ML20197J419

Submits Status Rept 2 Re Framework Team Status,Baseline Insp Team Status & Assessment Team Status.Three Projects Are on Track to Complete Deliverables in Dec

ML20197J419
Person / Time
Issue date:	11/11/1998
From:	Mallett B NRC
To:	NRC
Shared Package
ML20197J353	List: ML20197J347 ML20197J364 ML20197J419
References
NUDOCS 9812150070
Download: ML20197J419 (87)

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Table of Contents Enan 1

Program Overview / concept of Operations.................................. 1 2

Program Part 1: Inspectable Areas.'.............................

....... 3 2.1 Inspectable Areas Required in the Baseline Pro

...... f....... 3 Basis Documents....................... gram.........d%... T......... 5 2.2 2.3 Selection Process for Activities to Be insoected......... 2h. :.g4.8........... 5 Event Follow up...................w.......

2.4 Plant Walk Downs....................... JC......

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t......... A5 Program Part 2: Process for Verifying Per/ormance Indicators ['.

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Inspection Procedures....................

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Interface with Other NRC Activities.......

Allegations....................... dIh......... MSE,A@.......

6.1 i@pk....N3dd.............11 A...

6.2 Performance Assessment....

Enforcement.................Jgr..

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11 6.3 Training......................'..... $. wh..MDdh$................

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Projected Resourcesh..

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10 Prograrn. Feedback and Assessment..................................... 16 x

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M ist of Tables

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tf k Table Jylnspectable Areas by Comerstone...................................... 3 Tablef 2: Concept for Basialine; inspection Procedures.............................. 10 Table 3: Projected Resource' Estimates......................................... 15 q

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3R Appendices ik %g s bridiilfBnis Documents forinspectable Areas l

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1 PROGRAM OVERVIEW / CONCEPT OF OPERATIONS The NRC power reactor baseline inspection p*ogram defines the planned activities to evaluate licensee performance over a 12 month period. The overall objective of the program is to monitor all power reactor licensees at a defined level of effort to assure the licensees are using radioactive materials safely as defined by the. goals specified in the NRC's Strategic Plan.

The baseline reactor inspection program is divided into three parts:

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Part 1: Inspection in each inspectable area.

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i Part 2: Inspection to verify established performance indicators

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Part 3: Inspection to review licensee programs for ident tion andresolution gf problems /

and/orissues.

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The program concept for Part 1 is that all areas where t are is k need to inspect a licensee's performance are defined first. These are listed as "inspectable aressyn Table 1 of the document. Next, the baseline program is defined as onlyieqdhing inspection in those inspectable areas that are not bounded by performance' indicators orin'nisas where the s

performance indicators are limited in coverage. ThelnSectable afetas thit are no.1 required because of sufficient coverage by a performance indicatorhill be marled in Table 1 by an asterisk. These areas will also be clearly

" n' edin the basis documint for each inspdable i f f

Another key concept for Part 1 is that inspectable area will have a basis document, which describes the scope of the inspectable area and the reasons why the area is included in the I

l baseline program. Reasons include (1)' the linkage to t.bn NRC's mission, (2) the linkage to the key attribute of a comerstone of safety that,the inspectable area is measuring, and (3) the risk information that was used tobplain why thorn is[a~ nee' to include the inspectable area in the d

baseline program. A third key concept in Part 1 js that the regional managers and inspectors will l

plan the type and number of activities to inspect each year for each reactor site, based on the I

guidance containedin the Rifds$3f%

M NA YMA Use of risk inforrnation is^factorehintoTthis*part of the program in four ways: (1)inspectable areas are based ~on their risk jmporfarps in measuring a comerstone attribute, which supports the NRC mission, (2) the frequency, how many activities, how much time to inspect activities in each insbictable area it, based sh risk information in a Risk information Matrix (RIM),

(3) selection of activities to inspect in each inspectable area is based on the use of a RIM, mossfied by plant specifid}nformation, and (4) inspectors are trained in the use of risk inf6rmation.

M The concept for Partf of the program is that there will be verification of performance indicators (Pis);us'ed in lieu 6fihspection. This verification will be at each reactor site and across reactor sites $This verification will also include review of Pi information submitted by licensees to de'tengheX there is a declining trend in performance.

The concept for Part 3 of the program is that there will be inspection of licensee programs for j

identification and resolution of problems and/or issues in conjunction with inspection of activities in other inspectable areas. There will also be a defined team inspection of effectiveness of the licensee's overall program in this area each year.

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.m m _7 2 PROGRAM PART1: INSPECTABLE AREAS 2.1 inspectable Areas Required in the Baseline Program This part of the inspection program consists of the annual review of areas to inspect (i.e., l inspectable areas) at each power reactor facility. The inspectable areas and their link to the attributes they are measuring is depicted in the comerstone charts in Appendix 11. The { inspectable areas are also listed in Table 1, below, by comerstone. / ) 1 There are specified inspectable areas, or nortions of areas, 'that will n currently be measured as part of the baseline inspection program because they are s0fficiently covened by review of performance indicators submitted by licensees. These inspectable areas ~will belndicated in j Table 1 by an asterisk (*) next to the area. // f];!A y ff x2 y Table 1: Inspectable Areas by Comerstone (6 j T~h ~ r, .W The important attributes of each comerstone being verifish by the inspectable areas are identified in parentheses. e initiatine Events Comerstone % ap w.% Mbs N Adverse weather preparations,(extemal factors) Equipment alignment (configuration coritrsig ~ Emergent work (configuration' control)fNjfl_ - l Fire protection (extemal factors) g Flood protection measures (extemal factors identification and re.s'olution of problems /is s inservice inspection activities.(equipment performance) Piping system,erosl6n and c6rrosi Pre-job briefings (human performa,on (e(ufpment performance) 4hinhk k$[7 nce e MitiaAtio Systems Comerstone

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?R MA V nditions and safety analysis report (design) l Equipmentalignment,(equipment performance and configuration control) Fire protection,(design;and equipment performance) /- Flood' protection measures (design) Heat exchanger performance (equipment pertermance) A identification and resolution of problems / issues 8 Inservicejestirig of pumps and valves - ASME Section XI

$2 Licensed operator requalification (human performance)

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• Maintenance rule implementation (equipment performance) h Maintenance work prioritization and control (configuration control)

NweOfff 6rmal plant operations (human performance) & Ndoperability evaluations (equipment performance) %$#' Operator workarounds (design) Permanent plant modifications (design) Post maintenance testing (equipment performance) l Refueling and outage activities (configuration control) Safety system design and performance capability (design and equipment i performance) Technical specification surveillance testing (equipment performance) Temporary plant modifications (design and configuration control) 3

c . w - - - - -~..- y------_--.- ,o l Table 1: Inspectable Areas by Comerstone (continued) e Barrier Inteority Comerstone

• Fuel barrier performance (cladding performance and configuration control) l Identification and resolution of problems / issues inservice inspection activities'(barrier performance)
• Large containment isolation valve leak rate and status verification GS8C barrier performance and configuration control)

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• Maintenance rule implementation (barrier perfe,rmance).

j rrlance) Maintenance work prioritization control (con /guration cojf a j fi l Permanent plant modifications (design) / Refueling and outage activities (fuel: human perfo configuration control) g ,d 7$ e Emeroency Preoaredness Comerstone j%l'4 r L

• Alert and notification system testing (equipment

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• Drill and exercise performance (ERO performance)Mp$p$g$>

... i Emergency action level changes (procedure quality)l0 Emergency response organization augmentation (erb ' ' ness)

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• Licensed operatet requalification (ERO pe bf fW Occuoational Exoosure Corne,rstone f e

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• Access control tofad@iologicallyiignifica ireas (equipment / facilities)

ALARA planning sn'd controls (pie i.5/ process) v identification and ' resolution'of problems / issues of! Radiatiori%dnitohng instrurnentati6n (equipment) RORadiation w5%eip8riviinance (human performance) N5hgA N'T5 Public Exoosure*Comerstoneg e 6d N /Ga&@ddA seous and liquid effluent treatment systems (equipment) Identificabon and'1ssolution of problems / issues RadioactiYshaterial processing and shipping (program / process) f#+g Radiologisai iniironmental monitoring program (program / process) k $$b Physical Securits$ e f ^' Comerstone n f]F

• /Wries's authorization program (human performance, program / process) h' **lsg ? Jocess control (equipment, human performance, program / process)

QgChanges to license conditions and safety analysis report (program / process) identification and resolution of problems / issues ' Physical protection system (equipment, human performance) Response to contingency events (equipment, human performance, program / process) b i l 4 i

= ^ L..- : --. G.;.--..L ~ ^ ' ^ ^ ^^ ~ ~ ~ ' ~ - ~ " ~ ~ ~ ~ ^ l 2.2 Basis Documents Each inspectable area is described in a basis docurhent (see Appendix l). The documents discuss the scope of inspections within the areas and the basis for why each area needs to be l inspected in the baseline program. The basis includes risk insights from generic risk analyses l and studies, analyses of significant precurser events, and the judgement of an expert panel of l inspectors and risk analysts. j N l 2.3 Selection Process for Activities to be inspected s / j\\ / l The baseline inspection program defines inspectable areas dthin a comersiose. It also defines the total hours per year expected to be expended in inspecfijdVvithin esch inspectable a,ea in fy each comerstone. This information is obtained from thefederal guidelinis irithe' Risk f/ Information Matrix (RIM) No.1. To plan and track effortjnspectingjtsn embhjnspectableaires in each comerstone, however, would expend significantresources with little benefit.sTherefore, l the planning and tracking of hours for the baseline inspdctioh pr5 ram will be bassd on ttie total l hours allocated for each comerstone, as derived from RIM Nozitand not based on the hours allocated for each inspectable area. A summary table of thess tots 1 hours is contained in Section 9 of this document. [ Q M l Each year, inspections at a specific power reactorJitsTwill,be planned us% t ing a process much like the current Plant Performance Review process.fKey$60Ek steps in the prdoess will be: In each comerstone, determ/bVme the inspectable areas / i l 1. applicable for the specific plant for the upcoming ped 6d from Table 1'in Secti65 2.1 of this document. The only reason an inspectatile area msy be excluded is that the area may not be expected to occur at thesite during the next 12 months (e.g., the refueling and outage activities). [ j[ For each inspe,ctable area, se% 2. lect the systems or activities to be inspected during .jhe next 12imonths. Guidelines for selection of the type system or activity can be ._ Vo6tained ora a generic basis from' RIM No. 2. Modifications to this generic basis Vshould be m'ade to sc"comodate site specific information. Guidelines for the inumbeIrof systems or activities can be obtained using RIM No.1. %] sSchedule%%l$SY 3. inspection'of the systems and activities selected in stops 1 and 2 above l /bver the next j2 rnont6s. The 10.131 hours expended to inspect the systems and f activities for all. inspectable areas within a comerstone are fixed for the 12 month di[ period anIf must not exceed those hours specified in Section 9 of this document. The planned hours to be expended inspecting within each inspectable area in a l 57 comerstohs; however, are Dgi fixed and to not need to be tracked or match those d generaM in rim No.1. 2 Eventfollow p D$kidN[ Tlii be.seline inspection program includes a procedure for event follow up that will be used in conjunction with other inspectable areas to review plant events. Inspection activities would focus on reactor safety comerstone items such as reactor trips and safety system actuations as well as i events in the occupational dose, public dose, emergency preparedness, and physical security I comerstones. The purpose of the baseline inspection activities would be to ensure that the risk i significance of events are fully understood, the risk significant issues have been identified, and i that the licensee has taken corrective actions to address root causes. 1 l l 5

Initial reviews of equipment performance (availability, reliability and functional capability) and j personnel actions during the event would be considerations in determining the risk significance of the event. In addition, e detailed inspection of the licensee's post event review can be used to i assess the licensee's r -, ? to identify and correct any adverse conditions and to ensure that the plant systems and co ;.-. ants responded to the transient as designed. Equipment challenged by actual events may reveal operability concems not evident during surveillance testing or routine operations. The inspection activities provide the NRC with an important real time ass

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personnel performance during actual events. This information,, when coImbined%ith other information obtained during routine operations and simulatortraining, rmits'a comprehensive overall assessment of plant and personnel performance. jf' $N'" " A performance indicator for reactor trips is available; h.._N ~ / w ver, it would not provide' .de ' ~ real time information. Licensee response to ongoing evehts provideiinput reghtding tinDjV ^ licensee's process, programs and human perforrnance Arhich would not be availablejordthe performance indicator review. Mye4 Jqs:WA The baseline inspection program allocates inspection resources for this area within the various s comerstones, and allots 28 hours for following up events at each site @However, the limited baseline program resources do not permit following up~all,. events. The allocation of additional resources for reactive inspection of events, in addition to. the baseline gram, would be made on a case-by case-basis by NRC regional management.P dA f f%dL a The scope of the baseline inspection program does)at iricidde NRC followup complex or safety significant events o.rjncidentsqfollowiniup foisignificant operational events would be directed by senior NRC mahagement in accordance with NRC Management directive (MD) 8.3, "NRC incident investigation Proceddres." F M;i 2.5 Plant-Walk Downs e a $ht. bk jk h7bV The baseline inspection program includes s' procedure that is used in conjunction with other inspectable? areas for, routine controlfoom and plant walkdowns of all safety significant plant areas. For exarnple; plant areas that contain equipment included within the scope of the maintenance rule,"aressiw,ith significant radiological hazards and areas with important physical security equipment would tie a review of;conEoficfoml logs [ included iri this inspection inspection activities wo of the fa6!!ty's plan of day moeitirig and management's review of plant deficiencies. g %W The pnmary objective ofihese inspection activities would be to ensure that the inspectors are aviare of current plant and equipment problems and have an appropriate level of understanding of ths risk significancei^ f the proposed or ongoing operations, maintenance and testing activities. o The 16spection activities would focus on identification and understanding of emergent plant issues / potential afluirse trends, current equipment problems and /or ongoing activities and their overallimpiait on plant risk. This activity also allows for an independent assessment of the effectivenessbf the licensee in entering system and component deficiencies into the corrective action program. These aspects of the inspection effort are important because they will be used to aid in the risk informed selection process described in Section 2.3 to modify the scope and depth of inspections in other inspectable areas that support assessment of all comerstone areas. 6

l l l. There are no performance indicators that have been established that can provide results related to safety significance of emerging plant issues or ongoing activities. In addition, performance indicator data would be a lagging indicator and would not include current status of equipment. Therefore, the baseline inspection program includes this activity. The procedure to use in performing this inspection is referred to in Section 5 of this document. Hours have not been allotted specifically for plant walkdowns. The effort has been factored into the allotted times for each affected inspectable area. ,f l 'f r' I ; 8"4 $, ~,

