NRC INSPECTION MANUAL	IRIB

INSPECTION PROCEDURE 71111 ATTACHMENT 15

OPERABILITY DETERMINATIONS AND FUNCTIONALITY ASSESSMENTS

Effective Date:  01/01/2021

PROGRAM APPLICABILITY:  IMC 2515 A	

CORNERSTONES:	Mitigating Systems

Barrier Integrity

INSPECTION BASES:	See IMC 0308 Attachment 2 

SAMPLE REQUIREMENTS

71111.15-01	INSPECTION OBJECTIVE

To review operability determinations of technical specification (TS) SSCs (including support systems as defined in the TS) or functionality assessments associated with non-TS SSCs affecting mitigating systems and barrier integrity to ensure that operability or functionality is properly justified and the SSC remains capable of performing its specified safety function or current licensing basis (CLB) function, such that no unrecognized increase in risk has occurred.

71111.15-02	GENERAL GUIDANCE

Selection of operability determinations or functionality assessments should involve risk significant SSCs.  Operability is a term solely associated with TS compliance.  Functionality assessments do not involve compliance with TS.  Inspectors should apply risked informed insights together with other factors, such as engineering analysis and judgment, operating experience, and performance history, to determine which operability determinations or functionality assessments should be selected for review.  Selection of operability determinations or functionality assessments can emerge from the inspector's review of plant status documents such as operator shift logs, emergent work documentation, deferred modifications, and standing orders to determine if an operability determination or functionality assessment is warranted for a degraded or nonconforming condition.  

The following can be used to assist the inspector in identifying SSCs that have a risk priority:  

Operating - Mitigating systems and barrier integrity features as determined by 

plant-specific risk information such Risk Achievement Worth.  Examples:  High Pressure Coolant Injection (HPCI) system or Reactor Core Isolation Cooling (RCIC) system.

Shutdown - Mitigating systems and barrier integrity features that perform key safety functions during shutdown.  Examples:  SSCs associated with decay heat removal, inventory control, electrical power availability, reactivity control, core configuration, or containment.

IMC 0326, “Operability Determinations” provides guidance to NRC inspectors to assist in their review of licensee determinations of operability.  This section contains excerpts and discussions from IMC 0326.  More detailed information can be found in IMC 0326.  IMC 0326 no longer contains guidance on assessments of functionality.  However, pertinent guidance is retained in this Inspection Procedure (IP).  In addition, Attachment 1 of this IP contains a high-level visual representation of Operability Determinations / Functionality Assessments as they relate to SSCs described and in the TS and SSCs not described in the TS.

Operability refers to the capability of a TS SSC to perform its specified safety function.  The scope of SSCs considered within the operability determination process are:  1) SSCs that are required to be operable by TS (these SSCs may perform required support functions for other SSCs required to be operable by TS); and 2) SSCs that are not explicitly required to be operable by TS, but that perform support functions as defined in the TS for SSCs required to be operable by TS. 

Operability determinations are appropriate whenever a condition calls into question the ability of an SSC to perform its specified safety functions.  The operability determination process is used to assess operability of SSCs and their support functions for compliance with TS when a condition is identified for a specific SSC required to be operable by TS, or when a condition is identified which impacts a necessary and related support function.  Ensuring operability for any SSC described in TSs is a continual process.  Licensees should evaluate operability upon discovery of a condition that results in the loss of the presumption of operability.  

Functionality assessments generally refers to the capability of a non-TS SSC to perform its function set forth in the CLB.  Functionality assessments may be performed for SSCs not described in TS, but which warrant programmatic controls to ensure that SSC availability and reliability are maintained.  In general, these SSCs and the related controls are included in programs related to Appendix B to 10 CFR Part 50, “Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants,” and the maintenance rule (10 CFR 50.65).  Additionally, SSCs not described in TS may warrant functionality assessments within the processes used to address conditions because they perform functions described in the Updated Final Safety Analysis Report (UFSAR), technical requirements manual, emergency plan, fire protection plan, regulatory commitments, or other elements of the CLB. 

Normally, functionality is assessed and documented through other plant processes such as the corrective action process.  It is appropriate to consider safety significance in determining the appropriate depth of a functionality assessment.  Also, the effect of nonfunctional SSCs on compliance with other regulatory requirements (e.g., Appendix R, station blackout, ATWS, environmental qualification, maintenance rule) should be determined.  In addition, other licensee processes and programs may need to be considered (e.g., availability, maintenance rule, reportability) when SSCs are not functional.

When evaluating the effect of a condition, a licensee may decide to implement compensatory measures as an interim action until final corrective action to resolve the condition is completed.  IMC 0326 contains guidance on the use of compensatory measures.  In addition, compensatory measures that substitute manual operator actions for automatic actions should be resolved expeditiously.  IMC 0326 contains additional guidance on the temporary use of manual actions instead of automatic actions.  A licensee may refer to these compensatory measures as “Operator Work Arounds (OWAs).”  

