IP 71111.20, Refueling and Other Outage Activities
Refueling and Other Outage Activities
text
Issue Date: 11/28/17 1 71111.20
NRC INSPECTION MANUAL IRIB
INSPECTION PROCEDURE 71111 ATTACHMENT 20
REFUELING AND OTHER OUTAGE ACTIVITIES
Effective Date: January 1, 2018
PROGRAM APPLICABILITY: 2515 Appendix A
CORNERSTONE: Initiating Events
INSPECTION BASES: See IMC 0308, Attachment 2
SAMPLE REQUIREMENTS:
Sample Requirements Minimum Baseline Sample
Completion Requirements
Nominals and Budget
Sample Type Section Frequency Sample Size Samples Hours per site
Refueling/Other
Outage
03.01 One Each Outage* 1 unit: 71+/-15
2 units: 77+/-15
3 units: 81+/-15
- An outage is a shutdown with a plant cooldown or a shutdown for containment entry, or both.
71111.20-01 INSPECTION OBJECTIVES
01.01 To verify that outage activities important to safety are appropriately managed.
01.02 To verify that safety-related and risk-significant structures, systems, and components in
inaccessible areas during power operations are appropriately maintained to support
required safety functions.
01.03 To verify that risk is appropriately managed during outage-related activities such as
during reduced-inventory and midloop conditions.
71111.20-02 GENERAL GUIDANCE
Use Inspection Procedure (IP) 71153, “Follow-Up of Events and Notices of Enforcement
Discretion,” for noncomplicated reactor trips where a startup is performed without entering the
containment. Use IP 71111.19, “Post-Maintenance Testing,” and IP 71111.22, “Surveillance
Testing,” to address testing activities that normally occur during refueling outages, such as
physics testing, emergency diesel generator time response testing, reactor coolant system
(RCS) hydrostatic testing, control rod scram time testing, rod drop time testing, reactor trip
Issue Date: 11/28/17 2 71111.20
breaker testing, and containment sump valve testing. However, IP 71111.20 should take
precedence for outage planning and configuration management reviews in areas where it
overlaps with other areas that require inspections, such as maintenance risk assessments and
emergent work control, equipment alignment, and inservice inspection activities.
IMC 0609, “Significance Determination Process,” Appendix G, “Shutdown Operations
Significance Determination Process,” contains checklists for various plant configurations that
can be used to assess mitigating capability. Higher risk configurations have more checklist
guidelines for each safety function. The following examples are high-risk configurations:
pressurized-water reactors (PWRs)
breached RCS boundary with steam generators that cannot be used for decay
heat removal (DHR)
midloop conditions under which it is more likely that DHR can be lost because of
poor RCS-level control or poor DHR flow control
boiling-water reactors (BWRs)
cold shutdown conditions (i.e., technical specifications (TS) allow more
equipment to be inoperable during cold shutdown conditions than they do during
hot shutdown conditions)
inoperable safety relief valves under conditions in which such valves would be
needed to provide an alternate DHR path and pressure control during a loss of
the primary DHR system
For each sample, conduct a routine review of problem identification and resolution activities
using IP 71152, “Problem Identification and Resolution.”
Sample Considerations
Risk Priority Examples
Equipment or actions that could cause a loss of
Actions that could affect reactor vessel level
Activities that contribute to loss of offsite power
or station blackout
Inadvertent lowering of the reactor vessel
level in midloop as a result of operator
inattention
Improper hanging or restoration of clearance
tags that could affect reactor vessel level,
DHR, or electrical power availability
Actions that could cause the reactor vessel
level indication to be inaccurate.
