ML19199A089

IP 71111.15 Operability Determinations and Functionality Assessments

ML19199A089
Person / Time
Issue date:	12/20/2019
From:	Aron Lewin NRC/NRR/DRO/IRIB
To:
Lewin A, 415-2259, NRR/DRO
Shared Package
ML19259A077, ML19353A047	List:
References
CN 19-041, DC 19-024
Download: ML19199A089 (9)

Text

NRC INSPECTION MANUAL IRIB INSPECTION PROCEDURE 71111 ATTACHMENT 15 OPERABILITY DETERMINATIONS AND FUNCTIONALITY ASSESSMENTS Effective Date: 01/01/2020 PROGRAM APPLICABILITY: IMC 2515 A CORNERSTONES: Mitigating Systems Barrier Integrity INSPECTION BASES: See IMC 0308 Attachment 2 SAMPLE REQUIREMENTS Minimum Baseline Completion Sample Requirements Budgeted Range Sample Requirements Sample Type Section Frequency Sample Size Samples Hours 15 to 21 at 87 to 113 hours0.00131 days <br />0.0314 hours <br />1.868386e-4 weeks <br />4.29965e-5 months <br /> 15 at one reactor one reactor at one reactor unit sites unit sites unit sites 19 to 25 at 107 to 137 hours0.00159 days <br />0.0381 hours <br />2.265212e-4 weeks <br />5.21285e-5 months <br /> Operability 19 at two reactor two reactor at two reactor Determination or 03.01 Annual unit sites (4 for unit sites (4 to unit site (22 to 56 Functionality AP1000) 10 for hours for Assessment AP1000) AP1000) 22 to 30 at 127 to 161 hours0.00186 days <br />0.0447 hours <br />2.662037e-4 weeks <br />6.12605e-5 months <br /> 22 at three three reactor at three reactor reactor unit sites unit sites unit sites 71111.15-01 INSPECTION OBJECTIVE To review operability determinations of technical specification (TS) SSCs (including support systems as defined in the TS) or functionality assessments associated with non-TS SSCs affecting mitigating systems and barrier integrity to ensure that operability or functionality is properly justified and the SSC remains capable of performing its specified safety function or current licensing basis (CLB) function, such that no unrecognized increase in risk has occurred.

Issue Date: 12/20/19 1 71111.15

71111.15-02 GENERAL GUIDANCE1 Selection of operability determinations or functionality assessments should involve risk significant SSCs. Operability is a term solely associated with TS compliance. Functionality assessments do not involve compliance with TS. Inspectors should apply risked informed insights together with other factors, such as engineering analysis and judgment, operating experience, and performance history, to determine which operability determinations or functionality assessments should be selected for review. Selection of operability determinations or functionality assessments can emerge from the inspector's review of plant status documents such as operator shift logs, emergent work documentation, deferred modifications, and standing orders to determine if an operability determination or functionality assessment is warranted for a degraded or nonconforming condition.

The following can be used to assist the inspector in identifying SSCs that have a risk priority:

Operating - Mitigating systems and barrier integrity features as determined by plant-specific risk information such Risk Achievement Worth. Examples: High Pressure Coolant Injection (HPCI) system or Reactor Core Isolation Cooling (RCIC) system.

Shutdown - Mitigating systems and barrier integrity features that perform key safety functions during shutdown. Examples: SSCs associated with decay heat removal, inventory control, electrical power availability, reactivity control, core configuration, or containment.

IMC 0326, Operability Determinations provides guidance to NRC inspectors to assist in their review of licensee determinations of operability. This section contains excerpts and discussions from IMC 0326. More detailed information can be found in IMC 0326. IMC 0326 no longer contains guidance on assessments of functionality. However, pertinent guidance is retained in this Inspection Procedure (IP). In addition, Attachment 1 of this IP contains a high-level visual representation of Operability Determinations / Functionality Assessments as they relate to SSCs described and in the TS and SSCs not described in the TS.

