**ATTACHMENT 71111.20**

INSPECTABLE AREA: Refueling and Other Outage Activities

CORNERSTONES: Initiating Events (20%)

> Mitigating Systems (70%)
>
> Barrier Integrity (10%)

INSPECTION BASES: Shutdown risk can be high for deficiencies that occur
when vital SSCs are not available. Due to potentially high number of
out‑of­‑service SSCs during the fuel handling period of a refueling
outage and the potential off‑normal plant configurations during non‑fuel
handling outage periods, the risk of deficiencies can be high. Times of
reduced inventory are the most critical.

LEVEL OF EFFORT: The inspection is performed on an outage basis, whether
the outage is for refueling or other activities. The inspection should
focus on potential deficiencies with: RHR, containment isolation during
reduced water inventory, mid‑loop operations (PWR),
cooldown/heatup/startup, availability of alternate power
sources/switchyard, and refueling operations. All inspection sections
are to be conducted for refueling outages, if possible. For
non‑refueling outages, the inspectors should perform applicable
non‑refueling related sections consistent with the length and scope of
the outage.

> The requirement to enter IP 71111.20 should be if any shutdown occurs
> that requires a plant cool down and/or if the containment is entered
> for a shutdown tour. If a non-complicated reactor trip occurs, and the
> licensee chooses to conduct a start up without entering the
> containment, then IP71153 should be utilized for inspection of the
> event, corrective actions, and start up activities. This distinction
> also applies to the Resource Estimate and Completion Status sections.

71111.20‑01 INSPECTION OBJECTIVE

01.01 Evaluate licensee outage activities to verify that licensees
consider risk in

developing outage schedules; adhere to administrative risk reduction
methodologies they develop to control plant configuration; have
developed mitigation strategies for losses of key safety functions; and
adhere to operating license and technical specification requirements
that ensure defense‑in‑depth.

01.02 Ensure areas not accessible during at‑power operations are
inspected to verify

that safety‑related and risk significant SSCs are maintained in an
operable condition.

01.03 Evaluate licensee activities during reduced inventory and mid‑loop
conditions to

ensure that they appropriately manage risk using the commitments in
their response to GL 88‑17.

71111.20‑02 INSPECTION REQUIREMENTS

02.01. [Review of Outage Plan]{.underline}. Prior to the outage, review
the licensee=s outage risk

control plan and verify that the licensee has appropriately considered
risk, industry experience and previous site specific problems. Confirm
the licensee has mitigation/response strategies for losses of key safety
functions.

02.02 [Monitoring of Shutdown Activities]{.underline}. Observe portions
of the cooldown process to

verify that technical specification cooldown restrictions are followed.
If the outage allows an opportunity for containment entry, the inspector
should conduct a thorough containment walkdown as soon as reasonably
possible after shutdown to verify that structures, piping, and supports
in containment do not include stains or deposited material that could
indicate previously unidentified leakage from components containing
reactor coolant. Consideration should also be given to inspect other
plant areas which are inaccessible during power operations for evidence
of leakage and integrity of structures, systems, and components.

02.03 [Licensee Control of Outage Activities]{.underline}. Verify that
the licensee maintains defense­

in‑depth commensurate with the outage risk control plan for key safety
functions and applicable technical specifications when taking equipment
out of service. Verify that configuration changes due to emergent work
and unexpected conditions are controlled in accordance with the outage
risk control plan. For plants that use remote work centers, verify that
control room operators are kept cognizant of plant configuration.

Pick several items per week in the following areas based on risk.
Reviewing risk significant items or activities should take precedence
over completion of the list.

a.  [Clearance Activities]{.underline}. Verify that tags are properly
    hung and/or removed, and that associated equipment is appropriately
    configured to support the function of the clearance. Verify
    implementation of licensee procedures for foreign material
    exclusion.

b.  [Reactor Coolant System Instrumentation]{.underline}. Verify that
    reactor coolant system (RCS) pressure, level, and temperature
    instruments are installed and configured to provide accurate
    indication; and that instrumentation error was accounted for. Verify
    that instruments track with changes in plant conditions.

