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{{#Wiki_filter:Issue Date:  07/25/06- 1 -2515/169NRC INSPECTION MANUALIPABTEMPORARY INSTRUCTION 2515/169MITIGATING SYSTEMS PERFORMANCE INDEX VERIFICATIONCORNERSTONE:MITIGATING SYSTEMSAPPLICABILITY:This temporary instruction (TI) applies to all holders of operatinglicenses for light water nuclear power reactors. 2515/169-01OBJECTIVEThe objective of this TI is to verify that licensees have correctly implemented the MitigatingSystems Performance Index (MSPI) guidance for reporting unavailability and unreliabilityof the monitored safety systems.2515/169-02BACKGROUND02.01Purpose of the MSPI The MSPI was developed to replace the Safety System Unavailability (SSU) indicatorscurrently in use in the Reactor Oversight Process (ROP). The SSU indicators have severalweaknesses, including the following: (1) the use of design basis functions rather than risk-significant functions; (2) the use of thresholds developed from generic plant models ratherthan from plant-specific models; (3) the use of fault exposure unavailable hours as asurrogate for unreliability rather than monitoring unreliability directly, and (4) the cascadingof support system unavailability to the monitored systems rather than monitoring supportsystems separately. The MSPI monitors the unavailability and the unreliability of the samefour safety systems that comprise the SSU; it also monitors the cooling water supportsystems for those four safety systems. These systems include:Boiling Water Reactors:*Emergency AC (emergency alternating current (EAC))
{{#Wiki_filter:NRC INSPECTION MANUAL                                              IPAB TEMPORARY INSTRUCTION 2515/169 MITIGATING SYSTEMS PERFORMANCE INDEX VERIFICATION CORNERSTONE:             MITIGATING SYSTEMS APPLICABILITY:       This temporary instruction (TI) applies to all holders of operating licenses for light water nuclear power reactors.
*High pressure injection (high pressure coolant injection(HPCI)/high pressure core spray (HPCS)/feedwater coolantinjection (FWCI))
2515/169-01      OBJECTIVE The objective of this TI is to verify that licensees have correctly implemented the Mitigating Systems Performance Index (MSPI) guidance for reporting unavailability and unreliability of the monitored safety systems.
2515/169- 2 -Issue Date: 07/25/06*Heat removal (Reactor core isolation cooling (RCIC/isolationcondenser (IC))*Residual heat removal (RHR)
2515/169-02      BACKGROUND 02.01    Purpose of the MSPI The MSPI was developed to replace the Safety System Unavailability (SSU) indicators currently in use in the Reactor Oversight Process (ROP). The SSU indicators have several weaknesses, including the following: (1) the use of design basis functions rather than risk-significant functions; (2) the use of thresholds developed from generic plant models rather than from plant-specific models; (3) the use of fault exposure unavailable hours as a surrogate for unreliability rather than monitoring unreliability directly, and (4) the cascading of support system unavailability to the monitored systems rather than monitoring support systems separately. The MSPI monitors the unavailability and the unreliability of the same four safety systems that comprise the SSU; it also monitors the cooling water support systems for those four safety systems. These systems include:
*Cooling water support systems (Emergency Service Water(ESW) and component cooling water (CCW) or their equivalents)Pressurized Water Reactors: *Emergency AC (emergency alternating current (EAC))
Boiling Water Reactors:
*High pressure injection (High Pressure Safety Injection (HPSI))
* Emergency AC (emergency alternating current (EAC))
*Heat removal (auxiliary feedwater (AFW)/emergency feedwater(EFW))*Residual heat removal (RHR)
* High pressure injection (high pressure coolant injection (HPCI)/high pressure core spray (HPCS)/feedwater coolant injection (FWCI))
*Cooling water support systems (Emergency Service Water(ESW) and component cooling water (CCW) or their equivalents)2515/169-03INSPECTION REQUIREMENTS03.01General. There are no regulatory requirements for this program and licenseeparticipation is voluntary. Prior to the April 1, 2006, implementation of MSPI into the ROP, a team of NRC staff andcontractors involved in the development of the index, conducted an audit of the licensees'bases documents. On a sampling basis, the team selected key aspects of the index toensure that the licensees followed the MSPI guidelines. The key aspects included: (1) identification of the correct boundaries; (2) selection of the appropriate components; (3)establishment of baseline unavailability and unreliability information; and (4) resolution ofconcerns with respect to the individual licensee's Probabilistic Risk Assessments.The purpose of this Temporary Instruction is to validate the unavailability and unreliabilityinput data and to verify accuracy of the first reporting results for the 2006 second quarter.This Temporary Instruction will be completed by December 31, 2006.03.02Credit for Unavailabilitya.On a sampling basis, the inspector will review the licensee's list of surveillanceactivities which, when performed, do not render the train unavailable due to theshort duration of the activity (less than 15 minutes).b.On a sampling basis, the inspector will review the licensee's list of surveillanceactivities which, when performed, do not render the train unavailable due to thecredit for operator recovery activities as defined by Nuclear Energy Institute (NEI)
Issue Date: 07/25/06                                                               2515/169
Issue Date: 07/25/06- 3 -2515/16999-02 (Regulatory Assessment Performance Indicator Guideline), Revision 4, pageF-6. 03.03Verification of Unavailability and Unreliability Data a.For each MSPI system, using the general concepts discussed in Section 1.2.2 ofAppendix F of NEI 99-02, Revision 4, the inspector will independently determinethe baseline planned unavailability hours and confirm that these hours werecorrectly translated into the basis document.b.On a sampling basis for each MSPI system, using operating logs, correctivemaintenance records, and condition reports, the inspector will confirm that theactual planned and unplanned unavailability data is accurate.c.On a sampling basis for each MSPI system, based on a review of relatedmaintenance and test history, the inspector will confirm the accuracy of the failuredata (demand failures, run/load failures, and failures to meet the risk-significantmission time, as applicable) for the identified monitored components. 2515/169-04GUIDANCE04.01GeneralAlthough a detailed understanding of how the MSPI index is calculated is not required toconduct this TI, it is important that the inspector becomes familiar with the licensee's MSPIbases document. The inspector should be aware of each system boundary and thecomponents that the licensee will be specifically monitoring under the index. The regionalMSPI contacts, as well as training on the MSPI, should aid in this understanding.04.02Credit for Unavailability. a.As discussed in Section G.1.7 of Appendix G of NEI 99-02, Revision 4, thelicensee will develop a list of any periodic surveillances or evolutions of less than15 minutes of unavailability that the licensee will not include in the MSPI trainunavailability. The intent of this list is to minimize unnecessary burden of datacollection, documentation and verification because these short durations haveinsignificant risk impact. In many cases, the licensee may state "none" in thissection which means that all unavailability resulting from surveillance activities willbe counted as train unavailability in the MSPI calculations. For thosecircumstances where the licensee provides a list in the MSPI basis document,confirmation that the unavailability time is of short duration is necessary.Therefore, on a sampling basis, the inspector should review the listed surveillanceactivity and verify the duration of unavailability is less than 15 minutes. This canbe accomplished based on the inspector's knowledge of the surveillance or areview of the licensee's record keeping on previous surveillances. For example,the licensee may document unavailability in the control room log books. Theinspector should review log book entries for a sample of the surveillances toensure the time period of unavailability is less than 15 minutes.
* Heat removal (Reactor core isolation cooling (RCIC/isolation condenser (IC))
2515/169- 4 -Issue Date: 07/25/06b.As discussed in Section F.1.2.1 of Appendix F of NEI 99-02, Revision 4, credit foroperator recovery actions during testing or operational alignment, or during somemaintenance activities can be taken to reduce train unavailability time. Thelicensee will develop a list of these activities that will not be included in the MSPItrain unavailability. With some systems, the licensee may state "none" whichmeans that the system will not realign itself during surveillance activities oroperator actions to recover availability do not meet guidelines. For thosecircumstances where the licensee provided a list in the MSPI basis document,confirmation that the activities meet the guidelines is necessary. Therefore, on asampling basis, the inspector should review the listed surveillance activity andverify that the operator actions to recover unavailability are contained in a writtenprocedure and are uncomplicated. This can be accomplished based on theinspector's knowledge of the surveillance or a review of the surveillance oroperating procedure.04.03Entry of Baseline Dataa.Baseline Planned Unavailability: In developing the baseline unavailability for a trainor a segment, the licensee will determine the baseline planned unavailability timebased on actual plant specific values for the period of 2002 - 2004. These valuesare expected to remain fixed unless the licensee changes its maintenancephilosophy with respect to online maintenance or preventive maintenance. Thelicensee's calculations for this section will be documented in an Appendix to theMSPI basis document.The inspector should understand the MSPI system boundaries, particularly thesupport cooling functions, prior to performing this task. It is important to verify thatthe licensee has properly accounted for planned and unplanned unavailabilityresulting from cascading support system inoperability. In most cases, the lastvalve that connects the cooling water support system to another MSPI systemcomponent is included in that MSPI system. Unavailability of this last valve iscounted in that MSPI system, not in the cooling water system. In addition, all ofthe components within the system boundary will contribute to the unavailabilitytime of the system train or segment.For the cooling water system(s), the inspector will review related work historyinformation, maintenance rule information, corrective action program documents, and surveillance testing to determine periods of time where the licensee plannedto make the cooling water system unavailable. On a sampling basis, the inspectorshould review operating logs and the above information to determine the actualtime periods the system was not available due to planned activities. Thisinformation should be compared to the licensee's assessment and discrepanciesshould be resolved. For the remaining systems, the licensee will calculate the plant-specific baselineplanned