International Nuclear Forum, Bulgarian Nuclear Energy – National, Regional, and World Energy Safety Varna, Bulgaria, May

1. Current U.S. Part 52, Title 10 Code of Federal Regulations (10CFR52) Process for Early Site Permits, Standard Design Certification and Combined Construction and Operating License International Nuclear Forum, Bulgarian Nuclear Energy – National, Regional, and World Energy Safety Varna, Bulgaria, May 27 – 29, 2009

2. Introduction and Overview • 10CFRPart 50, Two Phases: Construction Permit, Operating License. • 10CFR50 Process For New NPP: Large Expenditures Of Money/Time Well Before Key Environmental, Site Safety And Emergency Plan Issues Could Be Resolved (e.g., Shoreham NPP) • Numerous Opportunities For Intervention, Public Hearings, And Consequential Delays • USNRC Promulgated 10 CFR Part 52 In 1989 To Address Industry Concerns • 10CFRPart 52 Established “One Step” Licensing Process • “One Step” Licensing Process Affirmed By Congress - 1992 Energy Policy Act. • Single Combined Construction and Operating License (COL) • Designed To Improve Licensing Process Efficiency, Predictability • Energy Policy Act of 2005 Provided “Kick-start” for Nuclear

3. Introduction and Overview • COL Granted Prior To Beginning Of Construction. • Reduces Financial Risk – “Exit Ramps”, Incremental Decision Making • Key Element Is Inspections, Tests, Analyses And Acceptance Criteria (ITAAC) • May First Obtain An Early Site Permit (ESP) From the NRC. • NRC Estimates 42 Months COLA Approval Process • Part 52 Licensing Approach Allows Early Resolution Of Reactor Safety, And Environmental Issues. • “FINALITY” - Regulatory Reviews Regarding Suitability Of Site or Design Of The Plant (Design Certification), Once Completed, Are Not Revisited Prior To Issuance Of The COL. • COL Contains Same Information As 10CFR Part 50 Operating License Application. • COL May be issued for multiple units

4. Overview of Previous 10CFR50 “Two Step” Licensing Process Sequential process – overlapping regulatory reviews; Design effort proceeded throughout process; Regulatory standards evolved ad construction proceeded. Process was inefficient, unpredictable and invited intervention/abuse. Construction Permit Application* 10-30% of Design Complete Operating License Proceeding* Completed plant idle during proceeding Operating License Issued* Construction (design as you build) Operation * Opportunity for intervention, hearings and delay

5. Completion Times for the Current Fleet Avg = 5.6 yrs Avg = 11.1 yrs

6. Overview of the “One Step”10CFR52 Licensing Process In this process, all regulatory reviews (site, reactor design, construction/operating license) are completed before major capital investment at risk. Potential for delay is significantly reduced Early Site Permit (ESP)* Combined Construction And Operating License (COL)* Design >90% Complete Construction ITAAC Met** Operation Design Certification* * Opportunity for public comment, intervention ** Opportunity for hearing; But, threshold very high

7. 10 CFR Part 52 • Part 52 — Licenses, Certifications, and Approvals for Nuclear Power Plants • Subpart A — Early Site Permits (ESP) • Subpart B — Standard Design Certifications (DC) • Subpart C — Combined Licenses (COL) • Other Subparts Cover Standard Design Approvals, Manufacturing Licenses, Enforcement

8. 10 CFR Part 52, Subpart AEarly Site Permit (ESP) • ESP Addresses Site Safety Issues, Environmental Protection Issues and Emergency Plans • ESP Separate from Construction/Operating License Application • ESP can be “Banked” — 20 Years, 10 to 20 Years Renewal • ESP Independent of Nuclear Power Plant Design • Plant Parameter Envelope (PPE) Used for ESPs • Surrogate Plant Approach • Circa 200 Plant And Site Parameters • Information To Support Safety & Environmental Reviews • Select Best Reactor Technologies Available • Encompasses Any Design Bounded By PPE • Specific Reactor Technology Need Not Be Selected At Site Approval Phase • ESP Application Includes: Administrative, Site Safety Analysis Report (RG 1.70, Ch. 2&3), Environmental Report (NUREG 1555), Emergency Plan, Redress Plan • Three (3) Early Site Permits Approved: Clinton, North Anna, Grand Gulf

9. Typical PPE Categories • Structures • Normal Plant Heat Sink • Ultimate Heat Sink • Containment Heat Removal System • Potable Water/Sanitary Waste Systems • Demineralized Water System • Fire Protection System • Miscellaneous Drains/Discharges • Unit Vent/Airborne Release Points • Radwaste Systems – Liquid, Gaseous,Solid • Spent Fuel Storage • HVAC Systems • Onsite/Offsite Electrical Power System • Standby Power System • Plant Characteristics • Construction

10. Example - Reactor Technologies Included in Exelon ESP PPE • Pebble bed modular reactor (PBMR) – 8 modules, 3200MWt • Advanced boiling-water reactor (ABWR) – 1 unit, 3926 MWt • Advanced pressurized-water reactor (AP1000) – 2 units, 6800 MWt • Economic Simplified Boiling Water reactor (ESBWR) – 1 unit,4000 MWt • Gas turbine-modular helium reactor (GT-MHR) – 4 modules,2400 MWt • Advanced Canada Deuterium Uranium (CANDU) Reactor(ACR-700) – 2 units, 3966 MWt • International Reactor Innovative andSecure (IRIS) – 3 units, 3000 MWt

