**NRC INSPECTION MANUAL** CTSB

INSPECTION PROCEDURE 71303

PART 52, TECHNICAL SPECIFICATIONS REVIEW

PROGRAM APPLICABILITY: 2504

71303-01 OBJECTIVES

This is an operational program inspection procedure specified in
Inspection Manual Chapter 2504. When this inspection is performed, the
majority of construction activities for the plant should have been
completed, and the licensee is making preparations for initial fuel
loading. The purpose of this procedure is to verify that the licensee
has updated and has processes in-place to implement plant technical
specification (TS) requirements.

01.01 Verify the TS contains the latest approved TS amendments.

01.02 Verify the licensee has implemented a procedure for assessing
degraded or non-conforming conditions adverse to quality or safety
(operability determination process).

01.03 Verify the licensee has procedures and processes in-place for
performing TS surveillance requirements.

01.04 Verify the licensee has procedures in-place for selected reporting
and programmatic requirements required by TS section 5.

01.05 Verify the licensee has procedures and processes to maintain TSs,
and they are consistent with the current licensing basis. Specifically,
there are procedures to identify TS implications with proposed plant
design changes, there are procedures to update TSs for approved
amendments, and TS changes are supported in the final safety analysis
report (FSAR).

71303-02 INSPECTION REQUIREMENTS AND GUIDANCE

02.01 [Requirement]{.underline}. The TSs have been maintained and the
plant specific changes have been made.

References: 10 CFR 50.36, applicable 10 CFR 52 Appendix (certified
designs), Combined Operating License Application, 10 CFR 50.34.

Inspection Guidance:

a\. Contact the NRC project manager for the plant and obtain the
approved TS amendments for the plant from the previous 12 months (or
further if necessary to obtain at least six TS amendments).

b\. Perform a line by line check that the amendment sample from 02.01.a
has been incorporated into the licensee=s TS.

02.02 [Requirement]{.underline}. The Licensee=s Operability
Determination Process and Procedures are acceptable.

References: RIS 2005-020, Appendix B to 10 CFR Part 50.

Inspection Guidance:

a\. Review the licensee=s corrective action procedures for controls to
identify and resolve degraded or non-conforming conditions related to
equipment operability. The corrective action procedures should include
provisions for the initial actions to take, and their final resolution.

b\. Review the licensee=s procedures for operability determinations on
degraded and non-conforming equipment. The procedure should include the
technical evaluation process, an extent of condition assessment, an
assessment of the ability to perform required safety functions,
compensatory measures, and the basis for the determination.

c\. Interview licensed operators to assess if they understand their
roles and responsibilities, with respect to operability determinations.
This should include initial actions (immediate operability
determination), how to apply the TS bases, prompt determinations, and
the process to resolve degraded and non-conforming equipment conditions.

d\. Select several corrective action documents associated with TS
equipment failures to determine if they were addressed according to the
licensee=s procedures. If available, routine inspections in this area
may be substituted.

02.03 [Requirement]{.underline}. TS Surveillances are being performed as
required.

Inspection Guidance:

a\. Identify ten surveillance requirements in the TS that are required
to be performed with fuel in the reactor vessel. Recommended sections
are electrical, instrumentation, and refueling. Have the licensee
provide the procedures or identify the process used to meet and document
the surveillance requirements.

b\. Request the latest documentation of the selected surveillance
activities that have been performed.

c\. Review the documentation obtained in (a.) and (b.) to verify that
the surveillance requirements stated in TS have been met. Exceptions or
deviations should be reviewed to ensure that TS requirements and
definitions are met.

02.04 [Requirement]{.underline}. Meet the Programmatic Requirements in
TS Section 5.

Reference: 10 CFR 50.36.

Inspection Guidance:

a\. Review the programmatic requirements in Section 5.0, AAdministrative
Controls.@ Review a sample of four programs for site implementing
procedures and actions to date. Assess whether the sampled programs are
successfully meeting the requirements in TS.

b\. Review the reporting requirements in TS and select several required
reports for review. Review examples of selected reports. Assess whether
the reports are successfully meeting the requirements in TS.

02.05 [Requirement.]{.underline} Engineering changes and amendments are
managed with respect to the TSs.

References: 10 CFR 50.90, 10 CFR 50.59, 10 CFR 50.34.

