Regulatory Guide 1.188: Difference between revisions

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{{Adams
{{Adams
| number = ML052200165
| number = ML012010322
| issue date = 08/08/2005
| issue date = 07/31/2001
| title = Draft Rev. 1, Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses (Draft for ACRS Review)
| title = Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses
| author name = Garrity P
| author name =  
| author affiliation = NRC/RES/PMPDAS
| author affiliation = NRC/RES
| addressee name =  
| addressee name =  
| addressee affiliation =  
| addressee affiliation =  
| docket =  
| docket =  
| license number =  
| license number =  
| contact person = jxd
| contact person = Anand R, NRR/DRIP, 415-1146
| case reference number = DG-1140
| case reference number = DG-1009, DG-1047, DG-1104
| document report number = RG-1.188, Rev 1
| document report number = RG-1.188
| document type = Regulatory Guide, Draft
| document type = Regulatory Guide
| page count = 10
| page count = 8
}}
}}
{{#Wiki_filter: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
{{#Wiki_filter:Regulatory guides are issued to describe and make available to the public such information as methods acceptable to the NRC staff for implementing specific parts of the NRCs  regulations, techniques used by the staff in evaluating specific problems or postulated accidents, and data needed by the NRC staff in its review of applications for permits and licenses.  Regulatory guides are not substitutes for regulations, and compliance with them is not required.  Methods and solutions different from those set out in the guides will be acceptable if they provide a basis for the findings requisite to the issuance or continuance of a permit or license by the Commission.


====c. The NRC====
This guide was issued after consideration of comments received from the public. Comments and suggestions for improvements in these guides are encouraged at all times, and guides will be revised, as appropriate, to accommodate comments and to reflect new information or experience.  Written comments may be submitted to the Rules and Directives Branch, ADM, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.
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
Regulatory guides are issued in ten broad divisions:  1, Power Reactors; 2, Research and Test Reactors; 3, Fuels and Materials Facilities; 4, Environmental and Siting;
, 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
5, Materials and Plant Protection; 6, Products; 7, Transportation; 8, Occupational Health; 9, Antitrust and Financial Review; and 10, General.
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
Single copies of regulatory guides (which may be reproduced) may be obtained free of charge by writing the Distribution Services Section, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by fax to (301)415-2289, or by email to DISTRIBUTION@NRC.GOV.  Electronic copies of this guide are available on the internet at NRCs web site at <WWW.NRC.GOV> in the Reference Library under Regulatory Guides.  This guide is also in the Electronic Reading Room at NRCs home page, along with other recently issued guides, Accession Number ML012010322.
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
U.S. NUCLEAR REGULATORY COMMISSION            July 2001 REGULATORY
CFR Part 2, 10
GUIDE
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
OFFICE OF NUCLEAR REGULATORY RESEARCH
0 years before the expiration of the o perating license current ly in e ffect.  [10 CF R 54.1 7(c)]
REGULATORY GUIDE 1.188 (Drafts were DG-1104, DG-1047, and DG-1009)
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/
STANDARD FORMAT AND CONTENT
.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
FOR APPLICATIONS TO RENEW
4, which the Office of Managemen t and Budget (O
NUCLEAR POWER PLANT OPERATING LICENSES
MB) approved und er OMB control number 3150-
015


===5. The NRC ===
==A. INTRODUCTION==
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.
GENERAL
The issuance of renewed operating licenses for nuclear power plants is governed by Title 10 of the Code of Federal Regulations (10 CFR) in Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants" (the license renewal rule), which specifies the information to be included as part of an application for license renewal.  This information is to be included in the application to renew an operating license submitted by a nuclear power plant licensee.  The application should include (1) general information, (2) the integrated plant assessment, (3) an evaluation of time-limited aging analyses, (4) a final safety analysis report (FSAR) supplement, (5) technical specification changes, and (6) an environmental report supplement.  The FSAR supplement should provide a summary description of the programs and activities for managing the effects of aging for the period of extended operation, which is determined by the integrated plant assessment and an evaluation of time-limited aging analyses.


