ML18047A127

IMC 1245 Appendix C2 Reactor Engineering Inspector Technical Proficiency Training and Qualification Journal

ML18047A127
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Issue date:	08/23/2018
From:	Alexander Schwab NRC/NRR/DIRS/IRGB
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CN 18-029, DC 18-011
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NRC INSPECTION MANUAL IRGB INSPECTION MANUAL CHAPTER 1245, APPENDIX C2 REACTOR ENGINEERING INSPECTOR TECHNICAL PROFICIENCY TRAINING AND QUALIFICATION JOURNAL Effective Date: 08/23/2018

Table of Contents Introduction ................................................................................................................................ 1 Required Reactor Engineering Inspector Training Courses ........................................................ 1 Post-Qualification and Refresher Training Requirements ........................................................... 1 Engineering Individual Study Guide ........................................................................................... 2 (ISA-ENG-1) Component Design Bases Inspection ........................................................ 3 (ISA-ENG-2) The NRCs Review of Temporary and Permanent Plant Modifications....... 6 (ISA-ENG-3) Evaluations of Changes, Tests, and Experiments (10 CFR 50.59) ............ 8 (ISA-ENG-4) Basic Codes, Standards, and Regulatory Guides for Engineering Support..........................................................................................................................10 (ISA-ENG-5) Significance Determination Process Reactor Inspection Findings for At-Power Situations .......................................................................................................19 (ISA-ENG-6) Maintenance Rule.....................................................................................26 Engineering On-the-Job Activity ................................................................................................28 (OJT-ENG-1) Component Design Bases Inspection ......................................................29 (OJT-ENG-2) Permanent Plant Modifications ................................................................32 (OJT-ENG-3) Inspection of Licensee Changes, Tests, and Experiments (10 CFR 50.59)..............................................................................................................35 (OJT-ENG-4) Security Plan and Implementation ...........................................................37 (OJT-ENG-5) Radiation Protection Program and Implementation ..................................39 Reactor Engineering Technical Proficiency-Level Signature Card and Certification ..................41 Form 1: Reactor Engineering Technical Proficiency-Level Equivalency Justification ................42 : Revision History Sheet ................................................................................ Att1-1 Issue Date: 08/23/18 i 1245 Appendix C2

Introduction Completion of IMC 1245, Appendix A is recommended before beginning activities or courses in this standard, but the trainees branch chief can override this recommendation based on the trainees experience. You may complete the General Proficiency requirements contained in Appendix B together with the Technical Proficiency requirements outlined in this journal.

Before signing up for any course, be sure that you have checked and have met any prerequisites.

Required Reactor Engineering Inspector Training Courses The following courses require completion of Appendix A as a prerequisite:

Reactor Full Series (either boiling-water reactor (BWR) or pressurized-water reactor (PWR))

- BWR Series = R-304B, R-504B, and R-624B or

- PWR Series = R-304P, R-504P, and R-624P Basic Reactor Operations for alternate reactor type

- R-104P, if you completed the BWR series

- R-104B, if you completed the PWR series The following courses DO NOT require the completion of Appendix A:

Power Plant Engineering (E-110) (course or self-study) 10 CFR 50.59 Refresher Training (course 254144 in iLearn) as part of ISA-3 Post-Qualification and Refresher Training Requirements This section has been moved to Appendix D1.

Issue Date: 08/23/18 1 1245 Appendix C2

Engineering Individual Study Guide Issue Date: 08/23/18 2 1245 Appendix C2

Engineering Individual Study Guide TOPIC: (ISA-ENG-1) Component Design Bases Inspection PURPOSE: The purpose of this guide is to acquaint you with the actions taken by the NRC in the review of risk-significant components to verify their initial design and subsequent modifications to determine their capability to perform their intended safety function(s) and to discover any performance issues that hinder that capability. Additional actions include the review of operating experience and its effect on risk- significant components if not adequately assessed for its potential effect and how operator actions required by the plants design analysis are implemented into plant procedures. As a reactor engineering inspector, you will be required to understand how the inability of one or more components to perform as intended affects its associated system and causes increased risk for core damage and increased likelihood that the plants inherent redundancy may not be able to mitigate the loss of the safety functions of those components. In addition, you will understand that operating experience, based on the lessons learned at other facilities, need to be adequately assessed for similar potential affects at the inspected plant and the importance of ensuring the plants design analysis is properly translated into plant operating procedures.

COMPETENCY AREA: INSPECTION LEVEL OF EFFORT: 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />

REFERENCES:

1. Inspection Procedure (IP) 71111.21, Component Design Bases Inspection

2. NUREG-1275, Volume 14, Causes and Significance of Design-Based Issues at U.S. Nuclear Power Plants

3. NUREG/CR-5640, Overview and Comparison of U.S. Commercial Nuclear Power Plants

4. Regulatory Guide (RG) 1.186, Guidance and Examples for Identifying 10 CFR 50.2 Design Basis, December 2000 (ADAMS Accession No. ML003754825)

5. Nuclear Energy Institute (NEI) 97-04, Design Basis Program Guidelines, Appendix B (ADAMS Accession No. ML003771698)

Issue Date: 08/23/18 3 1245 Appendix C2

6. 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, Appendix A, General Design Criteria for Nuclear Power Plants

7. Inspection Manual Chapter (IMC) 2515

8. Part 9900 10 CFR Guidance, 10 CFR 50.59 Changes, Tests, and Experiments

9. NRC staff safety evaluation report for a specific plant for the original operating license

10. NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants EVALUATION CRITERIA: Upon completion of the tasks in this guide, you will be asked to demonstrate your understanding of the NRCs periodic review of a sample of components, operator actions, and operating experience at a given nuclear power plant and the NRCs continuing role in determining design and engineering performance deficiencies that impact a licensees quality assurance program by performing the following:

1. State the NRCs inspection objectives for the reviews of samples of components, operator actions, and operating experience on a periodic basis and the reason for their importance.

2. Discuss the purpose of a component design bases inspection (CDBI) in terms of the following:

a. overall objective for each inspection

b. number of inspectors and their areas of expertise

c. duration of each inspection and the allocated resources

d. how the inspection is risk informed

3. State the basis for selecting components, operating experience, and operator actions for a CDBI and the various methods for that selection process. Emphasize some measure that can analytically determine or approximate the loss of a safety function.

4. Define the following terms and state how samples of each are developed and assembled/paired with others for review.

a. inspection attributes

b. system needs

c. component condition and capability

d. operating experience

e. component inspection activity

f. risk significant operator actions Issue Date: 08/23/18 4 1245 Appendix C2

5. Define the contribution of each of the following documents to a CDBI and the benefit of each in determining the functional capability of one or more components and operator actions:

a. design-basis documents

b. licensing-basis documents

c. calculations and analyses

d. technical specifications

e. design changes and modifications

f. operator training manual

g. maintenance procedures

h. surveillance and inservice test procedure results

i. applicable vendor manuals

j. generic communications (information notices, bulletins, and generic letters)

k. normal, abnormal, and emergency operating procedures

6. For the listed documents in the previous question, state how each provides insights into the assessment of a licensees quality assurance program, at a minimum with regard to the design and functional capability of safety components.

7. Develop a list of attributes that addresses the functional and operational capability of a selected component. For operator actions, develop a plan as to how a selected action will be assessed.

8. Define the Reactor Oversight Program cornerstones that are verified by the reviews of components, operating experience, and operator actions via a CDBI.

TASKS: 1. Read the references in sufficient detail to perform adequately in accordance with the requirements of the evaluation criteria.

2. Meet with your supervisor, or the person designated to be your resource for this activity, and discuss the answers to the questions listed under the evaluation criteria.

