Text

Draft 1, Revision 1 to Reg Guide 1.140, Design, Testing & Maint Criteria for Normal Ventilation Exhaust Sys Air Filtration & Adsorption Units of LWR Nuclear Power Plants. W/Encl Public Comments
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Issue date:	03/31/1979
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Draft 1 Revision 1

/jR Riog'o' U.S. NUCLEAR REGULATORY COMMISSION

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?g%) REGULATORY GU]Diarch'197c

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OFFICE OF STANDARDS DEVELOPMEN'.

.m, REGULATORY GUIDE 1.140 DESIGN, TESTING, AND MAINTENANCE CRITERIA FOR NORMAL VENTILATION EXHAUST SYSTEM AIR FILTRATION AND ADSORPTION UNITS OF LIGHT-WATER-COOLED NUCLEAR POWER PLANTS A.

INTRODUCTION General Design Criteria 60 and 61 of Appendix A.

" General Design Criteria for Nuclear Power Plants "

to 10 CFR Part 50, " Licensing of Production and Utilization Facilities." require that filtering systems be included in the nuclear power unit design to control suitably the release of radioactive materials in gase-ous effluents during normal reactor operation, includ-ing anticipated operational occurrences and fuel stor-age and handling operations. In addition, 9 950.34a,

" Design objectives for equipment to control releases of radioactive material in effluents-nuclear power reactors." and 50.36a, " Technical specifications on effluents from nuclear power reactors," of 10 CFR Part 50 require that means be employed to cnsure that

release of radioactive material to unrestricted ar during normal reactor operation, including expect 6dt operational occurrences, is kept as low as isfrea-sonably achievable.

g,7 Appendix f, " Numerical Guides f' r Design Objec tives and Limiting Conditions for Operation to Meet i

the Criterion 'As Low As Is Reasonably Achir.uble',

for Radioactive Material in Light Water Coore'd Nu-clear Power Re:ator Erfluents," to 10 CFR Part 50 i prosides guid,ance and numerical values for design objectives to help applicants.,gand holders of, licenses for nuclear power pfants Tneet the require-ments of50.34atimi.'50.36a') Appendix I requires that each light-water-coofed nuclear power reactor unit not excee&an annual dose design objective of 15 stricted area ('nt'all exposure pathways from airborne mrem to an organ iPiny individual in an unre-radioactive iolihigand particulate releases. Appendix I also requires that additional radwaste equipment be provided if the equipment has reasonably demon-strated technology and the cost-benefit ratio is favor-able. USNRC REGt1LATORY GUIDES Comaiea *

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This guide presents methods acceptable to the NRC staff for implementing the Commission's regulations in 10 CFR Part 50 and in Appendice's,A and I to 10 CFR Part 50 with regard to the design: testing, and maintenance criteria for air-filtration and adsorption units installed in thepormal %'ntifation exhaust sys-tems of light-wat:rcboled n' clear power plants. This u guide applies onifle.ar[nosphere cleanup systems de-signed to colleyirborneydioactive materials during normal plant opera,tiory meluding anticipated opera-tional occurrencessand addresses the atmosphere cleannpsyst'emh including the various componena s and.ductwork in the normal operating environment. ' his%uide does not apply to postaccident T %engiiipered-safety-feature atmosphere cleanup sys-Q'oQo,tbat are designed to mitigate the consequences em). stulated accidents. Regulatory Guide 1.52, ), a"ccident Engineered-Safety Feature Atmosphere Design Testing, and Maintenance Criteria for Post-Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants," pro-vides guidance for these systems. B. DISCUSSION Particulate filtration and radioiodine adsorption units are included in the design of the ventilation exhaust systems of light-water-cooled nuclear power plants to reduce the quantities of radioactive mate-rials in gaseous effluents released from building or containment atmospheres during normal operation, including anticipated operational occurrences. All such cleanup systems should be designed to operate i' continuously under normal environmental conditions. In this guide, cleanup systems that should operate to meet the "as low as is reasonably achievable" guidelines of Appendix I to 10 CFR Part 50 inside the primary containment (recirculating units) are desig. 2

nated as " primary systems." Primary systems gener-ally include a containment cicanup system (kidney tiltration system). Systems that operate outside pri- ' mary containment are designated as " secondary sys-tems." Secondary systems generally include cleanup systems installed in the ventilation exhaust systems for the reactor building, turbine building, radwaste building, auxiliary building, mechanical vacuum pump, main condenser air ejector, and any other re-Icase points that may contain particulates and gaseous radioiodine species. In some instances, filtration equipment installed in a postaccident hydrogen purge exhaust systein nuy be designed to the recom-mendations of this guide, e.g., where a removal effi-ciency of 90c'o or less for radioiodine species is suffi-cient for the hydrogen purge exhaust system when the sum of the calculated loss-of-coolant accident (LOCA) dose and the post-LOCA hydrogen purge dose is less than the guideline values of 10 CFR Part 100. Normal environmental conditions that these atmos. phere cleanup systems should withstand are inlet concentrations of radioactive iodine in the range of 10-* to 10-'8 pCi/cm*, relative humidity of the in-fluent stream up to 100%, temperatures of the in-fluent stream up to 125'F (52*C), and atmospheric pressure. The system should be operated in such a manner that radiation levels of airborne radioactive material and radiciodine buildup on the adsorber do not deleteriously affect the operation of the filter sys-tem or any component. An atmosphere cleanup system installed in a rior-mal ventilation exhaust system consists of some or all of the following components: heaters or cooling coils used in conjunction with heaters, prefilters, high-efficiency particulate air (HEPA) filters, iodine ad-sorption units, fans, and associated ductwork, dam-pers, and instrumentation. Heaters are designed to heat the influent stream to reduce its relative humid-ity before it reaches the filters and adsorbers. HEPA filters are installed to remove particulate matter, which may be radioactive, and pass the air stream to the adsorber. The adsorber removes gaseous iodine (elemental iodine and organic iodides) from the air stream. HEPA filters downstream of the adsorber ! units collect carbon fines and provide redundant pro-l tection against particulate release in case of failure of the upstream HEPA filter bank. He fan is the final item in an atmosphere cleanup system. Consideration should be given to installing prefilters upstream of the HEPA filters to reduce the particulate load and extend their service life. He environmental history will affect the perform-ance of the atmosphere cleanup system. Industrial contaminants, pollutants, temperature, and relative humidity contribute to the aging and weathering of i filters and adsorbers and reduce their capability to perform their intended functions. Therefore, aging, weathering, and poisoning of these components, which may vary from site to site, need to be consid-cred during design and cperation. Average temper-ature and relative humidity also vary from site to site, and de potential buildup of moisture in the adsorber .ortants equal design consideration. The effects of e ese factors on the atmosphere cleanup system can i.e determined by scheduled testing during operation. All components of the atmosphere cleanup system installed in normal ventilation exhaust systems need to be designed for reliable performance under the ex-pected operating conditions. Initial testing and proper maintenance are primary factors in ensuring the relia. bility of the system. Careful attentien during the de-sign phase to problems of system maintenance can ccatribute significantly to the reliability cf the system by iacreasing the case of such maintenance. Of par-ticular importance in the design is a layout that pro-vides accessibility and sufficient working space so that the required functions can be performed safely. Periodic testing during operation to verify the effi-ciency of the components is another important means of ensuring reliability. Built in features that will facilitate convenient in-place testing are important in system design. Standards for the design and testing of atmosphere cleanup systems include ANSI /ASME N509-1976, " Nuclear Power Plant Air Cleaning Units and Com-ponents" (Ref.1), and ANSI N510-1975, " Testing of Nudear Air Cleaning Systems" (Ref. 2). Other standards are available for the construction l and testing of certain components of systems. Where { such standards are acceptable to the NRC staff, they are referenced in this guide. Where no suitable stand-ard exists, acceptable approaches are presented in this guide. ERDA 76-21, " Nuclear Air Cleaning Handbook" (Ref. 3), provides a comprehensive re-view of air filtration systems. It is not a standard but a guide that discusses a number of acceptable design alternatives. Not all of the documents mentioned in ANSI N509-1976 (Ref.1), ANSI N510-1975 (Ref. 2), or other standards referenced in this guide have been the subject of an evaluation by the NRC staff as to their applicabilit/ or acceptability. It should be noted that ANSI N509-1976 and ANSI N510-1975 refer to ORNL-NSIC-65, " Design, Construction and Testing of High Efficiency Air Filtration Systems for Nuclear Application" (Ref. 4), which has been replaced by ERDA 76-21 (Ref. 3). C. REGULATORY POSITION Section 2 of ANSI N509-1976 'Ref.1) and Sec-tion 2 of ANSI N510-1975 (Ref. 2) list additional documents referred to in these standards. The specific appicability or acceptability of these listed docu-mer.ts, as well as documents listed in other standards referenced in this guide, has been or will be covered separately in other regulatory guides, where appro-pnate. Where reference is made to ORNL-NSIC-65 (Ref. 4 in ANSI N509-1976 and in ANSI N510-1975, it should be interpreted to mean the corresponding por-tion of ERDA 76-21 (Ref. 3). i l

1. Environmental Design Criteria j

a. The design of each atmosphere cleanup sys-tem insta!!ed in a normal ventilation exhaust system should be based on the maximum anticipated operat-ing parameters of temperature, pressure, relative humidity, and radiation levels. He cleanup system should be designed based on continuous operation for the expected life of the plant or the maximum antici-pated servic: life of the cleanup system.

b. If the atmosphere cleanup system is located in an area of high radiation during normal plant opera-tion, adequate shielding of components from the radiation source should be provided.

c. He operation of any atmosphere cleanup sys.

tem in a normal ventilation exhaust system should not deletariously affect the expected operation of any engineered safety-feature system that must operate aft:r a design basis accident.

d. The design of the atmosphere cleanup system should consider any significant contaminants such as dusts, chemicals, or other particulate matter that could deleteriously affect the cleanup system's opera-tion.

