**NRC INSPECTION MANUAL** ITSB

Temporary Instruction 2515/170

RISK MANAGEMENT TECHNICAL SPECIFICATIONS

INITIATIVE 4b

RISK-INFORMED COMPLETION TIMES

CORNERSTONE: MITIGATING SYSTEMS

APPLICABILITY: This Temporary Instruction (TI) applies to South Texas
Project only.

2515/170-01 OBJECTIVE

The objective of this TI is to support the review of licensees'
implementation of the risk management technical specification (RMTS)
Initiative 4b, described in the RMTS Guidelines (NEI 06-09), for
determining risk-informed completion times (RICT), also known as
allowable outage times (AOTs). As an ancillary benefit, this TI promotes
information gathering to help the Nuclear Regulatory Commission (NRC)
staff identify and shape possible future regulatory positions, generic
communications, and rulemaking.

2515/170-02 BACKGROUND

Consistent with the Commission's policy statements on technical
specifications (TS) and the use of probabilistic risk assessment (PRA),
the staff and the industry are developing risk‑informed improvements to
TS. These improvements are intended to maintain and/or improve safety
while reducing unnecessary burden, and to bring TS into congruence with
the Commission's other risk-informed regulatory requirements, in
particular risk management requirements of 10 CFR 50.65(a)(4). The term
"risk management technical specifications (RMTS)" is used to emphasize
the goal of constructing TS that reinforce the pro-active management of
the total risk presented by the plant configuration and actions that may
be needed to respond to planned or emergent conditions.

TS have taken advantage of risk technology as experience and capability
have increased. Since the mid-1980\'s, the NRC has been reviewing and
granting improvements to TS that are based, at least in part, on PRA
insights. In its final policy statement on TS improvements of July 22,
1993, the Commission stated that it expects that licensees will utilize
any plant specific PRA or risk survey in preparing their TS related
submittals. The Commission reiterated this point when it issued the
revision to 10 CFR 50.36, "Technical Specifications," in July 1995. In
August 1995, the NRC adopted a final policy statement on the use of PRA
methods in nuclear regulatory activities that encourage greater use of
PRA to improve safety decision making and regulatory efficiency. Since
that time, the industry and the NRC have been pursuing increased use of
PRA in developing improvements to TS. RMTS Initiative 4b is such an
improvement.

2515/170-03 INSPECTION REQUIREMENTS

03.01 [General]{.underline}

The inspection prescribed by this TI is required to be completed and all
findings resolved to the satisfaction of the NRC staff within 2 years
after implementation or when a question arises over the licensee's
implementation of the RICT technical specification modification in
accordance with NEI 06-09. To complete this TI the licensee must have
exercised the process of extending a Technical Specification (TS)
completion time by either, 1) preplanning and approving an activity
which requires a completion time extension, or 2) emergent conditions
require exercising a completion time extension.

The inspectors will verify that the licensee has effectively implemented
an adequate process, integrated with a comprehensive configuration risk
management program to support the accurate computation of risk-informed
TS completion times, taking all relevant factors into account. In
particular, when TS limiting conditions for operation (LCOs) are not met
(See RIS 2005-20, and IMC 9900 Guidance on Operability Determinations
and Degraded and Non-Conforming Conditions) and the associated
conventional TS CTs or AOTs cannot be met, licensees are expected to
take the specified Required Action OR manage the additional plant risk
with the objective of extending the CT or AOT past the original CT while
maintaining it within the guidelines set forth in the Risk Management
Guidance Document, NEI 06-09, dated November 2006.

