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{{#Wiki_filter:DG-1 145 PRE-WORKSHOP 7 COMMENTS COMBINED LICENSE APPLICATION INFORMATION REQUIREMENTS During the first 6 workshops on Draft DG-1 145, the timing and applicability of information requirements were discussed in several technical areas. Industry addressed these requirements in several pre-workshop and "Blue Card" comments.
{{#Wiki_filter:DG-1 145 PRE-WORKSHOP 7 COMMENTS COMBINED LICENSE APPLICATION INFORMATION REQUIREMENTS During the first 6 workshops on Draft DG-1 145, the timing and applicability of information requirements were discussed in several technical areas. Industry addressed these requirements in several pre-workshop and "Blue Card" comments. During Workshop 5, the Staff commented that COLA guidance should identify the information required for a reasonable assurance finding vs.
During Workshop 5, the Staff commented that COLA guidance should identify the information required for a reasonable assurance finding vs. what information would be available at the time of application.
what information would be available at the time of application. Industry presented tables at Workshop 6 that identified several instances where the information required is either 1) not appropriate for a COL application or 2) not available at the time of application submittal but would be available later.
Industry presented tables at Workshop 6 that identified several instances where the information required is either 1) not appropriate for a COL application or 2) not available at the time of application submittal but would be available later. The following revised table identifies examples of information requirements in these categories identified in the draft-for-comment version of DG-1 145 published September 6, 2006. Revisions to the earlier table are shown in red and italics. It should be noted that the examples are typical and the availability of information may vary for different applications.
The following revised table identifies examples of information requirements in these categories identified in the draft-for-comment version of DG-1 145 published September 6, 2006. Revisions to the earlier table are shown in red and italics. It should be noted that the examples are typical and the availability of information may vary for different applications. Further review of DG-1 145 may result in additions to the table. The table is draft but it provides a basis for further discussion of these issues.
Further review of DG-1 145 may result in additions to the table. The table is draft but it provides a basis for further discussion of these issues.
 
COL INFORMATION TIMING -DRAFT 9/15/2006 Item 1.02-1 1.03-1 DELETE Section C.1.2.3.3 C.1.3.6.3(1)(a)
COL INFORMATION TIMING - DRAFT 9/15/2006 Item     Section         NRC Item       Pre-WS/   Summary Description                         Availability            Proposed Review Approach No.           Blue Card ID 1.02-1    C.1.2.3.3       C.L.2.3.3-1   B (4)     Submit 2 consecutive years of met data.     1 year prior to          Submit 1st yr with application, NRC states approachacceptable but text     submittal, 2nd          2nd year as COLA still requires2 years data prior to         complete after          supplement docketing.                                   submittal 1.03-1    C.1.3.6.3(1)(a) C.L.3.6.3-1    P (3)    Submit types of materials and material       Types of materials      Submit material types DELETE                                            specifications (including heat numbers),     and specifications for  w/application, heat numbers for base metals, weldments, fittings and     most components          available on site before fuel safe ends.                                   available by            load for inspection Removed Heat numbers.                       application, heat numbers available during construction 1.03-2   C.1.3.6(3)(b)   C.1.3.6.3-3   P(3)     Requires application include material       Representative          Submit representative properties including toughness (J-R         properties available    properties with application; curves), tensile (stress-strain curves) data at application; as-built as-built material properties at temperatures near the upper range of     properties available    available on-site before fuel normal operating temperatures.              during construction. load for inspection.
NRC Item Pre-WS/ Summary Description No. Blue Card ID C.L.2.3.3-1 B (4)C.L.3.6.3-1 P (3)Submit 2 consecutive years of met data. NRC states approach acceptable but text still requires 2 years data prior to docketing.
Submit types of materials and material specifications (including heat numbers), for base metals, weldments, fittings and safe ends. Removed Heat numbers.1.03-2 1.03-3 1.03-4 C.1.3.6(3)(b)
C.1.3.6.3(2)(a)
C.1.3.6.3-3 P(3)C.I.3.6.3-5,-6 P(4) P(5)Requires application include material properties including toughness (J-R curves), tensile (stress-strain curves) data at temperatures near the upper range of normal operating temperatures.
Accepted per App. I but text not modified.
Accepted per App. I but text not modified.
This section requires that the application include as-built drawings of pipe geometry, etc. Accepted per App. I but text not modified.
1.03-3    C.1.3.6.3(2)(a) C.I.3.6.3-5,-6 P(4)      This section requires that the application   As-built drawings will  As-built drawings would be include as-built drawings of pipe           be completed during      made available as they are geometry, etc.                               construction. Design    completed on site for Accepted per App. I but text not modified. piping isometrics        inspection.
This section implies that the pre operational flow-induced testing of reactor internals would be complete at the time of COLA. Based on the workshop discussion, we understand this applies to later plants referencing results from an operating plant. Clarified in App. I but text not changed.Availability 1 year prior to submittal, 2nd complete after submittal Types of materials and specifications for most components available by application, heat numbers available during construction Representative properties available at application; as-built properties available during construction.
available in application.
As-built drawings will be completed during construction.
1.03-4    C.1. 3.9.2.4    C.L.3.9.2.4-1 P(5)      This section implies that the pre            Applicable to follow    Provide results in COLA.
Design piping isometrics available in application.
operational flow-induced testing of reactor  on plants. Provide internals would be complete at the time of  results of operating COLA. Based on the workshop                  plant testing.
Applicable to follow on plants. Provide results of operating plant testing.Proposed Review Approach Submit 1st yr with application, 2nd year as COLA supplement Submit material types w/application, heat numbers available on site before fuel load for inspection Submit representative properties with application; as-built material properties available on-site before fuel load for inspection.
discussion, we understand this applies to later plants referencing results from an operating plant.
As-built drawings would be made available as they are completed on site for inspection.
Clarified in App. I but text not changed.
Provide results in COLA.C.1. 3.9.2.4 C.L.3.9.2.4-1 COL INFORMATION TIMING -DRAFT 9/15/2006 Item Section NRC Item Pre-WSI No.Blue Card ID P(5)1.03-5 C.1.3.13.1.4 C.1.3.13.1.4-1 C.I.4-2 1.04- C.I.4 1DELETE (presentation)
 
