ML062640035
| ML062640035 | |
| Person / Time | |
|---|---|
| Issue date: | 09/30/2006 |
| From: | Office of Nuclear Regulatory Research |
| To: | |
| References | |
| DG-1145 | |
| Download: ML062640035 (22) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION September 2006 0
kOFFICE OF NUCLEAR REGULATORY RESEARCH Division 1 0DRAFT REGULATORY GUIDE
Contact:
E. Diesterle (301)415-1365 DRAFT REGULATORY GUIDE DG-1145 COMBINED LICENSE APPLICATIONS FOR NUCLEAR POWER PLANTS (LWR EDITION)
A. INTRODUCTION The issuance of combined licenses for nuclear power plants is governed by Title 10, Part 52, of the Code of Federal Regulations (10 CFR Part 52), "Licenses, Certifications, and Approvals for Nuclear Power Plants" (the Part 52 Rule), which specifies the information to be included in a combined license (COL) application.
The following general provisions, with the corresponding implementing regulations,.
apply to filing a COL application:
Any person, except one excluded by 10 CFR 50.38, may file a COL application for a nuclear power facility with the Director of the U.S. Nuclear Regulatory Commission (NRC),
Office of Nuclear Reactor Regulation (NRR) [10 CFR 52.75(a)].
The application must comply with the relevant filing requirements of 10 CFR 52.3 and 10 CFR 50.30 [10 CFR 52.75(b)].
The application must contain all of the information required by 10 CFR 50.33 [10 CFR 52.77].
This regulatory guide is being Issued In draft form to involve the public In the early stages of the development of a regulatory position in this area. It has not received staff review or approval and does not represent an official NRC staff position.
Public comments are being solicited on this draft guide (including any implementation schedule) and its associated regulatory analysis or value/impact statement. Comments should be accompanied by appropriate supporting data. Comments may be submitted In writing to the Rules and Directives Branch, Office of Administration, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or electronically through the NRCs interactive rulemaking Web page at http://ruleforum.llnl.qov/cqi-bin/rulemake?
sourcef=rgpst=draftrg. Copies of comments received may be examined at the NRC Public Document Room, 11555 Rockville Pike, Rockville, MD. Comments will be most helpful if received by October 21, 2006.
Please note that the NRC does not intend to distribute printed copies of this draft regulatory guide, unless specifically requested on an individual basis. Such requests for single copies of draft or final guides (which may be reproduced) or for placement on an automatic distribution list for single copies of future draft guides in specific divisions should be made in writing to the U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, Attention: Reproduction and Distribution Services Section; by email to DISTRIBUTIONinrc.gov; or by fax to (301 y415-2289. Telephone requests cannot be accommodated. Electronic copies
-of this draft regulatory guide are available through the NRC's interactive rulemaking Web page (see above); the NRC's public Web site under Draft Regulatory Guides in the Regulatory Guides document collection of the NRC's Electronic Reading Room at http:f/www.nrc.govfreading-rm/doc-collections ; and the NRC's Agencywide Documents Access and Management System (ADAMS) at http:/Iwww.nrc.gov/readinrg.rmladams.html, under Package Accession No. ML061800499.
The COL application is comprised of the various application items listed below.
The corresponding DG-1 145 sections indicate where this draft regulatory guide provides guidance for preparing the required application items.
Application Item Transmittal Letter (including oath and affirmation)
Final Safety Analysis Report Inspections, Tests, Analyses, and Acceptance Criteria Probabilistic Risk Assessment Environmental Report Security Plan General and Financial Information Quality Assurance Program Description Corresponding DG-1145 Section None C.I.1-C.I.19, C.II1.1, C.II1.2 C.ll.2, C.lI.5, C.I11.7 C.lI.1, C.I.1 1-Chapter 19 C.lI.3, C.M.3 C.I.13.6 C.IV.5 C.I.17.5 This regulatory guide applies to applications for combined licenses for nuclear power plants.
Applicants may submit their COL applications to the NRC in either paper format or electronically, as described in Section C.IV.2 of this guide.
The NRC issues regulatory guides to describe to the public methods that the staff considers acceptable for use in implementing specific parts of the agency's regulations, to explain techniques that the staff uses in evaluating specific problems or postulated accidents, and to provide guidance to applicants. Regulatory guides are not substitutes for regulations, and compliance with regulatory guides is not required. The NRC issues regulatory guides in draft form to solicit public comment and involve the public in developing the agency's regulatory positions. Draft regulatory guides have not received complete staff review and, therefore, they do not represent official NRC staff positions.
This regulatory guide contains information collections that are covered by the requirements of 10 CFR Parts 50 and 52, which the Office of Management and Budget (OMB) approved under OMB control numbers 3150-0011 and 3150-0151, respectively. The NRC may neither conduct 'nor sponsor, and a person is not required to respond to, an information collection request or requirement unless the requesting document displays a currently valid OMB control number.
DG-1 145, Page A-2
B. DISCUSSION The purpose of this regulatory guide is to provide guidance regarding the information to be submitted in a combined license (COL) application for a nuclear power plant. As such, this guide is intended to address many, albeit not all, of the application options allowed by Title 10, Part 52, of the Code of Federal Regulations (10 CFR Part 52). Although a COL applicant is not required to conform to this guidance, its use will facilitate both the applicant's preparation of a COL application and timely review of the application by the staff of the U.S. Nuclear Regulatory Commission (NRC). Nonetheless, the reader should note that although this guide may not cover all current regulations pertaining to a COL application, the application must address all such regulations.
The regulatory positions presented in Section C of this guide are divided into four parts. Part I addresses the information requirements specified in 10 CFR 52.79, "Contents of Applications; Technical Information in Final Safety Analysis Report." As such, Part I is intended to provide COL applicants with guidance regarding the information that the staff needs to resolve all safety issues related to the proposed combined license. Moreover, Part I is intended to be used by COL applicants who are not referencing certified designs. Toward that end, Part I includes 19 sections. Section C.I. 1 provides broad generic guidance, although COL applicants have the option not to maintain some of this information in Chapter 1 of the final safety analysis report (FSAR). Sections C.I.2-C.L.17 are based on the existing guidance provided in Regulatory Guide 1.70, "Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants,"
although the NRC'staff has updated the guidance in those sections to reflect the current information requirements for COL applications. By contrast, Sections C.I.I 8-C.I.19 present information requirements that are not-addressed in Regulatory Guide 1.70. In addition, the reader should note that Sections C.I.2-C.I. 19 correspond to Chapters 2-19 of NUREG-0800, "Standard Review Plan [SRP] for the Review of Safety Analysis. Reports for Nuclear Power Plants." The level of information needed for those sections depends on the complexity of the topic.
Part H1 of Section C addresses the information requirements specified in 10 CFR 52.80, "Contents of Applications; Additional Technical Information." In particular, these information requirements include the probabilistic risk assessment (PRA); inspections, tests, analyses, and acceptance criteria (ITAAC); and the environmental report. Use of the guidance in Part H assumes that a COL applicant is referencing a custom design. Together, Parts I and II are intended to represent the bulk of the technical information that an applicant should include in a COL application.
Part III of Section C is intended to be used by COL applicants who reference either a certified design or both a certified design and an early site permit (ESP). As such, Part III includes seven sections.
