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 hours 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.