ML19317F647

IMC 0611 Power Reactor Inspection Reports

ML19317F647
Person / Time
Issue date:	01/07/2020
From:	Cauffman C NRC/NRR/DRO/IRIB
To:
Cauffman C
Shared Package
ML20007E184	List: Inspection Manual Change Notice 20-003, Table of Contents for Inspection Manual Change Notice 20-003 ML19317F647
References
CN 20-003
Download: ML19317F647 (32)

Text

NRC INSPECTION MANUAL IRIB INSPECTION MANUAL CHAPTER 0611 POWER REACTOR INSPECTION REPORTS

Table of Contents 0611-01 PURPOSE ................................................................................................................ 1 0611-02 OBJECTIVES ........................................................................................................... 1 0611-03 DEFINITIONS ........................................................................................................... 1 0611-04 RESPONSIBILITIES AND AUTHORITIES ................................................................ 1 0611-05 FINDINGS AND VIOLATIONS .................................................................................. 2 0611-06 UNRESOLVED ITEMS ............................................................................................12 0611-07 DISCUSSED OPEN ITEMS .....................................................................................14 0611-08 LICENSEE-IDENTIFIED NON-CITED VIOLATIONS ...............................................14 0611-09 LICENSEE EVENT REPORT (LER) AND SECURITY EVENT REPORT (SER)

REVIEWS ................................................................................................................15 0611-10 CLOSURE OF CITED VIOLATIONS .......................................................................16 0611-11 VIOLATIONS WARRANTING ENFORCEMENT DISCRETION ...............................16 0611-12 MINOR PERFORMANCE DEFICIENCIES, MINOR VIOLATIONS, OBSERVATIONS, ASSESSMENTS, AND VERY LOW SAFETY SIGNIFICANCE ISSUES. .................17 0611-13 OTHER REQUIREMENTS ......................................................................................20 13.01 Treatment of Third Party Reviews ............................................................................20 13.02 Non-Routine Inspections..........................................................................................20 13.03 Treatment of Sensitive Unclassified Non-Safeguards Information (SUNSI) .............20 13.04 Amending Inspection Reports. .................................................................................21 13.05 Plain Language........................................................................................................21 13.06 Documenting Multiple Examples of a Finding. .........................................................21 13.07 Graphics/Visual Aids................................................................................................21 13.08 Caution Regarding the Creation of Staff Positions ...................................................21 0611-14 COMPILING AN INSPECTION REPORT ................................................................22 14.01 Cover Letter .............................................................................................................22 14.02 Cover Page..............................................................................................................22 14.03 Summary .................................................................................................................22 14.04 Table of Contents ....................................................................................................23 14.05 Plant Status .............................................................................................................23 14.06 Inspection Scopes ...................................................................................................23 14.07 Inspection Results ...................................................................................................25 14.08 Exit Meetings and Debriefs ......................................................................................25 14.09 Third Party Reviews .................................................................................................26 14.10 Documents Reviewed ..............................................................................................26 14.11 Report Attachments .................................................................................................26 14.12 Cover Letter Enclosures ..........................................................................................26 0611-15 ISSUING INSPECTION REPORTS .........................................................................26 15.01 Report Timeliness ....................................................................................................26 15.02 Submitting to Document Processing Center.............................................................26 15.03 Release and Disclosure of Inspection Reports.........................................................27 0611-16 REFERENCES ........................................................................................................27 EXHIBITS ................................................................................................................................28 APPENDICES ...........................................................................................................................28 ATTACHMENT 1 ................................................................................................................ Att1-1 Issue Date: 01/07/20 i 0611

0611-01 PURPOSE 01.01 Convey the basic requirements and content for preparing power reactor inspection reports.

01.02 Provide requirements for documenting power reactor inspections and findings, violations, and observations.

0611-02 OBJECTIVES 02.01 Clearly communicate significant inspection results in a consistent manner to licensees, NRC staff, and the public.

02.02 Document the basis for significance determination and enforcement action.

02.03 Document inspection results as input into the Operating Reactor Assessment Program (Inspection Manual Chapter (IMC) 0305) of the Reactor Oversight Process (ROP).

0611-03 DEFINITIONS The following terms along with those listed in IMC 0612, Issue Screening are applicable to documentation:

03.01 FIN. An inspection result type used to describe a finding without a violation. (Note, a finding with an associated violation(s) or violation(s) dispositioned using traditional enforcement without a finding will be designated as Apparent Violation (AV), Non-Cited Violation (NCV), or Notice of Violation (NOV).)

03.02 Observation. A factual detail noted during an inspection.

03.03 Sensitive Unclassified Non-Safeguards Information (SUNSI). Any information of which the loss, misuse, modification, or unauthorized access to can reasonably be foreseen to harm the public interest, the commercial or financial interests of the entity or individual to whom the information pertains, the conduct of NRC and Federal programs, or the personal privacy of individuals.

03.04 Reactor Program System - Inspection Module (RPS-Inspections). A web-based application that provides an integrated methodology for managing, planning, scheduling, reporting, documenting, and analyzing inspection functions and activities performed by the NRC. See IMC 0306, Planning, Scheduling, Tracking, and Reporting of the Reactor Oversight Process (ROP) for additional details concerning use of RPS-Inspections and the auto-report generation functionality within the application.

0611-04 RESPONSIBILITIES AND AUTHORITIES 04.01 General Responsibilities. Document inspections in accordance with the direction provided in this IMC. When generating and inspection report using RPS-Inspections the guidance in IMC 0306 supplements the requirements contained in IMC 0611.

Issue Date: 01/07/20 1 0611

04.02 Inspectors. Prepare power reactor inspection reports in accordance with the direction provided in this IMC. See IMC 0306 for requirements pertaining to how and when to use the auto-report generator function in RPS-Inspections.

a. Ensure that inspection results are objectively supported and accurately documented.

b. Ensure that inspection reports do not communicate regulatory determinations or actions not established in accordance with approved processes.

c. Ensure referenced material (such as documents reviewed) is correctly documented.

d. Ensure that the inspection report documents the conclusions presented to the licensee at the exit or re-exit meetings.

04.03 Branch Chiefs or Division Directors.

a. Review each inspection report to ensure it is consistent with the direction provided in this IMC.

b. Ensure the content, tone, overall regulatory focus, and timeliness of inspection reports are appropriate and support agency goals.

04.04 Division of Inspection and Regional Support - Reactor Inspection Branch.

a. Provide interpretations and support for information contained in this IMC.

b. Facilitate resolution of identified gaps in IMC directions and guidance.

0611-05 FINDINGS AND VIOLATIONS The directions for completing the table sections below can be found by going to the sections referenced in the brackets.

The following table shall be used to document findings without violation:

Table 1 - Finding without Violation (FIN)

[05.01a - Title]

Cornerstone Significance Cross-cutting Report Aspect Section

[05.01b - [05.01c1 - Significance and Tracking] [05.01d - Cross- [05.01e -

Cornerstone] Cutting Aspect] Section]

[05.01f - Introduction and Identification]

Description:

[05.02a - Description]

Corrective Actions: [05.02b - Corrective Actions]

Corrective Action

References:

[05.02c - Corrective Action References]

Issue Date: 01/07/20 2 0611

Performance Assessment:

Performance Deficiency: [05.03a - Performance Deficiency]

Screening: [05.03b - Screening]

Significance: [05.03c - Significance]

Cross-Cutting Aspect: [05.03d - Cross-Cutting Aspect]

Enforcement: The inspectors did not identify a violation of regulatory requirements associated with this finding.

