ML20254A355

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Shine Medical Technologies, LLC - Application for an Operating License Revision 1 of Shine Response to Request for Additional Information 7-4
ML20254A355
Person / Time
Site: SHINE Medical Technologies
Issue date: 09/10/2020
From: Jim Costedio
SHINE Medical Technologies
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
2020-SMT-0087
Download: ML20254A355 (16)
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Text

101 E. Milwaukee St., Suite 600 l Janesville, WI 53545 l P (608) 210-1060 l F (608) 210-2504 l www.shinemed.com September 10, 2020 2020-SMT-0087 10 CFR 50.30 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

References:

(1) SHINE Medical Technologies, LLC letter to the NRC, SHINE Medical Technologies, LLC Application for an Operating License, dated July 17, 2019 (ML19211C143)

(2) NRC letter to SHINE Medical Technologies, LLC, Issuance of Request for Additional Information Related to the SHINE Medical Technologies, LLC Operating License Application (EPID No. L-2019-NEW-0004), dated May 26, 2020 (ML20148M278)

(3) SHINE Medical Technologies, LLC letter to the NRC, SHINE Medical Technologies, LLC Operating License Application Response to Request for Additional Information and Supplement No. 3, dated August 28, 2020 SHINE Medical Technologies, LLC Application for an Operating License Revision 1 of SHINE Response to Request for Additional Information 7-4 Pursuant to 10 CFR Part 50.30, SHINE Medical Technologies, LLC (SHINE) submitted an application for an operating license for a medical isotope production facility to be located in Janesville, WI (Reference 1). The NRC staff determined that additional information was required to enable the staffs continued review of Chapter 7 of the Final Safety Analysis Report (FSAR)

(Reference 2). SHINE provided the response to the NRC staffs request for additional information (RAI) associated with Chapter 7 of the FSAR via Reference (3).

SHINE has determined that the SHINE Response to RAI 7-4, provided via Reference (3),

contains an administrative error in that a table referenced in the response was not provided to support the response.

provides Revision 1 of the SHINE Response to RAI 7 4. Revision 1 supersedes the previously provided SHINE Response to RAI 7-4, provided via Reference (3), in its entirety.

If you have any questions, please contact Mr. Jeff Bartelme, Director of Licensing, at 608/210-1735.

I declare under the penalty of perjury that the foregoing is true and correct.

Executed on September 10, 2020.

Document Control Desk Page 2 Very truly yours, James Costedio Vice President of Regulatory Affairs and Quality SHINE Medical Technologies, LLC Docket No. 50-608 Enclosure cc:

Project Manager, USNRC SHINE General Counsel Supervisor, Radioactive Materials Program, Wisconsin Division of Public Health

        

Page 1 of 14 ENCLOSURE 1 SHINE MEDICAL TECHNOLOGIES, LLC SHINE MEDICAL TECHNOLOGIES, LLC APPLICATION FOR AN OPERATING LICENSE REVISION 1 OF SHINE RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION 7-4 The NRC staff determined that additional information was required to enable the staffs continued review of Chapter 7 of the SHINE Medical Technologies, LLC (SHINE) Final Safety Analysis Report (FSAR) (Reference 1). SHINE provided the response to the NRC staffs request for additional information (RAI) associated with Chapter 7 of the FSAR via Reference (2).

SHINE has determined that the SHINE Response to RAI 7-4, provided via Reference (2),

contains an administrative error in that a table referenced in the response was not provided to support the response. Revision 1 of the SHINE Response to RAI 7-4 is provided below.

Chapter 7 - Instrumentation and Control Systems RAI 7-4 Chapter 7 of the SHINE FSAR describes the highly integrated protection system (HIPS) platform for the TRPS and engineered safety features actuation system (ESFAS). However, the FSAR appears to contain inconsistent descriptions of the use of the HIPS platform and/or implies how the HIPS platform will be used to implement the design of the TRPS and ESFAS.

(1) Clarify how the TRPS and ESFAS use the generically approved HIPS platform. If the application intends to credit the NRC-approved HIPS platform, then:

(a) Describe how the Application Specific Action Items identified for the HIPS platform are dispositioned, including those that are not applicable for the SHINE TRPS and ESFAS.

(b) Describe the differences between the system architecture approved for HIPS platform and the architecture proposed for the TRPS and ESFAS and explain it is acceptability for the SHINE design.

(2) Provide a description of the SHINE system design, as well as the suitability and adequacy of the HIPS platform for performing SHINE design functions, including conformance with the SHINE design criteria and bases. This RAI is similar to RAI 7-1, but in this case, SHINE should indicate the specific design or attributes in the HIPS platform that will meet each of its applicable design criterion.

SHINE Response (1) SHINE has revised Chapter 7 of the FSAR to describe SHINE crediting the prior NRC approval of the Highly Integrated Protection System (HIPS) platform, described in Topical Report TR-1015-18653, Design of the Highly Integrated Protection System Platform (Reference 3), for use in the SHINE facility. This clarification has been added to Subsections 7.1.2 and 7.1.3 of the FSAR.

Page 2 of 14 (a) The Application-Specific Action Items (ASAIs) identified in the Safety Evaluation for the HIPS platform (Reference 4) are dispositioned as described in Table 7-4-1. The table identifies the sections of the FSAR that address ASAIs that are applicable to SHINE.

(b) The architecture described in Section 3.0 of the HIPS topical report (Reference 3) is a representative architecture provided for reference to help describe the attributes of the HIPS platform. As stated in Section 3.1.6 of the Safety Evaluation for the HIPS platform (Reference 4), This example architecture is intended to illustrate the capability of the HIPS platform to implement a prospective system architecture and does not define a proposed usage. The approval of the HIPS platform is independent of architecture; therefore, the architecture of the SHINE control systems does not represent a difference from the approved HIPS platform.

(2) Section 7.4.5 of the FSAR describes the system design, suitability, and adequacy of the HIPS platform for performing SHINE design functions. Conformance with the SHINE design criteria and design bases for applicable HIPS platform design attributes is described in Section 7.4.5 of the FSAR.