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== y. j 3 PROGRAM PART 2: PROCESS FOR VERIFYING PERFORMANCE INDICATORS d 1 The NRC and industry have established a set of Pls, which relate to the 7 comerstones of safety; initiating events, mitigation systems, barrier integrity, emergency preparedness, occupational 1 exposure, public exposure, and physical security. The NRC will evaluate key attributes of performance within each comerstone such as configuration control, human perforrpance, i l procedure quality, equipment performance, design control, protection against extemal events, i and problem identificaton and resolution, using a combination of Pls anpinspec6on information. 6 As part of the Baseline Inspection Program, the NRC staff w1it hriodic}a ik$d$w y 8 bQW i performance indicator (PI) data to determine its accuracy drid reconcile d' iscrepaMies betweer the Pi indication of performance and actual performancehhe NRC staff willcoicet,and review i licensee plant specific Performance indicators (Pis) as 4stl as theiOjsetive r$w data 16at ftinhed the basis of the Pls. QN if WgaA 4 i To implement this process, licensees will be responsible f$r voluntarily maintaining Pi databases, and reporting to the NRC the P1 data periodically, perhapsluartetty2 Clear definitions, reporting thresholds, database structures, and any ana!ytical models for"eschjj will be established to { produce consistency throughout the industry. Establishment of these standards will be essential j to verify the worth of any licensee performance or risk assessment thatLmay"be inferred by each A i The NRC will develoo a Pi verification inspection process.jlt may tw determined that some j currently proposed Pts may not correlat,e:well wityant performance or risk associated with plant i activities. This discovery will resultjn's modification to thejnspection program to provide an i adequate level of inspection effort necessary for assessrnent. If a specific Pl is determined to no 3 longer provide an indication of performance Within an ares! the PI would no longer be used to reduce inspection effort. In these" instances 7the NRC4ill revert to the normal baseline j inspection pr6 gram to assess l performance *.yAsinep Pis are developed they will also be verified through this same inspec6on process. D 9~ On an a%i k \\ P *%s ~ nnual basisTdata for each P1 will be reviewed by the inspector to determine if (1) operating lexperien6e was entered inth,the database, (2) the data was appropriately characterized, (3) reporting thresholds were in accordance with agreed upon definitions and reporting criterta; and (4) any models used to prescribe action levels, based on a Pl, produce acceptableYesults. The inspector will review any changes that licensees make to their Pl databasiei or the models for'deteImining action levels that may alter PI results. As part of the PI verific'stion, the inspecto not'r'nodified without adeq(will determine whether Pl action thresholds were uate technical review. timate of the to me allocated for this Pl verification per site is provided in the table in Section.9. Note t. hat this also includes time, which will be expended in reviewing the Pl data submitteil for dobijning performance trends. The time projected for reviewing for trends is based up% cig Won 3 hours per quarter per site. 8

. 2. .= - ____.2 =r - r a { i 4 PROGRAM PART 3: PROCESS FOR EVALUATING PROBLEM IDENTIFICATION AND RESOLUTION An effective problem identification and resolution program is the primary means of reducing risk by effectively correcting deficiencies involving human performance, equipment, and programs and procedures. A In general, licensees identify problems (conditions adverse to quality) by three processes:

1) problem reports or condition reports that are initiated by plant personnIel wherittiey observe problems; 2) licensee self-assessments of individual departments (suc6 as sr@ineering, operations, and radiation control); and, 3) quality assurance'sudits. Problems identified by any of these processes are assessed by the licensee, root cause^ safe determidedland horrective actions are implemented under a plant wide corrective al:Li5n prograni?At'some plants department may have its own problem identification andErrective sdion program # ', e h$>S The process for evaluating problem identification and resolutionvili consist of reviewm$P l

g the l licensees' deficiency reporting process, self-assessments',; quality assurance audits, root cause analyses of events, corrective actions, and follow up to corrective actions to validate effective implementation. The NRC will review the licensee's aclWities inthisieriajo verify that: 1) the scope of licensees' identification and resolution programs bounds the key l attributes in the comerstones; 2) root causes of problems and issues have been property determined and corrective actions are timely and effective; an.d.#3) genericLimplications or' extent of condition have been considered. If the NRC review indicates that forany of thikey attributes the licensee has not been identifying and correcting problems, additionalinspectons in that area may be j 1 proposed. AMfif $ gip' / 7 1 The NRC program to review activities'in this ares is composed of two parts. The first part is a review of the associated inspectableirea withi5 each coim^erstone, along with the other applicable inspection areas, as virill be requiied'by the inipection procedure for each comerstone. J The seconchiart is an annualMisw of theloverall problem identification and resolution programs across all comerstonesM; specific procedure will be developed for this part of the program. Resources for the'first part are factored into the hours for inspectable areas in each comerstone; it is expected that th}s part willprovidi most of the inspection findings in this area. Resources for the second pirt are based uporfa twd w%ek team inspection with these inspectors; however, this part should not. tie" repetitive of thfinspection in the first part. V f~ w^ t $' l$hA / .i a as e A & m_b pfyy 9

_ 7, l l 5 INSPECTION PROCEDURES l The concept of operations includes planning for and the actual conduct of baseline inspections. l Tne planning portion is described in more detailin Section 2.3. In summary, it includes a series of planned inspections for a 12 month period. The inspections cover allinspectable areas within a comerstone as listed in Table I in Section 2.1. The activities to review during the inspections l within each inspectable area are selected using the process described in Section 2.3. i f l Baseline inspections will be performed using the procedures listed belovdgThere are certain procedures for each portion of the baseline inspection progragm. The tableW lists the procedures, along with the correlation to the applicable po of thepram;, i a r vo Table 2: Concept for Baseline inspection Procedures g / ;('lx [. t s n'

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( PROGRAM PART PROCEDURE hh UCABLE AREAS MM l s. m l Reviewing inspectable areas in the initiating Reactor Safety events /nftigation s'ystems, and barrier comersiones \\',p~?'A l Emergency ,Re%1ng inspeclaMaroEs in the emergency Preparedness j preparedness comerstone l Radiation Safety [#gf/ RedeMnfMa6fe areas in the inspectable Area oc60pational dciae'Innd public dose Review ,g ,ciifnerstories# l ifdf f 'Reviewin[inspectable areas in the physical l Security ;g L securil/comerstone g EverOc Up [jp Midd' wing emergent events 2 aw we 4Ml%g pggg, u IValking down plant activities and systems in WS w:s

uss, conjunction with reviewing inspectable areas 1

Identificationiandl IdentificaIIoi%% Reviewing the identification and resolution of Resolution ofa. Resolution 6f4roblems problems across comerstones Probleins"% D:% Verifidation of MW Verifying the accuracy and completeness of ed nnance forformance information used in the performance indicators /qindicators Sc within the comerstones pyM J l 60 i t e ( 10 l

l l l 6 INTERFACE WITH OTHER NRC ACTIVITIES 6.1 Allegations The baseline inspection program includes routine followup on allegations received by the NRC. The process for initial review of incoming allegations will continue to follow that described in NRC Management Directive 8.8, " Processing of Allegations". There is no special procedure in the inspection program for this followup. It will be performed as a part of theprocedur6(for inspecting each inspectable area within a comerstone. Followup of the allegatio6%ould occurin the inspectable area to which the allegation substance is most closely $slign $[& 3ML Y 6.2 Performance Assessment Inspection findings will be used, in conjunction with perfonpance i tors, iriless. >=,.. ! es ng licensees' performance within the newly developed assdismentpfocess. The inspectipfddings from the baseline program (and other inspection findings for plan!.s that receive m6re than the baseline program) will be recorded in inspection reports and collected in a document such as the s Plant issues Matrix. A level of risk significance will be detsrmined and documented for the findings. Some risk significance of findings can be infedtiid thfough tidrisk-informed nature of the program. For example, the program has established those riske ignificant areas that will be 's inspected, and it directs the inspector into the more^hsk4significant systems nnd activities. ~ 6.3 Enforcement j Findings identified in the NRC baseline inspection p)ro%2h f gram thatind te the occurrence of a j violation of NRC requirements will be pidcessedIn accordancEwith the NRC Enforcement i Policy, NUREG 1600. e5 / 5 NY l There are two additional areas whaire the baseline inspestion program and processing of enforcement.inctions interfacsdi) The Offics of Enfoicement (OE) and the Office of Nuclear j Reactor Regulation (NRR) coordinate to ens.ure thaf guidance in inspection procedures and the j enforcement policyls consistent and to conduct training of inspectors on changes to the i enforcement policy and handling of inspection findings in accordance with the enforcement policy; and (2)4E performs audits ofinspection reports to ensure consistent disposition of i inspection findin)s iriacdordynce'with the' enforcement policy. Feedback on the results of these audits are provided to NRR and the NRC Regional office from which the inspections were conduct [' '%W# /v G 6.4

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[j i The new program is based on the use of risk insights to select areas to inspect during the yeer. The[5 umber of hourgfo/each area will be allocated from a total number of hours for each cornerstone for the_ year. This is in contrast to the current " core" program concept which has fixed are^as ofirnlsection within procedures. Y%$ mis The propose ~d baseline inspection program will require the development of new inspection procedures, which incorporate the concept of risk insights defined not in the procedure, but in inspectable basis documents. It will also have procedures based on comerstones of safety rather than based on SALP functional areas. Because of these significant changes, additional i training is considered necessary for the inspection staff to successfully implement this program. { 11

. -: ~ - Specifically: Training on the organization and implementation of the baseline program (i.e., use of performance indicators, inspectable areas, planning, etc.); Training on the definition and use of risk insights in the Emergency Preparedness, Security and Radiation Protection inspection programs, and the use of generic and site specific PRA insights for all other inspectors; and h /g Guidance on inspecting selected portions of Emergency Planning l Radiation Protection and Security for resident inspectors. s y,:i, g,dy statedW1 mci 1245 / This training would be in addition to those requirements a r a up

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l 7 RISK INFORMATION MATRICES The Risk information Matrices (RIMS) are tools to be used in determining which activities, systems, or components are to be inspected in the Baseline inspection Program. The matrices are to be used, along with other generic and site specific information, in planning the baseline program at the beginning of each planning cycle to schedule inspections within each inspection area, and during inspections to help guide the inspector h selecting the more risk-significant inspection samples. j# [% The first table (RIM 1 in Appendix lil) includes the frequency,pumber of;activ' /~ i s or components l to inspect, and total hours expected in the baseline program fReach kispectable area. This RIM also describes the basis for these items. The data in RW)jyas derived from risk analysis in IPp l and IPEEE, inspection experience, and history of problems at plants. \\df' The second table (RIM 2 in Appendix lii) is a listing of ris{k-signifi t sma l l t systems based on l reviewing IPEs and IPEEEs for each power reactor plant in the~ United States. %s $?%. jd%%ik$bg. ~ g$ MM /..m:^%

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^ 1 l 8 DEFINITIONS 8.1 Baseline Inspection Pmgram The set of risk-informed inspectable areas that, coincident with performance l indicators, provide sufficient information to assess licenses performance within l comerstones and to detect trends in performance. It is the minimum inspection performed at all operating nuclear power plants. . A./, l 8.2 Comerstone Q TBD fpsh, i 8.3 DeterministicApproach j g Considering a set of challenges to safety nd determini6g l es" should be mitigated. f f 'Vlg'Q g ma d' 4 4 8.4 it,qectable Area hth n Those aspects of the physical plant or theiicensee's programs or processes that need to be verified to assure a desired attribute of a comerstone is achieved or maintained to assure safe operatiorf#' ' ' ed%3 A characteristic of a comerstons_[ hat needs to l 8.5 Key Attribute .v ygjy,N Wy t I assure public health and safety, f ifl / ' y e 8.6 Performance Indicator y ./y A set of data monitored overJI period of e to pron;de a measure oflicensee performance of a key attribu'tswithin a$cimerstone7 8.7 Risked-InformedAppjoa 4f ,dqA philosoph(whereby risk insights are considered together with other factors to establish requirements that better focus)ttention on issues commensurate with their imp %5?likortance to healthgnd. safety. ~ Q??% l 8.8 Validation (ofperformanoejndicetors) Jhe process of substanhating that the performance indicators produce their desired result. 16 Y // \\^? A 8.9 ferification (of p'erformance indicators) i 1 y The processyconfirming the accuracy of data used as the basis for a j performance indicator and the ability of the performance indicator to correlate with ar:tual .p performance. d{? \\ ... e .10E RiskInforme00n Matrix ) i@STM@rrnMie that lists for each inspectable area important activities from a risk t Jpois^ ective, a relative risk ranking for the area, a suggested frequency for inspecting the g p "actMties, and a methodology for selecting risk-informed inspection samples. I l ~ '14 l l

l ^m...--... \\ l l l l 9 PROJECTED RESOURCES Direct resource effort in the form of hours of inspection per year has been projected for each part of the baseline inspection program. These are provided in the table below, which will be used for planning the inspections at each site over a 12 month period. Table 3: Projected Resource Estimates (at each reactor site) yf $h d" \\ Prooram Part 1 insoectionHoutst ear initiating Events Mitigation Systems ~433g$$f j/ e 'WA - a Barrier integrity ypr g[h 'Q I Mgy Emergency Preparedness PiffA f f num Public Dose "NSE, Occupational Dose .J p ? }i} Wig %%9 pr 9 Physical Security f 77 jo Event Followup .-V p 1w x 2 Prooram Part 2 M,.; ms Performance 1ndicator Verificatio% s. M -.3h," a rQgg Mb d5NQ Progam Part 3 %gjagg 'QM$$sht hid3 toblemJdentification%.

