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NRC INSPECTION MANUAL RSIB

INSPECTION PROCEDURE 93802

OPERATIONAL SAFETY TEAM INSPECTION (OSTI)

PROGRAM APPLICABILITY: 2515

SALP Category: Plant Operations

93802-01 INSPECTION OBJECTIVES

01.01 Verify that the plant is being operated safely and in

conformance with regulatory requirements.

01.02 Verify that the organizations that control and support

plant operations are functioning effectively to ensure operational

safety. These entities include operations, maintenance, surveillance, management oversight, technical support, safety review,

quality assurance, and corrective action.

01.03 Verify that the licensee has properly prepared the staff

and the plant for resumption of power operations after an extended

shutdown.

93802-02 INSPECTION REQUIREMENTS

During this inspection, emphasis will be placed on the effectiveness

of the licensee's operations activities to ensure the safe operation

of the plant, including the effectiveness of other organizational

components in supporting operations. The inspection should focus

only indirectly on programs, and the primary emphasis should be

directed at the licensee's performance and whether the interfaces

between operations and the other areas in the plant organization are

controlled and conducted in a manner that contributes to plant

safety. In general, the identification of programmatic deficiencies

should be a by-product of the examination of the licensee's safety

significant performance problems, including the evaluation of test

data and any exceptions taken to test acceptance criteria.

The OSTI, which can be performed by either a Headquarters or

regional team, will typically consist of a two week onsite

inspection conducted by a team of approximately seven inspectors and

a team leader. Three team members will be assigned to the

operations area on a rotating shift basis to monitor control room

and related activities for a minimum of 72 continuous hours. When
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selecting team members, nuclear power plant operating experience

should be a primary consideration, especially in the operations

area.

Because the inspection is directed at safe performance and not

simply compliance, direct observations of licensee activities should

be emphasized (e.g., plant 
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evaluations, maintenance activities, surveillance testing, and QA

audits) and supplemented by personnel interviews and document

reviews.

A team member will be assigned the lead responsibility for the

inspection in each of the areas listed below. The inspection

procedures listed in Section 93802-03, "Inspection Guidance," may

be used for additional inspection guidance. Depending on the

particular plant inspected, the team may not be able to thoroughly

complete each of the inspection tasks described below. Team leaders

must exercise discretion to guide the individual inspectors toward

topics of safety significance in each functional area.

02.01 Operations

a. Observe the conduct of operations personnel both inside and

outside the control room for approximately 72 continuous

hours. When possible, periods of continuous observation

should be selected to include changes in plant operating

conditions, tests, and surveillances as these activities are

more illustrative of operator knowledge and skills than those

observed during sustained steady state operations. Based on

these observations, determine the quality of operator

professionalism, attentiveness, awareness of plant status,

communications, conduct of plant evolutions, response to

alarms and other abnormal indications, adequacy of training,

and overall planning and control of plant and shift activities.

b. Assess the effectiveness of shift turnovers by observing as

many different turnovers as possible. Determine if adequate

time is allotted for the conduct of turnovers and if control

room documentation (e.g., shift logs and night orders) is

useful and available.

c. While observing routine activities inside the control room,

evaluate access control and traffic in the control room.

Determine whether collateral duties of the operators (e.g.,

filling out tag-outs and interfacing with maintenance and

surveillance test performers) have an adverse effect on their

ability to operate the plant safely. Assess the adequacy of

annunciator response, number of continuously lit annunciators,

and response to out of service equipment and components.

d. Determine the effectiveness with which operations appropriately controls support activities in progress, including

maintenance, trouble shooting, and testing activities which

can potentially influence plant operations.

e. Accompany an auxiliary operator during routine rounds, or

otherwise tour the plant at least once per shift. During

these tours, assess the ability of operators to observe areas

secured as a result of radiation levels or security plan

requirements. Assess the adequacy of housekeeping, radiological controls, lighting, equipment labeling, and vital area

access controls.
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f. Walk down portions of selected safety systems and evaluate the

licensee's configuration control practices. Confirm that

valve and breaker positions conform to procedure requirements

and that positions required by procedure are consistent with

those on controlled plant drawings and system lineup procedures.

g. Review jumper, lifted lead, and other temporary modification

logs. Determine (1) if an adequate technical review was

performed before the plant modification was performed, and (2)

if plant drawings were updated, as needed, to reflect the

change before operators must operate the plant as changed.