2 Copies are available at current rates from the U.S. Government Printing Office, P.O. Box 37082, Washington, DC
The following general provisions, with the corresponding regulations, apply to filing an application for a renewed license.
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
!
The application must be 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)]
 
1 Regulatory Issue Summaries are available through the NRCs web site at WWW.NRC.GOV.
 
1.188-2
!
The application may not be submitted to the Commission earlier than 20 years before the expiration of the operating license currently in effect.  [10 CFR 54.17(c)]
 
!
For the timely renewal provisions of 10 CFR 2.109(b) to apply, a sufficient application must be filed at least 5 years prior to the expiration of the existing license.  [10 CFR 2.109(b)]
!
The application for a renewed license may be combined with applications for other types of licenses.  [10 CFR 54.17(d)]
!
The application may incorporate by reference information contained in previous applications for licenses or license amendments, statements, correspondence, or reports filed with the Commission, provided that the references are clear and specific.  [10 CFR 54.17(e)]
The requirements for filing a license renewal application are specified in 10 CFR 54.17.
 
An application may be submitted to the NRC in electronic or paper format, as described in Regulatory Issue Summary (RIS) 2001-05, Guidance on Submitting Documents to the NRC by Electronic Information Exchange or on CD-Rom.1   The RIS provides guidance on acceptable electronic formats for electronic submittals and references an NRC web site for further details at
<http://www.nrc.gov/NRC/EIE/index.html>.  This regulatory guide applies to license renewal applications or portions thereof.
 
The information collections contained in this regulatory guide are covered by the requirements of 10 CFR Part 54, which were approved by the Office of Management and Budget, approval number 3150-0155. If a means used to impose an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.


==B. DISCUSSION==
==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
The purpose of this guide is to provide guidance on the information to be submitted in an application for renewal of a nuclear power plant operating license in a uniform format that is acceptable to the NRC staff for structuring and presenting this information. Conformance with this guide is not required, but its use facilitates both preparation of a license renewal application by a licensee and timely, uniform review by the NRC staff.  A different format will be acceptable to the NRC staff if it provides an adequate basis for approval of the application for license renewal.
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
Drafts of this guide were issued for public comment as DG-1104 in August 2000, DG-1047 in August 1996, and DG-1009 in December 1990.  This guide incorporates lessons learned from the review of license renewal applications and Owners Group topical report reviews.  The guide also incorporates relevant information from the development of the Standard Review Plan for the
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-
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 from the National Technical Information Service by writing NTIS at 5285 Port Royal Road, Springfield, VA 22161; (telephone (703)487-4650; <http://www.ntis.gov/ordernow>.  Copies are available for inspection or copying for a fee from the NRC Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDRs mailing address is USNRC PDR, Washington, DC 20555; telephone (301)415-4737 or (800)397-4209; fax (301)415-3548; email is PDR@NRC.GOV.  Electronic copies of these documents are available on the NRC web site at <WWW.NRC.GOV> and through NRCs Electronic Reading Room at the same web site.
LR (NUREG-
 
1800) and GALL
3  Copies are available for inspection or copying for a fee from the NRC Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDRs mailing address is USNRC PDR, Washington, DC 20555; telephone (301)415-4737 or (800)397-
Report (NUREG
4209; fax (301)415-3548; email is PDR@NRC.GOV.  Electronic copies are available at the NRCs license renewal web site,
-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.
<WWW.NRC.GOV> .  Electronic copies are also available through NRCs Electronic Reading Room at the same web site; the accession number of NEI 95-10 is ML011100576.
 
1.188-3 Review of License Renewal Applications for Nuclear Power Plants (SRP-LR) (NUREG-1800),2 and Generic Aging Lessons Learned (GALL) Report (NUREG-1801),2 as well as from public comments received on these documents (these public comments are summarized in NUREG-1739, Analysis of Public Comments on the Improved License Renewal Guidance Documents).2 The Nuclear Energy Institute (NEI) has developed NEI 95-10, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54The License Renewal Rule," Revision 3 (March 2001),3 regarding implementation of the license renewal rule.  The NRC staff has reviewed this document and found that it provides guidance acceptable to the staff. Licensees may use methods other than those provided in NEI 95-10 to meet the intent of the license renewal rule, but the NRC staff will determine the acceptability of other methods on a case-by-case basis.
 
