ML18187A183

IMC 0609 Att 5 Inspection Finding Review Board

ML18187A183
Person / Time
Issue date:	10/23/2018
From:	Alex Garmoe NRC/NRR/DIRS/IRAB
To:
Garmoe A, NRR/DIRS, 415-3814
Shared Package
ML18187A155, ML18296A044	List:
References
CN 18-036, DC 18-019
Download: ML18187A183 (13)

Text

NRC INSPECTION MANUAL IRAB INSPECTION MANUAL CHAPTER 0609, ATTACHMENT 05 INSPECTION FINDING REVIEW BOARD Effective Date: 01/01/2019 0609.05-01 PURPOSE The purpose of the Inspection Finding Review Board (IFRB) is to provide a formal framework to obtain regional staff and management agreement on the proposed performance deficiency and to effectively manage the actions needed to reach a preliminary decision on the significance of inspection findings that do not initially screen to Green. This framework, through effective management oversight and project planning, aims to ensure that all involved regional managers and staff are aligned on the specific actions needed, the scope of the work to be done, and the associated schedule to reach an informed decision on licensee performance deficiencies and their preliminary significance prior to conducting a Significance and Enforcement Review Panel (SERP).

This document will be used in conjunction with Inspection Manual Chapter (IMC) 0609, Significance Determination Process, and IMC 0609, Attachment 1, Significance and Enforcement Review Panel (SERP) Process. These procedures are intended to ensure the Significance Determination Process (SDP) is efficient through appropriate management oversight and planning of the disposition of potentially greater-than-Green (GTG) inspection findings.

0609.05-02 APPLICABILITY The IFRB is a regional activity that should be convened when inspection findings do not initially screen to Green using the various SDP screening tools. Specifically, if the finding does not screen to Green using IMC 0609, Appendix A or in Phases 1 and 2 of IMC 0609, Appendices F, G, H, J, and K, the regional branch chief responsible for the issue and the senior reactor analyst (SRA) shall determine if an IFRB is warranted. A straightforward issue that experience has shown will ultimately result in a Green determination without significant effort would not require convening the IFRB. It is expected that IFRB meetings will be regularly scheduled and only held when needed (analogous to weekly allegation review board and enforcement meetings).

For security issues that do not initially screen to Green, an IFRB or a Security Information Forum (SIF) can be convened. Should a SIF be convened in place of an IFRB, the SIF should accomplish all of the tasks and assignments that an IFRB would have accomplished, and the overall management of the issue should be conducted in accordance with the Inspection Finding Resolution Management (IFRM) process.

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0609.05-03 OBJECTIVES Ensure regional management and staff align on the licensee performance deficiency, the degraded condition, and how the performance deficiency is the proximate cause of the degraded condition. The proposed violation can be discussed, but alignment is not necessary at this point.

Ensure there is early alignment on the scope, schedule and involved resources to support an efficient and effective preliminary significance assessment.

Develop key messages to be communicated to licensee senior management by the IFRB Chair.

0609.05-04 GUIDANCE The IFRB Finding Form (Exhibit 1 of this procedure) is used to document the receipt, evaluation, and IFRB decisions for inspection findings for which the responsible branch chief and the SRA agree should be subject to an IFRB. For non-deterministic SDPs, the IFRB should be convened when inspection findings do not initially screen to Green. However, the IFRB is not necessary for issues that do not initially screen to Green if the issue is straightforward and experience has shown it will ultimately result in a Green determination without significant effort. For deterministic SDPs, the IFRB should be convened when inspection findings involve complexities, such that the outcome of the deterministic SDP is not clear or straightforward.

For security inspection findings that involve complexities and are not clear, the SIF can be used in place of the IFRB. The SIF provides a forum for regional and headquarters staff (Office of the General Counsel, Office of Enforcement (OE), and Office of Nuclear Reactor Regulation (NRR))

to solicit input from each other regarding a number of security inspection-related issues, including potentially greater-than-Green security findings. When using a SIF instead of an IFRB, the SIF should accomplish all of the tasks an IFRB would have accomplished, including assignment of a designated division-level manager as the single point of contact for the issue, and the overall process for dispositioning the issue should otherwise follow the IFRM process.

An IFRB (or SIF) is not necessary when the significance of the finding using deterministic SDP flowcharts appears to be clear and straightforward, regardless of proposed significance. An IFRB can be held based on management discretion regardless of whether the entry criteria are met.

