ML19213A345

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Draft Regulatory Guide DG-1341, Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses
ML19213A345
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Issue date: 09/30/2019
From: Amy Hull
NRC/RES/DE
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Eudy M
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ML19213A339 List:
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DG-1341 RG-1.188
Download: ML19213A345 (12)
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U.S. NUCLEAR REGULATORY COMMISSION DRAFT REGULATORY GUIDE 1341 Proposed Revision 2 to Regulatory Guide 1.188 Issue Date: September 2019 Technical Leads: Bennett Brady Amy Hull STANDARD FORMAT AND CONTENT FOR APPLICATIONS TO RENEW NUCLEAR POWER PLANT OPERATING LICENSES A. INTRODUCTION Purpose This regulatory guide (RG) describes an approach that is acceptable to the staff of the U.S. Nuclear Regulatory Commission (NRC) for the format and content of an application to renew or subsequently renew an NRC-issued operating license under Title 10 of the Code of Federal Regulations (10 CFR) Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants (Ref. 1).

This RG endorses Revision 6 of Nuclear Energy Institute (NEI) 95-10, Industry Guideline for Implementing the Requirements of 10 CFR Part 54The License Renewal Rule, (Ref. 2), and NEI 17-01, Industry Guideline for Implementing the Requirements of 10 CFR Part 54 for Subsequent License Renewal, (Ref. 3).

Applicability This RG applies to initial license renewal applications (LRAs) and subsequent license renewal applications (SLRAs). It applies to applicants and licensees subject to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities (Ref. 4) that seek renewal of their current operating licenses.

Applicable Regulations The issuance of renewed operating licenses for nuclear power plants is governed by 10 CFR Part 54, commonly known as the license renewal rule.

This RG is being issued in draft form to involve the public in the development of regulatory guidance in this area. It has not received final staff review or approval and does not represent an NRC final staff position. Public comments are being solicited on this DG and its associated regulatory analysis. Comments should be accompanied by appropriate supporting data. Comments may be submitted through the Federal rulemaking Web site, http://www.regulations.gov, by searching for draft regulatory guide DG-1341. Alternatively, comments may be submitted to the Office of Administration, Mailstop: TWFN 7A-06M, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, ATTN:

Program Management, Announcements and Editing Staff. Comments must be submitted by the date indicated in the Federal Register notice.

Electronic copies of this DG, previous versions of DGs, and other recently issued guides are available through the NRCs public Web site under the Regulatory Guides document collection of the NRC Library at https://nrcweb.nrc.gov/reading-rm/doc-collections/reg-guides/. The DG is also available through the NRCs Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html, under Accession No. ML19213A345. The regulatory analysis may be found in ADAMS under Accession No. ML19213A343.

o 10 CFR 54.17, Filing of application, provides the requirements for filing an LRA or SLRA.

o 10 CFR 54.19, Contents of applicationgeneral information, provides the requirements for the general information in an LRA or SLRA.

o 10 CFR 54.21, Contents of applicationtechnical information, provides the requirements for the technical information in an LRA or SLRA.

o 10 CFR 54.22, Contents of applicationtechnical specifications, provides the requirements for the changes or additions to the technical specifications to manage the effects of aging in an LRA or SLRA.

o 10 CFR 54.23, Contents of applicationenvironmental information, provides the requirements for the environmental information in a renewal application.

Additional applicable regulations are as follows:

o Subpart A, Procedure for Issuance, Amendment, Transfer, or Renewal of a License, and Standard Design Approval, of 10 CFR Part 2 provides the procedures for the issuance, amendment, transfer, or renewal of a license, and standard design approval.

  • 10 CFR Part 50 provides the regulations governing the licensing of production and utilization facilities.

o 10 CFR 50.4, Written communications, provides the requirements for written communications.

o 10 CFR 50.30, Filing of application; oath or affirmation, provides the requirements for filing of an application and oath or affirmation.