unavailability using the ROP data from 2002-2004. In general, thisinformation will come from previously submitted SSU information and should beavailable on the ROP website. Using the process stated in Section 1.2.2 of theNEI guidance, the licensee should have developed tables for each train showing Issue Date: 07/25/06- 5 -2515/169the values used in their calculation. The inspector should verify that the licenseeaccurately transposed the SSU information into these tables, specifically,(1) totaltrain unavailability hours reported in the SSU; (2) fault exposure hours which wereincluded in the 2002-2004 data; and (3) unplanned unavailability time. Usinginformation from system health reports, corrective action program documents, andmaintenance rule information, the inspector should independently confirm theaccuracy of the additions and deletions from this data. For example, on asampling basis, the inspector will review operator logs and maintenance recordsas necessary to verify the number of hours the licensee added for plannedoverhauls which had not been included in the SSU calculation. The inspector willconfirm that the planned unavailability time listed in the plant-specific spr ead sheetdid occur and will confirm that pl anned unavailability time described in thelogs/condition reports is counted. It is key that the inspector confirm that thelicensee did not double subtract hours. For example, if unplanned unavailabilityoccurred due to low cooling water flow to a pump, the licensee should not subtractthese hours in both steps 2 and 7 of the process stated in Section 1.2.2 of the NEIguidance.The inspector will confirm the licensee's estimated critical hours reported bycomparing that estimate with the critical hours reported in the Scrams per 7,000Critical Hours performance indicator (PI) or the critical hours reported in themonthly operating reports.The inspector shall verify that the baseline planned unavailability information wascorrectly translated to the consolidated data entry (CDE) input sheet. b.Actual Performance Data - Unavailability: The actual performance data covers a12 quarter period. Because of the overlap with the baseline unavailability time (the2002-2004 data in the above activity), it is necessary only to verify the data for the2005-2006 time period in this section. Because Inspection Procedure 71151, "Performance Indicator Verification," wasnot performed for the mitigating systems in calendar year 2005, the informationpresented by the licensee in the SSU needs to be verified. Therefore, theinspector shall first determine the accuracy and completeness of the reportedunavailability data by reviewing out-of-service logs, operating logs, and themaintenance rule database. In addition to the review of these records, theinspector should, in conjunction with inspections in other inspectable areas, verifyplanned, unplanned, or fault exposure unavailable hours for the system underreview. Related inspectable areas under which inspectors can reviewunavailability determinations include equipment alignment, emergent work,maintenance rule implementation, and maintenance work prioritization and control.Once the accuracy of the SSU information is verified, the inspector should confirmthat the licensee accurately determined the MSPI unavailability. The inspectorshould verify the following information was recorded in the CDE input:1.For the 2003 and 2004 data, the total unavailability time would incl ude theplanned, as determined in section 04.03a of this procedure, and the 2515/169- 6 -Issue Date: 07/25/06unplanned unavailability, which was previously subtracted in step 3 of section1.2.2 of the NEI guidance. 2.For the 2005 and 2006 data, the inspector should confirm that the licenseedid not include any fault exposure hours or unavailability hours while thereactor was not critical. c.Actual Performance Data - Unreliability: Using Section F.2.2.2 of Appendix F ofNEI 99-02, Revision 4, the inspector will verify the licensee appropriately identifiedthe failures of the monitored components. Determination of a failure is definedusing the success criteria found in the licensee's basis document. It is importantto note that the MSPI success criteria may be less conservative than the licensingbases. For example, the MSPI success criteria may require a flow rate of450 gpm, whereas Technical Specifications may require 500 gpm. If thesurveillance as-found condition is 475 gpm, the pump will be TS inoperable;however, the pump would still be capable of fulfilling its MSPI function.For each MSPI monitored component, the inspector should gather backgroundinformation such as condition reports or system health information to determineperiods of time in which individual components failed to operate properly. Theunreliability component for valves include only failures on demand. Theunreliability component for pumps include both failures on demand and failures tomeet the risk-significant mission time. The unreliability component for emergencydiesel generators include failures on demand, failures to load/run, and failures tomeet the risk-significant mission time. On a sampling basis, the inspector shouldverify that the licensee captured these failures accurately in its documentation.Discovered conditions of non-monitored components that render the system/trainfrom performing its MSPI stated function, whether originating in the monitoredsystem or not, require special consideration. These situations are covered in detailin the MSPI training slides that can be located under the ROP link on the internalwebsite (Digital City). Situations not covered by the training slide examples shouldbe resolved between the inspector and the MSPI regional contact.2515/169-05REPORTING REQUIREMENTSThe results of this Temporary Instruction should be included in Section 4OA4 of anintegrated inspection report and should be forwarded to the Region contact person listedin this Temporary Instruction. The following questions and answers should bedocumented:1.For the sample selected, did the licensee accurately document the baselineplanned unavailability hours for the MSPI systems?2.For the sample selected, did the licensee accurately document the actualunavailability hours for the MSPI systems?
* Residual heat removal (RHR)
Issue Date: 07/25/06- 7 -2515/1693.For the sample selected, did the licensee accurately document the actualunreliability information for each MSPI monitored com ponent? 4.Did the inspector identify significant errors in the reported data, whichresulted in a change to the indicated index color? Describe the actualcondition and corrective actions taken by the licensee, including the datewhen the revised PI information was submitted to the NRC. 5.Did the inspector identify significant discrepancies in the basis documentwhich resulted in (1) a change to the system boundary; (2) an addition of amonitored component; or (3) a change in the reported index color? Describethe actual condition and corrective actions taken by the licensee, including,the date of when the bases document was revised. 2515/169-06COMPLETION SCHEDULEThis TI should be completed on or before December 31, 2006.
* Cooling water support systems (Emergency Service Water (ESW) and component cooling water (CCW) or their equivalents)
2515/169-07EXPIRATIONThis TI will expire on December 31, 2006. Before that date, this TI should be performedonce at each licensee facility, where applicable.2515/169-08CONTACTFor questions regarding the performance of this TI and emergent issues, contact JohnThompson (301-415-1011, jwt1@nrc.gov) or Regional Contacts: Region IChristopher Cahill610-337-5108cgc@nrc.govRegion IIWalt Rogers404-562-4619wgr1@nrc.govRegion IIISonia Burgess630-829-9752 sdb2@nrc.gov Region IVMichael Runyan817-860-8142mfr@nrc.gov2515/169-09STATISTICAL DATA REPORTINGAll direct inspection effort expended on this TI is to be charged to 2515/169 for reportingby the HRMS system with an IPE code of SI. Per memorandum dated January 20, 2006, from Mr. Michael J. Case, Director, Division ofInspection and Regional Support, Office of Nuclear Reactor Regulation to the RegionalDeputy Administrators, performance indicators MS01, MS02, MS03, and MS04 will not beinspected during CY 2006 as this Temporary Instruction evaluates equipment availabilityand reliability data. Therefore, no samples will be included in the RPS inspection trackingsystem.
Pressurized Water Reactors:
2515/169- 8 -Issue Date: 07/25/062515/169-10ORIGINATING ORGANIZATION INFORMATION10.01Organizational ResponsibilityThis TI was initiated by NRR/Division of Inspection & Regional Support(DIRS)/Performance Assessment Branch (IPAB).10.02Resource EstimateThe direct inspection effort to be expended in connection with this TI is estimated to be30-40 person-hours for a two-unit site. 10.03TrainingTraining on this TI was conducted in the Regional offices during the second quarter ofcalendar year 2006. Additional support can be obtained through the Regional contacts.
* Emergency AC (emergency alternating current (EAC))
END Issue Date: 07/25/062515/169, Att 1A1-1Attachment 1Revision History For TI 2515/169, Mitigating Systems Performance Index VerificationCommitmentTrackingNumberIssue DateDescriptionof ChangeTraining NeededTrainingCompletionDateComment Resolution Accession Number07/25/06Temporaryinstruction forconductingMSPI dataverifications.Training was conducted in each ofthe four regions via a two hourpresentation during the regionalinspector counterpart meetings.June 6, 2006ML060940629}}
* High pressure injection (High Pressure Safety Injection (HPSI))
* Heat removal (auxiliary feedwater (AFW)/emergency feedwater (EFW))
* Residual heat removal (RHR)
* Cooling water support systems (Emergency Service Water (ESW) and component cooling water (CCW) or their equivalents) 2515/169-03      INSPECTION REQUIREMENTS 03.01 General. There are no regulatory requirements for this program and licensee participation is voluntary.
Prior to the April 1, 2006, implementation of MSPI into the ROP, a team of NRC staff and contractors involved in the development of the index, conducted an audit of the licensees bases documents. On a sampling basis, the team selected key aspects of the index to ensure that the licensees followed the MSPI guidelines. The key aspects included:
(1) identification of the correct boundaries; (2) selection of the appropriate components; (3) establishment of baseline unavailability and unreliability information; and (4) resolution of concerns with respect to the individual licensees Probabilistic Risk Assessments.
The purpose of this Temporary Instruction is to validate the unavailability and unreliability input data and to verify accuracy of the first reporting results for the 2006 second quarter.
This Temporary Instruction will be completed by December 31, 2006.
03.02    Credit for Unavailability
: a. On a sampling basis, the inspector will review the licensees list of surveillance activities which, when performed, do not render the train unavailable due to the short duration of the activity (less than 15 minutes).
: b. On a sampling basis, the inspector will review the licensees list of surveillance activities which, when performed, do not render the train unavailable due to the credit for operator recovery activities as defined by Nuclear Energy Institute (NEI) 2515/169                                                            Issue Date: 07/25/06
 