c.  [Electrical Power]{.underline}. Verify that the status and
    configurations of electrical systems meet technical specifications
    requirements and the licensee=s outage risk control plan. Verify
    that switchyard activities are controlled commensurate with safety
    and are consistent with the licensee=s outage risk control plan
    assumptions.

d.  [Decay Heat Removal (DHR) System Monitoring]{.underline}. Observe
    DHR parameters to verify that the system is properly functioning.
    For PWRs, when the licensee is relying on the steam generators to
    provide a backup means of DHR by single­phase natural circulation,
    verify that the licensee has confirmed the viability of this method
    of cooling. Verify that training and procedures are in place for BWR
    alternate decay heat removal systems.

e.  [Spent Fuel Pool Cooling System Operation]{.underline}. Verify that
    outage work is not impacting the ability of the operations staff to
    operate the spent fuel pool cooling system during and after core
    offload.

f.  [Inventory Control]{.underline}. Verify that the flow paths,
    configurations, and alternative means for inventory addition are
    consistent with the outage risk plan. For activities which have the
    potential to cause a loss of inventory, verify that there are
    adequate controls in place to prevent inventory loss.

g.  [Reactivity Control]{.underline}. Verify that the licensee is
    controlling reactivity in accordance with the technical
    specifications. Verify that activities or SSCs which could cause
    unexpected reactivity changes are identified in the outage risk plan
    and are controlled accordingly.

h.  [Containment Closure]{.underline}. For PWRs, verify that licensees
    control containment penetrations in accordance with the refueling
    operations technical specifications and can achieve containment
    closure[^1] at all times. For BWRs, verify that licensees maintain
    secondary containment as required by technical specifications.

02.04 [Reduced Inventory and Mid‑Loop Conditions]{.underline}. Review
the licensee=s

commitments from GL 88‑17 and confirm by sampling that they are still in
place and adequate. Periodically, during the reduced inventory and
mid‑loop conditions, verify that the configurations of the plant systems
are in accordance with those commitments. During mid‑loop operations,
observe the effect of distractions from unexpected conditions or
emergent activities on operator ability to maintain required reactor
vessel level. In addition to reduced inventory and mid‑loop conditions,
assess outage activities that are planned to be conducted during other
periods when there is a short time‑to‑boil, and implement appropriate
portions of Section 03.04.

02.05 [Refueling Activities]{.underline}. Verify that fuel handling
operations (removal, inspection,

sipping, reconstitution, and insertion) and other ongoing activities are
being performed in accordance with technical specifications and approved
procedures. Verify that refueling seals have been properly installed and
tested, and that foreign material exclusion is being maintained in the
refueling, spent fuel, and suppression pool areas. Verify that the
location of the fuel assemblies is tracked, including new fuel, from
core offload through core reload. Verify that fuel assembles were loaded
in the reactor core locations specified by the design. Verify that
discharged fuel assemblies are placed in allowable locations in the
Spent Fuel Pool.

02.06 [Monitoring of Heatup and Startup Activities]{.underline}. If
containment was opened, the

inspector shall conduct a thorough inspection and walkdown of
containment prior to reactor startup. Particular attention should be
given to areas where work was completed to verify no evidence of
leakage, and to verify that debris has not been left which could affect
performance of the containment sumps. Verify on a sampling basis that
technical specifications, license conditions, and other requirements,
commitments, and administrative procedure prerequisites for mode changes
are met prior to changing modes or plant configurations. The inspector
should verify RCS integrity by reviewing RCS leakage calculations, and
verify containment integrity by reviewing the status of containment
penetrations and containment isolation valves. Review reactor physics
testing results to verify that core operating limit parameters are
consistent with the design.

02.07 [Identification and Resolution of Problems]{.underline}. Verify
that the licensee is identifying

problems related to refueling outage activities at an appropriate
threshold and entering them in the corrective action program. For a
sample of significant problems documented in the corrective action
program, verify that the licensee has identified and implemented
appropriate corrective actions. See Inspection Procedure 71152,
AIdentification and Resolution of Problems,@ for additional guidance.

71111.20‑03 INSPECTION GUIDANCE

[General Guidance]{.underline}

This activity is also addressed in other inspectable areas (i.e.,
maintenance work prioritization and control, inservice inspection
activities). In a refueling or other outage this procedure should take
precedence in relation to outage planning and configuration management
reviews.