DOCUMENTATION: Engineering Proficiency-Level Qualification Signature Card Item ISA-ENG-1 Issue Date: 08/23/18 5 1245 Appendix C2

Engineering Individual Study Guide TOPIC: (ISA-ENG-2) The NRCs Review of Temporary and Permanent Plant Modifications PURPOSE: The purpose of this activity is to acquaint you with the actions taken by the NRC in the review of both temporary and permanent plant modifications of power reactor facilities. As a reactor engineering inspector, you will be required to understand how design changes resulting in hardware modifications or different operating requirements of a facility can potentially impact the plants design and licensing basis, as well as the performance capability of structures, systems, and components.

COMPETENCY AREAS: INSPECTION LEVEL OF EFFORT: 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />

REFERENCES:

1. NUREG-1397, An Assessment of Design Control Practices and Design Reconstitution Programs in the Nuclear Power Industry

2. NEI 96-07, Revision 1, Guidelines for 10 CFR 50.59 Implementation

3. IP 71111.17, Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications

4. IP 71111.18, Plant Modifications EVALUATION CRITERIA: Upon completion of the tasks in this guide, you will be asked to demonstrate your understanding of permanent and temporary plant modifications and the NRCs continuing role in monitoring design changes to power reactor facilities through the review of these types of modifications by successfully performing the following:

1. State the NRCs inspection objectives for the reviews of both permanent and temporary plant modifications and indicate why they are important.

2. Discuss the typical format of both permanent and temporary modifications (including the major sections and the purpose of each).

3. Discuss how licensees control modifications both before and after implementation, including affected design documents and plant procedures.

Issue Date: 08/23/18 6 1245 Appendix C2

4. Define the following terms:

a. configuration management

b. current licensing basis

c. design

d. design basis

e. design-basis document

f. design change

g. design control

h. design margin

i. design output

j. engineering design bases

k. essential design documents

l. fully documented and auditable design

5. Justify why the NRC is concerned about agreement between the design change of a modification and the safety evaluation contained in the modification package. Be able to address the outside design basis and requirements for a license amendment for a design change.

6. State at least five of the types of changes that comprise the category permanent plant modifications and the reason for the inclusion of each one.

7. State at least five of the types of changes that comprise the category temporary plant modifications and the reason for the inclusion of each one.

8. State which Reactor Oversight Program cornerstones are verified by the independent reviews of permanent and temporary plant modifications.

9. List the following:

a. types of design documents that may be affected by modifications

b. types of plant procedures that could be affected by modifications TASKS: 1. Read the references in sufficient detail to perform adequately in accordance with the requirements of the evaluation criteria.

2. Meet with your supervisor, or the person designated to be your resource for this activity, and discuss the answers to the questions listed under the evaluation criteria.

DOCUMENTATION: Engineering Proficiency-Level Qualification Signature Card Item ISA-ENG-2 Issue Date: 08/23/18 7 1245 Appendix C2

Engineering Individual Study Activity TOPIC: (ISA-ENG-3) Evaluations of Changes, Tests, and Experiments (10 CFR 50.59)

PURPOSE: The purpose of this activity is to acquaint you with how to review safety evaluations that are used to determine if the power reactor facility change, test, or experiment requires NRC approval before implementation. As a reactor engineering inspector, you will be required to understand how design changes resulting in hardware modifications or different operating requirements of a facility can potentially impact the plants design and licensing basis, as well as the performance capability of safety systems and components.

The purpose of this activity is to do the following:

1. Familiarize you with the NRC regulations governing changes, tests, and experiments for commercial nuclear power facilities.

2. Enable you to demonstrate an ability to conduct an inspection under 10 CFR 50.59, Changes, Tests, and Experiments, in accordance with IP 71111.17.

COMPETENCY AREA: INSPECTION LEVEL OF EFFORT: 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

REFERENCES:

1. 10 CFR 50.59, Changes, Tests, and Experiments

2. RG 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, November 2000

3. NEI 96-07, Revision 1, Guidelines for 10 CFR 50.59 Implementation

4. Inspection Manual Part 9900, 10 CFR Guidance 50.59.CFR

5. Regulatory Issue Summary (RIS) 2001-03, Changes, Tests, and Experiments

6. RIS 2001-09, Control of Hazard Barriers (guidance on the applicability of 10 CFR 50.59 to barriers)

7. Current regional or office guidance for processing potential violations of 10 CFR 50.59 Issue Date: 08/23/18 8 1245 Appendix C2

8. IP 71111.17, Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications

9. IP 71152, Identification and Resolution of Problems

10. IP 71111.15, Operability Determinations and Functionality Assessments

11. NEI 97-04, Revised Appendix B, Guidance and Examples for Identifying 10 CFR 50.2 Design Bases EVALUATION CRITERIA: At the completion of this activity, you should be able to do the following:

1. State the criteria for when the licensee may make changes to the facility or procedures or perform tests or experiments without obtaining prior NRC approval. Identify the process owner in NRR.

2. State the meaning of key terms used in this regulation: updated final safety analysis report (UFSAR), changes, facility, procedures, tests, and experiments.

3. Describe when provision 10 CFR 50.65(a)(4) of the Maintenance Rule should be used instead of 10 CFR 50.59.

4. Describe the applicable NRC regulation governing when a licensee may make changes to the fire protection program of a facility.

TASKS: 1. Review the references listed above.

2. Review at least three recently documented examples of violations of 10 CFR 50.59.

3. Meet with your supervisor and demonstrate your understanding of 10 CFR 50.59, including your ability to satisfy the above evaluation criteria.

4. Evaluate example changes, tests, or experiments to determine whether the licensee may perform them without prior NRC approval and evaluate the example changes for their effect on operability.

5. Draft a notice of violation against 10 CFR 50.59.

6. Complete training on 10 CFR 50.59, course 254144 in iLearn.

DOCUMENTATION: Engineering Proficiency-Level Qualification Signature Card Item ISA-ENG-3 Issue Date: 08/23/18 9 1245 Appendix C2

Engineering Individual Study Activity TOPIC: (ISA-ENG-4) Basic Codes, Standards, and Regulatory Guides for Engineering Support PURPOSE: The purpose of this activity is to provide you with very fundamental knowledge of the basic NRC codes, RGs, and associated industry standards commonly used by engineering inspectors. This activity will also acquaint you with the requirements (codes), guidelines (RGs), and accepted methodologies (industry standards) for licensees to use in accomplishing various safety-related activities. Finally, this activity will prepare you to determine an individual licensees commitment to RGs and standards.

COMPETENCY AREA: INSPECTION LEVEL OF EFFORT: 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />

REFERENCES:

See attached listings of general and discipline-related references.

EVALUATION CRITERIA: At the completion of this activity, you should be able to do the following:

1. State the general code sections commonly used by engineering inspectors and discuss the topics included in these sections.

2. Discuss the relationship between RGs and industry standards.

3. Identify the RGs and associated industry standards that address the quality assurance criteria in Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50.

4. Discuss the topics included in the RGs and industry standards associated with your engineering discipline.

5. Discuss the application of these references to engineering inspection activities.

TASKS: 1. Read Appendix B to 10 CFR Part 50 and review a selected licensees quality assurance manual. Review a sample of licensee implementing procedures (such as those associated with engineering inspections, design control and corrective action) in accordance with an evaluation criterion to explain how a typical licensee meets the requirements.

Issue Date: 08/23/18 10 1245 Appendix C2

2. Review the references in the attached list of general references as well as those listed for your specific discipline.

