Regulatory Guide 1.188: Difference between revisions

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{{#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:U.S. NUCLEAR REGULATORY COMMISSION                                                                                                                          Revision 1 August 2005 REGULATORY GUIDE
                                                  OFFICE OF NUCLEAR REGULATORY RESEARCH
                                                                                                        Prepublication REGULATORY GUIDE 1.188 (Draft was issued as DG-1140, dated January 2005)
                                                    STANDARD FORMAT AND CONTENT
                                                            FOR APPLICATIONS TO RENEW
                            NUCLEAR POWER PLANT OPERATING LICENSES


====c. The NRC====
==A. INTRODUCTION==
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
The issuance of renewed operating licenses for nuclear power plants is governed by Title 10, Part 54, of the Code of Federal Regulations (10 CFR Part 54), Requirements for Renewal of Operating Licenses for Nuclear Power Plants (commonly known as the license renewal rule). As such, 10 CFR Part 54 specifies 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 Regulatory Commission (NRC). As discussed in this regulatory guide, the application should include (1) general information, (2) an integrated plant assessment (IPA), (3) an evaluation of time-limited aging analyses (TLAAs), (4) a supplement to the plants final safety analysis report (FSAR), (5) any necessary changes to the plants technical specifications (along with related justifications), and (6) a supplement to the plants environmental report. The FSAR supplement should provide a summary description of the programs and activities that the applicant will use to manage the effects of aging for the period of extended operation, which is determined by the IPA and the evaluation of TLAAs.
, 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
The following general provisions, with the corresponding regulations, apply to filing an application for a renewed operating license:
, 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
*              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)]
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
*              The applicant may not submit the application to the Commission earlier than 20 years before the expiration of the operating license currently in effect. [10 CFR 54.17(c)]
R REGULA TORY COMMISSION
The U.S. Nuclear Regulatory Commission (NRC ) issues regulatory guides to describe and make available to the public methods th a t th e N RC staff considers acceptable for use in im ple m en ting spe cific par ts of th e ag en cys re gu latio ns , tech niq ue s tha t the staff u se s in evaluating specific problems or postulated accidents, and data that the staff 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 required. Methods and solutions that differ from those set forth in regulatory guides will be deemed acceptable if they provide a basis for the findings required for the issuance or continuance of a permit or license by the Comm ission.
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
Th is guide was issued after consideration of comm ents received from the public. The NRC staff encourages an d w elc om e s co m m ents and sug ges tions in con nec tion w ith im prov em ents to p ub li sh e d r eg u la to ry g u id e s, a s w e ll a s i te m s fo r in c lu s io n in re g ul at or y g u id e s th a t a re cu rr en tl y b e in g de v el op e d. T h e N R C staff will revise existing 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 e c t i v e s B ra n c h, Office of Administration, U.S. Nuclear Regulatory Commission, W ashington, DC 20555-0001.
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  
Re gula tory guides are issued in 10 broad divisions: 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.
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 ===
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 ission, Washington, DC 20555, Attention: 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 Distribution@nrc.gov. Ele ctro nic c op ies o f this g uid e an d oth er re ce ntly issued guides are available through th e NRCs public W eb site under the Regulatory Guides document collection of the NRCs Electronic Reading Room a t http://ww w.nrc .gov /read ing-rm /d oc- collections/ a n d t hr o u g h th e N R C  s A g e n c y w id e D o c u m e n t s A c c e s s a n d M a n a ge m e n t S y st em ( A D A M S )
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.
at http://ww w.nrc .gov /read ing-rm /ada m s.htm l, under Accession No. ML050730286. Note, however, that the NRC has temporarily limited public access to ADAMS so that the agency ca n co mp l e te se cur ity r eviews of pub licly availa ble do cum ents and rem ove pote ntially sen sitive info rm ation. Please check the NRCs Web site for updates concerning t he re s um p ti on o f p u bl ic ac c es s t o A D A M S .
 
*        For the timely renewal provisions of 10 CFR 2.109(b) to apply, the applicant must file a sufficient application 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 kinds 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)]
        This regulatory guide applies to license renewal applications or portions thereof. The requirements for filing a license renewal application are specified in 10 CFR 54.17. Applicants may submit their license renewal applications to the NRC in either paper format or electronically, as described in Regulatory Issue Summary (RIS) 01-005, Guidance on Submitting Documents to the NRC by Electronic Information Exchange or on CD-ROM.1 The RIS provides general guidance on acceptable formats for electronic submittals and references detailed instructions, which are available through the NRCs public Web site at http://www.nrc.gov/site-help/eie.html.
 
