ML21033A557

IP 71111.22 Surveillance Testing

ML21033A557
Person / Time
Issue date:	03/29/2021
From:	Eric Duncan NRC/NRR/DRO/IRIB
To:
Duncan E
Shared Package
ML21035A185, ML21081A297	List: ML21033A557
References
CN 21-015, DC 21-003
Download: ML21033A557 (14)

Text

NRC INSPECTION MANUAL IRIB INSPECTION PROCEDURE 71111 ATTACHMENT 22 SURVEILLANCE TESTING Effective Date: July 1, 2021 PROGRAM APPLICABILITY: IMC 2515 A CORNERSTONES: Mitigating Systems Barrier Integrity INSPECTION BASES: See IMC 0308 Attachment 2 SAMPLE REQUIREMENTS Sample Requirements Minimum Baseline Completion Budgeted Range Sample Requirements Sample Type Section Frequency Sample Size Samples Hours Surveillance Test 10 per site Annual 5 at Vogtle Units 3 & 4 Inservice Test 3 per site Annual 1 at Vogtle Units 3 & 4* 13 to 21 per site 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per Containment 03.01 When Isolation Valve Test site Required* 1 per unit 5 to 7 at Vogtle Units 3 & 4 45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> at Ice Condenser Vogtle Test** When Units 3 & 4 1 per unit Required*

Reactor Coolant When monitoring for increasing System Leakage reactor coolant leakage occurs*

Detection Test Diverse and Flexible Coping Strategies 03.02 Annual 1 1 per site (FLEX) Testing

• Required Each Refueling Outage

• • Only applicable to Ice Condenser Units Issue Date: 3/29/21 1 71111.22

71111.22-01 INSPECTION OBJECTIVE 01.01 Verify that surveillance testing (including inservice testing (IST)) activities provide objective evidence that risk- or safety-significant structures, systems, and components (SSCs) remain capable of performing their intended safety functions and maintain their operational readiness consistent with their design and licensing bases (i.e., will operate within safety limits and limiting conditions for operation will be met).

01.02 Verify that testing activities provide objective evidence that FLEX SSCs remain capable of performing their intended functions and maintain their operational readiness consistent with their licensing bases.

71111.22-02 GENERAL GUIDANCE The following table outlines additional inspection guidance for selecting risk- or safety-significant systems.

Mitigating Systems - Identify any mitigating system, credited by the licensee as operable when assessing risk, which is adversely impacted by surveillance testing related failures such as failure to adequately test, failure to meet test criteria or, failure to realign equipment after the surveillance.

Risk Priority Example Focus in areas with potential for common Integrated safeguards testing mode failures.

Emergency diesel start/load testing Select surveillance tests which cross technical disciplines (electrical, mechanical, Battery performance testing instrument and control)

Reactor protection, Reactor Coolant System IST of pumps and valves that perform (RCS) leakage detection, and safety injection important functions in mitigating systems. instrumentation testing (For additional guidance on IST inspection refer to IP 73756, In-service Testing of Safety bus loss of voltage and degraded Pumps and Valves and NUREG-1482, voltage relay testing Guidelines for Inservice Testing at Nuclear Power Plants.) Pumps that provide injection water flow and valves that change position to provide injection water flow to the reactor coolant system.

Barrier Integrity - Identify any containment integrity supporting system, credited by the licensee as operable when assessing risk, which is adversely impacted by surveillance test failures such as failure to adequately test, failure to meet test criteria or failure to realign equipment after the test.

Risk Priority Example Containment isolation valve testing, ventilation/filtration system testing Issue Date: 3/29/21 2 71111.22

Consider selection of the IST activity based on the component or system performance history (known deficiencies), or if the component or system had recently undergone corrective or preventive maintenance.

For sites that have Lead Test Assemblies loaded in operating cores, consider selecting a sample to verify that RCS Specific Activity is within limits. NRC Memorandum titled Clarification of Regulatory Path for Lead Test Assemblies, (ML18323A169) has additional background information.

