IP 71111.15, Operability Determinations and Functionality Assessments
Operability Determinations and Functionality Assessments
- 2020 - https://www.nrc.gov/docs/ML2023/ML20238B973.pdf
- 2016 - https://www.nrc.gov/docs/ML1614/ML16147A250.pdf
- 2012 - https://www.nrc.gov/docs/ML1120/ML112010663.pdf
text
Issue Date: 10/05/20 1 71111.15
NRC INSPECTION MANUAL IRIB
INSPECTION PROCEDURE 71111 ATTACHMENT 15
OPERABILITY DETERMINATIONS AND FUNCTIONALITY ASSESSMENTS
Effective Date: 01/01/2021
PROGRAM APPLICABILITY: IMC 2515 A
CORNERSTONES: Mitigating Systems
INSPECTION BASES: See IMC 0308 Attachment 2
SAMPLE REQUIREMENTS
Sample Requirements Minimum Baseline Completion
Sample Requirements Budgeted Range Sample Type Section Frequency Sample Size Samples Hours Operability Determination or Functionality Assessment 03.01 Annual 15 at one reactor unit sites 15 to 21 at one reactor unit sites 87 to 113 hours0.00131 days <br />0.0314 hours <br />1.868386e-4 weeks <br />4.29965e-5 months <br /> at one reactor unit sites 19 at two reactor unit sites1 19 to 25 at two reactor unit sites 107 to 137 hours0.00159 days <br />0.0381 hours <br />2.265212e-4 weeks <br />5.21285e-5 months <br /> at two reactor unit site 9 at Vogtle Units 3 & 4 9 to 11 at Vogtle Units 3 & 4 50 to 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> at Vogtle Units 3 & 4 22 at three reactor unit sites 22 to 30 at three reactor unit sites 127 to 161 hours0.00186 days <br />0.0447 hours <br />2.662037e-4 weeks <br />6.12605e-5 months <br /> at three reactor unit sites
71111.15-01 INSPECTION OBJECTIVE
To review operability determinations of technical specification (TS) SSCs (including support
systems as defined in the TS) or functionality assessments associated with non-TS SSCs
affecting mitigating systems and barrier integrity to ensure that operability or functionality is
1 Also applicable to Vogtle Units 1 & 2
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 GENERAL GUIDANCE
Selection of operability determinations or functionality assessments should involve risk
significant SSCs. Operability is a term solely associated with TS compliance. Functionality
assessments do not involve compliance with TS. Inspectors should apply risked informed
insights together with other factors, such as engineering analysis and judgment, operating
experience, and performance history, to determine which operability determinations or
functionality assessments should be selected for review. Selection of operability determinations
or functionality assessments can emerge from the inspector's review of plant status documents
such as operator shift logs, emergent work documentation, deferred modifications, and standing
orders to determine if an operability determination or functionality assessment is warranted for a
degraded or nonconforming condition.
The following can be used to assist the inspector in identifying SSCs that have a risk priority:
Operating - Mitigating systems and barrier integrity features as determined by
plant-specific risk information such Risk Achievement Worth. Examples: High Pressure
Coolant Injection (HPCI) system or Reactor Core Isolation Cooling (RCIC) system.
Shutdown - Mitigating systems and barrier integrity features that perform key safety
functions during shutdown. Examples: SSCs associated with decay heat removal,
inventory control, electrical power availability, reactivity control, core configuration, or
containment.
IMC 0326, “Operability Determinations” provides guidance to NRC inspectors to assist in their
review of licensee determinations of operability. This section contains excerpts and discussions
from IMC 0326. More detailed information can be found in IMC 0326. IMC 0326 no longer
contains guidance on assessments of functionality. However, pertinent guidance is retained in
this Inspection Procedure (IP). In addition, Attachment 1 of this IP contains a high-level visual
representation of Operability Determinations / Functionality Assessments as they relate to SSCs
described and in the TS and SSCs not described in the TS.