99-02 (Regulatory Assessment Performance Indicator Guideline), Revision 4, page F-6.
03.03  Verification of Unavailability and Unreliability Data
: a. For each MSPI system, using the general concepts discussed in Section 1.2.2 of Appendix F of NEI 99-02, Revision 4, the inspector will independently determine the baseline planned unavailability hours and confirm that these hours were correctly translated into the basis document.
: b. On a sampling basis for each MSPI system, using operating logs, corrective maintenance records, and condition reports, the inspector will confirm that the actual planned and unplanned unavailability data is accurate.
: c. On a sampling basis for each MSPI system, based on a review of related maintenance and test history, the inspector will confirm the accuracy of the failure data (demand failures, run/load failures, and failures to meet the risk-significant mission time, as applicable) for the identified monitored components.
2515/169-04      GUIDANCE 04.01  General Although a detailed understanding of how the MSPI index is calculated is not required to conduct this TI, it is important that the inspector becomes familiar with the licensees MSPI bases document. The inspector should be aware of each system boundary and the components that the licensee will be specifically monitoring under the index. The regional MSPI contacts, as well as training on the MSPI, should aid in this understanding.
04.02  Credit for Unavailability.
: a. As discussed in Section G.1.7 of Appendix G of NEI 99-02, Revision 4, the licensee will develop a list of any periodic surveillances or evolutions of less than 15 minutes of unavailability that the licensee will not include in the MSPI train unavailability. The intent of this list is to minimize unnecessary burden of data collection, documentation and verification because these short durations have insignificant risk impact. In many cases, the licensee may state none in this section which means that all unavailability resulting from surveillance activities will be counted as train unavailability in the MSPI calculations. For those circumstances where the licensee provides a list in the MSPI basis document, confirmation that the unavailability time is of short duration is necessary.
Therefore, on a sampling basis, the inspector should review the listed surveillance activity and verify the duration of unavailability is less than 15 minutes. This can be accomplished based on the inspectors knowledge of the surveillance or a review of the licensees record keeping on previous surveillances. For example, the licensee may document unavailability in the control room log books. The inspector should review log book entries for a sample of the surveillances to ensure the time period of unavailability is less than 15 minutes.
Issue Date: 07/25/06                                                            2515/169
: b. As discussed in Section F.1.2.1 of Appendix F of NEI 99-02, Revision 4, credit for operator recovery actions during testing or operational alignment, or during some maintenance activities can be taken to reduce train unavailability time. The licensee will develop a list of these activities that will not be included in the MSPI train unavailability. With some systems, the licensee may state none which means that the system will not realign itself during surveillance activities or operator actions to recover availability do not meet guidelines. For those circumstances where the licensee provided a list in the MSPI basis document, confirmation that the activities meet the guidelines is necessary. Therefore, on a sampling basis, the inspector should review the listed surveillance activity and verify that the operator actions to recover unavailability are contained in a written procedure and are uncomplicated. This can be accomplished based on the inspectors knowledge of the surveillance or a review of the surveillance or operating procedure.
04.03  Entry of Baseline Data
: a. Baseline Planned Unavailability: In developing the baseline unavailability for a train or a segment, the licensee will determine the baseline planned unavailability time based on actual plant specific values for the period of 2002 - 2004. These values are expected to remain fixed unless the licensee changes its maintenance philosophy with respect to online maintenance or preventive maintenance. The licensees calculations for this section will be documented in an Appendix to the MSPI basis document.
The inspector should understand the MSPI system boundaries, particularly the support cooling functions, prior to performing this task. It is important to verify that the licensee has properly accounted for planned and unplanned unavailability resulting from cascading support system inoperability. In most cases, the last valve that connects the cooling water support system to another MSPI system component is included in that MSPI system. Unavailability of this last valve is counted in that MSPI system, not in the cooling water system. In addition, all of the components within the system boundary will contribute to the unavailability time of the system train or segment.
For the cooling water system(s), the inspector will review related work history information, maintenance rule information, corrective action program documents, and surveillance testing to determine periods of time where the licensee planned to make the cooling water system unavailable. On a sampling basis, the inspector should review operating logs and the above information to determine the actual time periods the system was not available due to planned activities. This information should be compared to the licensees assessment and discrepancies should be resolved.
For the remaining systems, the licensee will calculate the plant-specific baseline planned unavailability using the ROP data from 2002-2004. In general, this information will come from previously submitted SSU information and should be available on the ROP website. Using the process stated in Section 1.2.2 of the NEI guidance, the licensee should have developed tables for each train showing 2515/169                                                            Issue Date: 07/25/06
 
