ML21182A118
| ML21182A118 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 07/01/2021 |
| From: | Anderson V Nuclear Energy Institute |
| To: | Office of Administration |
| References | |
| 86FR24672 00002, NRC-2020-0252 | |
| Download: ML21182A118 (3) | |
Text
7/1/2021 blob:https://www.fdms.gov/d1173b75-6f68-47f5-9332-52bb23fa1695 blob:https://www.fdms.gov/d1173b75-6f68-47f5-9332-52bb23fa1695 1/1 PUBLIC SUBMISSION As of: 7/1/21 10:11 AM Received: June 29, 2021 Status: Pending_Post Tracking No. kqi-cuil-v1ij Comments Due: July 06, 2021 Submission Type: Web Docket: NRC-2020-0252 Quality Group Classifications and Standards for Water-, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants Comment On: NRC-2020-0252-0001 Quality Group Classifications and Standards for Water-, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants Document: NRC-2020-0252-DRAFT-0004 Comment on FR Doc # 2021-09728 Submitter Information Email:atb@nei.org
Organization:Nuclear Energy Institute General Comment See attached file(s)
Attachments 06-29-21_NRC_DG 1371 Comments SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Jim Steckel, Mary Neely Comment (2)
Publication Date: 5/7/2021 Citation: 86 FR 24672
VICTORIA K. ANDERSON Technical Advisor, Engineering and Risk 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8101 vka@nei.org nei.org June 29, 2021 Office of Administration Mail Stop: TWFN-7A06 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Program Management, Announcements and Editing Staff
Subject:
Industry Comments on Draft Regulatory Guide (DG) 1371, Quality Group Classifications and Standards for Water-, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants, 85 FRN 24672-24673; Docket ID NRC-2020-0252 Submitted via Regulations.gov Project Number: 689
Dear Program Management,
Announcements and Editing Staff:
On behalf of the Nuclear Energy Institutes (NEI)1 members (hereinafter referred to as industry), we provide the following comments on DG-1371, Quality Group Classifications and Standards for Water-, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants. We appreciate the opportunity to comment on the draft revision to Regulatory Guide 1.26.
In our review, we noted that the draft regulatory guide revision could be enhanced by better clarifying the separation between the applicability of the ANSI standard and the implementation of 50.69, particularly in the introduction and conclusion. Additionally, in Table 1 of Appendix A, Q Group B requires ASME Section III Class 2; this would not be the case for plants with 50.69 implemented. If a component is categorized as LSS, it is out of scope of the O&M codes and alternative treatments can be applied. We recommend clarifying that Table 1 of Appendix A is not applicable to plants with 50.69.
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.
Program Management, Announcements and Editing Staff June 29, 2021 Page 2 We encourage NRC to consider all stakeholder comments prior to finalizing the revision to this regulatory guide. Please contact me at vka@nei.org or (202) 739-8101 with any questions about the content of this letter or the attached comments.
Sincerely, Victoria K. Anderson c:
Mr. Thomas Scarbrough, NRR Mr. James Steckel, RES