ML18192A217

2018-7-19 ROP Public Meeting Handout - Draft IP7111118

ML18192A217
Person / Time
Issue date:	07/12/2018
From:	Aron Lewin NRC/NRR/DIRS/IRIB
To:
Lewin A, NRR/DIRS, 415-2259
References
IP7111118
Download: ML18192A217 (14)

Text

DRAFT NRC INSPECTION MANUAL IRIB INSPECTION PROCEDURE 71111 ATTACHMENT 18 Commented [A1]: IP is reformatted to new format found in IMC 0040 (ML18003A122). Additional comment blocks are provided for any revision not strictly associated with reformatting.

PLANT MODIFICATIONS Effective Date: January 1, 2019 PROGRAM APPLICABILITY: IMC 2515 Appendix A INSPECTABLE AREA: Plant Modifications CORNERSTONES: Initiating Events Mitigating Systems Barrier Integrity INSPECTION BASES: See IMC 0308 Attachment 2 Modifications to risk-significant structures, systems, and components (SSCs) can adversely affect their availability, reliability, or functional capability. Modifications to one system may also affect the design bases and functioning of interfacing systems. Similar modifications to several systems could introduce potential for common cause failures that affect plant risk.

A temporary modification may result in a departure from the design basis and system success criteria. Modifications performed during increased risk configurations could place the plant in an unsafe condition. This inspectable area verifies aspects of the Initiating Events, Mitigating Systems, and Barrier Integrity cornerstones for which there are no indicators to measure 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: Annually, review 3 to 7 temporary and/or permanent modifications as described in Section 71111.18-02.

SAMPLE REQUIREMENTS Sample Requirements Minimum Baseline Completion Budgeted Range Sample Requirements Sample Type Section Frequency Sample Size Samples Hours Issue Date: 1 71111.18

DRAFT Temporary 3 to 7 36 to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> 03.01 Annual Modifications 3 temporary temporary per site and/or permanent and/or Permanent modifications per permanent Modifications 03.02 Annual site modifications per site 71111.18-01 INSPECTION OBJECTIVE 01.01 This inspection will To verify that modifications have not affected the safety functions of important safety systems.

01.02 To verify that the design bases, licensing bases, and performance capability of risk significant SSCs have not been degraded through modifications.

01.03 To verify that modifications performed during increased risk-significant configurations do not place the plant in an unsafe condition.

71111.18-02 GENERAL INSPECTION GUIDANCE 03.01 Selection of Temporary and Permanent Modifications Preference should be given to reviewing modifications as they occur and that occur during at power operations or increased shutdown risk configurations.

a. Selected temporary modifications may include jumpers, lifted leads, temporary systems, repairs, design modifications and procedure changes which can introduce changes to plant design or operations. Although the focus of this inspection is on active modifications, inspectors may choose to review a recently removed temporary modification for adequate restoration and testing. The focus should be on identifying temporary modifications not previously identified by the licensee if there is no existing program tasked with making interested parties aware of the existence of all temporary modifications. See Table A, Sample Selection of Temporary Modifications for additional guidance.

b. Selected permanent modifications may include permanent plant changes, design changes, set point changes, procedure changes, aging management changes, equivalency evaluations, suitability analyses, calculations, and commercial grade dedications. See Table B, Sample Selection of Permanent Modifications for additional guidance.

Issue Date: 2 71111.18

DRAFT TABLE A - Sample Selection of Temporary Modifications Cornerstone Inspection Objective Risk Priority Example Mitigating Identify temporary Temporary Use of alternate Systems modifications which modifications which material when specified could affect the design could affect the design replacement parts are basis or the functional bases and functional not available capability of plant capability of interfacing mitigating systems systems During outages:

Temporary electrical Emphasize power to equipment modifications which required to minimize affect high safety shutdown risk significant Maintenance Rule SSCs/functions or Alternate water sources modifications which for equipment cooling or affect SSCs/functions fire protection of with high PRA rankings equipment required to minimize shutdown risk Barrier Integrity Identify temporary Multiple temporary Temporary changes to modifications which modifications to a single containment isolation could affect the design system or train, motor operated valve basis or the functional especially during designs.

capability of outages containment or reactor During outages:

coolant system Temporary Temporary power boundaries modifications which improperly routed into require operator containment when the workarounds ability to establish containment integrity is still required.

