ML20210N097
| ML20210N097 | |
| Person / Time | |
|---|---|
| Issue date: | 08/05/1999 |
| From: | Charemagne Grimes NRC (Affiliation Not Assigned) |
| To: | Walters D NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| References | |
| PROJECT-690 NUDOCS 9908110011 | |
| Download: ML20210N097 (15) | |
Text
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August 5, 1999 4
Mr' Douglas J. Walters Nuclear Energy Institute 17761 Street, NW, Suite 400 Washington, DC - 20006-3708
SUBJECT:
. LICENSE RENEWAL ISSUE No. 98-0082, SCOPING GUIDANCE
. Dear Mr. Waltersi Enclosed is the staff's evaluation and proposed resolution for the subject issue. This item was originally limited to scoping concems relating to " cascading," but has since been expanded to include guidance for the overall implementation of the requirements under 10 CFR 54.4 Changes to the draft " Standard Review Plan for the Review of License Renewal s
Applications for Nuclear Power Plant" (SRP-LR) will be initiated to reflect this position. If there are any industry comments on the evaluihtions or the proposed resolution, we request that you document those comments within 30 days following your receipt of this letter, to ensure a timely resolution of this issue. We also expect that NEl 95-10, " Industry Guideline for implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule," be revised to reflect any necessary guidance to implement the attached staff position. If you have any questions regarding th!s matter, please contact Robert Prato at 301-415-1147.
Sincerely,WWW Christopher I. Grimes, Chief License Renewal and Standardization Branch Division of Regulatory improvement Programs Office of Nuclear Reactor Regulation
Enclosure:
As stated 3
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Mr. Douglas J. Walters Nuclear Energy Institute l
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SUBJECT:
LICENSE RENEWAL ISSUE No. 98-0082, SCOPING GUIDANCE
Dear Mr. Walters:
l Enclosed is the staffs evaluation and proposed resolution for the subject issue. This item was originally limited to scoping concerns relating to " cascading," but has since been l
expanded to include guidance for the overallimplementation of the requirements under 10 CFR i
54.4.. Changes to the draft ' Standard Review Plan for the Review of License Renewal Applications for Nuclear Power Plant" (SRP-LR) will be initiated to reflect this position. If there are any industry comments on the evaluations or the proposed resolution, we request that you document those comments within 30 days following your receipt of this letter, to ensure a timely resolution of this issue. We also expect that NEl 95-10," Industry Guideline for implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule," be revised to reflect any necessary guidance to implement the attached staff position. If you have any questions regarding this matter, please contact Robert Prato at 301-415-1147.
Sincerely, a
Christopher I. Grimes, Chief License Renewal and Standardization Branch Division of Regulatory improvement Programs
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Office of Nuclear Reactor Regulation
Enclosure:
As stated cc w/ enclosure: Gee next page Distribution: See next page DOCUMENT NAME:G:\\RLSB\\PRATO\\LLP_lSS\\lL980082.WPD
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Mr. Douglas J. Walters 1
- Nuclear Energy institute 1776 i Street, NW, Suite 400 Washington, DC 20006-3708
SUBJECT:
LICENSE RENEWAL ISSUE No. 98-0082, SCOPING GUIDANCE
Dear Mr. Walters:
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Enclosed is the staff's evaluation and proposed resolution for the subject issue. Th(
item was originally limited to scoping concerns relating to
- cascading," but has since j expanded to include guidance for the overall implementation of the requirements unde 54.4. Changes to the draft " Standard Review Plan for the Review of License Renewal Applications for Nuclear Power Plant" (SRP-LR) will be initiated to reflect this positio are any industry comments on the evaluations or the proposed resolution, we requ document those comments within 30 days following your receipt of this letter resolution of this issue. We also expect that NEl 95-10, ' Industry Guideline for imp Requirements of 10 CFR Part 54 - The License Renewal Rule," be revised to re necessary guidance to implement the attached staff position. If you have any questions regarding this matter, please contact Robert Prato at 301-415-1147.
