IP 71111.17T, Evaluations of Changes, Tests, and Experiments
Evaluations of Changes, Tests, and Experiments
text
Issue Date: 12/08/16 1 71111.17T
NRC INSPECTION MANUAL IRIB
INSPECTION PROCEDURE 71111 ATTACHMENT 17T
EVALUATIONS OF CHANGES, TESTS, AND EXPERIMENTS
Effective Date: 01/01/2017
INSPECTABLE AREA: Evaluations of Changes, Tests, and Experiments
CORNERSTONES: Initiating Events
INSPECTION BASES: The inspection monitors the effectiveness of the licensee’s
implementation of changes to facility structures, systems, and
components (SSCs), risk significant normal and emergency
operating procedures, test programs, and the updated final safety
analysis report (UFSAR) in accordance with the requirements of
10 Code of Federal Regulations (CFR) 50.59. The inspection
provides assurance that required license amendments have been
obtained.
This inspection procedure verifies aspects of the Initiating Events,
Mitigating Systems, and Barrier Integrity cornerstones for which
there are no performance indicators to measure licensee
performance. Potential issues regarding the impact that changes
have on Emergency Preparedness and Security should be raised
and addressed under their respective Inspection Programs.
LEVEL OF EFFORT Triennially review 18 to 37 evaluations, screenings, and/or
applicability determinations for 10 CFR 50.59.
71111.17-01 INSPECTION OBJECTIVES
01.01 Verify that evaluations were performed in accordance with 10 CFR 50.59.
71111.17-02 INSPECTION REQUIREMENTS
02.01 Sample Selection
Review evaluations performed in accordance with 10 CFR 50.59, and changes, tests, or
experiments performed since the last triennial modification inspection that the licensee
determined did not require 10 CFR 50.59 evaluations based upon the following:
Issue Date: 12/08/16 2 71111.17T
a. Safety Significance;
b. Risk Significance;
c. Complexity.
02.02 Inspection
NOTE: NEI 96-07, Revision 1, Appendix E shall not be used by NRC staff in evaluating
compliance with the provisions of 10 CFR 50.59.
Inspection of evaluations performed in accordance with 10 CFR 50.59, and changes, tests,
experiments, or methodology changes that the licensee determined did not require 10 CFR 50.59 evaluations.
a. Verify that when changes, tests, or experiments were made, evaluations were
performed in accordance with 10 CFR 50.59. Verify that the licensee has
appropriately concluded that the change, test or experiment can be accomplished
without obtaining a license amendment.
b. Verify that safety issues related to the changes, tests, or experiments have been
resolved.
c. For the changes, tests, or experiments that the licensee determined that evaluations
were not required, verify that the licensee’s conclusions were correct and consistent
with 10 CFR 50.59.
02.03 Problem Identification and Resolution
Verify that the licensee is identifying problems related to 10 CFR 50.59 applicability
determinations, screenings and evaluations, and entering them in the corrective action program.
For a selected sample, evaluate appropriateness of corrective actions.
71111.17-03 INSPECTION GUIDANCE
03.01 Sample Selection
The resident inspector staff and the Nuclear Reactor Regulation project manager should be
consulted for recommendations on sample selection. Substantial changes performed since the
last triennial inspection should be reviewed as samples. Samples should be of such complexity
that the change affects either the license basis or the 10 CFR 50.2 Design Basis. Consideration
should also be given to degraded and non-conforming conditions by selecting evaluations or
screenings associated with operability evaluations and temporary modifications. If available as
a potential sample selection, additional consideration should also be given to reviewing 6 to 12
evaluations and 12 to 25 screenings and/or applicability determinations for 10 CFR 50.59.
Since lists of changes provided by the licensee will not necessarily indicate the complexity and
scope of a change, a number of changes should be reviewed prior to the inspection to meet the
“complexity” criteria contained in section 02.01. This is best accomplished by first choosing
documents from the list provided by the licensee and then requesting the actual documentation
for the changes. An initial review of these changes for complexity prior to the inspection should
result in a smaller final list of samples.
Issue Date: 12/08/16 3 71111.17T
03.02 Inspection
Regulatory Guide (RG) 1.187 “Guidance for Implementation of 10 CFR 50.59, Changes, Tests,
and Experiments,” states that Revision 1 of NEI 96-07, “Guidelines for 10 CFR 50.59
Evaluations” provides methods that are acceptable to the NRC staff for complying with the
provisions of 10 CFR 50.59. 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.