Issue Date: 3 71111.18

DRAFT TABLE B - Sample Selection of Permanent Modifications Cornerstone Inspection Objective Risk Priority Examples Initiating Events Modifications that Modifications to reactor increase the likelihood coolant pressure of initiating events boundary Modifications to switchyard or feedwater controls Mitigating Modifications which Modification of reactor Systems affect building drain system

• protection against Verify modifications external events such as Replacement of a low have maintained system fire, weather, and pressure safety injection availability, reliability, flooding system injection valve and functional

• risk-significant design with a valve of a capability.

features and different design assumptions

• functionality of mitigating systems used during risk-significant accident sequences Barrier Integrity Modifications which Modification of affect fuel cladding, personnel access hatch reactor coolant system, seal or containment 03.02 Inspection Regulatory Guide (RG) 1.187 Guidance for Implementation of 10 CFR 50.59, Changes, Test, and Experiments, states that Revision 1 of Nuclear Energy Institute (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, Users 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 licensees use of Appendix E can be raised with the DORL PM.

The review of the design aspects of the modification should focus on conformance to relevant design criteria not the programmatic elements of licensee programs. See Table C, Inspection Guidance for Parameters Affected by Modification for additional guidance. Consider informing Issue Date: 4 71111.18

DRAFT the Regional Senior Reactor Analyst if the plant modification added or deleted functions that could affect the plant specific significance determination process worksheets.

The review of the installation (and, if applicable, the restoration from a temporary modification) ensures that the impact on the operation of other equipment is what is expected and previously analyzed, and to verify all other unexpected effects were subsequently evaluated with the results being there is no significant impact on the safe operation of plant or equipment.

The review of the post-installation test results is to ensure that the parent system remains operable and that its safety function has not been impaired. Licensees often use existing procedures, such as surveillance procedures, for post-modification testing. Although performance of existing procedures may have been reviewed by inspectors for other inspectable areas, inspectors should consider the appropriateness of using the existing procedures for validating the modification (as opposed to simply confirming continued operability).

In addition, for temporary modifications, identification of temporary modifications on drawings and at placement of appropriate tags equipment being affected by the temporary modification should make operators aware of their impact on the operation of plant equipment and components. The synergistic effects of outstanding temporary modifications is best judged based on whether there are new impediments to the safety functions of mitigating safety systems, degradation of radiological barriers, an increase in the likelihood or consequences of accidents previously evaluated in the FSAR, or the possibility for an accident of a different type than any previously evaluated in the final safety analysis report.

If an optional document and procedure updating review is conducted, examples of design documents which could be affected by modifications are: UFSAR, drawings, supporting calculations and analyses, plant equipment lists, and vendor manuals. Examples of significant plant procedures which could be affected by modifications are normal, abnormal, alarm response, and emergency operating procedures, severe accident management guidelines, testing and surveillance procedures, and licensed operator training manuals.

Table C contains a list of parameters potentially affected by the modification. Consider inspecting only those parameters which are significant for the particular modification being reviewed.

TABLE C - Inspection Guidance for Parameters Affected by Modification Affected Parameter Inspection Considerations Energy Needs Energy requirements supplied by supporting systems when required

• Electricity under accident/event conditions.

• Steam

• Fuel + Air Energy requirements of modified SSCs will not deprive other SSCs

• Air of required energy under accident/event conditions.

Issue Date: 5 71111.18

DRAFT Affected Parameter Inspection Considerations Materials/replacement components are compatible with physical interfaces.

Material/replacement component properties serve functional requirements under accident/event conditions. This includes potential post LOCA debris sources and blockage mitigation.

Materials/ Replacement Components Materials/replacement components are environmentally qualified for

• Material Compatibility application.

• Functional Properties

• Environmental Replacement components are seismically qualified for application.

Qualification

• Seismic Qualification Code and safety classification of replacement SSCs is consistent

• Classification with design bases.

Replacement schedule consistent with inservice/equipment qualification life.

New SSCs added to the plant have been reviewed for inclusion in the maintenance rule scope.

Sequence changes are bounded by accident analyses and loading on support systems are acceptable.

Timing SSC response time is sufficient to serve accident/event functional requirements assumed by design analyses.

• Sequence

• Response Time Modified SSC response time does not cause an unintended

• Duration interaction with other SSCs.

Equipment will be able to function for the duration required under accident/event conditions.

Heat removal requirements will be addressed by support systems Heat Removal under accident/event conditions.

Control Signals

• Initiation

• Shutdown Control signals will be appropriate under accident/event conditions.

• Control

• Logic / Interlocks Issue Date: 6 71111.18

DRAFT Affected Parameter Inspection Considerations Equipment Protection

• Fire

• Flood Equipment protection barriers and systems have not been

• Missile compromised.

