upper SG support welds Circ. Location Max Stress (psi) Allowable Stress (psi) Stress Ratio Passed 1 Pm (( Yes Pm+Pb Yes 2 Pm Yes Pm+Pb Yes 3 Pm Yes Pm+Pb Yes 4 Pm Yes Pm+Pb Yes 5 Pm Yes Pm+Pb Yes 6 Pm Yes Pm+Pb Yes 7 Pm Yes Pm+Pb Yes 8 Pm Yes Pm+Pb }}2(a),(c) Yes Table 9. Bounding stresses in the lower SG support welds Circ. Location Max Stress (psi) Allowable Stress (psi) Stress Ratio Passed 1 Pm (( Yes Pm+Pb Yes 2 Pm Yes Pm+Pb Yes 3 Pm Yes Pm+Pb Yes 4 Pm Yes Pm+Pb Yes 5 Pm Yes Pm+Pb Yes 6 Pm Yes Pm+Pb Yes 7 Pm Yes Pm+Pb Yes 8 Pm Yes Pm+Pb }}2(a),(c) Yes NuScale Nonproprietary

Table 10. Maximum deflection in SG tubes Deflection (in) Column Radial Hoop Vertical 1 (( 11 21 }}2(a),(c) Table 11. Maximum deflection in SG tube support bars Deflection (in) Column Radial Hoop Vertical 1 (( 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 }}2(a),(c) NuScale Nonproprietary

(( }}2(a),(c) Figure 1. Bounding seismic spectra in X NuScale Nonproprietary

(( }}2(a),(c) Figure 2. Bounding seismic spectra in Y NuScale Nonproprietary

(( }}2(a),(c) Figure 3. Bounding seismic spectra in Z NuScale Nonproprietary

(( }}2(a),(c) Figure 4. ANSYS model for column 1 NuScale Nonproprietary

(( }}2(a),(c) Figure 5. SG tubes at feedwater plenum - top view (ROTx, ROTy, and ROTz) (( }}2(a),(c) Figure 6. SG tube columns at feedwater plenum - side view (Ux, Uy, and Uz) NuScale Nonproprietary

(( }}2(a),(c) Figure 7. SG tube columns at steam plenum - side view (ROTx, ROTy and ROTz) (( }}2(a),(c) Figure 8. SG tube columns at steam plenum - side view (Ux, Uy, and Uz) NuScale Nonproprietary

(( }}2(a),(c) Figure 9. SG tube support column 1 - top view (Ux and ROTz) NuScale Nonproprietary

(( }}2(a),(c) Figure 10. SG tube support column 21 - top view (Ux and ROTz) NuScale Nonproprietary

(( }}2(a),(c) Figure 11. SG tube to support column (local Coord. system - only one tube shown) NuScale Nonproprietary

(( }}2(a),(c) Figure 12. SG upper tube supports - top and side view (Uy and Uz coupling) NuScale Nonproprietary

(( }}2(a),(c) Figure 13. SG lower tube supports - top and side view (Uy coupling) NuScale Nonproprietary

(( }}2(a),(c) Figure 14. Significant mode in X NuScale Nonproprietary

(( }}2(a),(c) Figure 15. Significant mode in Y NuScale Nonproprietary

(( }}2(a),(c) Figure 16. Significant mode in Z NuScale Nonproprietary

Reactor Vessel Internals (RVI) The components and welds included in this evaluation are listed in Tables 12 and 13 below. Depending on whether seismic and loss of coolant accident (LOCA) forces and moments are available for a component under analysis, one of two major methodologies is used in this calculation. In the category 1 methodology, forces and moments are applied at the bounding cross section of the components and associated welds. For components with simple geometries, primary stresses are calculated using closed form equations. In the case of more complicated geometry, forces and moments are applied to a finite element (FE) model of the component and stresses are derived using a static FE analysis. The category 2 methodology is used when seismic and LOCA forces and moments are not available. In this case, response spectra are defined at the item supports and stresses are derived from the FE analysis. The applicable methodology for each component and weld included in this analysis is provided in Tables 12 and 13. Assumptions

1. Applicable loss of coolant accident (LOCA) time history data: It is assumed that the LOCA loads obtained at the top of the upper riser and on the RPV at the bottom of the SG are bounding. The loads from locations along the length of the upper riser are not used because the upper riser in the blowdown model is not supported in the radial direction in the blowdown calculation. Actually, the upper riser is coupled to the RPV shell in the radial direction via the stacks of SG tube supports. Therefore, due to this coupling, it is assumed that the loads on the RPV are representative of the loads at corresponding elevations on the upper riser.