The inspector may refer to IMC 0609, Appendix G, AShutdown Operations
Significance Determination Process,@ which contains checklists of
various plant configurations that ensure licensees are maintaining an
adequate mitigation capability. Certain plant configurations have higher
risks than others. For these configurations, the checklists have more
guidelines for each safety function. The following are examples of high
risk configurations for PWRs: (1) RCS boundary is breached and the steam
generators cannot be used for DHR; and (2) during mid‑loop conditions,
it is more likely that DHR can be lost due to poor RCS level control or
poor DHR flow control. Examples for BWRs are: (1) technical
specifications allow for more equipment to be inoperable in cold
shutdown than in hot shutdown; and (2) technical specifications allow
SRVs to be inoperable, but they are needed to provide an alternate decay
heat removal path and pressure control if the DHR system is lost.

Additional general guidance is provided in the following table.

+-------------+---------------------------+----------------------------+
| **CORNERST  | **RISK PRIORIT Y**        | **EXAMPLES**               |
| ONE**       |                           |                            |
+-------------+---------------------------+----------------------------+
| INITIATING  | Equipment or actions that | Inadvertent lowering of    |
|             | could cause               | reactor vessel             |
| EVENTS      |                           |                            |
|             | a loss of decay heat      | level in mid‑loop due to   |
|             | removal.                  | operator                   |
|             |                           |                            |
|             | Actions that could affect | inattention.               |
|             | reactor                   |                            |
|             |                           | Improper hanging or        |
|             | vessel level.             | restoration of             |
|             |                           |                            |
|             | Activities that           | clearance tags that could  |
|             | contribute to loss of off­ | affect reactor             |
|             |                           |                            |
|             | site power or station     | vessel level, DHR, or      |
|             | blackout.                 | electrical power           |
|             |                           |                            |
|             |                           | availability.              |
|             |                           |                            |
|             |                           | Actions that could cause   |
|             |                           | reactor vessel             |
|             |                           |                            |
|             |                           | level indication to be     |
|             |                           | inaccurate.                |
+-------------+---------------------------+----------------------------+
| MITIGATING  | Equipment used to         | Activities that affect the |
|             | mitigate a loss of        | ability of pumps           |
| SYSTEMS     |                           |                            |
|             | decay heat removal.       | designated in the shutdown |
|             |                           | risk                       |
|             | Equipment used to         |                            |
|             | mitigate a loss of        | analysis to add water to   |
|             |                           | the reactor                |
|             | reactor vessel level.     |                            |
|             |                           | vessel.                    |
|             |                           |                            |
|             |                           | Activities that affect the |
|             |                           | water source               |
|             |                           |                            |
|             |                           | for any of the pumps       |
|             |                           | designated in the          |
|             |                           |                            |
|             |                           | shutdown risk analysis.    |
|             |                           |                            |
|             |                           | Activities that affect the |
|             |                           | electrical power           |
|             |                           |                            |
|             |                           | sources designated in the  |
|             |                           | shutdown                   |
|             |                           |                            |
|             |                           | risk analysis.             |
|             |                           |                            |
|             |                           | Failure to verify          |
|             |                           | refueling interlocks.      |
+-------------+---------------------------+----------------------------+
| BARRIER     | Actions that affect the   | Exceeding the required     |
|             | fuel cladding             | heatup or                  |
| INTEGRITY   |                           |                            |
|             | barrier, reactor          | cooldown rates.            |
|             | vessel/reactor coolant    |                            |
|             |                           | Failure to establish       |
|             | system integrity, or      | containment                |
|             | affect containment        |                            |
|             |                           | integrity during fuel      |
|             | integrity.                | movement.                  |
+-------------+---------------------------+----------------------------+

[Specific Guidance]{.underline}

03.01 [Review of Outage Plan]{.underline}. Defense‑in‑depth should be
maintained. Backup SSCs

should be identified for those taken out of service when removal of the
SSC from service affects a key safety function. Consult with the
regional SRA to evaluate risk insights regarding the outage plan. Risk
should be considered for areas such as overlap of activities, handling
of heavy loads, scaffolding erection, and the increased potential for a
fire or internal flood.

