NRC INSPECTION MANUAL IRIB

INSPECTION MANUAL CHAPTER 0308 ATTACHMENT 2

TECHNICAL BASIS FOR INSPECTION PROGRAM

Effective Date: 01/01/2024

 CONTENTS

0308.2-01 INTRODUCTION ..................................................................................................... 1

0308.2-02 METHODOLOGY FOR IDENTIFYING INSPECTABLE AREAS ............................. 1
0308.2-03 BASELINE INSPECTION PROGRAM .................................................................... 1
03.01 PI Verification ........................................................................................................... 4
03.02 Problem Identification and Resolution ..................................................................... 4
03.03 Event Follow-up ....................................................................................................... 5
03.04 Plant Status ............................................................................................................ 6
0308.2-04 SUPPLEMENTAL INSPECTION PROGRAM ......................................................... 7
0308.2-05 EVENT RESPONSE ............................................................................................... 8
0308.2-06 OVERSIGHT OF PLANTS IN EXTENDED SHUTDOWN ....................................... 8
0308.2-07 THRESHOLD FOR DOCUMENTING FINDINGS AND INSIGHTS ......................... 9
0308.2-08 OTHER INSPECTION PROGRAM ASPECTS CONSIDERED BUT NOT
INCLUDED ............................................................................................................ 10
BASIS SUMMARY SHEETS ....................................................................................................... 11
Exhibit 1: Adverse Weather Protection (IP 71111.01) ............................................................. 12
Exhibit 2: Reserved (IP 71111.02)........................................................................................... 14
Exhibit 3: Reserved (IP 71111.03)........................................................................................... 15
Exhibit 4: Equipment Alignment (IP 71111.04) ........................................................................ 16
Exhibit 5: Fire Protection (IP 71111.05)................................................................................... 17
Exhibit 6: Flood Protection Measures (IP 71111.06) ............................................................... 19
Exhibit 7: Heat Exchanger/Sink Performance (IP 71111.07)................................................... 20
Exhibit 8: Inservice Inspection Activities (IP 71111.08) ........................................................... 22
Exhibit 9: Reserved (IP 71111.09)........................................................................................... 24
Exhibit 10: Reserved (IP 71111.10) ........................................................................................ 25
Exhibit 11: Licensed Operator Requalification Program and Licensed Operator
Performance(IP 71111.11) .................................................................................... 26
Exhibit 12: Maintenance Effectiveness (IP 71111.12) ............................................................. 28
Exhibit 13: Maintenance Risk Assessments and Emergent Work Control (IP 71111.13) ....... 30
Exhibit 14: Reserved (IP 71111.14) ........................................................................................ 32
Exhibit 15: Operability Determinations and Functionality Assessments (IP 71111.15) ........... 33
Exhibit 16: Reserved (IP 71111.16) ........................................................................................ 35
Exhibit 17: Evaluations of Changes, Tests, and Experiments (IP 71111.17T) ........................ 36
Exhibit 18: Plant Modifications (IP 71111.18) .......................................................................... 37
Exhibit 19: Post-Maintenance Testing (IP 71111.19) .............................................................. 38
Exhibit 20: Refueling and Other Outage Activities (IP 71111.20) ............................................ 39
Exhibit 21: Safety System Design and Performance Capability (IP 71111.21) ....................... 40
Exhibit 22: Surveillance Testing (IP 71111.22)........................................................................ 41
Exhibit 23: Reserved (IP 71111.23) ........................................................................................ 43
Exhibit 24: Testing and Maintenance of Equipment Important to Risk (IP 71111.24) ............. 44
Exhibit 25: Biennial Exercise and Drill Inspection (IP 71114.01, .06, .07 and .08) .................. 46
Exhibit 26: Alert and Notification System Evaluation (IP 71114.02) ........................................ 48
Exhibit 27: Emergency Response Organization Staffing and Augmentation System (IP
71114.03)............................................................................................................... 49
Exhibit 28: Emergency Action Level and Emergency Plan Changes (IP 71114.04) ............... 50

Issue Date: 10/31/23 i 0308 Att 2

 Exhibit 29: Correction of Emergency Preparedness Weaknesses and Deficiencies (IP
71114.05)............................................................................................................... 52
Exhibit 30: Access Control to Radiologically Significant Areas (IPs 71124.01, 71124.04, and
71124.08)............................................................................................................... 54
Exhibit 31: ALARA Planning and Controls (IPs 71124.01, and 71124.03) ............................. 55
Exhibit 32: Radiation Monitoring Instrumentation (IPs 71124.04 and IP 71124.05) ................ 57
Exhibit 33: Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (IPs
71124.05, 71124.06, and 71124.07) ...................................................................... 58
Exhibit 34: Radiological Environmental Monitoring Program (REMP) (IP 71124.07) .............. 60
Exhibit 35: Radioactive Material Processing and Radioactive Material Handling, Storage, and
Transportation (IP 71124.08) ................................................................................. 61
Exhibit 36: Discrepant or Unreported Performance Indicator Data (IP 71150)........................ 62
Exhibit 37: Performance Indicator Verification (IP 71151) ....................................................... 63
Exhibit 38: Problem Identification and Resolution (IP 71152) ................................................. 64
Exhibit 39: Follow up of Events and Notices of Enforcement Discretion (IP 71153) ............... 66
Exhibit 40: Light Water Reactor Inspection Program - Operations Phase (IMC 2515)............ 67
Exhibit 41: Risk Informed Baseline Inspection Program (IMC 2515, Appendix A) .................. 69
Exhibit 42: Supplemental Inspection Program (IMC 2515, Appendix B) ................................. 70
Exhibit 43: Special and Infrequently Performed Inspections (IMC 2515, Appendix C)............ 71
Exhibit 44: Plant Status (IMC 2515, Appendix D) .................................................................... 72
Exhibit 45: Inspection Program Modifications During Public Health Emergencies Or Other
Conditions Restricting Inspector Onsite Presence (IMC 2515, Appendix E) ......... 73
Exhibit 46: Supplemental Inspection Response to Action Matrix Column 2 (Regulatory
Response) Inputs (IP 95001) ................................................................................. 74
Exhibit 47: Supplemental Inspection Response to Action Matrix Column 3 (Degraded
Performance) Inputs (IP 95002) ............................................................................ 75
Exhibit 48: Supplemental Inspection Response to Action Matrix Column 4 (Multiple/Repetitive
Degraded Cornerstone) Inputs (IP 95003) ............................................................ 77
Exhibit 49: Special Inspection (IP 93812) ................................................................................ 78
Exhibit 50: Oversight of Operating Reactor Facilities in a Shutdown Condition Due to
Significant Performance and/or Operational Concerns (IMC 0350)....................... 79
Table 1: Inspectable Areas by Cornerstone ................................................................................ 81
Table 2: Other Inspection Program Elements Considered But Not Included .............................. 83
Attachment 1: Revision History for IMC 0308 Attachment 2 ................................................. Att1-1

Issue Date: 10/31/23 ii 0308 Att 2

0308.2-01 INTRODUCTION

The power reactor inspection program is composed of several elements to provide indication of
licensee performance. The key feature of the program is the baseline inspection program, which
defines the minimum level of inspection that all plants will receive regardless of performance.
The supplemental inspection program is performed to independently evaluate the root causes of
performance deficiencies when indications of declining licensee performance are obtained
through either the performance indicators (PIs) or other inspections (principally the baseline
inspection program). Plant events are inspected to determine their significance and to determine
the agency’s necessary response. Plants in extended shutdowns due to performance problems
are inspected and assessed by a separate inspection process (i.e., Inspection Manual Chapter
[IMC] 0350) because many of the PIs and much of the baseline inspection program would not
be applicable.

The risk-informed baseline inspection program for power reactors defines the minimum level of
planned inspections to evaluate licensee performance over a 12-month period. The overall
objective of the program is to monitor all power reactor licensees at a defined level of effort to
assure licensees’ performance meets the objectives for each cornerstone of safety. These
cornerstones support the agency’s performance goals in the NRC’s Strategic Plan.

0308.2-02 METHODOLOGY FOR IDENTIFYING INSPECTABLE AREAS

The objective in revising the inspection program was to develop a baseline program that is
risk-informed and performance-based that identifies the minimum level of inspection required for
a plant (regardless of performance) to give the NRC sufficient information to determine whether
plant performance is acceptable. A key input to this effort was the regulatory framework and the
cornerstones of safety, which are areas of reactor functions or licensee activities that must be
performed to a certain set of objectives to ensure that the NRC’s mission is met.

The baseline inspection program was developed using a risk-informed approach to determine a
comprehensive list of areas to inspect (inspectable areas) within each cornerstone of safety.
These inspectable areas were selected based on their risk significance (i.e., they are needed to
meet a cornerstone objective as derived from a combination of probabilistic risk analyses
insights, operational experience, deterministic analyses insights, and regulatory requirements).
The scope of inspection within each inspectable area was determined using the same
risk-informed approach. The scope of inspection was also modified by the applicability of a PI.
The more fully an indicator measures an area, the less extensive is the scope of inspection.

0308.2-03 BASELINE INSPECTION PROGRAM

The baseline inspection program contains certain concepts that are a change in the approach to
conducting inspections from the previous core inspection program. The key concepts are
summarized below:

• The baseline program is the minimum level of inspection conducted at all power reactor
facilities, regardless of their performance. Licensees performing at a level not requiring
additional NRC interaction will only be inspected at the baseline inspection level of effort.

Issue Date: 10/31/23 1 0308 Att 2

 • Inspections of performance issues beyond the baseline program are termed
supplemental inspections. This increased inspection effort is based on criteria specified
in the assessment program to address declining licensee performance and is not
included in the baseline program.

• The scope of the baseline program is defined by inspectable areas linked to the
cornerstones of safety. The justification for inclusion of the inspectable area in the
baseline program is described in this basis document.

• The baseline program has four parts: (1) inspection in inspectable areas in which PIs are
not identified and/or in which PIs do not fully cover the inspectable area; (2) ongoing
verification of the information provided in PIs; (3) comprehensive review of licensee
effectiveness in identifying and resolving problems, and (4) initial follow up to plant
events and degraded conditions to determine their safety significance.

• The process for planning inspections will be conducted in accordance with IMC 0305,
“Operating Reactor Assessment Program.”

Risk has been factored into the baseline inspection program in four ways: (1) inspectable areas
are based on their risk importance in measuring a cornerstone objective, (2) the inspection
frequency, how many activities to inspect, and how much time to spend inspecting activities in
each inspectable area is based on risk information, (3) the selection of activities to inspect in
each inspectable area is based on plant-specific risk information, and (4) inspectors are trained
in the use of risk information.

A panel consisting of Inspection Program Branch and senior regional managers and their staff
developed the sample size and the number of inspection hours expected to be necessary to
complete each of the inspection procedures, at the inception of the reactor oversight program
(ROP). Sample size and number of hours were developed based on their expert judgement and
relevant risk information on how much inspection activities would be sufficient to ensure
verification that the licensee was meeting the objectives of all seven cornerstones.

After the first year of implementation of the new ROP, regional management and inspectors
raised concerns regarding the lack of flexibility in the ROP inspection requirements for both
sample size requirements and number of hours for each inspectable area. They were
concerned with their ability to apply their inspection focus into areas they felt needed more or
less inspection effort based on their overall knowledge of a specific plant. As a result, in
consultation with regional management, the Inspection Program Branch changed the original
sample size from a single value to a range of values which were -15 percent to +15 percent of
the original sample size. The original sample size is the nominal or average of the -15 percent
and +15 percent values.

The idea was that any individual plant inspection program could then be adjusted within these
relatively limited ranges based on the plant-specific insights of the inspectors, but that at a
nationwide program level, the average (i.e., mean) level of samples and effort would continue to
fall in about the middle of these ranges. As experience with the ROP was accumulated, it was
felt that these program average values and ranges could then be adjusted as needed while still
retaining an appropriate degree of flexibility to accommodate plant-specific inspection focus
needs.

Appendix A to IMC 2515 contains a list of baseline inspection procedures and specifies the
required frequency for their performance. The baseline inspection procedures must be

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completed at every plant at a prescribed interval. In certain cases, completion of some
inspection requirements may be accomplished through other inspections. The expectation is
that the regions should normally complete the nominal (average) number of inspection samples
identified in the inspection procedure. The regions may vary the inspection samples within the
ranges as indicated in each baseline inspection procedure, based on the licensee performance
and inspector insights. For the purposes of completing the baseline inspection program, the
number of samples completed must be within the range of values specified in each inspection
procedure.

Similar changes were made to the inspection hours in order to maintain the relationship
between the level of inspection resources necessary to complete the inspection activities and
the range of inspection samples which could be accomplished with each inspection procedure
constant.

The program is indicative and not diagnostic. The baseline program delineates specific
inspection activities to evaluate aspects of licensee programs and processes and their
implementation by identifying findings that are indicative of licensee performance problems.
Inspection findings from the baseline program are evaluated for significance and used, along
with PIs, to assess licensee performance within the cornerstones of safety. The baseline
inspections are not diagnostic assessments of licensee performance leading to a root cause
determination. Those assessments and root cause determinations are intended to be reviewed
or independently made during supplemental inspections that are outside the scope of the
baseline inspection program.

The safety performance of nuclear power plants is assessed based on performance in each
cornerstone of safety. Verifying that a licensee meets the objectives of the cornerstones
provides reasonable assurance that public health and safety are protected. The inspectable
areas verify aspects of the key attributes for each of the associated cornerstones. The
cornerstones to which each inspectable area is applicable and their link to the attributes they
are measuring are depicted in table 1 of this attachment and exhibits 3 through 11 of IMC 0308.
Therefore, the baseline inspection program requires that most inspectable areas be reviewed at
each nuclear power plant each year. Several inspectable areas are reviewed at longer
frequencies.

All the important aspects of a cornerstone area are inspected where a PI has not been
established (e.g., design). In cornerstone areas where the PIs provide only limited indication of
performance, the inspectable areas provide indication of the aspects not measured (e.g.,
operator performance during an event). If performance of the cornerstone objective in a
cornerstone area is sufficiently measured by a PI, the inspection effort in the baseline program
only verifies that the PI is providing the intended data.

Exhibits 1 through 34 describe the scope of each inspectable area and explain the basis for why
each inspectable area is included in the baseline program. Reasons for inclusion in the program
may be that: (1) the area is linked to the NRC’s mission, (2) the inspectable area involves a key
attribute to a cornerstone of safety, and (3) risk information justifies including the area in the
baseline inspection program. These inspectable area basis summary sheets discuss the basis
for each inspectable area and include risk insights (from generic risk analyses and studies),
analyses of significant precursor events, and the risk-informed judgment of an expert panel of
inspectors and risk analysts. The summary sheet for each inspectable area also identifies
whether a PI applies to the area and what inspections may be needed in addition to the
information provided by the PIs in the area. The baseline inspection procedures are written to

Issue Date: 10/31/23 3 0308 Att 2

focus on the more risk-significant aspects of the inspectable areas as discussed in the summary
sheets, aspects that directly support the desired results and promote the important attributes of
the cornerstones of safety. The scope of any associated PIs is summarized in the inspectable
area portions of the baseline inspection procedures.

The exhibits related to the physical protection inspection procedures were removed because of
the Commission’s decision that certain security information will no longer be publicly available.

In addition to the inspectable areas identified for many of the key attributes of each cornerstone
of safety, the baseline inspection program also consists of inspection activities devoted to: (1) PI
verification, (2) problem identification and resolution, (3) event follow-up, and (4) plant status. As
discussed below, Exhibit 36 through 44 describe the scope and basis for these inspection
activities and other inspection program policies and practices (e.g., IMC 2515).

03.01 PI Verification

The monitoring of plant performance primarily relies on information provided by PIs and
inspection findings in areas not measured, or not adequately measured, by PIs. The
baseline inspection program will also selectively collect and review licensee
plant-specific raw data on a periodic basis to independently verify the accuracy and
completeness of the PI data.

Each PI is verified annually. The annual verification compares the reported PI data to
samples of raw data available (e.g., operating logs, corrective action program records,
maintenance records). Some PIs can be verified in conjunction with other baseline
inspections if the PI is difficult to accurately verify from plant records. The PI verification
inspection also reviews corrective action program records to determine if any problems
the licensee may have had in collecting PI data were adequately resolved and updates
provided to the NRC.

If a PI is found to be invalid based on inaccurate or incomplete data, then the associated

cornerstone may not be adequately evaluated, and additional inspections within the
areas measured by the PI are scheduled. The baseline inspection program also provides
guidance for NRC actions in response to incomplete or unreported PIs.

Exhibits 36 and 37 describe the scope and basis for: (1) the NRC response to discrepant
or unreported PI data, and (2) PI verification inspection activities, respectively.

03.02 Problem Identification and Resolution

Inspection of licensee problem identification and resolution (PI&R) programs has been a
key component of the ROP since the inception of the program. The PI&R
Comprehensive Review Attachment 4, “Problem Identification and Resolution Basis and
History,” (ML20247J599) is an in-depth history of the procedure and its basis.

One of the primary means by which licensees maintain an appropriate level of safety is
through an effective PI&R program to correct deficiencies involving human performance,
equipment, programs, and procedures. The NRC’s confidence in the effectiveness of
these programs is the basis for the NRC’s policy of closing lower-level violations when
they are entered into the licensee’s corrective action program without independently
verifying the final corrective actions, which in turn is a basis for implementation of the
ROP. Section 2.3.2 of the Enforcement Policy describes the NRC policy for

Issue Date: 10/31/23 4 0308 Att 2

 dispositioning most violations associated with green findings as NCVs for licensees that
have “implemented a corrective action program that is determined to be adequate by the
NRC.” That policy states that “[t]he NRC will credit a formal corrective action program
that has been inspected and found to meet regulatory guidance, industry standards, or
both.” The inspection program verifies that our confidence in licensees’ programs is still
deserved and periodically verifies the final actions on some of the lower-level violations
are proper.

The process for evaluating PI&R consists of a performance-based review of the

licensees’ deficiency reporting process, self-assessments, quality assurance audits,
causal analyses of events, and corrective actions. The review of corrective actions
includes following them up to validate their effective implementation. The NRC reviews
the licensee’s activities in this area to verify that: (1) the scope of licensees’ identification
and resolution programs bounds the key attributes in the cornerstones; (2) causes of
problems and issues have been properly determined and corrective actions are timely
and effective; and (3) the generic implication or extent of condition has been
appropriately considered. Issues identified regarding the licensee’s implementation of its
corrective action program are assessed for risk significance using the Significance
Determination Process (SDP).

