ML21288A112
| ML21288A112 | |
| Person / Time | |
|---|---|
| Issue date: | 01/31/2022 |
| From: | Mohammad Sadollah NRC/RES/DE |
| To: | |
| Jenkins R | |
| Shared Package | |
| ML21271A013 | List: |
| References | |
| RG-1.248, Rev 0 DG-1393 | |
| Download: ML21288A112 (2) | |
Text
REGULATORY ANALYSIS DRAFT REGULATORY GUIDE DG-1393 GUIDE FOR ASSESSING, MONITORING, AND MITIGATING AGING EFFECTS ON ELECTRICAL EQUIPMENT USED IN NUCLEAR POWER GENERATING STATIONS (Proposed New Regulatory Guide)
- 1. Statement of the Problem The U.S. Nuclear Regulatory Commission (NRC) is considering developing a new Regulatory Guide (RG) to endorse Institute of Electrical and Electronics Engineers (IEEE)
Standard (Std.) 1205-2014, IEEE Guide for Assessing, Monitoring, and Mitigating Aging Effects on Electrical Equipment Used in Nuclear Power Generating Stations. This standard reflects state of the art maintenance practices to manage the aging effects associated with electrical equipment and it is useful in meeting 10 CFR Part 50, 10 CFR Part 52, and 10 CFR Part 54 requirements.
- 2. Objective The objective of this regulatory action is to assess the need to issue NRC guidance in order to provide applicants and licensees with a method to demonstrate compliance with the requirements in Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities; 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants; 10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants to monitor the performance or condition of electrical equipment against licensee-established goals, in a manner sufficient to provide reasonable assurance that these structures, systems, and components (SSCs) are capable of fulfilling their intended functions.
- 3. Alternative Approaches The NRC staff considered the following alternative approaches:
a) Do not issue the RG.
b) Issue the RG.
Alternative 1: Do Not Issue the Regulatory Guide Under this alternative, the NRC would not issue new guidance to address aging effects of electrical equipment. This alternative is considered the no-action alternative and provides a baseline condition from which any other alternatives will be assessed. If the NRC does not take action, there would not be any changes in costs, or benefit to the public, applicants, licensees, or the NRC. The NRC would continue to review each application on a case-by-case basis.
However, this alternative would result in the continued absence of more comprehensive NRC guidance for maintenance and managing aging effects on the subject SSCs. This may result in increased NRC staff review time and the need for the NRC staff to request additional information from licensees and applicants. Licensees and applicants would then have to expend resources in responding to these requests for additional information.
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Alternative 2: Issue the Regulatory Guide Under this alternative, the NRC would issue the proposed RG. This issuance would provide regulatory guidance which incorporates the current information in IEEE Std. 1205-2014 and its supporting guidance and review practices. By doing so, the NRC would ensure that up-to-date regulatory guidance is available in this area for use by licensees and applicants, and that the guidance accurately reflects the staffs position.
Providing this RG to endorse IEEE Std. 1205-2014 is consistent with the NRC policy of reviewing the latest versions of national consensus standard to determine their suitability for endorsement by NRC regulatory guides. This approach will also comply with the NRCs directive that standards developed by consensus bodies must be used in accordance with the National Technology Transfer and Advancement Act of 1995 (Public Law 104-113) (Agencywide Documents Access and Management System Accession No. ML032740147).
The impact to the NRC would be the costs associated with preparing and issuing the new RG. The impact to the public would be the voluntary costs associated with reviewing the draft guide and providing comments to the NRC during the public comment period. Issuance of the new RG would afford value to the NRC staff, and agency licensees and future applicants, due to the benefits associated with enhanced efficiency and effectiveness in using a common guidance document as the technical basis for maintenance practices and aging management of the subject SSCs for license applications and other interactions with the NRC. In addition, this new RG would reduce the need for the NRC staff to request additional information from licensees and applicants where such information is rendered unnecessary by the new RG.
Conclusion Based on the above, the NRC staff concludes that issuance of a new RG is warranted and beneficial. The action will enhance reactor safety by providing guidelines for the review process of applications and interactions between the NRC and its regulated entities for compliance with the applicable requirements of 10 CFR Part 50, 10 CFR Part 52, and 10 CFR Part 54. This action could also lead to cost savings for the industry, especially with regard to NRC staff review time, and the need for requests for additional information and responses thereto, when the staff is reviewing applications for license amendments, license renewal, subsequent license renewal, standard plant design certifications, and combined licenses.
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