Temporary modification reviews should include an assessment

of the licensee's root cause analysis process and thoroughness

of 10 CFR 50.59 evaluations. The licensee's controls for

limiting the duration of temporary modifications should be

reviewed. Assess the role of the plant, system, and design

engineering groups in the temporary modification process.

h. Select one or more safety system tag-outs for inspection.

Determine if the tagout is adequate for the work to be

accomplished. Verify in the plant that operators are thorough

in tagging and isolation of plant equipment. Verify, by

observation that tags are properly hung and equipment has been

placed in the designated position. Determine if equipment

status changes and corresponding entry into or exit from

technical specification action statements are appropriately

documented. Determine if the licensee has adequate controls

to ensure the independent verification of equipment status,

particularly when equipment is returned to service. Assess

the adequacy of operability verification testing when

returning equipment to service.

i. Determine the availability and currency of normal and abnormal

operating procedures in the control room, including alarm

response procedures. Observe the extent to which operations

personnel appropriately follow plant procedures during the

conduct of changes to plant operations. Determine if the

licensees process to revise and control procedures encourages

or discourages identification and correction of procedure

deficiencies.

j. Select two recent required reading documents and familiarize

yourself with their contents. By questioning and discussing

these documents with on-shift reactor operators and senior

reactor operators, assess the effectiveness of the required

reading program.

k. Determine the qualification and license status of on-shift

operators. Ensure that the technical specification requirements controlling overtime and minimum shift staffing are

satisfied.

02.02 Maintenance

a. Observe licensee personnel performing corrective and preventive maintenance to verify that maintenance is planned,
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controlled, and performed in a manner that enhances safe

operation of the plant. Verify that the maintenance is

performed in accordance with current written and approved

instructions that are detailed enough to perform the intended

maintenance and adequately document the maintenance performed.

Also review a sample of completed work packages and machinery

history records and verify that they demonstrate these same

attributes.

b. Verify that maintenance jobs that could affect technical

specification limiting conditions for operation or

safety-related equipment performance, or otherwise influence

the safe operation of the plant, are appropriately prioritized

and dispositioned in a timely manner.

c. Verify that maintenance activities are coordinated with

control room operations and that appropriate briefings and

turnovers are held with control room operators. Verify that

machinery isolation and tagging is appropriate for the

activities and conforms to procedural requirements.

d. Review the maintenance training program and selected

craftperson's training records to verify that training is

adequate and appropriate for the level of work being performed

by that individual.

e. Determine the nature and extent of the licensee's backlog of

corrective and preventive maintenance, especially concerning

equipment of high safety significance. Assess the licensee's

efforts to integrate preventive and corrective maintenance to

minimize equipment unavailability. Identify licensee efforts

to reduce the corrective maintenance and preventive

maintenance deferrals.

f. Assess the adequacy and implementation of the preventive

maintenance program through the selection and examination of

several safety significant components or components for which

machinery history indicates high corrective maintenance

frequency.

g. Assess the adequacy of trending of corrective maintenance

history and measures to deal with high maintenance components.

Maintenance history and trending should support the

identification and correction of repetitive work.

h. Determine if engineering input into maintenance activities is

at an appropriate level to ensure safe and reliable plant

operations.

i. Determine whether quality control (QC) inspections are being

conducted during the performance of maintenance and whether

the number and nature of QC inspections are adequate to

contribute to effective maintenance.

j. Determine if specific guidance exists with regard to

designation of QC hold points and that the guidance is being

effectively applied.
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k. Determine if appropriate post-maintenance testing is being

specified following the conduct of maintenance activities and

that there is involvement of engineering in specifying the

tests when appropriate.

l. Observe activities and review documents related to the

licensee's control of measuring and test equipment. Verify

that calibrations are being performed at the required

frequencies and that the program includes a tracking system

so that when measuring and test equipment are found to be out

of calibration, an evaluation is made and documented of the

validity of previous inspection or test results and of the

acceptability of items previously inspected or tested. Verify

that appropriate measures are identified and employed to

handle, store, and distribute contaminated test and

measurement equipment.

