Number range CHAPTER**ATTACHMENT 71111.15**

INSPECTABLE AREA: Operability Evaluations

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 not capable of performing its design
function.

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
evaluations 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. Although the number of
required samples is an annual goal, available operability evaluation
samples should be inspected each quarter to ensure a reasonable
distribution throughout the year.

71111.15-01 INSPECTION OBJECTIVE

01.01 To review operability evaluations affecting mitigating systems and
barrier integrity to ensure that operability is properly justified and
the component or system remains available, such that no unrecognized
increase in risk has occurred.

71111.15-02 INSPECTION REQUIREMENTS

02.01 [Operability Evaluation Review]{.underline}

> a\. Select operability evaluations involving risk significant SSCs.
> Selection of operability evaluations can emerge from the inspector\'s
> review of plant status documents such operator shift logs, emergent
> work documentation, deferred modifications, and standing orders to
> determine if an operability evaluation is warranted for a degraded
> component.
>
> b\. Review the technical adequacy of the licensee's operability
> evaluation, and verify if operability is justified. Verify that the
> licensee considered other degraded conditions and their impact on
> compensatory measures for the condition being evaluated. Refer to the
> final safety analysis report (FSAR) and other design basis documents
> during the review. If operability is justified, no further review is
> required.
>
> c\. If the operability evaluation involves compensatory measures,
> determine if the measures are in place, will work as intended, and are
> appropriately controlled
>
> d\. Verify that degraded SSC or compensatory measures taken to address
> degraded SSC does not result in changes to tests or experiments
> described in UFSAR (for example a SSC utilized in a way either outside
> the design basis or inconsistent with the safety analyses). If the
> changes to tests or experiments are different than what is described
> in UFSAR, verify that these changes or experiments do meet the various
> criteria specified in 10 CFR 50.59 for not requiring a license
> amendment.
>
> e\. If operability is not justified:
>
> 1\. Determine impact on any Technical Specification (TS) limiting
> condition for operation (LCO).
>
> 2\. Use the Significance Determination Process to evaluate the risk
> significance of the equipment inoperability.

02.02 [Identification and Resolution of Problems]{.underline}. Verify
that the licensee is identifying problems with operability evaluations
at an appropriate threshold and entering them in the corrective action
program. For a sample of significant operability evaluations issues
documented in the corrective action program, verify that the licensee
has identified and implemented appropriate corrective actions. See
Inspection Procedure 71152, "Identification and Resolution of Problems,"
for additional guidance.

71111.15-03 INSPECTION GUIDANCE

The licensee's process of ensuring operability is continuous and
consists of the verification of operability by surveillances and
continuous monitoring of plant systems*.* Formal determinations of
operability are performed whenever a verification or other indication
calls into question the SSC's ability to perform its specified function.
Licensees are obligated to ensure the continued operability of SSCs as
specified by TS, or to take the remedial actions addressed in the TS.
The intent of this inspection is to sample licensee's operability
evaluations for risk significant SSCs to verify if operability is
justified, such that availability is assured, and no unrecognized
increase in risk has occurred. Also, the inspections should verify that
operability concerns associated with plant issues and events are being
identified.

Where there is a reason to suspect that the licensee's operability
determination is not, or was not correct based on the information
reviewed, the inspector should discuss the issue with regional
management for resolution. Depending on the complexity and risk
significance of the issue, in some cases, the inspector may need to
consult with regional specialists to complete verification of licensee's
operability evaluation. The regional specialist's time spent on
reviewing the issue should be charged to this procedure. The inspectors
are not required to spend additional time in reviewing an issue if the
discrepancies identified do not change the outcome of the operability
evaluation.

NRC Regulatory Issue Summary 2005-20, "Revision to Guidance Formerly
Contained in NRC Generic Letter 91-18, 'Information to Licensees
Regarding Two NRC Inspection Manual Sections on Resolution of Degraded
and Nonconforming Conditions and on Operability'," issued in September,
2005, informs licensees of updated NRC Inspection Manual, Part 9900,
Technical Guidance, "Operability Determinations & Functionality
Assessments for Resolution of Degraded or Nonconforming Conditions
Adverse to Quality or Safety." The manual section provides guidance to
NRC inspectors for reviewing the actions of licensees pertaining to the
operability of SSCs following the discovery of degraded and
nonconforming conditions in SSCs.

See table below for inspection guidance to assist the inspector in
selecting inspection activities to achieve each cornerstone objective
and to achieve those activities that have a risk priority.

+------------+------------------+------------------+------------------+
| **Cor      | **Inspection     | **Risk           | **Example**      |
| nerstone** | Objective**      | Priority**       |                  |
+------------+------------------+------------------+------------------+
| Mitigating | Identify any     | Operating -      | Improper         |
| Systems    | improperly       | mitigating       | conclusion on    |
|            | evaluated        | system as        | operability of   |
| Barrier    | degraded and/or  | determined by    | the              |
| Integrity  | nonconforming    | plant-specific   | high-pressure    |
|            | conditions which | information or   | coolant          |
|            | could            | Risk Importance  | injection (HPCI) |
|            | potentially      | Measure 2        | system such that |
|            | impact SSC's     | (RIM2).          | the system could |
|            | availability and |                  | not perform its  |
|            | result in an     | Shutdown -       | function during  |
|            | unrecognized     | Mitigating       | a station        |
|            | increase in      | systems that     | blackout event   |
|            | risk.            | perform key      | concurrent with  |
|            |                  | safety functions | planned          |
|            |                  | during shutdown  | unavailability   |
|            |                  | (decay heat      | of the reactor   |
|            |                  | removal,         | core isolation   |
|            |                  | inventory        | cooling (RCIC)   |
|            |                  | control,         | system.          |
|            |                  | electrical power |                  |
|            |                  | availability,    |                  |
|            |                  | reactivity       |                  |
|            |                  | control, and     |                  |
|            |                  | containment)     |                  |
+------------+------------------+------------------+------------------+