Additionally, as described in the SHINE Response to RAI 7-1 and RAI 7-2 (Reference 2),

Subsections 7.4.2 and 7.5.2 of the FSAR have been revised to state how the target solution vessel reactivity protection system (TRPS) and engineered safety features actuation system (ESFAS) meet or implement the applicable SHINE design criteria and system-specific design criteria.

A revision to the FSAR, incorporating the changes to Chapter 7 described above, was provided via Reference 2.

Page 3 of 14 Table 7-4-1: Disposition of Application-Specific Action Items ASAI No.

SER Referenced Section(s)

ASAI Description ASAI Applicability to SHINE and Description of How the TRPS and ESFAS Design Addresses the ASAI Applicable Design Criteria (As Stated in Subsections 7.4.2 and 7.5.2 of the FSAR) 1 2.0 An applicant or licensee referencing this SE must establish full compliance with the design criteria and regulations identified in NuScale DSRS Chapter 7, Table 7.1, or the appropriate plant design criteria that are relevant to the specific application(s) of the HIPS platform as a safety-related I&C system in an NPP as defined in 10 CFR 50.55a(h).

Partially applicable. Compliance to the NuScale DSRS and 10 CFR 50.55a(h) is not applicable to SHINE. Chapter 7 of the FSAR describes the application of the HIPS platform to implement the TRPS and ESFAS design, consistent with the requirements of 10 CFR 50.34(b)(2) and the guidance of NUREG-1537.

Not applicable 2

2.0 3.0 An applicant or licensee referencing this SE must demonstrate that the HIPS platform used to implement the application-specific or plant-specific system is unchanged from the base platform addressed in this SE. Otherwise, the applicant or licensee must clearly and completely identify any modification or addition to the base HIPS platform as it is employed and provide evidence of compliance by the modified platform with all applicable regulations that are affected by the changes.

Applicable. Evidence that the HIPS platform used to implement the TRPS and ESFAS design is unchanged from the base platform addressed in the Safety Evaluation for the HIPS platform (Reference 4) is provided in Subsections 7.1 and 7.4.5 of the FSAR.

Not applicable 3

3.6 Although the staff determined that the HIPS platform supports satisfying various sections and clauses of IEEE Std. 603-1991, an applicant or licensee referencing this SE must identify the approach taken to satisfy each applicable clause of IEEE Std. 603-1991. Because this SE does not address a specific application, establish a definitive safety system or protective action, or identify and analyze the impact of credible events along with their direct and indirect consequences, an applicant or licensee should identify its plant-specific design basis for its safety system application and the applicability of each IEEE Std. 603-1991 clause to its application-specific HIPS platform-based safety system or component. Furthermore, the applicant or licensee must demonstrate that the plant-specific and application-specific use of the HIPS platform satisfies the applicable IEEE Std. 603-1991 clauses in accordance with the plant-specific design basis and safety system application.

Not applicable. Compliance to IEEE 603-1991, IEEE Standard Criteria for Safety Systems for Nuclear Power Generating Stations, is not applicable to SHINE. The TRPS and ESFAS design supports satisfying various sections and clauses of IEEE 603-1991 because the HIPS platform supports satisfying various sections and clauses of IEEE 603-1991; however, the SHINE basis for application of the HIPS platform to implement the TRPS and ESFAS design is consistent with the guidance of NUREG-1537.

Not applicable

Page 4 of 14 ASAI No.

SER Referenced Section(s)

ASAI Description ASAI Applicability to SHINE and Description of How the TRPS and ESFAS Design Addresses the ASAI Applicable Design Criteria (As Stated in Subsections 7.4.2 and 7.5.2 of the FSAR) 4 3.7 Although the staff determined that the HIPS platform supports satisfying various sections and clauses of IEEE Std. 7-4.3.2-2003, an applicant or licensee referencing this SE must identify the approach taken to satisfy each applicable clause of IEEE Std. 7-4.3.2-2003. The applicant or licensee should consider its plant-specific design basis. This SE does not address a specific application, establish a definitive safety system or protective action, or identify and analyze the impact of credible events along with their direct and indirect consequences. The applicant or licensee should identify its plant-specific design basis for its safety system application and the applicability of each IEEE Std. 7-4.3.2-2003 clause to its application-specific HIPS platform-based safety system or component. Furthermore, the applicant or licensee must demonstrate that the plant-specific and application-specific use of the HIPS platform satisfies the applicable IEEE Std. 7-4.3.2-2003 clauses in accordance with the plant-specific design basis and safety system application.

Partially applicable. Compliance to IEEE 7-4.3.2-2003, IEEE Standard Criteria for Digital Computers in Safety Systems of Nuclear Power Generating Stations, is not applicable to SHINE. The TRPS and ESFAS design supports satisfying various sections and clauses of IEEE 7-4.3.2-2003 because the HIPS platform supports satisfying various sections and clauses of IEEE 7-4.3.2-2003; however, the SHINE basis for application of the HIPS platform to implement the TRPS and ESFAS design is consistent with the guidance of NUREG-1537. The following Sections of the FSAR address various clauses of IEEE 7-4.3.2-2003:

  • 7.1.4 (Highly Integrated Protection System Design)
  • 7.4.5.2.1 (Independence)
  • 7.4.5.2.2 (Redundancy)
  • 7.4.5.2.3 (Predictability and Repeatability)
  • 7.4.5.5 (HIPS Performance Analysis)
  • 7.4.3.13 and 7.5.3.12 (Design Codes and Standards)
  • 7.4.2.2.11 and 7.5.2.2.11 (Equipment Qualification)
  • 7.6 (Control Console and Display Instruments)
  • 7.4.3.7 and 7.5.3.6 (Human Factors)
  • 7.4.4.1 and 7.5.4.1 (Monitored Variables and Response)
  • 7.4.4.2 and 7.5.4.2 (Operational Bypass, Permissives, and Interlocks)

Not applicable 5

3.8 Although the staff determined that the HIPS platform includes features to support satisfying various sections and clauses of DI&C-ISG-04, an applicant or licensee referencing this SE must evaluate the HIPS platform-based system for full conformance against this guidance. The applicant or licensee should consider its plant-specific design basis. This SE does not address a specific application, establish a definitive safety system or protective action, or identify and analyze the impact of credible events along with their direct and indirect consequences.

