ML23296A032

Development of New Reactor Application Standard Content White Paper

ML23296A032
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Issue date:	10/23/2023
From:	Office of Nuclear Reactor Regulation
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PRE-DECISIONAL This pre-decisional white paper has not been subject to complete NRC management and legal reviews and approvals, and its contents are subject to change and should not be interpreted as official agency positions. The NRC staff is releasing this draft white paper to facilitate discussion at upcoming public meetings. The NRC staff plans to either prepare draft guidance, update current guidance, or issue a related generic communication, based on this white paper, at which time the staff will request public comments on the draft guidance or generic communication and provide written responses, accordingly.

October 23, 2023 NRC Staff Draft White Paper Development of New Reactor Application Standard Content to Support Timely, Efficient, and Effective Reviews of Subsequent Applications Purpose This paper provides draft high-level guidance for the development of standard content for future applications for reactor licenses using the design centered review approach (DCRA)1 to facilitate a more efficient and timely review of subsequent applications. As an example, where the U.S. Nuclear Regulatory Commission (NRC) has issued to a licensee both a construction permit (CP) and an operating license (OL), high-level guidance is provided for the vendor of a design to convert the final safety analysis report (FSAR) design information into a standard design approval application for review by the NRC. This would be done by identifying standard content in the OL FSAR and migrating that information to a standard design approval application to make the regulatory review process more efficient. In addition, draft guidance is provided for applicants to use the DCRA to effectively develop applications that will contain standard content that has been approved in a previous NRC review to facilitate a more efficient and timely review of subsequent applications.

This paper does not discuss the site-specific environmental review that would be required for the submission of each CP, OL, or combined license (COL) application.

BackgroundLicensing Applications The following summarizes the requirements and guidance associated with the technical information in several licensing applications. The focus here is on what information would be considered standard content of the facility design.

Construction Permit Regulatory Guide (RG) 1.70, Standard Form and Content of Safety Analysis Reports for Nuclear Power Plants, Revision 3 (Ref. 1), states that Title 10 of the Code of Federal Regulations (10 CFR) 50.34, Contents of applications; technical information (Ref. 2), requires that each application for a CP for a nuclear reactor 1

NRC, Conduct of New Reactor Licensing Proceedings; Final Policy Statement 73 FR 20963, 20969, April 17, 2008. The Policy statement treats hearing issues and the use of Part 50, Appendix N in detail. (https://www.nrc.gov/reading-rm/doc-collections/commission/policy/index.html#:~:text=(73%20FR%2020963%3B%20April%2017%2C%202008) 1 PRE-DECISIONAL

PRE-DECISIONAL facility include a preliminary safety analysis report (PSAR) and that each application for a license to operate such a facility include an FSAR. In 10 CFR 50.34(a), the NRC provides specific requirements for the information that should be included in the PSAR along with the CP application. Of note, 10 CFR 50.34(a)(1)(i) states the following:

the assessment must contain an analysis and evaluation of the major structures, systems and components of the facility which bear significantly on the acceptability of the site under the site evaluation factors identified in part 100.

RG 1.70 states the following:

In general, the PSAR should describe the preliminary design of the plant in sufficient detail to enable a definitive evaluation by the staff as to whether the plant can be constructed and operated without undue risk to the health and safety of the public.

RG 1.70 further states the design information provided in the [P]SAR should reflect the most advanced state of design at the time of submission. If certain information identified in the Standard Format

[i.e., information identified in RG 1.70] is not yet available at the time of submission of a PSAR because the design has not progressed sufficiently at the time of writing, the PSAR should provide the criteria and bases being used to develop the required information, the concepts and alternatives under consideration, and the schedule for completion of the design and submission of the missing information.

