**ATTACHMENT 71111.22**

INSPECTABLE AREA: Surveillance Testing

CORNERSTONES: Mitigating Systems

> Barrier Integrity

INSPECTION BASES: Inspection of this area ensures that safety systems
are capable of performing their safety function and would support the
Mitigating Systems and Barrier Integrity Cornerstones. The failure to
identify and resolve performance degradation of structures, systems and
components, could result in long periods of unknown equipment
unavailability. This inspectable area verifies aspects of the associated
cornerstones not measured by performance indicators.

LEVEL OF EFFORT: Review 18 to 26 surveillance tests per year regardless
of the number of reactor units at the site. Although the number of
required samples is an annual goal, available risk-significant
surveillance test samples should be inspected each quarter to ensure a
reasonable distribution throughout the year.

71111.22-01 INSPECTION OBJECTIVE

This inspection will focus on verifying that surveillance testing
(including inservice testing) of risk‑significant structures, systems,
and components (SSCs) are capable of performing their intended safety
functions and assessing their operational readiness.

71111.22-02 INSPECTION REQUIREMENTS

02.01 [Inspection Planning]{.underline}. Select risk-significant
surveillance activities each calender quarter based on risk information,
and the guidance contained in the inspection guidance, Section 03.

Every quarter select one inservice testing (IST) activity for a
risk‑significant pump or valve as one of the surveillance activities.
Consider selection of the IST activity based on the component
performance history (known deficiencies), or if the component had
recently undergone corrective or preventive maintenance.

Include one or two containment isolation valves each refueling cycle as
part of the surveillance testing samples. Also, for ice condenser
containment design sites, select one or two ice condenser system
surveillances to observe during each refueling outage as part of the
surveillance testing samples.

In addition, select one to three Reactor Coolant System (RCS) leakage
detection surveillances each calender year as part of the surveillance
testing samples.

02.02 [Inspection Activity]{.underline}

> a\. Verify by witnessing surveillance tests and/or reviewing the test
> data, that SSCs selected meet the Technical Specifications, Updated
> Final Safety Analysis Report (UFSAR), and licensee procedure
> requirements, and demonstrate that the SSCs are capable of performing
> their intended safety functions (under conditions as close as
> practical to accident conditions or as required by Technical
> Specifications) and their operational readiness.
>
> b\. Significant surveillance test attributes for consideration include
> the following:

1\. Preconditioning.

> 2\. Effect of testing on the plant has been adequately addressed by
> control room and/or engineering personnel.
>
> 3\. Acceptance criteria is clear and demonstrates operational
> readiness and is consistent with the supporting design calculations
> and other licensing documents.
>
> 4\. Test equipment range and accuracy are consistent with the
> application and has current calibration. Verify the plant equipment
> calibration is correct, accurate, properly documented and the
> calibration frequency is in accordance with TS, UFSAR, licensee
> procedures and commitments.
>
> 5\. Test is performed in sequence and in accordance with written
> procedure.
>
> 6\. Jumpers installed or leads lifted during testing are properly
> controlled.
>
> 7\. Test data is complete, verified and meets procedure requirements.
>
> 8\. Test frequency was adequate to demonstrate operability (meets
> Technical Specification requirements),and reliability.
>
> 9\. Test equipment is removed after testing.
>
> 10\. After completion of testing, equipment is returned to the
> positions/status required for the SSCs to perform its safety function.
>
> 11\. For IST activities, testing methods, acceptance criteria, and
> required corrective actions are in accordance with the applicable
> version of the ASME Code, Section XI. Review reference values or
> changes to reference values for consistency with the design bases.
>
> 12\. Unavailability of the tested equipment is appropriately
> considered in the licensees performance indicator data.
>
> 13\. For test results that do not meet the acceptance criteria,
> results of engineering evaluations, root cause analyses, and bases for
> returning to operable status are acceptable.
>
> 14\. For selected safety related instrumentation and control
> surveillance test (i.e. RPS, NIs, etc.) verify that reference setting
> data has been accurately incorporated to the test procedure.

15. Annunciator and other alarms are demonstrated to be functional and
    setpoints are consistent with design documents. Alarm response
    procedure entry points and actions are consistent with plant
    design/licensing documents.

