ML070390343

Preliminary Work Product to Support February 13, 2007, Public Meeting - RG1.206 Sections a, B, C.I.1 (Rdln/So) and C.III.1-1 (Rdln/So)

ML070390343
Person / Time
Issue date:	02/08/2007
From:	William Reckley NRC/NRO/DNRL/NGIF
To:
References
DG-1145, RG-1.206
Download: ML070390343 (33)

Text

Preliminary Work Product RG 1.206 To support February, 13, 2007, Public meeting REGULATORY GUIDE 1.206 (Draft was issued as DG-1145, dated September 2006)

COMBINED LICENSE APPLICATIONS FOR NUCLEAR POWER PLANTS (LWR EDITION)

A. INTRODUCTION The issuance of combined licenses for nuclear power plants is governed by Title 10, Part 52, of the Code of Federal Regulations (10 CFR Part 52), Licenses, Certifications, and Approvals for Nuclear Power Plants (the Part 52 Rule), which specifies the information to be included in a combined license (COL) application.

The following general provisions, with the corresponding implementing regulations, apply to filing a COL application:

• Any person, except one excluded by 10 CFR 50.38, may file a COL application for a nuclear power facility with the Director of the U.S. Nuclear Regulatory Commission (NRC),

Office of New Reactors (NRO) [10 CFR 52.75(a)].

• The application must comply with the relevant filing requirements of 10 CFR 52.3 and 10 CFR 50.30 [10 CFR 52.75(b)].

• The application must contain all of the information required by 10 CFR 50.33 [10 CFR 52.77].

The U.S. Nuclear Regulatory Commission (NRC) issues regulatory guides to describe and make available to the public methods that the NRC staff considers acceptable for use in implementing specific parts of the agencys regulations, techniques that the staff uses in evaluating specific problems or postulated accidents, and data that the staff need in reviewing applications for permits and licenses. Regulatory guides are not substitutes for regulations, and compliance with them is not required. Methods and solutions that differ from those set forth in regulatory guides will be deemed acceptable if they provide a basis for the findings required for the issuance or continuance of a permit or license by the Commission.

This guide was issued after consideration of comments received from the public. The NRC staff encourages and welcomes comments and suggestions in connection with improvements to published regulatory guides, as well as items for inclusion in regulatory guides that are currently being developed.

The NRC staff will revise existing guides, as appropriate, to accommodate comments and to reflect new information or experience. Written comments may be submitted to the Rules and Directives Branch, Office of Administration, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.

Regulatory guides are issued in 10 broad divisions: 1, Power Reactors; 2, Research and Test Reactors; 3, Fuels and Materials Facilities; 4, Environmental and Siting; 5, Materials and Plant Protection; 6, Products; 7, Transportation; 8, Occupational Health; 9, Antitrust and Financial Review; and 10, General.

Requests for single copies of draft or active regulatory guides (which may be reproduced) should be made to the U.S. Nuclear Regulatory Commission, Washington, DC 20555, Attention: Reproduction and Distribution Services Section, or by fax to (301) 415-2289; or by email to Distribution@nrc.gov.

Electronic copies of this guide and other recently issued guides are available through the NRCs public Web site under the Regulatory Guides document collection of the NRCs Electronic Reading Room at http://www.nrc.gov/reading-rm/doc-collections/ and through the NRCs Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html, under Accession No. ML052290422.

Preliminary Work Product to Support Feb 13, 2007 Public Meeting The COL application is comprised of the various application items listed below.

The corresponding Regulatory Guide (RG) 1.206 sections indicate where this regulatory guide provides guidance for preparing the required application items.

Application Item Corresponding RG 1.206 Section Transmittal Letter (including oath and affirmation) None Final Safety Analysis Report C.I.1-C.I.19, C.III.1, C.III.2 Inspections, Tests, Analyses, and Acceptance Criteria C.II.2, C.III.5, C.III.7 Probabilistic Risk Assessment C.II.1, C.III.1-Chapter 19 Environmental Report C.II.3, C.III.3 Security Plan C.I.13.6 General and Financial Information C.IV.5 Quality Assurance Program Description C.I.17.5 This regulatory guide applies to applications for combined licenses for nuclear power plants.

Applicants may submit their COL applications to the NRC in either paper format or electronically, as described in Section C.IV.2 of this guide.

The NRC issues regulatory guides to describe to the public methods that the staff considers acceptable for use in implementing specific parts of the agencys regulations, to explain techniques that the staff uses in evaluating specific problems or postulated accidents, and to provide guidance to applicants.

Regulatory guides are not substitutes for regulations, and compliance with regulatory guides is not required.

In general, information provided in regulatory guides is reflected in the NRCs Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants (NUREG-0800). The NRCs Office of New Reactors uses the Standard Review Plan as guidance in reviewing applications for early site permits, standard design certifications, combined licenses, and other activities addressed by 10 CFR Part 52.

Along with this RG, major revisions of 10 CFR Part 52 and NUREG-0800 were developed and issued in early 2007. The NRC has attempted to address the numerous comments received following the publication of the draft of this guide, Draft Regulatory Guide DG-1145, as well as coordinate its content with the changes in NRC regulations and review guidance in NUREG-0800. Lessons learned from the use of this guide by applicants developing COL applications will be considered in a future revision of this guide.

This regulatory guide contains information collections that are covered by the requirements of 10 CFR Parts 50 and 52, which the Office of Management and Budget (OMB) approved under OMB control numbers 3150-0011 and 3150-0151, respectively. The NRC may neither conduct nor sponsor, and a person is not required to respond to, an information collection request or requirement unless the requesting document displays a currently valid OMB control number.

Preliminary Work Product to Support Feb 13, 2007 Public Meeting B. DISCUSSION The purpose of this regulatory guide is to provide guidance regarding the information to be submitted in a combined license (COL) application for a nuclear power plant. As such, this guide is intended to address many, albeit not all, of the application options allowed by Title 10, Part 52, of the Code of Federal Regulations (10 CFR Part 52). Although a COL applicant is not required to conform to this guidance, its use will facilitate both the applicants preparation of a COL application and timely review of the application by the staff of the U.S. Nuclear Regulatory Commission (NRC). Nonetheless, the reader should note that although this guide may not cover all current regulations pertaining to a COL application, the application must address all such regulations.

The regulatory positions presented in Section C of this guide are divided into four parts. Part I addresses the information requirements specified in 10 CFR 52.79, Contents of Applications; Technical Information in Final Safety Analysis Report. As such, Part I is intended to provide COL applicants with guidance regarding the information that the staff needs to resolve all safety issues related to the proposed combined license. Moreover, Part I is intended to be used by COL applicants who are not referencing certified designs. Toward that end, Part I includes 19 sections. Section C.I.1 provides broad generic guidance, although COL applicants have the option not to maintain some of this information in Chapter 1 of the final safety analysis report (FSAR). Sections C.I.2-C.I.17 are based on the existing guidance provided in Regulatory Guide 1.70, Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants, although the NRC staff has updated the guidance in those sections to reflect the current information requirements for COL applications. By contrast, Sections C.I.18-C.I.19 present information requirements that are not addressed in Regulatory Guide 1.70. In addition, the reader should note that Sections C.I.2-C.I.19 correspond to Chapters 2-19 of NUREG-0800, Standard Review Plan [SRP] for the Review of Safety Analysis Reports for Nuclear Power Plants. The level of information needed for those sections depends on the complexity of the topic.

Part II of Section C addresses the information requirements specified in 10 CFR 52.80, Contents of Applications; Additional Technical Information. In particular, these information requirements include the probabilistic risk assessment (PRA); inspections, tests, analyses, and acceptance criteria (ITAAC); and the environmental report. Use of the guidance in Part II assumes that a COL applicant is submitting a custom design. Together, Parts I and II are intended to represent the bulk of the technical information that an applicant should include in a COL application.

Part III of Section C is intended to be used by COL applicants who reference either a certified design or both a certified design and an early site permit (ESP). As such, Part III includes seven sections.

Section C.III.1 is intended to address the topics that the NRC staff will review in a COL application that references a certified design. By contrast, Section C.III.2 addresses the remaining review topics for applications that reference both a certified design and an ESP. The guidance provided in both of these sections was derived from information presented in Part I of this guide. Section C.III.3 addresses the finality of an environmental impact statement associated with an ESP. Section C.III.4 provides generic guidance on addressing COL action/information items in COL applications. Section C.III.5 provides recommendations for COL applicants who reference certified designs that include design acceptance criteria (DACs). Section C.III.6 provides recommendations for coordinating the submittal of COL applications with design certifications and/or ESP applications that are under NRC review at the time the COL application is submitted. Finally, Section C.III.7 provides a process for developing the additional ITAAC necessary for applications that reference a certified design.

Preliminary Work Product to Support Feb 13, 2007 Public Meeting Part IV of Section C includes 12 sections that address a series of miscellaneous topics of interest to COL applicants. Section C.IV.1 includes the checklist that the NRC will use to perform its acceptance review of a COL application. Section C.IV.2 provides guidance and recommendations for the format of a COL application, with a particular focus on those that applicants submit electronically. Section C.IV.3 provides a general description of the change processes associated with custom COL applications and those that reference a certified design and/or an ESP. Section C.IV.4 provides guidance for use in implementing SECY-05-0197, Review of Operational Programs in a Combined License Application and Generic Emergency Planning Inspections, Tests, Analyses, and Acceptance Criteria. Section C.IV.5 provides submittal guidance for the general and financial information that a COL application is required to include.

Section C.IV.6 provides guidance regarding information to be included in the site redress plan and requests for limited work authorizations. Section C.IV.7 discusses pre-application activities that the NRC staff and the prospective applicant should perform before an application is submitted. Section C.IV.8 provides information on dealing with generic issues. Section C.IV.9 is reserved for future use. Section C.IV.10 provides guidance on handling the regulatory treatment of non-safety systems. Section C.IV.11 is reserved for future use. Finally, Section C.IV.12 discusses the applicability of industry guidance.