Section C.II. I is intended to address the topics that the NRC staff will review in a COL application that references a certified design. By contrast, Section C.Ill.2 addresses the remaining review topics for applications that reference both a certified design and an ESP. The guidance provided in both of these sections was derived from information presented in Part I of this guide. Section C.III.3 addresses the finality of an environmental impact statement associated with an ESP. Section C.Ill.4 provides generic guidance on addressing COL action/information items in COL applications. Section C.lI.5 provides recommendations for COL applicants who reference certified designs that include design acceptance
- criteria (DACs). Section C.Ifl.6 provides recommendations for coordinating the submittal of COL applications with design certifications and/or ESP applications that are under NRC review at the time the COL application is submitted. Finally, Section C.III.7 provides a process for developing the additional ITAAC necessary for applications that reference a certified design.
Part IV of Section C includes 12 sections that address a series of miscellaneous topics of interest to COL applicants. Section C.IV. 1 includes the checklist that the NRC will use to perform its acceptance DG-1 145, Page B-I
review of a COL application. Section C.IV.2 provides guidance and recommendations for the format of a COL application, with a particular focus on those that applicants submit electronically. Section C.IV.3 provides a general description of the change processes associated with custom COL applications and those that reference a certified design and/or an ESP. Section C.IV.4 provides guidance for use in implementing SECY-05-0197, "Review of Operational Programs in a Combined License Application and Generic Emergency Planning Inspections, Tests, Analyses, and Acceptance Criteria." Section C.IV.5 provides submittal guidance for the general and financial information that a COL application is required to include.
Section C.IV.6 provides guidance regarding information to be included in the site redress plan and requests for limited work authorizations. Section C.IV.7 discusses pre-application activities that the NRC staff and the prospective applicant should perform before an application is submitted. Section C.IV.8 provides information on dealing with generic issues. Section C.IV.9 is reserved for future use. Section C.1V.10 provides guidance on handling the regulatory treatment of non-safety systems. Section C.IV. 1I is reserve for future use. Finally, Section C.IV.12 discusses the applicability of industry guidance. Appendix A provides the questions and comments received during the public workshops on DG-1145 and the proposed staff responses.
Figure B-i below represents the scope of the staff's review of a COL application that references a certified design. In such instances, the referenced design contains DAC for certain design topics that the COL application review is not required to address; however, the COL application must discuss any departures from the certified design. In addition, the design must be sufficiently complete to enable the NRC staff to reach a final conclusion regarding all safety issues. Toward that end, the scope of the staff's review encompasses the entire facility. Thus, a COL applicant should not state that the staff should defer a portion of its application review because the information is not available at the time the applicatioi is submitted.
Rather, the COL applicant should provide sufficient information to enable the staff to reach a safety finding.
Design Certification Site-Specific 100% "-7 100%."
~
,average level of design Xcompletion to resolve 0
Translation into
-"safety issues Construction/Design Deviations from C.
Documents Certified Design
-E Design Acceptance
--*."Criteria (optional for "COL Review)
Cert.
1c acne of DG-1145 oes!
COL all values am representative 0%
arnd not absol 0%
% Design Scope 100%
Figure 1: Combined Ucense Application Referencing a Certified Design This guide is intended to be used by COL applicants who propose to construct and operate light water reactor (LWR) nuclear power plants. Thus, this guide does not attempt to distinguish between active and passive safety system LWRs. Rather, this guide attempts to bound the information needed in a COL application for any LWR. As a result, some of the guidance may not apply to some COL applicants.
DG-1 145, Page B-2
During the development of this guide, the staff provided numerous opportunities for public involvement. Upon completing each section of the guide, the staff placed the draft on the NRC's public Web site as a work-in-progress. In so doing, the staff solicited comments through the agency's Web site on all work in-progress sections, as well as the development of the guide in general. This afforded the public a very early opportunity to provide feedback on the development of this document. There were also several public meetings held to discuss draft sections of the guidance and regulatory positions. In addition, the staff afforded the public multiple opportunities to provide comments during a series of five public workshops, which the NRC held between March and July 2006. As a result, the staff has addressed many of the comments in Appendix A of this guide. In particular, the comments addressed in Appendix A focus on the development of individual sections of the regulatory positions in this guide, and are organized by the corresponding section. The NRC encourages readers to review Appendix A before submitting comments on the draft guide.
DG-1 145, Page B-3
C.I.I. Introduction and General Description of the Plant In accordance with Subpart C of Title 10, Part 52, of the Code of Federal Regulations (10 CFR Part 52), combined license (COL) applicants may incorporate by reference designs that have been certified according to Subpart B of 10 CFR Part 52 and early site permits according to Subpart A of 10 CFR Part 52. Additional guidance for COL applicants who reference a certified design and/or early site permit is provided in Section C.III of this regulatory guide. By contrast, the guidance provided in Section C.I of this regulatory guide applies to COL applicants who reference neither a certified design nor an early site permit.
The first chapter of the final safety analysis report (FSAR) should present an introduction to the report and a general description of the plant. This chapter should enable the reviewer or reader to obtain a basic understanding of the overall facility without having to refer to the subsequent chapters. Review of the detailed chapters that follow can then be accomplished with better perspective and recognition of the relative safety-significance of each individual item in the overall plant design.
C.1.1.1 Introduction In this section, the COL applicant should briefly present the principal aspects of the overall application, including the type of license requested, the number of plant units, a brief description of the proposed plant location, the type of containment structure and its designer, the type of nuclear steam supply system and its designer, the core thermal power levels (both rated and design), the corresponding net electrical output for each thermal power level, and the scheduled completion date and anticipated commercial operation date of each unit. The following subsections address these aspects of the application.
C.I.1.I.1 Plant Location The COL applicant should provide plant location information, such as the State 9ajd county, as well as one or more map(s) showing the site location and plant arrangement within the site, including whether the plant is colocated with existing operating nuclear power plants.
C.I.1.1.2 Containment Type The COL applicant should provide a summary level description of the containment design
[i.e., freestanding or supported, cylindrical or spherical, liner or vessel type, and shield building type (reinforced concrete, post-tensioned, etc.)].
C.I.1.1.3 Reactor Type The COL applicant should specify the nuclear steam supply system model and designer, as well as whether the reactor is a pressurized-water reactor or boiling-water reactor.
C.I.1.1.4 Power Output The COL applicant should provide the net electrical output and core thermal power rating.
.DG-1145, Page C.I. 1-1
(4) 10 CFR Part 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities."
(5) 10 CFR Part 52, "Early Site Permits; Standard Design Certifications; and Combined Licenses for Nuclear Power Plants."
(6) 10 CFR Part 55, "Operators' Licenses."
(7)
Regulatory Guide 1.8, "Qualification and Training of Personnel for Nuclear Power Plants."
(8)
Regulatory Guide 1.149, "Nuclear Power Plant Simulation Facilities for Use in Operator Training and Licensing Examinations."
(9)
NUREG-07 11, "Human Factors Engineering Program Review Model."
(10)
NUREG-1021, "Operator Licensing Examination Standards for Power Reactors."
(11)
NUREG-.1220, "Training Review Criteria and Procedures."
(12)
Generic Letter 86-04, "Policy Statement on Engineering Expertise on Shift," February 1986.
(13)
Regulatory Guide 1.134, "Medical Evaluation of Licensed Personnel at Nuclear Power Plants."