B(2)Summary Description Requires preservice inspection test results.
COL INFORMATION TIMING - DRAFT 9/15/2006 Item      Section        NRC Item        Pre-WSI    Summary Description                          Availability            Proposed Review Approach No.            Blue Card ID 1.03-5    C.1.3.13.1.4   C.1.3.13.1.4-1 P(5)       Requires preservice inspection test          Test requirements,      Provide requirements in results.                                     criteria available at    COLA, test results available Accepted per App. 1 but text not changed. COLA. Results              onsite during construction.
Accepted per App. 1 but text not changed.
available during construction.
First bullet, first slide. This bullet identified the COL Information item that any changes to the referenced design be identified to the Staff. As discussed in the workshop, the final fuel design and loading pattern may not be available until after the application and possibly after the COL is issued. In this case, the final design would be submitted as a license amendment request under the Tier 2* change process after the COL is issued. Does the staff agree that the design in the generic DCD is the required design until the license amendment request is approved, and the COL may be issued based on the approved fuel design described in the generic DCD?Accepted This section provides a list of information required to be included in the application.
1.04-      C.I.4         C.I.4-2         B(2)       First bullet, first slide. This bullet       For COLAs                Reference the DCD for the 1DELETE    (presentation)                            identified the COL Information item that     referencing a certified application. Submit License any changes to the referenced design be       design, the fuel        Amendment Request when identified to the Staff. As discussed in the design in the generic  the final design is complete.
Four of the 9 items would not be available at COLA. Accepted Section requires a comparison to operating procedures.
workshop, the final fuel design and           DCD is the COLA loading pattern may not be available until   design. During after the application and possibly after the construction, the final COL is issued. In this case, the final       design and loading design would be submitted as a license       pattern will be amendment request under the Tier 2*           developed.
Accepted Availability Test requirements, criteria available at COLA. Results available during construction.
change process after the COL is issued.
For COLAs referencing a certified design, the fuel design in the generic DCD is the COLA design. During construction, the final design and loading pattern will be developed.
Does the staff agree that the design in the generic DCD is the required design until the license amendment request is approved, and the COL may be issued based on the approved fuel design described in the generic DCD?Accepted 1.05-2    C.1.5.2.4.1    C.I.5.2.4.1-2  P(5)      This section provides a list of information  Some of the items      Provide available information, DELETE                                              required to be included in the application. are available at        remainder will be available on Four of the 9 items would not be available    COLA, others will       site during construction.
Proposed Review Approach Provide requirements in COLA, test results available onsite during construction.
at COLA.                                      become available Accepted                                      during construction 1.05-3   C.1. 5.3.2.2    C.L.5.3.2.2-1 P(5)       Section requires a comparison to              Operating procedures    Provide requirement in COLA DELETE                                              operating procedures.                        will not be available   that procedures will address Accepted                                      at COLA.                limits.
Reference the DCD for the application.
 
Submit License Amendment Request when the final design is complete.1.05-2 DELETE 1.05-3 DELETE C.1.5.2.4.1 C.I.5.2.4.1-2 C.1. 5.3.2.2 C.L.5.3.2.2-1 P(5) P(5)Some of the items are available at COLA, others will become available during construction Operating procedures will not be available at COLA.Provide available information, remainder will be available on site during construction.
COL INFORMATION TIMING - DRAFT 9/15/2006 Item     Section       NRC Item       Pre-WS/   Summary Description                        Availability          Proposed Review Approach No.            Blue Card ID 1.06-1   C.1.6.2.3.4                   P(5)      Section requires test results and periodic  Testing will not be  Provide test requirements in DELETE   C.l.6.2.4.4                             updates for containment tests              complete at COLA or  COLA.
Provide requirement in COLA that procedures will address limits.
C.1.6.2.5.4                             Accepted                                    before the COL is issued.
COL INFORMATION TIMING 9/15/2006 Item Section NRC Item No.-DRAFT Pre-WS/ Blue Card ID P(5)1.06-1 C.1.6.2.3.4 DELETE C.l.6.2.4.4 C.1.6.2.5.4 1.06-2 DELETE 1.08-2 1.08-3 DELETE 1.08-4 C.1.6.4.5 C.1.8.3.2.1 C.1.8.4.1 C.1.8.4.1 P(5) P(5)C.I.8.3.2.1-1 C.18.4.1-1 P(5) C.I.8.4.1-2 P(5) C.1.10.2.3.3-1 P(3) B(5)Summary Description Section requires test results and periodic updates for containment tests Accepted Section requires test results for habitability systems.
1.06-2   C.1.6.4.5                     P(5)      Section requires test results for          Testing will not be  Test requirements provided in DELETE                                            habitability systems.                       performed until after the COLA. Test results Accepted                                    the COL is issued. available onsite as tests are completed.
Accepted This section requires battery characteristic curves to be included in the application.
1.08-2    C.1.8.3.2.1   C.I.8.3.2.1-1 P(5)     This section requires battery              Design requirements  Application to include the characteristic curves to be included in the for safety-related    design requirements, battery application.                               batteries would be    characteristics to be available REJECTED. NRC wants before license is      available at COLA. on site as they become issued.                                                          available.
REJECTED.
1.08-3   C.1.8.4.1      C.18.4.1-1     P(5)     Section requires description of            Functional            General description in COLA, DELETE                                            procedures and training.                    requirements for      remainder available for Accepted                                   operator actions      inspection during available at COLA    construction.
NRC wants before license is issued. Section requires description of procedures and training.
1.08-4    C.1.8.4.1      C.I.8.4.1-2    P(5)      Requirement to identify local power         Requirements for      Describe requirements in sources and transmission paths that could   AAC sources can be    COLA, contracts for AAC be made available to resupply power         described but        supply to be developed plant following a SBO.REJECTED. NRC         transmission and      during construction and wants info before COL issued.               power sources may    available on site.
Accepted Requirement to identify local power sources and transmission paths that could be made available to resupply power plant following a SBO.REJECTED.
be under the control of a TSO and not available at the time of COLA.
NRC wants info before COL issued. This section requires pre-service inspection procedures and acceptance criteria for turbine rotors. Accepted Availability Testing will not be complete at COLA or before the COL is issued. Testing will not be performed until after the COL is issued. Design requirements for safety-related batteries would be available at COLA. Functional requirements for operator actions available at COLA Requirements for AAC sources can be described but transmission and power sources may be under the control of a TSO and not available at the time of COLA. General requirements for the procedures, including acceptance criteria, would be known at the time the application is filed. Procedures and criteria would be developed during Proposed Review Approach Provide test requirements in COLA. Test requirements provided in the COLA. Test results available onsite as tests are completed.
1.10-1    C.1.10.2.3.3  C.1.10.2.3.3-1 P(3)      This section requires pre-service          General requirements  General requirements to be DELETE    C.111.1.10.2.3                B(5)      inspection procedures and acceptance        for the procedures,  included in the application.
Application to include the design requirements, battery characteristics to be available on site as they become available.
criteria for turbine rotors.               including acceptance  Procedures and acceptance Accepted                                    criteria, would be    criteria made available during known at the time the construction.
General description in COLA, remainder available for inspection during construction.
application is filed.
Describe requirements in COLA, contracts for AAC supply to be developed during construction and available on site. General requirements to be included in the application.
Procedures and criteria would be developed during
Procedures and acceptance criteria made available during construction.
 