the values used in their calculation. The inspector should verify that the licensee accurately transposed the SSU information into these tables, specifically,(1) total train unavailability hours reported in the SSU; (2) fault exposure hours which were included in the 2002-2004 data; and (3) unplanned unavailability time. Using information from system health reports, corrective action program documents, and maintenance rule information, the inspector should independently confirm the accuracy of the additions and deletions from this data. For example, on a sampling basis, the inspector will review operator logs and maintenance records as necessary to verify the number of hours the licensee added for planned overhauls which had not been included in the SSU calculation. The inspector will confirm that the planned unavailability time listed in the plant-specific spread sheet did occur and will confirm that planned unavailability time described in the logs/condition reports is counted. It is key that the inspector confirm that the licensee did not double subtract hours. For example, if unplanned unavailability occurred due to low cooling water flow to a pump, the licensee should not subtract these hours in both steps 2 and 7 of the process stated in Section 1.2.2 of the NEI guidance.
The inspector will confirm the licensees estimated critical hours reported by comparing that estimate with the critical hours reported in the Scrams per 7,000 Critical Hours performance indicator (PI) or the critical hours reported in the monthly operating reports.
The inspector shall verify that the baseline planned unavailability information was correctly translated to the consolidated data entry (CDE) input sheet.
: b. Actual Performance Data - Unavailability: The actual performance data covers a 12 quarter period. Because of the overlap with the baseline unavailability time (the 2002-2004 data in the above activity), it is necessary only to verify the data for the 2005-2006 time period in this section.
Because Inspection Procedure 71151, Performance Indicator Verification, was not performed for the mitigating systems in calendar year 2005, the information presented by the licensee in the SSU needs to be verified. Therefore, the inspector shall first determine the accuracy and completeness of the reported unavailability data by reviewing out-of-service logs, operating logs, and the maintenance rule database. In addition to the review of these records, the inspector should, in conjunction with inspections in other inspectable areas, verify planned, unplanned, or fault exposure unavailable hours for the system under review. Related inspectable areas under which inspectors can review unavailability determinations include equipment alignment, emergent work, maintenance rule implementation, and maintenance work prioritization and control.
Once the accuracy of the SSU information is verified, the inspector should confirm that the licensee accurately determined the MSPI unavailability. The inspector should verify the following information was recorded in the CDE input:
: 1. For the 2003 and 2004 data, the total unavailability time would include the planned, as determined in section 04.03a of this procedure, and the Issue Date: 07/25/06                                                            2515/169
 