03.02 [Monitoring of Shutdown Activities]{.underline}. Cooldown rates
should be spot checked to

verify they meet technical specification requirements, thus avoiding
overcooling which can challenge the reactor coolant system boundary. The
period during transfer to shutdown cooling can be a time when risk of
overcooling is the greatest.

Containment should be inspected as soon as practicable after shutdown to
verify there is no evidence of RCS leakage (e.g., boric acid residue)
which might later become obscured due to licensee outage work. The
containment sump should be inspected for damage or debris. Supports,
braces, and snubbers should be inspected to verify there is no damage or
deformation due to excessive stress, water hammer, or aging.

The scope for the containment inspection should be based on inspector
judgement and discussions with region management. Items to consider
should include plant/containment type, ALARA, industrial/personnel
safety (heat stress), duration of the outage, and the amount of
unidentified leakage prior to the shutdown.

03.03 [Licensee Control of Outage Activities]{.underline}

IP 71111.13, A Maintenance Risk Assessments and Emergent Work
Evaluation,@ indicates that IMC 0609, Appendix G checklists are to be
used by inspectors to evaluate whether licensee risk assessments
(performed in accordance with 10 CFR 50.65(a)(4)) addressed SSCs
necessary to support the shutdown key safety functions.

Outage configuration management is an important issue related to
shutdown risk. The adequacy of the methods used and the operators=
understanding of plant configuration are key to controlling shutdown
risk.

When equipment is taken out of service for maintenance, declaring an SSC
available should be consistent with the SSC=s functional requirements.
Operators and outage control personnel should be aware of which
equipment is relied on for the key safety functions. This extends to the
containment sump (PWRs) or the suppression pool (BWRs), and associated
water flow paths. Equipment designated to perform a key safety function
should not be adversely affected by outage activities. Contingency plans
for restoring key safety functions should be available. Contingency
plans should include a prioritization of equipment to use.

Emergent work (maintenance, surveillance, etc.) or planned work which
exceeds scheduled time windows should be controlled to prevent overlap
with other activities when such overlap can potentially perturb the
plant or affect a key safety function. Risk assessments should be
maintained current with respect to emergent work and schedule changes.
Licensees should assess overlapping or potentially overlapping
activities and the effects of these activities on the key safety
functions.

Other baseline inspection procedures address observation of some
activities during an outage. The following areas should focus on only
those functions or components related to shutdown risk. The sampling of
the activities should be based on the risk importance of the function or
equipment in the particular mode or configuration. See IMC, 0609,
Appendix G.

a.  [Clearance Activities]{.underline}. Improper performance of
    clearance activities can increase risk by causing internal flooding,
    causing increased ignition sources, and affecting defense‑in‑depth.
    Clearance tags for boundaries associated with risk significant
    maintenance or modifications should be hung on the proper equipment
    and equipment configured such that they do not increase the risk
    associated with the relied upon remaining equipment.

> Examples of risk significant clearance activities include: 1)
> boundaries for a water system that will be open for maintenance in
> areas that are inclose proximity to risk important equipment; 2)
> clearance removal where return of electrical power to particular
> motor‑operated valves could cause the valves to reposition due to
> locked in signals, in particular those that have direct interaction
> with the reactor coolant system, decay heat removal, or spent fuel
> pool cooling. At multi‑unit sites, be aware of wrong unit and common
> unit tagging/clearance issues.

b.  [Reactor Coolant System Instrumentation]{.underline}.
    Instrumentation plays a key role in risk reduction during shutdown
    conditions. In particular, level instrumentation is a key factor
    during reduced inventory and mid‑loop, and pressure indication
    during loss of decay heat removal. RCS pressure, level and
    temperature instruments and associated components (including piping,
    RCS and connected system vents, etc.) should be installed and
    configured to provide accurate indication. Independent
    instrumentation for each parameter should be provided to minimize
    the potential for common cause failure.