2. Bellows concentric plate dimensions: The dimensions of the URVI bellows concentric plates are not yet finalized as the component details are to be provided by the supplier. The analysis performed on this component is based on a computer aided design (CAD) model.

3. Control rod drive mechanism (CRDM) SCRAM loads: A mechanical SCRAM load of ((

}}2(a),(c) per CRA is assumed in the analysis based on pre-test CRA drop test analysis. Input loading The load combinations applicable to this analysis are provided in Table 14. Each of the loads provided in Table 14 is discussed, below. NuScale Nonproprietary

1. Operating pressure difference (PD): The operating pressure difference across the internals does not vary significantly for different power levels. Therefore, this load is not included in the analysis.

2. Deadweight (DW): For the category 1 methodology, DW is applied as reaction forces and moments. For the category 2 methodology, DW is added as a separate load step in the analysis.

3. Buoyancy (B): The reaction forces and moments (category 1 methodology) used for DW include buoyancy effects. For the category 2 methodology, buoyancy is not included and therefore the full DW is considered. This provides minimal conservativism as the full DW contributes a small amount of stress to the final stress as compared to other applicable Level D loads.

4. Mechanical Loads such as RVI support reactions, fuel assembly weight, SCRAM Loads (EXT): A mechanical SCRAM load of ((

}}2(a),(c) per CRA is included in the analysis where applicable (see Assumption 3 above). Note that fuel assembly weight is included in the DW loading. RVI support reactions are captured in DW, LOCA, and SSE loads.

5. Rod ejection accident (REA): REA is not applicable.

6. Main steam pipe break/feedwater pipe break/design basis pipe break (MSPB/FWPB/LOCA):

MSPB and FWPB loads are not applicable to the components analyzed in this evaluation. LOCA loads (i.e. design basis loss of coolant accident (LOCA) loads) are applied as reaction forces and moments or as accelerations in static analysis.

7. SSE (Safe Shutdown Earthquake): Reaction forces and moments, ISRS, or time histories are used. A constant composite structural damping ratio of 4% is used for the multi-point response spectrum analysis.

Based on the loading information provided above, the loads applicable to the lower core plate (LCP) analysis are DW + SCRAM +/- SRSS (SSE + LOCA). For other components, the required loads are DW +/- SRSS (SSE + LOCA). Component structural modeling Modeling details are provided below for components analyzed via FE analysis.

1. Upper core plate (UCP)

Figure 17 shows the model of the UCP. Note the model was created based on a previous configuration of the bolt holes rather than the configuration currently documented in the NuScale Power Module (NPM) design drawings. This is acceptable because the boundary conditions are applied at the circumference of the UCP and no loads is applied on the bolt holes, so the bolt hole configuration has no effect on the analysis of the plate. (The stress evaluation of the UCP tabs is performed using the current configuration of the tab and NuScale Nonproprietary

closed form equations.) A static analysis is performed for the UCP. The applicable loads are the DW, SSE, and LOCA forces and moments (category 1 methodology) provided at the lower riser-UCP interface (( }}2(a),(c). The combined loads are applied to a single pilot node at the center of the UCP. This pilot node is connected to 36 slave nodes, as shown in Figure 17, where each slave node is created at the fuel assembly location. Each slave node is tied to each of the fuel pin holes using contact pairs. Therefore, the load is transferred from the pilot node to the slave nodes and then to the pin holes. This distributes the load across the entire plate for a realistic distribution of forces. The boundary conditions are applied at the circumference of the UCP. Here, all six degrees of freedom (DOF) are constrained as shown in Figure 17.