  • 10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions (Ref. 8), contains environmental protection regulations applicable to the NRCs domestic licensing actions and related regulatory functions, in accordance with the National Environmental Policy Act of 1969, as amended (Ref. 9).

Related Guidance

  • NUREG-1555, Standard Review Plans for Environmental Reviews for Nuclear Power Plants, Supplement 1, Operating License RenewalFinal Report, Revision 1 (Ref. 10), issued June 2013, provides the criteria used by the NRC staff for reviewing environmental reports (ERs) submitted with nuclear power plant applications for license renewal or subsequent license renewal.
  • NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, Revision 2, issued December 2010 (Ref. 11), provides the criteria used by the NRC staff for reviewing LRAs for nuclear power plants.

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  • NUREG-1801, Generic Aging Lessons Learned (GALL) Report, Revision 2, issued December 2010 (Ref. 12), provides guidance on the content of applications for the initial renewal of an operating license.
  • NUREG-2191, Volumes 1 and 2, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, issued July 2017 (Ref. 13), provides guidance on the content of applications for subsequent renewal of renewed operating licenses.

Purpose of Regulatory Guides The NRC issues RGs 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 events, and to provide guidance to applicants. Regulatory guides are not substitutes for regulations and compliance with them is not required. Methods and solutions that differ from those set forth in RGs will be deemed acceptable if they provide a basis for the findings required for the issuance or renewal of a permit or license by the Commission.

Paperwork Reduction Act This RG provides voluntary guidance for implementing the mandatory information collections in 10 CFR Parts 50 and 54 that are subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et.

seq.). These information collections were approved by the Office of Management and Budget (OMB),

approval numbers 3150-011 and 3150-0155. Send comments regarding this information collection to the Information Services Branch (T6-A10M), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the OMB reviewer at: OMB Office of Information and Regulatory Affairs (3150-0011, 3150-0155), Attn: Desk Officer for the Nuclear Regulatory Commission, 725 17th Street, NW Washington, DC 20503; e-mail:

oira_submission@omb.eop.gov.

Public Protection Notification The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the document requesting or requiring the collection displays a currently valid OMB control number.

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B. DISCUSSION Reason for Revision This revision of the guide (Revision 2) broadens the scope of the RG to include both license renewal and subsequent license renewal by endorsing NEI 17-01, which provides an acceptable approach for implementing the requirements of 10 CFR Part 54 for subsequent license renewal.

Background

The NRC initially issued RG 1.188 in July 2001, which incorporated lessons learned from the review of LRAs and owners group topical reports. The guide also incorporated relevant information from NUREG-1800, Revision 0, issued July 2001 (Ref. 16); and NUREG-1801, Revision 0, issued July 2001 Revision 0 (Ref. 17), as well as a summary of public comments received on those documents found in NUREG-1739, Analysis of Public Comments on the Improved License Renewal Guidance Documents, issued July 2001 (Ref. 18).

Since the initial publication of RG 1.188 in July 2001, the staff has updated both NUREG-1800 and NUREG-1801 based on experience gained from numerous LRA reviews and other insights identified by the industry. Consequently, the staff also revised RG 1.188 to reflect updates to the guidance documents. The NRC staff found Revision 6 of NEI 95-10 acceptable for use in implementing the license renewal rule, without exceptions, as discussed in RG 1.188, Revision 1, issued September 2005 (Ref. 19).

