U.S.

NUCLEAR REGULATORY COMMISSION February 2007

Revision 2

REGULATORY GUIDE
OFFICE OF NUCLEAR REGULATORY RESEARCH

REGULATORY GUIDE 1.128

(Draft was issued as DG-1154, dated October 2006)

INSTALLATION DESIGN AND INSTALLATION

OF VENTED LEAD-ACID STORAGE BATTERIES
FOR NUCLEAR POWER PLANTS
A. INTRODUCTION
The U.S. Nuclear Regulatory Commission (NRC) developed this regulatory guide to describe
a method that the NRC staff considers acceptable for use in complying with the agency’s regulations
with regard to satisfying criteria for the installation design and installation of vented lead-acid storage
batteries in nuclear power plants. Specifically, the method described in this regulatory guide relates to
General Design Criteria (GDCs) 1, 17, and 18, as set forth in Appendix A, “General Design Criteria
for Nuclear Power Plants,” to Title 10, Part 50, of the Code of Federal Regulations (10 CFR Part 50),
“Domestic Licensing of Production and Utilization Facilities”:
• GDC 1, “Quality Standards and Records,” requires that structures, systems, and components
important to safety shall be designed, fabricated, erected, and tested to quality standards
commensurate with the importance of the safety functions to be performed.
• GDC 17, “Electric Power Systems,” requires that an onsite electric power system and an offsite
electric power system shall be provided to permit functioning of structures, systems,
and components important to safety.
• GDC 18, “Inspection and Testing of Electric Power Systems,” requires that electric power systems
important to safety shall be designed to permit appropriate periodic inspection and testing
of important areas and features, such as wiring, insulation, connections, and switchboards,
to assess the continuity of the systems and the condition of their components.

The U.S. Nuclear Regulatory Commission (NRC) issues regulatory guides to describe and make available to the public methods that the NRC staff
considers acceptable for use in implementing specific parts of the agency’s regulations, techniques that the staff uses in evaluating specific problems
or postulated accidents, and data that the staff need in reviewing applications for permits and licenses. Regulatory guides are not substitutes
for regulations, and compliance with them is not required. Methods and solutions that differ from those set forth in regulatory guides will be deemed
acceptable if they provide a basis for the findings required for the issuance or continuance of a permit or license by the Commission.

This guide was issued after consideration of comments received from the public. The NRC staff encourages and welcomes comments and suggestions
in connection with improvements to published regulatory guides, as well as items for inclusion in regulatory guides that are currently being developed.
The NRC staff will revise existing guides, as appropriate, to accommodate comments and to reflect new information or experience. Written comments
may be submitted to the Rules and Directives Branch, Office of Administration, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.

Regulatory guides are issued in 10 broad divisions: 1, Power Reactors; 2, Research and Test Reactors; 3, Fuels and Materials Facilities;
4, Environmental and Siting; 5, Materials and Plant Protection; 6, Products; 7, Transportation; 8, Occupational Health; 9, Antitrust and Financial Review;
and 10, General.

Requests for single copies of draft or active regulatory guides (which may be reproduced) should be made to the U.S. Nuclear Regulatory Commission,
Washington, DC 20555, Attention: Reproduction and Distribution Services Section, or by fax to (301) 415-2289; or by email to [email protected].
Electronic copies of this guide and other recently issued guides are available through the NRC’s public Web site under the Regulatory Guides document
collection of the NRC’s Electronic Reading Room at http://www.nrc.gov/reading-rm/doc-collections/ and through the NRC’s Agencywide Documents
Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html, under Accession No. ML070080013.
 In addition, Criterion III, “Design Control,” in Appendix B, “Quality Assurance Criteria
for Nuclear Power Plants and Fuel Reprocessing Plants,” to 10 CFR Part 50 sets forth the following
requirements:
• Measures shall be established to assure that applicable regulatory requirements and the design basis,
as defined in §50.2 and as specified in the license application, for those structures, systems,
and components to which this appendix applies are correctly translated into specifications,
drawings, procedures, and instructions.
• These measures shall include provisions to assure that appropriate quality standards are specified
and included in design documents and that deviations from such standards are controlled.
• The design control measures shall provide for verifying or checking the adequacy of design,
such as by performance of design reviews, by the use of alternate or simplified calculational methods,
or by the performance of a suitable testing program.