unplanned unavailability, which was previously subtracted in step 3 of section 1.2.2 of the NEI guidance.
: 2. For the 2005 and 2006 data, the inspector should confirm that the licensee did not include any fault exposure hours or unavailability hours while the reactor was not critical.
: c. Actual Performance Data - Unreliability: Using Section F.2.2.2 of Appendix F of NEI 99-02, Revision 4, the inspector will verify the licensee appropriately identified the failures of the monitored components. Determination of a failure is defined using the success criteria found in the licensees basis document. It is important to note that the MSPI success criteria may be less conservative than the licensing bases. For example, the MSPI success criteria may require a flow rate of 450 gpm, whereas Technical Specifications may require 500 gpm. If the surveillance as-found condition is 475 gpm, the pump will be TS inoperable; however, the pump would still be capable of fulfilling its MSPI function.
For each MSPI monitored component, the inspector should gather background information such as condition reports or system health information to determine periods of time in which individual components failed to operate properly. The unreliability component for valves include only failures on demand. The unreliability component for pumps include both failures on demand and failures to meet the risk-significant mission time. The unreliability component for emergency diesel generators include failures on demand, failures to load/run, and failures to meet the risk-significant mission time. On a sampling basis, the inspector should verify that the licensee captured these failures accurately in its documentation.
Discovered conditions of non-monitored components that render the system/train from performing its MSPI stated function, whether originating in the monitored system or not, require special consideration. These situations are covered in detail in the MSPI training slides that can be located under the ROP link on the internal website (Digital City). Situations not covered by the training slide examples should be resolved between the inspector and the MSPI regional contact.
2515/169-05      REPORTING REQUIREMENTS The results of this Temporary Instruction should be included in Section 4OA4 of an integrated inspection report and should be forwarded to the Region contact person listed in this Temporary Instruction. The following questions and answers should be documented:
: 1. For the sample selected, did the licensee accurately document the baseline planned unavailability hours for the MSPI systems?
: 2. For the sample selected, did the licensee accurately document the actual unavailability hours for the MSPI systems?
2515/169                                                          Issue Date: 07/25/06
: 3. For the sample selected, did the licensee accurately document the actual unreliability information for each MSPI monitored component?
: 4. Did the inspector identify significant errors in the reported data, which resulted in a change to the indicated index color? Describe the actual condition and corrective actions taken by the licensee, including the date when the revised PI information was submitted to the NRC.
: 5. Did the inspector identify significant discrepancies in the basis document which resulted in (1) a change to the system boundary; (2) an addition of a monitored component; or (3) a change in the reported index color? Describe the actual condition and corrective actions taken by the licensee, including, the date of when the bases document was revised.
2515/169-06      COMPLETION SCHEDULE This TI should be completed on or before December 31, 2006.
2515/169-07        EXPIRATION This TI will expire on December 31, 2006. Before that date, this TI should be performed once at each licensee facility, where applicable.
2515/169-08      CONTACT For questions regarding the performance of this TI and emergent issues, contact John Thompson (301-415-1011, jwt1@nrc.gov) or Regional Contacts:
Region I          Christopher Cahill      610-337-5108  cgc@nrc.gov Region II          Walt Rogers            404-562-4619  wgr1@nrc.gov Region III        Sonia Burgess          630-829-9752   sdb2@nrc.gov Region IV          Michael Runyan          817-860-8142  mfr@nrc.gov 2515/169-09      STATISTICAL DATA REPORTING All direct inspection effort expended on this TI is to be charged to 2515/169 for reporting by the HRMS system with an IPE code of SI.
Per memorandum dated January 20, 2006, from Mr. Michael J. Case, Director, Division of Inspection and Regional Support, Office of Nuclear Reactor Regulation to the Regional Deputy Administrators, performance indicators MS01, MS02, MS03, and MS04 will not be inspected during CY 2006 as this Temporary Instruction evaluates equipment availability and reliability data. Therefore, no samples will be included in the RPS inspection tracking system.
Issue Date: 07/25/06                                                          2515/169
 