Operability refers to the capability of a TS SSC to perform its specified safety function. The
scope of SSCs considered within the operability determination process are: 1) SSCs that are
required to be operable by TS (these SSCs may perform required support functions for other
SSCs required to be operable by TS); and 2) SSCs that are not explicitly required to be
operable by TS, but that perform support functions as defined in the TS for SSCs required to be
operable by TS.
Operability determinations are appropriate whenever a condition calls into question the ability of
an SSC to perform its specified safety functions. The operability determination process is used
to assess operability of SSCs and their support functions for compliance with TS when a
condition is identified for a specific SSC required to be operable by TS, or when a condition is
identified which impacts a necessary and related support function. Ensuring operability for any
SSC described in TSs is a continual process. Licensees should evaluate operability upon
discovery of a condition that results in the loss of the presumption of operability.
Functionality assessments generally refers to the capability of a non-TS SSC to perform its
function set forth in the CLB. Functionality assessments may be performed for SSCs not
described in TS, but which warrant programmatic controls to ensure that SSC availability and
reliability are maintained. In general, these SSCs and the related controls are included in
programs related to Appendix B to 10 CFR Part 50, “Quality Assurance Criteria for Nuclear
Power Plants and Fuel Reprocessing Plants,” and the maintenance rule (10 CFR 50.65).
Additionally, SSCs not described in TS may warrant functionality assessments within the
processes used to address conditions because they perform functions described in the Updated
Final Safety Analysis Report (UFSAR), technical requirements manual, emergency plan, fire
protection plan, regulatory commitments, or other elements of the CLB.
Normally, functionality is assessed and documented through other plant processes such as the
corrective action process. It is appropriate to consider safety significance in determining the
appropriate depth of a functionality assessment. Also, the effect of nonfunctional SSCs on
compliance with other regulatory requirements (e.g., Appendix R, station blackout, ATWS,
environmental qualification, maintenance rule) should be determined. In addition, other licensee
processes and programs may need to be considered (e.g., availability, maintenance rule,
reportability) when SSCs are not functional.
When evaluating the effect of a condition, a licensee may decide to implement compensatory
measures as an interim action until final corrective action to resolve the condition is completed.
IMC 0326 contains guidance on the use of compensatory measures. In addition, compensatory
measures that substitute manual operator actions for automatic actions should be resolved
expeditiously. IMC 0326 contains additional guidance on the temporary use of manual actions
instead of automatic actions. A licensee may refer to these compensatory measures as
“Operator Work Arounds (OWAs).”
In addition, if a compensatory measure involves a temporary facility or procedure change,
10 CFR 50.59 should be applied to the temporary change with the intent to determine whether
the temporary change/compensatory measure itself (not the condition) impacts other aspects of
the facility or procedures described in the UFSAR. In considering whether a temporary facility
or procedure change impacts other aspects of the facility, a licensee should apply 10 CFR 50.59, paying particular attention to ancillary aspects of the temporary change that result from
actions taken to directly compensate for the condition. Licensees may use the guidance in NEI 96-07, Revision 1, “Guidelines for Implementing 10 CFR 50.59,” which is endorsed by
Regulatory Guide 1.187, “Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and
Experiments.” NEI has also published a NEI 96-07, Revision 1, Appendix E, “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
For each sample, a routine review of problem identification and resolution activities should be
conducted. Consider if the licensee is identifying problems with operability determinations and
functionality assessments at an appropriate threshold, entering them in the corrective action
program, and is identifying and implementing appropriate corrective actions. IP 71152,
“Problem Identification and Resolution,” contains background information with regards to
conducting reviews of Problem Identification and Resolution activities during the conduct of
baseline inspection procedures.
71111.15-03 INSPECTION SAMPLES
03.01 Review the licensee’s operability determination or functionality assessment to
verify that operability or functionality is justified and that the licensee is taking
appropriate actions.
Specific Guidance
The intent of this inspection is to sample licensee’s operability determinations and functionality
assessments for risk significant SSCs to determine if operability determinations and functionality
assessments are justified, such that operability and/or availability are assured, and no
unrecognized increase in risk has occurred. Also, the inspections should determine if
operability and functionality concerns associated with plant issues and events are being
identified. Inspectors should consider the following aspects:
- The selected operability determination or functionality assessment has appropriately
considered the potential cause(s), extent of the condition, and adverse effects on
associated SSC specified safety functions or CLB functions. Refer to the updated final
safety analysis report (UFSAR) and other design basis documents during the review.