2. System Design Criteria

a. Atmosphere cleanup systems installed in t

normal ventilation exhaust systems need not be re-dundact nor designed to seismic Category I classifica-tion, but should consist of the following sequential components: (1) HEPA filters before the adsorbers, (2) iodine adsorbers (impregnated activated carbon or i equivalent adsorbent such as metal zeolites), (3) l ducts and dampers, (4) fans, and (5) related in-strumentation. If it is desired to reduce the particulate load on the HEPA filters and extend their service life, the installation of prefilters upstream of the initial __ Mhaneve F. atmosphere cleanup system is HEPA bank is suggested. Consideration should also designU to re'nove only particulate be given to the installation of a HEPA filter bank matter, a component for iodine downstream of carbon adsorbers to retain carbon adsorption need not be included. fines. Heaters or cooling coils used in conjunction with heuters should be used when the humidity is to be controlled before filtration.n

b. Tne volumetric air flow rate of a single cleaup train should be limited to approxir tely 2

30,030 ft / min. If a total system air flow in excess of this rate is required, multiple trains should be used. For case of maintenance, a filter layout that is three HEPA filters high and ten wide is preferred.

c. Each atmosphere cleanup system should be l locally instrumented to monitor and alarm pertinent l pressure drops and flow rates in accordance with the i recommendations of Section 5.6 of ERDA 76-21 (Ref.3).

I

d. To maintain the radiation exposure to_operat-and maintenance ingjpersonnel as low as is reasonably achievable e and components 4..

nn.na, atmosphere cleanup systemsI should bu desiened to control leakare and facilitate , inspection and testing maintenancehn accordance with the guidelines of Regulatory Guide 8.8, "Information Relevant to En-suring that Occupational Radiation Exposures at Nu-clear Power Stations Will Be As Low As is Rea-sonably Achievable" (Ref. 5).

e. Outdoor air intake openings should be equipped with louvers, grills, screens, or similar pro-tective devices to minimize the effects of high winds, rain, snow, ice, trash, and other contaminants on the operation of the system. If the atmosphere surround-ing the plant could contain significant environmental contaminants, such as dusts and residues from smoke cleenup systems from adjacent coal burning power plants or industry, the design of the system should consider these contaminants and prevent them from affecting the operation of any atmosphere cleanup system.

f. Atmosphere cle inup system housings and ductwork should be designed to exhibit on test a maximum total leakage rate as defined in Section 4.12 of ANSI N509-1976 (Ref.1). Duct and housing leak tests should be performed in accordance with the provisions of Section 6 of ANSI N510-1975 (Ref. 2).

3. Component Design Criteria and Qualification Testing

s. Adsorption units funchn efficiently at a rela-average tive humidity of 70% or less. If the{ relative humidity of the incoming atmosphere is expected to be greater San 70% during normal reactor operation, heaters or cooling coils used in conjunction with heaters should average be designed to reduce thekelative humidity or tne in-coming atmosphere to 70%. Heaters should be de-signed, constructed, and tested in a cordance with the requirements of Section 5.5 of ANSI N509-1976 (Ref.1) exclusive of sizing criteria.

b. The HEPA filters should be designed, con-structed, and tested in accordance with the require-ments of Section 5.1 of ANSI N509-1976 (Ref.1).

Each HEPA filter should be tested for penetration of dioctyi phthalate (DOP) in accordance with the provi-sions of MIL-F-51068 (Ref. 6) and MIL-STD-282 (Ref.7).

c. Filter and adsorber mounting frames should be designed and constructed in accordance with the provisions of Section 5.6.3 of ANSI N509-1976 (Ref. 1).

d. Filter and adsorber banks should be arranged in accordance with the recommendations of Section 4.4 of ERDA 76-21 (Ref. 3).

c. System filter housings, including floors and doors, and electrical conduits, drains, and piping in-stalled inside filter housings should be designed and constructed in accord.mce with the provisions of Sec-tion 5.6 of ANSI N509-1976 (Ref.1).

f. Ductwork associated with the atmosphere cleanup system should be designed, constructed, and

-sted in accordance with the provisions of Section 5.10 of ANST N509-1976 (Ref.1).

g. The adscrber section of the atmosphere cleanup system may contain any adsorbent material demonttrated to rernove gaseous iodine (elemental iodine and organic iod:Jes) from air a: the required efficiency. Since i npregnated activated carbon is commonly used, only this adsorbent is discussed in this guide. Each original or replacement batch of im-pregnated activated carbon used in the adsorber sec-tion should meet the qualification and batch test re-sults summarized in Table 1 of this guide.

If an adsorbent oc.er thin impregnated activated carbon is proposed or tf the mesh size distnbution is different from the specifications in Table 1 the pro-posed adsorbent should have demonstrated the capa-bility to perform as well as or better than activated carbon in satisfying the specifications in Table 1. If impregnated activated carbon is used as the adsor-bent, the adsorber system should be designed for an average atmosphere residence time of 0.25 sec per two inches of adsorbent bed.

h. Adsorber cells should be designed, con-structed, and tested in accordance with the require-ments of Section 5.2 of ANSI N509j-976 (Ref.1).

9

i. 'Ihe system fan and motors mounting, and ;

ductwork connections should be designed, con-i stn:cted, and tested in accordance with the require- ! ments of Sections 5.7 and 5.8 of ANSI N509-1976 (R ef. 1).

3. The fan or blower used in the atmosphere cleanup system should be capable of operating under the environmental conditions postulated.

k. Ducts anc.ousings should be laid out with a minimum of ledges, protrusians, and crevices that could collect dust and moisture and that could impede personnel or create a hazard to them in the perform-Turning vanes or other air flow distributict acce of their work?...,...-.. 3..~ should be in-l devices stalled where regt. rd to ensure representative ait j flow measurement md uniform flow distribution through cleanup con ynents.

I

1. Dampers should be designed, constructed, and tested in accordance with the provisions of Section 5.9 of ANSI N509-1976 (Ref.1).

4. Maintenance

a. Accessibility of components and maintenance l should be considered in the design of atmosphere cleanup systems in accordance with the provisions of Section 2.3.S of ERDA 76-21 (Ref. 3) and Section 4.7 of ANSI N509-1976 (Ref.1).

b. For ease of maintenance, the system design !

should provide for a minimum of three feet from l mounting frame to mounting frame between banks of i components. If components are to be replaced, the i dimensions to be provided should be the maximura length of the component plus a minimum of three feet.

c. The system design should provide for perma-.

nent test probes with external connections in accord-ance with the provisions of Section 4.11 of ANSI N509-1976 (Ref.1). i

d. De c'eanup components (e.g., HEPA filters and adsorbers) should be installed after construction is completed.

l S. In Place Testing Criteria

s. A visual inspection of the atmosphere cleanup system and all associated components should be made before each in-place airflow distnbution test, DOP test, or activated carbon adsorber section leak test in accordance with the provisions of Secdon 5 of ANSI N510-1975 (Ref. 2).

b. The airflow distribution to the HEPA filters and iodine adsorbers should be rested inplace for uniformity initially and after maintenance affecting the flow distribution. The distribution should be within 20% of the average flow per unit when tested in accordance with the provisions of Section 9 of " Industrial Ventilation" (Ref. 8) and Section 8 of ANSI N510-1975 (Ref. 2).

c. The in-place DOP test for HEPA filters should conform to Section 10 of ANSI N510-1975 (Ref. 2).

HEPA filter sections should be tested in place ini-least once per tially and at..w_:n,, n. _ m::4, l3 months thereafter (during a schedu:ed reactor shutdown is ac-ceptable). The HEPA filter bank upstream of the ad-sorW section should also be tested following paint-ing, fire, or chemical release in any ventilation zone t communicating with the system in such a manner that the HEPA filters could become contaminated from the fumes, chemicals, or foreign materials. DOP penetration tests of all HEPA filter banks should con-firm a penetration of less than 0.05% at rated flow. A filtration system satisfying this condition can be con-sidered to warrant a 99% removal efficiency for par-ticulates. HEPA filters that fail to satisfy the in-place test criteria should be replaced with filters qualified pursuant to regulatory position C.3.F of this guide. If the HEPA filter bank is entirely or only partially re-placed, an in-place DOP test should be conducted. If any welding repairs are necessary on within, or adjacent to the ducts, housing, or mounting frames, the filters and adsorbers should be removed from the housing during such repairs. These repairs should be completed prior to periodic testing, filter inspection, and in-place testing. The use of silicone scalants or any other temporary patching material on filters, housing, mounting frames, or ducts should not be allowed.

d. The activated carbon adsorber section should be leak-tested with a gaseous halogenated hydrocarbon refrigerant in accordance with Section 12 of ANSI N510-1975 (Ref. 2) to ensure that bypass leakage through the adsorber section is less than 0.05%. After the test is completed, air flow through the unit should be maintained until the residual refrigerant gas in the effluent is less than 0.01 ppm. Adsorber leak testing

-8

should be conducted (1) initially. (2) at : %- Ieast once per ....Ql8 montas tnereaf ter (during a sched-u!ed reactor shutdown is acceptable), (3) following removal of an adsorber sample for laboratory testing l if the integrity of the adsorber section is affected, and (4) followirig painting, tire, or chemical release in any ventilation zone communicating with the system in such a manner that the charcoal adsorbers could become contaminated from the fumes, chemicals, or foreign materials.

