IP 71111.15, Operability Determinations and Functionality Assessments

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Operability Determinations and Functionality Assessments

https://www.nrc.gov/docs/ML1614/ML16147A250.pdf

text

Issue Date: 12/22/16 1 71111.15

NRC INSPECTION MANUAL IRIB

INSPECTION PROCEDURE 71111 ATTACHMENT 15

OPERABILITY DETERMINATIONS AND FUNCTIONALITY ASSESSMENTS

Effective Date: January 1, 2017

INSPECTABLE AREA: Operability Determinations and Functionality Assessments

CORNERSTONES: Mitigating Systems

Barrier Integrity

INSPECTION BASES: Improperly evaluated degraded and/or non-conforming conditions

may result in continued operation with a structure, system, or

component (SSC) that is inoperable or nonfunctional.

This inspectable area verifies aspects of the Mitigating Systems and

Barrier Integrity cornerstones for which there are no performance

indicators.

LEVEL OF EFFORT: Review the following sample sizes of operability determinations or

functionality assessments of degraded and non-conforming

conditions which impact mitigating systems and barrier integrity: 15

to 21 per year at one reactor unit sites; 19 to 25 per year at two

reactor unit sites; and 22 to 30 per year at three reactor unit sites.

71111.15-01 INSPECTION OBJECTIVE

To review operability determinations or functionality assessments affecting mitigating systems

and barrier integrity to ensure that operability or functionality is properly justified and the SSC

remains capable of performing its specified safety function or current licensing basis (CLB)

function, such that no unrecognized increase in risk has occurred.

71111.15-02 INSPECTION REQUIREMENTS

02.01 Sample Selection

Select operability determinations or functionality assessments involving risk significant SSCs.

02.02 Inspection

a. Review the technical adequacy of the licensee’s operability determination or

functionality assessment, and verify it is justified.

b. If the operability or functionality evaluation involves compensatory measures:

1. Verify that the measures are in place, will work as intended, do not cause system operation to be outside the design basis and are appropriately controlled, and
2. Verify that use of a compensatory measure does not require a license amendment.

NOTE: NEI 96-07, Revision 1, Appendix E shall not be used by NRC staff in

evaluating compliance with the provisions of 10 CFR 50.59.

c. If operability or functionality are not justified, verify appropriate actions are taken

including a determination of impact on any Technical Specification (TS) limiting

condition for operation (LCO).

02.03 Problem Identification and Resolution

Verify that the licensee is identifying problems with operability determinations and functionality

assessments at an appropriate threshold, entering them in the corrective action program, and is

identifying and implementing appropriate corrective actions.

71111.15-03 INSPECTION GUIDANCE

03.01 Sample Selection

Inspectors should apply risked informed insights together with other factors, such as

engineering analysis and judgment, operating experience, and performance history, to

determine which operability determinations or functionality assessments should be selected for

review. Selection of operability determinations or functionality assessments can emerge from

the inspector's review of plant status documents such as operator shift logs, emergent work

documentation, deferred modifications, and standing orders to determine if an operability

determination or functionality assessment is warranted for a degraded or nonconforming

condition.

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

Operating - Mitigating systems and barrier integrity features as determined by plantspecific risk information such Risk Achievement Worth. Examples: High Pressure

Coolant Injection (HPCI) system or Reactor Core Isolation Cooling (RCIC) system.

Shutdown - Mitigating systems and barrier integrity features that perform key safety

functions during shutdown. Examples: SSCs associated with decay heat removal,

inventory control, electrical power availability, reactivity control, core configuration, or

containment.

03.02 Inspection

IMC 0326, “Operability Determinations and Functionality Assessments for Conditions Adverse

to Quality or Safety” provides guidance to NRC inspectors to assist in their review of licensee

determinations of operability, assessments of functionality, and resolution of degraded and

nonconforming conditions. This section contains excerpts and discussions from IMC 0326.

