ML17258A580
| ML17258A580 | |
| Person / Time | |
|---|---|
| Issue date: | 04/30/2019 |
| From: | NRC/RES/DE |
| To: | |
| O'Donnell E | |
| Shared Package | |
| ML17257A104 | List: |
| References | |
| RG-1.199 DG-1284 | |
| Download: ML17258A580 (3) | |
Text
REGULATORY ANALYSIS DRAFT REGULATORY GUIDE (DG)-1284 ANCHORING COMPONENTS AND STRUCTURAL SUPPORTS IN CONCRETE (Proposed Revision 1 of Regulatory Guide 1.199, issued November 2003)
- 1. Statement of the Problem Regulatory Guide (RG) 1.199, "Anchoring Components and Structural Supports in Concrete, issued in November 2003, provides guidance to licensees and applicants on methods acceptable to the NRC staff for complying with the NRCs regulations in the design, evaluation, and quality assurance of anchors (steel embedments) used for component and structural supports in concrete structures.
Revision 0 of Regulatory Guide 1.199 endorsed American Concrete Institute (ACI)
Appendix D to ACI 349-01, ACI 355.2-01 (2001) Qualification of Post-Installed Mechanical Anchors in Concrete and Commentary, and American Society for Testing Materials (ASTM)
E488-96 Standard Test Methods for Strength of Anchors in Concrete and Masonry Elements, (1996). However, the most recent versions for these standards are ACI 349-13 (2013), ACI 355.2-07 (2007), and ASTM E488M-15 (2015). Some major changes have been incorporated in ACI 349-13, including changes of reduction factors and load combinations. Moreover, additional information has been presented in the updated versions of ACI 355.2-07, and ASTM E488M-15.
Use of these updated standards is desirable by both industry and the NRC staff.
- 2. Objective The objective of this regulatory action is to assess the need to update the NRC guidance on Anchoring Components and Structural Supports in Concrete.
- 3. Alternative Approaches The NRC staff considered the following alternative approaches for providing NRC guidance on acceptable methods and procedures for Anchoring Components and Structural Supports in Concrete:
- 1. Do not revise Regulatory Guide 1.199.
- 2. Withdraw Regulatory Guide 1.199.
- 3. Revise Regulatory Guide 1.199.
Alternative 1: Do Not Revise Regulatory Guide 1.199 Under this alternative, the NRC would not revise this guidance, and applicants would continue to use the present version of this regulatory guide. This is considered the No Action alternative. If NRC takes no action, there would be no cost to NRC in revising the guide.
However, the no-action alternative would not provide an update to address the issues identified above. This may result in requests from NRC to applicants for additional information.
The requests will impose a burden on the NRC staff. Applicants would also be burdened by the effort required to respond to the Requests for Additional Information (RAIs).
Alternative 2: Withdraw Regulatory Guide 1.199 Withdrawing this regulatory guide would eliminate the guidance regarding anchoring components and structural supports in concrete. Applicants would be impacted by a withdrawal by having to propose and justify methods and procedures for anchoring components and structural supports in concrete. NRC staff would be impacted by being required to review the alternate methods and procedures and the review may result in an increase in the number of RAIs, which could extend the length of an application review. Applicants would be burdened by the effort required to respond to the RAIs.
Alternative 3: Revise Regulatory Guide 1.199 Under this alternative, the NRC would revise Regulatory Guide 1.199. The value to NRC staff and applicants in revising the guide would be the benefits associated with providing guidance based on current generally-accepted methods and procedures for anchoring components and structural supports in concrete. With such guidance the need for requests for additional information is reduced. That is a benefit for both NRC and applicants. The impact on the NRC would be the costs associated with preparing and issuing the regulatory guide. For parties who submitted a previous application, the impact would be in the cost of addressing a revised guide versus dealing with an established one they had used before. Applicants who have not submitted an application previously would not be affected by a revision of the guide.
- 4. Comparison of Alternatives The three alternatives were compared against each other with respect to safety, as well as NRC and applicant resources.
With respect to safety, Alternative 1 does not update and add to the guidance references to various standards that have been updated, replaced, and or retracted when appropriate. This does not represent unsafe conditions but it may reduce the opportunity for application of superior methods. The withdrawal of formal NRC guidance (Alternative 2) does not necessarily represent unsafe results since organizations would either continue to use existing methods with which they are familiar and have not proven unsafe, or they may even adopt methods more recent than those found in the previous revisions of the RG. Alternative 3 would be superior to Alternative 1 and possibly 2 in that it would update the RG to include, where appropriate, revised standards and procedures that offer enhanced safety, improved clarity, reduce the uncertainty in the results, or facilitate the licensing process.
With regard to NRC resources, Alternative 3 represents the greatest initial cost to the NRC, which is attributable to the costs associated with preparing and issuing the regulatory guide. However, when considered over the lifetime of the RG and the potential for additional staff resource expenditures associated with evaluating applicant/licensee submittals which do not meet the RG, the overall NRC cost of Alternative 3 is less than the overall cost of Alternatives 1 or 2.
With regard to licensee and applicant resources, Alternatives 1 and 2 result in the most cost because the NRC may have to issue RAIs and licensees may have to perform additional analyses to address the RAIs. In addition, the licensees submittals may be delayed.
Conversely, Alternative 3 would result in the least costs for licensees and applicants because of a reduction in a need to address RAIs caused by use of outdated guidance.
- 5. Conclusion Based on this regulatory analysis, the NRC staff concludes that revision of Regulatory Guide 1.199 is warranted. The proposed action will enhance an applicants ability to prepare submittals to NRC. An updated guide will reduce staff review time and the need for RAIs, thus reducing costs to licensees, applicants, and the NRC. The cost to NRC in revising the RG and to licensees and applicants in adapting to a revised RG are deemed to be less than the benefits accrued by reducing the need for RAIs.