j Sincerely, Christopher I. Grimes, Chief License Renewal and Standardization Branch Division of Regulatory improvement Programs
Enclosure:
As stated Office of Nuclear Reactor Regulation cc w/ enclosure: See next page Distribution; See next page DOCUMENTNAME:G:\\RLSB\\PRATO\\LLP lSS\\lL980082.WPD
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Mr. Douglas J. Weiters
' Nuclear Energy institute 1776 ! Street, NW, Suite 400 Washington, DC 20006-3708
SUBJECT:
LICENSE RENEWAL ISSUE No. 98- 0082, CASCADING
Dear Mr. Walters:
. Enclosed la the staffs eva8uation and proposed resolu* ion for the subject is. sue. Changes
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to the draft " Standard Review Plan for the Review of License Ranewal Applications for Nuclear Power Plant" (SRP LR) v.ill be initiated to reflect this position. If there are any industry comments on the evaluations or the proposed resolution, we request that you document those
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comments within 30 days fo!!owing your receipt of this letter, to ensure a timely resolution of this issue. We also expect that NEl 95-10, alndustry Guideline for implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule " be revised to reflect any necessary guidance to implement the attached staff position. If you have any questions regarding this matter, please j
contact Robert Prato at 301-4151147.
Sincerely, Christopher I. Grimes, Chief License Renewal and Standardization Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation
Enclosure:
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- NUCLEAR ENERGY INSTITUTE F(License Renewal Steer!ng Committee)
Project No. 690.
cc:
Mrl Dennis Harrison Mr. Robert Gill'
' U.S. Department of Energy Duke Energy Corporation NE-42
. Mail Stop EC-12R -
p 1 Washington, D.C 20585 -
P.O. Box 1006 i
Charlotte, NC 28201 1006
- r Mr. Ricard P. Sedano, Commissioner Mr. Charles R, Pierce
. State Liaison Officer Southem Nuclear Operating Co.
4
- Department of Put;lic Service '
40 inverness Center Parkway 112 State Street BIN B064 U
Drawer 20 Birmingham, AL 35242 L
Monticelier. Vermont 05620-2601
. Mr. Dougias J. Walters Mr. Barth Doroshuk Nuclear Energy Institute Baltimore Gas & Elecific Ccmpany 1776 ! Street, N.W.
1650 Calvert Clif?s Parkway Washington, DC 20006 Lusby, Maryland 20657-47027 DJW@NEl.ORG National Whistleblower Center Chattooga River Watershed Coalition 3233 P Street,' N.W.
P. O. Box 2006 Washington, DC 20007 Clayton, GA 30525 Mr. William H. Mackay.
Entergy Operations. Inc.
' Arkansas Nuclear One 1448 SR 333 GSB-2E
' Russellville, Arkansas 72802 i
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Enclosure LICENSE RENEWAL ISSUE (JO. 98-0082 SCOPING GUIDANCE BACKGROUND On the basis of the experience gained with the first two license renewal applications end i
comments provided on the standard review plan, the staff has identified the need for additional guidance for determining the systems, structures, and components (SSCs) within the scope of the rule. Specifically, the staff has identified concems with the following scoping activities:
1.
Determining the events that need to be considered for identifying the safety-related systems, structures, and components which are relied upon to remain functional during design-basis events. After the events have been identified, determining the SSCs relied upon to remain functional during and following these events to meet the criteria under 10 CFR 54.4(a)(1).
2.
Determining the extent to which an applicant needs to apply " hypothetical failures" in identifying the SSCs under 10 CFR 54.4(a)(2) whose failure could prevent satisfactory accomplishment of any function required pursuant to 10 CFR 54.4(a)(1).
3.
Determining the extent to which an applicant needs to " cascade" to the second, third, and fourth-level support systems in identifying the SSCs relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with 10 CFR 54.4(a)(3).
