ML20274A209

IMC 0612 App B Additional Issue Screening Guidance

ML20274A209
Person / Time
Issue date:	12/10/2020
From:	Joylynn Quinones-Navarro NRC/NRR/DRO/IRAB
To:
joylynn Quinones-Navarro NRR/DRO
Shared Package
ML20274A140, ML20345A050	List:
References
CN 20-070, DC 20-036
Download: ML20274A209 (18)

Text

NRC INSPECTION MANUAL IRAB INSPECTION MANUAL CHAPTER 0612 APPENDIX B ADDITIONAL ISSUE SCREENING GUIDANCE Effective Date: 01/01/2021

Figure 1: Issue Screening TE1 TE2 1 Does traditional Is there a Document NCV per Issue of Determine willfulness and if Go to enforcement Assess violation in Go to potentially 0611-08 concern Yes screening can proceed Figure or Yes accordance with the Figure willful identified without delay 2A enforcement Enforcement Policy 2D violation?

discretion apply? Yes From No No willfulness Figure No 2B Yes Follow Continue with ROP path both Traditional enforcement path is the violation ROP path paths an NCV?

7 Does the issue involve a licensing basis question Document per Did the finding and can it be closed using the VLSSIR process, or if not, should No further evaluation or Is Yes 0611-12 involve a No it be considered for the COM-106, Technical Assistance documentation information Request (TAR) process?

violation?

required to Screen performance From Yes No deficiency when directed Figure determine if a violation by Figure 2 2C exists?

No 8  ? Yes Consider a URI Document NOV per 3 4 5 0611-05 Is the

? performance Does Evaluate using Is the finding 2 deficiency Yes the finding the SDP. Yes licensee- No More- than- screen Performance (See IMC 0609) identified?

Minor? to green?

deficiency is a Is there a Yes finding No performance deficiency? No No Green 6 No finding. Minor finding violations may be No documented in some Can Conduct SERP or Identify appropriate cases per 0611-12 significance SRA reviews as cross-cutting be resolved Yes appropriate No aspect(s) before issuing (follow outcome the report? path)

No finding.

Continue traditional enforcement path Pending significance determination (Block TE2) when a violation exists. Assess for cross-cutting aspect(s) under Block 6 Finding with Document FIN(TBD) or AV per Document per preliminary 0611-05 0611-05 significance Issue Date: 12/10/20 1 0612 Appendix B

Figure 2: Issue Screening (Traditional Enforcement)

TE3 TE5 TE4 Can Does From Determine willfulness Is OI screening proceed Wait for investigation Prepare and No Figure and if screening can investigation Yes without completion of confirm a conduct ARB.

1A proceed without delay warranted? compromising investigation. willful investigation? violation?

Yes No Yes No Goto Figure No willfulness 1B 8

Screen any performance deficiency Follow Consider URI for without potential traditional both TE6 potential violation enforcement violation paths Goto Screen performance Follow Screen performance Figure deficiency both deficiency (confirmed) 1C Figure 1 Block 3 paths 8

Consider a URI TE7 Determine the severity level of the violation (Work with OE via the Regional Enforcement Coordinator)

?

TE8 Is the Does Does the violation a Document violation per 0611-05 absent From Assess violation in a SL-IV or violation licensee specific and overriding enforcement Figure accordance with the greater Yes No warrant No identified guidance.

1D Enforcement Policy violation enforcement SL-IV exist? discretion?

NCV?

No Yes Yes Document violations receiving Minor violation or no violation. enforcement discretion in Minor violations may be accordance with specific and overriding documented in some cases per enforcement guidance.

0611-12 Document those violations without a performance deficiency per 0611-11 absence specific and overriding Document violation per enforcement guidance.