13.3 Emergency Planning This section of the FSAR should describe the applicant's plans for coping with emergencies pursuant to Subpart C of 10 CFR Part 52, which sets out the requirements applicable to issuance of combined licenses (COLs) for nuclear power facilities. Specifically, 10 CFR 52.77, 10 CFR 52.79, and 10 CFR 52.80 identify the requirements related to emergency plans that should be addressed in the COL application. The NRC's standards for review of applications and issuance of COLs are provided in 10 CFR 52.81, 10 CFR 52.83, and 10 CFR 52.97. The COL application, which includes the FSAR and other information (e.g., State and local emergency plans), should also address the emergency planning requirements contained in 10CFR 50.33(g), 10 CFR 50.34(f), and 10 CFR 52.79(a)(21). In addition, the COL application should address 10 CFR 50.54(t)(1), as it relates to implementation of the emergency preparedness program.
In addition, the application should address the requirements of 10 CFR 50.47, including the sixteen standards in 10 CFR 50.47(b), 10 CFR 50.72(a)(3), 10 CFR 50.72(aX4), 10 CFR 50.72(c)(3), the requirements in Appendix E of 10 CFR Part 50, and the Comnuission Orders of February 25, 2002, relating to security events, in order for the staff to make a positive finding that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency, including a security event. NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," which is a joint NRC and Department of Homeland Security (DHS) document, establishes an acceptable basis for NRC licensees and State and local governments to develop integrated radiological emergency plans and improve their overall state of emergency preparedness. Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors," endorses the criteria and recommendations in NUREG 0654/FEMA-REP-1, Rev. 1, as methods acceptable to the NRC staff for complying with the standards in 10 CFR 50.47. The applicant should specify the revision number and date of Regulatory Guide 1.101 used.
10 CFR 50.47(b)(4) requires a standard emergency classification and action level scheme.Section IV.C, "Activation of Emergency Organization," of Appendix E identifies the four emergency classes.
Section C.IV.B,' "Assessment Actions," of Appendix E to 10 CFR Part 50 also requires emergency action levels. The emergency plan should include the emergency classification level scheme described in Appendix I and Supplement 3 to NUREG-0654. It is expected that any new application will use an DG-1145, Page C.I.13-10
emergency action level scheme similar to that described in Revision 4 of NEI 99-01, "Methodology for Development of Emergency Action Levels," dated January 2003, which was endorsed in Revision 4 of Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors," dated October 2003. However, Revision 4 of NEI 99-01 is not considered to be entirely applicable to advanced light water reactor designs. Even thought the majority of Revision 4 of NEI 99-01 may be applicable to any reactor design and should be used, the unique characteristics of the new reactor should be addressed in the development of emergency action levels specific to the new plant and the site.Section IV.B, "Assessment Actions," of Appendix E to 10 CFR Part 50 also requires that the initial emergency actions be discussed and agreed on by the State and 16cal governmental authorities. The applicant should provide some form of confirmation of the agreement, such as a letter signed by State and local governmental authorities, in the emergency plan, if the applicant provides emergency action levels different from those for the existing reactor(s) on the site.
As addressed in Section C.I.2, the information provided in the application should also contribute to a determination that the exclusion area and the low population zone (LPZ) for the site comply with 10 CFR Part 100, and address whether there are significant impediments to the development of emergency plans, as required by 10 CFR 100.21(g).
DHS is the Federal agency with the lead responsibility for oversight of offsite nuclear emergency planning and preparedness. These responsibilities are now executed by the Radiological Emergency Preparedness (REP) Program (formerly held by the Federal. Emergency Management Agency (FEMA)).
The REP Program now resides within the Preparedness Directorate of DHS. While the responsibility for evaluating the emergency plans and procedures is shared between the DHS and the NRC under a Memorandum of Understanding (MOU), which is reflected in 44 CFR Part 353, the final decision-making authority on the overall adequacy of emergency planning and preparedness rests with the NRC. In addition to the NRC's regulations (described above), the COL application needs to include the applicable State, Tribal, and local plans and procedures that address the relevant DHS requirements contained in 44 CFR Parts 350, 351, and 352, as well as associated REP guidance documents.
Where an applicant is unable to make arrangements with State and local governmental agencies with emergency planning responsibilities and obtain the certifications required by 10 CFR 52.79(a)(22)(i),
due to non-participation of State and/or local governments, the applicant should discuss its efforts to make such arrangements and describe any compensatory measures the applicant has taken or plans to take because of the lack of such arrangements. To the extent that State and local governments fail to participate, the application must contain information and a utility plan in accordance with 10 CFR 52.79(a)(22)(ii) and 10 CFR 50.47(cXl). The utility plan must demonstrate compliance with the offsite emergency planning requirements, sufficient to show that the proposed plans nonetheless provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at the site.
Supplement I to NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for Utility Offsite Planning and Preparedness," should be consulted to develop offsite plans and preparedness when State and/or local governments decline to participate in emergency planning and preparedness.
Pursuant to 10 CFR 52.73, the FSAR may reference an early site permit (ESP) for the proposed site or a certified design, or both, and thereby incorporate the emergency planning aspects approved in those prior licensing actions into the COL-applicationr The FSAR-should address any-conditions or requirements in the referenced ESP or certified design that relate to emergency planning, such as COL action items, permit conditions, or ITAAC.' For a referenced ESP, 10 CFR 52.79(b)(4) requires that the applicant must include any new or additional information that updates or corrects the information that was provided under 1ITAAC - Inspections, Tests, Analyses, and Acceptance Criteria DG-1145, Page C.I.13-11
10 CFR 52.17(b), and discuss whether the new or additional information materially changes the bases for compliance with the applicable requirements. If the proposed facility emergency plans incorporate existing emergency plans or major features of emergency plans, the application must identify changes to the emergency plans or major features of emergency plans, following issuance of the ESP, that have been incorporated into the proposed facility emergency plans, and that constitute a decrease in effectiveness under 10 CFR 50.54(q). As stated in 10 CFR 52.79(b)(5), if complete and integrated emergency plans are approved as part of the ESP, new certifications meeting the requirements of 10 CFR 52.79(a)(22) are not required; however, updates are required to incorporate new and significant information.
13.3.1 Combined License Application and Emergency Plan Content At the COL application stage, a comprehensive (i.e., complete and integrated) emergency plan should be submitted. This plan should be a physically separate document identified as Section 13.3 of the FSAR, and may incorporate by reference various State and local emergency plans or other relevant materials. The application should include a copy of all referenced plans or other materials that serve to establish compliance with the emergency planning standards and requirements, including an analysis of the time required to evacuate and for taking other protective actions for various sectors and distances within the plume exposure pathway emergency planning zone (EPZ) for transient and permanent populations; i.e., an evacuation time estimate (ETE). The application should also include a table of contents and a cross reference to applicable regulatory requirements, guidance documents, generic communications, and other criteria that are used to develop the application and emergency plan. The cross-reference should indicate where the specific criteria in 10 CFR 50.72(a)(3), 10 CFR 50.72(a)(4), 10 CFR 50.72(c)(3), Appendix E to 10 CFR Part 50, 10 CFR 73.71(a), and NUREG-0654/FEMA-REP-1, Rev. 1 are addressed in the applicant's plans. The intent of this cross-reference is to be an aid in the review process, and facilitate the coordinated development and review of emergency plans that are part of the application.
The emergency plan, including implementing procedures (if applicable), should address the standards and requirements of 10 CFR 50.47 and Appendix E to 10 CFR Part 50. Ordinarily, lower tier documents such as emergency planning implementing procedures (EPIPs) are not considered to be part of the emergency plan. However, any relocation from an emergency plan of an emergency preparedness (EP) requirement to a lower tier document must be explained.? The location of relocated information should be described in the plan, and administratively controlled to ensure subsequent changes to those documents are reviewed in accordance with 10 CFR 50.54(q). If detailed EPIPs are not submitted at the time of the COL application, the requirement in Part V of Appendix E for the submission of detailed emergency plan implementing procedures may be addressed as either a proposed license condition or an emergency planning ITAAC (see section 13.3.3, below, and ITAAC 15.1 in Table B1 of Section C.ll.2, Appendix B).