Issue Date: 11/28/17 3 71111.20
Risk Priority Examples
Equipment used to mitigate a loss of DHR
Equipment used to mitigate a loss of reactor
vessel level
Activities that affect the ability of pumps
designated in the shutdown risk analysis to
add water to the reactor vessel
Activities that affect the water source for any
of the pumps designated in the shutdown
risk analysis
Activities that affect the electrical power
sources designated in the shutdown risk
analysis
Failure to verify refueling interlocks
Actions that affect the fuel cladding barrier,
reactor vessel/RCS integrity, or containment
integrity
Exceedance of heatup or cooldown rate
limits
Failure to establish containment integrity
during fuel movement
71111.20-03 INSPECTION SAMPLE
03.01 Refueling/Other Outage Sample
a. Outage Plan.
Before a planned outage, verify that the outage and risk control plan
appropriately considers risk, industry experience, and previous site-specific
problems.
Specific Guidance
1. Review the licensee’s outage risk control plan, related industry experience, and
previous site-specific problems. Confirm that the licensee has
mitigation/response strategies for losses of key safety functions.
2. Verify that the licensee maintains defense in depth. Evaluate risk insights
regarding the outage plan, including consideration of the overlap of work
activities, the handling of heavy loads, the erection of scaffolding, and the
increased potential for a fire or internal flooding. Verify that configuration
changes are controlled in accordance with the outage risk control plan and
applicable TS.
b. Fatigue Management.
Verify that the licensee manages worker fatigue appropriately during the outage.
Specific Guidance
Verify that the licensee has developed outage personnel work schedules that comply with Title 10 of the Code of Federal Regulations (10 CFR) 26.205(d)(4) and (5).
Consider the following:
1. Outage Work Schedules.
Review individual outage work schedules for operations, maintenance, and fire brigade personnel. Verify that the personnel who are working on outage activities are provided with the minimum days off to minimize the effects of cumulative fatigue. For multiple-unit sites, verify that the applicable control room staff for the operating unit remains on operating unit work hours control as specified in Regulatory Guide 5.73, “Fatigue Management for Nuclear Power Plant Personnel.” Verify that the reactor operators and senior reactor operators on the operating unit, if applicable, are under operating hours control and are not allowed the less-restrictive minimum days off requirements for outage activities. IP 93002, “Managing Fatigue,” provides additional guidance.
2. Waiver Requests, Self-Declarations, and Assessments.
Once during the outage, review three to five waiver requests (10 CFR 26.207, “Waivers and Exceptions”); self-declarations (10 CFR 26.209, “Self-Declarations”); and fatigue assessments (10 CFR 26.211, “Fatigue Assessments”), when they are available. Verify that the licensee is managing operator fatigue appropriately. IP 93002 provides additional guidance.
c. Shutdown.
Verify that the licensee conducts plant shutdown activities appropriately through the following activities:
1. Cooldown.
Observe portions of the cooldown process to verify that TS cooldown restrictions are followed.
2. Containment Opening.
If the containment is opened, conduct a walkdown of the containment promptly after it is opened.
Specific Guidance
If containment entry is available, conduct a thorough containment walkdown as soon as reasonably possible after shutdown to inspect plant areas that are inaccessible during power operations.
- (a) Consider the following:
- (1) ”as low as is reasonably achievable” controls
- (2) industrial/personnel safety (heat stress)
- (3) outage duration
- (4) unidentified RCS leakage before shutdown
- (b) Verify that structures, piping, and supports in containment do not include stains or deposited material that may indicate an unidentified RCS leakage. Verify that there is no evidence of RCS leakage (e.g., boric acid residue) that might later become obscured resulting from licensee outage work. IP 71111.08, “Inservice Inspection Activities,” requires an independent review of plant areas in which the licensee has recently conducted a boric acid walkdown.
- (c) Verify that the containment sump is undamaged and debris free.
- (d) Verify that supports, braces, and snubbers have no damage or deformation. Verify that hydraulic snubbers have no hydraulic fluid leaks and that the hydraulic fluid reservoir is adequately filled.
- (e) Check for items that may be indicative of a larger problem. These problems may include, but are not limited to, the following:
- (1) blistered paint and rust on containment liners
- (2) leakage from containment ventilation and cooling systems
- (3) cracks in concrete support structures
- (4) damaged cable insulation
- (5) presence of loose foreign material
- (6) presence of temporary plant equipment left or stored in containment that the licensee’s design-basis analyses may not have considered
d. Outage.