Not applicable. Compliance to DI&C-ISG-04, Interim Staff Guidance on Highly-Integrated Control Rooms -

Communications Issues (HICRc), is not applicable to SHINE.

The TRPS and ESFAS design supports satisfying various sections and clauses of DI&C-ISG-04 because the HIPS platform supports satisfying various sections and clauses of DI&C-ISG-04; however, the SHINE basis for application of the HIPS platform to implement the TRPS and ESFAS design is consistent with the guidance of NUREG-1537.

Not applicable 6

3.9 Although the staff determined that the HIPS platform includes features to support satisfying various sections of the SRM to SECY-93-087, an applicant or licensee referencing this SE must evaluate the HIPS platform-based system for full compliance against this requirement. The applicant or licensee should consider its plant-specific design basis. This SE does not address a specific application, establish a definitive safety system or protective action, or identify and analyze the impact of credible events along with their direct and indirect consequences.

Not applicable. Compliance to the SRM to SECY-93-087, Policy, Technical, and Licensing Issues Pertaining to Evolutionary and Advanced Light-Water Reactor (ALWR)

Designs, is not applicable to SHINE. The TRPS and ESFAS design supports satisfying various sections and clauses of the SRM to SECY-93-087 because the HIPS platform supports satisfying various sections and clauses of the SRM to SECY-93-087; however, the SHINE basis for application of the HIPS platform to implement the TRPS and ESFAS design is consistent with the guidance of NUREG-1537.

Not applicable

Page 5 of 14 ASAI No.

SER Referenced Section(s)

ASAI Description ASAI Applicability to SHINE and Description of How the TRPS and ESFAS Design Addresses the ASAI Applicable Design Criteria (As Stated in Subsections 7.4.2 and 7.5.2 of the FSAR) 7 3.1.4.3 An applicant or licensee referencing this SE must provide administrative controls (e.g., procedures, technical specifications) to prevent an operator from placing the same SFM across more than one division into maintenance bypass concurrent with a single failure of a different division.

Applicable. Subsections 7.4.4.3 and 7.5.4.4 of the FSAR describe how the HIPS-based TRPS and ESFAS equipment is used for maintenance bypasses. Limiting Conditions for Operation (LCOs) 3.2.3, 3.2.4, and 3.7.1 of the Technical Specifications provide the administrative controls related to placing a TRPS or ESFAS safety function module (SFM) into maintenance bypass.

TRPS Criterion 33 and 37 ESFAS Criterion 34 and 38 8

3.2 An applicant or licensee referencing this SE should verify having appropriate physical independence between nonsafety-related and safety-related equipment to satisfy the Class 1E to non-Class 1E separation requirements, consistent with the guidelines of RG 1.75, Revision 3.

Partially applicable. Compliance to Regulatory Guide 1.75, Power Reactor Criteria for Independence of Electrical Safety Systems, is not applicable to SHINE. Subsection 7.4.5.2.1 of the FSAR describes how the HIPS-based TRPS and ESFAS equipment implements physical, electrical, communications, and functional independence between nonsafety-related and safety-related equipment, consistent with the guidance of NUREG-1537.

TRPS Criterion 20 and 21 ESFAS Criterion 21 and 22 9

3.4 An applicant or licensee referencing this SE must provide the basis for the allocation of safety functions between the two diverse divisions to mitigate the effects of a postulated CCF concurrent with Chapter 15 events of its final safety analysis report.

Not applicable. Compliance to 10 CFR 50.55a(h) or the SRM to SECY-93-087 is not applicable to SHINE. Implementation of diversity within the TRPS and the ESFAS is discussed in Subsection 7.4.5.2.4 of the FSAR.

Not applicable 10 3.4 An applicant or licensee referencing this SE must verify that all diversity attributes of a HIPS platform (i.e., equipment diversity, design diversity, and functional diversity) conform to the diversity design details provided in the TR.

Not applicable. Compliance to 10 CFR 50.55a(h) or the SRM to SECY-93-087 is not applicable to SHINE. Implementation of diversity within the TRPS and the ESFAS is discussed in Subsection 7.4.5.2.4.

Not applicable 11 3.4 An applicant or licensee referencing this SE must verify that the diverse FPGA technologies have unique identification.

Not applicable. Compliance to 10 CFR 50.55a(h) or IEEE 603 is not applicable to SHINE. Subsections 7.4.3.10 and 7.5.3.9 of the FSAR describe how the HIPS-based TRPS and ESFAS equipment designs address unique identification.

Not applicable 12 3.6.2.1 3.6.2.5 3.6.2.6.3.1 3.6.2.6.3.3 3.8.1.18 An applicant or licensee referencing this SE should perform a system-level FMEA to demonstrate that the application-specific use of the HIPS platform identifies each potential failure mode and determines the effects of each failure. The FMEA should demonstrate that single failures, including those with the potential to cause a nonsafety system action (i.e., a control function) resulting in a condition requiring protective action (i.e., a protection function), cannot adversely affect the protection functions, as applicable.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for single failure. The TRPS and ESFAS designs include performance of a failure modes and effects analysis, which evaluates potential single failures and determines the effects of each failure, to inform the designs of TRPS and ESFAS.

TRPS Criterion 16 and 17 ESFAS Criterion 16, 17, and 18

Page 6 of 14 ASAI No.

SER Referenced Section(s)

ASAI Description ASAI Applicability to SHINE and Description of How the TRPS and ESFAS Design Addresses the ASAI Applicable Design Criteria (As Stated in Subsections 7.4.2 and 7.5.2 of the FSAR) 13 3.6.2.1 An applicant or licensee referencing this SE should demonstrate that the application-specific diagnostic, self-test, and manually initiated test and calibration features will not adversely affect channel independence, system integrity, or the systems ability to meet the single-failure criterion.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for single failure, redundancy, and independence. Subsections 7.4.5.2.1 and 7.4.5.2.2 of the FSAR describe how the principles of independence and redundancy are incorporated into the design of the TRPS and ESFAS. The TRPS and ESFAS designs include performance of a failure modes and effects analysis, which evaluates potential single failures and determines the effects of each failure, to inform the designs of TRPS and ESFAS.