2. Lower core plate (LCP)

Figure 18 shows the model of the LCP. Some of the holes in the LCP are shifted or excluded from the FE model. The effect of these shifts or exclusions is negligible because the highest stresses in the LCP are in the grids (fuel assembly locations) and not near these holes. Therefore, using this FE model for stress analysis is acceptable. A static analysis is performed for the LCP. The applicable loads are the SCRAM vertical force and the DW, SSE, and LOCA forces and moments (category 1 methodology) provided at the reflector-LCP-core barrel interface (elevation 47.3 inches). The combined loads are applied to a single pilot node at the center of the LCP. This pilot node was connected to 36 slave nodes, as shown in Figure 18, where each slave node is created at the fuel assembly location. Each slave node is tied to each of the fuel pin hole using contact pairs. Therefore, the load is transferred from the pilot node to the slave nodes and then to the pin holes. This distributes the load across the entire plate for a realistic distribution of forces. The boundary conditions are applied at the circumference of the LCP. Here, the six DOFs are constrained as shown in Figure 18.

3. Upper riser hanger ring Figure 19 shows the model of the upper riser hanger ring. This model was created based on a previous configuration of the hanger ring rather than the configuration currently documented in the NPM design drawings. However, since the previous configuration has NuScale Nonproprietary

less total material and since the holes are larger in this configuration, the stresses and deformation calculated from the previous configuration is larger and thus more conservative. On the other hand, the new configuration adds approximately 650 lbm. This added mass has negligible effect on the upper riser hanger ring stress as compared to the other applicable loads. Therefore, it is acceptable to use the previous configuration for analysis. A static analysis is performed for the upper riser hanger ring. The applicable loads are the DW and SSE forces and moments (category 1 methodology) provided at each hanger brace and the LOCA loads provided at the center of the upper riser hanger ring. The combined loads are applied at the hanger brace attachment points in the local coordinate systems for the braces (note that the reactions at the hanger brace locations due to the LOCA loads at the center of the hanger ring are determined before the loads are combined). The ring is constrained using a fixed support (six DOFs are constrained) at the 8 bolt holes which attach the hanger ring to the baffle plate. This is shown in Figure 19.

4. Control rod assembly (CRA) guide tube assembly

a. Overview The CRA guide tube assembly is composed of four components: CRA guide tube, CRA cards, CRD shaft alignment cone, and CRA lower flange. There are no available loads in form of forces and moments for the CRA guide tube assembly. Loads acting on the assembly are generated by performing a response spectra analysis for SSE loads and a static analysis of LOCA accelerations (category 2 methodology). Prior to the SSE response spectrum analysis, a modal analysis is performed. The modal analysis is run for 100 modes to capture the dynamic effect due to seismic events.

Considering the control rod assembly in a variety of parking positions (see Fluid modeling and mass distribution information, below), three ANSYS analyses are performed. Figure 20 shows the basic geometry and mesh of the CRA guide tube assembly model. The CRA guide tube is modeled using SHELL181 elements (teal), while other components are modeled using SOLID45 elements (purple). Figure 21 shows pilot nodes at which the response spectra are applied. This figure also shows the simulated constraints with the guide tube support plate (GTSP) and the UCP. These constraints are realized through multi-point constraint (MPC), as shown in NuScale Nonproprietary

Figure 22. CRA cards, the alignment cone, and the lower flange are also attached to the tube via bonded contact elements as shown in the same figure.

b. Fluid modeling and mass distribution To account for added mass of water inside the CRA guide tube assembly, the mass density of the CRA tube is adjusted by adding the mass of water contained inside the CRA guide tube assembly.

Interaction (parking) of the control rod is also accounted for. The control rod may be in a variety of positions - from rod completely inserted into fuel to fully elevated. In case of fully inserted control rods, only the alignment cone supports part of the CRD shaft. In the case of the control rods in the fully elevated position, the entire CRA guide tube assembly provides support for the CRD shaft. The interaction of the control rods is simulated using mass elements. For conservatism, the entire mass of the control rods is imposed on the alignment cone for the case of the rod completely elevated. Similarly, for the cases where the rod is partially elevated, the entire mass of the control rod is distributed to two of the longest fingers of the top card and then, in a separate run, the entire mass of the control rod is distributed to the second card from top of the CRA guide tube. The added mass locations for these three cases are illustrated in Figure 23.

5. CRA guide tube support plate (GTSP)

The CRA GTSP supports the top of the CRA. Static analysis is performed on the CRA GTSP. Loads acting on the CRA GTSP are extracted from the CRA analysis documented above (category 1 methodology). There are 16 CRAs supported by the CRA GTSP. The 16 locations are loaded through pilot nodes that distribute loads into the interface of the plate with the CRAs. Figure 24 shows the CRA GTSP model and boundary conditions. Connection of the CRA GTSP to the lower riser spacer is not modeled. Nodes at the CRA GTSP-spacer interface are instead constrained in all degrees of freedom. This simplification has negligible impact on stresses and is therefore acceptable.