Verify that the licensee has conducted outage-related activities appropriately.
Specific Guidance
Verify that the license maintains defense-in-depth when equipment is taken out of service. Verify that the licensee controls configuration changes in accordance with the outage risk control plan and applicable TS.
1. Isolation and Clearance/Cleanliness Activities.
Verify that tags are properly hung and removed and that associated equipment is appropriately configured to support the function during clearance restoration.
Specific Guidance
Examples of risk-significant clearance activities include the opening of water system boundaries for maintenance near risk-important equipment and power restorations that could adversely affect safety systems, such as the improper repositioning of a motor-operated value upon restoration of power. Pay particular attention to maintenance activities that could affect RCS, DHR, or spent fuel pool cooling.
2. Foreign Material Exclusion.
Verify that the licensee is implementing appropriate foreign material exclusion practices.
Specific Guidance
Review foreign material exclusion logs and records.
3. Reactor Coolant System Instrumentation.
Verify that RCS pressure, level, and
temperature instruments have been installed, calibrated, and configured to
provide accurate indications.
Specific Guidance
For level instruments, verify that the tubing runs do not have elevation changes
that could trap either liquid or vapor/gas in the instrument lines (i.e., loop seals).
If the plant uses normal operating level instrumentation, verify that the operators
have considered the effects of changes in water density (resulting from lower
temperature). Verify that the operators are aware of the effect of loss of DHR on
the plant's level instrumentation resulting from heatup and pressurization.
For temperature instruments, verify that the operators are aware of the effect of
loss of DHR on the plant’s temperature indication and the potential for
discrepancies between the temperature indications and the actual plant state.
Temperature may be measured in the DHR loop; in this case interruption,
bypass, or partial bypass of DHR flow could lead to incorrect and
nonconservative temperature indications.
4. Electrical Power.
Verify that the status and configurations of electrical
systems meet TS requirements and the licensee’s outage risk control plan.
Specific Guidance
Verify that switchyard activities are controlled commensurate with safety and are
consistent with the licensee’s outage risk control plan assumptions.
5. Containment.
Verify that the plant has the proper containment configuration
during risk-significant evolutions (e.g., PWR midloop operations, BWR
cavity drain down), including provisions for achieving prompt containment
closure during periods when containment is permitted to be open.
Specific Guidance
For BWRs, verify that secondary containment meets the TS requirements. Verify
that the containment closure procedures are available and that the licensee uses
them when applicable.
For PWRs, verify that containment penetrations meet TS requirements and that
containment closure1 can be achieved at all times.
1 Licensees of PWRs meet containment closure if all containment penetrations (including
temporary penetrations, the equipment hatch, and the personnel hatch) have a
6. Decay Heat Removal.
Observe DHR parameters to verify proper system
operation.
Specific Guidance
For BWRs, verify that training and procedures are in place for alternate DHR
systems.
For PWRs, when the licensee is relying on the steam generators to provide a
backup means of DHR by single-phase natural circulation, verify that the licensee
has confirmed the viability of this cooling method.
When the licensee is relying on the steam generators to provide a backup means
of DHR by single-phase natural circulation, verify the following:
(a) Procedures for these methods are derived from analyses, and the
required equipment is available.
(b) The RCS pressure boundary is closed.
(c) Steam generator tubes are full.
(d) Pressure control capability in the RCS is maintained to ensure the
subcooling margin.
(e) The plant has the capability to feed the steam generators.
(f) The plant has the capability to remove steam from the steam generators
(e.g., atmospheric relief valves, condenser with steam dump capability).
7. Inventory Control.
Verify that the flowpaths, configurations, and alternative
means for inventory addition are consistent with the outage risk plan.
Specific Guidance
For activities that have the potential to cause a loss of inventory, verify that
adequate controls are in place to prevent inventory loss. RCS pressure
boundary problems can pose significant shutdown risk.