16. *For RCPB leakage, to verify that licensees have programs and
    processes in place to (1) monitor plant-specific instrumentation
    that could indicate potential RCS leakage, (2) meet existing
    requirements related to degraded or inoperable leakage detection
    instruments, (3) use an inventory balance check when there is
    unidentified leakage (4) take appropriate corrective action for
    adverse trends in unidentified leak rates, and (5) pay particular
    attention to changes in unidentified leakage.* \[C1\]

02.03 [Identification and Resolution of Problems]{.underline}. Verify
that the licensee is identifying surveillance testing problems at an
appropriate threshold and entering them in the corrective action
program. For a sample of significant surveillance testing 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.

71111.22-03 INSPECTION GUIDANCE

The following table outlines the general inspection guidance.

+----------------+----------------+----------------+-----------------+
| Cornerstone    | Inspection     | Risk Priority  | Example         |
|                | Objective      |                |                 |
+================+================+================+=================+
| Mitigating     | Identify any   | Focus in areas | Integrated      |
| Systems        | mitigating     | with potential | safeguards      |
|                | system,        | for common     | testing         |
|                | credited by    | mode failures. |                 |
|                | the licensee   |                | Emergency       |
|                | as operable    | Select         | diesel          |
|                | when assessing | surveillance   | start/load      |
|                | risk, which is | tests which    | testing         |
|                | adversely      | cross          |                 |
|                | impacted by    | technical      | Battery         |
|                | surveillance   | disciplines    | performance     |
|                | testing        | (electrical,   | testing         |
|                | related        | mechanical,    |                 |
|                | failures such  | I&C)           | Reactor         |
|                | as failure to  |                | protection, RCS |
|                | adequately     | IST of pumps   | leakage         |
|                | test, failure  | and valves     | detection, and  |
|                | to meet test   | that perform   | safety          |
|                | criteria or,   | important      | injection       |
|                | failure to     | functions in   | instrumentation |
|                | realign        | mitigating     | testing         |
|                | equipment      | systems.^1^    |                 |
|                | after the      |                | Safety bus loss |
|                | surveillance.  |                | of voltage and  |
|                |                |                | degraded        |
|                |                |                | voltage relay   |
|                |                |                | testing         |
|                |                |                |                 |
|                |                |                | Pumps that      |
|                |                |                | provide         |
|                |                |                | injection water |
|                |                |                | flow and valves |
|                |                |                | that change     |
|                |                |                | position to     |
|                |                |                | provide         |
|                |                |                | injection water |
|                |                |                | flow to the     |
|                |                |                | reactor coolant |
|                |                |                | system.         |
+----------------+----------------+----------------+-----------------+
| Barrier        | Identify any   |                | Containment     |
| Integrity      | containment    |                | isolation valve |
|                | integrity      |                | testing,        |
|                | supporting     |                | ventila         |
|                | system,        |                | tion/filtration |
|                | credited by    |                | system testing  |
|                | the licensee   |                |                 |
|                | as operable    |                |                 |
|                | when assessing |                |                 |
|                | risk, which is |                |                 |
|                | adversely      |                |                 |
|                | impacted by    |                |                 |
|                | surveillance   |                |                 |
|                | test failures  |                |                 |
|                | such as        |                |                 |
|                | failure to     |                |                 |
|                | adequately     |                |                 |
|                | test, failure  |                |                 |
|                | to meet test   |                |                 |
|                | criteria or    |                |                 |
|                | failure to     |                |                 |
|                | realign        |                |                 |
|                | equipment      |                |                 |
|                | after the      |                |                 |
|                | test.          |                |                 |
+----------------+----------------+----------------+-----------------+

1\. For additional guidance on IST inspection refer to IP 73756,
AInservice Testing of Pumps and Valves@ and NUREG-1482, AGuidelines for
Inservice Testing at Nuclear Power Plants.@

71111.22-04 RESOURCE ESTIMATE

The annual resource expenditure for this inspection procedure is
estimated to be 95 to 115 hours to review surveillance testing
activities at a site regardless of the number of reactor units at that
site.

71111.22-05 COMPLETION STATUS

Inspection of the minimum sample size will constitute completion of this
procedure in the Reactor Programs Systems (RPS). That minimum sample
size will consist of 18 surveillance testing activities in a year
regardless of the number of reactor units at the site.