6. Upper riser assembly

a. Overview The Upper Riser Assembly (URA) is composed of upper CRD shaft supports, upper riser transition, upper riser section, upper riser hanger ring, upper riser hanger braces, and upper riser bellows. The 16 CRD shafts are also included in the structural model. There are no available loads in form of forces and moments for the URA, with the exception of NuScale Nonproprietary

the interface loads at the top of the upper riser hangers. Loads acting on the URA have are generated by performing a response spectra analysis for SSE loads and static analyses of LOCA accelerations (category 2 methodology). Prior to the SSE response spectrum analysis, the modal analysis was run for 2000 modes in order to capture an effective mass of at least 80 percent. Figure 25 depicts the basic geometry and mesh of the URA model. The element types used in the model are listed in Table 15. The contacts are bonded except bellows lateral restraints as shown in Figure 26. Constraints of the model are illustrated in Figure 27.

b. Fluid modeling and mass distribution To account for added mass of water inside the URA, the mass density of the URA is adjusted by adding the mass of water contained inside the URA assembly. A similar approach is taken for the drive shafts; the total mass is evenly distributed in PIPE288 elements. MASS21 elements are added to the ends of the drive shafts to account for the mass of the control rod assemblies.

Acceptance criteria Per paragraph NG-3225 of Section III, Subsection NG, the rules of ASME BPVC Appendix F are to be used for Level D conditions. In addition, when the special stress limits of NG-3227 are applicable for Level D Limits, the calculated stresses shall not exceed twice the stress limits given in NG-3227 as applied for Level A and Level B Service Limits. The applicable qualification criteria from ASME BPVC Table F-1200-1 and paragraph NG-3227 are summarized as follows:

1. F-1331.1 for general primary membrane stresses, local primary membrane stresses, general or local membrane plus bending primary stresses for components.

2. NG-3227.1(a) for bearing stress for components. Note that F-1331.3 is bounded by NG-3227.1(a).

3. F-1331.1(d) and NG-3227.2(a) for average primary pure shear stress of components.

4. F-1334.3 and F-1334.5 for buckling of components.

5. F-1335.1 for allowable tensile stress of bolted joints.

6. F-1335.2 for allowable shear stress of bolted joints.

7. F-1335.3 for allowable combined tensile and shear stresses of bolted joints.

Table 16 summarizes the applicable stress limits. NuScale Nonproprietary

The qualification criterion for welds is provided in ASME BPVC paragraph NG-3352 and is noted below: The quality factor is used by multiplying the allowable stress limit for primary and secondary categories times the quality factor in evaluating the design. The use of weld quality factor n is for static, not fatigue applications. Therefore, the allowable stresses for welds are the stress limits in Table 16 multiplied by a quality factor n, where n is provided in ASME BPVC Table NG-3352-1. Table 17 summarizes weld types and their applicable quality factors. Relative displacements between adjacent the control rod drive (CRD) shaft grids are evaluated. Note that there are no specific limits for the displacements and results are provided for information only. Results

1. Modal results

a. CRA guide tube assembly The modal results from CRA_1 analysis are shown in Figure 28, indicating the major horizontal modes are at ((

}}2(a),(c) Hz and major vertical mode at (( }}2(a),(c) Hz. Figure 29 shows the modal shape of the first horizontal major mode. The results for CRA_2 and CRA_3 are in a similar trend except that the major horizontal modes for CRA_2 and CRA_3 are (( }}2(a),(c) Hz and (( }}2(a),(c) Hz, respectively.

b. Upper riser assembly The modal results are shown in Figure 30 and Figure 31, indicating the major horizontal mode at ((

}}2(a),(c) Hz and major vertical mode at (( }}2(a),(c) Hz.

2. Stress results Stress results are compared to ASME BPVC requirements in Table 18 and Table 19 for components and welds, respectively.