02.03 Surveillance

a. Observe a number of surveillance tests being performed by

licensee personnel in the mechanical, electrical, and

instrumentation and control maintenance groups and verify

that:

1. Required administrative approvals were obtained before

testing was started and, when appropriate, entry into

technical specification action statements was documented.

2. Testing is being accomplished by qualified personnel in

accordance with current and approved procedures that are

adequate to meet technical specification requirements.

3. Test instrumentation is calibrated and properly used.

4. Procedures are adequate to satisfy the test requirements

of the technical specification surveillances.

5. Test results meet technical specification acceptance

criteria.

6. Test discrepancies or problems are documented and

properly resolved in a timely manner.

7. Surveillance testing is completed within the required

technical specification frequency.

b. Review a sample of completed surveillance tests. Determine

if the test procedures used are of the correct revision and

are technically accurate and if qualified personnel adequately

tested the designated equipment. Determine if the acceptance

criteria are clearly specified and shown to have been met in

the tests reviewed. Where discrepancies are noted, determine

if they have been adequately evaluated and if any required

corrective actions have been initiated.

c. The adequacy of the nontechnical specification surveillance

program should be assessed. Include plant equipment which is
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not explicitly addressed by the technical specifications but

which requires periodic surveillance (e.g., vibration

monitoring of rotating equipment, tank levels, instrument air

quality, and lube oil levels). The inspection guidance listed

above may also be applied to those required equipment

surveillance not listed in the technical specifications.

02.04 Engineering and Technical Support

a. By interviewing personnel and reviewing documents related to

equipment performance problems, evaluate the effectiveness of

the technical staff, including plant, technical, and design

engineers, in supporting safe operation of the plant. Verify

that the work backlog is manageable and that items that could

affect safety are given a high priority and are addressed in

a timely manner.

b. Evaluate the effectiveness of system engineers (when

applicable) to determine the extent that:

1. The system engineer has received classroom training and

practical experience on the systems assigned that

individual.

2. The system engineer is active and involved in the

performance of the assigned system(s) and components and

communicates effectively with operations, maintenance,

and other engineering groups.

3. System engineers effectively coordinate with design

engineering to evaluate and improve system performance

and safely modify the system when required.

c. By review of selected modification packages determine the

effectiveness of the licensee's efforts to meet its licensing

commitments and to preserve the design basis. Through

observations during the inspection assess the licensee's

concern for control over plant configuration by attempting to

identify unauthorized or undocumented modifications to plant

equipment. This review should include:

1. Identification of all temporary modifications currently

in place and an assessment of their impact upon the

plant's approved design configuration including

appropriateness of the installation duration.

2. Review of selected field change requests (FCRs) and

nonconformance reports (NCRs) to ensure that an

appropriate and timely evaluation, and where necessary,

a corrective action has been completed.

3. Ensure that the 10 CFR 50.59 safety evaluations have been

prepared or reviewed by engineering personnel familiar

with the technical basis of the associated licensing

commitments.
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4. Review the backlog of design changes (DCs) to be

installed. Ensure that safety evaluations of other later

DCs appropriately consider the status of related and yet

to be installed DCs.

5. Review the technical basis of selected DCs to ensure that

all multi-disciplinary licensing commitments are met and

a documented technical basis exists for the DC.

6. Verify that the corrective action associated with NCRs,

as well as DCs, address the root cause of the initiating

concern, and are not addressing merely the proximate

cause or a symptom.

7. Review the FCNs associated with selected DCs to ensure

that a modification is not engineered by FCN. Design

changes should not have an excessive number of FCNs

written against them.

