ML22066B308

IP 71111.01 Adverse Weather Protection

ML22066B308
Person / Time
Issue date:	08/01/2022
From:	Aron Lewin NRC/NRR/DRO/IRIB
To:
Aron Lewin, NRR/DRO/IRIB, 415-2259
Shared Package
ML22068A181	List: Inspection Manual Change Notice 22-015, Table of Contents for Inspection Manual Change Notice 22-015 ML22066B308 ML22066B334 ML22115A187 ML22123A169 ML22154A388 ML22154A389 ML22154A390
References
CN 22-015
Download: ML22066B308 (8)

Text

NRC INSPECTION MANUAL IRIB INSPECTION PROCEDURE 71111 ATTACHMENT 01 ADVERSE WEATHER PROTECTION Effective Date: January 1, 2023 PROGRAM APPLICABILITY: IMC 2515 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 Seasonal Extreme 1 to 2 per 03.01 Annual* 1 per site Weather site 10 to 24 per site Impending Severe 1 to 2 per 03.02 Annual** 1 per site Weather site

• Prior to the onset of seasonal extreme weather

• • When impending severe weather is anticipated 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) adversely affecting the ultimate heat sink (e.g., debris, ice blockages, frazil ice, sea grass, fish, etc.), offsite power systems, and alternate AC power sources. When practical, the inspection should be performed prior to the onset of adverse weather conditions at the site.

For each sample, routine review of problem identification and resolution activities should be conducted using IP 71152, Problem Identification and Resolution.

Issue Date: 08/01/22 1 71111.01

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 Exchanger/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.

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.

Issue Date: 08/01/22 2 71111.01

71111.01-03 INSPECTION SAMPLES 03.01 Seasonal Extreme Weather.

Verify the adequacy of the licensee seasonal readiness prior to the onset of seasonal extreme weather conditions.

Specific Guidance

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

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

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

d. For summer readiness, consider review of the material condition of the plants offsite AC power systems and onsite alternate AC power systems, including the switchyard and transformers. Consider review of outstanding work orders.

e. Consider selection of two to four risk-significant systems that are required to be protected from the seasonal extreme weather conditions. Consider review of the updated final safety analysis report (UFSAR), technical specifications, and plant documents associated with these systems and then consider assessing the following:

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

2. As applicable, 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. Consider 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, the 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, the 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, 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 programs, as necessary, Issue Date: 08/01/22 3 71111.01

to support the cold weather protection function. As appropriate, consider performing a walkdown to verify the physical condition of weather protection features.

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

5. 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, the licensee can demonstrate through testing or analysis that diesel fuel oil Cloud Point 1 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.

03.02 Impending Severe Weather.

Verify the adequacy of the overall preparations to protect risk-significant systems from impending severe weather.

Specific Guidance

a. Consider evaluating 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. Consider review of the licensees plans to address the ramifications of potentially lasting effects that may result from the severe weather conditions (e.g., drought, flood).

b. Consider if 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. Consider if required surveillances are current, or are scheduled and completed, if practical, before anticipated severe weather conditions develop.

d. Consider 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: 08/01/22 4 71111.01

e. Consider review of plant modifications, maintenance activities (i.e., temporary hazard barrier removal), new evolutions, procedure revisions, or operator workarounds implemented to address periods of adverse weather that can inadvertently affect maintenance rule systems and SSCs. Consider if the licensee has assessed and managed these challenges to safe plant operation. Further follow-up 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.

71111.01-04 REFERENCES IMC 2515, Appendix A, Risk-Informed Baseline Inspection Program IMC 0308, Attachment 2, Technical Basis for Inspection Program IP 71111.07, Heat Exchanger/Sink Performance IP 71111.12, Maintenance Effectiveness IP 71111.13, Maintenance Risk Assessments and Emergent Work Control IP 71111.15, Operability Determinations and Functionality Assessments IP 71111.18, Plant Modifications IP 71152, Problem Identification and Resolution END Issue Date: 08/01/22 5 71111.01

Attachment 1: Revision History for IP 71111.01 Commitment Accession Description of Change Description of Comment Resolution Tracking Number Training and Closed Feedback Number Issue Date Required and Form Accession Change Completion Number (Pre-Notice Date decisional, Non-public 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 resident offsite 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 ML073520325 01/31/08 Reactor Oversight Process (ROP) realignment (addition CN 08-005 of external flooding review formerly in IP 71111.06) and to address feedback form 71111.01-1163.

Issue Date: 08/01/22 Att1-1 71111.01

Commitment Accession Description of Change Description of Comment Resolution Tracking Number Training and Closed Feedback Number Issue Date Required and Form Accession Change Completion Number (Pre-Notice Date decisional, Non-public 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 71111.01-2043 CN 14-029 flooding that are not analyzed or not adequately ML14324A635 maintained, for 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 Issue Date: 08/01/22 Att1-2 71111.01

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

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 ML19291A217 Specified sampling requirements for AP1000 units. ML19316B051 12/20/19 Deleted Summer Readiness sample and reduced budget CN 19-041 estimate by 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Commitment C1 was decommitted though SECY-19-0067 (ML19070A036).

N/A ML22066B308 Samples revised per NRR direction using Enclosure 2 None N/A Issued as final.

08/01/22 (ML19070A040) of SECY-19-0067 (ML19070A050) as CN 22-015 guidance. Updated references and plain writing guidance in accordance with IMC 0040.

Issue Date: 08/01/22 Att1-3 71111.01