ML22208A234
| ML22208A234 | |
| Person / Time | |
|---|---|
| Issue date: | 04/27/2023 |
| From: | Hardin L NRC/RES/DE/CIB |
| To: | |
| Steckel J | |
| Shared Package | |
| ML22112A182:ML22112A182 | List: |
| References | |
| RG 1.204 Rev 1 DG-1409 | |
| Download: ML22208A234 (2) | |
Text
REGULATORY ANALYSIS DRAFT REGULATORY GUIDE DG-1409 GUIDELINES FOR LIGHTNING PROTECTION FOR PRODUCTION AND UTILIZATION FACILITIES (Proposed Revision 1 of Regulatory Guide 1.204, issued November 2005)
- 1. Statement of the Problem The U.S. Nuclear Regulatory Commission (NRC) is considering revising Regulatory Guide (RG) 1.204, Guidelines for Lightning Protection for Production and Utilization Facilities, whose Revision 0 the agency issued in November 2005.
Since several of the referenced Institute of Electrical and Electronics Engineers (IEEE) standards have been revised, the NRC expects that current licensees and new applicants should use the latest technical information. Therefore, the staff needs to determine whether revision of this RG is warranted to provide guidance that reflects updated information for the evaluation of lightning protection at production and utilization facilities.
- 2. Objective The objective of this regulatory action is to assess the need to provide up-to-date guidance to evaluate lightning protection at production and utilization facilities.
- 3. Alternative Approaches The staff considered three alternative approaches:
(1) Do not revise RG 1.204.
(2) Withdraw RG 1.204.
(3) Update RG 1.204 Alternative 1: Do Not Revise Regulatory Guide 1.204 Under this alternative, the NRC would not revise this guidance, and applicants would continue to use the present version of the guide. This is considered the no-action alternative. If the NRC takes no action the agency would not incur any initial cost to revise the guide. A periodic review conducted in 2017 mentioned no known technical or regulatory issues other than the cited revision of IEEE standards. However, the no-action alternative would not address the issues identified by those updated standards for evaluating guidelines for lightning protection at production and utilization facilities.
This may result in the NRC issuing requests for additional information (RAIs) to applicants. Applicants could be burdened by the effort required to respond to these RAIs, and the NRC staff would be burdened by the need to review the applicants responses.
Alternative 2: Withdraw Regulatory Guide 1.204 Under this alternative, the withdrawal of RG 1.204 would leave a void in NRC regulatory guidance for evaluating lightning protection at production and utilization facilities. By eliminating guidance for future applicants, the content of future applications could vary from applicant to applicant, thereby making the review of these applications more burdensome for the staff. The burden on applicants would also be greater under this alternative, because without specific guidance, applicants might spend more time preparing applications and potentially responding to RAIs.
Alternative 3: Update Regulatory Guide 1.204 Under this alternative, the NRC would update RG 1.204, resolving issues previously identified for future consideration. As one benefit, this action would enhance facility safety by providing up-to-date guidance and information on the evaluation guidelines for lightning protection production and utilization facilities. In addition, it would improve the staffs ability to review future applications quickly.
The costs to the NRC would be the one-time cost of revising and issuing the revised RG (which is expected to be small). The impact on 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 and its applicants would be the benefits associated with enhanced efficiency and effectiveness in using a common guidance document as the technical basis for license applications and other interactions between the NRC and its regulated entities.
Evaluating lightning protection at production and utilization facilities is required regardless of the existence or currency of the RG, so applicants would incur little or no additional cost relative to Alternative 1. Updated regulatory guidance might reduce the applicants cost relative to Alternative 2.
- 4. Comparison of Alternatives Alternative 1 is considered the baseline or no-action alternative and, as such, involves no value/impact considerations. Alternative 2 would make application review more burdensome for the staff and very likely make application preparation more burdensome for applicants.
Alternative 3 would impose a one-time additional cost to the NRC relative to Alternatives 1 and 2. This one-time cost would be offset by avoiding the burdens imposed by Alternative 2.
Alternative 3 would not impose significant additional costs on applicants relative to Alternative 1 and could possibly result in reduced costs to applicants relative to Alternative 2.
- 5. Conclusion Based on this regulatory analysis, the NRC staff concludes that revision of Regulatory Guide 1.204 is warranted. The action will enhance the safety of production and utilization facilities by providing up-to-date guidance and information on evaluating lightning protection.
Applicants and licensees can use this guidance to evaluate the design of their lightning protection systems and to help ensure the NRC staffs timely review of the submitted designs.
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