ML12159A049
| ML12159A049 | |
| Person / Time | |
|---|---|
| Issue date: | 10/04/2012 |
| From: | O'Driscoll J Office of New Reactors |
| To: | |
| Bayssie M | |
| Shared Package | |
| ML112091694 | List: |
| References | |
| DG-1274 RG-1.052, Rev 4 | |
| Download: ML12159A049 (6) | |
Text
Response to Public Comments on Draft Regulatory Guide DG-1274 Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants Proposed Revision 4 of Regulatory Guide (RG) 1.52 A notice that Draft Regulatory Guide, DG-1274 (Proposed Revision 4 of RG 1.52) was available for public comment and issued in the Federal Register on December 30, 2011 (76 FR 82323). The public comment period ended February 25, 2012. The U.S. Nuclear Regulatory Commission (NRC) received comments from the organizations listed below. The NRC staff has combined the comments, which are in the following table.
Comments were received from the following:
Eric M. Banks Ravi K. Aggarwal Manager, Field Services Department Senior Manager NUCON International, Inc. Sargent & Lundy LLC 7000 Huntley Road Mail Code 22 S 18 P.O. Box 29151 55 East Monroe Street Columbus, OH 43229 Chicago, IL 60603 ADAMS Accession No. ML12058A401 ADAMS Accession No. ML12058A403 Item Originator Section of Specific Comments NRC Resolution DG-1274 1 NUCON Last two We do not recommend removal of the Comment accepted. The last two sentences of the last paragraph on sentences of post filters. This will change the unit page 4, (Paragraph starting with the words Prefilters and HEPA last DP [differential pressure] and filters.will be deleted. This clarifies that removal of post filters paragraph therefore affect system flow rate. If for testing is not preferable due to the adverse effect of changing the (page 4) filters are removed [then] a second differential pressure in the system, and that the system should be airflow should be performed. If post designed such that the removal of components to facilitate testing is filters are to be removed it must be not necessary.
emphasized that all post filters must be June 2012
Item Originator Section of Specific Comments NRC Resolution DG-1274 removed. Removal of only part of the bank [may] allow some of the test aerosol that may bypass the upstream bank to be partially filtered by the post filters and give non-conservative test results. It is recommended that a sampling manifold be used.
2 NUCON C.3.f Remove this part To ensure reliable Comment accepted: Removed the first clause To ensure reliable (page 9) in-place testing of the sentence. in-place testing from C.3.f. The staff agrees that reliable in-place Reliable in-place test results [are] not testing is not dependent on airflow. The purpose of this guidance is dependent on airflow but [are] a as stated in DOE-HDBK 1169-2003, Nuclear Air Cleaning function of how the test is set up. Handbook, (Ref. 18), paragraph 4.4.11, Size of Banks. The However, the system should be purpose of this requirement was to facilitate maintenance and inplace operating at design airflow + -10%. testing, to improve control in the event of a system upset, and to enhance the reliability of the total system. Therefore the staff agrees that the guidance is not related to testing reliability per se.
This change does not impact the intent of following the guidance of U.S. Department of Energy (DOE) document DOE-HDBK 1169-2003, Nuclear Air Cleaning Handbook (Ref. 18), paragraph 4.4.11, Size of Banks.
3 NUCON C.4.d I would include section FK so as to Comment not accepted. Public comment provided neither an (page 10) allow special filters. It should be up to industry operating experience basis nor an adequate technical the A&E as to what type of filter justification as to why section FK should be endorsed by the staff for design to be used. engineered-safety feature (ESF) filtration systems. There are some advantages to using round high-efficiency particulate air (HEPA) filters as captured by the white paper presented at the 25th DOE/NRC Nuclear Air Cleaning and Treatment Conference entitled Circular HEPA Filters for Use in Nuclear Containment and Ventilation Systems.