Figure B-1 below represents the scope of the staffs review of a COL application that references a certified design. In such instances, the referenced design may contain DAC for certain design topics that the COL application review is not required to address; however, the COL application must discuss any departures from the certified design. In addition, the design must be sufficiently complete to enable the NRC staff to reach a final conclusion regarding all safety issues. Toward that end, the scope of the staffs review encompasses the entire facility. Thus, a COL applicant should not state that the staff should defer a portion of its application review because the information is not available at the time the application is submitted. Rather, the COL applicant should provide sufficient information to enable the staff to reach a safety finding.

Design Certification Site-Specific 100%

average level of design X completion to resolve

% Design Completion Translation into safety issues Construction/Design Deviations from Documents Certified Design Design Acceptance Criteria (optional for COL Review)

X Scope of DG-1145 Design COL Certification Review Finality all values are representative and not absolute 0%

0%  % Design Scope 100%

Figure 1: Combined License Application Referencing a Certified Design

Preliminary Work Product to Support Feb 13, 2007 Public Meeting This guide is intended to be used by COL applicants who propose to construct and operate light-water reactor (LWR) nuclear power plants. Thus, this guide does not attempt to distinguish between active and passive safety system LWRs. Rather, this guide attempts to bound the information needed in a COL application for any LWR. As a result, some of the guidance may not apply to some COL applicants.

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Preliminary Work Product to Support Feb 13, 2007 Public Meeting C.I.1. Introduction and General Description of the Plant In accordance with Subpart C of Title 10, Part 52, of the Code of Federal Regulations (10 CFR Part 52), combined license (COL) applicants may [incorporate by ]reference designs that have been certified according to Subpart B of 10 CFR Part 52 and early site permits according to Subpart A of 10 CFR Part 52. [Additional guidance for COL applicants who reference a certified design and/or early site permit is provided in Section C.III of this regulatory guide. By contrast, t]\T\he guidance provided in Section C.I of this regulatory guide applies to COL applicants [who]\that\ reference neither a certified design nor an early site permit\ but provides a design for a complete facility on a specified site (i.e., a custom design). For COL applicants that reference a certified design, additional guidance is provided in Section C.III.1 of this regulatory guide. For COL applicants that reference a certified design and an early site permit, additional guidance is provided in Section C.III.2 of this regulatory guide\.

The first chapter of the final safety analysis report (FSAR) should present an introduction to the report and a general description of the plant. This chapter should enable the reviewer or reader to obtain a basic understanding of the overall facility without having to refer to the subsequent chapters. Review of the detailed chapters that follow can then be accomplished with better perspective and recognition of the relative safety-significance of each individual item in the overall plant design.

C.I.1.1 Introduction In this section, the COL applicant should briefly present the principal aspects of the overall application, including the type of license requested, the number of plant units\1\, a brief description of the proposed plant location, the type of containment structure and its designer, the type of nuclear steam supply system and its designer, the core thermal power levels (both rated and design), the corresponding net electrical output for each thermal power level, and the scheduled completion date and anticipated commercial operation date of each unit. The following subsections address these aspects of the application.

C.I.1.1.1 Plant Location The COL applicant should provide plant location information, such as the State and county, as well as one or more map(s) showing the site location and plant arrangement within the site, including

[whether]\the extent (if any) to which\ the plant is colocated \and/or interfaces \with \a licensed, \existing

[operating ]nuclear power [plants]\plant (i.e., within the existing exclusion area boundary)\.

C.I.1.1.2 Containment Type

`

The COL applicant should provide a summary level description of the containment design

[i.e., freestanding or supported, cylindrical or spherical, liner or vessel type, and shield building type (reinforced concrete, post-tensioned, etc.)].

C.I.1.1.3 Reactor Type 1

10 CFR Part 52.8 allows for an applicant to combine several applications for different kinds of licenses (e.g., a power reactor and an ISFSI) and to combine in a single license the activities of an applicant which would otherwise be licensed separately (e.g., identical units on same site). However, multiple applicants may not file for the same license.

DG-1145, Page C.I.1-7

Preliminary Work Product to Support Feb 13, 2007 Public Meeting The COL applicant should specify the nuclear steam supply system model and designer, as well as whether the reactor is a pressurized-water reactor or boiling-water reactor.

[]\\C.I.1.1.4 Power Output The COL applicant should provide the \approximate \net electrical output \(for information only)

\and\ the\ core thermal power [rating]\levels (both rated and design)2\.

C.I.1.1.5 Schedule The COL applicant should provide estimated schedules for completion of construction and start of commercial operation (estimates may be specified in duration, rather than calendar dates, based on the application submittal date).\ As an alternative, COL applicants may include a commitment to provide the construction and startup schedules following issuance of the combined license and when a positive decision to construct the plant has been made by the licensee. \

C.I.1.1.6 Format and Content The COL applicant should provide information on the following aspects of the format and content of its application:

1.1.6.1 [c]\C\onformance with[ regulatory guides on] the format and content

[of a COL application]\guidance of this regulatory guide\ (i.e.,[ DG-1145]\ Regulatory Guide 1.206\).

1.1.6.2 [c]\C\onformance with the standard review plan (NUREG-0800)\ in effect 6 months prior to application submittal date 3\ (i.e., evaluation of the differences in the design features, analytical techniques and procedural measures proposed for a facility and those corresponding features [ ],

techniques and measures given in the SRP acceptance criteria)\.\

1.1.6.3 [t]\T\he format, content, and numbering of text, tables, and figures included in the application, and a discussion o[f]\n\ their use\ should be provided in the application.\

1.1.6.4 [f]\F\ormat for numbering of pages \should be discussed \in the application\.\

1.1.6.5 [t]\T\he method by which proprietary information is identified and referenced\ should be discussed.\

1.1.6.6 [a]\A\ list of acronyms used in the FSAR (documents that are not part of the FSAR but are part of the application should include their own list of acronyms)\.\

2 Rated power is defined as the power level at which the plant would be operated if licensed. Design power is defined as the highest power level that would be permitted by plant design and that is used in some safety evaluations.

3 Although the requirements of 10 CFR Part 52 specify ...in effect 6 months prior to docket date, NRC practice for implementation of this requirement has been to use 6 months prior to application submittal.

However, the rule language has been retained as docket date in order to retain flexibility for situations where an applicant submits an incomplete application which the staff does not docket for an extended period of time due to the additional work required of the applicant to complete the application. This footnote is applicable to the other references in this section to information with a baseline of 6 months prior to docket date.

DG-1145, Page C.I.1-8

Preliminary Work Product to Support Feb 13, 2007 Public Meeting C.I.1.2 General Plant Description In this section, the COL applicant should provide a summary description of the principal characteristics of the site and a concise description of the facility. The facility description should include a brief discussion of the principal design criteria, operating characteristics, and safety considerations for the facility; the engineered safety features and emergency systems; the instrumentation, control, and electrical systems; the power conversion system; the fuel handling and storage systems; the cooling water and other auxiliary systems; and the radioactive waste management system. The general arrangement of major structures and equipment should also be indicated by the use of plan and elevation drawings in sufficient number and detail to provide a reasonable understanding of the general layout of the plant.\4\ Those features of the plant that are likely to be of special interest because of their relationship to safety should also be identified. In addition, such items as unusual site characteristics, solutions to particularly difficult engineering and/or construction [problems]\considerations\ (e.g., modular construction techniques or plans), and significant extrapolations in technology represented by the design should be highlighted.

C.I.1.3 Comparison with Other Facilities The COL applicant should provide a comparison with other facilities of similar design and comparable power level.

C.I.1.4 Identification of Agents and Contractors In this section, the COL applicant should identify the primary agents or contractors for the design, construction, and operation of the nuclear power plant. The principal consultants and outside service organizations (such as those providing audits of the quality assurance program) should also be identified.

The division of responsibility between [the reactor]\the reactor/facility\ designer\(s)\, architect-engineer\(s)\, constructor\(s)\, and plant operator should also be delineated.

C.I.1.5 Requirements for Further Technical Information In this section, COL applicants [who]\that\ do not reference a certified design should provide information to demonstrate the performance of new safety features for nuclear power plants that differ significantly from those of evolutionary light-water reactors or utilize simplified, inherent, passive, or other innovative means to accomplish their safety functions. The requirement to provide this information is included in 10 CFR Part 52 and is necessary to ensure that (1) these new safety features will perform as predicted in the applicants FSAR, (2) the effects of system interactions are acceptable, and (3) the applicant provides sufficient data to validate analytical codes. The design qualification testing requirements may be met with either separate effects or integral system tests; prototype tests; or a combination of tests, analyses, and operating experience. These requirements implement the Commissions policy on proof-of-performance testing for all advanced reactors (51 FR 24643, dated July 8, 1986), as well as the Commissions goal of resolving all safety issues before authorizing construction.

4 The general arrangement drawings of buildings other than primary containment may warrant designating as sensitive unclassified non-safeguards information in accordance with the agency guidance described in SECY-04-0191, Withholding Sensitive Unclassified Information Concerning Nuclear Power Reactors from Public Disclosure.

DG-1145, Page C.I.1-9

Preliminary Work Product to Support Feb 13, 2007 Public Meeting The [guidance provided in this regulatory guide is based on a ]COL applicant [who]\that\ does not reference a certified design as part of the application[. Instead, this guidance focuses on a COL applicant who] must provide [a complete ]design \information \for the entire proposed facility,

[with the same]\with a level of detail necessary to resolve all safety issues (i.e., the same\ level of \detailed

\design[ completeness] information provided [for]\in\ a certified design\)\. [Because]\Even though\ a COL applicant [who]\that\ does not reference a certified design must provide sufficient design information for a complete facility, the NRC [staff anticipates]\expects\ that [there may only be minimal requirements]\the need\ for\ providing\ further technical information to [supplement the information included]\that provided\

in the application [discussions. These minimal requirements]\may exist and\ may include such items as verification of unique design concepts, for example, that may require tests and/or additional verification analyses for the first plant, first three plants, and so forth.

