ML19269E876
| ML19269E876 | |
| Person / Time | |
|---|---|
| Issue date: | 04/04/1979 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-1619, NUDOCS 7906290759 | |
| Download: ML19269E876 (21) | |
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MARCH 6, 1979 h e ACRS Regulatory Activities Subconmittee held a meeting on March 6, 1979, at 1717 H Street, N.W., Washington, D.C.
We purpose of this meeting was to review:
1.
proposed Regulatory Guides, 2.
revisions to existing Regulatory Guides, and 3.
other matters pertinent to activities that affect the current licensing process or reactor operations.
Notice of this meeting was published on Friday, Fehary 16, 1979, in the Federal Register, Volume 44, Number 34; a copy is included as Attachment A.
Mr. Gary Quittschreiber was the Designated Federal Dnployee for the meeting.
A list of meeting attendees is included as Attachment B.
INTRODUC'IORY STATEMENT BY THE CHAIRMAN Dr. Siess, the Subcommittae Chairman, convened the meetirq at 8:45 a.m.,
reviewed briefly the schedule for the meeting, and noted that the Sub-coctaittee had received written comments from the General Electric (GE)
Company on Regulatory Guide 1.143, Revision 1.
'Ihe Subccrnmittee had not received any requests for time to make oral statements frcra members of the public.
_RMUIATORY GUIDE 1.140, REVISION 1, " DESIGN, TESTI1G, AND MAINTENANCE Let TERIA FOR NORMAL VENTILATION EXHAUST SYSTEM AIR FILTRATION AND ADSORP-504 UNITS OF LIGHT--WATER-COOLED NUCLEAR POWER PLANTS" Dr. Siess provided a brief preamble, indicating that a draft copy of Regulatory Guide 1.140 was reviewed by the ACRS Environmental Subcommittee on October 20, 1977.
Dr. Moeller, t M Environmental Subcccmittee Chairman, had reviewed the present version of Regulatory Guide 1.140 and had sent 2142 095 79062907FC/
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t Reg Act Mtg 3/6/79 some written comments to the Reguletory Activities Subcommi'. tee.
Dr. Siess indicated that these comments will te discussed curing the course of the meeting.
Mr. Weinstein reviewed briefly the scope of this Guide, indicatirg that it provides methods acceptable to the NRC Staff for implement-ing the Commission's regulations in 10 CFR Part 50 and Appendices A and I to 10 CFR Part 50 with regard to the design, testing and maintenance criteria for air filtration and adsorption units in-stalled in the normal ventilation exhaust systems of light-water-cooled nuclear power plants. 21s Guide applies only to atmosphere cleanup systems designed to collect airborne radioactive materials during normal plant operation including anticipated operational occurrences. Wis Guide does not apply to post-accident engineered-safety-feature atmosphere cleanup systems that are designed to miti-gate the consequences of postulated accidents.
W e Subcommittee sought some response from the NRC Staff to Dr. Moeller's written comments (Attachment C).
In response to one of Dr. Moeller's comments as to whether any attempt has been made to revise this Guide to provide guidance to the Licensees to reduce the number of events that have occurred at operatirg plants relating to the atmospiere cleanup systems, Mr. Cardile roted that the results of the Licensee Event Reports (LERs) Study performed recently by the NRC St %dicated that 2ere were only four events relatirg to the atmosphere cleanup systems which resulted in the release of some low amount cf radioactivity. Personnel or procedural errors were the cause for these events. W e NRC Staff believes that it is beyond the scope of this Guide to include such events caused by personnel or procedural errors. He indicated that other events related to the Engineered-Safety-Feature (ESF) atmosphere 2142 096
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Reg Act Mtg 3/6/79 cleanup systems are also not within the scope of this Guide because this Guide provides guidance only to normal ventilation exhau.=t system al.: filtration ard adsorption units coupled with the fact that guidance l'or ESF systems are provided in Regulatory Guide 1.52.
In relatioa to Dr. Moeller's concern about the failures in the air-monitoring system, Mr. Cardile indicated that air-monitoring system is outside the scope of this Guide. Mr. Collins added that he believes that the eventn essociated with air-monitoring systems should be addressed in Regulatory Guide 1.21, " Measuring, Evaluating and Reportirq Radio-activity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants."
