ML112140617

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Request for Additional Information on Topical Report 09-10, Revision 1, Guidelines for Effective Prevention and Management of System Gas Accumulation
ML112140617
Person / Time
Site: Nuclear Energy Institute
Issue date: 08/04/2011
From: Stuchell S
Licensing Processes Branch (DPR)
To: Jeffrey Riley
Nuclear Energy Institute
Stuchell S, NRR/DPR,301-415-1847
References
TAC ME5291
Download: ML112140617 (4)


Text

August 4, 2011 Mr. James H. Riley, Principal Engineer Nuclear Generation Division Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION ON TOPICAL REPORT 09-10, REVISION 1, GUIDELINES FOR EFFECTIVE PREVENTION AND MANAGEMENT OF SYSTEM GAS ACCUMULATION (TAC NO. ME5291)

Dear Mr. Riley:

By letter dated December 21, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML110240124), the Nuclear Energy Institute (NEI) submitted for U.S.

Nuclear Regulatory Commission (NRC) staff review Topical Report (TR) NEI 09-10, Revision 1, Guidelines For Effective Prevention And Management Of System Gas Accumulation (ADAMS Accession No. ML110030918). TR NEI 09-10, Revision 1, provides recommendations and guidance to nuclear generating stations for the effective implementation of programs and processes to prevent and manage gas intrusion and accumulation in plant systems.

Upon initial review of TR NEI 09-10, Revision 1, and as a result of the public meeting held on July 27, 2011, the NRC staff has determined additional information is needed to complete the review. The NRC requests your response to the enclosed Request for Additional Information (RAI) within 30 days of issuance of this letter.

If you have any questions regarding this matter, please contact me at (301) 415-1847.

Sincerely,

/RA/

Sheldon D. Stuchell, Senior Project Manager Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Project No. 689

Enclosure:

RAI questions

Mr. James H. Riley, Principal Engineer Nuclear Generation Division Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION ON TOPICAL REPORT 09-10, REVISION 1, GUIDELINES FOR EFFECTIVE PREVENTION AND MANAGEMENT OF SYSTEM GAS ACCUMULATION (TAC NO. ME5291)

Dear Mr. Riley:

By letter dated December 21, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML110240124), the Nuclear Energy Institute (NEI) submitted for U.S.

Nuclear Regulatory Commission (NRC) staff review Topical Report (TR) NEI 09-10, Revision 1, Guidelines For Effective Prevention And Management Of System Gas Accumulation (ADAMS Accession No. ML110030918). TR NEI 09-10, Revision 1, provides recommendations and guidance to nuclear generating stations for the effective implementation of programs and processes to prevent and manage gas intrusion and accumulation in plant systems.

Upon initial review of TR NEI 09-10, Revision 1, and as a result of the public meeting held on July 27, 2011, the NRC staff has determined additional information is needed to complete the review. The NRC requests your response to the enclosed Request for Additional Information (RAI) within 30 days of issuance of this letter.

If you have any questions regarding this matter, please contact me at (301) 415-1847.

Sincerely,

/RA/

Sheldon D. Stuchell, Senior Project Manager Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Project No. 689

Enclosure:

RAI questions DISTRIBUTION:

PUBLIC PLPB Reading File RidsNrrDpr RidsNrrDprPlpb RidsNrrLADBaxley RidsNrrDssSnpb AUlses, NRR SStuchell, NRR JJolicoeur, NRR WLyon, NRR RidsOgcMailCenterResource RidsAcrsAcnwMail J. Gall, NRR ADAMS ACCESSION NO.: ML112140617 TAC - ME5291 OFFICE PLPB/PM PLPB/LA SRXB/BC PLPB/BC NAME SStuchell DBaxley AUlses JJolicoeur DATE 08 / 02 / 2011 08 / 03 / 2011 8/4/11 8/4/11 OFFICIAL RECORD COPY

REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION TOPICAL REPORT 09-10, REVISION 1, GUIDELINES FOR EFFECTIVE PREVENTION AND MANAGEMENT OF SYSTEM GAS ACCUMULATION NUCLEAR ENERGY INSTITUTE PROJECT NO. 689 As a result of the preliminary review of Topical Report (TR) NEI 09-10, Revision 1, and the July 27, 2011, public meeting on the TR, the NRC requests the following requests for additional information (RAI) be responded to.

RAI 1

The objective of the TR process is, in part, to add value by improving the efficiency of other licensing processes, for example, the process for reviewing license amendment requests (LARs) from commercial operating reactor licensees. The purpose of the U.S. Nuclear Regulatory Commission (NRC) TR program is to minimize industry and NRC time and effort by providing for a streamlined review and approval of a safety-related subject with subsequent referencing in licensing actions, rather than repeated reviews of the same subject.

A TR is a stand-alone report containing technical information about a nuclear power plant safety topic, which meets the criteria of a TR. A TR improves the efficiency of the licensing process by allowing the NRC staff to review a proposed methodology, design, operational requirements, or other safety-related subjects that will be used by multiple licensees, following approval, by referencing the approved TR. The TR provides the technical basis for a licensing action.

Request an explanation as to how TR NEI 09-10, Revision 1, will be used in licensing actions or improve efficiencies for the NRC and licensees.

SECTION 2

RAI 2

It is stated in Section 2.0 of the TR, within paragraph 4, The approach identified in this document is intended to satisfy 10 CFR [Title 10 of the Code of Federal Regulations Part] 50 Appendix B Quality Assurance requirements. Criterion III requires measures to ensure that applicable regulatory requirements and the design basis, as defined in 10 CFR 50.2, Definitions, and as specified in the license, are correctly translated into controlled specifications, drawings, procedures, and instructions. Criterion V requires important activities to be prescribed by documented instructions, procedures, or drawings, which must include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Criterion XI requires a test program to ensure that the subject systems will perform satisfactorily in service. Test results shall be documented and evaluated to ensure that test requirements have been satisfied.

ENCLOSURE

However, it is not apparent to the NRC staff specifically how Sections 3 through 14 apply to NRC regulations. Similar to an NRC Regulatory Guide, a TR should provide guidance to licensees on a way to meet regulatory requirements, therefore, the NRC staff requests more detail as to how the TR satisfies regulatory compliance.