**NRC INSPECTION MANUAL**IRAB

	INSPECTION PROCEDURE 71150

DISCREPANT OR UNREPORTED PERFORMANCE INDICATOR DATA

PROGRAM APPLICABILITY:  IMC 2515 C

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.  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

03.01	PI Review

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 Operating Reactor Assessment Program) because correction of the discrepancy results in a PI performance threshold being exceeded.  The current revision of NEI 99-02, Regulatory 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, Performance 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 Unplanned 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

71150	2	Issue Date: 01/04/07

Issue Date:  04/30/19	2	71150

ATTACHMENT 1

Revision History for IP 71150

Issue Date: 01/04/07	A1-1	71150, Att 1

Issue Date:  04/30/19	Att 1-1	71150