The IFRB should consist of the IFRB Chair, who will be a Senior Executive Service manager and the sponsor for the finding (this individual should also normally be the Sponsor during the SERP process), the lead inspector, the SRA, the inspection branch chief, the Division of Reactor Projects branch chief (if different from the inspection branch), the Division of Reactor Safety (DRS) branch chief for issues within a DRS technical area (if different from the inspection branch), and a regional enforcement specialist. Since the IFRB is a regional activity, attendance by headquarters staff is at the regions discretion. Included in the IFRB should be a decision on whether a planning SERP is needed, consistent with the guidance in Section 02.01.a.2 of IMC 0609, Attachment 1.

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It is beneficial to hold the IFRB promptly once it is known that the IFRB entry criteria are met to drive timely dispositioning of the issue. It is also beneficial to have as much certainty around the performance deficiency as possible at the IFRB since subsequent changes to the performance deficiency are likely to have resource implications. For this reason, regions should use judgement in determining when to schedule the IFRB, balancing the desire to delay for purposes of seeking additional information with the ability and desire to disposition the issue in a timely manner. However, it is also recognized that additional information might become available after the IFRB that warrants adjustments to the performance deficiency. A follow-up IFRB should be considered when it is expected that there may be significant departures from what was agreed upon at the initial IFRB. For example, a follow-up IFRB could be considered when:

A change to the previously-aligned-upon performance deficiency is proposed that may result in a significant change to the previously-aligned-upon resources, schedule, and plan for assessing the significance, or A previous IFRB on the issue determined that a follow-up IFRB should be held.

Following the IFRB, the IFRB Chairman will call senior site management to discuss the outcome of the IFRB and plan for dispositioning the issue. Specific topics to be discussed on this call include:

The outcome of the IFRB The performance deficiency NRCs planned schedule for dispositioning the issue Any information needs to support dispositioning the issue The concepts of proximate cause and best available information, as necessary Sensitivity should be given to the possible impact on the licensee of changes to resource and schedule plans, and whether an update call with licensee senior management by the IFRB Chair is appropriate.

Exhibit 1, IFRB Worksheet, serves as the basis for the discussion of the concerns during the IFRB. The sections of the worksheet contain a summary of the issue (Section 1), the performance deficiency details and initial evaluation (Section 2), inspection staff recommended action (Section 3), and IFRB decisions (Section 4). The IFRB Worksheet shall be promptly sent to the cognizant inspection branch chief and routed with SERP documentation if a SERP will be held.

Exhibit 2, Inspection and Significance Determination Process Metrics, is provided to illustrate the 255-day total period for greater-than-Green inspection findings to decide on the performance deficiency based on its proximate cause and to determine its final significance.

The exhibit reflects the completion milestones of 120 days from the issue identification until the final exit, 45 days to issue the inspection report, and 90 days to complete the SDP evaluation.

The enforcement action metric of 120 days from the exit meeting to the final determination is also provided to illustrate that when enforcement is involved the total time is 240 days.

Exhibit 3, Estimated Timeline for SDP Completion, is an editable file provided to show the process steps from the identification of an issue to the final SDP determination with an estimate of the time necessary to complete each step. This timeline shall be used by the IFRB in Issue Date: 10/23/18 3 0609.05

developing schedules for completing the evaluation of the finding. The milestones demonstrated on the timeline are ONLY considered estimates based on past experience with greater-than-Green inspection findings. All findings should be completed in an effective and efficient manner with a goal to complete all steps in less than 255 days. Additionally, it should be recognized that there are several steps which may be done concurrently.

04.01 IFRB Worksheet

a. Section 1, Issue Summary

1. General Information: Enter Facility Name, Docket/License #, EA Number and Responsible Inspection Branch.

2. Brief Overall Issue Summary: Provide a short summary of the degraded condition or issue of concern and how it was identified. Describe how the performance deficiency is the proximate cause of the degraded plant condition.

Determine if the issue should be considered for an old design issue.

3. Enter Issue Start Date using the calendar drop-box. The other dates will auto-calculate. (Reference IMC 0307, Appendix A for guidance on determination of the event date).

