ML21244A225

IP 71004 Power Uprate

ML21244A225
Person / Time
Issue date:	02/09/2022
From:	Aron Lewin NRC/NRR/DRO/IRIB
To:
Aron Lewin, NRR/DRO/IRIB, 415-2259
Shared Package
ML22033A355, ML21293A163	List:
References
CN 22-003, DC 21-020
Download: ML21244A225 (16)

Text

NRC INSPECTION MANUAL IRIB INSPECTION PROCEDURE 71004 POWER UPRATE Effective Date: 02/09/2022 PROGRAM APPLICABILITY: 2515 Appendix C 71004-01 INSPECTION OBJECTIVES 01.01 To verify the risk-significant aspects of the following when applicable:

a. That tests and experiments not described in the FSAR and changes to the facility or procedures as described in the UFSAR for power uprate were evaluated in accordance with 10 CFR 50.59 as appropriate.

b. That the licensee took the required actions to alleviate or prevent the effects of new or likely initiating events, in accordance with the license amendment or NRC safety evaluation (SE), that were due to changes such as higher core power densities, increased flow in primary or secondary systems including their interfacing systems, and the synergistic effects of multiple initiating events (e.g., higher primary flow rates coupled with greater fuel burnup leading to new potential problems).

c. That plant modifications for power uprate are in accordance with licensing and design bases, licensee commitments, and the FSAR.

d. That mitigating systems can initiate and perform their safety function in accordance with the timelines in new accident analyses, acceptance tests for plant modifications for power uprate, and applicable surveillance tests.

e. That individual components in mitigating systems that were altered or replaced can perform their intended safety function.

f. That new operator actions (normal, abnormal, and emergency) for power uprate are administered procedurally and have an appropriate basis. Appropriate training should be provided to operators on the new procedures.

g. That the licensee monitors changes, in accordance with NRC SE, made on systems and their effects on those systems and interfacing systems including potential problems that are slow in developing and issues that could not be immediately tested (e.g.,

erosion corrosion or flow accelerated corrosion).

71004-02 INSPECTION REQUIREMENTS Inspect samples that were developed as part of the inspection plan (and its revisions).

Issue Date: 02/09/22 1 71004

71004-03 INSPECTION GUIDANCE This inspection procedure should be performed for power uprates greater than 7.5% of current licensed thermal power, including those implemented in phases (i.e., when the total power increase approved by a single licensing action will be greater than 7.5%, but the initial power increase is less than 7.5%). Partial or complete implementation of this inspection procedure may be considered for power uprates less than 7.5% of current licensed thermal power.

Inspection planning should begin after a licensee submits an amendment request for a power uprate.

Inspection Plan. A site-specific inspection plan should be developed in order to select and review appropriate aspects of a power uprate. The resident inspection office (RIO) and regional staff should work closely together to identify areas for inspection, and to discuss the resources required to perform the inspections. A regional extended power uprate (EPU) point of contact should be identified by regional management early in the process. This individual should be contacted for assistance in developing the inspection plan. Inspection planning, execution, and tracking should generally follow the guidance provided in this IP. However, it is recognized that unique situations will necessitate slight deviations from this procedure. It may be useful to consult the other regions or the program office for suggestions. Regional management should be made aware of significant deviations from this IP.

a. The inspection staff should review IP 71004 soon after the power uprate application is submitted by the licensee. The associated NRC SE should be reviewed as soon as it is available (the RIO should keep in close communication with the NRR project manager to obtain a copy). The purpose of the review is to identify changes in plant hardware, integrated plant response characteristics, operator procedures, and margins to plant safety. Per Section 4.1 of Review Standard RS-001, Review Standard for Extended Power Uprates, the recommendations in the final SE do not constitute inspection requirements, but are provided to give the inspectors insight into important bases the NRC staff used for approving the EPU.

b. Once the IP 71004 samples are selected, the inspection staff should identify the types of resources necessary to complete IP 71004, and an estimate of schedule dates. Some inspection dates may take place before power increases above the previously licensed power setpoint, whereas some inspection may need to occur during power ascension testing, and at the new licensing limit for rated power output. To the extent possible, inspectors should evaluate plant changes and major tests prior to their implementation to ensure that plant safety is maintained.

c. Several samples are likely suited for resident inspector skills and may suffice for baseline IP samples, but the inspection plan should consider additional resources based on resident staff workload, and conflict with other foreseeable resident staff activities.

d. Once the IP 71004 samples and resources have been identified, the inspection staff should provide the inspection plan to the regional EPU point of contact. The sample inspection plan, provided as Attachment 1, is a recommended example. The regional EPU point of contact should review the inspection plan for IP 71004 requirements and should work with the appropriate regional engineering / technical branches to assign all necessary resources outside of the resident inspector staff.

e. The branch chief responsible for the affected plant should review and approve the inspection plan. Regional management should be briefed on the plan at the next Issue Date: 02/09/22 2 71004

available opportunity (e.g., end-of cycle meeting). In accordance with IMC 2515, Appendix C, Regional Administrator authorization is required to implement IP 71004.