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ction Hours 'Y The hou[rs are for a 12 n)onth@thd for the entire site. Exceptions must be al 3MFO % whereVach reactor unit kidifferent type. At these sites there will be additional baseline ins '^ftion hours in the aMasMisted in Part 1 of the table. sp%w5A /s 9:;M ?h khg< 1 Man e$IM D ir$*swee : ~ p Y> x.y+n5m. f 15 l

4 10 PROGRAM FEEDBACK AND ASSESSMENT The baseline program was developed using an approach to select areas to inspect that is different from the existing core inspection program. For example, the new program provides inspectable areas based on a risk informed and performance based comerstone framework. In contrast, the current program provides inspectable areas based on a SALP functional area framework. Because this is a new program and some of the data for hours to inspeo[and frequencyin the new program rely on an estimate, there should be a feedbac(process 6thbdify*the inspectable areas, the frequency and the hours to expend. The effectiveness of the' baseline program will be evaluated on a trial basis for a twelve month period. AftertMiompleti6ri f,thel trial period, the# f baseline program will be evaluated by an expert panel comprised of NRR and regional personnel. Feedback received from the participants in the trial programs would thebanalW improve the caseline inspection program. C%ygqlw.[/ n .g -^f ME. 4 %ba;m J .. am; y%g3E; ik

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A. APPENDIX l.jg ' D:l7dh .Y:&[iA:a M ^ \\d BASIS DOCUMENWFOR l_ ' ne$:$% ^ x n5% INSPECTABLE AREAS >h 4 'Te:. t,:.v.% s/.' g. ,cv .../., k le ' l ?q.o, j, s ., r, :/Mt D [.' b ^;,' '; ,v;;;. A . <:3 l .. ' ". ;t.t :-, -. vg 4 l! ..'*5 jf.T * '

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The following is an alphabetical listing of each inspectable area under the baseline inspection program. Following the list are the basis documents for each area. Inspectable Area Access Authorization...................................................... Eage . 1-1 Acces s Control............................................................ l-3 Access Control to Radiologically Significant Areas................................ 1-4 Adverse Weather Preparations...................................... ....... l-5 ALARA Planning and Controls............................... g ......... l-6 Alert and Notification System Testing......................... M.............. l-7 Changes to License Conditions and Safety Analysis ReportA... M$d.......... 1-8 Drill and Exercise Performance................... Add.... M536......... l.G Emergency Action Level Changes................ g...... M@l [0 .....N @ @g,..... Emergency Response Organization Augmentation Testieg..... ' ;11 Emergent Work..............................$g %g Equipment Alignment......................... Q ............ 7@[MP.1-12 EP Training Program.......................... .. l-13 Event Followup............................. hQh................. Fire Protection.............................. [##d%... Nish............... 1-16 Flood Protection Measures...........................Ihdh Gaseous en:i Liquid Effluent Treatment SystenW;&# Fuel Barrier Performance.................., u =..... ............. l-1 8 w-Heat Exchanger Performance.........gS'M%.... p%.'............. 1 ................. l-2 0 identification and Resolution of Problems /isabes.. $%hg................. 1-21 Inservice inspection Activities.......j7.'..... ...%ME5@.............. Inservice Testing of Pumps and ValvepnSME ion XI $M................... 1-23 .... 1-24 Large Containment isolation Valve GinIRate aris Status Yorification................. 1-25 Maintenance Rule implementatige$g.C....gf...... Licensed Operator Requalificatior '.........................1-26 .... M *.... ............................l-27 Maintenance, Work Prioritization$nd Contrailba....................... 1-Operabilitp Eselustions %$h........ Wk.............................. 28 Off-Normal Psnt OperatiorisW8...... p' ~.T.'.............. ...... 1-2g OperatoiWorl>Messnds..NidNk......................................... 1-30 .................. 1-31 Permanent'Plent Moildcationi%@f..................... Physical Protabilon18ystem....N@................................... Piping System ErosiorWQorrosion.. *T..................................... 1-33 .. 1-34 Post Mainlessnde Teglingh............................ Radialitin Monitoring ins'lise_n%........................ Pre-Job.8defings....WMi ................... l-36 ,ntiiition.......................................... 1-37 Radiation Worker Perforprice.................... ...................... 1-38 Ratli6 active Material Processing and Shipping.......... ................ 1-3 9 Radiological Environtp'erital Monitoring Program (REMP).......................... 1-40 Refueling and Outage Related Activities....................................... 1-41 Response to Contin 0ency Events............................................. l-42 safety System Design and Performance Capability............................... 1-43 Secunty Planifind Procedures.............................................. 1-44 Tec6hicsspecification Surveillance Testing.................................... 1-45 Temporary Plant Modifications............................................... 1-46 l-2

l r i INSPECTABLE AREA Access Authorization (Personnel Screening, Fitness-for duty l l and Behavior Observation) l l 8"P' l This area will verify that the licensee is properly implementing their personnel screening and l fitness-for-duty programs, including granting, denying, and revoking unescorted ess authorization into the protected area, as appropriate. l Basis dA \\ } f l inspection of these areas supports the Physical Protect' comersto TW) l l l ~ s i This is a risk significant area because the personnel screening and fitness-f yuty pro 5 esses { are used to verify personnel reliability and trustworthinWpriorMgranting unesegrted aiicess i to the site protected and vital areas and to assure continued reliability and trustworthiness l thereafter. The establishment of reliability and trustworthiness foipersons granted unescorted. i access to the protected area is a major component ofpfote'etion against the insider threat of l radiological sabotage. The behavioral observation pro 6ess is'used to morlitor the continuation l l of trustworthiness for persons authorized unescorted access andfor' escorted visitors. fju65 R Nf An unauthorized individual with malevolent inteTn dlan individual under the influence of drugs could be granted unescorted access duep6 humangprogram' fad 6r^e. The frequency of this l type of event has been low but the safety significance of this type svent is high. The probability of a single individual causing a radiological release is unknown although the consequences of an individual causing a radiological' release canbe high Tending on the individual's knowledge of plant systems. ,V Historically, licensees have#eNectively im mented the personnel screening and fitness-for-duty pr Q7 I The licensee is required by 0 CFR 73.5_6 to maintain an access authorization program, which ~ includes background investigations and psychological assessments, for granting individuals unescorted access to protected a'nd vital areas with the objective of providing high assuiance l that the individuals'are trustworthy and reliable and do not constitute an unreasonable risk to l public h,estth and saf5ty including the potential to commit radiological sabotage. The licensee is j also required by 10 CFR 26.10,to maintain a fitness-for-duty program that provides reasonable assurance that the workjorog will perform tasks in a reliable and trustworthy manner and that l they are not under the i fluence or impaired from any causes. Both rules require behavioral p observation to detect indications of behavioral problems that could constitute a threat to public lisalth and safety. Mk pperformance Indicator for this area will be based on the number and nature of reportable i analyzeW. Because the data reflects both program successes and failures, additio eveQs.~ (see attached). This data is currently available and there are regulatory requirements to report significant events in the areas of Personnel Screening and Fitness-For-Duty, Performance indicators are establit,hed on the number of events reported to the NRC i Operations Center. Reportable events per calendar year are established at 0-2 events - no inspections; 3-5 events - a baseline inspection and 5 or more events - a reactive inspection. . Some of the Behavior Observation significant events are captured in the FFD reporting l requirements (limited to supervisors and operators). However, a measurable performance l-1

-. -.. - ~ - - - f I l Indicator for the behavior observation portion of the program has not been defined. ( Consequently, a minimum baseline inspection should be conducted of the behavior observation program process and human performance attributes. i 7

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1 INSPECTABLE AREA: Access Control (Search of Personnel, Packages, and Vehicles; identification and Authorization) Scope This area will verify that the licensee has effective access controls and equipment in place designed to detect and prevent the introduction of contraband (firearms, explosives, incendiary devices) into the protected area that could be used to commit radiological sabotage and to assure that only authorized personnel are permitted unescorted access'io the site protected area and vital areas. The identification and Authorization pJocess is)6 assui's that, once personnel have been screened to verify their trustworthiness, those ersons have a need for access and to onfirm that only those persons who havebee~n screene'd and ha've a need aref granted access to the plant including vital areas. The ef uipment inv6fvedis metal' detectors $ l explosive detectors, x-ray machines, biometric sensors',' oomputerst keycardQard keys,'Isrid cardreaders, ~N Q/ l Basis VfA Inspection in this area supports the Physical P,Wtion'[Com% ' ?

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%[ 7;p l The areas to measure are the effectiveness of the search function (persofinel, packages and vehicles) and the identification and Authorization 7The search function is to prevent the introduction of contraband (firearms, explosives, incendiary devices) that could be used to commit radiological sabotage. The search functiorifor detection of firearms, explosivas and incendiary devices on individuals, in,pa'ckages,,or vehicles,yis a'ccomplished by equipment or a hands-on search. The identification and authorization functions are accomplished during issuing of badges or thru the use'of biometrids'or cardrehders. The licensee must also positively control all points personnel and vehicle access into vital areas.

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?/ orized individu(al or the introduction of contraband into th A The frequency of an una or vital areas is low. The consequ'ence of riiK~to radiological sabotage is moderate. %,.' A N.f O. There is no performance indicator for this inspectable area. Meaningful tracking data on the performance of' access control was not practical since much of the performance is dependent on the quality'of theimplernentatiodof the tasks. s),l 6 l-3

l lNSPECTABLE AREA-Access Control to Radiologically Significant Areas Scope This area will verify that the licensee has implemented effective Radiation Protection (RP) l barriers to prevent an uncontrolled access to an airbome, high (HRA) or very high (VHRA) radiation area that could potentially result in an overexposure. An RP barrier includes: identification and control of the hazard; procedures; physical barriers or, engineered' controls (e.g., barrier ropes, locked door, shielding or ventilation system); radiologicaljdnTeys and monitoring (e.g., RP technician coverage, personnel alarmi dosimeter or. remote monitoring / surveillance); and radiation worker training. A $vu A Basis /g;,, Q l Q:'t. t I g ...w m inspection in this area supports the plant facilities attrib e'of _the ccupational l comerstone. n 4@A ft. l This inspection will review the licensee's performance in instituting the physical and administrative controls defined in Subparts G, I and J'of 10 C Part 20, applicable technical specifications (TS), and licensee procedures for airbome areas, andVHRAs and worker .Q M] - p a;j 'y adherence to these controls, Radiological risk (i.e., exposure) to a worker;must be withinoccupational exposure limits I defined in 10 CFR Part 20 and ALARA to ininimizeMe potential folhealth effects. Collectively, the access controls provide a " defense %-deptiflagainst d significant exposure. Industry experience has identified frequent.cocurrences whore the' failure of multiple barriers resulted in j an uncontrolled entry and, in sond cases, a sig'nificant exposure. The established Performano's Inldicator (P!) does n6t a 4 k k rates <1000 nirem/hr. Th6refore{ these areas will be included in the baseline inspection. inciden that would be tracked under this Pilnclude: R %l A singblnonconformarios?Q l O of TS controls or comparable 10 CFR Part 20 requirements applied to all high-radiation areas #(HRAs) having dose rates 21000 mrem /hr. ,fNkA Y A single nonconformance with 10 CFR Part 20 and/or licensee procedural requirements = l . regarding radiatlon protection controls associated with VHRAs. 8 NY k; A single occurrenlce of an uncontro!!ed exposur ? = non-stochastic dr'2% of the stochastic dose limits specified in 10 CFR Part 20.

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INSPECTABLE AREA: Adverse Weather Preparations Scope inspection activities in this area would focus on the effectiveness of the licensee's program for protecting plant equipment from cold weather and other adverse weather related conditions. The inspection focus would be to ensure that risk significant systems and suppo ystems are operated and maintained within the design assumptions and to ensure at the ed instrumentation and actuation related components, such as level tran ers capable of ~ performing their design actuation and control functions. In etion a "this area would also include licensee preparations for high temperature, ' jain, Tor other site specific weather related preparations. .c3 . QM.% %$d Basis i "${g&_. A, Inspection of this item supports the initiation and Mitig comerstones by ensuring that systems and components remain capable of performing'their design functions. In addition, this inspection area would have an affect on the Barrier and Sec~yty comerstones. ~ Y MMS %, The inspection activities are intended to verify that the ticensee has taken the necessary steps to demonstrate that the reliability, availability and functional capability components are maintained during adverse weather, condition,s. Fope,of SSC l xample, operating experience indicates that cold weather corufftions continue to cause intake structure icing, process line freezing, instrument line fre0 ring, erge'rgerEcy diesel t il i it fogging, icing of security perimeterd.eiipctrical pniDiems s'uc problems, essential chiller problems grounds, security camera etection devices andesing or rain related problems with evacuation alarm sirens. g" g M 44 .1 Inadequate freeze protection, controls can d systems adch~as RWST1 velinsirumenta'and have le' to inoperable actuation and contr tion and tiie loss of automatic switch over, in addition to loss a('RWST level in,dication.fFrozen edulpTnent can lead to a common cause/ mode loss of multiple trains andioss of e'ipipmentin redundant systems without any indication of a problem until called upon,"which would have a significant impact on plant risk. In addition, high temperature conditions'can placi plant,elquipment and systems in an unanalyzed condition, which could also have a~ aidnificant impact on risk. Therea[re no perform %$$ ance indicators that have been established that can provide re3ults related to theidequacy of the lioe' nee' 's program for freeze protection or for the adequacy of the e liceIns'ee's preparations icir olher adverse weather conditions. Because extemal events are raire,'the lack of an initiating event due to an external event does not provide assurance that jrotection against such' events is adequate. In addition, due to the rare but possibly risk-mportant nature.a(th'ese events, no performance indicators were judged to be suitable to i i or licensee. performance in this area.