Finally, DNRL-ISG-2022-01, Safety Review of Light-Water Power-Reactor Construction Permit Applications, issued October 2022 (Ref. 3), provides both recent and extensive guidance on the development and submission of CP applications, as well as other topics related to this white paper. Draft Interim Staff Guidance DANU-ISG-2022-01, Review of Risk-Informed, Technology-Inclusive Advanced Reactor Applications Roadmap, appendix C, issued for public comment in May 2023 (Ref. 4), proposed CP application guidance for non-light-water reactors.

Operating License In 10 CFR 50.34(b), the NRC provides specific requirements for the information that must be included in the OL application FSAR. This subsection states the following:

The final safety analysis report shall include information that describes the facility, presents the design bases and the limits on its operation, and presents a safety analysis of the structures, systems, and components and of the facility as a whole.

Since the OL application is submitted before the end of construction, it is expected that amendments to the application will be made to reflect the final construction of the facility before the NRC makes a decision on the OL application. Therefore, the FSAR as amended, at OL issuance, represents the licensed facility. The FSAR describes the final design of the reactor and supporting equipment; the FSAR includes both design information that could be considered generic or representative of a standard plant and site-specific design information.

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PRE-DECISIONAL Standard Design Approval Subpart E, Standard Design Approvals, of 10 CFR Part 52, Licenses, Certification, and Approvals for Nuclear Power Plants (Ref. 5), includes the requirements for a standard design approval.2 . In 10 CFR 52.137, Contents of applications; technical information (Ref. 6), paragraph (a) states the following:

The application must contain a final safety analysis report that describes the facility, presents the design bases and the limits on its operation, and presents a safety analysis of the structures, systems, and components and of the facility, or major portion thereof.

In 10 CFR 52.147, Duration of design approval (Ref. 7), the NRC specifies that the approval of a standard design is valid for 15 years from the date of issuance and may not be renewed. Section 52.147 of 10 CFR further states A design approval continues to be valid beyond the date of expiration in any proceeding on an application for a construction permit or an operating license under part 50 or a combined license or manufacturing license under part 52 that references the final design approval and is docketed before the date of expiration of the design approval.

Combined License The requirements for a COL application are included in Subpart C, Combined Licenses, of 10 CFR Part 52 (Ref. 8). Section 52.73(a) states that an application for a COL may reference a standard design certification, standard design approval, or manufacturing license. Because a COL is granted before construction begins, 10 CFR 52.73(b) states that, before granting a COL that references a standard design certification, the Commission will require that information normally contained in certain procurement specifications and construction and installation specifications be completed and available for audit if the information is necessary for the Commission to make its safety determinations, including the determination that the application is consistent with the certification information. A similar requirement does not apply to a COL application referencing a standard design approval because the SDA can be limited to major portions of the design and to some extent binds the staff and the Advisory Committee on Reactor Safeguards (ACRS)an SDA does not finally resolve issues in litigation before an Atomic Safety & Licensing Board or the Commission. In addition, the entire staff evaluation of the design, including the staff evaluation of the standard portion of the design, would be subject to the mandatory hearing on a COL application that references the SDA. The requirements of 10 CFR 52.79(a), Contents of applications; technical information in final safety analysis report (Ref. 9), state that the application must contain an FSAR that describes the facility, presents the design bases and the limits on its operation, and presents a safety analysis of the structures, systems, and components (SSCs) of the facility as a whole. The FSAR must include information at a level sufficient to enable the Commission to reach a final conclusion on all safety matters that must be resolved by the Commission before issuance of a COL.

Revision 1 to Regulatory Guide 1.206, Applications for Nuclear Power Plants (Ref. 10), includes detailed guidance for the submission of COL applications.

2 The NRC is developing an optional performance-based, technology-inclusive regulatory framework for licensing nuclear power plants designated as 10 CFR Part 53, Licensing and Regulation of Advanced Nuclear Reactors, (RIN 3150-AK31). After promulgation of those regulations, the NRC staff anticipates that the guidance will be updated and incorporated into the NRCs Regulatory Guide (RG) series or a NUREG series document to address content of application considerations specific to the licensing processes in this document.