Operability refers to the capability of a TS SSC to perform its specified safety function. The scope of SSCs considered within the operability determination process are: 1) SSCs that are required to be operable by TS (these SSCs may perform required support functions for other SSCs required to be operable by TS); and 2) SSCs that are not explicitly required to be operable by TS, but that perform support functions as defined in the TS for SSCs required to be operable by TS.

1 Note: For AP1000 designs, in addition to safety-related Structures, Systems and Components (SSCs), focus on systems classified as Regulatory Treatment of Nonsafety Systems (RTNSS) of high or intermediate importance, which are used for protecting utilities investment and for preventing and mitigating severe accidents. A list of SSCs classified as RTNSS is in Chapter 16 of the Vogtle Electric Generating Plant (VEGP) Updated Final Safety Analysis Report (UFSAR), Table 16.3-1 (ML18179A291). The list of Risk-Significant SSCs within the Scope of Design Reliability Program, which evaluates the design of the AP1000 and identifies the aspects of plant operation, maintenance, and performance monitoring pertinent to risk-significant SSCs, is in Chapter 17 of the VEGP.UFSAR, Table 17.4-1 (ML18179A292). RTNSS is discussed in Section C.IV.9 Regulatory Treatment of Nonsafety Systems of Regulatory Guide 1.206, Applications for Nuclear Power Plants, (ADAMS Package Accession No. ML070720184).

Issue Date: 12/20/19 2 71111.15

Operability determinations are appropriate whenever a condition calls into question the ability of an SSC to perform its specified safety functions. The operability determination process is used to assess operability of SSCs and their support functions for compliance with TS when a condition is identified for a specific SSC required to be operable by TS, or when a condition is identified which impacts a necessary and related support function. Ensuring operability for any SSC described in TSs is a continual process. Licensees should evaluate operability upon discovery of a condition that results in the loss of the presumption of operability.

Functionality assessments generally refers to the capability of a non-TS SSC to perform its function set forth in the CLB. Functionality assessments may be performed for SSCs not described in TS, but which warrant programmatic controls to ensure that SSC availability and reliability are maintained. In general, these SSCs and the related controls are included in programs related to Appendix B to 10 CFR Part 50, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, and the maintenance rule (10 CFR 50.65).

Additionally, SSCs not described in TS may warrant functionality assessments within the processes used to address conditions because they perform functions described in the Updated Final Safety Analysis Report (UFSAR), technical requirements manual, emergency plan, fire protection plan, regulatory commitments, or other elements of the CLB.

Normally, functionality is assessed and documented through other plant processes such as the corrective action process. It is appropriate to consider safety significance in determining the appropriate depth of a functionality assessment. Also, the effect of nonfunctional SSCs on compliance with other regulatory requirements (e.g., Appendix R, station blackout, ATWS, environmental qualification, maintenance rule) should be determined. In addition, other licensee processes and programs may need to be considered (e.g., availability, maintenance rule, reportability) when SSCs are not functional.

When evaluating the effect of a condition, a licensee may decide to implement compensatory measures as an interim action until final corrective action to resolve the condition is completed.

IMC 0326 contains guidance on the use of compensatory measures. In addition, compensatory measures that substitute manual operator actions for automatic actions should be resolved expeditiously. IMC 0326 contains additional guidance on the temporary use of manual actions instead of automatic actions. A licensee may refer to these compensatory measures as Operator Work Arounds (OWAs).

In addition, if a compensatory measure involves a temporary facility or procedure change, 10 CFR 50.59 should be applied to the temporary change with the intent to determine whether the temporary change/compensatory measure itself (not the condition) impacts other aspects of the facility or procedures described in the UFSAR. In considering whether a temporary facility or procedure change impacts other aspects of the facility, a licensee should apply 10 CFR 50.59, paying particular attention to ancillary aspects of the temporary change that result from actions taken to directly compensate for the condition. Licensees may use the guidance in NEI 96-07, Revision 1, Guidelines for Implementing 10 CFR 50.59, which is endorsed by Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments. NEI has also published a NEI 96-07, Revision 1, Appendix E, Users Guide for NEI 96-7, Revision 1, Guidelines for 10 CFR 50.59 Implementation. However, NEI 96-07, Revision 1, Appendix E has not been reviewed or endorsed by the NRC. If needed, questions regarding potential 10 CFR 50.59 issues as a result of a licensees use of Appendix E can be raised with the DORL PM.