> For level instruments, tubing runs should not have elevation changes
> that could trap either liquid or vapor/gas in the instrument lines
> (i.e., loop seals). If normal operating level instrumentation is used,
> the effects of changes in water density (due to lower temperature)
> should be considered. Operators should be aware of the effect of loss
> of DHR on the plant=s level instrumentation due to heatup and
> pressurization.
>
> For temperature instruments, operators should be aware of the effect
> of loss of DHR on the plant=s temperature indication and the potential
> for discrepancies between the temperature indications and the actual
> plant state. Temperature may be measured in the DHR loop in which case
> interruption, bypass, or partial bypass of DHR flow could lead to
> incorrect and non‑conservative temperature indications.

c.  [Electrical Power]{.underline}. Loss of offsite power and station
    black out are major factors in shutdown risk. Control of electrical
    power to components is critical to risk during outages since
    components are deenergized and reenergized with systems in
    unusual/disassembled configuration. This can cause unexpected drops
    or increases in RCS level, internal flooding, false protective
    system actuations, as well as significant personnel hazards. The
    most important are those that would contribute to loss of decay heat
    removal. In addition, the defense‑in‑depth called for in the outage
    risk control plan should be maintained.

d.  [DHR System Monitoring]{.underline}. Loss of decay heat removal is a
    primary contributor to shutdown risk at PWRs. An important attribute
    to look at when decay heat removal is lost is RCS pressure relief
    due to the pressure increase with temperature. When the licensee is
    relying on the steam generators to provide a backup means of DHR by
    single‑phase natural circulation, verify:

    1.  procedures for these methods are derived from analyses and the
        required equipment is available;

    2.  RCS pressure boundary is closed;

    3.  steam generator tubes are full;

    4.  Pressure control capability in the RCS is maintained to ensure
        subcooling margin;

    5.  capability to feed the steam generators; and

    6.  capability to remove steam from the steam generators (e.g.,
        atmospheric relief valves, condenser with steam dump capability,
        etc.).

> Perform walkdown/inspection when the reactor inventory is lowest and
> soon after shutdown, i.e., when the time‑to‑boil is lowest.

e.  [Spent Fuel Pool Cooling System Operation]{.underline}. Spent Fuel
    Pool Cooling recovery procedures based on current/bounding heat
    loads should exist for situations involving loss of spent fuel pool
    cooling. Operators should be trained on backup equipment and
    procedures for loss of spent fuel cooling. Equipment designated in
    the recovery procedures should be readily available, dedicated, not
    obstructed by outage activities, and compatible with equipment that
    it must be connected to. Instrumentation, alarms, equipment,
    instructions, and training should be provided to alert operators for
    the need and enable them to add water to the spent fuel pool if it
    becomes necessary.

f.  [Inventory Control]{.underline}. Problems with the RCS pressure
    boundary have been found to be significant in analyzing shutdown
    risk insights. Examples of loss of inventory paths include:

    1.  DHR to suppression pool on BWRs;

    2.  main steam line paths including SRV removal, automatic
        depressurization system testing, main steam isolation valve
        maintenance, etc. on BWRs;

    3.  DHR system cross tie valves, thimble tube seals, and steam
        generator nozzle dams for PWRs;

    4.  maintenance activities on connected piping or components that
        are at an elevation lower than the vessel flange on all plants;
        and

    5.  paths for inter‑system LOCA such as maintenance and testing on
        the non­operating loop Low Pressure Injection (LPI) train or LPI
        testing on return back to RWST.

> For BWRs, automatic isolation on low level should not be disabled.
> This signal can mitigate a loss of inventory from the DHR system to
> the suppression pool. Maintaining this signal operational is required
> by some technical specifications. In addition, main steam line plugs
> should be considered for work activities on the main steam system.
> Reactor cavity seal should be inspected and maintained to preclude
> potential seal failure. Systems required for proper operation of the
> reactor cavity seal (e.g., instrument air) should also be maintained
> to prevent failure of the seal. Adequate vents should be provided to
> accomplish gravity feed and low pressure makeup when relied upon.

g.  [Reactivity Control]{.underline}. For PWRs, the licensee should
    identify and implement appropriate administrative controls on
    potential boron dilution paths. Uniform RCS boron concentration is
    important, therefore, addition of water with a lesser boron
    concentration or starting of reactor coolant pumps which could
    inject water with a lesser boron concentration into the core should
    be controlled. The licensee should have adequate controls during
    refueling to preclude improper sequencing of control rods or fuel
    assemblies, which can allow core regions to approach criticality
    without early detection by a source range monitor.

h.  Containment Closure. Verify proper containment configuration during
    risk‑significant evolutions (e.g., PWR mid‑loop operations, BWR
    cavity drain down) including provisions for achieving containment
    closure in a timely manner during periods when containment is
    permitted to be open.