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PRE-DECISIONAL Discussion Construction Permit and Operating License In simple terms, the PSAR of a CP application generally includes preliminary design and site-specific information. A subset of this information can be further defined as preliminary standard design information that will be identical for every site. The remaining information in the CP application is site-specific content, which includes site-specific SSCs and siting information. This is shown graphically in Figure 1.

Note that to obtain a CP for a facility, the applicant is required to provide preliminary design information in sufficient detail to enable a definitive evaluation by the staff as to whether the plant can be constructed and operated without undue risk to the health and safety of the public. This information is represented by the red shaded area on Figure 1. In contrast, the blue shaded area of Figure 1 is information developed to support construction of the facility, based on the preliminary design approved in the CP. The PSAR need not include final design information except to the extent the applicant is seeking Commission approval of a design feature or specification under 10 CFR 50.35(b).

The most recent example of a CP review is the Kairos Hermes test reactor. At the time of the application submission, Kairos had a preliminary design for the Hermes test reactor. Included in the application, as required, was a PSAR, which included both the preliminary design and information needed to evaluate the site.

As stated in the final safety evaluation report (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23158A268) (Ref. 11), the staff reviewed the Hermes PSAR against applicable regulatory requirements using appropriate regulatory guidance and standards to assess the sufficiency of the 4

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PRE-DECISIONAL preliminary design of the Hermes test reactor. As part of this review, the staff evaluated descriptions and discussions of the Hermes SSCs, with special attention to design and operating characteristics, unusual or novel design features, and principal safety considerations. The preliminary design of Hermes was evaluated to ensure the sufficiency of principal design criteria, design bases, and information relative to materials of construction, general arrangement, and approximate dimensions, sufficient to provide reasonable assurance that the final design will conform to the design bases. In addition, the staff reviewed the identification and justification for the selection of those variables, conditions, or other items that are determined to be probable subjects of technical specifications for the Hermes facility, with special attention given to those items that may significantly influence the final design. The staff also evaluated the SSCs to ensure that they would adequately prevent accidents and mitigate accident consequences. The staff considered the preliminary analysis and evaluation of the design and performance of the SSCs of the Hermes facility with the objective of assessing the risk to public health and safety resulting from its operation.

At some point after the issuance of a CP, construction of the facility begins. When the design is sufficiently complete, the applicant will prepare an FSAR for inclusion in the OL application. A subset of this information can be further defined as standard design information that will be identical for every site. The remaining information in the OL application is site content, which includes site-specific SSCs and siting information. This is shown graphically in Figure 2.

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PRE-DECISIONAL The area under the black dashed line represents the FSAR level of detail needed to resolve all safety issues.

The standard OL content highlighted in red is the information that represents the standard plant design that does not contain any site-specific design information. Again, all information above the black dotted line is needed to construct the facility and support issuance of the operating license but not needed for the staff to make its safety finding regarding the design descriptions and analyses in the FSAR.

The most recent OL application review performed for a power reactor by the NRC was for Watts Bar Nuclear (WBN) Plant Unit 2. This was a unique situation, as the Unit 2 OL was issued 42 years after the CP and 191/2 years after the issuance of the Unit 1 OL. The licensee proposed a unique approach to develop the FSAR for Unit 2. Specifically, as stated in NUREG-0847, Supplement 21, Safety Evaluation Report Related to the Operation of Watts Bar Nuclear Plant, Unit 2 (Ref. 12), to ensure operational fidelity between the units and, at the same time, demonstrate that WBN Unit 2 complies with applicable NRC regulatory requirements, the applicant aligned the licensing and design bases of the two units to the fullest extent practicable. The Commission endorsed this approach in staff requirements memorandum (SRM)-SECY-07-0096, Staff RequirementsPossible Reactivation of Construction and Licensing Activities for the Watts Bar Nuclear Plant Unit 2, dated July 25, 2007 (Ref. 13). In effect, the FSAR for Unit 1 contained the standard information for the Unit 2 OL application. The staff issued several supplemental safety evaluation reports documenting its review to support the issuance of the OL.