More detailed information can be found in IMC 0326.

The identification of degraded or nonconforming conditions may call into question the ability of a

SSC to perform its specified safety function or CLB function. A degraded condition is one in

which the qualification of an SSC or its functional capability is reduced. Examples of degraded

conditions are failures, malfunctions, deficiencies, deviations, and defective material and

equipment. Examples of conditions that can reduce the capability of a system are aging,

erosion, corrosion, improper operation, and maintenance. A nonconforming condition is a

condition of an SSC that involves a failure to meet the CLB or a situation in which quality has

been reduced because of factors such as improper design, testing, construction, or modification.

The following are examples of nonconforming conditions: 1) An SSC fails to conform to one or

more applicable codes or standards (e.g., the CFR, operating license, TS, UFSAR, and/or

licensee commitments); 2) An as-built or as-modified SSC does not meet the CLB; 3) Operating

experience or engineering reviews identify a design inadequacy; or 4) Documentation required

by NRC requirements such as 10 CFR 50.49 is unavailable or deficient.

Operability refers to the capability of a TS SSC to perform its specified safety function. The

scope of SSCs considered within the operability determination process are: 1) SSCs that are

required to be operable by TS (these SSCs may perform required support functions for other

SSCs required to be operable by TS); and 2) SSCs that are not explicitly required to be

operable by TS, but that perform required support functions for SSCs that are required to be

operable by TS.

Determinations of operability are appropriate whenever a review, TS surveillance, or other

information calls into question the ability of SSCs to perform specified safety functions. The

operability determination process is used to assess operability of SSCs and their support

functions for compliance with TS when a degraded or nonconforming condition is identified for a

specific SSC required to be operable by TS, or when a degraded or nonconforming condition is

identified for a necessary and related support function. The licensee’s process of ensuring

operability for any SSC described in TSs is a continual process.

Functionality generally refers to the capability of a non-TS SSC to perform its function set forth

in the CLB. A CLB function may also perform a necessary and related support function for a

SSC controlled by TS. Functionality assessments should be performed for SSCs not described

in TS, but which warrant programmatic controls to ensure that SSC availability and reliability are

maintained. In general, these SSCs and the related controls are included in programs related to

Appendix B to 10 CFR Part 50, “Quality Assurance Criteria for Nuclear Power Plants and Fuel

Reprocessing Plants,” and the maintenance rule (10 CFR 50.65). Additionally, SSCs not

described in TS may warrant functionality assessments within the processes used to address

degraded and nonconforming conditions because they perform functions described in the

Updated Final Safety Analysis Report (UFSAR), technical requirements manual, emergency

plan, fire protection plan, regulatory commitments, or other elements of the CLB.

Determinations of functionality are appropriate whenever a review, TS surveillance, or other

information calls into question the ability of an SSC not required to be operable by TS to perform

its CLB function(s). As stated above, a CLB function may also perform a necessary and related

support function for a SSC controlled by TS. Normally, functionality is assessed and

documented through other plant processes such as the corrective action process. It is

appropriate to consider safety significance in determining the appropriate depth of a functionality

assessment. Also, the effect of nonfunctional SSCs on compliance with other regulatory

requirements (e.g., Appendix R, station blackout, ATWS, environmental qualification,

maintenance rule) should be determined. In addition, other licensee processes and programs

may need to be considered (e.g., availability, maintenance rule, reportability) when SSCs are

not functional.

When evaluating the effect of a degraded or nonconforming condition, a licensee may decide to

implement compensatory measures as an interim action until final corrective action to resolve

the condition is completed. Section 07.03 of IMC 326 contains guidance on the use of

compensatory measures. In addition, compensatory measures that substitute manual operator

actions for automatic actions should be resolved expeditiously. Appendix C.05 of IMC 0326

contains additional guidance on the temporary use of manual actions instead of automatic

actions. A licensee may refer to these compensatory measures as “Operator Work Arounds

(OWAs).”