3. Locate the listing of RGs on the NRC external Web page.

4. Review a plant-specific UFSAR to identify the licensees commitments to particular RGs and standards.

5. Discuss with experienced inspectors any questions you have concerning the topics of the references or their application to inspection activities.

6. Meet with your supervisor to demonstrate your familiarity with the applicable references and discuss the applications of these references to engineering inspection activities.

DOCUMENTATION: Engineering Proficiency-Level Qualification Signature Card Item ISA-ENG-4 Issue Date: 08/23/18 11 1245 Appendix C2

REFERENCES FOR ISA-ENG-4 General 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, Appendix A, General Design Criteria for Nuclear Power Plants 10 CFR Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants 10 CFR 50.46, Acceptance Criteria for Emergency Core Cooling Systems for Light-Water Nuclear Power Reactors 10 CFR 50.49, Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants 10 CFR 50.55a, Codes and Standards 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants RGs American National Standards (Appendix B to 10 CFR Part 50) Institute (ANSI) Standards 1.28 ASME NQA-1 1.33 ANSI 18.1 1.37 ANSI N45.1 1.38 ANSI N45.2.2B1972 1.39 ANSI N45.2.3 1.30 ANSI N45.2.4 1.94 ANSI N45.2.5 1.116 ANSI N45.2.8 1.54 ANSI N101.4 ANSI/American Nuclear Society (ANS) 58.14, Safety and Pressure Integrity Classification Criteria for LWR RG 1.26, Quality Group Classifications and Standards for Water-, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants RG 1.29, Seismic Design Classification RG 1.100, Seismic Qualification of Electrical and Mechanical Equipment for Nuclear Power Plants RG 1.155, Station Blackout RG 1.186, Guidance and Examples for Identifying 10 CFR 50.2 Design Bases (ADAMS Accession No. ML003754825)

Issue Date: 08/23/18 12 1245 Appendix C2

NEI 97-04, Design Basis Program Guidelines, Appendix B (ADAMS Accession No. ML003771698)

Electrical RG 1.6, Independence Between Redundant Standby (Onsite) Power Sources and Between Their Distribution Systems (ADAMS Accession No. ML0037739924)

RG 1.30, Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment (Safety Guide 30) (ANSI N45.2.4/Institute of Electrical and Electronics Engineers (IEEE) 336)

RG 1.32, Criteria for Safety-Related Electric Power Systems for Nuclear Power Plants (IEEE 308)

RG 1.40, Qualification Tests of Continuous-Duty Motors Installed Inside the Containment of Water-Cooled Nuclear Power Plants (IEEE 334)

RG 1.47, Bypassed and Inoperable Status Indication for Nuclear Power Plant Safety Systems RG 1.53, Application of the Single-Failure Criterion to Nuclear Power Plant Protection Systems (IEEE 279 and IEEE 379)

RG 1.63, Electric Penetration Assemblies in Containment Structures for Light-Water-Cooled Nuclear Power Plants (IEEE 317)

RG 1.73, Qualification Tests of Electric Valve Operators Installed Inside the Containment of Nuclear Power Plants RG 1.75, Physical Independence of Electric Systems (IEEE 384)

RG 1.81, Shared Emergency and Shutdown Electric Systems for Multi-Unit Nuclear Power Plants RG 1.89, Qualification of Class 1E Equipment for Nuclear Power Plants (IEEE 323)

RG 1.106, Thermal Overload Protection for Electric Motors on Motor-Operated Valves RG 1.128, Installation Design and Installation of Large Lead Storage Batteries for Nuclear Power Plants (IEEE 484)

RG 1.129, Maintenance, Testing, and Replacement of Large Lead Storage Batteries for Nuclear Power Plants (IEEE 450)

RG 1.131, Qualification Tests of Electric Cables, Field Splices, and Connections for Light-Water-Cooled Nuclear Power Plants (IEEE 383)

RG 1.180, Guidelines for Evaluating Electromagnetic and Radio-Frequency Interference in Safety-Related Instrumentation and Control Systems Issue Date: 08/23/18 13 1245 Appendix C2

Instrumentation and Control RG 1.11, Instrument Lines Penetrating Primary Containment RG 1.12, Instrumentation for Earthquakes RG 1.30, Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment (ANSI N45.2.4/IEEE 336)

RG 1.32, Criteria for Safety-Related Electric Power Systems for Nuclear Power Plants (IEEE 308)

RG 1.47, Bypassed and Inoperable Status Indication for Nuclear Power Plant Safety Systems RG 1.53, Application of the Single-Failure Criterion to Nuclear Power Plant Protection Systems (IEEE 279 and IEEE 379)

RG 1.62, Manual Initiation of Protective Actions RG 1.63, Electric Penetration Assemblies in Containment Structures for Light-Water-Cooled Nuclear Power Plants (IEEE 317)

RG 1.75, Physical Independence of Electric Systems (IEEE 384)

RG 1.89, Qualification of Class 1E Equipment for Nuclear Power Plants (IEEE 323)

RG 1.97, Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident RG 1.105, Instrument Set Points (Instrument Society of America (ISA) S67.04)

RG 1.151, Instrument Sensing Lines (ISA S67.02)

Electric Power Research Institute (EPRI) TR-102348, Guideline on Licensing Digital Upgrades (ADAMS Accession No. ML02080169)

IEEE 7-4.3.2-1993, IEEE Standard Criteria for Digital Computers in Safety Systems of Nuclear Power Generating Stations IEEE 1050-1996, Guide for Instrument and Control Equipment Grounding in Generating Stations IEEE 338-1987, IEEE Standard Criteria for Periodic Testing of Nuclear Power Generating Station Class 1E Power and Protection Systems Mechanical RG 1.1, NPSH for ECCS & Containment Heat Removal System Pumps (Safety Guide 1)

Issue Date: 08/23/18 14 1245 Appendix C2

RG 1.9, Design, Qualification & Testing of Emergency Diesel Generator Units Used as Class 1E Onsite Electric Power Systems at Nuclear Power Plants RG 1.26, Quality Group Classifications and Standards for Water, Steam, and Radioactive Waste Containing Components of Nuclear Power Plants RG 1.27, Ultimate Heat Sink for Nuclear Power Plants RG 1.82, Water Sources for Long-Term Recirculation Cooling Following a Loss-of-Coolant Accident RG 1.84, Design, Fabrication, and Materials Code Case Acceptability, ASME Section III RG 1.85, Materials Code Case AcceptabilityASME Section III, Division 1 (incorporated into RG 1.84)

RG 1.102, Flood Protection for Nuclear Power Plants RG 1.116, QA Requirements for Installation, Inspection and Testing of Mechanical Equipment and Systems RG 1.137, Fuel Oil Systems for Standby Diesel Generators RG 1.140, Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Normal Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants RG 1.147, Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1 RG 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants American Society of Mechanical Engineers (ASME) OM CODE-(year), Code for Operation and Maintenance of Nuclear Power Plants (Section ISI, Rules for Inservice Testing of Light-Water Reactors; Subsection ISTA, General Requirements; ISTB, IST of Pumps; ISTC, IST of Valves; Appendix I, IST of Pressure Relief Devices; Appendix II, IST of Check Valves)

ASME OM-S/G-(year), Standards and Guides for Operation and Maintenance of Nuclear Power Plants NUREG-1482, Guidelines for Inservice Testing at Nuclear Plants Civil ASME OM CODE-(year), Code for Operation and Maintenance of Nuclear Power Plants (Section ISI, Rules for Inservice Testing of Light-Water Reactors, Subsection ISTD, Inservice Examination and Evaluation of Snubbers)