For AP1000 designs, in addition to safety-related structures, SSCs, focus on systems classified as regulatory treatment of nonsafety systems (RTNSS) of high or intermediate importance, which are used for protecting utilities investment and for preventing and mitigating severe accidents. A list of SSCs classified as RTNSS is in Chapter 16 of the Vogtle Electric Generating Plant (VEGP) Updated Final Safety Analysis Report (UFSAR), Table 16.3-1. The list of Risk-Significant SSCs within the Scope of Design Reliability Program, which evaluates the design of the AP1000 and identifies the aspects of plant operation, maintenance, and performance monitoring pertinent to risk-significant SSCs, is in Chapter 17 of the VEGP UFSAR, Table 17.4-

1. RTNSS is discussed in Section C.IV.9 Regulatory Treatment of Nonsafety Systems of Regulatory Guide 1.206, Applications for Nuclear Power Plants.

During plant outages, sample selection should focus on infrequent surveillance tests, and particularly large-scale actuation tests and full-flow engineered safety feature pump testing, as well as inspections of normally inaccessible SSCs (e.g., containment sump inspections, refueling water storage tank or condensate storage tank internal inspections).

As part of the sample, consider reviewing surveillance tests in which there was a modification of the surveillance frequency in accordance with the Risk Management Technical Specification (TS) Initiative 5b Surveillance Frequency Control Program.

For plants that have implemented the requirements of 10 CFR 50.69, sample selection should include consideration of SSCs that have been categorized as RISC-2, nonsafety-related SSCs that perform safety significant functions. Refer to inspection procedure (IP) 37060, 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components Inspection for additional information.

After Fukushima, the NRC ordered every U.S. commercial reactor to have mitigation strategies for dealing with the long-term loss of normal safety systems following the occurrence of a beyond-design-basis external event (NRC Order EA-12-049, ML12054A735). Because of the low probability of an external event causing a simultaneous loss of all AC and normal access to the ultimate heat sink, FLEX equipment may not be risk/safety significant. However, FLEX increases defense-in-depth for beyond-design-basis scenarios to address loss of power and loss of the ultimate heat sink occurring simultaneously at all units on a site.

Implementation guidance for FLEX is found in Nuclear Energy Institute (NEI) 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, and endorsed via Japan Lessons Learned Project Directorate Interim Staff Guidance (JLD-ISG) 2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events. Various revisions are in effect. NEI 12-06, Revision 0 (ML12242A378) is endorsed via JLD-ISG 2012-01, Revision 0 (ML12229A174).

NEI 12-06, Revision 2 (ML15348A015) is endorsed via JLD-ISG 2012-01, Revision 1 Issue Date: 3/29/21 3 71111.22

(ML15357A163). NEI 12-06, Revision 4 (ML16354B421) is endorsed via JLD-ISG 2012-01, Revision 2 (ML17005A188). It should be noted that not all revisions of NEI 12-06 are endorsed.

Verification of activities under this procedure should focus on performance-based field observations of complete surveillance / testing evolutions, followed by verification of the bases and of the proper demonstration of performance that supports operability / functionality determinations.

For each sample, conduct a routine review of problem identification and resolution activities using IP 71152, Problem Identification and Resolution. Examples of significant surveillance testing problems and appropriate inspector follow-up include:

a. Licensee actions to addressed measuring and test equipment (M&TE) that fails calibration. Inspectors should assess the adequacy of the licensees corrective actions, considering the following: the licensee tracks which surveillance tests used each piece of M&TE, compares the failed M&TE calibration information to each surveillance test that used that M&TE, and then assesses the impact to the operability of the affected system. Inspectors should also consider performing a 71111.15, Operability Determinations and Functionality Assessments, sample to more thoroughly assess the potential effects on operability.

b. Licensee actions to address degraded system performance identified during in-service testing. When degraded performance is revealed, inspectors should review the condition reporting data base to determine if the licensee is implementing appropriate corrective actions, such as testing with increased frequency in accordance with American Society of Mechanical Engineers (ASME) Code, Surveillance Frequency Control Program, or other applicable requirements.

71111.22-03 INSPECTION SAMPLES 03.01 Surveillance Test Verify by witnessing surveillance tests and/or reviewing the test data, that surveillance testing activities and results provide objective evidence that the affected SSCs remain capable of performing their intended safety functions (under conditions as close as practical to design bases conditions or as required by TS) and maintain their operational readiness consistent with the facilitys current licensing basis.

Specific Guidance Significant surveillance test attributes for consideration include the following:

1. Effect of testing on plant operations has been adequately addressed by licensee (control room and/or engineering) personnel.