8. Review DCs to ensure that appropriate and timely changes

have been made to Emergency Operating Procedures (EOPs),

off normal response procedures, or maintenance,

surveillance, and test procedures.

9. Review a select number of DCs to verify the proper

procedural steps were taken to declare a modification

operable, and verify appropriate operator training was

performed.

10. Review temporary modifications to verify proper 10 CFR

50.59 review and appropriate involvement of the onsite

safety review committee.

11. Review maintenance records to verify changes to design

were not made under maintenance requests.

d. Assess the communication interface between operations,

maintenance, and engineering. Verify that appropriate

engineering guidance is requested and obtained to resolve

technical problems. Assure that such guidance is accurate,

complete, and technically correct and that it is incorporated

into a corrective action plan.

02.05 Health Physics. By observation of activities and

interviews, evaluate the safety-significant interaction of the

health physics (HP) organization with the operations and maintenance

staffs.

02.06 Management Oversight

a. Interview licensee management personnel and observe activities

concerning safety-significant equipment (e.g., plan-of-day

meeting and outage planning meeting) to evaluate management's

involvement and effectiveness in operating the facility.

Evaluate its attitude toward operational safety, ALARA,

response to events, identification and documentation of

significant deficiencies, and corrective actions. Interview
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personnel at all levels on the plant staff to evaluate

communications effectiveness. Determine if workers understand

management directives, policies, and goals and if management

has a good perception of what is going on in the plant.

Assess the actual time spent by management on independent

observation of work in the control room and plant.

b. Evaluate management's concern for keeping the plant on the

line against its concern for safe operation of the plant by

assessing, for example, the thoroughness of management reviews

conducted before plant restart (e.g., post-trip and event

reviews) or for root-cause analyses of equipment failures and

corrective actions.

c. Review and discuss with licensee personnel the effectiveness

of any current licensee-initiated programs (e.g., procedures

upgrade).

d. Determine the extent to which licensed operators recognize the

supervisory responsibilities associated with their license and

assess their effectiveness in directing the activities of

nonlicensed operators, technicians, and craftspersons.

02.07 Safety Review. Attend onsite and offsite safety review

committee meetings and evaluate member participation, preparation,

the approval process (e.g., review adequacy, the availability of

technical experts to answer questions, and the 10 CFR 50.59

process). Determine if the overall conduct of the committee members

appropriately supports and enhances the safe operation of the plant.

Verify that technical specification requirements for document

reviews are being followed.

02.08 Corrective Action

a. Using safety-significant equipment that has had problems as

the focus, review the licensee's program for identifying,

documenting, and correcting problems. The program should have

a mechanism for raising significant deficiencies to an

appropriate level of management control.

b. Determine if deficiencies are prioritized on the basis of

safety significance and if deficiencies that could affect

plant safety are corrected in a timely manner.

c. Verify that deficiencies are reported to the appropriate level

of plant management and, if required, to the NRC.

d. Evaluate the effectiveness of the licensee's corrective action

programs, including root cause determinations, in supporting

operational safety by interviewing personnel, observing

activities, reviewing procedures, deficiency reports, root

cause evaluations, licensee event reports, and audit reports,

especially those associated with equipment or plant problems.

Assess whether the licensee makes appropriate periodic reviews

of corrective action effectiveness to evaluate the need for

an additional corrective action.
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e. Determine if the corrective action process is structured to

emphasize safety as well as compliance.

f. Verify that corrective action bounds the effects of any

identified operational safety deficiency.

g. Verify that the licensee's program for review and disposition

of industry notifications and NRC bulletins, information

notices, and generic letters addresses all safety aspects of

these documents.

02.09 Restart After Prolonged Outage. Before plant startup from

an extended outage, the inspection should ensure that the licensee

has properly prepared the plant and staff for operations. This

inspection supplements any inspections found necessary to ensure

satisfactory accomplishment of the approved objectives of the

licensee's restart plan. This inspection will also emphasize

management oversight, corrective action programs, root-cause

analysis, and the readiness to support operations.