American Welding Society (AWS) DI.1, Structural Welding Code American Concrete Institute (ACI) 311, Recommended Practice for Concrete Inspection Issue Date: 08/23/18 15 1245 Appendix C2

ACI 318, Building Code Requirements for Reinforced Concrete ACI 349.3, Evaluation of Existing Nuclear Safety Related Concrete Structures ACI 214-77, Recommended Practice for Evaluation of Strength Test Results of Concrete, 1983 ACI 304R-89, Guide for Measuring, Mixing, Transporting, and Placing Concrete ACI 309R-87, Guide for Consolidation of Concrete ACI 347R-88, Guide to Formwork for Concrete RG 1.12, Revision 2, Nuclear Power Plant Instrumentation for Earthquakes RG 1.35, Revision 3, Inservice Inspection of Ungrouted Tendons in Prestressed Concrete Containments, RG 1.35.1, Revision 0, Determining Prestressing Forces for Inspection of Prestressed Concrete Containments RG 1.59, Revision 2, Design-Basis Floods for Nuclear Power Plants RG 1.60, Revision 1, Design Response Spectra for Seismic Design of Nuclear Power Plants RG 1.61, Revision 0, Damping Values for Seismic Design of Nuclear Power Plants RG 1.76, Revision 0, Design-Basis Tornado for Nuclear Power Plants RG 1.102, Revision 1, Flood Protection for Nuclear Power Plants RG 1.117, Revision 1, Tornado Design Classification RG 1.122, Revision 1, Development of Floor Design Response Spectra for Seismic Design of Floor-Supported Equipment or Components RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants RG 1.132, Revision 1, Site Investigations for Foundations of Nuclear Power Plants RG 1.136, Revision 2, Materials, Construction, and Testing of Concrete Containments (Articles CC-1000, -2000, and -4000 through -6000 of the Code for Concrete Reactor Vessels and Containments)

RG 1.138, Revision 0, Laboratory Investigations of Soils for Engineering Analysis and Design of Nuclear Power Plants RG 1.142, Revision 2, Safety Related Concrete Structures for Nuclear Power Plants Issue Date: 08/23/18 16 1245 Appendix C2

RG 1.165, Revision 0, Identification and Characterization of Seismic Sources and Determination Safe Shutdown Earthquake Ground Motion RG 1.166, Revision 0, Pre-Earthquake Planning and Immediate Nuclear Plant Operator Postearthquake Actions RG 1.167, Revision 0, Restart of a Nuclear Power Plant Shut Down by a Seismic Event ANSI N14.6, Special Lifting Devices for Shipping Containers Weighing 10000 Pounds or More ANSI N45.2.5, Supplemental QA Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel ANSI/ANS 58.2, Design Basis for Protection of LWR Power Plants Against the Effects of Postulated Pipe Rupture ASME Boiler and Pressure Vessel (B&PV) Code, Sections III, V, IX, and XI Metallurgical/Welding AWS DI.7, Structural Welding Code RG 1.31, Control of Ferrite Content in Stainless Steel Weld Metal RG 1.43, Control of Stainless Steel Weld Cladding of Low-Alloy Steel Components RG 1.44, Control of the Use of Sensitized Stainless Steel RG 1.50, Control of Preheat Temperature for Welding of Low-Alloy Steel RG 1.54, Service Level I, II, and III Protective Coatings Applied to Nuclear Power Plants RG 1.71, Welder Qualification for Areas of Limited Accessibility RG 1.84, Design and Fabrication Code Case Acceptability RG 1.85, Materials Code Case Acceptability RG 1.147, Inservice Inspection Code Case Acceptability RG 1.150, Ultrasonic Testing of Reactor Vessel Welds During Preservice and Inservice Examinations RG 1.178, An Approach for Plant-Specific Risk-Informed Decisionmaking Inservice Inspection of Piping EPRI, PWR Steam Generator Examination Guidelines EPRI, Steam Generator Integrity Assessment Guidelines Issue Date: 08/23/18 17 1245 Appendix C2

ASME B&PV Code, Sections III, V, IX, and XI Generic Letter 90-05, Temporary Non-Code Repair of ASME Code Class 1, 2, and 3 Piping Industry Standards Industry standards endorsed by the above RGs ASME B&PV Code, Sections III, V, and VIII Issue Date: 08/23/18 18 1245 Appendix C2

Engineering Individual Study Activity TOPIC: (ISA-ENG-5) Significance Determination Process PURPOSE: The Significance Determination Process (SDP), as described in Appendix A to IMC 0609, aids NRC inspectors and staff in determining the safety significance of inspection findings. The SDP outcomes for inspection findings and the performance indicator information are both used as inputs to the power reactor assessment program. The purpose of this activity is for you to gain the requisite knowledge, understanding, and practical ability to use the significance determination process for findings at power.

COMPETENCY AREAS: INSPECTION TECHNICAL AREA EXPERTISE REGULATORY FRAMEWORK LEVEL OF EFFORT: 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />

REFERENCES:

1. IMC 0609, Significance Determination Process

2. IMC 0609, Attachment 0609.01, Significance and Enforcement Review Process

3. IMC 0609, Attachment 0609.02, Process for Appealing NRC Characterization of Inspection Findings (SDP Appeal Process)

4. IMC 0609, Attachment 4, Initial Characterization of Findings

5. IMC 0609, Appendix A, The Significance Determination Process (SDP) For Findings At-Power

6. IMC 0612, Issue Screening

7. Site-specific SDP Workspace and Plant Risk Information eBook (PRIB) accessed from the site-specific Standardized Plant Risk Analysis (SPAR) Model

8. LEGACY (information is no longer maintained current): Site-specific Risk-Informed Inspection Notebook and pre-solved table (http://nrr10.nrc.gov/adt/dssa/spsb/webpages/srapage/sdpnotebook s/sdpindex.html)

9. IMC 0308, Attachment 3 Significance Determination Process Technical Basis Issue Date: 08/23/18 19 1245 Appendix C2

EVALUATION CRITERIA: At the completion of this activity, you should be able to do the following:

1. Explain the purpose, objectives, and applicability of the SDP.

2. Describe and discuss the objectives of the Initiating Events (IE),

Mitigating Systems (MS), and Barrier Integrity (BI) cornerstones found in IMC 0612.

3. Process findings using the screening questions for IE, MS, and BI Cornerstones in Attachment 4 to IMC 0609.

4. Define the safety significance and give examples of Green, White, Yellow, and Red findings.

5. Discuss the Significance and Enforcement Review Panel (SERP) process and purpose, information contained in a SERP package, and the inspectors role during the SERP as described in IMC 0609, Attachment 1.

6. Discuss the process for appealing NRC characterization of inspection findings (i.e., the SDP appeal process), as described in IMC 0609, Attachment 2.

7. Explain the relationship between the licensee performance deficiency and the associated degraded condition, and how the SDP examines the risk increase from the degraded condition.

8. Explain why the proximate cause, not the root cause of the performance deficiency, is used to assess significance. Also discuss the importance of the initial inspection effort to correctly characterize the performance deficiency.

TASKS: 1. Read the referenced section of IMC 0609, with a particular focus on Appendix A. In addition, be aware of Appendix B (Emergency Preparedness Significance Determination Process), Appendix C (Occupational Radiation Safety Significance Determination Process), Appendix D (Public Radiation Safety Significance Determination Process), Appendix E (Security Significance Determination Process for Power Reactors), Appendix F (Fire Protection Significance Determination Process), Appendix G (Shutdown Operations Significance Determination Process),

Appendix H (Containment Integrity Significance Determination Process), Appendix K (Maintenance Risk Assessment and Risk Management Significance Determination Process), Appendix L (B.5.b Significance Determination Process), Appendix M (Significance Determination Process Using Qualitative Criteria) and Appendix O (Significance Determination Process for Mitigating Strategies and Spent Fuel Pool Instrumentation).