The NRC program to review activities in this area has four parts. The first part is
conducted during inspection of the associated inspectable areas within each
cornerstone. The second part is a semiannual trend review. The third part is a sample of
issues that are selected annually for more in-depth review. The fourth part is a biennial
review of the licensee’s PI&R programs. The biennial review complements the reviews
done throughout the year. The results of the biennial review are then integrated with the
PI&R insights gained via the other inspections.

NRC inspectors use licensees’ self-assessments to help direct these baseline

inspections into worthwhile areas. However, licensees’ self-assessments will not be
used to reduce or replace baseline inspections. Exhibit 38 provides additional
information on the scope and basis for PI&R inspections.

A determination that the NRC no longer has confidence in the licensee’s PI&R program
implies it is incapable of participation in the ROP because section 2.3.2.a of the
Enforcement Policy no longer applies. This determination should be coincident with
entrance into Column 5 of the Action Matrix or the IMC 0350 Process, an Action Matrix
deviation, or other appropriate oversight mechanisms. IMCs 0305 and 0350 provide
governance for these processes. A determination of that level can only be reached by
regional management in consultation with the NRR Officer Director and may require
approval by the Executive Director for Operations.

03.03 Event Follow-up

The NRC normally follows up plant events in three ways: (1) events of low safety
significance receive minimal follow up, usually by the resident inspectors, (2) events of
moderate safety significance receive more follow up, often by one or two regional
inspectors, and (3) events of greater safety significance are followed up by a special
team. The baseline program is designed to initially screen all operational events and
licensee event reports and to follow up only some of the more routine, noncomplex
events. The baseline program includes a procedure for event follow-up to be used in
conjunction with inspections in the various inspectable areas. Whether to follow up other

Issue Date: 10/31/23 5 0308 Att 2

 events with regional discretionary resources would depend on the significance of the
event as determined by the baseline inspection program.

Events of low safety significance, such as uncomplicated reactor trips, are reviewed by
resident or region-based inspectors to verify that the events are not complicated by
conditions such as loss of mitigation equipment or operator errors. The baseline
inspection program’s event follow-up procedure focuses the inspector’s initial evaluation
of events on communicating details regarding the event to risk analysts for their use in
determining risk significance. Inspectors will identify equipment malfunctions and
unavailability, operator errors, and other complications.

The follow-up of more extensive, nonroutine events is outside of the scope of the
baseline inspection program and would be performed with reactive inspection resources.
The decision to follow up such events would be made on a case-by-case basis by NRC
regional management and as directed by senior NRC management in accordance with
NRC Management Directive (MD) 8.3, "NRC Incident Investigation Program." Significant
operational events (defined in MD 8.3) are followed up by a graded response consisting
of inspections such as those conducted by Incident Investigation Teams (IITs) and
Augmented Inspection Teams (AITs), and Special Inspections (SIs). Follow-up of these
events is discussed in more detail later in this attachment.

Exhibit 39 provides additional information on the scope and basis of event follow-up
activities performed as part of the baseline inspection program.

03.04 Plant Status

The primary objective of the plant status activities is to ensure that the inspectors are
aware of current plant conditions and equipment problems and have a level of
understanding of the risk significance of proposed or ongoing operations, maintenance,
and testing by the licensee. Plant status focuses on identifying and understanding
emergent plant issues, current equipment problems, and ongoing activities and their
overall impact on plant risk. These activities also provide an independent assessment of
the licensee’s effectiveness in entering program, system, and component deficiencies
into the corrective action program.

The plant status portion of the inspection program is important because it will be used by
the inspectors in the risk-informed process to select inspection samples and to modify
the scope and depth of inspections in other inspectable areas that support assessment
of all cornerstone areas. This awareness of plant conditions, emerging problems or
work, and activities planned by the licensee is used by the inspectors in determining
which inspection procedures to use and the specific samples for inspections within the
inspectable areas of the baseline inspection program. Therefore, since plant status is
conducted in part to prepare for other baseline inspection activities, this effort is not
considered part of the direct inspection effort under the baseline program.

Exhibit 44 provides additional detail regarding the scope and basis of the plant status
activities performed under the baseline inspection program.

Issue Date: 10/31/23 6 0308 Att 2

0308.2-04 SUPPLEMENTAL INSPECTION PROGRAM

The supplemental element of the inspection program was designed to apply NRC inspection
resources in a graded manner when risk significant performance issues are identified, either by
inspection findings evaluated using the SDP or when PI thresholds are exceeded. Depending
on the risk significance and breadth of the identified performance issues, the supplemental
inspections provide a range of activities including: oversight of the licensee’s root cause
evaluation of the issues; expansion of the baseline inspection sample or a focused team
inspection (as necessary to evaluate extent of condition); or a broad scope multi-disciplined
team inspection which would include inspection of multiple cornerstone areas and inspection of
cross-cutting issues. Any new performance issues identified during the supplemental
inspections are evaluated by the SDP, and new findings issued. The need for additional NRC
actions, including additional supplemental inspections, are governed by the assessment
program Action Matrix.

At the lowest level, the intent of supplemental IP 95001, “Supplemental Inspection Response to
Action Matrix Column 2 (Regulatory Response) Inputs,” is to review and selectively challenge
aspects of the licensee’s root cause evaluation, but not to perform an independent assessment
of the performance issue. However, the identification by the NRC of significant issues pertaining
to the adequacy of the licensee’s root cause evaluation may result in the expansion of the
procedure as necessary to independently complete the inspection requirements. Also, the
original performance issue will not be removed from consideration of actions in the Action Matrix
until satisfaction of all supplemental inspection objectives.

The objective of supplemental IP 95002, “Supplemental Inspection Response to Action Matrix

Column 3 (Degraded Performance) Inputs,” is not only to review and selectively challenge
aspects of the licensee’s root cause evaluation, but to also independently assess the extent of
condition for the individual and collective risk significant performance issues that warranted this
supplemental inspection.

In general, all inspection requirements contained in these two procedures are intended to be
addressed for each issue; however, the extent that they are reviewed and their specific
applicability to the given issue will necessarily vary. The staff determined that this level of
flexibility was necessary given the various issues that potentially could lead to supplemental
inspections.

Also, these two supplemental inspections are intended to provide the information the NRC
needs in order to assess safety. The NRC can acquire this information by performing
independent inspections or can acquire the information by reviewing the licensee’s efforts to
assess the root cause of the issue. If the licensee chooses not to provide some of the
information needed to satisfy the inspection requirements, the NRC always has the option of
acquiring this information by independent inspection.

At the highest level, supplemental IP 95003, “Supplemental Inspection Response to Action

Matrix Column 4 (Multiple/Repetitive Degraded Cornerstone) Inputs,” is intended to determine
the breadth and depth of safety, organizational, and programmatic issues. This supplemental
procedure is more diagnostic than indicative and includes reviews of programs and processes
not inspected as part of the baseline inspection program. While the procedure does allow for
focus to be applied to areas where performance issues have been previously identified, the
procedure requires that some sample reviews be performed for all key attributes of the effected
strategic performance areas. The rationale behind this is that additional NRC assurance is
required to ensure public health and safety, beyond that provided by the baseline inspection

Issue Date: 10/31/23 7 0308 Att 2

program and the PIs at those facilities where significant performance issues have been
identified. The results of this inspection will aid the NRC in deciding whether additional
regulatory actions are necessary to assure public health and safety. These additional regulatory
actions could include orders, confirmatory action letters, or additional supplemental inspections,
as necessary to confirm that corrective actions to the identified performance concerns have
been effective.

Exhibits 46 through 48 provide additional information on the scope and basis for each of the
supplemental inspection procedures.

0308.2-05 EVENT RESPONSE

Management Directive 8.3 provides the criteria for NRC investigatory response to significant
operational events involving reactor and non-reactor facilities licensed by the NRC. The criteria
define several levels of response, including an IIT and AIT. IITs inspect events having greater
health and safety significance than events inspected by AITs.

As part of the development of the new reactor oversight process (ROP), MD 8.3 was revised to
risk-inform the deterministic criteria for event response at reactor facilities. The previous
deterministic criteria for IITs and AITs is now evaluated in conjunction with risk in order to
identify a graded response, based in part on the risk metric. The graded response will consist of
an IIT, AIT, and Special Inspection for the lowest level of response. The risk metric of
conditional core damage probability (CCDP) is used to best reflect the full extent of any loss of
defense-in-depth due to the event, regardless of whether the cause is due to licensee
performance or otherwise. Numerical risk estimation by itself is not meaningful unless
accompanied by an understanding of the most influential related assumptions and uncertainties.

One comment received during ROP development was that the risk evaluation to support a
prompt NRC determination of the level of response will be hampered by lack of information in
the early stages of the event. In addition, information from the NRC event response inspection
may significantly revise the risk value and thereby require a different level of NRC response.
This problem stresses the need to use deterministic criteria in conjunction with risk insights. In
addition, the program has the flexibility to revise the level of response based on new information
and changing risk levels.

Exhibit 49 provides additional information regarding the scope and basis for the Special
Inspection level of event response.

0308.2-06 OVERSIGHT OF PLANTS IN EXTENDED SHUTDOWN

During the development of the new ROP, the staff also significantly revised its process for
overseeing plants in an extended shutdown for performance problems. This process was
risk-informed through new criteria that better focuses agency attention on those safety
significant issues that contributed to the shutdown. These changes also made the process more
objective by using the Action Matrix and SDP to establish criteria and thresholds for actions.
The new guidance for plants in extended shutdowns for performance problems was
incorporated into a revision to IMC 0350, “Staff Guidelines for the Assessment and Review of
Plants that Are Not Under the Routine Reactor Oversight Process.” The title for IMC 0350 was
later changed to “Oversight of Operating Reactor Facilities in a Shutdown Condition Due to
Significant Performance and/or Operational Concerns.”

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The three major aspects of the IMC 0350 process are: (1) the criteria for placing a plant into the
process, (2) the scope of issues for the IMC 0350 required restart panel, and (3) the criteria for
removing a plant from this process and placing it back into the routine ROP. The thresholds for
placing a plant into the IMC 0350 process have been risk-informed and made more objective by
using the assessment program Action Matrix. Consideration is given for placing a plant in the
IMC 0350 process when a licensee’s performance is determined to be in the Multiple/Repetitive
Degraded Cornerstone column of the Action Matrix, and the plant is expected to be shut down
for at least 3 months.

The second area of the IMC 0350 process is the criteria used to determine what issues need to
be resolved before restarting a plant. The scope of issues to be considered prior to restart has
been risk informed by using the SDP. The issue(s) that have to be resolved before a plant
restarts, and would be within the restart panel’s scope, should have risk significance (i.e., White,
Yellow, or Red), but the issue(s) would not be limited to any specific performance area.

The third area of the IMC 0350 process is the criteria for returning a plant to the routine ROP.
These criteria also have been risk-informed by using the Action Matrix. The approval for exiting
the process and returning a plant to the routine ROP is based on the licensee satisfactorily
resolving all performance issues with low to moderate or greater risk significance (i.e., White,
Yellow, or Red), and has operated the plant for approximately four calendar quarters while
accumulating PI data needed for the routine assessment process.

After a year of implementation under the ROP, and from the experience gained with one
licensee that was under the IMC 0350 process, the staff revised the process to clarify the
conditions for entering the process, as well as clarifying the responsibilities of designated
positions, while encouraging the continued collection of PIs, if they remain valid. In
December 2003, IMC 0350 was revised to provide a comprehensive correlation between
aspects of the ROP and the IMC 0350 process, to provide an enhanced structure to the
inspection approach for IMC 0350 plants, and to incorporate other lessons learned and
clarifications. Additional detail on the scope and basis for the IMC 0350 process can be found in
exhibit 50.

0308.2-07 THRESHOLD FOR DOCUMENTING FINDINGS AND INSIGHTS

The ROP uses PIs and inspection findings evaluated for risk in determining a plant’s
performance in meeting the objectives of the seven cornerstones, and in determining agency
actions. Therefore, the format for inspection reports for the baseline inspection program was
developed to document only those issues that meet a minimum threshold for safety importance.
This change removed from the reports much of the discussion regarding inspector observations
of licensee activities (both positive and negative), minor findings and minor violations identified
by the inspector, and licensee identified findings of very low significance that would not be used
in objectively assessing performance.

Stakeholder feedback during the pilot program indicated that many inspectors and regional
managers were uncomfortable with removing from inspection reports these “insights” into
licensees’ performance. The inspectors and regional managers feel they need these
observations (i.e., issues that may have very little or no risk significance individually) to better
assess cross-cutting areas, such as problem identification and resolution and human
performance. Some licensees also expressed their concern with no longer having these insights
and observations from NRC inspectors. Therefore, the guidance for inspection reports was

Issue Date: 10/31/23 9 0308 Att 2

changed to allow inspectors to document observations in conjunction with and to support a
finding.

The assessment program was developed to use objective and repeatable indications of
problems to assist the NRC in assessing licensee performance and to determine the
appropriate level of NRC’s response. Positive findings, which generally are subjective and
usually have no measurable basis in regulation or safety, were not included in the assessment
process. Therefore, it was decided that they should not be documented in inspection reports.
Stakeholder comment was solicited during the development and pilot program for the ROP to
determine whether positive inspection findings should be captured and incorporated into the
oversight process.

The consensus was that the NRC does not have objective criteria for evaluating positive
findings. Therefore, because the assessment process does not explicitly incorporate positive
findings, they should not be documented in inspection reports. However, positive aspects of
licensee operations will be reflected in those items for which the SDP credits mitigation
capabilities, and those positive aspects will be recorded in inspection reports as assumptions
used in characterizing inspection findings.

Although not documented and used in the assessment process, inspection observations (both
positive and negative) and minor violations should be verbally communicated to the licensee in
routine interactions by the inspectors during the inspection. It was also considered to be more
appropriate for licensees to communicate positive aspects of their operations to the public.

0308.2-08 OTHER INSPECTION PROGRAM ASPECTS CONSIDERED BUT NOT

INCLUDED

While developing the baseline inspection program, several additional inspectable areas were
considered, but not included in the program. These other inspectable areas were not included
for several reasons, such as adequate coverage of the area by an existing PI, adequate
coverage by another inspectable area, or having low safety significance relative to the other
inspectable areas in the program. Some of these additional inspectable areas that were
considered, and the basis for not including them in the baseline inspection program, are listed in
table 2 of this attachment. In addition to inspectable areas, table 2 also includes other inspection
program attributes that were considered but not included.

Issue Date: 10/31/23 10 0308 Att 2

 BASIS SUMMARY SHEETS

Issue Date: 10/31/23 11 0308 Att 2

 Exhibit 1: Adverse Weather Protection (IP 71111.01)

Basis Summary Sheet

Inspectable Area: Adverse Weather Protection

Cornerstone(s): Initiating Events and Inspection Procedure: IP 71111.01

Mitigating Systems

Scope: Inspection activities in this area focus on evaluating the licensee’s readiness for
protecting mitigating systems and components from external factors such as tornado,
hurricane, high winds, high temperatures, cold weather, and other adverse weather-related
conditions. This inspection focus ensures that risk significant systems and components will
perform within the design assumptions for adverse weather.

Basis: Inspection of this item supports the Initiating Events and Mitigating Systems
cornerstones by ensuring that the licensee takes steps to reduce the effects of
weather-related initiating events and the impact of adverse weather on key portions of
mitigating systems. Weather conditions leading to loss of offsite power, freezing
temperatures, high temperatures, and high winds dominate external risk.

The inspection activities are intended to verify that the licensee has taken the necessary
steps to demonstrate that the reliability, availability, and functional capability of SSCs and
associated components are maintained during adverse weather conditions. For example,
operating experience indicates that cold weather conditions continue to cause intake
structure icing, process and instrument line freezing, emergency diesel generator oil viscosity
problems, essential chiller problems, and electrical problems leading to loss of power. High
winds, tornado, and hurricane could affect the availability of offsite power.

Frozen equipment can lead to a common cause/mode loss of multiple trains and loss of
equipment in redundant systems without any indication of a problem until called upon to
function, which would have a significant impact on plant risk. In addition, high temperature
conditions can place plant equipment and systems in an unanalyzed condition, which could
also have a significant impact on risk.

Performance Indicators: There are no performance indicators that have been established that
can provide information related to the adequacy of licensee’s readiness for seasonal
susceptibilities and for any impending adverse weather conditions.

Significant Changes in Scope or Basis: December 2001 - Revised procedure to provide

additional clarification to the inspection requirements and guidance for evaluating licensee’s
readiness for seasonal susceptibilities and impending weather conditions.

January 2002 - Revised to provide detailed inspection requirements and guidance for
evaluating licensee’s readiness for seasonal susceptibilities and impending weather
conditions. In addition, the inspection resources estimate is revised to provide a band for
more inspection flexibility.

Issue Date: 10/31/23 12 0308 Att 2

 January 2008 – Procedure was expanded to include a review of a site’s readiness to cope
with external flooding prior to the onset of adverse weather that poses a risk of flooding. Prior
to this change, review of external flooding readiness was located in IP 71111.06.

January 2016 - Revised to incorporate Fukushima Lessons Learned and Fukushima flooding
inspection insights as well as an inspection requirement to verify licensees can demonstrate
that diesel fuel oil cloud point specifications are acceptable for operability of diesel generator
systems with above ground fuel storage tanks during extreme cold weather conditions.