In addition, if a compensatory measure involves a temporary facility or procedure change, 10 CFR 50.59 should be applied to the temporary change with the intent to determine whether the

temporary change/compensatory measure itself (not the degraded or nonconforming condition)

impacts other aspects of the facility or procedures described in the UFSAR. In considering

whether a temporary facility or procedure change impacts other aspects of the facility, a

licensee should apply 10 CFR 50.59, paying particular attention to ancillary aspects of the

temporary change that result from actions taken to directly compensate for the degraded

condition. Licensees may use the guidance in NEI 96-07, Revision 1, “Guidelines for

Implementing 10 CFR 50.59,” which is endorsed by Regulatory Guide 1.187, “Guidance for

Implementation of 10 CFR 50.59, Changes, Tests, and Experiments.” NEI has also published a

NEI 96-07, Revision 1, Appendix E, “User’s Guide for NEI 96-7, Revision 1, Guidelines for 10 CFR 50.59 Implementation.” However, NEI 96-07, Revision 1, Appendix E has not been

reviewed or endorsed by the NRC. If needed, questions regarding potential 10 CFR 50.59

issues as a result of a licensee’s use of Appendix E can be raised with the DORL PM.

The intent of this inspection is to sample licensee’s operability determinations and functionality

assessments for risk significant SSCs to determine if prompt and immediate operability

determinations and functionality assessments are justified, such that operability and availability

are assured, and no unrecognized increase in risk has occurred. Also, the inspections should

determine if operability and functionality concerns associated with plant issues and events are

being identified. Aspects that an inspector should consider include:

 The selected operability determination or functionality assessment has appropriately

considered the potential cause(s), extent of the condition, and adverse effects on

associated SSC specified safety functions or CLB functions. Refer to the updated final

safety analysis report (UFSAR) and other design basis documents during the review.

Issue Date: 12/22/16 5 71111.15

 The licensee is looking beyond the prominent symptoms of the condition to ensure that

a narrow focus or non-conservative assumption does not compromise the justification

that the SSC remains capable of performing all of its specified safety functions or CLB

functions.

 The licensee is considering other conditions and their impact on any compensatory

measures for the condition being evaluated.

Depending on the complexity and risk significance of an issue, an inspector may consider

consulting with regional specialists to complete a review of a licensee’s operability determination

or functionality assessment. The regional specialist’s time spent on reviewing the issue should

be charged to this procedure.

03.03 Problem Identification and Resolution

For additional guidance, see Inspection Procedure (IP) 71152, “Problem Identification and

Resolution.”

71111.15-04 RESOURCE ESTIMATES

The annual resource expenditure for this inspection procedure is estimated to be 87 to 113

hours for sites with one reactor unit; 107 to 137 hours0.00159 days <br />0.0381 hours <br />2.265212e-4 weeks <br />5.21285e-5 months <br /> for sites with two reactor units; and 127 to

161 hours0.00186 days <br />0.0447 hours <br />2.662037e-4 weeks <br />6.12605e-5 months <br /> for sites with three reactor units.

71111.15-05 PROCEDURE COMPLETION

Inspection of the minimum sample size will constitute completion of this procedure in the

Reactor Programs System (RPS) inspection tracking system. That minimum sample size will

consist of 15, 19, and 22 operability determinations or functionality assessments of degraded

and non-conforming conditions in a year at 1-unit, 2-unit, and 3-unit sites, respectively. Refer to

IMC 2515, “Light-Water Reactor Inspection Program - Operations Phase” for further guidance

on procedure completion.