Additional information for preparing a license renewal application is provided in the Standard Review Plan for License Renewal (NUREG-1800).2 This guide provides guidance on applications for renewal of operating licenses for commercial nuclear power plants and is expected to ensure that actions have been identified and have been taken or will be taken with respect to (1) managing the effects of aging during the extended period of operation on the functionality of structures and components that have been identified to require review and (2) evaluating time-limited aging analyses that have been identified to require review, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the current licensing basis (CLB).
 
==C. REGULATORY POSITION==
1.
 
CONTENTS OF AN APPLICATION
The requirements that an applicant must meet for renewal of a nuclear power plant operating license are delineated in 10 CFR Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants."  This rule establishes the procedures, criteria, and standards governing renewal of an operating license.  Figure 1 provides a summary of the contents of a license renewal application.
 
1.188-4 The information developed and submitted or retained by an applicant for license renewal should permit the NRC staff to make the determination that the requirements of 10 CFR Part 54 have been met.  The format in which this information is presented should provide for optimum use of the applicant's resources and should facilitate the NRC staff review of the license renewal application.  An application will consist of general information concerning the applicant and the plant, technical information referenced or contained in the integrated plant assessment (IPA) and the evaluation of time-limited aging analyses (TLAAs), a supplement to the Final Safety Analysis Report (FSAR), technical specification changes and their justification, and a supplement to the environmental report.
 
The technical information submitted should focus on reviews of aging management, TLAAs, and the activities necessary to ensure that the CLB for the plant will be maintained for the period of extended operation.  The technical content of a license renewal application should be sufficient to allow an NRC reviewer to understand (1) the methodologies used to determine the structures and components subject to an aging management 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 review these areas to (1) determine whether the methodology is acceptable and whether the resultant lists of systems, structures, or components and TLAAs are comprehensive, (2) assess the effectiveness of actions taken or to be taken to manage aging during the period of extended operation, and (3) determine that TLAAs will remain valid for the period of extended operation or have been acceptably resolved or dispositioned for the purposes of license renewal.
 
The FSAR supplement should contain a summary description of programs and activities for managing the effects of aging and the evaluation of TLAAs.  The regulatory controls associated with placing a summary description of these activities and evaluations into the FSAR, along with the existing regulatory process, should ensure that future changes to programs that could decrease the overall effectiveness of aging management activities and the evaluation of TLAAs will receive appropriate review by the licensee.
 
The general information required by 10 CFR 54.17 and 54.19 is to be incorporated into the application.  Any conforming changes to the indemnity agreement to account for the expiration term of the proposed renewed license [10 CFR 54.19(b)] and restricted data agreements [10 CFR
54.17(f) and (g)] should be included in the application.  The technical information required by
10 CFR 54.21 and 54.22 should be contained or referenced in the integrated plant assessment, the evaluation of time-limited aging analyses, or the supplement to the current FSAR.
 
Technical specification changes or additions that are necessary to manage the effects of aging during the period of extended operation should be included or referenced in the license renewal application.  The applicant should identify technical specification changes or additions when additional regulatory control is warranted to ensure that the effects of aging will be managed such that the necessary quality of systems, structures, and components is maintained, that facility operation is within safety limits, and that limiting conditions for operation will continue to be met.
 
Justification for the changes or additions should be included in the application and the justifications must comply with the requirements of 10 CFR Part 50.  The NRC staff may also include conditions or limitations on the renewed license in accordance with 10 CFR 54.33(b) when
 
4 Single copies of regulatory guides, both active and draft, and draft NUREG documents may be obtained free of charge by fax to
(301)415-2289, or by email to <DISTRIBUTION@NRC.GOV>.  Active guides may also be purchased from the National Technical Information Service on a standing order basis.  Details on this service may be obtained by writing NTIS, 5285 Port Royal Road, Springfield, VA 22161; telephone (703)487-4650; online <http://www.ntis.gov/ordernow>.  Copies of certain guides and many other NRC documents are available electronically  at  <WWW.NRC.GOV>.  Documents are also available through the Electronic Reading Room (NRCs ADAMS document system) at the same web site.
 
