ML17013A624
| ML17013A624 | |
| Person / Time | |
|---|---|
| Issue date: | 10/03/2018 |
| From: | Hayes B NRC/NRO/DEIA/NRGB |
| To: | |
| Barbara Hayes 415-7442 | |
| Shared Package | |
| ML16326A144 | List: |
| References | |
| DG-1325, RG-1.206, Rev 1 | |
| Download: ML17013A624 (3) | |
Text
REGULATORY ANALYSIS DRAFT REGULATORY GUIDE DG-1325 APPLICATIONS FOR NUCLEAR POWER PLANTS (Proposed Revision 1 of Regulatory Guide 1.206, Revision 0 dated July 2007)
- 1. Statement of the Problem The U.S. Nuclear Regulatory Commission (NRC) is considering revising Regulatory Guide 1.206, Combined License Applications for Nuclear Power Plants, to reflect lessons learned about the review of large light-water nuclear power plant applications under Title 10 of the Code of Federal Regulations (10 CFR) Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants.
The NRC published the original version of RG 1.206 in 2007 with the title Combined License Applications for Nuclear Power Plants (LWR Edition) to provide general guidance related to applications for Combined Licenses for nuclear power plants. The current version of Regulatory Guide 1.206 does not provide guidance on related applications under 10 CFR Part 52 for a design certification (DC), an early site permit (ESP), and only limited guidance on limited work authorization (LWA) applications.
Additionally, the current version of RG 1.206 contains a detailed description of the technical information to be included in a COL applications safety analysis report (SAR), which has substantial overlap with NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition (SRP). The SRP contains guidance for the NRC staff to perform safety reviews of applications and describes methods or approaches that the staff previously has found acceptable for meeting NRC requirements.
- 2. Objective The objective of this regulatory action is to assess the need to revise NRC guidance by updating to guidance on applications for COL based on lessons learned, adding new guidance related applications for DC, ESP and LWA, and removing the detailed description of technical information to be included in SARs that has significant overlap with the SRP.
- 3. Alternative Approaches The NRC staff considered the following alternative approaches:
- 1. Do not revise RG 1.206
- 2. Withdraw RG 1.206
- 3. Revise RG 1.206 by adding guidance on applications for DC, ESP and LWA; updating guidance on COL applications; and removing detailed technical guidance on SARs.
Alternative 1: Do Not Revise Regulatory Guide 1.206 Under this alternative, considered the no-action alternative, the NRC would not issue additional guidance, and the current guidance would be retained. If NRC does not take action, there would not be any changes in costs or benefit to the public, licensees or NRC. However,
the no-action alternative would result in a divergence between the detailed application guidance related to SARs and revised technical guidance to staff on SARs found in the SRP.
The no-action alternative would also not provide guidance on applications for DC, ESP and LWA, nor would it reflect lessons learned since the initial issuance of RG 1.206. This alternative provides a baseline condition from which any other alternatives will be assessed.
Alternative 2: Withdraw Regulatory Guide 1.206 Under this alternative the NRC would withdraw this RG. This would eliminate the problems with divergence between RG 1.206 technical guidance on SARs and guidance to staff found in the SRP. It would also eliminate valuable, albeit old, guidance to applicants on the form and content of COL applications. Although this alternative would be less costly in the short term than the proposed alternative, it would have a negative impact on future COL applications due to a lack of guidance. This would in turn impede the staffs ability to review COL applications in a timely and cost-effective manner, and would be more costly to both applicants and the staff in the long term.
Alternative 3: Revise Regulatory Guide 1.206 Under this alternative, the NRC would revise RG 1.206. This revision would provide unified, updated guidance on the administrative and procedural aspects of applications for COL, DC, ESP and LWA. It would also satisfy the two remaining action items from NRCs April 2013 Lessons Learned Report (ADAMS Accession No. ML13059A240) by (1) revising RG 1.206 to reflect lessons learned and (2) incorporating DC/COL ISG11, Finalizing Licensing Basis Information, (ADAMS Accession No. ML092890623) in the revised RG 1.206. Revision of RG 1.206 will additionally allow the incorporation and retirement of three additional ISGs:
ESP/DC/COL-ISG-015, Post Combined License Commitments (ADAMS Accession No. ML091671355), DC/COL-ISG-08, Necessary Content of Plant-Specific Technical Specification When a Combined License is Issued (ADAMS Accession No. ML083310259), and COL/ESP-ISG-04, Definition of Construction and on Limited Work Authorizations (ADAMS Accession No. ML082970729). In addition, the removal of detailed technical information on the format and content of a SAR would simplify the update of technical guidance for SARs and reduce the risk of divergence of redundant guidance. Information on introducing guidance into future revisions of the SRP (and related RGs, as appropriate) will be included in the revised RG.
The impact to the NRC would be the costs associated with preparing and issuing the RG revision. The impact to the public would be the voluntary costs associated with reviewing and providing comments to the NRC during the public comment period. The value to NRC staff and applicants would be the benefits associated with enhanced efficiency and effectiveness in using a common guidance document related to COL, DC, ESP and LWA applications.
Conclusion Based on this regulatory analysis, the NRC staff concludes that revision of RG 1.206 is warranted. The action will make available to the staff, applicants and public the most current regulatory guidance in this area and enhance the efficiency and effectiveness of the licensing process for new nuclear power plants. It could also lead to cost savings for applicants by reducing the time spent by the NRC staff reviewing the application.
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