The applicant should address the various generic communications and Commission Orders that are in effed and applicable to emergency planning in support of an Operating License (see Generic Communications identified in Subsection 13.3.4, below).' The emergency plan should address any subsequently issued Generic Letters and Commission Orders that pertain to emergency planning and 2See RIS 2005-02,- "Clarifying the Process for-Making Emergency Plan Changes," February 14, 2005.
3See also 10 CFR 52.79(a)(37), which requires that a COL application contain information that demonstrates how operating experience insights from generic letiers and bulletins issued up to 6 months before the docket date of the application, or comparable international operating experience, have been incorporated into the plant design.
DG-1t45, Page C.I.13-12
preparedness. Sections C.I. I and C.IV.8 provide additional guidance associated with generic safety issues and generic communications.
Under 10 CFR 50.34(f), an application for a combined license must demonstrate compliance with the technically relevant portions of the requirements in 10 CFR 50.34(f)(1) through 10 CFR 50.34(0(3).
For those applicants that are subject to 10 CFR 50.34(f), the application must address the TMI-related requirements in 10 CFR 50.34(f)(2)(iv), (viii), (xvii), and (xxv). These requirements maybe met by satisfying the comparable requirements in 10 CFR 50.47 and Appendix E of 10 CFR Part 50. *Supplement 1 to NUREG-0737, "Requirements for Emergency Response Capability," should be consulted regarding TMI related items.
The FSAR should also address an emergency classification and action level scheme, as required by 10 CFR 50.47(bX4). The various emergency action level schemes that have been found acceptable by the NRC staff for complying with NRC's regulations are addressed Revisions 2, 3, and 4 of Regulatory Guide 1.101. The applicant may propose means other than those specified in Regulatory Guide 1.101. The proposal should describe and justify how the proposed method meets the applicable regulations.
The applicant should address the NRC Orders issued February 25, 2002, as well as any subsequent NRC guidance (or any NRC endorsed industry guidance developed in response to issues related to implementation of the Orders), to determine what security-related aspects of emergency planning and preparedness must be addressed in the emergency plan. Any information submitted to the NRC that is proprietary, sensitive, or safeguards information should be marked appropriately. (Security-based events and considerations are also addressed in Section C.I. 13.6.)
In accordance with 10 CFR 52.79(a)(41), the application must include an evaluation of the facility against the Standard Review Plan (SRP) (NUREG-0800) revision in effect six months prior to the docket date of the application. For those aspects of the emergency plan that differ from the SRP acceptance criteria, the applicant must identify and describe the differences, and discuss how the proposed alternative provides an acceptable method of complying with the applicable rules or regulations that underlie the corresponding SR.P acceptance criteria.
Emergency planning information (including supporting organization agreements) submitted in support of a COL application, as well as incorporated elements of an existing emergency plan for multi-unit sites (discussed below), should (1) be applicable to the proposed site, (2) be up-to-date when the application is submitted, and (3) reflect use of the proposed site for possible construction of a new reactor (or reactors).
The application should include adequate justification (e.g., an appropriate explanation or analysis) in support of the use of such information. The application should also address how the existing elements have been incorporated into the proposed plan, as it relates to expanding the existing program to include one or more additional reactors, and identify any impact on the adequacy of the existing emergency preparedness program for the operating reactor(s).
Copies of letters of agreement (or other certifications) from the State and local governmental agencies with emergency planning responsibilities should be included in the application. The agreements should clearly address the future presence of an additional reactor (or reactors) at the site. The application should discuss any ambiguous or incomplete language in theagreementsIf an existingletter of agreement is broad enough to cover an expanded site use and does not need to be revised, the application should also include a separate correspondence (or other form of communication with the organization) that addresses the new reactor(s) and the organization's acceptance of expanded responsibilities.
13.3.2 Emereency Plan Considerations for Multi-Unit Sites DG-1 145, Page C.I.13-13
If the new reactor will be located on, or near, an operating reactor site with an existing emergency plan (i.e., multi-unit site), and the emergency plan for the new reactor will include various elements of the existing plan, the application should:
(1)
Address the extent to which the existing site's emergency plan will be credited for the new unit(s),
including how the existing plan would be able to adequately accommodate an expansion to include one or more additional reactors, and include any -required modification of the existing emergency plan for staffing, training, EALs, etc.
(2)
Include a review of the proposed extension of the existing site's emergency plan pursuant to 10 CFR 50.54(q), to ensure the addition of a new reactor(s) would not decrease the effectiveness of the existing plans and the plans, as changed, would continue to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50.
(3)
Describe any required updates to existing emergency facilities and equipment, including the Alert Notification System (ANS).
(4)
Incorporate any required changes to the existing onsite and offsite emergency response arrangements and capabilities with State and local authorities, or private organizations.
(5)
Justify the applicability of the existing 10-mile plume exposure EPZ and 50-mile ingestion control EPZ.
(6)
Address the applicability of the existing ETE or provide a revised ETE, if appropriate;.
(7)
If applicable, address the exercise requirements for co-located licensees, in accordance with Section IV.F.2.c of Appendix E to 10 CFR Part 50, and the conduct of emergency preparedness activities and interactions discussed in Regulatory Guide 1.101, Rev. 5.
(8)
If applicable, include inspections, tests, analyses, and acceptance criteria (ITAAC).which will address any changes to the existing emergency plans, facilities and equipment, and programs that are to be implemented, along with a proposed schedule.
(9)
Describe how emergency plans, to include security, will be integrated and coordinated with emergency plans of adjacent sites.
13.3.3 Emergency Planning Inspections. Tests, Analyses, and Acceptance Criteria 10 CFR 52.80(b) requires that an application for a combined license include proposed emergency planning ITAAC which are necessary and sufficient to provide reasonable assurance that, if the inspections, tests and analyses are performed (by the licensee) and the acceptance criteria met, the facility has been constructed and will operate in conformity with the combined license, the provisions of the Atomic Energy Act, and the NRC's regulations.
The combined license applicant shall develop emergency planning ITAAC to address implementation of elements of the emergency plan, in accordance with the guidance provided in Sections C.I. 14 and C.II.2 of this Regulatory Guide. A reference, to the emergency planning ITAAC developed for the combined license application should be provided in this section of the FSAR. Table C.U.2-B I of Section C.II.2, Appendix B, provides an acceptable set of generic emergency planning ITAAC that an applicant may use to develop application-specific ITAAC tailored to the specific reactor design and emergency planning program requirements. A smaller set of ITAAC is acceptable if the application contains information that fully addresses emergency preparedness requirements associated with any of the DG-1145, Page C.I.13-14
generic ITAAC in Table C.H.2-B1 of Section C.11.2, Appendix B, that are not used.4 Table C.ll.2-B1 is not all-inclusive, or exclusive of other ITAAC anapplicant may, propose. Additional plant-specific emergency planning ITAAC (i.e., beyond those listed in Table BI) may be proposed, and they will be examined to determine their acceptability on a case-by-case basis.
Section C.I. 14.3 provides discussion on ITAAC proposed in a COL application. The COL applicant should also refer to the guidance provided in Section C.H.2 for development of ITAAC proposed for a COL application.
13.3.4 References (1) 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities."
(2) 10 CFR 50.33, "Contents of Applications; General Information."
