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NRC INSPECTION MANUAL RSIB

INSPECTION PROCEDURE 93803

SAFETY SYSTEMS OUTAGE MODIFICATIONS INSPECTION

PROGRAM APPLICABILITY: 2515, 2525

93803-01 INSPECTION OBJECTIVES

01.01 To verify that the licensee has appropriate programmatic

controls for accomplishing changes, modifications, and repairs.

01.02 To verify that the licensee is conducting activities

related to design changes, modifications, and repairs in accordance

with established procedures, commitments, and regulatory requirements.

01.03 To verify that completed modifications have been properly

designed, installed, inspected, and tested to ensure the adequate

performance of the modified systems and components.

01.04 To determine that the design margins of the modified

safety-related systems and components have not been reduced.

01.05 To verify that the modified systems and components are

ready for safe startup and operation of the plant.

93803-02 INSPECTION REQUIREMENTS

The Safety Systems Outage Modifications Inspection (SSOMI) consists

of a design inspection and an installation and testing inspection.

02.01 Advance Preparation. Each of the inspection teams should

review the following applicable documents, before the start of the

inspections. The teams should become familiar with the licensee's

administrative programs for designing, installing, and testing

modifications in addition to the components and systems for which

modifications are planned.

a. Final Safety Analysis Report (FSAR).

b. Technical Specifications (TS).

c. Descriptions of the proposed modifications.
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d. Administrative documents used to implement modifications.

e. Corporate and site engineering procedures.
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f. Licensee event reports for the past 2 years.

g. Past inspection reports.

h. System descriptions.

02.02 Design Inspection. This part of the inspection should be

performed by a design engineering team staffed with electrical and

mechanical engineers who are familiar with design and analysis

practice and techniques. The inspection should be conducted before

the outage starts or soon after the start of a major outage, and

should be done at the offices of the organization with principal

engineering responsibility for the modifications. The inspection

will verify the following for a sample of modifications selected

during the advance preparation for the SSOMI.

a. Regulatory requirements and design bases as specified in the

FSAR and TS and as documented in NRC safety evaluations, have

been correctly reflected in the modifications.

b. The licensee has adequately performed 10 CFR 50.59 safety

evaluations for the modifications, as required.

c. Design information is current and correct and the assumptions

used in the design calculations are based on sound engineering

principles and practices.

d. Design information has been properly incorporated into project

documents such as specifications, drawings, procedures, and

instructions used for the modifications.

e. Design information is controlled and has been applied to the

original design changes, including field changes.

f. Field changes are properly recorded and evaluated.

g. The licensee's engineering staff has sufficient technical

guidance and experience to adequately perform the assigned

engineering functions.

h. The design verification process, such as alternate or

independent calculation review or qualification testing, is

performed correctly.

02.03 Installation Inspection. Sections 02.03 and 02.04 are

performed by multi-discipline teams with expertise in electrical and

mechanical system installation and testing requirements. The

installation inspection should be conducted at the plant site at a

time during the outage when sufficient modification installation

activities have been accomplished to warrant the inspection.

The inspection should verify the following for a sample of

modifications selected during the advance preparation phase of the

SSOMI.

a. The licensee has adequately performed 10 CFR 50.59 safety

evaluations for the modifications, as required.
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b. The installed modifications agree with design requirements

such as those pertaining to as-built dimensions, code

requirements, ANSI standards, regulatory guides, A/E specifications, welding and NDE requirements, and seismic requirements.

c. For the work packages selected, the proper maintenance

procedures or work procedures were invoked and followed, QA/QC

hold points were properly accomplished and verified, and all

required forms were properly completed, signed, and reviewed.

d. Required QA/QC audits and surveillances have been performed

on the selected modifications, and the audit and surveillance

findings have been properly dispositioned.

e. Work requests and maintenance orders are in agreement with the

work originally authorized, and work requests, if revised, did

not expand the scope of the work originally planned by the

modification.

f. Deficiency reports, field change requests, engineering change

notices, and similar documents recorded deviations from

original design requirements, and adequate engineering review

was done before corrective actions were accepted.

g. QA documentation for replacement items is in agreement with

the material installed, and the material is properly environmentally qualified (EQ) and agrees with design specifications.

h. Maintenance or modifications on EQ components do not invalidate the qualification.

i. All controlled documents (e.g., drawings, work procedures,

site administration procedures, test procedures, TS, FSAR)

affected by the modified component, system or structure have

been revised or are being revised.