This regulatory guide contains information collections that are covered by the requirements of 10 CFR Part 54, which the Office of Management and Budget (OMB) approved under OMB control number 3150-0155. The NRC may neither conduct nor sponsor, and a person is not required to respond to, an information collection request or requirement unless the requesting document displays a currently valid OMB control number.
 
1 Regulatory issue summaries are available through the NRCs public Web site at http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/.
                                              RG 1.188, Rev. 1, Page 2
 
==B. DISCUSSION==
This revised guide provides guidance on the information that applicants must submit in their applications for renewal of nuclear power plant operating licenses, as well as the uniform format that the NRC staff considers acceptable for structuring and presenting the required information.
 
Conformance with this guide is not required, but its use facilitates both an applicants preparation of a license renewal application and the NRC staffs timely and consistent review. The NRC staff will consider different formats if they provide an adequate basis for approval of the application for license renewal.
 
The NRC initially issued Regulatory Guide 1.188 in July 2001, after soliciting and resolving public comments on three draft regulatory guides (DG-1104 in August 2000, DG-1047 in August 1996, and DG-1009 in December 1990). As such, Regulatory Guide 1.188 incorporated lessons learned from the review of license renewal applications and Owners Group topical reports. The guide also incorporated relevant information from the development of the Standard Review Plan for the 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 a summary of public comments received on those documents (NUREG-1832, Analysis of Public Comments on the Revised License Renewal Guidance Documents.2 )
        Since the NRC initially published Regulatory 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 gained from numerous license renewal application reviews and other insights identified by industry. Consequently, the staff also decided to revise 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 NEI 95-10, Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 The License Renewal Rule, which the Nuclear Energy Institute (NEI) published in January 2005.3 Specifically, the staff took exception to the use of a portion of Appendix F to Revision 5 of NEI 95-10,
from the unnumbered paragraph following paragraph 4.4 through the end of Section 4, Non-Safety SSCs Directly Connected to Safety-Related SSCs. In addition, the NRC staff took exception to the use of paragraph 5.2.3.1, Exposure Duration.


2 Copies are available at current rates from the U.S. Government Printing Office, P.O. Box 37082, Washington, DC
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
        20402-9328 (telephone (202) 512-1800); or from the National Technical Information Service at 5285 Port Royal Road, Springfield, VA 22161; http://www.ntis.gov; or (703) 487-4650. Copies are available for inspection or copying for a fee from the NRCs 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; or email PDR@nrc.gov. These documents are also available electronically through the NRCs public Web site at http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/.
nforma tion Servic e at 5285 Port Roy al Road, Springfie ld, VA 22161;  
3 Copies are available for inspection or copying for a fee from the NRCs 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 PDR@nrc.gov. Revision 5 of NEI 95-10 is also available through the NRCs license renewal Web page at http://www.nrc.gov/reactors/operating/licensing/renewal/guidance.html#nuclear, and through the NRCs Agencywide Documents Access and Management System (ADAMS)
http://ww w.ntis.g ov; or (703) 487-4650. C
        at http://www.nrc.gov/reading-rm/adams.html, under Accession No. ML050280113. Note, however, that the NRC
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
        has temporarily limited public access to ADAMS so that the agency can complete security reviews of publicly available documents and remove potentially sensitive information. Please check the NRCs Web site for updates concerning the resumption of public access to ADAMS.
ashington, D
 
C 20555; telephone (301) 415-4737 or (800) 397-4209; f ax (301) 415-3548;  
RG 1.188, Rev. 1, Page 3
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
Subsequently, in response to the exceptions stated in DG-1140, NEI issued Revision 6 of NEI 95-10
, 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
in June 20054 to accept the NRC staffs position with respect to each of those issues, thereby rendering the staffs two exceptions unnecessary. Having reviewed this latest revision of NEI 95-10, the NRC staff finds Revision 6 acceptable for use in implementing the license renewal rule, without exceptions, as discussed in this revised regulatory guide. Applicants may meet the intent of the license renewal rule using methods other than those provided in Revision 6 of NEI 95-10; however, the NRC staff will determine the acceptability of such methods on a case-by-case basis. For additional information concerning the preparation of acceptable license renewal applications, applicants should refer to the SRP-LR (NUREG-1800).5
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.
4 Copies are available for inspection or copying for a fee from the NRCs 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 PDR@nrc.gov. Revision 6 of NEI 95-10 is also available through the NRCs Agencywide Documents Access and Management System (ADAMS)
        at http://www.nrc.gov/reading-rm/adams.html, under Accession No. ML051860406. Note, however, that the NRC
        has temporarily limited public access to ADAMS so that the agency can complete security reviews of publicly available documents and remove potentially sensitive information. Please check the NRCs Web site for updates concerning the resumption of public access to ADAMS.
 
