ML18278A281

IP 71111.01 Adverse Weather Protection

ML18278A281
Person / Time
Issue date:	12/20/2018
From:	Cauffman C NRC/NRR/DIRS/IRIB
To:
Cauffman C
Shared Package
ML18288A003, ML18353A198	List:
References
CN 18-044, DC 18-026
Download: ML18278A281 (10)

Text

NRC INSPECTION MANUAL IRIB INSPECTION PROCEDURE 71111 ATTACHMENT 01 ADVERSE WEATHER PROTECTION Effective Date: January 1, 2019 PROGRAM APPLICABILITY: IMC 2515 A, IMC 2561 A CORNERSTONES: Initiating Events Mitigating Systems INSPECTION BASES: See Inspection Manual Chapter (IMC) 0308, Attachment 2 SAMPLE REQUIREMENTS:

Sample Requirements Minimum Baseline Sample Budgeted Range Completion Requirements Sample Type Section(s) Frequency Sample Size Samples Hours Summer Readiness 03.01 Annual 1 per site 1 27 +/- 3 per site Seasonal Extreme 03.02 Prior to the onset of 1 to 2 Weather Seasonal Extreme Weather Impending Severe 03.03 When impending severe 1 Weather weather is anticipated External Flooding 03.04 Annual 1 per site 1 71111.01-01 INSPECTION OBJECTIVES 01.01 To verify that mitigating systems are not adversely impacted or challenged by adverse weather conditions.

01.02 To verify that adverse weather-related problems that could cause initiating events or impact the availability and functional capability of mitigating systems are identified and resolved.

71111.01-02 GENERAL GUIDANCE This inspection procedure should be used to inspect weather-related risks (e.g., high winds, hurricanes, torrential rains, electrical storms, tornadoes, extreme high or low temperatures),

conditions adversely affecting the ultimate heat sink (e.g., debris, ice blockages, frazil ice, sea grass, fish, etc.), offsite power systems, alternate AC power sources, and external flooding Issue Date: 12/20/2018 1 71111.01

mitigation measures. When practical, the inspection should be performed prior to the onset of adverse weather conditions at the site.

Conduct a routine review of problem identification and resolution activities using Inspection Procedure (IP) 71152, Problem Identification and Resolution.

Sample Considerations Inspection Objective: To verify that mitigating systems are not adversely impacted or challenged by adverse weather conditions.

Conditions and Potential Risk Impacts Examples For high winds, high risk exists for outdoor Adequacy of protection of equipment outside components, including power supplies, structures from high winds (tornadoes and/or fuel/air lines, and sensing lines. hurricanes) and high wind generated missiles.

For cold weather, high risk exists for Adequacy of heat tracing and space heaters components/sensing lines located in areas for cold weather protection of piping and exposed to outside weather (including areas equipment (e.g., refueling water storage tank with natural air intake/ventilation) or located (RWST)/condensate storage tank level, steam outside structures. generator/main steam line pressure and flow, and feedwater flow sensing lines, fire suppression systems, minimum flow path return lines for safety injection pumps to the RWST, cooling lines for service water pumps, or ultimate heat sink cooling water supply (protection from frazil ice or intake structure blockage due to debris, including ice).

For hot weather, high risk exists for marine Adequacy of site marine biofouling treatment fouling of various heat exchangers due to and monitoring program. This area may be clams/mussels, etc. inspected using IP 71111.07, Heat Sink Performance.

Plant modifications, new evolutions, Adequacy of safety evaluation for modification procedure revisions, or operator or change.

workarounds implemented to address periods of adverse weather. Refer to IMC 0326, Operability Determinations &

Functionality Assessments for Conditions Adverse to Quality or Safety for operator workaround guidance.

For extreme weather, high risk exists due to Adequacy of communication protocols potential grid stress and disturbances. between transmission operator and the NPP to verify appropriate information is conveyed when issues arise that could impact offsite power system or alternate AC power source.

Potential for common-cause failures Water-tight doors, sump pumps, and alarms.

barriers between flood areas.

Site specific: hurricane or river-level caused Adequate sealing of safe-shutdown electrical flooding. equipment below the flood line.

Areas below flood plaine. Check valves in open drain systems common to different flood areas.

Issue Date: 12/20/2018 2 71111.01

71111.01-03 INSPECTION SAMPLES 03.01 Summer Readiness Sample Verify that the licensees nuclear power plant (NPP) procedures and associated plant features for operation of both offsite AC power systems and the onsite alternate AC power systems appropriately address measures to monitor and maintain continued availability and reliability.

