ML21292A307

Industry Feedback on NRCs Consideration of Endorsement of IEEE Std 1819-2016

ML21292A307
Person / Time
Site:	Nuclear Energy Institute
Issue date:	10/06/2021
From:	Anderson V Nuclear Energy Institute
To:	Louise Lund NRC/RES/DE
Roche-Rivera R
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ML21292A304	List: ML21292A307 ML21292A308
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Download: ML21292A307 (2)

Text

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 October 6, 2021 Ms. Louise Lund NRC Standards Executive Office of Nuclear Reactor Research U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Industry Feedback on NRCs consideration of endorsement of IEEE Std 1819-2016, Standard for Risk-Informed Categorization and Treatment of Electrical Equipment in Nuclear Facilities Project Number: 689

Dear Ms. Lund:

On behalf of our Members, the Nuclear Energy Institute (NEI) 1 offers this input regarding the Nuclear Regulatory Commission (NRC) consideration of endorsement of IEEE Std 1819-2016, Standard for Risk-Informed Categorization and Treatment of Electrical Equipment in Nuclear Facilities, as documented in your December 26, 2019 letter to Daryl Harmon of the IEEE Nuclear Power Engineering Committee (ML19352E115). This letter notes that the NRC staff will consider assessing feasibility of endorsing IEEE Std 1819-2016, and we understand that the NRC staff has moved forward to potentially endorse this standard.

After extensive consultation with our members, including stakeholders involved with both operating reactors and advanced reactors, NEI urges the NRC to not pursue endorsement of IEEE Std 1819-2016. None of NEIs members have any intent to use this standard in their implementation of 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors, so there appears to be no value in the NRCs endorsement of this standard. Moreover, NEI is concerned that NRC endorsement of IEEE Std 1819-2016 would create an unnecessarily confusing and complicated scenario where licensees would perceive an expectation that mechanical and electrical components be treated differently under 50.69. Finally, given the success licensees have had in categorization under 50.69 without endorsement of such a standard, it is evident that it is not needed to 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. Louise Lund October 6, 2021 Page 2 support implementation of 50.69. In the interests of regulatory stability, NEI strongly recommends that the NRC decline to endorse IEEE Std 1819-2016.

If you have questions concerning this matter, please contact me at vka@nei.org or (202) 739-8101.

Sincerely, Victoria K. Anderson c: Mr. Michael Franovich, NRR Mr. Bob Pascarelli, NRR Ms. Sheila Ray, NRR Mr. Khoi Nguyen, NRR NRC Document Control Desk