ML070390473

Preliminary Work Product to Support Feb 13, 2007 Public Meeting - Rg 1.206 Section C.IV.2 - Submittal Guidance

ML070390473
Person / Time
Issue date:	02/08/2007
From:	William Reckley NRC/NRO/DNRL/NGIF
To:
References
DG-1145, RG-1.206
Download: ML070390473 (4)

Text

Preliminary Work Product to support February 13. 2007 Public MeetingRG 1.206 Section C.IV.2 RewriteRG 1.206, Page C.IV.2-1 C.IV.2. Submittal Guidance for Combined Licenses (COLs)

The purpose of this section is to provide information to combined license (COL) applicants on methods of submitting COL applications. COL applicants are also referred to U.S. Nuclear Regulatory

Commission (NRC) guidance for submitting electronic documentation. The electronic submission

guidance found on the NRC's public Web site will be updated as appropriate to reflect new conventions

and best practices for the electronic submittal of COL applications.

C.IV.2.1

Background

In accordance with the provisions of 10 CFR 52.3, all correspondence, reports, applications, and other written communications from an applicant, licensee, or holder of a standard design approval to the

NRC concerning regulations, individual license conditions, or the terms and conditions of an early site

permit or standard design approval, must be sent either by mail to the NRC's Document Control Desk, or

where practicable by electronic submission (e.g., CD-ROM). Distribution requirements for specific

correspondence is described in 10 CFR 52.3(b) and summarized in Table C.IV.2.2-1.

Table C.IV.2.2-1. Submission of Documentation per 10 CFR 52.3Type of SubmissionAddressees and Copies (CD-ROM or paper)Regulation Application for amendments of permits and licenses;

reports; and other

communications NRC's Document Control Desk (if on paper, signed original)

1 copy to the appropriate Regional Office

1 copy to the Resident Inspector, if applicable (to be provided under oath or affirmation) 52.3(b)(1) 50.30 Applications and amendments to applications NRC's Document Control Desk (if on paper, signed original)

1 copy to the appropriate Regional Office

1 copy to the Resident Inspector, if applicable (to be provided under oath or affirmation) 52.3(b)(2) 50.30Acceptance review applicationNRC's Document Control Desk (if on paper, signed original)

1 copy to the appropriate Regional Office 52.3(b)(3)

Security plan and related submissions NRC's Document Control Desk (if on paper, signed original)

1 copy to the appropriate Regional Office 52.3(b)(4)

Emergency plan and related submissions NRC's Document Control Desk (if on paper, signed original)

1 copy to the appropriate Regional Office

1 copy to the Resident Inspector, if applicable 52.3(b)(5)Updated FSARNRC's Document Control Desk (if on paper, signed original)

1 copy to the appropriate Regional Office

1 copy to the Resident Inspector, if applicable 52.3(b)(6)

Preliminary Work Product to support February 13. 2007 Public MeetingRG 1.206 Section C.IV.2 RewriteType of SubmissionAddressees and Copies (CD-ROM or paper)RegulationRG 1.206, Page C.IV.2-2 Quality assurance-related submissions NRC's Document Control Desk (if on paper, signed original)

1 copy to the appropriate Regional Office

1 copy to the Resident Inspector, if applicable 52.3(b)(7)

[50.54(a)(3) or

50.55(f)(3)]

Certification of permanent cessation of operations NRC's Document Control Desk (to be provided under oath or affirmation) 52.3(b)(8)

Certification of permanent fuel removal NRC's Document Control Desk (to be provided under oath or affirmation) 52.3(b)(9)

C.IV.2.2 Referencing a Design Certification Rule or Early Site Permit In accordance with the applicable DCR, the COL applicant must include the plant-specific DCD in its application. The plant-specific DCD, as defined in the design certification rules which are set forth

in the DCR II.C, is a combination of the generic DCD and the plant specific departures and exemptions

from the generic DCD. The COL applicant must include the generic DCD in the application. However, per 10 CFR 52.79(b), the generic DCD may be included in the plant specific DCD using incorporation by

reference. To facilitate staff review and support features such as hyperlinks between electronic files, the

actual generic DCD (complete and current to the revision referenced in the COL application) should be

identified as a reference document when an electronic media is used for the COL application. The DCD

and other reference documents to which the application includes hyperlinks should be the files within the

NRC electronic recordkeeping system, ADAMS. Documents related to an ESP may likewise be

incorporated by reference within a COL application and the electronic applications may include

hyperlinks to the ESP references in ADAMS.

The NRC recommends that COL applicants facilitate NRC review of COL applications. One acceptable method to facilitate NRC review is to integrate the generic DCD into the FSAR included in

the COL application. This can be accomplished by inserting actual portions of the generic DCD into the

FSAR or, if using electronic submittals, by providing hyperlinks from the COL application to the

appropriate section of generic DCD. While these are not the only means to include the generic DCD in

the COL application, they will provide the NRC technical reviewer with a complete description of the

area of review in the COL application with ready access to the related discussions in the generic DCD.