Issue Date: 08/23/18 20 1245 Appendix C2

2. Go to the Reactor Oversight Process Web site and review a sample of Green, White, Yellow, and Red findings in each of the three cornerstones (if samples of each level of safety significance are posted).

3. Read Scenarios A-D and complete tasks a-d below for each scenario. Discuss your results with your supervisor or a qualified inspector.

a. Assess the indicated finding using IMC 0609, Attachment 4 and proceed to the applicable appendix as directed. Ensure that you are able to describe the nexus between the inspection finding and the degraded condition.

b. Use the applicable appendix to determine if the issue is Green or if a more detailed risk evaluation is required. Do not perform the additional detailed risk evaluation if applicable; however, discuss possible outcomes with a regional Senior Reactor Analyst (SRA).

Be able to justify your determination.

c. Discuss your results with your supervisor or a qualified inspector.

4. Whenever possible, attend a (SERP). If you are unable to attend a SERP, review IMC 0609, Attachment 1 and an actual SERP package to develop an understanding of the SERP purpose, process, and the contents of the SERP package. Discuss the rationale for the outcome/resolution of the panel with a qualified inspector.

5. Meet with your supervisor or a qualified inspector to discuss any questions you may have as a result of this training activity.

DOCUMENTATION: Engineering Proficiency-Level Qualification Signature Card Item ISA-ENG-5 Issue Date: 08/23/18 21 1245 Appendix C2

Scenario A During the Unit 1 spring 1R16 refueling outage (RFO), plant staff identified that control rod drive mechanism nozzle XX was leaking. Workers repaired the nozzle weld and returned the unit to operation for another cycle. When the unit was shut down for RFO 1R17, visual examination of the reactor vessel head revealed repeat leakage of the nozzle. Based on the 1R16 RFO leakage, licensee staff performed an embedded flaw repair in accordance with Section XI of the ASME Code. However, the licensee staff recently concluded that this repair method is inadequate to prevent recurrence of the original primary water stress-corrosion cracking.

Issue Date: 08/23/18 22 1245 Appendix C2

Scenario B On September 26, 2002, Unit 1 was at 99-percent reactor power, coasting down for the RFO scheduled to begin on October 5. At 5:41 a.m., the Unit 1 control room received a condenser off-gas alarm. At 12:43 p.m., the condenser off-gas 182 alarm actuated again and the No. 2 steam generator main steamline N-16 monitor went into alarm. At 10:24 p.m., the N-16 alarm cleared and the reading continued to trend downward.

On September 27, 2002, at 12:19 a.m., the condenser off-gas 182 alarm cleared. At 10:25 a.m., the N-16 alarm returned. At 10:40 a.m., the condenser off-gas 182 alarm came in, followed by the condenser off-gas 182 Hi alarm at 10:51 a.m. At 1:06 p.m., these alarms cleared. These alarms came in twice more on this day. At 7:54 p.m., the condenser off-gas 182 alarm came in, and at 10:32 p.m., the condenser off-gas 182 HiHi alarm was reached. The alarms cleared in less than an hour.

On September 28, 2002, at 1:40 a.m., the Unit 1 control room operators commenced power reduction in response to the 1-02 steam generator tube leak. At 3:12 a.m., the Unit 1 control room operators performed a planned trip of the Unit 1 reactor.

Through subsequent inspection and testing, the licensee determined the source of the leakage to be a stress-corrosion crack initiating from the outer diameter surface in the U-bend region of tube R41C71 of the No. 2 steam generator. The licensee also determined through pressure testing that the tube failed to exhibit structural and accident leakage integrity margins consistent with the plant design and licensing basis.

An NRC inspection team independently reviewed eddy current test data from the previous (1RF08) inspection in 2001 for the specific tube location where the leakage developed in September 2002. The team found that a clearly detectable indication was present at the leak location during the previous outage (1RF08) inspection in 2001. The indication did not meet the reporting criteria in the RFO 1RF08 analysis guidelines, and therefore neither the primary nor secondary analyst reported it in 2001.

The inspection team concluded that an experienced analyst should have recognized that the large wobble signal could mask a dent that could distort or rotate an indication outside the reportable phase angle response criteria. In such a case, the guidelines enabled the analyst to bring the indication to the attention of the lead analyst and the senior analyst. Therefore, the team determined that the analyst should have recognized the large wobble signal and should have brought it to the attention of a senior analyst.

As a direct consequence of the failure to detect the flaw, the tube was not removed from service and subsequently degraded to the point that it leaked and no longer satisfied the applicable tube integrity performance criteria. This occurred because the examination methods and the analysis guidelines used during the RFO were not effective for ensuring that tubes would maintain their integrity until the next scheduled inspection.

Issue Date: 08/23/18 23 1245 Appendix C2

Scenario C The assumptions regarding the instruments used for safety-related heating, ventilation, and air-conditioning (HVAC) systems (i.e., the auxiliary building ventilation system and the control room HVAC system in the licensees 120 volt alternating current (Vac) degraded voltage calculation) did not reflect the actual plant configuration. Specifically, the 120 Vac degraded voltage calculation, Evaluation of the 120 Vac Distribution Circuits Voltage at the Degraded Voltage Setpoints, assumed the input voltage to specific HVAC process instrumentation to be at 95 Vac. While the vendor information associated with the instrumentation specified a higher voltage for proper operation, the licensee had stated in the assumption for the calculation that the instrumentation would be able to operate because tests on the instrumentation while in service demonstrated that the control circuits would perform their design function at a reduced voltage of 95 Vac. It was unclear whether the licensee had a program in place for testing replacement instrumentation put in service at this reduced voltage. Without a test for each instrument placed in service, the licensee would have to use the vendors specification for voltage as it could not guarantee that the replacement instruments would operate at these assumed reduced voltages.

While the licensee was able to determine the operability of the affected instruments through the bounding voltage drop calculation, the licensees existing design basis (the assumptions in the degraded voltage calculation) had not been adequately verified or maintained. The design-basis assumption relied on testing the instruments at 95 Vac; however, the licensee did not test some instruments and replaced others without retesting the specific instrument at the assumed degraded voltage included in the calculation. Therefore, the licensee had failed to maintain accurate design-basis assumptions that were essential for its design-basis calculation.

Issue Date: 08/23/18 24 1245 Appendix C2

Scenario D The licensee did not identify potential common-mode failures that existed involving power supplies to the recirculation line air-operated valve in the auxiliary feedwater system and other system components. In addition, the licensees corrective actions for the potential common-mode failure associated with a loss of instrument air did not prevent the failures from repeating.

Although the licensee upgraded the safety function of the air-operated recirculation valve, this corrective action failed to ensure that successful operation of the recirculation line air-operated valve depended only on safety-related support systems. After the corrective actions, successful operation of the valve still depended upon nonsafety-related power to an interposing relay. In addition, the corrective actions did not to discover a single failure mechanism involving a system orifice modification.

Issue Date: 08/23/18 25 1245 Appendix C2

Engineering Inspector Individual Study Activity TOPIC: (ISA-ENG-6) Maintenance Rule PURPOSE: The NRC requires that licensees operate their facilities in compliance with 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, (i.e., the Maintenance Rule). This activity will provide you with a working knowledge of the maintenance rule, including background, history, and industry implementation of the requirements; and you will become familiar with the key maintenance rule guidance documents.