With regard to Dr. Moeller's comment concernirg lack of better definition of variables in the data yielded by various methods of testing the efficiency of adsorber and filter systems within nuclear power plants, Dr. Siess asked to what extent this comment would apply to the normal atmosphere cleanup systems and the ESF atmosphere cleanup systems.
Mr. Cardile responded that he is net definite about this point; he believes that Dr. Moeller's comment may apply to both the normal and ESF atmosphere cleanup systems.
Dr. First commented that he believes that Dr. bbeller's comment will apply to both the normal and ESF atmophere cleanup systems because the problems that adhere to the ESF systems are in no way different than those that adhere to the normal ventilation systems.
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Reg Act Mtg 3/6 /79 Mr. Cardile reiterated that most of the events reported in the LERs are outside the scope of Regulatory Guide 1.140.
In response to a question frce Dr. Siess as to whether there is a real need for this Guide in view of the fact that there are no LERs falling within the scope of this Guide, Mr. Cardile noted that he believes that this Guide is needed to provide basic design guidance for the normal atmosphere cleanup systems.
Dr. First commented that Dr. Mceller is also concerned about the fre-quent occurrence of false alarms. Dr. First expressed concern about the fact that this Guide does not provide explicit guidance for design, maintenance, calibration and testirg of the instruments used in the j
ventilation systems.
a Mr. Collins indicated that the instruments referenced in this Guide are those that are used to measure the pressure drops and flow rates through the filters. He believes that section 5.6 of ERDA 76-21,
" Nuclear Air Cleaning Handbook," referenced in this Guide would provide a3 equate guidance for design, maintenance, and testing of instruments.
In response to a question from Mr. Parker, the NRC Staff noted that the referer.?es ANSI N509-1976 and ANSI N510-1975 mentioned in this Guide are beirn revised and it wuld take at least five months to get these revised Standards.
Dr. Siess asked, in view of the fact that the Standards ANSI N509 and ANSI N510 are being revised, is it worthwhile to issur Regulatory Guide 2142 098 1.140?
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Reg Act Mtg 3/6/79 Mr. Collins indicated that Regulatory. Guide 1.140 does not endorse these Standards completely; it simply references some specific portions. fereover, this Guide provides the basic design guidance for the normal atmosphere cleanup systems; without this Guide the NRC Staff may find it very difficult to judge the design adequacy of the normal atmosphere cleanup systems. In addition, this Guide includes the contents of Branch Technical Position 11-2 which was withdrawn last year. 'Iherefore, if this Guide is not issued, the NRC Staff may have to develop some interim criteria and make them available to the applicants.
Dr. Siess asked whether the Subcommittee and its consultants are satisfied with the objective and scope of this Guide.
Mr. Parker suggested that additional information needs to be included in this Guide so as to clearly identify the interface between this Gdide and the other applicable Guides.
Mr. Bender and Dr. First concurred that there should be some clear identi-fication of the interfaces.
Dr. First conmented that he is dissatisfied with the reference to ERDA 76-21, because it does not provide specific guidance for instruments to monitor and alarm pertinent pressure drops and flow rates. He suggested that some other specific references to provide adequate guidance for monitoring pres-sure drops and flow rates need to be included.
Mr. Bender concurred that better guidance for instrumentation to monitor the filters would be helpful.
Mr. Cardile stated that he will discuss this issue with the appropriate branch of the NRC who deals with instrumentation and try to include addi-tional references, if available.
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Reg Act Mtg 3/6/79 Dr. Steindler expressed concert about the fact that this Guide does not include any specific information or reference to other Guides on radi-ation monitoring. He suggested that at least a reference to Regulatory Guide 1.21 which addresses radiation monitoring should be included in thIs Guide.
Mr. Collins indicated that although Regulatory Guide 1.21 covers radiation monitoring systems, it may not provide adequate guidance.
The Subcommittee reviewed this Guide page by page along with the public comments and the NRC Staff's resolution of those comments.
Mr. Parker and Dr. Steirxiler indicated that they concur with the suggestions made by the ASME Committee on Nuclear Air and Gas that the expected ranges of mass concentration of iodine and its compounds (of all isotopic form) be included in the Discussion Section of this Guide rather than including only the concentration of radioactive iodines.
N NRC Staff indicated tht they do not believe that non-radioactive iodines are much of a concern in normal atmosphere cleanup systems.
