ML093080126
| ML093080126 | |
| Person / Time | |
|---|---|
| Issue date: | 02/28/2010 |
| From: | Office of Nuclear Regulatory Research |
| To: | |
| R. A. Jervey, RES/DE/RGDB, 301-251-7404 | |
| Shared Package | |
| ML093080086 | List: |
| References | |
| DG-1150 RG 1.40, Rev 1 | |
| Download: ML093080126 (3) | |
Text
1 Response to Public Comments on Draft Regulatory Guide 1150 Qualification of Continuous Duty Safety-Related Motors For Nuclear Power Plants A notice that Draft Regulatory Guide (DG) 1150 was available for public comment was published in the Federal Register on September 3, 2009 (74 FR 45654). The comment period ended October 30, 2009. Comments were received from the stakeholders listed below. The U.S. Nuclear Regulatory Commission (NRC) staff's disposition and comments have been combined in the following table.
Comments were received from the following:
Tom Figiel Exelon Corporate Engineering.
thomas.figiel@exeloncorp.com William A. Horin, Counsel to the Nuclear Utility Group on Equipment Qualification (NUGEQ)
Winston & Strawn, LLP 1700 K Street, N.W.
Washington DC 20006-3817 Telephone: 1-202-282-5737 Originator Section of DG-1150 Specific Comment NRC Resolution Tom Figiel Regulatory Analysis When I reviewed Draft Reg Guide DG-1150 for Qualification of Continuous Duty Safety-Related Motors for Nuclear Power Plants, I noticed one sentence in which I suspect may contain a typographical error, so I am bringing it to your attention to ask you to double check to see whether or not this is indeed the case. On page 6 of this document under the Conclusion Section, the end of the second sentence in this paragraph reads "...for qualifying safety-related motor control centers." Since this document was directed at safety-related MOTORS, I was wondering if it was intended that this sentence be written the way it appears or should that sentence read "...for qualifying safety-related motors."
Staff agrees. The commenter was correct, the guide relates to motors, not motor control centers. The error was removed in the final guide when the regulatory analysis was removed to conform to the regulatory guide format.
William Horin Discussion
- 1. Inclusion of Components/Accessories Limited to those Staff reviewed the commenters suggestion
2 Originator Section of DG-1150 Specific Comment NRC Resolution (NUGEQ)
Required for Motor Safety Functions Referenced DG-1150 text:
B. Discussion (page 3) - entire text discussion on IEEE-334 improvements that address Exception 1 in RG 1.40, dated March 1973.
NUGEQ Comment: The NRC in this discussion describes several improvements in IEEE 334 that, in sum, adequately address the prior NRC comment (Exception 1) that was intended to ensure that all equipment required for the motor to perform as intended was included in testing.
This discussion should emphasize that these improvements focus on those components and accessories that are required to perform or support a safety function. See in particular IEEE 334 Section 5.11, Seals and Gaskets and Section 5.12, Accessories. These improvements do not require components/accessories that are not required to perform or support a motor's safety function to be included in the qualification program.
NUGEQ Recommendation: Revise the paragraph beginning with Exception 1:. as follows:
Exception 1: To the extent practicable, auxiliary equipment that will be part of the installed motor assembly should also be qualified in accordance with IEEE Std 334-1971. This statement was included in the RG 1.40 to assure that all equipment required for the motor to perform its safety functions as intended was included in the qualification program testing. The following improvements have been identified to address this exception:
- 2. Some IEEE-334 Sections Cited Under Exception 2 Not and agreed that that the discussion section of the draft guide DG 1150 which identified specific items of concern to Staff should not be included in the final guide, as the comments could cause a mis-interpretation of the intent. The discussion which included changes between the existing guide and the proposed guide were removed from the final guide.
3 Originator Section of DG-1150 Specific Comment NRC Resolution Related to Simulating DBEs Referenced DG-1150 text:
B. Discussion (page 3) - entire text discussion on IEEE-334 improvements that address Exception 2 in RG 1.40, dated March 1973.
NUGEQ Comment: The NRC in this discussion describes several improvements in IEEE 334 that, in sum, adequately address the prior NRC comment (Exception 2) that Qualification tests should simulate as close as practicable all design basis events.
However, the subsequent NRC discussion includes two IEEE-334 sections that are not directly related to simulating such DBEs. These sections are Section 3.3, Components, and Section. 5.3.2, Type Test Model, Para 1.
The discussion text for these sections is unrelated to simulating DBEs and is more related to the auxiliary equipment addressed in Exception 1.
DG-1150 - NUGEQ Comments 2 NUGEQ Recommendation: Delete reference to and discussion of IEEE 334 Section 3.3, Components, and Section. 5.3.2, Type Test Model, Para 1 under Exception 2..