Issue Date: 10/31/23 13 0308 Att 2

 Exhibit 2: Reserved (IP 71111.02)

Basis Summary Sheet

Inspectable Area: Reserved

Cornerstone(s): Inspection Procedure: IP 71111.02

Scope:

Basis:

Performance Indicators:

Significant Changes in Scope or Basis:

Issue Date: 10/31/23 14 0308 Att 2

 Exhibit 3: Reserved (IP 71111.03)

Basis Summary Sheet

Inspectable Area: Reserved

Cornerstone(s): Inspection Procedure: IP 71111.03

Scope:
Basis:

Performance Indicators:

Significant Changes in Scope or Basis:

Issue Date: 10/31/23 15 0308 Att 2

 Exhibit 4: Equipment Alignment (IP 71111.04)

Basis Summary Sheet

Inspectable Area: Equipment Alignment

Cornerstone(s): Initiating Events, Mitigating Inspection Procedure: IP71111.04

Systems, and Barrier Integrity

Scope: To verify equipment alignment and identify any discrepancies that impact the
function(s) of the system and, therefore, potentially increase risk. This includes conducting
approximately three partial walkdown inspections each calendar quarter to verify the
operability of a redundant or backup system/train or a remaining operable system/train with
the highest risk significance for the current plant configuration (considering out-of-service,
inoperable, or degraded equipment); or a risk-significant system/train that was recently
realigned following an extended system outage, maintenance, modification, or testing; or a
risk-significant single-train system. In addition, inspectors will perform one complete
walkdown every 6 months to support only the Mitigating Systems cornerstone. This
inspection activity will be performed during both shutdown and operating conditions.

Basis: Inspection of this area supports the Initiating Events, Mitigating Systems and Barrier
Integrity cornerstones.

The inspection activities are intended to verify that the licensee has an effective process for
maintaining system configuration control, which ensures that the functional capability of the
plant system is maintained. Systems or components that are not properly aligned can lead to
the initiation of an event and can impact the availability and functional capability of plant
equipment, thereby significantly increasing the overall risk to the plant. Inspection activities
would normally be performed following emergent work activities, planned removal of
risk-significant systems for online maintenance, and during outage related activities.

Performance Indicators: Unavailability and safety system functional failure performance

indicators have been identified. Due to the monitoring of a limited number of systems, this
inspection supplements those PIs. Also, there is no similar PI for equipment lineup during
shutdown conditions, requiring this baseline inspection.

Significant Changes in Scope or Basis:

None

Issue Date: 10/31/23 16 0308 Att 2

 Exhibit 5: Fire Protection (IP 71111.05)

Basis Summary Sheet

Inspectable Area: Fire Protection

Cornerstone(s): Initiating Events and Inspection Procedure: IP 71111.05

Mitigating Systems

Scope: The inspection is conducted in three phases. Phase one consists of the routine
inspection conducted by the resident inspectors and it incorporates a quarterly assessment of
conditions related to ignition sources, control of combustible materials, and fire protection
systems and equipment. Phase two, also conducted by the resident inspectors includes the
assessment of fire brigade staffing, training, and performance. Phase three is the triennial
team inspection to conduct a design based risk-informed inspection that includes the
defense-in-depth elements of the fire protection installed to mitigate the consequences of a
fire. The team assesses the capability of equipment necessary for plant shutdown following a
fire.

Basis: Inspection of this item supports the Initiating Events and Mitigating Systems
cornerstones.

The inspection reviews licensee controls designed to minimize the probability of a fire and the
availability and reliability of equipment necessary to mitigate the effects of a fire.

Proper implementation of the fire protection program is important to provide defense-in-depth

against fires by maximizing prevention, detection, suppression, and mitigation capabilities for
fires. An effective program reduces the risk of a fire being an initiating event. Also, in the
event of a fire, reliable detection, suppression, and mitigation capabilities ensure the plant
can be safely shut down. Plant specific evaluations have shown internal fires to be high
contributors to risk at some plants due to the potential for damaging redundant systems and
multiple control circuits and due to the adverse effect on operator mitigation strategies.

Performance Indicators: There are no performance indicators that assess performance in the
area of fire protection.

Significant Changes in Scope or Basis:

March 2001 - The scope of the procedure was reduced while criteria for review of fire-induced
circuit failures of associated circuits is the subject of a voluntary industry initiative. Per this
temporary revision, the inspector is not required to address associated circuits issues as a
direct line of inquiry nor develop associated circuits inspection findings (with certain
exceptions contained in section 02.03 of the procedure). However, in certain instances
associated circuits issues may arise unavoidably and indirectly during the inspector’s review
of safe shutdown system selection, redundant train separation, and the provision of
independent alternative shutdown capabilities ("byproduct" associated circuits issues). This
byproduct associated circuits issues shall be documented as unresolved items awaiting
generic resolution of the related associated circuits issues.

Issue Date: 10/31/23 17 0308 Att 2

 March 2003 - Revised to provide inspection guidance to evaluate licensee manual actions
which have been incorporated into the procedure as enclosure 2.

September 2004 – separated the Triennial Fire Protection Inspection Procedure (71111.05T)
from the Quarterly and Annual Inspection Procedure (71111.05QA). There are no substantial
changes to the Quarterly and Annual inspection procedure.

January 2005 – Reinstated the inspection of circuits, with enforcement discretion for
escalated findings extended through 2005.

June 2005 – Reissued 71111.05AQ inspection procedure with new guidance to assess fire
brigade performance.

August 2018 – Reissued 71111.05AQ as 71111.05, quarterly walkdown requirements made

annual.

June 2019 – Retired 71111.05T, replaced with 71111.21N.05, under the Engineering
Inspections Program. That IP retains the Fire Protection inspection objectives of the original
triennial inspection procedure. Other objectives under 71111.05 remain.

Issue Date: 10/31/23 18 0308 Att 2

 Exhibit 6: Flood Protection Measures (IP 71111.06)

Basis Summary Sheet

Inspectable Area: Flood Protection Measures

Cornerstone(s): Initiating Events and Inspection Procedure: IP 71111.06

Mitigating Systems

Scope: Inspection activities in this area focus on licensee’s readiness to protect the plant from
potential internal and external flooding. These inspection activities would include walkdown
verification of key plant areas to verify flood protection features, review of procedures
including verification of key operator actions credited for coping with flood, and evaluation of
compensatory measures during impending conditions of flooding or heavy rains. The
inspection will also focus on verifying that the licensee’s flooding mitigation plans and
equipment are consistent with the licensee’s design requirements and the risk analysis
assumptions, and equipment is routinely tested and remains fully capable to perform the
intended functions.

Basis: This activity would be an input to the Initiating Events and Mitigating Systems
cornerstones.

Verification of the licensee’s implementation of the flood control program would be performed
to ensure that the facility is capable of withstanding potential internal and external flooding.
Flooding would have a significant adverse effect on the functional capability of safety- and
risk-related equipment needed to maintain the plant in a safe shutdown condition.

Flooding due to external and internal causes has been shown to be a significant contributor to
risk at some facilities. In addition, flooding has the potential to make multiple trains of
equipment and support equipment inoperable which would result in a significant increase in
risk to the plant. Flooding also has a significant consequence of preventing or limiting
operator mitigation and recovery actions.

Performance Indicators: There are no performance indicators that have been established that
can provide results related to the adequacy of the licensee’s program for mitigating the
consequences for flooding. Due to the rare but possibly risk significant nature of flooding
events, no performance indicator was judged to be suitable for monitoring licensee
performance in this area.

Significant Changes in Scope or Basis:

None

Issue Date: 10/31/23 19 0308 Att 2

 Exhibit 7: Heat Exchanger/Sink Performance (IP 71111.07)

Basis Summary Sheet

Inspectable Area: Heat Exchanger/Sink Performance

Cornerstone(s): Initiating Events and Inspection Procedure: IP 71111.07
Mitigating Systems
Scope: To verify that any potential heat exchanger deficiencies which could mask degraded
performance or common cause heat sink performance problems that have the potential to
increase risk are identified. Applies to all heat exchangers connected to safety-related service
water systems.

To verify that the licensee has adequately identified and resolved heat exchanger/sink
performance problems that could result in initiating events or affect multiple heat exchangers
in mitigating systems and thereby increase risk.

Basis: Inspection in this area supports the Initiating Events and Mitigating Systems
cornerstones by ensuring initiating events are not caused by a loss of heat sink and that
mitigating systems heat removal capabilities are not degraded.

Heat exchangers and heat sinks are required to remove decay heat and provide cooling
water for operating equipment. Degradation in performance can result in failure to meet
system success criteria, and lead to increased risk primarily due to common cause failures.
This inspectable area verifies aspects of the associated cornerstones for which there are no
indicators to measure performance.

The inspection focuses on events that could result in the simultaneous loss of both the
normal and ultimate heat sinks due to events such as ice buildup, grass intrusion or blockage
of pipes and components by other foreign materials, and verifying the heat transfer
capabilities of risk significant heat exchangers by observing performance testing, reviewing
the results of those same tests, inspection/cleaning, or by monitoring licensee’s bio-fouling
controls.

Also, industry experience has shown that many plants have experienced significant problems
with repeated loss of heat sink and degraded performance of heat exchangers due to
problems that include corrosion, silting and fouling. Since the subject heat exchangers do not
normally operate at design heat loads, it is important for the licensee to routinely monitor the
performance of the heat exchangers to ensure that the heat exchangers are capable of
meeting their design requirements.

Performance Indicators: None of the established PIs cover this area.

Significant Changes in Scope or Basis:

April 2000 - The inspection scope and basis were revised to address the following: (1) The
procedure not only addresses heat sinks but also heat exchangers and the different bases for
measuring their respective performances; (2) Heat exchanger heat transfer capabilities can
be measured not only by observing performance tests, but by reviewing those same tests,
inspection/cleaning, or by monitoring licensee’s bio-fouling controls; (3) Methods of
measuring the performance of heat sinks and their subcomponents like piping, valves, and
pumps within the cooling medium servicing the ultimate heat sink were included in the

Issue Date: 10/31/23 20 0308 Att 2

 procedure; and (4) Methods of measuring the performance of heat exchangers based on their
design basis and design data sheets were included in procedure for all risk significant heat
exchangers including those in closed-cooling systems.

Issue Date: 10/31/23 21 0308 Att 2

 Exhibit 8: Inservice Inspection Activities (IP 71111.08)

Basis Summary Sheet

Inspectable Area: Inservice Inspection Activities
Cornerstone(s): Initiating Events and Barrier Inspection Procedure: IP 71111.08
Integrity
Scope: Inspection activities in the area would focus on the effectiveness of the licensee’s
program for inservice inspection (ISI), repair, replacement of reactor coolant system (RCS)
pressure retaining components, and monitoring of licensee’s program for verifying the
integrity of steam generator (SG) tubes. Inspection activities would include a review of the
results of the SG tube inspections for in situ pressure testing, identification of new
degradation mechanisms for SG tubes, confirmation that the licensee has taken appropriate
actions for SG tube leakage, repairs, and any foreign material identified in them, selected
review of risk significant non-code repairs, and a review or observation of the reactor vessel
ISI examinations.

Basis: Inspection activities in this area primarily support the Barrier Integrity cornerstone.
Activities also support the Initiating Events cornerstone because ISI activities can detect
precursors to RCS boundary failures.

The inspection activities are intended to ensure that the licensee has an effective program for
monitoring degradation of reactor coolant system boundary, including steam generator tubes,
control of non-code repairs to ASME components, and performing the required periodic ISI
examinations.

Degradation of the RCS, SG tubes, or safety-related support systems would result in a

significant increase in risk. Degraded piping or tubes would increase the risk impact due to
initiation of events. In addition, it would result in mitigating systems not being capable of
performing their intended design functions. Based on these considerations, inspection
activities are necessary to ensure that the licensee has an effective ISI program to ensure
that risk significant degradation of the RCS boundary is identified and is promptly and
appropriately corrected.

Performance Indicators: There are no performance indicators that have been established that
can provide results related to the adequacy of the licensee’s program for ensuring system
integrity in accordance with ASME requirements.

Issue Date: 10/31/23 22 0308 Att 2

 Significant Changes in Scope or Basis:

October 2001 - The procedure was revised to emphasize the inspector review of the
licensee’s total program for ensuring the integrity of SG tubes so as to provide clear indication
of impending problems before they could actually develop. The inspector no longer verifies
the results of eddy current testing just to ensure that scope and expansion criteria meet
technical specifications. Significant aspects of in situ pressure testing are reviewed along with
whether licensee has identified new degradation mechanisms for SG tubes. The inspector
also confirms that the licensee has appropriately addressed repairs, leakage, and foreign
material, and refers any serious questions on eddy current testing to NRC staff with the
requisite experience.

January 2004 - The procedure has been revised to add periodic inspection requirements and
guidance for PWR vessel head penetrations and boric acid corrosion control, and to make
other minor clarifications. In addition, the resource estimate for PWR inspection has been
increased.

Issue Date: 10/31/23 23 0308 Att 2

 Exhibit 9: Reserved (IP 71111.09)

Basis Summary Sheet

Inspectable Area: Reserved

Cornerstone(s): Inspection Procedure: IP 71111.09

Scope:

Basis:

Performance Indicators:

Significant Changes in Scope or Basis:

Issue Date: 10/31/23 24 0308 Att 2

 Exhibit 10: Reserved (IP 71111.10)

Basis Summary Sheet

Inspectable Area: Reserved

Cornerstone(s): Inspection Procedure: IP 71111.10

Scope:

Basis:

Performance Indicators:

Significant Changes in Scope or Basis:

Issue Date: 10/31/23 25 0308 Att 2

 Exhibit 11: Licensed Operator Requalification Program and
Licensed Operator Performance (IP 71111.11)

Basis Summary Sheet

Inspectable Area: Licensed Operator Requalification Program and Licensed Operator

Performance
Cornerstone(s): Mitigating Systems, Barrier Inspection Procedure: IP 71111.11
Integrity, and Emergency Preparedness

Scope: Inspection activities in this area would focus on the effectiveness of the licensee’s
program for conducting operator requalification training. Inspection activities would include a
review of requalification examinations, the remedial training program, the training feedback
system, and programs for ensuring medical fitness of licensed operators. In addition,
inspection activities also verify that the facility’s operating history has been factored into the
requalification program and verifies conformance with operator license conditions.

Basis: Inspection of this area supports the Mitigating Systems, Barrier Integrity, and
Emergency Preparedness cornerstones because it can assess operator performance
adequacy in responding to events.

This inspection evaluates operator performance in mitigating the consequences of events.

Poor operator performance results in increased risk due to its impact on the human factors
terms, assumed operator recovery rates and personnel induced common cause error rates
assumed in the facility Individual Plant Evaluations (IPE). Human performance errors and
failure to recover from accident events are the most risk important events at a facility.

The inspection interval was established at a biennial frequency to allow for more
comprehensive inspections of licensee requalification program cycles that approached
24 months in duration.

Performance Indicators: There are no performance indicators that have been established that
can provide results related to the adequacy of the licensee’s licensed operator requalification
program.

Issue Date: 10/31/23 26 0308 Att 2

 Significant Changes in Scope or Basis:

March 2001 - Added additional guidance to allow the conduct of this inspection in separate
parts during the biennial inspection cycle. This was done to provide additional scheduling
flexibility to allow the regions to observe portions of the licensed operator requalification
program that occur at different times, such as the annual written exams.

August 2002 - Revised to reflect the amended 10 CFR Part 55, "Operators' Licenses,"
regarding operator license eligibility and the use of simulation facilities in operator licensing
(66 FRN 52657, dated October 17, 2001). This revision provides specific guidance to
inspector when assessing conformance with simulator requirements specified in 10 CFR
55.46.

December 2003 - Revised to include an additional section that inspects excessive test item
repetition among comprehensive requalification exams that are taken by crews undergoing
the same training program cycle. Excessive item repetition adversely affects validity of the
exam.

Issue Date: 10/31/23 27 0308 Att 2

 Exhibit 12: Maintenance Effectiveness (IP 71111.12)

Basis Summary Sheet

Inspectable Area: Maintenance Effectiveness

Cornerstone(s): Initiating Events, Mitigating Inspection Procedure: IP 71111.12

Systems, and Barrier Integrity

Scope: To independently verify the licensee’s appropriate handling of structures, systems, or

components (SSCs) performance or condition problems in terms of:

− Appropriate work practices;

− Identifying common-cause failures;

− Scoping in accordance with 10 CFR 50.65(b);

− Characterizing reliability issues (performance);

− Charging unavailability (performance);

− Trending key parameters (condition monitoring)

− 10 CFR 50.65 (a)(1) or (a)(2) classification and reclassification;

− Appropriateness of performance criteria for SSCs/functions classified (a)(2) or

appropriateness of goals and corrective actions for SSCs/functions classified (a)(1)

The scope of the inspection activities would include performance issues associated with risk
significant SSCs covered under the maintenance rule. This inspection will also assess the
effectiveness of the licensee’s periodic evaluation and resulting adjustments among those
performed pursuant to 10 CFR 50.65(a)(3) every two years.

Basis: Inspection of this item supports the Initiating Events, Mitigating Systems and Barrier
Integrity cornerstones. Reliability and availability of maintenance rule (MR) SSCs as
monitored or demonstrated under the MR directly affect those reactor safety cornerstones
and are dependent upon maintenance effectiveness (including work practices and
common-cause problems).

Proper monitoring and implementation of the MR attributes should ensure that there is a
proper balance that optimizes availability and reliability when removing equipment from
service for preventive maintenance. High availability and reliability result in a high probability
that accident mitigation systems will perform successfully when needed and that Barrier
Integrity will remain effective in preventing the release of radioactivity. Proper work practices,
corrective actions, and reducing potential common cause failures will also ensure that the
SSCs are capable of fulfilling their intended safety functions.

Performance Indicators: This inspection area supplements the scram, transient, safety
system unavailability, and safety system functional failure performance indicators. While
these indicators provide some insights of equipment performance in a limited number of

Issue Date: 10/31/23 28 0308 Att 2

 safety systems, they do not provide adequate information to monitor the equipment
performance of systems covered under the scope of the maintenance rule. In addition,
inspection activities in this area would provide an assessment of equipment reliability where a
performance indicator does not exist.

Significant Changes in Scope or Basis:

December 2001 - This IP was revised extensively to focus the inspection activities on
reviewing maintenance effectiveness issues associated with availability, reliability, common
cause failures, and work practices of risk significant SSCs.

July 2002 - Revised to clarify inspection objectives and to improve effectiveness of this
procedure based on feedback and lessons learned from implementation. This revision
provides greater focus on reviewing licensee's effectiveness at performing routine
maintenance. The revised procedure also focuses on review of equipment performance
issues associated with availability and reliability, preferably on high-risk significant systems,
maintenance work practices, and common cause issues. Sample size and inspection
resource requirements were revised based on experience gained from four verification and
validation visits at one site in each region.

