ML080420543
| ML080420543 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 02/08/2008 |
| From: | Jeffrey Riley Nuclear Energy Institute |
| To: | Office of Nuclear Reactor Regulation, Nuclear Energy Institute |
| References | |
| GL-08-001 | |
| Download: ML080420543 (2) | |
Text
1776 I Street, NW l Suite 400 l Washington, DC l 20006-3708 l P: 202.739.8137 l F: 202.533.0193 l jhr@nei.org l www.nei.org James H. Riley Director Engineering Nuclear Generation Division February 8, 2008, To:
NEI Administrative Points of Contact
Subject:
Generic Letter 2008-01 Three Month Response Evaluation Guidance The purpose of this letter is to provide industry guidance to identify the potential actions and areas within the required three (3) month response for areas that may not meet the nine (9) month response criteria for the subject generic letter. Please distribute this letter to the organization(s) and person(s) responsible for the applicable system(s) concerning gas accumulation management.
The NEI Gas Management template response team has performed a screening of the Generic Letter four areas of principle concern and summarized below the recommended areas for review and also assessed the potential for the need to have a three month response letter to address actions which cannot be completed in the proposed timeframe. Based on this review, it appears possible to complete the nine month evaluation with potential actions going forward, and not require a three month letter response. NEI has discussed this approach with the NRC staff and they are in agreement with the evaluation approach and screening per this three month response letter.
The U.S. Nuclear Regulatory Commission (NRC) issued generic letter (GL) 2008-01 to address the issue of gas accumulation in the emergency core cooling, decay heat removal (DHR), and containment spray systems. The NRC issued the GL for two purposes: (1) to request addressees to submit information to demonstrate that the subject systems are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance, and (2) to collect the requested information to determine if additional regulatory action is required.
The NRC requests that each addressee evaluate its ECCS, DHR system, and containment spray system licensing basis, design, testing, and corrective actions to ensure that gas accumulation is maintained to a level that is less than the amount that challenges the operability of these systems, and that appropriate action is taken when conditions adverse to quality are identified. Within nine (9) months of the date of the GL, each addressee is requested to submit a written response consistent with the requested actions and information. If an addressee cannot meet the requested
Administrative Points of Contact February 8, 2008 Page 2 response date, the addressee shall provide a response within three months of the date of this GL and is requested to describe the alternative course of action that it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
The NEI recommended industry guidance is as follows:
Licensing Basis - The NEI team recommends a review of current Technical Surveillance (TS) surveillance requirements for shortcomings related to verifying that there are no voids in applicable systems / components. Shortcomings in the TS may be corrected through the corrective action program post nine month response, if required. A UFSAR review should also be performed for accurate description of plant systems, as appropriate, to mitigate gas voiding events. The UFSAR or TS changes can be performed before or after the 9 month response as long as they are captured as open items. Portions of either the TS basis or UFSAR which describe acceptable criteria for system gas voiding should be verified.
Design - The NEI team agreed aspects of design requirements such as P&IDs, isometrics, vent valve locations, physical piping/equipment layouts, insulation criteria, pump specifications, void criteria, valve location criteria, etc need to constitute the design review. However, it's also important that plant detailed walkdowns be completed to verify the information from the design review. This aspect may not be an option for some plants within the nine month evaluation period. Other stations may have an outage, but no time to plan for detailed walkdowns using industry criteria which is yet to be issued.
Therefore, the nine month response should include an up-to-date description of previously performed pipe walkdowns, a description of pipe conditions, i.e., insulated or not, and actions taken to determine high points and locations and installation of vent valves. Plants with limited or no walk downs performed to-date will need to document actions going forward to complete detailed walk-downs, addressing the specific systems as described in the GL. This will be documented as an open item in a plant nine month response letter to the NRC and treated as plant commitments. Gas accumulation evaluations will be performed using best available information (e.g., drawings, etc.)
pending availability of complete walk down information.
Testing - The NEI team anticipates that plant test procedures, such as surveillance testing, instructions, maintenance work practices, NDE examinations, etc can be reviewed within the nine month period and issues addressed either within the nine month evaluation or corrective actions can be issued as appropriate for completion post nine month response submittal. Note that Long term pump testing for void acceptance limits will be formulated by the Industry task teams and will likely extend beyond 2009. Once the proper testing is identified and approved, NEI will communicate the status of the program to NRC during ongoing communications.
Corrective Actions - The NEI team agrees that the Corrective Action program (CAP), system trending, operations and maintenance procedures can be reviewed within the nine months for adequacy per the GL issue description. Interest points include current system CAP trending, thresholds for issuing a corrective action document, and status of corrective actions.
A review of INPO SER 2-05 revision 1 will also provide detailed areas for consideration for the principle areas above.
Administrative Points of Contact February 8, 2008 Page 3 If you have any questions, please contact me at 202-739-8137; jhr@nei.org or Mike Melton at 202-739-8049; mam@nei.org.
Sincerely,