The process for this authorization may vary from region to region; but the date that authorization is given should be clearly annotated in the inspection plan (see example in Attachment 1).

f. The branch chief responsible for the affected plant and RIO should track completion of IP 71004. Attachment 1, Table 1 is a sample that may be used to ensure inspection requirements will be completed, and necessary coordination obtained.

Sample Selection and Inspection. Samples should be selected in order to verify that the power uprate can be achieved in a safe manner. Samples should be risk-informed and focused on items concerning new integrated plant response characteristics, new operator procedures, and plant safety during any required tests.

The samples selected should be inspected per the referenced baseline inspection procedures (except for those covered by this inspection procedure and IP 49001). The intention is not to replace the requirements of baseline inspection activities. Credit should be given to the normal baseline samples when performing those activities as a power uprate inspection sample under IP 71004 whenever possible (to prevent duplication of inspection efforts). It is important to take credit for those normal baseline samples under IP 71004. In certain instances, the IP 71004 inspection sample may not correlate 100 percent with the referenced baseline inspection procedure. In these situations, it may be appropriate to perform the inspection requirements necessary for the power uprate inspection and to credit the corollary baseline sample as complete, even if the sample was modified slightly from the definition in the baseline IP.

However, the overall intent of the baseline inspection procedure must continue to be met, and these situations should be discussed with appropriate regional management.

For sites where there are multiple units undergoing an EPU (under one license amendment request), performing an inspection sample on one unit and crediting that sample for both units may be warranted. This will depend on the nature of the EPU, the design of the plant and, the specifics of the inspection.

A sample should be selected from each of the following areas, as available:

a. 10 CFR 50.59 evaluations that are required for power uprate from the following:

1. Changes to facility as described in UFSAR

2. Changes to procedures as described in UFSAR

3. Tests or experiments not described in UFSAR Consider implementing IP 71111.17T, IP 71111.18, or IP 71111.21M. The inspection sample selection should evaluate the impact of extended power uprates on safety analysis margins. Some inspection may take place before power increases above the previously licensed power setpoint, whereas testing of some modifications, power ascension testing, and integrated system testing may not be conducted until the original licensing limit for rated power output is exceeded, and the new licensing limit for rated power output approached and even reached.

Issue Date: 02/09/22 3 71004

b. Risk-significant plant modifications implemented for the power uprate. Risk-significant modifications may include the following:

1. Modifications which impact Emergency Core Cooling System (ECCS) initiation, or the ability of an ECCS system to mitigate an event.

2. Modifications which impact heat exchanger performance.

3. Modifications which could contribute to the initiation of an event following installation (e.g., higher core power densities; increased flow in primary, secondary, or their interfacing systems; and synergistic effects).

(a) Consider changes to balance of plant systems or components that could increase the likelihood of an initiating event (such as a loss of offsite power, a reactor trip, or a reactor trip without heat sink).

(b) Consider flow rates and whether the licensee is analyzing the long-term effects and adopting a means to monitor those effects in accordance with NRC SE.

Preferably the inspector should witness an actual flow test when verifying flow rates but the review of flow test results is acceptable.

(c) Consider changes that impact the integrity of barriers (e.g., higher flow rates in a primary or secondary system which increases flow-accelerated corrosion on internal piping surfaces and vibration at specific support points which then results in increased likelihood of leaks).

(d) Consider changes which result in higher flow rates internal to the core / inside the reactor vessel, which can cause components to degrade / fail due to flow induced

/ acoustic vibrations. Licensees should be aware of industry experience regarding these issues, analyze impacts of EPU on reactor vessel components, and monitor vibrations / structural integrity of vessel components.

4. Modifications which implement new equipment set points on risk-significant equipment. This includes the effects on design margins, instrument inaccuracy assumptions, accident analysis assumptions, and operator responses.