After issuance of RG 1.188, Revision 1, the nuclear power industry indicated interest in submitting applications to operate nuclear power plants for an additional 20 years beyond the initial license renewal period. As identified above in Section A of this RG, the NRC developed and published guidance documents on aging management programs that provide reasonable assurance of safe operation during operation from 60 to 80 years, in NUREG-2191 and NUREG-2192. Additionally, in December 2017, the staff issued NUREG-2221, Technical Bases for Changes in the Subsequent License Renewal Guidance Documents NUREG-2191 and NUREG-2192 (Ref. 20), which provides the technical bases for the changes in the guidance documents from initial license renewal to subsequent license renewal. The staff also issued NUREG-2222, Disposition of Public Comments on the Draft Subsequent License Renewal Guidance Documents NUREG-2191, and NUREG-2192, in December 2017 (Ref. 21), which provides the disposition of the public comments on the draft guidance documents for subsequent license renewal. Concurrently, the industry developed NEI 17-01 to provide guidance to utilities on implementing the license renewal rule for subsequent license renewal, incorporating lessons learned from industry experience and completing initial LRAs. The NRC endorses NEI 17-01 in this RG.

Harmonization with International Standards The NRC staff has been actively involved with the IAEA in developing and updating the IAEA International Generic Aging Lessons Learned (IGALL) program. The development of IGALL started with NRC guidance for license renewal from GALL Revision 2, and the latest updates to IGALL used GALL-SLR technical information as the basis for many of the updates. The NRC continues to review information from IGALL counterparts and evaluate the necessity of making changes to GALL and GALL-SLR.

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Documents Discussed in Staff Regulatory Guidance This RG endorses the use of one or more third party guidance documents. These third party guidance documents may contain references to other codes, standards or third party guidance documents (secondary references). If a secondary reference has itself been incorporated by reference into NRC regulations as a requirement, then licensees and applicants must comply with that standard as set forth in the regulation. If the secondary reference has been endorsed in a RG as an acceptable approach for meeting an NRC requirement, then the standard constitutes a method acceptable to the NRC staff for meeting that regulatory requirement as described in the specific RG. If the secondary reference has neither been incorporated by reference into NRC regulations nor endorsed in a RG, then the secondary reference is neither a legally-binding requirement nor a generic NRC approved acceptable approach for meeting an NRC requirement. However, licensees and applicants may consider and use the information in the secondary reference, if appropriately justified, consistent with current regulatory practice, and consistent with applicable NRC requirements.

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C. STAFF REGULATORY GUIDANCE This section discusses the NRC staffs regulatory position on the standard format and content of applications for renewal and subsequent renewal of operating licenses for commercial nuclear power plants. Therefore, the guidance provided in this section is expected to ensure that applicants have identified and taken (or will take) actions to ensure plant safety throughout the period of extended operation.

Specifically, such actions relate to (1) managing the effects of aging on the functionality of plant structures, systems, and components that the NRC staff has identified as requiring aging management, and (2) evaluating time-limited aging analyses (TLAAs) that the NRC staff has identified as requiring such review.

1. Contents of a License Renewal Application or Subsequent License Renewal Application To renew a nuclear power plant operating license, an applicant must meet the requirements delineated in 10 CFR Part 54. This license renewal rule establishes the procedures, criteria, and standards governing renewal of an operating license. The application must include (1) general information, (2) technical information, including an integrated plant assessment, changes to the current licensing basis, an evaluation of TLAAs, and a supplement to the plants final safety analysis report (FSAR), (3) any necessary changes to the plants technical specifications (along with related justifications), and (4) a supplement to the plants ER.

NUREG-1801, Revision 2, provides guidance on the content of an LRA for the initial renewal of an operating license. NUREG-1800, Revision 2, provides the criteria used by the NRC staff for reviewing LRAs. NUREG-2191, Volumes 1 and 2, provides guidance on the content of an SLRA for subsequent renewal of the initial renewed operating license. NUREG-2192 provides the criteria used by the NRC staff for reviewing SLRAs. RG 4.2, Supplement 1, provides additional guidance on the format and content of the ER. Supplement 1 to NUREG-1555 provides the criteria used by the NRC staff for reviewing ERs submitted with LRAs and SLRAs.

2. Endorsement of Nuclear Energy Institute Guidelines The NRC staff endorses Revision 6 of NEI 95-10 as acceptable for complying with the requirements of 10 CFR Part 54 for preparing an initial LRA. For additional information concerning the preparation of acceptable LRAs, applicants may refer to NUREG-1800 or NUREG-1801 for operation from 40 to 60 years.