2. Preconditioning of SSCs prior to or post-testing. Unacceptable preconditioning is defined as the alteration; variation; manipulation; or adjustment of the physical condition of an SSC before or during TS surveillance or ASME Code testing such that it will alter one or more of SSCs operational parameters, which results in Issue Date: 3/29/21 4 71111.22

acceptable test results. Such changes could mask the actual as-found condition of the SSC and possibly result in an inability to verify the operability of the SSC. In addition, preconditioning could make it difficult to determine whether the SSC would perform its intended function during a design basis event in which the SSC might be needed (See Inspection Manual Part 9900, Technical Guidance, Maintenance -

Preconditioning of Structures, Systems, and Components Before Determining Operability, for additional guidance).

3. Acceptance criteria are clearly derived from the supporting technical bases (design bases, setpoint calculations, UFSAR, TS Bases, etc.) and demonstrate operational readiness consistent with the facilitys current licensing basis.

4. M&TE specified in procedures are part of the measuring and test equipment program, their calibration status is within acceptable limits, and their range and accuracy are consistent with the application as supported by design bases documents. Plant equipment calibration is correct, accurate, properly documented and the calibration frequency is in accordance with TS, UFSAR, licensee procedures and commitments.

5. Test is performed in sequence and in accordance with written procedure.

6. Jumpers installed or leads lifted during testing are properly controlled.

7. Electrical connections are properly torqued, secure, and maintain their intended design function.

8. For cases where the licensee relies on multiple surveillance tests to satisfy a surveillance requirement, the affected surveillance test procedures collectively accomplish the entire scope of the surveillance requirement.

9. Setpoints, required test accuracy, test frequency, and allowable setpoint drift for selected safety-related instrumentation and control surveillance tests (i.e., RPS, NIs, etc.) conform to applicable setpoint calculations. Reference setpoint data has been accurately incorporated into the applicable test procedure(s). To determine whether open phase condition (OPC) detection and protection circuits (as applicable) are functional, review OPC alarm setpoints and alarm response procedure(s) to verify whether operators can take timely manual actions consistent with the licensees commitments to the OPC Voluntary Industry Initiative. [C2]

10. Annunciator and other alarms are demonstrated to be functional and setpoints are consistent with design bases documents. Alarm response procedure entry points and actions are consistent with plant design/licensing bases documents.

11. Testing methods, acceptance criteria, and required corrective actions for IST activities meet with the applicable version of the ASME Code,Section XI. In concert with TS requirements, IST programs are intended to ensure the operational readiness of certain safety-related pumps and valves. Inspectors must review reference values or changes to reference values for consistency with the design bases and verify that the current acceptance criteria match the most recent reference test data. For pump testing, the inspectors should verify that the licensee established system operating conditions that reflect limiting operational conditions Issue Date: 3/29/21 5 71111.22

and are sufficiently repeatable to allow performance trending. Inspectors should also review sufficient test performance history to verify that the licensee identified and is addressing any adverse trends.

12. For local leak rate testing, isolation valves inside and outside containment are each tested with pressure exerted in a direction consistent with expected accident conditions. The inspectors should verify that the licensee updates the total containment leak rate data with the new measured value and confirm that the overall leak rate is still within acceptable limits. The inspectors should verify that the licensee schedules the isolation valve(s) for maintenance if administrative limits are exceeded. The inspectors should also verify that the containment penetration(s) is declared inoperable if acceptance criteria are exceeded.

13. Test frequency was adequate to demonstrate operability (meets TS requirements),

and reliability. Appendix A, Risk Management TS Initiative 5b Surveillance Frequency Control Program, provides additional guidance if a selected sample is associated with the application of the Risk Management TS Initiative 5b Surveillance Frequency Control Program.

14. If an adverse trend in RCS leakage is being monitored by the licensee, the inspectors should verify that the licensee has programs and processes in place to (1) monitor plant-specific instrumentation that could indicate potential RCS leakage, (2) meet existing requirements related to degraded or inoperable leakage detection instruments, (3) use an inventory balance check when there is unidentified leakage (4) take appropriate corrective action for adverse trends in unidentified leak rates, and (5) pay particular attention to changes in unidentified leakage. [C1]

15. Unavailability of the tested equipment is appropriately considered in the licensees Mitigating System Performance Index data.

16. After completion of testing, equipment is returned to the positions/status required for the SSCs to perform its intended safety function.

