Regulatory Guide 1.188

Draft Rev. 1, Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses (Draft for ACRS Review)

ML052200165
Person / Time
Issue date:	08/08/2005
From:	Garrity P NRC/RES/PMPDAS
To:
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References
DG-1140 RG-1.188, Rev 1
Download: ML052200165 (10)

The U.S. Nucl ear Regul ator y Commission (NRC) i ssues r egulat ory guide s to d escri be and make avail able t o the p ubli c methods t hat t he NR C staf f cons ider s accept able f or use in im ple m en ting spe cific par ts of th e ag en cy's re gu latio ns , tech niq ue s tha t the staff u se s in evalu ati ng speci fi c probl ems or post ulat ed acci dents, and dat a that the s taf f need in review ing ap plicatio ns for p erm its and licens es. R egu latory guid es are not s ub stitu tes for re gu latio ns , and com plia nc e w ith the m is not r equir ed. Met hods and sol uti ons th at dif fer from those set fort h in regul atory guides wil l be deemed acceptable if they provide a basi s for t he findi ngs requir ed for t he issuance or con ti nuance of a permit or li cense by t he Comm issi on.Th is guide was issued af ter consi derati on of comm ents recei ved from the publi

c. The NRC

staff encourages a nd we l co me s co m m ents and sug ges tions in con nec tion w ith im prov em ents t o pu bl is hed re gul at or y gui des , as wel l as it ems f or i ncl usi on i n r egu la to ry gui des t hat ar e c ur re nt ly bei ng d eve lo ped. The NRC staff will revise ex isti ng guides, a s app rop riate , to ac co m m od ate com m en ts an d to re flec t new infor m atio n or exp erie nc e. W ritten com m en ts m ay be sub m itted to the Ru les a nd Dir ectives Branch

, Offi ce of Administ rat ion, U.S. Nucl ear Regul ator y Commission, W ashing ton, DC 20555-0001.

Re gula tory guides are i ssued in 10 broad di visi ons: 1, Power Reactors; 2, Research and Test Re ac tors; 3, Fu els a nd Ma teria ls Fa cilities; 4, E nv iron m en tal an d S iting; 5, M ate rials an d P lan t Pro tec tion; 6, P rod uc ts; 7, T ran sp orta tion; 8, O ccu pa tion al H ea lth; 9, An titrus t and Fina nc ial R ev iew; and 10, G en era l.Re que sts for sing le cop ies of d raft or ac tive reg ulatory g uide s (wh ich m ay be repro duc ed) s hou ld be m ade to the U.S. N ucle ar R egu latory Comm issi on, Washington

, DC 20555, Atten ti on: Re pro du ctio n an d D istrib utio n S erv ices Se ctio n, or by fax to (30 1) 4 15-22 89; or by e m ail to Distr ibut ion@nrc.gov. Ele ctro nic c op ies o f this g uid e an d oth er re ce ntly issue d guide s are a vail able t hrou gh th e NRC's publi c W eb sit e under the Regul ator y Gui des document co ll ecti on of t he NRC's Elect roni c Reading Room at http://ww w.nrc.gov/read ing-rm/d oc-coll ections/ and th rough t he NRC's Agencywi de Documents Access and Manag ement Sys te m (ADAMS)at http://ww w.nrc.gov/read ing-rm/ada m s.htm l , under Accessio n No. ML05073028

6. Note, however, that the NRC has te mporari ly li mited publ ic ac cess t o ADAMS so th at the agency can c omplet e secu ri ty rev iews of pub licly availa ble do cum ents and rem ove pote ntially sen sitive info rm ation. Please ch eck the NRC's Web site for update s concer ning th e r esu mpt io n of pub li c a cce ss to ADAMS.U.S. NUCLEA

R REGULA TORY COMMISSION

Revision 1 Au gust 2005 REGULATO RY GUIDE OFFICE OF NUCLEAR REGULA

TORY RESEARCH

Pr epublication REGU LATORY GUIDE 1.188 (Draft was issued as DG-1140, dat ed January