It is the responsibility of the COL applicant providing a complete design for its proposed facility to identify any requirements for further technical information in its application, including an estimated schedule for providing the additional technical information that may be necessary for issuance of a combined license.

C.I.1.6 Material Referenced In this section, the COL applicant should tabulate all topical reports that are incorporated by reference as part of the application. In this context, topical reports are defined as reports that have been prepared by reactor designers and manufacturers, architect-engineers, or other organizations, and filed separately with the NRC in support of this application or other applications or product lines. For each topical report, this tabulation should include the report number and title, the date on which the report was submitted to the NRC, and the sections of the COL application in which the report is referenced. For any topical reports that have been withheld from public disclosure as proprietary documents pursuant to 10 CFR 2.[790]\390\(b), this tabulation should also reference nonproprietary summary descriptions of the general content of each such report. This section should also include a tabulation of any documents submitted to the Commission in other applications that are incorporated in whole or in part by reference in the application. If any information submitted in connection with other applications is incorporated by reference in this application, summaries of such information should be included in appropriate sections of this application, as necessary\, to provide clarity and context\.

Results of test and analyses may be submitted as separate reports. In such cases, these reports should be referenced in this section and summarized in the appropriate section(s) of the FSAR.

C.I.1.7 Drawings and Other Detailed Information The COL applicant should provide a tabulation of all instrument and control functional diagrams, as well as electrical one-line diagrams cross-referenced to the related application section(s), including legends for electrical power, instrument and control, lighting, and communication drawings.

In addition, the COL applicant should provide a tabulation of system drawings \(e.g., piping and instrumentation diagrams) \and system designators that are cross-referenced to the related section(s) of the application. This information should include the applicable drawing legends and notes.

C.I.1.8 Interfaces (with Standard Designs and Early Site Permits)

[The guidance provided in this section of the regulatory guide is for ]COL applicants [who]\that\

do not reference a certified design as part of the application[. Instead, the COL applicant who is the focus DG-1145, Page C.I.1-10

Preliminary Work Product to Support Feb 13, 2007 Public Meeting of this guide] must provide [a ]design \information \for a complete facility\ (i.e.\,[ which is] not limited in scope such as a certified design[, but to the same of level of]\) and with a level of detail necessary to resolve all safety issues (i.e., the same level of detailed\ design information as provided in a certified design\)\. By definition, there [is]\are\ no interface\ requirements\ between standard designs and site-specific designs for a complete facility design. All interfaces, such as those that may exist between certified designs, early site permits, and a COL application that references [those documents]\a certified design and/or early site permit\, are expected to be integral to a COL application that provides a complete facility design. [T]\COL applicants t\hat [is, there are no interfaces from]\reference\ a certified design and/or early site permit [for a COL applicant who does not reference those documents.

Based on the focus of this section of the regulatory guide, there should be no]\are the only applicants that will have\ interface requirements[ identified for a ]\.

\COL applicant[ who]\s that\ do[es] not reference a certified design [and/or early site permit.

Likewise, a COL application that does not reference a certified design, by definition,]\will need to submit design information on the entire facility and\ should not include any conceptual design information for the facility. In order to facilitate the NRC staffs review of previous applications for design certification, conceptual designs were included in their design control documents (DCDs) to provide a comprehensive design perspective. However, the conceptual design portions of the DCDs were not (and were not intended to be) certified by the NRC. Rather, these conceptual designs typically included portions of the balance-of-plant. Thus, COL applicants [who]\that\ do not reference a certified design are expected to provide complete designs for the facility without reliance on conceptual designs.

C.I.1.9 Conformance with Regulatory Criteria C.I.1.9.1 Conformance with Regulatory Guides The requirements of [proposed ]10 CFR 52.79(a)(4)(i) specify that the contents of a COL application must include information on the design of the facility, including its principal design criteria.

Appendix A to 10 CFR Part 50, General Design Criteria for Nuclear Power Plants, establishes minimum requirements for the principal design criteria for water-cooled nuclear power plants that are similar in design and location to plants for which the Commission has previously issued construction permits, and provides guidance to applicants for use in establishing principal design criteria for other types of nuclear power units. In general, regulatory guides describe methods that the NRC staff considers acceptable for use in implementing the general design criteria specified in Appendix A to 10 CFR Part 50. Thus, COL applicants should provide an evaluation of conformance with the guidance provided in the NRCs regulatory guides that are in effect 6 months before the [docket]\submittal\ date of the COL application.

That evaluation should also include an identification and description of [any departures]\deviations\ from the guidance contained in the NRCs regulatory guides, as well as suitable justifications for [the]\any\

alternative approaches proposed by the COL applicant.

\COL applicants should provide an evaluation of conformance with the following Regulatory Guides:

Division 1, Power Reactors Division 4, Environmental and Siting (applies to Environmental Report and should be discussed therein)

Division 5, Materials and Plant Protection (applies to Security Plan and should be discussed therein)

Division 8, Occupational Health DG-1145, Page C.I.1-11

Preliminary Work Product to Support Feb 13, 2007 Public Meeting

\C.I.1.9.2 Conformance with [the Standard]\Application and\ Review [Plan]\Guidance\

DG-1145, Page C.I.1-12

Preliminary Work Product to Support Feb 13, 2007 Public Meeting The requirements of [proposed] 10 CFR 52.79(a)(41) specify that for applications for light-water cooled nuclear power plant combined licenses, COL applicants should provide an evaluation of the

[facilitys conformance with]\facility against\ the [standard]\NRCs application and\ review [plan (SRP)]\guidance\ in effect 6 months before the docket date of the application.5 The evaluation required by this [section should]\section shall\ include an identification and description of a[ny]\ll\ differences in design features, analytical techniques, and procedural measures proposed for the facility and those corresponding features, techniques, and measures [specified]\given\ in the[ SRP] acceptance criteria\ in the application and review guidance\. Where differences exist, the evaluation should discuss how the proposed alternative provides an acceptable method of complying with the Commissions regulations, or portions thereof, that underlie the corresponding [SRP ]acceptance criteria.\ \

\ \

C.I.1.9.3 Generic Issues The requirements of [proposed] 10 CFR 52.79(a)(20) specify that the contents of a COL application must include proposed technical resolutions for those [u]\U\nresolved [s]\S\afety [i]\I\ssues and medium- and high-priority generic safety issues [that]\which\ are[ (1) technically relevant to the design, and (2)] identified in the version of NUREG-0933[, A Prioritization of Generic Safety Issues, in effect]\ current on the date up to\ 6 months before the docket date of the [COL ]application\ and which are technically relevant to the design\.

Since the inception of the generic issues program in 1976, the NRC has identified and categorized reactor safety issues. These issues were grouped into TMI action plan items, task action plan items, new generic items, human factors issues, and Chernobyl issues, and are collectively called generic safety issues (GSIs). Section C.IV.8 of this regulatory guide provides [a list of these GSIs (i.e., those]\additional guidance for addressing the\ unresolved safety issues and medium- and high-priority GSIs that are identified in [the version of ]NUREG-0933[ that was current as of the date of issuance of DG-1145) for use by COL applicants. In preparing that list, the NRC staff reviewed these GSIs to determine whether they have been closed by other Commission actions or requirements. Those issues that remain open and are technically relevant to the COL applicants design should be addressed in the application].

C.I.1.9.4 Operational Experience (Generic Communications)

The requirements of [proposed] 10 CFR 52.79(a)(37) specify that the contents of a COL application must include information to demonstrate how operating experience insights from generic letters and bulletins [up to]\issued after the most recent revision of the applicable standard review plan and\ 6 months before the docket date of the application, or comparable international operating experience, have been incorporated into the plant design.

To ensure that the operational experience \described in generic letters and bulletins \from decades of nuclear power plant operation in the United States [is]\was captured in the knowledge base for reviewers and applicants, the insights from these generic letters and bulletins were\ incorporated in[to] the

[designs for new/standardized nuclear power plants, the application should review and assess the 5

The \review guidance is the standard review plan (SRP) contained in NUREG-0800. The \SRP was issued to establish criteria that the NRC staff intends to use in evaluating whether an applicant/licensee meets the Commissions regulations. The SRP is not a substitute for the NRCs regulations, and compliance is not a requirement.\ \

DG-1145, Page C.I.1-13

Preliminary Work Product to Support Feb 13, 2007 Public Meeting highlights of this]\updates to applicable standard review plans6. To ensure that applicants consider the\

operational experience [(as documented in generic NRC communications]\incorporated in these standard review plan (SRP) updates, applicants whose plant designs are based on or are evolutions of plants that have operated in the United States are required by 10 CFR 52.79(a)(41) to evaluate their facility design against the review guidance (i.e., SRPs) in effect 6 months before the docket date of the application. In addition, applicants are required to demonstrate how the operating experience insights from generic letters and bulletins issued after the review guidance update (i.e., in or about March 2007) have been incorporated into the plant design (i.e., address those generic communications not incorporated in the SRP update\).

The significance of limiting this review to generic letters and bulletins is that these documents pertain to issues that were considered to have risen to a level of safety-significance such that [they required

]responses and resolutions from nuclear operating plant licensees\ were required\. Other forms of generic communications have included circulars, information notices, and regulatory information summaries; however, these types of generic communications d[o]\id\ not require responses or actions on the part of licensees\ and do not need to be addressed by COL applicants\. In addition, the issues discussed in these\

types of\ communications are generally of a more specific (rather than generic) nature.