With reference to a statement in the Discussion Section of this Guide which states " Normal environmental conditions that these atmosphere cleanup systems should withstand are inlet concentrations of radioactive iodine in the range
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of 10 to 10 u Ci/cn......," Dr. Steindler comented that the specified lower limit (10 egjc33) is unnecessary and unmeasurable.
-13 He suggested that some modifications would be helpful.
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The NRC Staff indicated that they would delete the lower limit (10 uCi/:n ),
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t Reg Act Mtg 3/6/79 Mr. Parker pointed out that Table 2.2 of ERDA 76-21 (one of the references included in Regulatory Gaide 1.140) classifies Iodine-129 (I-129) as slightly radioactive. He believes that sudden accidental release of a major amount of I-129 accumulated in a filter may cause some severe pro-blems. He suggested that this issue should be spelled out in this Guide.
Mr. Bender suggested that the NRC Staff review this problem carefully and decide whether it is necessary to include.some statement in this Guide to make the applicants aware of this problem. However, if the NRC Staff decides th::. it is unnecessary to point out this problen, the Subcormnittee would like to know the reasons.
D e NRC Staff ind!.cated that they will look into this and provide informa-tion to the Subesmittee as appropriate.
With regard to the NRC Staff's response to one of the public comments which states that the Staff is not aware of any Dioctyl Phthalate (DOP) generators capable of testing systems substantially larger than 30,000 cfm, Mr. Parke. commented that the Staff's response is inconsistent with the information provided in ANSI N510 (referenced inC(5)(c) of this Guide) which indicates that gas thermal generators are designed to produce suffi-cient air results for testing systems in as much as 50,000 cfm installed capacity.
Mr. Bender suggested that the NRC Staff look into this issue and provide further clarification as necessary to creclude the inconsistency.
Dr. Siess conmented that paragraph C(4) (b) is not clear and some modifica-tions would be helpful.
Se NRC Staff indicated that they will make appropriate charx3es.
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s Reg Act Mtg 3/6/79 After further discussion, the Subcommittee and its consultants suggested several editorial changes, provided suggestions for clarifications and improvement in several areas of this Guide.
Because of the several concerns raised by the Subcommittee and its consultants on the scope and the technical contents of this Guide, the Subcommittee suggested that the NRC Staff try to resolve these concerns and brirg this Guide back at a near future date for further review.
RIIiUIAIVRY GUIDE 1.143, REVISION 1, " DESIGN GUIDANCE FOR RADIOACTIVE WASTE MANAGEMENT SYSTEMS, STRUC'IURES, AND COMPONENTS INSTALLED IN LIGHT-+AfER-COOLED NUCLEAR POWER PIANTS" Regulatory Guide 1.143 provides design guidance acceptable to the NRC Staff relatirg to seismic and quality group classification arxi quality assurance
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provisions for radioactive waste aanagement systems, structures, and com-
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ponents. Further, it describes provisions for controlling releases of liquids containing radioactive materials, e.g., spills or tank overflows, from all plant systems outside reactor containment.
The ' Subcommittee sought response from the NRC Staff for Dr. Neller's written comments on this Guide (Attachment D).
In response to one of Dr. Neller's ccanents as to why spent fuel handling, storage, or cleanup systems are not included in this Guide, the NRC Staff noted that they do not classify these systems as radioactive waste systems; I,
specific guidance for these systems is provided in Section 9.4.1 of the Standard Review Plar In response to another comment'from Dr. Moeller as to whether this Guide considers the LERs associated with waste gas decay tank releases, Mr. Cardile noted that the NRC Staff's review of these LERs indicated that a major portion of them are related to personnel or procedural errors. 'Ihey believe that there were not sufficient occurrences of a specific nature that could be irw-livhwi in this Gnido.
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Reg Act Mtg 3/6/79 Mr. Bender commented that the NRC Staff's response to Dr. N eller's comment is inadequate; they are not making it clear as to whether this Guide should provide any corrective measures so as to preclude the recurrence of the events associated with waste gas decay tank releases.
S e NRC Staff reiterated that they believe that most of those events are due to procedural or personnel errors, and they are not within the scope of this Guide.
