ML102730465
| ML102730465 | |
| Person / Time | |
|---|---|
| Issue date: | 12/31/2010 |
| From: | Office of Nuclear Regulatory Research |
| To: | |
| Hicks, Angelisa L., 301-251-7448 RES/DE | |
| Shared Package | |
| ML102730357 | List: |
| References | |
| DG-3034 RG 3.12, Rev. 1 | |
| Download: ML102730465 (2) | |
Text
Staff Responses to Public Comments on Draft Regulatory Guide DG-3034 General Design Guide for Ventilation Systems of Plutonium Originators NEI Felix M. Killar, Jr.
Senior Director, 17761 Street, NW, Suite 400 Washington, DC 20006 10/1/2008 Comment Number Submitted By Comment
Response
- 1.
NEI General Safety - Section 1.c --Third sentence - Consider changing that may contain plutonium to that may contain dispersible plutonium.
Comment incorporated.
- 2.
NEI General Safety -Section 1.h -- Last sentence - Considering changing protect shutdown systems to protect systems that are shut down for clarification.
Comment incorporated.
- 3.
NEI Process Ventilation System - Section 3.c -- Recommend that the section be revised to allow a glove box confinement capability based on results of the plant-specific Integrated Safety Analysis (ISA). In some cases, the credible breach would drive a large airflow capacity; whereas the option to make these events Highly Unlikely should be addressed.
The way the section is currently written, it meets the intent of the recommendation.
- 4.
NEI Fans - Section 4.a -- First sentence, consider changing redundant fans to installed spare fans.
Comment not incorporated as redundant is a more commonly used term.
Page 2 of 2
- 5.
NEI Fans - Section 4.c -- Recommend that the section be revised to remove the term Items Relied on for Safety (IROFS). In many cases, supply fans are not required to maintain the confinement and are not identified as IROFS. However these fans should still be interlocked to prevent supply fan operation without exhaust fan operation and the resultant pressurization of faculty confinement zones. Another option would be to discuss the fans in terms of the ISA.
Section rewritten to clarify requirement.
- 6.
NEI Ventilation System Construction and Layout - Section 5.a -- Suggest rephrasing the last sentence to state that only final filter assemblies and duct work, that represent a barrier to the environment, should be designed to AG-1. Another option would be to suggest that the layout simply be consistent with the ISA.
Section has been revised to suggest ventilation systems be designed based on the ISA results. Additionally, it is the intent to ensure that the entire IROFS ventilation system is in accordance with AG-1, not just some of the components to ensure the reliability and availability of IROFS when needed.
- 7.
NEI Ventilation System Construction and Layout - Section 5.b -- Same as comment as 5a Comment incorporated. See response to Comment 5 above.
- 8.
NEI Ventilation System, Inspection, Testing, and monitoring - Section 6.b
-- Suggest clarifying that the intent of the Regulatory Guide is not to designate the continuous air monitoring system (CAMS) as an IROFS just because it supports a ventilation system that is an IROFS.
CAMS IROFS designation (if there is one) would be consistent with the results of the ISA.
Comment incorporated.