ML19213A343
| ML19213A343 | |
| Person / Time | |
|---|---|
| Issue date: | 09/30/2019 |
| From: | Office of Nuclear Regulatory Research |
| To: | |
| Eudy M | |
| Shared Package | |
| ML19213A339 | List: |
| References | |
| RG-1.188 DG-1341 | |
| Download: ML19213A343 (3) | |
Text
REGULATORY ANALYSIS DRAFT REGULATORY GUIDE DG-1341 STANDARD FORMAT AND CONTENT FOR APPLICATIONS TO RENEW NUCLEAR POWER PLANT OPERATING LICENSES (Proposed Revision 2 of Regulatory Guide 1.188, dated July 2019)
- 1. Statement of the Problem The U.S. Nuclear Regulatory Commission (NRC) is considering revising Regulatory Guide (RG) 1.188 to update references to the appropriate guidance and extend the guidance to applications for subsequent license renewal. The current version of RG 1.188 (Revision 1) does not reference the most recent industry guidance for license renewal and subsequent license renewal as discussed below.
The NRC published Revision 1 of RG 1.188, Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses, in September 2005 to provide licensees and applicants with agency-approved guidance for complying with Title 10, of the Code of Federal Regulations, Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants (10 CFR 54). Revision 1 endorsed industry guidelines for license renewal in Nuclear Energy Institute (NEI) 95-10 Industry Guideline for Implementing the Requirements of 10 CFR Part 54The License Renewal Rule.
Since 2005, the industry has developed revised guidance on license renewals to address standard review plans, aging management programs and the development of subsequent license renewal documentation and issued it in Revision 6 to NEI 95-10. The proposed revision to the guide RG would update the staffs endorsement of NEI 95-10 to Revision 6.
In addition, NEI has developed NEI 17-01, Industry Guideline for Implementing the Requirements of 10 CFR Part 54 for Subsequent License Renewal, dated December 2017. NEI 17-01 provides an approach acceptable to the staff for implementing the requirements of 10 CFR Part 54 for subsequent license renewal. The proposed revision to the guide RG would also endorse NEI 17-01.
- 2. Objective The objective of this regulatory analysis is to assess the need to update NRC guidance and provide applicants with a method to demonstrate compliance with the 10 CFR Part 54 requirements for license renewal and subsequent license renewal applications.
Revising this regulatory guide to endorse NRC approved industry guidance is consistent with the NRC policy of evaluating the latest versions of industry guidance to determine their suitability for endorsement by regulatory guides. This approach also will comply with the NRCs Management Directive (MD-6.5) - NRC Participation in the Development and Use of Consensus Standards. This is in accordance with Public Law 104-113, National Technology Transfer and Advancement Act of 1995.
- 3. Alternative Approaches The NRC staff considered the following alternative approaches:
- 1. Do not revise Regulatory Guide 1.188
- 2. Withdraw Regulatory Guide 1.188
- 3. Revise Regulatory Guide 1.188 to address the current methods and procedures.
Alternative 1: Do Not Revise Regulatory Guide 1.188 Under this alternative, the NRC would not revise [or issue additional] guidance, and the current guidance would be retained. This alternative is considered the no-action alternative and provides a baseline condition from which any other alternatives will be assessed. 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 not address identified concerns with the current version of the regulatory guide or endorse the newly developed industry guidance, NEI 17-01. The NRC would continue to review each application on a case-by-case basis. On January 31, 2018, the NRC granted a temporary endorsement of NEI 17-01 for 4 licensees who plan to submit SLRs before the end of CY 2019 (ML18029A368) and indicated that a revision to RG 1.188 is expected to be completed by CY 2019 which would endorse NEI 17-01 and supersede the temporary endorsement accordingly. Not revising RG 1.188 would leave industry and NRC without an endorsed guidance document for SLRs after CY 2019.
Alternative 2: Withdraw Regulatory Guide 1.188 Under this alternative the NRC would withdraw this regulatory guide. This would pose challenges for potential applicants for license renewal and subsequent license renewal as there would be no NRC-endorsed industry guidance available. It would therefore eliminate the only readily available NRC-endorsed industry description of what constitutes a suitable application for license renewal and subsequent license renewal as well as references to the methods the NRC staff considers acceptable for demonstrating compliance with 10 CFR Part 54. Although this alternative would be less costly to the NRC than the proposed alternative, it would be costlier for applicants by impeding power reactor licensees ability to effectively and efficiently submit an application to extend their operating license from 60 to 80 years.
Alternative 3: Revise Regulatory Guide 1.188 Under this alternative, the NRC would revise Regulatory Guide 1.188. This revision would incorporate the latest information in the NRC and industry guidance, supporting guidance, and review practices. By doing so, the NRC would ensure that the RG guidance available in this area is current, and accurately reflects the staffs position. This revision would also allow the NRC to endorse the new industry guidance for subsequent license renewal, NEI 17-01, beyond December 2019, and reaffirm the endorsement of NEI 95-10 for license renewal applications.
The impact to the NRC would be the costs associated with preparing and issuing the regulatory guide revision. The impact to the public would be the voluntary costs associated with reviewing and providing comments to NRC during the public comment period. The value to NRC staff and its applicants would be the benefits associated with enhanced efficiency and Page 2
effectiveness in using a common guidance document as the technical basis for license renewal applications and other interactions between the NRC and its regulated entities.
Conclusion Based on this regulatory analysis, the NRC staff concludes that revision of Regulatory Guide 1.188 is warranted. The action will enhance reactor safety by allowing the staff to incorporate new guidance for subsequent license renewal. It could also lead to cost savings for the industry, especially regarding the NRC endorsement of NEI 17-01 as an acceptable approach to subsequent license renewal applications.
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