In response to some questions from Mr. Bender, the NRC Staff noted that they believe that this Guide provides adequate guidance to preclude or minimize the events associated with leak testing, material selection, and fabrication methods. Wey also indicated that in the past little guidance was given on the design and testing of these systems. Wey believe that the present requirements and improved testing capabilities would preclude or minimize the recurrence of some of these events.
%e.Suhemnittee reviewed this Guide page by page, and also discussed the NRC Staff's resolution of p1blic comments.
Mr. Parker commented that the NRC Staff's resolution"to one of Ebasco's comments (which points out the.=-loiguity in paragraph C.l.2 and suggests that a minimum permissible amount of radioactive material in the tanks be quantified) is inadequate; he suggested that some acceptable minimum radioactivity level to ce present in these tanks should be specified.
Mr. Collins noted that the NRC -Staff does not have any criteria for specifying minimum radioactivity level in these tanks.
Se Subecmittee connented that the phrase " Potential overflow conditions" in paragraph C.l.2.1 is ambiguous and suggested that some clarification would be helpful 2142 103
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Reg Act Mtg 3/6/79 We NRC Staff indicated that they would make appropriate charges to avoid the ambiguity.
The Subcommittee discussed GE comments on this Guide (Attachment E) and sotsht some response from the NRC Staff for those comments.
(Being a fomer employee of of GE, Mr. Parker did not participate in the discussion of GE comments.)
Indicating that the NRC Staff's response to r...a of the public comments states that the scope of this Guide does not include instrument control and operatire systems and components, Dr. Staindler commented that there is no expicit statement in this Guide to indicate that instrument con-trol and operatirg systems and components are not. covered by this Guide.
Dr. Siess cocnented that the present title of this Guide implies that instrument controls are within the scope of r.his Guide. He suggested that if the NRC Staff does not intend to cover instrument controls in this Guide, it should be stated explicitly in the Introduction Section of this Guide.
Dr. Steindler pointed out that the NRC Staff's response to one of the public comments on the hydrogen detonation problem seems inadequate.
In view of the frequency of the incidents associated with hydrcqen, he believes that it is an important issue to be addressed in this Guide.
We NRC Staff responded that the guidance for hydrogen detonation problem is included in Section 11.3 of the Standard Review Plan.
Since this problem is still being analyzed by the NRC Staff, they did not address it in this Guide.
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Reg Act Mtg 3/6/79
'Ihe Subcommittee stated that it believes that it is ".- important issue to be addressed and suggested that some mention of this issue in this Guide would be helpful.
The NRC Staff indicated that they would address this probles in para-graph C.2.1.2 of this Guide.
With regard to paragraph C.5.1.1 of this Guide, Mr. Etherington commented that the NRC Staff's intent. is not clearly expressed.
The Subcommittee suggested that rewording of this paragraph to as to clarify the NRC Staff's intent would be helpful.
l 2e NRC Staff indicated that they would make appropriate charges to this paragraph.
After further discussion, the Subcommittee suggested several editorial changes, provided suggestions for clarification in some areas, and irr-dicated that it would recommend this Guide to the full Committee for concurrence with the Regulatory Position durirg the 227th ACRS meeting subject to the incorporation of the changes proposed by the Subcommittee.
PROPOSED REGULA70RY GUIDE 1.33, REVISION 2, " QUALITY ASSURANCE PROGRAM REQUIREMENTS (OPERATION)"
Regulatory Guide l'.33 describes a method acceptable to the NRC Staff for comply'ng with the Commission's regulations with regard to overall quality assurance program requirements for the operation phase of nuclear power plants. This Guide endorses, with certain exceptions, ANSI N18.7-1976/ANS-3.2, "Adminstrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants." 1he proposed revision to this Guide is a result of a feedback program I;etween the Offices of Standards Developnent and Inspection and Enforcement (I&E).
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4 Reg Act Mtg 3/6 /79 W e Subcomittee reviewed this Guide page by page.
With regard to the term " access circuits" used in 3.5.1 of Appendix A to this Guide, Mr. Ray commented that it seems to be a non-standard tenu.
Mr. Etherington suggested that the NRC Staff should try to avoid using non-standard terms in Regulatory Guides to preclude confusion.
Se NRC Staff indicated that they will check into this and make appropriate changes, if necessary.
In response to a question from Mr. Bender as to whether an I&E inspector has any way of knvaing what needs to be checked and calibrated, Mr. McKee noced that there is no specific list in the I&E manual to provide guidance on this issue. I&E inspectors normally get some guidance from Regulatory Guide 1.33.