This Revision 2 of Regulatory Guide 1.128 endorses (with certain clarifying regulatory positions
described in Section C of this guide) the “IEEE Recommended Practice for Installation Design
and Installation of Vented Lead-Acid Batteries for Stationary Applications,” which the Institute
of Electrical and Electronics Engineers (IEEE) published as IEEE Std 484-2002.1 By contrast,
Revision 1 of Regulatory Guide 1.128, dated October 1978, endorsed (with certain clarifying
regulatory positions described in Section C) IEEE Std 484-1975.

This revised regulatory guide is intended for licensees of new nuclear power plants. 2 Previous
revisions of this regulatory guide remain in effect for licensees of current operating reactors, 2 who are
unaffected by this revision. However, licensees of current operating reactors may voluntarily convert
their battery installation design and installation to the criteria in this revised guide.

This regulatory guide contains information collections that are covered by the requirements
of 10 CFR Part 50, which the Office of Management and Budget (OMB) approved under OMB control
number 3150-0011. The NRC may neither conduct nor sponsor, and a person is not required to respond to,
an information collection request or requirement unless the requesting document displays a currently
valid OMB control number.

1
IEEE publications may be purchased from the IEEE Service Center, which is located at 445 Hoes Lane, Piscataway, NJ
08855 [http://www.ieee.org, phone (800) 678-4333].

2
The terms “new nuclear power plant” and “new plant” refer to any nuclear power plant for which the licensee obtained
an operating license after the NRC issued Revision 2 of Regulatory Guide 1.128. The terms “current operating reactor”
and “current plant” refer to any nuclear power plant for which the licensee obtained an operating license before
the NRC issued Revision 2 of Regulatory Guide 1.128.

Rev. 2 of RG 1.128, Page 2

 B. DISCUSSION
IEEE Std 484-2002, was developed by the IEEE Working Group on Vented Lead-Acid Battery
Installation, Station Design Subcommittee of the Power Generation Committee, and was approved by
the IEEE-SA Standards Board on September 12, 2002. IEEE Std 484-2002 provides the recommended
design practice and procedures for storage, location, mounting, ventilation, instrumentation, pre-assembly,
assembly, and charging of vented lead-acid batteries. As such, IEEE Std 484-2002 is applicable to
full float stationary applications, in which a battery charger normally maintains the battery in a fully
charged state and provides power to the direct current (dc) loads.
In comparison to IEEE Std 484-1975, which addresses large lead storage batteries,
IEEE Std 484-2002 adds new recommendations and requirements, and incorporates some elements
of the regulatory positions of Regulatory Guide 1.128, Revision 1. IEEE Std 484-2002 is generalized
for stationary batteries for generating stations and substations and has been relaxed by deleting
recommendations and requirements in IEEE Std 484-1975 specific to nuclear power generating stations.
This standard eliminates the use of IEEE Standards 308, 336, 344, and 384, which provide additional
recommendations and requirements related to the installation and tests upon installation of Class 1E batteries
for nuclear power generating stations. It also deletes the requirement for a quality assurance program,
reduces the requirement that the battery installation shall be protected against natural and induced
phenomena (such protection is now presented as a recommendation). In addition, IEEE Std 484-2002
deletes separation requirements, and reduces the number of tests used to identify the pilot cell
during the freshening charge. This standard also uses the applicable building codes for seismic protection,
and deletes the requirement that the installation shall be able to withstand the force calculated
for a safe shutdown earthquake to allow continuous battery service during such events as required
by IEEE Std 344 and endorsed in the NRC’s regulatory guidance.
Portions of IEEE Std 484-2002 continue to be directed toward recommendations in the area
of battery room cleanliness and ventilation, temperature control, and fire prevention. Battery room
cleanliness and ventilation are important because the battery chemistry for lead-acid storage batteries
is sensitive to contaminants and temperatures above and below the manufacturer’s rating. In addition,
the batteries also release hydrogen (a potential fire hazard) to the battery room during charging.
The NRC also has regulatory guidance for preventing fires in battery rooms; however, some of its elements
(such as the value for the hydrogen accumulated limits, air flow sensors and alarms in the control room,
and fire detection design features) are not recommended in this IEEE standard.
IEEE Std 484-2002 eliminates the IEEE Std 484-1975 recommendation that cells should be
mounted in accordance with the manufacturer’s recommended separation distance, and adds a mounting
arrangement that eliminates the requirement that cell plates shall be able to be inspected. It is common
practice to inspect battery cell plates for conditions that are known to result in degradation of battery
performance, including excessive accumulation of lead sulfate, growth of the positive plates against
the container, and evidence of excessive cell plate corrosion. In addition, the battery cells must be
arranged on the racks to allow for inspection of cell plates.
This Revision 2 of Regulatory Guide 1.128 evaluates the new recommendations and requirements
in IEEE Std 484-2002, with respect to their importance to safety. It also updates the regulatory positions
in Revision 1 of Regulatory Guide 1.128 by (1) deleting those that have been incorporated into IEEE
Std 484-2002; (2) adding a regulatory position to update and carry forward the use of other IEEE standards,
recommendations, and requirements applicable to nuclear power generating station batteries, which were
contained in IEEE Std 484-1975 but deleted in IEEE Std 484-2002; (3) updating and carrying forward
the regulatory positions for preventing fires in battery rooms based on the current NRC guidance in
Regulatory Guide 1.189, “Fire Protection for Operating Nuclear Power Plants”; and (4) updating
and carrying forward past regulatory positions that took exception to IEEE Std 484.