6. Laboratory Testing Criteria for Activated Carbon

a. The activated carbon adsorber section of the atmosphere cleanup system should be assigned the decontamination efficiencies given in Table 2 for radiciodine if the following conditions are met:

(1) The adsorber section meets the conditions given in regulatory position C.5.d of this guide, (2) New activated carbon meets the physical property specifications given in Table 1, and (3) Representative samples of used activated carbon pass the laboratory tests given in Table 2. If the activated carbon fails to meet any of the above conditions, it should not be used in adsorption units.

b. The efficiency of the activated carbon ad-sorber section should be determined by laboratory testing of representative samples of the activated car-bon exposed simultanecusly to the same service con-ditions as the adsorber section. Each representative sample should be not less than two inches in both !

length and diameter, and each sample should have the j same qualification and batch test characteristics as I the system adsorbent. There should be a sufficient I number of representative samples located in parallel with the adsorber section to estimate the amount of penetration of the system adsorbent throughout its _g.

service life. The design of the samplers should be in accordance with the provisions of Appendix A of ANSI N5091976 (Ref.1). Where the system acti. vated carbon is greater than two inches deep, each representative sampling station should consist of enough two-inch samples in series to equal the thick-ness of the system adsorbent. Once representative samples are removed for laboratory test, their posi-tions in the sampling array should be blocked off. Laboratory tests of representative samples should be conducted, as indicated in Table 2 of this guide, with the test gas flow in the same direction as the flow during service conditions. Similar laboratory tests should be performed on an adsorbent sample be-fore loading into the adsorbers to establish an initial point for comparison of future test results. The acti. vated carbon adsorber section should be replaced with new unused activated carbon meeting the physi. cal property specifications of Table 1 if (1) testing in accordance with the frequency specified in Foot. ate e of Table 2 results in a representative sample failing to pass the applicable test in Table 2 or (2) no represen-tative sample is available for testing. as outlined in Section 11.3 of the D. IMPLEMENTATION -Standard Review P1an. The method The purpose of this section is to provide informa. presented in this guide has been tion to applicants a.' "..:...: regarding the NRC recognized as acceptable for comply-staff's plans for using this regulatory guide. ing with the Commission's This guide reflects current NRC staff practiceA regulations since November 1975. Therefore, except in those cases in which the appli. cant. "..c..; proposes an acceptable alternative the method for complying withlspecified portions of the Commission's regulations, the method described in this guide W'S ",g and will e ntinue t applications for all be used in the evaluation of,. _. g..:.. g con-and reference system preliminary struction permits _, 4 Jj] GEsb ] ""~~ .E design applications docketed after (the publication date of this guide) except those. portions of a con-struction permit application which:

a. reference an approved standard reference system preliminary or final design (PDA or FDA).

b. reference an approved standard duplicate plant preliminary or final design (PDDA or FDDA).

c. reference parts of a base plant design qualified and approved for replication,

d. reference a plan; design approved or under review for approval for manufacture under a manufacturing license, or applications for such approval.

TABLE 1 PHYSICAL PROPERTIES OF NEW ACTIVATED CARBON i BATCH TESTS

TO DE PERFORSTED ON FINISHED ADSORBENT I

Acceptable Test Test Method Acceptable Results

1. Pa:ticle size desmonion ASTat D2862 (Ref. 9)

Retained on #6 AST51 Ell

Siese: 0.0%

Retained on #8 AST51 Ell

Sieve: 5.0% max.

Through #8, retained on #12 Sieve: 40% to 60% Through #12 retained on #16 Sieve: 40% to 60% Through #16 AST51 Ell

Sieve: 5.0% max.

Through #18 AST51 Ell

Sieve: 1.0% max.

2. Hardness number RDT Sil6-IT Appendix C (Ref.10) 95 minimum

3. Ignition temperature RDT Ail 6-IT, Appendix C (Ref.10) 330*C minimum at 100 fpm

4. CCle Activity' CCI a Activity, RDT 5116-IT, Appendix C (Ref.10) 60 minimum

5. Radioiodine removal efficier.cy

a. Elemental iodine, RDT 5116-!T 99.5 %

25'C (Ref.10) and 95'* relatise para. 4.5.1, except e humidity 95cc relative humidity air is required

b. Afethyl iodide, 25'C RDT 5116-IT (Ref.10) 95 %

and 954 relative para. 4.5.3, except humidity 95% relative humidity air is required

6. Bulk density AST51 D2854 (Ref. I1) 0.38 g/mi minimum 7 Impregnant content State procedure State type (not to exceed Src by weight)

I

A " batch test" is a test made on a prod.setion batch of a product to establish suitability for a specific application. A " batch of activated carbon" as a quantity of matenal of the same grade. type, and senes that has been bomogeaired to enhabit, r ithis reason.

aNe tolerance. the same performance and physical charactenstics and for which the manufacturer can demonstrate by am1rkble tests and quahty control practices such aniforr sty. All =aterial in :he same batch should be activated, impregnated, and omae, *ise treated under the same procesa corJittens and procedures in the same process equipment and should be produced under the same as wfactur-ing telease and instructions. Matenal produced in the same charge of batch equipment constitutes a batch; tr.atenal pre *wed in Jiffere 't charges of the same batch equipment should be included in the same batch only if it can be homoge.'tzed as abo .The reanimum batch size shouiJ be 3!o fr of activated carboa. a

See Reference I2.
This teu shoulJ be performed on base material.

TABLE 2 LABORATORY TESTS FOR ACTIVATED CARBON Assigned Activa:ed Carbon Activa:ci Carbon

Decon: amination Efficiencies Labora:on Testsfor a Bed Depn*

For Radiciodine Representative Sample c 2 inches. Air filtratica 90 % Per Test 5.b in Table I system designed to oper2:e for a methyl iodide pene-inside primary containment. tration of less than 10"e. 2 inches. Air filtration 70% Per Test 5.b in Table I system designed to operate at a relative humidity of cuiside the primary contain. 70% for a rnethyl iodide ment, and relative humidity penetration of less than is controlled to 70% 10%. 4 inches. Air filtration 90 % Per Test 5.b in Table I at system designed to operate a relative humidity of 70% outside the primary contain-for a methyl iodide pene. ment, and relative humdity tration of less than 10%. is controlled to 70%. 6 inches. Air filtration 99 % Per Test 5.b in Table I at system designed to operate a reistive humidity of 70cc outside the primary contain-for a methyl it 'ide penetra-ment, and relative humidity is tion of less tha.s 1%. contro!!ed to 70".

The activated carbon, when new, shovu rece tse specifications of regulatory position C.3 g of this ge;4e.
Mult:ple beds, e.g. two 2 inch beds in senes, shouW be treated as a singte bed of ags egate depth.

Ie8St Once per

See reeutators resition C.6 b for definition of representative sample. Testing shoeu be performed (t) initially. (2) ark,

- && mootn4 Janng a scheduled reaster shutJoes is acceptable), and (3) followies paisting, fire, ce chemical release is any ventilation zore corimunecattag with the system in such a maaper that the charcoal adwrbers comu become contaminated from the fames, cheroicals, or foreign matenals. thereafter REFERENCES

1. American National Standard ANSI /ASME N509 1976, " Nuclear Power Plant Air Cleaning Units and Components." Copies may be obtained from the American Society of Mechanical Engineers, United Engineering Center,345 East 47th Street.

New York, N.Y.10017.

2. American National Standard ANSI N510-1975,

" Testing of Nue! ear Air Cleaning Systems," American Society of Mechanical Engineers.

3. ERDA 76-21, " Nuclear Air Cleaning Hand.

book," Oak Ridge National Laboratory, C. A. Burchsted, J. E. Kahn, and A. B. Fuller, March 31, 1976. Copies may be obtained from the Na-tional Technical Information Service, Springfield, Va.22161.

4. ORNL NSIC-65, " Design, Construction, and Testing of High Efficiency Air Filtration Systems for Nuclear Application " Oak Ridge National Laboratory, C. A. Burchsted and A. B. Fuller, January 1970. Copies may be obtained from the National Technical Information Service.

5. Regulatory Guide 8.8, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable,"' Office of Standards Development, U.S. Nuclear Regulatory Commis-sion.

6. MIL-F-51068, " Filter, Particulate, High.

Efficiency, Fire. Resistant" (latest edition), Mili-tary Specification. Copies may be obtained from the Naval Publications and Forms Center, 5801 Tabor Ave., Philadelphia, Pena.19120.

7. MIL.STD.282, " Filter Units, Protective Cloth-ing, Gas-Mask Components and Related Products:

Performance-Test Methods," Military Standard, 28 May 1956. Copies may be obtained from the address given in Reference 6.

8. American Conference of Governmental Industrial Hygienists, " Industrial Ventilation " 14th Edi-tion,1976, Committee on Industrial Ventilation, P.O. Box 453, Lansing, Mich. 48902.

i

9. ASTM D2862-70, " Test for Particle Size Distribu-tion of Granulated Activated Carbon." Copies may be obtained from the American Society for l

Testing and Materials,1916 Race Street. l Philadelphia, Penn.19103.

10. RDT Standard M16-IT, " Gas-Phase Adsorbents for Trapping Radioactive Iodine and Iodine Com-pounds," USAEC Division of Reactor Research and Development, October 1973, Oak Ridge, Tenn.

37830.

11. ASTM D2854-70, " Test for Apparent Density of Activated Carbon," American Society for Test-ing and Materials.

12. ASTM Ell 70, " Specifications for Wire Cloth Sieves for Testing Purposes." American Society for Testing and Materials.

O 9 PUBLIC COMMENTS

.' t.. 0, !, hM SACRAMENTO f.tuNICIPAt. UTILITY DISTRICT C 6201 S Street. Box 15330. Sacramento. C'aiifornia 95313; 0 16) 45' RJR 78-190 April 19, 1978 OGC '~i.%'i. 52,37 w. P.;10L'05ED E*.E 8 \\~ M4 /' N ... y ~ ~# Secretary of the Commission '/ { ' n 13ig p U. S. Nuclear Regulatory Commission l-i Washington, D. C. 20555 $N gs.g g\\ f .t *3 7 Attention: Docketing & Service Branch "h. W M

Subject:

Regulatory Guide 1.140, March 1978 (FOR COMMENT) /I4/g W #' Title Design, Testing and Maintenance Criteria ~ For Normal Filteration, Exhaust System, Air ventilation and A'dsorbtion Units of Light-Water Cooled Nuclear rover Plants.