1.188-5 the NRC staff determines that the additional regulatory control is warranted to ensure that the effects of aging will be adequately managed.
 
Environmental information should be provided in a supplement to the environmental report that complies with the requirements of Subpart A of 10 CFR Part 51 as required by 10 CFR 54.23.
 
Guidance on the format and content of the environmental report is in Supplement 1 to Regulatory Guide 4.2, "Preparation of Supplemental Environmental Reports for Applications To Renew Nuclear Power Plant Operating Licenses" (September 2000).4
2.  ENDORSEMENT OF NEI GUIDELINE
The Nuclear Energy Institutes NEI 95-10, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54The License Renewal Rule," Revision 3 (March 2001),3 provides methods that are acceptable to the NRC staff for complying with the requirements of
10 CFR Part 54 for preparing a license renewal application.


Toward that end, the staff prepared DG-1140, in which the NRC endorsed (with two exceptions)
3.
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
FORMATTING SPECIFICATIONS
uration."
The filing requirements for a license renewal application are specified in 10 CFR 54.17.
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
The application may be submitted to the NRC in electronic or paper format, as described in Regulatory Issue Summary (RIS) 2001-05, Guidance on Submitting Documents to the NRC by Electronic Information Exchange or on CD-Rom.1  This guide applies to license renewal applications or portions thereof.
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
3.1 Graphical Presentations Graphical presentations such as drawings, maps, diagrams, sketches, and tables should be employed if the information may be presented more adequately or conveniently by such means.
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.
Due concern should be taken to ensure that all information so presented is legible, that symbols are defined, that no essential information is lost when colored drawings are printed in black on white paper, and that scales are not reduced to the extent that visual aids are necessary to interpret pertinent items of information. These graphical presentations should be located in the section where they are primarily discussed.  References used may appear either as footnotes to the page where discussed or at the end of each chapter.


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.
1.188-6
3.2 Physical Specifications Paper Size
1.


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
Text pages:  8-1/2 x 11 inches.
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.
(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
Drawings and graphics:  8-1/2 x 11 inches; however, a larger size is acceptable provided that the finished copy when folded does not exceed 8-1/2 x 11 inches.
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
Paper Stock and Ink.  Suitable quality in substance, paper color, and ink density for handling and reproduction by microfilming or image-copying equipment.
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.
Paper Margins.  A margin of no less than 1 inch should be maintained on the top, bottom, and binding side of all pages submitted.


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
Printing.
FR Part 5


===0. The N===
1.
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
Composition -- Text pages should be single spaced.
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/
2.
.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
Type face and style -- Should be suitable for microfilming or image-copying equipment.
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.


3.2 Physical Specifications
Reproduction -- May be mechanically or photographically reproduced.   All pages of text should be printed on both sides and the image printed head-to-head.
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.
Binding.  Pages should be punched for standard 3-hole loose leaf binders.


All text pages sho uld be printed on both sides, with the im age printed head- to-head.
Page Numbering.  Pages should be numbered with the two digits corresponding to the chapter followed by a hyphen and a sequential number (e.g., the third page of Section 4.1 of Chapter 4 should be numbered 4.1-3).  Do not number the entire report sequentially.


RG 1.188, Re v. 1, Pag e 9 3.2.5 Binding Pages should be punched for standard 3- hole looseleaf binders.
Table of Contents. A table of contents and index of key items should be provided for the renewal application.


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-
3.3 Procedure for Updating or Revising Pages The text should be revised by replacing pages. The changed or revised portion of each page should be highlighted by a "change indicator" mark consisting of a bold vertical line drawn in the margin opposite the binding margin. The line should be of the same length as the portion changed.
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.
All pages submitted to update, revise, or add pages to the report should show the date of the change and the change or amendment number. A guide page listing the pages to be inserted and the pages to be removed should accompany the revised pages. When major changes or additions are made, a revised table of contents should be provided.


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.
==D. IMPLEMENTATION==
The purpose of this section is to provide information to applicants regarding the NRC
staff's plans for using this regulatory guide.


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.
1.188-7 Except in those cases in which an applicant proposes an acceptable alternative method for complying with specified portions of the NRC's regulations, the methods described in this guide that reflects public comments will be used in the evaluation of applications to renew nuclear power plant operating licenses.


