ML23198A312
| ML23198A312 | |
| Person / Time | |
|---|---|
| Issue date: | 01/19/2024 |
| From: | Hartage K NRC/NRR/DEX/EEEB |
| To: | |
| Shared Package | |
| ML23198A308 | List: |
| References | |
| DG-1386 RG 1.73 Rev 2 | |
| Download: ML23198A312 (6) | |
Text
Responses to Public Comments on Draft Regulatory Guide (DG)-1386 Qualification of Safety-Related Actuators in Production and Utilization Facilities Proposed Revision 2 to Regulatory Guide 1.73
On May 22, 2023, the U.S Nuclear Regulatory Commission (NRC) pu blished a notice in the Federal Register (88 FR 32693) that Draft Regulatory Guide (DG)-1386 (Proposed Revision 2 to Regulatory Guide (RG) 1.73) was available for public comment. The public c omment period ended on June 21, 2023.
The NRC received comments from individuals listed in the table below. This document identifies how the NRC dispositioned the comments received. The comments are quote d verbatim in italics.
Comment Submission No. Commenter ADAMS Accession No.
1 (Six Comments) Richard T. McCarty ML23178A045 Winston & Strawn LLP 1901 L Street, N.W.
Washington, D.C. 20036-0081
2 (Two Comments) Suresh Channarasappa ML23178A048 Westinghouse Electric Co. LLC 1000 Westinghouse Dr.
New Stanton, PA 15672
Comment 1-1:
The regulatory guidance section is missing RG 1.183, which is specifically addressed in C.2 of DG-1386.
Also see Comment 3. Consider including RG 1.183 in the Related Guidance section.
NRC Response
The staff agrees with the comment and revised the RG to include RG 1.183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear P ower Reactors, in the Regulatory Guidance section.
Comment 1-2
The stated staff position in C.1 that operational experience is not an adequate method for qualifying equipment should be deleted because it is contrary to 10 CFR 50.49(f)(3), which specifically allows the use of experience with identical or similar equipmen t under similar conditions with a supporting analysis as a qualification method to show that the equipment to be qualified is acceptable.
The methods of qualification in Section 4.2 of IEEE 382-2019 are identified as deriving from IEC/IEEE-60780-323. Specifically, the discussion on Operating Experience as a qualification method in Section 4.2(b) of IEEE 382-20 19 is identical to the discussion in Section 6.1.2 of IEC/IEEE-60780-323-2016 (endorsed by RG 1.89 (Rev. 2).
Therefore, the statement in C.1 could be in terpreted as a new staff position in that:
- It contradicts the allowed qualification method in § 50.49(f)(3).
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- Section C.1 of DG-1386 is inconsistent with IEC/IEEE-60780-323-2016 as endorsed by RG 1.89 (Rev. 2), which is a normative referen ce to IEEE 382-2019. This inconsistency is germane because the NRC staff did not include in RG 1.89 (Rev 2) any specific clarification or exception to Section 6.1.2, Operating Exp erience of IEC/IEEE-607803-323-2016 as a qualification method.
- Section C.3 of RG 1.73 R1, which endors es IEEE 382-2006, states that applicants and licensees should perform environmental qualificati on of safety-related actuators using the guidance in RG 1.89. Revision 1 of RG 1. 89 endorses Section 6.4 of IEEE 323-1974, which contains specific guidance on the applicati on of Operating Experience as a qualification method without clarification or exception.
Delete statement that The staff finds that op erational experience is not an adequate method for qualifying equipment or reword so that it is not in conflict with 10 CFR 50.49(f)(3) or RG 1.89 R2.
NRC Response
The staff agrees with the comment. The staff revised the RG to delete the statement operational experience is not an adequate m ethod for qualifying equipment to ensure consistency with RG 1.89.
Comment 1-3
The following comment is similar to a previous NUGEQ comment on DG-1361 that was addressed as reflected in Revision 2 to RG 1.89 that RG 1.183 is not the only approved methodology for accident source terms As a result, there should be consiste ncy in the discussion of radiological source terms used to establish qualification between RG 1.89 R2 and DG-1386.
This draft regulatory guide makes no provision or allowance for the continued use of TID-14844 as a radiological source term for environmental qualific ation purposes. The wording in C.2 specifically focuses on AST, which would be appropriate for new plants, but not necessarily applicable to the qualification of actuators for existing plants. DG-1386 should expand upon and clarify the continued acceptability of source terms based on TID-14844 for EQ purposes in a manner that is consistent with RG 1.89 R2.
Also, the guidance on the applicable source term for EQ should be consistent with the resolution of GSI-187, which concluded that licensees may continue to use TID-14844 for EQ even if they adopt AST (See ML011210348). The NRC staff concluded that there is no clear basis for backfitting the requirements to modify the design basis for equipmen t qualification to adopt the AST.
