ML082810214: Difference between revisions

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{{#Wiki_filter:March 13, 2009 Response to Public Comments for Draft Regulatory Guide DG-1198, "Physical Models for Design and Operation of Hydraulic Structures and Systems for Nuclear Power Plants"  Proposed Revision 2 of Regulatory Guide (RG) 1.125 A notice that Draft Regulatory Guide DG-1198 (proposed Revision 2 to Regulatory Guide 1.125) was available for public comment was published in the Federal Register (73 FR 39731) on Thursday, July 10, 2008. The public comment period closed September 5, 2008. One set of comments was received from the organization identified below. The following table contains the comments and staff disposition.
{{#Wiki_filter:Response to Public Comments for Draft Regulatory Guide DG-1198, Physical Models for Design and Operation of Hydraulic Structures and Systems for Nuclear Power Plants Proposed Revision 2 of Regulatory Guide (RG) 1.125 A notice that Draft Regulatory Guide DG-1198 (proposed Revision 2 to Regulatory Guide 1.125) was available for public comment was published in the Federal Register (73 FR 39731) on Thursday, July 10, 2008. The public comment period closed September 5, 2008. One set of comments was received from the organization identified below. The following table contains the comments and staff disposition.
Comments were received from: James H. Riley, Director of Engineering, Nuclear Generation Division Nuclear Energy Institute (NEI) 1776 I Street, NW, Suite 400 Washington, DC 20006 Phone: 202-739-8137   (ADAMS Accession No. ML082540323)
Comments were received from:
Comment NRC Response The draft regulatory guide DG-1198 provides an update to Regulatory Guide 1.125 (1978) and describes the detail and documentation of data and studies that an applicant should include in the PSAR or the FSAR to support the use of physical hydraulic model testing for predicting the performance of hydraulic structures and systems for nuclear power plants. The regulatory position of this guide is applicable only to physical models used to predict the action or interaction of surface waters with features located outside of containment. The recommendations of this guide do not apply to internal plant systems or structures. No response required. RG 1.125 only applied to modeling safety-related features located outside containment. Is the intent of the DG to bound both safety and non-safety related structures?   No. The guide has been revised to make it safety-related specific. The inclusion of pump designs does not appear to be consistent with the definition of hydraulic structures included in Section A of the DG. We recommend that pump designs be removed from DG-1198 or further explanation be provided on how to ensure pump designs comply with the DG. Wording of guide has been revised. Is it the intent of DG-1198 to remove investigation reports, such as the U.S. Army Experimental Waterways Station, as an acceptable means of demonstrating compliance? RG 1.125 found this kind of report to be acceptable. No. The reference to single report from the U. S. Army Waterways Experiment Station in Vicksburg, MS. was removed to clarify that multiple types of reports consistent with the regulatory position is acceptable.
James H. Riley, Director of Engineering, Nuclear Generation Division Nuclear Energy Institute (NEI) 1776 I Street, NW, Suite 400 Washington, DC 20006 Phone: 202-739-8137 (ADAMS Accession No. ML082540323)
March 13, 2009 Comment NRC Response Is it the intent of DG-1198 to encompass plants that now have FSAR vs. a PSAR? RG 1.125 applied only to PSARs. It is the intent of RG 1.125 to apply to all plants,   those licensed in accordance with 10 CFR Part 50 as well as those licensed in accordance with 10 CFR Part 52. Plants licensed in accordance with 10 CFR Part 52 will not have a PSAR.}}
Comment                                             NRC Response The draft regulatory guide DG-1198 provides an update to           No response required.
Regulatory Guide 1.125 (1978) and describes the detail and documentation of data and studies that an applicant should include in the PSAR or the FSAR to support the use of physical hydraulic model testing for predicting the performance of hydraulic structures and systems for nuclear power plants. The regulatory position of this guide is applicable only to physical models used to predict the action or interaction of surface waters with features located outside of containment. The recommendations of this guide do not apply to internal plant systems or structures.
RG 1.125 only applied to modeling safety-related features         No. The guide has been revised to make located outside containment. Is the intent of the DG to bound     it safety-related specific.
both safety and non-safety related structures?
The inclusion of pump designs does not appear to be consistent Wording of guide has been revised.
with the definition of hydraulic structures included in Section A of the DG. We recommend that pump designs be removed from DG-1198 or further explanation be provided on how to ensure pump designs comply with the DG.
Is it the intent of DG-1198 to remove investigation reports, such No. The reference to single report from as the U.S. Army Experimental Waterways Station, as an             the U. S. Army Waterways Experiment acceptable means of demonstrating compliance? RG 1.125             Station in Vicksburg, MS. was removed found this kind of report to be acceptable.                       to clarify that multiple types of reports consistent with the regulatory position is acceptable.
March 13, 2009
 