RG 1.188, Re v. 1, Pag e 10 D.  IMPLEMEN
1.188-9 REGULATORY ANALYSIS
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.
A separate regulatory analysis was not prepared for this regulatory guide.  The regulatory analysis prepared for the final license renewal rule provides the regulatory basis for this guide and examines the costs and benefits of implementing the rule.  A copy of the regulatory analysis,
"Nuclear Power Plant License Renewal10 CFR Part 54" (February 1995), is available for inspection and copying for a fee at the NRC's Public Document Room, located at 11555 Rockville Pike, Rockville, MD.


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.}}
BACKFIT ANALYSIS
This regulatory guide proposes NRC staff guidance on complying with the final license renewal rule, 10 CFR Part 54, which was effective June 7, 1995.  Accordingly, publication of this regulatory guide is not a backfit under 10 CFR 50.109, and no backfit analysis is necessary or has been prepared for this regulatory guide.}}


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Latest revision as of 01:52, 17 January 2025

Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses
ML012010322
Person / Time
Issue date: 07/31/2001
From:
Office of Nuclear Regulatory Research
To:
Anand R, NRR/DRIP, 415-1146
References
DG-1009, DG-1047, DG-1104 RG-1.188
Download: ML012010322 (8)
v • d • e


Regulatory guides are issued to describe and make available to the public such information as methods acceptable to the NRC staff for implementing specific parts of the NRCs regulations, techniques used by the staff in evaluating specific problems or postulated accidents, and data needed by the NRC staff in its review of applications for permits and licenses. Regulatory guides are not substitutes for regulations, and compliance with them is not required. Methods and solutions different from those set out in the guides will be acceptable if they provide a basis for the findings requisite to the issuance or continuance of a permit or license by the Commission.

This guide was issued after consideration of comments received from the public. Comments and suggestions for improvements in these guides are encouraged at all times, and guides will be revised, as appropriate, to accommodate comments and to reflect new information or experience. Written comments may be submitted to the Rules and Directives Branch, ADM, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.

Regulatory guides are issued in ten broad divisions: 1, Power Reactors; 2, Research and Test Reactors; 3, Fuels and Materials Facilities; 4, Environmental and Siting;

5, Materials and Plant Protection; 6, Products; 7, Transportation; 8, Occupational Health; 9, Antitrust and Financial Review; and 10, General.

Single copies of regulatory guides (which may be reproduced) may be obtained free of charge by writing the Distribution Services Section, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by fax to (301)415-2289, or by email to DISTRIBUTION@NRC.GOV. Electronic copies of this guide are available on the internet at NRCs web site at <WWW.NRC.GOV> in the Reference Library under Regulatory Guides. This guide is also in the Electronic Reading Room at NRCs home page, along with other recently issued guides, Accession Number ML012010322.

U.S. NUCLEAR REGULATORY COMMISSION July 2001 REGULATORY

GUIDE

OFFICE OF NUCLEAR REGULATORY RESEARCH

REGULATORY GUIDE 1.188 (Drafts were DG-1104, DG-1047, and DG-1009)

STANDARD FORMAT AND CONTENT

FOR APPLICATIONS TO RENEW

NUCLEAR POWER PLANT OPERATING LICENSES

A. INTRODUCTION

GENERAL

The issuance of renewed operating licenses for nuclear power plants is governed by Title 10 of the Code of Federal Regulations (10 CFR) in Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants" (the license renewal rule), which specifies the information to be included as part of an application for license renewal. This information is to be included in the application to renew an operating license submitted by a nuclear power plant licensee. The application should include (1) general information, (2) the integrated plant assessment, (3) an evaluation of time-limited aging analyses, (4) a final safety analysis report (FSAR) supplement, (5) technical specification changes, and (6) an environmental report supplement. The FSAR supplement should provide a summary description of the programs and activities for managing the effects of aging for the period of extended operation, which is determined by the integrated plant assessment and an evaluation of time-limited aging analyses.

The following general provisions, with the corresponding regulations, apply to filing an application for a renewed license.

!

