NRC-2022-0151, Comment (1) of Jeff Bartelme on Qualification of Class 1E Battery Chargers, Inverters, and Uninterruptible Power Supply Systems for Production and Utilization Facilities
| ML23061A147 | |
| Person / Time | |
|---|---|
| Site: | SHINE Medical Technologies |
| Issue date: | 02/23/2023 |
| From: | Bartelme J SHINE Technologies |
| To: | Office of Administration |
| References | |
| NRC-2022-0151, 88FR6672 00001, 2023-SMT-0017, RG-1.210, Rev 1 | |
| Download: ML23061A147 (1) | |
Text
3/2/23, 2:33 PM blob:https://www.fdms.gov/fae38c3d-316e-4110-a6ab-2b2e76406463 SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 As of: 3/2/23, 2:31 PM Received: February 23, 2023 PUBLIC SUBMISSION ADD: Michael Eudy, Bridget Curran, Solomon Sahle, Status: Pending_Post Harriet Karagiannis, Amir Tracking No. leh-3ic2-xegt Mobasheran, Mary Neely Comments Due: March 03, 2023 Comment (1)
Publication Date: 2/1/2023 Submission Type: Web Citation:88 FR 6672 Docket: NRC-2022-0151 Qualification of Class 1E Battery Chargers, Inverters, and Uninterruptible Power Supply Systems for Production and Utilization Facilities Comment On: NRC-2022-0151-0001 Qualification of Class 1E Battery Chargers, Inverters, and Uninterruptible Power Supply Systems for Production and Utilization Facilities Document: NRC-2022-0151-DRAFT-0001 Comment on FR Doc # 2023-02012 Submitter Information Email: jeffbartelme@shinefusion.com Organization: SHINE Technologies, LLC General Comment See attached file(s)
Attachments 2023-SMT-0017 blob:https://www.fdms.gov/fae38c3d-316e-4110-a6ab-2b2e76406463 1/1
February 23, 2023 2023-SMT-0017 Submitted Via Regulations.gov Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission ATTN: Program Management, Announcements and Editing Staff Washington, DC 20555-0001
References:
(1) U.S. Nuclear Regulatory Commission, Qualification of Class 1E Battery Chargers, Inverters, and Uninterruptible Power Supply Systems for Production and Utilization Facilities, Draft Regulatory Guide DG-1412, January 2023 (ML22160A570)
SHINE Technologies, LLC Comments on the Proposed Revision 1 to Regulatory Guide 1.210 (Docket ID NRC-2022-0151)
SHINE Technologies, LLC (SHINE) appreciates the opportunity to comment on the NRCs proposed revision to Regulatory Guide 1.210, Qualification of Class 1E Battery Chargers, Inverters, and Uninterruptible Power Supply Systems for Production and Utilization Facilities (Reference 1).
Enclosure 1 provides the SHINE comments on Reference (1).
If you have any questions, please contact me at 608/210-1735.
Very truly yours, Jeff Bartelme Director of Licensing SHINE Technologies, LLC Docket No. 50-608 cc: Project Manager, USNRC 3400 Innovation Ct.
- Janesville, WI 53546
- 877.512.6554
- info@shinemed.com
- www.SHINEtechnologies.com
ENCLOSURE 1 SHINE TECHNOLOGIES, LLC SHINE TECHNOLOGIES, LLC COMMENTS ON THE PROPOSED REVISION 1 TO REGULATORY GUIDE 1.210 (DOCKET ID NRC-2022-0151)
The NRCs proposed revision to Regulatory Guide (RG) 1.210, Qualification of Safety-Related Battery Chargers and Inverters for Nuclear Power Plants (Reference 1), modifies the applicability of the RG from being specific to nuclear power plants to more generally applying to production and utilization facilities. This modification in intended applicability in the proposed revision (Reference 2) is apparent via the modification of the RG title and the described applicability, which states, in part, Under 10 CFR Part 50, this RG applies to licensees or applicants for nuclear power plants and utilization facilities.
The proposed modification in the applicability of the RG introduces confusion in the applicability to non-power production and utilization facilities (i.e., facilities other than nuclear power plants) licensed under 10 CFR Part 50. The described reason for revision in Section B. of the proposed revision to the RG states, in part, This revision (Revision 1) of RG 1.210 revises the title of the RG to clarify that other nuclear facilities are also within the scope of this RG; however, the revision provides no regulatory basis for expanding the scope of applicability. The applicable regulations listed in the proposed revision (i.e., 10 CFR 50.49(b)(1) and (c)(3);
10 CFR 50.55a(h)(3); Appendices A, B, and S to 10 CFR Part 50; and 10 CFR Part 52) are nuclear power plant-specific regulations and are not applicable to non-power production and utilization facilities. Additionally, the standard endorsed by the proposed revision to the RG, Institute of Electrical and Electronics Engineers (IEEE) Standard 650-2017, IEEE Standard for Qualification of Class 1E Static Battery Chargers, Inverters, and Uninterruptible Power Supply Systems for Nuclear Power Generating Stations (Reference 3), is specific to nuclear power plants.
In establishing the licensing basis for a first-of-its-kind facility, non-power production and utilization facility applicants have fewer industry codes and standards which are directly applicable to the facility as compared to nuclear power plants. The applicant is required to review a series of codes and standards developed specifically for other types of facilities, including nuclear power plants, to identify those codes and standards (or portions thereof) required to satisfy facility-specific design criteria, as SHINE did in establishing the licensing basis in our operating license application. As written, this proposed revision to the RG, with the expanded scope of applicability providing equivalent guidance to nuclear power plants and non-power production and utilization facilities, does not consider the relative risk of these non-power facilities against the risks associated with nuclear power plants. This may lead an applicant to believe compliance with IEEE Standard 650-2017, without any facility-specific exceptions, is required to meet regulatory requirements for qualification of safety-related battery chargers, inverters, and uninterruptible power supply systems at non-power production and utilization facilities.
As the listed applicable regulations and the IEEE standard itself are specific to nuclear power plants, SHINE recommends the applicability of the RG be reverted back to being specific to nuclear power plants, including revision to the title and the described applicability, to remove Page 1 of 2
reference to the more general production and utilization facilities. SHINE recommends the NRC instead propose a non-power production and utilization facility applicant consider the guidance provided in IEEE Standard 650-2017 on a voluntary basis and to the extent necessary to meet facility-specific design criteria and the relative risk of the facility. This proposal would be more appropriately captured in non-power production and utilization facility application guidance (e.g., a NUREG-series publication or Interim Staff Guidance), with appropriate context for the consideration of the standard, in lieu of establishing the consideration in a power reactor-specific division RG (i.e., a Division 1 series RG).
References
- 1. U.S. Nuclear Regulatory Commission, Qualification of Safety-Related Battery Chargers and Inverters for Nuclear Power Plants, Regulatory Guide 1.210, June 2008 (ML080640184)
- 2. U.S. Nuclear Regulatory Commission, Qualification of Class 1E Battery Chargers, Inverters, and Uninterruptible Power Supply Systems for Production and Utilization Facilities, Draft Regulatory Guide DG-1412, January 2023 (ML22160A570)
- 3. Institute of Electrical and Electronics Engineers, IEEE Standard for Qualification of Class 1E Static Battery Chargers, Inverters, and Uninterruptible Power Supply Systems for Nuclear Power Generating Stations, IEEE Standard 650-2017, New York, NY Page 2 of 2