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 from the National Technical Information Service at 5285 Port Royal Road, Springfield, VA 22161; http://www.ntis.gov; or (703) 487-4650. Copies are available for inspection or copying for a fee from the NRCs 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; or email PDR@nrc.gov. These documents are also available electronically through the NRCs public Web site at http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/.
                                                  RG 1.188, Rev. 1, Page 4


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
==C. REGULATORY POSITION==
This section discusses the NRC staffs regulatory position on the standard format and content of applications for renewal of operating licenses for commercial nuclear power plants. As such, the guidance provided in this section is expected to ensure that applicants have identified and taken (or will take) actions to ensure plant safety throughout the period of extended operation. Specifically, such actions relate to (1) managing the effects of aging on the functionality of plant structures, systems, and components that the NRC staff has identified as requiring aging management, and (2) evaluating TLAAs that the NRC staff has identified as requiring such review. Following this guidance provides reasonable assurance that the applicant will continue to conduct the activities authorized by the renewed licenses, in accordance with the plants current licensing basis (CLB).
1.      Contents of an Application To renew a nuclear power plant operating license, an applicant must meet the requirements delineated in 10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants.


==B. DISCUSSION==
This license renewal 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.
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
The information that an applicant develops and submits or retains for license renewal should permit the NRC staff to determine that the applicant has met the requirements of 10 CFR Part 54. The standard format in which the applicant presents this information should allow optimum use of the applicants resources, while facilitating the NRC staffs review of the license renewal application. As required by 10 CFR Part 54, an application shall consist of general information concerning both the applicant and the plant, technical information referenced or contained in the IPA and the evaluation of TLAAs, a supplement to the FSAR, any technical specification change(s) and their associated justification(s), and a supplement to the plants environmental report.
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
The technical information that an applicant submits should focus on identifying structures, systems, and components within the scope of 10 CFR Part 54, and on reviews of aging management, TLAAs, and the activities necessary to ensure that the applicant will maintain the plants 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 methodologies used to determine the structures, systems, and components that are subject to aging management review, and (2) the actions taken (or to be taken)
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-
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 lists of structures, systems, and 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 whether TLAAs will remain valid for the period of extended operation or have been acceptably resolved or dispositioned for the purposes of license renewal.
LR (NUREG-
 
1800) and GALL
The FSAR supplement should contain a summary description of the TLAA evaluation and the programs and activities that the applicant will use to managing the effects of aging. The regulatory controls associated with placing a summary description of these evaluations and activities into the FSAR,
Report (NUREG
along with the existing regulatory process, should ensure that future program changes that could decrease the overall effectiveness of the TLAA evaluation and aging management activities will receive appropriate review by the applicant.
-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.
 
RG 1.188, Rev. 1, Page 5
 
RG 1.188, Rev. 1, Page 6 The license renewal application must also incorporate the general information required by
10 CFR 54.17 and 54.19. This information should include any conforming changes to the indemnity agreement to account for the expiration term of the proposed renewed license [10 CFR 54.19(b)]
and any restricted data agreements [10 CFR 54.17(f) and (g)]. In addition, the IPA, the TLAA evaluation, and/or the FSAR supplement should contain or reference the technical 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 manage the effects of aging during the period of extended operation.
 
The applicant should identify technical specification changes or additions when additional regulatory control is warranted to ensure that the applicant will manage the effects of aging, such that the necessary quality of systems, structures, and components will continue to be maintained, facility operation will continue to be within safety limits, and limiting conditions for operation will continue to be met. As such, the application should include justifications for the proposed changes or additions, 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 the staff determines that additional regulatory control is warranted to ensure that the applicant will adequately manage the effects of aging.