(3) 10 CFR 50.34, "Contents of Applications; Technical Information."
(4) 10 CFR 50.47, "Emergency Plans."
(5) 10 CFR 50.54, "Conditions of Licenses."
(6) 10 CFR 50.72, "Immediate Notification Requirements for Operating Nuclear Power Reactors."
(7) 10 CFR Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants."
(8) 10 CFR Part 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities."
(9) 10 CFR Part 52, "Early Site Permits; Standard Design Certifications; and Combined Licenses for Nuclear Power Plants."
(10) 10 CFR Part 52, Subpart C, "Combined Licenses."
(11) 10 CFR 52.77, "Contents of Application; General Information."
(12) 10 CFR 52.79, "Contents of Application; Technical Information."
(13) 10 CFR 52.81, "Standards for Review of Applications."
(14) 10 CFR 52.83, "Applicability of Part 50 Provisions."
(15) 10 CFR 52.97, "Issuance of combined licenses."
(16) 10 CFR 73.71, "Reporting of Safeguards Events."
(17) 10 CFR Part 100, "Reactor Site Criteria."
(18) 10 CFR Part 100.21, "Non-Seismic Siting Criteria."
(19) 44 CFR Part 350, "Review and Approval of State and Local Radiological Emergency Plans and Preparedness."
(20) 44 CFR Part 351, "Radiological'Emergency Planning and Preparedness."
(21) 44 CFR Part 352, "Commercial Nuclear Power Plants: Emergency Preparedness Planning."
4See SECY-05-0197, "Review of Operational Programs in a Combined License Application and Generic Emergency Planning Inspections, Tests, Analyses, and Acceptance Criteria," October 28, 2005; and SRM SECY-05-0197, February 22, 2006. The generic emergency planning ITAAC in SECY-05-0197 formed the basis for Table C.II.2-B1.
DG-1145, Page C.I.13-15
(22) 44 CFR Part 353, Appendix A, "Memorandum of Understanding Between NRC and FEMA Relating to Radiological Emergency Planning and Preparedness."
(23)
Regulatory Guide 1.23, Second proposed revision 1, "Meteorological Measurement Program for Nuclear Power Plants," April 1986 [Draft Regulatory Guide DG-XXXX, "Meteorological Monitoring Requirements for Nuclear Power Plants," August 17, 2006](ADAMS Accession No. ML003739962).
(24)
Regulatory Guide 1.97, Rev. 3, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and En-virons Conditions During and Following an Accident," May 1983 (ADAMS Accession No. ML003740281).
(25)
Regulatory Guide 1.70, Rev. 3, "Standard Format and Content of Safety Analysis Report for Nuclear Power Plants," November 1978 (ADAMS Accession Nos. ML003740072, ML003740108,
& ML003740116).
(26)
Regulatory Guide 1.101, Rev. 2, "Emergency Planning and Preparedness for Nuclear Power Reactors," October 1981.
(27)
Regulatory Guide 1.101, Rev. 3, "Emergency Planning and Preparedness for Nuclear Power Reactors," August 1992.
(28)
Regulatory Guide 1.101, Rev. 4, "Emergency Planning and Preparedness for Nuclear Power Reactors," July 2003.
(29)
Regulatory Guide 1.101, Rev. 5, "Emergency Planning and Preparedness for Nuclear Power Reactors," September 2004 (ADAMS Accession No. ML050730286).
(30)
Regulatory Guide 4.7, Rev. 2, "General Site Suitability Criteria for Nuclear Power Stations," April 1998 (ADAMS Accession No. ML003739894).
(31)
Regulatory Guide 5.62, Rev.., "Reporting of Safeguards Events," November 1987 (ADAMS Accession No. ML003739271).
(32)
NUREG-0396, EPA 520/1-78-016, "Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants," December 1978.
(33)
NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants - Final Report,"
November 1980 (supplemented by the March 2002 addenda).
(34)
Supplement 1 to NUREG-0654/FEMA-REP-l, Rev. 1, "Criteria for Utility Offsite Planning and Preparedness," November 1987.
(35)
Supplement 2 to NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for Emergency Planning in an Early Site Permit Application," April 1996 (ADAMS Accession No. ML050130188).
(36)
Supplement 3 to NUREG-0654/FEMA-REP-I, Rev. 1, "Criteria for Protective Action Recommendations for Severe Accidents," July 1996.
(37)
NUREG-0660, "NRC Action Plan Development as a Result of the TMI-2 Accident," May 1980.
(38)
NUREG-0696, "Functional Criteria for Emergency Response Facilities," February 1981.
(39)
NUREG-0718, Rev. 2, "Licensing Requirements for Pending Applications for Construction Permits and Manufacturing Licenses," January 1982.
(40)
NUREG-0737, "Clarification of TMI Action Plan Requirements," October 30, 1980.
DG-1145, Page C.I.13-16
(41)
Supplement I to NUREG-0737, "Requirements for Emergency Response Capability," January 1983.
(42)
NUREG-0800, "Standard Review Plan for the Review of Safety Analyses for Nuclear Power Plants," [March 2007].
(43)
NUREG-0814, "Methodology for Evaluation of Emergency Response Facilities," August 1981.
(44)
NUREG-0835, "Human Factors Acceptance Criteria for the Safety Parameter Display System,"
October 1981.
(45)
NUREG-0933, "A Prioritization of Generic Safety Issues," August 2004.
(46)
NUREG-1022, Rev. 2, "Event Reporting Guidelines - 10 CFR 50.72 and 50.73," October 2000.
(47)
NUREG-1394, Rev. 1, "Emergency Response Data System (ERDS) Implementation," June 1991.
(48)
NUREG-1793, Vol. 2, "Final Safety Evaluation Report Relating to Certification of the AP1000 Standard Design," Section 13.3, "Emergency Planning," September 2004.
(49)
NUREG/CR-4831 (PNL-7776), "State of the Art in Evacuation Time Estimate Studies for Nuclear Power Plants," March 1992.
(50)
NUREG/CR-6863 (SAND2004-5900), "Development of Evacuation Time Estimate Studies for Nuclear Power Plants," January 2005.
(51)
NUR.EG/CR-6864, Vol. 1 (SAND2004-590 1), "Identification and Analysis of Factors Affecting Emergency Evacuations-Main Report," January 2005.
(52)
SECY-91-041, "Early Site Permit Review Readiness," February 13, 1991 (ADAMS Accession No. ML003781623).
(53)
SECY-05-0197, "Review of Operational Programs in a Combined License Application and Generic Emergency Planning Inspections, Tests, Analyses, and Acceptance Criteria," October 28, 2005 (ADAMS Accession No. ML052770225).
(54)
SRM on SECY-05.0197, "Review of Operational Programs in a Combined License Application and Generic Emergency Planning Inspections, Tests, Analyses, and Acceptance Criteria,"
February 22, 2006 (ADAMS Accession No. ML060530316).
(55)
SECY-06-0098, "Licensee Response to Demand for Information Regarding Mitigation Strategies Required Under Section B.5.b of the Orders Dated February 25, 2002, and Staff Recommendations for Follow-up Action," May 2, 2005 (Safeguards document).
(56)
NRR Review Standard, RS-002, "Processing Applications for Early Site Permits," May 3, 2004 (ADAMS Accession No. ML040700236).
(57)
NRC Office Procedure LIC-1 01, Rev. 3, "License Amendment Review Procedures," February 9, 2004 (ADAMS Accession No. ML040060258).