[05.05 - Unresolved Item Closure]

The following table shall be used to document findings with violations being dispositioned using the ROPs SDP.

Table 2 - Finding with Violation

[05.01a - Title]

Cornerstone Significance Cross-cutting Report Aspect Section

[05.01b - [05.01c1 - Significance and Tracking] [05.01d - Cross- [05.01e -

Cornerstone] Cutting Aspect] Section]

[05.01f - Introduction and Identification]

Description:

[05.02a - Description]

Corrective Actions: [05.02b - Corrective Actions]

Corrective Action

References:

[05.02c - Corrective Action References]

Performance Assessment:

Performance Deficiency: [05.03a - Performance Deficiency]

Screening: [05.03b - Screening]

Significance: [05.03c - Significance]

Cross-Cutting Aspect: [05.03d - Cross-Cutting Aspect]

Enforcement:

Violation: [05.04b - Violation]

Enforcement Action: [05.04c - Enforcement Action]

[05.05 -Unresolved Item Closure]

Issue Date: 01/07/20 3 0611

The following table shall be used to document Traditional Enforcement (TE) violations without an associated finding. Refer to Section 0611-11 of this IMC when the violation involves enforcement discretion.

Table 3 - Traditional Enforcement Violation

[05.01a - Title]

Cornerstone Severity Cross-cutting Report Aspect Section Not Applicable [05.01c2 - Severity and Tracking] Not Applicable [05.01e -

Section]

[05.01f - Introduction and Identification]

Description:

[05.02a - Description]

Corrective Actions: [05.02b - Corrective Actions]

Corrective Action

References:

[05.02c - Corrective Action References]

Performance Assessment:

[05.03e - Traditional Enforcement Assessment]

Enforcement:

[05.04 - Reason]

Severity: [05.04a - Severity]

Violation: [05.04b - Violation]

Enforcement Action: [05.04c - Enforcement Action]

[05.05 - Unresolved Item Closure]

The following table shall be used to document findings with associated TE violations documented together in the same report. Findings with associated TE violations are those findings and violation sharing a common performance deficiency or closely related by cause and effect, or both.

Table 4 - Finding with Traditional Enforcement Violation

[05.01a - Title]

Cornerstone Significance/Severity Cross-cutting Report Aspect Section

[05.01b - [05.01c3 - Significance/Severity and [05.01d - Cross- [05.01e -

Cornerstone] Tracking] Cutting Aspect] Section]

[05.01f - Introduction and Identification]

Description:

[05.02a - Description]

Issue Date: 01/07/20 4 0611

Corrective Actions: [05.02b - Corrective Actions]

Corrective Action

References:

[05.02c - Corrective Action References]

Performance Assessment:

Performance Deficiency: [05.03a - Performance Deficiency]

Screening: [05.03b - Screening]

Significance: [05.03c - Significance]

Cross-Cutting Aspect: [05.03d - Cross-Cutting Aspect]

Enforcement:

[05.04 - Reason]

Severity: [05.04a - Severity]

Violation: [05.04b - Violation]

Enforcement Action: [05.04c - Enforcement Action]

[05.05 - Unresolved Item Closure]

05.01 Header.

a. Title. Provide a title that describes the performance deficiency or violation when there is no finding (e.g., Failure to Remove Plastic Shipping Plug during Rosemount Transmitter Installation, Failure to Establish Proper Electrical Connections during Main Transformer Maintenance, or Failure to Obtain Prior Approval for a Change Which Decreased the Effectiveness of the Emergency Plan).

b. Cornerstone. Enter the cornerstone associated with the finding (i.e., Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, or Security).

c. Synopsis.

1. Significance and Tracking.

(a) On the first line, enter the significance color/status of the finding (i.e., Green, Pending, Preliminary White, Preliminary Yellow, Preliminary Red, or Preliminary Greater than Green).

(b) On the second line, enter FIN, NCV, NOV, or AV followed by the Tracking Number ([Docket Number(s)]/[Report Number]-[Unique Sequential Integer]),

as described in IMC 0306.

Issue Date: 01/07/20 5 0611

(c) On the third line, enter the status of the finding. Enter Open/Closed for Green FIN, Green NCV, and Green NOV when no licensee response is required. Otherwise designate as Open.

(d) On the fourth line for Preliminary White/Yellow/Red/Greater than Green findings and NOVs (if applicable), obtain and enter the Enforcement Action Number (EA-##-###).

2. Severity and Tracking.

(a) On the first line, enter the severity level of the violation or apparent violation (i.e., Severity Level IV or Apparent Violation).

(b) On the second line, enter NCV, NOV, or AV followed by the Tracking Number ([Docket Number(s)]/[Report Number]-[Unique Sequential Integer]),

as described in IMC 0306.

(c) On the third line, enter the status of the violation. Enter Open/Closed for Severity Level (SL) IV NCV and SL IV NOV when no licensee response is required. Otherwise designate as Open.

(d) On the fourth line for AVs or NOVs (if applicable), obtain and enter the Enforcement Action Number (EA-##-###).

3. Significance/Severity and Tracking.

(a) On the first line, enter the significance of the finding (i.e., Green, Pending, Preliminary White, Preliminary Yellow, Preliminary Red, or Preliminary Greater than Green).

(b) On the second line, enter the severity level of the violation or apparent violation on the second line. Indicate the apparent violation is being assessed using traditional enforcement (i.e., Severity Level IV or Apparent Violation (Traditional Enforcement)).

(c) On the third line, enter NCV, NOV, or AV followed by the Tracking Number

([Docket Number(s)]/[Report Number]-[Unique Sequential Integer]), as described in IMC 0306.

(d) On the fourth line, enter the status of the finding/violation. Enter Open/Closed for Green/SL IV NCV and Green/SL IV NOV when no licensee response is required. Otherwise designate as Open.

(e) On the fifth line, for AVs or NOVs (if applicable), obtain and enter the Enforcement Action Number (EA-##-###).

d. Cross-Cutting Aspect. Provide the alpha-numeric identifier associated with the selected Cross-Cutting Aspect (CCA) listed in IMC 0310, followed by the title of the aspect (e.g., [H.1] - Resources). When no CCA is assigned enter None (Not Present Performance), None when there is no corresponding CCA that describes the most-significant contributor, or Not Applicable when there is no finding.

Issue Date: 01/07/20 6 0611

e. Section. List the inspection procedure number.

f. Introduction and Identification. Identify the requirement or standard that was not met, the significance, and the assignment of identification (i.e., self-revealed, NRC-identified, or licensee-identified). For violations, indicate whether it is an NOV, AV, or NCV. Examples:

For FIN: A self-revealed Green finding was identified when the licensee failed to

[identify unmet standard]. Specifically, the licensee failed to [describe how the licensee failed to meet the standard].

For Finding with Violation: The inspectors identified a Green finding and associated Non-cited Violation (NCV) of [identify unmet requirement] when the licensee failed to [describe how the licensee failed to meet the requirement].

For Traditional Enforcement Violation: A self-revealed Severity Level IV Non-cited Violation (NCV) of [identify unmet requirement was identified] was identified when the licensee failed to [describe how the licensee failed to meet the requirement].

