ML24040A165
| ML24040A165 | |
| Person / Time | |
|---|---|
| Issue date: | 04/18/2024 |
| From: | Darrell Murdock NRC/RES/DE/DICB |
| To: | |
| Shared Package | |
| ML23093A191 | List: |
| References | |
| RG-1.030, Rev 1 DG-1419 | |
| Download: ML24040A165 (2) | |
Text
1 Responses to Public Comments on Draft Regulatory Guide DG-1419 Installation, Inspection, and Testing for Class 1E Power, Instrumentation, and Control Equipment at Production and Utilization Facilities, Revision 1 to Regulatory Guide 1.30 On December 20, 2023, the U.S. Nuclear Regulatory Commission (NRC) published a notice in the Federal Register (88 FR 87967) that Draft Regulatory Guide, DG-1419 (Proposed Revision 1 to Regulatory Guide (RG) 1.30), was available for public comment. The public comment period ended on January 19, 2024. The NRC received comments from the individual listed below. The NRC has combined the comments and NRC staff responses in this document.
Comment Submission 1 ADAMS Accession No. ML24019A024 Name: Yvonne Williams Address: Kennewick, WA 99337 Email: dinorupert@gmail.com Comment 1-1 Page 2, 2nd bullet on page:
The bullet addresses GDC 1 and is led into by the 1st bullet; it is subordinate to the first bullet. Suggest either indenting this bullet for GDC 1 or moving the content up into the end of the first bullet. This second suggestion would result in the GDC bullet ending with:
The GDC related to quality assurance (QA) is GDC 1, Quality standards and records, which requires, in part, that SSCs important to safety be designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety functions to be performed.
NRC Comment 1-1 Response The NRC agrees with the comment. The staff fixed the bulleting in RG 1.30, Revision 1.
Comment 1-2 Page 4, Background, 2nd paragraph:
The second paragraph states The revised IEEE Std 336-2010 incorporates The correct date for the revised IEEE standard is 2020.
NRC Comment 1-2 Response The NRC agrees with the comment. The staff fixed the date of the standard in RG 1.30, Revision 1.
Comment 1-3 Page 6, last paragraph:
It is not clear why RG 1.28 Rev 5 is referenced instead of Rev 6 (which endorses later versions of NQA-1). Note also that Reference 10 on page 8 is to Rev 6 of RG 1.28.
2 NRC Comment 1-3 Response The staff agrees with the comment and has updated DG-1419 to reflect Rev 6 and fix the error.
Comment 1-4 Page 6, last paragraph:
The Foreword of ANSI/ANS 3.2-2012 (page ii, last paragraph) indicates that the working group developed a major revision to the standard that separated the quality assurance controls from the managerial and administrative controls. Since the combination of ANSI/ASME NQA-1-2008 and NQA-1a-2009 Addenda and ANSI/ANS-3.2-2012, Managerial, Administrative, and Quality Assurance Controls for the Operational Phase of Nuclear Power Plants, provides the quality assurance requirements and the managerial controls necessary for safe operation of nuclear facilities, the working group continued with the objective to have ANS-3.2 supplement NQA-1 for operating plants. This industry guidance was fully coordinated with the ASME NQA-1 Standards Committee. This supplementing between ANSI/ANS 3.2-2012 and ASME NQA-1 is why IEEE Std 336-2020 references both of them in Clause 4.1 for the operations phase. I do not currently have access to ANSI/ANS 3.2 to see whether or how it references ASME NQA-1, so I can only share why the working group for IEEE Std 336 included both standards for the operations phase.
NRC Comment 1-4 Response The NRC does not agree nor disagree with the comment. The staff has removed all quality assurance guidance from RG 1.30 and instead points the user to the quality assurance guidance in RG 1.33 (Revision 3) for the operational phase. Thus, any changes made beyond the current version of ANSI/ANS 3.2-2012 endorsed by RG 1.33 (Revision 3) would fall outside the scope of RG 1.30. No changes were needed as a result of this comment.