71111.22‑06 REFERENCES

Inspection Procedure 73756, AInservice Testing of Pumps and Valves@

Inspection procedure 61720, AContainment Local Leak Rate Testing@

Inspection Procedure 71152, AIdentification and Resolution of Problems@

Bulletin 88‑04, \"Potential Safety‑Related Pump Loss,\" May 5, 1988.

Code of Federal Regulations, Title 10, Part 50, Section 50.55a, \"Codes
and Standards.\"

Generic Letter 89‑04, \"Guidance on Developing Acceptable Inservice
Testing Programs,\" April 3, 1989.

Information Notice 97‑90, AUse of Nonconservative Acceptance Criteria in
Safety‑Related Pump Surveillance Tests,@ December 30, 1997

10CFR50, Appendix J including Option B.

NUREG‑1482, AGuidelines for Inservice Testing at Nuclear Power Plants@

ASME Boiler and Pressure Vessel Code, Section XI, ARules for Inservice
Inspection of Nuclear Power Plant Components@

Inspection Manual Part 9900, Technical guidance, AMaintenance -
Preconditioning of Structures, Systems, and Components Before
Determining Operability@

Regulatory Guide, 1.45, AReactor Coolant Pressure Boundary Leakage
Detection Systems@

Regulatory Issue Summary 06‑17, ANRC Staff Position on the Requirements
of 10 CFR 50.36, Technical Specifications, Regarding Limiting Safety
System Settings During Periodic Testing and Calibration of Instrument
Channels@

END

ATTACHMENT

Revision History - IP 71111.22

+--------+--------+------------------------------+-----+-------+-------+
| 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    | 01/1   | Revised to incorporate minor | NO  | N/A   | N/A   |
|        | 7/2002 | changes to the inspection    |     |       |       |
|        |        | requirements. In addition,   |     |       |       |
|        | CN     | inspection resource          |     |       |       |
|        | 02-001 | estimates and inspection     |     |       |       |
|        |        | level of effort are revised  |     |       |       |
|        |        | to provide a band for more   |     |       |       |
|        |        | inspection flexibility.      |     |       |       |
+--------+--------+------------------------------+-----+-------+-------+
| C1     | 05/1   | Revised to include RCS leak  | YES | 9/24  | N/A   |
|        | 1/2004 | detection system             |     | /2003 |       |
| Refe   |        | surveillance as part of the  |     |       |       |
| rence: | CN     | surveillance testing         |     |       |       |
| Davis  | 04-013 | samples. Revision also       |     |       |       |
| -Besse |        | includes surveillance        |     |       |       |
| L      |        | testing attributes for       |     |       |       |
| essons |        | reviewing annunciator/alarm  |     |       |       |
| L      |        | setpoints and alarm response |     |       |       |
| earned |        | procedure actions.           |     |       |       |
| Task   |        |                              |     |       |       |
| Force  |        |                              |     |       |       |
| Item   |        |                              |     |       |       |
| 3.     |        |                              |     |       |       |
| 2.1(3) |        |                              |     |       |       |
+--------+--------+------------------------------+-----+-------+-------+
| N/A    | 01/0   | Reduced the estimated        | NO  | N/A   | N/A   |
|        | 5/2006 | resources required to        |     |       |       |
|        |        | complete this inspection     |     |       |       |
|        | CN     | activity based on inspection |     |       |       |
|        | 06-001 | hours charged to this IP     |     |       |       |
|        |        | during last several ROP      |     |       |       |
|        |        | cycles. Completed historical |     |       |       |
|        |        | CN search.                   |     |       |       |
+--------+--------+------------------------------+-----+-------+-------+
| N/A    | 02     | IP 71111.22 address feedback | NO  | N/A   | N/A   |
|        | /27/07 | form 71111.22‑912 to clarify |     |       |       |
|        |        | Section 02.02 to more        |     |       |       |
|        | CN-    | clearly describe what is to  |     |       |       |
|        | 07-007 | be accomplished when         |     |       |       |
|        |        | conducting the leakage       |     |       |       |
|        |        | detection surveillance       |     |       |       |
|        |        | inspection.                  |     |       |       |
+--------+--------+------------------------------+-----+-------+-------+