ML20054B668

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IMC 0609 Update for February 2020 ROP Monthly Meeting
ML20054B668
Person / Time
Issue date: 02/20/2020
From: David Aird
NRC/NRR/DRO/IRAB
To:
Aird D, NRR/DRO, 301-287-0725
References
IMC 0609
Download: ML20054B668 (3)


Text

1 Changes to IMC 0609

  • Target for issuance by end of April 2020
  • Minor update to include:

- Edits post NRR-NRO merger

- Deleted reference to App. O, revised titles to other updated references

- Added VLSSIR guidance in section 3 (see next slide)

- Added note in section 3 - For any inspection findings associated with the development of operational programs for the AP1000, the staff shall use IMC 2519, Construction Significance Determination Process, to determine the significance.

  • A similar note is already in IMC 2519, Section 4.0 - If the operational program implementation milestone has been reached, go to the appropriate ROP SDP in IMC 0609.

2 Very Low Safety Significance Issue Resolution (VLSSIR)

  • IMC 0612, Issue Screening was revised in December 2019 to include guidance on implementing VLSSIR
  • One of the conditions for using VLSSIR is:

The issue (if it were assumed to be an inspection finding) would have insufficient safety significance to warrant additional resource expenditure (i.e., the issue would be very low safety significance as defined in the ROP). The inspector determines whether the issue has insufficient safety significance by processing the issue using IMC 0609, Significance Determination Process, and if the issue does not proceed to a detailed risk evaluation, or a Phase 2 evaluation when relevant, or Appendix M, then the issue would have insufficient safety significance.

IMC 0612, Appendix B also includes the Very Low Safety Significance Issue Resolution (VLSSIR) process as part of issue screening. Inspectors can use the VLSSIR process to discontinue evaluation of an issue involving a current licensing basis question in which the issue cannot be resolved without a significant level of effort and an expenditure of resources the agency has chosen not to utilize because the issue is expected to be of very low safety significance if found to be valid. The VLSSIR process uses IMC 0609 to determine if an issue is of very low safety significance even though it has not yet been established whether there is an associated performance deficiency.

3 Not included?

  • This update does not include revised descriptions for White/Yellow Findings

- Commission approval is required since these descriptions are in the Enforcement Policy (See SECY-19-0067)