1.10-1 C.1.10.2.3.3 DELETE C.111.1.10.2.3 COL INFORMATION TIMING 9/15/2006 Item Section NRC Item DRAFT Pre-WS/Summary Description No. Blue Card ID Availability construction.
COL INFORMATION TIMING               DRAFT 9/15/2006 Item     Section     NRC Item       Pre-WS/   Summary Description                         Availability            Proposed Review Approach No.             Blue Card ID construction.
Proposed Review Approach 1.13-1 DELETE 1.13-2 DELETE C.1.13.1.2.1 C.1.13.1.2.1-1 P(3)This section requires an applicant to provide an organization chart for the operating organization.
1.13-1   C.1.13.1.2.1 C.1.13.1.2.1-1 P(3)       This section requires an applicant to       General organization    Provide general organization DELETE                                          provide an organization chart for the       description available  in the application, make operating organization. The detailed       for application,        detailed org chart available organization won't be known at the time     detailed description    for inspection during the application is filed. A high level     available during        construction.
The detailed organization won't be known at the time the application is filed. A high level organization chart would be available then and more details filled in during construction.
organization chart would be available then construction.
This position is consistent with SRP 13.1-13.2, Rev. 5 dtd 7/05 Accepted The introduction to this section requires identification of persons (by position) who are responsible for writing and approving procedures.
and more details filled in during construction. This position is consistent with SRP 13.1-13.2, Rev. 5 dtd 7/05 Accepted 1.13-2    C.1.1 3.5    C.I.13.5-1    B(3)      The introduction to this section requires   General description    General description in COLA, DELETE                                          identification of persons (by position) who of the position and    remainder available for are responsible for writing and approving   experience              inspection during procedures. This level of detail would not requirements for        construction.
This level of detail would not be known at the time the application is submitted.
be known at the time the application is     procedure writers and submitted.                                 approvers available Accepted                                   at time of application.
Accepted General organization description available for application, detailed description available during construction.
Specific responsibilities would become available during construction
General description of the position and experience requirements for procedure writers and approvers available at time of application.
 
Specific responsibilities would become available during construction Provide general organization in the application, make detailed org chart available for inspection during construction.
COL INFORMATION TIMING - DRAFT 9/15/2006 Item      Section      NRC Item      Pre-WS/  Summary Description                          Availability          ProDosed Review ADDroach No.            Blue Card ID 1.13-3    C.1.1 3.5.2.1 C.1.13.5.2.1-2 B(3)     Guidance requires that each procedure          Procedure types      Classification of types of DELETE                                          performed by licensed operators be            could be classified. procedures could be included identified by title and included in a                                in the application and the described classification system. This                                details developed during level of detail will not be known at the time                        construction and available for of application.                                                      inspection.
General description in COLA, remainder available for inspection during construction.
Accepted 1.13-4    C.1.13.5.2.1A C.1.13.5.2.1-3 B(3)     Requires identification of the groups        The part of the       Part of the organization responsible for procedure development,         organization          responsible identified from maintenance and format. This level of         responsible would be  the high level organization detail would not be known at the time of       available and the    chart in the application.
C.1.1 3.5 C.I.13.5-1 B(3)
application.Accepted per App. 1 - text not     details would become  Detailed assignments made changed.                                      available during      available on site as they are construction.        defined.
COL INFORMATION TIMING -DRAFT 9/15/2006 Item Section NRC Item Pre-WS/No. Blue Card ID C.1.13.5.2.1-2 B(3)1.13-3 DELETE 1.13-4 C.1.1 3.5.2.1 C.1.13.5.2.1A C.1.13.5.2.1-3 B(3)Summary Description Guidance requires that each procedure performed by licensed operators be identified by title and included in a described classification system. This level of detail will not be known at the time of application.
1.13-5   C.1. 13.5.2.1 C.1.13.5.2.1-2 B(3)      Section 13.5.2.1, third sentence: The         The general content  COLA would include a general format and content of each class       will be available at  description of the general of procedures should be described.             the time the COLA is  content of each class of Accepted per App. 1 - text not changed         filed. Format would  procedure. Writer's guide be developed as part  avail;able during construction.
Accepted Requires identification of the groups responsible for procedure development, maintenance and format. This level of detail would not be known at the time of application.Accepted per App. 1 -text not changed.
of a writer's guide after the COL is issued 1.14-1   C.1. 14.2.2   C.1.14.2.2-3   P(3)     SAR should describe how and to what            General requirements  Submit general requirements extent the applicant's plant operating and    for plant staff      in COLA, detailed procedures technical staff will participate in each      participation defined available for inspection on major test phase.                             prior to application; site prior to to Accepted per App. 1 but text not changed. detailed requirements     commencement of preop defined in procedures testing.
Section 13.5.2.1, third sentence:
prior to commencement of
The general format and content of each class of procedures should be described.
                                                                                              .preop testing
Accepted per App. 1 -text not changed SAR should describe how and to what extent the applicant's plant operating and technical staff will participate in each major test phase. Accepted per App. 1 but text not changed.1.13-5 C.1. 13.5.2.1 1.14-1 C.1. 14.2.2 C.1.13.5.2.1-2 B(3) C.1.14.2.2-3 P(3)Availability Procedure types could be classified.
 