TRPS Criterion 47 ESFAS Criterion 48 14 3.6.2.1 An applicant or licensee referencing this SE must review the actions to be taken when failures and errors are detected during tests and self-tests and ensure that these actions are consistent with system requirements. In addition, the applicant or licensee should describe how errors and failures are indicated and managed after they are detected. Finally, the applicant or licensee should confirm that this information is provided in the single-failure analysis for the plant-specific application.

Partially applicable. Compliance to 10 CFR 50.55a(h) or IEEE 603 is not applicable to SHINE. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for self-testing and diagnostics. Subsections 7.4.4.4, 7.5.4.5, and 7.4.5.5 of the FSAR describe the self-testing and diagnostic features of the TRPS and ESFAS design. The TRPS and ESFAS designs include performance of a failure modes and effects analysis, which evaluates potential single failures and determines the effects of each failure, to inform the designs of TRPS and ESFAS.

Not applicable 15 3.6.2.2 3.6.4.3 An applicant or licensee referencing this SE must demonstrate that the application-specific logic satisfies the completion of protective action requirements.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for completion of protective actions. Subsections 7.4.3.3 and 7.5.3.2 of the FSAR discuss how the TRPS and ESFAS designs ensure completion of protective actions.

TRPS Criterion 43, 44, and 45 ESFAS Criterion 44, 45, and 46 16 3.6.2.3 3.7.1.3 An applicant or licensee referencing this SE must confirm that the HIPS platform manufacturer is currently on the Nuclear Procurement Issues Committee list or confirm that the HIPS manufacturing quality processes conform to the applicants or licensees program that is compliant with 10 CFR Part 50, Appendix B (i.e., vendor is included in the applicants Approved Vendor List). The applicant or licensee will need to demonstrate that the HIPS software and associated development life cycle conform to applicable regulatory requirements.

Partially applicable. Compliance to 10 CFR 50 Part B is not applicable to SHINE. The SHINE Quality Assurance Program Description (QAPD) is based upon ANSI/ANS-15.8-1995 and complies with the requirements of 10 CFR 50.34 for a production or utilization facility. The HIPS manufacturing quality processes, including the HIPS software and associated development life cycle, conform to the SHINE QAPD requirements.

TRPS Criterion 4, 5, 6, 7, 8, 9, 10, 11, 12, and 13 ESFAS Criterion 4, 5, 6, 7, 8, 9, 10, 11, 12, and 13 17 3.6.2.4 3.6.2.6.2 3.7.1.4 3.8.1.17 An applicant or licensee referencing this SE must confirm that the HIPS platform equipment is qualified to the applicable regulatory requirements.

Applicable. The SHINE QAPD is based upon ANSI/ANS 15.8-1995 and complies with the requirements of 10 CFR 50.34 for a production or utilization facility. Subsections 7.4.3.13 and 7.5.3.12 of the FSAR identify the required codes and standards to be used in qualifying the TRPS and ESFAS equipment.

TRPS Criterion 54 and 55 ESFAS Criterion 55 and 56

Page 7 of 14 ASAI No.

SER Referenced Section(s)

ASAI Description ASAI Applicability to SHINE and Description of How the TRPS and ESFAS Design Addresses the ASAI Applicable Design Criteria (As Stated in Subsections 7.4.2 and 7.5.2 of the FSAR) 18 3.6.2.5 3.7.1.5.1 3.8.1.20 An applicant or licensee referencing this SE must identify the safe states for protective functions and the conditions that require the system to enter a fail-safe state. The applicant or licensee must also demonstrate system qualification for installation and operation in mild environment locations.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for safe states. The safe states for the TRPS and ESFAS are provided in Subsection 7.4.3.8 and Table 7.5-2 of the FSAR and the conditions that require the TRPS and ESFAS to enter a fail-safe state are provided in Subsections 7.4.3.1 and 7.5.3.1 of the FSAR. FSAR Subsections 7.4.3.13 and 7.5.3.12 identify the required codes and standards to be used in qualifying the TRPS and ESFAS equipment.

TRPS Criterion 28 and 46 ESFAS Criterion 29 and 47 19 3.6.2.5 3.7.1.5.1 3.8.1.19 3.8.1.20 An applicant or licensee referencing this SE must confirm that system real-time performance is adequate to ensure completion of protective actions within critical time frames required by the plant safety analyses.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for completion of protective actions within critical time frames. Assumed maximum response time and response time analysis for the TRPS and ESFAS is discussed in Subsection 7.4.5.2.3 of the FSAR.

SHINE Design Criterion 13 TRPS Criterion 14 and 24 ESFAS Criterion 14 and 25 20 3.6.2.6.1 3.8.1.2 3.8.1.16 An applicant or licensee referencing this SE must demonstrate that the full system design, any use of a shared component, the equipments installation, and the power distribution architecture provide the required independence.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for independence.

Subsection 7.4.5.2.1 of the FSAR describes how the HIPS-based TRPS and ESFAS equipment implements physical, electrical, communications, and functional independence.

TRPS Criterion 18, 20, 21, 22, and 23 ESFAS Criterion 19, 21,22, 23, and 24 21 3.6.2.6.1 3.8.1.2 3.8.1.16 An applicant or licensee referencing this SE must provide redundant power sources to separately supply the redundant power conversion features within the HIPS platform.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for redundancy.

Subsection 7.4.5.2.2 of the FSAR describes how the HIPS-based TRPS and ESFAS equipment implements redundancy.

TRPS Criterion 17 ESFAS Criterion 17 22 3.2.2 3.6.2.6.3.1 3.8.1.1 3.8.1.2 3.8.1.3 3.8.1.8 3.8.1.16 An applicant or licensee referencing this SE must verify that the safety network provides electrical, physical, and communications independence and security requirements for communication from safety to nonsafety-related systems.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for independence.

Subsection 7.4.5.2.1 of the FSAR describes how the HIPS-based TRPS and ESFAS equipment implements physical, electrical, communications, and functional independence.