03.04 Reduced Inventory and Mid‑Loop Conditions. **The period of reduced
inventory and mid‑loop are the times of greatest risk during shutdown**.
The inspector should review the planned activities during those
conditions and consider the risk effect of those activities on the
critical parameters that affect time‑to‑boil. Review unit/outage
specific time‑to‑boil curves. The inspector should:

a.  Review licensee commitments to GL 88‑17.

b.  Verify the licensee has reviewed their controls and administrative
    procedures governing mid‑loop operation, and have conducted training
    for mid‑loop operation.

c.  Verify that procedures are in use for:

    1.  Containment closure capability for mitigation of radioactive
        releases.

    2.  Identifying unexpected RCS inventory changes and verifying an
        adequate RCS vent path during RCS draining to mid‑loop.

    3.  Emergency/abnormal operation during reduced inventory.

d.  Verify that:

    1.  Indications of core exit temperature are operable and
        periodically monitored (typically at least 2 independent and
        continuous indications).

    2.  Indications of RCS water level are operable and periodically
        monitored (typically at least 2 independent and continuous
        indications).

    3.  RCS perturbations are avoided.

    4.  Means of adding inventory to the RCS are available (typically at
        least 2 means in addition to RHR pumps).

    5.  Reasonable assurance is obtained that not all hot legs are
        simultaneously blocked by nozzle dams unless the upper plenum is
        vented.

    6.  Contingency plans exist to repower vital electrical busses from
        an alternate source if the primary source is lost.

Time‑to‑boil can be less than 30 minutes when decay heat removal is lost
in mid‑loop conditions. During mid‑loop operations the operator provides
the only prevention/mitigating function for a loss of reactor vessel
level prior to the loss of decay heat removal. There generally are no
alarms that provide indication of loss of level in the mid‑loop
condition. Operator attention to plant conditions is the key prevention
aspect for a loss of decay heat removal event. The inspector should
closely observe operator performance during drain down, and frequently
observe control room activities while the plant is in reduced inventory
or mid‑loop conditions. Specifically, the inspector should observe how
distractions, such as unexpected conditions and emergent work, affect
operator focus.

03.05 [Refueling Activities]{.underline}. Fuel loading should be
performed in a manner to maintain

coupling between the instruments used for monitoring reactivity and fuel
loaded in any location within the vessel. To verify that the fuel
cladding barrier will not be challenged, verification that fuel
assembles were loaded in the correct reactor core locations may be
accomplished by reviewing licensee videotape and other records of the
core loading.

Another method is to review physics testing to verify the testing was
adequately conducted and that core operating limit parameters are as
predicted by the design.

03.06 [Monitoring of Restart Activities]{.underline}. This activity
should focus on the licensee having

the required equipment available for mode changes to ensure that risk is
kept to a minimum. The activity can be conducted by direct observation
of system/equipment operation, documentation reviews, or a combination
of both. The sampling should be adequate to provide reasonable
verification that the licensee is following the administrative program
laid out to ensure that risk is maintained at a minimum level. Prior to
containment closure, a thorough walkdown of containment shall be
completed to verify there is no evidence of leakage, tags are cleared,
there is no obvious damage to passive systems, and there is no debris
left that might contribute to ECCS sump blockage. The inspector should
observe that technical specifications RCS boundary leakage requirements
are met prior to the applicable mode changes and that containment
integrity is established prior to entering the applicable technical
specifications mode.

03.07 [Identification and Resolution of Problems]{.underline}. No
guidance provided.

71111.20‑04 RESOURCE ESTIMATE

Inspection resources are affected by the length of the outage, amount of
risk significant work and the plant configuration. The inspection
resources for performing this procedure at each reactor unit is
estimated at 70 to 100 hours each refueling outage. Inspection resources
are estimated at no more than 70 hours annually for non‑refueling and
forced outages, regardless of the number of units.

