ML18334A120
| ML18334A120 | |
| Person / Time | |
|---|---|
| Issue date: | 04/24/2019 |
| From: | Aron Lewin NRC/NRR/DIRS/IRIB |
| To: | |
| Lewin A, 415-2259, NRR/DIRS | |
| References | |
| Download: ML18334A120 (3) | |
Text
Inspection Procedure Assessment Summary and Outline of Proposed Changes Inspection Procedure (IP): IP 71111.06, "Flood Protection Measures" Inspector Procedure Lead: Chris Cauffman Estimated Hours to Complete Review: 16 hrs Date Review Completed: 8/16/18
- 2. Results and assessment of review of any applicable changes to PIs A three year review by the PI lead did not identify any significant changes to PIs that would result in a reduction or unintended gap in the key safety attributes of each safety cornerstone.
- 3. Results and assessment of review of any applicable changes to Rules and STSs Revisions to rules and Standard Technical Specifications within the last three years did not indicate a need for revision.
- 4. Results and assessment of review of recent Operating Experience Might be able to add some additional guidance related to highlighted text below.
- Degraded door seals
- Design issues (missing seals, missing drains, etc.)
- Introduction of errors or unanalyzed conditions during modifications or maintenance where Seals are breached or removed temporarily, or Flood flow paths are affected by new construction
- Debris left near drains or clogging drains
- Unprotected or unanalyzed equipment
- Inadequate, incomplete, incorrect or missing procedures to respond to a flood
- Inadequate, incomplete, incorrect or missing procedures to inspect/maintain seals
- Disable barrier flood barrier compensate and track
- Fire suppression equipment potentially impacting multiple trains of safety related equipment
- 5. Results and assessment of review based on RRPS data (see separate IP [list IP number]
Assessment Data file for details of RRPS data)
Adverse trends or outliers noted: No Discuss if the actual inspection hours charged per IP sample is consistent with the estimated inspection hours listed in the IP. (2.9 samples
- 6.3 hrs/sample = ~18 hrs, IP is budgeted for 20 +/-3)
Discuss any greater than green findings or greater than Severity Level IV violations: None documented in last 3 years
Theory: Decline in findings due to design issues being identified and fixed (Fort Calhoun &
Fukushima)
- 6. Feedback Forms Date Status - Title ADAMS 5/21/2015 Approved - Cable / Dewatering ML15141A060 5/21/2015 Approved - Cable Vault Sample Flexability ML15141A072
- 7. Other Considerations None
- 8. Results of discussions with regions Ken Kolacyzk No RII Representation Charles Phillips Trisa Voss Suggest retitling the name of IP to Internal Flooding and Cable Vault or something more representative of the activity.
Other areas the procedure should look at - External Pumping Systems / Containment Mat Drain System - hydrostatic pressure on containment structures (There is an IN from 90s on the subject)
Postulated flooding wording & power availability in one part of the procedure is not quite right.
Section 02.02c1 - improve guidance on when to contact NRR - make less subjective
- 1) For facilities that do not have a history of flooded cable vaults, selection of cable vaults as the flood area is viable sample. My initial reaction would be to look at cable vault flooding every three years as 1 of the 2 required samples. However, opinions likely vary so I would recommend something along the lines of the following: For sites that do not have a history of cable failures due to wetting, inspectors may select cable routing areas as one of the annual samples.
- 2) Under 02.01, there is a review of cable monitoring programs. The review should be expanded to include reviews of the results on cable monitoring (megger, Hi-pot, etc0 The flood procedure should also address external flooding design features and the external flood requirement removed from 71111.01. The .01 procedure should focus on preps for flood conditions- such availability of flood damming material, installation of temp barriers, briefs to plant staff. The permanent flood mitigation features should be covered under .06.
One small thing: Section 02.01.a says to seek input from an SRA regarding site specific flood risk information. I talked with Laura Kozak and she told me that it would really be more beneficial to use licensee PRA staff because the SRAs dont really have a ton of site specific internal flooding information.
Recommendations Consider improvement during next routine revision.