For Finding with Traditional Enforcement Violation: The inspectors identified a Green finding and associated Severity Level IV Non-cited Violation (NCV) of

[identify unmet requirement] when the licensee failed to [describe how the licensee failed to meet the requirement].

05.02 Description and Corrective Actions.

a. Description. Describe the circumstances associated with the finding or violation or both, and include the factual information that is both necessary and sufficient to support the determinations described in the performance assessment and enforcement sections and to enable an informed, independent reader to understand the actual or potential impact to safety or security. Most findings can be described in less than one page and should rarely exceed two pages; findings based on more-complex circumstances may merit more discussion.

Include the approximate dates the NRC and licensee became aware of the problem.

Also include references to any other documented inspection activities or docketed correspondence associated with the finding or violation (e.g., Unresolved Items (URIs), LERs) as appropriate.

For findings or violations determined to be NRC-identified because the inspector identified a previously unknown weakness in the licensees classification, evaluation, or corrective actions, include evidence that the licensee had identified the issue but failed to properly classify, evaluate, or correct the problem.

When the guidance contained in an Operating Experience Smart Sample (OpESS) contributed to the identification of a finding, identify the OpESS procedure by including a statement similar to Operating Experience Smart Sample 2012-01, High Wind Generated Missile Hazards contributed to the identification of this finding.

Issue Date: 01/07/20 7 0611

b. Corrective Actions. Describe in sentence format any licensee corrective actions taken. As applicable, describe any immediate corrective actions taken to restore compliance, or address any immediate safety or security concerns. As applicable, indicate why continued non-compliance does not present an immediate safety or security concern. As applicable, describe any compensatory measures in place while licensee long-term corrective measures are being implemented.

c. Corrective Action References. Provide a reference to any established licensees corrective action program document number(s).

05.03 Performance Assessment. The level of detail must allow a knowledgeable reader to reconstruct the decision logic used to arrive at any documented conclusions.

a. Performance Deficiency. State the performance deficiency. Identify the requirement or standard that was not met and describe how the licensee failed to satisfy the requirement or standard. Refer to Section 13.06 when documenting multiple examples of a finding.

b. Screening. Identify an appropriate More-than-Minor screening question found in IMC 0612 Appendix B that was answered yes for the stated performance deficiency. Describe the reason why the identified screening question was answered yes (e.g., describe how the cornerstone objective was adversely affected, or describe the potential to lead to a more significant safety concern if left uncorrected).

c. Significance. Describe the logic used to determine the significance of the finding. If the significance has been determined, then characterize the finding as described below. For those findings with pending significance (i.e., the Significance Enforcement Review Panel (SERP) has not determined the significance characterization), state that the finding could not be screened to Green and is pending a significance determination. Characterize the finding as described in items 1(a), 2(a), 4(a), and 4(b) below. When the preliminary or final significance determination is complete, document the remaining items below in a subsequent inspection report or cover letter.

1. For all SDP results describe:

(a) the affected cornerstone as determined by IMC 0609, Attachment 4; (b) the SDP Appendix used in the determination, as applicable; (c) any assumptions used in the determination (these assumptions may be referenced and described in the report attachment; and (d) the resulting color.

2. For risk-informed SDP (e.g., IMC 0609 Appendix A, F, G, H, and K) results describe:

(a) The screening criteria used to assess the finding as Green or the satisfied screening criterion that caused the finding to be assessed in a more Issue Date: 01/07/20 8 0611

detailed risk evaluation or analysis. For a detailed risk evaluation or analysis that results in a Green characterization, include the most dominant core damage sequences, any remaining mitigation capability, recovery credit, or both, that limited the significance and the exposure time.

(b) For a detailed risk evaluation that results in a greater than Green characterization, include:

(1) the most dominant core damage sequences (2) any mitigation capability that affected the significance (3) any recovery credit that affected the significance (4) exposure time The detailed risk evaluation can be documented in the significance section of the report, included as a report attachment, or can be a standalone document in ADAMS and referenced in the report.

3. For deterministic SDP (e.g., IMC 0609 Appendix B, C, D, E, I, J, L, and M) results describe:

(a) the table or flowchart used; and (b) the path on the flowchart used to arrive at the conclusion.

4. For all pending or preliminarily significance characterizations discuss the following:

(a) For findings with preliminarily significance, include the risk characterization or other basis, as determined by the SERP.

(b) State that the significance determination is preliminary or pending an initial significance characterization. Emphasize that the safety or security characterization is not yet finalized. Do not make statements regarding safety or security significance in the inspection report when the agency has not yet reached a conclusion.

d. Cross Cutting Aspect. Include the basis for assigning or not assigning the CCA.

1. When a CCA is assigned:

(a) Identify which CCA described in IMC 0310 best corresponds to the apparent cause or most significant causal factor of the performance deficiency. Provide the alpha-numeric identifier associated with the selected CCA followed by the title and description of the aspect. (e.g., H.1

- Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.)

(b) Identify the apparent cause or most-significant contributor of the performance deficiency and explain why it best aligns with the assigned CCA.

Issue Date: 01/07/20 9 0611

(c) If assigning a CCA to a finding that occurred outside of the nominal three-year period for present performance, explain why the identified apparent cause or most significant causal factor represents present licensee performance.

(d) For licensee-Identified findings with pending or preliminary significance, state that the assigned CCA is dependent on the final significance determination being White, Yellow, or Red.

2. When a CCA is not assigned, include a statement briefly describing the reason.

Examples:

No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

No cross-cutting aspect was assigned to this finding because the inspectors determined that none of the cross-cutting aspects described in Inspection Manual Chapter 0310 corresponded to the apparent cause or most significant causal factor of the performance deficiency.

e. Traditional Enforcement Assessment. When a TE violation is documented without an associated finding, indicate why.

1. When no performance deficiency exists, include a statement similar to:

The NRC determined that this violation was not reasonably foreseeable and preventable by the licensee and, therefore, is not a performance deficiency.

2. When a minor performance deficiency exists, include a statement similar to:

The NRC determined this violation was associated with a minor performance deficiency.

3. When the TE violation is associated by common performance deficiency with a previously documented finding, reference the tracking number of the finding and include a statement similar to:

This violation was associated with a previously documented finding assessed using the significance determination process which was documented under FIN

[Docket Number(s)]/[Report Number]-[Unique Sequential Integer].

05.04 Enforcement. Violations must be dispositioned in accordance with the Enforcement Policy. Additional enforcement related guidance can be found in the Enforcement Manual.

For 10 CFR 50, Appendix B, Criterion XVI violations involving significant conditions adverse to quality and repetition, refer to the Enforcement Manual for additional documentation requirements.

Issue Date: 01/07/20 10 0611

Reason. Describe why TE is being used to disposition the violation (i.e. willfulness, impacting regulatory process, actual consequence, or a violation without a finding). Include a statement similar to:

The ROPs significance determination process does not specifically consider [willfulness or the regulatory process impact] in its assessment of licensee performance. Therefore, it is necessary to address this violation which [involves willfulness or impedes the NRCs ability to regulate] using traditional enforcement to adequately deter non-compliance.

a. Severity. Describe the logic used to determine the SL of the violation and the resulting SL. Include reference to Enforcement Policy examples. For AVs, indicate the NRC has not made an enforcement decision.

Note: Inspection reports that contain material that may be related to an ongoing investigation must be reviewed by the Office of Investigations and the Office of Enforcement prior to issuance.

b. Violation. Document the disposition of violations as follows:

1. Describe what requirement was violated and how it was violated (this requires a contrary to statement consistent with guidance in the Enforcement Manual, using language that is parallel to that of the requirement).