Dear Sir:

We have reviewed the subject Regulatory Guide and have severr.1 comments which we feel should be incorporated prior to its issue _. CzNs,it References to ANSI N510-19f5 " Testing. of Nuclear Air Cleaning Systems" 'should be. revised to reflect the new revision to that standard scheiduled for publication in 1978. TABLE I COMMENTS This table makes frequent reference to a docu=ent identified as RDT M 16-lT for laboratory test conditions on new activated charcoal. This docu=ent has been found deficient as a test procedure for the radio-iodine testing of LWR adsorbers. As a result, ASTM is presently preparing to issue a standard covering this testing. The new documenc shocid be referenced as the pre-- ferred test method. TABLE II COMMENTS No provisions are made for systems designed to operate outside of primary containment which c:ay not have relative humidity control. There are numerous systems in service which are operating quite nicely without humidity control; hence, a test condition for them should be specified. For the two-inch bed [* ,"$~m# xcwno<aceced b'I ** ,g

~ Secretary of the Cor =ission April 19, 1978 designed to operate outside che primary containtient, you have assig:ed an activated carbon decontanination ef ficiency for radio-iodine of 70%, while specifying a methyl iodide penetration of less than 10%. I believe this may be a typographical error as 10% penetration is equivalent to a 90% decontamination deficiency. Respectfully, d V, 7,4 8. 8 - . J. Matticoe Assistant General Manager and Chief Engineer RJR:DDW:sc r es: Alex O'}ran, Cha'ir.:an ANSI N-510 Testing Subcoccittee c/o A=erican Air Filter Co=pany P. O. Box 1100 Louisville, KT 40201 NRC, Region V Office' l' t

q) IC @ z. ce=as,nr cozcts Wannac,rc,0 Bescu, ca ?zs4 .n :n ne=ca l &f M 7 5' Fc ::o autz PR - 43_.v4' . J 4 s 5 % t*'t .Seendaq cA-}h k is %... -i N dsptc... ~ ..tda.3b> h, It ',csss.. $ _.g 11.$37g M;o: 'm / Suvae 3neh... w, W. m i g sys" l YA & _ a 4 3 y c::un:a o.0 Rej Guale. !.Ho, .t c!u5ccacd ane err.,,- J;c!, l

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i Moa n.ds "d a. b ueuq ncHe exceed i2 n,e.c}t,.r... ' 4 r.? 6._4 AL.k" e!- leasl cuee. pto 12 men 4Lt.... i %c. carew+ M,3 way !c ikkt%4 as, scme M y w/ac!4 l is less -H,.u cuee is ne mess.. A e:c.u.ple. o.C a se *'cMRe ' l ' Freyuay wealcL be. cace r 4,0 yeu:, ut<<a r.r ee.~.d=,uty ten - L m,k. w m Ja.s. %, sa is c~alr9-4o 4t%. t.de:k I et. w. ycde. %. M . s. & :.1 G,. a. % uwtL i .. wl-bc # fast em A tt .q. i t %L M.K:s % ka h-asu. d.h. L., l I,, Ucu,s N \\ se n,u erca. v s.,.adou

DCC.'Q i;U.'iXR -L p ... i. wau eua N!AGARA MO WK POWER CORPORATION mAcAna h McHAwx 'f soo case soui.cvano, west c::ccrs) synaeuse. N. v. is aan f i 4 0973Y j June 1,1978 p! 3Y W.* <@$ 'iken Mr. Samuel J. Chilk Secretary of the Co= mission W s* I* Attn: Docketing and Service Section U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Re: Regulatory Guide 1.140: " Design, Testing, and Maintenance Criteria for Nor=al Ventilation Exhaust Systa= Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants" Centlemen: We have review'ed the above-referenced Regulatory Guide and have the -following comments: a) A cost-benefit analysis would not favor installation of e e e e filtration and adsorption units alluded to in this Guide. 7' If the entire man-thyroid-rem dose calculated to the population expected to. reside in the 50 mile region around Nine Mile Point Unit 2 were to be eliminated by the installation of normal ventilation filters, the saving in exposure would amount to 4.4 man-thyroid-rem. At $1,000 per man-thyroid-rem, a cost-benefit analysis would limit expenditures to $4,400. A ventilation / filtration. system to neet the requirements of this Guide would probably cost $500,000 to $1,000;000. b) Assuming the Guide is to be applied, it does not appear reasonable to apply the same removal criteria for a normal ventilation system as for an engineered safety system (i.e., atmospheric cleanup system). Our suggestion vocid be to structure the Guide such that it requires removal efficiency consistent with the cost-benefit. For example, for a given plant, it may be cost-beneficial to have a SO:: removal efficiency system; but not cost-beneficial for a 99% removal system. d % c!g M d 6 card..., _ W Very truly yours, / .s -w..; x NIACARA MOHAWK POWER CORPORATION sh %.)- Donald P. Dise Vice President-Engineering

r. T-N Consumers 1 i I POWBT ....e ' ^ /.C0mpany ~ 1; y, . e ' 9..;/ ;

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..y,:. l-Washington, DC. 20555 .i. a... .2.;. .c The following comments concerning Regulatory Guide 1.1ko, "Desian, Testing, And V Maintenance Criteria For Normal Ventilation Dchaust System Air Filtration And .. Adsorption Units Of Li6 t-Water-Cooled Nuclear Power Plants," are presented for h your consideration) ~ 1. There is no universal need for iodine adsorbers in normal ventilation ex- ~ baust systems to m:eet re6ulated dose requirements. Regulatory Position C.2.a should therefore be rewritten to allow latitude in the use of iodine r, .adsorbers2 ..t g .i, 2. Regulatory Position p.5.d reco= ends adsorber leal testing "...following removal of an adsorber sample for laboratory testing if the inte6rity of the adsorber section is affected...." It is our position that removal,.

of a test cannister,and replace =ent with either an identical test cannistar..

. or an appropriate cap does not constitute an effeci on the inte6rity, of the j' ' adsorber. 3 Regulatory Positions C.S.e and C.S.d specify testing frequencies for HEPA ' filters and activated carbon adsorbers. The' puryu.m, design basis, and frequency of use of systems addressed by this. Guide Quld suggest that the frequency of the tests endorsed by ANSI N510-1975 shduld more appropriately . be determined by the individual licensee with specific plant design a:ui ' Eood engineering practice as inputs to this decision. At a minimum, tho testing frequency should have the latitude to allor its periodicity to co-incide with plant outa6es.

4. Section C.3.b requires DOP testing of each EEPA filter in accordance with MIL-F-51068 and MIL-STD-282. The practice of testing each HEPA filter by the manufacturer in co=bination with in-place testieg as required by Regulatory Position C.5 is adequate in itself to ensure filter perfor=ance.

Further testing of HEPA filters designated for use in normal ventilation systems at a DOE Quality Assurance Station vould result in needless cost and unvarranted exposure to handifng damnge and 'siculd therefore be elimi ~. nated. g g ...1.s....eu.--nn[ofB......:..'.; ~-

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M EBASCO SERVICES INC0nPOnATED UTILITY CONSULTANTS E N GIN E E R s - CONSTRUCTORS TWO RECTOR STREET NEW YO RK. N.Y.10005 c m..aa ......eae-x o ~ q DO M yquggg y j e m m :: m z ? R me June 27, 1978 = k, E JULI.319 8 ~ Secretary of th6 Co =ission egd *;W U. S. Nuclear Regulatory Co==ission E // Washington, D. C. 20555 Attention: Docketing and Service Section Centlemen: - Subj ect: CO) DENTS OF REGUIATORY CUIDE 1.140, (REV. O, MARCH 1978 FOR CO> DENT) " DESIGN, TESTING, AND MAINTENANCE CRITERIA FOR NORMAL VENTILATION EXHAUST SYSTDi AIR FILTRATION AND ADSORPTION i! NITS Or, LIGHT-VATER-COOLED NUCLEAR POWER PLANTS" Ebasco Service has reviewe.d the subject Regulatory Guide and has a number of co==ents. These are as follows: Regulatory Position General The stated purpose of this' guide is to present acceptable =ethods for imple=enting NRC regulations, including 10 CFR 50 Appendix I, with regard to the subject air filtration and adsorption units. The increased annual fixed operating and =aintenance costs associated with this escalation of regulatory require =ents should therefore be considered in the cost benefit analyses perfor=ed pursuant to 10 CFR 50, Appendix I. Ebasco requests the NRC to factor these costs into Regulatory Guide 1.110 " Cost-3enefit Analysis For Radwaste Syste=s For Light-Uqter-Cooled Nuclear Power Reactors". Section B In the fourth paragraph, delete the words, "...and provide redundant protection against particulate release in case of failure of the upstream HEPA filter bank". This is inconsistent with design criteria in Regulatory Position C.2.a which states "...syste=s need not be redundant..." Additionally, downpeream HEPA's are of questionable value ,.for tne following reasons and 'should not require consideration: 1. Breach of an upstrea= HEPA filter is easily detected and repaired with little i= pact on the annual integrated dose. A

EBASCO ' SERVICES 4%CetteRAftt Secretary of the Commission June 27, Regulatory Position 2. Based on.01% carbon dusting (DP-778) and an adsorber efficiency of 90%, the increase of integrated dose is 0.5%. At an adsorber efficiency of 99%, the increase of integrated dose is 6.0%. This assumes that ~~ released dust has six times the average conceration of trapped iodine per lb. of carbon. C.2.a on the fourth line, revise the words to read "... but should consist of some of the following sequential components:" The components required in air cleanin,g unit should be determined by dose considerations only and therefore the wording of this paragraph should not require that all air cleaning units contain HEPA filters and charcoal adsorbers. For example, the ventilation exhaust system for the hot machine shop should contain HEPA filters but need not have charcoal adsorbers. C. 2. b It is Ebasco's understanding (based on discussions at the August 10, 1977 meeting of the ACRS subcommittee on Regulatory Activities) that the limitation of syste=s to 30,000 cfn was based not on maintainability, but on the presumed inability to generate sufficient quantities of dioctyl'phtalate (DOP) to perform an' integrated leak test on larger HEPA banks. Information from testing companies indicates that high espacity DOP generators are now available which can test up to approximately 100,000 cfm. Ebasco therefore, recom= ends elimination of 30,000 cfm size limit and insertion of a requirement for testability. ThisposEtionrequiresheaterswhentherelativehumidityof C.3.a incoming air exceed 70% during normal reactor operation but gives no guidance on the criteria for determining the relative humidity. Ebasco suggests that providing guidance on the relative humidity of outside air would be sufficient and that the average relative humidity should be sufficient. Utilizing the relative humidity of outside air which -is seen 50% of the time recognizes that the relative humidity will decrease as it is heated inside the building, that the decrease in adsorber efficiency is only applicable to same release (i.e. methyl and not elemental iodine), and that the decrease in efficiency is gradual so that 10 CFR 20 guidelines are noy likely to be exceeded. a-