Specific Guidance

a. Ensure that equipment or procedure changes which potentially affect operation or reliability of offsite and alternate AC power systems have occurred since the last summer readiness sample. Review the NPP procedures affecting these areas and the communications protocols between the transmission system operator (TSO) and the NPP to verify that the appropriate information is exchanged when issues arise that could impact the offsite power system. Examples of appropriate information to be conveyed would include (1) coordination between the TSO and the NPP during an off-normal or emergency event affecting the NPP, (2) explanation of the event, (3) an estimate of when the offsite power system will be returned to a normal state, and (4) notification to the NPP when the offsite power system is returned to normal. [C1]

Verify that the reviewed procedures address the following:

1. Actions to be taken when notified by the TSO that the post-trip voltage of the offsite power system at the NPP will not be acceptable to assure the continued operation of the safety-related loads without transferring to the onsite power supply.

2. Compensatory actions to be taken when it is not possible to predict the post-trip voltage at the NPP for the current grid conditions.

3. Required re-assessment of plant risk based on maintenance activities which could affect grid reliability or the ability of the transmission system to provide offsite power.

4. Required communications between the NPP and the TSO when changes at the NPP could impact the transmission system or when the capability of the transmission system to provided adequate offsite power is challenged. Note that the TSO is completely independent of the licensee.

b. Review the material condition of the plants offsite AC power systems and onsite alternate AC power systems, including the switchyard and transformers. Review outstanding work orders.

1. Verify that appropriate compensatory measures have been taken, commensurate with risk, to address degraded conditions affecting these systems. Review the corrective actions for degraded conditions. Note that, depending on the grid operator, the licensee may have limited control over prioritization of outstanding work orders affecting the offsite power systems.

Issue Date: 12/20/2018 3 71111.01

2. Walk down the switchyard and verify the physical condition of AC power systems. Arrange for a walkdown with appropriate plant personnel. Observe the material condition of the offsite power sources.

03.02 Seasonal Extreme Weather Sample Verify the adequacy of the licensee seasonal readiness prior to the onset of seasonal extreme weather conditions.

Specific Guidance

a. Review seasonal extreme weather preparation procedures (e.g., extreme high temperatures, extreme low temperatures, or hurricane season preparations).

b. Verify that weather-related equipment deficiencies identified during the previous year have been corrected prior to the onset of seasonal extremes.

c. Evaluate implementation of the seasonal extreme weather preparation procedures and compensatory measures for the seasonal extremes. Consider accessibility of controls, indications, and equipment.

d. Select for inspection two to four risk-significant systems that are required to be protected from the seasonal extreme weather conditions. Review the updated final safety analysis report (UFSAR), technical specifications, and plant documents associated with these systems and then assess the following:

1. Verify that the selected systems or components will remain operable/functional when challenged by seasonal extreme weather conditions.

2. As applicable, verify that plant features and procedures for operation and continued availability of the ultimate heat sink (i.e., river, lake, and ocean) during seasonal extreme weather conditions are appropriate. Evaluate the licensees plans to address the ramifications of potentially lasting effects of seasonal extreme weather conditions (e.g., drought, flood, extreme cold weather). As applicable, verify that ultimate heat sink maximum and minimum temperature limits, as specified in the technical specifications and/or UFSAR, are appropriately and conservatively translated into system operating procedures, alarm response procedures, operability guidance, and design basis calculations.

During extended periods of high or low temperatures, ensure that vital plant areas (e.g., Emergency Core Cooling System pump rooms, containment or drywell, electrical switchgear rooms, and diesel rooms) cooled directly/indirectly by process mediums affected by external environmental conditions are adequately maintained within design basis limits. Independently verify by walkdowns where possible. This includes consideration for instrument accuracy to support conservative and timely operator action to ensure adequate margin to design basis limits.

3. As applicable, verify cold weather protection features, such as heat tracing, space heaters, and weatherized enclosures are monitored sufficiently to ensure that they support operability/functionality of the system, structure, or component (SSC) they protect. This includes instrument controller and alarm calibration Issue Date: 12/20/2018 4 71111.01

programs, as necessary, to support the cold weather protection function. As appropriate, perform a walkdown and verify the physical condition of weather protection features.

4. Verify that operator actions defined in the licensees seasonal extreme weather procedure maintain readiness of essential systems. Verify that minimum/adequate operator staffing is specified.

5. Verify that systems and/or components required for a reactor shutdown and affected by the seasonal extreme weather conditions are available to perform their reactor shutdown functions under assumed conditions.

6. As applicable, verify that the licensee can demonstrate through testing or analysis that diesel fuel oil Cloud Point1 specifications are acceptable for operability of diesel generator systems with above ground fuel storage tanks (e.g., emergency diesel generators, station blackout diesel generators, security diesels, fire protection diesel generators, etc.) during extreme cold weather conditions.

03.03 Impending Severe Weather Sample Verify the adequacy of the overall preparations to protect risk-significant systems from impending severe weather.