The application must be 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)]

1 Regulatory Issue Summaries are available through the NRCs web site at WWW.NRC.GOV.

1.188-2

!

The application may not be submitted to the Commission earlier than 20 years before the expiration of the operating license currently in effect. [10 CFR 54.17(c)]

!

For the timely renewal provisions of 10 CFR 2.109(b) to apply, a sufficient application must be filed at least 5 years prior to the expiration of the existing license. [10 CFR 2.109(b)]

!

The application for a renewed license may be combined with applications for other types of licenses. [10 CFR 54.17(d)]

!

The application may incorporate by reference information contained in previous applications for licenses or license amendments, statements, correspondence, or reports filed with the Commission, provided that the references are clear and specific. [10 CFR 54.17(e)]

The requirements for filing a license renewal application are specified in 10 CFR 54.17.

An application may be submitted to the NRC in electronic or paper format, as described in Regulatory Issue Summary (RIS) 2001-05, Guidance on Submitting Documents to the NRC by Electronic Information Exchange or on CD-Rom.1 The RIS provides guidance on acceptable electronic formats for electronic submittals and references an NRC web site for further details at

<http://www.nrc.gov/NRC/EIE/index.html>. This regulatory guide applies to license renewal applications or portions thereof.

The information collections contained in this regulatory guide are covered by the requirements of 10 CFR Part 54, which were approved by the Office of Management and Budget, approval number 3150-0155. If a means used to impose an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.

B. DISCUSSION

The purpose of this guide is to provide guidance on the information to be submitted in an application for renewal of a nuclear power plant operating license in a uniform format that is acceptable to the NRC staff for structuring and presenting this information. Conformance with this guide is not required, but its use facilitates both preparation of a license renewal application by a licensee and timely, uniform review by the NRC staff. A different format will be acceptable to the NRC staff if it provides an adequate basis for approval of the application for license renewal.

Drafts of this guide were issued for public comment as DG-1104 in August 2000, DG-1047 in August 1996, and DG-1009 in December 1990. This guide incorporates lessons learned from the review of license renewal applications and Owners Group topical report reviews. The guide also incorporates relevant information from the development of the Standard Review Plan for the

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 from the National Technical Information Service by writing NTIS at 5285 Port Royal Road, Springfield, VA 22161; (telephone (703)487-4650; <http://www.ntis.gov/ordernow>. Copies are available for inspection or copying for a fee from the NRC Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDRs mailing address is USNRC PDR, Washington, DC 20555; telephone (301)415-4737 or (800)397-4209; fax (301)415-3548; email is PDR@NRC.GOV. Electronic copies of these documents are available on the NRC web site at <WWW.NRC.GOV> and through NRCs Electronic Reading Room at the same web site.

3 Copies are available for inspection or copying for a fee from the NRC Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDRs mailing address is USNRC PDR, Washington, DC 20555; telephone (301)415-4737 or (800)397-

4209; fax (301)415-3548; email is PDR@NRC.GOV. Electronic copies are available at the NRCs license renewal web site,

<WWW.NRC.GOV> . Electronic copies are also available through NRCs Electronic Reading Room at the same web site; the accession number of NEI 95-10 is ML011100576.

1.188-3 Review of License Renewal Applications for Nuclear Power Plants (SRP-LR) (NUREG-1800),2 and Generic Aging Lessons Learned (GALL) Report (NUREG-1801),2 as well as from public comments received on these documents (these public comments are summarized in NUREG-1739, Analysis of Public Comments on the Improved License Renewal Guidance Documents).2 The Nuclear Energy Institute (NEI) has developed NEI 95-10, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54The License Renewal Rule," Revision 3 (March 2001),3 regarding implementation of the license renewal rule. The NRC staff has reviewed this document and found that it provides guidance acceptable to the staff. Licensees may use methods other than those provided in NEI 95-10 to meet the intent of the license renewal rule, but the NRC staff will determine the acceptability of other methods on a case-by-case basis.

Additional information for preparing a license renewal application is provided in the Standard Review Plan for License Renewal (NUREG-1800).2 This guide provides guidance on applications for renewal of operating licenses for commercial nuclear power plants and is expected to ensure that actions have been identified and have been taken or will be taken with respect to (1) managing the effects of aging during the extended period of operation on the functionality of structures and components that have been identified to require review and (2) evaluating time-limited aging analyses that have been identified to require review, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the current licensing basis (CLB).