The NRC staff endorses NEI 17-01 as acceptable for complying with the requirements of 10 CFR Part 54 for preparing an SLRA. For additional information concerning the preparation of acceptable SLRAs, applicants may refer to NUREG-2192 or NUREG-2191 for operation from 60 to 80 years. Applicants for initial license renewal may also follow the guidance in NUREG-2191 and NUREG-2192 if they inform the staff that they intend to do so.

Applicants may meet the intent of the license renewal rule for initial license renewal or subsequent license renewal using methods other than those described in Revision 6 of NEI 95-10 or NEI 17-01, respectively, as endorsed in this RG. However, the NRC staff will determine the acceptability of alternative methods on a case-by-case basis.

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3. Selected Submission Requirements and Guidelines Applicants must submit the LRA and SLRA in accordance with 10 CFR 54.17. The following general provisions, with the corresponding regulations, also apply to filing an application for a renewed operating license:
  • As stated in 10 CFR 54.17(c), the applicant may not submit the application to the Commission earlier than 20 years before the expiration of the operating license currently in effect.
  • For the timely renewal provisions of 10 CFR 2.109(b) an applicant must file a sufficient application at least 5 years before the expiration of the existing license.
  • As stated in 10 CFR 54.17(d), the application for a renewed license may be combined with applications for other kinds of licenses.
  • As stated in 10 CFR 54.17(e), the application may incorporate by reference information contained in previous applications for licenses or license amendments, statements, correspondence, or reports filed with the Commission, provided the references are clear and specific.

The information that an applicant develops and submits or retains for license renewal or subsequent license renewal should permit the NRC staff to determine that the applicant has met the requirements of 10 CFR Part 54. The standard format in which the applicant presents this information should allow optimal use of the applicants resources, while facilitating the NRC staffs review of the LRA.

Where practicable, licensees should electronically submit the entire document through, for example, the Electronic Information Exchange, e-mail, or CD ROM. If a licensee chooses to use an electronic submission, then the NRC staff recommends that all subsequent updates or submissions be performed on a total page replacement basis and the applicants should follow the guidance discussed below. The regulation in 10 CFR 50.4(a) specifies that Electronic submissions must be made in a manner that enables the NRC to receive, read, authenticate, distribute, and archive the submission, and process and retrieve it a single page at a time. The NRC provides specific guidance on acceptable procedures for electronic submissions on its public Web site at http://www.nrc.gov/site-help/e-submittals.html. Users who are new to the process should select the Getting Started link, http://www.nrc.gov/site-help/e-submittals/getting-started.html, and access the Reference Materials for Electronic Submissions link at http://www.nrc.gov/site-help/electronic-sub-ref-mat.html. The Reference Materials for Electronic Submissions link also provides a link to the current version of the primary guidance document, Guidance for Electronic Submissions to the NRC (Ref. 22). Licensees should use the most recent processes and guidance when submitting documents in electronic format. Applicants may use the formatting specifications in NUREG-1379, NRC Editorial Style Guide (Ref. 23), in the development of LRAs and SLRAs.

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For revisions and changes to the LRA, SLRA, updated FSAR, or subsequent FSAR updates, the applicant must follow the applicable requirements of 10 CFR 50.4, and 10 CFR 50.71, Maintenance of Records, Making of Reports. Per 10 CFR 50.4(b)(6), paper copy submissions of updated FSARs may be made using replacement pages. Under 10 CFR 50.4(a), all paper submissions to the Document Control Desk must be the signed originals. As stated in 10 CFR 50.71(e)(5), each updated FSAR replacement page shall include both a change indicator (a bold line vertically drawn in the margin adjacent to the portion that has changed), and a page change identification (with date changed or change number or both). Licensees that submit paper copies of their LRAs, SLRAs, or subsequent FSAR updates should follow 10 CFR 50.4(b)(6) and 50.71(e)(5). As discussed above, if a licensee chooses to use an electronic submission, then the NRC staff recommends that all subsequent updates or submissions be performed on a total page replacement basis.