4. Answer whether all timeliness metrics will be met and if not, explain the reason.

It is understood that at this point, it isnt definitively known whether the metrics will be met, so the question should be answered based on the most reasonable projection given the information known at the time. It is best to raise potential concerns with meeting metrics early, even if they may ultimately be met.

b. Section 2, Issue Information

1. Performance Deficiency and Associated Violation: Provide a concise statement of the performance deficiency and associated violation. This is the version of the performance deficiency that, after approval by the IFRB, will be used at the SERP and documented in the inspection report.

2. Affected Structures, Systems, Components (SSCs), Operator Actions, and Risk-Relevant Functions: List the SSCs, operator actions, and relevant probabilistic risk assessment (PRA) functions that have been affected by the identified performance deficiency. The functions important to the SDP are the risk-relevant functions as described in documents such as the plant risk information e-book (PRIB), the NRCs SPAR model, the historical SDP notebooks, or the licensees PRA. The functions may be different from the specified safety function as described in the plants Updated Final Safety Analysis Report.

3. Conditions When the Performance Deficiency Would Manifest Itself: Describe the type of accident, environmental conditions, plant configuration (as applicable) during which the performance deficiency would impact plant safety.

4. Initial SDP Screening: Determine which cornerstones are affected. Provide basis for more-than-minor determination. Provide the basis for why the finding Issue Date: 10/23/18 4 0609.05

does not screen-to-Green in IMC 0609 Appendix A or in Phases 1 and 2 of IMC 0609 Appendices F, G, H, J, K, as applicable.

5. Exposure Time: Enter the duration the degraded condition existed or is assumed to have existed, including repair time. Include both the start time and end time for the exposure period, along with the basis for the selection of these dates/times. Describe whether T (if the actual start time of PRA non-functionality is known) or T/2 (if the actual start time of PRA non-functionality is not known) should be considered for calculating the duration. When using T/2, the time period to be halved starts with the last known time the SSC was definitively shown to be PRA functional. Any repair time in which the SSC was unable to perform a PRA function is always included in the exposure time. Additional information about the determination of exposure time is included in the Risk Assessment Standardization Project Handbook. Consult with the SRA to determine the exposure time.

6. Are External Events Likely to be the Main Risk Contributor (i.e., earthquake, fire, external flooding and tornados/high winds): Answer yes/no and if yes, describe the scenarios where the affected component(s) would be called upon.

7. Is Recovery of the Failed Function Credible? Describe the conditions for which the licensee may be able to recover the function that was impaired or lost as a result of the performance deficiency. For example, if an operator action could be taken, is there training provided, procedures already established, and equipment necessary to take the action available. Is credit for FLEX equipment appropriate?

8. Describe How Current PRA Techniques and Tools and Tools Apply. Are the existing PRA models and techniques sufficient to adequately determine the issue significance? Which risk metric will be used for the SDP evaluation (delta core damage frequency, delta large early release frequency, condition core damage probability)? If not, describe alternate means available or needed to determine significance.

9. Additional Issue Complexities, if any.

10. Licensees Perspective. Provide licensees position on the performance deficiency, if known.

c. Section 3, Branch Recommendations

1. Select from the following options:

(a) Region completes the detailed risk evaluation (DRE). Proceed to SERP, if necessary. Select this option when the SRA has determined that the finding can be evaluated with regional resources only. If possible, estimate a planned completion date for the DRE and planned SERP date. Coordinate with regional enforcement staff for the planned completion date(s).

(b) Request additional resources. Proceed to Planning SERP. Select this option when resources outside the region are necessary for completing the DRE.

Issue Date: 10/23/18 5 0609.05

Identify the additional resources required and form an SDP project team with all the individuals needed to complete the analysis. List those individuals on the IFRB Finding Form. Schedule a Planning SERP and provide the date on the IFRB Finding Form. Conduct planning SERP in accordance with IMC 0609, Attachment 1.

2. Proposed next steps. Include proposed next steps and actions, including proposed milestones and assignments for discussion at the IFRB.

d. Section 4, IFRB Outcome

1. Document the IFRB date and the date of any previous IFRBs on the issue.

2. Indicate whether this is an Initial IFRB or Follow-up IFRB. If it is a Follow-up IFRB, document the reason for the Follow-up IFRB.

3. Document IFRB logistical information.

4. List the IFRB attendees.

5. Document pertinent discussion or comments resulting from the IFRB related to the issue, including actions and due dates, as applicable. Additional actions could include, for example, gathering more information, additional evaluation of the performance deficiency, or accelerated due dates.