Comment                                         NRC Response Is it the intent of DG-1198 to encompass plants that now have It is the intent of RG 1.125 to apply to all FSAR vs. a PSAR? RG 1.125 applied only to PSARs.             plants, those licensed in accordance with 10 CFR Part 50 as well as those licensed in accordance with 10 CFR Part
: 52. Plants licensed in accordance with 10 CFR Part 52 will not have a PSAR.
March 13, 2009}}

Latest revision as of 13:18, 14 November 2019

Response to Public Comments for Draft Regulatory Guide DG-1198
ML082810214
Person / Time
Issue date: 03/13/2009
From:
Office of Nuclear Regulatory Research
To:
Orr M P/RES/301-415-6373
Shared Package
ML082810194 List:
References
DG-1198, RG-1.125 Rev 2
Download: ML082810214 (2)
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Text

Response to Public Comments for Draft Regulatory Guide DG-1198, Physical Models for Design and Operation of Hydraulic Structures and Systems for Nuclear Power Plants Proposed Revision 2 of Regulatory Guide (RG) 1.125 A notice that Draft Regulatory Guide DG-1198 (proposed Revision 2 to Regulatory Guide 1.125) was available for public comment was published in the Federal Register (73 FR 39731) on Thursday, July 10, 2008. The public comment period closed September 5, 2008. One set of comments was received from the organization identified below. The following table contains the comments and staff disposition.

Comments were received from:

James H. Riley, Director of Engineering, Nuclear Generation Division Nuclear Energy Institute (NEI) 1776 I Street, NW, Suite 400 Washington, DC 20006 Phone: 202-739-8137 (ADAMS Accession No. ML082540323)

Comment NRC Response The draft regulatory guide DG-1198 provides an update to No response required.

Regulatory Guide 1.125 (1978) and describes the detail and documentation of data and studies that an applicant should include in the PSAR or the FSAR to support the use of physical hydraulic model testing for predicting the performance of hydraulic structures and systems for nuclear power plants. The regulatory position of this guide is applicable only to physical models used to predict the action or interaction of surface waters with features located outside of containment. The recommendations of this guide do not apply to internal plant systems or structures.

RG 1.125 only applied to modeling safety-related features No. The guide has been revised to make located outside containment. Is the intent of the DG to bound it safety-related specific.

both safety and non-safety related structures?

The inclusion of pump designs does not appear to be consistent Wording of guide has been revised.

with the definition of hydraulic structures included in Section A of the DG. We recommend that pump designs be removed from DG-1198 or further explanation be provided on how to ensure pump designs comply with the DG.

Is it the intent of DG-1198 to remove investigation reports, such No. The reference to single report from as the U.S. Army Experimental Waterways Station, as an the U. S. Army Waterways Experiment acceptable means of demonstrating compliance? RG 1.125 Station in Vicksburg, MS. was removed found this kind of report to be acceptable. to clarify that multiple types of reports consistent with the regulatory position is acceptable.

March 13, 2009

Comment NRC Response Is it the intent of DG-1198 to encompass plants that now have It is the intent of RG 1.125 to apply to all FSAR vs. a PSAR? RG 1.125 applied only to PSARs. plants, those licensed in accordance with 10 CFR Part 50 as well as those licensed in accordance with 10 CFR Part

52. Plants licensed in accordance with 10 CFR Part 52 will not have a PSAR.

March 13, 2009

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