C. REGULATORY POSITION

1.

CONTENTS OF AN APPLICATION

The requirements that an applicant must meet for renewal of a nuclear power plant operating license are delineated in 10 CFR Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants." This rule establishes the procedures, criteria, and standards governing renewal of an operating license. Figure 1 provides a summary of the contents of a license renewal application.

1.188-4 The information developed and submitted or retained by an applicant for license renewal should permit the NRC staff to make the determination that the requirements of 10 CFR Part 54 have been met. The format in which this information is presented should provide for optimum use of the applicant's resources and should facilitate the NRC staff review of the license renewal application. An application will consist of general information concerning the applicant and the plant, technical information referenced or contained in the integrated plant assessment (IPA) and the evaluation of time-limited aging analyses (TLAAs), a supplement to the Final Safety Analysis Report (FSAR), technical specification changes and their justification, and a supplement to the environmental report.

The technical information submitted should focus on reviews of aging management, TLAAs, and the activities necessary to ensure that the CLB for the plant will be maintained for the period of extended operation. The technical content of a license renewal application should be sufficient to allow an NRC reviewer to understand (1) the methodologies used to determine the structures and components subject to an aging management 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 review these areas to (1) determine whether the methodology is acceptable and whether the resultant lists of systems, structures, or components and TLAAs are comprehensive, (2) assess the effectiveness of actions taken or to be taken to manage aging during the period of extended operation, and (3) determine that TLAAs will remain valid for the period of extended operation or have been acceptably resolved or dispositioned for the purposes of license renewal.

The FSAR supplement should contain a summary description of programs and activities for managing the effects of aging and the evaluation of TLAAs. The regulatory controls associated with placing a summary description of these activities and evaluations into the FSAR, along with the existing regulatory process, should ensure that future changes to programs that could decrease the overall effectiveness of aging management activities and the evaluation of TLAAs will receive appropriate review by the licensee.

The general information required by 10 CFR 54.17 and 54.19 is to be incorporated into the application. Any conforming changes to the indemnity agreement to account for the expiration term of the proposed renewed license [10 CFR 54.19(b)] and restricted data agreements [10 CFR

54.17(f) and (g)] should be included in the application. The technical information required by

10 CFR 54.21 and 54.22 should be contained or referenced in the integrated plant assessment, the evaluation of time-limited aging analyses, or the supplement to the current FSAR.

Technical specification changes or additions that are necessary to manage the effects of aging during the period of extended operation should be included or referenced in the license renewal application. The applicant should identify technical specification changes or additions when additional regulatory control is warranted to ensure that the effects of aging will be managed such that the necessary quality of systems, structures, and components is maintained, that facility operation is within safety limits, and that limiting conditions for operation will continue to be met.

Justification for the changes or additions should be included in the application and the justifications must comply with the requirements of 10 CFR Part 50. The NRC staff may also include conditions or limitations on the renewed license in accordance with 10 CFR 54.33(b) when

4 Single copies of regulatory guides, both active and draft, and draft NUREG documents may be obtained free of charge by fax to

(301)415-2289, or by email to <DISTRIBUTION@NRC.GOV>. Active guides may also be purchased from the National Technical Information Service on a standing order basis. Details on this service may be obtained by writing NTIS, 5285 Port Royal Road, Springfield, VA 22161; telephone (703)487-4650; online <http://www.ntis.gov/ordernow>. Copies of certain guides and many other NRC documents are available electronically at <WWW.NRC.GOV>. Documents are also available through the Electronic Reading Room (NRCs ADAMS document system) at the same web site.

1.188-5 the NRC staff determines that the additional regulatory control is warranted to ensure that the effects of aging will be adequately managed.

Environmental information should be provided in a supplement to the environmental report that complies with the requirements of Subpart A of 10 CFR Part 51 as required by 10 CFR 54.23.