The part of the organization responsible would be available and the details would become available during construction.
COL INFORMATION TIMING - DRAFT 9/15/2006 Item      Section    NRC Item      Pre-WS/  Summary Description                        Availability          Proposed Review Approach No.           Blue Card ID 1.14-2    C.1.14.2.4  C.!.14.2.4-1  P(4)      The wording in the section implies that the Admin Control          The COLA could contain a DELETE                                        details of administrative control          procedures will be    description of the procedures will be known at the time the    developed during      requirements for development COLA is submitted.                         construction.         of these procedures and the Accepted                                                          procedures would be available on site as they are completed.
The general content will be available at the time the COLA is filed. Format would be developed as part of a writer's guide after the COL is issued General requirements for plant staff participation defined prior to application; detailed requirements defined in procedures prior to commencement of .preop testing Classification of types of procedures could be included in the application and the details developed during construction and available for inspection.
1.14-3    C.1.14.2.8  C.1. 14.2.8-1 P(4)     This section requests a description of how  Recent operating and  The COLA could include a operating and test experience is            test experience would  comitment to review incorporated into the development of test  be reviewed just prior operating experience and the procedures.                                 to writing the test    test procedures would be Accepted per App. I - text not changed. procedures during      available on site as they are construction.          completed.
Part of the organization responsible identified from the high level organization chart in the application.
1.14-4   C.1.14.2.11 C.1.14.2,11-1 P(4)     This section requires that each "test"      The test procedures    These test procedures would required to be completed before fuel load  and even a detailed    be available on site as they or designed to satisfy ITAAC should be      listing of the tests  are completed.
Detailed assignments made available on site as they are defined.
cross referenced and provided with the     would not typically be application.                               available prior to Accepted per App. I - text not changed. COLA 1.14-5    C.1.14.2.11 C./. 14.2.11-3 P(4)      This section requires the sequential test  The detailed test     Test schedules will be DELETE                                        schedule for each SSC be provided with     schedule would not    available on site as they are the application                             typically be available completed.
COLA would include a description of the general content of each class of procedure.
Accepted                                   prior to COLA.
Writer's guide avail;able during construction.
1.17-1    C.1.17.5.1  C.L 17.5.1-3  B(3)      This section requires that the planned     Decisions related to  General QA program sharing of personnel between units be       sharing personnel      requirements described in the addressed in the COLA. REJECTED             would not be finalized COLA. If a decision is made at the time of COLA. to share personnel, it would This level of detail  be documented in should not be          administrative procedures required in the COLA  prior to fuel load.
Submit general requirements in COLA, detailed procedures available for inspection on site prior to to commencement of preop testing.ProDosed Review ADDroach COL INFORMATION TIMING -DRAFT 9/15/2006 Item Section NRC Item Pre-WS/No. Blue Card ID C.!.14.2.4-1 P(4)1.14-2 DELETE 1.14-3 C.1.14.2.4 C.1.14.2.8 C.1. 14.2.8-1 P(4)Summary Description The wording in the section implies that the details of administrative control procedures will be known at the time the COLA is submitted.
 
Accepted This section requests a description of how operating and test experience is incorporated into the development of test procedures.
COL INFORMATION TIMING - DRAFT 9/15/2006 Item      Section  NRC Item  Pre-WSI  Summary Description                        Availability          Proposed Review Approach No.        Blue Card ID 1.17-2   C.1.17.6 ????      P(3)     This item requires a listing of SSCs        A general description  Provide a general description (1.1.5)                       explicitly mentioned in the EOPs. EOPs      of how the EOPs will  in the COLA. EOPs and the will not be available at time of COLA.      be addressed in the    requested listing would be NOT ADDRESSED                              Maintenance Rule      available on site for program available at   inspection during the time of           construction.
Accepted per App. I -text not changed.
application.
This section requires that each "test" required to be completed before fuel load or designed to satisfy ITAAC should be cross referenced and provided with the application.
1.17-3    C.1.17.6 C.1.17.6-4 B(3)      General content issues for the COLA.        General description    General description in COLA, DELETE                                  Guidance included requirements for         of the program        remainder available for information on several aspects of the MR    including              inspection during program that would not exist at the time of requirements          construction.
Accepted per App. I -text not changed.
application.                                available at the time Accepted                                    of application. Other aspects would be developed after the license is issued.
This section requires the sequential test schedule for each SSC be provided with the application Accepted This section requires that the planned sharing of personnel between units be addressed in the COLA. REJECTED 1.14-4 1.14-5 DELETE 1.17-1 C. 1. 14.2.11 C.1.14.2,11-1 C.1.14.2.11 C./. 14.2.11-3 P(4) P(4) B(3)Availability Admin Control procedures will be developed during construction.
1.17-4    C.1.17.6 C.1.17.6-7 B(5)      The site personnel qualification and        General position      Provide general requirements DELETE                                  functional descriptions level of detail is  descriptions would be  for positions in the application much greater than that specified in        available in the      and detailed procedures C.13.1. For example, the listing includes  application. Detailed  would be available on site as titles like Shift Supervisors, Shift        position descriptions  they become available.
Recent operating and test experience would be reviewed just prior to writing the test procedures during construction.
Technical Advisors, Reactor Operators,      would become etc. instead of licensed operators and      available during non-licensed operators.                    construction.
The test procedures and even a detailed listing of the tests would not typically be available prior to COLA The detailed test schedule would not typically be available prior to COLA. Decisions related to sharing personnel would not be finalized at the time of COLA. This level of detail should not be required in the COLA Proposed Review Approach The COLA could contain a description of the requirements for development of these procedures and the procedures would be available on site as they are completed.
Accepted 1.17-5   C.1.17.6 C.1.17.6-8 B(5)     This section requires detailed training    General training      General requirements DELETE                                  procedures for Maintenance Rule            requireents would be  discussed in the application, personnel.                                   available at the time detailed procedures available Accepted                                    of COLA.               on site as they become available.
The COLA could include a comitment to review operating experience and the test procedures would be available on site as they are completed.
1.17-6   C.1.17.6 C.1.17.6-9 B(5)     This section requires detailed descriptions  Program                Program requirements DELETE                                  of site procedures and database              requirements          provided in COLA, detailed descriptions for Maintenance Rule          consistent with the    descriptions available on site implementation                              description in C.IV.4   as they become available.
These test procedures would be available on site as they are completed.
Accepted                                    available in the
Test schedules will be available on site as they are completed.
 