The following specific requirements from the Code of FederalRegulations, and the Commission guidance from the Statements of Consideration published on May 8,1995, in the Federal Register (60 FR 22461) apply to the scoping activities in question:
10 CFR 54.3 Definitions.
Current licensino basis (CLB) is the set of NRC requirements applicable to a specific plant and a licensee's written commitments for ensuring compliance with and operation within applicable NRC requirements and the plant-specific design basis (including all modifications and additions to such commitments over the life of the license) that are docketed and in effect. The CLB includes the NRC j
tegulations contained in 10 CFR Paris 2,19, 20, 21, 26, 30, 40, 50, 51, 54, 55, 70, 72, 73,100 and appendices thereto; orders; license conditions; exemptions; and V chnical specifications. It also includes the plant-specific design-basis j
infor, sation defined in 10 CFR 50.2 as documentedin the most recent final safety analysis report (FSAR) as required by 10 CFR 50.'71 and the licensee's commitments remaining in effect that were made in docketed licensing correspondence such as licensee responses to NRC bulletins, generic letters, and enforcement actions, as well as licensee commitments documented in NRC safety evaluations orlicensee event reports.
1
10 CFR 54.4 Sccpe.
(a) Plant systems, structures, and components within the scope of this part are -
(1)
Safety-related systems, structures, and components which are those relied upon to remain functional during and following design-basis events (as defined in 10 CFR 50.49 (b)(1)) to ensure the k
following functions-
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(i)
The integrity of the reactor coolant pressure boundary; I
(ii)
The capability to shut down the reactor and maintain it in a safe shutdown condition; or (iii)
T' mability to prevent or mitigate the consequences of ants that could result in potential offsite exposure wmparable to the guidelines 11' f 50.34(a)(1) or f 100.11 of this chapter, as applicable.
(
I (2)
AIInonsafety-related systems, structures, and components whose failure could prevent satisfactory accomplishment of any of the functions identified in pamgraphs (a)(1)(i), (ii), or (iii) of this section.
i (3)
All systems, structures, and components relied on in safety analyses orplant evaluations to perform a function that demonstrates compliance with the Commission's regulations for fire protection (10 CFR 50.48), environmental qualification (10 CFR 50.49), pressurized thermal shock (10 CFR 50.61),
anticipated transients without scram (10 CFR 50.62), and station blackout (10 CFR 50.63).
(b)
The intended functions that these systems, structures, and components must be shown to fulfillin f54.21 are those functions that are the bases for including them within the scope oflicense renewal as specified in paragraphs (a)(1)-(3) of this section.
10 CFR 50.49(b)(ll)
Design basis events are defined as conditions of normal operntion, including 1
anticipated operational occurrences, design basis accidents, extemalevents and naturalphenomena for which the plant must be designed to ensure functions (b)(1)(i) (A) through (C).
SOC - Subsection lil.e(l) Current Licensing Basis (60FR22465)
As definedin f 54.3 of the rule, the CLB is the set of NRC requirements applicable to a specific plant and a licensee's written commitments for ensuring compliance with and operation within applicabic NRC requirements and the plant-specific design basis (including all modifications and additions to such commitments over the life of the license) that are docketed and are in effect. A 2
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detailed explanation Of the CLB, the regulatory processes underlying the CLB, l
compliance with the CLD, and considtiration of the CLB is containedin the SOC for the previous license renewal rule (56 FR 64949: December 13,1991). In summary, the conclusions made in the SOC for the previous rule remain valid.
The CLB represents the evolving set of requirements and commitments for a specific plant that are modified as necessary over the life of a plant to ensuro continuation of an adequate level of safety. The regulatory process is the means by which the Commission continually assesses the adequacy of and compliance with the CLB. Compilation of the CLB is unnecessary to perform a license renewalreview.