Regardless of the incorporation approach selected for referencing the generic DCD in the FSAR, the

applicant is strongly encouraged to clearly distinguish information quoted directly from the generic DCD

from the plant-specific departures and exemptions to the DCD that the NRC will review in the COL

application. In addition, site specific information and operational programs should also be distinguished

from the generic DCD. Applicants are encouraged to clearly identify the information being provided in

the application, including the FSAR, in terms of its role in addressing COL information items, proposing

departures or variances, replacing conceptual design information, and supplementing information

provided in a DCD or ESP. Applicants are likewise encouraged to clearly identify that information that

is specific to the subject application and information that is referencing or will be referenced by another

COL application (e.g., reference or standard information).

It is anticipated that, as described in 10 CFR 52.55(c), some COL applications will reference a design for which a design certification application has been docketed but not granted. Such COL applications may Preliminary Work Product to support February 13. 2007 Public MeetingRG 1.206 Section C.IV.2 RewriteRG 1.206, Page C.IV.2-3 use the above guidance in terms of incorporating by reference the DCD under review by the NRC and clearly indicating relevant departures, COL information items, and other information correlating the

application to the proposed design. The NRC staff, design certificate applicant, and COL applicant will

need to closely coordinate their activities related to the reviews of the proposed design and COL

applications. In some cases, it may be appropriate for a COL applicant to submit a revision of major

COL documents (e.g., the FSAR) to reflect intermediate revisions to the DCD. The COL applicant

should at least submit a letter following each revision of the referenced DCD to supplement the COL

application and acknowledge the related activities in the design review. In all cases, the COL applicant

should submit a revision to its application, including the FSAR and other affected documents, upon the

NRC completing its review and certification of the referenced design.

Some COL applications are expected to reference DCRs for which an amendment to the applicable design certification has been requested but not yet granted by the NRC. The COL applicant is required by Section X.B, "Reporting," of the applicable appendix to10 CFR 52 to submit a report to the NRC describing departures from the certified design documents. The report regarding departures from thecertified design may refer to the request for an amendment to the certified design. The COL applicationmay then be presented in terms of incorporating by reference the DCD under review by the NRC. Within the FSAR and other parts of the application, the COL applicant may co rrelate the proposed departures,COL information items, and other information to the version of DCD under review by the NRC. Asmentioned above, there are several ways to handle the coordination of activities related to the reviews of the DCD and COL applications. The COL applicant should submit a revision to its application, includingthe FSAR and other affected documents, upon the NRC issuing a decision on the request to amend thereferenced design certification.

C.IV.2.3 Electronic SubmissionsEffective January 1, 2004 (68 FR 58792), the NRC amended its rules regarding electronicsubmissions in order to implement the Government Paperwork Elimination Act (GPEA). As stated inthis final rule, entitled "Electronic Maintenance and Submission of Information" (e-rule), the NRC issuedspecific guidance on acceptable procedures for electronic submissions. Since electronic technology isevolving, the staff laid out specific guidance in a document that can be updated as necessary to reflectnew technology and experience. This guidance, entitled "Appendix A: United States NuclearRegulatory Commission (NRC) Guidance for Electronic Submissions to the Commission" (Appendix A)(from now on referred to as "the Guidance Document"), which is posted on the NRC's public Web site at "http://www.nrc.gov/site-help/eie/guid-elec-submission.pdf", supersedes previous information forelectronic submissions under 10 CFR Part 50 and the proposed 10 CFR Part 52. Forms used to submitinformation electronically are available on the NRC's public Web site at "http://www.nrc.gov/site-help/eie.html."

10 CFR 52.3 addresses electronic submissions in a general manner for COL applicants. The NRC guidance document for electronic submittals will specifically address COL applications and describes anacceptable protocol to provide new or revised documents, reference documents available in ADAMS,and a companion file to describe the content of the CD-ROM or DVD. COL applicants should use theprocess described in the Guidance Document to the final e-rule when submitting documents to the NRCin electronic format.

Preliminary Work Product to support February 13. 2007 Public MeetingRG 1.206 Section C.IV.2 RewriteRG 1.206, Page C.IV.2-4 C.IV.2.4 Submission of Revised or Additional InformationDuring the licensing process, the applicant may submit various revisions of COL applications,or portions thereof, as the review progresses. The Guidance Document to the e-rule provides informationregarding the process to submit changes to electronic documents. For electronic submittals, a completerevised document (e.g., a FSAR) is submitted even if only portions of the document are being revised. If the revised document includes hyperlinks to other documents within the COL application and thosedocuments are not being revised (e.g., revised FSAR with hyperlinks to same generic DCD), thereferenced documents may be identified as reference documents on the CD-ROM or DVD and would notbe input as new records into ADAMS (whether or not the reference documents are included on theCD-ROM or DVD). The updated version of a document should include a list of changes to the previousversion. Each page should include a change indicator (e.g., a bold vertical line at the margin adjacent tothe portion that has been changed) and a page change identification including either the date of change,revision, or both. Alternative means may be acceptable when designating changes to drawings and

pictures. In addition to the initial COL application and the revision of major parts of the application such as theFSAR, the licensing process will likely involve general correspondence, responses to requests for additional information, and other submittals. It is expected that the supplemental submittals will involvea combination of electronic information exchange, additional CDs or DVDs, and paper correspondence. Applicants should follow established requirements and practices to ensure these various submittals areaddressed in accordance with 10 CFR 52.3, include the docket number and subject, and copies areprovided to the NRC project manager. Specific requirements for submitting documents directly relatedto the hearing process are provided in 10 CFR Part 2.