ML23158A216

Comment (2) of Alan Campbell on Draft Regulatory Guide: Guidelines for Lightning Protection for Production and Utilization Facilities

ML23158A216
Person / Time
Site:	Nuclear Energy Institute
Issue date:	06/02/2023
From:	Andy Campbell Nuclear Energy Institute
To:	Office of Administration
References
NRC-2023-0089, 88FR27714 00002, DG-1409
Download: ML23158A216 (1)

Text

6/7/23, 1:38 PM blob:https://www.fdms.gov/2ad4e4d3-2378-45db-b85e-f2bfe7748e86 blob:https://www.fdms.gov/2ad4e4d3-2378-45db-b85e-f2bfe7748e86 1/1 PUBLIC SUBMISSION As of: 6/7/23, 1:38 PM Received: June 02, 2023 Status: Pending_Post Tracking No. lie-ngj9-cqgd Comments Due: June 02, 2023 Submission Type: Web Docket: NRC-2023-0089 Draft Regulatory Guide: Guidelines for Lightning Protection for Production and Utilization Facilities Comment On: NRC-2023-0089-0001 Draft Regulatory Guide: Guidelines for Lightning Protection for Production and Utilization Facilities Document: NRC-2023-0089-DRAFT-0004 Comment on FR Doc # 2023-09390 Submitter Information Email:atb@nei.org Organization:Nuclear Energy Institute General Comment See attached file(s)

Attachments 06-02-2023 NEI Comments on DG-1409 SUNSI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Joseph Bridget Curran, Jim Steckel, Mary Neely Comment (2)

Publication Date: 5/3/2023 Citation: 88 FR 27714

ALAN CAMPBELL Technical Advisor, Technical and Regulatory Services 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8011 adc@nei.org nei.org June 2, 2023 Office of Administration U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Program Management, Announcements and Editing Staff Submitted via regulations.gov

Subject:

NEI Comments on Draft Regulatory Guide DG-1409, Guidelines for Lightning Protection for Production and Utilization Facilities (Docket ID NRC-2023-0089)

Project Number: 689

Dear Program Management,

Announcements, and Editing Staff:

The Nuclear Energy Institute (NEI)1, on behalf of our members, appreciates the opportunity to comment on draft regulatory guide DG-1409 (RG 1.204, Rev. 1). NEI recognizes the importance of ensuring NRC endorsed guides and standards represent modern approaches to addressing technical requirements.

However, the scope of the proposed, endorsed IEEE guides exceeds that of the technical topic being addressed (i.e., lightning protection) and the draft regulatory guidance is unclear whether the endorsed IEEE guides are intended to be used for informational purposes or strict regulatory conformance.

Each of the four (4) primary references proposed for endorsement (IEEE 665-1995, IEEE 666-2007, IEEE 1050-2004, IEEE C62.23-2017) provides limited guidance specific to lightning protection. For example, IEEE 665-1995 only contains guidance for lightning protection in Section 5.6; however, DG-1409 endorses the entire guide. These guides primarily provide guidance for grounding methods for both protection and noise elimination. Only the portions of the IEEE guides associated with lightning protection should be within the scope of this draft guide. Regulatory Guide 1.180 provides guidance for electromagnetic compatibility (EMC) issues. The broad endorsement of these IEEE guides, as currently described in the draft guide, present potential conflicts related to other regulatory guidance.

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 2, 2023 Page 2 Additionally, the four (4) primary references proposed for endorsement (IEEE 665-1995, IEEE 666-2007, IEEE 1050-2004, IEEE C62.23-2017) are IEEE Guides, not Standards. According to the IEEE Standards Association (IEEE SA) a standard is a document with mandatory requirements, whereas a guide is a document in which alternative approaches to good practice are suggested but no clear-cut recommendations are made. The endorsement of these Guides results in unclear expectations regarding their intended use (i.e., informational purposes vs. conformance) since these documents provide no clear-cut recommendations, nor mandatory requirements. The NRC should clarify the intended use of these endorsed guides (and their associated secondary references) to meet regulatory requirements.

We appreciate the opportunity to provide comments on DG-1409 and encourage your consideration of NEIs comments prior to finalizing and publishing the regulatory guide. Please contact me at adc@nei.org or (202) 439-3698 with any questions or comments.

Sincerely, Alan Campbell

Comments on DG-1409 Cc:

Roy Hardin (RES/DE/ICEEB)

James Steckel (RES/DE/RGPMB)

Comments on DG-1409 Section Comment Recommendation 1

C. Staff Regulatory Guidance Each of the four (4) primary references proposed for endorsement (IEEE 665-1995, IEEE 666-2007, IEEE 1050-2004, IEEE C62.23-2017) provides limited guidance specific to lightning protection. For example, IEEE 665-1995 only contains guidance for lightning protection in Section 5.6; however, DG-1409 endorses the entire guide. These guides primarily provide guidance for grounding methods for both protection and noise elimination. Only the portions of the IEEE guides associated with lightning protection should be within the scope of this draft guide. Regulatory Guide 1.180 provides guidance for electromagnetic compatibility (EMC) issues. The broad endorsement of these IEEE guides, as currently described in the draft guide, present potential conflicts related to other regulatory guidance.

NRC should specify the specific sections/requirements associated with lightning protection.

2 C. Staff Regulatory Guidance The four (4) primary references proposed for endorsement (IEEE 665-1995, IEEE 666-2007, IEEE 1050-2004, IEEE C62.23-2017) are IEEE Guides, not Standards. According to the IEEE Standards Association (IEEE SA) a standard is a document with mandatory requirements, whereas a guide is a document in which alternative approaches to good practice are suggested but no clear-cut recommendations are made. The endorsement of these Guides results in unclear expectations regarding their intended use (i.e., informational purposes vs. conformance) since these documents provide no clear-cut recommendations, nor mandatory requirements. The NRC should clarify the intended use of these endorsed guides (and their associated secondary references) to meet regulatory requirements.

NRC should clarify the intended use of these endorsed guides (and their associated secondary references) to meet regulatory requirements.