SOC - Subsection Ill.c(iii) Bounding the Scope of Review (60FR22467)
Pre-application rule implementation has indicated that the description of systems, structures, and components subject to review forlicense renewal could be broadly interpreted and result in an uunecessary expmsion of the review. To limit this possibility for the scoping category relat:ng 10 nonsafety-related systems, structures, and compnnents, the Commission intends this nonsafety-related category (f 54.4(a)(2)) to apply to systems, simctures, and components whose failure would prevent the accomplishment of an intended function of a safety-related system, structure, and component. An applicant forlicense renewal should rely on the plant's CLB, actualplant-specific experience, industry-wide operating experience, as appropriate, and existing engineering evaluations to determine those nonsafety-related systems, structures, and components that are the initial focus of the license renewal review. Consideration cf hypothetical failures that could result from system interdependsncies that are not part of the CLB and that have not been previously experienced is not required.
Likewise, to limit the potential for unnecessary expansion cf the review for the scoping category conceming !bose systems, structures, and components whose function is rehed upon in certain plant safety analyses to demonstrate compliance with the Commission regulations (i.e., environmental qualification, station blackout, anticipated transient without scram, pressurized them1a! shock, and fire protection), the Commission intends that this scoping categoryinclude all systems, structures, and components whose function is relied upon to demonstrate compliance with these Commission's regulations. An applicant for license renewal should rely on the plant's current licensing bases, actualplant-specific experience, industry-wide operating experience, as appropriate, and existing engineering evaluations to detemline those systems, structures, and components that are the initial focus of the license renewal review.
Consideration of hypothetical fatiures that could result from system interdependencies, that are not part of the current licensing bases and that have not been previously experienced is not required.
Several commenters noted that the word "directly" did not precede the phrase
" prevent satisfactory accomplishment of any of the functions identified in paragraphs (a)(1)(i), (ii), or(iii) of this section"in f54.4(a)(2) and concluded that, in the absence of the word "directly," the license renewalreview could cascade into a review of second, third, or fourth-level support systems. The Commission reaffim1s its position that consideration of hypothetical failures that could result from sysiam interdependencies that are not oart of the CLB and that have not 3
been pr3viously experienc:d is not requir:d. Howevxr, for some licznse renewal applicants, the Commission cannot exclude the possibility that hypothetical failures that are cart of the CLB may require consideration of second, third, or
. fourth-level support systems. In these cases the word "directly"may cause additional confusion, not clarity, regarding the systems, structures, and components required to be within the scope oflicense renewal. In removing the word "directly"from this scoping criterion, the Commission believes it has (1) achieved greater consistency between the scope of the license renewal rule and the scope of the maintenance rule (@50.65) regarding nonsafety-related systems whose failure could prevent satisfactory accomplishment of safety-related functions and thus (2) promoted greater efficiency and predictability in the license renewalscoping process.
The inclusion of nonsafety-related. systems, structures, and components whose failure could prevent other systems, structures, and components from accomplishing a safety function is intended to provide protection against safety function failure in cases where the safety-related structure or component is not itselfimpaired by age-related degradation but is vulnerable to failure from the
~ failuta of another structure or component that may be so impaired. Although it may be considered outside the scope of the maintenance rule, the Commissior; intends to include equipment that is not seismically qualified located near seismically qualified equipment (i.e., Seismic II/I equipment already identified in a plant CLB) in this set of nonsafety-related systems, structures and components.
EVALUATION 1
Safety Related Systems Structures and Components - 10 CFR 54.4(a)(1) i in general, the scoping criteria under 10 CFR 54.4(a)(1) for safety related SSCs are consistent with the criteria used by most licensees in defining safety-related SSCs under their current licensing bases. However, a number of the earlier licensed plants were not licensed to these criteria. These older plants were built and licensed to safety-related criteria that were based on identifying SSCs that served as barriers to the release of fission products. These licensees have been working to convert to the more current safety-related criteria for consistency across the industry, however, some differences may still exist.