2005)STA NDA RD FORMA T A ND CONTEN T FOR A PPLI CAT IONS T O RENEW NUCLEA R POWER PLANT OPERA

TI NG LI CENSES A. INTRODUC

TION The issuance of renewed op erating licenses for nuc lear power plants is g overned by Title 10, Part 54, of the Code of Federal Re gulations (10 CFR Part 54

), "Requirements for Renewal of Opera ting Licenses for Nuclear Power Plan ts" (comm only know n as the license renewal rule). As such, 10 CFR Part 54 sp ecifies the information that a nuclear power plant applicant must include as part of an application to renew an operating license issued by the U.S. Nuclear Reg ulatory Com mission (NRC

). As discussed in this regulatory g uide, the application should include (1) g eneral information, (2) an integrated plant assessment (I

PA), (3) an ev aluation of time- limited aging analyses (TLAAs), (4) a supplement to the plant's final safety analy sis report (FSAR), (5) any necessa ry changes to the p lant's te chnical specifi cations (along with re lated just ificatio ns), an d (6) a supplem ent to t he plan t's environmental report. The FSAR su pplement should provide a sum mary descriptio n of the program s and activities that the applicant will use to manage the effects of aging for the period of extend ed operation, which is determined by the I PA and the ev aluation of TLAAs.

The following ge neral provisions, w ith the corresponding regulations, apply to filing an applicatio n for a renewed operating license:*The application must b e filed in accordance with Subpart A of 10

CFR Part 2, 10

CFR 50.4, and 10 CFR 50.30. [10 CFR 54.17 (a)]*The applicant may not submit the application to the Com mission earlier than 2

0 years before the expiration of the o perating license current ly in e ffect. [10 CF R 54.1 7(c)]

1 Regulator y issue summ aries ar e avail able through the NRC's public Web site at http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/

.RG 1.188, Re v. 1, Pag e 2*For the timely renewal provisions of 10 CFR 2.109(b) to apply, the applicant must file a sufficient applica tion at least 5 years prior to the exp iration of the e xisting license. [10 C FR 2.1 09(b)]*The application for a renewed license may be combined w ith applications for other k inds of licen ses. [1 0 CFR 54.17(d)]*The application may incorporate by referen ce information con tained in previous a pplications for lice nses or license amen dmen ts, stat emen ts, corr espond ence, o r report s filed w ith the Com missi on, pro vided that th e refere nces are clear an d specif ic. [10 CFR 5 4.17(e)]This regula tory guide applies to license renewal applications or portions thereof. The requirem ents for filin g a lic ense ren ewal ap plicatio n are sp ecified in 10 C FR 54.17. A pplican ts ma y sub mit th eir license renewal applica tions to the NR C in eit her pap er form at or ele ctronica lly, a s descri bed in Regul atory Issu e Sum mary (RI S)01-005, "G uidance on Sub mittin g Doc umen ts to the NRC b y Elec tronic Informa tion Exchange or on CD-R OM."1 The RI S prov ides g eneral g uidance on acce ptable f ormat s for elec tronic s ubmit tals and referen ces deta iled ins truction s, whic h are av ailable throug h the N RC's public W eb site at htt p://www.nrc.gov/sit e-hel p/e ie.h tml.This reg ulatory guide contain s inform ation co llection s that a re cov ered by the req uirem ents of 10 CFR Part 5

4, which the Office of Managemen t and Budget (O

MB) approved und er OMB control number 3150-

015

5. The NRC

may neither conduct nor sponsor, and a person is not req uired to respond to, an inform ation co llection reques t or req uirem ent unle ss the r equesti ng do cume nt displ ays a currentl y valid OMB co ntrol nu mber.