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l l \\ I i INSPECTABLE AREA: ALARA Planning and Controls Scope This area will verify that the licensee maintains occupational exposure ALARA by properly 1 planning and controlling radiologically significant work activities. Controls, as stated here, refer to those physical (e.g., locked doors, barrier ropes, shielding, engineering controls),and l administrative (e.g., surveys, procedures, training, monitoring) barriersg , c(aggregate, at, in th serve to mitigate exposure, I mig Basis 9 2 Inspection in this area supports the program / process a, j ghh ute of theOccupational Dose j'; cornerstone. l This inspection will review whether the licensee meets ll}e requirements of Subpart B to 10 CFR Part 20, which requires that a Radiatiori Protection program,' including procedures and engineering controls, be instituted to maintain occupational dose ALARA. l Y %$P k Radiological risk (i.e., exposure) to a worker be within the occupational' exposure limits defined in 10 CFR Part 20 and ALARA and to minimize the potential for health effects. Effective l ALARA planning will ensure that adequate physical and administratiye controls are in place to mitigate exposure during radiologically significant works industry's experience includes frequent I events where problems in this area have resulted iiuna'nticipated 6xposure or a loss of control of the work activity. Specific attention sh'ould be 'given to Planneif Special Exposures and exposures to Declared Pregnant W6rkers owing to the hi fer risk involved. W hY

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i INSPECTABLE AREA: Alert and Notification System Testing SCOPE-inspection in this area includes a review of testing activities for the Alert and Notification System (ANS) in order to assess licensee performance. /[# BASIS: l P) come[rstone and the Fa h. This inspection area supports the Emergency Preparedness and Equipment key attribute. 3 6 9', X / h1 ' 'N p The ANS is a risk significant system for notifying the public of the need.to take protinctive actions. The licensee generally maintains the ANS and the local [O6vemmental"autho'ritiesfoperate thsV'" l ANS when necessary. Assurance that the system has a high rate'of availabilit/irycreasesWe l l assurance that the licensee can protect public health artd safetijuring an emergencyJff an EP program consistently ensures that the ANS is in a high state of readiness it indicates that the program is operating at or above the threshold of licenseefsafetylpisformance above which the NRC can allow licensees to address weaknesses with.pC o~versight through a risk informed 1 inspection program. Y l h. jdN,$1A \\^ ' i s 7 l A Pl, ANSA, addresses performance in this areif However Jor the statistics of the PI to be valid, the testing program must be conducted in ao66rdsfiT:s with NRC guidance. The inspection l verifies testing program compliance. // >W b e ,/ f [ sA A At(l bb, WA I A se al y ' ~ )/> N' % 3 - A' % ,. $)%, ' )Y y' l

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l lNSPECTABLE AREA: Changes to License Conditions and Safety Analysis Report (10 CFR 50.54 and 10 CFR 50.59) l Scope Inspection activities in this area focus on those changes to the facility and licensee programs performed under the requirements of 10 CFR 50.54 and those changes to the facility, procedures, tests or the Final Safety Analysis Report (FSAR) performecj under thlF requirements of 10 CFR 50.59. The inspection activities include a revjew of thIe licensee's required submittals as specified by 10 CFR 50.54 and 50.59 A more detaile' ieview would be 4 d performed on those changes that have the potential to be ind/or appear to be intent changes. Examples of inspection areas would include safety evaludtioris performed by the licensee for ;/ permanent and temporary facility modifications, procedure changes,'fSA'R nges, / emergency and security plan changes. IQ // "*f ,; p ff yy Basis .%4 Inspection of this area supports the design snd desigr) control attributes of the Mitigating Systems, Barriers, initiating Events, Emergency Planning, and Securiti cornerstones. Ms Y 'h Inspection of this item provides monitoring of the, effectiveness of the. licensee's programs for implementing changes to facility SSCs, procedures, test programs,fSAR and security plans and ensures that the changes were in accordance with the requirements of 10 CFR 50.54 and 10 CFR 50.59. This would provide assurance thatjhe f5cility changes have not reduced the safety margins of the SSCs or reduced the effectiveness of the facility security plans. /W No performance indicators have b[een establis$ed that can provide results r adequacy of the licensee's p%) gram for maliing %f ro chang s~to the facility. 4] +: ,y L' 9 q \\v.:. '. @k gg n, .j -f ,f h 1 4 3 l8

= _. l lNSPECTABLE AREA: Drill and Exercise Performance l SCOPE: l This inspection area includes an evaluation of licensee performance during the conduct of drills, l exercises, appropriate training evolutions and actual events, to verify that the statistics gathered i for the DEP PI represent the actual success rate of performance in risk significant reas. l f i BASIS: A / A/ 4 g This inspection area supports the EP comerstone and theERO Perfor{ nance key attribute. fjQL % } The implementation of the Emergency Plan is dependan/f l l their EP assignments. There are many areas im t on the performance of the ERO l ost l risk significant areas of ERO performance are: %g jp' l 'Q l Timelv and accurate classification of events: including the recognition of events as i potentially exceeding emergency action levelsfEAL's) and any assessment actions i necessary to support the classification.

W% h fu Timelv and accurate notification of offsite covemmental authorities; including adequate

)erformance of notifications as sp ied in lan.

'Y Timelv and accurate develooment and communication of protective action i recommendations to offsite authorities; including p,roviding protective action recommendations (PARS) develop the PARS and any)o governmental authorities, the decision making pro accident assessment'necessary to support PAR A[gf

4jf development.

a m If ERO cons /,istently performs these activitled E$ a tirhely and accurate manner, it indicate the EP program is operating at'or above thithreshold of licensee safety performance above which the'NRC can~ allow licensees to address weaknesses with NRC oversight through a risk informed inspection program.The DEP PJ has been developed to indicate this performance.

f.,

K. ;f' However, the~/ data used to develop the DEP Pi is based on licensee assessment. This inspection area verifies the voracity of licensee self assessment of activities that generate this data y /

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q%. p) . J l i J 1-9

INSPECTABLE AREA: Emergency Action Level Changes SCOPE: Inspection activities in this area includes a review and assessment of changes to the Emergency Action Levels (EALs). BASIS: A This inspection area supports the timergency Preparedness {EP) cornerstone and the Procedure Quality key attribute. $w th,%s / Recognition and subsequent classification of events is a risk significant a because / classification leads to activation of the Emergency Res%~is'not tricompl se Orga'nization a'nd,notificatiogof governmental authorities. However,if the EAL scheme x configuration or with regulations, it will not result in the kxpected emergency classification. b.M '?g, Appendix E to 10 CFR Part 50, states that NRC will approve EALs.? Emergency Preparedness Position (EPPOS) on Emergency Plan and Implementing Prodedure Changes," EPPOS No. 4, provides additional guidance. EAL changes are expected to be submitted for NRC review and approval prior to implementation. This inspectiori area addresses the need to perform this review. 4 V / %W No Pls were established for this area. 9 /'y / J J y 4 s .i w.y 3 s .wd % m~QQ 2 m q[' Q y% /j: A.h., 4%. Tr$ j a h l10

i l INSPECTABLE AREA: Emergency Response Organization Augmentation Testing SCOPE-I Inspection in this area involve reviews of licensee self assessments of Emergency Response l Organization (ERO) augmentation including the design of augmentation tests to ensure they provide assurance that emergency response facilities could have been staffed in 3, timely manner if it had been necessary, the self assessment of test conduct ar)ide d an anafysis of test results. The inspector will also review the ability of self assessments to. and implement the associated corrective actions. gy@d/ LpQm BASIS: rMs l .jf

• )G ;b ss(EP bornerstoneandthAER l

l This inspection area supports the Emergency Prepare l Readiness key attribute. \\g% Eg/

, g The licensee system to augment the on shift staff with ERO members is a risk significant process because the ERO is critical to implementing ti)e' Plan,1ria timely manner. This system involves a notification system for individual ERO members, training of ERO members in its use, and testing to ensure facility activation goals can be met.

%@p &gQ 2: No Pls were established for this area. 7 -9 ' A f Sh, _ f / - :f:f f f f a n'Y \\ .r f - k j a.s i ' 3.g .gg .m mm =-iV ~, , %fl. mn 3 .l R Y{ * 'f - 7; _. }'11-1-11

INSPECTABLE AREA-Emergent Work Scope The inspection activities in this area would focus on the effectiveness of the licensee's controls for the repair of emergent equipment failures that need immediate licensee attention and would not be planned through the licensee's normal 12 week planning schedule. Thesejnspection activities would include a review of related troubleshooting, work planniryg, establish, ment of plant conditions, tagging, conformance with Technical Specifications and restofetion of equipment to service, with an emphasis on verification of plant configdratidn[ Moth during and following the maintenance activity. The inspection activitiesiisould beJimitedio observing and/or reviewing only those potentially higher risk significint' emerge / Basis " hp g &g ;. yt,W 1 ,e m. o l Inspection of this item supports the initiating Events, Mitigation Systems and Secudty cornerstones. In addition, this inspection area would have an affect on the Barrier and Radiological Controls comerstones. / % inspection activities are intended to verify that theAconsee has taken the necessary steps to derr.onstrate that emergent activities are adeguately planned, controlled and documented. This l would include proper control of troubleshooting and maintenance activities so that appropriate post maintenance testing is identified. Tiyis will ens,ure the. continued reliability, availability and functional capability of SSCs and associated components {in addition, emergent failure of equipment can lead to significant risk configurations if other, equipment is currently unavailable because of planned maintenance pitesting. fidper job planning to minimize risk may involve l retuming to service the equipment undergoi planned maintenance prior to working on the failed equipment. g 7 [ A %V w@ Industry experie.nce has that inadequate control of repair activities to equipment during power operation have rdsulted in plant transients, inoperable safety systems, and/or loss of redundan'cy.Lin addition, when the plant is at full power operation, thorough post-maintenance ~ testing by the licensee can be'copie more difficult and may warrant additional NRC attention to l verify equipmerit reliability is not jeopardized due to inadequate or inappropriate testing. l hSKW Y In additionithe inspection activities should ensure that the licensee has appropriately consider 5d the prioritization and timing of repairs and that the repair activities are factored in ) with 6ther previously pla'nned maintenance or surveillance activities such that overall plant risk j isjninimized. l /M l There,are no perforp$nce indicators established that provide results related to the adequacy of N control or emergent maintenance work activities. I flM MP wp l l 1-12 l

l l INSPECTABLE AREA: EP Training Program SCOPE: Inspect training program for adequacy, changes and the knowledge level and qualifications of ERO members. BASIS: hs l This inspection supports the Emergency Preparedness (EP cornerstone and the ERO l Readiness and ERO Performance key attributes. 5 4 >% m

nx

~h Emergency Preparedness is the final barrier in the " defense in dep for ensuring the public health and safety. The training program mu,th" NRCiegulati l members are adequately prepared to perform their assigned EP, duties. The ER st ensure'that ERO rs l V must be qualified to perform their assigned duties. ih s

ab,

{ Two PI's, DEP and ERO, address this area and therefor'e a bas $line inspection is not j l required. V u ',3 x,} j

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l l INSPECTABLE AREA: Equipment Alignment Scope i Inspection activities in this area focus on the effectiveness of the licensee's program for i changing the alignment of plant equipment (configuration control) based on procedural and/or operational needs or for clearance control in returning or removing equipment to/from service for activities such as maintenance, modification or testing. The inspectipn focusfo^uld be to ensure that systems and components are appropriately returned to service byissessing the effectiveness of the licensee's programs for independent verification locked ' valve verification, y switching and tagging clearances and system lineups. The' inspection, activities would be more addition, much of the inspection focus would be to review the licensee ide'ntifi area and to verify that adequate corrective actions are jmplemente'd.' M/ Q/ ] Basis 34 Inspection of this area supports the Initiating Events, Mitigation Syst' ems and Barrier Integrity Cornerstones. V N, f%.. The inspection activities are intended to verify that the licensee has an effective process for maintaining system configuration control, which ensures that the functional capability of the plant system is maintained. Systems and components that are not properly configured may not be capable of performing their intended function ivhich'resultsin a loss of availability and functional capability. // J l M Systems or components that are not p'roperl aligned can lead to the initiation of events, can result in personnel injuries, and can significantly impact the availability and functional capability of plant equipment, which would/could significantly~ increase the overall risk to the plant. It is understood that inspection activities will have minimal impact on reducing the frequency of initiating ~ events.' However; a revidw and documentation of those events does provide valuable assessment _information and is an indicator for similar problems within the Mitigation and Barrier cornerstones.sinspection activiti.es would normally be expended following emergent work activities, following risk significant system realignments, or during outage related activities. A perfor.mance indicator for\\ g% V the unavailability of three systems has been identified. However, unavailability time could/would include unavailability for testing, preventive maintenance, predictive maintenance,' corrective maintenance in addition to loss of configuration control. TI) refore, the unavailability' performance indicator would not be a clear link to the licensee's program or performanc's related to the control of plant configuration, making it necessary and reasonable to perform inspection activities in this area. In addition, iicensees often distribute the configuration problems into multiple site specific performance indicators, such as inadequate procedure, failure to follow procedure, human performance, or "other", and in some c'ases the errors in the field are not documented. l-14

l lNSPECTAtiLE AREA: Event Followup l Scope l Inspections activities in this area would focus on automatic or unanticipated manual reactor trips, significant safety system actuations, and significant plant events, including those in areas such as radiation control, security or emergency preparedness, inspection activities in this area would include initial observations of plant and equipment status following trips orMetuations and l the initial evaluation of significant plant events. In addition, inspection fctlyities'would include a l detailed review of the licensee's post reactor trip review / evaluation. The inte6t'of the inspection activities would be to ensure that the risk significance of thieivent isiully understood, the risk significant issues have been identified and that the licenske fias taken'the appropriate corrective actions. [f Mg / a . m ~49 ; QNj k jF Basis W * :,,h This review would verify the actual impact on the Initiation and Mitigation cornerstones. In adcition, based on a significant issue or event, this inspection area sould have an affect on the Security and Radiological Controls cornerstones. V