2. Describe when the violation occurred and how long it existed (Use bracketing dates or date and duration. Indicate when estimated or ongoing at time of the exit meeting).

Use the following format, unless directed otherwise by the Enforcement Manual:

[Requirement violated] requires [Requirement].

Contrary to the above, [When the violation occurred and how long it existed. (e.g.,

from January 20, 2012 (estimated) to January 30, 2012)], the licensee [what the licensee did contrary to the requirement].

c. Enforcement Action. For NCVs, AVs, and NOVs, provide a statement similar to:

1. NCVs: This violation is being treated as a Non-Cited Violation (NCV),

consistent with Section 2.3.2 of the Enforcement Policy.

2. AVs: This violation is being treated as an apparent violation (AV) pending a final significance (enforcement) determination.

3. NOVs: See the Enforcement Manual for guidance on developing the notice and cover letter.

If an NOV is being used to disposition a violation normally dispositioned as an NCV (e.g., Green finding), describe the circumstances in accordance with Section 2.3.2.a of the Enforcement Policy (e.g., This violation is being cited because the licensee failed to place it in the corrective action program to restore Issue Date: 01/07/20 11 0611

compliance and address recurrence consistent with Section 2.3.2 of the Enforcement Policy., This violation is being cited because the licensee failed to restore compliance within a reasonable period of time after the violation was identified consistent with Section 2.3.2 of the Enforcement Policy., or This violation is being cited because the violation was willful.). Record all NOV related corrective action program document number(s) in section 05.02c.

05.05 Unresolved Item Closure. If a finding or very low safety significant issue results in a URI closure, include a reference to URI [Docket Number(s)]/[Report Number]-[Unique Sequential Integer] being closed to this finding. (e.g., This finding closes URI 050000123/2014007-01.).

0611-06 UNRESOLVED ITEMS Use the following table to document URIs being opened. Do not document URIs in the list of findings and violations section or in the inspection report cover letter.

Table 5 - Open Unresolved Item Unresolved Item [06.01a -Title and Tracking] [05.01e -

(Open) Section]

Description:

[06.01b1 - Description]

Planned Closure Actions: [06.01c - Planned Closure Actions]

Licensee Actions: [06.01d - Licensee Actions]

Corrective Action

References:

[05.02c - Corrective Action References]

Use the following table to document URI closures associated with no finding or minor violation determinations (e.g., not reasonably within the licensee ability to foresee and correct, minor performance deficiency, or not a violation or licensee standard). Do not use Table 6 to document URI closures associated with findings or violations using Section 0611-05, licensee-identified NCVs using Section 0611-08, enforcement discretion using Section 0611-11, or the Very Low Safety Significance Issue Resolution Process using Section 0611-12, because the URIs closure bases will captured in the respective writeup. Document the URI closure in the results section of the report under the inspectable area associated with the sample or inspection activity that resulted in the opening of the URI. Otherwise, such as in cases where the URI was opened during a reactive inspection, document the closure under the inspectable area associated with the sample or inspection activity used to inspect the URI (typically a baseline procedure).

Issue Date: 01/07/20 12 0611

Table 6 - Closed Unresolved Item Unresolved Item [06.01a -Title and Tracking] [05.01e -

(Closed) Section]

Description:

[06.01b2 - Description]

Corrective Action

References:

[05.02c - Corrective Action References]

06.01 Unresolved Item.

a. Title and Tracking. Provide a title for the URI. The title should describe the issue of concern (e.g., Cable Insulation Resistance during Flooding) on line one. On line two, enter URI followed by the [Docket Number(s)]/[Report Number]-[Unique Sequential Integer], as described in IMC 0306.

b. Description. Describe the URI using Section 05.02 of this IMC as a guide.

1. When opening a URI, clearly state that an URI was identified, and describe the issue with sufficient detail so that another inspector could complete the inspection and documentation effort. Indicate whether the issue of concern was, in part, determined to be performance deficiency, violation, or more-than-minor and indicate what additional information is needed to make the performance deficiency, violation, or more-than-minor determination.

2. When closing a URI, the level of detail devoted to closing URIs depends on the nature and significance of the additional information identified.

In the first paragraph, summarize the topic, inspector follow-up actions, and describe any licensee actions.

In the second paragraph, include why the issue was or was not a finding or more than minor violation (e.g., not reasonably within the licensee ability to foresee and correct, minor performance deficiency, or not a violation or licensee standard).

Caution should be used when describing why a violation didnt exist. See Section 13.08.

If resolution to a URI was based on discussions between inspector(s) and Nuclear Reactor Regulation (NRR) technical staff, concisely document the details of these discussions. Additionally, branch chiefs of the inspector(s) and technical staff who were involved in these discussions should concur on the inspection report.

c. Planned Closure Actions. Identify the specific licensee or NRC actions needed to determine whether the issue of concern is a performance deficiency, violation, or more-than-minor.

d. Licensee Actions. Describe any corrective actions taken to eliminate any perceived immediate safety or security concerns.

Issue Date: 01/07/20 13 0611

0611-07 DISCUSSED OPEN ITEMS Use the following table to document open items being discussed.

Table 7 - Discussed Item

[07.02a - Item Type] [07.02b -Title and Tracking] [05.01e -

(Discussed) Section]

Discussion: [07.02c - Discussion]

07.01 Discussed Open Items. Open Items such as unresolved items, apparent violations, preliminary and pending findings, and notices of violation requiring a response were assigned an open tracking status in a previously issued inspection report. Document discussed open items in the results section of the report under the inspectable area associated with the sample or inspection activity that resulted in the opening of the item.

a. Item Type. Describe the item type (e.g., Unresolved Item).

b. Title and Tracking. Enter the previously used title and tracking number assigned when the item was opened in a prior report on lines one and two.

c. Discussion. Capture follow up actions, pertinent facts gathered, and observations which may support a disposition of the potential violation or finding assessment.

0611-08 LICENSEE-IDENTIFIED NON-CITED VIOLATIONS Licensee-identified violations, which meet the requirements for an NCV in accordance with Section 2.3.2.a of the Enforcement Policy, should receive minimal documentation. These licensee-identified NCVs are not considered during the assessment process to prevent discouraging aggressive problem identification processes.

All other non-minor violations must be documented in accordance with Section 0611-05 or 0611-11.

Document licensee-identified violations in the results section of the report under the inspectable area associated with the sample or inspection activity. Use the following table to document licensee-identified violations.

Table 8 - Licensee-Identified Non-Cited Violation Licensee-Identified Non-Cited Violation [05.01e -

Section]

This violation of very low safety significant was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: [05.04b - Violation]

Significance/Severity: [08.01 - Significance/Severity]

Issue Date: 01/07/20 14 0611

Corrective Action

References:

[05.02c - Corrective Action References]

[05.05 - Unresolved Item Closure]

08.01 Significance/Severity.

a. For violations of very low safety or security significance (Green), briefly explain why the finding is Green.

b. For SL IV violations, identify why TE is applicable and briefly describe the SL categorization in accordance with the Enforcement Policy.

Note: Licensee identified NCVs are documented because they were identified within the scope of inspection and Enforcement Policy requires their disposition. These NCVs are not assessed in the ROP so as not to discourage aggressive licensee problem identification and resolution processes. In support efficient documentation and acknowledging the fact all violations need to be corrected, the documentation of the minor or more determination is not required for licensee identified NCVs.

