Number range CHAPTER**ATTACHMENT 71111.06**

INSPECTABLE AREA: Flood Protection Measures

CORNERSTONES: Initiating Events

Mitigating Systems

INSPECTION BASES: Flooding due to internal causes has been shown to be a
significant contributor to risk at some facilities. Flooding has the
potential to make multiple trains of equipment and support equipment
inoperable. Flooding may also affect operator mitigation and recovery
actions.

LEVEL OF EFFORT: Each inspection sample should consist of at least 1
internal flooding area. The selected area could consist of one room or
multiple rooms depending upon plant layout.

71111.06-01 INSPECTION OBJECTIVE

01.01 This inspection will focus on verifying that the licensee's
flooding mitigation plans and equipment are consistent with the
licensee's design requirements and the risk analysis assumptions.

71111.06-02 INSPECTION REQUIREMENTS

02.01 [Document Review and Inspection Area Selection]{.underline}.

> a\. Review the final safety analysis report (FSAR) and related flood
> analysis documents to identify those areas that can be affected by
> internal flooding, including water intake facilities. Review licensee
> documentation that shows the design flood levels for areas containing
> safety-related equipment. Review problem reports and corrective
> actions for past flooding events.
>
> b\. Based on licensee's flooding risk studies, select plant areas
> containing risk significant structures, systems, and components (SSCs)
> which are susceptible to flooding.

02.02 [Inspection Activities]{.underline}.

> a\. Walkdown the selected area(s) or room(s). By observation/design
> review, including reviews of preventive maintenance (PM) activities,
> consider the following attributes. Give priority to those attributes
> which are risk significant for the site specific installation:

1.  Sealing of equipment below the floodline, such as electrical
    conduits.

2.  Sealing of equipment floor plugs, holes or penetrations in floors
    and walls between flood areas.

3.  Adequacy of watertight doors between flood areas.

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

5.  Verify that the drain system has adequate protection
    (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.  Sources of potential internal flooding that are not analyzed or not
    adequately 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.

8.  Condition and availability of temporary or removable flood barriers
    (i.e., gaskets).

    b\. Inspect underground bunkers/manholes subject to flooding that
    contain multiple train or multiple function risk-significant cables.
    Consider the following attributes which are risk significant for the
    site specific installation:

    1\. Verify by record review that operable sump pumps will deliver at
    the expected flow rate established by the licensee's design basis
    documentation or FSAR.

    2\. Verify level alarm circuits are set appropriately.

    3\. Cables/splices subject to submergence appear intact.

    4\. Determine whether drainage is provided for the bunkers/manholes
    selected, or if not, why not?

    NOTE: The intent is not to inspect bunkers/manholes that are welded
    shut or to request extraordinary effort by the licensee to open
    bunkers/manholes for inspection unless a problem has been identified
    or is suspected that could adversely affect risk significant
    component(s). Inspectors should be alert for bunkers/manholes and
    take advantage to inspect. If such opportunity is identified, the
    inspector should select the bunkers/manholes to be inspected based
    on the licensee's inspection activities as much as possible.

    c\. 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.

    02.03 [Problem Identification and Resolution]{.underline}.

    Flooding has the potential to cause common mode failure of equipment
    in multiple areas. Verify that the licensee has entered the problems
    identified during the inspection in the licensee's corrective action
    program. Verify that the licensee is identifying issues at an
    appropriate threshold and entering them in the corrective action
    program. Verify that problems included in the licensee's corrective
    action program are properly addressed for resolution. See Inspection
    Procedure 71152, "Identification and Resolution of Problems," for
    additional guidance.

    71111.06-03 INSPECTION GUIDANCE

+------------+-------------+---------------------+--------------------+
| Number     | *           | **Risk Priority**   | **Example**        |
| range      | *Inspection |                     |                    |
| CH         | Objective** |                     |                    |
| APTER**Cor |             |                     |                    |
| nerstone** |             |                     |                    |
+============+=============+=====================+====================+
| Initiating | Identify    | Potentials for      | Adequate           |
| Events     | internal    | common-cause        | maintenance of     |
|            | flooding    | failures            | expansion joints   |
|            | which could |                     | on high volume/low |
|            | cause       | Barriers between    | pressure systems   |
|            | initiating  | flood areas         |                    |
|            | events      |                     | Firewater          |
|            |             | Unanalyzed sources  | sprinkler          |
|            |             | of internal         | maintenance        |
|            |             | flooding            |                    |
|            |             |                     | Unusual testing    |
|            |             | Areas below the     | configurations for |
|            |             | flood plane         | large volume water |
|            |             |                     | systems            |
+------------+-------------+---------------------+--------------------+
| Mitigating | Identify    | Locations           | Water-tight doors, |
| Systems    | internal    | containing high     |                    |
|            | flooding    | volume/low pressure | sump pumps, and    |
|            | events      | systems, such as    | alarms             |
|            | which could | firewater, service  |                    |
|            | cause loss  | water and component | Adequate sealing   |
|            | of          | cooling water,      | of safe-shutdown   |
|            | sa          | especially in areas | electrical         |
|            | fe-shutdown | contain flexible    | equipment below    |
|            | equipment   | piping expansion    | the flood line     |
|            |             | joints              |                    |
|            |             |                     | Check valves in    |
|            |             |                     | open drain systems |
|            |             |                     | common to          |
|            |             |                     | different flood    |
|            |             |                     | areas              |
+------------+-------------+---------------------+--------------------+

Number range CHAPTER71111.06-04 RESOURCE ESTIMATE

The annual resource expenditure for this inspection procedure is
estimated to be 13 to 19 hours to review internal flood protection
features based on inspector's discretion at a site regardless of the
number of units at that site.