Toward that end, the staff prepared DG-1140, in which the NRC endorsed (with two exceptions)
In addition, the applicant should provide environmental information in a supplement to the plants environmental report, and such information must comply with the requirements of Subpart A
Revision 5 of N
of 10 CFR Part 51, as required by 10 CFR 54.23. For additional guidance concerning the format and content of the environmental report, applicants should refer to Supplement 1 to Regulatory Guide 4.2, Preparation of Supplemental Environmental Reports for Applications To Renew Nuclear Power Plant Operating Licenses, dated September 2000.6
EI 95-10, "Indus try Guidelines for I
2.      Endorsement of NEI Guidelines Revision 6 of NEI 95-10, Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 The License Renewal Rule, dated June 2005,7 provides methods that the NRC staff considers acceptable for complying with the requirements of 10 CFR Part 54 for preparing a license renewal application.
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
6 Single copies of regulatory guides, both active and draft, and draft NUREG documents may be obtained free of charge by writing the Reproduction and Distribution Services, USNRC, Washington, DC 20555-0001, or by fax to
uration."
        (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,
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
        5285 Port Royal Road, Springfield, VA 22161; telephone (703) 487-4650; online at http://www.ntis.gov. Copies of active and draft guides are also available for inspection or copying for a fee from the NRCs Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDRs mailing address is USNRC PDR, Washington, DC 20555;
ashington, D
        telephone (301) 415-4737 or (800) 397-4209; fax (301) 415-3548; email PDR@nrc.gov.
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
7 Copies are available for inspection or copying for a fee from the NRCs 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 PDR@nrc.gov. This document is also available through the NRCs Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html, under Accession No. ML051860406. Note, however, that the NRC has temporarily limited public access to ADAMS
20402-9328 (telephone (202) 512-1800); or f rom the N ational T echnical I
        so that the agency can complete security reviews of publicly available documents and remove potentially sensitive information. Please check the NRCs Web site for updates concerning the resumption of public access to ADAMS.
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
RG 1.188, Rev. 1, Page 7
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.
3.       Formatting Specifications The filing requirements for a license renewal application are specified in 10 CFR 54.17.


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.
Applicants may submit applications to the NRC in electronic or paper format, as described in RIS 2001-05, Guidance on Submitting Documents to the NRC by Electronic Information Exchange or on CD-ROM.8 This guidance applies to license renewal applications or portions thereof.


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
3.1      Graphical Presentations Applicants should employ graphical presentations (such as drawings, maps, diagrams, sketches, and tables) if such means may convey the information more adequately or conveniently. In so doing, applicants should ensure that all information so presented is legible, symbols are defined, no essential information is lost when colored drawings are printed in black on white paper, and scales are not reduced to the extent that visual aids are necessary to interpret pertinent information. Such graphical presentations should appear in the section where they are primarily discussed. References used may be cited either as footnotes on the page where they are discussed, or as endnotes at the end of the chapter in which they are discussed.
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
3.2      Physical Specifications
(2) the actions taken (or to be taken)
3.2.1   Paper Size
to manage the effects of aging during the period of extended operation.
*        Text pages: 81/2 x 11 inches.


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: 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.
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
3.2.2    Paper Stock and Ink Use 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.
3.2.3    Page Margins Maintain a margin of no less than 1 inch 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
3.2.4    Printing
FR Part 5
*        Composition: Text pages should be single-spaced.


===0. The N===
*        Type Face and Style: Use type faces and styles that are suitable for reproduction by microfilming or image-copying equipment.
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
*        Reproduction: Copies may be mechanically or photographically reproduced.
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/
All text pages should be printed on both sides, with the image printed head-to-head.
.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
8 Regulatory issue summaries are available through the NRCs public Web site at http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/.
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.
                                              RG 1.188, Rev. 1, Page 8


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.
3.2.5    Binding Pages should be punched for standard 3-hole looseleaf binders.


3.2 Physical Specifications
3.2.6    Page Numbering Pages should be numbered with digits corresponding to the chapter and section, followed by a hypen and a sequential page 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.
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.
3.2.7    Table of Contents Provide a table of contents and index of key terms for the renewal application.


All text pages sho uld be printed on both sides, with the im age printed head- to-head.
3.3      Procedure for Updating or Revising Pages Text and graphical presentations should be revised by providing replacement pages. The new or modified portion of each page should be highlighted by a change indicator, consisting of a bold vertical line drawn in the margin opposite the binding margin. The line should be of the same length as the new or modified portion of the page.


RG 1.188, Re v. 1, Pag e 9 3.2.5 Binding Pages should be punched for standard 3- hole looseleaf binders.
All pages submitted to update, revise, or add pages to the report should show the date of the change, as well as the change or amendment number. A guide page listing the pages to be inserted and pages to be removed should accompany each submission of revised pages. In addition, when making major changes or additions, the applicant should provide a revised table of contents.