• High Energy Line Break

• Freeze Affected operation procedures and training have been identified and necessary changes are in process.

Operations Plant simulator has been updated as required.

Annunciator and alarm response updated as required.

Revised flowpaths serve functional requirements under Flowpaths accident/event conditions.

Pressure Boundary Pressure boundary integrity is not compromised.

Changes to ventilation boundaries do not increase risk of spreading contamination.

Ventilation Boundary Changes to ventilation boundaries do not adversely affect functionality of ventilation system under accident/event conditions.

Modified SSCs structural integrity acceptable for accident/event conditions.

Structural Modified SSCs structural effects upon attachment points acceptable.

Modified SSCs effect on seismic evaluations acceptable.

Process Medium

• Fluid Pressures Afected process medium properties will be acceptable for both

• Fluid Flowrates modified SSCs and unmodified SSCs under accident/event

• Voltages conditions.

• Currents Verify that necessary Technical Specification changes have been identified and NRC approvals, if required, were obtained prior to modification implementation.

Licensing Basis

• 10 CFR 50.59 Verify acceptability of licensees conclusions for those modifications where evaluations in accordance with 10 CFR 50.59 were not performed.

Issue Date: 7 71111.18

DRAFT Verify those failure modes introduced by the modification are Failure Modes bounded by existing analyses.

03.03 Problem Identification and Resolution See Inspection Procedure (IP) 71152, Problem Identification and Resolution, for additional guidance.

71111.18-03 INSPECTION SAMPLES REQUIREMENTS NOTES: (1) Inspectors shall use risked informed insights together with other factors, such as engineering analysis and judgment, and performance history, to determine which temporary and permanent modifications will be selected for review.

(2) 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.

03.01 Temporary modifications.

a. Review the temporary modifications and associated 10 CFR 50.59 screening against the system design bases documentation, including Updated Final Safety Analysis Report (UFSAR) and Technical Specifications (TS). Verify that the modifications have not affected system operability/availability.

b. Verify that the installation of the temporary modifications (if accessible) are consistent with the modification documents. Also, if applicable, verify restoration of the temporary modification (if accessible).

c. Verify configuration control of the modification is adequate by verifying that the plant documents, such as drawings and procedures are updated including adequacy of operating and maintenance procedures.

d. Verify that temporary modifications are identified on Control Room drawings and appropriate tags are placed on equipment being affected by the temporary modifications.

e. Review post-installation test results to confirm that the tests are satisfactory and the actual impact of the temporary modifications on the permanent systems and interfacing systems have been adequately verified by test.

Also, if applicable, review planned testing after removal of the temporary modifications.

03.02 Permanent modifications.

a. Review the design adequacy of the modification.

Issue Date: 8 71111.18

DRAFT

b. Verify that modification preparation, staging, and implementation does not impair the following:

(1) In-plant emergency/abnormal operating procedure actions (2) Key safety functions (3) Operator response to loss of key safety functions

c. Verify that post-modification testing will maintain the plant in a safe configuration during testing. Verify that post-modification testing establishes operability.

d. (Optional) Verify that design and licensing documents have either been updated or are in the process of being updated to reflect the modifications.

Verify that significant plant procedures are updated to reflect the effects of the modification prior to being used.

e. (If applicable) Verify that site SAMGs are updated when the BWROG or PWROG generic severe accident technical guidelines are revised.

Specific Guidance The PWROG issued new severe accident technical guidelines in February 2016 (Revision 0), while the BWROG issued a Revision 4 to severe accident technical guidelines guidance in June 2018.

Licensees have committed to updating site SAMGs within 2 refueling outages or 3 years (whichever time period is greater) of the publication date of new BWROG or PWROG generic severe accident technical guidelines.

Licensees have also commited to updating site SAMGs in accordance with processes outlined in NEI 14-01, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents. Section 3.2 of NEI 14-01 contains guidance on the process for updating site SAMGs when either the BWROG or PWROG revise their generic severe accident technical guidelines. As discussed in NEI 14-01, the main highlights of the process are document development, verification, and validation. NEI 14-01, Revision 1 was issued in February 2016 (ML16224A619). Commented [A2]: Provides oversight of licensee commitments to update site specific SAMGs when the PWROG/BWROG issues revised generic severe accident technical guidelines. Directed by SRM SECY-15-0065 03.03 Problem Identification and Resolution. Verify that problems associated with (ML15239A767). The reference section of this IP is also revised to add reference to NEI 14-01.

modifications are being identified by the licensee at an appropriate threshold and are properly addressed for resolution in the licensee corrective action program. (Optional) In addition to the above, verify appropriateness of the Issue Date: 9 71111.18

DRAFT corrective actions for selected sample of problems documented by the licensee involving plant modifications.