General QA program requirements described in the COLA. If a decision is made to share personnel, it would be documented in administrative procedures prior to fuel load.C.1.17.5.1 C.L 17.5.1-3 COL INFORMATION TIMING -DRAFT 9/15/2006 Item Section 1.17-2 1.17-3 DELETE 1.17-4 DELETE 1.17-5 DELETE 1.17-6 DELETE C.1.17.6 (1.1.5) C.1.17.6 C.1.17.6 C.1.17.6 C.1.17.6 NRC Item Pre-WSI No. Blue Card ID ???? P(3) C.1.17.6-4 B(3) C.1.17.6-7 B(5) C.1.17.6-8 B(5) C.1.17.6-9 B(5)Summary Description This item requires a listing of SSCs explicitly mentioned in the EOPs. EOPs will not be available at time of COLA. NOT ADDRESSED General content issues for the COLA. Guidance included requirements for information on several aspects of the MR program that would not exist at the time of application.
COL INFORMATION TIMING - DRAFT 9/15/2006 Item      Section  NRC Item    Pre-WS/  Summary Description                          Availability            Proposed Review Approach No.        Blue Card ID application.
Accepted The site personnel qualification and functional descriptions level of detail is much greater than that specified in C.13.1. For example, the listing includes titles like Shift Supervisors, Shift Technical Advisors, Reactor Operators, etc. instead of licensed operators and non-licensed operators.
1.18-1    C.1.18  C.I. 18-1  B(5)     This section states that by the time of       Fewer than 11          Application will describe DELETE                                  application, the first 11 elements should    elements will be        completed elements. Others be complete.                                  complete. Those not    will be available as completed Accepted                                      completed in DCD        during construction.
Accepted This section requires detailed training procedures for Maintenance Rule personnel.
are covered by DAC.
Accepted This section requires detailed descriptions of site procedures and database descriptions for Maintenance Rule implementation Accepted Availability A general description of how the EOPs will be addressed in the Maintenance Rule program available at the time of application.
11.01    C.I1.1.4 C.l. 1.4-1  B(4)      This section requires that the PRA            The plant design will   The PRA should reasonably 1DELETE                                  realistically reflect the actual plant design not be complete at      reflect the plant design as it at the time the COLA is                      the time the COLA is    exists at the time the COLA is subm itted.Accepted                          submitted.             submitted.
General description of the program including requirements available at the time of application.
N/A        N/A      This section requires manuals, reports,      Tech Spec              Provide the Admin Controls Submitted            etc., identified in the Tech Spec Admin      requirements to        section in the application and after WIS 6          Controls Sections to be submitted with the   develop these          develop the programs during application.                                 documents will be       construction. This is Not addressed - guidance still requires      included in the        consistent with the approach submittal of these documents.                application but the    taken for regulatory required details needed to      programs.
Other aspects would be developed after the license is issued. General position descriptions would be available in the application.
complete the documents won't be known.
Detailed position descriptions would become available during construction.
111.03-1  C.111.3  C.111.3-5  P(2)      Some required environmental information      Preliminary            Submit preliminary will not be available at the time the COLA    information available  information with COLA.
General training requireents would be available at the time of COLA. Program requirements consistent with the description in C.IV.4 available in the Proposed Review Approach Provide a general description in the COLA. EOPs and the requested listing would be available on site for inspection during construction.
is submitted. An example is the final        at time of application. Updated information available routing of transmission lines                Final information      during construction for NRC REJECTED                                      would be developed      inspection.
General description in COLA, remainder available for inspection during construction.
during construction.
Provide general requirements for positions in the application and detailed procedures would be available on site as they become available.
 
General requirements discussed in the application, detailed procedures available on site as they become available.
COL INFORMATION TIMING - DRAFT 9/15/2006 Item      Section  NRC Item    Pre-WSI  Summary Description                          Availability          Proposed Review Approach No.        Blue Card ID 111.04-1 C.111.4.3 C.1114-2    P(2)      In Section C.II.4.3, the staff says it        COL Action and        Identify required information intends to include license conditions for    Information items      in COLA with a commitment COL action or information items that a        identified in generic  to complete the actions.
Program requirements provided in COLA, detailed descriptions available on site as they become available.
COL applicant "cannot address" before        DCD and ESP and        Documentation of completion the license is issued. COL applications      required information  available during review or must, and therefore will, address all        to be developed        construction.
COL INFORMATION TIMING -DRAFT 9/15/2006 Item Section NRC Item Pre-WS/ Summary Description No. Blue Card ID Availability application.
required COL items. For items that refer      available for the to actions that will take place after the     COLA. Information license is issued, COLAs will contain        required to document commitments to complete those activities      completion would be at the appropriate point in the construction  available at various or operation of the plant. These              times during COLA commitments are expected to be               review and inspected as part of the NRC construction    construction.
Proposed Review Approach 1.18-1 DELETE 11.01 1 DELETE C.1.18 C.I1.1.4 111.03-1 C.111.3 C.I. 18-1 C.l. 1.4-1 N/A Submitted after WIS 6 C.111.3-5 B(5) B(4) N/A P(2)This section states that by the time of application, the first 11 elements should be complete.
inspection program and typically do not rise to the level of significance that would call for creation of a license condition.
Accepted This section requires that the PRA realistically reflect the actual plant design at the time the COLA is subm itted.Accepted This section requires manuals, reports, etc., identified in the Tech Spec Admin Controls Sections to be submitted with the application.
Why does the staff intend to create a suite of license conditions, rather than rely on its CIP, for COL Items that refer to actions that will take place after the license is issued?
Not addressed
Not completely addressed.
-guidance still requires submittal of these documents.
111.05    C.I1.5.1  C.I11.5.1-3 B(5)      This section states that "detailed design      As discussed with the  Identify the information that is 1DELETE                                    information should be submitted early in      Staff, the            available in the COLA and the COL application phase". Specifically      development process    supplement the application for I and C systems, at the time of            for I and C designs    information after submittal as application or shortly thereafter, sufficient  will proceed beyond    design details are completed.
Some required environmental information will not be available at the time the COLA is submitted.
as-built and procurement information is      the COL application available for NRC review to assure that        date and even DAC are satisfied.Accepted                    beyond COL issuance
An example is the final routing of transmission lines REJECTED Fewer than 11 elements will be complete.
 