QK gg Wi$

] Initial review and follow up of significant event,s would be performe to verify that equipment functioned as designed, that personnel actions were appropriate and lo' determine the risk ~ significance of the event. The inspection,a'tivities dould verify the availability, reliability and c functional capability of risk significant SSCs during) actual plant events. The inspection would also be used to identify human performance issues)and t6 ensure appropriate corrective actions were implemented. M / Y lyf l# The inspection activities provide'the NRC with a real time assessment of plant and personnel performance for major event's a~nd /or issues. This~information is needed for the NRC to appropriateiy address theIrisk sig'nificancdof the. event and/or issue and to evaluate the need to expend additional reactive inspection resoulces. Yh b% in addition, the detailed review of the licensee's post trip review can be used to assess the licensee's abilitito identify and c'orrect ady adverse conditions and to ensure that the plant systems and components respond 5d to the transient as designed. Equipment challenged by actual eyeht5 may lehd to operability concerns not discovered by surveillance testing. In the past, this"has been fouhd to be very risk significant, for example; with the failure on two occasidns of both reactdr trip breakers to trip on automatic actuation from the plant's reactor protection system which%as'not initially identified by the licensee. M M A performance indicator for reactor trips is available, however; it would not provide the desired {eal tirine information." Licensee response to ongoing events provides input regarding the licensee's'processiprograms and human performance which would not be available from the performance indicator review. v l 1-15

i i i l INSPECTABLE AREA: Fire Protection Scope The inspection includes a review of ignition sources, control of combustible materials, and fire protection systems and equipment. Fire brigade staffing, training and performance as well as equipment necessary for plant shutdown following a fire such as emergency light', Appendix R diesel generators (when applicable) and remote shutdown equipmen would -be included as part of the inspection activities. ~. Bh h Basis

1. f$$6

/ MMb inspection of this item supports both the initiating Events / Mitigation ste 'and Barrier comerstones. 1. p j The inspection would review licensee controls designed to. minimize the probabilit)rof ~a fire and s would also review the availability and reliability of equipment necessary to mitigate the effects of i [ 1% a fire. i W3f6 Proper implementation of the fire protection program is important to pN:) defense-in-depth against fires by maximizing prevention, detection [suppr asion, and mitipat' ion capabilities for fires. An effective program reduces the risk of a fire being iinn.initiatin0' event. Also, in the event of a fire, reliable detection, suppression and mitigation capabilities s'nsure the plant can be ~ l safely shut down without challenging an/Bf the bafriers'(fuel llreacfor coolant system, or containment). Plant specific evaluations'have shown interpal fires to be high contributors to risk at some plants due to the potential for damagirigiredundant systems and multiple control circuits and due to the adverse effect'6n operator mitigat'dn strategies. i W h$ N There are no performance Mdicators that aseess performance in the area of fire protection. Mi$%m

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l i INSPECTABLE AREA: Flood Protection Measures Scope l Inspection activities in this area focus on licensee's program to protect the plant from potential { flooding. These inspection activities would include verification that compensatory measures are documented, equipment is available and staged, and equipment is routinely tested and remains i fully capable to perform the intended functions. These activities would 12e perfoJa$ed' at those facilities that have the potential for extemal flooding and would also include, pt see facilities with intemal flooding concems. @[nM e i$ l j/jd l $h Basis This activity would be an input to the initiation and Mitigation co ';fones. % g. naddition,. inspection area would have an affect on the Barrier, Security anil' Radiological bontrols7 comerstones. ' W! V d'$ Verification of the licensee's implementation of the flood co'ntrol program would be performed to insure that the facility is capable of withstanding poteritlal internal and external flooding without undue risk to the safe operation and shutdown of the plant. Flodding'would have a significant adverse affect on the functional capability of s,afe,ty and risk related uipment needed to maintain the plant in a safe shutdown condition.' ' R4 [ IE Flooding has been shown to be a significant contr tor to risk at some facilities, in addition, flooding has the potential to make multi ~ple trains'of equiprhent siid support equipment inoperable which would result in a significant inifease in dsk to the plant. Flooding also hris a significant consequence of preventing ^or limit ln'g operatoEmitigation and recovery actions. W lN& .e8l There are no performance jridiostors that have bee,n established that can provide results related to the adeq' acy,of the ljcirisee'iprogram}6f flooding events, no performan u the rare but possibly risk'significant nature judged to'be suitable for monitoring licensee performance in this area. ' gy sqq s y%y ', ki h ,,vjgy 9 .M] g k 1 e s e r,

qyy i

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l \\ l i INSPECTABLE AREA: Fuel Barrier Performance Scope Inspection includes verification of operation of the licensee's capability and performance of in-plant radio-chemical analyses of the reactor coolant system (RCS). Basis / Inspection of this item supports the cladding performance attribute of<thelBarrier comerstone. h.) % ' l%. Inspection of fuel cladding radio-chemistry analysis performance will provide assurance that the fi,st barrier against release of radioactivity to the envir 'm'ent is maintain 5d.c Failure of fuel [/ cladding would increase the radiation dose to workers potentially to members of the~ lic. h%8 The fuel cladding integrity is maintained by controlling reacter operation within the established operationallimits. Routine sampling and radio-chemical' analysis ~of reactor coolant will detect workers from increased dose due to fuel failures and fo [preve'nt. release o any fuel cladding failures. Appropriate plant procedures ah'd rneasures for protecting plant environment should be implemented. 3 y p:9p m; 4 ..s .m mf A performance indicator is provided for RCS-ivity.LThis inspectable area could be deleted, if the performance indicator for this area is acceptable'and the indicato'r is verified. / %;h/ f p i j[ .s y ,.xWR a' f fiu w vi: K{)Q uf}}% .s fx as y_g n-

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ci l-18

INSPECTABLE AREA Gaseous and Liquid Effluent Treatment Systems Scope This area will verify that gaseous and liquid radioactive effluent treatment systems are maintained such that radiological releases are properly mitigated, monitored and assessed. The focus is to ensure that releases are reasonably controlled, that system modifications are properly performed, and that effluent and meteorological monitors are a,ccurate a6d' reliable. Other aspects of system operation (including administrative controls) Ibe asiessed by reviewing licensee assessments, the Annual Environmental Monitori RepcIrt'and the Annual Effluent Release Report. f} Basis },' 5; ,R } . M9 % inspection in this area supports the plant facilities / equipment andinstrumentationg i program / process attributes of the Public Dose cornerstone;. g hJh This inspection will verify that gaseous and liquid effluent processing systems are maintained as required by General Design Criteria 60,63 and 64'of Appe'ndix A to 10 CFR Part 50, Radiological Effluent Technical Specifications (&j) and the Offsite Dose RETS (ODCM). d., fy%5 ' *% Radiological risk (i.e., exposure) to the publici below the;10 CFR P 20 and 40 CFR Part 190 limits and ALARA to minimize the potential for health effects.'l Doses below the design objectives of Appendix I to 10 CFR Fjart 50 are considered ALARA by the NRC. Proper operation of the effluent treatment. system and, monitors vdll ensure an adequate " defense in-depth" against an unmonitored, unanticipated (kease of' radioactivity to the environment. Overall industry pedormance hah irhproved, but concein~s still exist with abnormal releases, system modifications, and,m^onitor operability.1 }Y$ f> g% W Although a Performance indicator (PI) was established for this area, it does not address abnormal' releases," system' modifications, and meteorological and effluent monitors. Incidents that will be tfacked 'as a Pi include'ariy effluent release not in accordance with 10 CFR Part 20, Appendix ! to 1D CFR Part 50, ODCMparid RETS. \\y Q f k /e jV .a

, v /

1-19

I j INSPECTABLE AREA: Heat Exchanger Performance Scope l l The inspection includes a review of the performance monitoring, maintenance and testing activities designed to ensure heat exchanger operability. This inspectable area will be included i as a sub-part of the engineering plant modification inspection activity, inspection activities would be limited to observations of the licensee's heat exchanger foulin inspectioris and a review of heat exchanger performance data for the more risk significa system'sf l , C %<j/ l Basis f YM ww Q GRM. / Inspection in this area supports the Mitigation Systems 'merstone by ensuring .the h / exchangers' performance remains adequate to suppor 6 function $7 Industry experience has shown that many plants have experienced significant problems with degraded performance of heat exchangers' due to problems that include corrosion, sitting and fouling. Resultant reduction in flow rates and heat transfer' capabilities may result in a loss of redundancy of safety systems or a loss of the safety function due to a common mode failure of multiple safety trains. Since the subject heat exchangers never/ rarely seeldesign basis heat loads, it is important for the licensee to routinelyfmonitor the performance of the heat l exchangers to ensure that the heat exchangers are capable ~ of meeting ~their design ll '*4******* There are no specific performance indicators estab ished that can provide results related to the t l adequacy of heat exchanger perforinarice, f . !/ $f bi x-Q 2R h l 8% W&jh }[ % 4 /y hly %) Y Y( l 4 i i l 20

l l INSPECTABLE AREA: Identification and Resolution of Problems / Issues Scope l This item will verify that the licensee has an effective problem identification and resolution program. Problem identification and resolution refers to: (1) the deficiency reporting process; (2) licensee self assessments; and (3) Quality Assurance audits. Additionally, in some plants each department may have its own problem identification and resolutior progra the inspection is on the licensee's effectiveness in identifying, resolving;and pre venting risk significant problems. ,W [&. Q f. k OR / Basis A, M,, f,,< Inspection in this area supports all seven of the cornerptones, j ?% / y LW The objective of this inspection is to ensure that the lic{nsee effectively assesses e in the key attributes of each cornerstone to correct declihing performance prior to having significant events. An effective problem identification and resolution, program is the primary means of reducing risk by correcting deficiencies involving people (i.e., training,' knowledge and skills), processes (i.e., procedures and programs), and equipment,d safety of workers or th'e public. I (i.e.r design and maintenance) before they manifest in a significant event affecting the health an experience indicates that licensees having an effective $rogram for' identifying and resolving uency of evenhi. V problems also have a reduced freq/& // There are no Performance Indicators (Pis) that have been/ established for this item. However, some insight may be obtained from the Plo' developed for each comerstone which may reduce the overall inspection effort in this~ area. I "" W The insp/ % [ A & j? ector shay select a set of outputs from a selected program for review. For each cornerstone of interest, a sample set comprising licensee assessments and deficiency reports will be selecied for review. The selection will be made using information contained in the Risk Information Matrik (RIMf and ins'ights gained from site-specific PRA results, industry experience and NRC inspsetionfindings. V f7" Y h For selected programs, additionalissues may be identified by periodic observations of specific actlylties such as operator simulator training, or emergency preparedness, security and fire Protection drills and exe'rcise's. Some issues may also be identified by reviewing operating esperience information,' engineering and maintenance work request data bases, operator work around lists and thejlon-conformance report data base. Collectively, these issues shall also be reviewed for inclusion in the sample set. y .yy When reviewinh the sample set, consider whether individuals involved in the problem identification and resolution process offectively identify, resolve and correct risk-significant problems. Additionally determine if risk insights were used to allocate licensee resources for investigating and correcting identified deficiencies. The inspection should verify that: (1) the assessments were of sufficient scope to address the key attributes of the cornerstone; (2) the risk significance of the findings was properly assessed; (3) root cause analyses and corrective actions were timely and adequate to prevent 1 21

recurrence; (4) industry and NRC generic issues were considered; (5) required reports to the Commission or input to a PI were made; and (6) the performance trend indicated by the sample set was consister.t with the applicable Pls. Periodically during the inspection, discuss with the residents (or other inspection team members if applicable) to identify common issues that cross other cornerstones. For example, procedural adherence problems in the Occupational Dose, initiating Events and Barrier Corne.rstones. Review the common finding as stated above and determine if the licensee was anale of the common issues. / Additional sampling of the licensee's performance assessmerit feedback loopis required if: (1) recurrent issues or highly risk significant findings were id ntifi5d; (2) actions were not taken in response to a declining trend or performanc,a'deq or (3) the NRC or licensee assessment results indicate risk significarit findings'that should rnve' been manifested in a negative P1 trend. / / An observed discrepance between Pl data and NRC or icensee findings is indication that additional review of PRA assumptions, re-verification of applicable Pts and an assessment of changing risk may be required. V yik lf tAs hf ;r %ww A

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INSPECTABLE AREA: Inservice inspection Activities Scope Inspection activities in the area would focus on the effectiveness of the licensee's program for controlling inservice inspection, repair, and replacement of ASME Class 1,2, and 3 pressure retaining components. Inspection activities would include a review of the results oJthe licensee's steam generator tube inspections, a selected review of risk significantoon-code repairs, and at a minimum a review or observation of the reactor vessellSI exa'minations at the facility year interval. qW Basis L;$$h j f %k / Inspection activities in this area support the Barrier corper, stone.)n addition, inepecini? area would have an affect on the Initiation and Mitigation systems comerstones.Q/ \\p A The inspection activities are intended to ensure that the licensee has an effective program for monitoring degradation of steam generator tubes, controiting non-code repairs to ASME components, and performing the required periodic 10' year ISi' examinations, all of which relate to the continued reliability of the risk significant systems and components,lj> Degradation of the reactor coolant system, steam generator tubes,$7 gy A orsafety related and/or support systems would result in a significarit increas' ir risk. Degra"ded piping or tubes would e jeopardize the integrity of barrier systerps and would inc(rease the risk impact due to initiatio events in addition,it would result in mitigation sys'tems npt beirig capable of performing thek intended design functions. Based.on these considerations,# nspection activities are necessary i to ensure that the licensee has arieffe'etive JSI'progran)to' ensure that risk significant ASME Class 1,2 or 3 piping system de' gradation isidentified arid is promptly and appropriately vAj , ) < %g j%7 corrected. 4 There ar/ % M9 e no performance indicators that ave been established that can provide results related to the adequacy of the licensee's program for ensuring system integrity in accordance with E mqdregents i{ A y e f W M g y. ps ~ W 1-23