0611-09 LICENSEE EVENT REPORT (LER) AND SECURITY EVENT REPORT (SER)

REVIEWS LERs and SERs are submitted by licensees and are reviewed and inspected using IP 71153, Follow-up of Events and Notices of Enforcement Discretion. Document reviewed LERs and SERs in the scope section of the report under Section 71153. Document the review by identifying the SER or LER reviewed and providing a general reference to the submitted document as illustrated below for an LER.

The inspectors evaluated the following licensee event reports (LERs):

(1) Licensee Event Report [Unique Identifier e.g., 05000325/2014-005-00], [Title] (ADAMS accession: ML#########)

Any findings and violations identified during the LER or SER review, including violations which are minor, shall be dispositioned in the report.

If the LER or SER review is documented in a separate NRC correspondence or inspection report and the review involves an updated submittal, then provide reference in report Section 71153 to the correspondence or inspection with a statement similar to:

The inspectors reviewed the updated LER submittal. The previous LER submittal was reviewed in Inspection Report [Docket Numbers]/[Report Numbers].

If the circumstances surrounding an LER or SER review are documented in a separate NRC correspondence or inspection report, then provide reference in report Section 71153 to the correspondence or inspection with a brief statement similar to:

Issue Date: 01/07/20 15 0611

The circumstances surrounding this LER are documented in [Inspection Report [Docket Numbers]/[Report Numbers] Section [Section].

Additionally, include a statement similar to the following when no performance deficiency nor violation was identified during the LER or SER review:

The inspectors determined that the cause of the condition described in the LER was not reasonably within the licensees ability to foreseen and corrected and therefore was not reasonably preventable. No performance deficiency nor violation of NRC requirements was identified.

0611-10 CLOSURE OF CITED VIOLATIONS After receipt of the licensees response to an NOV and the satisfactory completion of any required supplemental inspections, document the closure of the cited violation. Generally, this will be captured in the Supplemental Inspection Report and its cover letter, along with the corresponding Action Matrix response and assessment letter. However, Green or SL IV NOVs may need to be documented in the inspection report as being closed when the NRC has verified a satisfactory docketed licensee response. In such cases, include a sentence similar to the following in the scope section of the report associated with the sample or inspection activity used to inspect the NOVs closure:

The inspectors reviewed the licensees response to NOV [Docket Number(s)]/[Report Number]-

[Unique Sequential Integer] and determined that the reason, corrective actions taken and planned to address recurrence, and the date when full compliance will be/was achieved for this violation is adequately addressed and captured on the docket.

0611-11 VIOLATIONS WARRANTING ENFORCEMENT DISCRETION Bring violations that may warrant enforcement discretion (e.g., escalated violations without performance deficiencies) to the attention of the Regional Enforcement Coordinator. Default to any overriding directions found in an Interim Enforcement Policy, an Enforcement Guidance Memorandum, or the Enforcement Manual. Unless otherwise directed, document violations receiving enforcement discretion in the results section of the report under the applicable inspectable area. Use the following table to document violations receiving enforcement discretion.

Table 9 - Enforcement Discretion Enforcement [11.01 - Enforcement Action] [05.01e -

Discretion Section]

Description:

[05.02a - Description]

Corrective Actions: [05.02b - Corrective Actions]

Corrective Action

References:

[05.02c - Corrective Action References]

Enforcement:

Issue Date: 01/07/20 16 0611

Severity/Significance: [05.04a - Severity]

Violation: [05.04b - Violation]

Discretion Basis: [11.02 - Discretion]

[11.03 - Unresolved Item Closure]

11.01 Enforcement Action. Identify the Enforcement Action Number and provide a title with a reference to any applicable Enforcement Guidance Memorandum (EGM). Example:

Enforcement Action 17-003: Emergency Diesel Generator Exhaust Stack - Tornado Missile Protection (EGM 15-002)"

11.02 Discretion. State why enforcement discretion is being granted. Include an appropriate statement such as:

The NRC exercised enforcement discretion in accordance with Section [#.#] of the Enforcement Policy because [reason].

Note: Violations that receive enforcement discretion are not assigned an ROP tracking number but are listed as additional tracking items. They must be assigned an enforcement action (EA) number, which can be obtained through the Regional Enforcement Coordinator. The cover letter must contain the required language for exercising enforcement discretion.

11.03 Unresolved Item Closure. If the granting of enforcement discretion results in a URI closure, include a reference to URI [Docket Number(s)]/[Report Number]-[Unique Sequential Integer] being closed. (e.g., This closes URI 050000123/2014007-01.).

0611-12 MINOR PERFORMANCE DEFICIENCIES, MINOR VIOLATIONS, OBSERVATIONS, ASSESSMENTS, AND VERY LOW SAFETY SIGNIFICANCE ISSUES.

Minor performance deficiencies, minor violations, and observations are not routinely documented in inspection reports. However, observations may be documented when specifically allowed by an inspection procedure (e.g., 71152) or temporary instruction. Minor performance deficiencies and minor violations would only be documented when it becomes necessary to capture a required inspection activity or conclusion for the record, such as closing out an LER, SER, or URI or when the report describes a condition or situation that would raise a question as to why a finding or violation is not being documented. When a minor performance deficiency or violation is documented, provide enough detail to allow an informed, independent reader to understand the basis for the minor determination. Document minor performance deficiencies or violations in the results section of the report under the applicable inspectable area, when necessary.

Use the following two tables to document minor performance deficiencies and violations associated with the review and inspection of licensee submittals, such as LERs. Document minor performance or violations associated with URI closures in accordance with Section 06.01b2. Document all other minor performance deficiencies and violations where they are discussed in the report along with the screening and applicable enforcement basis Issue Date: 01/07/20 17 0611

described in Section 12.01. For example, when documenting an observation with an associated minor violation, document the minor violation with the observation using Table 12.

Table 10 - Minor Performance Deficiency Minor Performance Deficiency [05.01e -

Section]

Minor Performance Deficiency: [12.01a - Minor Issue]

Screening: [12.01b - Screening]

Table 11 - Minor Violation Minor Violation [05.01e -

Section]

Minor Violation: [12.01a - Minor Issue]

Screening: [12.01b - Screening]

Enforcement: [12.01c]

12.01 Minor Performance Deficiency / Minor Violation

a. Minor Issue. Briefly describe the minor performance deficiency or minor violation.

b. Screening. State the reason why the performance deficiency or TE violation is minor in accordance with IMC 0612 Appendix B, More-than-Minor screening questions or the Enforcement Policy, as applicable.

c. Enforcement. For violations, state the licensee has taken actions to restore compliance and include a statement similar to the following: This failure to comply with

[requirement] constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

12.02 Observations / Assessments When specifically allowed by the IP, document observations in the results section of the report under the applicable inspectable area. Use the following table to document observations.

Provide a title for observations. Include a title which describes the observation (e.g., Repetitive Safety Relief Value Surveillance Failures).

Table 12 - Observation Observation: [12.02 - Title] [05.01e -

Section]

Issue Date: 01/07/20 18 0611

Document the biennial problem identification and resolution program and other supplemental (e.g., assessment conclusion regarding holding open or closing an inspection finding) or infrequent abnormal assessments in the results section of the report using the following table.