71111.15-06 REFERENCES

IP 71152, “Problem Identification and Resolution”

IMC 0326, “Operability Determinations and Functionality Assessments for Conditions Adverse

to Quality or Safety”

IMC 2515, “Light-Water Reactor Inspection Program - Operations Phase”

10 CFR 50.59, “Changes, tests, and experiments.”

Issue Date: 12/22/16 6 71111.15

NRC Regulatory Guide 1.187, “Guidance for Implementation of 10 CFR 50.59, Changes, Test,

and Experiments,” Nov 2000. (ML003759710)

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

END

Issue Date: 12/22/16 Att1-1 71111.15

Attachment 1 - Revision History for IP 71111.15

Commitment

Tracking

Number

Accession

Number

Issue Date

Change Notice

Description of Change Description of

Training Required

and Completion

Date

Comment and

Feedback Resolution

Accession Number

(Pre-Decisional, NonPublic Information)

ML003729444

04/03/00

CN 00-003

Initial Issuance Yes

N/A ML020380579

01/17/02

CN 02-001

Revised to provide minor clarifications to inspection

requirements and additional inspection guidance

concerning operability determinations. In addition,

inspection resource estimates and inspection level

of effort are revised to provide a band for more

inspection

N/A N/A

N/A ML040690557

02/02/04

CN 04-003

Revised to include deferred modifications to the

inspection sampling list.

N/A N/A

N/A ML060060380

01/05/06

CN 06-001

Increased the estimated resources required to

complete this inspection activity based on increased

inspection hours charged to this IP during last

several ROP cycles. Completed historical CN

search.

N/A N/A

N/A ML061730334

07/26/06

CN 06-018

Revised to reflect changes of reference documents:

GL91-18 was superseded by RIS 2005-20.

Revision history reviewed for the last four years.

N/A N/A

N/A ML073050448

01/31/08

CN 08-005

Add inspection guidance to verify that licensee has

correctly implemented 10 CFR 50.59 regulatory

requirements if operability determinations warrant

such 50.59 evaluations be performed.

N/A N/A

Issue Date: 12/22/16 Att1-2 71111.15

Commitment

Tracking

Number

Accession

Number

Issue Date

Change Notice

Description of Change Description of

Training Required

and Completion

Date

Comment and

Feedback Resolution

Accession Number

(Pre-Decisional, NonPublic Information)

N/A ML092300320

11/16/09

CN 09-027

Added 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of inspection resources. See 2009

ROP Realignment Results (ML092090312)

N/A N/A

N/A ML110030073

04/05/11

CN 11-005

This change clarifies and enhances the sample

selection guidance related to functionality

assessments associated with TS SSC operability

determinations and provides the additional latitude

to select risk significant SSCs which may not be

identified in TS for sampling (71111.15 – 1597).

Added the definition of a degraded condition

(71111.15 – 1625).

N/A ML110630221

N/A ML112010663

10/28/11

CN 11-025

Resources changed to reflect the 2011 ROP

Realignment (ML11178A329).

N/A N/A

N/A ML14260A356

12/17/14

CN 14-030

1. Relocate operator workaround from IP 71152 per

BIP Enhancement Project Encl. 5 Operability

Recommendation 1; 2. Delete 02.01.f. as it is

redundant with IMC 0612 App. B; 3. Update

71111.15-06 REFERENCES;

This revision addresses or partially addresses

ROPFF #’s 71111.15-1742, 71111.15-1974, and

beyond-scope administrative comments that were

accepted during 30-day comment process

(ML14287A037)

Yes

12/31/14

ML14287A037

FBF 71111.15-1742

ML14351A020

FBF 71111.15-1974

ML14351A022

Issue Date: 12/22/16 Att1-3 71111.15

Commitment

Tracking

Number

Accession

Number

Issue Date

Change Notice

Description of Change Description of

Training Required

and Completion

Date

Comment and

Feedback Resolution

Accession Number

(Pre-Decisional, NonPublic Information)

N/A ML16147A250

12/22/16

CN 16-035

Revisions are made to address use of mandatory

and discretionary language concerns and

recommendations found in OIG-16-A-12

(ML16097A515). Requirement to inspect at least

one sample associated with OWAs has been

deleted.

None ML16158A083