71111.06-05 COMPLETION STATUS

Inspection of the minimum sample size will constitute completion of this
procedure in the Reactor Program System (RPS). That minimum sample size
will consist of 2 samples per section 02.02 of this procedure in a year
regardless of the number of reactor units at that site.

71111.06-06 REFERENCES

Inspection Procedure 71152, "Identification and Resolution of Problems."

Regulatory Guide 1.102, "Flood Protection for Nuclear Power Plants."

Circular 78-06, "Potential Common Mode Flooding of ECCS Equipment Rooms
at BWR Facilities," May 31, 1978.

Information Notice 83-44, "Potential Damage to Redundant Safety
Equipment as a Result of Backflow Through the Equipment and Floor Drain
System," July 1, 1983.

Information Notice 83-44s1, "Potential Damage to Redundant Safety
Equipment as a Result of Backflow Through the Equipment and Floor Drain
System," August 30, 1990.

Information Notice 87-49, "Deficiencies in Outside Containment Flooding
Protection," October 9, 1987.

NRC Information Notice 88-60, \"Inadequate Design and Installation of
Watertight Penetration Seals,\" August 11,1988.

Information Notice 92-69, "Water Leakage from Yard Area Through Conduits
into Buildings," September 22, 1992.

Information Notice 94-27, "Facility Operating Concerns Resulting from
Local Area Flooding," March 31, 1994.

Information Notice 98-31, "Fire Protection System Design Deficiencies
and Common-Mode Flooding of Emergency Core Cooling System Rooms at
Washington Nuclear Project Unit 2," August 18, 1998.

Information Notice 05-11, "Internal Flooding/Spray-Down of
Safety-Related Equipment Due to Unsealed Equipment Hatch Floor Plugs
and/or Blocked Floor Drains," May 6, 2005.

Information Notice 05-30, \"Safe Shutdown Potentially Challenged by
Unanalyzed Internal Flooding Events and Inadequate Design," November 07,
2005.

END

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Revision History For 71111.06

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|       | umber | CHAPTERRevision history     | one |      |        |
|       | range | reviewed for the last four  |     |      |        |
|       | CHAPT | year                        |     |      |        |
|       | ER01/ |                             |     |      |        |
|       | 25/07 |                             |     |      |        |
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|       | umber | CHAPTER71111.06 has been    | one |      |        |
|       | range | issued to provide the       |     |      |        |
|       | CHAPT | minimum inspection          |     |      |        |
|       | ER04/ | oversight for determine the |     |      |        |
|       | 03/00 | safety performance of       |     |      |        |
|       |       | operating nuclear power     |     |      |        |
|       | CN-0  | reactors.                   |     |      |        |
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| N/A   | N     | Number range                | N   | N/A  | N/A    |
|       | umber | CHAPTER71111.06 has been    | one |      |        |
|       | range | issued to provide the       |     |      |        |
|       | CHAPT | minimum inspection          |     |      |        |
|       | ER01/ | oversight for determine the |     |      |        |
|       | 17/02 | safety performance of       |     |      |        |
|       |       | operating nuclear power     |     |      |        |
|       | CN-0  | reactors.                   |     |      |        |
|       | 2-001 |                             |     |      |        |
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| N/A   | N     | Number range CHAPTERIP      | N   | N/A  | Number |
|       | umber | 71111.06 has been revised   | one |      | range  |
|       | range | to address feedback form    |     |      | CHAPTE |
|       | CHAPT | 71111.06-889 to update      |     |      | RML063 |
|       | ER01/ | procedure based on          |     |      | 470279 |
|       | 25/07 | inspection and operating    |     |      |        |
|       |       | experience. Also, the Level |     |      |        |
|       | CN-0  | of Effort and Inspection    |     |      |        |
|       | 7-003 | Basis sections were changed |     |      |        |
|       |       | to give the flexibility to  |     |      |        |
|       |       | select either internal or   |     |      |        |
|       |       | external samples based on   |     |      |        |
|       |       | inspectors\' discretion.    |     |      |        |
+-------+-------+-----------------------------+-----+------+--------+
| N/A   | 01/   | IP 71111.06 has been        | N   | N/A  | ML073  |
|       | 31/08 | revised to address the 2007 | one |      | 520328 |
|       |       | ROP realignment, shifting   |     |      |        |
|       | CN-0  | external flooding review to |     |      |        |
|       | 8-005 | IP 71111.01, and to correct |     |      |        |
|       |       | typographic errors.         |     |      |        |
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| N/A   | 08/   | IP 71111.06 has been        | N   | N/A  | N/A    |
|       | 19/08 | revised to clearly state    | one |      |        |
|       |       | that an inspection sample   |     |      |        |
|       | CN    | is one area. This addresses |     |      |        |
|       | 0     | feedback form               |     |      |        |
|       | 8-024 | 71111.06-1267.              |     |      |        |
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