http://www.hss.doe.gov/nuclearsafety/qa/hepa/nureg_25th/filter6.pdf DOE laboratories are more apt, than nuclear power plant operators to 2
Item Originator Section of Specific Comments NRC Resolution DG-1274 have the need for using special round and duct-connected HEPA filters in non- ESF applications. Current nuclear plant operators under Title 10 of the Code of Federal Regulations (10 CFR) Part 50 (Ref. 1) and design certification document and combined operating license applicants under the 10 CFR Part 52(Ref. 2) licensing process may choose to specify special round and duct-connected HEPA filters for their plants in ESF filtration systems but would have to take exception to the guidance of RG 1.52, in which case, the staff would evaluate the exception on a case-by-case basis.
4 NUCON Table 2 This sentence is hard to understand. Comment accepted. The staff agrees that Table 2 footnote b is hard Last two Maybe reword to this: When two or to read. In order to improve readability, the staff replaced the last sentences of more beds are used in a series, it may two sentences of footnote b with the words:
footnote b be advantageous to locate these beds (page 18) in separate housings. This may aid in When two or more beds are used in series, it may be advantageous the mixing of the challenge agent and to locate these beds in separate housings. This may aid in the mixing contribute to the overall accuracy of of the challenge agent and contribute to the overall accuracy of the the test. This does not preclude the test. This does not preclude the use of test manifolds. Each bank use of test manifolds. Each bank shall shall be individually in-place leak tested.
be individually in-place leak tested.
5 NUCON Table 2, Misspelled, should be adsorbed. Comment accepted. The staff agrees that the correct word is Note (2) adsorbed because activated carbon functions via the process of (page 18) adsorption not absorption, and makes the note consistent with the rest of the RG in that regard. The misspelled word absorbed was corrected to adsorbed in Note (2) 6 Sargent & Figure 1 Add post filter or HEPA to Figure 1. Comment not accepted. Figure 1 already displays a HEPA filter Lundy LLC (page 6) after the Adsorber section of the filter train. The figure is also (S&L) annotated that other acceptable configurations exist; this figure is only provided for conceptual purposes. The last full paragraph on page 4 indicates that HEPA filters or postfilters downstream of the adsorber section are permitted. Therefore, to modify the figure with additional guidance is unnecessary.
7 S&L Figure 2 Add post filter or HEPA to Figure 2. Comment not accepted. Figure 2 already displays a HEPA filter (page 7) after the Adsorber section of the filter train. The figure is also 3
Item Originator Section of Specific Comments NRC Resolution DG-1274 annotated that other acceptable configurations exist; this figure is only provided for conceptual purposes. The last full paragraph on page 4 indicates that HEPA filters or postfilters downstream of the adsorber section are permitted. Therefore, to modify the figure with additional guidance is unnecessary.
8 S&L C.1(page 7) Add for design of test canisters only Comment not accepted. Based on the staffs response to the after (Ref. 11) in first sentence of C.1. reviewers comment (immediately below) for C.2.a (page 7), to add for design of test canisters only would make C.1 inconsistent with what follows.
9 S&L C.2.a Delete in accordance with Section 4.4 Comment not accepted. Section 4.4 of ASME N509-2002 provides (page 7) of ASME N509-2002 (Ref. 11) in the basis for the criteria established in C.2.a. In addition, section 4.4 first sentence of C.2.a. points to other industry guidance documents to consider when establishing the environmental qualification requirements for the components of the air-cleaning unit. Staff understands that ASME N509-2002 will be sunset by the ASME CONAGT in the not too distant future after the ASME AG-1 Code and ASME N511 completely replaces the guidance of N509.
10 S&L C.3 (page 8) Add for design of test canisters only Comment not accepted. Based on the staffs response to the after (Ref. 11) in the first sentence of reviewers comment (immediately above) for C.2.a (page 7), to add C.3. for design of test canisters only would make C.3 inconsistent with other passages of the regulatory guide.