2515/169-10        ORIGINATING ORGANIZATION INFORMATION 10.01  Organizational Responsibility This TI was initiated by NRR/Division of           Inspection   &   Regional   Support (DIRS)/Performance Assessment Branch (IPAB).
10.02  Resource Estimate The direct inspection effort to be expended in connection with this TI is estimated to be 30-40 person-hours for a two-unit site.
10.03  Training Training on this TI was conducted in the Regional offices during the second quarter of calendar year 2006. Additional support can be obtained through the Regional contacts.
END 2515/169                                                      Issue Date: 07/25/06
 
Attachment 1 Revision History For TI 2515/169, Mitigating Systems Performance Index Verification Commitment      Issue Date    Description    Training Needed                    Training        Comment Resolution Tracking                      of Change                                        Completion      Accession Number Number                                                                          Date 07/25/06    Temporary        Training was conducted in each of  June 6, 2006    ML060940629 instruction for  the four regions via a two hour conducting      presentation during the regional MSPI data        inspector counterpart meetings.
verifications.
Issue Date: 07/25/06                                          A1-1                                            2515/169, Att 1}}

Latest revision as of 20:23, 23 November 2019

Temporary Instruction 2515/169, Mitigating System Performance Index Verification.
ML060950136
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 07/25/2006
From:
NRC/NRR/ADRO/DIRS/IPAB
To:
Ortega-Luciano, J NRR/DIRS, 415-1159
Shared Package
ML062020769 List:
References
CN-06-017
Download: ML060950136 (9)


Text

NRC INSPECTION MANUAL IPAB TEMPORARY INSTRUCTION 2515/169 MITIGATING SYSTEMS PERFORMANCE INDEX VERIFICATION CORNERSTONE: MITIGATING SYSTEMS APPLICABILITY: This temporary instruction (TI) applies to all holders of operating licenses for light water nuclear power reactors.

2515/169-01 OBJECTIVE The objective of this TI is to verify that licensees have correctly implemented the Mitigating Systems Performance Index (MSPI) guidance for reporting unavailability and unreliability of the monitored safety systems.

2515/169-02 BACKGROUND 02.01 Purpose of the MSPI The MSPI was developed to replace the Safety System Unavailability (SSU) indicators currently in use in the Reactor Oversight Process (ROP). The SSU indicators have several weaknesses, including the following: (1) the use of design basis functions rather than risk-significant functions; (2) the use of thresholds developed from generic plant models rather than from plant-specific models; (3) the use of fault exposure unavailable hours as a surrogate for unreliability rather than monitoring unreliability directly, and (4) the cascading of support system unavailability to the monitored systems rather than monitoring support systems separately. The MSPI monitors the unavailability and the unreliability of the same four safety systems that comprise the SSU; it also monitors the cooling water support systems for those four safety systems. These systems include:

Boiling Water Reactors:

  • Emergency AC (emergency alternating current (EAC))

Issue Date: 07/25/06 2515/169

  • Cooling water support systems (Emergency Service Water (ESW) and component cooling water (CCW) or their equivalents)

Pressurized Water Reactors:

  • Emergency AC (emergency alternating current (EAC))
  • High pressure injection (High Pressure Safety Injection (HPSI))
  • Cooling water support systems (Emergency Service Water (ESW) and component cooling water (CCW) or their equivalents) 2515/169-03 INSPECTION REQUIREMENTS 03.01 General. There are no regulatory requirements for this program and licensee participation is voluntary.

Prior to the April 1, 2006, implementation of MSPI into the ROP, a team of NRC staff and contractors involved in the development of the index, conducted an audit of the licensees bases documents. On a sampling basis, the team selected key aspects of the index to ensure that the licensees followed the MSPI guidelines. The key aspects included:

(1) identification of the correct boundaries; (2) selection of the appropriate components; (3) establishment of baseline unavailability and unreliability information; and (4) resolution of concerns with respect to the individual licensees Probabilistic Risk Assessments.

The purpose of this Temporary Instruction is to validate the unavailability and unreliability input data and to verify accuracy of the first reporting results for the 2006 second quarter.

This Temporary Instruction will be completed by December 31, 2006.

03.02 Credit for Unavailability

a. On a sampling basis, the inspector will review the licensees list of surveillance activities which, when performed, do not render the train unavailable due to the short duration of the activity (less than 15 minutes).
b. On a sampling basis, the inspector will review the licensees list of surveillance activities which, when performed, do not render the train unavailable due to the credit for operator recovery activities as defined by Nuclear Energy Institute (NEI) 2515/169 Issue Date: 07/25/06

99-02 (Regulatory Assessment Performance Indicator Guideline), Revision 4, page F-6.

