ML18093A676
| ML18093A676 | |
| Person / Time | |
|---|---|
| Issue date: | 02/28/2019 |
| From: | Office of Nuclear Regulatory Research |
| To: | |
| O'Donnell E | |
| Shared Package | |
| ML18093A659 | List: |
| References | |
| DG-1328 RG-1.100 | |
| Download: ML18093A676 (2) | |
Text
REGULATORY ANALYSIS DRAFT REGULATORY GUIDE DG-1328 Seismic Qualification of Electrical and Mechanical Equipment for Nuclear Power
- Plants, (Proposed Revision 4 of Regulatory Guide 1.100, dated September, 2009)
- 1.
Statement of the Problem The U.S. Nuclear Regulatory Commission (NRC) issued Revision 3 of Regulatory Guide 1.100, Seismic Qualification of Electric and Mechanical Equipment for Nuclear Power Plants, in September 2009 to describe acceptable methods for complying with the NRCs regulations governing the seismic qualification of nuclear power plant electrical [including instrumentation and control (I&C) components] and active mechanical equipment that are important to safety.
With some exceptions and clarifications, Revision 3 endorsed IEEE Std 344-2004 and ASME QME-1-2007. Subsequently these standards were revised and the current versions are IEEE Standard 344-2013 and ASME QME-1-2017. Consideration needs be given to updating RG 1.100 to endorse the revised standards.
- 2.
Objectives The objective of the regulatory action is to assess the need to update the NRCs guidance in the area of seismic qualification of electrical and active mechanical equipment, and functional qualification of active mechanical equipment.
- 3.
Alternatives and Consequences of the Proposed Action The NRC staff considered the following alternative approaches for providing NRC guidance on seismic qualification of electrical and active mechanical equipment for nuclear power plants:
- 1. Do not revise Regulatory Guide 1.100.
- 2. Withdraw Regulatory Guide 1.100.
- 3. Revise Regulatory Guide 1.100.
3.1 Alternative 1: Do Not Revise Regulatory Guide 1.100 Under this alternative, the NRC would not revise RG 1.100 and applicants would continue to use the present version of this regulatory guide. This is considered the No Action alternative. If NRC takes no action, there would be no initial cost to NRC in revising the guide.
However, the no-action alternative would not provide an update to newer standards or include knowledge and experience gained on the seismic effects on mechanical and electrical equipment since 2009. This may result in the need for NRC to request additional information (RAI) from applicants. The requests would impose a burden on applicants to respond to the RAIs and on the NRC staff to review the responses.
3.2 Alternative 2: Withdraw Regulatory Guide 1.100 Withdrawing this regulatory guide would eliminate the guidance regarding the seismic qualification of mechanical and electrical equipment in a nuclear power plant. Applicants would be impacted by a withdrawal by having to propose and justify criteria to establish equipment qualifications. NRC staff would be impacted by being required to review the alternate methods and procedures. The review may result in an increase in the number of RAIs which could extend the length of the review. Applicants would be burdened by the effort required to respond to the RAIs.
3.3 Alternative 3: Revise Regulatory Guide 1.100 Under this alternative, the NRC would revise Regulatory Guide 1.100. Revising the guide would provide the following benefits:
(1) Licensees would have guidance on the use of the latest industry standards related to the seismic qualification of electrical and active mechanical equipment, and functional qualification of active mechanical equipment.
(2) Regulatory efficiency would be improved by reducing uncertainty as to what is acceptable and by encouraging consistency in the seismic qualification of electrical and active mechanical equipment, and the functional qualification of active mechanical equipment.
Benefits to the industry and the NRC will accrue to the extent this occurs. NRC reviews would be facilitated because licensee submittals would be more predictable and consistent.
(3) Both the NRC and the nuclear industry would realize cost savings. From the NRCs perspective, relative to the baseline, the NRC will incur one-time incremental costs to issue the revised regulatory guide. However, the NRC should also realize cost savings associated with the review of licensee and applicant submittals. In the staffs view, the ongoing cost savings associated with these reviews should more than offset the one-time cost. For industry, they will be clear about the NRC positions on the revised industry consensus standards. The NRC staff expects that industry would realize a net savings by the efficiencies (e.g., minimized follow-up questions, and revisions) associated with each licensee submission. The impact on the NRC would be the costs associated with preparing and issuing the regulatory guide. New applications and amendments would benefit from updated guidance by reducing the need for RAIs.
- 4.
Conclusion Based on this regulatory analysis, the staff believes a revision of Regulatory Guide 1.100 is warranted. The staff concludes that the proposed action will clarify NRCs positions on the revised industry consensus standards related to seismic qualification of electrical and active mechanical equipment, and functional qualification of active mechanical equipment.