2 Copies are available at current rates from the U.S. Government Printing Office, P.O. Box 37082, Washington, DC

20402-9328 (telephone (202) 512-1800); or f rom the N ational T echnical I

nforma tion Servic e at 5285 Port Roy al Road, Springfie ld, VA 22161;

http://ww w.ntis.g ov; or (703) 487-4650. C

opies are availabl e for ins pection or copy ing for a fee from the NRC's Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDR's mailing address is USNRC PDR , Washing ton, DC 20555; tel ephone (301) 415-4737 or (800) 397-4209; fa x (301) 415-3548; or email PDR@nrc.gov. These documents are also available ele ctronically through the NRC's public Web site at http://www.nrc.gov/re ading-rm/d oc-coll ections/nuregs/st aff/.3 Copies are availa ble for ins pection or copy ing for a fee f rom the N RC's Public Doc ument Room at 11555 Rock ville Pike, Rock ville, MD; the PDR's m ailing addr ess is U SNRC PDR, W

ashington, D

C 20555; telephone (301) 415-4737 or (800) 397-4209; f ax (301) 415-3548;

email PDR@nrc.gov. Revisi on 5 of NEI 95-

10 is also a vailable through the NRC's lic ense rene wal W eb page a t http://www.nrc.gov/reactors/operating/licensing/renewal/guidance.html#nuclear

, and through the NRC's A gency wide Doc uments A ccess a nd Managem ent Sys tem (A DAMS)at http://www.nrc.gov/r eadin g-rm/ad ams.ht ml , under Accession No. ML050280113. Note, h owever, that the NRC

has tem porarily limite d public acc ess to A DAMS so t hat the ag ency c an comple te securi ty rev iews of publicly availabl e documents and rem ove potentia lly se nsitive inf ormation.

Please che ck the NR C's Web site for updates conc erning the resum ption of public access to ADA MS.RG 1.188, Re v. 1, Pag e 3

B. DISCUSSION

This rev ised g uide pro vides guida nce on the info rmatio n that a pplican ts mu st subm it in the ir applications for renewal of nuclear power plant ope rating licenses, as w ell as the uniform format that the NRC staff con siders acceptable for structuring and presenting the required information. Conformance w ith this guide is no t required, but its use facilitates both an applicant's prepa ration of a lice nse ren ewal ap plicatio n and th e NRC staff's t imely and co nsisten t revie w. The NRC st aff will consider different forma ts if they provide an adequat e basis for approval of the application for license renewal.The NRC initially issue d Regulatory Guide 1.188 in July 2001, after soliciting and resolving public comm ents on three draft reg ulatory guides (DG-1104 in August 2000 , DG-10 47 in August 1

996, and DG-1 009 in Decem ber 1990). As su ch, Regulatory Guide 1.188 inco rporated lessons learned from the review of license renewal applications and Owners Group topica l reports. The guide also incorporated relevant info rmation from the developm ent of the "Standard R

eview Plan for th e Review of Lice nse Ren ewal A pplicati ons for Nuclear Power Plants" (SRP-LR) (N UREG-1800), 2 and "G eneric A ging Lesson s Learn ed (GA LL) Re port" (N UREG-1801), 2 as well as a sum mary of public comm ents received on tho se documents (N

UREG-1 832, "Analysis of Public Com ments on the Revised License R

enewal Guidance Do cuments."2)Since the NRC initially published Regul atory Guide 1.188 in July 2001, the staff proposed to update both the SRP-

LR (NUREG-

1800) and GALL

Report (NUREG

-1801) based on experience gaine d from numerou s lice nse ren ewal ap plica tion r eviews a nd othe r insi ghts ide ntifi ed by indu stry. Con sequen tly, the staff also decided to rev ise Regulatory Guide 1.188 to reflect the proposed updates to the guidance documents.

