ML14356A247

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Regulatory Analysis for DG-1314
ML14356A247
Person / Time
Issue date: 04/10/2015
From:
Office of Nuclear Regulatory Research
To:
Burton S
Shared Package
ML14356A238 List:
References
DG-1314 RG 1.26
Download: ML14356A247 (3)


Text

REGULATORY ANALYSIS DRAFT REGULATORY GUIDE DG-1314 QUALITY GROUP CLASSIFICATIONS AND STANDARDS FOR WATER-, STEAM-,

AND RADIOACTIVE-WASTE-CONTAINING COMPONENTS OF NUCLEAR POWER PLANTS (Proposed Revision 5 of Regulatory Guide 1.26, dated September 2014)

Purpose The purpose of Revision 5 of the guide clarifies content (e.g., the definition of Quality Group A and the scope of requirements for pumps and valves), corrects errors (e.g., a misplaced footnote), and provides additional references to related classification systems such as risk-informed classification and industry and international standards that may be proposed by applicants or licensees as an alternative means to comply with NRC requirements for the classification of water, steam, and radioactive-waste containing components of nuclear power plants. This update also aligns the format and content of the guide with the current program guidance for regulatory guides.

1.

Statement of the Problem The U.S. Nuclear Regulatory Commission (NRC) is considering revising Regulatory Guide (RG) 1.26, Quality Group Classifications and Standards for Water-, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants to update references to related guidance and appropriate regulations and incorporate lessons learned from recent reviews and regulatory activities.

Since 2007, the staff has reviewed several large light-water reactor designs and much has been learned. The current version of RG 1.26 (Revision 4) does not provide a complete set of references to the correct sections of the regulations.

In the early 1970s the NRC staff developed a quality classification system for water-and steam-containing components important to safety of water-cooled nuclear power plants. In March 1972 the NRC staff issued Safety Guide 26, Quality Group Classification Standards to describe the quality classification system and provide licensees and applicants guidance on using the quality classification system to satisfy the requirements of General Design Criterion (GDC) 1, Quality Standards and Records, as set forth in Appendix A, General Design Criteria for Nuclear Power Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities.

The quality classification system consists of four quality groups, A through D; methods for assigning components to those quality groups; and specific quality standards applied to each quality group. In September 1974, the NRC staff replaced Safety Guide 26 with Regulatory Guide (RG) 1.26, which has been revised as 10 CFR § 50.55a, Codes and Standards has been updated. Revision 4 of RG 1.26 was issued to align this RG with the revision of 10 CFR 50.55a, issued in 1984 (Volume 49 of the Federal Register, p. 9711 (49 FR 9711)). The regulations were revised to incorporate by reference the criteria in Section III of the ASME Code, as they relate to the design and fabrication of Class 2 and 3 components (Quality Group B and C components, respectively) and Section VIII, Division I of the ASME Code (Quality Group D components).

Page 2

2.

Objective The objective of this regulatory action is to update the guidance for applicants and licensees of nuclear power plants that provides one acceptable method of demonstrate compliance with GDC 1 and 10 CFR 50.55a. Revision 5 of this RG clarifies content (e.g., the definition of Quality Group A and the scope of requirements for pumps and valves), corrects errors (e.g., a misplaced footnote), and provides additional references to related classification systems such as risk-informed classification and industry and international standards that may be proposed by applicants or licensees as an alternative means to comply with NRC requirements.

Revising this RG to approve for use portions of a consensus standard is consistent with the NRC policy of evaluating the latest versions of national consensus standards to determine their suitability for endorsement by RGs. This approach also will comply with the NRCs Management Directive (MD 6.5), NRC Participation in the Development and Use of Consensus Standards (ML100600460). This is in accordance with Public Law 104-113, National Technology Transfer and Advancement Act of 1995.

3.

Alternative Approaches The NRC staff considered the following alternative approaches:

1. Do not revise RG 1.26
2. Withdraw RG 1.26
3. Revise RG 1.26 to address the current methods and procedures.

Alternative 1: Do Not Revise RG 1.26 Under this alternative, the NRC would not revise or issue additional guidance, and the current guidance would be retained. If NRC does not take action, there would not be any changes in costs or benefit to the public, licensees or NRC. However, the no-action alternative would not address identified concerns with the current version of the RG. The NRC would continue to review each application on a case-by-case basis. This alternative is considered the no-action alternative and provides a baseline condition from which any other alternatives will be assessed.

Alternative 2: Withdraw RG 1.26 Under this alternative the NRC would withdraw this RG. This would eliminate the problems identified above regarding the RG. It would also eliminate the only readily available description of the methods the NRC staff considers acceptable for demonstrating compliance with GDC 1 and 10 CFR 50.55ain particular, the definitions of Quality Groups B and C, for which 10 CFR 50.55a points directly to this RG. Although this alternative would be less costly than the proposed alternative, it would impede the publics accessibility to the most current regulatory guidance.

Page 3 Alternative 3: Revise RG 1.26 Under this alternative, the NRC would revise RG 1.26. This revision would incorporate the latest information, supporting guidance, and review practices. By doing so, the NRC would ensure that the RG guidance available in this area is current, and accurately reflects the current staff position on classification of water, steam, and radioactive-waste containing components of nuclear power plants. Updated regulatory guidance will enhance applicants and licensees ability to provide the appropriate level of detail to support the NRC staffs safety finding on a licensing action.

The impact to the NRC would be the costs associated with preparing and issuing the RG revision. The impact to the public would be the voluntary costs associated with reviewing and providing comments to NRC during the public comment period. The value to NRC staff and its applicants would be the benefits associated with enhanced efficiency and effectiveness in using a common guidance document as the technical basis for license applications and other interactions between the NRC and its regulated entities.

Conclusion Based on this regulatory analysis, the NRC staff concludes that a revision of RG 1.26 is warranted. The action will enhance the assurance of reactor safety by ensuring that appropriate guidance is available for applicants and licensees. It could also lead to cost savings for the industry, especially with regard to support new, near term reactor licensing activities.