Specific Guidance

a. Evaluate implementation of appropriate severe weather preparation procedures and compensatory measures for the severe weather that is currently impacting or is expected to imminently impact the facility, its operations, or the ability of personnel to respond to an emergency. Review the licensees plans to address the ramifications of potentially lasting effects that may result from the severe weather conditions (e.g.,

drought, flood).

b. Verify that severe weather procedure operator actions maintain the readiness of essential systems. Verify that minimum/adequate operator staffing is specified.

Consider accessibility of controls, indications, and equipment.

c. Verify that required surveillances are current, or are scheduled and completed, if practical, before anticipated severe weather conditions develop.

d. Examine the status of safety related equipment and to ensure inoperable equipment does not prompt a Notice of Enforcement Discretion (NOED) request. Note: The Enforcement Policy provides for the exercise of enforcement discretion under circumstances in which maintaining the stability and reliability of the electrical power supply system is consistent with protecting the public health and safety. Weather-related NOED requests usually involve a missed surveillance, an improperly scheduled surveillance, or inoperable equipment.

1 Cloud Point defines the temperature at which a cloud or haze of wax crystals appears in the oil under prescribed test conditions, which generally relates to the temperature at which wax crystals begin to precipitate from the oil in use. [Source: ASTM D-975]

Issue Date: 12/20/2018 5 71111.01

e. Plant modifications, maintenance activities (i.e., temporary hazard barrier removal), new evolutions, procedure revisions, or operator workarounds implemented to address periods of adverse weather can inadvertently affect maintenance rule systems and SSCs, and should therefore be reviewed. Determine that the licensee has assessed and managed these challenges to safe plant operation. Further followup may be appropriate using IP 71111.12, Maintenance Effectiveness; IP 71111.13, Maintenance Risk Assessments and Emergent Work Control; IP 71111.15, Operability Determinations and Functionality Assessments; and IP 71111.18, Plant Modifications.

03.04 External Flooding Sample Verify that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding.

Specific Guidance

a. Review the UFSAR and related flood analysis documents to identify those areas that can be affected by external flooding, including water intake facilities. Review seasonal susceptibilities, such as floods caused by hurricanes, heavy rains, and flash floods.

Review licensee documentation that shows the design flood levels for areas containing safety-related equipment.

b. Based on the licensees flooding risk studies, select plant areas containing risk-significant SSCs which are below flood levels or otherwise susceptible to flooding.

Use weather-related information gathered during plant status reviews or from external news sources to assist in scheduling this inspection prior to the season of highest risk.

c. Conduct a walkdown of the selected areas or rooms. By observation/review of design features, including reviews of preventive maintenance activities, consider the following, giving priority to those attributes which are risk significant for the site-specific installation:

1. Sealing of equipment below the flood line, such as electrical conduits. Verify that the service life of seals is consistent with the manufacturers recommendations or that a documented engineering evaluation provides justification for service life beyond the manufacturers recommendations.

2. Sealing of equipment floor plugs, holes, or penetrations in floors and walls between flood areas. Verify seals and grout, and ensure that procedures or programs to monitor for degraded conditions have been implemented.

3. Adequacy of watertight doors between flood areas. Verify alignment of dog ears, adequacy of seals, and inspect for wear or impact damage on critical parts of the doors.

4. Common drain system and sumps, including floor drain piping and check valves, were credited for isolation of flood areas within plant buildings.

Issue Date: 12/20/2018 6 71111.01

5. Adequate protection of the drain system (e.g., screens/covers) to prevent debris from disabling the drain system or components in the drain system.

6. Operable sump pumps, level alarm, and control circuits, including maintenance and calibrations of flood protection equipment.

7. Anti-siphon features, such as check values and vacuum breaks, used to prevent external flooding ingress.

8. Condition, availability, and sufficient quantity of temporary or removable flood barriers (i.e., gaskets, sand bags, sand baskets, or other temporary barriers).

9. Protection of access to the ultimate heat sink for safe shutdown from storm surge debris impact.

10. Perimeter drain systems that minimize the egress of water to safety-related plant areas are functional.

d. For those areas where operator actions are credited, verify that the procedures such as abnormal or emergency procedures for coping with flooding can reasonably be used to achieve the desired actions, including whether the flooding event could limit or preclude the required operator actions. Observe flood mitigation drills and tabletops when possible.

Evaluations of operator actions must consider the following:

1. Can procedures or activities be executed as specified and within the required timeframe(s)? For example, are flood mitigation actions (e.g., closure of water-tight doors) achievable in the available timeframe between the flood warning and the onset of the flooding?

2. Will water levels and associated effects (e.g., waves, run-up, or debris) impair support functions or the performance of necessary actions?

3. Will other factors (e.g., equipment availability and staffing) prevent implementation of the required actions?

4. Will proposed actions result in consequences that adversely affect other required safety or security functions (e.g., impairing required cooling functions)?

