ML22307A144
| ML22307A144 | |
| Person / Time | |
|---|---|
| Issue date: | 02/27/2023 |
| From: | Liliana Ramadan NRC/NRR/DEX/EEEB |
| To: | |
| Sahle, S | |
| Shared Package | |
| ML22304A007 | List: |
| References | |
| RG 1.212 Rev 2 DG 1418 | |
| Download: ML22307A144 (2) | |
Text
1 REGULATORY ANALYSIS DRAFT REGULATORY GUIDE DG-1418 SIZING OF LARGE LEAD-ACID STORAGE BATTERIES (Proposed Revision 2 of Regulatory Guide 1.212, Revision 1 issued October 2015)
- 1. Introduction This document presents the results of a regulatory analysis of the U.S. Nuclear Regulatory Commissions (NRCs) determination of whether to issue Draft Regulatory Guide (DG)-1418 (proposed Revision 2 of Regulatory Guide (RG) 1.212), Sizing of Large Lead-Acid Storage Batteries. The analysis provides the public with an insight into how the NRC arrives at a decision.
- 2. Statement of the Problem The NRC staff developed the current version (Revision 1) of RG 1.212 in October 2015, which endorsed Institute of Electrical and Electronics Engineers (IEEE) Standard (Std.) 485-2010, IEEE Recommended Practice for Sizing Lead-Acid Batteries for Stationary Applications.
IEEE Std. 485 was revised in 2020 and, it is expected that current licensees and new applicants, including advanced reactor and small modular reactor applicants, would use the new standard endorsed in a revised RG. Therefore, the staff needs to determine whether revision of this RG is warranted to provide guidance that reflects updated information to address the sizing of large lead-acid batteries.
- 3. Objective The objective of this regulatory action is to assess the need to update RG 1.212 to incorporate the 2020 version of IEEE 485 guidance for applicants and licensees of production and utilization facilitates.
- 4. Alternative Approaches The staff considered three alternative approaches:
(1)
Do not revise RG 1.212.
(2)
Withdraw RG 1.212.
(3)
Update RG 1.212 Alternative 1: Do Not Revise Regulatory Guide 1.212 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 NRC takes no action, there would be no initial cost to the NRC to revise the guide. However, the No-Action alternative would not provide updated information to address the sizing of large lead-acid batteries.
2 This may result in the NRC issuing requests for additional information (RAIs) to applicants. Applicants would be burdened by the effort required to respond to the RAIs, and the NRC staff would be burdened by the need to review the applicant responses.
Alternative 2: Withdraw Regulatory Guide 1.212 Under this alternative, the withdrawal of RG 1.212 would leave a void in the NRCs regulatory guidance for the sizing of large lead-acid batteries. 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 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 1.212 Under this alternative, the NRC would update RG 1.212. One benefit of this action is it would enhance safety by providing up-to-date guidance and information on the sizing of large lead-acid batteries. In addition, it would improve the staffs ability to quickly review future applications. The costs to the NRC would be the one-time cost of issuing the revised RG (which is expected to be relatively small). Evaluating the sizing of large lead-acid batteries 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.
- 5. 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. The one-time cost would be offset by the avoidance of 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 the applicant relative to Alternative 2.
- 6. Decision Rationale Based on this regulatory analysis, the staff recommends that the NRC revise RG 1.212 to reflect the availability of new information. The staff concludes that the proposed action would enhance the safety of production and utilization facilities by providing up-to-date guidance and information on the sizing of large lead-acid batteries. Applicants and licensees can use this guidance to ensure that designs are constructed to be safe and to help ensure timely review by the NRC staff of the submitted designs.