INSPECTABLE AREA: Inservice Testing of Pumps and Valves-ASME Section XI SCOPE Inspection activities in this area would be focused en the effectiveness of the licensee's program for testing of pumps and valves as required by ASME Section XI. Inspection activities in this area would include a review of equipment trend results and observations of selected pump performance testing, valve stroke time testing, relief valve setpoirjt testing,4n'd check valve testing. Test failures would be captured for review under the corrective 4ction program inspection activities. Mf ap Q INSPECTION BASIS 7 J % ;%, Inspection activities in this area would provide input to thi Initiating l Mitig\\;( figation an M / cornerstones. ( // / \\. Inspection of this area would be performed to verify that the regulred testing is being performed as required and that plant equipment is functioning as, designed. ' Inspection activities in this area are intended to verify the effectiveness of the liebnsee's program for festing of pumps and valves. Section XI testing program was specificallydesigned to de,monsthie the reliability of components and to identify degrading compor)ents prior to actual failure.'The trending of the Section XI test data is necessary to identify, degradation of components'so that the licensee can initiate prompt corrective actions before the degradation causes a loss of functional capability. This ensures that equipment will be available and fiaive adequatefunctional capability if called upon to mitigate the consequences offri acciden't.' The ASME Section XI pump and valve' testing // j/ p equiprnent will function as designed. Degraded equipm,provides assurance that plan program ent, even on less significant systems can collectively have a significant impact on overall' plant risk. [% h Qf There are no performan{ce indicators that have'been established that can prov to the adequacy of the Section XI testing activities. Therefore, the Baseline inspection program includes inspection of this inspectable it.erp. [>..., % N,,, Q. f .3% y 7s .] Rr %A;y,f a, A l / l Sf i I l l-24

INSPECTABLE AREA: Large Containment isolation Valve Leak Rate and Status Verification Scope Inspection activities m Inis area would be focused on the adequacy of the licensee's testing program for large cort ainment isolation valves that provide a direct flow path from the containment atmosphere to outside containment. At most facilities the ipspection'acope would be limited to the containment purge and ventilation valves and personr)disccesis hatches. Inspection activities related to leak rate testing for most of tg contaliynes inolation valves and/or containment integrity issues would be captured by corre action program inspection activities. %g% Sasis 5 N e. ,9 v Inspection in this area supports the Barrier comerstone The inspection activities are intended to verify that the licenses has ar(acceptable process for insuring that major containment isolation valves will fu'nction aidesigned in preventing the is release of contamination following a design basis accident. g(g The normal containment ventilation isolation v[alves tend to be very la N$k seats. Industry experience has shown that the seats tapto dry out'over long periods and fail to maintain their leakage integrity. Pressurized wat6r reactor containment purge valves are routinely opened during plant operation'to purge the contalnment or to allow reductions in containment pressure. The constant cycling results in degradation of the valve seats. In both cases inspection efforts would be focused orlinsuring that the valves continue to meet the design leakage requirements an' that theFMY' ' tenanossnd testing efforts d A dlY There is a performancejndicator for total leakage from all containment penetrations. However; the limited inspection activities detailed in tiiisinspectable area would still be necessary due to the failure'mechaniem, of th'elarge containment ventilation isolation valves and the failure of the personnel access hatches and containment purge isolation valves caused by routine cycling during power operation.1, Y R? y% w. k [ p.t k; -} s h j w e

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1 1 25 1 l

INSPECTABLE AREA: Licensed Operator Requalification J Scope Inspection activities in this area would focus on the effectiveness of the licensee's program for conducting operator requalification training, inspection activities would include a review of requalification examinations, administration of requalification examinations, the training feedback system and the remedial training program. In addition, inspection activlMs would i verify that'.he facility's operating history has been factored into the re dalification' program and

1. ft@'

would verify conformance with operator license conditions.. ypq f Basis / %!b% { $h Y inspection of this area supports the initiation, Mitigatiort,'and Barrior/'comerston J k.? k Operator performance provides a vital link in mitigating (the consequences o unforseen equipment performance. Degraded operator performance results in increased risk due to its impact on the human factors terms, assumed'op'5rator recovery rates and personnel ^ induced common cause error rates assumed in the facility IPEsJ Humsn performance errors and failure to recover from accident events are the most risk important events at a facility. k %!$F' There are no performance indicators that hav[e been, established tha,t c ,m to the adequacy of'the licensee's licensed operator equalification program. yf a , 4, / ? (*Q M M y E g ji 9 0p ,4 eq% wy p g D ~ ,pa v s ./ La[ p}i 7 h(i j/ <[39' l i a l l-26

INSPECTABLE AREA: Maintenance Rule implementation Scope The inspection includes a review of goal setting, performance monitoring, repetitive failure determinations, and evaluations of functional failures and maintenance preventable functional failures. The scope of the inspection activities would include those systems covered under the maintenance rule which would also include a review of the licensee's im lementation of the maintenance rule requirements for those systems. / Basis M mA ~;A -r Inspection of this item supports the initiating event, miti hon systemib bani fintegrity, cornerstones by assessing the effectiveness of the lice'gnsee pro rim ~in ensdring availabili reliability of plant equipment. bg

h Proper implementation of the maintenance rule is important to ensure reliable operation of plant equipment within the scope of the rule. The progrim'should ensure that there is a proper balance that optimizes availability and reliability when'reimovirigguiptrient from service for preventive maintenance. High availability and reliability result in a high probability that accident mitigation systems will perform successfully w, hen neede"d and that barriers will remain effective in preventing the release of radioactivity, y

p This inspection area supplements the safety system a !! ability performance indicator. In addition, inspection activities in this are'a'would pfovide an! asses'sment of equipment reliability where a performance indicator doed'not exist /[ f jf h Y d - % 47 .M > J R4 ~ a t-g ,4g 't ./ ~ ?.Q [k w;j^%9 h A 9% %mA / r 5, N ..,,Y x,4 w,M l l l-27 i l

i 4 INSPECTABLE AREA: Maintenance Work Prioritization and Control Scope Inspection activities in this area would focus on the effectiveness of the licensee's programs for work prioritization and control during shutdown and power operations. Licensee work i prioritization methodologies, work backlog trends, level of maintenance support, and assessments of integrated risk of the work backlog would be reviewed by the i ~. or 4 Basis %=k N j This inspection item primarily supports the Mitigation Comerstone, although the initiating a Events and Barriers Comerstones may also be effectedV ~D / w%... M e effects of componentp) n Maintenance is the primary means of mitigating and m{anaging x degradation and failures. Operating experience shows'that the' lack of maintenanc' e" (component deficiencies not corrected) or improperly performed maintenance (maintenance activities not well controlled) can greatly contribute to the risk for event _ initiation, and may cause SSCs to not function properly if called upon to mitigats ' he consequence of an event. t Operating experience shows that for risk significant events identified through the Accident Sequence Precursor (ASP) program, work control'or failure to maintain equipment represent the majority of causes. Appropriate identificationsp'rioritization, plarining, scheduling, and completion of work that is the most risk significant is essential to safe operation. There are several established Performa/f f ^ Vf nce indicators (Pl ),that indirectly infer the quality of work prioritization and control to reduce ~ inspection effort this area. However, events that have reached the ASP threshold (E-06)' tended to be random and were not predicted through existing w m}y/ { , a{ fjQ Dis. ,A 'h {CP'- p Aq iA. A .g 3 r b' a ) ' alO.W Q 5fmf \\ :.g .sl .i I g g[ j Y gg/ l-28

1 l INSPECTABLE AREA: Off-Normal Plant Operations l Scope The inspection activities will be used to evaluate operator and equipment performance for other l than normal / routine operations. This inspection activity will provide a vital tie between operator performance observed under simulated conditions and those obsented during non, routine plant operations. This activity will also provide a snapshot of plant and equippent perft$mance during transient conditions. Inspection activities will be limited to observationstf plant shutdowns, selected portions of plant startup activities, and, selected,down'pimer evolutions related to equipment testing or repair. In addition to providing observations.of non-routine plant operations, observations in this area provide increased oiportunities tiobserv non-simulated transient conditions. hi M/MlW W,, Basis ? %g% 4 This inspection primarily supports the Mitigating Syste,ms comerstone by providing assessment l of operator performance during transient and off-normal operations.) Poor, operator performance could also affect the Initiating Events and Barrier Integrity comerstones. Operator performance provides a vital link in mitigating the consequ%j/ QL _ % 1 ences of improper or l unforseen equipment performance. Degrading operator performance results in increased risk l due to its impact on human factors terms,' assumed operator recovery rates, and personnel induced common cause errors. Probabilistic risk'a'ssessrTients tiave shown that human errors l can be very significant contributorsio risk, in particular duhng recovery from accident events. Operator performance under abn[ormal plant operating // ?Y /d l conditions cannot be sufficiently covered I l by a performance indicatort(pdf MV

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INSPECTABLE AREA: Operability Evaluations Scope inspection activities in this area would focus on the effectiveness of the licensee's program for the evaluation of degraded and non-conforming conditions affecting plant systems, structures and components (SSCs). Inspection activities would be limited to a review of those.potentially risk significant degraded and non-conforming conditions affecting SSCsythat aredensidered to be operable and fully capable of performing their design functions based on wdttsn operability evaluations. Initial reviews of the operability evaluations should be performoffiollowing formal completion of the evaluations by the licensee. O M! Basis lg b Dhih inspection of this item primarily supports the mitigating and barde,r systems by ensuringYisk-significant SSCs are fully functional to perform their deilign function. In addition, thisinspection area would have an affect on the Initiating Events, Physical Protsetion and Occupational Dose comerstones. 3 The inspection activities are intended to verify that the licensee has_taken the necessary steps to demonstrate that the reliability, availability and functional, capability of th'e SSCs and associated components are maintained although the SSCs'are degrabeiid and/or non-conforming in some way. 7 j As a result of the size and complexity of a nuclear power plant,' egraded and non-conforming conditions are frequently identified at all plants.* frisk-significant SSCs are often affected and the degraded or non conforming condition cannot always the corrected immediately. An improperly evaluated degraded and/or non/ conforming c'ondition may result in continued operation with a SSC that is'not ciapable of performing its design function which would result in operation of ttie plant outilde of its design'and licen'se bases. The potential effects on safe operatiodcould include tbs loiss~of redundancy"within a safety system, the loss of safety function o'r a reduction in th'e' safety' margin assumed in the plant design and analyses. Y% %dM% The inspection would ensure that the evaluations include an adequate technical justification to support the Mrabil evaldation a'nd would verify the implementation of any compensatory measuresV MA ) There// Mkf are no performance Indicators that provide effective assessment of the quality of o 'rability evaluations. hQ{ 3 el\\ i Qs%L s - 9:qg y a 1 30

INSPECTABLE AREA: Operator Work-Arounds l I Scope inspection activities in this area would focus on plant and control room deficiencies that have the potential to affect operator performance in conducting routine and non-routine evolutions or 1 the potential to affect equipment performance during non-routine evolutions or transients. l Detailed inspection activities would be limited to those risk significant deficiencies'itiat could compromise equipment and personnel mitigation strategies. A more detailedNview would be l conducted on those items / issues where operator performance during franeio6t'or mitigation l evolutions would be affected. This would include those defibianciesihat would require operator l actions for the SSCs to meet their design functions. p%% ~p WM Basis Mk. a new e .n. %,r v.:?:% Inspection of this area supports the initiating event and' mitigating system cornerstones. In addition, this inspection area would have an affect on the Serrier,' Emergency Preparedness, l Occupational Dose, Public Dose, and Physical Protectio 6 iiornerstones. r V ygg Operational work-arounds can have an adverse effect on the functional' capability of a system to perform its design function in that the system ina' not be capabie pe'rforming its design y D/ h ]%k[Q function without operator intervention. j f Operator work-arounds imply that a system or cornponent is not functioning as designed and that special operator intervention or usebf other compone'nts would be necessary to complete a ~ required task. Too many operator (ork!aroundibr work-a' ounds requiring complex operator actions reduce the effectiveness,o)f thioperations staff irjlresponding to transient cond r and willincrease the chance of rator errors, PRAs have identified human errors as significant contributors to rieIcJ hpM[ s that hav$j@been established that can provide Ah 44M There are no performance e to the adequacyilthe licen'see's process for controlling operator work arounds. Performance indicators may be able to iden'tify the number of operator work arounds and length of time in around item.4[ttiey will'not be able to iridicate the significance of any one operator w I place, however vuHdg V [ hkh mv l f^ V m ,mA.w ,f cy~y v p . ?" l e = n. p - l l 31 - - - - ~.. _. _,

=--. t INSPECTABLE AREA: Permanent Plant Modifications Scope l Inspection activities in this area includes the review of design, installation, configuration control, I and post modification testing for the potentially risk significant permanent modifications of the SSCs covered by the maintenance rule. Inspection activities would also include an in-depth review of changes to the initial licensed design and/or design basis documents... ~ h inspection Basis f@Q at: d% Inspection of this area supports the design and design control attribute's of theiVlitigating 3 Systems, Barriers, and initiating Events cornerstones. h addition this" inspection area wo have an affect on the Occupational Dose, Public Dose,/and Physid,a! Protection g

b. A,,./7 D4..M comerstones.