03.03 Verification of Unavailability and Unreliability Data

a. For each MSPI system, using the general concepts discussed in Section 1.2.2 of Appendix F of NEI 99-02, Revision 4, the inspector will independently determine the baseline planned unavailability hours and confirm that these hours were correctly translated into the basis document.
b. On a sampling basis for each MSPI system, using operating logs, corrective maintenance records, and condition reports, the inspector will confirm that the actual planned and unplanned unavailability data is accurate.
c. On a sampling basis for each MSPI system, based on a review of related maintenance and test history, the inspector will confirm the accuracy of the failure data (demand failures, run/load failures, and failures to meet the risk-significant mission time, as applicable) for the identified monitored components.

2515/169-04 GUIDANCE 04.01 General Although a detailed understanding of how the MSPI index is calculated is not required to conduct this TI, it is important that the inspector becomes familiar with the licensees MSPI bases document. The inspector should be aware of each system boundary and the components that the licensee will be specifically monitoring under the index. The regional MSPI contacts, as well as training on the MSPI, should aid in this understanding.

04.02 Credit for Unavailability.

a. As discussed in Section G.1.7 of Appendix G of NEI 99-02, Revision 4, the licensee will develop a list of any periodic surveillances or evolutions of less than 15 minutes of unavailability that the licensee will not include in the MSPI train unavailability. The intent of this list is to minimize unnecessary burden of data collection, documentation and verification because these short durations have insignificant risk impact. In many cases, the licensee may state none in this section which means that all unavailability resulting from surveillance activities will be counted as train unavailability in the MSPI calculations. For those circumstances where the licensee provides a list in the MSPI basis document, confirmation that the unavailability time is of short duration is necessary.

Therefore, on a sampling basis, the inspector should review the listed surveillance activity and verify the duration of unavailability is less than 15 minutes. This can be accomplished based on the inspectors knowledge of the surveillance or a review of the licensees record keeping on previous surveillances. For example, the licensee may document unavailability in the control room log books. The inspector should review log book entries for a sample of the surveillances to ensure the time period of unavailability is less than 15 minutes.

Issue Date: 07/25/06 2515/169

b. As discussed in Section F.1.2.1 of Appendix F of NEI 99-02, Revision 4, credit for operator recovery actions during testing or operational alignment, or during some maintenance activities can be taken to reduce train unavailability time. The licensee will develop a list of these activities that will not be included in the MSPI train unavailability. With some systems, the licensee may state none which means that the system will not realign itself during surveillance activities or operator actions to recover availability do not meet guidelines. For those circumstances where the licensee provided a list in the MSPI basis document, confirmation that the activities meet the guidelines is necessary. Therefore, on a sampling basis, the inspector should review the listed surveillance activity and verify that the operator actions to recover unavailability are contained in a written procedure and are uncomplicated. This can be accomplished based on the inspectors knowledge of the surveillance or a review of the surveillance or operating procedure.

04.03 Entry of Baseline Data

a. Baseline Planned Unavailability: In developing the baseline unavailability for a train or a segment, the licensee will determine the baseline planned unavailability time based on actual plant specific values for the period of 2002 - 2004. These values are expected to remain fixed unless the licensee changes its maintenance philosophy with respect to online maintenance or preventive maintenance. The licensees calculations for this section will be documented in an Appendix to the MSPI basis document.

The inspector should understand the MSPI system boundaries, particularly the support cooling functions, prior to performing this task. It is important to verify that the licensee has properly accounted for planned and unplanned unavailability resulting from cascading support system inoperability. In most cases, the last valve that connects the cooling water support system to another MSPI system component is included in that MSPI system. Unavailability of this last valve is counted in that MSPI system, not in the cooling water system. In addition, all of the components within the system boundary will contribute to the unavailability time of the system train or segment.

For the cooling water system(s), the inspector will review related work history information, maintenance rule information, corrective action program documents, and surveillance testing to determine periods of time where the licensee planned to make the cooling water system unavailable. On a sampling basis, the inspector should review operating logs and the above information to determine the actual time periods the system was not available due to planned activities. This information should be compared to the licensees assessment and discrepancies should be resolved.

For the remaining systems, the licensee will calculate the plant-specific baseline planned unavailability using the ROP data from 2002-2004. In general, this information will come from previously submitted SSU information and should be available on the ROP website. Using the process stated in Section 1.2.2 of the NEI guidance, the licensee should have developed tables for each train showing 2515/169 Issue Date: 07/25/06

the values used in their calculation. The inspector should verify that the licensee accurately transposed the SSU information into these tables, specifically,(1) total train unavailability hours reported in the SSU; (2) fault exposure hours which were included in the 2002-2004 data; and (3) unplanned unavailability time. Using information from system health reports, corrective action program documents, and maintenance rule information, the inspector should independently confirm the accuracy of the additions and deletions from this data. For example, on a sampling basis, the inspector will review operator logs and maintenance records as necessary to verify the number of hours the licensee added for planned overhauls which had not been included in the SSU calculation. The inspector will confirm that the planned unavailability time listed in the plant-specific spread sheet did occur and will confirm that planned unavailability time described in the logs/condition reports is counted. It is key that the inspector confirm that the licensee did not double subtract hours. For example, if unplanned unavailability occurred due to low cooling water flow to a pump, the licensee should not subtract these hours in both steps 2 and 7 of the process stated in Section 1.2.2 of the NEI guidance.

The inspector will confirm the licensees estimated critical hours reported by comparing that estimate with the critical hours reported in the Scrams per 7,000 Critical Hours performance indicator (PI) or the critical hours reported in the monthly operating reports.

The inspector shall verify that the baseline planned unavailability information was correctly translated to the consolidated data entry (CDE) input sheet.

b. Actual Performance Data - Unavailability: The actual performance data covers a 12 quarter period. Because of the overlap with the baseline unavailability time (the 2002-2004 data in the above activity), it is necessary only to verify the data for the 2005-2006 time period in this section.