Current TS contain structures, systems, or components (SSCs) with
specific allowed outage times, known as TS completion times (CTs). These
times are in effect when the requirements of an LCO are not met and the
unit is in the applicable Mode of Operation for the associated SSC
(e.g., if the diesel generator is inoperable with the unit in Mode 1,
restore to operable within 7 days; otherwise, be in Mode 3 within 6
hours). Current TS address systems independently and do not generally
provide actions for the combined risk impact due to multiple systems
being out of service concurrently. The maintenance rule configuration
risk assessment requirement was added to address this consideration, but
does not obviate compliance with current TS requirements. These current
TS requirements may present inconsistencies with the maintenance rule
requirements, and may require plant shutdown, or other actions, that are
not the most risk-appropriate actions given the specific plant
configuration. The overall objective of this initiative is to modify the
TS, on a case-by-case basis, to reflect a configuration risk management
approach that is more consistent with the maintenance rule 50.65(a)(4)
approach. The proposal involves a combination of the current TS CTs, a
quantified 50.65(a)(4) based risk assessment to determine CT extension
feasibility, and CT backstop limits. The CT backstop limits ensure that
low risk safety functions are not permitted to be inoperable for an
excessive period of time. This initiative would permit, contingent upon
the results of a plant configuration risk assessment, an extension of
the existing CT within an LCO using a quantitative implementation of
50.65(a)(4). During the time the plant is in the CT extension the
configuration risk must be continuously monitored and re-evaluated as
changes in configuration/risk occur. Licensees who undertake to use
RICTs must provide the means and staff for their prompt and accurate
calculation. Where on watch operators are expected to get involved with
RICT calculations, the means to do so should be automated to the extent
that there is minimal or virtually no impact on the operators ability to
operate the plant safely. On watch operators should have the ability to
promptly evaluate changes in plant risk as risk significant equipment
becomes inoperable or operable using on-line risk management tools.

2515/170-04 GUIDANCE

04.01 [General]{.underline}.

The requirements for implementing RICTs are provided in NEI 06-09,
Revision 0. These requirements shall be incorporated in the site
specific procedures and are only applicable in Modes 1 and 2. Some
portions of this Temporary Instruction may not be applicable depending
upon actual plant circumstances (e.g., no additional risk significant
equipment became unavailable while in an extended completion time which
would have required a revised RICT). Portions which could not be
completed should be documented in the report details so further
inspection can be accomplished at a later date, if required. Section
04.05 may require additional support from an SRA at the discretion of
the inspection lead (Senior Resident Inspector).

04.02 [Configuration Risk Management and Application of TS]{.underline}

a.  Review the licensee's process for extending a TS completion time
    past the front stop CT. Verify that the appropriate equipment
    configuration was evaluated and appropriate compensatory risk
    management actions were taken in a prompt manner. Verify the risk
    calculation was performed prior to exceeding the front stop CT.
    Verify that a revised RICT was calculated if additional risk
    significant equipment subsequently became unavailable once the front
    stop CT had been exceeded. Additionally, verify the associated time
    clock had remained in effect until the applicability of the LCO was
    exited.

b.  Perform a review of the RICT calculation with respect to PRA
    Functionality. Refer to Section 2.3.1.11 of NEI 06-09 for PRA
    Functionality Assessment Guidance.

04.03 [Documentation Requirements]{.underline}

a.  Verify station procedures accurately reflect the documentation
    requirements specified in Section 2.3.2 of NEI 06-09. Review the
    associated documentation for a specific instance where the RICT was
    extended past a front stop CT. This documentation should include, as
    a minimum, operator logs, engineering assessments, condition
    reports, functionality assessments and work management tools.
    Additionally, review any risk management actions that were
    implemented. Review Section 2.3.2.6 of NEI 06-09 for further
    documentation requirements.

b.  Review the accumulated annual risk above the zero maintenance
    baseline when equipment is out of service beyond the front stop CT
    as required every refueling cycle.

04.04 [Training]{.underline}

a.  Verify that required training was administered to the following
    personnel, as a minimum: licensed operators, work control personnel,
    PRA personnel, and station management. The required training should
    cover the areas listed in Section 2.3.3 of NEI 06-09 and should be
    commensurate with their respective responsibilities. Select an
    instance where a RICT was extended past the front stop CT OR is
    planned to be extended past the front stop CT and verify personnel
    involved with the approval of the condition received appropriate
    training.