3. Deflections Maximum relative displacements between adjacent CRD shaft grids are provided in Table

20. Since the maximum value (((

}}2(a),(c)) is insignificant, it is concluded that the CRD shafts do not experience excessive displacements. Conclusions The analysis described above demonstrates that the design of the RVI satisfies the structural requirements of the ASME BPVC for Service Level D loads. NuScale Nonproprietary

Table 12. Components Item Part Number Methodology Upper Riser Transition A023.300 1 Upper Riser Section A023.301 2 Upper CRD Shaft Support A023.305 2 Top CRD Shaft Support A023.312 2 Upper Riser Hanger Ring A023.306 1 Upper Riser Hanger Brace A023.307 1 Upper Alignment Hanger Threaded Structural Fastener A023.309 1 Upper Riser Bellows A023.310 2 Upper Core Plate (UCP) A023.200 1 Lower Riser Section A023.201 1 Lower Riser Transition A023.202 1 Lower Riser Spacer A023.203 1 In-core Instrument Guide Tube (ICIGT) Support A023.210 2 CRA Guide Tube Support Plate (GTSP) A023.230 1 CRA Guide Tube A023.231 2 CRD Shaft Alignment Cone A023.232 2 CRA Card A023.233 2 CRA Lower Flange A023.234 2 Fuel Pin Cap A023.250 1 Fuel Pin A023.251 1 A023.061 1 Core Barrel A023.009 1 Reflector Block A023.044-046 1 Upper Support Block A023.047-048 1 Reflector Block Alignment Pin A023.049 1 Lower Core Plate (LCP) A023.008 1 Socket Head Cap Screw A011.043 1 Control Rod Drive Shaft 01D4484H01, 01D4485H01, 01D4486H01 (Drive Shaft Sections) 2 NuScale Nonproprietary

Table 13. Welds Weld Number Description Methodology A023.300.001 Upper Riser Transition Seam 1 A023.301.001 Upper Riser Section Seam 1 A023.305A-H.001 - A023.305A-H.008 Upper CRD Shaft Support 2 A023.307A-H.001 Brace to Upper Riser Hanger Ring 1 A023.307A-H.002 Brace to Upper Riser Section 1 A023.310.001 Upper Riser to Bellows 1 A023.310.002 Bellows to Upper Riser Transition 1 A023.200.001 Lower Riser to UCP 1 A023.201.001 Lower Riser Section 1 A023.202.001 Lower Riser Transition 1 A023.203.001 Lower Riser Spacer 1 A023.203.001A Lower Riser Spacer to Lower Riser Section 1 A023.203.002 Lower Riser Transition to Lower Riser Spacer 1 A023.210.001A-H ICIGT Support to Lower Riser Transition 1 A023.230.001A-D CRA GTSP to Lower Riser Spacer 1 A023.231.001A-P CRA Lower Flange to CRA Guide Tube 2 A023.231.002A-P - A023.231.009A-P CRA Card to CRA Guide Tube 2 A023.231.010A-P - A023.231.013A-P CRDS Alignment Cone 2 A023.009.001 - A023.009.004 Upper Support Block 1 A023.008.001 Core Barrel to LCP 1 Table 14. Required load combinations Plant Event Service Level Load Combination Allowable Limit Rod Ejection Accident D PD + DW + B + EXT + REA Level C Main Steam and Feedwater Pipe Breaks D PD + DW + B + EXT + MSPB-FWPB Level D SSE + DBPB-MSPB-FWPB D PD + DW + B + EXT +/- SRSS (SSE + LOCA-MSPB-FWPB) Level D Note: SRSS is the square root sum of the squares Table 15. Element types in URA model Item Element Type Control Rod Drive Shaft PIPE288 URVI Section SHELL181 Control Rod mass MASS21 contact pairs TARGE170, CONTA174, CONTA175 other components SOLID45 NuScale Nonproprietary

Table 16. Allowable stress limits for Level D Stress Category Code Paragraph Criterion Component General primary membrane stress, Pm F-1331.1(a) lesser of 2.4Sm and 0.7Su Local primary membrane stress, Pl F-1331.1(b) 1.5Pm General or local primary membrane plus bending stress, Pm+Pb F-1331.1(c)(1) 1.5Pm Bearing stress NG-3227.1(a) 2Sy(1) Average primary pure shear stress F-1331.1(d), NG-3227.2(a) lesser of 0.42Su and 1.2Sm Compressive loads F-1334.3,F-1334.5 Multiple criteria Bolted Joint Tensile stress F-1335.1 (lesser of 0.7Su and Sy) or Su(2) Shear stress F-1335.2(a) lesser of 0.42Su and 0.6Sy Combined tensile and shear stress F-1335.3(a) f t 2 Ftb 2 + f v 2 Fvb 2 1 Notes:

1. This is for general bearing stress, which bounds the 2.1Su (F-1336 for pinned joints) and 3Sy (NG-3227.1(a) for bearing stress distance to free edge distance larger than distance over which the bearing load is applied). Therefore, the 2Sy limit is conservatively used in this document.

