ML070390549
| ML070390549 | |
| Person / Time | |
|---|---|
| Issue date: | 02/08/2007 |
| From: | William Reckley NRC/NRO/DNRL/NGIF |
| To: | |
| References | |
| DG-1145, RG-1.206 | |
| Download: ML070390549 (3) | |
Text
Preliminary Work Product to Support the Public Meeting on February 13, 2007 RG 1.206 Section C.III.4 C.III.4. COL Action or Information Items C.III.4.1 Background Appendices A-D to 10 CFR Part 52 set forth the design certification rules that specify the NRCs requirements for the certified reactor designs (i.e., the U.S. Advanced Boiling-Water Reactor, System 80+,
AP600, and AP1000, respectively). Section II.E of each design certification appendix defines Tier 2 information, which includes COL action or information items, defined as follows in Section II.E.3:
Combined license (COL) action items (COL license information), which identify certain matters that shall be addressed in the site-specific portion of the final safety analysis report (FSAR) by an applicant who references this appendix. These items constitute information requirements but are not the only acceptable set of information in the FSAR. An applicant may depart from or omit these items, provided that the departure or omission is identified and justified in the FSAR.
After issuance of a construction permit or COL, these items are not requirements for the licensee unless such items are restated in the FSAR.
The design control documents for each certified design contain COL information items, which the design certification vendor has deferred to the COL applicant to address in its application. The NRC staffs final safety evaluation report (FSER) for each certified design also contains a set of COL action items, which are cross-referenced with COL information items in the related design control document.
In addition, at the early site permit (ESP) stage, the NRC staff adds COL action items to the ESP in order to ensure that particular site-related issues are considered during the review of later applications referencing the ESP. The NRC staff has determined that these COL action items do not affect its regulatory findings at the ESP stage and are more appropriately addressed during later stages in the licensing process.
Section C.III.1 of this guide provides both a generic and comprehensive set of information a COL applicant should provide in the FSAR portion of its COL application that references a certified design.
This section provides guidance on how COL applicants should address the COL action or information items associated with the certified design referenced in its COL application.
C.III.4.2 Addressing COL Action or Information Items As previously noted, the design control documents specify the COL information items that the applicant is required to address. The COL applicant referencing a certified design should address all COL information items in their application. COL applicants should review the COL information items to determine those items which can be resolved as part of the COL application and those items which cannot be resolved as part of the COL application. Regardless of the disposition of these information items, each COL applicant should provide a cross-reference identifying the location in the COL application where each COL information item from the referenced certified design is addressed.
The NRC staff recommends that the applicant include this cross-reference information in Chapter 1 of the FSAR portion of the COL application.
Similarly, COL applicants referencing an ESP should review each COL action item identified in the early site permit and determine those items which can be resolved as part of the COL application and those items which cannot be resolved as part of the COL application. The COL applicant should provide a cross-reference identifying the location in the COL application where each COL action item DG-1145, Page C.III.4-1
Preliminary Work Product to Support the Public Meeting on February 13, 2007 RG 1.206 Section C.III.4 from the referenced ESP is addressed. The NRC staff recommends that the applicant include this cross-reference information in Chapter 1 of the FSAR portion of the COL application.
As previously noted, the FSER for each design certification contains a set of COL action items, which are cross-referenced with COL information items in the related design control document.
In addressing the COL information items in the design control document, the COL applicant should ensure that it has also addressed the issues described by the COL action items listed in the related FSER.
The staff intends to review the FSER list of COL action items during its review of each COL application and may request additional information from the COL applicant to address issues described by the listed action items that the COL application did not adequately address. In accordance with Section III.D of the applicable design certification rule, if there is a conflict between the generic DCD and the corresponding FSER for the certified design, then the generic DCD controls.
C.III.4.3 COL Information Items that cannot be Resolved Prior to the issuance of a License For each COL action or information item that is not resolved, whether it is derived from the design certification or an ESP, the COL applicant should provide justification in the COL application for why that item is not resolved. For example, items that require plant walkdowns cannot be completed because the plant has not been constructed at the time the application is submitted. The COL applicant should identify, in Chapter 1 of the FSAR portion of the COL application, the COL information items that cannot be completely resolved before the COL is issued. The COL applicant should provide sufficient information on these items to support the NRC licensing decision and also provide a proposed method of ensuring the final closure of the item following issuance of the combined license. There are several situations that could support issuance of the combined license before the complete resolution of a COL information item:
(1) The COL information is found to be completely redundant to an ITAAC from the referenced certified design that will be included in the COL.
(2) The COL applicant proposes new ITAAC to resolve the COL information item.
(3) The COL applicant proposes a condition to the license or identifies an existing license condition (e.g., technical specification) for COL information items (e.g., the operational programs discussed in Section C.IV.4). The license condition should include implementation schedules to allow coordination of activities with the NRC construction inspection program.
(4) The COL applicant describes in its application (e.g., within the appropriate section of the FSAR) the proposed approach to addressing a COL information item in sufficient detail to support the NRC licensing finding and includes the requirements for updating the affected document (e.g.,
the FSAR update process) or otherwise informing the NRC staff of the final disposition of the COL information item. The descriptions provided should include implementation schedules to allow coordination of activities with the NRC construction inspection program.
The NRC recommends that COL applicants carefully review COL information items that cannot be completely resolved until after the issuance of a combined license. The COL applicant should consider approaches such as those listed above to ensure all COL information items can be sufficiently resolved to support issuance of the combined license. The applicants ultimate closure of the COL DG-1145, Page C.III.4-2
Preliminary Work Product to Support the Public Meeting on February 13, 2007 RG 1.206 Section C.III.4 information item, either through ITAAC or another approach, would be subject to the NRCs construction inspection program.
DG-1145, Page C.III.4-3