11 S&L C.3.f C.3.f addresses filter layout for Comment not accepted. The regulatory guide does not preclude the (page 9) walk-in units. Add recommended use of a bag-in/bag-out type filter. Alternate arrangements may be filter layout for bag-in/bag-out type permitted if an adequate technical justification is provided to the units. staff. In this particular case, section 4, Component Design Criteria and Qualification Testing, 4.f and 4.g endorses the use of section HA of ASME AG-1-2009 with addenda. Figure HA-1120-2 provides the details of a bag-out housing. Therefore, additional words are not warranted in section C.3.f.
12 S&L C.3.g Delete and Section 4.9 of Comment accepted. Section 4.9, Monitoring of Operational (page 9) ASME N509-2002 (Ref. 11) from Variables, reads: Instruments and Controls shall meet the C.3.g. requirements of ASME AG-1, Section IA. Therefore, the clause and Section 4.9 of ASME N509-2002 (Ref. 11) is redundant 4
Item Originator Section of Specific Comments NRC Resolution DG-1274 with the clause that immediately precedes it. Changed C.3.g to read:
The ESF atmosphere cleanup system should be instrumented to signal, alarm, and record pertinent pressure drops and flow rates at the control room in accordance with the recommendations of Section IA of ASME AG-1-2009 with addenda (Ref. 13).
Instrumentation, readout, recording, and alarm provisions for ESF atmosphere cleanup systems should meet the guidance given in Table 1 of this regulatory guide as a minimum.
13 S&L C.3 g Table 1 of this guide is not consistent Comment not accepted. The reasons for adding Table 1 to the RG (page 9) with Non-Mandatory Appendix were carefully considered by the staff during DG-1274s Table 1A-C1000. Suggest deleting development. The intent was to restore guidance that was absent in Table 1 from this guide. AG-1 and later revisions of ASME N509 but found in the current revision of NUREG-0800, SRP 6.5.1.
14 S&L C.3.j Page 10, [c]larify replacement of Accepted comment since filter trains are normally constructed as a (page 10) segmented sections as ultimately the welded unit. Segmented sections would suggest bolted flange and entire filter unit would be replaced. gasket connections, which are not found in industry. Removed the last clause of the last sentence or a minimum number of segmented sections without removal of individual components.
15 S&L C.3.l Also refer to section HA-4500 Comment accepted. The staff inserted a reference to section HA-(page 10) 4500 in C.3.1 because this section is the applicable section in the industry standard for housing, whereas SA-4500 applies to ductwork.
16 S&L C4.i Suggest relocating humidity control Suggested change not accepted. The opening paragraph of C.4.i (page 11) discussion to heater section C.4.b. reads: Adsorption units function most efficiently for the removal of radioiodine, particularly organic iodides, at an input relative humidity of 70 percent or less. The second paragraph (which the reviewer suggests relocating) is a continuation and further explanation of the opening paragraph. Therefore, the staff believes that the placement of the words of C.4.i should remain largely unchanged from the words contained in section 4.9 of RG 1.52 Revision 3.
17 S&L C.4.j Are the manual fire systems No change required. Fire protection systems, in general, are not (page 12) safety-related or nonsafety related? safety related and have no technical specifications.
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Item Originator Section of Specific Comments NRC Resolution DG-1274 18 S&L C.4.m Add section 4.13.b and before Comment accepted. It appears that the comment was directed at the (page 13) Appendix I. last sentence of C.4.k (not C.4.m), since this RG paragraph matches the reference in the comment. To change this typographical error, the staff changed section C.4.k to read, If sample canisters are used, they should be designed in accordance with section 4.13(b) and Appendix I to ASME N509-2002 (Ref. 11).
19 S&L C.6.c Replace of' with and in third line. Comment accepted; changed C.6.c accordingly to correct (page 14) typographical error.
20 S&L C.6.f Replace of' with and in second Accepted comment; changed C.6.f accordingly to correct (page 15) line. typographical error.
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