5. Modifications which caused unexpected problems when installed at another plant.

Consider implementing IP 71111.17T, or IP 71111.18; and consider performing IP 71111.07 for heat exchangers in mitigating systems included in samples selected.

Consider concentrating on changes to systems, e.g., RHR system, ECCS systems, or secondary systems with changes that may adversely impact primary systems plant safety.

c. Mitigating systems or components modified for power uprate for which surveillance testing or startup testing will be performed.

For post-maintenance or surveillance tests conducted by licensee for mitigating systems or radiation barriers, consider implementing IP 71111.19 or IP 71111.22. Consider focusing on those surveillance tests that affect core or containment cooling, higher flow rates in primary system or an ECCS, etc.

Issue Date: 02/09/22 4 71004

d. Major tests to be monitored and evaluated (e.g., turbine load reject trip, runback, Main Steam Isolation Valve (MSIV) closure from full power, or Loss of Offsite Power tests).

Consider witnessing or reviewing test results of any major plant tests including MSIV closure. A partial test may consist of verifying the operation of control and protective circuitry for either a turbine load reject or loss of offsite power test without actually putting the plant through an actual transient or actually demonstrating excess decay heat removal. The inspector should evaluate the major test procedures, prior to their being performed, to ensure the test can be conducted. The inspector should also witness or review the results of any power ascension tests to ensure that the licensee correctly predicted plant response, and charge that effort to this IP (IP 71004). The testing portion of the approved license amendment or NRC SE should provide guidance on major test details like installation of sensors, requisite plant conditions, and prescribed actions.

e. Operator actions during integrated plant evolutions (e.g., power changes) being conducted by the licensee during initial power ascension and at the uprated power level.

Consider witnessing initial power ascension after implementing changes for power uprate and observing operator actions in accordance with IP 71111.20. Also, as appropriate consider using IP 71111.11 under requalification training as a means to observe plant evolutions. The inspector should focus on those operator actions that affect risk-significant mitigating systems or radiation barriers. The inspector may also observe any modified operator actions for BOP systems that may initiate plant transient events.

f. Risk-significant concerns identified by licensees flow accelerated corrosion (FAC) and erosion corrosion programs which could be exacerbated by power uprate changes or evolutions.

Consider implementing IP 49001 to review the licensees erosion and FAC programs, as required, and charge that effort to this IP (IP 71004). The concerns selected can be from BOP systems if they are risk significant. If there are concerns from multiple systems, then consider selecting the one that is the most risk significant so that estimated resources for this sample will be approximately 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />. For assistance in selecting samples, inspectors may refer to the FAC section of the NRC SE (Section 2.1.8 for Pressurized Water Reactors, and Section 2.1.6 for Boiling Water Reactors).

g. Licensee required actions. Consider obtaining a copy of the NRC SE and reviewing Section 4.0, Regulatory Commitments and Section 5.0, Recommended Areas for Inspection for any licensee actions. In addition, consider reviewing any license conditions related to the power uprate. Consider if the licensee has taken all required actions to address the effects of new or more probable initiating events as stated in license amendment, licensee commitments, or in the NRC SE, and charge that effort to the most applicable baseline IP or to this IP (IP 71004) if necessary. The inspector should merely confirm the sample items to verify that the licensee has performed the required actions. The inspector should not repeat the initial analysis, or the evaluation found in the NRC SE.

Identification and Resolution of Problems. Consider verifying that the licensee is identifying problems related to power uprate, at an appropriate threshold, and entering them in the corrective action program (CAP). Consider selecting a sample of problems documented in the Issue Date: 02/09/22 5 71004

CAP (focusing mainly on mitigating systems) to verify that the licensee has appropriately resolved the technical concerns and regulatory requirements. See Inspection Procedure 71152, Identification and Resolution of Problems, for additional guidance.

71004-04 RESOURCES ESTIMATE The estimated resource expenditure for this inspection procedure is 32 to 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br />. This does not include the baseline inspection effort referenced by this procedure. Approximately 100-150 hours are expected to be credited toward baseline inspections as part of the normal conduct of those procedures. These are general estimates, provided for planning purposes only; they should not be viewed as requirements. Inspectors should use their experience and expertise (along with input from management) to determine how much time should be dedicated to specific inspection efforts.

This inspection procedure integrates the results of several baseline inspection procedures being performed under the established risk-informed baseline inspection program and that are related to plant modifications and testing associated with an approved increase in licensed reactor power. Most inspection activities for a power uprate should be conducted within the normal resource constraints of the baseline procedures being implemented. The types of samples selected for those baseline procedures should be as stated in this inspection procedure.