6. If the performance deficiency discussed at the IFRB is not approved, determine what is required for approval, next steps, and document who is to complete the action. Determine if communication with the licensee is required, at the appropriate level, to complete any of the actions developed.

7. If the performance deficiency discussed at the IFRB is approved, the IFRB Chair shall contact the respective licensees senior management to inform them of the regions decision to move forward with conducting a DRE and/or a Planning SERP. The IFRB Chair shall advise licensee management that all subsequent management level communications on the finding should be coordinated through the IFRB Chair.

04.02 IFRB Documentation Retention.

Once the IFRB is completed, the IFRB worksheet should be treated as a record of the IFRB, entered into the Agencywide Documents Access and Management System (ADAMS), and not further edited. If a follow-up IFRB is held it should have its own IFRB worksheet. IFRB worksheets should be included in the information provided to SERP members ahead of a SERP or PRCR.

IFRB packages containing supporting information for a SERP shall be saved to the SERP package repository in ADAMS, which can be accessed as follows:

1. Open ADAMS Navigator.

2. Click on the search icon on the left side ribbon.

3. Click on New Search.

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4. Add the following filters:

Document Type includes Enforcement Action Worksheet Docket Number starts with 05000

5. Click search.

IFRB packages associated with issues that will not move forward to a SERP should still be added to ADAMS, ensuring that the title includes the text IFRB for retrievability.

END Issue Date: 10/23/18 7 0609.05

EXHIBIT 1 - IFRB FINDING FORM INSPECTION FINDING REVIEW BOARD WORKSHEET If issue will go to SERP, attach to the SERP Worksheet and route together.

Section 1 - ISSUE

SUMMARY

Lead branch to complete prior to IFRB Facility: Click here to enter text. Licensee: Click here to enter text.

IFRB Chair: Click here to enter text. Lead Branch: Click here to enter text.

Issue Summary:

Provide a short summary of the degraded condition or issue of concern and how it was identified. Describe how the performance deficiency is the proximate cause of the degraded plant condition.

Issue Start Date 120 Days 165 Days 255 Days Click to add date Click to add date Click to add date Click to add date Will all timeliness metrics be met? Yes No If no, please explain:

Section 2 - ISSUE INFORMATION Lead Branch to complete prior to IFRB with support from SRA Proposed Performance Deficiency:

Provide a concise statement clearly stating deficient licensee performance and degraded plant condition based on proximate cause. Ref IMC 0612 Section 03.02 Associated Violation (if known and applicable):

Click here to enter text.

Affected Structures, Systems, Components (SSCs), Operator Actions, and Risk-Relevant Functions:

Click here to enter text.

Conditions when the performance deficiency would manifest Itself (e.g., type of event, plant configuration):

Click here to enter text.

Initial SDP Screening:

Click here to enter text.

Exposure Time:

Click here to enter text.

Are External Events Likely to be the Main Risk Contributor (i.e., earthquake, fire, external flooding, and tornados/high winds)? Yes No If yes, briefly describe the scenario where the component(s) would be called upon.

Is Recovery of the Failed Function Credible? Yes No If yes, describe under what conditions.

Issue Date: 10/23/18 Exh1-1 0609.05

Do Current PRA Techniques and Tools Apply? Yes No If not, describe alternate means to determine significance.

Additional Issue Complexities, if any:

Click here to enter text.

Licensees Perspective of the Issue:

Include description of licensees position on the performance deficiency if known.

Section 3 - BRANCH RECOMMENDATIONS Lead Branch to complete prior to IFRB with support from SRA. If no IFRB, document the basis.

Region completes the DRE. Document the basis Proceed to SERP, if necessary.

Reason(s) a Planning SERP is recommended:

Click here to enter text.

Additional comments for Planning SERP consideration:

Request Additional Provide any additional comments e.g., known Resources. Proceed to a conservatisms, significant uncertainties, influential Planning SERP.

assumptions.

Proposed Planning SERP Date: Click here to enter a date.

Proposed next steps and needs:

Discuss proposed evaluation methodology, level of effort, and resource needs.

Additional Information required Owner Due date Click here to enter a date.

Click here to enter a date.

Click here to enter a date.

Section 4 - IFRB OUTCOME Lead branch to complete at IFRB IFRB Date: Click to add date Previous IFRBs: Click here to enter text.