%( \\ ^ Inspection of permanent plant modifications provides mdnitoring of the licensee's performance to ensure that the design bases for risk-significant sys,tems,' structures, and components (SSCs) have been maintained and that the changes have not adversely affected the licensing and design bases and safety functions of the SSCs.- Plant modifications may introduce changes to the assumptions and models used in'the plant specific PRA.4 Modifications to one system may affect the design bases and functioning of other interfacing systems. Also, similar modifications to several systems could introduce p[otential for common cau plant risk. - yf + i P Industry experience has shown that m ifications to risk-significant SSCs can adversely affect their availability, reliability or functional. capability. The baseline inspection of permanent modifications should focus on: (1) compliance with reg 0lations, (2) consistency with defense-in- ~ depth philosophy, (3) mainta'inirig sufficient safety rhargins, and (4) acceptability of the effects ~ on risk. /, Q/ Verification of post-modification testing to confirm that the objectives of the modification are met and verification that the. system is restored to the required configuration after completion of the modification are important., Design requirements that cannot be verified by testing of the modification, such as seismic or enWronmental qualifications should also be reviewed. g N A No performance indicators have been established that can provide results related to the ade,quscy of permanent [ mod,ifications. Therefore, the baseline Inspection program includes inspection of this inspectable area. y ,Q7 + +, l s 1 I 1-32

INSPECTABLE AREA: Physical Protection System (Barriers, intrusion Detection System, and Alarm Assessment) Scope i Verify that the licensee has an effective physical protection system in place c,pable of providing high assurance that the facility is protected against the external threat of radiological sabotage. The system includes protected and vital area barriers, associated intrus'on detection systems, and alarm assessment capabilities. Basis .f) [;k Inspection of this area supports the Physical Protection-erstone;[ f ig'g gf a This is a risk significant system that is necessary for protection against the exthmal threat of radiological sabotage. Operability of the protected area intnJsion detection syster'n an'd of the vital area intrusion detection system is necessary to ideritify and initiate response to security events. The system is the first linc of defense in the " defense,in depth", concept of protection against radiological sabotage. The risk significance is based on an exploitable vulnerability by a person (s) with the intent and capability of committing radiological sabotage. The frequency of occurrence of this type event has been low. HoWever, the consequences'of such an event lW ' i *.h V would be moderate to high. (Q [:y% The performance indicator for this area)s that ea, of these syster'ns are available and capable of performing their intended functions 5% of the time. This indicator is considered adequate to assess performance and no additionalinspectiori of this aina is necessary. /W' V i f trl ',k@ R M y - M{ ~ y ~ Q ' [qh y .1 m,;;y -Q ? m,.- a..,: 7 r i ~ 9O \\ l +k g 'N y';gy d 4 l 33

l l ) { l iNSPECTABLE AREA: Piping System Erosion / Corrosion Scope The inspection activities in this area would focus on the effectiveness of the licensee's erosion and corrosion program. Inspection activities would include reviews of the licensee's monitoring, detection and correction of piping and component degradation caused by erosion and/or corrosion, inspection activities would ensure that SSCs were being adequately f"itored and that appropriate corrective actions were implemented. Inspection activlbes w be limited to the site specific risk significant SSCs and would include revie,ws of s ' m' test"results and reviews of corrective actions for identified deficiencies. g W Basis /%em 5 c Inspection of this item supports the initiating events and mitigation s / ' N&k.p 3 in addition, this inspection area would have an affect on the Barrier, Emergency Preparedness, Occupational Dose, Public Dose, and Physical Protection comersiones. The inspection activities are intended to verify that the[licen%NNh see has adequately implemented the erosion / corrosion program so that the SSCs remain reliable and fully functional. l 4&g% Ryf Effective implementation of an erosion / corr program is~ important to minimize the potential for high energy fluid system failures that can iresultjn plant trainsien6i, damage to plant equipment and/or injury of personnel. The industry has experienced failures of steam system piping as a result of the effects of erosibn/ corrosion which'ynderscore the importance of monitoring licensee performance in'this' area. Affective implementation of the erosion / corrosion program is also important to minirnize the poteritial for irdernal flooding or a loss of system function. This includes loss of ' em or component c6o!ing due to service water system [f % ] F ~ failures. 4 AJ

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e no peNormance_ indicators establish that can provide results related to the l adequacyof the erbsion/co"rroson'pfogram. 1 w N l l /l Nd l Y h,j pyy: .~ f l l-34

l INSPECTABLE AREA: Post Maintenance Testing Scope i Inspection activities would focus on verification that the post maintenance testing activities were l adequate to verify system operability and functional capability for the maintenance that was l performed. The inspection would focus on significant maintenance involving highjisk significant systems or components, in areas that have the potential to c mode /cause failures, where repetitive failures indicate programmatic pJoblem,s,er on l maintenance activities that have the potential to significantlyJmpact r' iThese would also l include the areas of emergency preparedness, radiological' controls, "% physical security. y gg Basis f/ &[ $, g e Inspection of this item supports the mitigation systemspnd bar _. r comerstoneQinl addition, this inspection area would have an affect on the Initiating Events, Emergency Preparedness, Radiological Controls and Security comerstones. M.y3g p gwg This is the only process available to verify that a system or component'is reliable and fully functional following maintenance. Aq, Q yd l f.JWss, Post maintenance testing provides the final check that'a' system and, component has been returned to its required design configuratio6 and will' perform its design function (s) following l completion of maintenance activities. IrddequateMaintenance' activities that are not detected prior to retuming the equipment to servic'e can rei6lt in a significhnt increase in unidentified risk l for the subject system and in comrrion mode /cidse failure's'and potential for loss of function on i redundant trains and identical cor'npohents ' ' other systems. l This inspection activity will,Nel areas not covered by performance indicators and I will provide' performance input into the as$essment process. nieg W yA p ga 7 l ' 7' [;... ' M[j gn3 nm- \\ y, s ye i~ff f ~* gf.M. ++ y c A$h,f& l y gp > hk.,. ~' nm-D.Od,h,,,MF I I i l i l-35

INSPECTABLE AREA: Pre-Job Briefings Scope Inspections in this area focus on the effectiveness of pre-job briefings. This would include the adequacy of licensee discussions regarding scope of the work activity, expected plant I responses, contingency actions, work responsibilities, plant status requirements and precautions. Inspection activities in this area would be limited to observ tions ot emergent and or complex evolutions or high risk initiating evolutions $ m) Basis Ap M l!h &:r y ..... hh f> '. ~O .m. Inspection of this item supports the initiation cornerstor efin addition /thisinspection. area would have an affect on the Mitigating Systems and Ba}rrier cornerisiones. AWfM) (%))' .f g inadequate pre-job briefings can result in inappropriate actionstor actions out of sequence, inappropriate responses to changing plant conditions, wrong equipment being taken out of service, unintended actuations, plant trips, and unnecessary radiation. exposure. Deficiencies in human performance or controlling work processes dufirig maintenanciand testing activities have been shown to be a dominant factor in risk-significant events.: Poor pre-job briefings tend to cause an increase in risk, and in some instances, could be a sightficant contributor to risk. I g%.i Q )W There are no established performance indicators (Pis) that can provide information as to the adequacy of licensee programs for co cting prebb b'rief ngs h lNlk f 1 1 @$Y - %,c : m. ;s- <qu _ Y ', % '3 ...s. ,l. , Y '; l a 4; r:e, 1_ p kN/ 1 i-m M g .a ~ Q. my i e 1 1-36 l

_.= 1 INSPECTABLE AREAS: Radiation Monitoring Instrumentation Scope inspection of this area should ensure that criticality, area radiation (ARMS) and continuous air (CAMS) monitors are reliable and accurate during activities that could produce transient, HRAs, VHRAs or airborne areas. This inspection will also include the containment dome onitors, because of their importance in accident analysis and classification. // .h [ Basis ~ ghe j f4 inspection in this area supports the plant facilities / equipment and inst fw the Occupational Dose comerstone V [ 'W% f ea This inspection will verify that these monitors are calibrpte' and mb;intained a d 10 CFR Part 20 or a licensee's technical specifications and procedures. p ',h Radiological risk (i.e., exposure) to a worker should be maintaineM,in the occupational exposure limits defined in 10 CFR Part 20 and ALARA and to' minimize'the potential for health effects. These monitors identify changing radiological conditions to workers such that actions to prevent an overexposure can be taken. Industry has experienceKsever'al events where these monitors were the primary indication that radiological l conditions had significantly changed as a result of planned or unplanned activiti s: W ih // jf y QJ There is no Performance Indicator established f this area.~ Monitor locations are site speci;fic and assessments of their reliability and accuracy will require baseline inspection. Lj d x 4 Ah N g}Q g g /A X A 2 ;p /~l_ L, ^%_ ^~ Y w ^ /li .a W l-37

_ ~ 1 INSPECTABLE AREA: Radiation Worker Performance Scope inspection activities in this area consists of observing radiation worker (including Radiation Protection and Chemistry (RP&C) technicians) performance to verify that they aware of and use appropriate radiological controls when performing radiologically significant work. Basis / 4/ Inspection in this area supports the Occupational and Pub [ Dose ratNas. The objective of this area is to verify that workers unde the r I / associated with nuclear plant operation, effectively identify and co6 trol theseMl identify I and resolve adverse trends or deficiencies, and maintain prope(dversight of workF W h% The associated risk is the potential for a significant, unplanned exposure resulting either directly or in part by the failure of a worker to perform a required'taskowing'to poor knowledge or training. Recurrent problems in this area have been ide'ntified ty the industry as a root or 1 contributing cause in many exposure events and in some events' involving,the unplanned i i release of radioactive material to the environmenit This is of special concern during outages, when radiologically significant work is often rformed by' contract staff having varying levels of experience. /'jy.pCg >:, o ' ndication of performance for this The established Performance Indicator provides only parti i area and additional inspection is n.e6essary. J6is indicatoirls any inadvertent release of radioactive material from the protected area which could' reasonably result in public exposure > 1 mrem /yr Total Effective Dose E_quivalent/Qj#f 1 '"jy A we Q .,Q ~W %;fl_l W )% \\ g. p, "'*Q ) g i g A 4 M s m?! h j Y j ,qo# l f i 2 l i l 38 i

l l l l l INSPECTABLE AREA: Radioactive Material Processing and Shipping l Scope Inspection of this area should verify that appropriate controls are instituted for the processing and shipping of radioactive material to a burial site or other licensed recipient. The inspection focus is to review the administrative and physical controls for radiologically significant activities (Type A, Type B and higher risk material shipments) that prevent an inadverten}4xposure to workers and the public. Other routine aspects of the program will be as,sessed% rough a review of licensee assessments. /N A Q;% s h Basis l This inspection supports the program / process attributeof,the Pu Dose comerstone, s - N!d' NME This inspection will verify that the radioactive material processing and shipping l l complies with the requirements of 10 CFR Parts 20 andT1 and DOT regulations 49 CFR Parts l 170-189. Radioactive material intended for burial must 51sd compifwith 10 CFR 61.55 - 61.57 waste classification and stability requirements. V qQ% The regulations state specific physical and ad, thcontrols de for a layered defense against unplanned radiation exposure'd0 ring radioactive mater processing and transport or from an accidental breech of)fje' shipping container., frequency of industry events, the actual or potential consequence;Although there is release of radioactive material)is typicdily high. / gW (i.e., significant exposures or t I' l h There is no established Performan[ce l}ndicator,for this area given the low freque (nd w A nay.

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l 1 l 1 i INSPECTABLE AREA: Radiological Environmental Monitoring Program (REMP) Scope inspection of this area will ensure that the REMP reasonably measures the effects of radioactive releases to the environment and sufficiently validates the integrity of the gaseous and liquid effluent release program. The focus is on adverso trends or recurrent problems identified through licensee assessments or the Annual Environmental Njonitoringfjeport and periodic observations of worker and equipment performance. The inspnctiorjdjhould not focus i on the quality of procedures or minor administrative processes as these will be addressed in the l licensee assessments. %NA I z l O$$h s 3ff$yn i Basis ? x A n w ;m. Inspection in this area supports the plant facilities / equipment andInstrumentatig program / process attributes of the Public Dose comerstoneljg This inspection will verify that the REMP is implemented) consistent with the dOMN l specifications to validate that the effluent release progrsm meets the"ALARA principle of l Section IV.B of Appendix l to 10 CFR Part 50. g.% VWp fMQ k!' The REMP supplements the effluent monitoring program by verifying, at the measurable i concentrations of radioactive materials and livels of radiation are as predicted by the effluent measurements and modeling of effluent Mthways.p^s 5uch, it'serfes as the final barrier in assuring that the associated dose from radioactive releas5s is within regulatory limits. Industry l experience has shown that the REMP is ofter! the priman/rnethod of assessing the potential risk from unplanned or unmonitor5d iridioactiie releaseb.VAdditionally, REMP results have served to allay public concer,ns regarding thb actual health effects due radioactive releases associated with power plant' operation. Collectivelff these concems provide Justification for including,this' area in the tiaseliris inspecti'ogn rogram. QNk %MNA There are no ance indicators' established for this area. 75 r V;M. h N \\ . f 4[( k a. 4, s - QM %pg)ge 39 i i i i l-40 i l

l INSPECTABLE AREA: Refueling and Outage Related Activities Scope Inspection activities in this area would focus on those outage related activities that have the potential to impact the risk to the plant. These areas include plant cool down, transfer to shutdown cooling, solid operations, drain down evolutions, fuel handling (core off-load / reload), mid-loop / reduced inventory operations, containment integrity, plant hea up, reaolor'startup and physics testing. In addition, the inspection activities would include supp} ort sy,seem to mitigate the consequences of shutdown accidents, which)ncludespontrol[of switch yard activities, emergency diesel generator availability and vital power av@y. linspection activities in this area would include activities during forced or planned ges and would not, limited to only refueling outages. sigQ l Basis l Md% l Inspection of this item supports the initiating events, mit systems and barrier integrity 1%jg. cornerstones. N;Mw. The inspection activities are intended to verify that the licensee has taken'the necessary steps ( to minimize potential events, maintain defense,iridopth, ensure the" priate SSCs are maintained available to mitigate and contain ated accidents. nations [of e(quipment, outages can place th

nys.,

Due to changing plant configuration, co,ickly lead'to significant adverse conditio a condition where single failures can,qu l l boiling. In addition, operations and maintena,nce persong are performing non-routine tasks which have greater risk impact du' to the extensive amount of equipment that is usually out of e l service. These items, along witti th"e fact triat the bardiis to prevent a radiological release are l also degraded, result in a signific5nt increase irErisk if 'not appropriately controlled by the licensee.g;g)in 4jpg g There are'no perfo,rmance indica & t tors that have been established that can provide results related to the licens5e's performance'during' refueling outages. %'I f, 2%g

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INSPECTABLE AREA: Response to Contingency Events (Protective Strategy and I implementation of Protective Strategy) Scope Verify that the licenseu has the capability to protect its vital area target sets against the design basis threat. The implementation of the protective strategy includes demonstrating t, hat the strategy works, and that cecurity force can successfully protect against he desi ' basis threat through drills and exercises. A ~ y v.c M Djh Basis ,~ agg Inspection in this area supports the Physical ProtectionC$rnerstoney!kb j f y &g g There is no performance indicator for this inspectable area.'. g - 'y NyQ This is a high risk-significant system necessary to protect against the design basis threat of radiological sabotage. The licensee should be able tqdsmonstrate the, ability to respond with sufficient force, properly armed, appropriately trained and within.the appropriate time frame to protected positions in order to interdict and defeat th(design-ba$ls~ adversary force in order to protect vital equipment necessary for the safe. shutdown of the plan't' /DL jb% The ability of the security force to effectively respond to.the dekign' asis threat is contingent upon the number of armed responders /oinmittedjo in the physica' security plan; the intrusion l detection system being able to detect;'the alarm' status being c6mmunicated to the alarm stations; the assessment function,s'(closed-ci,rc' ult televisio~n and lighting) and the training of CAS and SAS operators, the respor::: officers and response team leaders, including handling and qualification with ansigned weapons, and the use of proper tactics. A /Ni No power plants in the United. States have$ 928 been attacked by a terrorist group. However, the d . consequence to radiolo 'esi sabotage if an attack did occur is high. t f gg, ; ylWa /; 3 vg 4 'd rd $ .f d