Regardless of the criteria used by a licensee under 10 CFR Part 50, an applicant for license renewal needs to use the scoping criteria under 10 CFR 54.4(a)(1) for determining the safety-related SSCs within the scope of license renewal. However, these criteria need to be applied consistent with the plant's CLB. When an applicant's definition of safety-related SSCs within its CLB is not wholely consistent with the scoping cnteria under 10 CFR 54.4(a)(1) for safety-related SSCs, an applicant needs to ensure that its scoping methodology clearly uses the criteria under 10 CFR 54.4(a)(1), and not its definition for safety-related SSCs. The following guidance can be used to determine the safety-related SSCs within the i scope oflicense renewal:
As stated in the scoping criteria under 10 CFR 54.4(a)(1), and referenced under 10 CFR 50.49(b)(1), to determine the scope of safety-related SSCs within the scope of license renewal, an applicant needs to consider those 4
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' SSCs thit era r: lied upon to ramiin functional during and following d: sign-basis events, which are conditions of normal operation, including anticipated operational occurrences, design basis accidents, extemal events, and natural phenomena for which the plant must be designed to ensure the 1
following functions:
(i)
The integrity of the reactor coolant pressure boundary; (ii)
The capability to shut down the reactor and maintain it in a safe
. shutdown condition; or
. (iii)
The capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposure comparable to the guidelines in 9 50.34(a)(1) or 9100.11 of this chapter, as applicable.
To provide consistency with its current licensing basis (as defined 10 CFR 54.3) an applicant needs to consider 'the set of NRC requirements f
applicable to a specific plant and a licensee's written commitments for 1
ensuring compliance with and operation within applicable NRC requirements and the plant specific design basis (including all modifications and additions to such commitments over the life of the license) that are docketed andin effect." The NRC requirements referred to in this definition are the
' requirements contained in 10 CFR Parts 2,19, 20, 21, 26, 30, 40, 50, 51, 54,55,70,72,73,100, and appendices thereto; orders, license conditions,
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exemptions, and technicalspecifications."
j lt is expected that an applicant can limit its scoping review for safety-related SSCs to the design as documented in its plant-specific design basis information documents (e.g., the UFSAR) and written commitments that are docketed and in effect. In addition, an applicant may have to consider engineering evaluations, codes and standards, referenced topical reports, NUREGs and other documentation that serve an integral part of the applicant's compliance with and operation within the requirements and the commitments that are docketed and in effect. For example, if an applicant had a license condition to evaluate pipe breaks as part of its licensing basis, the applicant needs to consider its documented resolution if it is still in effect.
In addition, the applicant may need to consider other documentation such as detailed evaluations that are the basis for the documented commitments that are docketed and in effect. Applicants need not consider site-specific evaluations, codes and standards, topical reports, or any other information that is not documented in its licensing documents or written commitments that are docketed and in effect that do not contribute to the compliance with and operation within NRC requirements.
2 ~
Nonsafety-related Systems Structures and Components - 10 CFR 54,4(a)(2)
The scoping criterion under 10 CFR 54.4(a)(2), in general, is intended to identify those nonsafety-related SSCs that support safety related functions. More specifically, this scoping criterion requires an applicant to identify all nonsafety-j related SSCs whose failure could prevent satisfactory accomplishments of the l
applicable functions of the SSCs identified under 10 CFR 54.4(a)(1). The SOC i
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e (60FR22467), Srction Ill.c (iii) contrins a ci:rific tion of tha Commission's intant for t
this requirement in the following statement:
The inclusion of nonsafety-related systems, structures, and components whose failure couldprevent other systems, structures, and components l
- from accomplishing a safety function is intended to provide protection l
against safety function failure in cases where the safety-related structure 1
or component is not itselfimpaired by age-related degradation but is vulnerable to failure from the failure of another structure or component l
that may be so impaired.
