ML23283A047

Neop Letter Dated October 8, 2023 - Vogtle 3 & 4 - TS 3.7.6 License Amendment Request

ML23283A047
Person / Time
Site:	Vogtle
Issue date:	10/08/2023
From:	Saporito T Nuclear Energy Oversight Project
To:	Cayetano Santos NRC/NRR/VPOB
References
EPID L-2023-LRQ-0004
Download: ML23283A047 (1)

Text

Nuclear Energy Oversight Project Oversight of the U.S. Nuclear Regulatory Commission to protect public health and safety and the environment 6526 S. Kanner Hwy. Thomas Saporito Stuart, Florida 34997 Executive Director Email: NEOP@gmx.com Phone: (772) 262-0728 October 8, 2023 Cayetano (Tanny) Santos Project Manager Vogtle Project Office Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission RE: Vogtle Units 3 and 4 (LAR 23-009)

Ms. Santos:

This communication is in reference to the Vogtle (licensee's) submittal of LAR 23-009 regarding licensed operation of Units 3 and 4. (Unit 4 not operational at this time). The licensee is requesting authorization from the U.S. Nuclear Regulatory Commission (NRC) to change its technical specifications related to air quality surveillance of the control room from ANSI/CGA G-7.1 to ASHRAE Standard 62. The Nuclear Energy Oversight Project (NEOP) offers the NRC the following overview related to this matter to assist the NRC's review and decision of whether or not to approve the licensee's LAR accordingly.

Discussion In the context of a nuclear power plant control room, both ANSI/CGA G-7.1 and ASHRAE Standard 62 play crucial roles, but they address different aspects of environmental control.

1. ANSI/CGA G-7.1 (Grade E Air):

• Relevance: This standard is more directly applicable to environments where compressed breathing air is used. It specifies the quality of air for respiratory protection equipment, setting limits for contaminants to ensure the safety of individuals relying on compressed air.

• Application in Control Rooms: While Grade E air is not specifically designed for control room environments, its principles can be indirectly relevant. For instance, if there are compressed air systems or breathing apparatus used in emergency situations within the control room, adherence to G-7.1 would be essential.

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2. ASHRAE Standard 62:

• Relevance: ASHRAE 62 focuses on ventilation rates and indoor air quality in buildings. It aims to provide occupants with acceptable air quality by determining appropriate ventilation rates based on factors such as occupancy, space size, and activities.

• Application in Control Rooms: ASHRAE 62 is highly relevant to the control room environment. Proper ventilation is critical to ensuring that the air quality within the control room remains within acceptable limits, especially considering the potential presence of electronic equipment, potential off-gassing, and the need to manage heat loads effectively.

Comparison:

• Primary Focus:

• ANSI/CGA G-7.1: Safety of compressed breathing air.

• ASHRAE Standard 62: Indoor air quality and ventilation rates in buildings.

• Specificity:

• G-7.1 is specific to compressed air quality for breathing.

• ASHRAE 62 is more general, applying to a wide range of indoor spaces.

• Application in Control Rooms:

• G-7.1 may be indirectly relevant in situations involving compressed air systems or emergency breathing apparatus.

• ASHRAE 62 is directly applicable, ensuring proper ventilation and air quality for occupants.

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Conclusion:==

For a nuclear power plant control room, both standards are important. ASHRAE Standard 62 should be the primary guide for maintaining indoor air quality, managing heat loads, and ensuring the well-being of personnel. ANSI/CGA G-7.1 may come into play if there are specific compressed air systems or emergency breathing apparatus within the control room that require adherence to breathing air quality standards.

For the Nuclear Energy Oversight Project Thomas Saporito Executive Director 2/2