Issue Date: 10/31/23 29 0308 Att 2

 Exhibit 13: Maintenance Risk Assessments and Emergent
Work Control (IP 71111.13)

Basis Summary Sheet

Inspectable Area: Maintenance Risk Assessments and Emergent Work Control

Cornerstone(s): Initiating Events, Mitigating Inspection Procedure: IP 71111.13

Systems and Barrier Integrity

Scope: Inspection activities in this area would focus on the effectiveness of the licensee’s
configuration controls during shutdown and power operations. Paragraph (a)(4) of 10 CFR
50.65, the Maintenance Rule (MR), requires licensees to assess and manage plant risk
related to maintenance activities during all modes of plant operation. The inspector would
verify that before performing maintenance activities (including but not limited to surveillances,
post-maintenance testing, and corrective and preventive maintenance), the licensees assess
and manage the increase in risk that may result from configuration change related to the
proposed maintenance activities. The inspectors also verify that the licensees effectively plan
and control emergent work activities to minimize the probability of initiating events, maintain
the functional capability of mitigating systems and maintain barrier integrity.

Basis: This inspection item supports the Mitigating Systems, Initiating Events and Barrier
Integrity cornerstones.

Maintenance is the primary means of mitigating and managing the effects of component
degradation and failures. Operating experience shows that the lack of maintenance
(component deficiencies not corrected) or improperly performed maintenance (maintenance
activities not well controlled) can greatly contribute to the risk for event initiation and may
cause SSCs to not function properly if called upon to mitigate the consequence of an event.
Operating experience also shows that for risk significant events identified through the
Accident Sequence Precursor (ASP) program, work control and failure to maintain equipment
represent the majority of causes. Loss of configuration control of risk-significant safety
equipment can initiate a reactor transient and simultaneously compromise mitigation
capability. During shutdowns, when equipment is out of service for maintenance or testing or
when off-normal lineups or infrequent tests and evolutions are being conducted, configuration
control problems are more likely to result in initiating events or loss of barrier integrity.

Performance Indicators: The safety system unavailability performance indicators provide only
some information on the adequacy of configuration control of selected systems. Inspections
will monitor plant configuration changes to ensure that the risk is assessed and managed
properly to minimize the probability of initiating events, maintain the functional capability of
mitigating systems, and maintain barrier integrity. This inspection supplements the PI.

Issue Date: 10/31/23 30 0308 Att 2

 Significant Changes in Scope or Basis:

April 2000 - The emergent work inspection requirements and guidance were added to the
procedure since this IP covered inspection of configuration control issues.

November 2000 - Revised to clarify inspection objectives and requirements and to provide
detailed guidance to support the 10 CFR 50.65(a)(4) rule change.

January 2002 - Revised to provide bands for inspection resource estimates and sample sizes
and guidance for inspection procedure status.

Issue Date: 10/31/23 31 0308 Att 2

 Exhibit 14: Reserved (IP 71111.14)

Basis Summary Sheet

Inspectable Area: Reserved

Cornerstone(s): Inspection Procedure: IP 71111.14

Scope:

Basis:

Performance Indicators:

Significant Changes in Scope or Basis:

Issue Date: 10/31/23 32 0308 Att 2

 Exhibit 15: Operability Determinations and Functionality Assessments
(IP 71111.15)

Basis Summary Sheet

Inspectable Area: Operability Determinations and Functionality Assessments

Cornerstone(s): Mitigating Systems and Inspection Procedure: IP 71111.15

Barrier Integrity

Scope: Inspection activities in this area would focus on the evaluation of degraded and
non-conforming conditions affecting plant systems, structures, and components (SSCs).
Inspection activities would be limited to a review of those potentially risk significant degraded
and non-conforming conditions affecting SSCs that are considered to be either operable or
functional based on written evaluations. Initial reviews of the operability or functionality
evaluations should be performed following formal completion of the evaluations by the
licensee. The inspection would ensure that the evaluations include an adequate technical
justification to support the operability or functionality evaluation and would verify the
implementation of any compensatory measures.

Basis: Inspection of this item supports the Mitigating Systems and Barrier Integrity
cornerstones by ensuring risk-significant SSCs can perform their specified safety or current
licensing basis (CLB) function. Improperly evaluated degraded and/or non-conforming
conditions may result in continued operation with an SSC that is not capable of performing its
specified safety or CLB function.

The inspection activities are intended to verify that the licensee has taken the necessary
steps to demonstrate that the reliability, availability, and functional capability of the SSCs and
associated components are maintained although the SSCs are degraded and/or
non-conforming in some way.

As a result of the size and complexity of a nuclear power plant, degraded and non-conforming
conditions are frequently identified at all plants. Risk-significant SSCs are often affected, and
the degraded or non-conforming condition cannot always be corrected immediately. An
improperly evaluated degraded and/or non-conforming condition may result in continued
operation with an SSC that is not capable of performing its specified safety or CLB function
which would result in operation of the plant outside of its design and/or license bases. The
potential effects on safe operation could include the loss of redundancy within a safety
system, the loss of specified safety or CLB function or a reduction in the safety margin
assumed in the plant design and analyses.

Performance Indicators: There are no performance indicators that provide effective

assessment of the quality of operability evaluations.

Significant Changes in Scope Basis:

January 2002 - Revised to provide minor clarifications to inspection requirements and

additional inspection guidance concerning operability evaluations. In addition, inspection

Issue Date: 10/31/23 33 0308 Att 2

 resource estimates and inspection level of effort are revised to provide a band for more
inspection flexibility.

February 2004 - Revised to include deferred modifications to the inspection sampling list.

April 2011 - Revised to allow for the oversight of functionality assessments associated with
risk-significant SSCs, regardless of the potential impact to technical specification (TS) SSC
operability.

December 2014 – Revised to relocate operator workaround (OWA) sample requirements

from IP 71152 per 2013 ROP Enhancement effort (ML14017A340 & ML14017A391).

December 2016 - Revisions are made to address use of mandatory and discretionary
language concerns and recommendations found in OIG-16-A-12 (ML16097A515). In addition,
the requirement to inspect at least one sample associated with OWAs was deleted. However,
as discussed in guidance section of the IP, review of manual compensatory measures /
OWAs may still be afforded if a sample opportunity exists (i.e., flexibility offered in sample
selection).

Issue Date: 10/31/23 34 0308 Att 2

 Exhibit 16: Reserved (IP 71111.16)

Basis Summary Sheet

Inspectable Area: Reserved

Cornerstone(s): Inspection Procedure: IP 71111.16

Scope:

Basis:

Performance Indicators:

Significant Changes in Scope or Basis:

Issue Date: 10/31/23 35 0308 Att 2

 Exhibit 17: Evaluations of Changes, Tests, and Experiments
(IP 71111.17T)

Basis Summary Sheet

Inspectable Area: Evaluations of Changes, Tests, and Experiments

Cornerstone(s): Initiating Events, Mitigating Inspection Procedure: IP 71111.17T

Systems, and Barrier Integrity

Scope: This 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 CFR 50.59. This inspection provides
assurance that required license amendments have been obtained. It verifies aspects of
Initiating Events, Mitigating Systems and Barrier Integrity cornerstones for which there are no
indicators to measure performance.

Basis: Inspection of this area supports the Mitigating Systems, Barrier Integrity, and Initiating
Events cornerstones.

Inspection of this item verifies that changes to facility and procedures as described in the
UFSAR, and changes to tests and experiments not described in the UFSAR are in
accordance with the requirements of 10 CFR 50.59. This would provide assurance that the
changes in facility, procedures, or test/experiments have not reduced the safety margins of
the SSCs or for operation of the plant.

Performance Indicators: No performance indicators have been established that can provide
results related to the adequacy of the licensee’s program for making changes to the facility.

Significant Changes in Scope or Basis:

January 2008 - IP 71111.17, “Permanent Plant Modifications,” was revised to IP 71111.17T,

“Evaluations of Changes, Tests, and Experiments and Permanent Plant Modifications.” This
new revision combined 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. The changes are associated with a 2007 ROP realignment effort as
indicated in SECY-08-0046 (ML073020593).

December 2016 - Revisions were 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 a revised IP 71111.21M, “Design
Bases Assurance Inspection (Teams).” As a result, IP 71111.17T was retitled “Evaluations of
Changes, Tests, and Experiments.”

January 2023 – Made a reference procedure. Objectives incorporated into IP 71111.21M,

“Comprehensive Engineering Team Inspection.”

Issue Date: 10/31/23 36 0308 Att 2

 Exhibit 18: Plant Modifications (IP 71111.18)

Basis Summary Sheet

Inspectable Area: Plant Modifications

Cornerstone(s): Initiating Events, Mitigating Inspection Procedure: IP 71111.18

Systems, and Barrier Integrity

Scope: Inspection activities in this area include the review of design, installation, configuration
control, and post-modification testing for the potentially risk significant permanent and
temporary modifications of the systems, structures, and components (SSCs). Inspection
activities may also include a review of changes to documents and procedures affected by the
modification.

Inspection activities may also include a review of site SAMGs updates when the BWROG or
PWROG revise generic severe accident technical guidelines.

Basis: Modifications to risk-significant structures, systems, and components (SSCs) can

adversely affect their availability, reliability, or functional capability. Modifications to one
system may also affect the design bases and functioning of interfacing systems. Similar
modifications to several systems could introduce potential for common cause failures that
affect plant risk. A temporary modification may result in a departure from the design basis and
system success criteria. Modifications performed during increased risk configurations could
place the plant in an unsafe condition.

SRM SECY-15-0065 (ML15239A767) directed the NRC staff to update the ROP to explicitly
provide periodic oversight of the industry's implementation of the SAMGs.

Inspection of this area supports the design and design control attributes of the Initiating
Events, Mitigating Systems, and Barrier Integrity cornerstones.

Performance Indicators: No performance indicators have been established that can provide
results related to the adequacy of plant modifications.

Significant Changes in Scope or Basis:

January 2008 - IP 71111.18, “Plant Modifications,” was created. This new IP combined
previous aspects of IP 71111.17, “Permanent Plant Modifications” and IP 71111.23,
“Temporary Plant Modifications.” The changes are associated with a 2007 ROP realignment
effort as indicated in SECY-08-0046 (ML073020593).

November 2016 and November 2018 – IP revised to provide oversight of SAMGs.

Issue Date: 10/31/23 37 0308 Att 2

 Exhibit 19: Post-Maintenance Testing (IP 71111.19)

Basis Summary Sheet

Inspectable Area: Post-Maintenance Testing

Cornerstone(s): Mitigating Systems and Inspection Procedure: IP 71111.19

Barrier Integrity

Scope: Inspection activities would focus on verification that the post maintenance test
procedures and test activities were adequate to verify system operability and functional
capability for the maintenance that was performed. The inspection would focus on significant
maintenance involving high risk significant systems or components, in areas that have the
potential to cause common mode/cause failures, where repetitive failures indicate
programmatic problems, or on maintenance activities that have the potential to significantly
impact risk.

Basis: Inspection of this item supports the Mitigating Systems and Barrier Integrity
cornerstones.

Post maintenance testing provides the final check that a system and /or component has been
returned to its required design configuration and will perform its design function(s) following
completion of maintenance activities. Inadequate maintenance activities that are not detected
prior to returning the equipment to service can result in a significant increase in unidentified
risk for the subject system and in common mode/cause failures and potential for loss of
function on redundant trains and identical components in other systems.

Performance Indicators: This inspection activity will supplement PIs (scram, transient, and
safety system unavailability and safety system functional failure). These PIs do not directly
measure the adequacy of the post-maintenance test procedures but indirectly confirm the
quality of maintenance and test procedures.

Significant Changes in Scope or Basis:

January 2023 – Made a reference procedure, objectives transferred to IP 71111.24, “Testing

and Maintenance of Equipment Important to Risk.”

Issue Date: 10/31/23 38 0308 Att 2

 Exhibit 20: Refueling and Other Outage Activities (IP 71111.20)

Basis Summary Sheet

Inspectable Area: Refueling and Other Outage Activities

Cornerstone(s): Initiating Events, Mitigating Inspection Procedure: IP 71111.20

Systems, and Barrier Integrity

Scope: Inspections focus on the licensee’s shutdown risk management program and outage
related activities having the potential to impact plant risk. Areas include clearance activities,
reactor coolant system instrumentation, electrical power, decay heat removal monitoring,
spent fuel pool cooling system operation, inventory control, reactivity control, containment
closure, reduced inventory/mid-loop operations, refueling activities, and heatup/startup
activities. The inspection also focuses on inspection of SSCs in containment. The inspection
applies to planned outages (such as refueling outages) as well as forced outages.

Basis: Shutdown risk can be high for deficiencies that occur when vital SSCs are not
available, such as during the fuel handling period of a refueling outage and off-normal plant
configurations in other outage periods. Times of reduced inventory are the most critical.
During outages, barriers to prevent radiological releases may be degraded. Inspection
activities assess licensee steps to preclude events, maintain defense in depth, and ensure
appropriate SSCs are available.

Performance Indicators: There are no performance indicators for licensee performance during
refueling and other outages.

Significant Changes in Scope or Basis:

January 2002 - Revised to integrate with IMC 0609, Appendix G, “Shutdown Operations
Significance Determination Process,” regarding risk insights and how to evaluate inspection
findings. It also addresses refueling controls, improper sequencing of control rods or fuel
assemblies, reactivity control, and methods to ensure fuel assembles are loaded in correct
positions.

November 2003 - Revised to address licensee procedures for foreign material exclusion,
instruments tracking plant condition changes, training procedures for BWR alternate decay
heat removal. It also cross references IMC 2515, Appendix D, “Plant Status” regarding plant
status tours of areas accessible only

May 2004 - revised to add guidance for containment inspections, when possible, and to add a
completion status section.

Issue Date: 10/31/23 39 0308 Att 2

 Exhibit 21: Safety System Design and Performance Capability (IP 71111.21)

Basis Summary Sheet

Inspectable Area: Safety System Design and Performance Capability

Cornerstone(s): Mitigating Systems Inspection Procedure: IP 71111.21

Scope: Inspection includes review of design bases, updated final safety analysis report
(UFSAR), supporting calculations, as-built conditions, modifications, testing, and normal and
emergency operations of risk-significant systems and interfaces with support systems. This
would be an in-depth review of a selected risk significant system and support systems with an
emphasis on changes to the design bases and normal and emergency plant procedures. The
selection of the system(s) should be based on systems with high probabilistic risk analysis
(PRA) rankings; with design attributes not fully demonstrated through testing; with significant
modifications, changes to design bases, and operating procedure changes; that have not
received recent NRC review; which have multiple maintenance rule functions or which support
multiple systems; which complement each other (e.g., for a PWR, AFW and pressurizer
PORVs; for a BWR, HPCI and ADS) like from a dominant accident sequence since the
systems would be complimentary in regard to one type of accident; and which are contained
within the NRC risk-informed notebook for a specific plant for a particular initiating event.

Basis: Inspection of safety system design and performance verifies the initial design and
subsequent modifications and provides monitoring of the capability of the selected system to
perform its design basis functions. The inspection should focus on the design and functional
capability of components that are not validated by in-plant testing. Also, seismic and
environmental qualifications of the SSCs should be verified. The PRA assumptions and
models are based on the ability of the as-built safety system to perform its intended safety
function successfully. If the design bases of the system had not been correctly implemented in
the installed system, the operation and test procedures, and the supporting analyses and
calculations, the system cannot be relied upon to meet its design bases and performance
requirements. The design interfaces with support systems, such as cooling systems,
ventilation systems, and instrument air system, should also be reviewed.

The baseline inspection should focus on: (1) maintaining design bases (2) consistency with
defense-in-depth philosophy, and (3) maintaining sufficient safety margins.

Performance Indicators: There are no performance indicators that have been established that
can provide results related to correct implementation of the design bases in the as-built system
and the associated plant documents.
Significant Changes in Scope and Basis:

Focused Engineering Inspections (IP 71111.21N) allows for engineering inspections focused
on samples in specific areas that may be of high risk and may not have been inspected
previously as part of ROP baseline. The basis for the inspections remains the same for all
IP 71111.21 inspections. In addition, IP 71111.17T was made a reference procedure, and the
objectives were incorporated into IP 71111.21M, “Comprehensive Engineering Team
Inspection.”

Issue Date: 10/31/23 40 0308 Att 2

 Exhibit 22: Surveillance Testing (IP 71111.22)

Basis Summary Sheet

Inspectable Area: Surveillance Testing

Cornerstone(s): Mitigating Systems and Inspection Procedure: IP 71111.22

Barrier Integrity

Scope: This inspection will focus on verifying that surveillance testing (including inservice
testing) of risk-significant structures, systems, and components (SSCs) are capable of
performing their intended safety functions and assessing their operational readiness. The
inspector will review surveillance test results for adequacy in meeting the requirements,
observe ongoing testing to evaluate human performance, and ensure that appropriate test
acceptance criteria agrees with design requirements.

This inspection will also 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.

Basis: Inspection of this area ensures that safety systems are capable of performing their
safety function and support the Mitigating Systems and Barrier Integrity Cornerstones. The
failure to identify and resolve performance degradation of structures, systems, and
components, could result in long periods of unknown equipment unavailability. This
inspection procedure verifies aspects of the associated cornerstones not measured by
performance indicators.

Surveillance testing including inservice testing of pumps and valves are required to verify that
systems and components are reliable and functionally capable of performing their design
function. Inspection will review the adequacy of test procedures to test those design functions
being verified. Important design functions not verified by testing will be subject to risk
informed design inspection. Surveillance testing is the minimum required testing specified in
the facility license and ensures that a conservative safety margin exists for system capability.
Operating experience has shown that test procedure deficiencies may invalidate previously
acceptable test results and improper testing could result in undisclosed problems that last
until the next required testing creating long periods of unknown equipment inoperability.

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.

Performance Indicators: The PIs indirectly verify the adequacy of required surveillance test
activities. This inspection is performed to provide insights into licensee performance in
addition to those provided by the PIs.
Significant Changes in Scope or Basis:

Issue Date: 10/31/23 41 0308 Att 2

 April 2000 - Procedure incorporated requirements and guidance to review licensee’s inservice
testing activities, containment isolation valve and ice condenser system surveillances.