(a) Examples of loss of inventory paths include the following:
(1) on BWRs—DHR to the suppression pool
differential capability equal to the ultimate pressure or would be expected to remain
intact following an accident. Leakage requirements, as described in Appendix J, are not
a concern. Results from the shutdown probabilistic risk analysis that the Office of
Nuclear Regulatory Research conducted at Surry Power Station shows that containment
pressure (in a subatmospheric containment) can be high at shutdown after a core
damage event.
(2) on BWRs—main steamline paths, including safety relief value
removal, automatic depressurization system testing, and main
steam isolation valve maintenance
(3) on PWRs—DHR system crosstie valves, thimble tube seals, and
steam generator nozzle dams
(4) maintenance activities on connected piping or components that
are at an elevation lower than the vessel flange on all plants
(5) paths for an intersystem loss-of-coolant accident, such as
maintenance and testing on the nonoperating loop low-pressure
injection (LPI) train or LPI testing on return back to the refueling
water storage tank
(b) For BWRs, verify the following:
(1) The automatic isolation on low level is aligned in accordance with
TS requirements that apply to the mode.
(2) The main steamline plugs are installed, and the systems required
for proper operation of the reactor cavity seal (e.g., instrument air)
are maintained to prevent seal failure.
(3) The plant has adequate vents to accomplish gravity feed and
low-pressure makeup when relied upon.
8. Reduced Inventory. Verify that the licensee safely controls plant conditions
during reduced inventory and midloop operations.
Specific Guidance
For BWR licensees that have adopted reactor pressure vessel water inventory
control, review the licensees’ drain time calculation and calculation assumptions.
Verify that the plant water inventory levels and limiting drain rate are consistent
with plant conditions. Verify that TS-required equipment and instrumentation is in
the required configuration.
For all other licensees, review their commitments from Generic Letter 88-17,
“Loss of Decay Heat Removal,” dated October 17, 1988, and confirm by
sampling that they are still in place and adequate. Review the
unit/outage-specific time-to-boil curves. During midloop operations, observe the
effect of distractions from unexpected conditions or emergent activities on the
operator’s ability to maintain the required reactor vessel level. In addition to
reduced inventory and midloop conditions, assess planned outage activities
occurring during other periods when there is a short time-to-boil.
Verify the following:
(a) The licensee has reviewed its controls and administrative procedures
governing midloop operation and has conducted training for midloop
operations.
(b) The licensee uses procedures for the following:
(1) identifying unexpected RCS inventory changes and verifying that
an RCS vent path is adequate during RCS draining to midloop
(2) emergency/abnormal operation during reduced inventory
(c) Indications of core exit temperature are operable and periodically
monitored (typically at least two independent and continuous indications).
(d) Indications of RCS water level are operable and periodically monitored
(typically at least two independent and continuous indications).
(e) RCS perturbations are avoided.
(f) Means of adding inventory to the RCS are available (typically at least two
means in addition to residual heat removal pumps).
(g) Reasonable assurance is obtained that not all hot legs are simultaneously
blocked by nozzle dams unless the upper plenum is vented.
(h) Contingency plans exist to repower vital electrical busses from an
alternate source if the primary source is lost.
The time-to-boil period can be less than 30 minutes when DHR is lost under
midloop conditions. During midloop operations, the operator provides the only
prevention/mitigating function for a loss of reactor vessel level before the loss of
DHR. The plant does not generally have alarms that indicate a loss of level
under midloop conditions. The operator’s attention to plant conditions is the key
preventative aspect for a loss of DHR event. Closely observe the operator’s
performance during drain down, and frequently observe control room activities
while the plant is under reduced inventory or midloop conditions. Observe how
potential control distractions, such as unexpected conditions and emergent work,
affect the operator’s focus.
9. Spent Fuel Pool Cooling.
Verify that outage work is not affecting the ability
of the operations staff to operate the spent fuel pool cooling system during
and after core offload.