2. Su for material of ultimate tensile strength exceeding 100ksi at operating temperature.

NuScale Nonproprietary

Table 17. Weld geometry summary Component 1 Component 2 Weld Geometry and Size Weld Category and Type Quality Factor n(1) Upper Riser Hanger Brace (A023.307) Upper Riser Hanger Ring (A023.306) (( Category E, Type VI 0.55(2) Upper Riser Hanger Brace (A023.307) Upper Riser Section (A023.301) Category E, Type VI 0.35 Upper CRDS Support (A023.305) Upper Riser Section (A023.301) Category E, Type IV 0.4 Upper Riser Bellows (A023.310) Upper Riser Transition (A023.300) Category B, Type I 0.5 ICIGT Support (A023.210) Lower Riser Transition (A023.202) Category E, Type IV 0.4 Lower Riser Spacer (A023.203) Lower Riser Section (A023.201) Category B, Type II 0.5 Lower Riser Section (A023.201) Upper Core Plate (A023.200) Category C, Type III 0.5 CRA GTSP (A023.230) Lower Riser Spacer (A023.203) Category E, Type III 0.5 CRA Guide Tube (A023.231) CRA Alignment Cone (A023.232) Category E, Type VIII 0.3 CRA Card (A023.233) CRA Guide Tube (A023.231) Category C, Type III 0.5 CRA Lower Flange (A023.234) CRA Guide Tube (A023.231) Category C, Type III 0.5 Upper Support Block (A023.048) Core Barrel (A023.009) Category E, Type IV 0.4 Core Barrel (A023.009) Lower Core Plate (A023.008) Category C, Type III 0.5 Upper Riser Section (A023.301) Upper Riser Bellows (A023.310) Category B, Type I 0.5 Lower Riser Transition (A023.202) Lower Riser Spacer (A023.203) }}2(a),(c) Category C, Type III

0.5 Notes

1. Assuming using surface visual examination method except note (2).

2. Assuming using progressive UT examination method based on the geometry NuScale Nonproprietary

Table 18. ASME BPVC compliance - components Item (Part Number) Stress Type Stress Ratio Upper Riser Transition (A023.300) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c)

(( }}2(a),(c) Upper Riser Section (A023.301) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c) Upper CRD Shaft Support (A023.305) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c) Upper Riser Hanger Ring (A023.306) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c) Upper Riser Hanger Brace (A023.307) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c)

(( }}2(a),(c) Upper Alignment Hanger Threaded Structural Fastener (A023.309) Shear at stud cross section, cs (( }}2(a),(c) Tensile stress in stud, ns (( }}2(a),(c) Shear stress in stud threads, s (( }}2(a),(c) Shear stress in hanger ring threads, t (( }}2(a),(c) Combined cs and ns (( }}2(a),(c) Upper Riser Bellows (A023.310) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c) Upper Core Plate (tabs) (A023.200) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c)

(( }}2(a),(c) bearing (( }}2(a),(c) Upper Core Plate (A023.200) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c) Lower Riser Section (A023.201) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c)

(( }}2(a),(c) Compressive stress, bu_c (( }}2(a),(c) Combined axial compression and bending, NF-3322.1(e) (1), eq. 20, bu_cs_20 (( }}2(a),(c) Combined axial compression and bending, NF-3322.1(e) (1), eq. 21, bu_cs_21 (( }}2(a),(c) NuScale Nonproprietary

Item (Part Number) Stress Type Stress Ratio Combined axial compression and bending, NF-3322.1(e) (1), eq. 21, bu_cs_22 (( }}2(a),(c) Lower Riser Transition (A023.202) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c)

(( }}2(a),(c) Lower Riser Spacer (A023.203) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c)