0611-08 Issue Date: 12/10/20 2 0612 Appendix B

Additional Guidance to Clarify Figures Inspectors will not use the Reator Oversight Process (ROP) screening process to screen traditional-enforcement violations, but will use that process to screen their underlying performance deficiencies if any exist. Inspectors will separate traditional enforcement violations from their underlying performance deficiencies and screen those traditional enforcement violations using the examples and guidance in the Enforcement Manual and Enforcement Policy.

When dispositioning performance deficiencies associated with traditional enforcement violations, inspectors will not consider the traditional enforcement aspect as part of the ROP performance deficiency.

Figure 1, Issue Screening Block 1 Issue of concern identified An issue of concern is a well-defined observation or collection of observations potentially impacting safety or security which may warrant further inspection, screening, evaluation, or regulatory action.

For issues of concern with multiple examples, inspectors will screen each example separately.

On rare occasions, an inspector may identify an issue of concern that is neither a regulatory requirement nor an accepted licensee standard which may warrant consideration under the backfit process due to its perceived impact on safety or security. Inspectors identifying such an issue of concern should raise the concern to management and refer to Management Directive 8.4, Management of Facility-specific Backfitting and Information Collection.

Block TE1 Is there a potentially willful violation?

Although inspectors screen issues of concern for indications of potentially willful violations, the determination of willfulness is a legal decision that can only be made by the Office of the General Council (OGC) using facts developed during an investigation conducted by Office of Investigations (OI), normally at the recommendation of the Allegation Review Board (ARB).

See the Enforcement Policy, Enforcement Manual, and Allegation Manual for additional insights involving willfulness. See 10 CFR 50.5 for regulations addressing deliberate misconduct.

Block TE2 Does traditional enforcement or enforcement discretion apply?

If any of the following questions can be answered yes, the inspector will compare the violation with examples in the Enforcement Policy to determine if the violation rises to SL-IV or above and thus constitutes a non-minor traditional enforcement violation.

1. Was there a violation that impacted the regulatory process? Examples:

• Failure to provide complete and accurate information

• Failure to receive prior NRC approval for changes in licensed activities

• Failure to notify the NRC of changes in licensed activities Issue Date: 12/10/20 3 0612 Appendix B

Block TE2 Does traditional enforcement or enforcement discretion apply?

• Failure to perform 10 CFR 50.59 analyses

• Reporting failure, etc.

2. Was there a violation that contributed to actual safety consequences? Examples:

• Actual onsite or offsite releases of radiation exceeding regulatory limits

• Onsite or offsite radiation exposures exceeding regulatory limits

• Accidental criticalities

• Core damage

• Loss of significant safety barriers

• Loss of control of radiological material exceeding regulatory limits for public dose

• Radiological emergencies

3. Is there a SL-IV or greater violation with no associated performance deficiency?

Circumstances may arise where enforcement discretion should be considered or exercised to either escalate or mitigate enforcement sanctions or otherwise refrain from taking enforcement action for a particular violation. The Enforcement Policy and Enforcement Manual describe situations where this may apply. Specific circumstances may include:

• Specific cases for which temporary Enforcement Guidance Memoranda prescribes enforcement discretion

• Non-minor violations absent a performance deficiency

• Violations identified during extended shutdowns or work stoppages

• Violations involving old design issues

• Violations identified because of previous enforcement action

• Violations involving certain discrimination issues Note: Independent spent fuel storage installations (ISFSI), and nuclear materials facilities are not subject to the Significance Determination Process (SDP) and, thus, traditional enforcement will be used for these facilities and their associated license.

Block 2 Is there a performance deficiency?

The issue of concern is a performance deficiency if the answer to both of the following questions is yes:

• Was the issue of concern the result of the licensees failure to meet a requirement or standard? (A standard includes a self-imposed standard such as a voluntary initiative or a standard required by regulation)

• Was the cause of the issue of concern reasonably within the licensees ability to foresee and correct and should the issue of concern have been prevented?