17. Test equipment is removed after testing.

18. Test data is complete, verified, and meets procedure requirements.

19. For test results that do not meet the acceptance criteria, the results of licensee engineering evaluations provide an acceptable bases for returning affected SSCs to an operable status.

20. Performance trends for the last several completed tests are appropriately documented and addressed. If testing indicates unacceptable setpoint drift or otherwise demonstrates degradation, the inspector must assess the adequacy of the licensees corrective actions. These may include component replacement and/or increased frequency of testing, for example.

03.02 FLEX Testing Verify by witnessing tests and/or reviewing the test data, that testing activities and results provide objective evidence that FLEX SSCs remain capable of Issue Date: 3/29/21 6 71111.22

performing their intended functions (under conditions as close as practical to licensing conditions) and maintain their operational readiness consistent with the facilitys current licensing basis.

Specific Guidance Section 11.5 of NEI 12-06 contains guidance on FLEX maintenance and testing. If needed, questions regarding FLEX issues can be raised with either the regional Technical Support Branch Chief or with the NRR Beyond Design Basis Engineering Branch (via the NRR DORL PM).

71111.22-04 REFERENCES Cross Reference of Generic Communications to IP 71111.22 and Inspection Resources:

https://drupal.nrc.gov/nrr/ope/34018 (nonpublic)

Operating Experience: http://drupal.nrc.gov/nrr/ope (nonpublic)

IHS Codes and Standards: https://drupal.nrc.gov/tech-lib/35748 (nonpublic)

IMC 2515, Light-Water Reactor Inspection Program - Operations Phase IMC 2515, Appendix A, Risk-Informed Baseline Inspection Program IP 73756, Inservice Testing of Pumps and Valves IP 61720, Containment Local Leak Rate Testing IP 71152, Problem Identification and Resolution IP 37060, 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components Inspection Bulletin 88-04, "Potential Safety-Related Pump Loss," May 5, 1988.

Code of Federal Regulations, Title 10, Part 50, Section 50.55a, "Codes and Standards."

Generic Letter 89-04, "Guidance on Developing Acceptable Inservice Testing Programs," April 3, 1989.

Information Notice 97-90, Use of Nonconservative Acceptance Criteria in Safety-Related Pump Surveillance Tests, December 30, 1997 10 CFR 50, Appendix J, including Option B.

NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants ASME Boiler and Pressure Vessel Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components Issue Date: 3/29/21 7 71111.22

Inspection Manual Part 9900, Technical guidance, Maintenance - Preconditioning of Structures, Systems, and Components Before Determining Operability Regulatory Guide (RG), 1.45, Reactor Coolant Pressure Boundary Leakage Detection Systems Regulatory Issue Summary 06-17, NRC Staff Position on the Requirements of 10 CFR 50.36, Technical Specifications, Regarding Limiting Safety System Settings During Periodic Testing and Calibration of Instrument Channels Information Notice 2010-25, Inadequate Electrical Connections NEI 12-06, Revision 0, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, (ML12242A378)

NEI 12-06, Revision 2, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, (ML15348A015)

NEI 12-06, Revision 4, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, (ML16354B421)

JLD-ISG 2012-01, Revision 0, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (ML12229A174)

JLD-ISG 2012-01, Revision 1, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (ML15357A163)

JLD-ISG 2012-01, Revision 2, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (ML17005A188)

RG 1.200, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities, U.S. Nuclear Regulatory Commission, Washington, DC. (ML090410014)

RG 1.201 Guidelines for Categorizing Structures, Systems, and Components in Nuclear Power Plants according to Their Safety Significance, U.S. Nuclear Regulatory Commission, Washington, DC. (ML061090627)

NEI 00-04, 10 CFR 50.69 SSC Categorization Guideline, Nuclear Energy Institute, Washington, DC, July 31, 2005. (ML052900163)

NRC Memorandum Clarification of Regulatory Path for Lead Test Assemblies, (ML18323A169)

END Issue Date: 3/29/21 8 71111.22

APPENDIX A RISK MANAGEMENT TECHNICAL SPECIFICATIONS (TS) INITIATIVE 5b SURVEILLANCE FREQUENCY CONTROL PROGRAM (SFCP) GUIDANCE 71111.22A-01 INSPECTION OBJECTIVE The objective of this Appendix is to provide additional guidance if a selected sample is associated with a licensees implementation of the risk management TS (RMTS) Initiative 5b, described in the RMTS Guidelines Document NEI 04-10, Risk Informed Method for Control of Surveillance Frequencies.