COMPETENCY AREA: INSPECTION LEVEL OF EFFORT: 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />

REFERENCES:

1. 10 CFR 50.65

2. Regulatory Guide 1.160, Revision 3, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants (ML113610098)

3. NRC Enforcement Manual, Part II, Section 2.1.10, Actions Involving the Maintenance Rule

4. NUMARC 93-01, Revision 4A, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, issued April 2011 by the Nuclear Energy Institute (ML11116A198)

5. IP 71111.12, Maintenance Effectiveness

6. IP 71111.13, Maintenance Risk Assessments and Emergent Work Control EVALUATION CRITERIA: At the completion of this activity, you should be able to do the following:

1. Discuss the different categories of SSCs which may be in the scope of the maintenance rule.

2. Discuss the different methods by which licensees may monitor the performance or condition of in scope SSCs.

3. Discuss what actions are required if the requirements of the various aspects of the maintenance rule are not met.

4. Describe the typical activities that licensees perform before taking equipment out of service for maintenance.

Issue Date: 08/23/18 26 1245 Appendix C2

TASKS: 1. Complete Maintenance Rule Training (available in iLearn). Discuss the results of the knowledge checks with your supervisor or a senior inspector.

2. Meet with your supervisor or a qualified engineering or operations inspector to discuss any questions that you may have as a result of this activity and demonstrate that you can meet the evaluation criteria listed above.

DOCUMENTATION: Engineering Proficiency-Level Qualification Signature Card Item ISA-ENG-6 Issue Date: 08/23/18 27 1245 Appendix C2

Engineering On-the-Job Activity Issue Date: 08/23/18 28 1245 Appendix C2

Engineering On-the-Job Activity TOPIC: (OJT-ENG-1) Component Design Bases Inspection PURPOSE: The purpose of this activity is to do the following:

1. Familiarize yourself with activities commonly performed by an inspector while participating as a member of a CDBI team.

2. Observe and perform portions of the CDBI, as assigned by the team leader, using IP 71111.21.

3. Provide you with the opportunity to locate and identify the design-and licensing-basis requirements for a risk-significant component and determine if those requirements are met and maintained.

COMPETENCY AREA: INSPECTION LEVEL OF EFFORT: 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> in-office preparation 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> onsite inspection

REFERENCES:

1. IP 71111.21, Component Design Bases Inspection

2. IP 71152, Identification and Resolution of Problems

3. IMC 1245, Appendix A, On-the-Job Activity 4, Inspection Activities

4. IMC 0611, Power Reactor Inspection Reports

5. Site-specific inspection plan (provided by team leader)

6. Site-specific design-basis documents (e.g., system descriptions, calculations, accident analyses, etc.)

7. Site-specific licensing basis (e.g., UFSAR, technical specifications, license amendments, and license amendment requests)

8. Licensee-provided preparation information (e.g., lists for applicable calculations, equipment history, problem reports, engineering evaluations, modifications, and procedures)

9. OpE gateway (http://nrr10.nrc.gov/ope-info-gateway/index.html)

Issue Date: 08/23/18 29 1245 Appendix C2

EVALUATION CRITERIA: 1. Complete the activities as outlined in this guide and meet with your supervisor to discuss any questions you may have as a result of completing this activity. Upon completion of the tasks in this guide, you will be asked to demonstrate your understanding of the baseline IP 71111.21.

2. Demonstrate your ability to conduct inspection activities as applied to a CDBI (IP 71111.21).

3. Demonstrate your ability to locate and identify design- and licensing-basis information.

4. Demonstrate your familiarity with the design and licensing bases for the component(s) selected by the CDBI team inspection plan.

Identify critical parameters and performance criteria.

5. Demonstrate your ability to identify critical equipment required to achieve the design-basis function of the selected system(s).

6. Demonstrate your ability to develop an individualized inspection plan for the discipline/component/operating experience/operator action you are assigned from the team inspection plan.

7. Discuss your conclusions regarding the capability of your assigned component(s) to achieve its design- and licensing-basis functions.

Provide the bases for that conclusion (e.g., evaluations, testing, performance history, etc.).

8. Discuss your conclusions regarding the licensees evaluation and implementation of corrective actions of your assigned operating experience.

9. Discuss your conclusions regarding the implementation of your assigned operator action and whether they can be performed in accordance with the plants design bases. Provide the bases for that conclusion (e.g. simulator scenario, in plant walkdown, procedure review, etc.)

10. Demonstrate your capability to document your inspection findings consistent with IMC 0611.

11. Demonstrate your familiarity with SDP Group 1, 2, and 3 questions in IMC 0611 for an actual or simulated finding.

TASKS: 1. Perform the tasks listed in IMC 1245, Appendix A, On-the-Job Activity 4, Inspection Activities, as applied to an inspection focused on IP 71111.21.

Issue Date: 08/23/18 30 1245 Appendix C2

2. Review IP 71111.21 and IP 71152 for an overview of CDBI activity.

3. Review previous CDBI reports to improve your understanding of the implementation of IP 71111.21.

4. Review site-specific design- and licensing-basis documentation, provided during preparation week, to become familiar with the design and licensing bases for the components selected for review in the team inspection plan.

5. Develop an individualized inspection plan for the component/operating experience/operator action you are assigned.

Determine if any system components have been identified as Operating Experience Smart Samples (http://nrr10.nrc.gov/ope-info-gateway/opess.html.

6. Identify specific critical equipment required for the safety system to achieve its design- and licensing-basis functions.

7. Review available information to determine if equipment is capable of achieving and maintaining its design function. Such information includes vendor manuals, specification documents, maintenance and testing documents, problem identification reports, etc.

8. Based on your inspection activity, assess if the component is capable of meeting its design function.

9. Based on your inspection activity, assess if the licensees evaluation and implementation of corrective actions of your assigned operating experience was acceptable.

10. Based on your inspection activity, assess if the operator action can be performed in accordance with the plants design bases.

11. Perform a walkdown of accessible portions of the selected components and its associated system.

12. For at least one observed or simulated finding, apply SDP to the issue.

13. Meet with your supervisor or a qualified inspector designated by your supervisor and discuss the result of your activities.

DOCUMENTATION: Engineering Proficiency-Level Qualification Signature Card Item OJT-ENG-1 Issue Date: 08/23/18 31 1245 Appendix C2

Engineering On-the-Job Activity TOPIC: (OJT-ENG-2) Permanent Plant Modifications PURPOSE: The purpose of this activity is to do the following:

1. Familiarize you with activities commonly performed by an inspector while reviewing permanent plant modifications.

2. Observe and perform portions of an inspection of permanent plant modifications using IP 71111.17.

COMPETENCY AREA: INSPECTION LEVEL OF EFFORT: 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />

REFERENCES:

1. IP 71111.17, Permanent Plant Modifications

2. Criterion III, Design Control, in Appendix B to 10 CFR Part 50

3. IMC 1245, Entry-Level On-the-Job Activity 4, Inspection Activities

4. IMC 0611, Power Reactor Inspection Reports

5. ANSI Standard N45.2.11-1974, Quality Assurance Requirements for the Design of Nuclear Power Plants

6. NEI 97-04, Revised Appendix B, Guidance and Examples for Identifying 10 CFR 50.2 Design Bases EVALUATION CRITERIA: Complete the activities as outlined in this guide and meet with your supervisor to discuss any questions you may have as a result of completing this activity. Upon completion of the tasks in this guide, you will be asked to demonstrate your understanding of how to conduct an inspection of plant modifications using the baseline IP 71111.17 by doing the following:

1. Demonstrate your ability to satisfy the evaluation criteria given in Entry-Level On-the-Job Activity 4, as applied to an inspection focused on IP 71111.17.