Toward that end, the staff prepared DG-1140, in which the NRC endorsed (with two exceptions)

Revision 5 of N

EI 95-10, "Indus try Guidelines for I

mplementin g the Requirem ents of 10 CFR P

art 54 -The License Renewal Ru le," which the Nuclea r Energy I

nstitute (NEI) p ublished in January 200

5.3 Specifically, the staff to ok exception to th e use of a portion of Appendix F to Re vision 5 of NE

I 95-10, from the unnumbered paragraph fo llowing paragraph 4.4 thr ough the end of Section 4, "Non-Safety SSCs Directly Connected to Safety- Related SSCs." I

n addition, the NRC

staff took exception to the use of paragraph 5.2.

3.1, "Exposure D

uration."

4 Copies are availa ble for ins pection or copy ing for a fee f rom the N RC's Public Doc ument Room at 11555 Rock ville Pike, Rock ville, MD; the PDR's m ailing addr ess is U SNRC PDR, W

ashington, D

C 20555; telephone (301) 415-4737 or (800) 397-4209; f ax (301) 415-3548;

email PDR@nrc.gov. Revisi on 6 of NEI 95-

10 is also a vailable through the NR

C's Ag encyw ide Docum ents Ac cess and Managem ent Sys tem (A DAMS)at http://www.nrc.gov/r eadin g-rm/ad ams.ht ml , under Accession No. ML051860406. Note, h owever, that the NRC

has tem porarily limite d public acc ess to A DAMS so t hat the ag ency c an comple te securi ty rev iews of publicly availabl e documents and rem ove potentia lly se nsitive inf ormation.

Please che ck the NR C's Web site for updates conc erning the resum ption of public access to ADA MS.5 Copies are available at current rates from the U.S. Government Printing Office, P.O. Box 37082, Washington, DC

20402-9328 (telephone (202) 512-1800); or f rom the N ational T echnical I

nforma tion Servic e at 5285 Port Roy al Road, Springfie ld, VA 22161;

http://ww w.ntis.g ov; or (703) 487-4650. C

opies are availabl e for ins pection or copy ing for a fee from the NRC's Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDR's mailing address is USNRC PDR , Washing ton, DC 20555; tel ephone (301) 415-4737 or (800) 397-4209; fa x (301) 415-3548; or email PDR@nrc.gov. These documents are also available ele ctronically through the NRC's public Web site at http://www.nrc.gov/re ading-rm/d oc-coll ections/nuregs/st aff/.RG 1.188, Re v. 1, Pag e 4 Subseq uentl y, in response to the exceptions stated in DG-1140, NEI issued Revision 6 of NEI 95-10 in June 2005

4 to accept the NRC

staff's position with respect to each of those issues, thereby rendering the staf f's two excepti ons unn ecessary. Hav ing re viewe d this la test rev ision of NEI 95-10, the NRC s taff finds Revision 6 acceptable for use in im plementing th e license renewal rule, w ithout exceptions, as discu ssed in this rev ised reg ulatory guide. App licants may meet the int ent of t he licen se renew al rule using meth ods oth er than those p rovide d in Re vision 6 of NE I 95-10; howev er, the NRC st aff will determine the acceptability of such m ethods on a case- by-case basis. For additional info rmation concern ing th e prepa ration o f accept able lic ense ren ewal ap plicatio ns, app licants should refer to the SRP-LR (NURE G-1 800).5 RG 1.188, Re v. 1, Pag e 5 C. REGULATO

RY POSITION

This section discusses the NR

C staff's regulatory position on the standard format and con tent of applications for renewal of operating licenses fo r comme rcial nuclear power plants.

As such, the guidance prov ided in this section is exp ected to ensure that applican ts have identified and taken (or wil l take) actio ns to en sure pl ant saf ety thro ughout t he peri od of ext ended o perat ion. Spe cific ally, such actions relate to (1) m anaging the effects of aging on the functionality o f plant structures, syste ms, and componen ts that the NRC staff has identified as requiring aging m anagement, and (2) evaluating TLAAs that the NRC

staff has identified as requiring such review.