Issue Date: 12/20/19 3 71111.15

For each sample, a routine review of problem identification and resolution activities should be conducted. Consider if the licensee is identifying problems with operability determinations and functionality assessments at an appropriate threshold, entering them in the corrective action program, and is identifying and implementing appropriate corrective actions. IP 71152, Problem Identification and Resolution, contains background information with regards to conducting reviews of Problem Identification and Resolution activities during the conduct of baseline inspection procedures.

Nuclear power plants are designed to ensure that SSCs needed to maintain the facility in a safe condition will be available to mitigate the effects of natural phenomena, including tornadoes and tornado-generated missiles. Over the past several years, licensees and the NRC have identified facilities that have not conformed to their licensing basis for tornado-generated missile protection and are therefore not in compliance with applicable regulations. Revision 1 of Enforcement Guidance Memorandum (EGM) 15-002, Enforcement Discretion for Tornado-Generated Missile Protection Noncompliance, (ML16355A286) provides guidance to exercise enforcement discretion for tornado-generated missile non-compliances and is applicable to operating power reactor licensees. This enforcement discretion expired on June 10, 2018, for plants of a higher tornado missile risk (Group A Plants) and expires on June 10, 2020, for plants of a lower tornado missile risk (Group B Plants). The enclosure to the EGM includes all operating reactors grouped according to analysis. Additional background information can be found in Regulatory Issue Summary (RIS) 2015-06, Tornado Missile Protection, (ML15020A419) and NRC Memorandum titled, Timely Resolution of Issues Related to Tornado-Missile Protection, (ML18338A085).

71111.15-03 INSPECTION SAMPLES 03.01 Review the licensees operability determination or functionality assessment to verify that operability or functionality is justified and that the licensee is taking appropriate actions.

Specific Guidance The intent of this inspection is to sample licensees operability determinations and functionality assessments for risk significant SSCs to determine if operability determinations and functionality assessments are justified, such that operability and/or availability are assured, and no unrecognized increase in risk has occurred. Also, the inspections should determine if operability and functionality concerns associated with plant issues and events are being identified. Inspectors should consider the following aspects:

• The selected operability determination or functionality assessment has appropriately considered the potential cause(s), extent of the condition, and adverse effects on associated SSC specified safety functions or CLB functions. Refer to the updated final safety analysis report (UFSAR) and other design basis documents during the review.

• The licensee is looking beyond the prominent symptoms of the condition to ensure that a narrow focus or non-conservative assumption does not compromise the justification that the SSC remains capable of performing its specified safety functions or CLB functions.

Issue Date: 12/20/19 4 71111.15

• If the operability or functionality assessment involves compensatory measures: The measures are in place, work as intended, do not cause system operation in a manner inconsistent with the specified safety function or CLB function, and are appropriately controlled. The licensee is considering other conditions and their impact on any compensatory measures for the condition being evaluated. The licensee is considering whether use of a compensatory measure requires a license amendment.

• If operability or functionality are not justified, appropriate actions are taken including a determination of impact on any TS limiting condition for operation (LCO).

Depending on the complexity and risk significance of an issue, an inspector may consider consulting with regional specialists to complete a review of a licensees operability determination or functionality assessment. The regional specialists time spent on reviewing the issue should be charged to this procedure.

71111.15-04 REFERENCES IP 71152, Problem Identification and Resolution IMC 0326, Operability Determinations IMC 2515, Light-Water Reactor Inspection Program - Operations Phase 10 CFR 50.59, Changes, tests, and experiments.

NRC Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Test, and Experiments, Nov 2000. (ML003759710)

NEI 96-07, Revision 1, Guidelines for 10 CFR 50.59 Evaluations, (Nov 2000). (ML003771157)

Revision 1 of EGM 15-002, Enforcement Discretion for Tornado-Generated Missile Protection Noncompliance, (ML16355A286)

RIS 2015-06, Tornado Missile Protection, (ML15020A419)

NRC Memorandum titled, Timely Resolution of Issues Related to Tornado-Missile Protection, (ML18338A085)

END Issue Date: 12/20/19 5 71111.15

Attachment 1: Operability Determinations / Functionality Assessments of SSCs Structures, Systems, and Components (SSCs)

SSCs not described in Technical Specifications (TS) SSCs described in TS Subject to functionality Subject to operability requirements of the determinations.

current licensing basis SSC can perform its (CLB). specified safety function(s).