Using the Final Safety Analysis Report Approved in the Operating License as the Basis for the Standard Design Approval The version of the Updated FSAR (UFSAR) for a facility for which the Commission has granted an OL in effect six months before submission of the SDA application is the document that should be used as the basis for preparation of the FSAR for the standard design approval application. All the changes since the submission of the OL application will have been incorporated into the latest version of the FSAR. How this information is identified and translated from the OL FSAR to the standard design approval application is the key question if one wants to develop an efficient, effective, and timely process for preparing the standard design approval application. A second question is how to determine the design scope for the standard design approval.

At a minimum, the scope of the standard design approval should include all the SSCs that would be identical at every facility constructed, including the interfaces between the standard design and the balance of the nuclear power plant. The standard design should also include site information, such as postulated site parameters to determine if the approved design can be located at a specific site without further regulatory review beyond verification that the site characteristics identified in a CP or COL fall within the postulated site parameters. A standard design approval referenced in a COL application needs to meet all 10 CFR Part 52 requirements.3 Once the vendor establishes the scope, the relevant information from the OL FSAR can be identified. This information would be considered standard content for the design. To simplify the NRCs review of the standard design approval application, each section in the standard design approval should be identical, to the extent practical, to the corresponding content (identified as standard) in the OL FSAR. If the vendor minimizes any changes to the standard content, the NRCs review of the standard design approval application in areas that have not departed from the standard content can be limited to a verification of the information included in the approval of the OL application.

Upon obtaining a CP, the holder, working with the vendor, should begin to prepare the FSAR that would be included in the OL application. The identification of standard content in the OL application and differentiating 3

Vendors may submit topical reports on operational programs that can be referenced in OL or COL applications.

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PRE-DECISIONAL that content from the site-specific content would be one approach to preparing the content for the standard design approval application. Maintaining that differentiation throughout the review of the OL, such that the FSAR reflects the standard language, would allow the standard design approval application to be prepared and reviewed more quickly. The challenge with this approach is the added administrative burden on the applicant to maintain the identification of standard design information throughout the review of the OL application. As such, the applicant should weigh the advantages and disadvantages of the approach described above. While the method of annotating the FSAR is the responsibility of the OL applicant, a method that was used to annotate COL applications that could be applied in the case of an OL final safety evaluation report is discussed below.

The Design-Centered Review Approach The concept of the DCRA involves the formation of an industry-led design center working group comprising the vendor of a reactor design and prospective entities developing licensing applications that include the vendors design. Other stakeholders could also be included in this industry-led working group, such as a manufacturer of long lead time components or a vendor contracted to construct the facility. In the formation of a design-centered working group, industry members collaborate to simultaneously file applications with the NRC that reflect identical content to standardize their plants insofar as is practicable. NRC would be expected to coordinate the review of these applications to the maximum extent practicable, with the objective of reviewing the standard content for a design and reaching a conclusion that could be applied across multiple application reviews referencing that design. An engaged design center has the potential to efficiently identify standard content and effectively migrate this information into subsequent applications without alteration such that the NRC could perform more efficient reviews of the applications, thereby reducing costs associated with an NRC review while continuing to ensure that the review provides reasonable assurance of adequate protection of public health and safety.

The NRC issued Regulatory Issue Summary (RIS) 2006-06, New Reactor Standardization Needed to Support the Design Centered Licensing Review Approach (Ref. 14) on May 31, 2006, to promote the standardization of COL applications submitted under 10 CFR Part 52 and to facilitate the establishment of a predictable and consistent method for reviewing applications. In the SRM for SECY-06-0187, Semiannual Update of the Status of New Reactor Licensing Activities and Future Planning for New Reactors (Ref. 15), dated November 16, 2006, the Commission expressed support for the staffs DCRA, as described in RIS 2006-06 for reviewing COL and design certification applications. RG 1.206, Revision 1, section C.2.7, provides guidance for implementing the DCRA. The agencys DCRA is a strategy based on industry standardization of COL applications referencing a particular reactor design. As described in RG 1.206, when such standardization is achieved, the NRC staff intends to conduct one technical review for each reactor design issue and use this one decision to support its conclusion on the design certification application and on multiple COL applications.