Because Inspection Procedure 71151, Performance Indicator Verification, was not performed for the mitigating systems in calendar year 2005, the information presented by the licensee in the SSU needs to be verified. Therefore, the inspector shall first determine the accuracy and completeness of the reported unavailability data by reviewing out-of-service logs, operating logs, and the maintenance rule database. In addition to the review of these records, the inspector should, in conjunction with inspections in other inspectable areas, verify planned, unplanned, or fault exposure unavailable hours for the system under review. Related inspectable areas under which inspectors can review unavailability determinations include equipment alignment, emergent work, maintenance rule implementation, and maintenance work prioritization and control.

Once the accuracy of the SSU information is verified, the inspector should confirm that the licensee accurately determined the MSPI unavailability. The inspector should verify the following information was recorded in the CDE input:

1. For the 2003 and 2004 data, the total unavailability time would include the planned, as determined in section 04.03a of this procedure, and the Issue Date: 07/25/06 2515/169

unplanned unavailability, which was previously subtracted in step 3 of section 1.2.2 of the NEI guidance.

2. For the 2005 and 2006 data, the inspector should confirm that the licensee did not include any fault exposure hours or unavailability hours while the reactor was not critical.
c. Actual Performance Data - Unreliability: Using Section F.2.2.2 of Appendix F of NEI 99-02, Revision 4, the inspector will verify the licensee appropriately identified the failures of the monitored components. Determination of a failure is defined using the success criteria found in the licensees basis document. It is important to note that the MSPI success criteria may be less conservative than the licensing bases. For example, the MSPI success criteria may require a flow rate of 450 gpm, whereas Technical Specifications may require 500 gpm. If the surveillance as-found condition is 475 gpm, the pump will be TS inoperable; however, the pump would still be capable of fulfilling its MSPI function.

For each MSPI monitored component, the inspector should gather background information such as condition reports or system health information to determine periods of time in which individual components failed to operate properly. The unreliability component for valves include only failures on demand. The unreliability component for pumps include both failures on demand and failures to meet the risk-significant mission time. The unreliability component for emergency diesel generators include failures on demand, failures to load/run, and failures to meet the risk-significant mission time. On a sampling basis, the inspector should verify that the licensee captured these failures accurately in its documentation.

Discovered conditions of non-monitored components that render the system/train from performing its MSPI stated function, whether originating in the monitored system or not, require special consideration. These situations are covered in detail in the MSPI training slides that can be located under the ROP link on the internal website (Digital City). Situations not covered by the training slide examples should be resolved between the inspector and the MSPI regional contact.

2515/169-05 REPORTING REQUIREMENTS The results of this Temporary Instruction should be included in Section 4OA4 of an integrated inspection report and should be forwarded to the Region contact person listed in this Temporary Instruction. The following questions and answers should be documented:

1. For the sample selected, did the licensee accurately document the baseline planned unavailability hours for the MSPI systems?
2. For the sample selected, did the licensee accurately document the actual unavailability hours for the MSPI systems?

2515/169 Issue Date: 07/25/06

3. For the sample selected, did the licensee accurately document the actual unreliability information for each MSPI monitored component?
4. Did the inspector identify significant errors in the reported data, which resulted in a change to the indicated index color? Describe the actual condition and corrective actions taken by the licensee, including the date when the revised PI information was submitted to the NRC.
5. Did the inspector identify significant discrepancies in the basis document which resulted in (1) a change to the system boundary; (2) an addition of a monitored component; or (3) a change in the reported index color? Describe the actual condition and corrective actions taken by the licensee, including, the date of when the bases document was revised.

2515/169-06 COMPLETION SCHEDULE This TI should be completed on or before December 31, 2006.

2515/169-07 EXPIRATION This TI will expire on December 31, 2006. Before that date, this TI should be performed once at each licensee facility, where applicable.

2515/169-08 CONTACT For questions regarding the performance of this TI and emergent issues, contact John Thompson (301-415-1011, jwt1@nrc.gov) or Regional Contacts:

Region I Christopher Cahill 610-337-5108 cgc@nrc.gov Region II Walt Rogers 404-562-4619 wgr1@nrc.gov Region III Sonia Burgess 630-829-9752 sdb2@nrc.gov Region IV Michael Runyan 817-860-8142 mfr@nrc.gov 2515/169-09 STATISTICAL DATA REPORTING All direct inspection effort expended on this TI is to be charged to 2515/169 for reporting by the HRMS system with an IPE code of SI.

Per memorandum dated January 20, 2006, from Mr. Michael J. Case, Director, Division of Inspection and Regional Support, Office of Nuclear Reactor Regulation to the Regional Deputy Administrators, performance indicators MS01, MS02, MS03, and MS04 will not be inspected during CY 2006 as this Temporary Instruction evaluates equipment availability and reliability data. Therefore, no samples will be included in the RPS inspection tracking system.

Issue Date: 07/25/06 2515/169

2515/169-10 ORIGINATING ORGANIZATION INFORMATION 10.01 Organizational Responsibility This TI was initiated by NRR/Division of Inspection & Regional Support (DIRS)/Performance Assessment Branch (IPAB).

10.02 Resource Estimate The direct inspection effort to be expended in connection with this TI is estimated to be 30-40 person-hours for a two-unit site.

10.03 Training Training on this TI was conducted in the Regional offices during the second quarter of calendar year 2006. Additional support can be obtained through the Regional contacts.

END 2515/169 Issue Date: 07/25/06

Attachment 1 Revision History For TI 2515/169, Mitigating Systems Performance Index Verification Commitment Issue Date Description Training Needed Training Comment Resolution Tracking of Change Completion Accession Number Number Date 07/25/06 Temporary Training was conducted in each of June 6, 2006 ML060940629 instruction for the four regions via a two hour conducting presentation during the regional MSPI data inspector counterpart meetings.

verifications.

Issue Date: 07/25/06 A1-1 2515/169, Att 1