ML17256A103

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DG-1388 (Rg 1.158) Public Comment Resolution Table
ML17256A103
Person / Time
Issue date: 03/31/2018
From:
Office of Nuclear Regulatory Research
To:
Burton S
Shared Package
ML17256A096 List:
References
DG-1338 RG-1.158, Rev.1
Download: ML17256A103 (2)


Text

Response to Public Comments on Draft Regulatory Guide (DG)-1338 Qualification of Safety-Related Vented Lead-Acid Storage Batteries for Nuclear Power Plants Proposed Revision 1 of Regulatory Guide (RG) 1.158 On May 31, 2017, the NRC published a notice in the Federal Register (82 FR 24996) that Draft Regulatory Guide, DG-1338 (Proposed Revision 1 of RG 1.158), was available for public comment. The public omment period ended on July 31, 2017. The NRC received comments from the organizations listed below. The NRC has combined the comments and NRC staff responses in the following table.

Comments were received from the following:

Michael Berg First Energy Nuclear Operating Company 76 South Main Street Akron, Ohio 44308 ADAMS Accession No. ML17207A103 Commenter Section of DG-1338 Specific Comments NRC Resolution Michael Section B Safety-related batteries and battery racks The NRC staff agreed with the comment and Berg Discussion/Background undergo a qualification program for the made changes to the RG. The revision verification that the battery meets or exceeds included the replacement of the battery to its design specification throughout its installed each battery to ensure it is not exclusive to life." Consider replacing "the battery" with one particular battery.

"each battery" to clarify that the qualification program is not exclusive to one specific battery.

Michael Section B The predominant failure mechanism for the The NRC staff agreed with the comment and Berg Discussion/Background batteries are addressed" employs a singular made changes to the RG. The revision subject and a plural verb. Consider changing included the predominant failure mechanism the clause to "the predominant failure for the batteries is addressed.

mechanism for the batteries is addressed" or "the predominant failure mechanisms for the batteries are addressed.

Month Year

Commenter Section of DG-1338 Specific Comments NRC Resolution Michael Section B The type testing methodology provides The NRC staff agreed with the comment and Berg Discussion/Background qualification guidance for batteries to made changes to the RG. The revision demonstrate the battery's capacity and replaced the batterys capacity and capability to perform its design function. capability with each batterys capacity and Consider replacing "the battery's capacity" capability to clarify that the type of testing is with "each battery's capacity" to clarify that the not exclusive to one particular battery.

type testing method is not exclusive to one specific battery.

Michael Section B The IEEE Std. 450 (as endorsed by RG 1.129) The NRC staff agreed with the comment.

Berg Discussion/Background and IEEE Std. 484 (as endorsed by RG 1.128) However, the section was deleted because it provides the user with a general guide to was duplicative of a regulatory position in qualify vented lead-acid batteries in nuclear Section C.

power plants employs a plural subject and a singular verb. Consider replacing "provides" with provide.

Michael Section B IAEA Safety Guide No. 34 address the The NRC staff agreed with the comment and Berg Discussion/Background management, verification, testing, and made changes to the RG. The revision documentation of the electrical power systems replaced the verb address with addresses.

design and components. The subject is singular, and the verb is plural. Consider replacing "address" with "addresses."

Michael Section B There's additional applicable sections .... " The NRC staff agreed with the comment and Berg Discussion/Background The subject is plural, and the verb is singular. made changes to the RG. The revision Consider replacing There's" with "There are." replaced theres with there are.

Michael Throughout the RG The word "methodology" is used where The NRC staff agreed with the comment and Berg "method" is more appropriate. made the appropriate changes to ensure Refer to Section 7 of the NRC Editorial Style there is a proper use of plain language.

Guide (NUREG-1379), which discusses the use of plain language.

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