[A listing of generic communications (i.e., generic letters and bulletins that had been issued prior to the date of issuance of DG-1145) has been provided in Section C.IV.8, Generic Issues, of this regulatory guide for use by COL applicants. A review of these generic communications was performed to determine whether they have been superceded by other NRC generic communications, NRC actions, or requirements.

Those generic communications that remain open and that are technically relevant to the]\Alternatively,\

COL applicants [facility design should be addressed in the application.

C.I.1.9.4.1 Comparable International Operating Experience Applicants for certified designs or combined licenses are required to address]\whose plant design is not based on or is an evolution of plants that have operated in the United States should demonstrate how\

comparable international operating experience [in accordance with proposed 10 CFR 52.47(a)(19) and 10 CFR 52.79(a)(37), respectively. To the extent that the design (or portions thereof), for which an applicant seeks a design certification or COL, originates or is based on international design, the application should address how international operating experience has contributed to the design process]\has been incorporated into their plant design\. Nuclear industry regulators or owners groups in countries that include nuclear reactor vendors and/or nuclear power plants (e.g., Canada, France, Germany, Japan, etc.)

may track, maintain, and/or issue operating experience bulletins or reports similar to the NRCs generic letters and bulletins. [Thus, the design certification or COL]\The COL\ applicant should address how [this body of]\the applicable\ operating experience has been assessed and/or incorporated into the \plant \design.

[Design certification and]\In addition,\ COL applicants [are responsible for procuring any]\should consult organizations such as the Institute for Nuclear Power Operations (INPO) or the World Association of Nuclear Operators (WANO) for applicable comparable\ international operating experience[ information for use in this assessment].

\\

C.I.1.9.5 Advanced and Evolutionary Light-Water Reactor Design Issues

[This section (i.e., Section C.I) of the regulatory guide is applicable to ]COL applicants [who]\that\

do not reference a certified design[. Therefore, such applicants] should provide sufficient information 6

The SRP was updated in March 2007 to support COL applications for new nuclear power plants that were planned to be submitted to the NRC as early as September 2007.

DG-1145, Page C.I.1-14

Preliminary Work Product to Support Feb 13, 2007 Public Meeting on the complete design of the proposed facility, including those portions of the facility design that are typically provided by reactor vendors or applicants for reactor design certification in accordance with Subpart B of 10 CFR Part 52. As such, COL applicants should address the licensing and policy issues developed by the NRC \and documented in the following SECY documents and their associated SRMs \for advanced and evolutionary light-water reactor designs that are applicable to the\ir\ proposed facility design. The following documents provide guidance to applicants on issues that should be considered

[and/or]\and, as appropriate,\ addressed in a COL application that does not reference a certified design\

(i.e., a custom design)\; however, this list may not be comprehensive \and some of the references may not be applicable \for all potential COL applicants:

SECY-89-013, Design Requirements Related to the Evolutionary Advanced Light-Water Reactors (ALWRs)

SECY-90-016, Evolutionary Light-Water Reactor (ELWR) Certification Issues and Their Relationship to Current Regulatory Requirements SECY-90-241, Level of Detail Required for Design Certification Under Part 52 SECY-90-377, Requirements for Design Certification Under 10 CFR Part 52 SECY-91-074, Prototype Decisions for Advanced Reactor Designs SECY-91-178, ITAAC for Design Certifications and Combined Licenses SECY-91-210, ITAAC Requirements for Design Review and Issuance of FDA SECY-91-229, Severe Accident Mitigation Design Alternatives for Certified Standard Designs SECY-91-262, Resolution of Selected Technical and Severe Accident Issues for Evolutionary Light-Water Reactor (LWR) Designs SECY-92-053, Use of Design Acceptance Criteria During the 10 CFR Part 52 Design Certification Reviews SECY-92-092, The Containment Performance Goal, External Events Sequences, and the Definition of Containment Failure for Advanced LWRs SECY-93-087, Policy, Technical, and Licensing Issues Pertaining to Evolutionary and Advanced Light-Water Reactor (ALWR) Designs SECY-94-084, Policy and Technical Issues Associated with the Regulatory Treatment of Non-Safety Systems in Passive Plant Design (RTNSS)

SECY-94-302, Source-Term-Related Technical and Licensing Issues Relating to Evolutionary and Passive Light-Water-Reactor Designs DG-1145, Page C.I.1-15

Preliminary Work Product to Support Feb 13, 2007 Public Meeting SECY-95-132, Policy and Technical Issues Associated with Regulatory Treatment of Non-Safety Systems in Passive Plant DesignsSECY-91-229, Severe Accident Mitigation Design Alternatives for Certified Standard Designs

[SECY-91-262, Resolution of Selected Technical and Severe Accident Issues for Evolutionary Light-Water Reactor (LWR) Designs SECY-92-053, Use of Design Acceptance Criteria During the 10 CFR Part 52 Design Certification Reviews SECY-92-092, The Containment Performance Goal, External Events Sequences, and the Definition of Containment Failure for Advanced LWRs SECY-93-087, Policy, Technical, and Licensing Issues Pertaining to Evolutionary and Advanced Light-Water Reactor (ALWR) Designs SECY-94-084, Policy and Technical Issues Associated with the Regulatory Treatment of Non-Safety Systems in Passive Plant Design (RTNSS)

SECY-94-302, Source-Term-Related Technical and Licensing Issues Relating to Evolutionary and Passive Light-Water-Reactor Designs

]

DG-1145, Page C.I.1-16

Preliminary Work Product to Support Feb 13, 2007 Public Meeting WordPerfect Document Compare Summary Original document: C:\NRO RG1-206\DG1145 for compare\C-III-1.wpd Revised document: @PFDesktop\:MyComputer\C:\MyFiles\Checkout\C-III-1-Chap1.wpd Deletions are shown with the following attributes and color:

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DG-1145, Page C.I.1-17

Preliminary Work Product to Support Feb 13, 2007 Public Meeting C.III.1. Information Needed for a COL Application Referencing a Certified Design C.III.1.1 Introduction

\ \

Combined license (COL) applicants that have referenced a certified design\ (CD)\ will have a significant portion of the facility reviewed by NRC prior to applying for a COL. The remaining portions of the facility design and operation that require review will constitute the information contained in the final safety analysis report (FSAR) of the COL application. This section of the guide will identify the generic information that should be submitted with a combined license application that references a certified design, but not an early site permit (ESP).

\Part I of the guide includes the information that should be included in a COL application that does not reference either a certified design or an ESP. \The information\ contained\ in this section [was taken from]\is consistent with\ Part I of the guide\ and\,\ in some sections, the applicable information from Part I has been duplicated\ to help preclude repetitive submission of information[ for NRC COL review that is]

already covered in the design control document (DCD) of a referenced certified design, or that is covered in other portions of the COL application. [Part I of the guide includes the information that should be included in a COL application that does not reference either a certified design or an ESP.] \Where the guidance for a COL applicant referencing a DCD is not significantly different than that for a COL applicant with a custom design, reference to the specific sections of the guidance in Part I has been provided to ensure consistency and to reduce the bulk of this guide. As such, use of this regulatory guide by a COL applicant referencing a DCD should not be limited to Section C.III.1. The COL applicant referencing a DCD should also consult the guidance contained in Part I of this guide, as appropriate. \

In this section of the guide, the staff has identified the scope of the FSAR on a generic basis for COL applications that reference a certified design\ but do not reference an ESP\.

C.III.1.2 How to Use this Section This section of the guide [contains a listing of all the]\presents the guidance information in a format that is consistent with the organization and numbering of the applicable\ standard review plan (SRP) sections [that are included]\and follows the format\ in Part I of this guide. If the FSAR for a COL application that references a certified design needs to address a particular section of the SRP, that information is identified in this section. The specific information that the applicant should provide

[has]\should\ be[en copied]\ consistent with the information\ from the corresponding section in Part I[ and pasted into this section of the guide]. For design topics that have been resolved in the design certification, the guide will state that the COL applicant does not need to include additional information.

Depending on the technology, some design topics may not have been reviewed during the design certification. COL applicants will need to provide this information only if it was not covered in the design certification.

The intent of this information is to facilitate the applicants effort to submit a complete and concise COL application. However, it should be noted that it will be the combination of information provided by the specific, referenced DCD, \the FSAR, \and the [FSAR]\additional technical information provided\ with the COL application, that will be considered by\ the\ staff in their evaluation as to whether or not to grant a COL. Thus, due diligence is required by the applicant to provide proper and sufficient information to meet the regulations, in order for the staff to make its determination.

C.III.1.3 Design Acceptance Criteria RG 1.206, Page C.III.1-18

Preliminary Work Product to Support Feb 13, 2007 Public Meeting All the designs that have been certified [when]\at the time\ this guide was issued use design acceptance criteria (DAC) for certain portions of the design that were not completed during the design certification review. A unique set of inspections, test, analyses, and acceptance criteria (ITAAC) were established that provide the criteria for which the COL applicant can complete the design. Because DAC are associated with ITAAC, the regulations do not require these portions of the design to be completed prior to issuance of a COL. Section C.III.5 of this guide provides recommendation\s\ for COL applicants to complete the design portion of the DAC prior to the issuance of the COL. [The development of]\This\

section [C.III.1 ]of th[is]\e\ guide assumes that the design was reviewed and certified without the use of DAC.