January 2002 - Revised to incorporated minor changes to the inspection requirements. In

addition, inspection resources estimates, and inspection level of effort are revised to provide
a band for more inspection flexibility.

May 2004 - Revised to include RCS leak detection system surveillance as part of the
surveillance testing sample. Revision also includes surveillance testing attributes for
reviewing annunciators/alarms setpoints and alarms response procedure actions.

November 2018 - Revised to allow for oversight of FLEX testing, and as a minimum, require
one inspection sample per year.

January 2023 – Made a reference procedure, objectives transferred to IP 71111.24, “Testing

and Maintenance of Equipment Important to Risk.”

Issue Date: 10/31/23 42 0308 Att 2

 Exhibit 23: Reserved (IP 71111.23)

Basis Summary Sheet

Inspectable Area: Reserved

Cornerstone(s): Inspection Procedure: IP 71111.23

Scope:

Basis:

Performance Indicators:

Significant Changes in Scope or Basis:

Issue Date: 10/31/23 43 0308 Att 2

 Exhibit 24: Testing and Maintenance of Equipment Important to Risk (IP 71111.24)

Basis Summary Sheet

Inspectable Area: Testing and Maintenance of Equipment Important to Risk

Cornerstone(s): Mitigating Systems and Inspection Procedure: IP 71111.24

Barrier Integrity

Scope: Inspection activities would focus on verification that the post maintenance test
procedures and test activities were adequate to verify system operability and functional
capability for the maintenance that was performed. The inspection would focus on significant
maintenance involving high risk significant systems or components, in areas that have the
potential to cause common mode/cause failures, where repetitive failures indicate
programmatic problems, or on maintenance activities that have the potential to significantly
impact risk.

This inspection will also focus on verifying that surveillance testing (including inservice
testing) of risk-significant structures, systems, and components (SSCs) are capable of
performing their intended safety functions and assessing their operational readiness. The
inspector will review surveillance test results for adequacy in meeting the requirements,
observe ongoing testing to evaluate human performance, and ensure that appropriate test
acceptance criteria agrees with design requirements.

Finally, this inspection will also 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.

Basis: Inspection of these areas ensures that safety systems are capable of performing their
safety function and support the Mitigating Systems and Barrier Integrity Cornerstones.

Post maintenance testing provides the final check that a system and /or component has been
returned to its required design configuration and will perform its design function(s) following
completion of maintenance activities. Inadequate maintenance activities that are not detected
prior to returning the equipment to service can result in a significant increase in unidentified
risk for the subject system and in common mode/cause failures and potential for loss of
function on redundant trains and identical components in other systems.

The failure to identify and resolve performance degradation of structures, systems and
components, could result in long periods of unknown equipment unavailability. This
inspection procedure verifies aspects of the associated cornerstones not measured by
performance indicators.

Surveillance testing including inservice testing of pumps and valves are required to verify that
systems and components are reliable and functionally capable of performing their design
function. Inspection will review the adequacy of test procedures to test those design functions
being verified. Important design functions not verified by testing will be subject to risk
informed design inspection. Surveillance testing is the minimum required testing specified in
the facility license and ensures that a conservative safety margin exists for system capability.

Issue Date: 10/31/23 44 0308 Att 2

 Operating experience has shown that test procedure deficiencies may invalidate previously
acceptable test results and improper testing could result in undisclosed problems that last
until the next required testing creating long periods of unknown equipment inoperability.

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.

Performance Indicators: This inspection activity will supplement PIs (scram, transient, and
safety system unavailability and safety system functional failure). These PIs do not directly
measure the adequacy of the post-maintenance test or surveillance test procedures/activities
but indirectly confirm their procedures. This inspection is performed to provide insights into
licensee performance in addition to those provided by the PIs.

Significant Changes in Scope or Basis:

January 2023 – IP 71111.24, “Testing and Maintenance of Equipment Important to Risk” is a

new IP that combines the former IP 71111.19, “Post-Maintenance Testing,” and IP 71111.22,
“Surveillance Testing,” into a unified procedure.

Issue Date: 10/31/23 45 0308 Att 2

 Exhibit 25: Biennial Exercise and Drill Inspection (IP 71114.01, .06, .07 and .08)

Basis Summary Sheet

Inspectable Area: Biennial Exercise and Drill Inspection

Inspection Procedure: IP 71114.01, IP

Cornerstone(s): Emergency Preparedness
71114.06, IP 71114.07, and IP 71114.08

Scope: This inspection area consists of two major aspects:

• Verification of the licensee challenging drill and exercise program performed under IP
71114.08 “Exercise Evaluation – Scenario Review” and

• Evaluation and verification of the licensee’s capability to appropriately critique drill and
exercise program performance performed under IP 71114.01, IP 71114.06 “Drill
Evaluation” and IP 71114.07 “Exercise Evaluation - Hostile Action (HA) Event.”

Basis: This inspection area supports the EP cornerstone through the emergency response
organization (ERO) Readiness, Facilities and Equipment, Procedure Quality and ERO
Performance key attributes.

The implementation of the Emergency Plan is dependent on the performance of the ERO in
their EP assignments. There are many areas important to Plan implementation, but the most
risk significant areas (RSPS) of ERO performance are:

• Timely and accurate classification of events; including the recognition of events as

potentially exceeding emergency action levels and any assessment actions necessary
to support the classification.

• Timely and accurate notification of offsite governmental authorities; including

adequate performance of notifications as specified in the Plan.

• Timely and accurate assessment and monitoring of actual and or potential offsite
radiological release consequences during an emergency.

• Timely and accurate development and communication of protective action

recommendations to offsite authorities; including providing protective action
recommendations (PARs) to governmental authorities, the decision-making process to
develop the PARs and any accident assessment necessary to support PAR
development.

The inspection scope verifies the licensee Emergency Preparedness (EP) drill and exercise
program provides opportunities to develop and maintain the key skills to perform the major
functions of the emergency response plan and that unacceptable performance in the
implementation of the emergency plan is identified and corrected. It also verifies the efficacy
and veracity of the critique program used to develop the success rate reported by the
drill/exercise performance (DEP) performance indicators (PI) success rate of risk significant
planning standard performance.

Issue Date: 10/31/23 46 0308 Att 2

 Consistent timely and accurate ERO performance of these activities indicates that ERO
performance is within the licensee response band and that NRC oversight can be through the
risk informed baseline inspection program

Performance Indicators:

The DEP PI has been developed to indicate performance in the RSPSs of EP. The data used
to develop the DEP PI value is based on licensee critiques of RSPS performance during
actual events, drills, exercises and appropriate training evolutions. These inspections verify
the efficacy of the licensee critique program.

Significant Changes in Scope or Basis:

April 2000 - The review of licensee correction of weaknesses was initially performed within
the scope of 71114.01. This was seen as supportive to preparation for observation of the
exercise, but proved to be too demanding of licensee and inspection staff. Licensee focus
during the week of the exercise is proper scenario conduct. Providing corrective action
documentation and staff for discussion to NRC detracts from the primary focus. The review of
weakness correction was moved to 71114.05.

June 2006 - Rewrite of document structure to align with IMC 0612 and SDP Appendix B.
Added guidance for review and understanding of DHS deficiencies per SRM to SECY-05-
0045 and restored previously deleted inspection commitment to ensure E-Plans and EPIPs
contain criteria non-essential onsite personnel protective actions, including evacuation for
Site Area Emergencies and General Emergencies

May 2012 - Re-write document structure to align with IMC 0040 “Preparing, Revising, and
Issuing Documents for the NRC Inspection Manual,” and make changes in support of the
2011 final EP rulemaking including: scenario review; classification timeliness; review of
backup and alternate facilities and demonstration of 50.54(hh)(2) strategies, procedures
guidance.

Issue Date: 10/31/23 47 0308 Att 2

 Exhibit 26: Alert and Notification System Evaluation (IP 71114.02)

Basis Summary Sheet

Inspectable Area: Alert and Notification System Evaluation

Cornerstone(s): Emergency Preparedness Inspection Procedure: IP 71114.02

Scope: Inspection in this area includes a review of testing and maintenance activities for the
Alert and Notification System (ANS) in order to assess licensee compliance.

Basis: This inspection area supports the Emergency Preparedness (EP) cornerstone through
the Facilities and Equipment key attribute.

The ANS is the most important system/equipment maintained by the EP program. The
purpose of the EP program is to implement adequate measures to protect the public health
and safety in the event of a radiological emergency and the ANS is the method used for
notifying the public of the need to take such protective actions. Generally, the licensee
maintains the ANS, and local governmental authorities operate it when necessary.

A highly reliable ANS increases the assurance that the public health and safety can be
protected during an emergency. As long as the ANS reliability remains high the NRC’s
oversight is through the risk informed baseline inspection program. The ANS PI measures the
reliability of the ANS based on the results scheduled testing program. This inspection verifies
the licensee’s compliance with their Federal Emergency Management Agency approved ANS
design report testing requirements.

Performance Indicators: The ANS PI provides a uniform industry reporting of the ANS
reliability. A site that does not have sirens as part of the FEMA approved ANS design does
not report data for this PI and the licensee’s ANS performance is evaluated only through the
NRC baseline inspection program.

Significant Changes in Scope or Basis:

June 2012 - Added inspection requirement and guidance to address the 2011 EP rule
enhancement requirements for backup ANS capability.

Issue Date: 10/31/23 48 0308 Att 2

 Exhibit 27: Emergency Response Organization Staffing and Augmentation System
(IP 71114.03)

Basis Summary Sheet

Inspectable Area: Emergency Response Organization Staffing and Augmentation System

Cornerstone(s): Emergency Preparedness Inspection Procedure: IP 71114.03

Scope: Inspection in this area involves a review of licensee Emergency Response

Organization (ERO) member qualifications, the processes and equipment that would be used
for an emergency. Licensees normally conduct tests of the augmentation system and the
people assigned to the ERO to ensure that emergency response facilities can be staffed in
accordance with the emergency response plan activation commitments. Licensee ability to
identify and disposition augmentation corrective actions is also inspected.

Basis: This inspection area supports the Emergency Preparedness (EP) cornerstone through
the ERO Readiness, Procedure Quality and Facilities and Equipment key attributes.

The licensee system to augment the on-shift staff with ERO members is an important process
in implementing the Emergency Plan. This inspection involves the verification of: ERO
augmentation system testing to ensure notification of individual ERO members, ERO member
training and qualification records, that emergency plan facility activation commitments can be
meet.

Performance Indicators: No PIs were established that cover this area.

Significant Changes in Scope or Basis:

October 2006 - Revised IP to add objective for explicit review of adequate ERO staffing levels
using NUREG-0654, table B-1 as the standard. Added clarification on the review of ERO
responder training and qualifications.

Issue Date: 10/31/23 49 0308 Att 2

 Exhibit 28: Emergency Action Level and Emergency Plan Changes
(IP 71114.04)

Basis Summary Sheet

Inspectable Area: Emergency Action Level and Emergency Plan Changes

Cornerstone(s): Emergency Preparedness Inspection Procedure: IP 71114.04

Scope: Inspection activities in this area include a review of all changes to the Emergency
Action Levels (EALs) and a sampling of changes to the Emergency Plan (Plan).

Basis: This inspection area supports the Emergency Preparedness (EP) cornerstone through
the Procedure Quality key attribute.

Recognition and subsequent classification of events is a risk significant activity (RSPS)

because classification leads to activation of the Emergency Response Organization,
notification of governmental authorities and in the extreme, development of protective action
recommendations. However, if the EAL scheme is not in compliance with NRC approved
classification schemes, the expected emergency classification may not occur. Appendix E to
10 CFR Part 50 requires licensees to have and maintain an NRC approved EAL scheme.
Title 10 CFR 50.54(q) allows licensees to make changes to the Plan and EAL scheme as
long as the changes do not reduce the effectiveness of the Plan or scheme without prior NRC
approval. This inspection is the method for NRC inspectors to review all EAL changes and a
sample of Plan changes.

Performance Indicators: No PIs were established that cover this area.

Significant Changes in Scope or Basis:

April 2000 -– Initially, only the EAL element was addressed in this IP. The plan review was
combined with an IP which also addressed UFSAR and Safeguards Plan changes. This was
found to be cumbersome, and the Plan elements were placed in this IP.

October 2006 – Revised the IP to capture RIS 2005-02 “Clarifying the Process for Making
Emergency Plan Changes” guidance for making Emergency Plan changes that included
(1) clarification of the meaning of “decrease in effectiveness,” as stated in 10 CFR 50.54(q);
(2) clarification of the process for evaluating proposed changes to emergency plans; (3) a
method for evaluating proposed changes to emergency plans; and (4) clarifying guidance on
the appropriate content and format of applications submitted to the NRC for approval prior to
implementation.

October 2008 – Revised to incorporate a review of security-related Emergency Action Levels

and Emergency Plan changes.

July 2016 – Reformatted the IP to align with IMC 0040 “Preparing, Revising and Issuing
Documents for the NRC Inspection Manual” formatting expectations. Changed “decrease in
effectiveness” to “reduction in effectiveness.” Added an inspection requirement to review
10 CFR 50.54(q) emergency plan change process, practice and guidance. Updated 10 CFR
50.54(q) description in accordance with the December 2011 EP rule enhancement. Added

Issue Date: 10/31/23 50 0308 Att 2

 the 10 CFR 50 Appendix E.IV.B guidance for a licensee desiring to change its entire EAL
scheme would require prior NRC approval before implementing the change and that less
substantial EAL changes may be made using the § 50.54(q) process.

Issue Date: 10/31/23 51 0308 Att 2

 Exhibit 29: Correction of Emergency Preparedness Weaknesses and Deficiencies
(IP 71114.05)

Basis Summary Sheet

Inspectable Area: Correction of Emergency Preparedness Weaknesses and Deficiencies

Cornerstone(s): Emergency Preparedness Inspection Procedure: IP 71114.05

Scope: Evaluate the licensee efforts to maintain their Emergency Preparedness (EP)
program by verifying accurate and appropriate identification and correction of EP weaknesses
noted during actual event critiques, drill and exercise critiques and program self-assessment
activities.

Basis: The licensee drill and exercise critique program (and other self-assessment
processes) are expected to identify ERO performance weaknesses and other problems that
would detract from the Plan implementation. The identification of repeat items, trends and the
appropriate disposition of corrective actions are inspected. The ability to identify and correct
problems is integral to the efficacy of an EP program. The ability to identify drill and exercise
weaknesses are inspected under IP 71114.01 & .06. This inspection addresses the licensee
ability to identify and correct weaknesses in a timely manner. The inspection is meant to
include all the licensee efforts that assess the EP program and or the ERO performance such
as, but not limited to

• Self-assessment reports including all reports of actual events and missed

classification of actual events,

• Biennial exercise and drill critiques,

• Audits conducted under 10 CFR 50.54(t), and

• Assessments performed by the Quality Assurance organization.

Performance Indicators: No PIs were established that cover this area.

Significant Changes in Scope or Basis:

October 2006 -– Revised inspection procedure (IP) to clarify the inspection is to focus on the
timeliness and effectiveness of corrective action associated with 10 CFR 50.47(b)(14) and
conform to the reactor oversight program emphasis on correction of EP weaknesses.

May 2012 – Reformatted IP in accordance with IMC 0040 “Preparing, Revising and Issuing
Documents for the NRC Inspection Manual” formatting expectations. Added inspection
requirements and guidance for review of licensee: letters of agreement and/or memorandums
of understanding, 10 CFR 50.54(q) plan change process and practice, maintenance of
equipment important to emergency preparedness, record(s) of evacuation time estimate
population evaluations, and emergency plan provisions for, and implementation of, primary,
backup and alternate emergency response facility maintenance

Issue Date: 10/31/23 52 0308 Att 2

 July 2016 -– Added note stating NUREG-0654 Sup 3 dated July 1996 is no longer acceptable
guidance. Added inspection requirements and guidance for reviewing protective action
recommendation strategy procedures and the incorporation and implementation of
evacuation time estimate updates.

Issue Date: 10/31/23 53 0308 Att 2

 Exhibit 30: Access Control to Radiologically Significant Areas
(IPs 71124.01, 71124.04, and 71124.08)

Basis Summary Sheet

Inspectable Area: Access Control to Radiologically Significant Areas

Cornerstone(s): Occupational Radiation Inspection Procedure: IP 71124.01,

Safety IP 71124.04, and IP 71124.08

Scope: Inspection procedures (IPs) in this Inspectable Area evaluate aspects of licensee
radiation protection programs that control access to radiologically significant areas. These
areas include airborne radioactivity areas, high radiation areas, very high radiation areas and
areas used to store radioactive materials or radioactive waste that is radiologically significant.
Hazard assessments and access controls form the foundation of licensee efforts within this
area. Hazard assessments include identification and proper characterization of radiological
conditions to identify the extent of radiation levels, contamination levels and airborne
concentrations or quantities of radioactive materials that comprise the radiological hazard
(e.g., radiological surveys and monitoring). Access controls include instructions to workers
(e.g., training, radiation work permits and pre-job briefings); physical barriers or engineered
controls (e.g., locked doors, fences, ropes); postings and warning lights and supervision of
radiation workers by qualified radiation protection personnel.

Basis: Inspection in this area supports the Occupational Radiation Safety Cornerstone of the
Reactor Oversight Process.

As required by 10 CFR Part 19 and 10 CFR Part 20, licensees shall ensure they provide
adequate access controls to radiologically significant areas and adequate instructions to
workers accessing these areas. In general, adequate protection from routine exposures is
demonstrated by maintaining the resultant doses below the applicable limits of 10 CFR
Part 20 Subpart C and as low as is reasonably achievable (ALARA).

The occupational Exposure Control Effectiveness Performance Indicator (PI) monitors the
control of access and work activities within radiologically significant areas as well as
occurrences involving the degradation, or failure, of radiation safety barriers that result in
unintended dose. However, this PI does not provide oversight in situations where the
radiological hazards are not adequately reflected by the dose outcome (e.g., substantial
potential exists for an overexposure or substantial release of radioactive materials).