He believes that the Licensee manual identifies several items that need to be checked and calibrated, and these items will vary from Licensee to Licensee. m is Guide provides a minimum list of specific examples that should be adopted by all the Licensees.
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With regard to paragraph 8.b of Appendix A, the Subcomittee comented that the NRC Staff's intent is not clearly defined; it suggested that certain modifications to this paragraph would be helpful. W e Subconmittee also suggested that the NRC Staff should check the appropriateness of including all those items under Section 8.b and make sure that this list of itens will pro-vide guidance rather than confusion.
S e NRC Staff indicated that they will consider Eubcommitteee's suggestions and make appropriate changes, if necessary.
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. Reg Act Mtg 3/6/79 We S'hittee suggested several editorial charges, provided guidance for clarification and suggestion for improvement in several areas, and indicated that the NRC Staff could issue this Guide for public coment.
REGUIA'IDRY GUIDE 1.137, REVISION 1, "f1JEL OIL atSTEMS FOR STANDBY DIESEL-GENERA'ICRS" Regulatory Guide 1.137 describes a method acceptable to the NRC Staff for ccx::plyirs with the Commission's regulations regardirg fuel oil systems for stndby diesel-generators and assurance of odequate fuel oil quality. ' Ibis Guide endorses, with cerain exceptions, ANSI N195-1976, " Fuel Oil Systems for Standby Diesel-Generators".
A draft version of this Guide was reviewed by the Regulatory Activities S'hittee on November 2,1977 and was issued for public comment in January 1978. 'Ihe present version of this Guide reflects consideration of public comments.
D e Su h ittee reviewed this Guide page by page.
With regard to the requirement listed in C l.e(l) that a fuel oil system sb uld be pressi;re tested to a pressure 1.10 times the system design pressure, Mr. Etherington pointed out that this does not seem tD be d sensitive test. Unless a fuel oil system is tested at a specified pramwe well above the design pressure the results of the test may not be helpful. He believes that if a fuel oil system does not leak at the design pressure, it may not lex at 10 percent over the design pressure. Although he believes that this is an
-u-cmry test, he does not have any strong objection in leaving this requirement in this Guide.
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k Reg Act Mtg 3/6/79 We Subcommittee suggested several editorial changes, provided guidance for clarification ard improvement in some areas and indicated that it would recommend this Guide to the ACRS full Committee for concurrence with the Regulatory Position during the 227th ACRS meeting.
SCHEDULE FOR 'IHE APRIL 4,1979 MEETING he NRC Staff indicated that the following Regulatory Guides will be subnitted to the Subcommittee for its review at the April 4,1979 meeting:
1.
Proposed Regulatory Guide, " Cable Penetration Fire Stop Qualification Test for Nuclear Power Plants" (Pre Ccmment) 2.
Proposed Regulatory Guide 1.58, Revision 1, " Qualification of Nuclear Power Plant Inspection, Examination, and Teating Persc,..ael" (Pre Comment) 3.
Revised copy of Regulatory Guide 1.140, Revision 1, " Design, Testing, and Maintenance Criteria for Normal Ventilation Exhaust System Air Filtration and Adsorption Units of Light-Water-cooled Raclear Power Plants."
Dr. Siess thanked all the participants and adjourned the meeting at 4:30 p.m.
NorE:
For additional details,.a complete transcript of the meeting is available in the NRC Public Document Rocm, 1717 H St., N.W.,
Washington, D.C. 20555, or from Ace-Federal Reporters, Inc.,
444 North Capital Street, N.W., Washington, D.C.
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Persons wishing to submit written
[7590-01-M]
statements regarding Regulatory NUCLEAR REGULATORY Guides 1.140. Revision 1. and 1.143 COMMISSION Revision 1. may do so by providing a readily reproducible copy to the Sub-ADVI5CtY COMMITTIE ON Rf aCfot EArt-committee at the beginning of the G'JARDS SUSCOMMIT1tE ON REGULATORY meeting. However, to insure that ade.