\

\C.III.1.4 COL Action or Information Items Section C.III.1 of the guide does not address any specific COL action or information items for any of the designs previously certified. Instead, Section C.III.4 provides generic guidance for addressing COL action or information items in a COL application referencing a certified design. The NRC recommends the COL action or information items be addressed in the appropriate sections of the FSAR.\ In addition, COL applicants should identify or uniquely designate the information provided in the application, including the FSAR, that addresses the COL action or information items. \

C.III.1.5 Conceptual Design Information Several factors, including whether the\ referenced\ certified design incorporates either active or passive safety systems, determine the scope of the NRC review of a COL application referencing a certified design. COL applicants that reference a certified design with systems that are included in the DCD on a conceptual basis should provide the actual design information for these systems so that the staff can complete its review of the design[. Further]\ (additional\ guidance is provided in Section 1.8 of C.III.1[.]\). In addition, COL applicants should identify or uniquely designate the actual design information that has been provided in the application, including the FSAR, to replace the conceptual design information in the DCD of the referenced certified design. \

C.III.1.6 Departures from the \Referenced \Certified Design Departures from the \referenced \certified design should be discussed in the section \of the application \that corresponds to where the topic is discussed in the [design control document associated with the certified design referenced by the COL applicant]\DCD. A list or table of departures with a reference to the affected section of the application should be provided in Chapter 1 of the FSAR\ .

Sufficient information should be provided for the NRC to resolve all safety and security issues in its review of the departure. COL applicants should \also \consult Sections C.I.1 through C.I.19 of this guide for [the]\a more comprehensive set of\ information that needs to be included in the FSAR. Information on the applicable design certification change processes is included in Section C.IV.3 of this guide. [

]\ In addition, COL applicants should identify or uniquely designate the information provided in the application, including the FSAR, that is a departure from the referenced certified design.

The following definition for departure is provided for COL applicants:

A departure is a plant-specific deviation from design information in a standard design certification rule. A departure may be distinguished from a change to a standard design RG 1.206, Page C.III.1-19

Preliminary Work Product to Support Feb 13, 2007 Public Meeting certification rule by recalling that a departure is plant-specific, whereas a change is generic.

Therefore, a departure:

• Is requested by the applicant referencing a design certification.

• Applies to the design of a nuclear power reactor referencing the design certification rule for which a departure is sought by the applicant.

• Requires the applicant to obtain an exemption from the referenced design certification rule if the proposed departure is inconsistent with one or more of the Commissions regulations. The exemption would be granted under the provisions of § 52.7 (which references the same criteria for the granting of exemptions that are set forth in § 50.12).\

C.III.1.7 Exemptions from the \Referenced \Certified Design The NRC regards an exemption from the \referenced \certified design as a potential critical path item in the review of a COL application. [I]\During pre-application interactions, i\t is recommended that COL applicants inform the NRC of the[ potential for an exemption during pre-application interactions.

As with departures, exemptions from the]\ir intent to request exemptions, including the number and nature of these exemptions, as part of their application.

A departure from the referenced\ certified design\ that requires an exemption from NRC regulations\ should be discussed in the section \of the application \that correspond\s\ to where the topic is discussed in the [design control document associated with the certified design referenced by the]\DCD.

The\ COL applicant\ should also include in the cover letter or other summary of a COL application that the application includes requests for specific exemptions\. Sufficient information should be provided\ within the appropriate section of the COL application\ for the NRC to resolve all safety and security issues [in its review of the exemption.]\related to the exemption as well as the regulatory basis for the exemption as described in 10 CFR 52.93. \ COL applicants should\ also\ consult Sections C.I.1 through C.I.19 of this guide for [the]\a more comprehensive set of\ information that needs to be included in the FSAR.

Information on the applicable design certification change processes is included in Section C.IV.3 of this guide.[

]\ In addition, COL applicants should identify or uniquely denote the information provided in the application, including the FSAR, that constitutes a departure from the referenced certified design that requires an exemption from NRC regulations.

The following definition of exemption is provided for COL applicants:

An exemption is a Commission-granted dispensation from compliance with one or more of the Commissions rules and regulations which would otherwise apply to an entity, a license, permit or other approval such as a standard design certification rule. Exemption from the requirements in any particular design certification rule would be provided under § 52.7. Exemption from an underlying technical requirement in Part 50 would be provided under § 50.12. This would be true even in the Commission adoption of a design certification rule. For example, if the design certification did not, at the time of final rulemaking, comply with a technical requirement in Part 50, the Commission would provide an exemption to that requirement as part of the final design certification rulemaking.

RG 1.206, Page C.III.1-20

Preliminary Work Product to Support Feb 13, 2007 Public Meeting

\

C.III.1.8 Verification of Consistency Between\ Referenced\ Certified Design and COL FSAR The NRC expects to verify that the information provided in the FSAR of a COL application is consistent with the \referenced \certified design. The NRC recommends that the COL application facilitate this review wherever possible.

C.III.1.9 Conformance of Site Characteristics with Site Parameters Per \10 CFR \Part 52[ - Licenses]\, Licenses\, Certifications, and Approvals for Nuclear Power Plants,[ Commission]\the NRCs\ review of a COL application that references a [design certification]\certified design\ will involve a comparison to ensure that the actual characteristics of the site chosen by the [combined license]\COL\ applicant fall within the site parameters in the design certification.

Additional guidance is provided in Section 1.8 of \Chapter 1, Introduction and General Plant Description, of \C.III.1.

If the COL application (FSAR) does not demonstrate that the site characteristics fall within the site parameters specified in the design certification, the application shall include a request for an exemption or departure, as appropriate, that complies with the requirements of the referenced design certification rule and \10 CFR \52.93.

C.III.1.10 Portions of a Final Safety Analysis Report not Addressed by a \Referenced \Certified Design The following chapters specify[,] the generic information that should be provided by the applicant when submitting a COL application\ that references a certified design\. While the intent of th[is]\e\

information\ provided in this guide\ is to facilitate the applicants effort to submit a complete and concise COL application, it may not be practical to identify in this guide all \the specific \information needed to meet the threshold required by a COL application.\ For example, it is not practical to identify the specific requirements for onsite electrical power systems and their support systems for plant designs that incorporate passive safety systems.\ Additionally, if information listed in the following subsections is not needed - such as being already provided in the specific, referenced DCD, it is suggested that the applicant indicate so in the appropriate portion of their FSAR.[

]\ COL applicants referencing a certified design should use the organization and numbering contained in the Tier 2 document of the referenced certified design. Additional guidance on referencing a certified design in a COL application is provided in Section C.IV.2 of this guide.

C.III.1.11 Completeness and Accuracy of the Referenced Certified Design COL applicants that reference a certified design are not required to revise the information included in the DCD for that certified design. However, pursuant to 10 CFR 52.6, each applicant or licensee that identifies information as having, for the regulated activity, a significant implication for public health and safety or common defense and security shall notify the Commission of this information.\

RG 1.206, Page C.III.1-21

Preliminary Work Product to Support Feb 13, 2007 Public Meeting Chapter 1. Introduction and General Plant Description Combined license (COL) applicants per 10 CFR 52, Subpart C, may [incorporate by ]reference designs that have been certified per 10 CFR 52, Subpart B, and early site permits per 10 CFR 52, [

]Subpart A. The guidance provided in Section C.III.1 of this regulatory guide is applicable to a COL applicant that references a certified design, but does not reference an early site permit (ESP).

Section IV, Additional Requirements and Restrictions, of the appendices to 10 CFR Part 52 codifying the certified designs, requires that COL applicants referencing the certified designs shall incorporate by reference, as part of its application, the applicable appendix codifying the certified design.

COL applicants referencing a certified design will, therefore, have a significant portion of their proposed facility design already reviewed by the NRC prior to submission of their application.

1.1 Introduction In this section, the COL applicant should \briefly \present[ briefly] the principal aspects of the overall application, including the type of license requested, the number of plant units\7\, a brief description of the proposed [location of the plant, the certified plant design incorporated by reference in the application]\plant location, the type of containment structure and its designer, the type of nuclear steam supply system and its designer, the core thermal power levels (both rated and design)\, the corresponding net electrical output [for the plant]\for each thermal power level\, and the scheduled completion date and anticipated commercial operation date of each unit. The [COL applicant should provide a general description or summary level information on the following areas]\following subsections address these aspects\ of the application.

1.1.1 Plant Location The COL applicant should provide plant location information\,\ such as [s]\the S\tate[,]\ and\

county,\ as well as one or more\ map(s) showing\ the\ site location and plant arrangement within the site, including [whether]\the extent (if any) to which\ the plant is co[-]located \and/or interfaces \with \a licensed, \existing [operating ]nuclear power [plants]\plant (i.e., within the existing exclusion area boundary)\.

1.1.2 Containment Type Included as part of the referenced certified design. No additional information needs to be provided by a COL applicant referencing a certified design.

1.1.3 Reactor Type Included as part of the referenced certified design. No additional information needs to be provided by a COL applicant referencing a certified design.

7 10 CFR Part 52.8 allows for an applicant to combine several applications for different kinds of licenses (e.g., a power reactor and an ISFSI) and to combine in a single license the activities of an applicant which would otherwise be licensed separately (e.g., identical units on same site). However, multiple applicants may not file for the same license.

RG 1.206, Page C.III.1-22

Preliminary Work Product to Support Feb 13, 2007 Public Meeting 1.1.4 Power Output The COL applicant should provide \approximate \net electrical output\ (for information only)\ as this rating may vary (core thermal power [rating is]\levels are\ provided as part of the referenced certified design).

1.1.5 Schedule The COL applicant should provide estimated schedules for completion of construction and commercial operation (estimates may be in durations rather than calendar dates based on application submittal date).\ As an alternative, COL applicants may include a commitment to provide the construction and startup schedules following issuance of the combined license and when a positive decision to construct the plant has been made by the licensee. \

1.1.6 Format and Content The COL applicant should provide information on the following aspects of the format and content of their application:

[]1.1.6.1[] Conformance with [regulatory guides on]\the\ format and content \guidance \of [a combined license application]\this regulatory guide\ (i.e.,[ DG-1145]\ Regulatory Guide 1.206\).