11. 10 CFR Part 52, Subpart BStandard Design Certifications • NRC can certify a reactor design for 15 years through the Rulemaking Process, independent of a specific site • Application for a DC must include information describing the design and proposed ITAAC • Specific Reactor Design Control Document (DCD) followsRG 1.70 (FSAR) • Tier 1 – Approved and Certified by Rulemaking • Tier 2 – Approved • Tier 1 based on Tier 2 Details. Changes to Tier 1 may lead to regulatory review, public comment, intervention and are avoided • Multinational Design Approval Program (MDAP) leverages information reviewed by licensing authority of another country. • ITAAC provides objective evidence and reasonable assurance that if ITAAC are performed and acceptance criteria met, a plant which references the design, is built and will operate in accordance with the Design Certification. • Four Design Certified: Westinghouse AP600 and AP1000; GE ABWR; CE System 80+

12. Pre-Construction Early Site Permit OR Equivalent Site Information Construction Verification Combined License Review, Hearing, and Decision Verification of Regulations with ITAAC Reactor Operation Decision Optional Pre-Application Review Standard Design Certification OR Equivalent Design Information • Licensing decisions finalized before major construction begins • Inspections to verify construction • Limited work may be authorized before license is issued New Licensing Process – 10 CFR Part 52 -

13. 10 CFR Part 52, Subpart CCombined Licenses • COL applicant may reference ESP and/or a DCD, or neither one. • COLA may be submitted for multiple units • If ESP or DC is not referenced, applicant required to provide equivalent level of information in COLA • If applicant does not reference an ESP, applicant must provide detailed siting information that would have been provided during ESP process. • If DCD not referenced, COL applicant must provide complete design information and associated ITAAC for complete design(Very Risky) • Application for COL must contain essentially same information required in an application for an operating license submitted under 10 CFR Part 50. • Part 52 Final Rule Issued In September, 2007, clarifying/revising regulations applicable to licensing of nuclear plants (Parts 52, 50, 1, 2, 10, 19, 20, et al) • Issues resolved in a prior proceeding generally not subject to further review at COL – HIGH THRESHOLD • After COL granted, licensee must complete ITAAC established in the license

14. 10 CFR Part 52, Sub Part CCombined Licenses (COL) - Continued • NRC strong preference for Standard COLA and Certified Design (if not standard, you will always be at the end of the queue) • Other applications to model COLAs after first COLA submitted (Change Site Conditions Only) • COLA application includes: Administrative, FSAR, ER, EP, Tech Specs, DCD Exemptions/DCD Departures, Security Plan (withheld from public) • May be submitted in 2 Parts (ER, FSAR), Not Preferred by NRC • FSAR based on Certified Reactor Design Control Document (DCD) • Reference to DCD with site specific deviations/exceptions • Regulatory Guide 1.206 provides NRC guidance for COLAs

15. Projected Locations of New Nuclear Power Reactors

16. New Reactor Licensing Applications (Site and Technology Selected) Hearing Progress Energy - Harris (NC) (2) Duke – Lee Station (SC) (2) Hearing TVA – Bellefonte (AL) (2) Hearing Hearing South Carolina E&G-Summer (2) Florida P&L – Turkey Point (2) Progress Energy–Levy County (FL) (2) Hearing Hearing Hearing Vogtle ESP Hearing Southern – Vogtle (GA) (2) Legend: Post SER/EIS Hearing (other hearing activities occur during ESP/COL safety and environmental reviews) Number in ( ) next to COL name indicate number of units/site. Design Certification Grand Gulf ESP Hearing Early Site Permit Combined License Exelon – Victoria Co. (TX) (2) Entergy – Grand Gulf (MS) (1) Hearing Hearing Hearing North Anna ESP Hearing TXU Power –Comanche Peak (TX) (2) Hearing Dominion - North Anna (VA) (1) Hearing Entergy – River Bend (LA) (1) Hearing UniStar-Calvert Cliffs (MD) (1) Hearing AmerenUE – Callaway (1) UniStar-Nine Mile Pt (NY) (1) Hearing Hearing NRG Energy–South Texas Project (2) Hearing Alternate Energy Holdings (ID) (1) Amarillo Power (TX) (2) Hearing Hearing PPL Generation – Berwick (1) Hearing An estimated schedule by Fiscal Year 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 AP1000 Program Review * Schedules depicted for future activities represent nominal assumed review durations based on submittal time frames in letters of intent from prospective applicants. Actual schedules will be determined when applications are docketed. DC Amendment Design Cert ESBWR Program Review Design Certification EPR Program Review Design Certification ABWR Program Review USAPWR Program Review 1/02/08 DC – Mitsubishi USAPWR

17. Nuclear Plant Licensing:“Then and Now”

18. ESP/COLA Process Observations • ESP Type Process (Equivalent Siting Information) with PPE Allows: • Early Identification of Site Issues Prior to Major $$ Expenditures • Site Selection Prior to Selection of Reactor Technology • Later Final Construction Decision • Leveraging Design Certifications/Compliance to EUR - Standardization • Standardization - Lump Sum vs. T&M, Parts, Training, Services, Fuel • Previously Approved/Certified Standard FSAR with Deviations or Exceptions Helps Expedite Licensing Reviews • Use of Existing Site Offers Many Advantages • Site Characterization • >2 Years Meteorological Data for Chi/Q, set EAB • Geology, Geotechnical, Seismic • Hydrology, Geography, Demography, Offsite Hazards, etc.

19. ESP/COLA Process Observations • Perform Gap Analysis – FSAR info vs. Current • Existing Grid Connections/Stability Conditions • Site Infrastructure • Baseline Information: EIA, EP, FSAR • Existing Site Potential Issues • Available Space • UHS Considerations – Capacity, Dilution, Thermal • Makeup Water • Grid Capacity/Stability • Transportation of Major Components • Security