Whenever possible, the sample size stated in that particular baseline procedure should be adhered to on an annualized basis. In certain instances, the IP 71004 inspection sample may not correlate 100 percent with the referenced baseline inspection procedure. In these situations, it may be appropriate to perform the inspection requirements necessary for the power uprate inspection and to credit the corollary baseline sample as complete, even if the sample was modified slightly from the definition in the baseline IP. However, the overall intent of the baseline inspection procedure must continue to be met, and these situations should be discussed with appropriate regional management.

The intent is not to redirect baseline inspection efforts, but to complete the requirements of this inspection procedure concurrently when possible. Every effort should be made to schedule baseline inspection procedures that have a frequency of greater than annually to coincide with the licensees EPU activities. However, scheduling of such inspections, and the allotment of required resources, remains the discretion of regional management.

This inspection should be performed by inspectors (e.g., engineering specialists) knowledgeable in the affected subject areas.

71004-05 PROCEDURE COMPLETION Samples selected for inspection should verify that the power uprate can be achieved in a safe manner. Inspection of the samples that were developed as part of the inspection plan (and its revisions) constitutes completion of this procedure. Completion of the samples shall be described in the roadmap documentation of an integrated inspection report. An example of a roadmap documentation of an integrated inspection report can be found in ADAMS under ML20042C802.

Issue Date: 02/09/22 6 71004

Issues will be documented as required by IMC 0611 in the integrated inspection report for the time period when the inspection occurred. Because IP 71004 integrates several baseline and other inspection procedures, the inspection scope is key in recording the NRC effort to complete IP 71004. The scope should accurately describe the activities inspected consistent with the inspection plan.

Section, Other Activities - Temporary Instructions, Infrequent and Abnormal, of the report should contain all IP 71004 samples that were completed, regardless of an associated baseline inspection procedure. The idea is to maintain a single inspection report entry point for all IP 71004 samples within section Other Activities - Temporary Instructions, Infrequent and Abnormal. Those IP 71004 samples that also suffice for baseline inspection samples should be documented in the applicable section of the integrated inspection report and referenced in section Other Activities - Temporary Instructions, Infrequent and Abnormal. For example, a surveillance inspection activity should be primarily documented in Section 71111.22 -

Surveillance Testing. Meanwhile, the activity should also be listed in section Other Activities -

Temporary Instructions, Infrequent and Abnormal, as a sample performed for IP 71004; and refer the reader to Section 71111.22 for more information on the details of the surveillance inspection activity.

Separately, once it has been verified that all IP 71004 sample requirements have been completed and recorded, consistent with the inspection plan, a summary of the inspection activities should be provided in section Other Activities - Temporary Instructions, Infrequent and Abnormal, of the integrated inspection report. The summary should include a description of each sample, the inspection procedure used to inspect the sample, and the applicable inspection report(s) the samples were documented in. The intent is to provide a roadmap to all inspection reports that document power uprate-related inspection activities.

Findings associated with the performance of IP 71004 (including those identified through a referenced baseline procedure) should include the words power uprate (preferably in the title) in order to facilitate tracking and trending efforts.

71004-06 REFERENCES IP 49001, Inspection of Erosion-Corrosion / Flow-Accelerated-Corrosion Monitoring Programs IP 71111.07, Heat Exchanger/Sink Performance IP 71111.11, Licensed Operator Requalification Program and Licensed Operator Performance IP 71111.17T, Evaluations of Changes, Tests, and Experiments IP 71111.18, Plant Modifications IP 71111.19, Post-Maintenance Testing IP 71111.20, Refueling and Other Outage Activities IP 71111.21M, Design Bases Assurance Inspection (Team)

IP 71111.22, Surveillance Testing Issue Date: 02/09/22 7 71004

IP 71152, Problem Identification and Resolution Review Standard RS-001, Review Standard for Extended Power Uprates END Issue Date: 02/09/22 8 71004

Attachment 1: Example EPU Inspection Plan

Background:

In month, year, the NRC accepted a power uprate license amendment application from licensee for plant name. The proposed amendment will increase the thermal power output of plant name from xxxx megawatts thermal (MWt) to xxxx MWt, which is an increase of approximately xx percent. The power level increase is considered an extended power uprate (EPU), and is within the scope of Inspection Procedure 71004, Power Uprate. It is projected that plant name will implement the EPU in month, year, following NRC approval of the license amendment. To facilitate the power increase, licensee has installed, or plans to install the following modifications:

Modifications and expected schedule dates.