DG-1386 should provide wording similar to the cl arification for RG 1.183 in the Related Guidance section of RG 1.89 R2 that RG 1.183 is not the only approved methodology for accident source terms and while other accident source term methodologies are not specifically reference in RG 1.89 R2, approved accident source term methodologies may continue to be used provided they remain applicable.
NRC Response
The staff partially agrees with the comment. The staff disagrees that DG-1386 should expand upon and clarify the continued acceptability of source terms based on TID-14844 for EQ purposes in a manner that is consistent with RG 1.89 R2. T he staff references RG 1.183 wh ich clarifies the use of TID-14844 as a radiological source term for envi ronmental qualification purposes.
Page 2 However, the staff agrees that RG 1.183 is not the only approve d methodology for accident source terms and additional source term met hodologies may be approved in the future. The staff revised the Related Guidance section of the RG to include RG 1.183 Alternative Ra diological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors to discuss additional methodologies to be used for EQ.
Comment 1-4
The position in C.4.3 goes beyond clarifying the guidance in Section 16 of IEEE 382-2016, Seismic Simulation Test and can be interpreted to imply that IEEE 382-2019 does not provide a full set of qualification requirements without being supplemen ted by ASME QME-1-2017 (as endorsed by RG 1.100 R4) for qualification of power operated valves.
It should be recognized that IEEE Std 382-2019 is sp ecific to qualification of valve actuators and that there can be additional requirements relative to ensu ring functional qualification of valve assemblies without implying that IEEE 382-2019 is deficient in providing comprehensive guidance for the qualification of valve actuators as well as avoiding a potential circular reference scheme. Note that ASME QME-1-2017 states that environmental qualific ation of actuators is performed in accordance with IEEE Std 323 and IEEE Std 382, which also in volves IEEE Std 344. So simply pointing back to ASME QME-1-2017 or RG 1.100 R4 to address envir onmental or seismic qualification is circular in nature. Because functional qualific ation in QME-1 focuses on valve assembly performance, it covers different aspects of qualification from envi ronmental qualification of actuators.
Plants not currently committed to ASME QME-1 have s upplemented the environmental qualification per IEEE Std 323 and IEEE Std 382 with programs that are specific to power operated valves that were developed in response to generic communications such as GL 89-10 and GL-96-05. These programs were put in place prior to the first endorsement of QME-1-2007 in 2009 by RG 1.100 R3 and were recently the subject of NRC inspection under IP 711 11.21N.02. The position in C.4.3 does not appear to address, account for, or acknowledge that licensees may address functional qualification of valve actuator assemblies by supplementing qualificatio n developed in accordance with IEEE 382 in the manner discussed above. Therefore, to address plants not committed or licensed to ASME QME 2007 or -2017, this DG should recognize or address other me thods acceptable to the staff that are being implemented to supplement the qualification basis est ablished in accordance with IEEE 382 in a manner that provides reasonable assurance of actuator performance.
Also see comment 5. See Comment and recommend that C.4.3 become a standalone clarification (e.g.,
C.5).
NRC Response
The staff agrees that other programs may be used to satisfy fun ctional qualification requirements, as noted by the commenter. The NRC issues Regulatory Guides to provide a n acceptable approach to meeting regulatory requirements. RG 1.73 provides an acceptable approach for meeting the environmental qualification requirements for saf ety-related power-operated valve actuators, but it does not address other aspects of qualification, such as functional qualification. The staff provided a reference to RG 1.100 which describes methods that the NRC staff considers acceptable for use in the seismic qualification of electrical and active mechanical equipment and the functional q ualification of active mechanical equipment for nuclear power plant s, but this reference is not i ntended to provide an exhaustive list of options available to meet regulat ory requirements for qualifica tion.
Page 3 The staff agrees with the comment. The staff revised the RG to delete seismic because RG 1.100 addresses seismic qualification. The staff also revised the RG to make C 4.3 to a standalone regulatory position C.6 and revised the RG to clarify that RG 1.100 is ref erenced as an example.
Comment 1-5
The qualification of valve actuators under IEEE 382-201 9 includes consideration of seismic testing per IEEE Std 344, since it is a normative reference. So ot her than the clarifications provided in C.4.1 and C.4.2 (which are the same as C.9.1 and C.9.2 in RG 1.73 R1), DG-1386 should specifically clarify what other elements of seismic qualification are missing from IEEE 382-2019 or delete the term seismic from the phrase such as seismic and functional qualification.
NRC Response
The staff agrees with the comment. The staff revised the RG to delete the word seismic from this phrase.
Comment 1-6
Per IEEE 382-2019, undated references require the use of the latest edition of the referenced document.
DG-1386 provides no clarification on undated normative references such as IEEE 344. In the case of IEEE 344, this would involve the application of IEC/IEEE-60980-344-2020, wh ich is not a currently endorsed edition.