Note assessments are different than observations because observations only communicate factual details and do not draw conclusions.

Table 13 - Assessment Assessment [05.01e -

Section]

12.03 Very Low Safety Significance Issue Resolution Process Use the following table to document issues in accordance with the very low safety significance issue resolution process. Do not use this table to document an issue that is a more than minor performance deficiency.

Table 14 - Very Low Safety Significance Issue Resolution Process Very Low Safety Significance Issue Resolution Process: [12.03a - Title] [05.01e -

Section]

This issue is a current licensing basis question and inspection effort is being discontinued in accordance with the Very Low Safety Significance Issue Resolution (VLSSIR) process. No further evaluation is required.

Description:

[12.03b - Description]

Licensing Basis: [12.03c - Licensing Basis]

Significance: [12.03d - Significance]

Technical Assistance Request: [12.03e - Technical Assistance Requests]

Corrective Action

Reference:

[05.02c - Corrective Action References]

[05.05 - Unresolved Item Closure]

a. Title. Include a title which describes the very low safety significance issue.

b. Description. Describe the circumstances associated with the issue.

c. Licensing Basis. Describe the licensees supporting basis on why the issue of concern is not in their licensing basis and any relevant information on the licensing basis developed during the inspection process.

d. Significance. Describe the logic used to determine that the issue of concern would not have proceeded to a detailed risk evaluation if processed through IMC 0609, Significance Determination Process as a performance deficiency for the purpose of Issue Date: 01/07/20 19 0611

the VLSSIR process. Describe the screening criteria used to assess the issue of concern. For example:

For the purpose of the VLSSIR process, the inspectors screened the issue of concern through IMC 0609, Appendix X and determine the issue of concern would likely be Green had a performance deficiency been identified.

e. Technical Assistance Requests. If the issue of concern was processed through NRRs COM-106, Technical Assistance Request (TAR) Process, briefly summarize how the results of that process led to the issue being documented in accordance with the VLSSIR process.

0611-13 OTHER REQUIREMENTS 13.01 Treatment of Third Party Reviews. When reviewing Institute of Nuclear Power Operations (INPO) or other third party evaluations, accreditation reports in accordance with Executive Director of Operations Policy 220, include in THIRD PARTY REVIEWS section of the report a brief statement that the review was completed. Do not include a recounting or listing of INPO conclusions or reference a final INPO rating. Discuss the specifics of any significant differences between NRC and INPO perceptions with regional management.

Further, INPO related conclusions, recommendations, or corrective actions are not referenced in NRC inspection reports. If an INPO or other third party issue is of such safety significance that it warrants tracking, it should be independently evaluated, inspected, documented, and then tracked as an NRC finding or URI.

INPO conclusions, recommendations, corrective actions, and operating experience which are placed in the licensees corrective action program, are considered appropriate for inspection.

When documenting review of these issues, inspection reports should not reference INPO reports or documents, INPO designations, or specific sites affected by operating experience.

Referencing the licensees corrective action program and providing a brief description (e.g.,

Condition Report 235235 concerning industry information on pumps.) will generally suffice.

13.02 Non-Routine Inspections. Results from IMC 2515 Appendix C inspections, temporary instructions, or other non-routine inspection activities are documented in the OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL section of the report. See IMC 0611, Exhibit 1, Standard Reactor Inspection Report Outline. If it is necessary to document a minor issue, minor violation, or observation follow the directions in Section 0611-12, Minor Performance Deficiencies, Minor Violations, Observations, And Assessments. Temporary Instructions or other non-routine procedures may provide more specific documentation instructions, which take precedence over IMC 0611. If clarification is needed on proper integration into the report, contact the program office.

13.03 Treatment of Sensitive Unclassified Non-Safeguards Information (SUNSI). SUNSI must not be made publicly available and must be segregated from other portions of the report, which are to be made publicly available. This can typically be accomplished by creating and referencing a separate report enclosure, which can be profiled in Agencywide Documents Access and Management System (ADAMS) as Non-Publicly Available. The documents containing SUNSI must be marked in accordance with Management Directive 12.6, NRC Sensitive Unclassified Information Security Program. Security inspection reports should not be used to document inspection activities or findings that fall outside of the security cornerstone.

Issue Date: 01/07/20 20 0611

Additional staff direction for handling of SUNSI is published on the NRC internal Web site at https://drupal.nrc.gov/sunsi and IMC 0620, Inspection Documents and Records.

13.04 Amending Inspection Reports. If it becomes necessary to correct an issued report for the record, revise the previously issued report and reissue it in its entirety under the same inspection report number. The revised report must receive a new and unique ADAMS accession number and must be added into an ADAMS package, which contains the original report. The cover letter accompanying the reissued report must reference the inspection report it replaces with its associated ADAMS accession number, explain why the report is being reissued, briefly describe the changes, including the renumbering of any results, and indicate which section of the report was revised. The cover letter should not reiterate previously communicated information. Changes which affect the Action Matrix or Cross-cutting Issues must be coordinated with the ROP Assessment Branch (IRAB). After the report is revised, the responsible branch should update RPS-Inspections as appropriate and contact the IRAB lead for IMC 0305, Operating Reactor Assessment Program to initiate any required public web page updates in accordance with IMC 0306. Note that a revised inspection report must not be used to document new inspection findings or inspection activities, which occurred after the initial report was issued.

13.05 Plain Language. Use plain language in reports. For additional direction, refer to NUREG-1379, NRC Editorial Style Guide.

13.06 Documenting Multiple Examples of a Finding. Multiple examples of the same performance deficiency that share the same cause and require the same corrective actions shall be documented as a single finding. Note that each example must be able to stand alone as a finding. Do not use the number of finding examples to aggregate the significance; base the significance off the most significant example. Provide an accounting of the examples after stating the performance deficiency.

13.07 Graphics/Visual Aids. Use graphics (drawings, diagrams, photographs, or photocopies) if their inclusion will simplify describing a complex condition that would otherwise require substantially more text.

Photographs of plant areas or equipment or photocopies of technical or vendor manual pages must be handled in accordance with IMC 0620, Inspection Documents and Records. When including graphics, the following should be considered:

a. Format as a jpeg and adjust size (height, width, and resolution) so as not to significantly increase overall file size.

b. Locate on less than 1/2 page or put in an attachment.

c. Center on page and left/right indented from the text.

d. Include a unique identifier (Figure/Diagram/Photograph X) with a descriptive title (e.g.,

Breaker Trip Latch Alignment).

13.08 Caution Regarding the Creation of Staff Positions.

The statement The NRC inspectors did not identify any findings or violations of more than minor significance, does not create a staff position. This language acknowledges the possibility Issue Date: 01/07/20 21 0611

that there were non-compliances but that the inspectors did not document them in the report (e.g., because of the sampling nature of the inspection process, the inspectors area of expertise, or because any identified noncompliances were found to be minor).

However, if the inspection report states, The licensee complied with [Requirement X], as related to an issue of concern, that language would constitute a staff position. If the NRC subsequently determined there is a noncompliance with Requirement X related to the issue of concern, then the NRC may need to consider that discovery a change in staff position subject to the backfitting provisions.

As such, the staff must exercise caution and avoid creating staff positions by not documenting statements about the adequacy of the licensing basis or statements about licensee compliance (some exceptions may apply depending on the type of inspection).