TRPS Criterion 20, 21 and 22 ESFAS Criterion 21, 22 and 23 23 3.6.2.6.3.2 3.6.2.6.4 3.8.1.1 3.8.1.2 3.8.1.16 An applicant or licensee referencing this SE must perform isolation testing on the HIPS platform equipment to demonstrate the capability to satisfy the Class 1E to non-Class 1E isolation requirements, consistent with the guidelines of RG 1.75, Revision 3.

Partially applicable. Compliance to 10 CFR 50.55a(h) or IEEE 603 is not applicable to SHINE. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for independence. Subsection 7.4.5.2.1 of the FSAR describes how the HIPS-based TRPS and ESFAS equipment implements physical, electrical, communications, and functional independence.

TRPS Criterion 19, 20, 21, and 22 ESFAS Criterion 20, 21, 22, and 23 24 3.6.2.7 3.6.3.5 An applicant or licensee referencing this SE must describe how the HIPS platform equipment is used for testing and calibration of safety-related features.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for testing and calibration.

Subsections 7.4.4.4, 7.5.4.5, and 7.4.5.5 of the FSAR describe the self-testing and calibration features of the TRPS and ESFAS design.

TRPS Criterion 47 and 48 ESFAS Criterion 48 and 49

Page 8 of 14 ASAI No.

SER Referenced Section(s)

ASAI Description ASAI Applicability to SHINE and Description of How the TRPS and ESFAS Design Addresses the ASAI Applicable Design Criteria (As Stated in Subsections 7.4.2 and 7.5.2 of the FSAR) 25 3.6.2.7 3.6.3.5 An applicant or licensee referencing this SE must provide additional diagnostics or testing functions (i.e., self-tests or periodic surveillance tests) to address any system-level failures that are identified as detectable only through periodic surveillance.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for test and calibration.

Subsections 7.4.4.4, 7.5.4.5, and 7.4.5.5 of the FSAR describe testing and calibration for the TRPS and the ESFAS.

LCOs 3.2.1 and 3.2.2 of the Technical Specifications identify the periodic surveillance requirements for TRPS and ESFAS equipment.

TRPS Criterion 48 and 49 ESFAS Criterion 49 and 50 26 3.6.2.7 3.6.3.5 An applicant or licensee referencing this SE must describe how the HIPS platform equipment is used for any automatic sensor cross-check as a credited surveillance test function and the provisions to confirm the continued execution of the automatic tests during plant operations.

Partially applicable. Compliance to 10 CFR 50.55a(h) or IEEE 603 is not applicable to SHINE. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for system tests and surveillances. Automatic testing methods and use of TRPS and the ESFAS equipment for performing cross-checks is discussed in Subsections 7.4.4.4, 7.5.4.5, and 7.4.5.5 of the FSAR. Required channel checks are discussed in the Technical Specifications.

TRPS Criterion 47 ESFAS Criterion 48 27 3.6.2.8.1 An applicant or licensee referencing this SE must describe any manual controls and associated displays used to support manually controlled safety actions necessary to accomplish a safety function for which no automatic control is provided.

Not applicable. The SHINE design does not include manually controlled safety actions for which no automatic control is provided.

Not applicable 28 3.6.2.8.2 An applicant or licensee referencing this SE must describe how the HIPS platform safety system status information is used in displays to provide unambiguous, accurate, complete, and timely status of safety system protective actions.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for indication. A description of how safety system status is used in displays is provided in Section 7.6 of the FSAR.

SHINE Design Criterion 6 29 3.6.2.8.3 An applicant or licensee referencing this SE must describe how the HIPS platform bypass status information is used to automatically actuate the bypass indication for bypassed or inoperable conditions, when required, and provide the capability to manually activate the bypass indication from within the control room.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for indication of bypasses. A description of how safety system status is provided to the operators is provided in Subsections 7.4.4.2 and 7.5.4.2 of the FSAR. Subsections 7.4.4.3 and 7.5.4.4 of the FSAR provide a description of manual switches for placing HIPS modules in bypass.

TRPS Criterion 42 ESFAS Criterion 43 30 3.6.2.8.4 An applicant or licensee referencing this SE must describe how the information displays are accessible to the operator and are visible from the location of any controls used to effect a manually controlled protective action provided by the front panel controls of a HIPS-based system.

Partially applicable. Compliance to 10 CFR 50.55a(h) or IEEE 603 is not applicable to SHINE. TRPS and ESFAS equipment is not used to display information for the operator or to affect a manually-controlled protective action provided by the front panel controls. A description of how safety system status is used in displays is provided in Section 7.6 of the FSAR.

SHINE Design Criterion 6 31 3.6.2.9 An applicant or licensee referencing this SE must provide additional control of access features to address the system-level aspects for a safety system using the HIPS platform.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for access control.

Subsection 7.4.5.3 of the FSAR describes how the HIPS-based TRPS and ESFAS equipment design addresses the control of access.

TRPS Criterion 1, 2, and 3 ESFAS Criterion 1, 2, and 3

Page 9 of 14 ASAI No.

SER Referenced Section(s)

ASAI Description ASAI Applicability to SHINE and Description of How the TRPS and ESFAS Design Addresses the ASAI Applicable Design Criteria (As Stated in Subsections 7.4.2 and 7.5.2 of the FSAR) 32 3.6.2.10 3.8.1.13 An applicant or licensee referencing this SE must provide additional diagnostics or testing functions (self-tests or periodic surveillance tests) to address any system-level failures that are identified as detectable only through periodic surveillance. The applicant or licensee must also ensure that failures detected by these additional diagnostics or testing functions are consistent with the assumed failure detection methods of the application-specific single-failure analysis.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for test and calibration.

Subsections 7.4.4.4, 7.5.4.5, and 7.4.5.5 of the FSAR describe testing and calibration for the TRPS and the ESFAS.

LCOs 3.2.1 and 3.2.2 of the Technical Specifications identify the required surveillance tests for the TRPS and ESFAS actuation priority logic. A TRPS and ESFAS failure modes and effects analysis identified no nondetectable system failures.