Those not completed in DCD are covered by DAC. The plant design will not be complete at the time the COLA is submitted.
COL INFORMATION TIMING - DRAFT 9/15/2006 Item     Section   NRC Item   Pre-WS/  Summary Description                        Availability        Proposed Review Approach No.         Blue Card ID 111.05-2 C.111.5.1 C.111.5.1-4 P(5)      The first paragraph states that sufficient  Some DAC            Describe DAC completion DELETE                                    as-built and as-procured information to     completion          information available at the address DAC should    be  available at the information will be  time of application.
Tech Spec requirements to develop these documents will be included in the application but the details needed to complete the documents won't be known. Preliminary information available at time of application.
time of the COL application submittal, or  available. Remainder Remainder available on site shortly after and that this detailed design will be completed    as it is completed.
Final information would be developed during construction.
information should be submitted during      during construction.
Application will describe completed elements.
the COL application phase. This implies an unrealistic expectation of the level of detail of information available at the time of submitting the application. Further, in some design areas, as-built and as procured information may not be available until after the COL review is completed. It should not be expected that applicants procure I&C equipment, valves, etc. prior to receipt of the COL. As-built information may not.be available until the construction phase; which is authorized by the COL.
Others will be available as completed during construction.
In other forums, NRC has consistently and correctly recognized that DAC may be completed after the COL is issued.
The PRA should reasonably reflect the plant design as it exists at the time the COLA is submitted.
We recommend that the first two sentences of this paragraph be deleted.
Provide the Admin Controls section in the application and develop the programs during construction.
Accepted}}
This is consistent with the approach taken for regulatory required programs.
Submit preliminary information with COLA. Updated information available during construction for NRC inspection.
COL INFORMATION TIMING -DRAFT 9/15/2006 Item Section NRC Item Pre-WSI No. Blue Card ID C.1114-2 P(2)111.04-1 C.111.4.3 Summary Description In Section C.II.4.3, the staff says it intends to include license conditions for COL action or information items that a COL applicant "cannot address" before the license is issued. COL applications must, and therefore will, address all required COL items. For items that refer to actions that will take place after the license is issued, COLAs will contain commitments to complete those activities at the appropriate point in the construction or operation of the plant. These commitments are expected to be inspected as part of the NRC construction inspection program and typically do not rise to the level of significance that would call for creation of a license condition.
Why does the staff intend to create a suite of license conditions, rather than rely on its CIP, for COL Items that refer to actions that will take place after the license is issued? Not completely addressed.
This section states that "detailed design information should be submitted early in the COL application phase". Specifically for I and C systems, at the time of application or shortly thereafter, sufficient as-built and procurement information is available for NRC review to assure that DAC are satisfied.Accepted Availability COL Action and Information items identified in generic DCD and ESP and required information to be developed available for the COLA. Information required to document completion would be available at various times during COLA review and construction.
Proposed Review Approach Identify required information in COLA with a commitment to complete the actions.
Documentation of completion available during review or construction.
111.05 1 DELETE C.I1.5.1 C.I11.5.1-3 B(5)As discussed with the Staff, the development process for I and C designs will proceed beyond the COL application date and even beyond COL issuance Identify the information that is available in the COLA and supplement the application information after submittal as design details are completed.
COL INFORMATION TIMING -DRAFT 9/15/2006 Item Section NRC Item Pre-WS/Summary Description No. Blue Card ID 111.05-2 DELETE C.111.5.1 C.111.5.1-4 P(5)The first paragraph states that sufficient as-built and as-procured information to address DAC should be available at the time of the COL application submittal, or shortly after and that this detailed design information should be submitted during the COL application phase. This implies an unrealistic expectation of the level of detail of information available at the time of submitting the application.
Further, in some design areas, as-built and as procured information may not be available until after the COL review is completed.
It should not be expected that applicants procure I&C equipment, valves, etc. prior to receipt of the COL. As-built information may not.be available until the construction phase; which is authorized by the COL. In other forums, NRC has consistently and correctly recognized that DAC may be completed after the COL is issued. We recommend that the first two sentences of this paragraph be deleted.
Accepted Availability Some DAC completion information will be available.
Remainder will be completed during construction.
Proposed Review Approach Describe DAC completion information available at the time of application.
Remainder available on site as it is completed.}}

Latest revision as of 13:59, 23 November 2019

Regulatory Guide DG-1145 - Pre-Workshop Comments, COL Application Information Requirements
ML062640042
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Issue date: 09/15/2006
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DG-1145
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DG-1 145 PRE-WORKSHOP 7 COMMENTS COMBINED LICENSE APPLICATION INFORMATION REQUIREMENTS During the first 6 workshops on Draft DG-1 145, the timing and applicability of information requirements were discussed in several technical areas. Industry addressed these requirements in several pre-workshop and "Blue Card" comments. During Workshop 5, the Staff commented that COLA guidance should identify the information required for a reasonable assurance finding vs.

what information would be available at the time of application. Industry presented tables at Workshop 6 that identified several instances where the information required is either 1) not appropriate for a COL application or 2) not available at the time of application submittal but would be available later.

The following revised table identifies examples of information requirements in these categories identified in the draft-for-comment version of DG-1 145 published September 6, 2006. Revisions to the earlier table are shown in red and italics. It should be noted that the examples are typical and the availability of information may vary for different applications. Further review of DG-1 145 may result in additions to the table. The table is draft but it provides a basis for further discussion of these issues.

COL INFORMATION TIMING - DRAFT 9/15/2006 Item Section NRC Item Pre-WS/ Summary Description Availability Proposed Review Approach No. Blue Card ID 1.02-1 C.1.2.3.3 C.L.2.3.3-1 B (4) Submit 2 consecutive years of met data. 1 year prior to Submit 1st yr with application, NRC states approachacceptable but text submittal, 2nd 2nd year as COLA still requires2 years data prior to complete after supplement docketing. submittal 1.03-1 C.1.3.6.3(1)(a) C.L.3.6.3-1 P (3) Submit types of materials and material Types of materials Submit material types DELETE specifications (including heat numbers), and specifications for w/application, heat numbers for base metals, weldments, fittings and most components available on site before fuel safe ends. available by load for inspection Removed Heat numbers. application, heat numbers available during construction 1.03-2 C.1.3.6(3)(b) C.1.3.6.3-3 P(3) Requires application include material Representative Submit representative properties including toughness (J-R properties available properties with application; curves), tensile (stress-strain curves) data at application; as-built as-built material properties at temperatures near the upper range of properties available available on-site before fuel normal operating temperatures. during construction. load for inspection.

Accepted per App. I but text not modified.

1.03-3 C.1.3.6.3(2)(a) C.I.3.6.3-5,-6 P(4) This section requires that the application As-built drawings will As-built drawings would be include as-built drawings of pipe be completed during made available as they are geometry, etc. construction. Design completed on site for Accepted per App. I but text not modified. piping isometrics inspection.

available in application.

1.03-4 C.1. 3.9.2.4 C.L.3.9.2.4-1 P(5) This section implies that the pre Applicable to follow Provide results in COLA.

operational flow-induced testing of reactor on plants. Provide internals would be complete at the time of results of operating COLA. Based on the workshop plant testing.

discussion, we understand this applies to later plants referencing results from an operating plant.

Clarified in App. I but text not changed.

COL INFORMATION TIMING - DRAFT 9/15/2006 Item Section NRC Item Pre-WSI Summary Description Availability Proposed Review Approach No. Blue Card ID 1.03-5 C.1.3.13.1.4 C.1.3.13.1.4-1 P(5) Requires preservice inspection test Test requirements, Provide requirements in results. criteria available at COLA, test results available Accepted per App. 1 but text not changed. COLA. Results onsite during construction.

available during construction.

1.04- C.I.4 C.I.4-2 B(2) First bullet, first slide. This bullet For COLAs Reference the DCD for the 1DELETE (presentation) identified the COL Information item that referencing a certified application. Submit License any changes to the referenced design be design, the fuel Amendment Request when identified to the Staff. As discussed in the design in the generic the final design is complete.

workshop, the final fuel design and DCD is the COLA loading pattern may not be available until design. During after the application and possibly after the construction, the final COL is issued. In this case, the final design and loading design would be submitted as a license pattern will be amendment request under the Tier 2* developed.

change process after the COL is issued.