Specific Guidance
Verify the following:
(a) Spent fuel pool cooling recovery procedures exist for situations that
involve loss of spent fuel pool cooling and are based on current/bounding
heat loads.
(b) Operators are trained on backup equipment and procedures for loss of
spent fuel cooling.
(c) Equipment designated in the recovery procedures is readily available, is
dedicated, is unobstructed by outage activities, and has compatible
equipment connections.
(d) Instrumentation, alarms, equipment, instructions, and training are
provided to alert operators of the need, and to enable them, to add water
to the spent fuel pool when necessary.
10. Refueling.
Verify that the licensee conducts reactor core refueling activities
appropriately.
Specific Guidance
Verify the following:
(a) Fuel handling operations (removal, inspection, sipping, reconstitution, and
insertion) and other ongoing activities are being performed in accordance
with TS requirements and approved procedures.
(b) Refueling seals have been properly installed and tested, and foreign
material exclusion is being maintained in the refueling, spent fuel, and
suppression pool areas.
(c) Fuel assembly locations are being tracked, including new fuel, from core
offload through core reload. Verify that coupling between the reactivity
monitoring instruments and fuel loading location within the core is
maintained.
(d) Fuel assembles are loaded in the reactor core locations as specified by
the design. Verify fuel assembly loading by reviewing video recording,
other core loading records, or physics testing results with as-predicted
core operating limit parameters.
(e) Discharged fuel assemblies are placed in allowable locations in the spent
fuel pool.
11. Reactivity Control.
Verify that reactivity is being controlled in accordance
with the TS. Verify that the outage risk plan identifies activities or
structures, systems, and components that could cause unexpected
reactivity changes and that the licensee is controlling them accordingly.
Specific Guidance
For PWRs, verify that the licensee has implemented appropriate administrative
controls on potential boron dilution paths. Verify that the licensee has
established adequate controls during refueling to preclude improper sequencing
of control rods or fuel assemblies to prevent any approach to criticality in any
core region without early source range monitor detection.
e. Startup.
Verify that the licensee conducts plant startup activities appropriately
through the following activities:
1. Heatup and Startup. Verify that the licensee has met TS; license conditions;
and other requirements, commitments, and administrative procedure
prerequisites for mode changes before it changes modes or plant
configurations.
Specific Guidance
(a) Review the reactor physics testing results. Verify that core operating limit
parameters are consistent with the design.
(b) Review the RCS boundary leakage calculations. Verify that the licensee
has met the TS leakage requirements before making the applicable mode
changes.
(c) Review the status of containment penetrations and containment isolation
valves. Verify that the licensee has established containment integrity
before entering the applicable TS mode.
(d) Verify that the licensee is appropriately considering and managing plant
risk.
2. Containment Closure. If containment is opened, conduct a walkdown of
containment just before closure.
Specific Guidance
During required containment walkdowns, verify the following:
(a) There is no evidence of leakage, and pay attention to areas recently
worked.
(b) There is no debris left adrift that might contribute to emergency core
cooling system sump blockage.
(c) Maintenance tags have been appropriately cleared.
(d) Passive systems have no obvious indications of damage.
71111.20-04 REFERENCES
Cross Reference of Generic Communications to IP 71111.20 and Inspection Resources:
http://nrr10.nrc.gov/rorp/ip71111-20.html
Operating Experience:
http://nrr10.nrc.gov/ope-info-gateway/index.html
IHS Codes and Standards:
http://www.internal.nrc.gov/TICS/library/standards/ihs.html
Issue Date: 11/28/17 12 71111.20
NRC Technical Library:
http://www.internal.nrc.gov/TICS/library/index.html
END
Issue Date: 11/28/17 Att 1-1 71111.20
Attachment 1 – Revision History for IP 71111.20
Commitment
Tracking
Number
Accession
Number
Issue Date
Change Notice
Description of Change Description
of Training
Required
and
Completion
Date
Comment and
Feedback
Resolution
Accession Number
(Pre-Decisional,
Non-Public
Information)
N/A 04/03/00
CN-00-003
Initial Issuance. Revision history reviewed for the last
four years
None
N/A 03/06/01
CN-01-006
Revised to clarify resource estimates for refueling,
non-refueling, and forced outages. The IP was also
revised to show the interaction between the shutdown
operations SDP and IP 71111.13, "Maintenance Risk
Assessments and Emergent Work Evaluation," in
performing risk assessments in accordance with 10 CFR 50.65(a)(4).