(58)
NRC Office Procedure LIC-200, Rev. 1, "Standard Review Plan (SRP) Process," May 8, 2006 (ADAMS Accession No. ML060300069).
(59)
H.R. 5005, "Homeland Security Act of 2002," P.L. 107-296, enacted November 25, 2002.
(60)
H.R. 6, "Energy Policy Act of 2005," P.L. 109-58, enacted August 8, 2005.
(61)
FEMA "Interim Radiological Emergency Preparedness (REP) Program Manual," August 2002.
(See also DHS successor document (under development): 'REP Program Planning Guidance DG-1145, Page C.I.13-17
Document: "Radiological Emergency Preparedness: Planning Guidance,"' (see 68 FR 9669, February 28, 2003).)
(62)
NRC Commission Orders of February 25, 2002, to all operating commercial nuclear power plants, relating to terrorist threats.
Generic Communications
.(63)
Administrative Letter (AL) 94-04, "Change of the NRC Operations Center Commercial Telephone
& Facsimile Numbers," April 11, 1994.
(64)
AL 94-07, "Distribution of Site-Specific and State Emergency Planning Information," May 6, 1994.
(65)
AL 94-16, "Revision of NRC Core Inspection Program for Annual Emergency Preparedness Exercise," November 30, 1994.
(66)
Bulletin (BL) 79-18, "Audibility Problems Encountered on Evacuation of Personnel from High Noise Areas," August 7, 1979.
(67)
BL 80-1"5, "Possible Loss of Emergency Notification System (ENS) with Loss of Offsite Power,"
June 18, 1980.
(68)
BL 05-02, "Emergency Preparedness and Response Actions for Security-Based Events," July 18, 2005 (ADAMS Accession No. ML051740058).
(69)
Generic Letter (GL) 82-33, "Supplement I to NUREG-0737 - Requirements for Emergency Response Capability (Generic Letter 82-33)," December 17, 1982.
(70)
GL 91-14, "Emergency Telecommunications," September 23, 1991 (ADAMS Accession No. ML031140150).
(71)
Information Notice (IN) 81-34, "Accidental Actuation of Prompt Public Notification System,"
November 16, 1981.
(72)
IN 85-41, "Scheduling of Pre-Licensing Emergency Preparedness Exercises," May 25, 1985.
(73)
IN 85-44, "Emergency Communication System Monthly Test," May 30, 1985.
(74)
IN 85-52, "Errors in Dose Assessment Computer Codes and Reporting Requirements Under 10 CFR Part 21," July 10, 1985.
(75)
IN 85-80, "Timely Declaration of an Emergency Class, Implementation of an Emergency Plan, and Emergency Notifications," October 15, 1985.
(76)
IN 86-18, "NRC On-Scene Response During a Major Emergency," March 26, 1986.
(77)
IN 86-43, "Problemns with Silver Zeolite Sampling of Airborne Radioiodine," June 10, 1986.
(78)
IN 86-55, "Delayed Access to Safety-Related Areas and Equipment During Plant Emergencies,"
July 10, 1986..
(79)
IN 86-98, "Offsite Medical Services," December 2, 1986.
(80)
IN 87-54, "Emergency Response Exercises (Off-Year Exercises)," October 23, 1987.
(81)
IN 87-58, "Continuous Communications Following Emergency Notification," November 16, 1987.
(82)
IN 88-15, "Availability of U.S. Food and Drug Administration (FDA)-Approved Potassium Iodide for Use in Emergencies Involving Radioactive Iodine," April 18, 1988.
(83)
IN 89-72, "Failure of Licensed Senior Operators to Classify Emergency Events Properly," October 24, 1989.
DG-1145, Page C.I.13-18
(84)
IN 90-74, "Information on Precursors to Severe Accidents," December 4, 1990.
(85)
IN 91-64, "Site Area Emergency Resulting from a Loss of Non-Class IE Uninterruptible Power Supplies," October 9, 1991.
(86)
IN 91-64, Supplement 1, "Site Area Emergency Resulting from a Loss of Non-Class I E Uninterruptible Power Supplies," October 7, 1992.
(87)
IN 91-77, "Shift Staffing at Nuclear Power Plants," November 26, 1991.
(88)
IN 92-32, "Problems Identified with Emergency Ventilation Systems for Near-Site (Within 10 Miles) Emergency Operations Facilities and Technical Support Centers," April 29, 1992.
(89)
IN 92-38, "Implementation Date for the Revision to the EPA Manual of Protective Action Guides and Protective Actions for Nuclear Incidents (EPA-400-R-92-00 1)," May 12, 1992.
(90)
IN 93-53, "'Effect of Hurricane Andrew on Turkey Point Nuclear Generating Station and Lessons Learned," July 20, 1993.
(91)
IN 93-8 1, "Implementation of Engineering Expertise on Shift," October 12, 1993.
(92)
IN 93-94, "Unauthorized Forced Entry into the Protected Area at Three Mile Island Unit 1 on February 7, 1993.
(93)
IN 94-27, "Facility Operating Concerns Resulting from Local Area Flooding," March 31, 1994.
(94)
IN 95-23, "Control Room Staffing Below Minimum Regulatory Requirements," April 24, 1995.
(95)
IN 95-48, "Results of Shift Staffing Study," October 10, 1995.
(96)
IN 96-19, "Failure of Tone Alert Radios to Activate When Receiving a Shortened Activation Signal," April 2, 1996.
(97)
IN 97-05, "Offsite Notification Capabilities," February 27, 1997.
(98)
IN 98-20, "Problems with Emergency Preparedness Respiratory Programs," June 3, 1998.
(99)
IN 02-14, "Ensuring a Capability to Evacuate Individuals, Including Members of the Public, from the Owner-Controlled Area," April 8, 2002.
(100)
IN 02-25, "Challenges to Licensees' Ability to Provide Prompt Public Notification and Information During an Emergency Preparedness Event," August 26, 2002.
(101)
IN 04-19, "Problems Associated with Back-up Power Supplies to Emergency Response Facilities and Equipment," November 4, 2004.
(102)
IN 05-06, "Failure to Maintain Alert and Notification System Tone Alert Radio Capability,"
March 30, 2005.
(103)
IN 05-19, "Effect of Plant Configuration Changes on the Emergency Plan," July 18, 2005.
(104)
Regulatory Issue Summary (RIS) 2000-08, "Voluntary Submission of Performance Indicator Date,"
March 29, 2000 (ADAMS Accession No. ML003685821).
(105)
RIS 2000-11, "NRC Emergency Telecommunications System," June 30, 2000 (ADAMS Accession No. ML003727812).
(106)
RIS 2000-11, Supp. 1, "NRC Emergency Telecommunications System," March 22, 2001 (ADAMS Accession No. ML010570103).
(107)
RIS 2001-16, "Update of Evacuation Time Estimates," August 1, 2001 (ADAMS Accession No. ML012070310).
DG-1 145, Page C.I.13-19
(108)
RIS 2002-01, "Changes to NRC Participation in the International Nuclear Event Scale," January 14, 2002.(ADAMS Accession No. ML013200502).
(109)
RIS 2002-16, "Current Incident Response Issues," September 13, 2002 (ADAMS Accession No. ML022560256).
(110)
RIS 2002-21, "National Guard and Other Emergency Responders Located in the Licensee's Controlled Area," November 8, 2002 (ADAMS Accession No. ML023160020).
(111)
RIS 2003-12, "Clarification of NRC Guidance for Modifying Protective Actions," June 24, 2003 (ADAMS Accession No. ML031680611).