Does the staff agree that the design in the generic DCD is the required design until the license amendment request is approved, and the COL may be issued based on the approved fuel design described in the generic DCD?Accepted 1.05-2 C.1.5.2.4.1 C.I.5.2.4.1-2 P(5) This section provides a list of information Some of the items Provide available information, DELETE required to be included in the application. are available at remainder will be available on Four of the 9 items would not be available COLA, others will site during construction.

at COLA. become available Accepted during construction 1.05-3 C.1. 5.3.2.2 C.L.5.3.2.2-1 P(5) Section requires a comparison to Operating procedures Provide requirement in COLA DELETE operating procedures. will not be available that procedures will address Accepted at COLA. limits.

COL INFORMATION TIMING - DRAFT 9/15/2006 Item Section NRC Item Pre-WS/ Summary Description Availability Proposed Review Approach No. Blue Card ID 1.06-1 C.1.6.2.3.4 P(5) Section requires test results and periodic Testing will not be Provide test requirements in DELETE C.l.6.2.4.4 updates for containment tests complete at COLA or COLA.

C.1.6.2.5.4 Accepted before the COL is issued.

1.06-2 C.1.6.4.5 P(5) Section requires test results for Testing will not be Test requirements provided in DELETE habitability systems. performed until after the COLA. Test results Accepted the COL is issued. available onsite as tests are completed.

1.08-2 C.1.8.3.2.1 C.I.8.3.2.1-1 P(5) This section requires battery Design requirements Application to include the characteristic curves to be included in the for safety-related design requirements, battery application. batteries would be characteristics to be available REJECTED. NRC wants before license is available at COLA. on site as they become issued. available.

1.08-3 C.1.8.4.1 C.18.4.1-1 P(5) Section requires description of Functional General description in COLA, DELETE procedures and training. requirements for remainder available for Accepted operator actions inspection during available at COLA construction.

1.08-4 C.1.8.4.1 C.I.8.4.1-2 P(5) Requirement to identify local power Requirements for Describe requirements in sources and transmission paths that could AAC sources can be COLA, contracts for AAC be made available to resupply power described but supply to be developed plant following a SBO.REJECTED. NRC transmission and during construction and wants info before COL issued. power sources may available on site.

be under the control of a TSO and not available at the time of COLA.

1.10-1 C.1.10.2.3.3 C.1.10.2.3.3-1 P(3) This section requires pre-service General requirements General requirements to be DELETE C.111.1.10.2.3 B(5) inspection procedures and acceptance for the procedures, included in the application.

criteria for turbine rotors. including acceptance Procedures and acceptance Accepted criteria, would be criteria made available during known at the time the construction.

application is filed.

Procedures and criteria would be developed during

COL INFORMATION TIMING DRAFT 9/15/2006 Item Section NRC Item Pre-WS/ Summary Description Availability Proposed Review Approach No. Blue Card ID construction.

1.13-1 C.1.13.1.2.1 C.1.13.1.2.1-1 P(3) This section requires an applicant to General organization Provide general organization DELETE provide an organization chart for the description available in the application, make operating organization. The detailed for application, detailed org chart available organization won't be known at the time detailed description for inspection during the application is filed. A high level available during construction.

organization chart would be available then construction.

and more details filled in during construction. This position is consistent with SRP 13.1-13.2, Rev. 5 dtd 7/05 Accepted 1.13-2 C.1.1 3.5 C.I.13.5-1 B(3) The introduction to this section requires General description General description in COLA, DELETE identification of persons (by position) who of the position and remainder available for are responsible for writing and approving experience inspection during procedures. This level of detail would not requirements for construction.

be known at the time the application is procedure writers and submitted. approvers available Accepted at time of application.

Specific responsibilities would become available during construction

COL INFORMATION TIMING - DRAFT 9/15/2006 Item Section NRC Item Pre-WS/ Summary Description Availability ProDosed Review ADDroach No. Blue Card ID 1.13-3 C.1.1 3.5.2.1 C.1.13.5.2.1-2 B(3) Guidance requires that each procedure Procedure types Classification of types of DELETE performed by licensed operators be could be classified. procedures could be included identified by title and included in a in the application and the described classification system. This details developed during level of detail will not be known at the time construction and available for of application. inspection.

Accepted 1.13-4 C.1.13.5.2.1A C.1.13.5.2.1-3 B(3) Requires identification of the groups The part of the Part of the organization responsible for procedure development, organization responsible identified from maintenance and format. This level of responsible would be the high level organization detail would not be known at the time of available and the chart in the application.

application.Accepted per App. 1 - text not details would become Detailed assignments made changed. available during available on site as they are construction. defined.

1.13-5 C.1. 13.5.2.1 C.1.13.5.2.1-2 B(3) Section 13.5.2.1, third sentence: The The general content COLA would include a general format and content of each class will be available at description of the general of procedures should be described. the time the COLA is content of each class of Accepted per App. 1 - text not changed filed. Format would procedure. Writer's guide be developed as part avail;able during construction.

of a writer's guide after the COL is issued 1.14-1 C.1. 14.2.2 C.1.14.2.2-3 P(3) SAR should describe how and to what General requirements Submit general requirements extent the applicant's plant operating and for plant staff in COLA, detailed procedures technical staff will participate in each participation defined available for inspection on major test phase. prior to application; site prior to to Accepted per App. 1 but text not changed. detailed requirements commencement of preop defined in procedures testing.

prior to commencement of

.preop testing

COL INFORMATION TIMING - DRAFT 9/15/2006 Item Section NRC Item Pre-WS/ Summary Description Availability Proposed Review Approach No. Blue Card ID 1.14-2 C.1.14.2.4 C.!.14.2.4-1 P(4) The wording in the section implies that the Admin Control The COLA could contain a DELETE details of administrative control procedures will be description of the procedures will be known at the time the developed during requirements for development COLA is submitted. construction. of these procedures and the Accepted procedures would be available on site as they are completed.

1.14-3 C.1.14.2.8 C.1. 14.2.8-1 P(4) This section requests a description of how Recent operating and The COLA could include a operating and test experience is test experience would comitment to review incorporated into the development of test be reviewed just prior operating experience and the procedures. to writing the test test procedures would be Accepted per App. I - text not changed. procedures during available on site as they are construction. completed.

1.14-4 C.1.14.2.11 C.1.14.2,11-1 P(4) This section requires that each "test" The test procedures These test procedures would required to be completed before fuel load and even a detailed be available on site as they or designed to satisfy ITAAC should be listing of the tests are completed.

cross referenced and provided with the would not typically be application. available prior to Accepted per App. I - text not changed. COLA 1.14-5 C.1.14.2.11 C./. 14.2.11-3 P(4) This section requires the sequential test The detailed test Test schedules will be DELETE schedule for each SSC be provided with schedule would not available on site as they are the application typically be available completed.

