ML19156A128

Public Comments Rg 1.151

ML19156A128
Person / Time
Issue date:	02/06/2020
From:	Office of Nuclear Regulatory Research
To:
Eudy M
Shared Package
ML19156A117	List: ML19156A128 ML19156A129
References
DG-1352, RG-1.151, Rev 2
Download: ML19156A128 (4)

Text

Response to Public Comments on Draft Regulatory Guide (DG)-1352 Instrument Sensing Lines Proposed Revision 2 of Regulatory Guide (RG) 1.151 On 02/08/2019, the NRC published a notice in the Federal Register (84 FR 2934) that Draft Regulatory Guide, DG-1352 (Proposed Revision 2 of RG 1.151), was available for public comment. The public comment period ended on 04/09/2019. The NRC received comments from the organizations listed below. The NRC has combined the comments and NRC staff responses in the following table.

Comments were received from the following:

Ronald LaVera Southern Nuclear Anonymous NRO/DLSE/RPAC 3535 Colonnade Parkway ADAMS Accession No. ML19099A192 US NRC Birmingham, AL 35243 11555 Rockville Pike ADAMS Accession No. ML19102A240 Rockville, MD 20852 ADAMS Accession No. ML19072A243 Commenter Section of Specific Comments NRC Resolution DG-1352 Ronald Section The proposed revision to RG 1.151 omitted 2 key criteria The staff agreed that IEEE Std 622-1987 should be in LaVera B/Section C from the Regulatory Positions of the 2010 version of the Section C instead of Section B. The staff does not agree RG 1.151. that ANSI/ISA-67.02.01-1999 should be in Section C.

IEEE Std 622-1987 regarding heat tracing.

ANSI/ISA-67.02.01-1999 regarding non-condensable The staff met with Mr. LaVera and discussed his gases. comments and reached agreement. IEEE Std 622-1987 is important enough to add an item in Section C to clarify While these documents are discussed to some limited NRCs position. The added statement in Section C is as degree in section B of the proposed revision, unless there follows: Instrument sensing lines should be designed is some other RG that you can point to within this RG and maintained to ensure that the fluids or gases in the that endorses those 2 Regulatory Positions, the references lines remain within the temperature ranges necessary to to those documents should not be deleted. perform their intended functions. Should heat tracing be used, the staff considers IEEE Std. 622-1987 to be acceptable for the design and installation of these systems. The staff explained that the non-condensable gases are addressed in ANSI/ISA-67.02.01-2014, Month Year

Commenter Section of Specific Comments NRC Resolution DG-1352 therefore, there is no need to endorse the older ANSI/ISA-67.02.01-1999 and Mr. LaVera agreed.

For these reasons, the staff decided to add a position to clarify IEEE Std. 622-1987 in Section C and modified Section B which states This revision (Revision 2) of RG 1.151 clarifies the previous Regulatory Position C.3 that was in Revision 1 regarding the acceptability and use of ANSI/IEEE Std. 622-1987.

Ronald Section B In addition, the discussion about Heat Tracing in Section The staff agreed with the comment and made two LaVera B does not sufficiently address the need for heat trace to changes to the DG.

prevent the deposition of radionuclides of interest on the sampling line surfaces. The first change is to add a position to clarify IEEE Std. 622-1987 in Section C. The second change is to modify Section B which states This revision (Revision 2) of RG 1.151 clarifies the previous Regulatory Position C.3 that was in Revision 1 regarding the acceptability and use of ANSI/IEEE Std. 622-1987.

Ronald Section C RG 4.16, ANSI N13.1 should be mentioned in the The staff disagreed with the comment.

LaVera regulatory positions section. RG 4.16, ANSI N13.1 and 10 CFR 20 Subpart F Surveys and Monitoring should be During the meeting with Mr. LaVera, he agreed with the discussed in Section B. staffs position that these two documents are unrelated to the scope of the DG, which is intended as guidance for the design and installation of instrument sensing lines (including sample lines) in nuclear power plants.

For this reason, no change to the DG is made.

Ronald Section C The regulatory positions section should include The staff disagreed with the comment.

LaVera references to GDC 60 and GDC 64.

GDC 60 discusses control of release of radioactive materials to the environment and GDC 64 discusses monitoring radioactivity release. These are topics covered in RG 4.16 but are not within the scope of RG 2

Commenter Section of Specific Comments NRC Resolution DG-1352 1.151, which is intended as guidance for the design and installation of instrument sensing lines (including sample lines) in nuclear power plants. During the meeting with Mr. LaVera, he agreed with the staffs position.

For this reason, no change to the DG was made.

Ronald General RG 4.16, Monitoring and Reporting Radioactivity in The staff disagreed with the comment.

LaVera Releases of Radioactive Materials in Liquid and Gaseous Effluents from Nuclear Fuel Processing and Fabrication The staff reviewed 10 CFR 20 Subpart F, Surveys and Plants and Uranium Hexafluoride Production Plants, Monitoring, and found no direct impact to RG 1.151.

states, The NRC recognizes the guidance developed in During the meeting with Mr. LaVera, he agreed with the American National Standards Institute (ANSI)/Health staffs position.

Physics Society (HPS) N13.1-1999, Sampling and Monitoring Releases of Airborne Radioactive Substances For this reason, no change to the DG was made.

from the Stacks and Ducts of Nuclear Facilities.

ANSI N13.1 states, If the contaminants are in the form of condensible vapors or reactive gases, long transport lines and large temperature changes in the sample or the transport line shall either be avoided or measures shall be taken to minimize potential loss of sample. Heat tracing of the transport line is readily accomplished, but conditioning of the sample may be necessary, such as a deliberate temperature change and purposeful dilution with a carrier gas.

Conformance with this guidance is necessary in order for licensees to demonstrate compliance with 10 CFR 20 Subpart F Surveys and Monitoring.

Anonymous General Good The staff made no changes to the DG in regards to this comment.

Southern General Typically, ISA standards have an "S" at the beginning of The staff disagreed with the comment.

Nuclear the number to differentiate it as a standard. Thus, it is 3

Commenter Section of Specific Comments NRC Resolution DG-1352 expected that the ANSI/ISA standard would be The staff checked the standard and the standard number S67.02.01-2014 versus 67.02.01-2014. is correct.

For this reason, no change to the DG was made.

Southern Section B GDC 2, "Design Basis for Protection Against Natural The staff agreed with the comment.

Nuclear Phenomena" was not included in Revision 1 of RG 1.151.

Because the "Reason for Revision" does not address the In Section B, a statement This revision of RG 1.151 inclusion of GDC 2, is not clear from the current context (Revision 2) also includes a reference to GDC 2 as an as to why the staff chose to add it in this revision. applicable regulation because the fluids or gases in sensing lines are required to remain within the temperature ranges necessary to perform their intended functions was added.

Southern Section B In revision 1 of RG 1.151, a later version of IEEE Std. The staff disagreed with the comment.

Nuclear 279 (1971) is referenced. It is not clear why the staff chose to refer to an earlier version of IEEE Std. 279 Section B of RG 1.151 (Revision 2) quotes information (1968) instead of the later version that was previously and standards directly from the requirements specified in referenced in revision 1 of RG 1.151 . 10 CFR 50.55 a(h) which includes references to both IEEE Std 279-1968, Proposed IEEE Criteria for Nuclear Power Plant Protection Systems and IEEE Std 279-1971, Criteria for Protection Systems for Nuclear Power Generating Stations, accordingly. For this reason, no changes to the DG were made.

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