IFRB Type: Initial Follow-up Provide reason for Follow-up IFRB if applicable (e.g., revised PD)

IFRB

Participants:

IFRB Chair: Click here to enter text. Inspection Branch Chief: Click here to enter text.

Lead Inspector: Click here to enter text. SRA: Click here to enter text.

Projects Branch: Click here to enter text. Enforcement Specialist: Click here to enter text.

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Other(s): Click here to enter text.

Summary of IFRB Discussion:

Provide a short summary of the IFRB discussion topics and key decisions Performance Deficiency Approved: Yes No State the exact approved performance deficiency Next Steps and Actions:

Green issue, no SERP Planning SERP Complete DRE and SERP Assigned Date Action Owner Due date Click here to enter Click here to a date. enter a date.

Click here to enter Click here to a date. enter a date.

Click here to enter Click here to a date. enter a date.

IFRB Chair Signature: Date: Click to add date IFRB Chair to discuss IFRB outcome with Licensee individual: Click here to enter text.

senior licensee management Date contacted: Click to add date Issue Date: 10/23/18 Exh1-3 0609.05

EXHIBIT 2 - INSPECTION AND SIGNIFICANCE DETERMINATION PROCESS METRICS Issue Date: 10/23/18 Exh2-1 0609.05

EXHIBIT 3 - ESTIMATED TIMELINE FOR SDP COMPLETION ESTIMATED TIMELINE FOR SDP COMPLETION Est. time to complete Activity Metric Metric Date Actual Date Comments activity Event/Condition Occurs PD Metric:T=0 01/00/1900 60 days Licensee Evaluation complete, if needed 01/00/1900 Inspection Finding identified. SDP 6 weeks 01/00/1900 screening complete.

IFRB Conducted PD Metric: T=120 Exit 01/00/1900 IR Metric: T=0 6 weeks Detailed Risk Evaluation Complete 01/00/1900 NRR/DRA peer review complete. Submit 7 days 01/00/1900 package to Regional enforcement staff.

IFRB (SERP) package submitted to 7 days 01/00/1900 Headquarters SERP conducted.

IR Metric: T=45 Inspection report issued TBD 01/00/1900 SDP Metric: T=0 7 days Preliminary Determination Letter Issued 01/00/1900 Licensee Response to Preliminary 10 days 01/00/1900 Determination Letter 5 days Meeting Notice Issued 01/00/1900 Licensee Submits information prior to 01/00/1900 regulatory conference Regulatory Conference 01/00/1900 Receive additional information requested at 7 days 01/00/1900 the regulatory conference Post-conference review and final 14 days 01/00/1900 determination T=240 (after IR Approximate Enforcement Metric issued) 7 days Final determination letter in concurrence 01/00/1900 Final determination letter ready for OE, 10 days 01/00/1900 NRR, Reg concurrence. EN issued.

3 days Final determination letter issued. SDP Metric: T=90 01/00/1900 Note: These times are ONLY estimates based on past experience with more challenging and complex GTG inspection findings. Also, this is not a serial representation as some steps may be done concurrently.

Issue Date: 10/23/18 Exh3-1 0609.05

- Revision History Table for IMC 0609 Attachment 05TP Commitment Accession Description of Change Description of Comment Resolution and Tracking Number Training Closed Feedback Form Number Issue Date Required and Accession Number (Pre-Change Notice Completion Decisional, Non-Public Date Information)

ML16103A405 This is a new inspection manual chapter developed Presentations ML16110A211 10/28/16 as part of an NRC initiative to improve the efficiency were made in CN 16-028 and effectiveness for making decisions on greater three regional than Green inspection findings. This document will offices prior to be used throughout a test phase which is expected procedure to be completed by December 31, 2017, if not issuance. In sooner. addition, question and answer sessions will be conducted shortly after the procedure is issued.

No ML18187A183 Revised to incorporate applicable recommendations No ML18191A004 10/23/18 from the IFRM Effectiveness Review Report CN 18-036 (ML18123A319). Changes primarily reflect expansion of the IFRM process to all ROP cornerstones, revised criteria for holding an IFRB, and clarifications to the purpose of an IFRB. The IFRB-SERP worksheet was revised with the SERP worksheet being relocated to IMC 0609 Attachment 1 and the IFRM survey that supported the pilot period was removed.

Issue Date: 10/23/18 Att1-1 0609.05