(( }}2(a),(c) ICIGT Support (A023.210) N/A(1) N/A CRA Guide Tube Support Plate (A023.230) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c) CRA Guide Tube (A023.231) Pm (( }}2(a),(c) CRDS Alignment Cone (A023.232) CRA Card (A023.233) Pm + Pb (( }}2(a),(c) CRA Lower Flange (A023.234) bearing (( }}2(a),(c) CRA Guide Tube (A023.231) Compressive stress, bu_c (( }}2(a),(c) Combined axial compression and bending, NF-3322.1(e) (1), eq. 20, bu_cs_20 (( }}2(a),(c) Combined axial compression and bending, NF-3322.1(e) (1), eq. 21, bu_cs_21 (( }}2(a),(c) Combined axial compression and bending, NF-3322.1(e) (1), eq. 22, bu_cs_22 (( }}2(a),(c) Fuel Pin and Cap (A023.250, A023.251, A023.061) Pm + Pb (( }}2(a),(c)

(( }}2(a),(c) Core Barrel (A023.009) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c)

(( }}2(a),(c) Compressive stress, bu_c (( }}2(a),(c) Combined axial compression and bending, NF-3322.1(e) (1), eq. 20, bu_cs_20 (( }}2(a),(c) Combined axial compression and bending, NF-3322.1(e) (( }}2(a),(c) NuScale Nonproprietary

Item (Part Number) Stress Type Stress Ratio (1), eq. 21, bu_cs_21 Combined axial compression and bending, NF-3322.1(e) (1), eq. 22, bu_cs_22 (( }}2(a),(c) Reflector Block (A023.044, A023.045, A023.046) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c)

(( }}2(a),(c) bearing (( }}2(a),(c) Upper Support Block (A023.047) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c)

(( }}2(a),(c) Reflector Block Alignment Pin (A023.049)

(( }}2(a),(c) bearing (( }}2(a),(c) Lower Core Plate (A023.008) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c) Lower Core Plate (tabs) (A023.008) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c)

(( }}2(a),(c) bearing (( }}2(a),(c) Socket Head Cap Screw (A011.043) Tensire stress in screw, ns (( }}2(a),(c) Shear stress in screw threads, s (( }}2(a),(c) Shear stress in upper support block threads, n (( }}2(a),(c) Control Rod Drive Shaft (All Parts of Assembly) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c) Note:

1. This component is similar in location and configuration to the lowest upper CRD shaft support. Thus, the evaluation of the CRD shaft support is used to determine acceptability of the ICIGT support.

NuScale Nonproprietary

Table 19. ASME BPVC compliance - welds Item 1 (Part Number) Item 2 (Part Number) Stress Type Stress Ratio Upper Riser Hanger Brace (A023.307) Upper Riser Hanger Ring (A023.306) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c)

(( }}2(a),(c) Upper Riser Hanger Brace (A023.307) Upper Riser Section (A023.301) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c)

(( }}2(a),(c) Upper CRD Shaft Support (A023.305) Upper Riser Section (A023.301) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c)

(( }}2(a),(c) Upper Riser Bellows (A023.310) Upper Riser Transition (A023.300) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c)

(( }}2(a),(c) ICIGT Support (A023.210) Lower Riser Transition (A023.202) N/A(1) N/A Lower Riser Spacer (A023.203) Lower Riser Section (A023.201) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c)

(( }}2(a),(c) Lower Riser Section (A023.201) Upper Core Plate (A023.200) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c)

(( }}2(a),(c) CRA GTSP (A023.230) Lower Riser Spacer (A023.203) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c)

(( }}2(a),(c) CRA Guide Tube (A023.231) CRA Alignment Cone (A023.232)

(( }}2(a),(c) CRA Card (A023.233) CRA Guide Tube (A023.231)

(( }}2(a),(c) CRA Lower Flange (A023.234) CRA Guide Tube (A023.231)

(( }}2(a),(c) Upper Support Block (A023.048) Core Barrel (A023.009) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c)

(( }}2(a),(c) Core Barrel (A023.009) Lower Core Plate (A023.008) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c)

(( }}2(a),(c) Upper Riser Section (A023.301) Upper Riser Bellows (A023.310) N/A(2) N/A Lower Riser Transition (A023.202) Lower Riser Spacer (A023.203) Pm (( }}2(a),(c) Pm + Pb (( }}2(a),(c)

(( }}2(a),(c) Notes:

