Revision 2 to NEI 09

-14 Revision

2 to NEI 09 14

Jim Riley

December 5, 2012 December 5, 2012
NEI 09-14 Rev 2 NEI 09 14 Rev 2

 Issued revision 2 on November 21 2012 Issued revision 2 on November 21, 2012 Revision incudes:

I t t ti – Interpretations

– Inspection planning document

– Clarifications and editorial changes
Definitions

 Adverse inspection finding

– Results from an inspection that has been 

determined to require an Indications from inspections that require immediate repair or 

a repair within one operating cycle

F il  a ure

– Unexpected system leakage or loss of A 

b h i th ttl l k i t it breach in the structural or leakage integrity 

of a piping system or a tank.
Changes Due to Interpretations Changes Due to Interpretations

 Added the following to the definition of 

Licensed Material

– This definition does not associate a s

pecific 

level of radioactivity with licensed material because it is not possible to do so. A determination of what is licensed material in any situation must be made by radiation health personnel at each utility.
Changes Due to Interpretations Changes Due to Interpretations

 Added the following to the description of Initiative 

Scope (sec 6 1) Scope (sec

6.1)

– Pump casings (the column or pipe that surrounds the actual 

pump) that penetrate the floors of buildings are not within the 

scope of the Initiative even if the casing is in contact with the soil scope of the Initiative even if the casing is in contact with the soil.

– Some tanks that are safety related or contain licensed material sit 

at grade on a concrete donut shaped foundation with a center filled with com

pacted sand. The ke

y factor that determines if such p y

a tank is within the scope of the Initiative is the position of the bottom of the tank with respect to grade and the capability of detecting leaks by monitoring the tank level. If the tank contains licensed material it is incumbent on the licensee to ensure that licensed material, it is incumbent on the licensee to ensure that

the tank is covered by either the Underground Piping and Tanks Integrity Initiative or the Ground Water Protection Initiative. 
Changes Due to Interpretations Changes Due to Interpretations

 Added the following notes to the 

description of plan implementation (sec 6.2.4)

1. This milestone refers to inspection plans; it does 

not refer to reactor units or stations. Therefore, 

the start of implementation is defined as the the start of implementation is defined as the

completion of at least one direct examination of piping included in the inspection plan for a site.

2 Th t t f i ti li t ll i . The s

tar

t o

f inspections applies 

to all in-scope 

lines and not just those that contain licensed material .
Changes Due to Interpretations

 Section 6.2.4 notes continued

3. Implementation of the inspection plan should include at 

l t di t i ti f i i i l d d i th leas

t one direc

t examination o

f piping inclu

d

e

d in the 

inspection plan. It is not sufficient that the inspection has been planned; it also must be completed. Previous 

inspections that meet the intent of a direct examination as inspections that meet the intent of

a direct examination as

defined in the industry’s inspection planning document qualify as starting even if they were performed prior to the 

approval of the Initiative or the formal development of the approval of the Initiative or the formal development of the

inspection plan. 

4. In accordance with Appendix C, the condition assessment 

does not require an actual examination of the component does not require an actual examination of the component

for other than high risk lines, but it should involve an engineering evaluation and associated documentation of the condition of the lines.
Appendix C: Inspection Planning Appendix C: Inspection Planning

 Revision 2 of the “Reasonable Assurance Document” 

incorporated as Appendix C incorporated as Appendix

C

– Rev 2 added underground piping with no significant 

change to philosophy or process

 Revision 2 significant changes

– Additional considerations for grouping of underground 

piping

– Additions to the susceptibility analysis and risk ranking 

section to better align with the latest GALL revision

–

A special section for tanks was not added based on the limited scope and current programs or regulations that already apply
Summary

 Revision 2 did not include any significant 

changes that were not already expected under the Initiative

 Implementation expected by the end of the 

first quarter 2013 quarter 2013