71111.22A-02 GENERAL GUIDANCE A highlight of the SFCP change process is found in the specific guidance below. The SFCP change process does allow for extending Surveillance Test Intervals (STIs) even when SSCs have had prior failures. However, focus should be placed on previous SSC performance.

The surveillance frequency should be adequate to demonstrate operability. As indicated in Surveillance Requirement (SR) 3.0.1, SRs shall be met during the Modes or other specified conditions in the Applicability for individual Limited Conditions for Operations, unless otherwise stated in the SR. A Surveillance is met only when the acceptance criteria are satisfied. Known failure of the requirements of a Surveillance, even without a Surveillance specifically being performed, constitutes a Surveillance not met. Given an SSCs previous performance, the Surveillance will still need to be met during the extended STI. Any concerns associated with extending STIs given prior SSC performance can be raised with NRR/DRO/IRIB.

71111.22A-03 INSPECTION SAMPLES See Section 03.01 of IP 71111.22.

Specific Guidance:

The following guidance highlights the SFCP change process, as recommended in NEI 04-10, Risk-Informed Technical Specifications Initiative 5b, Risk Informed Method for Control of Surveillance Frequencies, Industry Guidance Document (see list of References for the applicable revision).

If the STI was previously extended through the SFCP, a minimum number of surveillance intervals is needed per the NEI guidance prior to further extending the STI. A minimum of three successive satisfactory performances of the surveillance is needed when the STI is less than or equal to six months, and a minimum of two successive satisfactory performances of the surveillance is needed when the STI is greater than six months.

Surveillance frequency change was evaluated by the licensee for prohibitive commitments, and either no such commitments existed, or they were revised prior to implementation of the STI change.

The qualitative evaluation by the licensee included, as a minimum, the items identified in NEI 04-10, step 7. Some of the items identified include considerations for SSC performance history, Issue Date: 3/29/21 AppA-1 71111.22

vendor specified maintenance frequency, and test intervals specified in applicable industry codes and standards.

If the affected component or system is modeled in the PRA, or was added to the PRA model to support application of the SFCP: The acceptance criteria for licensees evaluation, using the licensee's PRA model, is <1 E-6 CDF and <1 E-7 LERF. If the affected component or system is not modeled in the PRA: The acceptance criteria for the licensees qualitative or bounding analyses is the acceptance criteria of <1 E-7 CDF and <1 E-8 LERF. The acceptance criteria for the cumulative impact of all STI changes is <1 E-5 CDF and <1 E-6 LERF. Sensitivity studies associated with the revised STI are performed by the licensee. An in-depth review of the licensees PRA evaluation or analysis is not required.

An Independent Decisionmaking Panel (IDP) approves the STI change. The IDP is comprised of the site Maintenance Rule Expert Panel, a Surveillance Test Coordinator, and a Subject Matter Expert. If approved, the STI changes are appropriately implemented by revising plant procedures and affected documents, and training personnel as needed. SSC performance associated with the revised STI is also monitored by the licensee. SSC performance is considered during periodic re-assessments.

71111.22A-04 REFERENCES IMC 2515, Appendix A, Risk-Informed Baseline Inspection Program IMC 0308, Attachment 2, Technical Basis for Inspection Program IP 71111.13, Maintenance Risk Assessments and Emergent Work Control.

RG 1.174, An Approach for Using Probabilistic Risk Assessment in Risk Informed Decisions on Plant Specific Changes to the Licensing Basis.

RG 1.177, An Approach for Plant-Specific, Risk-Informed Decision-making: Technical Specifications.

RG 1.200, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk Informed Activities.

EPRI 1009474, Dec 2004 RMTS Guidelines.

Licensee Safety Evaluation Report (SER) for the license amendments adopting RITS 5b.

NEI 04-10 Revision 0 1, Risk-Informed Technical Specifications Initiative 5b, Risk Informed 0F Method for Control of Surveillance Frequencies, Industry Guidance Document (ML062570416).

NEI 04-10 Revision 1, Risk-Informed Technical Specifications Initiative 5b, Risk Informed Method for Control of Surveillance Frequencies, Industry Guidance Document (ML071360456).

NUMARC 93-01, NEI - Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 3.

1 NEI 04-10, Revision 0, is referenced in the Limerick Generating Station technical specification surveillance frequency control program. All other licensees reference NEI 04-10, Revision 1.