Inspection Requirements:

NRC Inspection Procedure 71004, Power Uprate, requires several samples for inspection.

Table 1 provides an inspection schedule. Some inspection samples will be determined following a review of the NRC Safety Evaluation Report which is projected to be issued in month, year.

Resource Recommendations:

As shown in Table 1, the inspection activities for IP 71004 will be an integrated effort utilizing the resident staff and staff from appropriate regional engineering / technical branches. Table 1 lists the minimum required inspection activities, as well as a recommendation as to who should perform those inspections. The resource expenditure for IP 71004 is 32 to 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br />, without regard to the number of units at a site and does not include the baseline inspection effort.

Approximately 100-150 hours are expected to be credited toward baseline inspection procedures.

Issued Date: 02/09/22 Att1-1 71004

Table 1 Inspectable Inspection Inspection to Minimum Projected Notes Area Procedure be Inspection Inspection to be Used Performed Samples per Hours by IP 71004 and/or NRC SE

1. 10 CFR 71111.17T, Staff from 71004: Charged to (Example) 50.59 inspection team scheduled for 50.59 71111.18, appropriate 71111.17T 7/16/2008. XXGS should provide list of completed 10 Evaluations or regional 1 10 CFR consistent CFR 50.59 evaluations and NRC team should pick two 71111.21M engineering / 50.59 safety with baseline EPU related 10 CFR 50.59 evaluations for inspection.

technical eval The XXGS CBDI team scheduled for 10/2007 will sample branches components with low margin that may be affected by NRC SE: x EPU. EOP and abnormal operating procedure changes (Section 5.x) for new operator actions or timelines are suggested samples. Operator actions are described in several sections of the NRC SER and Section 2.11 is devoted to Human Performance. LICENSEE plans to have completed changes to Operations procedures by 2/15/2008.

COMPLETE.

2. Plant 71111.17T Staff from 71004: Charged to (Example) Mods inspection team scheduled for Modifications or appropriate 71111.17T 7/16/2008.

71111.18 regional 1 plant mod consistent COMPLETE.

with engineering / with baseline 71111.07 technical NRC SE: x branches (Section 5.x)

Issued Date: 02/09/22 Att1-2 71004

3. Post- 71111.17T, Resident 71004: Charged to (Example) Residents will inspect STs during plant startup.

Maintenance 71111.18, staff 71111.19 or PMTs on RFP upgrade recommended. Residents will or Surveillance 71111.19, 1 PMT or ST 71111.22 review SER in June 2008 for recommendations. Applies Tests or consistent to mitigating systems or barriers.

71111.22 NRC SE: x with baseline Update: NRC SER will not be available until late 2008 or (Section 5.x) early 2009. Residents plan to complete this section during RFXX in October 2008.

4. Monitor 71004 Resident 71004: Power (Example) Residents will review NRC SER when major staff ascension available in June 2008.

integrated 1 major tests should Update: LICENSEE submitted one integrated test tests integrated be charged procedure to the resident staff on 10/23/2008. Residents test to 71004. will review procedure and observe portions of the testing Major during power ascension in RFXX and during EPU power NRC SE: x integrated ascension testing in spring 2009.

(Section 5.x) tests that do not also fall into power ascension tests should be charged to the most applicable baseline IP, or 71004 if necessary.

Issued Date: 02/09/22 Att1-3 71004

5. Integrated 71004 Resident 71004: Charged to (Example) Witness power ascension activities above plant with staff 71004, current rated thermal power. LICENSEE plans to have operations at 71111.11 1 integrated managed by the IPTE for plant startup available by 4/2/2008.

the uprated or Staff from plant RIO. 71004 Residents will review IPTE and follow during execution.

power level 71111.20 appropriate evolution estimated Involve appropriate regional engineering / technical regional integrated branches to verify LICENSEE has adequately evaluated engineering / NRC SE: x resources system vibrations at the higher power levels.

technical (Section 5.x) are 32 to 64 Update: This section will be executed in two portions.

branches to hours without The first during power ascension following RFXX which specifically regard to the will only be to CLTP of XXXX MWt. The second will be review number of during spring 2008 when LICENSEE uprates from 100%

system units at a site to approx 115% of CLTP. This is due to delay in approval vibration and all of EPU license amendment.

testing activities charged to Joe Inspector is from the appropriate regional 71004 engineering / technical branch and is inspecting FAC and should be vibration related issues associated with EPU. FAC work managed by will be completed in RFXX. Vibration issues will be the RIO. inspected in RFXX and during EPU power ascension activities in 2008.