Rev. 2 of RG 1.128, Page 3

 C. REGULATORY POSITION
Conformance with the IEEE Std 484-2002 requirements (indicated by the verb “shall”)
for installation design and installation of vented lead-acid storage batteries for nuclear power plants
provides an adequate basis for complying with the design, fabrication, erection, and testing requirements set
forth in GDCs 1, 17, and 18 of Appendix A to 10 CFR Part 50, as well as Criterion III of Appendix B
to 10 CFR Part 50, subject to the following stipulations:

1. Subsection 2, “References,” which stipulates that this standard should be used in conjunction
with other IEEE standards, should be supplemented as follows:
“For nuclear power generating stations, the recommended practice should also be used
in conjunction with other pertinent publications. (In some cases, the specific applicability
or acceptability of these documents may be covered separately in other regulatory guides.)
The pertinent publications include the following IEEE standards:
• IEEE Std 308, ‘Criteria for Class 1E Power Systems for Nuclear Power Generating
Stations,’ as endorsed by Regulatory Guide 1.32
• IEEE Std 336-2005, ‘Installation, Inspection, and Testing Requirements for Power,
Instrumentation, and Control at Nuclear Facilities’
• IEEE Std 344, ‘Recommended Practices for Seismic Qualification of Class 1E Equipment
for Nuclear Power Generating Stations,’ as endorsed by Regulatory Guide 1.100
• IEEE Std 450, ‘Recommended Practice for Maintenance, Testing, and Replacement
of Vented Lead-Acid Batteries for Stationary Applications,’ as endorsed by Regulatory
Guide 1.129
• IEEE Std 384, ‘Standard Criteria for Independence of Class 1E Equipment and Circuits,’
as endorsed by Regulatory Guide 1.75”

2. Subsection 5.1, “Location, ” item (d) should be supplemented to add the following:
“(d) For nuclear power generating stations, the general requirement that the battery should be
protected against fires should be supplemented with the applicable recommendations for
battery rooms in Regulatory Guide 1.189, ‘Fire Protection for Operating Nuclear Power Plants.’”

3. Subsection 5.1, “Location,” should be supplemented to add item (k), as follows:

“(k) For nuclear power generating station Class 1E batteries, where batteries are required
in redundant systems, the batteries shall be separated as specified by IEEE Std 384,
‘Standard Criteria for Independence of Class 1E Equipment and Circuits,’ and as recommended
for battery rooms in Regulatory Guide 1.189, ‘Fire Protection for Operating Nuclear Power Plants.’”

4. Subsection 5.2, “Mounting,” item (c), should be supplemented to add the following:
“(c) For nuclear power generating stations, battery cells must be arranged on racks to provide for
the ability for cell plates to be inspected.”

5. Subsection 5.3, “Seismic,” criteria should be supplemented to add the following:

“(d) For nuclear power generating station Class 1E batteries, the racks, anchors, and installation
thereof shall be able to withstand the force calculated for a safe shutdown earthquake to allow
continuous battery service during and following the event in accordance with IEEE Std 344,
‘Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations,’
and the associated Regulatory Guide 1.100, ‘Seismic Qualification of Electric Equipment
for Nuclear Power Plants.’”

Rev. 2 of RG 1.128, Page 4

6. In Subsection 5.4, “Ventilation,” revise the second sentence to be consistent with Regulatory
Guide 1.189, as follows:
“The ventilation system shall limit hydrogen accumulation to one percent of the total volume of the
battery area.”

7. In Subsection 6.3.1, “Freshening Charge Sequence,” item (a) should be supplemented as follows:
“(a) The pilot cell determined by sampling shall not be used to support maintenance and test
measurements in IEEE Std 450 as endorsed by Regulatory Guide 1.129, unless that pilot cell
has been verified through measurement of each cell’s specific gravity and float voltage to be
representative of the average of the entire battery.”

