**NRC INSPECTION MANUAL**IRIB 

EVALUATIONS OF CHANGES, TESTS, AND EXPERIMENTS  

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:  DRAFT 	1 	71111.17T 

Issue Date:  DRAFT 	1 	71111.17T 

Issue Date:  12/08/16 	1 	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. 

## 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.” 

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

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Attachment 1 

Revision History for IP 71111.17T 

Issue Date:  12/08/16 	Att 1-1 	71111.17T

Issue Date:  12/08/16 	Att 1-2 	71111.17T