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-
RG 1.188, Rev. 1, Page 9
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.
==D. IMPLEMENTATION==
The purpose of this section is to provide information to applicants regarding the NRC staffs plans for using this regulatory guide. Except in those cases in which an applicant proposes or has previously established an acceptable alternative method for complying with specified portions of the NRCs regulations, the methods described in this guide reflect public comments and will be used in evaluating applications to renew nuclear power plant operating licenses.


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.
REGULATORY ANALYSIS
        The NRC staff did not prepare a separate regulatory analysis for 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.
The regulatory analysis prepared for the final license renewal rule also provides the regulatory basis for this guide and examines the costs and benefits of implementing the rule. A copy of that regulatory analysis, Nuclear Power Plant License Renewal 10 CFR Part 54, dated February 1995, is available for inspection and copying for a fee at the NRCs Public Document Room, located at 11555 Rockville Pike, Rockville, Maryland.


RG 1.188, Re v. 1, Pag e 10 D.  IMPLEMEN
BACKFIT 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.
        This regulatory guide proposes NRC staff guidance on complying with the final license renewal rule,
10 CFR Part 54, which became effective on June 7, 1995. Accordingly, publication of this regulatory guide does not constitute a backfit under 10 CFR 50.109, and no backfit analysis is necessary or has been prepared for this regulatory guide.


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.}}
RG 1.188, Rev. 1, Page 10}}


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Revision as of 00:09, 24 November 2019

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:
jxd
References
DG-1140 RG-1.188, Rev 1
Download: ML052200165 (10)
v • d • e


U.S. NUCLEAR REGULATORY COMMISSION Revision 1 August 2005 REGULATORY GUIDE

OFFICE OF NUCLEAR REGULATORY RESEARCH

Prepublication REGULATORY GUIDE 1.188 (Draft was issued as DG-1140, dated January 2005)

STANDARD FORMAT AND CONTENT

FOR APPLICATIONS TO RENEW

NUCLEAR POWER PLANT OPERATING LICENSES

A. INTRODUCTION

The issuance of renewed operating licenses for nuclear power plants is governed by Title 10, Part 54, of the Code of Federal Regulations (10 CFR Part 54), Requirements for Renewal of Operating Licenses for Nuclear Power Plants (commonly known as the license renewal rule). As such, 10 CFR Part 54 specifies 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 Regulatory Commission (NRC). As discussed in this regulatory guide, the application should include (1) general information, (2) an integrated plant assessment (IPA), (3) an evaluation of time-limited aging analyses (TLAAs), (4) a supplement to the plants final safety analysis report (FSAR), (5) any necessary changes to the plants technical specifications (along with related justifications), and (6) a supplement to the plants environmental report. The FSAR supplement should provide a summary description of the programs and activities that the applicant will use to manage the effects of aging for the period of extended operation, which is determined by the IPA and the evaluation of TLAAs.

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

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

The U.S. Nuclear Regulatory Commission (NRC ) issues regulatory guides to describe and make available to the public methods th a t th e N RC staff considers acceptable for use in im ple m en ting spe cific par ts of th e ag en cys re gu latio ns , tech niq ue s tha t the staff u se s in evaluating specific problems or postulated accidents, and data that the staff 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 required. Methods and solutions that differ from those set forth in regulatory guides will be deemed acceptable if they provide a basis for the findings required for the issuance or continuance of a permit or license by the Comm ission.

Th is guide was issued after consideration of comm ents received from the public. The NRC staff encourages an d w elc om e s co m m ents and sug ges tions in con nec tion w ith im prov em ents to p ub li sh e d r eg u la to ry g u id e s, a s w e ll a s i te m s fo r in c lu s io n in re g ul at or y g u id e s th a t a re cu rr en tl y b e in g de v el op e d. T h e N R C staff will revise existing 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 e c t i v e s B ra n c h, Office of Administration, U.S. Nuclear Regulatory Commission, W ashington, DC 20555-0001.

Re gula tory guides are issued in 10 broad divisions: 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 ission, Washington, DC 20555, Attention: 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 Distribution@nrc.gov. Ele ctro nic c op ies o f this g uid e an d oth er re ce ntly issued guides are available through th e NRCs public W eb site under the Regulatory Guides document collection of the NRCs Electronic Reading Room a t http://ww w.nrc .gov /read ing-rm /d oc- collections/ a n d t hr o u g h th e N R C s A g e n c y w id e D o c u m e n t s A c c e s s a n d M a n a ge m e n t S y st em ( A D A M S )

at http://ww w.nrc .gov /read ing-rm /ada m s.htm l, under Accession No. ML050730286. Note, however, that the NRC has temporarily limited public access to ADAMS so that the agency ca n co mp l e te se cur ity r eviews of pub licly availa ble do cum ents and rem ove pote ntially sen sitive info rm ation. Please check the NRCs Web site for updates concerning t he re s um p ti on o f p u bl ic ac c es s t o A D A M S .