Following this g uidance provides reasonable assurance that the applicant will continue to conduct the activities authorized by the renewed licenses, in accordance with the plant's current licensi ng ba sis (CL B).1.Contents of an Application To renew a nucle ar powe r plant operatin g lice nse, an applica nt mu st me et the re quirem ents delineated in 10 CFR Part 54, "Requi remen ts for Renewal of Operating Licenses for Nuclear Power Plants." This license renewal rule establishes the procedures, criteria, and standards gov erning renewal of an operating licen se. Figure 1 provides a sum mary of th e contents of a license ren ewal application.

The information that an applicant develops and subm its or retains for license renewal should perm it the NR C staff to deter mine that the applica nt has m et the re quirem ents of 10 CFR Part 54. The st andard format in which the applicant present s this information should allow optimum use of the applica nt's resources, while facilitating the NRC staff's review of the license renewal application.

As required by 10 CFR Part 54, an appl ication shall co nsist of gener al infor matio n conce rning both th e applic ant and the pla nt, technical information re ferenced or contained in th e IPA and the evaluation of TLAAs, a supplem ent to the FSAR, an y technical specification change(s) and their a ssociated justification(s), and a supple ment to the p lant's e nviron menta l report.The technical information that an applicant subm its should focus on identifying structures, systems, and componen ts within the scope of 1

0 CFR Part 54, and on reviews of aging m anagement, TLAAs, and the activities necessa ry to ensure that the applicant will maint ain the plant's CLB throughout the period of extended operation.

The technical content of a license renewal application should be sufficient to allow NRC reviewers to understand (1) the m ethodologies used to determine the struc tures, system s, and componen ts that are subject to aging managem ent review, and

(2) the actions taken (or to be taken)

to manage the effects of aging during the period of extended operation.

The NRC staff will rev iew these areas to (1) determ ine whether the m ethodology is acceptable and whether th e lists of structures, systems, an d components and TLAAs are com prehensive; (2) assess the effectiveness of action s taken (or to be taken) to manage ag ing during th e period of extended o peration; and (3) determ ine whether TLAAs will remain valid for the period of extended operation o r have been accep tably resolved or dispo sitioned for the purpos es of lic ense ren ewal.The FSAR supplem ent should contain a su mmary description of the TLAA

evaluation and the prog rams and activities that the applicant will use to managing the effects of aging. The regula tory controls asso ciated with pla cing a summary description of these evaluations and act ivities into the FSAR, along with the ex isting regulatory process, should ensure that future program changes that cou ld decrease the over all ef fecti veness o f the T LAA evalu ation and aging man agement ac tiviti es will recei ve appropr iate rev iew by the app licant.

RG 1.188, Re v. 1, Pag e 6

6 Single co pies of regul atory guides , both ac tive and d raft, and d raft NUREG docu ments may be obtain ed free of charge by wr iting the R

eproduction and D

istribution Ser vices, U SNRC, Wa shington, DC

20555-0001, or by f ax to (301) 415-2289, or by email to DISTRIB UTION@nrc.gov. Active guides ma y also be purchased from the National Technica l Inform ation Serv ice on a s tanding order basis. De tails on this servic e may be obtained by writing NTIS, 5285 Port Royal Road, Springf ield, VA 22161; t elephone (703)

487-4650; online at http://ww w.ntis.g ov. Copies of active and draft guides ar e also av ailable f or inspection or copying for a f ee from the NRC's Public Docum ent Room at 11555 Rockv ille Pike, R

ockville , MD; the PDR'

s mail ing addres s is USNR C PDR, Was hington, DC 20555;

telephone (301)