Specific Guidance See Inspection Procedure (IP) 71152, Problem Identification and Resolution, for additional guidance 71111.18-04 RESOURCE ESTIMATE The inspection procedure is estimated to take 36 to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> a year at a site regardless of the number of units.

71111.18-05 PROCEDURE COMPLETION Inspection of the minimum sample size will constitute completion of this procedure in the Reactor Programs Systems (RPS). That minimum sample size will consist of 3 temporary and/or permanent modification reviews. Refer to IMC 2515, Light-Water Reactor Inspection Program - Operations Phase for further guidance on procedure completion.

71111.18-0604 REFERENCES IP 71111.17, Permanent Plant Modifications IP 71152, Problem Identification and Resolution 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).

NEI 14-01, Revision 1, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents, Feb 2016 (ML16224A619).

Reactor Oversight Process Changes to Address Severe Accident Management Guidelines with Enclosure containing Commitment Letters by Site (ML16032A029).

RIS 2016-03, 10 CFR 50.59 Issues Identified in NRC's San Onofre Steam Generator Tube Degradation Lessons Learned Report, April 2016. (ML15196A575)

END Issue Date: 10 71111.18

DRAFT Attachment 1 - Revision History for IP 71111.18 Commitment Accession Description of Change Description of Comment and Tracking Number Training Required Feedback Resolution Number Issue Date and Completion Accession Number Change Notice Date (Pre-Decisional, Non-Public) 01/31/08 New procedure. Combined contents of N/A CN 08-005 No N/A IP 71111.17A and IP 71111.23 into IP 71111.18 ML073050453 N/A 10/31/08 Revise to include consideration of GS -191 issue No N/A CN 08-031 related to potential sump blockage. Editorial.

ML082670330 N/A 12/21/10 Changed the minimum sample requirement from 3 No N/A CN 10-028 temporary and 1 permanent modification reviews to 3 ML101320542 to 7 temporary and/or permanent modifications (feedback form 71111.18-1475).

Issue Date: Att1 - 1 71111.18

DRAFT Commitment Accession Description of Change Description of Comment and Tracking Number Training Required Feedback Resolution Number Issue Date and Completion Accession Number Change Notice Date (Pre-Decisional, Non-Public)

N/A ML15208A031 Revisions are made in order to: (1) ensure that No ML15208A095 11/13/15 security related issues identified as a result of 71111.18-1851 CN 15-024 changes are raised so that they may be considered ML15306A013 under the Security Inspection Program; (2) ensure 71111.18-2063 that there is awareness that changes to aging ML15306A015 management programs associated with 10 CFR 71111.18-2110 54.21(d) are within scope of this IP; and (3) ensure ML15306A017 that there is awareness that NEI 96-07, Revision 1, 71111.17T-2145 Appendix E has not been reviewed or endorsed by ML15306A011 the NRC.

Feedback forms incorporated into this revision:

71111.17-2145.

Feedback forms reviewed but not incorporated:

71111.18-1851, 2063, and 2110.

Issue Date: Att1 - 2 71111.18

DRAFT Commitment Accession Description of Change Description of Comment and Tracking Number Training Required Feedback Resolution Number Issue Date and Completion Accession Number Change Notice Date (Pre-Decisional, Non-Public)

N/A ML16138A284 Revisions are made to: No ML16146A057 ML16306A185 11/17/16 (1) Provide oversight of licensee commitments to 71111.18-2212 CN 16-031 consider Severe Accident Management Guidelines ML16188A244 (SAMGs) within plant configuration management processes in order to ensure that the SAMGs reflect changes to the facility over time. Additional background information can be found in SRM SECY-15-0065 (ML15239A767) and a February 23, 2016 letter from the NRC to NEI (ML16032A029). The February 23, 2016 letter, which also references the SRM, is added to the References section.

(2) Address use of mandatory and discretionary language concerns and recommendations found in OIG-16-A-12 (ML16097A515).

Issue Date: Att1 - 3 71111.18

DRAFT N/A Revisions are made to: None (1) Provide oversight of licensee commitments to update site specific SAMGs when the PWROG/BWROG issues revised generic severe accident technical guidelines. Additional background information can be found in SRM SECY-15-0065 (ML15239A767) and a February 23, 2016 letter from the NRC to NEI (ML16032A029).

(2) Conform to new IP format requirements found in IMC 0040 (ML18003A122).

Issue Date: Att1 - 3 71111.18