While this guidance discusses how the DCRA can be applied for design certification and COL applications, much of the guidance can be applied to the CP and OL applications discussed in this white paper.

A key referencing approach associated with the DCRA, as discussed in Section C.2.7 of RG 1.206, Revision 1, involves the use of left-margin annotations in the FSAR. This RG identifies several acronyms that were standardized through practice during the development of COL applications. The specific choice of annotation is up to the design-centered working group, as it may have an equally effective approach. The approach developed by a design-centered working group should be clear and consistent among the different applications that reference the standard content identified in the FSAR. Acronyms that could be used in a left-margin annotation include, but are not limited to, the following:

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PRE-DECISIONAL STD standard information that is identical in each FSAR DEP information that deviates from the standard information in the reference application SUP information that supplements standard information in the subsequent FSAR Using the Design-Centered Review Approach for a Reference Construction Permit and Operating License When applying this approach to a design center that is composed of the initial, or reference, CP and OL, the vendor and prospective applicants should inform the NRC as early as possible that they are going to form a design center. The design center has several options to identify standard content in the reference applications.

One option is to identify standard information in the initial PSAR for the reference CP application and update that standard information throughout the CP review. As discussed above, while this would assist the NRC and subsequent applicants in understanding the scope of the standard information, it would involve a high degree of collaboration for members of the design center.

Upon CP issuance, the annotations in the PSAR would facilitate updating the standard information in the FSAR. Left-margin annotations identifying standard information in the OL application FSAR should be included and updated as appropriate in the FSAR for the SDA. Upon OL issuance, the standard information in the FSAR becomes the basis for development of the standard design approval application. In preparing its SDA application, the vendor should consider developing it with a format identical to that of the OL FSAR. The standard design approval FSAR would include left-margin annotations identifying standard information from the OL application FSAR, departures from the OL FSAR, and any supplemental information not included in the OL FSAR. Presented in this manner, the NRCs review of the standard design approval application would involve

1) verifying that the standard information in the SDA FSAR is identical to the information approved for the OL or 2) a more detailed review of any departures from the reference OL FSAR and supplemental information.

While using identical language in the OL FSAR would facilitate the review of the standard design approval application, a vendor might want to depart from the OL FSAR language identified as standard even where there are no design changes. For example, if there is a plan to market this design internationally, the vendor may want to change some of the information in the standard design approval application to give it more flexibility with other regulatory bodies. In this situation, the vendor should both communicate these changes to the NRC in the preapplication period and highlight the change, as discussed above, with left-margin annotations, noting its departure from the OL FSAR language identified as standard. Identifying this information as early as possible will allow the staff to determine if each departure impacts the NRCs ability to make the necessary regulatory findings in the area impacted by the change. Changes of this type could impact the review schedule if they are not identified in advance.

An example of how a DCRA could be used for a standard design approval being referenced by a subsequent CP or COL applications is included in Figure 3 below by means of a timeline. In this example, early engagement of a design-centered working group to produce a reference CP and OL application is used to develop a standard design approval that facilitates submission of subsequent CP applications under 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, or subsequent COL applications under 10 CFR Part 52.