Inspection Guidance:

a\. Review the plant 10 CFR 50.59 change process to assure that it
contains controls to identify plant changes that have TS implications.
These controls should prevent plant changes from being implemented prior
to the approval of any required TS changes.

b\. Verify that the licensee has procedures to perform the analysis and
revise the FSAR to support TS amendments.

71303-03 GENERAL INSPECTION GUIDANCE

The scope of the inspection should be focused on verifying that the
currently approved version of the TS are complete (i.e., there are no
outstanding \[bracketed\] values or information), and that the licensee
has processes and procedures for implementing the TS requirements.

The review should compare the technical specification to achieving the
requirements specified in the current licensing basis. The goal is to
identify programmatic deficiencies or discrepancies within a technical
specification indicating poor preparation or technical errors. Systems
affected should be checked against the FSAR, TS, and available as-built
drawings, including a subsequent walk-down inspection, if applicable.
Information on weakness should also be provided to NRO, as it may have
generic applicability to other similar plants under construction.

Other Inspection Procedures areas should be reviewed to determine if
inspections specified in this procedure have been satisfied. If other
Inspection Procedures are used to meet the requirements of this
procedure, reference them in the inspection report.

71303-04 RESOURCE ESTIMATES - 80 hrs total

04.01 [Initial Preparations]{.underline}. 16 hours.

a\. Contact agency Project Manager (PM) for the licensee to determine
status and revision of TS.

b\. Obtain current TS from licensee.

c\. Request process documentation from the licensee.

d\. Review requirements documentation and formulate specific inspection
plan.

04.02 The TSs are current and plant specific changes have been made. 4
hrs.

04.03 The Licensee has processes for managing the TSs and maintaining
the current licensing basis. 4 hrs.

04.04 The Licensee has an acceptable Operability Determination Process.
16 hrs.

04.05 The Licensee is performing required TS Surveillances. 16 hrs.

04.06 Meet the Programmatic Requirements in TS Section 5. 8 hrs.

04.07 Final write-up of the inspection procedure results. 16 hrs.

71303-05 REFERENCES

References are included in section 71303-02.

71303-06 PROCEDURE COMPLETION

Recommended sample sizes are described as part of each inspection
described in section 2, AInspection Requirements and Guidance.@ For
cases where the term Aseveral@ is used, the sample size is two to five
items. If the recommended sample size is not available, state that in
the inspection write-up and use the samples available.

This inspection procedure can be considered complete when the
inspections described in section 2 have been completed and the
inspection report has been issued.

END

Attachment

Revision History for IP 71303

Attachment 1

Revision History Sheet for IP 71303

Part 52, Technical Specifications Review

+--------+--------+-----------+----------+-------------+---------------+
| Comm   | Issue  | De        | Training | Training    | Comment       |
| it­ment |        | scription | Needed   | Comple­tion  | Resolu­tion    |
|        | Date   | of Chan­ge |          | Date        |               |
| Tr     |        |           |          |             | Accession     |
| acking |        |           |          |             | Number        |
|        |        |           |          |             |               |
| Number |        |           |          |             |               |
+--------+--------+-----------+----------+-------------+---------------+
| NA     | 10     | Initial   | None     | Not         | ML073380022   |
|        | /20/08 | issue to  |          | Applicable  |               |
|        |        | support   |          |             |               |
|        | CN     | in        |          |             |               |
|        | 08-029 | spections |          |             |               |
|        |        | of        |          |             |               |
|        |        | op        |          |             |               |
|        |        | erational |          |             |               |
|        |        | pro­grams  |          |             |               |
|        |        | described |          |             |               |
|        |        | in IMC    |          |             |               |
|        |        | 2504,     |          |             |               |
|        |        | NON-ITAAC |          |             |               |
|        |        | IN        |          |             |               |
|        |        | SPECTIONS |          |             |               |
|        |        |           |          |             |               |
|        |        | Completed |          |             |               |
|        |        | 4 year    |          |             |               |
|        |        | search of |          |             |               |
|        |        | CNs and   |          |             |               |
|        |        | no        |          |             |               |
|        |        | co        |          |             |               |
|        |        | mmitments |          |             |               |
|        |        | found.    |          |             |               |
+--------+--------+-----------+----------+-------------+---------------+
|        |        |           |          |             |               |
+--------+--------+-----------+----------+-------------+---------------+