02.04 Testing Inspection. The testing inspection should be

conducted near the end of the outage at a time when a significant

amount of post-modification testing is being performed. The

inspection team should verify the following for the systems

modified:

a. Modified systems and components were tested in accordance with

approved procedures, and the results were properly reviewed

and approved before startup testing occurred and the systems

and components were placed into service.

b. Performance of the modified systems and components conforms

to requirements and acceptance standards identified in

licensee procedures, and the operational margins of safety

have not been compromised.

c. Testing of individual modified components or subsystems takes

into account the effects of the modifications on the operational performance of the entire system and on affected

interfacing systems.
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d. Piping and instrumentation diagrams, critical drawings,

including control room drawings, and operating procedures were

revised to incorporate system changes before system operation.

e. Operator training for significant operational changes occurred

before system startup, and operator training programs were

revised in a reasonable time to reflect the design changes or

modifications that were implemented.

f. As-built drawings were changed to reflect the current

configurations, and this was accomplished not only for the

modified systems, but also for other systems, components or

structures which were affected by the modification activities.

g. Deficiencies were clearly identified, and appropriate

corrective actions were implemented.

h. After corrective actions, or changes to the modifications,

have been completed, tests were rerun as necessary to ensure

that performance of the system is adequate.

i. Results of the evaluations are reviewed by appropriate

licensee personnel and/or contractor personnel, including the

persons responsible for approving the original test procedures.

93803-03 INSPECTION GUIDANCE

General Guidance

a. Team Composition. The design team normally is comprised of

a team leader and four to six engineers who are experts in the

design areas of electrical, instrumentation and control,

mechanical systems, and mechanical components. The installation and testing team normally consists of a team leader for

each of the mechanical and electrical disciplines, with,

typically, two or three additional inspectors per discipline

area. The installation inspectors should be knowledgeable in

construction or modification and maintenance activities, and

the testing inspectors should be knowledgeable in component

and system testing.

Team compositions should be changed as necessary to meet

changing inspection requirements or priorities for specific

plants or specific outages. For example, one or more

procurement specialists may be added to either the design team

or the installation and testing team for a broader or more

detailed inspection in that area. In addition, for major

outages, separate teams may be warranted for installation

activities and for testing activities.

b. Inspection Scheduling. The design inspection and the

installation and testing inspection are each normally four

weeks long. The first week is typically devoted to in-office

preparation, then two weeks are normally spent inspecting,

with an interim week devoted to in-office review. If
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extensive or unusual findings are identified during the onsite

inspection, team leaders should consider lengthening the

onsite inspection period as necessary to complete the required

inspections. Some other factors to consider when extending

the inspection period include the complexity of the modifications to be reviewed, the length of the plant outage, travel

time needed to get to the site, and the scope of the review.

Following completion of the inspection activities, report

inputs should be provided by each inspector on a schedule

determined by the team leader and NRC management.

03.01 Specific Guidance

a. Inspection Requirement 02.01. Advance preparation should be

performed by the design team and the installation and test

team. The teams should review the licensee's applicable

administrative, corporate and site engineering procedures in

detail during this period so that they are thoroughly familiar

with the utility's program for performing modifications. In

addition, individual inspectors should become familiar with

the systems being modified so that they can understand the

impact of the modifications. Before each team's advance

review period, the team leader and selected team members

should make a "bagman" trip to the utility to find and bring

back the material needed during the advance preparation. The

teams should also be familiar with other applicable documents

such as the FSAR, Technical Specifications, LERS, and NRC

inspection reports.

b. Inspection Requirement 02.02. The design team inspectors will

typically spend most of their time at the engineering offices

where the organization responsible for the design of the

modifications is located. Sharing of design findings and

concerns with the installation and test team is particularly

important for the successful completion of the SSOMI. If

practical, the installation and test team leader and discipline leaders should attend the design team preexit and exit

meetings to become more familiar with the design team findings

and concerns.

c. Inspection Requirement 02.02a. The inspector should verify

that system information is consistent between the Technical

Specifications, the FSAR, design documents, and other licensee

technical manuals.

d. Inspection Requirement 02.02d. Design documents and information should be numbered and categorized for future use and

reference. Most licensees with good design engineering

department practices will have all of the design documents

numbered so that future modifications can be referenced to

preexisting and accurate design information on the system

rather than having to research existing design documents such

as the TS and FSAR to resurrect good information whenever a

system is modified.

e. Inspection Requirement 02.02e. All design calculations should

have technical independent reviews performed to ensure that
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design calculations are free from errors and that the

assumptions made and the engineering approach taken are both

conservative and reasonable.

f. Inspection Requirement 02.03a. Proper safety evaluations

should consist of more than a checklist and should state why

the modification does not need a safety evaluation, if so

noted. Additionally, the inspector should review for

potential unreviewed safety questions.

g. Inspection Requirement 02.03c. All work performed for the

modifications should be with approved procedures which have

been through the appropriate site approval process. If work

has been completed with the use of a locally generated

procedure, the assumptions made in the safety analysis may be

incorrect and the licensee should perform a technical

evaluation of the work performed to determine system

operability.

h. Inspection Requirement 02.04. A combined installation and

test team may not have the opportunity to witness modification

testing during a SSOMI of a short duration outage. Therefore,

the team may have to rely on reviews of test procedures,

evaluation of completed test results and limited observation

of testing.

i. Inspection Requirement 02.04a. Test results should be

compared with the FSAR values (if values are specified in the

FSAR) and the licensee's In-Service Testing reference values

in order to determine the effect of the new test results on

the ASME Section XI requirements.

j. Inspection Requirement 02.04c. The site review and approval

process for functional test procedures that have been written

for specific modifications should be evaluated for adequacy

and completeness.

END