NRC guidance found in Also performs necessary If yes, such functions are IMC 0326.

and related support within scope of functions for TS SSCs? operability determination.

Issue Date: 12/20/19 Att1-1 71111.15

Attachment 2 - Revision History for IP 71111.15 Commitment Accession Description of Change Description of Comment Resolution Tracking Number Training Required and Closed Feedback Number Issue Date and Completion Form Accession Change Notice Date Number (Pre-Decisional, Non-Public Information)

ML003729444 Initial Issuance Yes 04/03/00 CN 00-003 N/A ML020380579 Revised to provide minor clarifications to inspection N/A N/A 01/17/02 requirements and additional inspection guidance CN 02-001 concerning operability determinations. In addition, inspection resource estimates and inspection level of effort are revised to provide a band for more inspection N/A ML040690557 Revised to include deferred modifications to the N/A N/A 02/02/04 inspection sampling list.

CN 04-003 N/A ML060060380 Increased the estimated resources required to N/A N/A 01/05/06 complete this inspection activity based on increased CN 06-001 inspection hours charged to this IP during last several ROP cycles. Completed historical CN search.

N/A ML061730334 Revised to reflect changes of reference documents: N/A N/A 07/26/06 GL91-18 was superseded by RIS 2005-20.

CN 06-018 Revision history reviewed for the last four years.

N/A ML073050448 Add inspection guidance to verify that licensee has N/A N/A 01/31/08 correctly implemented 10 CFR 50.59 regulatory CN 08-005 requirements if operability determinations warrant such 50.59 evaluations be performed.

Issue Date: 12/20/19 Att2-1 71111.15

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

N/A ML092300320 Added 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of inspection resources. See 2009 N/A N/A 11/16/09 ROP Realignment Results (ML092090312)

CN 09-027 N/A ML110030073 This change clarifies and enhances the sample N/A ML110630221 04/05/11 selection guidance related to functionality CN 11-005 assessments associated with TS SSC operability determinations and provides the additional latitude to select risk significant SSCs which may not be identified in TS for sampling (71111.15 - 1597).

Added the definition of a degraded condition (71111.15 - 1625).

N/A ML112010663 Resources changed to reflect the 2011 ROP N/A N/A 10/28/11 Realignment (ML11178A329).

CN 11-025 N/A ML14260A356 1. Relocate operator workaround from IP 71152 per Yes ML14287A037 12/17/14 BIP Enhancement Project Encl. 5 Operability 12/31/14 CN 14-030 Recommendation 1; 2. Delete 02.01.f. as it is FBF 71111.15-1742 redundant with IMC 0612 App. B; 3. Update ML14351A020 71111.15-06 REFERENCES; FBF 71111.15-1974 This revision addresses or partially addresses ML14351A022 ROPFF #s 71111.15-1742, 71111.15-1974, and beyond-scope administrative comments that were accepted during 30-day comment process (ML14287A037)

Issue Date: 12/20/19 Att2-2 71111.15

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

N/A ML16147A250 Revisions are made to address use of mandatory None ML16158A083 12/22/16 and discretionary language concerns and CN 16-035 recommendations found in OIG-16-A-12 (ML16097A515). Requirement to inspect at least one sample associated with OWAs has been deleted.

N/A ML19113A142 Editorial revision to support proposed modification None N/A - Editorial change 04/30/19 to RPS-Inspections for tracking inspection activity / issued without CN 19-013 completion. comment period.

N/A ML19199A089 Revisions are made to: (1) conform to new IP format None ML19259A079 12/20/19 requirements found in IMC 0040 (ML18003A122),

CN 19-041 and (2) reflect revisions to IMC 0326.

Issue Date: 12/20/19 Att2-3 71111.15