5. Do the procedures or activities include a discussion on warning time and notification that a flood is imminent?

6. Do the procedures include a discussion on how long the site could be flooded and appropriate considerations for the duration of the flood (e.g., availability of required consumables)?

e. Evaluate implementation of flood protection preparation procedures and compensatory measures during impending conditions of flooding or heavy rain, including the process for incorporating or assimilating information from external sources (e.g., the National Oceanic and Atmospheric Administration or Army Corp of Engineers).

Issue Date: 12/20/2018 7 71111.01

71111.01-04 REFERENCES Cross Reference of Generic Communications to IP 71111.01 and Inspection Resources:

http://drupal.nrc.gov/nrr/ope/33977 (nonpublic)

Operating Experience Gateway:

http://drupal.nrc.gov/nrr/ope (nonpublic)

IHS Codes and Standards:

http://www.internal.nrc.gov/TICS/library/standards/ihs.html (nonpublic)

NRC Technical Library:

http://www.internal.nrc.gov/TICS/library/index.html (nonpublic)

END Issue Date: 12/20/2018 8 71111.01

Attachment 1 Revision History for IP 71111.01 Commitment Accession Description of Change Description of Comment Resolution and Tracking Number Training Closed Feedback Form Number Issue Date Required and Accession Number (Pre-Change Notice Completion decisional, Non-public Date Information) 04/03/00 71111.01 has been issued to provide the minimum CN 00-003 inspection oversight for determining the safety performance of operating nuclear power reactors.

ML020380469 IP 71111.01 has been revised to provide detailed 01/17/02 inspection requirements and guidance for evaluating a CN 02-001 licensee's readiness for seasonal susceptibilities and impending weather conditions. In addition, the inspection resource estimate is revised to provide a band for more inspection flexibility.

ML041050003 IP 71111.01 has been revised to clarify sample sizes, 04/13/04 minimum samples for completion and improve guidance CN 04-008 provided in the inspection requirements.

03/02/07 Revision history reviewed for the last four years C1 ML070240487 IP 71111.01 has been revised to address feedback form Training ML070670471 SRM 03/23/07 71111.01-902 to include recommended inspection performed at M050426 CN 07-011 guidance and also to incorporate inspections for the offsite resident power system and the alternate AC power source. inspector counterpart meetings and completed on 12/13/06.

ML072960230 IP 71111.01 has been revised to reflect the 2007 Reactor ML073520325 01/31/08 Oversight Process (ROP) realignment (addition of external CN 08-005 flooding review formerly in IP 71111.06) and to address feedback form 71111.01-1163.

Issue Date: 12/20/18 Att 1-1 71111.01

Commitment Accession Description of Change Description of Comment Resolution and Tracking Number Training Closed Feedback Form Number Issue Date Required and Accession Number (Pre-Change Notice Completion decisional, Non-public Date Information)

ML080650308 IP 71111.01 has been revised to address feedback form ML081220121 05/01/08 7111.01-1150 to include recommended clarification of CN 08-013 inspection guidance regarding offsite power grid reliability verification. Revisions have also been made to include consideration for drought ramifications and to reorganize the inspection requirements.

ML083170657 IP 71111.01 has been revised to clarify the expectations ML090700219 04/09/09 for performing the grid reliability sample (FBF 71111.01-CN 09-011 1305).

ML092290690 IP 71111.01 has been revised based on the 2009 ROP 11/09/09 realignment (adjustment of resource estimate and CN 09-026 clarification of sample requirements).

ML14337A104 Editorial change based on FBF 71111.01-2043. Deleted ML14324A635 12/04/14 Subsection 2.04.c.7, Sources of potential internal flooding 71111.01-2043 CN 14-029 that are not analyzed or not adequately maintained, for ML14324A635 example failure of flexible piping expansion joints, failure of fire protection system sprinklers, roof leaks, rest room backups, and failure of service water lines, which is already in IP 71111.06 and not needed in IP 71111.01.

ML14343A684 Incorporated Fukushima lessons learned (06/12/13 ML15215A044 09/04/15 meeting) and Fukushima flooding inspection insights. 71111.01-2130 CN 15-016 Revised to incorporate FBF 71111.01-2130. ML15246A215 ML17101A803 Added additional ultimate heat sink considerations to ML17164A302 11/28/17 Summer Readiness sample. Eliminate redundancy and 71111.01-2220 CN 17-027 improved for plain writing. Relocated optional ML17200C868 requirements to the guidance section to better align with IMC 2515, Section 8.04, sample completion requirements.

ML18278A281 Changed seasonal extreme weather baseline sample ML18288A004 12/20/18 requirement to prior to the onset of seasonal extreme 71111.01-2336 CN 18-044 weather. ML18288A013 Issue Date: 12/20/18 Att 1-2 71111.01