TRPS Criterion 48 and 49 ESFAS Criterion 49 and 50 33 3.6.2.11 An applicant or licensee referencing this SE must establish the identification and coding requirements for cabinets and cabling for a safety system.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for identification. Subsections 7.4.3.10 and 7.5.3.9 of the FSAR describe how TRPS and ESFAS equipment design addresses identification.

TRPS Criterion 50 ESFAS Criterion 51 34 3.6.2.12 An applicant or licensee referencing this SE must demonstrate that the application-specific system design implemented with the HIPS platform meets the applicable regulatory requirements for auxiliary features.

Not applicable. Compliance to 10 CFR 50.55a(h) or IEEE 603 is not applicable to SHINE. The ESFAS and TRPS designs comply with the requirements of 10 CFR 50.34(b)(2), consistent with the guidance of NUREG 1537.

Not applicable 35 3.6.2.13 An applicant or licensee referencing this SE must demonstrate that the application-specific system design implemented with the HIPS platform meets the applicable regulatory requirements for shared systems.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for shared systems.

Subsection 7.1.2 and Figure 7.1-1 of the FSAR describe the use of a separate TRPS subsystem for each IU Cell.

SHINE Design Criterion 5 36 3.6.2.14 An applicant or licensee referencing this SE must confirm that the HIPS platform equipment meets any specified human factors requirements.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for human factors.

Subsections 7.4.3.7 and 7.5.3.6 of the FSAR describe how human factors are incorporated into the design of the TRPS and ESFAS.

TRPS Criterion 51 ESFAS Criterion 52 37 3.6.2.15 3.7.1.15 An applicant or licensee referencing this SE must confirm that the HIPS platform equipment meets any specified quantitative or qualitative reliability goals.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for reliability. Reliability characteristics of the TRPS and ESFAS designs are described in Subsection 7.4.5.2.3 of the FSAR.

TRPS Criterion 23 and 24 ESFAS Criterion 24 and 25 38 3.6.3.1 3.6.4.1 An applicant or licensee referencing this SE must describe how the HIPS platform equipment is used to provide automatic safety system sense and command features for required safety functions.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for automatic sense and command features. Subsections 7.4.3.1 and 7.5.3.1 of the FSAR describe the automatic sense and command features of the TRPS and ESFAS.

SHINE Design Criterion 14 39 3.6.3.2 3.6.4.2 An applicant or licensee referencing this SE must describe how the HIPS platform equipment is used to provide manual safety system sense and command features for required safety functions.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for manual sense and command features. Subsections 7.4.3.7 and 7.5.3.6 of the FSAR describe the manual sense and command features of the TRPS and ESFAS.

TRPS Criterion 15 and 52 ESFAS Criterion 15 and 53 40 3.6.3.3 An applicant or licensee referencing this SE must describe how the HIPS platform equipment is used for sense and command features to provide protection against the resulting condition of a nonsafety system action that has been caused by a single credible event, including its direct and indirect consequences.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for sense and command features. Subsections 7.4.3.12 and 7.5.3.11 of the FSAR describe the sense and command features of the TRPS and ESFAS.

TRPS Criterion 27 ESFAS Criterion 28

Page 10 of 14 ASAI No.

SER Referenced Section(s)

ASAI Description ASAI Applicability to SHINE and Description of How the TRPS and ESFAS Design Addresses the ASAI Applicable Design Criteria (As Stated in Subsections 7.4.2 and 7.5.2 of the FSAR) 41 3.6.3.4 An applicant or licensee referencing this SE must describe how the HIPS platform equipment is used to acquire and condition field sensor measurements of the required variables.

Applicable. The design basis for acquiring and conditioning inputs in the TRPS and ESFAS is provided in Subsection 7.4.5 of the FSAR.

SHINE Design Criterion 13 42 3.6.3.6 3.6.4.4 An applicant or licensee referencing this SE must describe how the HIPS platform equipment is used for operating bypasses.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for operating bypasses.

Subsections 7.4.4.2 and 7.5.4.2 of the FSAR describe how the HIPS-based TRPS and ESFAS equipment is used for operating bypasses.

TRPS Criterion 33, 34, 35, 36, 37, 38, 39, 40, and 42 ESFAS Criterion 34, 35, 36, 37, 38, 39, 40, 41, and 43 43 3.6.3.7 An applicant or licensee referencing this SE must describe how the HIPS platform equipment is used for maintenance bypasses and provide the technical specification requirements.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for maintenance bypasses.

Subsections 7.4.4.3 and 7.5.4.4 of the FSAR describe how the HIPS-based TRPS and ESFAS equipment is used for maintenance bypasses. LCOs 3.2.3, 3.2.4 and 3.7.1 of the Technical Specifications provide the administrative controls related to placing a TRPS or ESFAS SFM into maintenance bypass.

TRPS Criterion 41 ESFAS Criterion 42 44 3.6.3.8 An applicant or licensee referencing this SE must describe the setpoints, setpoint methodologies, or HIPS platform module accuracies used for a safety system implemented with the HIPS platform equipment.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for setpoints. Subsection 7.2.1 of the FSAR discusses the setpoint methodology. Tables 7.4-1 and 7.5-1 of the FSAR provide the accuracies required for the TRPS and ESFAS monitored variables.

TRPS Criterion 29, 30 and 32 ESFAS Criterion 30, 31 and 33 45 3.6.4.5 An applicant or licensee referencing this SE must describe how the HIPS platform equipment is used for maintenance bypasses.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for maintenance bypasses.

Subsections 7.4.4.3 and 7.5.4.4 of the FSAR describe how the HIPS-based TRPS and ESFAS equipment is used for maintenance bypasses.

TRPS Criterion 37 and 41 ESFAS Criterion 38 and 42 46 3.6.5 An applicant or licensee referencing this SE must describe power sources to the HIPS platform equipment and how they meet applicable regulatory requirements.

Applicable. The ESFAS and TRPS designs conform to the design criteria of NUREG-1537 for safety system power sources. The description of the TRPS and ESFAS power source is provided in Subsection 8a2.2 of the FSAR.