2. Demonstrate your ability to select modifications for review that are risk significant.

Issue Date: 08/23/18 32 1245 Appendix C2

3. For selected modifications, demonstrate your ability to identify the design safety function of the SSC and the design requirements.

4. For each modification, discuss the licensees approach to assuring that the modification did not adversely impact the design, availability, reliability, or functional capability of the SSC.

5. Demonstrate an understanding of potential risk-significant plant configurations that could occur during modification implementation and identify the licensees method for addressing them.

6. Demonstrate your ability to document your inspection findings consistent with IMC 0611.

7. Demonstrate your familiarity with the SDP Group 1, 2, and 3 questions in IMC 0611 for an actual or simulated finding.

TASKS: 1. Perform the tasks listed in Entry-Level On-the-Job Activity 4, as applied to an inspection focused on IP 71111.17.

2. With the regional probabilistic risk assessment specialist, discuss which systems or equipment modifications have the highest risk significance.

3. For the modifications selected, determine the intended safety function and design requirements for the applicable SSC.

4. For the modifications selected, determine the motivation for the change (e.g., problem report, equipment failure, etc.) and verify that the modification resolved the problem.

5. Review testing and inspection documentation after the modification and verify that the testing was adequate to assure that the functional capability or design function of the SSC was not degraded.

6. Review the plant configuration for modification implementation and testing. Review the licensees actions to assure that the plant was not placed in a risk-significant configuration.

7. When possible, perform a field walkdown of the SSC modified and determine whether the final condition was as designed by the modification documentation.

8. For a change in or substitution of component parts via the procurement or modification process, review equivalency evaluations that validate the adequacy of the replacement part.

Issue Date: 08/23/18 33 1245 Appendix C2

9. For at least one observed or simulated finding, apply SDP to the issue.

10. Meet with your supervisor or a qualified inspector designated by your supervisor and discuss the result of your activities.

DOCUMENTATION: Engineering Proficiency-Level Qualification Signature Card Item OJT-ENG-2 Issue Date: 08/23/18 34 1245 Appendix C2

Engineering On-the-Job Activity TOPIC: (OJT-ENG-3) Inspection of Licensee Changes, Tests, and Experiments (10 CFR 50.59)

PURPOSE: The purpose of this activity is to do the following:

1. Familiarize you with activities commonly performed by an inspector while inspecting licensee changes, tests, and experiments to determine if they may be accomplished before receiving NRC approval.

2. Observe and perform portions of an inspection of changes, tests, and experiments using IP 71111.17.

COMPETENCY AREA: INSPECTION LEVEL OF EFFORT: 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />

REFERENCES:

1. IP 71111.17, Evaluations of Changes, Tests, or Experiments

2. Engineering Individual Study Activity ISA-ENG-3 on 10 CFR 50.59

3. Entry-Level On-the-Job Activity 4, Inspection Activities EVALUATION CRITERIA: Complete the activities as outlined in this guide and meet with your supervisor to discuss any questions you may have as a result of completing this activity. Upon completion of the tasks in this guide, you will be asked to demonstrate your understanding of the baseline IP 71111.17 by doing the following:

1. Demonstrate your ability to satisfy the evaluation criteria of Entry-Level On-the-Job Activity 4, as applied to an inspection focused on IP 71111.17.

2. Describe the changes, tests, or experiments that you reviewed and your evaluation of the licensees ability to perform them without prior NRC approval and their effect, if any, on operability.

TASKS: 1. Perform the tasks listed in Entry-Level On-the-Job Activity 4, as applied to an inspection focused on the topic of 10 CFR 50.59 (IP 71111.17).

2. For at least one observed or simulated finding, relating to 10 CFR 50.59, apply SDP.

Issue Date: 08/23/18 35 1245 Appendix C2

3. Meet with your supervisor or a qualified inspector designated by your supervisor and discuss the result of your activities.

DOCUMENTATION: Engineering Proficiency-Level Qualification Signature Card Item OJT-ENG-3 Issue Date: 08/23/18 36 1245 Appendix C2

Engineering On-the-Job Activity TOPIC: (OJT-ENG-4) Security Plan and Implementation PURPOSE: The purpose of this activity is to familiarize you with a typical security plan for a nuclear facility.

COMPETENCY AREA: INSPECTION LEVEL OF EFFORT: 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />

REFERENCES:

1. Security plan for a selected facility

2. Technical specifications for the selected facility

3. 10 CFR Part 73.1, Purpose and Scope

4. 10 CFR 73.55, Requirements for Physical Protection of Licensed Activities in Nuclear Power Reactors against Radiological Sabotage

5. Appendix B to 10 CFR Part 73, Section VI

6. Appendix C,Section II to 10 CFR Part 73

7. 10 CFR Part 73.58, Safety/Security Interface requirements for Nuclear Power Reactors

8. 10 CFR 50.54 Conditions of Licenses (p)(1) & (2)

EVALUATION CRITERIA: Upon completion of the tasks, you should be able to perform the following:

1. Generally describe how the site will implement 10 CFR Part 73.55 requirements through the establishment and maintenance of a security organization, the use of security equipment and technology, the training and qualification of security personnel, the implementation of predetermined response plans and strategies, and the protection of digital computer and communication systems and networks.

2. Generally describe the methods used by the site security force to maintain access control of the owner-controlled, protected, and vital areas.

3. Demonstrate the appropriate procedures for escorting visitors into and out of the protected and vital areas.

Issue Date: 08/23/18 37 1245 Appendix C2

4. Explain the site-specific methods used to detect, assess, interdict, and neutralize threats up to and including the design basis threat of radiological sabotage as stated in 10 CFR 73.1.

5. Explain the need to maintain classification of certain safeguards material.

TASKS: 1. Review the references listed above, as appropriate, to develop an understanding of the site security system.

2. Conduct a walkdown of the protected and vital areas to identify the various types of intruder-detection equipment used.

3. Discuss with appropriate licensee security and plant operation management how the licensee will assess and manage the potential for adverse effects on safety and security, before implementing changes to plant configurations, facility conditions, or security.

4. Tour the central and secondary alarm stations. Discuss the duties and responsibilities of personnel stationed in those facilities with the watchstanders and the security shift supervisor.

5. Discuss inspector responsibilities related to site security and safeguards with your supervisor or a qualified operations or physical security inspector. Include practical circumstances that you may encounter, such as the loss of a security badge or the identification of an inattentive guard. In addition, discuss any questions that you may have as a result of this activity.

6. Meet with your supervisor or a qualified inspector designated by your supervisor and discuss the result of your activities.

DOCUMENTATION: Engineering Inspection Proficiency-Level Qualification Signature Card Item OJT-ENG-4 Issue Date: 08/23/18 38 1245 Appendix C2

Engineering Inspector On-the-Job Activity TOPIC: (OJT-ENG-5) Radiation Protection Program and Implementation PURPOSE: The radiation protection program and implementing procedures are intended to ensure adequate protection of worker health and safety from exposure to radiation from radioactive material during routine nuclear reactor operation. Licensee procedures, 10 CFR Part 19, Notes, Instructions and Reports to Workers: Inspection and Investigations, and 10 CFR Part 20, Standards for Protection Against Radiation, address the as-low-as-reasonably-achievable (ALARA) program, external exposure, internal exposure, respiratory protection, posting and labeling, survey, and reporting requirements. This activity will provide you with a general understanding of the applicable regulatory requirements, the licensees radiation protection program, and implementing procedures.