The inspection should concentrate on plant operations, but should

give due consideration to the importance of maintenance,

surveillance, engineering, health physics, and technical staff

effort in support of restart. Suggested inspection points include

the following areas:

a. Focus the inspection on activities that have the greatest

potential impact on safety, such as reactor startup,

heatup/cooldown, refueling, and surveillances. Direct

observations are preferred and should be supplemented by

personnel interviews and document reviews. Systems should be

selected for inspection on the basis of their potential to

cause safety challenges. Recently modified components or

systems are likely candidates for examination. Also, the

results of probabilistic risk assessment studies should be

used, if available.

b. Evaluate licensee management's attention to transitional

controls. For example, outage deficiency "punch" list items

converted to maintenance work order items still represent

incomplete work. Evaluate management's oversight and controls

in daily work and preparation activities. Review licensee

performance in conducting preventive maintenance activities

on schedule and in exercising appropriate control over

deferred preventive maintenance.

c. Review the licensee's operating experience feedback program

as an administrative control program that continually

addresses lessons learned and that establishes the safety

significance of problems that have developed in the startup

of similarly designed plants. Determine if procedural

problems are being effectively identified and expeditiously

corrected.

d. Evaluate the licensee's self-assessment capability as it

relates to readiness for operation. Evaluate the

effectiveness of the root-cause analysis process and generic
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applicability review of self-identified problems, as well as

the effectiveness of the corrective action program.

e. Determine whether operator training, including simulator

usage, includes appropriate core characteristics and system

response. Through operator interviews, control room

observations, and review of alarm response procedures,

establish whether shift personnel are prepared to properly

respond to abnormal plant conditions, instrumentation and

control (I&C) set point and display anomalies, and the

potential for a high number of challenges to safety systems

during testing. Determine if operator training has been

provided on recently modified systems or components where the

equipment may be expected to operate differently than before

modification.

f. Evaluate differences in the QA/QC organizational interfaces

with other station departments under operational versus outage

controls. Look for the adequacy of planning to complement

startup testing activities under technical specification

constraints as opposed to the latitude for "troubleshooting"

problems that exists under outage testing controls. Verify

QA/QC participation during maintenance work performed on

backshifts.

g. Determine if the licensee has implemented an effective

technical specification update process and if human factors

improvements (e.g., color coding) for the ease of operations

and maintenance are being continually assessed and implemented

in a timely manner. Verify that plant procedures accurately

reflect the correct technical specification section.

h. Assess whether the licensee has an effective program to review

and focus attention on balance-of-plant (BOP) operations to

reduce the frequency of plant transients.

i. Evaluate the adequacy of licensee procedures to deal with

material and personnel access and work control problems when

the radiologically controlled areas (RCA) and protected and

vital areas are reestablished.

j. Evaluate the status of control room annunciators, alarms, and

recorders. Verify the acceptability of the licensee's

methodology for compensatory measures for those indications

not operating properly.

k. Evaluate the licensee's program to review and evaluate the

impact of the backlog of the maintenance work requests,

including its collective impact on safety system availability.

l. Review some modifications to determine if 10 CFR 50.59 reviews

were properly conducted and were appropriate. Consider if a

technical specification change or relief should have been

initiated in conjunction with the 10 CFR 50.59 review and if

the evaluation was adequate to determine whether the

modification involved an unreviewed safety question.
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m. Inspect a sample of completed modifications and review the

conduct and adequacy of any additionally required operator

training, the need for updating operating and emergency

procedures, the adequacy of post-modification testing, and the

proper control of affected drawing revisions to include the

issuance of updated drawings to all controlled drawing areas

(e.g., control room, technical support center, and emergency

operations facility) before making the modification

operational.

n. Examine licensee adherence to commitments made in response to

NRC orders, bulletins, and notices of violations.

o. Inspect a sample of QA/QC records covering the conduct of

outage activities to verify that the licensee has established

the correct level of independent quality overview of the work

and the specification of and compliance with meaningful

inspection hold points.