(112)
RIS 2003-18, "Use of NEI 99-01, "Methodology for Development of Emergency Action Levels,"
Revision 4, Dated January 2003," October 8, 2003 (ADAMS Accession No. ML032580518),
(113)
RIS 2003-18, Supp. 1, "Supplement 1, Use of Nuclear Energy Institute (NEI) 99-01, "Methodology for Development of Emergency Action Levels," Revision 4, Dated January 2003," July 13, 2004 (ADAMS Accession No. ML041550395).
(114)
RIS 2003-18, Supp. 2, "Supplement 2, Use of Nuclear Energy Institute (NEI) 99-01, "Methodology for Development of Emergency Action Levels," Revision 4, Dated January 2003," December 12, 2005 (ADAMS Accession No. ML051450482).
(115)
RIS 2004-13, "Consideration of Sheltering in Licensee's Range of Protective Action Recommendations," August 2, 2004 (ADAMS Accession No. ML041210046).
(116)
RIS 2004-13, Supp. 1, "Consideration of Sheltering in Licensee's Range of Protective Action Recommendations, Dated August 2004," March 10, 2005 (ADAMS Accession No. ML050340531).
(117)
RIS 2004-15, "Emergency Preparedness Issues: Post 9/11," (Official Use Only - See RIS 2006-02),
October 18, 2004.
(118)
RIS 2004-15, Supp. 1, "Emergency Preparedness Issues: Post-9/11," May 25, 2006 (ADAMS Accession No. ML053000046).
(119)
RIS 2005-02, "Clarifying the Process for Making Emergency Plan Changes," February 14, 2005 (ADAMS Accession No. ML042580404).
(120)
RIS 2005-08, "Endorsement of Nuclear Energy Institute (NEI) Guidance "Range of Protective Actions for Nuclear Power Plant Incidents"," June 6, 2005 (ADAMS Accession No. ML050870432).
(121)
RIS 2006-02, "Good Practices for Licensee Performance During the Emergency Preparedness Components of Force-On-Force Exercises," February 23, 2006 (ADAMS Accession No. ML052970294).
(122)
RIS 2006-03, "Guidance on Requesting an Exemption from Biennial Emergency Preparedness Exercise Requirements," February 24, 2006 (ADAMS Accession No. ML053390039).
(123)
RIS 2006-12, "Endorsement of Nuclear Energy Institute Guidance "Enhancements to Emergency Preparedness Programs for Hostile Action!'," July 19, 2006 (ADAMS Accession No. ML061530290).
(124)
Emergency Preparedness Position (EPPOS) No. 1, Rev. 0, "Acceptable Deviations from Appendix 1 of NUREG-0654 Based Upon the Staff's Regulatory Analysis of NUMARC/NESP-007, "Methodology for Development of Emergency Action Levels"," June 1, 1995 (ADAMS Accession No. ML022970165).
DG-1145, Page C.I. 13-20
(125)
EPPOS No. 1, Rev. 0, "Acceptable Deviations from Appendix I of NUREG-0654 Based Upon the Staff's Regulatory Analysis of NUMARC/NESP-007, "Methodology for Development of Emergency Action Levels"," June 1, 1995.
(126)
EPPOS No. 2, Rev. 0, "Timeliness of Classification of Emergency Condition," August 1, 1995.
(127)
EPPOS No. 3, Rev. 0, "Requirement for Onshift Dose Assessment Capability, November 8, 1995.
(128)
EPPOS No. 5, Rev. 0, "Emergency Planning Information Provided to the Public,"
December 4, 2002.
(129)
Circular (CR) 80-09, "Problems with Plant Internal Communications Systems," April, 28, 1980.
13.4 Operational Program Implementation Operational programs are specific programs that are required by regulations. Further guidance on programs that are classified as operational programs is provided in Section C.IV.4 of this regulatory guide.
Operational programs should be fully described, as defined in SECY-05-0197, in an application for a combined license.. In accordance with Commission direction in SRM-SECY-05-0197, COL applicants should also provide schedules for implementation of these operational programs, as discussed below.
The combined license applicant should provide commitments for implementation of operational programs that are required by regulation. An example, Table 13.4-X, has been provided on the following page to demonstrate a suitable method of providing this information. The attached table is an example only and COL applicants should provide specific information relative to their operational programs.
Descriptions of operational programs, consistent with the definition of "fully described" as discussed in Section C.IV.4, should be provided in this chapter of the FSAR or in other, more applicable sections of the FSA.R The implementation milestone commitments for these operational programs (e.g., prior to fuel load, at fuel load, prior to exceeding 5% power, etc.) should be provided in a table similar to the example table provided. In some instances, programs may be implemented in phases, where practical, and the phased implementation milestones should also be provided in the attached table by the applicant. For example, radiation protection program implementation milestones may be based on radioactive sources on site, fuel on site, fuel load, and first shipment of radioactive waste.
In lieu of providing implementation milestone commitments for operational programs required by regulations, the combined license applicant may propose ITAAC for implementation, using the guidance contained in C.IV.4. Guidance on ITAAC development is provided in C.I1.2 of this regulatory guide.
DG-1145, Page C.I. 13-21
APPENDIX C.II.2-B DEVELOPMENT GUIDANCE FOR EMERGENCY PLANNING ITAAC A generic set of acceptable emergency planning (EP) ITAAC was developed through coordination efforts between the NRC and the Nuclear Energy Institute (NEI). This coordination effort resulted in the development of generic EP-ITAAC that are provided in Table C.ll.2-B 1'. The combined license applicant should consider this set of EP-ITAAC in the development of their application-specific EP-ITAAC that is tailored to the specific reactor design and emergency planning program requirements for their proposed plant site. A smaller set of EP-ITAAC is acceptable if the application contains information that fully addresses emergency preparedness requirements associated with any of the generic ITAAC contained in Table C.U.2-B I. Table C.ll.2-B1 is not all-inclusive, or exclusive of other ITAAC an applicant may propose. Additional plant-specific EP-ITAAC (i.e., beyond those listed in Table C.II.2 BI) may be proposed, and they will be examined to determine their acceptability on an applicant-specific basis.
'See SECY-05-0197, "Review of Operational Programs in a Combined License Application and Generic Emergency Planning Inspections, Tests, Analyses, and Acceptance Criteria," October 28, 2005; and SRM SECY-05-0197, February 22, 2006. The generic emergency planning ITAAC in SECY-05-0197 formed the basis for Table C.II.2-B1.
Appendix B to DG-1 145, Section C.II.2, Page C.II.2.B-1
Table C.II.2-BI EMERGENCY PLANNING Generic Inspections, Tests, Analyses, & Acceptance Criteria (EP ITAAC)'3 Planning Standard EP Program Elements' Inspections, Tests, Analyses Acceptance Criteria" 1.0 Assignment of Responsibility Organization Control 10 CFR 50.47(bX))- Primary responsibilities for 1.1 The staff existsto provide 24-hour per *
.1 An inspectionofthicimplementing 1.1 The staff exists to provide 24-hour per emergency response by the nuclear facility day emergency response and manning.of procedures or staffing rosters will be day emergency response and manning of licensee, and by State and local organizations communications links, including performed.
communications links, including continuous within the emergency planning zones (EPZs) have continuous operations for a protracted operations for a protracted period. [The COL been assigned, the emergency responsibilities of period. [A.l.e, A.4]
applicant will identify specific capabilities.]
the various supporting organizations have been specifically established, and each principle response organization has staff to respond and to augment its initial response on a continuous basis.