0611-14 COMPILING AN INSPECTION REPORT Compile and arrange the inspection report using Exhibit 1, Standard Reactor Inspection Report Outline, as a guide. The Enforcement Manual for enforcement related matters and IMC 0305, Operating Reactor Assessment Program for assessment related matters may also provide additional directions.

14.01 Cover Letter. Write a cover letter to communicate the overall inspection results and the inspection findings to the licensee. Inspection reports are sent from the applicable NRC official (Branch Chief, Division Director, or Regional Administrator) to the designated licensee executive. Refer to Exhibit 4, ROP Inspection Report Cover Letter Templates for additional requirements. Cover letter formats for communicating enforcement actions vary and are found in the Enforcement Manual, Appendix B. An EA number shall be obtained from the Office of Enforcement and included on the cover letter when either required by the Enforcement Manual or when a finding having preliminary significance is documented in the inspection report.

14.02 Cover Page. The report cover page gives a succinct summary of information about the inspection. It contains: the docket number(s), license number(s), report number, enterprise project identifier, licensee name, facility name, facility location (city and state), dates of the inspection, names and titles of participating inspectors (and may include names of those inspectors who have achieved basic inspector certification but are not yet fully qualified or participating State inspectors), and name and title of the approving NRC manager. The inspection report number is to be identified in the following format as required by IMC 0306:

Docket No. / Year [sequential number of the report in that year] (e.g.,

05000410/2019001) 14.03 Summary.

a. Summary Paragraph. Include a paragraph similar to the following and modify it to accurately describe the content of the report regarding findings, violations, and licensee identified violations.

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a [Inspection Type] at [Site], [Units], in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for Issue Date: 01/07/20 22 0611

overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. A licensee-identified non-cited violation is documented in report section: [Section/Number].

b. List of Findings and Violations. Copy the finding and violation headers from the write-ups done for Section 0611-05. Organize the finding and violation headers by the order they appear in the report. If no findings or violations were identified, include a statement similar to No findings or violations of more than minor significance were identified., as appropriate under the List of Findings and Violations Section. See Section 13.08 for caution regarding the creation of staff positions.

c. Additional Tracking Items. Include a list of items opened, closed, and discussed which are not directly covered in the list of findings and violations above. For each listed item, include the item type, tracking number, title, status (i.e., Open, Closed, or Discussed),

and a reference to the appropriate report section. See IMC 0306 for additional details on how to handle tracking items.

14.04 Table of Contents. Develop a table of contents when the report is considered complicated or lengthy. This requirement does not apply to routine integrated and team inspection reports.

14.05 Plant Status. Include a Summary of Plant Status section, if appropriate. Briefly describe pertinent operational events and plant status, such as significant planned and unplanned transients or power changes in excess of performance indicator thresholds, unplanned system actuations, or degraded conditions which significantly affected operations. This summary is not needed for some inspections since plant operating status may not be relevant.

14.06 Inspection Scopes.

a. Scope Paragraph. Include a paragraph similar to the following once at the beginning of the scope section.

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase.

[Include for integrated report: The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution.] The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

Inspection Scope. Following the scope paragraph, for inspection activities performed, identify the report section by the IP number, and title. On another line indicate the sample type or repeat the title when there is only one sample type in the IP followed by the applicable IP section and number of samples. See example further below.

Issue Date: 01/07/20 23 0611

For a typical inspection scope, use a sentence to describe the sample or inspection activity, followed by a listing of samples or items reviewed, as appropriate. Arrange using the standard report outline shown in Exhibit 1.

Identify what was inspected for each listed item reviewed or sample completed. Be specific, so that future inspections can be informed. Include the following information for each listed item or sample, as appropriate:

1. The equipment/space walked-down, documents reviewed, or evolution observed to fulfill the sample requirement or complete the inspection activity.

2. Methods of inspection (e.g., a walk-down, in-office review, observation): If the method differs from the methods discussed in the inspection procedure or the method was selected from a range of acceptable methods presented in the IP.

3. Dates of inspection: If dates provide important context. For example:

surveillance test performance, post maintenance test, or fire protection walk-downs typically would have dates, while a maintenance rule or annual problem identification and resolution samples may not need dates.

4. Location of inspection: If a substantive portion of the inspection activity was conducted at a location other than the site (e.g., an off-site vendor review)

A baseline inspection scope, which meets all inspection procedure sample requirements, is shown below:

71111.04 - Equipment Alignment Partial Walkdown (IP Section 03.01) (2 Samples)

The inspectors evaluated system configurations during partial walk downs of the following systems/trains:

(1) Unit 1 reactor core isolation cooling on January 10, 2019 (2) Unit 1 high pressure coolant injection on January 26, 2019 An example of an incomplete or partial baseline sample is shown below:

71111.20 - Refueling and Other Outage Activities Refueling and Other Outage Activities (IP Section 03.01) (Partial Sample)

The inspectors evaluated refueling outage ## activities from March 20, 2019 to March 31, 2019. The inspectors completed inspection procedure Sections ### and ###.

When documenting a sample completed by performing a subset of all procedure requirements (i.e. those most appropriate to the inspection activity being performed, per IMC 2515 Section 08.04), annotate in the scope which portions of the procedure were actually performed, similar to the example shown above for a partial sample.

Issue Date: 01/07/20 24 0611

When an OpESS is used to inform an inspection sample, annotate in the scope section which OpESS procedure was used, as shown in the example below.

71111.01Adverse Weather Protection Impending Severe Weather (1 Sample)

The inspectors evaluated readiness for impending adverse weather conditions for Hurricane Harvey on August 23, 2017. Operating Experience Smart Sample 2012-01, High Wind Generated Missile Hazards was used to inform this sample.

14.07 Inspection Results. Organize the inspection results (e.g. tabled information documented using Sections 0611-05 through 0611-12) in accordance with IMC 0611 Exhibit 1, grouped by IP, applicable IP Section / Sample Type, and finally by the order of the table used in this IMC to document the results (except Table 13, Assessment, which should be listed first when used).

When there are no inspection results in the report, include a statement similar to No findings were identified.

14.08 Exit Meetings and Debriefs. Write a brief summary for each exit meeting or formal debrief, such as those that might be done by the in-service inspection team prior to leaving the site, related to report inspections in EXIT MEETINGS AND DEBRIEFS section of the report.

The summary must identify the most senior licensee manager who attended the exit meeting and should include the following information:

a. Proprietary Information. Confirm with the licensee at the exit meeting that the NRC has (or has not) returned any proprietary materials used during the inspection (Refer to IMC 2515, Section 12.01 and IMC 0620 for further direction).

If proprietary information was not retained, use a statement similar to:

The inspectors verified no proprietary information was retained or documented in this report.

If proprietary information was retained, use a statement similar to:

The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

Note: When an inspection is likely to involve proprietary information (i.e., given the technical area or other considerations of inspection scope), handling of proprietary information should be discussed at the entrance meeting.

b. Subsequent Contacts or Changes in NRC Position. If the NRC's position on an inspection finding changes after the exit meeting, conduct an additional exit meeting to discuss that change with the licensee.

c. Licensees Exit Meeting Response. Do not attempt to characterize or interpret any oral statements the licensee makes, at the exit meeting or at any other time during the inspection, as a commitment. If the licensee disagrees with an inspection finding, this position may be characterized by the licensee in its formal response to the inspection report.