  • For the timely renewal provisions of 10 CFR 2.109(b) to apply, the applicant must file a sufficient application 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 kinds 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)]

This regulatory guide applies to license renewal applications or portions thereof. The requirements for filing a license renewal application are specified in 10 CFR 54.17. Applicants may submit their license renewal applications to the NRC in either paper format or electronically, as described in Regulatory Issue Summary (RIS)01-005, Guidance on Submitting Documents to the NRC by Electronic Information Exchange or on CD-ROM.1 The RIS provides general guidance on acceptable formats for electronic submittals and references detailed instructions, which are available through the NRCs public Web site at http://www.nrc.gov/site-help/eie.html.

This regulatory guide contains information collections that are covered by the requirements of 10 CFR Part 54, which the Office of Management and Budget (OMB) approved under OMB control number 3150-0155. The NRC may neither conduct nor sponsor, and a person is not required to respond to, an information collection request or requirement unless the requesting document displays a currently valid OMB control number.

1 Regulatory issue summaries are available through the NRCs public Web site at http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/.

RG 1.188, Rev. 1, Page 2

B. DISCUSSION

This revised guide provides guidance on the information that applicants must submit in their applications for renewal of nuclear power plant operating licenses, as well as the uniform format that the NRC staff considers acceptable for structuring and presenting the required information.

Conformance with this guide is not required, but its use facilitates both an applicants preparation of a license renewal application and the NRC staffs timely and consistent review. The NRC staff will consider different formats if they provide an adequate basis for approval of the application for license renewal.

The NRC initially issued Regulatory Guide 1.188 in July 2001, after soliciting and resolving public comments on three draft regulatory guides (DG-1104 in August 2000, DG-1047 in August 1996, and DG-1009 in December 1990). As such, Regulatory Guide 1.188 incorporated lessons learned from the review of license renewal applications and Owners Group topical reports. The guide also incorporated relevant information from the development of the Standard Review Plan for the 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 a summary of public comments received on those documents (NUREG-1832, Analysis of Public Comments on the Revised License Renewal Guidance Documents.2 )

Since the NRC initially published Regulatory 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 gained from numerous license renewal application reviews and other insights identified by industry. Consequently, the staff also decided to revise 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 NEI 95-10, Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 The License Renewal Rule, which the Nuclear Energy Institute (NEI) published in January 2005.3 Specifically, the staff took exception to the use of a portion of Appendix F to Revision 5 of NEI 95-10,

from the unnumbered paragraph following paragraph 4.4 through the end of Section 4, Non-Safety SSCs Directly Connected to Safety-Related SSCs. In addition, the NRC staff took exception to the use of paragraph 5.2.3.1, Exposure Duration.

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 at 5285 Port Royal Road, Springfield, VA 22161; http://www.ntis.gov; or (703) 487-4650. Copies are available for inspection or copying for a fee from the NRCs 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; or email PDR@nrc.gov. These documents are also available electronically through the NRCs public Web site at http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/.

3 Copies are available for inspection or copying for a fee from the NRCs 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 PDR@nrc.gov. Revision 5 of NEI 95-10 is also available through the NRCs license renewal Web page at http://www.nrc.gov/reactors/operating/licensing/renewal/guidance.html#nuclear, and through the NRCs Agencywide Documents Access and Management System (ADAMS)

at http://www.nrc.gov/reading-rm/adams.html, under Accession No. ML050280113. Note, however, that the NRC

has temporarily limited public access to ADAMS so that the agency can complete security reviews of publicly available documents and remove potentially sensitive information. Please check the NRCs Web site for updates concerning the resumption of public access to ADAMS.