04.05 [PRA Models and Risk Management Tools]{.underline}

> **NOTE**: The following inspection guidance need not duplicate the PRA
> audit that was performed to support issuance of the license amendment.
> Review the plant specific audit to determine if there were any
> deficiencies or follow-up items that are related to the steps below.
> Any portions of the following steps may be repeated at the discretion
> of the lead inspector to support verification that the deficiencies or
> follow-up items were adequately dispositioned.

a.  Verify that the PRA and Configuration Risk Management tool/monitor
    are accurately depicting plant configuration risk. This review shall
    include the licensee's PRA and CRM tool/monitor updates to reflect
    plant modification since the completion of the last PRA update. The
    review shall include NRC inspections of PRA quality (Regulatory
    Guide 1.200) and must verify that the PRA and CRM tool/monitor
    continues to have the scope and capabilities needed for the purposes
    to which it is being applied (e.g., SSCs modeled, initiating events,
    plant conditions and transitions, external events, etc.). Then PRA
    uncertainties must be addressed. Finally, the PRA review must assess
    maintenance of the PRA to reflect design and/or procedural changes
    and significant, persistent changes in SSC reliability or failure
    rates (i.e., updating values assumed in fault-tree analysis). Refer
    to Section 4 of NEI 06-09 for detailed Risk Management Tool
    Attributes.

b.  Review the licensee's risk assessment (RA) processes (See IP 7111.13
    for guidance). Some RA tools or processes use pre-computed risk
    values directly from the PRA. In these cases, because the PRA has
    already been reviewed, the RA process review need only verify that
    the process or tool can readily and accurately access the required
    PRA information and also accurately compute the RICT when an ICDP
    limit is programmed in. For those licensee RA processes that involve
    separate RA tools (e.g., so-called "on-line" risk monitors) that are
    derived from the plant's PRA, the review must verify that (1) there
    is adequate fidelity to the PRA, including no over-simplification
    (e.g., excessive cutset truncation), (2) that PRA fidelity is
    maintained, and (3) that the RA tool can accurately compute the RICT
    taking all relevant factors into account, including, but not limited
    to, plant configuration (for whatever reasons), mode of operation
    and inter-modal transition, maintenance and other activities that
    may affect initiating event frequencies, external events (including
    fire, internal flooding, grid instability and other adverse
    environmental conditions), and containment integrity. Refer to
    Section 4 of NEI 06-09 for detailed Risk Management Tool Attributes.

c.  Verify that the application tools and software are being maintained
    by a quality program. Review section 2.3.5.8 of NEI 06-09 for the
    quality program criteria. This review includes a verification that
    issues related to the RICT program are being identified and entered
    into the corrective actions program.

04.06 [Disposition of Findings]{.underline}

a.  In general, findings of performance deficiencies with respect to 10
    CFR 50.65(a)(4) will be handled in accordance with existing guidance
    (i.e., IP 71111.13, IMC 0612, Appendices B, E, and F, and IMC 0609,
    Appendix K). However, in those cases in which an inadequate RA is
    identified (i.e., underestimate of total overall plant risk and/or
    the increase in risk due to the TS SSC outage), and the inadequate
    RA leads the licensee to exceed the conventional TS AOT/CT and also
    what would have been the RICT, had it been correctly calculated,
    then the licensee must declare the TS LCO not met and promptly
    commence to comply with the TS action statement(s). The licensee
    may/should also take additional risk management actions (RMAs) in
    parallel to limit further risk increases, and also, if practicable,
    to reduce risk at least to the point at which the RICT may remain
    valid. If the front stop CT has expired and that portion of the RICT
    that is valid has expired before the inadequate RA is discovered,
    then the licensee may be found to be in violation of the TS. In
    those instances, the TS violation will be handled as other TS
    violations are handled.

