**NRC INSPECTION MANUAL** IPAB

INSPECTION PROCEDURE 71150

DISCREPANT OR UNREPORTED PERFORMANCE INDICATOR DATA

PROGRAM APPLICABILITY: 2515

CORNERSTONES: ALL

71150-01 INSPECTION OBJECTIVE

01.01 To obtain performance indicator (PI) data when (a) licensees do
not provide PI data in accordance with the most current guidance, (b)
reported PI data has major discrepancies, or (c) NRC loses confidence in
the licensee=s ability to collect and report PI data.

01.02 To utilize inspections in order to obtain sufficient insights on
licensee performance in the absence of reliable PI data.

71150-02 INSPECTION REQUIREMENTS

02.01 [PI Review]{.underline}. The following should be considered in
addressing the objectives of this IP, depending on the specific
circumstances:

a.  Ensure that licensees correct major discrepancies with reported data
    for one or more PIs, including the associated collection and
    reporting process.

b.  NRC can independently collect the PI data, if this appears to be
    feasible considering the number and specific nature of the PIs for
    which data is needed.

c.  When independent NRC collection of the data is not feasible, NRC
    should augment the baseline inspection program with additional
    inspection to provide insights on licensee performance to address
    the cornerstone attributes intended to be covered by the PI.

d.  Upon a determination that the PI is discrepant and the data
    unreliable, the NRC will inform the licensee by letter that it is
    entering the discrepant PI process and will modify the NRC web page
    to indicate that the PI is under review.

e.  Once the root cause(s) of the discrepant PI data have been
    identified and corrected, the data corrected, and the NRC has
    verified that the PI data can be collected and reported accurately,
    the NRC will inform the licensee by letter that it is exiting the
    discrepant PI process. The PI will then reflect the appropriate
    color based on licensee reporting, and oversight of the PI reporting
    will return to normal inspection per Inspection Procedure 71151.

71150-03 INSPECTION GUIDANCE

[Specific Guidance]{.underline}

03.01 [PI Review]{.underline}

a.  A PI discrepancy is a difference between the number of occurrences
    of scrams, unplanned power changes, equipment/system
    unavailability/failures, etc., and what is being reported by the
    licensee in the quarterly PI data submittals. PI discrepancies may
    involve a licensee error in data collection and/or reporting, or an
    incorrect licensee interpretation of the PI guidelines in NEI 99-02.
    PI discrepancies are major when they may affect NRC response in
    accordance with the Action Matrix (IMC 0305 AOperating Reactor
    Assessment Program@) because correction of the discrepancy results
    in a PI performance threshold being exceeded. The current revision
    of NEI 99-02, ARegulatory Assessment Performance Indicator
    Guideline@, and the PI section of the reactor oversight process on
    the NRC=s external web page indicates PI performance thresholds.
    This procedure may be used even if the PI data in question is
    outside of the PI data evaluation period.

b.  The entrance criteria for implementation of this procedure is after
    the region has attempted to resolve major or recurring discrepancies
    with the licensee in a timely manner and has lost confidence in the
    licensee=s ability to collect and report PIs. The issues may be
    identified by licensees or by NRC inspections in accordance with IP
    71151,APerformance Indicator Verification.@

c.  The inspector should review licensee records to determine the
    pertinent PI data. IP 71151, Table 1 lists pertinent licensee
    records for NRC use in conducting independent verification of
    licensee reported PI data. These records can also be used for NRC
    independent collection of PI data. The level of effort for this
    should be weighed against that for conducting NRC inspections, as
    outlined in the Resource Estimate section below. For example, the PI
    titled AUnplanned Scrams Per 7000 Critical Hours@ requires data on
    the number of unplanned automatic and manual scrams while critical
    in the previous quarter and the number of hours of critical
    operation in the previous quarter. This data may be obtainable from
    licensee event reports, monthly operating reports, operating logs
    and NRC inspection reports.

d.  Using IP 71151 and other inspection procedures as necessary, the
    region should develop an inspection plan based on the identified PI
    discrepancies. The plan should be implemented at a frequency as
    required to compensate for the lack of reliable PI data. Program
    office assistance should be sought in situations where the guidance
    in this procedure does not seem appropriate.

e.  Upon the NRC determining the need for a discrepant PI inspection, a
    letter should be sent to the licensee informing them that the staff
    has lost confidence in their ability to report PI data accurately
    and/or in a timely manner, and the NRC will be conducting a
    discrepant PI inspection. The letter should also state that the NRC
    will modify the NRC web page to show the PI in question as
    discrepant (i.e., gray) and that the PI is under NRC review. Upon
    completion of the NRC inspection, and recalculation of the PI, if
    applicable, the PI will be assigned the color appropriate with the
    results of the inspection.