ACTIVIT115 quate time is available for full consid-eration of these comments at the meeting, it is desirable to send a readi-The March 7.1979, meeting of the ly reproducible copy of the comments ACRS Subcommittee on Reculatory as far in advance of the meeting as Activitics has been rcscheduled to be practicable to Mr. Gary R. Quittsch-held on March 6.1979. in Room 1046.
reiber tACRS). the Designated Federal 1117 H St.. N W Washington DC Employee for the meeting. in care of 20555. Notice of this meetina sas put>
ACRS. Nuclear Regulatory Commis-lished in the Fanr.naL Rrca:;tta on J.tn-sion. Washington D.C. 20555 or tele-uary ID. 1979144 FR 40%).
copy them to the Dcdgnated Federal in accordance with the procedures Employee Gn::-634-3319) as far in ad-out!med in the Frmitat. TIrcistr.a on vnnee of the-meeting as practicable.
October 4.1978143 Fit 4T926) oral or Such comments shaf t be based upon written statements may be premented documents on file and available for public inspection at the NRC Public br members of the public, recordings Document Room. 1717 11 Street. N.W 3ill be permitted only during those Washin:: ton, DC 20555.
portions of the meetinc when a tran-fun tirr information regarding script is being kept. and questions may Lopics to be discussed whether the be asked only by members of the Sub-
'""# ling has been cancelled or resched-committec its ersimilt mts. and Staff.
uh d.. t he Chairma.n s ruling on re-Persons desiring to make oral state-que for the oppoNunity to present ments should notify the Dest:nated oral statements and the time allotted Fs d. -al Fmp!crec r.s f:tr in advance as therrfor enn be oblatnnt by a prctiald practicable so that appropriate ar.
teh phonc call to the Desirnated Vni-rancements can be made to allow the oral Emplovce f or thin enretion. Mr.
necessary time during the mectirig for Gary i t.
Outtb.chreiber. (Icletehone 20.'. -G3 4 3"ti7 beturen 6.15 a.m. and e
nda for subject meeting 40 p.tn. M.
shall be as follows:
Dated: February 13.1979.
Tursnav. Manen 6.1979 O
(The Meeting Will C ence 't 8 45 a m.:
Ma nagernent Offscer.
The Subcommittee will htar presentations IFR Doc.79 51:3 Filed 215-79,8 45 ami from the NRC Staff and wt!! hold rtiscus.
sacrs with this group pertinent to the fol-lowtDE' (1) Draft Jtegrulste Ontde 1.33. Retts;on
- 3. -Quality Assurance Program Require-ments (Operstlen t**
C Craft Regulatory Guide 1.137. Rett-I slon 1.* INel Ott Systerns for Standby Diesel Generaars."
(3) Rcrulatory Guide 1.140. Rettston 1 j
"Deten. Testing. and Maintenance Criterta for Ncrmal Ven't!atten Exhaust System Air Filtration and Adsorption Units 0! laght-Water-Cooled Nuclear Power Plants."
(4) Regulatory Guide 1.143. Rettsfon 1.
" Design Gu: dance for Radioactive Waste Manaae nent Systems. Etructures, and Com-ponents Installed in IJght Water-Cooled Nuclear Power Plants."
Other matters shich may be of a predecisional nature relevant to reac-tor operation or !! censing activstles may be discussed following this ses-
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2142 109 FEDttAt arcegyIE. VOt. 44, NO. 34-tatory, pgg,gg,y,d
. iy79 ATTACH 1'.ENT ~ A
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ACRS SUBCOMMITTEE MEETING ON i
REGULATORY ACTIVITIES WASHINGTON, D.C.
MARCH 6,1979 ATTENDEES LIST ACRS NPC i
C. P. Siess, Chairman R. Lumpkins, NRR I
M. Bender, Member J. Collins, NRR I
H. Etherington, Member R. Bangart, NRR J. Ray, Member R. E. Lipinski, NRR H. First, Consultant W. R. Pearson, SD H. Parker, Consultant S. D. Richardson, SD M. Steindler, Consultant C. B. Balthrop, SD I
G. Quittschreiber, Staff
- Designated Federal Employea h,0rrso c
SD i
MRG-A K. G. Steyer, SD M. S. Weinstein, SD E. O'Brien F. Cardile BECHTEL B&W B. Montgomery R. Borsum i
ATTACHMENT B 2142 110
D. W. Moeller i
Feb. 25, 1979 l
l Comments on Draft 1, Rev.1, R. G. 1.140 The changes recommended in this revision of Regulatory Guide 1.140 are few in number and do not, in my opinion, necessarily address the real problems with such systems.