.1 EBASCG SERVICES Ist8er0laATEa Secretary of the Coc=ission June 27,19 Regulatory Position C.S.c It is i= practical and unnecessary to require testing of entire HEpA filter banks.that are used during nor=al plant operation whenever paints or chemicals are used during routine =aintenance or in the event of fires. It is difficult to i=agine any significant a=ount of particulates being ;;;enerated by use of paints or chemicals but if there are, the effect vill be shown by an increased pressure drop across the filters. This is monitored as part of routine maintenance and the filters changed as required. Additionally, =enitors in plant ventilation discharge ducts provide continuous surveillance that would detect any significant change in system reIcases and thereby require testing of system co=ponents. This approach should be more than enough to assure that the public is protected from plant air-borne releases in accordance with both 10 CFR Part 20 and Part 50, Appendix I. r C.S.d and It is i= practical to require testing of entire charcoal Table 2 adsorber banks that are used during nor=al plant operation Footnote c whenever paints or chemicals are used or in the event of a s=all fire within the area served by the air clean *q system. Obviously a half pint can of touch up paint open'ed for half an hour is not going to degrade the charcoal of a 50,000 CFM system. Monitors in plant ventilation discharge ducts provide ~ continuous surveillance that vould detect any significant change in system releases and thereby require testing of system components. If the =enitors show the effluent releases to be within regulatory require =ents, then undue testing should not be required just because there is possible degradation of filters. If it is felt necessary to go beyond =onitoring, then we suggest that the NRC staff establish specific guidelines in t er=s of -w'-" square feet of surface to be painted per 1000 Cai per 2 inch adsorber bed depth. It vould be . presu=ed that the air cleaning unit in question is exhausting the room centaining these exposed conta=inant sources for seme mini =us ti=e period. Another possible approach is to require, af ter painting or use of other charcoal conta=inants,- ,one of the sa=ples to be re=oved, a leak test perfor=ed on it, and the sa=ple replaced if the results are acceptable.

EBASCO SERVICES imeenretATES Secretary of the Co= mission June 27,1978 Regu,latory Position Where a systen.is continuously exposed to contacinants (i.e. lab hood exhaust) some frequent periodic leak testing of a sample should be adequate, particularly .s where these exhausts are normally a very small part of the effluent passing through an air cleaning unit. C.6 and The purpose of the efficiencies given in Table 2 is not Table 2 stated although they are assumed to be for Appendix I . calculations. Furthermore, the efficiences assigned are not based on actual tests of activated charecal but are correlated with the efficiencies assigned to post accident safety grade systems. There is no rational for using these latter efficiencies since theyinclude the margins required for post accident calculations. Ebasco suggests that the purpose of the efficiency assign-ment be defined and that efficiencies associated with actual tests (Table 1) be given. Alternatively, the qualification and testing criteria should be revised for, consistency with the assigned efficiencies. Ebasco hopes our cocments will be considered carefully and would welcome the opportunity to participate in any discussion with the NRC staff on this proposed guide. Very truly yours, / 4" E M E P O'Donnell Chief Engineer Nuclear Licensing EPO:bds y.- ,, ~. -

_=__ O P. O. box 013100, MIAMI, FL 33101 1 (sXms mn g gg(3w.-.,g e.,g. g y FLORioA POWER & 4.lGHT COMPANY DOCIET I:Uuate August 29. 1978 DVDSEDEULE <3 tv 282 d' h[f 4l Secretary of the Commission O. S. Nuclear Regulatory Commission - g h Hashington, D. C. 20555 g.g Attention:, Docketing and Service Branch Gentlemen: boy Re: Regulatory Guide 1.140 Design, Testing and Maintenance Cr*+a-ia for Normal Ventilation Exhaust System Air Filtration and Absorption Units of Light-Water-Cooled Nuclear Power Plants .1 Florida Power and Light Company wishes to submit the follcwing comments on Regulatory Guide 1.140 " Design. Testing and Maintenance Criteria for Nonnal Ventilation Exhaust System Air Filtration and Absorption Units of Light-Water-Cooled Nuclear Power Plants:" .v r, Regulatory Guide 1.140 expressly states that post accident cleanup systems do not fall within its purview; however, close comparison with Regulatory Guide 1.52 for pos.t accident systems reveals testing and maintenance criteria which are very nearly identical. As a result an unnecessary restriction is imposed upon the normal operation system i, 'which clearly exceeds any resulting benefit. As described in'the guide, the normal operation cleanup system and post accident system are widely divergent in duties and operating conditions. The post accident system is designed to function properly under adverse conditions ta mitigate the effects of design basis accidents, while the system in question is designed for normal controlled operation..To require the same maintenance and testing criteria for such divergent systems is clearly excessive and diminishes the required flexibility for an, oper-ating system. It is therefore, recommended that testing frequencies and criteria set forth in Regulatory Guide 1.140 be modified to provide more flexibility and compatability with operating schedules and safety considerations. We appreciate the opportunity to comment on the Guide. Very truly yours. & f M. } {. S ^ mertE.U{g Mngd %g,,((,,,,,;,,,, g-

s...s The American Society of Mechanical Engineers ) .CS United Engineering Center /345 E. 47th St., New York. N.Y.10017/212 644-7722 M\\~ 9 g 000:U I:1.C;-m-PJiGP03EQ AULE g 'h hM 1@ se22137B> j %a sf 6 Septembe.r 18, 1978 a-I f Secretary of The Coc::ission U; S. Nuclear Regulatory Co=nission i Washington, DC 20555

Subject:

ASME CONAGT co=nents' on, Reg. Guide 1.%

Dear Sir:

The ASME Cocinittee on Nuclear Air and Gas Treat =ent has developed consents on Regulatory Guide 1.%, " Design, Testing, and Maintenance criteria for normal ventilation exhaust system air filtration and f . adsorption units of Light-water-cooled Nuclear Power Plants." They are enclosed for your consideration. Very truly yo rs, Ray E. Weber Senior Nuclear Engineering Administrator -i' am:cv Eccl. ~ c.c: J. 7. Fish D. Wittike dr j ..=.ewsw e - - + - l i g' l k - - = =..

o* n-ASME Coccittee on Nuclear Air and Gas Treatment Comments on USNRC Reg. Cuide 1.1d4) Canaral comment: we question the need for such a detailed document in light of the fact that N509 and N510 are available and.are being revised to further improve them with estimated availability at least by early.1979. It is recognized that Reg. t.uide 1.52 was the model for 1.140 but it is further recognized that when 1.52 was first published, neither N509 nor N510 was in existence. Today it seems practical to reduce these Guides from their present length and likely produce core pertinent documents by limiting their content to qualifying or taking exceptions to specific sections of the ASME/ ANSI documents as is done in.a number of other existing Regulatory Guides. Specific comments as follows: Section B. 3rd paraerno'h, first sentence. Concerns: This brings up the subject of very low concentrations of radioactive iodine. While not referred to in the rest of the document, this could prove to be a questionable subject to prove or disprove in the future. . Discussion: The standard test procedures for radiciodine adsorb'ers uses canisters 50=m in diameter with a velocity of 12 m/ min. Hence the flow is 3 cm / min (3/4) (5) (5) (1200) 23580 ~ = For a 120 minute test, we sample a gas volume of: 6 2.83 x 10 120 x 23580 = At a concentration of 10-0)QCi/cm, we have 2.83Jyci reaching the canister. 3 For a penetration of cay 0.01% (as for I ) we have 283 x 10-6[L Ci, or 283/2 Ci 2 Thisisabout10 counts /see,whichisreadilydetectable. However, passiq-3)(Ci/cm, we are far below the lower limit of detection. at 10 3 Thus, there is no practical means of demostrating the performance of the materials at this activity; we can only infer _that the performance is equivalent to that at higher ac activities. This is a reasonable assumption, since there is no reliable evidence that adsorber performance is a function of specific activity until very hig. activity level are reached. Performance is, however, very sensitive to the mass concentration of contaminants, and the expected range of these should be specifeed. The problem with such specification seems to be that NRC regulates only radioactire contaminant concentrations, and here the significant factor is the concentration of all isotopic forms, not just the radioactive ones. However, the Guide lists humidity ranges of con:ern; there is no reason that ~ a statement cannot be put in about mass concentrations. We suggest this wording: s r 6 o \\ = h*

