ML11223A061

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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

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Technical Specifications Task Force TSTF A Joint Owners Group Activity 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 Group Activity 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.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity 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

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Technical Specifications Task Force TSTF A Joint Owners Group Activity 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 Group Activity 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