COMPETENCY AREA: INSPECTION LEVEL OF EFFORT: 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />

REFERENCES:

1. Licensee procedures addressing the implementation of NRC inspections of the radiation protection program

2. Plant technical specifications

3. Plant UFSAR

4. 10 CFR Part 19, Notices, Instructions and Reports to Workers:

Inspection and Investigations

5. 10 CFR Part 20, Standards for Protection Against Radiation

6. RG 8.38, Control of Access to High and Very High Radiation Areas

7. Radiation work permit used for NRC inspection activities EVALUATION CRITERIA: Upon completion of the tasks, you should be able to perform the following:

1. Generally describe the following terms and provide examples of each term:

a. unrestricted area

b. controlled area

c. radiological restricted area

d. radiation area

e. high radiation area Issue Date: 08/23/18 39 1245 Appendix C2

f. technical specification locked high radiation area

g. very high radiation area

h. hot spots

i. contaminated area

j. hot or discrete particle area

k. airborne radioactivity area

2. Explain the ALARA concept and its application to the performance of radiological work at your site.

3. Describe the plants overall administrative procedures for control of external, internal, and airborne exposure and its process for implementing the procedures during NRC inspections.

4. Describe physical and administrative controls for contaminated areas, radiation areas, high radiation areas, technical specification locked high radiation areas, very high radiation areas, and airborne radioactivity areas.

TASKS: 1. Locate the listed references for a selected facility.

2. Review the references and licensee procedures to develop an overall understanding of the regulatory requirements and the implementation of the radiation protection program. Review the radiation work permit, which allows a visiting NRC inspector to complete the assigned inspection.

3. During a plant tour, identify at least one of each of the following:

contaminated area, radiation area, high radiation area, technical specification locked high radiation area, very high radiation area, hot spots area, and an airborne radioactivity area. Observe the licensees method of controlling access to each in accordance with regulations and licensee requirements.

4. Review at least one completed set of radiation survey results and explain how you will incorporate the survey results into your inspection effort.

5. Review the licensee procedures for radiation control. Review the actions required of an individual when contamination is detected before exiting the radiation controlled area.

6. Meet with your supervisor or a qualified engineering inspector to discuss any questions that you may have as a result of these activities and demonstrate that you can meet the evaluation criteria.

DOCUMENTATION: Engineering Inspector Proficiency-Level Qualification Signature Card Item OJT-ENG-5 Issue Date: 08/23/18 40 1245 Appendix C2

Reactor Engineering Technical Proficiency-Level Signature Card and Certification Inspector Name: ___________________________________ Employee Supervisors Initials/Date Signature/Date A. Training Courses 10 CFR 50.59 (course 254144 in iLearn)

Power Plant Engineering (self study)

Reactor Full Series (either BWR or PWR)

Basic Reactor Operations for alternate reactor type B. Individual Study Activities ISA-ENG-1 Component Design Bases Inspection ISA-ENG-2 The NRCs Review of Temporary and Permanent Plant Modifications ISA-ENG-3 Evaluations of Changes, Tests, and Experiments (10 CFR 50.59)

ISA-ENG-4 Basic Codes, Standards, and Regulatory Guides for Engineering Support ISA-ENG-5 Significance Determination ProcessCReactor Inspection Findings for At-Power Situations ISA-ENG-6 Maintenance Rule C. On-the-Job Training Activities OJT-ENG-1 Component Design Bases Inspection OJT-ENG-2 Permanent Plant Modifications OJT-ENG-3 Inspection of Licensee Changes, Tests, and Experiments (10 CFR 50.59)

OJT-ENG-4 Security Plan and Implementation OJT-ENG-5 Radiation Protection Program and Implementation Supervisors signature indicates successful completion of all required courses and activities listed in this journal and readiness to appear before the Oral Board.

Supervisors Signature: ______________________________ Date: _____________

The appropriate Form 1, Reactor Engineering Technical Proficiency-Level Equivalency Justification, if applicable, must accompany this signature card and certification.

Issue Date: 08/23/18 41 1245 Appendix C2

Form 1: Reactor Engineering Technical Proficiency-Level Equivalency Justification Identify equivalent training and Inspector Name: _________________________________ experience for which the inspector is to be given credit A. Training Courses 10 CFR 50.59 (course 254144 in iLearn)

Power Plant Engineering (self study)

Reactor Full Series (either BWR or PWR)

Basic Reactor Operations for alternate reactor type B. Individual Study Activities ISA-ENG-1 Component Design Bases Inspection ISA-ENG-2 The NRCs Review of Temporary and Permanent Plant Modifications ISA-ENG-3 Evaluations of Changes, Tests, and Experiments (10 CFR 50.59)

ISA-ENG-4 Basic Codes, Standards, and Regulatory Guides for Engineering Support ISA-ENG-5 Significance Determination ProcessCReactor Inspection Findings for At-Power Situations ISA-ENG-6 Maintenance Rule C. On-the-Job Training Activities OJT-ENG-1 Component Design Bases Inspection OJT-ENG-2 Permanent Plant Modifications OJT-ENG-3 Inspection of Licensee Changes, Tests, and Experiments (10 CFR 50.59)

OJT-ENG-4 Security Plan and Implementation OJT-ENG-5 Radiation Protection Program and Implementation Supervisors Recommendation Signature/Date_________________________

Division Directors Approval Signature/Date_________________________

Issue Date: 08/23/18 42 1245 Appendix C2

Revision History Sheet for IMC 1245 Appendix C2 Attachment 1 Commitment Accession Description of Change Description of Comment Resolution Tracking Number Training and Closed Number Issue Date Required and Feedback Form Change Notice Completion Date Accession Number (Pre-Decisional, Non-Public Information)

N/A ML062400496 To update reference lists and incorporate minor editorial None N/A 10/31/06 changes. Completed 4 year historical CN search CN 06-032 N/A ML073530651 To add G-204 as a post qualification training requirement and None ML073510727 01/10/08 to update ISA-ENG-1 and OJT-ENG-1 to reflect the new CN 08-001 Component Design Bases Inspection Approach N/A ML090360461 Updates ISA-ENG-3 and ISA-ENG-5, and moves post- None ML091590710 07/08/09 qualification and refresher training requirements into Appendix CN 09-017 D-1. Specifically, ISA-ENG-3 is updated to remove the task to take Web-based 50.59 training that is no longer available on the Web. ISA-ENG-5 is updated to reference the current location of the SDP initial screening criteria.

N/A ML11175A324 This revision adds ISA-6 on the Maintenance Rule, adds None ML11326A208 12/29/11 training on the OpE gateway and OpE smart samples to OJT-CN 11-044 1, and adds key radiation protection terms to OJT-5.

N/A ML12251A050 This revision updates training on the SDP in ISA-5 to reflect None ML12290A180 12/19/12 recent changes to IMC 0609, Significance Determination CN 12-029 Process. Specifically, references to the At-Power SDP (0609, Appendix A) Phase 1, 2, and 3 were replaced and references and scenarios were updated.

N/A ML15181A328 This revision updates format, references in ISA-6 None ML15195A163 10/21/15 (Maintenance Rule), and removes writing guidance in ISA-5 CN 15-020 (SDP), including two scenarios that are out of date.

Issue Date: 08/23/18 Att1-1 1245 Appendix C2

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

N/A ML16301A158 This revision adds training on 10 CFR 50.59 to ISA-3, updates ML16301A347 12/19/16 ISA-5 (SDP) and OJT-4 (security plan), and relaxes the CN 16-034 prerequisite (to complete Appendix A before beginning this qualification standard) to a recommendation the branch chief can override.

N/A ML18047A127 This revision accounts for the creation of IMC 0611. ML18065A653 08/23/18 Closed FF:

CN 18-029 1245C2-2264 ML18134A020 Issue Date: 08/23/18 Att1-2 1245 Appendix C2