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s "Nor=al environ = ental conditions underwhich these at=osphere cleanup system: should operate are: inlet = ass concentrations of iodine and its compounds 3 (of all isotopic forms) in the range from 0.01 to 100 mg/m ; relative hu=idity..." i i + In the following paragraph, instead of " carbon fines" I suggest " fine particles that may be blo'un off from the adsorber" would be more readily understandable to many people. We aIso suggest that Section C. 6.a be revised to reference ANSI N509, in the l same way that Reg. Guide 1.52 now does. Th'.s will eliminate conflicting state =ents a=ong these documents. B, 4th Paragraoh - Pace 2: Concern: A second set of REPA filters are discussed t l to collect carbon fines and used as redundant protection in case the first set fails. l Discussion: t For theelpv levels of particulate contamination and radioicdine, I redundancy should not be required nor should sufficient contaminated carbon i fines be generated near the exit of the adsorber to be a hazard, particularly l in the 12-18 month test cycel required. Section C.2.a relieves the requirement for redundancy. 3,'4th Pararrach - Pace 2: Concern: The fan.is th,e final item in an at=osphere cleanup system. Discussion: Suggest '*Ihe fan is an item....." Depending on the use, the fan could be the first item or in so=e other location. I E, 5th Paraerach - Page 2: Concern: '*"herefore, aging, weathering, and poisoning of these...." Discussion: This paragraph has some redundant portions and the word poisoning ,l is nebulous. Suggest the following wording: "Therefore the life of these cc=pon.:acs m.y vary from site to site and requires consideration during design ~I and operation." Also delete the next sentence in the text., E, 5th Paracrach - Pace 2-Concern:- "... scheduled testing durine coeration." ~ It is i=pract:ical to test a. system during operation. Suggest the Discussion: +- last two words of the paragraph to be deldted. C.I.a - Pace 3: Concern: Second sentence poorly structured. Discussion: Suggest the following wording: "The cleanup system design should be based on continuous...." p .'e. e a ~

~ ~ ~ '

rase s 0-s. C.2.a - Pace 3: Concern: Atmosphere cleanup systems consist of the following sequential...." i Discussion: See previous item. Suggest omission of the word secuential. There is also a difference in the equipment enumerated here and on Page 2, i ~ B, 5th paragraph. C.2.b - Page 3: Concern: The limit of '30,000 cfm per train. . Discussion: This may be a desirable goal but should not be, mandatory. When lR.'G.1.52wasfirstwrittentherewasdifficultywithequipmentgenerating sufficient aerosol or ' gas to obtain accurate readings. These equipment problems have been solved and the limitation is not neceasary. C.2.c - Pace 3: Concern: Section 5.6.7 of ERDA 76-21 tequiresEonly local indication of 6 p across each HEPA bank and indication of critical air flow I rates. Discussion: Suggest the following wording: "Each atmosphere cleanup system shall be locally instrumented to indicate pressure drop across each HEPA filter bank and indicate flow rate. In addition, there shall be (control room) alarm for high pressure drop across the first HEPA filter bank and alarm high or low flow rate. C.2.'f - Page 3: Concern: Leakage rates for non-ESF systems. Discussion: Leakage of ductwork and htusings and methods for testing is receiving considerable work by the committee revising ANSI N509 and N510 R. G. 1.140 should reflect their work. C.3.b - Paee 3: Concern: Specification for use of dioctyi phthalate (DOP) as the test aerosol. Discussion: MIL specs and st'andards amply designate the test method and material. g Suggest the phrase "...for penetration of dioctyl phthalate -(DOP)..." be. I deleted. 2 ~. C.3.1 - Page 4: Concern: Typo error, " motors" should be singular. C.3.1 - Page 4: ' Concern: Typo errorf Should reud: "The fan and motor used'in...". ~ C.3.k - Paee 4: Concern: In last sentence straightening vanes are required to, " ensure... uniform flow distribution...". ~ ~

r. s-Discussion: Straightening vanes reduce turbulence and flow vectors not parallel with duct but do not provide a unifor= flow distribution as found after a change of direction. Turning vanes or perforated resistance plates are required for reducing gross non-unifor=ity of flow. C 4.b - Page 4: Concern: The =eaning is not entirely clear. Discussion: Suggest the following wording efianges. "For_ ease of inspection and =aintenance with =ini=u= danger of da= age, the syste= design should provide for a minu=tru of three feet clear access space in each ce=partment after allowing for the co=ponent di=ension itself.(if l any) and the =axi length of the co=ponent during changeout (if any)." l C.S.d - Pace 5: Concern: (4) require =ents for retesting. I-Discu'ssion: Painting, fire, or che=ical release in a connecting ventilation zone vill not, by itself, i:aus'e a leak. The above occurences =ay reduce the adsorber's ability to retain radiciodine species and are therefore reasons for laboratory retesting but not ror leak testing. ~ Table 1.Page 6: Concern: Values and references. l . Discussion: This table should confor:s to Table 5-1 of ANSI N509 (to be revised 19 78). Reg. Guide 1*.52 dropped this table. If ve.end up with two different table's (one in 1.140 and'one in N509) we create confusion. We probably also will find carbon qualified to one set of require =ents used in syste=s built to .other require =ents. We should end up with one requirement for nuclear usage., Table 2, footnote C refers to Testing (1) initially etc. Carbon test requirements are based on 957. RH perfor=ance.. Table 2 is based on 707. RH perfor=ance. Thus I this require =ent seems to =andate two initial " batch" tests, one at 957. and one at 707., a require =ent which probably was not intended.

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rP (.ol-y i [s. Gilbert / Commonwealth enginee s and conse. antsN, Q)en. g @ GILBERT ASSOCIATES, INC. P. O. Ecx MS2. Reading. PA 1SSG3/Tel 215 775-2SC0/ Cable G3aso:/Te!ez E33431 October 4, 1978 i2.tb ne a O PRQtQgg g y .M i OC,t t sP 9 .g. s .i g wa f Secretary of the Com:nission "U**s.n U. S. Nuclear Regulatory Co=sission b g j Washington, D. C. 20555 a go Attention: Docketing and Service Section Gentlemen: We appreciate the opportunity to review Regulatory Guide 1.140 dated March, 1978. Although we are in' general agreement with the goals and procedures of the guides, we have the following comnent to offer for your consideration. Current air filter manufacturers are supplying separator "" less HEPA filters rated at 1500 cfm each. Therefore a three high by ten vide arrangenent would yield a flow of 45,000 cfm. 'Since this is the current industry offering, it is requested that Para. C.2.b. be updated to reflect a limit epnsistent with available technology. Very truly yours, S. D. Goodnan Manager Support Engineering SDG:LEM:C Power Engineering Division-Reading cc: L. B. Myers 'D. C. Kasperski

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RESOLUTION OF COMMENTS REGULATORY GUIDE 1.140 " DESIGN, TESTING, AND MAINTENANCE CRITERIA FUR NORMAL VENTILATION EXHAUST SYSTEM AIR FILTRATION AND ADSORPTION UNITS OF LIGHT-WATER-COOLED NUCLEAR POWER PLANTS"

SUMMARY

This revision is the result of public comments received on the guide (March 1978) and additional staff review. The revisions are essentially editorial and have been made to clarify criteria for (1) atmc3phere cleanup system design, (2) incoming atmosphere relative humidity, (3) in-place testing frequency of HEPA filters and activated carbon adsorption units, and (4) laboratory testing frequency of representative samples of activated carbon. DISCUSSION Comments were received from: 1. Sacramento Municipal Utility District, dated 4/19/78 2. James J. Drasier, dated 5/1/78 3. Niagara Mohawk Power Corporation, dated 6/1/78 4. Consumers Power Company, dated 6/9/78 5. Ebasco Services, Inc., dated 6/27/78 6. Florida Power and Light Company, dated 8/29/78 7. ASME/ Committee on Nuclear Air and Gas Treatment, dated 9/18/78 8. Gilbert Associates, Inc., dated 10/4/78 All comments were carefully considered and some resulted in changes which appear in the proposed Revision 1 draft. The significant comments 1

are enumerated along with their resolutions in the summary below. Responses indicating changes in regulatory position are underscored. Commenters are identified by the number designation above and individual comments are identified parenthetically by the item number, where appropriate, as desig-nated in each letter of comment. A. GENERAL Comment: #3 (Item 1) commented that a cost-benefit analysis would not favor installation of filtration and adsorption units alluded to in this guide in the case of Nine Mile Point Unit #2. Response: The staff agrees, assuming the calculations are correct. The guide presents methods acceptable to the NRC staff for implementing the Commission's regulations in 10 CFR Part 50 and in Appendices A and I to 10 CFR Part 50. Appendix I provides, among other things, that the appli-cant include in the radwaste system all items of reasonably demonstrated technology that, when added to the system sequentially and in order of diminishing cost-benefit return, can for a favorable cost-benefit ratio effect reductions in dose to the population reasonably expected to be within 50 miles of the reactor. If the cost of additional equipment is greater than the benefit of reduced population exposure, such additional equipment would not be justified according to the criteria of Section II D of Appendix 1. 2

Coment:

5 (Item 1) requested that the NRC factor the fixed operat-ing and maintenance costs associated with implementation of Appendix I, 10 CFR Part 50 into Regulatory Guide 1.110, " Cost-Benefit Analysis For Radwaste Systems For Light-Water-Cooled Nuclear Power Reactors."

Response: The costs in Regulatory Guide 1.110 do, in fact, already include the annual fixed operating and maintenance costs associated with systems that are designed, tested, and maintained in accordance with the recommendations of Regulatory Guide 1.140. It is the objective of Regula-tory Guide 1.110 to provide an acceptable method of performing the cost-benefit analysis required by Section II D of Appendix I. The guide pro-vides cost parameters for estimating the costs for the various radwaste treatment equipment items in use or proposed for use at LWRs and a methodo-logy for performing the analysis. The costs presented consider the direct equipment cost and the costs of building space, supportive services, maintenance, interest and operating, as well as other costs generally considered in analyzing capital and operating costs in power plant estimating. Comment: #6 suggested that testing frequencies and maintenance criteria be modified to provide more flexibility and compatability with operating schedules and safety considerations. 3

Response: The staff disagrees. The testing frequencj and maintenance criteria are equally applicable to both ESF systems and normal ventilation systems. Further, these criteria provide sufficient flexibility and compatability with operating schedules and safety considerations. Comment:

3 (Item 2) suggested that the guide be structured such that it requires removal efficiency consistent with the cost-benefit.