Guidance on the format and content of the environmental report is in Supplement 1 to Regulatory Guide 4.2, "Preparation of Supplemental Environmental Reports for Applications To Renew Nuclear Power Plant Operating Licenses" (September 2000).4

2. ENDORSEMENT OF NEI GUIDELINE

The Nuclear Energy Institutes NEI 95-10, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54The License Renewal Rule," Revision 3 (March 2001),3 provides methods that are acceptable to the NRC staff for complying with the requirements of

10 CFR Part 54 for preparing a license renewal application.

3.

FORMATTING SPECIFICATIONS

The filing requirements for a license renewal application are specified in 10 CFR 54.17.

The application may be submitted to the NRC in electronic or paper format, as described in Regulatory Issue Summary (RIS) 2001-05, Guidance on Submitting Documents to the NRC by Electronic Information Exchange or on CD-Rom.1 This guide applies to license renewal applications or portions thereof.

3.1 Graphical Presentations Graphical presentations such as drawings, maps, diagrams, sketches, and tables should be employed if the information may be presented more adequately or conveniently by such means.

Due concern should be taken to ensure that all information so presented is legible, that symbols are defined, that no essential information is lost when colored drawings are printed in black on white paper, and that scales are not reduced to the extent that visual aids are necessary to interpret pertinent items of information. These graphical presentations should be located in the section where they are primarily discussed. References used may appear either as footnotes to the page where discussed or at the end of each chapter.

1.188-6

3.2 Physical Specifications Paper Size

1.

Text pages: 8-1/2 x 11 inches.

2.

Drawings and graphics: 8-1/2 x 11 inches; however, a larger size is acceptable provided that the finished copy when folded does not exceed 8-1/2 x 11 inches.

Paper Stock and Ink. Suitable quality in substance, paper color, and ink density for handling and reproduction by microfilming or image-copying equipment.

Paper Margins. A margin of no less than 1 inch should be maintained on the top, bottom, and binding side of all pages submitted.

Printing.

1.

Composition -- Text pages should be single spaced.

2.

Type face and style -- Should be suitable for microfilming or image-copying equipment.

3.

Reproduction -- May be mechanically or photographically reproduced. All pages of text should be printed on both sides and the image printed head-to-head.

Binding. Pages should be punched for standard 3-hole loose leaf binders.

Page Numbering. Pages should be numbered with the two digits corresponding to the chapter followed by a hyphen and a sequential number (e.g., the third page of Section 4.1 of Chapter 4 should be numbered 4.1-3). Do not number the entire report sequentially.

Table of Contents. A table of contents and index of key items should be provided for the renewal application.

3.3 Procedure for Updating or Revising Pages The text should be revised by replacing pages. The changed or revised portion of each page should be highlighted by a "change indicator" mark consisting of a bold vertical line drawn in the margin opposite the binding margin. The line should be of the same length as the portion changed.

All pages submitted to update, revise, or add pages to the report should show the date of the change and the change or amendment number. A guide page listing the pages to be inserted and the pages to be removed should accompany the revised pages. When major changes or additions are made, a revised table of contents should be provided.

D. IMPLEMENTATION

The purpose of this section is to provide information to applicants regarding the NRC

staff's plans for using this regulatory guide.

1.188-7 Except in those cases in which an applicant proposes an acceptable alternative method for complying with specified portions of the NRC's regulations, the methods described in this guide that reflects public comments will be used in the evaluation of applications to renew nuclear power plant operating licenses.

1.188-9 REGULATORY ANALYSIS

A separate regulatory analysis was not prepared for this regulatory guide. The regulatory analysis prepared for the final license renewal rule provides the regulatory basis for this guide and examines the costs and benefits of implementing the rule. A copy of the regulatory analysis,

"Nuclear Power Plant License Renewal10 CFR Part 54" (February 1995), is available for inspection and copying for a fee at the NRC's Public Document Room, located at 11555 Rockville Pike, Rockville, MD.

BACKFIT ANALYSIS

This regulatory guide proposes NRC staff guidance on complying with the final license renewal rule, 10 CFR Part 54, which was effective June 7, 1995. Accordingly, publication of this regulatory guide is not a backfit under 10 CFR 50.109, and no backfit analysis is necessary or has been prepared for this regulatory guide.


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