In addition, if a compensatory measure involves a temporary facility or procedure change, 

10 CFR 50.59 should be applied to the temporary change with the intent to determine whether the temporary change/compensatory measure itself (not the condition) impacts other aspects of the facility or procedures described in the UFSAR.  In considering whether a temporary facility or procedure change impacts other aspects of the facility, a licensee should apply 10 CFR 50.59, paying particular attention to ancillary aspects of the temporary change that result from actions taken to directly compensate for the condition.  Licensees may use the guidance in NEI 96-07, Revision 1, “Guidelines for Implementing 10 CFR 50.59,” which is endorsed by Regulatory Guide 1.187, “Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments.”  NEI has also published a NEI 96-07, Revision 1, Appendix E, “User’s Guide for NEI 96-7, Revision 1, Guidelines for 10 CFR 50.59 Implementation.”  However, NEI 96-07, Revision 1, Appendix E has not been reviewed or endorsed by the NRC.  If needed, questions regarding potential 10 CFR 50.59 issues as a result of a licensee’s use of Appendix E can be raised with the DORL PM.  

For each sample, a routine review of problem identification and resolution activities should be conducted.  Consider if the licensee is identifying problems with operability determinations and functionality assessments at an appropriate threshold, entering them in the corrective action program, and is identifying and implementing appropriate corrective actions.  IP 71152, “Problem Identification and Resolution,” contains background information with regards to conducting reviews of Problem Identification and Resolution activities during the conduct of baseline inspection procedures. 

71111.15-03	INSPECTION SAMPLES

03.01	**Review the licensee’s operability determination or functionality assessment to verify that operability or functionality is justified and that the licensee is taking appropriate actions.**

Specific Guidance

The intent of this inspection is to sample licensee’s operability determinations and functionality assessments for risk significant SSCs to determine if operability determinations and functionality assessments are justified, such that operability and/or availability are assured, and no unrecognized increase in risk has occurred.  Also, the inspections should determine if operability and functionality concerns associated with plant issues and events are being identified.  Inspectors should consider the following aspects: 

· The selected operability determination or functionality assessment has appropriately considered the potential cause(s), extent of the condition, and adverse effects on associated SSC specified safety functions or CLB functions.  Refer to the updated final safety analysis report (UFSAR) and other design basis documents during the review.  

· The licensee is looking beyond the prominent symptoms of the condition to ensure that a narrow focus or non-conservative assumption does not compromise the justification that the SSC remains capable of performing its specified safety functions or CLB functions. 

· If the operability or functionality assessment involves compensatory measures:  The measures are in place, work as intended, do not cause system operation in a manner inconsistent with the specified safety function or CLB function, and are appropriately controlled.  The licensee is considering other conditions and their impact on any compensatory measures for the condition being evaluated.  The licensee is considering whether use of a compensatory measure requires a license amendment. 

· If operability or functionality are not justified, appropriate actions are taken including a determination of impact on any TS limiting condition for operation (LCO).

Depending on the complexity and risk significance of an issue, an inspector may consider consulting with regional specialists to complete a review of a licensee’s operability determination or functionality assessment.  The regional specialist’s time spent on reviewing the issue should be charged to this procedure.  

71111.15-04	REFERENCES

IP 71152, “Problem Identification and Resolution”

IMC 0326, “Operability Determinations” 

IMC 2515, “Light-Water Reactor Inspection Program - Operations Phase”

10 CFR 50.59, “Changes, tests, and experiments.”

NRC Regulatory Guide 1.187, “Guidance for Implementation of 10 CFR 50.59, Changes, Test, and Experiments,” Nov 2000. (ML003759710)

NEI 96-07, Revision 1, “Guidelines for 10 CFR 50.59 Evaluations,” (Nov 2000). (ML003771157)

END

Issue Date:  10/05/20	1	71111.15

Attachment 1:  Operability Determinations / Functionality Assessments of SSCs

Structures, Systems, and Components (SSCs)

SSCs described in TS

· Subject to operability determinations.

· SSC can perform its specified safety function(s).

· NRC guidance found in IMC 0326.

SSCs not described in Technical Specifications (TS)

· Subject to functionality requirements of the current licensing basis (CLB).

· Also performs necessary and related support functions for TS SSCs?

If yes, such functions are within scope of operability determination.

Issue Date:  10/05/20	Att1-1	71111.15

Attachment 2 - Revision History for IP 71111.15

Issue Date:  10/05/20	Att2-1	71111.15

Issue Date:  10/05/20	Att2-3	71111.15