IP 71111.17T, Evaluations of Changes, Tests, and Experiments

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Evaluations of Changes, Tests, and Experiments

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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

Mitigating Systems

Barrier Integrity

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

ML15306A007

71111.17T-2088

ML15306A008

71111.17T-2109

ML15306A009

71111.17T-2145

ML15306A011

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

CY 2017.

None ML16158A103

71111.17T-2211

ML16147A281

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

ML16147A281

See non-concurrence

package

ML16341C689.