Sensitive or proprietary information included in the LRA, SLRA, or updated FSAR Supplement, that the licensee seeks to have withheld from the public must be marked and submitted in accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding. Applicants must submit nonpublic, security-related information included in the LRA or SLRA related to safeguards information, as defined in 10 CFR 73.2, Definitions, in accordance with 10 CFR 73.21, Protection of Safeguards Information: Performance requirements (Ref. 24).

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D. IMPLEMENTATION The purpose of this section is to provide information on how applicants and licensees 1 may use this guide and information regarding the NRCs plans for using this RG. In addition, it describes how the NRC staff complies with 10 CFR 50.109, Backfitting.

Use by Applicants and Licensees Applicants and licensees may voluntarily 2 use the guidance in this document to demonstrate compliance with the underlying NRC regulations. Methods or solutions that differ from those described in this RG may be deemed acceptable if they provide sufficient basis and information for the NRC staff to verify that the proposed alternative demonstrates compliance with the appropriate NRC regulations.

Current licensees may continue to use guidance the NRC found acceptable for complying with the identified regulations as long as their current licensing basis remains unchanged.

Licensees may use the information in this RG for actions that do not require NRC review and approval such as changes to a facility design under 10 CFR 50.59, Changes, Tests, and Experiments.

Licensees may use the information in this RG or applicable parts to resolve regulatory or inspection issues.

Use by NRC Staff The NRC staff does not intend or approve any imposition or backfitting of the guidance in this RG. The NRC staff does not expect any existing licensee to use or commit to using the guidance in this RG. The NRC staff does not expect or plan to request licensees to voluntarily adopt this RG to resolve a generic regulatory issue. The NRC staff does not expect or plan to initiate NRC regulatory action which would require the use of this RG without further backfit consideration. Examples of such unplanned NRC regulatory actions include issuance of an order requiring the use of the RG, requests for information under 10 CFR 50.54(f) as to whether a licensee intends to commit to use of this RG, generic communications, or a rule requiring the use of this RG.

During regulatory discussions on plant specific operational issues, the staff may discuss with licensees various actions consistent with staff positions in this RG, as one acceptable means of meeting the underlying NRC regulatory requirement. Such discussions would not ordinarily be considered backfitting even if prior versions of this RG are part of the licensing basis of the facility. However, unless this RG is part of the license for a facility, the staff may not represent to the licensee that the licensees failure to comply with the positions in this RG constitutes a violation.

Additionally, an existing applicant may be required to comply with new rules, orders, or guidance if 10 CFR 50.109(a)(3) applies.

If a licensee believes that the NRC is either using this RG or requesting or requiring the licensee to implement the methods or processes in this RG in a manner inconsistent with the discussion in this Implementation section, then the licensee may file a backfit appeal with the NRC in accordance with the 1 In this section, licensees refers to licensees of nuclear power plants under 10 CFR Part 50, and the term applicants refers to applicants for licenses and permits for nuclear power plants under 10 CFR Part 50.

2 In this section, voluntary and voluntarily means that the licensee is seeking the action of its own accord, without the force of a legally binding requirement or an NRC representation of further licensing or enforcement action.

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guidance in NRC Management Directive 8.4, Management of Facility-Specific Backfitting and Information Collection, (Ref. 25), and in NUREG-1409, Backfitting Guidelines, (Ref. 26).

