ML11223A061

NEI Gat Presentation at 8/4/11 Meeting - Purpose of NEI 09-10, Guidelines for Effective Prevention and Management of System Gas Accumulation.

ML11223A061
Person / Time
Site:	Technical Specifications Task Force, Nuclear Energy Institute
Issue date:	08/03/2011
From:	Petersen K Technical Specifications Task Force
To:	Division of Policy and Rulemaking
References
Download: ML11223A061 (3)

Text

8/3/2011

-I-_ Technical Specifications Task Force TSTF A JointOwners GroupActivity Purpose of NEI 09-10, "Guidelines for Effective Prevention and Management of System Gas Accumulation" Ken Petersen STARS / NEI GAT ITechnical Specifications Task Force TSTF A Joint Owners Group Activity NEI 09-10 Purpose

" Provides insights and attributes to implement an acceptable approach to effectively prevent and manage gas intrusion and accumulation in plant systems.

" To aid licensees in:

- Identifying susceptible systems,

- Outlining principles and practices designed to effectively prevent, identify, manage and monitor accumulation of gas that would challenge the capability of a system to satisfy its design functional requirement(s), and

- Identifying training to ensure plant personnel can readily recognize and effectively respond to gas intrusion and accumulation in susceptible systems to determine if the degraded system is Operable.

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8/3/2011 I_ Technical Specifications Task Force TSTF A Joint Owners GroupActivity Submittal of NEI 09-10 to the NRC

" As stated in the December 21, 2010 transmittal letter of NEI 09-10, Rev. 1:

- "NRC endorsement of the guidance would be appropriate in order to document our mutual understanding of an acceptable approach to managing gas accumulation in plant systems."

" NRC endorsement of this approach was also requested to proactively address potential questions that may arise during inspection of licensee programs.

3 I_ Technical Specifications Task Force TSTF A Joint Owners GroupActivity Regulatory Significance of NEI 09-10 As stated in the December 21, 2010 transmittal letter of NEI 09-10, Rev. 1,

- "The industry would like to emphasize that NEI 09-10 was not created as a regulatory requirements document, and, as such is not referenced in the traveler [TSTF-523] nor would such a reference be appropriate."

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8/3/2011

__L__ Technical Specifications Task Force TSTF A JointOwners GroupActivity Summary NEI 09-10 is:

- An industry-developed guidance document that may be used by licensees to prevent and manage system gas accumulation; including identifying entrained gas and addressing potential degradation on Operability.

S Technical Specifications Task Force Il_ Technical Specifications Task Force TSTF A Joint Owners GroupActivity Summary NEI 09-10 is not:

- A description of actions required in response to Generic Letter 2008-01

- A basis for any regulatory requirements

- A description of actions required to maintain or confirm system operability when degraded conditions are identified

- A formal industry initiative document

- A document that affects any licensee's licensing basis 3