Issue Date: 3/29/21 AppA-2 71111.22

GDC in 10 CFR Part 50, Appendix A.

NEI 00-04, Revision 0, 10 CFR 50.69 SSC Categorization Guideline (ML052900163).

END Issue Date: 3/29/21 AppA-3 71111.22

Attachment 1 - Revision History for IP 71111.22 Commitment Accession Description of Change Description of Comment Resolution and Tracking Number Training Closed Feedback Form Number Issue Date Required and Accession Number (Pre-Change Notice Completion Decisional, Non-Public Date Information)

N/A 01/17/2002 Revised to incorporate minor changes to the NO N/A CN 02-001 inspection requirements. In addition, inspection resource estimates and inspection level of effort are revised to provide a band for more inspection flexibility.

C1 ML041340229 Revised to include RCS leak detection system YES N/A

Reference:

05/11/2004 surveillance as part of the surveillance testing 9/24/2003 Davis-Besse CN 04-013 samples. Revision also includes surveillance Lessons testing attributes for reviewing annunciator/alarm Learned Task setpoints and alarm response procedure actions.

Force Item 3.2.1(3) DBLLTF Report: ML022760172 N/A ML053490179 Reduced the estimated resources required to NO N/A 01/05/2006 complete this inspection activity based on CN 06-001 inspection hours charged to this IP during last several ROP cycles. Completed historical CN search.

N/A ML070540275 IP 71111.22 address feedback form 71111.22-912 NO N/A 02/27/07 to clarify Section 02.02 to more clearly describe CN-07-007 what is to be accomplished when conducting the leakage detection surveillance inspection.

Issue Date: 3/29/21 Att1-1 71111.22

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

N/A ML092780504 Revised IP to make changes recommended by NO N/A 12/24/09 2009 ROP Realignment process. (Ref.

CN-09-032 ML092090312.)

• Did not make changes recommended by FF71111.19-1334; see FF for details.

• Incorporated FF2515-1309 by adding reference to IMC 2515 in Section 2.02 to emphasize observation of plant activities.

• Incorporated FF2515-1325 by removing quarterly sample requirements in Level Of Effort section and Section 2.01. Quarterly samples are not required by IMC 2515.

In Section 04, reduced the resource estimate by 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.

N/A ML11213A004 Revised to incorporate feedback associated with NO ML112840035 11/08/11 Feedback Form No. 71111.22-1550.

CN 11-031 N/A ML12086A064 Revised to reflect NRC approval of Risk YES ML12086A084 04/12/2012 Management Technical Specification Initiative 5b To be CN 12-005 Surveillance Frequency Control Program. conducted by NRR after IP issuance.

N/A ML15040A283 Revised to incorporate feedback associated with NO ML15127A419 06/15/15 the ROP Enhancement Project.

CN 15-011 Issue Date: 3/29/21 Att1-2 71111.22

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

N/A ML18177A109 Revisions are made to: None ML18179A042 11/19/18 (1) Address recommendations from the working CN 18-039 group established to update the ROP for regulatory actions taken following the Fukushima Dai-ichi accident. IP revised to allow for oversight of FLEX testing, and as a minimum, require one inspection sample per year. (2) Conform to new IP format requirements found in IMC 0040.

N/A ML19197A106 Added AP 1000 Sampling Requirements. Revised None ML19210C941 12/20/19 to provide additional guidance associated with 71111.22-2329 CN 19-041 inspection of Risk Management Technical ML19301A005 Specification Initiative 5b Surveillance Frequency 71111.22-1857 Control Program. Addresses concerns raised in ML19233A026 Feedback Form 71111.22A-1857. Removed language regarding vertical slice (Feedback Form 71111.22-2329).

N/A ML20191A205 Revised AP1000 baseline sampling range from 5 None ML20233A522 10/06/20 to 9 to 5 to 7. Added references for operating CN 20-047 experience.

ML20324A093 Administrative change to clarify information in the None N/A 11/20/20 Sample Requirements table.

CN 20-064 C2 ML21033A557 Revised to incorporate Commission direction in None ML21035A251 SRM-SECY 03/21/19 SRM-SECY-16-0068 to update the ROP to provide 16-0068 CN 21-015 periodic oversight of the industrys Open Phase Condition initiative Issue Date: 3/29/21 Att1-3 71111.22