1. The weld evaluation is bounded by the evaluation for the upper CRD shaft-upper riser section weld.

2. The weld evaluation is bounded by the evaluation for the upper riser bellows-upper riser transition weld.

NuScale Nonproprietary

Table 20. Maximum CRD shaft grid relative displacements (inch) X (Hori.) Y (Vert.) Z (Hori.) Horizontal Final Grid 1~2 (( Grid 2~3 Grid 3~4 Grid 4~5 }}2(a),(c) (( }}2(a),(c) Figure 17. Upper core plate model and boundary conditions NuScale Nonproprietary

(( }}2(a),(c) Figure 18. Lower core plate boundary conditions NuScale Nonproprietary

(( }}2(a),(c) Figure 19. Upper riser hanger ring boundary conditions NuScale Nonproprietary

(( }}2(a),(c) Figure 20. CRA model NuScale Nonproprietary

(( }}2(a),(c) Figure 21. Location of pilot nodes NuScale Nonproprietary

(( }}2(a),(c) Figure 22. CRA bonded connections NuScale Nonproprietary

(( }}2(a),(c) Figure 23. Control rod mass locations for three cases (( }}2(a),(c) Figure 24. CRA GTSP model NuScale Nonproprietary

(( }}2(a),(c) Figure 25. Upper riser assembly model NuScale Nonproprietary

(( }}2(a),(c) Figure 26. Bellows profile and constraint location NuScale Nonproprietary

(( }}2(a),(c) Figure 27. Constraints at URA NuScale Nonproprietary

(( }}2(a),(c) Figure 28. Modal analysis results for CRA_1 NuScale Nonproprietary

(( }}2(a),(c) Figure 29. First major mode shape for CRA_1 NuScale Nonproprietary

(( }}2(a),(c) Figure 30. Modal analysis results for URA NuScale Nonproprietary

(( }}2(a),(c) Figure 31. First major lateral mode shape for URA Impact on DCA: There are no impacts to the DCA as a result of this response. NuScale Nonproprietary

RAIO-1218-63980 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvalis, Oregon 97330, Office: 541.360.0500, Fax: 541.207.3928 www.nuscalepower.com : Affidavit of Zackary W. Rad, AF-1218-63981

AF-1218-63981 NuScale Power, LLC AFFIDAVIT of Zackary W. Rad I, Zackary W. Rad, state as follows: I am the Director, Regulatory Affairs of NuScale Power, LLC (NuScale), and as such, I 1. 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. I am knowledgeable of the criteria and procedures used by NuScale in designating 2. 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: The information requested to be withheld reveals distinguishing aspects of a process a. (or component, structure, tool, method, etc.) whose use by NuScale competitors, without a license from NuScale, would constitute a competitive economic disadvantage to NuScale. The information requested to be withheld consists of supporting data, including test b. 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. Use by a competitor of the information requested to be withheld would reduce the c. competitor's expenditure of resources, or improve its competitive position, in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product. The information requested to be withheld reveals cost or price information, production d. capabilities, budget levels, or commercial strategies of NuScale. The information requested to be withheld consists of patentable ideas. e. Public disclosure of the information sought to be withheld is likely to cause substantial 3. harm to NuScale's competitive position and foreclose or reduce the availability of profit-making opportunities. The accompanying Request for Additional Information response reveals distinguishing aspects about the method by which NuScale develops its power module seismic analysis. NuScale has performed significant research and evaluation to develop a basis for this method 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, NuScale's 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 NuScale's intellectual property, and would deprive NuScale of the opportunity to exercise its competitive advantage to seek an adequate return on its investment.

AF-1218-63981 The information sought to be withheld is in the enclosed response to NRC Request for 4. Additional Information No. 202, eRAI 8911. 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. The basis for proposing that the information be withheld is that NuScale treats the 5. 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). Pursuant to the provisions set forth in 10 CFR § 2.390(b)(4), the following is provided for 6. consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld: The information sought to be withheld is owned and has been held in confidence by a. NuScale. The information is of a sort customarily held in confidence by NuScale and, to the best b. 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. The information is being transmitted to and received by the NRC in confidence. c. No public disclosure of the information has been made, and it is not available in public d. 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. Public disclosure of the information is likely to cause substantial harm to the e. 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 NuScale's 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 December 21, 2018. Zackary W. Rad}}