8. Subsection 6.3.4, “Acceptance test,” should be revised to specify capability and capacity tests
upon initial installation, as follows:
“Upon initial installation, the battery’s capability shall be demonstrated by completing a service test
or modified performance test in accordance with IEEE Std 450, as endorsed by Regulatory Guide 1.129.
If factory tests did not include capacity tests, the battery’s capacity shall also be demonstrated
by completing a performance test or modified performance test in accordance with IEEE Std 450,
as endorsed by Regulatory Guide 1.129.”

9. IEEE Std 484-2002 should be supplemented to add Section 8.0, as follows:

“8.0 Quality Assurance Program
For nuclear power generating stations, where the battery performs a Class 1E function,
a quality assurance program shall be adopted to control and document all activities related to
such functions.”

10. In addition to the requirements of IEEE Std 484-2002, the recommendations (indicated by
the verb “should”) contained in the following sections of that standard have sufficient
safety importance to be treated the same as the requirements of the standard:
(a) Subsection 5.1, “Location,” item (c) recommends that the battery area be clean, dry,
and well-ventilated and provide adequate space and illumination for inspection,
maintenance, testing, and cell/battery replacement.
(b) Subsection 5.1, “Location,” item (d) recommends that the battery be protected
against natural phenomena, such as earthquakes, winds, and flooding, as well as
induced phenomena, such as fire, explosion, missiles, pipe whips, discharging fluids,
and carbon dioxide. In addition, the examples of induced phenomena are revised
to add the following:
“radiation.”
(c) Subsection 5.1, “Location,” item (g), which recommends providing stationary water
facilities for rinsing spillage, should be supplemented with the following:
“Where portable or stationary water facilities are provided within the battery room,
their design should preclude any inadvertent spilling of water from these facilities
onto the battery itself.”

Rev. 2 of RG 1.128, Page 5

 (d) In Subsection 5.5, “Instrumentation and Alarms,” the four listed items should be
supplemented with two recommended items, as follows:
“(e) Ventilation air flow sensor(s) and alarm(s) in the control room”
“(f) Fire detection sensor(s), instrumentation, and alarm(s), as recommended
for battery rooms in Regulatory Guide 1.189, ‘Fire Protection for Operating
Nuclear Power Plants’”

(e) Subsection 6.1.3, “Storage,” item (a) recommends avoiding extremely low or high
ambient temperatures or localized sources of heat.

(f) Subsection 6.3.2, “Data collection,” is supplemented with the following:

“(e) At the completion of the freshening charge, a hydrogen survey shall be
performed to verify that the design criteria required by Subsection 5.4,
‘Ventilation,’ are met (see Section 7, ‘Records’).”

(g) Subsection 7, “Records,” is supplemented with the following:

“(f) Initial hydrogen survey data”

D. IMPLEMENTATION
The purpose of this section is to provide information to applicants and licensees regarding
the NRC staff’s plans for using this regulatory guide. No backfitting is intended or approved
in connection with its issuance.

Except in those cases in which an applicant or licensee proposes or has previously established
an acceptable alternative method for complying with specified portions of the NRC’s regulations,
the NRC staff will use the methods described in this guide to evaluate (1) submittals in connection with
applications for construction permits, standard plant design certifications, operating licenses, early site
permits, and combined licenses; and (2) submittals from operating reactor licensees who voluntarily
propose to initiate changes involving the installation design and installation of vented lead-acid storage
batteries in nuclear power plants.

REGULATORY ANALYSIS / BACKFIT ANALYSIS

The regulatory analysis and backfit analysis for this regulatory guide are available in Draft
Regulatory Guide DG-1154, “Installation Design and Installation of Vented Lead-Acid Storage Batteries
for Nuclear Power Plants.”3 The NRC issued DG-1154 in October 2006 to solicit public comment on the
draft of this Revision 2 of Regulatory Guide 1.128.

3
Draft Regulatory Guide DG-1154 is available electronically under Accession #ML062220170 in the NRC’s
Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html.
Copies are also available for inspection or copying for a fee from the NRC’s Public Document Room (PDR), which is
located at 11555 Rockville Pike, Rockville, Maryland; the PDR’s mailing address is USNRC PDR, Washington, DC
20555-0001. The PDR can also be reached by telephone at (301) 415-4737 or (800) 397-4205, by fax at (301) 415-3548,
and by email to [email protected].

Rev. 2 of RG 1.128, Page 6