p. Review the scope of the licensee's restart plan to ensure

comprehensive coverage of staffing and training requirements,

system valve lineups, equipment operability, surveillance

requirements, mode change checklists, and control of

incomplete plant work. Special emphasis should be placed on

inspection of completed corrective actions for the causes of

the extended outage.

q. Determine whether senior management has been closely involved

in the restart effort, whether management is effective in

directing restart activities for around-the-clock activities,

and whether technical and other support staff coverage is

available at all times. Where significant management turnover

has occurred, verify that adequate training was completed.

r. Evaluate the restart processes for problem identification and

resolution, established authority for decisionmaking, and

corrective action followup. Determine if these processes

differ from those in practice during routine operations and

whether quality goals are being achieved.

The inspection of a startup after a prolonged outage should include

72-hour coverage of shift operations for at least a portion of the

readiness review period. The performance of different operating

crews and other station staff should be monitored for effective

communications, adequate support, and correct control of and

response to major operational evolutions. Discussions with

operations, maintenance, radiation control, technical support, and

other plant personnel should be conducted on backshifts and the

cognizance and effective control of backshift activities by plant

management should be confirmed.

93802-03 INSPECTION GUIDANCE

General Guidance. Previous NRC evaluations disclosed that a team

inspection focused on operational safety can be of value in

assessing operational safety at a plant and especially in
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identifying the root causes of operational problems. Teams have

been found to be more effective than individual inspectors because

operational problems contain implications for many functional

groups, including operations, maintenance, surveillance testing,

management, technical support, safety review, quality assurance, and

all groups responsible for participating in the completion of

required corrective actions.

In general, the identification of programmatic deficiencies in the

preventive maintenance program should be a byproduct of the

examination of the licensee's safety significant performance

problems, including the evaluation of test data and any exceptions

taken to test acceptance criteria.

03.01 Specific Guidance. Detailed inspection guidance for each

applicable functional area is provided in the following inspection

procedures.

Appropriate sections of the inspection procedures are to be used as

additional guidance in performing the inspection. Inspection

Procedure 42700, "Plant Procedures," should be used as guidance in

assessing the adequacy and appropriate use of procedures in each of

the areas.

a. Inspection Requirement 02.02.a, Operations

1. 71707 Operational Safety Verification.

2. 71710 Engineered Safety Features System Walkdown.

3. 71715 Sustained Control Room and Plant Observation.

b. Inspection Requirement 02.02.b, Maintenance

1. 62702 Maintenance Program.

2. 62703 Monthly Maintenance Observation.

3. 62704 Instrumentation Systems (Components and Systems).

4. 62705 Electrical Maintenance (Components and Systems).

c. Inspection Requirement 02.02.c, Surveillance

1. 61700 Surveillance Procedures and Records.

2. 61725 Surveillance Testing and Calibration Control

Program.

3. 61726 Monthly Surveillance Observation.

4. 73753 Inservice Inspection.

d. Inspection Requirement 02.02.f, Management Oversight

1. 36100 10 CFR Part 21 Inspection.
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2. 37700 Design, Design Changes, and Modifications.

3. 10 CFR 50.59 Part 9800 CFR Discussions, Changes to

Facilities, Procedures and Tests (or Experiments).

e. Inspection Requirement 02.02.g, Safety Review

1. 40500 Evaluation of Licensee Self-Assessment Capability.

f. Inspection Requirement 02.02.h, Corrective Action

1. 35701 QA Program Annual Review.

2. 40702 Audit Program.

3. 92720 Corrective Action.

93804-04 INSPECTION RESOURCES

Each inspection is planned for 4 weeks for seven to nine persons

with 2 of the 4 weeks being onsite inspection (an accumulative

onsite total of 14 to 18 staff weeks) and two weeks in-office

inspection preparation and report writing. With expected additional

effort by the team leader, the resource allocation typically totals

30 to 38 staff weeks. This total includes preparation, inspection,

and report writing.

END