Therefore, I would urge that, if this Guide is to be re-vised at this time, additional work be conducted along the following lines:
1.
A paper presented by Moeller at the 15th DOE Nuclear Air Cleaning Conference showed that:
a.
About 13% of all LERs reported for co:cercial nuclear power plants involve failures in air-monitoring, air-cleaning, and ventilation systems.
b.
For BWRs, over half (51%) of these failures relate to failures in equipment for moni-toring the performance of air cleaning systems (as contrasted to failures in the systems themselves).
For PWRs, the figure is 32%.
Question:
Has a conscientious atte=pt been made in revising this Guide to assist licensees in solving these problems?
If a third to a half of the problems are in the systems monitoring the systems, does the Guide offer sufficient guidance on these aspects?
2.
In the 1978 ACRS " Review and Evaluation of the NRC Safety Research Program,"
questions were raised as to the better definition of the variables in the data yielded by various methods of testing y
i the efficiency of adsorber and filter syste=a I
within nuclear power plants.
(Paragraph 8.3.1, i
pages S-2 and 8-3).
Are these proble=s adequately I
addressed in the revision of this Guide?
In surzary, I would prefer to see the above points addressed, if the Guide is to be revised at this time.
Other-wise I would have to conclude that the suggested revision is inco:plete and inadequate.
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D. W. Moeller Feb. 15, 1979 Comments on Draft B, Rev. 1, R.G. 1.143 1.
Page 2 -- first intert -- will the new ANS standard I
significantly change N197 and N1997 If so, l
would there be any value in delaying publication of this revision of R.G. 1.143?
i 2.
Page 2 -- fourth insert -- what'is a " system with the higher design category"?
Has th' been pre-viously explained?
3 Page 2 -- last insert -- although it may be obvious I
to others, I do not follow why " spent fuel l
handling, storage, or fuel pool water cleanup syste=s" are excluded.
i 4.
Page 3 -- it is presumed that the published guide will show footnote "2" at the bottom of this pa68.
5 Page 5 -- paragraph 2.1.3 -- a review of LERs for 1975 i
through June 30, 1978, shows that there were 25 i
instances in which there were excessive airborne releases from P7iR waste gas decay tanks.
Has an analysis of these failures been conducted and have corrective measures been incorporated into this paragraph?
6.
Page 5 -- paragraph 3.1.3 -- perhaps it is obvious to others but I do not follow why it is necessary for a structure that houses solid radwaste system need be protected to contain the maximum liquid inventory expected to be present.
Where does the liquid come from if it is a solid waste system?
Or is it a system for converting wastes containing liquids into solida?
7 Page 6 -- first insert -- should this be labelled paragraph "4 1"?
In the third line of the pro-posed insert, the word, should, is repeated.
8.
Page 6 -- paragrpbh 4 3 -- what is the purpose of the first sentence: " Process piping systems and instrument lines."?
It appears out of place in contrast to the opening sentences in paragraphs 4.1, 4.2, etc.
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4 Page 6 -- paragrpph 4.3 -- should this be numbered "4.4"?
Also, should not the last sentence be phrased" Acceptability 9
something along the following lines:should be conti hold for a minimum of 30 minutes with no leakage indicated."?
Page 6 -- paragraph 4 4 -- should this be 4 57 10.
Page 7, paragraph 5 1.2 -- should the first sentence read "The allowable stresse s...... Buildings,"
11.
adopted by the American Institute of Steel _
Or in february 1969."?
Construction, Inc.t adopted the code in 19697
~was it the fiRC that Page B -- second insert -- should this end with a reference Tnia would refer the reader to 12.
to footnote "6"?
i the AISC specifications.
Page 9 -- paragraph 4.2.3 -- in quoting from re l
I 13 Is this
".. standards specified herein."If the reader of R.G. 1.
the quote as guidance, need not he also know proper.
[_p, 10 -- finst insert -- the second sentence of the what is " quoted herein"?