Clarification Request: Therefore, DG-1386 should pr ovide specific guidance on the use of normative references that may not be part of the current licensing ba sis for a plant in a manner similar to what is set forth in C.5 of RG 1.73 Rev 1. See Comment for the requested clarification.
NRC Response
The staff agrees with the comment. In the RG, the staff added C.2 to the Staff Regulatory Guidance section to replace, the normative reference IEEE Std. 344 with the RG 1.100, Seismic Qualification of Electric and Mechanical Equipment for Nuclear Power Plants.
Comment 2-1:
Section C Item 1 makes the following statement:
Acceptable qualification methods include type testing, analysis, or a combination thereofThe staff finds that operational experience is not an adequate method for qualifying equipment.
The proposed elimination of the use of operating exp erience as part of qualification as included in DG-1386 is in conflict with existing and established NRC guidance and regulations.
The NRC has previously issued RG 1.89 REV 1 endorsing IEEE 323-1974 and RG 1.89 REV 2 endorsing IEC/IEEE 60780/323-2016. Both the NRC RGs and versions of IEEE 323 include the method of operating experience. NRC RG 1.89 is a reference included within DG-1386.
NRC Regulation 10 CFR 50.49 Section (f)(3) whic h allows Experience with identical or similar equipment under similar conditions with a sup porting analysis as an acceptable qualification methodology.
Page 4 The previous REV 1 to RG 1.73 endorsed I EEE 382-2006 which also included the use of operating experience as taken from IEEE 323-2 003, and RG 1.73 REV 1 did not take any exception to its use.
This statement appears to be a new NRC position and is recommended to be deleted from DG-1386 based on the existing approved NRC guidance and regulations.
NRC Response:
The staff agrees with the comment and has revised the RG to del ete the statement operational experience is not an adequate method for qua lifying equipment to ensure c onsistency with RG 1.89.
Comment 2-2
Section C Item 4.3 makes the following statement:
IEEE Std. 382-2019 does not provide a full set of the qualification requirements for valve actuators.
The users of this RG should address the other asp ects of the qualification process (such as seismic and functional qualification) for power operated valves, as described in RG 1.100, which accepts the use of American Society of Mechanical Engin eers (ASME) Standard QME-1-2017, Qualification of Active Mechanical Equipment Used in Nuclear Facilities (Ref. 20), with specific conditions. ASME Standard QME-1-2017 includes more stringent provisions for the functional qualification of power-operated valves than the ones specified in IEEE Std. 382-2019, including acceptable qualification methods, actuator grouping, actuator output ca pability testing, and extrapolation of actuator qualification.
This is a new addition to the draft DG-1386 Sta ff Regulatory Guidance items compared to the previous RG 1.73 REV 1 which did not include this as part of the endorsement of IEEE 382-2006. In DG-1386, it is stating that ASME QME-1-2017 is re quired to be used with IEEE 382-2019 for the full acceptable environmental qualification of actuators.
RG 1.73 REV 1 included a reference to ASME QME-1-2007 under Related Guidance. However, there were no specific regulatory positions tied to AS ME QME-1-2007 included under Section C Staff Regulatory Guidance of RG 1.73 REV 1 for the endorsement and use of IEEE 382-2006 for qualification of actuators. This change is new to DG-13816 for pending RG 1.73 REV 2.
IEEE 382-2019 qualification programs can include additional information via ASME QME-1-2017 activities. However, the current wording in DG-1386 Section C Item 4.3 implies that the use of IEEE 382-2019 is not adequate in establishing the environmental qualification for actuators without ASME QME-1-2017 qualification which is fo cused on mechanical qualification. The purpose of DG-1386 is for the endorsement of IEEE 382-2019 for the en vironmental qualification of actuators.
It is recommended that the current wording of DG-1386 Section C Item 4.3 be revised to clarify the use of IEEE 382-2019 as being adequate and accep table for the environmental qualification of actuators.
NRC Response:
The staff partially agrees with the comment as discussed above in NRC Response to Comment 1-2. The staff disagrees to the extent that the comment is asserting that DG-1386 requires ASME QME-1-2017 to
Page 5 be used with IEEE 382-2019 for the full acceptable environmenta l qualification of actuators. RG 1.100 provides guidance for the qualification of all aspects of activ e mechanical equipment (such as safety-related actuators), including seismic, environmental, and funct ional qualification. RG 1.73 provides guidance for one portion (environmental qualification) of the q ualification of safety-related actuators.
The staff considers RG 1.73 to be clear regarding this limitati on in its scope. As discussed in Comment 1-4, DG-1386 was revised to clarify that RG 1.100 is referenced as an example. No additional changes to DG-1386 were made as a result of this comment.
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