IP 71111.15, Operability Determinations and Functionality Assessments
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
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)
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
Yes
12/31/14
FBF 71111.15-1742
FBF 71111.15-1974
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