Response: The staff disagrees. It would be unworkable and arbitrary to assign a sliding scale removal efficiency based on a cost-benefit analysis as suggested in this comment. If this suggestion was incorpora-ted, filter systems would be nonstandard with different acceptance criteria for different systems. There is some choice, as the guide is now structured, with different removal efficiencies for different carbon bed depths. Comment:

7 questioned the need for such a detailed document and suggested that it be reduced by limiting its content to qualifying or taking eaceptions to specific sections of ANSI /ASME N509-1976 and ANSI N510-1975.

Response: The need for a detailed document was discussed with the ACRS Subcommittee on Regulatory Activities during its review of the draft guide. The ACRS concurred with the staff decision to include all necessary details until ANSI /ASME N509-1976 and ANSI N510-1975 are revised to be in a 4

more useable form. As is noted in Section B (Discussion) of the guide, these two ANSI standards and other standards are referenced in the guide where they are acceptable to the NRC staff. B. DISCUSSION Third Paragraph Coninent:

7 suggested that the expected ranges of mass concentration of iodine and its compounds (of all isotope forms) be specified, in the first sentence, rather than concentrations of radioactive iodine.

Response: The staff disagrees. The suggested mass range specifica-tion fcr iodine is the responsibility of the designer. The NRC is pri-marily concerned with the radioactive isotopes of iodine and not with stable iodine isotopes. Fourth Paragraph Comment: (a) #7 suggested, for increased clarity in the fifth sen-tence, substitution of " fine particles that may be blown off from the adsorber" for " carbon fines." (b) #7 suggested that redundancy should not be required in the fifth sentence for the low levels of particulate contamination and radiciodine and that Regulatory Position C.2.a. relieves the requirement for redundancy. 5

(c) #5 (Item 2) suggested deletion from the fifth sentence of the words, "...and provide redundant protection against particulate release in case of failure of the upstream HEPA filter bank," since this is inconsistent with design criteria in Regulatory Position C.2.a. which states "... systems need not be redundant...." (d) #7 suggested that the penultimate sentence be changed from "The fan is the final item -- " to "The fan is an item-- "since the fan could be the first item or in some other location, depending on the use.

Response

(a) The need for any change is not apparent. Although the suggested rewording is more accurate, the terminology presently used in the guide is acceptable by industry and is, in our opinion, readily understandable. (b)(c) The need for any change is not apparent. The staff considers it good engineering practice to include the downstream bank of HEPA filters, but it is not part of the regulatory position to include them. Therefore, an applicant need not include downstream HEPA filters to satisfy the recommendations of the regulatory guide. (d) The staff disagrees. The fan should be the final item in an atmosphere cleanup system to provide negative pressure in as much of the duct system as possible and thus prevent outleakage of air from any portion of the air cleanup system. 6

Fifth Paragraph Comment: (a) #7 suggested rewording of this paragraph to eliminate redundancy as well as the word " poisoning" which is nebulous. (b) #7 suggested eliminating the last two words of the paragraph since it is impractical to test a system during operation.

Response

(a) The need for any change is not apparent. (b) The need for the change is not apparent. The intent of this sentence is not to require filter testing during operation of the filter system but to require that the scheduling of testing reflect filter system operation. Seventh Paragraph Comment:

1 (Item 1) suggested that references to ANSI N510-1975,

" Testing of Nuclear Air Cleaning Systems," should be revised to reflect the new revision to that standard scheduled for publication in 1978. Response: The staff agrees. However, such suggested changes will be deferred until after publication and evaluation by the NRC of the proposed revision to ANSI N510-1975. 7

C. REGULATORY POSITION C.l.a. Coment:

7 suggested that the second sentence was poorly structured and should be reworded.

Response: The need for any change is not apparent. C.2.a. Coment: (a) #7 suggested omission of the word " sequential" in the first sentence, presumably to allow for location of the fan other than as the final item in the atmosphere cleanup system. (b) #7 suggested that there is a difference in the equipment enumerated here and in the fourth paragraph of Section B (Discussion). (c) #4 (Item 1) and #5 (Item 3) suggested that this section be modified to allow latitude in the use of charcoal adsorbers. Response _: (a) The need for the suggested change is not apparent. See response to comment (d) for Section 8 (Discussion) - Fourth Paragraph. (b) There is no difference in the equipment enumerated in C.2.a. and in the fourth paragraph of Section B (Discussion). 8

(c)Thecommentisincorporated. A sentence is added at the end of this section. It reads: "Whenever an atmosphere cleanup system is designed to remove only particulate matter, a component for iodine adsorption need not be included." C.2.b. Comment: (a) #5 (Item 4) suggested elimination of the 30,000 cfm size limit and insertion of a requirement for testability since information from testing companies indicates that high capacity D0P generators are now available which can test up to approximately 100,000 cfm. (b) #7 suggested that the limit of 30,000 cfm per train should not be mandatory since the limitation, originally based on dif-ficulty with equipment generating sufficient aerosol or gas to obtain accurate readings, is no longer necessary. (c) #8 suggested modification of this section to reflect a limit consistent with the use of HEPA filters rated at 1500 cfm each.

Response

(a) (b) The staff disagrees. The 30,000 cfm limitation is based on the inability to generate sufficient uniform quantities of 00P for leak testing on larger HEPA banks. The staff is not aware of any DOP generators capable of testing systems substantially larger than 30,000 cfm with acceptable reliability. 9

(c) The staff disagrees. The position states that a filter layout that is three HEPA filters high and ten wide is preferred; this is not a requirement or a recommendation but a suggestion. There-fore, HEPA filters rated at 1500 cfm and other layouts are allowable so long as the volumetric air flow rate of a single cleanup train is limited 3 to approximately 30,000 ft / min for ease of maintenance and testing. C.2.c. Comment: #7 suggested the following wording: "Each atmosphere cleanup system should be locally instrumented to indicate pressure drop across each HEPA filter bank and indicate flow rate. In addition, there shall be (control room) alarm for high pressure drop across the first HEPA filter bank and alarm high or low flow rate." Response: The staff disagrees. There is no technical justification for requiring control room indication of normal venti-lation system operation. C.2.f. Comment: #7 suggested that this guide reflect the work done by the committee revising ANSI N509 and N510 with respect to leakage of duct-work and housings and methods for testing. Response: When ANSI standards N509 and N510 are revised, the staff will consider revising this regulatory guide to reflect the work of this committee. 10

C.3.a. Comment:

5 (Item 5) suggested that the average relative humidity of the outside air be used as the criterion for determining relative humidity.

Response: The comment is incorporated as follows. The second sentence is revised to read: "If the average relative humidity of the incoming atmosphere is expected to be greater than 70% during normal reactor operation, heaters or cooling coils used in conjunction with heaters should be designed to reduce the average relative humidity of the incoming atmosphere to 70%." C.3.b Comment: (a) (Item 4) suggested that furtiier testing of HEPA filters designated for use in normal ventilation systems at a DOE Quality Assurance Station would result in needless cost and unwarranted exposure to handling damage and should therefore be eliminated. (b) #7 suggested deleting the phrase "---for penetration of dioctyl phthalate (00P)--- ". Response: (a) The need for the suggested change is not apparent. Nowhere in the guide is it recommended that HEPA filter testing be done at a DOE Quality Assurance Station. 11

(b) The need for the suggested change is not apparent. C.3.i. Comment:

7 suggested " Motors" should be singular.

Response: The comment is incorporated. C.3.j. Comment:

7 suggested a typographical error and revised the sen-tence to read: "The fan and motor used in --- ".

Response: This is not a typographical error and there is no need for the suggested change. C.3.k. Comment:

7 suggested that turning vanes or perforated resistance plates are required, rather than straightening vanes, for reducing gross non-uniformity of flow.

Response: The second sentence is changed to read: " Turning vanes or other air flow distribution devices should be installed---." C.4.b. Comment:

7 suggested the following word changes to clarify the meaning:

"For ease of inspection and maintenance with minimum danger 12

of damage, the system design should provide for a minimum of three feet clear access space in each compartment after allowing for the component dimension itself (if any) and the maximum length of the component during changeout (if any)." Response: The need for the suggested change is not apparent. C.5.c. Comment: (a) The second sentence should be revised, in accordance with the suggestion of #2 (Item 1), to read: "HEPA filter sections should be tested in place initially and at least once per 18 months thereafter (during a scheduled reactor shutdown is acceptable)." (b) #4 (Item 3) suggested that the frequency of the test should be determined by the individual licensee with specific plant design and good engineering practice as inputs to this decision and that, at a minimum, the testing frequency should have the latitude to allow its periodicity to coincide with plant outages. (c) #5 (Item 6) suggested that it is impractical and unnecessary to require testing of entire HEPA filter banks that are used during normal plant operation whenever paints or chemicals are used during routine maintenance or in the event of fires. 13

Resoonse: (a) The comment is incorporated. (b) The need for any change is not apparent. The purpose of the guide is to present minimum acceptable criteria. The testing frequencies have been determined considering specific plant designs and good engineering practice, as the coment suggests. The testing frequency does allow for testing coincidental with plant outages. (c) The need for any change is not apparent. Testing of HEPA filter banks is only required following painting, fire, or chemical release when there is communication with the ventilation zone in such a manner that the HEPA filters could become contaminated from the fumes, chemicals, or foreign materials. C.5.d. Comment: (a) #2 (Item 1) suggested that the third sentence be revised to read: Adsorber leak testing should be conducted (1) initially, (2) at least once per 18 months thereafter (during a scheduled reactor shutdown is acceptable), (3)...from the fumes, chemicals, or foreign materials." (b) #4 (Item 3) suggested that the frequency of the test should be determined by the individual licensee with specific plant design and good engineering practice as inputs to this decision and that, at a minimum, the testing frequency should have the latitude to allow its periodicity to coincide with plant outages. 14

(c) #4 (Item 2) suggested that removal of a test canister and replacement with either an identical test canister or an appropriate cap does not constitute an effect on the integrity of the adsorber. (d) #5 (Item 7) suggested that it is imptactical to require testing of entire charcoal adsorber banks that are used during normal plant operation whenever paints or chemicals are used or in the event of a small fire within the area served by the air cleaning system. (e) #7 suggested that painting, fire, or chemical release in a connecting ventilation zone will not, by itself, cause a leak but may reduce the adsorber's ability to retain radioiodine species and are therefore reasons for laboratory retesting but not for leak testing.