In addition, the SOC, Section Ill.c (iii), provides the following guidance to assist an applicant in determining the extent to which failures need to be consider when applying this scoping criterion:
Consideration of hypothetical failures that could result from system i
interdependencies, that are not part of the current licensing bases and that have not been previously experienced is not required.... However, for some license renewal applicants, the Commission cannot exclude the possibility that hypothetical failures that are cart of the CLB may require 8
consideration of second, third, or fourth-level support systems.
l Therefore, to satisfy the scoping criterion under 10 CFR 54.4(a)(2), an applicant needs to identify those nonsafety-related SSCs (including certain second, third, or fourth-level support systems) whose failure can prevent the satisfactory accomplishment of the safety-related function identified under 10 CFR 54.4(a)(1). In order to identify such systems, an applicant would consider those failures identified in 1) the documentation that makes up its CLB,2) plant-specific operating experience, and 3) industry-wide operating experience that is specifically applicable to its facility. The applicant need not consider hypothetical failures that are not part of the CLB, and that have not been previously experienced.
In determining the nonsafety-related SSCs that are within the scope of the rule, an applicant, for example, needs to consider including such SSCs as the following: 1) the portion of a fire-protection system that supplies water to the refueling floor (even if not required by the FP Plan) that is re'ied upon in a design basis accident analysis as an attemate source of cooling water that can be used to mitigate the consequences from the loss of spent fuel pool cooling; 2) a nonsafety-related, non-seismically qualified building whose failure could result in the failure of a tank that is relied upon as an attemate source of cooling water needed to mitigate the consequences of a design basis event; and 3) a segment of nonsafety-related j
piping identified as a Seismic 11/1 component in the applicant's CLB.
j On the basis of the staff's experience to date, it is important to clarify that the scoping criterion under 10 CFR 54.4(a)(2) specifically applies to those functions "identifieKi in paragraphs (a)(1)(i), (ii), and (iii)" of 10 CFR 54.4. An applicant need not extend this requirement to the scoping criteria under 10 CFR 54.4(a)(3), as is I
discussed below.
l 6
l
3 Commi:sfon Regulation Syctems Structures and Components - 10 CFR J
54.4(a)(3)
. The' scoping criteria under 10 CFR 54.4(a)(3) states that an applicant must consider
- (a]il systems, structures, and components relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the [specified]
Commission regulations [.]" In addition, the SOC, Section Ill.c(iii), states that the Commission intended to limit the potential for unnecessary expansion of the review for SSCs that meet the scoping criteria under 10 CFR S4.4(a)(3), and provides additional guidance that qualifies what is meant by "those SSCs relied on in safety analyses orplant evaluations to perform a function that ciemonstrates compliance with the Commission regulations.."in the following statement:
' [T]he Commission intends that this [ referring to 10 CFR 54.4(a)(3)]
scoping category include all systems, structures, and components whose function is relied upon to demonstrate compliance with these Commission's regulations. M applicant forlicense renewal should rely on the plant's current licer. '
bases, actualplant-specific experience, industry-wide operating ex,
~nce, as appropriate, and existing engineering evaluations v mine those systems, structures, and components that are the
.a focus oflicense renewal.
Therefore, all SSCs that are relied upon in the plant's CLB (as defined in 10 CFR 54.3), plant-specific experience, industry-wide experience (as appropriate) and existing engineering analysis to perform a function that demonstrates compliance with and operation within the Commission regulations identified under 10 CFR 54.4(a)(3) are required to be included within the scope of the rule. For example, if a nonsafety-related diesel generator is required for safe shutdown under the fire protection plan, the diesel generator and all SSCs specifically required for that ds:;sho comply with and operate within the Commission's regulations based on the popl6 ant's design specifications for that diesel shall be included within the scope of unse renewal under 10 CFR 54.4 (a)(3). This may include, but should not be innited to the cooling water system or systems required for operability, the diesel suppon pedestal, and any applicable power supply cable specifically required for safe shutdown in the event of a fire.
i in addition, the last sentence of the second paragraph in the SOC, Section Ill.c (iii),
provides the following guidance for limiting the application of the scoping criteria under 10 CFR 54.4(a)(3) as it applies to the use of hypothetical failures:
Consideration of hypothetical failures that could result from system i
interdependencies, that are not part of the current licensing bases and
' ' that have not been previously experienced is not required.