- The licensee is looking beyond the prominent symptoms of the condition to ensure that
a narrow focus or non-conservative assumption does not compromise the justification
that the SSC remains capable of performing its specified safety functions or CLB
functions.
- If the operability or functionality assessment involves compensatory measures: The
measures are in place, work as intended, do not cause system operation in a manner
inconsistent with the specified safety function or CLB function, and are appropriately
controlled. The licensee is considering other conditions and their impact on any
compensatory measures for the condition being evaluated. The licensee is
considering whether use of a compensatory measure requires a license amendment.
- If operability or functionality are not justified, appropriate actions are taken including a
determination of impact on any TS limiting condition for operation (LCO).
Depending on the complexity and risk significance of an issue, an inspector may consider
consulting with regional specialists to complete a review of a licensee’s operability determination
or functionality assessment. The regional specialist’s time spent on reviewing the issue should
be charged to this procedure.
71111.15-04 REFERENCES
IP 71152, “Problem Identification and Resolution”
IMC 0326, “Operability Determinations”
IMC 2515, “Light-Water Reactor Inspection Program - Operations Phase”
Issue Date: 10/05/20 5 71111.15
10 CFR 50.59, “Changes, tests, and experiments.”
NRC Regulatory Guide 1.187, “Guidance for Implementation of 10 CFR 50.59, Changes, Test,
and Experiments,” Nov 2000. (ML003759710)
NEI 96-07, Revision 1, “Guidelines for 10 CFR 50.59 Evaluations,” (Nov 2000). (ML003771157)
END
Issue Date: 10/05/20 Att1-1 71111.15
Attachment 1: Operability Determinations / Functionality Assessments of SSCs
Structures, Systems, and Components (SSCs)
SSCs described in TS
➢ Subject to operability
determinations.
➢ SSC can perform its
specified safety
function(s).
➢ NRC guidance found in
SSCs not described in
Technical Specifications (TS)
➢ Subject to functionality
requirements of the
current licensing basis
(CLB).
➢ Also performs necessary
and related support
functions for TS SSCs?
If yes, such functions are
within scope of
Issue Date: 10/05/20 Att2-1 71111.15
Attachment 2 - 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 Resolution
and Closed Feedback
Form Accession
Number (PreDecisional, Non-Public
Information)
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: 10/05/20 Att2-2 71111.15
Commitment
Tracking
Number
Accession
Number
Issue Date
Change Notice
Description of Change Description of
Training Required
and Completion
Date
Comment Resolution
and Closed Feedback
Form Accession
Number (PreDecisional, Non-Public
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
Yes
12/31/14
FBF 71111.15-1742
FBF 71111.15-1974
Issue Date: 10/05/20 Att2-3 71111.15
Commitment
Tracking
Number
Accession
Number
Issue Date
Change Notice
Description of Change Description of
Training Required
and Completion
Date
Comment Resolution
and Closed Feedback
Form Accession
Number (PreDecisional, Non-Public
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
N/A ML19113A142
04/30/19
CN 19-013
Editorial revision to support proposed modification
to RPS-Inspections for tracking inspection activity /
completion.
None N/A - Editorial change
issued without
comment period.
N/A ML19199A089
12/20/19
CN 19-041
Revisions are made to: (1) conform to new IP format
requirements found in IMC 0040 (ML18003A122),
and (2) reflect revisions to IMC 0326.
None ML19259A079
N/A ML20238B973
10/05/20
CN 20-046
Revisions are made to: (1) add inspection samples
specifically for Vogtle 3 & 4 as identified in SECY20-0050, “Planned Revisions To The Baseline
Inspection Program For The AP1000 Reactor
Design,” (ML20058F491), and (2) remove guidance
associated with tornado missile protection
compliance issues due to expiration of enforcement
discretion.
None ML20239A738