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REFERENCES3

1. U.S. Code of Federal Regulations (CFR), Requirements for Renewal of Operating Licenses for Nuclear Power Plants, Part 54, Chapter I, Title 10, Energy.
2. Nuclear Energy Institute (NEI) 95-10, Industry Guideline for Implementing the Requirements of 10 CFR Part 54The License Renewal Rule, Revision 6, Washington, DC, June 2005 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML051860406)4
3. NEI 17-01, Industry Guideline for Implementing the Requirements of 10 CFR Part 54 for Subsequent License Renewal, Washington, DC, December 2017 (ADAMS Accession No. ML17339A599)
4. CFR, Domestic Licensing of Production and Utilization Facilities, Part 50, Chapter I, Title 10, Energy.
5. Atomic Energy Act of 1954, as amended, Title 42, Public Health and Welfare, United States Code (U.S.C.) § 2011 et seq.
6. Energy Reorganization Act of 1974, Title 42 Public Health and Welfare, U.S.C. § 5801 et seq.
7. CFR, Agency Rules of Practice and Procedure, Part 2, Chapter I, Title 10, Energy.
8. CFR, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, Part 51, Chapter I, Title 10, Energy.
9. National Environmental Policy Act of 1969, as amended, Title 42, Public Health and Welfare, U.S.C. § 4321 et seq
10. U.S. Nuclear Regulatory Commission (NRC), NUREG-1555, Standard Review Plans for Environmental Reviews for Nuclear Power Plants, Supplement 1, Operating License Renewal, Final Report, Revision 1, Washington, DC, June 2013.
11. NRC, NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, Revision 2, Washington DC, December 2010.
12. NRC, NUREG-1801, Generic Aging Lessons Learned (GALL) Report, Revision 2, Washington, DC, December 2010.
13. NRC, NUREG-2191, Volumes 1 and 2, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, Washington, DC, July 2017.

3 Publicly available NRC published documents are available electronically through the NRC Library on the NRCs public Web site 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 The documents can also be viewed online or printed for a fee in the NRCs Public Document Room (PDR) at 11555 Rockville Pike, Rockville, MD. For problems with ADAMS, contact the PDR staff at 301-415-4737 or (800) 397-4209; fax (301) 415-3548; or e-mail pdr.resource@nrc.gov.

4 Publications from NEI are available at their Web site: http://www.nei.org or by contacting the headquarters at Nuclear Energy Institute, 1201 F St., NW, Suite 1100, Washington DC 20004-1218, Phone: 202-739-8000, Fax 202-785-4019.

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14. NRC, NUREG-2192, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants- Final Report, Washington, DC, July 2017.
15. NRC, Regulatory Guide 4.2, Supplement 1, Preparation of Environmental Reports for Nuclear Power Plant License Renewal Applications, Washington, DC.
16. NRC, NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, Revision 0, Washington, DC, July 2001. (ADAMS Accession Nos.

ML012070391 and ML012070409)

17. NRC, NUREG-1801, Generic Aging Lessons Learned (GALL) Report, Revision 0, Washington, DC, July 2001. (ADAMS Accession Nos. ML012060392, ML012060514, ML012060539, and ML012060521)
18. NRC, NUREG-1739, Analysis of Public Comments on the Improved License Renewal Guidance Documents, Washington, DC, July 2001.
19. NRC, Regulatory Guide 1.188, Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses, Revision 1, Washington, DC, September 2005.
20. NRC, NUREG-2221, Technical Bases for Changes in the Subsequent License Renewal Guidance Documents NUREG-2191 and NUREG-2192, Washington, DC, December 2017.
21. NRC, NUREG-2222, Disposition of Public Comments on the draft Subsequent License Renewal Guidance Documents NUREG-2191 and NUREG-2192, Washington, DC, December 2017.
22. NRC, Guidance for Electronic Submissions to the NRC, Washington, DC.
23. NRC, NUREG-1379, Revision 2, NRC Editorial Style Guide, Washington, DC.
24. CFR, Physical Protection of Plants and Materials, Part 73, Nuclear Regulatory Commission, Chapter I, Title 10, Energy.
25. NRC, Management Directive 8.4, Management of Facility-Specific Backfitting and Information Collection, Washington, DC.
26. NRC, NUREG-1409, Backfitting Guidelines, Washington, DC.

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