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t i l-42

INSPECTABLE AREA: Safety System Design and Performance Capability Scope Inspection includes review of design bases, final safety analysis report (FSAR), supporting calculations, as-built conditions, modifications, testing, and normal and emergency operations of risk-significant systems and interfaces with support systems. This would be an -depth review of a selected risk significant system or systems. / A Basis M 4, i Wh Inspection of this area supports the design attribute of t Mitigating Systems, Barriers, and y initiating Events comerstones. %dh W. ' %.,5.,.5 Inspection of safety system design and performance verifies the initial design and subseq/ 3 uent modifications and provides monitoring of the capability'of the selected system to perfoim its design basis functions. The Inspection should focus on the design and functional capability of components that are not validated by in-plant testing./dsofseismic and environmental qualifications of the SSCs should be verified. The PR(assurnptions and models are based on the ability of the as-built safety system to performJts intended safety function successfully. If the design bases of the system had not been correctly implementedJn thsinstalled system, the ~ i l operation and test procedures, and the suppcirting" analyses and calchlations, the system ) cannot be relied upon to meet its design bais6s and performarios reiluirements. The design interfaces with support systems, such as'ciooling systerris; ventilati6n systems, and instrument air system, should also be reviewed / 1 . um 2 The baseline inspection should focus on: (1) compliance with regulations, (2) consistency with defense-in-depth philosophy arsi(3) maintaining sufficient safety margins. p. hU W?W There are no performance indicators that hve been established that can provide results related to correc't 'impleriientatiol of the design bashs irithe as-built system and the associated plant documents. Therefore, the' baseline' inspection program includes inspection of this inspectable ~ pg-area. 2 yy 94 ~ ~W }l5? 3

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i 1 l i INSPECTABLE AREA Security Plans and Procedures (includes Security System Modifications) i Scope To assure that changes in the licensee's NRC approved physical security plan (PSP), safeguards contingency plan and guard training and qualification plan (T&O) has not decreased the safeguards effectiveness of the plans. l l Basis W Inspection in this area supports the Physical Protection Comerstone. Md[h ~ 14 m The licensee may make no changes which would decrease the effe ivenessW a secur

lan, safeguards contingency plan, or guard training and qualification' plan without prior approval of the commission. Changes that decrease the effectiveness of a plan and are implemented without commission approval can affect the risk significa)ce of the physical protection capabilities of the security organization necessary to protect against the design basis threat of I

radiological sabotage. V pA There is no performance indicator for this inspectable a%Fri,3} f rea., W +h Wh ) a, y a, x, w[ . a s,i ay y my 93;.h g ,rp ? 3 A %;f j . < 1 n, s. wa 4 l 24. n[I '5 4 m ar: "-g _ > a 1-44

{ INSPECTABLE AREA: Technical Specification Surveillance Testing 1 Scope Inspection activities in this area would be focused on Technical Specification (TS) surveillance l testing and would include reviews and observations of required surveillance testing. The l inspector would review TS testing results for adequacy in meeting the TS requirer,nents, observe ongoing testing to evaluate human performance, and ensure tt}at appropriate test acceptance criteria is in agreement with facility's design requirements./ Surveillance test failures l would be captured for review under the corrective action program inspection' activities. The ~ inspection activities would verify that the surveillance test ually meets the TS requirements. l {/;f W:QlQ l y Basis Wh /.. ,,pjf/ \\ Inspection of this area ensures that safety systems are capable of performing their safet function and would support the Mitigation and Barrier c'ornerstones. V htl Surveillance activities are required to verify that systems and.c% omponents are reliable and l functionally capable of performing their design functio'n.' Tectinical Spscification surveillance testing may or may not in itself be risk or safety significant. However, it is the minimum required testing specified in the facility license and ensures that a cogservative safety margin exists for system capability. In addition, inspe,ctionslare necessary toimsure licensee compliance with the NRC regulations and licensing bases.E perating experience has shown O that test procedure deficiencies may invalidate previously accep' table test results. E H i=' There are no established performan,ce indicators (Pis) tha}t can provide an ind i l adequacy of TS rerpred surveilla'nce't'esting' activities. // A, a im aw ..,f :} YY kfb f. 7 s n 4 h ). Q 9.q5 gx mg c R/ s. 97 1 1 l-45

x u-INSPECTABLE AREA: Temporary Plant Modifications Scope inspection activities in this area includes a review of design, installation, configuration control, and post-rnodification testing for potentially risk significant temoorary modifications of the SSCs covered by the maintenance rule. Basis .A%g inspection of this area supports the design and design co attrib "kN t Mitigating Systems, Barriers, and initiating Events comerstones. f /gj3gQ :( j Inspection of temporary plant modifications provides trpnitoring of,the licensee s pe , e in ensuring that the design bases for risk-significant systems, structures, and cornponents (SSCs) have been maintained and that the changes ha've not adversely affected the' safety functions of the SSCs. Temporary modifications may introduce):hange to the assumptions and models used in the plant specific PRA. A temporary chingelo one' system may affect the - design bases and safety functions of other interfacing'Ishfety Eystems.?An increase in the likelihood of the occurrence of an initiating event could result from,a temporary change. Also, similar temporary modifications to several systenis could introduce the ential for common cause failures that affect plant risk. - 9%)y%h )]Q&i&%i;+ J Industry experience has shown that temporary modifications to risk-significant SSCs can adversely affect their availability, reliability or fun 6tional ca'pabilft. Verification that all safety functions of the system are restored after completion of the' temporary modification is important. e No performance indicators thve been established th can provide results related to the adequacy of temporaryJnodifications. Th' refore,'ttie baseline inspection program includes e" Inspection of this inspectable area's y; v gj &g gtM k3 y c 3 i s M'Q ) bf'p;f s , gy a l-46 ]

~ ~ ' 1 _ n.__. es 1 / r 4.s / + a: p APPENDIX H .f 4,wpn ...a% \\ CORNERSTONE C . RTS= . d6 \\ %Q..;;/./ f ,.p~.. t*

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DRAFT e .- i S = Screms T = Transients Eved IO " 8h"'#'*" "'#8'" II"'I Rf1 = Risk Informed inspections t Key: um = Malatoaance Rule l jg V = Verriestion and Velldetten CAP = Corrective Action Program ISI = Intervice Inspection JL JL Jk JL Jk JL Protection Agehnt Human Procedure Equipment External Performance Quauty Performance Design Configuration Factore Contret JL JL Jk JL 4 enesse nswey*, N SGTW Lee,orHeatsh4

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TRpr Key: SSPI = Sofety System Performance Indicatot Megating init e initlet Operator Esem sys ems Requel Operator Requel e SD = Shutdown Mergin (Futete) Mll = Rish Informed Inspect 6ons A left = Maintenance Rule V = Vertfleetion end VeRdellen a q >g at sk ^ Protectiost oa'ea Agelnet Conngurellon Equipment Procedure Human { t iemmi Conitoi ve,to.inonce Evente ousiity perfomience + g a I \\ 7 ^ L nr yR / ee .ee / \\ .noe. .o. ee., cos. ree.e.o e me - ',e,,',-* o.e e e. e .e.e ee ,,,,,,,,es, t,,,es, e, -se se re:, e,m e,,,, i-> ,,,e,,e,,,,, se. e

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'e 2-OccupaDonal t Exposure Key: Jk HPT = Healtfi Physics Technicien MP e Redletion Protection Indicator i Uncontrolleif dose il TS HRA nonconformence IN VHRA nonconformence p) < WRWmns Ril e Mist Inferrned Inspections (2) Ma!ntain ALARA JL k i f mom Feche f Program # Process Instrumentation Hymen Performance Jk Jk pi,,e g% hecedwee tapeewe s ceeemane# co*se end usesen, et ALAR A Monaang I AN h I sept treansne t needeene 4 taged Osere f Capteder MPT Oesfe 8 A#ts Com & a spenseW G RedMw e epc m es e eseeswee. A med wester im mas. em a her'seavy u seeree teemcasees re e ep, ne pg M e RP.Re Pe=RP. WW me Jk N h t M e aP. twe Jk Jk Jk Event Fameene WSPECitopts: w Penne wendoene l Verwy M l l Verwy Pt l l Ve'Hy M Eweat Ftflowup N MM A eese ceawee

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mm W =- / o Key Erpostne RETS e Redfological Effluent Technical Speelfleetlens REMP e Redfelogical Environmental Monitoring Progesm 4 ODCM = OffsNe Dese Calculation Menvel i OS = OffsNe Dose indlester i Reportable OffsNe Dese Projections and Dose to enembers of the PubNe from effluents meterist release end ODCMIRETS events transportetton settvities gg Unautherfred Release of conteminated meteriel Ril e Risk Informed inspections (t) = 10ern Part 20 a 50 App I (2) Moledoin ALARA Jk Jk JL AL Plent Feetteles i Estuepenent & Instrumentetton Progrom f Process Performenee i \\ I.,,. _e. a -.e -s.e-ec . o.a.e.. e. .e- . c oc e~ ..e te = * - - - ' ~ *

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CDF %str.wq % (+s & NInh A D'sh PWRs $= Westinghouse SS=CE S$$=B&W Base CDPInput (Increase Resuking in delta CDF=lx10-5) = CDF change <165 when set at I (100%) + Plant EAC U EAC R AFW U AFW R HPSI U HPSI R RHR U RHR R SCRAMS I 1.9*4 4.7E-3 .6% 9.9E-3 1.8 % 4E-4 .8% 4.7E-4 3 (2.2%) (1.551) (23.7%) (1.8E-1) (61%) (9.4E-1) (20.7%) (9.8E-2) (10) 2 SS 1.2% 353 .5% 4.6E-3 1.9% 6.3 E-4 N/A N/A 1.4 i (1.3%) (1.152) (.72%) (6.4&3) (22%) (5.3E-3) N/A N/A (4.5) 3 1.8% H++ 2% am 2% w m N 5 (67%) N/A N/A 96% N/A N/A (34) 4 1.39E-2 9.36E-3 5.37E-3 6.20E-3 4.07E-3 1.96E-3 4.22 & 3 1.5 5 3 7 (2.6061) (2.61E-1) (1.04E-1) (1.02E-1) (5.29E-1) (5.23E-1) (27) 5 3 2./6E-2 7.87E-3 1.36E-2 ')52B-2 2.2 l E-2 1.18 & 3 1.74 E-3 6.95E-3 2.75 (11%) 0%) (36%) (26%) (31%) (17%) (12%) (9%) 00) 6 S 1.9E-2 1.43 & 2 3.45E-3 1.85 & 2 3.52E-2 5.08E-3 2.38E-3 4.02E-3 1.95 (11%) (12%) (13%) (18%) (6.4%) (6.4%) (10.3) 7 S 3.02E-2 4.6653 5.14E-3 9.43 & 3 1.73E-3 6.82E-4 4.77E-4 7.2E-4 1.1 (6.5&l) (4.69E-2) (3.16E-2) (2.6E 2) (8.3451) (3.63&l) (2.75&l) (2.85&l) y T.l 2. 8 3 5.54 & 3 1.7E-2 1.1562 1.4E-2 4.49 & 3 6.2563 1.68 & 3 4.84 & 3 1.04 (25.6%) (25'A) (43.5%) (40.5%) ((58%) (45.7%) (32.5%) (29.6%) (4.66) i t g M cersvCr1

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<~ General: Used anost limiting train / system based on info provided BWRS Base CDF Input (Increase Resulting in delta CDF=1x10-5)

• = CDF change <!E-3 when set at 1 (100%)

Pisal EAC U EAC R RCIC U RCICR HPK'U BPIC R CS U CS R I 6E-3 6.6E-3 2.2% 4.253 1.8% 4.253 6.5&3 8.9E-4 i (23%) (5.4&2) (13%) (SE-2) -[ i 2 3% 6.5 E-3 2.5% 2.6E-2 2.5% 2.6E-2 2% 4.2E-4 (58%) (4.9E-1) (48%) (4.2E-1) l 3 3.8E-2 8.1E-3 1.06E-2 1&2 1.26E-2 3.4E-3 4.lE-3 1.5&3 j (30%) (17%) (43%) (12%) (18%) (20%) (50%) (50%) 4 1.55 & 3 3.91E-4 4.47E-3 2.39E-4 7.46 & 3 239E-3 NO DATA NO DATA (1.26EO) (437E-1) (4.83E-1) (430&l) (4.98&l) (5.86E-1) NO DATA NO DATA Plant RHR U R'IR R Scrans I .5% 5.7E-3 4 (10) 2 2% 4.2&3 6.27 (18.8) 3 SE-3 2.1&3 1.5 (32%) (25%) (22) 4 7.53E-3 2.78E-4 7.1E-1 (533E-1) (535E-1) (9.12) 1 t t J

4' e i I FAX COVOr Sheet NUCLEAR ENERGY INSTITUTE 1776 i Street, N.W., Suite 400 Washington. DC 20006-3708 TO: hgere ###A/ FROM: Company: Phone: p,,yf g-Phone: Fax: Fax: l Date: Page(s) including Cover Sheet: Comments: l i I l NOTICE OF CONFIDLNTALTTY THE INFORMATION CONTAINED IN THIS TELECOPIED MESSAGE IS CONFIDENTIAL INFORMATON INTENDED FOR THE USE OF THE ADDRESSEE USTED ABOVE ANY DISCLOSURE. COPYING. OR DISTRIBUTION OR THE TAKING OF ANY ACTION IN RELLANCE ON THE CONTENTS OF THIS TELECOPIED INFORMATION SY OTHER THAN THE INTENDED RECIPIENT IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS TELECOPY IN ERROR PLEASE IMMEDIATELY NOTIFY ME BY TELEPHONE AT (202) 739-8000. j, i l I}}