[]1.1.6.2[] Conformance with the standard review plan (NUREG-0800) [for technical guidance and]\in effect 6 months prior to application submittal date (i.e., evaluation of the differences in the design features, analytical techniques and procedural measures proposed for a facility and those corresponding features , techniques and measures given in the SRP\

acceptance criteria\)\. Guidance on providing conformance evaluations with individual SRPs is discussed in C.III.1, Section 1.9 of this regulatory guide.

[]1.1.6.3[] The format, content, and numbering for text, tables, and figures included in the application and a discussion on their use should be provided in the application.

1.1.6.4[] Format for numbering of pages should be discussed in the application.

1.1.6.5[] The method by which proprietary information is identified and referenced should be discussed.

1.1.6.6[] A list of acronyms used in the application should be provided. For applicants referencing a certified design, the acronyms provided in the DCD should be used for consistency and a supplemental list of acronyms for items not included in the \referenced \certified design should be provided, as necessary.

Note that Section IV, [Additional]\Additional\ Requirements and Restrictions,\\ of the appendices to Part 52 codifying the certified designs, require that COL applicants referencing the certified designs include the same organization and numbering as the \referenced \certified design, as modified and supplemented by the applicants exemptions and departures.\ COL applicants referencing a certified RG 1.206, Page C.III.1-23

Preliminary Work Product to Support Feb 13, 2007 Public Meeting design should use the organization and numbering contained in the Tier 2 document of the certified design.

\

1.2 General Plant Description In this section, the COL applicant referencing a certified design should include a summary description of the principal characteristics of the site and a concise description of the facility and supplemental information to that \which is \included in the referenced certified design. In particular, the supplement should include a brief discussion of the principal design criteria, operating characteristics, and safety considerations for the portions of the facility not included in the \referenced \certified design. The general arrangement of major site-specific structures and equipment should be indicated by the use of plan and elevation drawings in sufficient number and detail to provide a reasonable understanding of the general layout of the plant.\8\ Those site-specific features of the plant likely to be of special interest because of their relationship to safety should be identified. Such items as unusual site characteristics, solutions to particularly difficult engineering and/or construction problems (e.g., modular construction techniques or plans) and significant extrapolations in technology represented by the design should be highlighted.

1.3 Comparisons with Other Facilities Included as part of the referenced certified design. No additional information needs to be provided by a COL applicant referencing a certified design.

1.4 Identification of Agents and Contractors In this section, the COL applicant referencing a certified design should identify the prime agents or contractors for the design, construction and operation of the nuclear power plant. Some of this information may have been included in the DCD for the \referenced \certified design. Any additional information provided should supplement the DCD information.

The principal consultants and outside service organizations (such as those providing audits of the quality assurance program) should be identified. The division of responsibility between the [certified plant]\reactor/facility\ designer\(s)\, architect-engineer, constructor, and plant operator should be delineated.

1.5 Requirements for Further Technical Information The requirements for further technical information are included as part of the referenced certified design. The COL applicant that references a certified design should identify any requirements for further technical information in their application for the portions of the facility that are not certified, including an estimated schedule for providing the additional technical information that \was not provided with the initial COL application submittal and which \may be necessary for issuance of a combined license.

8 The general arrangement drawings of buildings other than primary containment may warrant designating as sensitive unclassified non-safeguards information in accordance with the agency guidance described in SECY-04-0191, Withholding Sensitive Unclassified Information Concerning Nuclear Power Reactors from Public Disclosure.

RG 1.206, Page C.III.1-24

Preliminary Work Product to Support Feb 13, 2007 Public Meeting 1.6 Material Referenced In this section, the COL applicant that references a certified design should supplement the information included in the \DCD for the referenced \certified design by providing a supplemental tabulation of any additional topical reports incorporated by reference as part of the application (i.e., topical reports in addition to those incorporated by reference into the DCD). In this context, topical reports are defined as reports that have been prepared by reactor designers, reactor manufacturers, architect-engineers, or other organizations and filed separately with the NRC in support of this application or of other applications or product lines. \For example, some COL applicants may choose to incorporate optional design features for a referenced certified design that have been approved as part of a vendor-submitted topical report but have not been included in the DCD for the referenced certified design (e.g., zinc addition system for primary water treatment system).

\Th[is]\e\ tabulation\ discussed above\ should include, for each topical report, the title, the report number, the date submitted to the NRC, and the sections of the COL application in which the report is referenced. For any topical reports that have been withheld from public disclosure pursuant to Section 2.[790]\390\(b) of 10 CFR Part 2 as proprietary documents, nonproprietary summary descriptions of the general content of such reports should also be referenced. This section should also include a tabulation of any documents submitted to the Commission in other applications that are incorporated in whole or in part in this application by reference. If any information submitted in connection with other applications is incorporated by reference in this application, summaries of such information should be included in appropriate sections of this application. Results of tests and analyses may be submitted as separate reports.

In such cases, these reports should be referenced in this section and summarized in the appropriate section of the FSAR.

1.7 Drawings and Other Detailed Information In this section, the COL applicant that references a certified design should supplement the information included in the \referenced \certified design by providing a supplemental tabulation of the additional and/or updated instrument and control functional diagrams, electrical one-line diagrams cross-referenced to application section, including legends for electrical power, instrument and control, lighting, and communication drawings.

In addition, the COL applicant should provide a supplemental tabulation for systems not included in the design certification of system drawings and system designators that are cross-referenced to applicable section\s\ of the application. The information should include the applicable drawing legends and notes.

RG 1.206, Page C.III.1-25

Preliminary Work Product to Support Feb 13, 2007 Public Meeting 1.8 Site and Plant Design Interfaces and Conceptual Design Information The requirements of[ proposed] 10 CFR 52.79(d) specify that COL applicants referencing a certified design must provide sufficient information to demonstrate that the characteristics of the site fall within the site parameters specified in the design certification and must contain information sufficient to demonstrate that the interface requirements established for the design under §52.47 have been met. In addition,Section IV, [Additional]\Additional\ Requirements and Restrictions,\\ of the appendices to Part 52 codifying the certified designs, require\s\ that COL applicants referencing the certified designs[ to]

provide information that addresses the COL action items, and[ to provide] reports on generic changes and plant-specific departures from the\ referenced\ certified design. COL applicants that reference a certified design should provide a discussion in this section that demonstrates how the interface requirements identified in the \referenced \certified design have been met.\ If not specifically discussed in Section 1.8 of the FSAR, COL applicants should provide a cross-referenced tabulation identifying the specific FSAR sections that provide discussions to demonstrate how the site interface requirements identified in the certified design have been met.

\

Appendix A to Regulatory Guide 1.70 provides guidance on interfaces for standard designs, however, this guidance was developed for standard design concepts that existed prior to the codification of 10 CFR Part 52. During the development of designs for certification per Subpart B of 10 CFR Part 52, however, reactor vendors utilized the guidance provided in Appendix A of [Reg.]\Regulatory\ Guide 1.70 to more clearly define the interfaces between certified designs and the remainder of the proposed facility design (i.e., site-specific designs) that are necessary, per 10 CFR 52.47, for a combined license application per Subpart C of 10 CFR Part 52. These site interfaces are \typically \identified and discussed in Section 1.8 of the DCD\s\ for the\ referenced\ certified [design]\designs that have been\ codified in the [applicable appendix]\appendices\ to 10 CFR Part 52. These interfaces include requirements for completing site-specific designs for the facility, developing the operational programs for the facility, and verifying that the proposed site for the facility is in compliance with the site parameters upon which the \referenced \certified design is based. Site parameters assumed in design certifications may be found in the Tier 1 section of the DCD.

\ In addition, applicants for design certification included conceptual designs in their DCDs[ in order] to facilitate NRC staff review by providing a more comprehensive design perspective. The portions of the design provided in the DCD that are conceptual, and were not certified, are also identified and discussed in Section 1.8 of the DCD for the \referenced \certified design. These conceptual designs typically included portions of the balance-of-plant. COL applicants that reference a certified design are expected to provide complete designs for the entire facility including appropriate site-specific design information to replace the conceptual design portions of the DCD for the referenced certified design.

[Where this]\Replacement of the conceptual design information in a DCD with actual design information is not considered a departure from the referenced certified design because the conceptual design was not certified. However, where the actual design\ information differs from the conceptual design information

[assumed for]\provided in\ the [design certifications]\DCD\, the COL applicant should address the impact of these differences on the \NRCs evaluation of the referenced \certified design and the design PRA\, as applicable\. The level of detail needed for the site-specific designs that replace conceptual designs should be consistent with the level of detail provided in the DCD for the non-conceptual (or specific) designs and should be sufficient to resolve all safety issues.

\

\ In addition to the above, reactor vendors for certified designs included a list of information items or action items that a COL referencing that \specific \certified design is required to address. These COL RG 1.206, Page C.III.1-26

Preliminary Work Product to Support Feb 13, 2007 Public Meeting information items include\:\ providing completed design information for the remainder of a proposed facility referencing a certified design, verification of site parameters, completion of analyses and design reports for as-built plant systems, development and implementation of operational programs, completion of designs included in design acceptance criteria, etc. [COL applicants should provide a]\In addition to the\

cross-referenced tabulation [identifying where in the FSAR the]\on\ verification of site [parameters is located. In addition]\interface requirements\, COL applicants should provide a cross-referenced tabulation identifying [where in ]the\ specific\ FSAR\ sections in which\ the COL information items \from the referenced certified design \are addressed.[

]\ \Additional [recommendations]\guidance\ for addressing COL information items [are]\is\

included in Section C.III.4 of this guide.

[

]

1.9 Conformance with Regulatory Criteria 1.9.1 Conformance with Regulatory Guides The requirements of [proposed] 10 CFR 52.79(a)(4)(i) specify that the contents of a combined license application must include information on the design of the facility, including the principal design criteria for the facility. [10 CFR 50, ]Appendix A\ to 10 CFR 50\, General Design Criteria for Nuclear Power Plants, establishes minimum requirements for the principal design criteria for water-cooled nuclear power plants similar in design and location to plants for which construction permits have previously been issued by the Commission and provides guidance to applicants in establishing principal design criteria for other types of nuclear power units. Regulatory Guides, in general, describe methods acceptable to the NRC staff for implementing the criteria associated with the General Design Criteria.