Inspectors may review programmatic procedures to verify that licensee processes and
standards are met.
03.03 Problem Identification and Resolution
See Inspection Procedure (IP) 71152, "Problem Identification and Resolution," for additional
guidance.
71111.17-04 RESOURCE ESTIMATE
This inspection procedure is estimated to take 86 to 106 hours0.00123 days <br />0.0294 hours <br />1.752645e-4 weeks <br />4.0333e-5 months <br /> and should be performed by
engineering specialists knowledgeable in the affected subject areas.
71111.17-05 COMPLETION STATUS
Inspection of the minimum sample size will constitute completion of this procedure in the
Reactor Programs Systems. That minimum sample size will consist of the review of at least 18
evaluations, screenings, and/or applicability determinations. Refer to Inspection Manual
Chapter 2515, “Light-Water Reactor Inspection Program - Operations Phase,” for further
guidance on procedure completion.
71111.17-06 REFERENCES
IP 71111.18, “Plant Modifications”
IP 71152, “Problem Identification and Resolution”
IMC 2515, “Light-Water Reactor Inspection Program - Operations Phase”
NRC Inspection Manual Part 9900 10 CFR Guidance, “10 CFR 50.59 Changes, Tests, and
Experiments”
10 CFR 50.59, “Changes, tests, and experiments.”
Issue Date: 12/08/16 4 71111.17T
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)
RIS 2016-03, “10 CFR 50.59 Issues Identified in NRC's San Onofre Steam Generator Tube
Degradation Lessons Learned Report,” April 2016. (ML15196A575)
http://nrr10.nrc.gov/rorp/ip71111-17.html
END
Issue Date: 12/08/16 Att 1-1 71111.17T
Attachment 1
Revision History for IP 71111.17T
Commitment
Tracking
Number
Accession
Number
Issue Date
Change Notice
Description of Change Description of
Training Required
and Completion
Date
Comment and
Feedback Resolution
Accession Number
(Pre-Decisional,
Non-Public)
NA ML082670321
01/31/08
CN 08-005
New inspection procedure (IP) which combines the
previous IP 71111.02, “Evaluations of Changes, Tests,
or Experiments,” and the biennial portion of IP 71111.17, “Permanent Plant Modifications” as a
triennial inspection.
No ML080250279
NA ML073180042
10/31/08
CN 08-031
Revise to include consideration of GSI-191 issue
related to potential sump blockage.
No N/A
NA ML101340791
03/05/13
CN 13-007
Revised procedure to incorporate recommendations
from the modification working group conference.
No
N/A ML15208A030
11/13/15
CN 15-024
Revisions are made in order to: (1) ensure that security
related issues identified as a result of changes are
raised so that they may be considered under the
Security Inspection Program; (2) ensure that there is
awareness that changes to aging management
programs associated with 10 CFR 54.21(d) are within
scope of this IP; and (3) ensure that there is awareness
that NEI 96-07, Revision 1, Appendix E has not been
reviewed or endorsed by the NRC.
Feedback forms incorporated into this revision: 2145.
Feedback forms reviewed but not incorporated: 2062,
2088, and 2109.
No ML15187A245
71111.17T-2062
71111.17T-2088
71111.17T-2109
71111.17T-2145
Issue Date: 12/08/16 Att 1-2 71111.17T
Commitment
Tracking
Number
Accession
Number
Issue Date
Change Notice
Description of Change Description of
Training Required
and Completion
Date
Comment and
Feedback Resolution
Accession Number
(Pre-Decisional,
Non-Public)
N/A ML16147A416
DRAFT
CN 16-___
Revisions are made to: 1) address use of mandatory
and discretionary language concerns and
recommendations found in OIG-16-A-12
(ML16097A515), and 2) relocate inspection of
permanent plant modifications to IP 71111.21M,
“Component Design Bases Inspection (Teams).”
Made draft version public prior to final version being
issued to allow viewing of potential inspections starting
None ML16158A103
71111.17T-2211
N/A ML16340A998
12/08/16
CN 16-032
Changes associated with ML16147A416.
A new ADAMS Accession Number was created to
address a non-concurrence on the changes proposed
by version of the IP associated with ML16147A416.
Completed non-concurrence package can be found in
ML16341C689. No additional changes were made to
this IP.
None ML16158A103
71111.17T-2211
See non-concurrence
package