Performance Indicators: Occupational Exposure Control Effectiveness

Significant Changes in Scope or Basis:

June 2017 – (1) The scope was revised to more clearly identify it as the scope of the
Inspectable Area, not necessarily a specific IP attachment. Multiple attachments in IP 71124
(IP 71124.01, IP 71124.02, IP 71124.04, and IP 71124.08) are applicable to this Inspectable
Area; and (2) The basis was revised to specifically identify the applicable PI and more
accurately describe the interface between the PI and the Inspectable Area.

Issue Date: 10/31/23 54 0308 Att 2

 Exhibit 31: ALARA Planning and Controls
(IPs 71124.01, and 71124.03)

Basis Summary Sheet

Inspectable Area: ALARA Planning and Controls

Cornerstone(s): Occupational Radiation Inspection Procedure: IP 71124.01, and IP
Safety 71124.03

Scope: Inspection procedures in this Inspectable Area verify that the licensee establishes and
maintains adequate procedures and engineering controls, based on sound radiation
protection principles to achieve occupational doses that are as low as is reasonably
achievable (ALARA). Controls, as stated here, refer to those physical barriers (e.g., locked
doors, ropes, shielding, respiratory protection, engineered devices) and administrative
barriers (e.g., surveys, planning, procedures, training, monitoring) that serve to mitigate
radiation exposure. Work activities with a potential for a high individual and/or collective dose;
that are performed in an area of high radiological risk; or are of concern because of industry
or licensee experience (e.g., spent fuel pool diving) are prioritized in this inspection area.

Inspections in this area focus on the reasonableness of dose goals that are the outcome of
ALARA planning and whether the licensee’s performance results in achieving those ALARA
goals. Inspections in this area include observing selected activities to verify that the
assumptions underlying ALARA planning are valid and that the appropriate controls are
implemented. Inspections also review licensee assessments of radiation protection programs
to determine whether adequate administrative controls, management oversight, and exposure
controls (e.g., source term reduction, physical barriers, surveys, and monitoring) were
applied.

Basis: Inspection in this area supports the Occupational Radiation Safety Cornerstone of the
Reactor Oversight Process.

As required by 10 CFR Part 20, licensees shall use, to the extent practicable, procedures and
engineering controls based on sound radiation protection principles to achieve occupational
doses that are ALARA. Additionally, 10 CFR Part 20, provides regulatory requirements for
maintaining total effective dose equivalent ALARA when it is not practical to apply process or
other engineering controls to control the concentration of radioactive material in the air below
airborne radioactivity area levels.

Performance within this Inspectable Area is judged on whether the licensee has taken
appropriate measures to track, and if necessary, to reduce exposures and not whether each
individual exposure and dose represents an absolute minimum, or whether the licensee has
used all possible methods to reduce exposures.

Performance Indicators: None

Issue Date: 10/31/23 55 0308 Att 2

 Significant Changes in Scope or Basis:

June 2017 – (1) The scope was revised to more clearly identify it as the scope of the
Inspectable Area, not necessarily a specific IP attachment. Multiple attachments in IP 71124
(IP 71124.01, IP 71124.02, and IP 71124.03) are applicable to this Inspectable Area; and
(2) the scope and basis were revised to be consistent with Part 20 language and to add
reference to respiratory protection

Issue Date: 10/31/23 56 0308 Att 2

 Exhibit 32: Radiation Monitoring Instrumentation
(IPs 71124.04 and IP 71124.05)

Basis Summary Sheet

Inspectable Area: Radiation Monitoring Instrumentation

Cornerstone(s): Occupational Radiation Inspection Procedure: IP 71124.04 and

Safety IP 71124.05

Scope: This Inspectable Area verifies the licensee is performing surveys to ensure
compliance with radiation protection regulations and that these surveys are reasonable to
evaluate the magnitude and extent of radiation levels, contamination levels, airborne
concentrations, quantities of residual radioactivity and potential radiological hazards.
Procedures associated with this Inspectable Area verify proper operation of equipment used
in surveys and monitoring (e.g., criticality and post-accident monitors; area radiation monitors;
continuous air monitors; containment dome monitors; portable survey equipment; personnel
dosimetry; whole body counting equipment and other equipment used in dose assessment
and monitoring). Inspections verify that equipment is calibrated and operated in accordance
with manufacturers’ recommendations and licensee procedures; that dosimetry is processed
by appropriately accredited processors; and that the results of monitoring are reasonably
interpreted and recorded. Specific attention will be given to exposures in excess of the
occupational dose limits and exposures to Declared Pregnant Workers, because of the
inherent risk and public interest.

Inspections in this area will not include monitors that a licensee has included under their
Maintenance Rule program.

Basis: Inspection in this area supports the Occupational Radiation Safety Cornerstone of the
Reactor Oversight Process. 10 CFR Part 20 Subpart F requires that licensees survey to
ensure compliance with radiation protection regulations and that these surveys are
reasonable to evaluate the magnitude and extent of radiation; concentrations and quantities
of radioactivity; and potential radiological hazards. Additionally, Subpart F requires that
equipment used for the quantitative measurement of radiation be properly calibrated for the
radiation measured.

Performance Indicators: None

Significant Changes in Scope or Basis:

June 2017 – (1) The scope was revised to more clearly identify it as the scope of the
Inspectable Area, not necessarily a specific IP attachment. Multiple attachments in IP 71124
(IP 71124.04 and IP 71124.05) are applicable to this Inspectable Area. Scope revised to be
consistent with Part 20 language, to reference personnel dosimetry and to reference
overexposures and monitoring of DPWs, these areas were moved from the previous basis
sheet on ALARA planning and controls; and (2) the basis was revised to align language with
Part 20

Issue Date: 10/31/23 57 0308 Att 2

 Exhibit 33: Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems
(IPs 71124.05, 71124.06, and 71124.07)

Basis Summary Sheet

Inspectable Area: Radioactive Gaseous and Liquid Effluent Treatment and Monitoring
Systems
Cornerstone(s): Public Radiation Safety Inspection Procedure: IP 71124.05, IP
71124.06, and IP 71124.07
Scope: Inspection procedures (IPs) in this Inspectable Area verify that licensees maintain
gaseous and liquid radioactive effluent treatment systems such that radiological releases are
properly mitigated, monitored, and assessed. Inspections verify that radiological effluent
releases are controlled in accordance with license conditions and regulatory limits; that
modification of equipment used to treat or monitor effluents is properly controlled; and that
radiological effluent and meteorological monitors are accurate and reliable. Additionally,
inspections ensure certain aspects of post-accident monitoring; especially those aspects that
contribute to the declaration of emergency action levels and protective action
recommendations.

The baseline program includes a review of the Annual Radiological Effluent Release Report
to verify the effluent program is being implemented as described in the licensee’s Offsite
Dose Calculation Manual (ODCM). Specific areas of review include calibration, operation,
and modifications of the gaseous and liquid radiological effluent monitors; calibration,
operation, and modifications of the site meteorological monitoring system; and operation and
modifications to the radioactive waste treatment system. Inspections also include walk-downs
of the gaseous and liquid radioactive processing and monitoring systems to observe routine
activities, equipment condition and to verify deficiencies are corrected. Additionally,
inspectors review dose calculations for adequacy.

Basis: Inspection in this area supports the Public Radiation Safety Cornerstone.

Requirements associated with radioactive effluent treatment, monitoring and reporting are
found in license conditions, 10 CFR 50.36a, the licensee’s ODCM and Subpart D to 10 CFR
Part 20. Additionally, 10 CFR Part 20.1101(b) requires licensees to use—to the extent
practical—procedures and engineering controls to achieve doses to members of the public
that are as low as is reasonably achievable (ALARA). Per 10 CFR 50.36a(b), doses below
the design objectives contained in Appendix I to 10 CFR Part 50 are considered ALARA. As
discussed in the Federal Register (49 FR 2859), for licensees emitting direct radiation that is
indistinguishable from background radiation levels, maintaining doses from effluents below
the Appendix I design objectives demonstrates compliance with 40 CFR 190 (imposed by
10 CFR Part 20.1301(e) on NRC licensees). Licensees who have sources of direct radiation
that are above background must account for doses that result from direct radiation sources in
addition to doses from effluents when demonstrating compliance with 10 CFR
Part 20.1301(e).

Additionally, regulatory requirements associated with post-accident effluent monitoring

capability are described in Appendix E to 10 CFR Part 50 and plant-specific requirements are
reflected in licensee-specific emergency plans and procedures.

Issue Date: 10/31/23 58 0308 Att 2

 This Inspectable Area is complemented by the RETS/ODCM Radiological Effluent
Occurrence Performance Indicator (PI). The related PI is based on calculated radiation doses
to members of the public from the routine release of gaseous and liquid radioactive effluents.
However, the PIs do not monitor all aspects of radiological effluent treatment and monitoring
systems. For example, identification and mitigation of unmonitored release paths; control of
modifications to treatment and monitoring systems and proper operation, maintenance,
calibration and set point control of effluent monitoring equipment are areas that require
inspection to ensure effluent releases are properly mitigated, monitored, and assessed.

Performance Indicators: RETS/ODCM Radiological Effluent Occurrence

Significant Changes in Scope or Basis:

June 2017 – The scope was revised to more clearly identify it as the scope of the Inspectable
Area, not necessarily a specific IP attachment. Multiple attachments in IP 71124
(IP 71124.05, IP 71124.06, and IP 71124.07) are applicable to this Inspectable Area

Issue Date: 10/31/23 59 0308 Att 2

 Exhibit 34: Radiological Environmental Monitoring Program (REMP)
(IP 71124.07)

Basis Summary Sheet

Inspectable Area: Radiological Environmental Monitoring Program (REMP)

Cornerstone(s): Public Radiation Safety Inspection Procedure: IP 71124.07

Scope: Inspection procedures in this Inspectable Area ensure that Radiological

Environmental Monitoring Programs (REMPs) suitably measure and report the effects of
radioactive releases to the public and environment so that the relationship between effluents
and doses to individuals from principle pathways can be evaluated. This area focuses on the
programs licensees use to collect and process (i.e., analyze for the type and amount of
radioactive material) environmental samples, and how licensees evaluate the results of
environmental monitoring to determine the impact of plant operation on the environment.

Inspections include walk-downs of environmental sampling stations; observations of

environmental sampling and analyses; and evaluations of radiation detection and
meteorological instrumentation calibration and maintenance. Document reviews verify
environmental sampling and analyses were completed, that results are representative of the
radioactive effluent release pathways and that any problems (e.g., missed samples and/or
inoperable sampling/analyses equipment) are appropriately addressed.

Basis: The basis for effluent monitoring is described in exhibit 33. The REMP supplements
annual effluent reports required by plant technical specifications and 50.36a by comparing the
results of environmental monitoring with the effluent monitoring. The REMP is required by
radiological technical specifications and is an integral component in licensees demonstrating
compliance with the design objectives of Appendix I to 10 CFR Part 50 (as described in
section IV to Appendix I) and ultimately the public dose limits imposed by 10 CFR 20.1301(e).

The NRC has determined that an independent assessment of performance in this area is
necessary to ensure that adequate protection of the public health and safety is maintained.

Performance Indicators: There are no Performance Indicators for these areas.

Significant Changes in Scope or Basis:

June 2017 – (1) The scope was revised to more clearly identify it as the scope of the
Inspectable Area, not necessarily a specific IP, (2) the language in the scope was simplified
and revised to be consistent with 50.36a and Appendix I to 10 CFR Part 50, (3) references
were removed to the radiological material control program and the area is evaluated as
described in Exhibit 34, and (4) the basis was revised to align with language of Appendix I,
and to draw a nexus between REMP and demonstration of compliance with 10 CFR
20.1301(e)

Issue Date: 10/31/23 60 0308 Att 2

 Exhibit 35: Radioactive Material Processing and Radioactive Material
Handling, Storage, and Transportation (IP 71124.08)

Basis Summary Sheet

Inspectable Area: Radioactive Material Processing and Radioactive Material Handling,

Storage, and Transportation
Cornerstone(s): Public Radiation Safety Inspection Procedure: IP 71124.08

Scope: Inspection procedures in this area verify that appropriate administrative and physical
controls are implemented by licensees for the storage, processing and transportation of
radioactive material and radioactive waste (i.e., Class A, B, C, greater than Class C (GTCC)
and irradiated fuel shipments). Inspections verify that radioactive material storage, control,
posting, and shipping requirements are being met and that radioactive waste is characterized
and shipped in accordance with regulatory requirements. Inspectors perform walkdowns of
radioactive waste processing systems to verify that the systems are in good material
condition and that modifications are appropriately controlled. Additionally, inspectors review
and observe selected risk-significant shipping, waste characterization and classification
activities to ensure waste characterization and manifesting requirements are being met.
Additionally, inspections in this area verify that U.S. Department of Transportation (DOT) and
NRC transportation requirements are met by reviewing applicable licensee documentation.

Basis: This inspection will verify that the radioactive material processing and transportation
program comply with the requirements of 10 CFR Parts 20 and 71 and DOT regulations 49
CFR Parts 170-189. Radioactive material intended for disposal must also comply with
10 CFR 61.55 – 61.57 waste classification and stability requirements.

The regulations contain specific physical and administrative controls that provide a
defense-in-depth approach for the safe processing and transport of radioactive material,
including situations involving the breach of a loaded transport package. Although there is a
low frequency of industry events, the actual or potential consequence (i.e., significant
exposures or release of radioactive material) can be high. Therefore, the NRC has
determined that an independent assessment of performance in this area is necessary to
ensure that adequate protection of public health and safety is maintained.

Performance Indicators: There is no Performance Indicator for this area.

Significant Changes in Scope or Basis:

March 2002 -– Revised to add the requirement to review the licensee'’s audit program to
verify that it complies with the requirements of 10 CFR 20.1101(c). The base inspection hours
were increased, and a range of inspection hours was established based on actual inspection
hours during the first year of ROP implementation.

June 2017 – The scope was revised to simplify language and distinguish between material
and waste.

Issue Date: 10/31/23 61 0308 Att 2

 Exhibit 36: Discrepant or Unreported Performance Indicator Data
(IP 71150)

Basis Summary Sheet

Inspectable Area: Discrepant or Unreported Performance Indicator Data

Cornerstone(s): All Seven Inspection Procedure: IP 71150

Scope: In the absence of reliable licensee-provided performance indicator (PI) data, the NRC
inspector either independently obtains PI data or performs inspections in order to obtain
insights on licensee performance.

Basis: SECY-99-007 and this basis document describe the cornerstone attributes considered
in the development of each PI. In the absence of reliable data for a PI, the region performs
additional baseline and other inspections which cover these attributes.

As a function of the particular PI, NRC effort for independent collection of PI data may be
significantly greater than for the sampling done in PI verification, per IP 71151. Resource
estimates for NRC inspection in lieu of obtaining PI data shall be based upon the underlying
framework of the cornerstone, baseline and other inspections that could provide insights into
the cornerstone attributes, and the level of effort required to achieve the inspection objective.

Significant Changes in Scope or Basis:

September 2000 – Issued to obtain PI data when licensees fail to provide PI data, or provide
data having major discrepancies, or when NRC loses confidence in the licensee’s ability to
collect and report PIs. The IP will also utilize inspections for providing licensee performance
insights when NRC is unable to obtain reliable PI data.

March 2001 – Revised to better define the criteria of NRC losing confidence in a licensee’s
ability to collect and report performance indicators.

Issue Date: 10/31/23 62 0308 Att 2

 Exhibit 37: Performance Indicator Verification (IP 71151)

Basis Summary Sheet

Inspectable Area: Performance Indicator Verification

Cornerstone(s): All Seven Inspection Procedure: IP 71151

Scope: This item includes verification of all 17 performance indicators (PIs).

Basis: The objective of this inspection is to perform periodic reviews of PI data to determine
its accuracy and completeness. PI verification inspections should consist of a “sampling” of PI
data, not validation of the PI value.

Each performance indicator will be verified annually. The performance indicator verifications
will be planned inspections during which either a resident or regional inspector will review a
sample of plant records and data against the reported performance indicators. In addition to
the review of various plant records, the inspector may also, where applicable and as needed,
observe the plant activity that generates a PI data input. These observations can be
performed as part of the various inspectable areas within the cornerstone inspection
procedures.

A review of licensee self assessment shall not be substituted for independent inspector
verification of PIs.

Significant Changes in Scope or Basis:

March 2001 – Provided guidance for the documentation of minor PI reporting discrepancies
to be consistent with the application of 10 CFR 50.9 per the revised enforcement policy. With
a few exceptions, minor reporting discrepancies should not be documented.

January 2007 – Revised to remove Safety System Unreliability Index and add Mitigating
System Performance Index verification.

June 2007 – Replaced Unplanned Scrams with loss of Normal Heat Sink with Unplanned
Scrams with Complications.

December 2016 – Reduced inspection effort estimates by half to comply with requirements of
SRM SECY-16-009.

Issue Date: 10/31/23 63 0308 Att 2

 Exhibit 38: Problem Identification and Resolution (PI&R) (IP 71152)

Basis Summary Sheet

Inspectable Area: Problem Identification and Resolution

Cornerstone(s): All seven Inspection Procedure: IP 71152

Scope: This item will verify that the licensee has an effective problem identification and
resolution program. Problem identification and resolution refers to: (1) the deficiency reporting
process; (2) licensee self-assessments; and (3) Quality Assurance audits. Additionally, in
some plants each department may have its own problem identification and resolution
program. The focus of the inspection is on the licensee’s effectiveness in identifying,
resolving, and preventing risk significant problems.

Basis: The objective of this inspection is to ensure that the licensee effectively assesses
performance to identify and correct situations that could impact the cornerstone objectives.

An effective problem identification and resolution program is the primary means of reducing
risk by correcting deficiencies involving people (i.e., training, knowledge, and skills),
processes (i.e., procedures and programs), and equipment (i.e., design and maintenance)
before they manifest in a significant event affecting the health and safety of workers or the
public. Industry experience indicates that licensees having an effective program for identifying
and resolving problems also have a reduced frequency of events.

The inspection should verify that: (1) the licensee’s assessments of problems and issues
were of sufficient scope to address the key attributes of the cornerstone; (2) the risk
significance of the findings was properly assessed; (3) cause analyses and corrective actions
were timely and adequate to prevent recurrence; (4) industry and NRC generic issues were
considered; (5) required reports to the Commission or input to a PI were made; and (6) the
performance trend indicated by the sample set was consistent with the applicable PIs.

