ML22307A144

DG-1418 (RG 1.212 Rev 2) Regulatory Analysis

ML22307A144
Person / Time
Issue date:	02/27/2023
From:	Liliana Ramadan NRC/NRR/DEX/EEEB
To:
Sahle, S
Shared Package
ML22304A007	List: ML22307A132 ML22307A144 ML22307A248
References
RG 1.212 Rev 2 DG 1418
Download: ML22307A144 (2)

Text

REGULATORY ANALYSIS

DRAFT REGULATORY GUIDE DG-1418

SIZING OF LARGE LEAD-ACID STORAGE BATTERIES

(Proposed Revision 2 of Regulatory Guide 1.212, Revision 1 issu ed October 2015)

1. Introduction

This document presents the results of a regulatory analysis of the U.S. Nuclear Regulatory Commissions (NRCs) determination of whether to iss ue Draft Regulatory Guide (DG)-1418 (proposed Revision 2 of Regulatory Guide (RG) 1.212), Sizing of Large Lead-Acid Storage Batteries. The analysis provides the public with an in sight into how the NRC arrives at a decision.

2. Statement of the Problem

The NRC staff developed the current version (Revision 1) of RG 1.212 in October 2015, which endorsed Institute of Electrical and Electronics Engineer s (IEEE) Standard (Std.) 485-2010, IEEE Recommended Practice for Sizing Lead-Acid Batteries for Stationary Applications.

IEEE Std. 485 was revised in 2020 and, it is expected that curr ent licensees and new applicants, including advanced r eactor and small modular reacto r applicants, would use the new standard endorsed in a revised RG. Therefore, the staff needs t o determine whether revision of this RG is warranted to provide guidance that reflects updated information to address the sizing of large lead-acid batteries.

3. Objective

The objective of this regulatory action is to assess the need t o update RG 1.212 to incorporate the 2020 version of IEEE 485 guidance for applicant s and licensees of production and utilization facilitates.

4. Alternative Approaches

The staff considered three alternative approaches:

(1) Do not revise RG 1.212.

(2) Withdraw RG 1.212.

(3) Update RG 1.212

Alternative 1: Do Not Revise Regulatory Guide 1.212

Under this alternative, the NRC would not revise this guidance, and applicants would continue to use the present version of the guide. This is consi dered the No-Action alternative.

If NRC takes no action, there would be no initial cost to the N RC to revise the guide. However, the No-Action alternative would not provide updated informati on to address the sizing of large lead-acid batteries.

1 This may result in the NRC issuing requests for additional info rmation (RAIs) to applicants. Applicants would be burdened by the effort required to respond to the RAIs, and the NRC staff would be burdened by the need to review the applicant responses.

Alternative 2: Withdraw Regulatory Guide 1.212

Under this alternative, the withdrawal of RG 1.212 would leave a void in the NRCs regulatory guidance for the sizing of large lead-acid batteries. By eliminating guidance for future applicants, the content of future applications could vary from applicant to applicant, thereby making the review of these applications more burdensome for the staff. The burden on applicants would be greater under this alternative because with out specific guidance, applicants might spend more time preparing applications and potentially re sponding to RAIs.

Alternative 3: Update Regulatory Guide 1.212

Under this alternative, the NRC would update RG 1.212. One benefit of this action is it would enhance safety by providing up-to-date guidance and infor mation on the sizing of large lead-acid batteries. In addition, it would improve the staffs ability to quickly review future applications. The costs to the NRC would be the one-time cost o f issuing the revised RG (which is expected to be relatively small). Evaluating the sizing of l arge lead-acid batteries is required regardless of the existence or currency of the RG, so applicant s would incur little or no additional cost relative to Alternative 1. Updated regulatory g uidance might reduce the applicants cost relative to Alternative 2.

5. Comparison of Alternatives

Alternative 1 is considered the baseline or No-Action alterna tive and, as such, involves no value/impact considerations. Alternative 2 would make applic ation review more burdensome for the staff and very likely make application preparation more burdensome for applicants.

Alternative 3 would impose a one-time additional cost to the NR C relative to Alternatives 1 and 2. The one-time cost would be offset by the avoidance of th e burdens imposed by Alternative 2. Alternative 3 would not impose significant addit ional costs on applicants relative to Alternative 1 and could possibly result in reduced costs to the applicant relative to Alternative 2.

6. Decision Rationale

Based on this regulatory analysis, the staff recommends that th e NRC revise RG 1.212 to reflect the availability of new information. The staff concl udes that the proposed action would enhance the safety of production and utilization facilities by providing up-to-date guidance and information on the sizing of large lead-acid batteries. Applica nts and licensees can use this guidance to ensure that designs are constructed to be safe and to help ensure timely review by the NRC staff of the submitted designs.

2