ML20261H516

Comment (24) of Stephen J. Vaughn on Setpoints for Safety-Related Instrumentation

ML20261H516
Person / Time
Site:	Nuclear Energy Institute
Issue date:	09/14/2020
From:	Vaughn S Nuclear Energy Institute
To:	Office of Administration
References
85FR49685 00024, NRC-2020-0171
Download: ML20261H516 (4)

Text

Page 1 of 1 SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Meraj Rahimi, Michael Eudy, As of: 9/15/20 11:28 AM Dawnmathews Received: September 14, 2020 Kalathiveettil, Status: Pending_Post PUBLIC SUBMISSION Kyle Song, Jeanne Johnston, Tracking No. kf2-t21k-0xo9 Holly Cruz, Mary Neely Comments Due: September 14, 2020 Submission Type: Web Comment (24)

Publication Date: 8/14/2020 Docket: NRC-2020-0171 CITATION 85 FR 49685 Setpoints for Safety-Related Instrumentation Comment On: NRC-2020-0171-0001 Setpoints for Safety-Related Instrumentation Document: NRC-2020-0171-DRAFT-0025 Comment on FR Doc # 2020-17763 Submitter Information Email: sjv@nei.org Organization: Nuclear Energy Institute General Comment Industry Comments on Draft Regulatory Guide (DG) 1363, Draft Revision 4 to RG 1.105, Setpoints for Safety Related Instrumentation; 85 FR 49685; Docket ID NRC-2020-0171 Attachments 9-14-2020_NEI Comments on DG-1363 with attachment https://www.fdms.gov/fdms/getcontent?objectId=09000064848579f9&format=xml&showorig=false 09/15/2020

STEPHEN J. VAUGHN Senior Project Manager, Engineering and Risk 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8163 sjv@nei.org nei.org September 14, 2020 Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Industry Comments on Draft Regulatory Guide (DG) 1363, Draft Revision 4 to RG 1.105, Setpoints for Safety Related Instrumentation; 85 FR 49685; Docket ID NRC-2020-0171 Project Number: 689 Submitted via regulations.gov

Dear Ms. Jennifer Borges:

The Nuclear Energy Institute (NEI) 1, on behalf of its members, submits the following comments on DG-1363, Draft Revision 4 to RG 1.105, Setpoints for Safety Related Instrumentation. We greatly appreciate the effort to revise RG 1.105 by endorsing the ANSI/ISA 67.04.01-2018 Standard without exceptions and appreciate the opportunity to comment on the draft revision. We are considering an industry workshop to ensure practitioners have a better understanding of the RG 1.105 revision and its impact on the maintenance of instrument setpoints. If initial plans for a workshop are developed, we will reach out to the NRC for participation.

Please contact me at sjv@nei.org and (202) 739-8163 if you have any questions or concerns.

Sincerely, Stephen Vaughn 1

The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.

Ms. Jennifer Borges September 14, 2020 Page 2 Attachment NEI Comments on DG-1363 c: Ms. Jeanne Johnston, NRR Ms. Dawnmathews Kalathiveettil, NRR Mr. Michael Eudy, RES

NEI Comments on DG-1363 Affected Section Comment/Basis Recommendation

1. Section B.1 ANSI/ISA S67.04-2018 should be ANSI/ISA S67.04.01- Change ANSI/ISA S67.04-2018 to ANSI/ISA 2018 S67.04.01-2018.

2. Section B.2.1 First sentence. The term anticipated conditions is not Change the term anticipated conditions with commonly used and causes confusion. The term accident conditions. Consider other events that accident conditions is a more appropriate term because would rely on safety-related systems and/or any of the non-normal conditions are not anticipated. components (e.g., Anticipated Operational Occurrences (AOOs)).

3. Section B.2.2.1 Paragraph 3 reaffirms the NRC staffs approval of Option B State that Option A of TSTF-493 is still a viable of TSTF-493, Revision 4 but there is no mention path.

throughout the DG-1363 of Option A of TSTF-493, Revision 4.

4. Section B.2.2.3 This section refers to drift as though is mentioned in the Clarify the language to address the inconsistency.

footnote under 4.6 of the standard; however the footnote in the standard only mentions test acceptance criteria and TLU.

5. Section B.2.2.5 The term (Performance Acceptance Criteria) should be Change the term (Performance Acceptance (Performance Test Acceptance Criteria) Criteria) to (Performance Test Acceptance Criteria).

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