2515/170-05 REPORTING REQUIREMENTS

The results of this Temporary Instruction should be included in Section
4OA4 of an

integrated inspection report and should be forwarded to NRR/DIRS/ITSB,
Attention: Timothy Kolb via e-mail at [tck@nrc.gov]{.underline}. Mr.
Kolb can also be reached by telephone at (301) 415-1428.

2515/170-06 COMPLETION SCHEDULE

This TI should be completed within 2 years after the licensee has
implemented the Risk Managed Technical Specifications license amendment.

2515/170-07 EXPIRATION

This TI will expire 11/30/2009.

2515/170-08 CONTACT

For questions regarding the performance of this TI and emergent issues,
contact: Timothy Kolb at 301-415-1428 or [tck@nrc.gov]{.underline} ; or
Timothy Kobetz at 301-425-5170 or [tjk1@nrc.gov]{.underline}; or Andrew
Howe at 301-415-3078, or [ajh1@nrc.gov]{.underline}.

2515/I70-09 STATISTICAL DATA REPORTING

All direct inspection effort expended on this TI is to be charged to
2515/170 for reporting by the Regulatory Information Tracking System
(RITS) with an IPE code of TI. Indirect inspection effort for
preparation is charged to 2515/170 with an IPE code of TIP. Indirect
inspection effort for documentation is charged to 2515/170 with an IPE
code of TID.

2515/170-10 ORIGINATING ORGANIZATION INFORMATION

10.01 [Organizational Responsibility]{.underline}

This TI was prepared by the Technical Specifications Branch
(NRR/DIRS/ITSB), and issued by the Inspection Programs Branch
(NRR/DIPM/IIPB).

10.02 [Resource Estimate]{.underline}

The estimated direct inspection effort to perform this TI is estimated
to be 20 to 50 hours per unit. This TI should be performed by a Resident
Inspector with assistance from Regional SRA/PRA personnel.

10.03 [Training]{.underline}

No formal training is proposed for the performance of this TI. The
inspectors should be familiar with the information provided in Section
10.04, References.

10.04 [References]{.underline}

IP 71111.13, Maintenance Risk Assessments and Emergent Work Control.

RG 1.174, An Approach for Using Probabilistic Risk Assessment in
Risk-Informed Decisions on Plant Specific Changes to the Licensing
Basis.

RG 1.177, An Approach for Plant-Specific, Risk-Informed Decisionmaking:
Technical Specifications.

RG 1.200, An Approach for Determining the Technical Adequacy of
Probabilistic Risk Assessment Results for Risk Informed Activities.

EPRI 1009474, Dec 2004 RMTS Guidelines.

NEI 06-09, Risk-Informed Technical Specifications Initiative 4b,
Risk-Managed Technical Specifications (RMTS) Guidelines, Industry
Guidance Document (ML063390639).

Risk Assessment Standardization Project NUREG 1896.

Audit Report regarding South Texas Project, Units 1 and 2, Risk-managed
Technical Specifications Application (ML062860170).

END

Attachment 1

Revision History Page

+-------------+---------+------------------+----------+--------------+
| Commitment  | Issue   | Description of   | Training | Comment      |
| Tracking    | Date    | Change           | Needed   | Resolution   |
| Number      |         |                  |          | Accession    |
|             |         |                  |          | Number       |
+-------------+---------+------------------+----------+--------------+
| N/A         | 1       | This TI was      | N/A      | N/A          |
|             | 1/29/07 | created to       |          |              |
|             |         | provide          |          |              |
|             | CN      | inspection       |          |              |
|             | 07-037  | guidance related |          |              |
|             |         | to Risk Informed |          |              |
|             |         | Completion Time  |          |              |
|             |         | Change           |          |              |
|             |         | implementation.  |          |              |
+-------------+---------+------------------+----------+--------------+