+;
Have the 14 Psgu proposed insert is confusing to me.
methods been considered acceptable "sinceub then), or were the Comcission's regulationsal Nn*.4 Perhaps what is troubling me is acceptable.
c;uld be corrected by changing this to read:
"The methods and criteria in this guide have been recognized since Novembcr,1975, as acesptable for complying with the Concission's regulations." (this is a very minor point).
j e^
2142 113 ATTSchMe NT dD 2,
~4
, i TGWcoW Tu t (54)2Y QU/YC'/sectskin j ri-~
' (zat) d.TF-33/f nuci.u a eneaov EL'EfML E ELECTRIC Pit O J ECT S OtViSIO
'C CO6tPANY.175 CURTt(CR AVE.,8 AN JOGE.CA1.tFORN!A 95125
$. Muclear Regulatory Cor.nission ccretary of ttte Co=aission ashington, D. C.
20555 Chief Docketing and Scrdce-Section
.ttention:
lentlecen:
GENERAL ELECTRIC ComENTS ON REGULATORY GUIDE 1.143,
" DESIGN GU10At:CE FOR RADICACTIVE W iUBJECT:
NUCLEAR FO IER PLANTS," SEV.1, DATED 1/29/79 l
G. S. Shomood Istter to Secretary of the Connission, dated Referenca:
October 9, 1978 td The General Electric Cocpany reviewed draft Regulatory Guide 1.143, July 1S78 and submitted our coments by the letter referenced above (copy attached),
d January 29, 1979, does not incor-
. Reg. Guide 1.143. Revision 1, dateparate our coments in the ic Raduasta Systems, Section C.2.1.3.
t to withstand the force of hydrogon detonations (350 psi) but operates A i
a norce.1 systen pressure of 6 psi, it is sufficiently strong to rema n In addition, the intact even in the event of a collapse of the butiding.
ifi-dose consequences of a failure of the vessel have been shown to be cantly less than 0.5 Res.
the Wo believe that sig.nificant costs would be incurred in fr.pleconting t
changos required by Reg. Guide 1.143 which cannot be justified.on a k's requcst tilat the HRC revise Esculatory Guida 1.143 benefit basis.
in accordance with our previous recom.cndations. 4 If you have any questions rcce.rding this letter, please contact
,Vic Kovecevic of cy staff, (403) 925-2996.
Very truly our s U S fu la s 4bfA /_/tJ3 I
U8I
/
cnn G..hcrviood, Kanegor 42 114 Scfety and Licensing agoration 1
GGS:daj/C73 ATTAc umen t 5
+4 s'
v
.s e.
d
.Attech-ent i CEt! ERAT. ELECYRIC ComEMTS ON REGULATORY
- 0EsfcN C010AMOE FOR RADI0 ACTIVE WASTE E i
STRUCTURES. AHD COMPONENTS INSTALLED RUCCEAR POWER PLANTS." DATED JULY 1978 Seletions a,e indicated by brackets and additions by und Note:
fection C.2.1.3 - test sentence "For 1.
Revise Section C.2,1.3 to read as follows:
Tsystems that operate near erhient pressure and retain gase froposed Chawe:
to the tant support l
. charcoal adscrbers, t.hase criteria should app y elements (for example, charcoal delay tanks in a 8WR) C building housing the tanks). boundary, dose due to a fa11ur
~
" Tiding housGd ~e
. icharcoal_ delay tant's' edoeds G.I~Re5 ' tim 13u charcoal tanks shoufdlEcinToriiT_o ThesE criterta.=
The probabif'c; of a catastrophic failure of the 350 psi charcoal vessel is creote, even if the butiding fe Justf fication:
shielding for the charcoal in the GE design is provided by heau concrete walls and ceilings whic
. Additionally, tht vessel.
h k
very unitkely to fall in tiw acnt of an operat t
Report NEDE-210!
vessel have been analyzed in the GE Licensing Topical The release
- E66 SJAE offsas Treatstent System," February 1977. 0.5 effects have been demonstrated to be significantly less than Rem using a very conservative analysis. for exac'ple, a 10 of the noble gases.
iderli There is no benefit accrued to the public health and safety co l
the inherent safe 4esign of the charcoal ves l
e effects of any hypothetical accident,any HRC benefit f
i saaking the charcoal vault seismic qualified.
l fcction C.4.2 - Fourth Sentence-Revise the fourth sentence of Section C.4.2 t 2.
"Scretted connections in which throads provide the Proposedchafpg.
i only seal should not be used except for instrumenta read as follows:
end cast Lum bed are not suitab e..,
.,o P00R ORMR zu2 us A T7oc HMEN-)- 6