SHINE Design Criterion 27 47 3.7.1.5.2 An applicant or licensee referencing this SE must confirm that the manufacturer followed the same design, development, and iV&V processes for test and calibration functions as for all other HIPS platform functions.

Applicable. The required quality and standards of TRPS and ESFAS software development processes is described in Subsection 7.4.5.4 of the FSAR.

TRPS Criterion 4, 5, 6, 7, 8, 9, 10, 11, and 12 ESFAS Criterion 4, 5, 6, 7, 8, 9, 10, 11, and 12 48 3.7.1.5.2 An applicant or licensee referencing this SE that relies on a separate computer for the sole verification of test and calibration data should ensure adequate iV&V, configuration management, and quality assurance for the test and calibration functions of the separate computer.

Not applicable. A separate computer is not relied upon for the sole verification of test and calibration data for the TRPS and ESFAS.

Not applicable 49 3.7.1.5.3 An applicant or licensee referencing this SE must confirm that the manufacturer followed the same design, development, and iV&V processes for self-diagnostics functions as for all other HIPS platform functions.

Applicable. The required quality and standards of TRPS and ESFAS software development processes is described in Subsection 7.4.5.4 of the FSAR.

TRPS Criterion 4, 5, 6, 7, 8, 9, 10, 11, and 12 ESFAS Criterion 4, 5, 6, 7, 8, 9, 10, 11, and 12

Page 11 of 14 ASAI No.

SER Referenced Section(s)

ASAI Description ASAI Applicability to SHINE and Description of How the TRPS and ESFAS Design Addresses the ASAI Applicable Design Criteria (As Stated in Subsections 7.4.2 and 7.5.2 of the FSAR) 50 3.7.1.5.3 An applicant or licensee referencing this SE must verify that the manufacturer included the self-diagnostic functions within its type testing of the HIPS platform standardized circuit boards during EQ.

Applicable. The required quality and standards of TRPS and ESFAS software development processes is described in Subsection 7.4.5.4 of the FSAR. Subsections 7.4.2.2.11 and 7.5.2.2.11 of the FSAR identify the equipment qualifications for applicable operating environments.

TRPS Criterion 4, 5, 6, 7, 8, 9, 10, 11, 12, and 47 ESFAS Criterion 4, 5, 6, 7, 8, 9, 10, 11, 12, and 48 51 3.7.1.5.3 An applicant or licensee referencing this SE must demonstrate that the combination of HIPS platform self-tests and system surveillance testing provide the necessary test coverage to ensure that there are no undetectable failures that could adversely affect a required safety function.

Applicable. Testing and calibration for the TRPS and the ESFAS is described in Subsections 7.4.4.4, 7.5.4.5, and 7.4.5.5 of the FSAR. LCOs 3.2.1 and 3.2.2 of the Technical Specifications identify the required surveillance testing for the TRPS and ESFAS.

TRPS Criterion 47 ESFAS Criterion 48 52 3.7.1.6 An applicant or licensee referencing this SE must demonstrate that the full system design, any use of a shared component, the equipments installation, and the communication bus architecture provide the required independence.

Applicable. Subsection 7.4.5.2.1 of the FSAR describes how the HIPS-based TRPS and ESFAS equipment implements physical, electrical, communications, and functional independence.

TRPS Criterion 18, 19, 20, 21, 22, 23, 24, 25, and 26 ESFAS Criterion 19, 20, 21, 22, 23, 24, 25, 26, and 27 53 3.7.1.6 An applicant or licensee referencing this SE must verify that the safety network provides communications independence and security requirements for communication from safety-to nonsafety-related systems.

Applicable. Subsection 7.4.5.2.1 of the FSAR describes how the HIPS-based TRPS and ESFAS equipment implements physical, electrical, communications, and functional independence.

TRPS Criterion 20 and 22 ESFAS Criterion 21 and 23 54 3.7.1.11 An applicant or licensee referencing this SE must establish the identification and coding requirements for cabinets and components for a safety system and the methods to verify that the correct firmware or software is installed in the correct hardware component.

Applicable. Subsections 7.4.5.4.6.3, 7.4.3.10, and 7.5.3.9 of the FSAR describe how the HIPS-based TRPS and ESFAS equipment design addresses identification.

TRPS Criterion 50 ESFAS Criterion 51 55 3.8.1.1 An applicant or licensee referencing this SE must demonstrate that a full system design does not, with the exception of division voting logic, depend on any information or resource originating or residing outside its own safety division to accomplish its safety function.

Applicable. Subsection 7.4.5.2.1 of the FSAR describes how the HIPS equipment implements divisional voting logic. Other than divisional voting logic, the TRPS and ESFAS do not depend on any information or resource originating or residing outside of each safety division to accomplish their safety functions.

TRPS Criterion 18, 20, and 21 ESFAS Criterion 19, 21, and 22 56 3.8.1.5 An applicant or licensee referencing this SE must confirm that system real-time performance is adequate, assuming the longest possible completion time to ensure the completion of protective actions within the critical time frames required by the plant safety analyses.

Applicable. A response time analysis for the TRPS and ESFAS is discussed in Subsection 7.4.5.2.3 of the FSAR.

TRPS Criterion 23 and 24 ESFAS Criterion 24 and 25 57 3.8.1.12 An applicant or licensee referencing this SE must configure the slave modules (e.g., SFMs and EIMs) to alarm and assume a fail-safe state.

Applicable. The TRPS and ESFAS EIMs are configured to provide fault indication and assume the deenergized state as identified in Subsection 7.4.3.8 of the FSAR for TRPS and Table 7.5-2 of the FSAR for ESFAS. The SFMs will also be configured to provide fault indications, and the specific fail-safe state for each TRPS and ESFAS SFM will be configured during the detailed programmable logic requirements and design phases.

TRPS Criterion 48 ESFAS Criterion 49

Page 12 of 14 ASAI No.

SER Referenced Section(s)

ASAI Description ASAI Applicability to SHINE and Description of How the TRPS and ESFAS Design Addresses the ASAI Applicable Design Criteria (As Stated in Subsections 7.4.2 and 7.5.2 of the FSAR) 58 3.8.1.18 An applicant or licensee referencing this SE should verify having appropriate physical, logical, and programmatic controls during the system development phases to ensure that unwanted, unneeded, and undocumented functionality is not introduced into digital safety systems.