The SOC does not provide any additional guidance relating to the use of hypothetical failures or the need to consider second, third, or fourth-level support systems for scoping under 10 CFR 54.4(a)(3). Therefore, in the absence of this guidance, an applicant need not I
consider hypothetical failures or second, third, or fourth-level support systems in determining the SSCs within the scope of the rule required by the applicable Commission i
regulations.- For example, if a nonsafety-related diesel generator is only relied upon to remain functional to demonstrate compliance with the Commission regulations, an applicant 7
m y not n::d to consid r tha following SSCs: 1) an cit::rnats / backup cooling water r
system,2) the diesel generator non-seismically qualified building walls, or 3) an overhead segment of non seismically qualified piping (in a Seismic 11/l configuration). This guidance is not intended to exclude any support system (identified by an applicant's CLB, actual plant-specific experience, industry-wide experience, as applicable, or existing engineering evaluations) that is specifically required for compliance with or operation within applicable Commission regulation. For example, if a nonsafety-related diera generator (required to demonstrate compliance with an applicable Commission regulation) specifically requires a second cooling system to cool the diesel generator Jacket Water Cooling System for the diesel to be operable then both cooling systems must be included with the scope of the rule under 10 CFR 54.4(a)(3).
RESOLUTION To identify the SSCs within the scope of license renewal consistent with the scoping criteria under 10 CFR 54.4 (a), an applicant needs to consider the following:
1 The safety-related systems, structures, and components which are relied upon to remain functional during and following design basis events (which are defined as conditions of normal operation, including anticipated operational occurrences, design basis accidents, external events and natural phenomena for which the plant is designed) to ensure the functions under 10 CFR 54.4(a)(1)(i), (ii), and (iii). The events to be considered need to be determined by NRC requirements and licensee written commitments that are docketed and in effect.
2 The nonsafety-related SSCs (including certain second, third, or fourth-level support systems) whose failure can prevent the satisfactory accomplishment of the safety-related function identified under 10 CFR 54.4(a)(1). In order to identify such SSCs, an applicant needs to consider those failures identified ir' the CLB and, to the l
extent that it is applicable and appropriate, any plant-specific or industry-wide operating experience that is specifically applicable to the facility.
3.
The SSCs that are relied upon in the plant's CLB to demonstrate compliance with the Commission regulations identified under 10 CFR 54.4(a)(3). In doing so, an applicant needs to consider those SSCs required to comply with and operate within the Commission regulations based on the applicant's CLB. In determining the SSCs within the scope of the rule under 10 CFR 54.4(a)(3), an applicant also needs to consider, to the extent that it is applicable and appropriate, any plant-specific or industry-wide operating experience that is specifically applicable to the facility.
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Distribution:
Hard coov -
PUBLIC
%DochetfM' RLSB~RF N. Dudley, ACRS - T2E26 EHylton E-mail:
R. Zimmerman W. Kane D. Matthews
- S. Newberry C. Grimes C. Carpenter B. Zaleman J. Strosnider R. Wessman E. Imbro W. Bateman J. Calvo
+i.4 rammer T.Hiltz G. Holahan T. Collins C. Gratton B. Boger -
R. Correia R. Latta j
J. Moore J, Rutberg
- R. Weisman e
-M. Zobler M. Mayfield S. Bahadur A. Murphy
' D. Martin W. McDowell i
S. Droggitis RLSB Staff G. Tracy A.Thadani C. Julian o