415-4737 or (800) 397-4209; f ax (301) 415-3548;

email PDR@nrc.gov

.7 Copies are availa ble for ins pection or copy ing for a fee f rom the N RC's Public Doc ument Room at 11555 Rock ville Pike, Rock ville, MD; the PDR's m ailing addr ess is U SNRC PDR, W

ashington, D

C 20555; telephone (301) 415-4737 or (800) 397-4209; f ax (301) 415-3548;

email PDR@nrc.gov. This docum ent is als o availa ble through the NRC's Agenc ywide Docume nts Acc ess and Ma nagem ent Sys tem (A DAMS) a t http://www.nrc.gov/r eadin g-rm/ad ams.ht ml , under Acc ession No. ML 051860406. Note, how ever, tha t the NRC ha s tempor arily limited public acce ss to AD AMS so that th e agency can complet e security reviews o f publicl y available do cuments and remove poten tially sensit ive informa tion. Please check the NRC's W eb site f or updates c oncerning the resumpt ion of public a ccess t o ADA MS.RG 1.188, Re v. 1, Pag e 7 The license renewal application m ust also incorporate the g eneral information req uired by 10 CFR 54.17 and 54.19. Th is infor matio n shoul d includ e any conform ing ch anges to the i ndem nity agreem ent to a ccount for the expirati on term of the p roposed renewe d licens e [10 C FR 54.19(b)]and any restricted data agreem ents [10 CFR 54.17(f) and (g)]. In addition, the IPA, the TLAA evaluation, and/or the FSAR su pplement should contain or reference the techn ical information required by 10 CFR 54.21 and 54.22.

The license renewal application should also include or reference any technical specification changes or additions that are necessary to manag e the effects of aging during the period of extended operation.

The appl icant sh ould id entify technic al specification changes or additions when additional regula tory control is warranted to ensure that the app licant w ill ma nage t he effec ts of ag ing, such th at the n ecessary quality of systems, structures, and com ponents will continue to be maintained, fa cility operation will con tinue to be within safety limits, and lim iting conditions for op eration will continue to be met. As su ch, the application should includ e justifications for the proposed cha nges or additions, and the justifications must com ply with the require ments of 10 C

FR Part 5

0. The N

RC staff may also include conditions or limitations on the renewed license, in a ccordance with 10 C

FR 54.33(b), wh en the staff determin es that a dditi onal re gulato ry contr ol is wa rrant ed to en sure t hat the applic ant wil l adequ ately man age the ef fects of aging.

In addition, the applicant should provide environmenta l information in a supplement to the plant's enviro nmen tal repo rt, and such in forma tion m ust com ply w ith the requirem ents of Subpar t A of 10 CFR Part 5

1, as required by

10 CFR 54.2

3. For additional g uidance concerning the format and content of the environmenta l report, applica nts should refer to Supplement

1 to Regul atory Guide 4.2,"Preparation of Supplem ental Environm ental Reports for Application s To Renew Nuclear P

ower Plant Operating Licenses," dated Septemb er 2000.6 2.Endorsement of NEI Guidelines Revision 6 of NEI 95-10, "Ind ustry Guidelines for Implem enting the Require ments of 10 CFR Part 54 -The License Renewal Ru le," dated June 2005, 7 provi des m ethods that the NRC s taff con siders a cceptab le for complyin g with the requirem ents of 10 CFR P

art 54 for preparing a license renewal application.

8 Regulator y issue summ aries ar e avail able through the NRC's public Web site at http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/

.RG 1.188, Re v. 1, Pag e 8 3.Form atting Spec ifications The filing requireme nts for a license renewal a pplication are specified in 10 CFR 54.17.

Applica nts may subm it applications to the NRC in electron ic or paper forma t, as described in RIS 2001-05,"Guidance on Subm itting Docum ents to the NRC b y Electronic I

nformation Exchan ge or on CD-ROM."8 This gu idance applies to licen se renew al appli cations or port ions the reof.3.1 Graphical Presentations Applicants should em ploy graphical presentations (such as draw ings, map s, diagram s, sketches, and tab les) i f such mea ns may convey t he info rmation more adeq uatel y or conven ientl y. In so doing, applicants should ensure th at all information so presented is legible, symbols are defined, no essential information is lost w hen colored drawing s are printed in black on white paper, an d scales are not reduced to the extent that visual aids are necessa ry to interpret pertinent information.