Accepted prior to COLA.

1.17-1 C.1.17.5.1 C.L 17.5.1-3 B(3) This section requires that the planned Decisions related to General QA program sharing of personnel between units be sharing personnel requirements described in the addressed in the COLA. REJECTED would not be finalized COLA. If a decision is made at the time of COLA. to share personnel, it would This level of detail be documented in should not be administrative procedures required in the COLA prior to fuel load.

COL INFORMATION TIMING - DRAFT 9/15/2006 Item Section NRC Item Pre-WSI Summary Description Availability Proposed Review Approach No. Blue Card ID 1.17-2 C.1.17.6 ???? P(3) This item requires a listing of SSCs A general description Provide a general description (1.1.5) explicitly mentioned in the EOPs. EOPs of how the EOPs will in the COLA. EOPs and the will not be available at time of COLA. be addressed in the requested listing would be NOT ADDRESSED Maintenance Rule available on site for program available at inspection during the time of construction.

application.

1.17-3 C.1.17.6 C.1.17.6-4 B(3) General content issues for the COLA. General description General description in COLA, DELETE Guidance included requirements for of the program remainder available for information on several aspects of the MR including inspection during program that would not exist at the time of requirements construction.

application. available at the time Accepted of application. Other aspects would be developed after the license is issued.

1.17-4 C.1.17.6 C.1.17.6-7 B(5) The site personnel qualification and General position Provide general requirements DELETE functional descriptions level of detail is descriptions would be for positions in the application much greater than that specified in available in the and detailed procedures C.13.1. For example, the listing includes application. Detailed would be available on site as titles like Shift Supervisors, Shift position descriptions they become available.

Technical Advisors, Reactor Operators, would become etc. instead of licensed operators and available during non-licensed operators. construction.

Accepted 1.17-5 C.1.17.6 C.1.17.6-8 B(5) This section requires detailed training General training General requirements DELETE procedures for Maintenance Rule requireents would be discussed in the application, personnel. available at the time detailed procedures available Accepted of COLA. on site as they become available.

1.17-6 C.1.17.6 C.1.17.6-9 B(5) This section requires detailed descriptions Program Program requirements DELETE of site procedures and database requirements provided in COLA, detailed descriptions for Maintenance Rule consistent with the descriptions available on site implementation description in C.IV.4 as they become available.

Accepted available in the

COL INFORMATION TIMING - DRAFT 9/15/2006 Item Section NRC Item Pre-WS/ Summary Description Availability Proposed Review Approach No. Blue Card ID application.

1.18-1 C.1.18 C.I. 18-1 B(5) This section states that by the time of Fewer than 11 Application will describe DELETE application, the first 11 elements should elements will be completed elements. Others be complete. complete. Those not will be available as completed Accepted completed in DCD during construction.

are covered by DAC.

11.01 C.I1.1.4 C.l. 1.4-1 B(4) This section requires that the PRA The plant design will The PRA should reasonably 1DELETE realistically reflect the actual plant design not be complete at reflect the plant design as it at the time the COLA is the time the COLA is exists at the time the COLA is subm itted.Accepted submitted. submitted.

N/A N/A This section requires manuals, reports, Tech Spec Provide the Admin Controls Submitted etc., identified in the Tech Spec Admin requirements to section in the application and after WIS 6 Controls Sections to be submitted with the develop these develop the programs during application. documents will be construction. This is Not addressed - guidance still requires included in the consistent with the approach submittal of these documents. application but the taken for regulatory required details needed to programs.

complete the documents won't be known.

111.03-1 C.111.3 C.111.3-5 P(2) Some required environmental information Preliminary Submit preliminary will not be available at the time the COLA information available information with COLA.

is submitted. An example is the final at time of application. Updated information available routing of transmission lines Final information during construction for NRC REJECTED would be developed inspection.

during construction.

COL INFORMATION TIMING - DRAFT 9/15/2006 Item Section NRC Item Pre-WSI Summary Description Availability Proposed Review Approach No. Blue Card ID 111.04-1 C.111.4.3 C.1114-2 P(2) In Section C.II.4.3, the staff says it COL Action and Identify required information intends to include license conditions for Information items in COLA with a commitment COL action or information items that a identified in generic to complete the actions.

COL applicant "cannot address" before DCD and ESP and Documentation of completion the license is issued. COL applications required information available during review or must, and therefore will, address all to be developed construction.

required COL items. For items that refer available for the to actions that will take place after the COLA. Information license is issued, COLAs will contain required to document commitments to complete those activities completion would be at the appropriate point in the construction available at various or operation of the plant. These times during COLA commitments are expected to be review and inspected as part of the NRC construction construction.

inspection program and typically do not rise to the level of significance that would call for creation of a license condition.

Why does the staff intend to create a suite of license conditions, rather than rely on its CIP, for COL Items that refer to actions that will take place after the license is issued?

Not completely addressed.

111.05 C.I1.5.1 C.I11.5.1-3 B(5) This section states that "detailed design As discussed with the Identify the information that is 1DELETE information should be submitted early in Staff, the available in the COLA and the COL application phase". Specifically development process supplement the application for I and C systems, at the time of for I and C designs information after submittal as application or shortly thereafter, sufficient will proceed beyond design details are completed.

as-built and procurement information is the COL application available for NRC review to assure that date and even DAC are satisfied.Accepted beyond COL issuance

COL INFORMATION TIMING - DRAFT 9/15/2006 Item Section NRC Item Pre-WS/ Summary Description Availability Proposed Review Approach No. Blue Card ID 111.05-2 C.111.5.1 C.111.5.1-4 P(5) The first paragraph states that sufficient Some DAC Describe DAC completion DELETE as-built and as-procured information to completion information available at the address DAC should be available at the information will be time of application.

time of the COL application submittal, or available. Remainder Remainder available on site shortly after and that this detailed design will be completed as it is completed.

information should be submitted during during construction.

the COL application phase. This implies an unrealistic expectation of the level of detail of information available at the time of submitting the application. Further, in some design areas, as-built and as procured information may not be available until after the COL review is completed. It should not be expected that applicants procure I&C equipment, valves, etc. prior to receipt of the COL. As-built information may not.be available until the construction phase; which is authorized by the COL.

In other forums, NRC has consistently and correctly recognized that DAC may be completed after the COL is issued.

We recommend that the first two sentences of this paragraph be deleted.

Accepted

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