COL Applicants That Reference a Certified Design

[Applicants for design certification also have a requirement to include information on the design of the facility, including the principal design criteria for the facility. This also includes conformance with Regulatory Guides, as discussed above. Designs for which certification has been provided are included in the appendices to 10 CFR Part 52. ]Certified designs have already provided information addressing conformance with Regulatory Guides that were in effect 6 months before the [docket]\submittal\ date of the design certification application. In accordance with the provisions of 10 CFR 52.63, Finality of standard design certifications, COL applicants that reference a certified design are not required to re-address conformance with Regulatory Guides for the portions of the facility design included in the

\referenced \certified design. However, a COL applicant should address conformance with Regulatory Guides in effect 6 months before the [docket]\submittal\ date of the COL application for the site-specific portions of the facility design [which]\that\ are not included in the\ referenced\ certified design. In addition, the COL applicant should address conformance with Regulatory Guides in effect 6 months before the [docket]\submittal\ date of the COL application insofar as they pertain to operational aspects of the facility.

For a COL application that includes departures from the \referenced \certified design, these departures should be evaluated for conformance with the Regulatory Guides in effect 6 months before the

[docket]\submittal\ date of the COL application, unless the departure is included in a Topical Report. In the case of a Topical Report, the departure from the\ referenced\ certified design should be evaluated for conformance with the Regulatory Guides in effect 6 months before the submittal date of the Topical Report.

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Preliminary Work Product to Support Feb 13, 2007 Public Meeting

\ Consistent with the guidance provided above, COL applicants should provide an evaluation of conformance with the following Regulatory Guides for those portions of the facility design not included in the certified design:

Division 1, Power Reactors Division 4, Environmental and Siting (applies to Environmental Report and should be discussed therein)

Division 5, Materials and Plant Protection (applies to Security Plan and should be discussed therein)

Division 8, Occupational Health

\COL Application Timing In addition, it is expected that the timing of design certification and COL application submittal may differ by a considerable [number]\length\ of [years]\time\ (i.e., a design certification is valid for 15 years and COL applications that reference a certified design may do so at any point during the valid life of the design certification). Therefore, the revision level of Regulatory Guides that a COL applicant should address might differ considerably from those addressed in the \referenced \certified design. For example, in the years following issuance of a design certification, new revisions to Regulatory Guides may have been issued by the NRC staff that should be addressed by the COL applicant for the portions of the facility design not included in the [certified design. For example, if a design was certified in December 2005, new revisions to Regulatory Guides issued after December 2005 need not be addressed by the COL applicant for the portions of the facility design included in the]\referenced\ certified design. The COL applicant should, however, address those Regulatory Guide revisions issued after [December 2005]\the Regulatory Guides that were evaluated in the DCD for the referenced certified design and\ only insofar as they may impact site-specific portions of the facility design not included in the\ referenced\ certified design. In addition, the COL applicant should address conformance with the Regulatory Guides in effect 6 months before the [docket]\submittal\ date of the COL application insofar as they pertain to operational aspects of the facility.\ Operational aspects of the facility may have been included as COL information items in the DCD for the referenced certified design. Additional guidance on COL information items is included in Section C.III.4 of this guide.\

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Preliminary Work Product to Support Feb 13, 2007 Public Meeting 1.9.2 Conformance with [Standard]\Application and\ Review [Plan]\Guidance\

The requirements of [proposed]\\ 10 CFR 52.79(a)(41) specify that for applications for light-water cooled nuclear power plant combined licenses, COL applicants should provide an[ ]\ \evaluation of the facility against the [Standard Review Plan (SRP)]\NRCs application and review guidance\ in effect 6[

]\ \months before the docket date of the application.\9\ The evaluation required by this section[ ]\ \shall include an identification and description of all differences in design features, analytical techniques\,\ and procedural measures proposed for [a]\the\ facility and those corresponding features, techniques\,\ and measures given in the [SRP ]acceptance criteria\ in the application and review guidance\. Where[ a]

difference\s\ exist[s], the evaluation [shall]\should\ discuss how the proposed alternative provides an acceptable method of complying with the Commissions regulations, or portions thereof, that underlie the corresponding [SRP ]acceptance criteria. The [SRP was issued to establish criteria that the NRC staff intends to use in evaluating whether an applicant or licensee meets the Commissions regulations. The SRP]\NRCs application and review guidance\ is not a substitute for the regulations, and compliance is not a requirement.

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\COL Applicants That Reference a Certified Design

[Applicants for design certification also have a requirement in proposed 10 CFR 52.47(a)(26) to provide an evaluation of the facility against the Standard Review Plan (SRP) in effect 6 months before the docket date of the design certification application. Designs for which certification has been provided are included in the appendices to 10 CFR 52. ]Certified designs have already provided information addressing conformance with the \standard review plan (\SRP\)\ that [were]\was\ in effect 6 months before the

[docket]\submittal\ date of the design certification application. In accordance with the provisions of 10 CFR 52.63, Finality of standard design certifications, COL applicants that reference a certified design are not required to re-address conformance with the SRP for the portions of the facility design included in the \referenced \certified design. However, a COL applicant should address conformance with the SRP in effect 6 months before the [docket]\submittal\ date of the COL application for the site-specific portions of the facility design which are not included in the\ referenced\ certified design. In addition, the COL applicant should address conformance with the SRP insofar as they pertain to operational aspects of the facility.\ Operational aspects of the facility may have been included as COL information items in the DCD for the referenced certified design. Additional guidance on COL information items is included in Section C.III.4 of this guide.\

There may be cases where a \referenced \certified design addresses SRP conformance on design-related issues for which the COL applicants operationally-related issues/programs are dependent (e.g., fire protection). In such cases, where the SRPs applicable to the \referenced \certified design have been revised/updated, the COL applicant may address conformance with the version of the SRP evaluated in the\ referenced\ certified design even though a later revision of the SRP is in effect. However, it is expected that the COL applicant, in this situation, will identify and justify a deviation or exception from conformance with the SRP in effect 6 months before the [docket]\submittal\ date of the COL application.

9 The review guidance is the standard review plan (SRP) contained in NUREG-0800. The SRP was issued to establish criteria that the NRC staff intends to use in evaluating whether an applicant/licensee meets the Commissions regulations. The SRP is not a substitute for the NRCs regulations, and compliance is not a requirement.

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Preliminary Work Product to Support Feb 13, 2007 Public Meeting For a COL application that includes departures from the\ referenced\ certified design, these departures should be evaluated for conformance with the Standard Review Plan in effect 6 months before the [docket]\submittal\ date of the COL application, unless the departure is included in a Topical Report.

In the case of a Topical Report, the departure from the\ referenced\ certified design should be evaluated for conformance with the Standard Review Plan in effect 6 months before the submittal date of the Topical Report.

COL Application Timing In addition, it is expected that the timing of design certification and COL application submittal may differ by a considerable [number]\length\ of [years]\time\ (i.e., a design certification is valid for 15 years and COL applications referencing a certified design may do so at any point during the valid life of the design certification). Therefore, the revision level of SRPs that a COL applicant should address may also differ from those addressed in the \referenced \certified design. For example, in the years following issuance of a design certification, new revisions to SRPs may \have \be\en\ issued by the NRC staff and should be addressed by the COL applicant.[ For example, if a design was certified in December 2005, new revisions to SRPs issued after December 2005 need not be addressed by the COL applicant for the portions of the facility design included in the certified design.] The COL applicant should, however, address those SRP revisions issued after [December 2005]\the SRPs evaluated in the DCD for the referenced certified design and\ only insofar as they may impact site-specific portions of the facility design not included in the\

referenced\ certified design. In addition, the COL applicant should address conformance with SRPs in effect 6 months before the [docket]\submittal\ date of the COL application as they pertain to operational aspects of the facility.

1.9.3 Generic Issues The requirements of [proposed] 10 CFR 52.79(a)(20) specify that the contents of a combined license application must include the proposed technical resolutions of those unresolved safety issues and medium- and high-priority generic safety issues that are identified in the version of NUREG-0933 current on the date 6 months before application and that are technically relevant to the design.

Since the inception of the generic issues program in 1976, the NRC has identified and categorized reactor safety issues. These safety issues were grouped into TMI Action Plan Items, Task Action Plan Items, New Generic Items, Human Factors Issues, and Chernobyl Issues and are collectively called Generic Safety Issues (GSIs). [A listing of these GSIs (i.e., those]\Section C.IV.8 of this regulatory guide provides additional guidance for addressing the\ unresolved safety issues and medium- and high-priority [generic safety issues]\GSIs\ that are identified in NUREG-0933[ through Supplement 29) has been provided in Section C.IV.8, Generic Issues, of this guide for use by COL applicants. A review of these GSIs was performed to determine whether they have been closed by other NRC actions or requirements. Those issues that remain open and which are technically relevant to the COL applicants design should be addressed in the application].