f.  Discrepant PI(s) that have inspection findings and/or apparent
    violations need to be documented in an inspection report along with
    their root causes and licensee planned corrective actions to prevent
    recurrence. Discrepant PI findings that also result in apparent
    violations (i.e., 10 CFR 50.9 violations) should be documented in a
    choice letter accompanying the inspection report containing the
    finding(s).

g.  The PI will remain discrepant and the NRC will control the PI until
    the NRC concludes the licensee can report the data correctly and a
    letter is sent to the licensee informing them that the NRC is
    exiting the discrepant PI process. At that point, the PI will
    reflect the data as determined under this process.

71150-04 RESOURCE ESTIMATE

NRC independent collection of PI data may require 100% review of
applicable information. In some cases, NRC effort for 100% review would
be similar to the sampling that is done in IP 71151. In other cases,
conducting 100% review of applicable information would require
significantly greater effort.

Resource estimates for NRC inspection in lieu of obtaining PI data
should be based upon the underlying framework for the pertinent
cornerstone, the existing baseline or other scheduled inspections that
could provide potential insights into the cornerstone attributes, and
the level of effort required by the region to achieve the inspection
objective. Utilization of baseline inspections to provide PI insights
generally requires resources in addition to those expended on the
baseline program. Depending on the situation (such as the length of time
that the PI data is discrepant or unreported), the level of effort may
be expended in a concentrated period of time, spread out over an
extended period, or conducted on an as needed basis. All of these
considerations need to be included in the determination of the
appropriate course of action. Because of the wide range of potential
inspection activities, resource requirements for conducting this
inspection may vary widely.

END

Attachments:1. Revision History

ATTACHMENT 1

[Revision History for IP 71150]{.underline}

+--------+--------+-------------------+------+----------+--------------+
| Comm   | Issue  | Description of    | Trai | Training | Comment      |
| itment | Date   | Change            | ning | Co       | Resolution   |
| Tr     |        |                   | Requ | mpletion | Accession    |
| acking |        |                   | ired | Date     | Number       |
| Number |        |                   |      |          |              |
+--------+--------+-------------------+------+----------+--------------+
| NA     | 03     | Revised to better | NA   | NA       | NA           |
|        | /06/01 | define the        |      |          |              |
|        |        | criteria of NRC   |      |          |              |
|        |        | losing confidence |      |          |              |
|        |        | in a licensee\'s  |      |          |              |
|        |        | ability to        |      |          |              |
|        |        | collect and       |      |          |              |
|        |        | report            |      |          |              |
|        |        | performance       |      |          |              |
|        |        | indicators.       |      |          |              |
|        |        | CN01-006          |      |          |              |
+--------+--------+-------------------+------+----------+--------------+
| NA     | 06     | Revised to add    | NA   | NA       | NA           |
|        | /06/05 | additional        |      |          |              |
|        |        | clarity for entry |      |          |              |
|        |        | and exit          |      |          |              |
|        |        | conditions to use |      |          |              |
|        |        | this procedure,   |      |          |              |
|        |        | as well as        |      |          |              |
|        |        | additional        |      |          |              |
|        |        | guidance to       |      |          |              |
|        |        | regions on        |      |          |              |
|        |        | determining when  |      |          |              |
|        |        | a PI is           |      |          |              |
|        |        | discrepant.       |      |          |              |
|        |        |                   |      |          |              |
|        |        | CN05-015          |      |          |              |
+--------+--------+-------------------+------+----------+--------------+
|        | 01     | Researched        | NA   | NA       | ML063510005  |
|        | /04/07 | commitments back  |      |          |              |
|        |        | four years - none |      |          |              |
|        | CN     | found as of       |      |          |              |
|        | 07-001 | 12/20/06.         |      |          |              |
|        |        |                   |      |          |              |
|        |        | Revised to delete |      |          |              |
|        |        | references to     |      |          |              |
|        |        | safety system     |      |          |              |
|        |        | unavailability    |      |          |              |
|        |        | PIs and           |      |          |              |
|        |        | incorporate       |      |          |              |
|        |        | mitigating system |      |          |              |
|        |        | performance       |      |          |              |
|        |        | indices.          |      |          |              |
|        |        | Eliminated other  |      |          |              |
|        |        | unnecessary       |      |          |              |
|        |        | sections. CN06-13 |      |          |              |
+--------+--------+-------------------+------+----------+--------------+