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MONTHYEARML18333A0222018-11-28028 November 2018 Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors Project stage: Request ML18337A0382018-11-29029 November 2018 Supplement to Application to Adopt 10 CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors Project stage: Supplement ML19007A0092019-01-0707 January 2019 Acceptance of Requested Licensing Action Risk-Informed Categorization and Treatment of Structure, Systems, and Components Project stage: Acceptance Review ML19065A0442019-03-20020 March 2019 Audit Plan in Support of Review of License Amendment Request to Allow Use of Risk-Informed Categorization and Treatment of Structures, Systems, and Components Project stage: Other ML19141A1942019-05-30030 May 2019 Regulatory Audit Summary Regarding Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors Project stage: Other ML19155A1272019-06-0404 June 2019 Request for Additional Information Regarding Request to Adopt 10 CFR 50.69 Risk Informed Categorization and Treatment of Systems, Structures, and Components Project stage: RAI ML19155A1612019-06-11011 June 2019 Changes to Draft Request for Additional Information Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Systems, Structures and Components Project stage: Draft RAI ML19217A1432019-08-0505 August 2019 Revised Response to Request for Additional Information Regarding the Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors Project stage: Response to RAI ML19217A3372019-08-0606 August 2019 Response to RAI 6 Regarding the Application to Adopt 10 CFR 50.69 Project stage: RAI ML19266A4842019-10-0101 October 2019 Summary of Pre-Licensing Meeting with Dominion Energy Regarding a License Amendment Request to Adopt a Risk-Informed 10 CFR 50.69 Categorization Program Project stage: Meeting ML19282B7182019-10-0909 October 2019 Revised Response to Request for Additional Information Regarding the Application to Adopt 10 CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors Project stage: Response to RAI ML19303A0052019-10-30030 October 2019 Revised Response to Application to Adopt 10 CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors Project stage: Request ML19298C9722019-10-31031 October 2019 50.69 Apla SE Input L-2018-LLA-0482 Project stage: Other ML19343A0192019-12-0606 December 2019 Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors Project stage: Request NMP2L2716, Application to Adopt 10 CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors2019-12-26026 December 2019 Application to Adopt 10 CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors Project stage: Request ML20034E6612020-01-29029 January 2020 Acceptance of Requested Licensing Action Risk-Informed Categorization and Treatment of Structure, Systems, and Components Project stage: Acceptance Review ML20037A0652020-02-0606 February 2020 Audit Plan Regarding License Amendment Request Regarding Risk Informed Categorization and Treatment of Structures, Systems and Components (L-2019-LLA-0290) Project stage: Other ML19330D9092020-02-28028 February 2020 Issuance of Amendment Nos. 332 and 310 Risk-Informed Categorization and Treatment of Systems, Structures, and Components Project stage: Approval ML20058A0102020-03-0505 March 2020 Audit Proposed License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors Project stage: Other ML20239A8002020-03-31031 March 2020 NRR E-mail Capture - Surry - Enforcement Guidance Memorandum Closure - Enforcement Discretion for Tornado Missile Protection Non-Compliance Project stage: Request ML20094K4222020-04-20020 April 2020 Audit Plan Supplement in Support of Review of License Amendment Request Regarding Risk-Informed Categorization and Treatment of Structures, Systems, and Components Project stage: Other NMP2L2729, Supplemental Information No.1 for Nine Mile Point Nuclear Station, Unit 2, to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors2020-04-30030 April 2020 Supplemental Information No.1 for Nine Mile Point Nuclear Station, Unit 2, to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors Project stage: Supplement ML20181A4222020-06-29029 June 2020 Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors Response to Request for Additional Information Project stage: Response to RAI ML20212L8702020-07-30030 July 2020 Request for Additonal Information Review of License Amendment Requests Regarding Riskinformed Categorization and Treatment of Structures, Systems and Components (L-2019-LLA-0290) Project stage: Approval NMP2L2742, Response to Request for Additional Information by NRR to Support Review of Nine Mile Point Nuclear Station, Unit 2, License Amendment Request Re Risk Informed Categorization & Structures, Systems and Components2020-08-28028 August 2020 Response to Request for Additional Information by NRR to Support Review of Nine Mile Point Nuclear Station, Unit 2, License Amendment Request Re Risk Informed Categorization & Structures, Systems and Components Project stage: Response to RAI ML20302A2022020-10-19019 October 2020 NRR E-mail Capture - Surry Power Station, Units 1 & 2 - Audit Plan and Setup of Online Reference Portal for the LAR to Adopt 10 CFR 50.69 Project stage: Approval ML20293A1602020-12-0808 December 2020 Issuance of Amendment Nos. 301 and 301 to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors Project stage: Approval ML20332A1152021-01-29029 January 2021 Issuance of Amendment No. 183 Regarding Risk-Informed Categorization and Treatment of Structures, Systems, and Components Project stage: Approval ML21067A0922021-04-20020 April 2021 Documentation of Decision by NRC Staff That EPRI Report 3002012988, Alternative Approaches for Addressing Seismic Risk in 10 CFR 50.69 Risk-Informed Categorization, Meets Criteria for a Federal Record Project stage: Other 2019-08-06
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1 of 2 Talking Points August 6, 2019 Public Telephone Conference Calvert Cliffs Nuclear Power Plant, Units 1 &2 - Response to RAI #6 Regarding the Application to Adopt 10 CFR 50.69 (ML19183A012)
Paragraph 50.69 (c) requires that the categorization process:
(i) Consider results and insights from the plant-specific PRA. This PRA must at a minimum model severe accident scenarios resulting from internal initiating events occurring at full power operation.
(ii) Determine SSC functional importance using an integrated, systematic process for addressing initiating events (internal and external), SSCs, and plant operating modes, including those not modeled in the plant-specific PRA.
(iii) Maintain defense-in-depth (iv) Include evaluations that provide reasonable confidence that for SSCs categorized as RISC-3, sufficient safety margins are maintained The response to RAI 6 states that interfacing components that support uncategorized interfacing systems may be categorized, in some cases by:
[], an assessment of interface component risk associated with uncategorized systems will be limited to:
- 1. cases where an interfacing component failure cannot prevent performance of interface systems functions, or
- 2. the risk is limited to passive failures assessed as low safety-significant following the passive categorization process for the applicable pressure boundary segments.
The above assessment that will be used in some cases is a deviation from the NEI 00-04 guidance. To support the NRC staff review of the licensees proposal, a step-by-step description of the process to implement the above assessment for categorizing interface components should be provided. This would include a description of the scope, a methodology to assess the impact to interfacing system functions, and examples including those that would result in categorizing the interfacing component as LSS.
- a. It is unclear how the determination that the interfacing component failure cannot prevent performance of interface systems functions is accomplished, and how that meets the requirement for an integrated, systematic categorization process that maintains defense-in-depth and sufficient safety margins. The categorization process in NEI 00-04 includes several deterministic steps for the evaluation of systems functions to satisfy all the rule requirements. Please clarify if and how all the applicable steps in the categorization process are applied to the interface system functions supported by the interfacing component or explain how the process otherwise satisfies all the requirements in 50.69(c).
- b. Clarify why only 1 of the 2 criteria listed in the RAI response needs to be met. (if the or after 1 should be an and). Explain why if only one of the criteria is successfully applied, why the other criterion is no longer important.
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- c. Provide specific examples of applying the two proposed criteria to categorization of interface components, including examples that would result in categorizing the interfacing component as LSS.