Additional sampling of the licensee’s performance assessment feedback loop is required if:
(1) recurrent issues or highly risk significant findings were identified; (2) adequate corrective
actions were not taken in response to a declining trend or performance above a PI threshold;
or (3) the NRC or licensee assessment results indicate risk significant findings that should
have been manifested in a negative PI trend.

An observed discrepancy between PI data and NRC or licensee findings is indication that
additional review of PRA assumptions, re-verification of applicable PIs and an assessment of
changing risk may be required.

Performance Indicators: None of the established PIs cover this area. However, some insight
may be obtained from the PIs developed for each cornerstone, which may reduce the overall
inspection effort in this area.

Significant Changes in Scope or Basis:

December 2001 – Decreased the frequency of the inspection from annual to biennial and
added the inspection of three to six PI&R samples per year. Based on experience and
lessons learned during initial implementation, it was determined that an annual team

Issue Date: 10/31/23 64 0308 Att 2

 inspection into PI&R was not necessary to gain insights into licensee performance. This was
due to the other methods available in the inspection program to assess PI&R more
frequently, and the fact that it is not likely that significant PI&R program degradations would
occur from one year to the next.

September 2003 – revised to incorporate recommendations made by the PI&R focus group to
address several items from the Davis-Besse Lessons Learned Task Force. The changes
include enhanced requirements regarding the routine PI&R reviews conducted by resident
inspectors, biennial reviews of longstanding issues, and biennial reviews of operating
experience issues.

January 2022 – Routine review moved to IMC 2515, “Plant Status” along with commitments
and bases

January 2024 – Major rewrite to incorporate recommendations from the PI&R Comprehensive
Review (ML20247J590) and commission direction in SRM-SECY-2022-0087,
“Recommendation for Problem Identification and Resolution Team Inspection Frequency,”
(ML23062A686).

Issue Date: 10/31/23 65 0308 Att 2

 Exhibit 39: Follow up of Events and Notices of Enforcement Discretion (IP 71153)

Basis Summary Sheet

Inspectable Area: Event Followup

Cornerstone(s): All Seven Inspection Procedure: IP 71153

Scope: Evaluate licensee events and degraded conditions regarding plant status and
performance of equipment/operators in order to provide input to senior management and risk
analysts in determining the need for an Incident Investigation Team (IIT), Augmented
Investigation Team (AIT), or Special Inspection (SI). Review written event reports.

Basis: In accordance with Management Directive 8.3, “NRC Incident Investigation Program,”
senior NRC management makes decisions regarding the level of investigatory response for a
significant operational event or degraded condition. These decisions are based upon
deterministic and risk criteria. On-site inspectors review plant status and equipment/operator
performance in order to provide inputs to senior management and risk analysts as required to
evaluate event/degraded condition regarding the deterministic and risk criteria.

Inspector effort for events and degraded conditions may range from minimal up to 24 hours
for significant operational events to allow the inspectors to gather sufficient information to
determine the need for an SI, AIT, or IIT per the MD 8.3 criteria. LER review may range from
1-8 hours depending on the significance and complexity of the issue documented.

Significant Changes in Scope or Basis:

April 2000 – revised to provide inspection requirements and guidance for review of event
reports

March 2001 – revised to better define the scope of the inspection procedure (IP), to expand
the definition of power reactor events to include degraded conditions, and to integrate the IP
with the options for inspection activities related to the deterministic and risk criteria in
Management Directive 8.3

January 2002 – revised to delete the previous Appendix A since that material was included in
MD 8.3 It also clarifies that written LERs are actuations, as allowed in 10 CFR 50.73.

June 2003 – revised to provide clarification that the risk metric for events is Conditional Core
Damage Probability (CCDP) and the metric for degraded conditions is incremental CCDP.
Also, this revision lists examples of events addressed by this IP in cornerstones outside of
reactor safety.

Issue Date: 10/31/23 66 0308 Att 2

 Exhibit 40: Light Water Reactor Inspection Program – Operations Phase
(IMC 2515)

Basis Summary Sheet

Title: Light-Water Reactor Inspection Program – Procedure Number: IMC 2515

Operations Phase

Scope: All commercial power reactors licensed to operate until permanently shut down, when
they enter the post-operational phase (after the certification date for removing all nuclear fuel
from the reactor vessel [10 CFR 50.82(a)(1)(ii)])

Basis: Atomic Energy Act; 10 CFR 50.70, “Inspections”

Significant Changes in Scope or Basis:

April 2000 – Rewritten to accommodate the newly implemented ROP, recognizing the
risk-informed baseline inspection program, supplemental inspections, cornerstones, and
performance indicators. Includes a discussion of ROP framework and inspection’s role in it.

January 2002 – Revised to clarify guidance for distributing inspection effort across units at
multi-unit sites and focusing efforts if no inspection opportunities area available.

January 2003 – Revised to define what constitutes a baseline inspection program completion
for an annual ROP inspection cycle.

February 2004 – Revised to reflect changes to define the inspection periodicity requirements
for biennial and triennial inspections. Revised to allow early assignment of replacement
senior and resident inspectors to a site prior to the end of the tour of the incumbent.

July 2005 – Revised to address recommendations from the Office of Inspector General'’s
audit of the NRC’s baseline inspection program:

• Provided guidance on inspection program expectation that nominal number of

samples should be inspected for each inspection procedure during a ROP cycle.

• Provided additional management guidance for assigning inspectors to perform

inspection procedures to ensure that inspectors are adequately qualified for their
assignments.

• Improved inspection guidance on whether performance of one inspection procedure

sample can be counted as a sample for another

• Clarified expectations and requirements for which inspection procedures cannot be

deferred, plants where procedures cannot be deferred, criteria for deferring a
procedure and reporting requirements when inspections are deferred

• Added a program requirement for regions to maintain an inspection tracking system

so that no more than four inspection procedures are deferred in a calendar year.

Issue Date: 10/31/23 67 0308 Att 2

 March 2017 -– Revised to add section discussing a process for “Coordination of Regional
Requests for Headquarter Staff to Participate in the Conduct of Inspection Activities.” The
intention was to document availability of a potentially less burdensome process. It was not the
intention to exclude pursuit of other existing processes.

Issue Date: 10/31/23 68 0308 Att 2

 Exhibit 41: Risk Informed Baseline Inspection Program
(IMC 2515, Appendix A)

Basis Summary Sheet

Title: Risk-Informed Baseline Inspection Program Procedure Number: IMC 2515,

Appendix A

Scope: All commercial power reactors licensed to operate until permanently shut down and
not in an extended shutdown for performance problems (IMC 0350)

Basis: Structure and scope of the program based on risk-informed decisions on what aspects
of licensed operations are important to safety and risk. Structure, original areas for inspection,
and scope of the areas are described in SECY-99-007, which formed the basis for the
inspection procedure bases documents. Scope of inspectable areas based on applicability of
any performance indicators within the area.

Significant Changes in Scope or Basis:

April 2000 – Essentially a new document for the baseline inspection program. Explains the
concept and philosophies behind the ROP and baseline inspection concepts.

September 2000 – Revised to correct the frequency listed for baseline IP 71111.11 from A/B
to Q/B, and to reflect the change in frequency for 71130.03 from biennial to triennial. No
change in hours has resulted from this change.

March 2001 – Added guidance to clarify how to close IPs with fewer samples inspected.
Explains the meaning of the cornerstone tables in the attachments to IP 71111. Other
changes included editorial changes and removing duplication with IMC 2515.

Issue Date: 10/31/23 69 0308 Att 2

 Exhibit 42: Supplemental Inspection Program
(IMC 2515, Appendix B)

Basis Summary Sheet

Title: Supplemental Inspection Program Procedure Number: IMC 2515,

Appendix B

Scope: Additional inspections required when a licensee is no longer in Column 1 of the action
matrix

Basis: The NRC’s revised inspection program includes three parts: baseline inspections;
generic safety issues and special inspections; and supplemental inspections performed as a
result of risk significant performance issues. The inspection program is designed to apply
NRC inspection assets in an increasing manner when risk significant performance issues are
identified, either by inspection findings evaluated using the significance determination
process (SDP) or when performance indicator thresholds are exceeded. Accordingly,
following the identification of an inspection finding categorized as risk significant (i.e., White,
Yellow, or Red) via the SDP, or when a performance indicator exceeds the “licensee
response band” threshold, the NRC regional office will perform supplemental inspection(s).
The scope and breadth of these inspections will be based upon the guidance provided in the
NRC’s assessment “Action Matrix” and the Supplemental Inspection Table (included in
IMC 2515 Appendix B). The supplemental inspection program is designed to support the
NRC’s goals of maintaining safety, enhancing, improving the effectiveness and efficiency of
the regulatory process, and reducing unnecessary regulatory burden.

Significant Changes in Scope or Basis:

September 2000 – revised to include newly issues IP 62708, “Motor-Operated Valve

Capability” and to delete IP 50001, “Steam Generator Replacement Inspection.” IP 50001 has
been moved to IMC 2515, Appendix C.

March 2001 – revised to include newly issued IP 62709, “Configuration Risk Assessment and
Risk Management Process.”

January 2002 – revised to include new Inspection Procedure 62710, “Power-Operated Gate
Valve Pressure Locking and Thermal Binding.”

October 2020 – major revision that established several commitments. The first commitment
was established in response to an EDO Assessment and enhanced direction regarding
supplemental inspection, the second commitment was established in response to
OIG-19-A-119, and the third commitment was established in response to
SRM-SECY-15-0108. More details can be found in the revision history table for IMC 2515,
Appendix B.

Issue Date: 10/31/23 70 0308 Att 2

 Exhibit 43: Special and Infrequently Performed Inspections
(IMC 2515, Appendix C)

Basis Summary Sheet

Title: Special and Infrequently Performed Procedure Number: IMC 2515,

Inspections Appendix C

Scope: Expected but infrequent conditions that are outside of the ROP but warrant NRC
oversight.

Basis: The ROP was based on maintaining safety during normal, routine operational
conditions, including regularly scheduled outages. Nonroutine, non-normal conditions that
can have an effect on plant conditions or performance are overseen on an ad hoc basis after
approval by the regional administrator.

Significant Changes in Scope or Basis:

April 2000 - Initial issuance of Appendix C for ROP.

September 2000 - Added three IPs that were part of the previous program and are expected
to be used infrequently in the current program: 50001, steam generator replacement; 92050,
QA for extended construction delays; and 36100, Part 21 inspections at nuclear power
reactors.

March 2001 - Added IP 60853, on-site ISFSI construction. This was added to Appendix C to
assure it is scheduled should the need arise before IMC 2690 is revised.

October 2002 - revised to list Independent Spent Fuel Storage (ISFSI) Installation inspection
procedures that are funded for NRR inspections at operating reactor sites.

December 2002 - revised to include addition of 71003, Post Approval Site Inspection for
License Renewal

February 2003 - revised to include IP 71007, “Reactor Vessel Head Replacement Inspection.”

May 2004 - revised to include Inspection Procedure for inspecting Independent Spent Fuel
Storage Installations (ISFSIs) at operating plants as well as to add Inspection Procedures
71004, “Power Uprate,” and 71005, “Inspector Review of Licensing-Related Information.”

Issue Date: 10/31/23 71 0308 Att 2

 Exhibit 44: Plant Status (IMC 2515, Appendix D)

Basis Summary Sheet

Title: Plant Status Procedure Number: IMC 2515,

Appendix D

Scope: Periodic tours of areas of the plant important to safety and observation of planning
and status meetings.
Basis: An important responsibility of the resident inspectors is to be aware of plant conditions
and activities. Plant status provides the mechanism for residents to tour areas of their
facilities and observe meetings that would otherwise be limited under the routine baseline
inspection program. Although the baseline inspection program is planned, the resident’s
portion is highly dependent on day-to-day activities in the plant. Plant status, therefore, allows
the residents to determine what is happening in the plant to better plan which inspections are
most appropriate.

The plant status activities were direct inspection under the previous program through
IP 71750, "Plant Operations." Plant status was changed from direct inspection effort to other
direct effort in the ROP because it more closely relates to inspection preparation than actual
inspection.

Plant status is also related to performance indicator verification. Because the resident
inspectors will be frequently touring various areas of the plant, it is more efficient to have the
residents periodically check certain parameters (such as locked high radiation barriers) during
plant status tours than to send an inspector into the plant for just that one purpose.
Significant Changes in Scope or Basis:

April 2000 - Initial issuance of Appendix D.

September 2003 - Revised to provide guidance to an inspector on the requirement to inform

the Materials and Chemical Engineering Branch, NRR, of steam generator tube leaks of
greater than 3 gallons per day.

May 2004 - Revised to provide guidance to ensure that the licensee properly monitors for
RCS pressure boundary leakage or potentially unidentified leakage exceeding technical
specifications limits. Additional guidance was provided to monitor licensee’s actions when the
licensee is operating within multiple or repetitive, or unplanned TS action statement entries
and to review licensee’s corrective action entry summary reports.

January 2005 - (Change Notice 05-003) IMC 2515, App. D, has been revised to require
inspectors to monitor and trend RCS leakage indications. The change requires inspectors to
review licensee procedures and action plans to identify sources of RCS unidentified leakage.
In addition, guidance and techniques necessary for assessing potential adverse trends and
action levels in response to increasing levels of RCS unidentified leakage have been
provided as an attachment to this appendix.

January 2022 – Daily PI&R review moved to this IMC from IP 71152; this is a commitment
from the Davis Besse Lessons Learned

Issue Date: 10/31/23 72 0308 Att 2

 Exhibit 45: Inspection Program Modifications During Public Health Emergencies Or
Other Conditions Restricting Inspector Onsite Presence
(IMC 2515, Appendix E)

Basis Summary Sheet

Title: Inspection Program Modifications During Procedure Number: IMC 2515,

Public Health Emergencies Or Other Conditions Appendix E
Restricting Inspector Onsite Presence

Scope: Modifications to the inspection program when conditions restrict onsite inspector
presence

Basis: During public health emergencies or other conditions impacting or restricting inspector
onsite presence, the inspection program may need to be modified to maintain oversight of
licensees. The guidance for these modifications is described in Appendix E and can be used
to maintain oversight of a nuclear facility when inspector onsite presence is impacted. While
the guidance allows for deferment of the baseline inspection program, the normally scheduled
baseline inspection program should be implemented if reasonably possible considering the
health and safety of any personnel involved.

The guidance should typically be used for situations where inspector onsite presence is
restricted due to public health emergencies or other conditions including local, state, or
federal public emergencies (e.g., flooding, hurricane, etc.). This is not necessarily an
all-inclusive list but provides examples for when the guidance may be implemented.

Significant Changes in Scope or Basis:

January 2007 – Initial Issuance of Appendix E.

March 2020 – Revisions were made to update guidance regarding reactor oversight process
inspection program modifications, resident inspector site staffing, the expanded use of
technology and other considerations to perform inspections remotely.

June 2023 – Revisions were made to incorporate recommendations from the Comprehensive
Baseline Inspection Program Review - Calendar Year 2021 and expand the scope of the IMC
to include any conditions restricting onsite inspector presence.

Issue Date: 10/31/23 73 0308 Att 2

 Exhibit 46: Supplemental Inspection Response to Action Matrix Column 2 (Regulatory
Response) Inputs (IP 95001)

Basis Summary Sheet

Title: Supplemental Inspection Response to Action Procedure Number: IP 95001

Matrix Column 2 (Regulatory Response) Inputs

Scope: This procedure provides the supplemental response for one or two White inputs in a
strategic performance area.

Basis: In order to provide for adequate protection of public health and safety, once a risk
significant performance issue is identified, the NRC needs to ensure that licensees take
actions to identify the causes of the performance issue and preclude repetition. The most
effective and efficient way for the NRC to accomplish this objective is allow the licensee the
opportunity to perform their own evaluation of the performance issue, and then perform a
review of the licensee’s evaluation. The inspection requirements contained in this procedure
represent a comprehensive set of attributes related to problem identification, root cause
analysis, and establishment of corrective actions. In order to ensure that the causes of the
performance issue are identified and that effective corrective actions are taken to prevent
recurrence, it is expected that the licensee’s evaluation will generally need to address each of
the inspection requirements; however, the depth of the licensee’s analysis may vary
depending on the significance and complexity of the issue(s). While the inspection
requirements do not necessarily represent NRC requirements for the licensee, significant
weaknesses in the licensee’s evaluation may require that the NRC conduct additional
inspections to acquire the information independently. The inspection requirements should be
independent of the specific root cause methodology chosen by the licensee.

Significant Changes in Scope or Basis:

June 2003 - revised to clarify guidance on extent of condition review and add guidance for
evaluating whether credit should be given for “old design issues.”

August 2016 - Incorporated Staff Requirements Memorandum, SECY-15-0108

“Recommendation to Revise the Definition of Degraded Cornerstone as used in the Reactor
Oversight Process” direction to revise IP 95001 to include additional resources [Increased
from “approximately 40 hours” to “approximately 40 hours to complete for one white issue
and approximately 120 hours to complete for two white issues”] and guidance to be used to
review licensee common cause analyses when a licensee has a second White input in the
same cornerstone in order to consider the potential for programmatic weaknesses in a
licensee’s performance.

October 2020 – Commitment (C3) established to update the governance for documenting
supplemental inspection in response to OIG-19-A-19. Commitment (C4) was established to
enhance direction regarding supplemental inspections as follows: (a) Highly qualified
inspectors are entrusted with the responsibility to inspect to the requirements of the
procedure, (b) Inspectors should document their assessment of how the licensee met the
inspection objectives, (c) The inspection report should clearly communicate the outcomes to
an independent reader, and (d) The inspection report’s conclusions should be explicit
regarding additional actions required by the inspectors.

Issue Date: 10/31/23 74 0308 Att 2

 Exhibit 47: Supplemental Inspection Response to Action Matrix Column 3 (Degraded
Performance) Inputs (IP 95002)

Basis Summary Sheet

Title: Supplemental Inspection Response to Action Procedure Number: IP 95002

Matrix Column 3 (Degraded Performance) Inputs

Scope: This procedure provides the supplemental response for one degraded cornerstone or
three White inputs in a strategic performance area. The inspection requirements are generally
applicable for single inspection findings, multiple inspection findings, and for performance
issues reported by PIs that might represent more than one independent event (e.g., multiple
scrams). The scope of this inspection should include all white or yellow performance issues
(inspection findings or PIs) in the associated degraded cornerstone or strategic performance
area. For example, if this procedure is being performed due to a yellow PI in the mitigating
systems cornerstone, the inspection scope should also include any white PIs or inspection
findings in that cornerstone. If the procedure is being performed due to three white PIs in the
reactor safety strategic performance area, the inspection scope should include all white PIs in
the reactor safety strategic performance area.