None
N/A 01/17/02
CN-02-001
Revised to integrate with IMC 0609, Appendix G,
"Shutdown Operations Significance Determination
Process," regarding risk insights and how to evaluate
inspection findings. It also addresses refueling
controls, improper sequencing of control rods or fuel
assemblies, reactivity control, and methods to ensure
fuel assembles are loaded in correct positions.
None
N/A ML033230221
11/05/03
CN-03-036
Revised to address licensee procedures for foreign
material exclusion, instruments tracking plant condition
changes, training procedures for BWR alternate decay
heat removal. It also cross references IMC 2515,
Appendix DProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 2515,</br></br>Appendix D" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., "Plant Status" regarding plant status tours
of areas accessible only during outages.
None
N/A ML041280023
05/06/04
CN-04-011
Revised to add guidance for containment inspections,
when possible, and to add a completion status section.
None
Issue Date: 11/28/17 Att 1-2 71111.20
Commitment
Tracking
Number
Accession
Number
Issue Date
Change Notice
Description of Change Description
of Training
Required
and
Completion
Date
Comment and
Feedback
Resolution
Accession Number
(Pre-Decisional,
Non-Public
Information)
N/A ML052580099
09/02/05
CN-05-024
Revised to add the objective of evaluating licensee
activities during reduced inventory and mid-loop
conditions to ensure that they appropriately manage
risk using commitments made in response to GL 88-17
(Loss of Decay Heat Removal). The IP was also
revised to recognize that the need for containment
walkdown should factor in containment type with
regard to ALARA and heat stress.
None
NA ML080300064
01/31/08
CN-08-005
Revised as part of the 2007 ROP realignment to: (1)
clarifies when outages should be addressed via
IP 71111.20 vs IP 71153, and (2) clarifies annual
inspection resources for non-refueling and forced
outages.
Incorporated guidance regarding: (1) managing fatigue
(IP 93002), (2) containment walkthroughs, and (3)
inspection resources in accordance with the 2009 ROP
realignment. The revised inspection procedure will
take effect on January 1, 2010.
None ML080250276
NA ML092090694
11/09/09
CN 09-026
Guidance regarding (1) managing fatigue (IP 93002),
(2) containment walkthroughs, and (3) inspection
resources in accordance with the 2009 ROP
realignment.
Revised to group existing fatigue assessment
guidance into a new, separate section, and to add
IP 71111.11 as acceptable guidance to observe startup activities in the control room, based on the 2014
ROP Enhancement Project feedback.
None ML092780024
Issue Date: 11/28/17 Att 1-3 71111.20
Commitment
Tracking
Number
Accession
Number
Issue Date
Change Notice
Description of Change Description
of Training
Required
and
Completion
Date
Comment and
Feedback
Resolution
Accession Number
(Pre-Decisional,
Non-Public
Information)
NA ML15016A138
01/27/15
CN 15-001
(1) Grouped existing fatigue assessment guidance into
new, separate section; and (2) added IP 71111.11 as
acceptable guidance to observe start-up activities in
the control room (2014 ROP Enhancement Project
feedback)
None 71111.20-2046
71111.20-2047
71111.20-2048
ML17179A651
11/28/17
CN 17-027
Added guidance to review calculations for reactor
pressure vessel water inventory control. Eliminated
redundancy and improved plain language. Relocated
optional requirements to the guidance section to better
align with the sample completion requirements in
IMC 2515, Section 08.04.
None ML17184A001
71111.20-2274