RG 1.188, Rev. 1, Page 3

Subsequently, in response to the exceptions stated in DG-1140, NEI issued Revision 6 of NEI 95-10

in June 20054 to accept the NRC staffs position with respect to each of those issues, thereby rendering the staffs two exceptions unnecessary. Having reviewed this latest revision of NEI 95-10, the NRC staff finds Revision 6 acceptable for use in implementing the license renewal rule, without exceptions, as discussed in this revised regulatory guide. Applicants may meet the intent of the license renewal rule using methods other than those provided in Revision 6 of NEI 95-10; however, the NRC staff will determine the acceptability of such methods on a case-by-case basis. For additional information concerning the preparation of acceptable license renewal applications, applicants should refer to the SRP-LR (NUREG-1800).5

4 Copies are available for inspection or copying for a fee from the NRCs 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 PDR@nrc.gov. Revision 6 of NEI 95-10 is also available through the NRCs Agencywide Documents Access and Management System (ADAMS)

at http://www.nrc.gov/reading-rm/adams.html, under Accession No. ML051860406. Note, however, that the NRC

has temporarily limited public access to ADAMS so that the agency can complete security reviews of publicly available documents and remove potentially sensitive information. Please check the NRCs Web site for updates concerning the resumption of public access to ADAMS.

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 from the National Technical Information Service at 5285 Port Royal Road, Springfield, VA 22161; http://www.ntis.gov; or (703) 487-4650. Copies are available for inspection or copying for a fee from the NRCs 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; or email PDR@nrc.gov. These documents are also available electronically through the NRCs public Web site at http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/.

RG 1.188, Rev. 1, Page 4

C. REGULATORY POSITION

This section discusses the NRC staffs regulatory position on the standard format and content of applications for renewal of operating licenses for commercial nuclear power plants. As such, the guidance provided in this section is expected to ensure that applicants have identified and taken (or will take) actions to ensure plant safety throughout the period of extended operation. Specifically, such actions relate to (1) managing the effects of aging on the functionality of plant structures, systems, and components that the NRC staff has identified as requiring aging management, and (2) evaluating TLAAs that the NRC staff has identified as requiring such review. Following this guidance provides reasonable assurance that the applicant will continue to conduct the activities authorized by the renewed licenses, in accordance with the plants current licensing basis (CLB).

1. Contents of an Application To renew a nuclear power plant operating license, an applicant must meet the requirements delineated in 10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants.

This license renewal 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.

The information that an applicant develops and submits or retains for license renewal should permit the NRC staff to determine that the applicant has met the requirements of 10 CFR Part 54. The standard format in which the applicant presents this information should allow optimum use of the applicants resources, while facilitating the NRC staffs review of the license renewal application. As required by 10 CFR Part 54, an application shall consist of general information concerning both the applicant and the plant, technical information referenced or contained in the IPA and the evaluation of TLAAs, a supplement to the FSAR, any technical specification change(s) and their associated justification(s), and a supplement to the plants environmental report.

The technical information that an applicant submits should focus on identifying structures, systems, and components within the scope of 10 CFR Part 54, and on reviews of aging management, TLAAs, and the activities necessary to ensure that the applicant will maintain the plants 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 methodologies used to determine the structures, systems, and components that are subject to 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 lists of structures, systems, and 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 whether 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 the TLAA evaluation and the programs and activities that the applicant will use to managing the effects of aging. The regulatory controls associated with placing a summary description of these evaluations and activities into the FSAR,

along with the existing regulatory process, should ensure that future program changes that could decrease the overall effectiveness of the TLAA evaluation and aging management activities will receive appropriate review by the applicant.

RG 1.188, Rev. 1, Page 5

RG 1.188, Rev. 1, Page 6 The license renewal application must also incorporate the general information required by

10 CFR 54.17 and 54.19. This information should include any conforming changes to the indemnity agreement to account for the expiration term of the proposed renewed license [10 CFR 54.19(b)]

and any restricted data agreements [10 CFR 54.17(f) and (g)]. In addition, the IPA, the TLAA evaluation, and/or the FSAR supplement should contain or reference the technical 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 manage the effects of aging during the period of extended operation.

The applicant should identify technical specification changes or additions when additional regulatory control is warranted to ensure that the applicant will manage the effects of aging, such that the necessary quality of systems, structures, and components will continue to be maintained, facility operation will continue to be within safety limits, and limiting conditions for operation will continue to be met. As such, the application should include justifications for the proposed changes or additions, 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 the staff determines that additional regulatory control is warranted to ensure that the applicant will adequately manage the effects of aging.

In addition, the applicant should provide environmental information in a supplement to the plants environmental report, and such information must comply with the requirements of Subpart A

of 10 CFR Part 51, as required by 10 CFR 54.23. For additional guidance concerning the format and content of the environmental report, applicants should refer to Supplement 1 to Regulatory Guide 4.2, Preparation of Supplemental Environmental Reports for Applications To Renew Nuclear Power Plant Operating Licenses, dated September 2000.6

2. Endorsement of NEI Guidelines Revision 6 of NEI 95-10, Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 The License Renewal Rule, dated June 2005,7 provides methods that the NRC staff considers acceptable for complying with the requirements of 10 CFR Part 54 for preparing a license renewal application.