COL Applicants That Reference a Certified Design

[Applicants for design certification also have a requirement for addressing unresolved safety issues in proposed 10 CFR 52.47(a)(18). Designs for which certification has been provided are included in the appendices to 10 CFR Part 52. ]Certified designs have already provided, and have had approved, their proposed technical resolutions of those unresolved safety issues and medium- and high-priority generic RG 1.206, Page C.III.1-30

Preliminary Work Product to Support Feb 13, 2007 Public Meeting safety issues that were identified in the version of NUREG-0933 that was current on the date 6 months before application and that were technically relevant to the design. In accordance with the provisions of 10 CFR 52.63, [Finality]\Finality\ of standard design certifications,\\ COL applicants that reference a certified design are not required to re-propose technical resolutions for the portions of the facility design included in the\ referenced\ certified design as these have already been approved. However, a COL applicant should address any and all applicable unresolved safety issues and medium- and high-priority generic safety issues identified in NUREG-0933, as discussed above, for the site-specific portions of the facility design which are not included in the \referenced \certified design. In addition, the COL applicant should address these generic issues insofar as they pertain to operational aspects of the facility. \

Operational aspects of the facility may have been included as COL information items in the DCD for the referenced certified design. Additional guidance on COL information items is included in Section C.III.4 of this guide.\

COL applicants that reference a certified design should perform a review of the applicability of generic issues that are technically relevant to the site-specific portions of the facility design that are not included in the referenced certified design. An assessment of the applicable generic issues with respect to the site-specific portions of the facility design should be provided. The COL applicant should include the results of the applicability review and assessment in their application.

In addition, certified designs may include COL action or information items related to generic issues. COL applicants must also address those generic issues that have been identified in the [design control documents]\DCDs\ for\ referenced\ certified designs as the responsibility of the COL applicant.

These generic issues typically involve operational aspects of the facility and may include design aspects of the facility for which no specific design or conceptual designs were provided in the \referenced \certified design.

For a COL application that includes departures from the\ referenced\ certified design, these departures should be evaluated for compliance with the generic issues that are technically relevant and in effect 6 months before the [docket]\submittal\ date of the COL application, unless the departure is included in a Topical Report. In the case of a Topical Report, the departure from the\ referenced\ certified design should be evaluated for compliance with the generic issues that are technically relevant in effect 6 months before the submittal date of the Topical Report.

COL Application Timing In addition, it is expected that the timing of design certification and COL application submittal may differ by a considerable [number]\length\ of [years]\time\ (i.e., a design certification is valid for 15 years and COL applications referencing a certified design may do so at any point during the valid life of the design certification). Therefore, the set of generic issues that a COL applicant should review and assess may also differ from those addressed in the \referenced \certified design. For example, in the years following issuance of a design certification, new generic issues may be identified by the NRC staff and which should be addressed by the COL applicant. That is, [if a design was certified in December 2005,

]new generic issues that \were \included in \the revisions/supplements of \NUREG-0933 [after December 2005]\issued after the revision/supplement referenced in the DCD for the referenced certified design\ need not be addressed by the COL applicant for the portions of the facility design included in the \referenced

\certified design. The COL applicant should address the[se] generic issues in effect 6 months before the

[docket]\submittal\ date of the COL application only insofar as they may impact site-specific portions of the facility design not included in the \referenced \certified design. In addition, the COL applicant should address the[se] generic issues in effect 6 months before the [docket]\submittal\ date of the COL application insofar as they pertain to operational aspects of the facility.

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Preliminary Work Product to Support Feb 13, 2007 Public Meeting Backfit Issues The resolution of generic issues that were not resolved prior to design certification includes two categories[,]\;\ those identified generic issues for which resolution efforts were still in progress at the time of design certification, and new generic issues that were identified following design certification. These generic issues may be related to the existing fleet of operating reactors licensed under Part 50 or the new reactor designs certified and licensed to operate under the applicable provisions in Part 52. Should the NRC determine that resolution of a generic issue, included in the two categories discussed above, requires implementation on a new plant design, the implementation requirement would be in accordance with the backfit provisions specified in Section VIII for the applicable certified designs in the Part 52 appendices and in 10 CFR 52.63.

Backfits related to specific certified designs will be implemented on a COL plant-specific basis in accordance with Section VIII for the applicable certified design appendix in Part 52 and in accordance with 10 CFR 52.63. Implementation of the backfit on a certified design may occur prior to the issuance of a COL which references the affected certified design or following issuance of the COL, as necessary\,\ to ensure the health and safety of the public.

1.9.4 Operational Experience (Generic Communications)

[A listing of generic communications (i.e.,]\The requirements of 10 CFR 52.79(a)(37) specify that the contents of a COL application must include information to demonstrate how operating experience insights from generic letters and bulletins issued after the most recent revision of the applicable standard review plan and 6 months before the docket date of the application, or comparable international operating experience, have been incorporated into the plant design.

To ensure that the operational experience described in\ generic letters and bulletins [that had been issued prior to date of issuance of DG-1145) has been provided in Section C.IV.8 of this guide for use by COL applicants. A review of these generic communications was performed to determine whether they have been superceded by other NRC generic communications, NRC actions or requirements. Those]\from decades of nuclear power plant operation in the United States was captured in the knowledge base for reviewers and applicants, the insights from these generic letters and bulletins were incorporated in the updates to applicable standard review plans10. To ensure that applicants consider the operational experience incorporated in these standard review plan (SRP) updates, applicants whose plant designs are based on or are evolutions of plants that have operated in the United States are required by 10 CFR 52.79(a)(41) to evaluate their facility design against the review guidance (i.e., SRPs) in effect 6 months before the docket date of the application. In addition, applicants are required to demonstrate how the operating experience insights from generic letters and bulletins issued after the review guidance update (i.e., approx. March 2007) have been incorporated into the plant design (i.e., address those\ generic communications [that remain open and which are technically relevant to the COL applicants facility design, including operational aspects of the facility, should be addressed in the application.]\issued after the SRP update). \

COL Applicants That Reference a Certified Design 10 The SRP was updated in March 2007 to support COL applications for new nuclear power plants that were planned to be submitted to the NRC as early as September 2007.

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Preliminary Work Product to Support Feb 13, 2007 Public Meeting

[Applicants for design certification also have a requirement for addressing generic communications in proposed 10 CFR 52.47(a)(19). Designs for which certification has been provided are included in the appendices to 10 CFR 52. ]Certified designs have already provided information which demonstrates how operating experience insights from generic letters and bulletins \in effect/issued \up to 6 months before the [docket]\submittal\ date of the application, or comparable international operating experience, have been incorporated into the \referenced \certified design. In accordance with the provisions of 10 CFR 52.63, [Finality]\Finality\ of standard design certifications,\\ COL applicants that reference a certified design are not required to re-demonstrate how operating experience insights from generic letters and bulletins \in effect/issued \up to 6 months before the [docket]\submittal\ date of the design certification application, or comparable international operating experience, have been incorporated into the portions of the facility design included in the \referenced \certified design. However, [a ]COL applicant\s\ that reference[s] a certified design should address [any and all operating experience insights from generic letters and bulletins up to 6 months before the docket date of the COL application for the site-specific]\only those generic communications that are applicable to the\ portions of [the]\their proposed\

facility[ design which are] not included in the [certified design]\design certification and which have been issued after the SRP update (see footnote 3)\.

In addition, certified designs may include COL action or information items related to operational experience. COL applicants must also address those generic letters and bulletins that have been identified in the design control documents for\ referenced\ certified designs as the responsibility of the COL applicant. These generic letters and bulletins typically involve operational aspects of the facility and may include design aspects of the facility for which no specific design or conceptual designs were provided in the \referenced \certified design.\ Additional guidance on COL information items is provided in Section C.III.4.\

For a COL application that includes departures from the \referenced \certified design, these departures should address the applicable generic letters and bulletins \in effect/issued \up to 6 months before the [docket]\submittal\ date of the COL application\ and which were issued after the SRP update\,

unless the departure is included in a Topical Report. In the case of a Topical Report, the departure from the \referenced \certified design should address the applicable generic letters and bulletins \in effect/issued

\up to 6 months before the submittal date of the Topical Report\ and issued after the SRP update\.

COL Application Timing In addition, it is expected that the timing of design certification and COL application submittal may differ by a considerable [number]\length\ of [years]\time\ (i.e., a design certification is valid for 15 years and COL applications referencing a certified design may do so at any point during the valid life of the design certification). Therefore, the set of generic communications that a COL applicant should address may also differ from those addressed in the \referenced \certified design. For example, in the years following issuance of a design certification, new generic letters and bulletins may be issued by the NRC staff and should be addressed by the COL applicant. That is, [if a design was certified in December 2005,

]new generic letters and bulletins issued after [December 2005]\those addressed in the DCD for the referenced certified design\ need not be addressed by the COL applicant for the portions of the facility design included in the \referenced \certified design. The COL applicant should, however, address those

\new \generic letters and bulletins issued after [December 2005 only]\those addressed in the DCD for the referenced certified design and issued after the SRP update\ insofar as they may impact site-specific portions of the facility design not included in the\ referenced\ certified design.

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Preliminary Work Product to Support Feb 13, 2007 Public Meeting

[Comparable International Operating Experience Applicants for certified design and applicants for a combined license are required to address]\

Alternatively, COL applicants whose plant design is not based on or is an evolution of plants that have operated in the United States should demonstrate how\ comparable international operating experience

[in accordance with proposed 10 CFR 52.49(a)(19) and 10 CFR 52.79(a)(37), respectively. To the extent that the design or portions of the design for which certification or a COL is sought originates or is based on international design, the design certification or COL application should address how international operating experience has contributed to the design process]\has been incorporated into their plant design\.

Nuclear industry regulators or [industry ]owners groups in[ ]\ \countries that include nuclear reactor vendors and/or nuclear power plants (e.g., Canada, France, Germany, Japan, etc.) may track, maintain, and/or issue operating experience bulletins or[ ]\ \reports similar to the NRCs generic letters and bulletins.

[The applicant for design certification or a COL]\The COL applicant referencing a certified design\ should address how [this body of]\the applicable\ operating experience [information ]has been assessed [or incorporated]\and/or incorporated\ into the \portions of the plant \design[. Applicants for]\ not included in the\ design certification[ and combined license are responsible for procuring any]\, as applicable. COL applicants should consult organizations such as the Institute for Nuclear Power Operations (INPO) or the World Association of Nuclear Operators (WANO) for applicable comparable\ international operating experience[ information].

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