Action Reqd: resources from the appropriate regional engineering / technical branch need to be reserved for this activity when LICENSEE communicates a set date.

Residents will review the following documents and tests in reference to this row and rows 5 & 7:

1. DCP 80048085, Supp 19 XXGS Extended Power Uprate Implementation & Power Ascension Test Plan

2. ER-AA-2003, Rev. 5, EPU System Performance &

Monitoring Plans

3. XXGS.OP-FT.ZZ-0004, Rev. 0, Extended Power Uprate Power Ascension testing Issued Date: 02/09/22 Att1-4 71004

6. Flow 49001 Staff from 71004: Charged to (Example) Coordinate with the appropriate regional accelerated appropriate 71004, engineering / technical branches to perform inspection.

corrosion and regional 1 risk- managed by Action Reqd: resources from the appropriate regional erosion engineering / significant RIO. 71004 engineering / technical branch need to be reserved for corrosion technical concern for estimated this activity.

program branches each integrated reviews program resources are 32 to 64 NRC SE: x hours without (Section 5.x) regard to the number of units at a site and all activities charged to 71004 should be managed by the RIO.

Issued Date: 02/09/22 Att1-5 71004

7. Licensee 71004 Resident 71004: Charged to (Example) Residents to review SER in June 2008 to actions for staff the most determine impact, if any. Residents will also review new or more 1 sample applicable operator training in the simulator.

likely initiating baseline IP, Update: residents will review NRC SER when it becomes events NRC SE: x or 71004 if available. SER not available as of 10/23/2008.

(Section 5.x) necessary.

Issued Date: 02/09/22 Att1-6 71004

Attachment 2: Revision History for IP 71004 Commitment Accession Description of Change Description of Comment Resolution Tracking Number Training and Closed Feedback Number Issue Date Required and Form Accession Change Notice Completion Number (Pre-Date Decisional, Non-Public)

NA 05/09/06 Revision history reviewed for the last four NA NA years NA 05/09/06 IP 71004 (Power Uprate) has been revised to NA ML061240247 indicate that Component Design Bases inspections (IP 71111.21) are used to evaluate the impact of extended power uprates on safety analysis margins. New inspection guidance for evaluating higher flow rates internal to the core and inside the reactor vessel, which can cause components to degrade or fail due to vibrations.

NA 07/01/08 IP 71004 (Power Uprate) has been revised to NA ML081680243 CN 08-019 address concerns identified during the OIG 2007 audit of the Power Uprate process by providing guidance on planning, tracking, and documenting completion of IP 71004. In addition, previously provided guidance was moved to Section 02, Inspection Requirements and Guidance, and referenced baseline procedures were changed to reflect the 2007 ROP realignment.

NA 02/02/09 IP 71004 (Power Uprate) has been revised to NA NA CN 09-004 require all IPs related to power uprated to be clearly designated as such in RPS.

NA 08/11/09 IP 71004 (Power Uprate) has been revised to NA ML091400389 CN 09-020 address feedback form 71004-1326 by providing clarification on the approval process.

Issue Date: 02/09/22 Att2-1 71004

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

NA 04/30/10 IP 71004 (Power Uprate) has been revised to NA ML100880018 CN 10-013 address internal stakeholder comments provided after implementing the changes to the IP that were made as a result of the 2007 OIG Audit (July 2008 revision) and to address feedback form 71004-1405 (sample size clarification).

NA ML15121A676 IP 71004 (Power Uprate) has been revised to NA ML15124A653 05/21/15 address feedback form 71004-1862 by CN 15-010 removing guidance related to the use of RPS as a tool to identify team inspections to support completion of inspection sample requirements.

NA ML17116A213 IP 71004 (Power Uprate) has been revised to NA NA 05/15/17 address feedback form 71004-2240 to update 71004-2240 CN 17-010 references to IP 71111.17T and 71111.21M. ML17130A466 Revision is considered editorial.

NA ML21244A225 Removes reference to mid-cycle meetings. NA ML21293A226 02/09/22 Formatted to IMC 0040 (ML19352E640)

CN 22-003 requirements. 71004-2438 ML21293A217 Issue Date: 02/09/22 Att2-2 71004