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PRE-DECISIONAL Figure 3: Construction permit/operating license to standard design approval and Subsequent CP and COL The above timeline presumes that each of the activities associated with licensing activities for a group of applicants using the DCRA are conducted in series. In practice, for 10 CFR Part 52 applications that were submitted in the 2007-2010 timeframe, multiple COL applications were submitted for review in multiple design centers while the design certification applications were also under review or being amended. Several timing conflicts resulted from these overlapping reviews. Using the OL FSAR, applicants in the design center can leverage their applications based on a design that the NRC has approved. The complexity of the subsequent reviews will depend on the changes made to the information in the OL FSAR identified as standard, as well as any necessary design changes that occur once the reference plant is licensed and begins operation.

An option to accelerate the above timeline would be for the applicant to simultaneously prepare a standard design approval with the OL application FSAR and make corresponding changes to the SDA FSAR during the review of the OL application. The NRC and the design-centered working group can discuss schedules and potential departures from the OL FSAR that may need to be made, if any, during the OL application review.

Upon OL issuance, the standard design approval application can be submitted. Another option for an applicant to consider would be for the vendor to submit an application for the standard design approval before the final safety evaluation report for the reference OL has been completed and published. While this represents an additional risk, departures from the standard portions of the design described in the OL FSAR should be well understood and the SDA application amended, if necessary, upon OL issuance. This scenario is shown in Figure 4.

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PRE-DECISIONAL Figure 4: Construction permit/operating license to standard design approval and subsequent CP and COL In all scenarios, it is incumbent on the design center to discuss options they are considering with the NRC so that the availability of resources can be assessed.

NRC guidance for advanced reactors also acknowledges the benefits of early agency engagement before the submission of applications. In DANU-ISG-2022-01, appendix A, the interim staff guidance emphasizes the benefits of robust preapplication engagement to optimize application reviews. While the specific guidance is focused on advanced reactor applications, much of the guidance discussed in the interim staff guidance would be beneficial for any application for reactor licensing.

Other Scenarios in Which Standard Language Can Be Identified A design center could decide to forego a standard design approval altogether. Instead, a SAR for a subsequent CP application (or a subsequent COL application) could include left-margin annotations identifying standard information, as well as departures and supplemental information from what was included in the reference OL final safety evaluation report. The NRC could then use the identification of standard information to inform its review of the subsequent CP application, a subsequent COL application, or a subsequent operating license application. Use of this approach would presumably reduce the scope of each subsequent application review provided that the departures were minimal. These scenarios are illustrated in Figure 5.

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PRE-DECISIONAL Figure 5: Reference construction permit/operating license to subsequent CP, COL, and OL While subsequent applicants would not bind the staff and the ACRS as does a standard design approval, the NRC staff could still apply the concept of one issue, one review, one position, provided that the design center communicated its intentions to the NRC and provided that the application had a consistent level of standardization by following the left-margin annotation approach or a similar means to identify standard language in the subsequent application.

Another option would be to submit an application under 10 CFR Part 50, Appendix N, Standardization of Nuclear Power Plant Designs: Permits to Construct and Licensees to Operate Nuclear Power Reactors of Identical Design at Multiple Sites (Ref. 16), or 10 CFR Part 52, Appendix N, Standardization of Nuclear Power Plant Designs: Combined Licenses to Construct and Operate Nuclear Power Reactors of Identical Design at Multiple Sites (Ref.17). These appendices are for situations in which applications are filed by one or more applicants for licenses to construct and operate nuclear power reactors of essentially the same design to be located at different sites. The design must have identical SSCs important to radiological health and safety and the common defense and security for the application to be processed under Appendix N. This appendix under Part 50 was used for the initial license reviews of the Byron and Braidwood Generating Stations in the current operating fleet. Their respective FSARs were annotated to denote which portions should be considered applicable to licensing under Appendix N. As noted previously, the key is to identify the identical information by the use of some scheme, such as left-margin annotations.

Finally, the design center could use the FSAR as amended at the OL issuance to provide the basis for a design certification application. As with the other scenarios discussed above, the identification of standard information in the FSAR and then using that exact language, as practicable, would allow the vendor to obtain a comprehensive certification of the design and achieve the maximum available level of finality for use in subsequent 10 CFR Part 50 and 10 CFR Part 52 applications over the options discussed above.