Response

(a) The comment is incorporated. (b) The need for any change is not apparent. See response to comment (b) for C.5.0. (c) The need for any change is not apparent. The guide as presently written agrees with the comment. (d) The need for any change is not apparent. Testing of charcoal adsorbers is only required following painting, fire, or chemical 15

release when thcre is communication with the ventilation zone in such a manner that the charcoal adsorbers could become contaminated from the fumes, chemicals, or foreign materials. (e) The staff disagrees. The need for any change is not apparent. C.6.a. Comment: (a) #5 (Item 8) suggested that the purpose of the efficiency assignments in Table 2 be defined and that efficiencies associated with actual tests (Table 1) be given since the efficiencies assigned in Table 2 are not based on actual tests of activated charcoal but are correlated with the efficiencies assigned to postaccident safety gr> "a systems. (b) #7 suggested that this section be revised to reference ANSI N509 in the way that Regulatory Guide 1.52 now does, there-by eliminating conflicting statements among these documents.

Response

(a) The staff disagrees. The purpose of the efficiencies in Table 2 is explained in Regulatory Position C.6.a. and in the Intro-duction. The efficiencies assigned to Table 2 have no correlation whatsoever with the efficiencies assigned to postaccident safety grade systems. Efficiencies for postaccident safety grade systems are assigned 16

in Table 2 of Regulatory Guide 1.52. New unused activated carbon must meet the physical property specifications of Table 1 (including radio-iodine removal efficiency tests) in order to be assigned the removal efficiencies in Table 2 for design purposes. (b)Thestaffdisagrees. ANSI N509-1976 cannot be referenced since it does not contain a corresponding table for new acti-vated carbon to be used in the activated carbon adsorber section of a normal ventilation atmosphere cleanup system. Table 1 Comment:

Q #1 (Item 2) suggested that an ASTM standard (to be issued)should

. referenced for preferred test procedures for radio-iodine testing of new activated carbon instead of RDT Standard M16-lT since the analogous procedures in the latter standard have been found to be deficient. (b) #7 suggested that this table conform to Table 5-1 of ANSI-N509.

Response

(a)Thestaffagrees. However, such suggested changes will be deferred until after publication and evaluation by the NRC of the ASTM standard. 17

(b) The staff disagrees. This reference Table does not conform to Table 5-1 of ANSI N509-1976 because that table applies to new activated charcoal to be used in the activated carbon adsorber section of an engineered-safety-feature atmosphere cleanup system. Table 2 Connent: (a) #1 (Item 3) suggested that a test condition should be specified for systems (designed to operate outside of primary containment) which may not have relative humidity control. (b) #5 (Item 8) suggested that the purpose of the efficiency assignments in Table 2 be defined and that efficiencies associated with actual tests (Table 1) be given since the efficiencies assigned in Table 2 are not based on actual tests of activated charcoal but are correlated with the efficiencies assigned to postaccident safety grade systems. (c) #1 (Item 3) suggested that there may be a typographical error in the assigned activated carbon decontamination efficiency for radiciodine in the case of the two-inch deep activated carbon bed designed to operate outside the primary containment. 18

(d) Footnote c should be revised, in accordance with the suggestion of #2 (Item 2), to read: ... Testing should be performed (1) initially, (2) at least once per 18 months thereafter (during a scheduled reactor shutdown is acceptable), and (3)...." (e) #5 (Item 7) suggested that it was impractical to require testing of representative samples of activated carbon whenever paints or chemicals are used or in the event of a small fire within the area served by the air cleaning system. (f) #7 suggested that the requirement in Footnote c seems to mandate two initirl " batch tests", one at 95% and one at 70%, which was probably not intended.

Response

(a) As stated in the implementation section of this guide, the guide reflects current NRC staff practice. Accordingly, the guide is directed toward new filter systems rather than systems already in service. As stipulated in Regulatory Position C.2.a., systems that are designed to meet the recommendations of this guide should include heaters or cooling coils used in conjunction with the heaters when the humidity is to be controlled before filtration. Accordingly, there is no need to revise Table 2 to include test conditions for systems which may not have relative humidity control. (b)Thestaffdisagrees. See response to comment (a) for C.6.a. 19

(c) The entry is not a typographical error. The staff has made the determination that activated carbon (of two-inch and four-inch bed depth) may be considered exhausted and should be replaced whenever laboratory tests for representative samples indicate methyl iodide removal efficiencies less than 90% irrespective of the assigned activated carbon decontamination efficiencies for radioiodine. (d) The comment is incorporated. (e) The need for any change is not apparent. See response to comment (d) for C.S.d. (f) The radiciodine removal efficiency tests (at 95% relative humidity) in Table 1 are part of the qualification and batch test requirements for each original or replacement batch of impregnated activated carbon to be used in the adsorber section. The methyl iodide penetration tests 1 (at 70% relative humidity) in Table 2 are for labora-tory tests of representative samples of the activated carbon used in the adsorber section (and exposed simultaneously to the same service conditions) to verify that the activated charcoal in the adsorber section is still acceptable. In order to establish an initial point for compari-son of future laboratory test results, laboratory tests similar to those conducted as indicated in Table 2 should be performed on an adsorbent sample before loading into the adsorbers. 20

a VALUE/ IMPACT ASSESSMENT ON 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 NUCLEAR POWER PLANTS" I. The Proposed Action A. Description Design, testing and maintenance guidance on normal ventilation exhaust systems for light-water-cooled nuclear power plants is provided to applicants or licensees to ensure that these systems will function to collect airborne radioactive materials during normal plant operation including anticipated operational occur-rences. Regulatory Guide 1.140 addresses the atmosphere cleanup system and was issued for public comment in March 1978. Proposed Revision 1 of the guide (1) incorporates public comments, as appropriate, and (2) clarifies ambiguities. B. Need for the Proposed Action Regulatory Guide 1.140 needs revision tn incorporate comments received from industry and staff and to clarify design, testing and maintenance criteria. C. Value/ Impact of the Proposed Action 1. NRC The proposed revision clarifies design, testing, and maintenance criteria and incorporates comments from industry

and staff. It modifies several requirements without reduc-ing reliability of performance of the atmospheric cleanup system, thereby reducing cost and effort. Since the revised positions of this guide continue to reflect current regula-tory practice, no change is required in the implementation schedule indicated in the guide issued for comment. 2. Other Government Agencies Not applicable, unless the government agency is an applicant, as TVA. 3. Industry The value/ impact on applicants and licensees will be the same as for the NRC, as indicated above. 4. Workers To maintain the radiation exposure to operating personnel as low as is reasonably achievable during plant maintenance, the proposed action provides (as does the original guide) that atmospheric cleanup systems should be designed to control leakage and facilitate maintenance in accordance with the guidelines of Regulatory Guide 8.8, "Information Relevant to Ensuring that Occupational Radiation Exposures at 2

Nuclear Power Stations Will Be As Low As Is Reasonably Achievable." Accordingly, a beneficial impact on workers can be expected. 5. Public Since there is no reduction in reliability of performance of the air cleanup system, no impact on the public is expected. D. Decision on the Proposed Action Regulatory Guide 1.140 should be rt " sed. II. Technical Approach A. Technical Alternatives The proposed revision involves primarily two technical considera-tions each of which can be expressed in alternative terms. These are: Criteria for iodine adsorbers Performance criteria for heaters Alternative approaches relating to these technical considerations are described in the following section. 3

B. Discussion and Comparison of Technical Alternatives 1. Criteria for Iodine Adsorbers Regulatory Guide 1.140 is not sufficiently clear in allowing flexibility in the use of iodine adsorbers in atmosphere cleanup systems. As an alternative, the guide can be modified to allow for flexibility in system design criteria. 2. Performance Criteria for Heaters Regulatory Guide 1.140 does not provide sufficient design criteria, with respect to relative humidity of the incoming atmosphere, for heaters or cooling coils used in conjunction with heaters. As an alternative, this information can be incorporated into the guide. C. Decision on Technical Approach 1. The guide is modified to indicate clearly that a component for iodine adsorption need not be included in an atmosphere cleanup system whenever the system is designed to remove only particulate matter. A saving in cost may be realized from this change since it permits greater flexibility by the user of the guide without reducing reliability of performance of the atmosphere cleanup system. 4

2. The design criteria for heaters or cooling coils used in conjunction with heaters are clarified in the revised guide by specifying average relative humidity of the incoming atmos-phere as a benchmark for comparison. No significant impact is anticipated as a result of this change. III. Procedural Approach A. Procedural Alternatives None. The proposed action is a revision of an existing regulatory guide. B. Value/ Impact of Procedural Alternatives Not applicable. C. Deci'sion on Procedural Approach Regulatory Guide 1.140 should be revised. IV. Statutory Considerations A. NRC Authority The Comission's regulations in 10 CFR Fart 50 and in Appendices A and I to 10 CFR Part 50 require, in part, that means be employed by applicants for, and holders of, licenses for nuclear power plants, to assure that release of radioactive material to unrestricted 5

areas during normal reactor operation, including expected opera-tional occurrences, be kept as low as is reasonably achievable. B. Need for NEPA Assessment The proposed action is not a major action, as defined by 10 CFR 51.5(a)(10), and does not require an environmental impact statement. V. Relationship to Other Existing or Proposed Regulations or Policies The revised guide reflects current NRC staff practic( and no backfitting is expected from its issuance. VI. Summary and Conclusions Revision 1 to Regulatory Guide 1.140 has been prepared. It(1) incorporates public comments, as appropriate and (2) clarifies ambiguities. Revision 1 to Regulatory Guide 1.140 should be issued. References None. 6 t}}

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