NRC to Update Regulatory Guide for Initial and Subsequent License Renewal Applications

Morgan Lewis
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Morgan Lewis

NRC Staff has made publicly available copies of Draft Regulatory Guide 1341, Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses, and a supporting Regulatory Analysis. Draft Regulatory Guide 1341 is intended to revise Regulatory Guide 1.188 (as Revision 2 thereto) to update references to other NRC license renewal guidance documents, and to expressly extend the guidance to applications for subsequent license renewal (SLR), i.e., the renewal of a reactor operating license for a second 20-year period, from 60 years to 80 years. The revised guidance document would provide applicants with a method to demonstrate compliance with the 10 CFR Part 54 requirements for both initial license renewal and SLR applications. Three SLR applications currently are under review by the NRC Staff, and others are expected to be submitted in the future.

Revision 1 of Regulatory Guide 1.188, which the NRC issued in September 2005, endorsed industry guidelines for license renewal in Revision 5 of Nuclear Energy Institute (NEI) 95-10, Industry Guideline for Implementing the Requirements of 10 CFR Part 54—The License Renewal Rule. The industry has since developed revised guidance on license renewals to address standard review plans, aging management programs, and the development of SLR documentation. The proposed revision to Regulatory Guide 1.188 would include the NRC Staff’s endorsement of NEI 95-10, Revision 6 (the latest version of NEI 95-10).

Additionally, in December 2017, NEI issued NEI 17-01, Industry Guideline for Implementing the Requirements of 10 CFR Part 54 for Subsequent License Renewal. The proposed revision to Regulatory Guide 1.188 also would formally endorse NEI 17-01, which provides an NRC Staff-approved approach for implementing the requirements of 10 CFR Part 54 for SLR.

We expect the NRC to shortly publish a notice in the Federal Register soliciting public comments on Draft Regulatory Guide 1341 and the associated Regulatory Analysis. The NRC typically provides 60 days for public comments on a draft regulatory guide, but may extend that period at its discretion.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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