Issue Date: 01/07/20 25 0611

14.09 Third Party Reviews. Document the completion of third part reviews in this section. For example, state The inspectors reviewed Institute on Nuclear Power Operations reports that were issued during the inspection period. Omit this report section when there are no reviews.

14.10 Documents Reviewed. List critically reviewed documents in support of future inspection activities (e.g., inform future design bases assurance inspection sample selections) or that support NRC determinations (e.g., findings, significance). Documents recorded in the official agency record or report must have appropriate informational value to warrant preservation. Do not duplicate documents described in the report in the documents reviewed section.

Include sufficient detail about the listed documents to allow the NRC to retrieve the document from the licensee in the foreseeable future. A unique identifier, which may include the tracking number, title, revision and/or date, must be provided for each document referenced.

Note: Inspection reports should not reference specific INPO reports or documents. If it is absolutely necessary to document review of a specific INPO document (e.g., an evaluation referring to the INPO document was an inspection sample or justification for a finding) after considering Section 13.01 of this IMC, then state the reference number of the item reviewed and provide general words for the title (e.g., November 2011 INPO plant assessment of Your Plant dated January 17, 2012).

14.11 Report Attachments. If desired, attachments (e.g., significance determination supporting details) may be referenced and added to the end of the inspection report. The attachments may be combined into a single attachment entitled "Supplemental Information" if desired.

14.12 Cover Letter Enclosures. The inspection report, starting with the cover page, is typically cover letter Enclosure 1. Additional cover letter enclosure may be necessary to communicate an NOV.

0611-15 ISSUING INSPECTION REPORTS 15.01 Report Timeliness. Most inspection reports, including special inspections, should be issued no later than 45 calendar days after inspection completion. Augmented Inspection Team reports must be issued no later than 30 calendar days after inspection completion.

Note: Inspection completion is defined as the last day of the inspection quarter for integrated inspection reports (e.g., resident inspector quarterly report), and the day of the exit meeting for all other inspection reports (e.g., team inspections).

15.02 Submitting to Document Processing Center. Submit approved and finalized inspection reports in their native application (e.g., MS Word) to the Document Processing Center to be declared as an Official Agency Record. Do not scan the signed copy of the cover letter and report, but instead use the /RA/ in bold italic font, to the right of the sender's typed name and title indicate approval.

Issue Date: 01/07/20 26 0611

15.03 Release and Disclosure of Inspection Reports.

a. General Public Disclosure and Exemptions. Except for report enclosures containing exempt information (Refer to IMC 0620), all non-security cornerstone inspection reports will be routinely disclosed to the public.

b. Security Cornerstone Inspection Reports. Security cornerstone inspection reports containing security-related information (OUO-SRI) or safeguard information (SGI) will not be made available to the public and need to have the proper control and portion markings. However, security cornerstone inspection reports cover letters will be made publicly available after removal of any security-related attachment to the letter.

Reports containing SGI or OUO-SRI will be sent to the respective State Liaison Officers and State Homeland Security Advisors when they have been appointed, authorized, communicated a desire to receive the report, and have the resources to control the SGI or OUO-SRI.

Security inspection reports which do not contain SGI, OUO-SRI, Controlled Unclassified Information (CUI) or SUNSI can be made publicly available.

The cover letters will be marked for the highest level of controlled information contained in the inspection report: official use only SUNSI or SGI. The marking requirements for SGI are in Management Directive 12.6, NRC Sensitive Unclassified Information Security Program, and the requirements for marking OUO -SRI documents are on the Web at: https://drupal.nrc.gov/sunsi, Sensitive Unclassified Non-Safeguards Information (SUNSI).

c. Release of Investigation-Related Information. When an inspector accompanies an investigator on an investigation, the inspector shall not release the investigation report, nor their individual input to the investigation report to the public. This information is exempt from disclosure by 10 CFR 9.17, Agency Records Exempt from Public Disclosure, and must not be circulated outside the NRC without specific approval of the Chairman (Refer to OI Policy Statement 23).

The latest revisions of the exhibits and appendices referenced in this document may be accessed from the NRC Public Inspection Manual Chapters Web Page, located at:

http://www.nrc.gov/reading-rm/doc-collections/insp-manual/manual-chapter/index.html.

The latest revisions of NRC Public Inspection Procedures are also available at the NRC Public Inspection Procedures Web Page, located at: http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/.

0611-16 REFERENCES IMC 0305, Operating Reactor Assessment Program IMC 0306, Planning, Scheduling, Tracking, and Reporting of the Reactor Oversight Process (ROP)

IMC 0310, Aspects Within Cross Cutting Areas Issue Date: 01/07/20 27 0611

IMC 0612, Issue Screening IMC 0620, Inspection Documents and Records IMC 2515, Light-Water Reactor Inspection Program - Operations Phase MD 12.6, NRC Sensitive Unclassified Information Security Program NUREG-1379, NRC Editorial Style Guide ATTACHMENTS : Guidance for Reactive Inspection Reports : Reserved for next update to Guidance for Supplemental Inspection Reports : Reserved for next update to Guidance for Problem Identification and Resolution Inspection Reports EXHIBITS Exhibit 1: Standard Reactor Inspection Report Outline Exhibit 2: Inspection Report Documentation Matrix Exhibit 4: ROP Inspection Report Cover Letter Templates APPENDICES Appendix A: Acronyms Used in Inspection Reports Appendix C: Guidance for Supplemental Inspection Reports Appendix D: Guidance for Problem Identification and Resolution Inspection Reports END Issue Date: 01/07/20 28 0611

Attachment 1 Revision History for IMC 0611 Commitment Accession Description of Change Description of Comment Resolution Tracking Number Training and Closed Feedback Number Issue Date Required and Form Accession Change Notice Completion Number (Pre-Date Decisional, Non-Public Information)

ML17122A252 Initial issue of IMC 0611. This IMC has been created n/a 05/03/17 to separate power reactor inspection reports from issue CN 17-009 screening, and is consistent with the inspection report documentation guidance that was formerly in IMC 0612.

ML17150A030 Revised to reflect new streamlined report format. This ML17164A299 12/13/17 is a complete rewrite. 0612-2269 CN 17-029 ML17348A017 Completed non-concurrence can be found at ML17353A319.

ML18043A807 Revised to indicate that Security inspection report may ML19108A007 08/19/19 be made public when completely devoid of any FBF 0611-2297 CN 19-027 security-related information. Added direction to submit ML18047A093 approved and finalized inspection reports in their native FBF 0611-2332 application (e.g., MS Word) to the Document ML19108A016 Processing Center to preserve word search-ability. FBF 0611-2343 Added direction to document the reason why no ML19115A003 performance deficiency or violation was identified FBF 0611-2353 during an LER review, as applicable. Added direction ML18353A955 to reference the OpESS when it is used to inform a sample and when it contributes to the identification of a finding. Added directions for documenting Very Low Safety Significance Issues. Made other minor editorial changes to align report formatting with RPS-Inspections (auto-report generator).

Issue Date: 01/07/20 Att1-1 0611

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

ML19317F647 Clarified direction on how and when to document minor n/a n/a 01/07/20 performance deficiencies and violations, revised CN 20-003 direction for documenting Very Low Safety Significance Issue Resolution Process determinations. Added cautionary discussion regarding the creation of staff positions. Added additional direction beyond that already existing for findings to reference any applicable URI closure with its documented closure basis (e.g.,

VLSSIR).

Issue Date: 01/07/20 Att1-2 0611