6 Single copies of regulatory guides, both active and draft, and draft NUREG documents may be obtained free of charge by writing the Reproduction and Distribution Services, USNRC, Washington, DC 20555-0001, or 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 at http://www.ntis.gov. Copies of active and draft guides are also available for inspection or copying for a fee from the NRCs 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 PDR@nrc.gov.

7 Copies are available for inspection or copying for a fee from the NRCs 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 PDR@nrc.gov. This document is also available through the NRCs Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html, under Accession No. ML051860406. Note, however, that the NRC has temporarily limited public access to ADAMS

so that the agency can complete security reviews of publicly available documents and remove potentially sensitive information. Please check the NRCs Web site for updates concerning the resumption of public access to ADAMS.

RG 1.188, Rev. 1, Page 7

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

Applicants may submit applications to the NRC in electronic or paper format, as described in RIS 2001-05, Guidance on Submitting Documents to the NRC by Electronic Information Exchange or on CD-ROM.8 This guidance applies to license renewal applications or portions thereof.

3.1 Graphical Presentations Applicants should employ graphical presentations (such as drawings, maps, diagrams, sketches, and tables) if such means may convey the information more adequately or conveniently. In so doing, applicants should ensure that all information so presented is legible, symbols are defined, no essential information is lost when colored drawings are printed in black on white paper, and scales are not reduced to the extent that visual aids are necessary to interpret pertinent information. Such graphical presentations should appear in the section where they are primarily discussed. References used may be cited either as footnotes on the page where they are discussed, or as endnotes 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.
  • Drawings 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 Ink Use suitable quality in substance, paper color, and ink density for handling and reproduction by microfilming or image-copying equipment.

3.2.3 Page Margins Maintain a margin of no less than 1 inch on the top, bottom, and binding side of all pages submitted.

3.2.4 Printing

  • Composition: Text pages should be single-spaced.
  • Type Face and Style: Use type faces and styles that are suitable for reproduction by microfilming or image-copying equipment.
  • Reproduction: Copies may be mechanically or photographically reproduced.

All text pages should be printed on both sides, with the image printed head-to-head.

8 Regulatory issue summaries are available through the NRCs public Web site at http://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/.

RG 1.188, Rev. 1, Page 8

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 section, followed by a hypen and a sequential page 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.

3.2.7 Table of Contents Provide a table of contents and index of key terms for the renewal application.

3.3 Procedure for Updating or Revising Pages Text and graphical presentations should be revised by providing replacement pages. The new or modified portion of each page should be highlighted by a change indicator, consisting of a bold vertical line drawn in the margin opposite the binding margin. The line should be of the same length as the new or modified portion of the page.

All pages submitted to update, revise, or add pages to the report should show the date of the change, as well as the change or amendment number. A guide page listing the pages to be inserted and pages to be removed should accompany each submission of revised pages. In addition, when making major changes or additions, the applicant should provide a revised table of contents.

RG 1.188, Rev. 1, Page 9

D. IMPLEMENTATION

The purpose of this section is to provide information to applicants regarding the NRC staffs plans for using this regulatory guide. Except in those cases in which an applicant proposes or has previously established an acceptable alternative method for complying with specified portions of the NRCs regulations, the methods described in this guide reflect public comments and will be used in evaluating applications to renew nuclear power plant operating licenses.

REGULATORY ANALYSIS

The NRC staff did not prepare a separate regulatory analysis for this regulatory guide.

The regulatory analysis prepared for the final license renewal rule also provides the regulatory basis for this guide and examines the costs and benefits of implementing the rule. A copy of that regulatory analysis, Nuclear Power Plant License Renewal 10 CFR Part 54, dated February 1995, is available for inspection and copying for a fee at the NRCs Public Document Room, located at 11555 Rockville Pike, Rockville, Maryland.

BACKFIT ANALYSIS

This regulatory guide proposes NRC staff guidance on complying with the final license renewal rule,

10 CFR Part 54, which became effective on June 7, 1995. Accordingly, publication of this regulatory guide does not constitute a backfit under 10 CFR 50.109, and no backfit analysis is necessary or has been prepared for this regulatory guide.

RG 1.188, Rev. 1, Page 10


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