2.0 Onsite Emergency Organization 10 CFR 50.47(bX2) - On-shift facility licensee 2.1 The staff exists to provide minimum 2.1 An inspection of the implementing 2.1 The staff exists to provide minimum and responsibilities for emergency response are and augmented on-shift staffing levels, procedures or staffing rosters will be augmented on-shil staffing levels, consistent unambiguously defined, adequate staffing to consistent with Table B-I ofNUREG-.
performed.
with Table B4-ofNUREG-0654/FEMA provide initial facility accident response in key 0654/FEMA-REP-I, Rev. 1. [B.5, B.7]
REP-i, Rev. I. [The COL applicant will functional areas is maintained at all times, timely identify responsibilities and specific augmentation of response capabilities is available, capabilities.]
and the interfaces among various onsite response activities and offsite support and response activities are specified.
NOTE:
a The alphanumeric designations correspond to NUREG-0654/FEMA-REP-1, Rev. 1, evaluation criteria.
- b.
A license condition may be used, if required, to address those aspects of emergency planning and preparedness that reflect oflsite (i.e., non-licensee) responsibilities.
2See also SRM SECY-05-0197, "Review of Operational Programs in a Combined license Application and Generic Emergency Planning Inspections, Tests, Analyses, and Acceptance Criteria," October 28,2005 (ADAMS Accession No. ML052770225); and associated February 22,2006, StaffRequirements Memorandum (SRM) (ML060530316). These COL EP ITAAC are identified as asterisked "*" & bolded texL 3Standard design certification criteria or COL ITAAC may replace specific (generic) ITAAC in this table.
Appendix B to DG-1 145, Section C.11.2, Page r 11.2.B-2
C.I1I.7.3 Emergency Planning ITAA C (EP-ITAA C)
COL applications must include ITAAC on emergency planning, as required by the Energy Policy Act (EPACT) of 1992 and conforming Part 52 amendments. This requirement responds to the singularly contentious and disruptive role played by the late treatment of emergency planning issues in operating license proceedings on completed Part 50 facilities. The requirements for inclusion of ITAAC in an ESP are specific to EP-ITAAC and are contained inproposed 10 CFR 52.17(b)(3). The requirements for including EP-ITAAC in a COL application are contained in proposed 10 CFR 52.80(b). In the staff requirements memorandum (SRM) regarding Commission paper SECY-05-0197, "Review of Operational Programs in a Combined License Application and Generic Emergency Planning Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC)," the NRC Commission approved EP-ITAAC for use in COL applications. In this SRM, the Commission approved a set of generic EP-ITAAC for use by ESP and COL applicants. A generic set of EP-ITAAC based on those approved in SECY-05-0197 is contained in Section C.II.2 of this regulatory guide.
The scope and general content of the generic EP-ITAAC approved in SRM-SECY-05-0197 and that 'should be included in a COL application was established through a series of industry-NRC interactions. These EP-ITAAC were established on a generic basis; they are not associated with any particular site or design. As such, several of the generic EP-ITAAC require the COL applicant to provide more specific acceptance criteria that reflect the plant-specific design and site-specific emergency response plans and facilities. These generic EP-ITAAC are included in Section C.ll.2 of this regulatory guide.
The EP-ITAAC in Table C.ll.2-B 1 represent an acceptable set of generic EP-ITAAC for a COL application, including ITAAC on emergency response facilities that are within the scope of the design certification. COL applications referencing a certified design must include the design certification ITAAC on emergency response facilities.
EP-ITAAC are proposed by the COL applicant and, except for EP-ITAAC from the referenced design certification or ESP, are subject to NRC review and a hearing with respect to whether they satisfy the "necessary and sufficient" requirement of 10 CFR 52.80(b). The complete set of COL-ITAAC will be incorporated into the COL as a license condition to be satisfied prior to fuel load. As such, a COL holder may request a change in one or more of the EP-ITAAC, except those provided in the referenced certified design, via the license amendment process applicable to Part 52.
c.m.7.4 Physical Security ITAA C (PS-ITAA C)
COL applicants must include physical security ITAAC identified in the referenced DCD and that should be supplemented, as necessary, consistent with the guidance provided on generic PS-ITAAC in Section C.lI.2 and Appendix C.II.2-C of this regulatory guide. In addition, in SRM-SECY-05-0120, the Commission provided direction to the staff to proceed with rulemaking to establish security design requirements for new reactor licensing (i.e., in certified designs). Several security-related rulemakings are in progress and it is expected that further guidance related to the development of PS-ITAAC will be developed in conjunction with these security rulemakings. At the present time, the staff anticipates that a set of generic PS-ITAAC that may be modified by each COL applicant to accommodate site-specific design impacts and site-specific features, similar to the EP-ITAAC approach, will be proposed for future NRC endorsement. COL applications that do not reference a certified design must develop the entire set of PS-ITAAC for the facility. The following discussion assumes that a generic PS-ITAAC approach similar to the approach for EP-ITAAC would be endorsed by the NRC.
DG-1 145, Page C.III.7-5
The generic PS-ITAAC represent the complete scope of PS-ITAAC required for a COL application, including ITAAC on physical security features that are within the scope of the design certification. COL applications referencing a certified design must include the design certification ITAAC on physical security features.
PS-ITAAC are proposed by the COL applicant and, except for PS-ITAAC from the referenced design certification, are subject to NRC review and a hearing with respect to whether they satisfy the "necessary and sufficient" requirement of 10 CFR 52.80(b). The complete set of COL-ITAAC will be incorporated into the COL as a license condition to be satisfied prior to fuel load. As such, a COL holder may request a change in one or more of the PS-ITAAC, except those provided in the referenced certified design, via the license amendment process applicable to Part 52.
C.11I.7.5 Terminology Definitions of terminology used in certified designs are provided in the specific appendices of Part 52 that are applicable to the certified design. The certified design terminology such as generic DCD, plant-specific DCD, Tier 1, Tier 2*, and Tier 2 are not applicable to COL applications that do not reference a certified design. As such, these terms do not have any meaning for a COL application that does not reference a certified design.
The COL applicant that references a certified design must incorporate the DCD in accordance with Section ILI.B of the applicable appendix to 10 CFR Part 52 for that certified design. Therefore, the terms above have significant meaning for the certified design portion of the COL application. !TAAC for the certified design are included in the Tier 1 portion of the DCD. However SS-ITAAC, EP-ITAAC, and PS-ITAAC that are developed as part of the COL application are not contained in a document similar to the Tier I document. The terminology denotes the origin of the information contained in the COL application and determines the change process that applies to that information. The change process for COL application information that originates in a DCD is governed by Section VIII of the appendix of 10 CFR Part 52 that is applicable to that certified design. For COL information that does not originate in a DCD, a separate change process applies. More detailed guidance on the change processes applicable to COL applicants is provided in Section C.IV.3 of this regulatory guide.
In addition, as the terminology associated with the ITAAC denotes its origin, the origin of the ITAAC will also determine the "active life" of the ITAAC. The ITAAC for the entire facility (COL-ITAAC) will be subject to a license condition that requires successful completion of the ITAAC to obtain Commission approval for fuel load. Compliance with that license condition renders the ITAAC inactive (i.e., the ITAAC have been successfully completed and are no longer applicable as they are a one-time requirement). ITAAC that are contained in the DCD have been codified by rulemaking in appendices to Part 52 and they will remain as part of the certified design rule following completion by a COL applicant that references that certified design.
DG-1 145, Page C.III.7-6