GS-R-3 can still be mentioned in 4.13 but increases in safety level with make the requirement for integration a integration; however, this may not recommendation only. always be the case for every facility at any stage in its lifetime. Integration may not make sense in some facilities in certain situations and may not have any added safety benefit. 4.14 Change appendix 2 to appendix 5. Please check, I think the wrong last sent. appendix is being referenced. 1st sentence: stated in GS-R-3 [8], aAn “As clar GER2 28 4.14 In a Safety Guide, usually integrated management system (including recommendations (or “should” safety, health, environmental, nuclear statements) are provided. Modify security, quality and economic elements) is wording to emphasize that two required to be established, implemented, requirements (or “shall” assessed and continually improved by the statements) are cited here. The operating organization. and iIt has to should respective requirements should be be applied to all steps of the predisposal addressed in two separate management of radioactive waste [8] [4].” sentences. 3rd sentence: systems should “Management clar GER2 29 4.14 For completeness. The Draft Safety make provision for siting, design, Guide DS441 “Construction for construction, commissioning, operation, Nuclear Installations” provides maintenance and decommissioning of the specific recommendations on the predisposal radioactive waste management management system for the facility.” construction of nuclear installations. Remember that the revised definition of the term ‘nuclear installation’ includes facilities for the predisposal management of radioactive waste arising from nuclear fuel cycle
4.14 last sent. GS-R-3 can still be mentioned in 4.13 but make the requirement for integration a recommendation only. Change appendix 2 to appendix 5. increases in safety level with integration; however, this may not always be the case for every facility at any stage in its lifetime. Integration may not make sense in some facilities in certain situations and may not have any added safety benefit. Please check, I think the wrong appendix is being referenced. clar GER2 28 4.14 1st sentence: “As stated in GS-R-3 [8], aAn integrated management system (including safety, health, environmental, nuclear security, quality and economic elements) is required to be established, implemented, assessed and continually improved by the operating organization. and iIt has to should be applied to all steps of the predisposal management of radioactive waste [8] [4].” In a Safety Guide, usually recommendations (or “should” statements) are provided. Modify wording to emphasize that two requirements (or “shall” statements) are cited here. The respective requirements should be addressed in two separate sentences. clar GER2 29 4.14 3rd sentence: “Management systems should make provision for siting, design, construction, commissioning, operation, maintenance and decommissioning of the predisposal radioactive waste management facility.” For completeness. The Draft Safety Guide DS441 “Construction for Nuclear Installations” provides specific recommendations on the management system for the construction of nuclear installations. Remember that the revised definition of the term ‘nuclear installation’ includes facilities for the predisposal management of radioactive waste arising from nuclear fuel cycle
a%20Consolidated%20MS%20Comments%20DS447.docx