Applicable. Subsections 7.4.5.3.1 and 7.4.5.4 of the FSAR describe the secure development environment requirements for TRPS and ESFAS system development.

TRPS Criterion 2, 5, and 6 ESFAS Criterion 2, 5, and 6 59 3.8.1.19 3.8.1.20 An applicant or licensee referencing this SE must describe how the HIPS platform equipment is used to provide a deterministic communication structure for required safety functions.

Applicable. TRPS and ESFAS integrity characteristics which support a deterministic communication structure are discussed in Subsection 7.4.5.2.3 of the FSAR.

TRPS Criterion 24 ESFAS Criterion 25 60 3.8.3.1.2 An applicant or licensee referencing this SE must demonstrate that the full system design supports cross-divisional and nonsafety communication with the appropriate independence and isolation.

Applicable. Communications independence within the TRPS and the ESFAS is discussed in Subsection 7.4.5.2.1 of the FSAR.

TRPS Criterion 21 and 22 ESFAS Criterion 22 and 23 61 3.8.3.1.3 An applicant or licensee referencing this SE must demonstrate that the application-specific use of an enable nonsafety switch and its configuration details will not adversely affect the channel independence nor the operation of safety-related equipment when the safety-related equipment is performing its safety function. In addition, the applicant or licensee must demonstrate that the application-specific use of an enable nonsafety switch should not be able to bring a safety function out of bypass condition unless the affected division has itself determined that such action would be acceptable.

Applicable. The use of an enable nonsafety switch and associated priority logic within the TRPS and ESFAS is described in Subsections 7.4.3.3, 7.4.3.4, 7.5.3.2, and 7.5.3.3 of the FSAR. Specific logic diagrams for how the enable nonsafety switch is implemented in TRPS and ESFAS logic is provided in Figures 7.4-1 and 7.5-1 of the FSAR. Use of the enable nonsafety switch is also discussed in Section 7.6 of the FSAR.

Not applicable 62 3.9.1 3.9.2 An applicant or licensee referencing this SE must demonstrate that the HIPS platform equipment is used to provide FPGA diversity between redundant portions of the systems to eliminate HIPS platform digital CCF vulnerabilities.

Partially applicable. Compliance to 10 CFR 50.55a(h) is not applicable to SHINE. Implementation of diversity within the TRPS and the ESFAS is discussed in Subsections 7.4.5.2.4 and 7.4.5.2.5 of the FSAR. The diversity of equipment between the TRPS/ESFAS and the PICS is also relied upon to provide defense-in-depth and diversity against digital common cause failures (CCF) in the TRPS and ESFAS.

TRPS Criterion 16 ESFAS Criterion 16 63 3.9.2 3.9.3 An applicant or licensee referencing this SE must address any other digital CCF vulnerabilities in the application-specific D3 analysis.

Applicable. Implementation of diversity within the TRPS and the ESFAS is discussed in Subsections 7.4.5.2.4 and 7.4.5.2.5 of the FSAR. The diversity of equipment between the TRPS/ESFAS and the PICS is also relied upon to provide defense-in-depth and diversity against digital CCF in the TRPS and ESFAS.

TRPS Criterion 16 ESFAS Criterion 16 64 3.9.3 An applicant or licensee referencing this SE must demonstrate that the HIPS platform equipment is used to provide FPGA diversity between redundant portions of the system architecture (e.g., in each of two redundancies in a four-fold redundant system or in one redundancy in a two-fold redundant system) to ensure HIPS platform safety performance in the presence of a digital CCF.

Partially applicable. Compliance to 10 CFR 50.55a(h) is not applicable to SHINE. Implementation of diversity within the TRPS and the ESFAS is discussed in Subsections 7.4.5.2.4 and 7.4.5.2.5 of the FSAR. The diversity of equipment between the TRPS/ESFAS and the PICS is also relied upon to provide defense-in-depth and diversity against digital CCF in the TRPS and ESFAS.

TRPS Criterion 16 ESFAS Criterion 16

Page 13 of 14 ASAI No.

SER Referenced Section(s)

ASAI Description ASAI Applicability to SHINE and Description of How the TRPS and ESFAS Design Addresses the ASAI Applicable Design Criteria (As Stated in Subsections 7.4.2 and 7.5.2 of the FSAR) 65 3.9.4 An applicant or licensee referencing this SE must demonstrate that the HIPS platform equipment is used to provide diversity for indication and component control signals to ensure HIPS platform monitoring and control performance in the presence of a digital CCF.

Partially applicable. Compliance to 10 CFR 50.55a(h) is not applicable to SHINE. Implementation of diversity within the TRPS and the ESFAS is discussed in Subsections 7.4.5.2.4 and 7.4.5.2.5 of the FSAR. The diversity of equipment between the TRPS/ESFAS and the PICS is also relied upon to provide defense-in-depth and diversity against digital CCF in the TRPS and ESFAS.

TRPS Criterion 16 ESFAS Criterion 16

Page 14 of 14 References (1) NRC letter to SHINE Medical Technologies, LLC, Issuance of Request for Additional Information Related to the SHINE Medical Technologies, LLC Operating License Application (EPID No. L-2019-NEW-0004), dated May 26, 2020 (ML20148M278)

(2) SHINE Medical Technologies, LLC letter to the NRC, SHINE Medical Technologies, LLC Operating License Application Response to Request for Additional Information and Supplement No. 3, dated August 28, 2020 (3) NuScale Power, LLC letter to NRC, NuScale Power, LLC Submittal of the Approved Version of NuScale Topical Report TR-1015-18653, Design of the Highly Integrated Protection System Platform, Revision 2 (CAC No. RQ6005), dated September 13, 2017 (ML17256A892)

(4) NRC letter to NuScale Power, LLC, Final Safety Evaluation for NuScale Power, LLC Licensing Topical Report: 1015-18653, Design of the Highly Integrated Protection System Platform, Revision 2, CAC No. RQ6005, dated June 6, 2017 (ML17116A097)

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