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PRE-DECISIONAL In all scenarios, it is incumbent on the design center to discuss options it is considering with the NRC so that the agency can plan schedules and resources.

Conclusion The FSAR version available at the time the OL for the facility is issued (or, if time has passed after the issuance of the OL, the latest version of the UFSAR available 6 months before the SDA application is submitted) contains a set of standard information on the design that can be used in the development of a standard design approval application. Identification of this standard information by the vendor and its migration to a standard design approval application should be focused on the scope of the standard design and migrating the exact language from the version of the OL FSAR, to the extent practicable. Applicants could find a benefit from forming a design center and identifying standard content using left-margin annotations (or some other similar method for identifying such information) in a reference OL application. A design center engaged throughout all NRC review activities has the potential to facilitate a more effective, efficient, and timely review benefiting all applicants and the NRC by improving regulatory consistency and minimizing the resources needed to conduct both the standard design approval and subsequent reviews referencing it. Durable guidance exists for the DCRA in RG 1.206, Revision 1, section C.2.7.

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PRE-DECISIONAL REFERENCES

1. U.S. Nuclear Regulatory Commission (NRC), Regulatory Guide (RG) 1.70, Standard Form and Content of Safety Analysis Reports for Nuclear Power Plants, Revision 3, (Agencywide Documents Access and Management System (ADAMS) (ML011340072). Washington, DC

2. Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, § 50.34 Contents of applications; technical information

3. NRC, DNRL-ISG-2022-01, Safety Review of Light-Water Power Reactor Construction Permit Applications, Interim Staff Guidance, (ML22189A099). October 2022

4. NRC, DANU-ISG-2022-01, Review of Risk-Informed, Technology-Inclusive, Advanced Reactor ApplicationsRoadmap, Draft Interim Staff Guidance, (ML22048B546). May 2023

5. 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants Subpart E, Standard Design Approvals

6. 10 CFR Part 52.137, Contents of applications; technical information

7. 10 CFR Part 52.147, Duration of design approval

8. 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants Subpart C, Combined Licenses

9. 10 CFR Part 52.79(a), Contents of applications; technical information in final safety analysis report

10. NRC, RG 1.206, Revision 1, Applications for Nuclear Power Plants, Section C.2.7, Design Centered Review Approach, Washington, DC (ML18131A181). October 2018

11. Safety Evaluation Related to the Kairos Power LLC Construction Permit Application for the Hermes Test Reactor Docket 50-7513 (ML23158A268). June 2023

12. NRC, NUREG-0847, Supplement 21, Safety Evaluation Report Related to the Operation of Watts Bar Nuclear Plant, Unit 2, Docket Number 50-391, Tennessee Valley Authority, (ML090570741). February 2009

13. NRC, Staff Requirements Memorandum, Staff Requirements - SECY-07-0096 Possible Reactivation of Construction and Licensing Activities for the Watts Bar Nuclear Plant Unit 2, (ML072060688).

July 25, 2007

14. NRC, Regulatory Issue Summary 2006-06, New Reactor Standardization Needed to Support the Design-Centered Licensing Review Approach (ML053540251). May 31, 2006 13 PRE-DECISIONAL

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15. NRC, Staff Requirements Memorandum, Staff RequirementsSECY-06-0187Semiannual Update of the Status of New Reactor Licensing Activities and Future Planning for New Reactors, (ML063200352).

November 16, 2006

16. 10 CFR Part 50, Appendix N, Standardization of Nuclear Power Plant Designs: Permits to Construct and Licensees to Operate Nuclear Power Reactors of Identical Design at Multiple Sites

17. 10 CFR Part 52, Appendix N, Standardization of Nuclear Power Plant Designs: Combined Licenses to Construct and Operate Nuclear Power Reactors of Identical Design at Multiple Sites 14 PRE-DECISIONAL