Such graphical presentations should appear in the sec tion where they a re primarily dis cussed. References us ed may be cited either as footnotes on the page where they are discussed, or as e ndnotes at the end of the chapter in which they are discussed.

3.2 Physical Specifications

3.2.1 Paper Size

• Text pages: 81/2 x 11 inches.*Drawin gs and graphics: 81/2 x 11 inches. A larger size is acceptable, provided that the finished copy, when folded, does not exceed 81/2 x 11 inches.3.2.2 Paper Stock and In k Use suitable quality in substance, paper colo r, and ink dens ity for handling and reproduction by m icrofilm ing or imag e-co pying equipm ent.3.2.3 Page Margins Maintain a marg in of no less than 1 inch on the top, bott om, and binding side of all pages submitted.

3.2.4 Printing*Composition: Text p ages should be s ingle-space d.*Type Face and Sty le: Use type face s and styles that are suitable for reproduction by m icrofilm ing or imag e-co pying equipm ent.*Reproduction: Copies may be mechanically or photographically reproduced.

All text pages sho uld be printed on both sides, with the im age printed head- to-head.

RG 1.188, Re v. 1, Pag e 9 3.2.5 Binding Pages should be punched for standard 3- hole looseleaf binders.

3.2.6 Page Numbering Pages should be numbered with digits corresponding to the chapter and sectio n, followed by a hypen and a sequential page num ber (e.g., the third page of Sectio n 4.1 of Chapter 4 should be numbered 4.1-

3). Do not number the entire report sequentially.

3.2.7 Table o f Conte nts Provide a table of contents and index of k ey terms for the renewal application.

3.3 Procedure for Updating or Revising Pages Text and graphical presen tations should be rev ised by prov iding replacem ent pages. The ne w or mo dified p ortion o f each p age sh ould be highl ighted by a "chang e indica tor," co nsisting of a bo ld vertic al line d rawn in the m argin opposit e the bi nding marg in. The line sho uld be o f the sa me le ngth as the new or m odified portion of the pag e.All pages submitted to update, revise, or add pages to the report should show the date of the change, as well as the chang e or amendm ent number.

A guide pag e listing the pag es to be inserted and p ages to be remov ed should accom pany each subm ission of revised pag es. In ad dition, when m aking m ajor changes or additions , the applicant should p rovide a revised table of contents.

RG 1.188, Re v. 1, Pag e 10 D. IMPLEMEN

TATION The purpose of this section is to provide information to applica nts regarding the NRC staff's plans for usin g this regul atory guide. Exce pt in th ose cas es in w hich an applica nt prop oses or has pre vious ly establis hed an accepta ble alte rnativ e met hod for comp lying with sp ecified portion s of the NRC's regulations, the m ethods described in this g uide reflect public com ments and will be used in evalua ting applications to renew nuc lear power plant operating licenses.

REGUL ATORY ANAL YSIS The NRC staff did not prepare a separate reg ulatory analysis for this regulatory guide. The reg ulatory analy sis prep ared for the fin al licen se renew al rule a lso prov ides the regul atory basis for this guide and examines the costs and benefits of im plementing th e rule. A copy of that regula tory analysis, "Nuclear Power Plant License Renewal - 10 CFR Part 54," dated Februa ry 199 5, is av ailable for inspection and copying for a fee at the NRC's Public Document Room, located at 11555 Rockv ille Pike, Rockville, Mary land.BACKF IT ANA LYSIS This regula tory guide proposes NRC staff guidance on complying with the final license renewal rule, 10 CFR Part 54, which beca me effec tive on June 7, 1995. Accord ingly, publication of this regula tory guide does not constitu te a backf it under 10 CFR 50.109, and no backf it analy sis is necessa ry or has been prepared for this regulatory guide.