Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability (Generic Letter 91-18)

November 7, 1991 


TO:       ALL NUCLEAR POWER REACTOR LICENSEES AND APPLICANTS

SUBJECT   INFORMATION TO LICENSEES REGARDING TWO NRC INSPECTION MANUAL 
          SECTIONS ON RESOLUTION OF DEGRADED AND NONCONFORMING CONDITIONS 
          AND ON OPERABILITY (GENERIC LETTER 91-18)

The NRC staff has issued two sections to be included in Part 9900, Technical 
Guidance, of the NRC Inspection Manual.  The first is, "Resolution of 
Degraded and Nonconforming Conditions."  The second is, "Operable/ 
Operability:  Ensuring the Functional Capability of a System or Component."  
Copies of the additions to the NRC Inspection Manual (enclosure) are 
provided for information only.  No specific licensee actions are required.  

The additions to the NRC Inspection Manual are based upon previously issued 
guidance.  However, because of the complexity involved in operability 
determinations and the resolution of degraded and nonconforming conditions, 
there have been differences in application by NRC staff during past 
inspection activities.  Thus, the purpose of publishing this guidance is to 
ensure consistency in application of this guidance by the NRC.  Regional 
inspection personnel have been briefed on this guidance.  The NRC will 
conduct further training on these topics to ensure uniform staff 
understanding.  

The use of this guidance by inspectors may raise backfitting issues for 
specific licensees.  The NRC backfitting procedures apply in such cases.  
Licensees should consult with the Regional office regarding the application 
of specific staff positions in the guidance.  

Please contact the appropriate NRC Project Manager if you have any questions 
regarding this matter.



                    James G. Partlow
                    Associate Director for Projects
                    Office of Nuclear Reactor Regulation

Enclosure:     As stated


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