In the case where a performance indicator is associated with multiple events or occurrences,
or for evaluations of multiple performance issues, it is expected that the licensee’s evaluation
would address each of the events or occurrences collectively, as well as individually. In those
instances where the licensee’s evaluation was previously reviewed as part of Inspection
Procedure 95001, a re-review of the evaluation during this procedure is not required;
however, a review of the licensee’s collective evaluation for multiple performance issues
would generally need to be performed.

Basis: The inspection requirements contained in this supplemental inspection procedure

relate to the minimum set of information that the NRC will generally need to acquire in order
to assure that the causes of risk significant performance issues are identified and that
appropriate corrective actions are taken to prevent recurrence. While the inspection
requirements are generally written to address individual performance issues, the procedure
may also be utilized to assess the adequacy of licensee’s evaluations associated with
multiple performance issues. While these inspection requirements do not necessarily
represent NRC requirements for the licensee, significant weaknesses in the licensee’s
evaluation may require that the NRC conduct additional inspections to acquire the information
independently. It is recognized that the depth of the licensee’s evaluation may vary
depending on the significance and complexity of the issues. In some cases, the answers to
specific inspection requirements will be self-evident with little additional review or analysis
required by the inspectors.

This procedure also requires an independent NRC inspection to inspect the adequacy of the
licensee’s extent of condition determination. In order to accomplish this objective, the
inspection team leader should develop a customized inspection plan using the applicable
portions of the inspection procedure(s) listed in Appendix B to IMC 2515. The objective
should be to independently sample performance, as necessary to provide assurance that the
licensee’s evaluation regarding extent of condition is sufficiently comprehensive. The intent is
not to re-perform the licensee’s evaluation, but it is to assess the validity of the licensee’s

Issue Date: 10/31/23 75 0308 Att 2

 evaluation by independently sampling performance within the key attributes of the
cornerstone(s) that are related to the subject performance issue.

Significant Changes in Scope or Basis:

March 2001 - revised to provide additional guidance regarding the scope of the inspection
when multiple issues are identified within the affected cornerstone(s). It also provides
additional guidance concerning the inspection requirement to perform an independent extent
of condition review.

June 2003 - revised to clarify guidance on extent of condition review and add guidance for
evaluating whether credit should be given for “old design issues.”

Issue Date: 10/31/23 76 0308 Att 2

 Exhibit 48: Supplemental Inspection Response to Action Matrix Column 4 (Multiple/Repetitive
Degraded Cornerstone) Inputs (IP 95003)

Basis Summary Sheet

Title: Supplemental Inspection Response to Action Procedure Number: IP 95003

Matrix Column 4 (Multiple/Repetitive Degraded
Cornerstone) Inputs

Scope: This procedure provides the supplemental response for repetitive degraded
cornerstones, multiple degraded cornerstones, multiple Yellow inputs, or one Red input to the
Assessment Action Matrix.

Basis: The intent of this procedure is to provide the NRC with supplemental information
regarding licensee performance, as necessary to determine the breadth and depth of safety,
organizational, and programmatic issues. As such, this procedure is more diagnostic than
indicative, and includes reviews of programs and processes not inspected as part of the
baseline inspection program. While the procedure does allow for focus to be applied to areas
where performance issues have been previously identified, the procedure does require that
some sample reviews be performed for all key attributes of the effected strategic performance
areas. The rationale behind this is that additional NRC assurance is required to ensure public
health and safety, beyond that provided by the baseline inspection program and the
performance indicators at those facilities where significant performance issues have been
identified. The results of this inspection will aid the NRC in deciding whether additional
regulatory actions are necessary to assure public health and safety. These additional
regulatory actions could include orders, confirmatory action letters, or additional supplemental
inspections, as necessary to confirm that corrective actions to the identified performance
concerns have been effective.

Significant Changes in Scope or Basis:

January 2002 - revised to incorporate lessons learned from the Indian Point Unit 2
inspections, and adds a section on security, which was not included in the initial version of
this procedure. IP 95003.01 (Emergency Preparedness) inspection procedure was revised to
reflect lessons learned from Indian Point 2 inspections.

Issue Date: 10/31/23 77 0308 Att 2

 Exhibit 49: Special Inspection (IP 93812)

Basis Summary Sheet

Title: Special Inspection Procedure Number: IP 93812

Scope: Provides implementing procedures for Special Inspection (SI) responses to

operational events and degraded conditions at power reactor facilities.

Basis: In accordance with Management Directive 8.3, "NRC Incident Investigation Program",
significant operational power reactor events and degraded conditions meeting specific
deterministic criteria are evaluated for risk based on conditional core damage probability
(CCDP) in order to determine the level of investigatory response. An SI is considered where
CCDP is between 10-4 and 10-6. Resources for an SI are less than for an Augmented
Inspection Team (AIT) in that they are less in team size and not augmented with resources
external to the region. Special Inspections were developed to provide an additional level of
Agency response for those events where some level of follow-up above the baseline effort is
appropriate, but the significance of the event or degraded condition does not warrant the
resources of an AIT.

Significant Changes in Scope or Basis:

March 2001 - revised to provide consistency with Management Directive (MD) 8.3, “NRC
Incident Investigation Program,” and to provide guidance on preliminary notifications.

October 2002 - revised to provide guidance on documenting information relating to events

that is in addition to that currently required by IMC 0612, “Power Reactor Inspection Reports,”
such as description/chronology, risk-significance, and probable contributing causes.

July 2003 - revised to reflect revision to MD 8.3 and to delete the prohibition for Special
Inspections to review licensee actions related to plant restart.

Issue Date: 10/31/23 78 0308 Att 2

 Exhibit 50: Oversight of Reactor Facilities in a Shutdown Condition Due to Significant
Performance and/or Operational Concerns (IMC 0350)

Basis Summary Sheet

Inspectable Area: Oversight of Reactor Procedure Number: IMC 0350

Facilities in a Shutdown Condition Due to
Significant Performance and/or Operational
Concerns

Scope: This manual chapter will provide regulatory oversight for NRC actions and activities
when a plant has been shut down for performance problems and/or after a significant event.
This oversight will include shutdown, resolution of risk-significant issues and identification of
root causes prior to restart, as well as oversight for a period of time after restart. During such
time as a licensee may be under this manual chapter guidance, the normal revised oversight
process is suspended.

Basis: IMC 0350 was revised to incorporate a number of risk-informed insights and new ROP
regulatory guidance and policy. The first area of change was to establish risk-informed criteria
for entry into this IMC. The entry conditions of this IMC requires as a prerequisite that a
licensee’s performance be commensurate with the multiple/repetitive degraded cornerstone
column of the Action Matrix, as defined by IMC 0305, “Operating Reactor Assessment
Program,” and/or be a result of a risk-significant plant event.

The second area to be risk-informed was to provide regulatory oversight of risk significant
issues, identification of their root causes, and identification of the extent of condition related to
these root causes once a licensee is under the IMC 0350 process. This approach aids the
staff to focus on the risk-significant issues and their root causes, wherever they originate,
while increasing the efficiency and effectiveness of the regulatory oversight by not expending
resources where there is little or no risk impact.

The third major area of enhancement is establishing criteria for exiting the IMC 0350 process.
The length of time of post-restart oversight may vary, depending on licensee performance
and resolution of identified problems, in order to reestablish applicable reliable PIs and to
allow the staff to assess licensee performance before a return to the routine oversight
process is warranted.

Significant Changes and Basis:

March 1990 - Inspection Manual Chapter 0350 issued to codify the EDO’s directives on the
actions necessary to authorize the restart of nuclear power plant that is shut down due to
significant operational or management deficiencies. The IMC incorporates lessons learned
from recent restart reviews and comments from a GAO report issued on June 6, 1989,
entitled “NRC’s Restart Actions Appear Reasonable - But Criteria Needed.”

January 1993 - revised in response to the EDO memorandum of November 23, 1992, to the
Commission, “Corrective Action Plan for Turkey Point Lessons Learned.” The revision
incorporates a comprehensive restart checklist (Appendix A) to be used in developing a
plant-specific restart checklist.

Issue Date: 10/31/23 79 0308 Att 2

 September 1993 - revised in response to the July 28, 1993, memorandum, “Review of NRC’s
Restart Review Process,” from the Office of the EDO to the Office of the Inspector General.
This revision incorporates requirements for tracking and documenting the resolution of restart
issues.

April 1997 - revised to incorporate objective and measurable acceptance criteria for
evaluating the effectiveness of licensee’s corrective action plans for restart approval and to
further emphasize the importance that the restart issues be clearly defined and
communicated to the licensee.

December 1997 - revised to address new applicants for operator licenses while a plant is in
an extended shutdown requiring restart approval.

March 2000 - revised to incorporate policy and guidance relating to the revised reactor
oversight process (ROP).

March 2001 - IMC 0350 was revised to add clarity to the entry conditions for implementing
this IMC stating that as a prerequisite, a regulatory hold would be in effect, such as a
Confirmatory Action Letter or an Order, prior to implementing this manual chapter. An
additional change included clarification to encourage the continued collection of PI data
throughout the shutdown and implementation of the IMC 0350 process, if practical.

December 2003 - revised to provide comprehensive correlation between aspects of the ROP
and the IMC 0350 process, to provide an enhanced structure to the inspection approach for
IMC 0350 plants, and to incorporate other lessons learned and clarifications.

Issue Date: 10/31/23 80 0308 Att 2

 Table 1: Inspectable Areas by Cornerstone

Occupational Public
Initiating Mitigating Barrier Emergency
Radiation Radiation
Inspectable Area Events Systems Integrity Preparedness
Safety Safety
Access control to radiologically significant areas X
Adverse weather protection X X
ALARA planning and controls X
Alert and notification system testing X
Drill evaluation X
Emergency response organization augmentation
testing X
Emergency action level and emergency plan
changes X
Equipment alignment X X X
Evaluations of changes, tests, or experiments X X X
Exercise evaluation X
Fire protection X X
Flood protection measures X X
Heat sink performance X X
Identification and resolution of problems X X X X X X
Inservice inspection activities X X
Licensed operator requalification X X

Issue Date: 10/31/23 81 0308 Att 2

Table 1 Inspectable Areas by Cornerstone (continued)
Occupational Public
Initiating Mitigating Barrier Emergency
Inspectable Area Radiation Radiation
Events Systems Integrity Preparedness
Safety Safety
Maintenance risk assessments and emergent work
X X X
control
Maintenance effectiveness X X X
Operability evaluations and functionality
X X
assessments
Post maintenance testing X X
Plant modifications X X X
Radiation monitoring instrumentation X
Radiation worker performance X
Radioactive material processing and transportation X
Radioactive Gaseous and liquid effluent treatment
X
and monitoring systems

Radiological environmental monitoring program X

Refueling and outage activities X X X
Safety system design and performance capability X
Surveillance testing X X
Testing and Maintenance of Equipment Important to
X X
Risk

Issue Date: 10/31/23 82 0308 Att 2

 Table 2: Other Inspection Program Elements Considered But Not Included

Inspectable Area or Basis for Not Including in Baseline

Program Attribute Cornerstone Scope Inspection Program
Piping System Initiating Events Equipment performance, detecting and Reactor coolant system piping
Erosion/Corrosion correcting component degradation generally isn't subject to
erosion/corrosion because of the
materials used, water chemistry
control, and the general absence of
two-phase (water/steam) mixtures.
Balance of plant steam piping is
subject to erosion/corrosion.
However, because they are
balance of plant (BOP) systems,
there would be little risk impact to
the reactor core. The primary
concern for erosion/corrosion in
BOP systems is personnel safety
rather than reactor safety.
Additionally, significance failures
would be tracked by performance
indicators such as unplanned
shutdowns. Mitigating systems are
sometimes subject to
erosion/corrosion. However, that
particular aspect of a system can
be reviewed under the safety
system design inspection
procedure.
Pre-Job Briefs Initiating Events Human performance Covered by PI’s (transients,
scrams, SSU)
Operating Initiating Events Design. Sources of experience including NRC Considered covered by PI’s
Experience Review Mitigating Systems bulletins, notices, generic letters, vendor (transients, scrams, SSU)
reports, and Part 21 notifications. design-related inspections
Operator Shift Initiating Events Configuration control, effectiveness of Covered by PI’s (transients,
Turnovers Mitigating Systems communications between operating shifts. scrams)

Issue Date: 10/31/23 83 0308 Att 2

 Inspectable Area or Basis for Not Including in Baseline
Program Attribute Cornerstone Scope Inspection Program
Testing of Pumps Initiating Events Inspection activities in this area would be Incorporated into IP 71111.22,
and Valves Mitigating Systems focused on the effectiveness of the licensee’s “Surveillance Testing”
program for testing of pumps and valves as
required by ASME Section XI. Inspection
activities in this area would include a review of
test procedure adequacy, testing methodology,
equipment trend results and observations of
selected pump performance testing, valve
stroke time testing, relief valve setpoint testing,
and check valve testing.
Spent Fuel Cooling Mitigating Systems Structure, systems, and components associated A separate inspection procedure
with handling, and providing cooling for, spent for spent fuel cooling systems or
fuel assemblies. fuel movement was not developed
because the baseline inspection
program is primarily based on the
risk associated with reactor core
damage when the reactor fuel is in
the reactor vessel. However, the
baseline inspection procedure for
refueling and outage activities does
include spent fuel handling and
operation of spent fuel pool cooling
systems. The guidance in the
procedure includes verifying
availability of equipment and
procedures for recovery if spent
fuel cooling is lost.

Issue Date: 10/31/23 84 0308 Att 2

 Inspectable Area or Basis for Not Including in Baseline
Program Attribute Cornerstone Scope Inspection Program
Motor-Operated Mitigating Systems The NRC has been inspecting licensees’ A separate inspection procedure
Valves (MOVs) programs for assuring proper performance of for MOVs was not necessary since
MOVs through Temporary Instruction 2515/109 the baseline inspection program
since 1989. The latest revision of the temporary provides opportunities to inspect
instruction includes verifying that licensees are MOVs through several inspectable
trending valve performance and closing areas such as safety system
previously identified issues. design and performance capability,
permanent plant modifications, and
surveillance testing. Also, the
baseline inspection program places
an emphasis on continual
assessment of a licensees’
corrective action programs, which
would include problems found
during the implementation of their
programs for MOVs.
Equipment Mitigating Systems Equipment performance and configuration Covered by PIs (transients,
Switching and control scrams, SSU)
Tagging
Large Containment Barrier Integrity Inspection activities in this area would be Incorporated into IP 71111.22,
Isolation Valve focused on the adequacy of the licensee’s “Surveillance Testing”
Leak Rate and testing program for large containment isolation
Status Verification valves that provide a direct flow path from the
containment atmosphere to outside
containment. At most facilities, the inspection
scope would be limited to the containment
purge and ventilation valves and personnel
access hatches. Inspection activities related to
leak rate testing for most of the containment
isolation valves and/or containment Integrity
issues would be captured by the corrective
action program inspection activities.

Issue Date: 10/31/23 85 0308 Att 2

 Inspectable Area or Basis for Not Including in Baseline
Program Attribute Cornerstone Scope Inspection Program
Fuel Barrier Barrier Integrity Inspection includes verification of operation of A performance indicator is
Performance the licensee’s capability and performance of provided for RCS activity.
in-plant radio-chemical analyses of the reactor
coolant system (RCS). Inspection of fuel
cladding radio-chemistry analysis performance
will provide assurance that the first barrier
against release of radioactivity to the
environment is maintained. Failure of fuel
cladding would increase the radiation dose to
workers and potentially to members of the
public.
EP Training Emergency Inspect training program for adequacy, changes Two PI’s, DEP and ERO, address
Program Preparedness and the knowledge level and qualifications of this area and therefore a baseline
ERO members. Emergency Preparedness is inspection is not required.
the final barrier in the “defense in depth” NRC
regulations provide for ensuring the public
health and safety. The training program must
ensure that ERO members are adequately
prepared to perform their assigned EP duties.
The ERO members must be qualified to perform
their assigned duties.
Radiation Worker Occupational and The objective of this area is to verify that Worker performance is a cross
Performance Public Rad Safety workers understand the radiological hazards cutting area. Since the PIs are
associated with nuclear plant operation, performance based, problems in
effectively identify and control these hazards, this area should result in an
identify and resolve adverse trends or operational occurrence that meets
deficiencies, and maintain proper oversight of the definition of a PI.
work.

Issue Date: 10/31/23 86 0308 Att 2

 Attachment 1: Revision History for IMC 0308 Attachment 2

Commitment Accession Description of Change Description of Comment Resolution and

Tracking Number Training Required Closed Feedback Form
Number Issue Date and Completion Accession Number
Change Notice Date (Pre-Decisional, Non-
Public Information)
N/A ML042100185 Initial Issuance N/A N/A
7/27/04
CN 04-020
N/A ML050410043 Revised to reflect IMC / IP revisions. N/A N/A
1/26/05
N/A ML052100182 Minor revision to section 3 discussion on event N/A N/A
7/28/05 follow-up.
CN 05-022
N/A ML062890421 This IMC has been revised to incorporate comments N/A N/A
10/16/06 from the Commission in which the term public
CN 06-027 confidence has been change to openness
N/A ML17114A050 This IMC is being revised to reflect changes to IMCs N/A ML17156A217
01/05/18 / IPs since last revision and address open feedback 0308.2-1930
CN 18-001 forms. ML17178A051
ML19056A200 This IMC is being revised to reflect significant N/A ML18179A038
N/A 05/29/19 changes to IMCs / IPs since last revision. ML18179A039
CN 19-017
N/A ML23214A382 This IMC is being revised to reflect significant N/A ML23222A179
10/31/23 changes to IMCs / IPs since last revision.
CN 23-032

Issue Date: 10/31/23 Att1-1 0308 Att 2