Some testing activities normally occur during refueling outages. These
include physics testing, emergency diesel generator time response
testing, RCS hydrostatic testing, control rod scram time testing, rod
drop time testing, reactor trip breaker testing, and containment sump
valve testing. Inspection of these activities that is not related to
shutdown risk should be charged to IPs for post‑maintenance and
surveillance testing (IP 71111.19 and IP 71111.22). IMC 2515, Appendix
D, Plant Status, states that Aduring changing plant conditions (plant
refueling or maintenance outages), the frequency and scope of plant
status tours may be increased to tour areas not normally accessible and
to observe equipment in an abnormal lineup.@ This effort should be
charged to IMC 2515, Appendix D.

71111.20‑05 COMPLETION STATUS

Inspection of the minimum sample size will constitute completion of this
procedure in the Reactor Programs System (RPS). That minimum sample size
will consist of 1 sample for each outage at the facility. For refueling
outages, the sample consists of all the requirements in this procedure,
if possible. For other outages, the sample consists of the applicable
portions of this procedure.

71111.20‑06 REFERENCES

GL 87‑12, ALoss of Residual Heat Removal (RHR) While the Reactor Coolant
System (RCS) is Partially Filled,@ July 9, 1987.

NUREG‑1269, ALoss of Residual Heat Removal System, Diablo Canyon, Unit
2, April 10, 1987,@ June 1987.

GL 88‑17, ALoss of Decay Heat Removal, 10 CFR 50.54(f),@ October
17,1988.

NUREG‑1410, ALoss of Vital AC Power and the Residual Heat Removal System
During Mid‑Loop Operations at Vogtle Unit 1 on March 20, 1990,@ June
1990.

NUREG‑1449, AShutdown and Low‑Power Operation at Commercial Nuclear
Power Plants in the United States,@ September 1993.

IN 93‑72, AObservations from Recent Shutdown Risk and Outage Management
Pilot Team Inspections,@ September 14, 1993.

NUREG‑0700, REV.1, AHuman System Interface Design Review Guideline,@
June, 1996

Generic Letter 98‑02, ALoss of Reactor Coolant Inventory and Associated
Potential for Loss of Emergency Mitigation Functions while in a Shutdown
Condition,@ May 28, 1998

Information Notice 95‑03, Loss of Coolant Inventory and Associated
Potential Loss of Emergency Mitigation Functions while in a Shutdown
Condition,@ January 18, 1995

Inspection Manual Chapter 0609, Appendix G, AShutdown Operations
Significance Determination Process@

Inspection Procedure 71111.13, AMaintenance Risk Assessments and
Emergent Work Control@

Inspection Procedure 71152, AIdentification and Resolution of Problems@

END

**Revision History for IP 71111.20**

+--------+--------+-----------------------+-----+-------+--------------+
| Comm   | Issue  | Description of Change | Tr  | Tra   | Comment      |
| itment | Date   |                       | ain | ining | Resolution   |
| Tr     |        |                       | ing | Compl | Accession    |
| acking |        |                       | Nee | etion | Number       |
| Number |        |                       | ded | Date  |              |
+--------+--------+-----------------------+-----+-------+--------------+
| NA     | 01     | \(1\) clarifies when  | No  | NA    | ML080250276  |
|        | /31/08 | outages should be     |     |       |              |
|        |        | addressed via IP      |     |       |              |
|        | CN     | 71111.20 vs IP 71153, |     |       |              |
|        | 08-005 | and (2) clarifies     |     |       |              |
|        |        | annual inspection     |     |       |              |
|        |        | resources for         |     |       |              |
|        |        | non-refueling and     |     |       |              |
|        |        | forced outages.       |     |       |              |
+--------+--------+-----------------------+-----+-------+--------------+
|        |        |                       |     |       |              |
+--------+--------+-----------------------+-----+-------+--------------+
|        |        |                       |     |       |              |
+--------+--------+-----------------------+-----+-------+--------------+

[^1]: For PWRs, containment closure is met if all containment
    penetrations (including temporary penetrations, the equipment hatch,
    and the personnel hatch) have a differential capability equal to
    ultimate pressure or would be expected to remain intact following an
    accident. Leakage requirements as described in Appendix J are not a
    concern. Results from the RES Surry shutdown PRA show that
    containment pressure (in a sub‑atmospheric containment) following a
    core damage event at shutdown can be high.