ML20192A230
| ML20192A230 | |
| Person / Time | |
|---|---|
| Issue date: | 12/10/2020 |
| From: | Office of Nuclear Regulatory Research |
| To: | |
| Eudy M | |
| Shared Package | |
| ML20183A421 | List: |
| References | |
| DG-1361 RG 1.89 | |
| Download: ML20192A230 (3) | |
Text
REGULATORY ANALYSIS DRAFT REGULATORY GUIDE DG-1361 Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants (Proposed Revision 2 of Regulatory Guide 1.89, dated June 1984)
- 1.
Statement of the Problem The U.S. Nuclear Regulatory Commission (NRC) is considering revising Regulatory Guide 1.89, Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants, Revision 1, to endorse a joint logo International Standard with International Electro-technical Commission (IEC) IEC/Institute of Electrical and Electronics Engineers (IEEE) 60780-323:2016, Nuclear Facilities-Electric Equipment important to safety Qualification, and to incorporate the NRCs implementation of a risk-informed, performance-based approach to licensing.
Revision1 of Regulatory Guide 1.89 was issued in June 1984 and endorsed the use of IEEE Standard 323-1974. The IEEE updated this standard in 1983, 2003, and then again in 2016. However, the NRC has not officially endorsed these versions in a regulatory guidance document.
In 2016, the IEEE standard was issued as a joint logo International Standard with IEC (IEC/IEEE 60780-323:2016). The joint standard describes principles, methods, and procedures for qualifying, maintaining, and extending qualification, as well as updating qualification, of safety-related electrical equipment that is important to safety and interfaces that are to be used in nuclear power plants, including components or equipment of any interface whose failure could adversely affect any safety-related equipment.
This revision of the guide (Revision 2) would reflect almost 40 years of experience gained in implementing regulatory requirements and industry research/testing related to equipment qualification. Nuclear plant license renewal provides additional motivation for continuing attention to equipment qualification. This revised guide would contain information specific for equipment qualification for both older plants and newer reactors licensed under both Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, and 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants.
- 2.
Objective The objective of this regulatory action is to access the need to revise NRC guidance and provide applicants with an updated method to demonstrate compliance with 10 CFR 50.49, Environmental qualifications of electric equipment important to safety for nuclear power plants.
Revising this regulatory guide to endorse portions of a consensus standard is consistent with the NRC policy of developing and evaluating the latest versions of national and multi-lateral international consensus standards to determine their suitability for supporting the NRCs mission and endorsement by regulatory guides. This approach also will comply with the NRCs Management Directive (MD) 6.5, NRC Participation in the Development and Use of Consensus Standards, (Agencywide Document and Management System (ADAMS) Accession No.
Page 2 ML18073A164). 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 Regulatory Guide 1.89
- 2. Withdraw Regulatory Guide 1.89
- 3. Revise Regulatory Guide 1.89 to address the current methods and procedures.
Alternative 1: Do Not Revise Regulatory Guide 1.89 Under this alternative, the NRC would not revise the Regulatory Guide, and the current guidance would be retained. If NRC does not take action, then there would not be any changes in costs or benefit to the public, licensees, or the NRC. This alternative is considered the no-action alternative and provides a baseline condition from which any other alternatives will be assessed. However, the no-action alternative would not address nearly 40 years of experience gained in implementing regulatory requirements and industry research/testing related to equipment qualification.
Alternative 2: Withdraw Regulatory Guide 1.89 Under this alternative the NRC would withdraw this regulatory guide. This would eliminate the problems identified above regarding the regulatory guide. It would also eliminate the only readily available description of the methods the NRC staff considers acceptable for demonstrating compliance with 10 CFR 50.49. Although this alternative would be less costly than the proposed alternative in the short term, it would be more costly in the long term because a void in the guidance would reduce predictability, efficiency, and regulatory stability.
Alternative 3: Revise Regulatory Guide 1.89 Under this alternative, the NRC would revise Regulatory Guide 1.89. This revision would incorporate the latest information in IEC/IEEE 60780-323:2016, supporting guidance, and review practices. By doing so, the NRC would ensure that the regulatory guidance available in this area is current and accurately reflects the staffs position.
The impact to the NRC would be the costs associated with preparing and issuing the regulatory guide revision. The impact to the public would be the voluntary costs associated with reviewing and providing comments to the NRC during the public comment period. The value to the NRC staff, licensees, and applicants would be the benefits associated with enhanced efficiency and effectiveness in using a common guidance document as the technical basis for license applications, including license renewal, and other interactions between the NRC and its regulated entities.
Conclusion Based on this regulatory analysis, the NRC staff concludes that revision of Regulatory Guide 1.89 is warranted. The action will enhance efficiency and effectiveness by using up-to-
Page 3 date guidance for ensuring reactor safety. It could also lead to cost savings for nuclear power reactor licensees, especially with regard to providing guidance for using alternative approaches to satisfy the environmental qualification requirements specified in 10 CFR 50.49.