71111.15-04 RESOURCE ESTIMATES

The annual resource expenditure for this inspection procedure is
estimated to be 84 to 102 hours for sites with one reactor unit; 96 to
118 hours for sites with two reactor units; and 108 to 136 hours for
sites with three reactor units.

71111.15-05 COMPLETION STATUS

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 evaluations of degraded and non-conforming conditions in a
year at 1-unit, 2-unit, and 3-unit sites, respectively.

71111.15-06 REFERENCES

NRC Regulatory Issue Summary 2005-20, "Revision to Guidance Formerly
Contained in NRC Generic Letter 91-18, 'Information to Licensees
Regarding Two NRC Inspection Manual Sections on Resolution of Degraded
and Nonconforming Conditions and on Operability'"

Inspection Manual Part 9900, "Operable/Operability - Ensuring the
Function Capability of a System or Component"

NRC Inspection Manual Part 9900, "10 CFR 50.59 Changes to Facility,
Procedures, and

Tests (Experiments)."

Title 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," Rev. Nov 2000.

NEI 96-07, Revision 1 (Nov 2000), Guidance for 10 CFR 50.59
Implementation.

Information Notice 97-78, "Crediting of Operator Actions in Place of
Automatic Actions and Modification of Operator Actions, including
Response Times"

Inspection Procedure 71152, "Identification and Resolution of Problems"

END

ATTACHMENT 1

Revision History - IP 71111.15

+--------+--------+------------------------------+-----+-------+-------+
| Comm   | Issue  | Description of Change        | Tr  | Tra   | Co    |
| itment | Date   |                              | ain | ining | mment |
| Tr     |        |                              | ing | Compl | Resol |
| acking |        |                              | Nee | etion | ution |
| Number |        |                              | ded | Date  | Acce  |
|        |        |                              |     |       | ssion |
|        |        |                              |     |       | N     |
|        |        |                              |     |       | umber |
+--------+--------+------------------------------+-----+-------+-------+
| N/A    | 07     | Revision history reviewed    |     | N/A   | N/A   |
|        | /26/06 | for the last four years.     |     |       |       |
+--------+--------+------------------------------+-----+-------+-------+
| N/A    | 01/1   | Revised to provide minor     | NO  | N/A   | N/A   |
|        | 7/2002 | clarifications to inspection |     |       |       |
|        |        | requirements and additional  |     |       |       |
|        | CN     | inspection guidance          |     |       |       |
|        | 02-002 | concerning operability       |     |       |       |
|        |        | evaluations. In addition,    |     |       |       |
|        |        | inspection resource          |     |       |       |
|        |        | estimates and inspection     |     |       |       |
|        |        | level of effort are revised  |     |       |       |
|        |        | to provide a band for more   |     |       |       |
|        |        | inspection                   |     |       |       |
+--------+--------+------------------------------+-----+-------+-------+
| N/A    | 02/0   | Revised to include deferred  | NO  | N/A   | N/A   |
|        | 2/2004 | modifications to the         |     |       |       |
|        |        | inspection sampling list.    |     |       |       |
|        | CN     |                              |     |       |       |
|        | 04-003 |                              |     |       |       |
+--------+--------+------------------------------+-----+-------+-------+
| N/A    | 01/0   | Increased the estimated      | NO  | N/A   | N/A   |
|        | 5/2006 | resources required to        |     |       |       |
|        |        | complete this inspection     |     |       |       |
|        | CN     | activity based on increased  |     |       |       |
|        | 06-001 | inspection hours charged to  |     |       |       |
|        |        | this IP during last several  |     |       |       |
|        |        | ROP cycles. Completed        |     |       |       |
|        |        | historical CN search.        |     |       |       |
+--------+--------+------------------------------+-----+-------+-------+
| N/A    | 07     | Revised to reflect changes   | NO  | N/A   | N/A   |
|        | /26/06 | of reference documents:      |     |       |       |
|        |        | GL91-18 was superseded by    |     |       |       |
|        | CN     | RIS 2005-20                  |     |       |       |
|        | 06-018 |                              |     |       |       |
+--------+--------+------------------------------+-----+-------+-------+
| N/A    | 01     | Add inspection guidance to   | No  | N/A   | N/A   |
|        | /31/08 | verify that licensee has     |     |       |       |
|        |        | correctly implemented 10 CFR |     |       |       |
|        | CN     | 50.59 regulatory             |     |       |       |
|        | 08-005 | requirements if operability  |     |       |       |
|        |        | evaluations warrant such     |     |       |       |
|        |        | 50.59 evaluations be         |     |       |       |
|        |        | performed.                   |     |       |       |
+--------+--------+------------------------------+-----+-------+-------+