1 REGULATORY ANALYSIS 
 
DRAFT REGULATORY GUIDE DG-1386 
 
QUALIFICATION OF SAFETY-RELATE D ACTUATORS IN PRODUCTION AND 
UTILIZATION FACILITIES 
 
(Proposed Revision 2 of Regulatory Guide 1.73, Revision 1, issu ed October 2013) 
 
1.  Introduction 
 This document presents the results of a regulatory analysis con ducted by the 
U.S. Nuclear Regulatory Commission (NRC) concerning its determi nation of whether to issue 
Draft Regulatory Guide (DG)-1386 (proposed Revision 2 of Regula tory Guide (RG) 1.73), 
“Qualification of Safety-Related Actuators in Production and Ut ilization Facilities.” The analysis 
provides the public with an insight into how the NRC arrives at  a decision. 
 2.  Statement of the Problem 
 
The NRC staff developed the current version (Revision 1) of RG 1.73 in October 2013 to 
endorse Institute of Electrical and Electronics Engineers (IEEE ) Standard (Std.) 382-2006, 
“Standard for Qualification of Safety-Related Actuators for Nuc lear Power Generating Stations.” 
However, the IEEE standard was revised in 2019. In September 20 20, the Office of Nuclear 
Reactor Regulation, Division o f Engineering and External Hazard s, and the Office of Nuclear 
Regulatory Research, Division of Engineering, agreed to conside r updating the RG to endorse 
the revised standard. As environmental qualification is a recen t focus area for the agency and 
licensees, the NRC expects that current licensees and new appli cants would use the new 
standard and revised RG. Further, the new standard and updated RG can be used in license 
renewals under 10 CFR Part 54 for replacing equipment or extend ing the qualified life. 
Therefore, the staff needs to determine whether revision of thi s RG is warranted to provide 
guidance that reflects updated information to address those ide ntified recommendations and 
current methodologies for the qualification of safety-related a ctuators in production and 
utilization facilities. 
 
3.  Objective 
 
The objective of this regulatory action is to assess the need t o provide up-to-date 
guidance for evaluating the qualification of safety-related act uators in production and utilization 
facilities. 
 
4.  Alternative Approaches 
 
The staff considered three alternative approaches:  
(1) Do not revise RG 1.73. (2) Withdraw RG 1.73. 
(3) Update RG 1.73. 
 2 Alternative 1: Do Not Revise Regulatory Guide 1.73 
 
Under this alternative, the NRC w ould not revise this guidance,  and applicants and 
licensees would continue to use the present version of the guid e. This is considered the 
“no-action” alternative. If the NRC took no action, there would  be no initial cost to the NRC to 
revise the guide. However, the no-action alternative would not provide updates to address the 
identified recommendations and current methodologies for the qu alification of safety-related 
actuators in production and utilization facilities. This may re sult in the NRC issuing requests for 
additional information (RAIs) to applicants and licensees. Appl icants and licensees would be 
burdened by the effort required to respond to the RAIs, and the  NRC staff would be burdened 
by the need to review applicants’ and licensees’ responses.  
 
Alternative 2: Withdraw Regulatory Guide 1.73 
 Under this alternative, withdrawing RG 1.73 would leave a void in the NRC’s regulatory 
guidance for the qualification of safety-related actuators. Eli minating guidance for licensees and 
future applicants would mean the content of future applications  could vary from licensee to 
licensee and from applicant to applicant, making the review of these applications more 
burdensome for the staff. The burden on applicants and licensee s would also be greater under 
this alternative because without specific guidance, applicants and licensees might spend more 
time preparing applications and potentially responding to RAIs.  
 
Alternative 3: Update Regulatory Guide 1.73 
 
Under this alternative, the NRC would update RG 1.73 , implementing the 
recommendations of the expert evaluation team report and addres sing current methodologies . 
One benefit of this action is that it would enhance reactor saf ety by providing up-to-date 
guidance and information on the qualification of safety-related  actuators in production and 
utilization facilities. It would also improve the staff’s abili ty to quickly review future applications. 
The costs to the NRC would be the one-time cost of issuing the revised RG, expected to be 
relatively small. address those identified recommendations and current methodologies for the 
qualification of safety-related actuators in production and uti lization facilities. The environmental 
qualification of safety related power operated valve actuators in production and utilization 
facilities is required regardless of the existence or currency of the RG, so applicants and 
licensees would incur little or no additional cost relative to Alternative 1. Updated regulatory 
guidance might reduce applicants’ and licensees’ costs relative  to Alternative 2. 
 
5.  Comparison of Alternatives 
 Alternative 1 is considered the baseline or no-action alternati ve 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 and 
licensees. Alternative 3 would impose a one-time additional cos t to the NRC relative to 
Alternatives 1 and 2. The one-time cost would be offset by the avoidance of the burdens 
imposed by Alternative 2. Alternat ive 3 would not impose signif icant additional costs on 
applicants and licensees relative to Alternative 1 and could po ssibly result in reduced costs to 
the applicant and licensee relative to Alternative 2.  3  
6.  Decision Rationale 
 
Based on this regulatory analysis, the staff recommends that th e NRC revise RG 1.73 to 
reflect the availability of new information and improved method ologies. The staff concludes that 
the proposed action would enhance the safety of production and utilization facilities by providing 
up-to-date guidance and information on the qualification of saf ety-related actuators in production 
and utilization facilities. Applicants and licensees can use th is guidance to ensure that designs 
are constructed to be safe and to help ensure that the NRC staf f review submitted designs in a 
timely manner.