Notes: (1) The performance deficiency is the proximate cause of the degraded condition and is not the degraded condition. To determine this cause, inspectors need not complete a rigorous root-cause evaluation, but instead may complete an evaluation based on reasonable inspector assessment and judgment.

(2) Inspectors should define a performance deficiency at the level of deficient performance that directly led to the issue of concern. Organzational weaknesses should not be identified as performance deficiencies, but should be considered as the CCA. The impact of an organizational weakness could be a PD.

Issue Date: 12/10/20 4 0612 Appendix B

Block 2 Is there a performance deficiency?

(3) Enforcement Manual, Part I, Section 1.3.5, Documenting Related Violations, discusses grouping closely related violations. Considering this guidance, when an issue of concern caused or resulted in multiple violations, it is appropriate for the performance deficiency to be defined at the problem level, thereby creating a relationship between one performance deficiency and many violations.

(4) When more than one performance deficiency exists associated with an issue of concern, consideration may be given to selecting a performance deficiency that captures the most significant risk increase of the concern and represents current licensee performance.

When evaluating the licensees failure to meet a requirement or standard, the inspector should consider the licensees intent:

• By definition, the licensee intends to meet regulatory requirements, including license conditions and Technical Specifications.

• The inspector can generally conclude the licensee intends to meet standards established in current licensing basis documents. LIC-100, Control of Licensing Bases for Operating Reactors, provides insights into what documents may constitute current licensing basis.

• Failure to meet an industry standard constitutes a performance deficiency only if the licensee intended to meet that standard. Inspectors may reasonably conclude that standards implemented via licensee procedures or as Nuclear Energy Institute (NEI) initiatives committed to by the industry are standards that the licensee intended to meet.

• The inspector should focus on whether the licensee met regulatory requirements in an acceptable manner rather than whether the licensee met the requirements in a manner specifically approved in a generic communication.

Block 3 Is the performance deficiency More-than-Minor?

If the answer to any of the following questions is yes, then the performance deficiency is More-than-Minor and is a finding. If the answer to all of the following questions is no, then the performance deficiency is minor and is not a finding.

• Could the performance deficiency reasonably be viewed as a precursor to a significant event?

• If left uncorrected, would the performance deficiency have the potential to lead to a more significant safety concern?

• Is the performance deficiency associated with one of the cornerstone attributes listed at the end of this attachment and did the performance deficiency adversely affect the associated cornerstone objective?

Inspectors shall use IMC 0612, Appendix E, Examples of Minor Issues, to inform answers to the screening questions listed above.

Block 4 Does the finding screen to Green?

Inspectors will screen all findings using IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings worksheet. Any finding which cannot be determined to be Green will require a Significance Enforcement Review Panel (SERP).

Issue Date: 12/10/20 5 0612 Appendix B

Block 5 Is the finding licensee-identified?

In determining whether a finding is licensee-identified, NRC-identified, or self-revealing, a measure of subjectivity is anticipated and accepted. To make these determinations, inspectors and regional staff should consider not only the definitions of these terms, but also past experience, related precedents, and the over-arching regulatory message that the determination could send.

Block 6 Identify appropriate cross-cutting aspect(s)

To identify an appropriate cross-cutting aspect for a finding, the inspector will:

• Review applicable causal information related to the finding to identify the cause(s) of the performance deficiency. (To identify causes, inspectors need not perform independent causal evaluations beyond what would be appropriate for the complexity of the issue. For the most-complex issues, inspectors may need to complete informal apparent-cause evaluations.)

• Among those causes, identify the performance characteristic that is either the primary cause of the performance deficiency or the most-significant contributor to it.

• Also, apply additional considerations to determine whether the CCA is reflective of present performance.

• Select the cross-cutting aspect listed in IMC 0310 that best reflects the performance characteristic that is the most significant contributor to the finding (i.e., determine which cross-cutting aspect provides the most meaningful insight into why the finding occurred.) A cross-cutting aspect is a finding characteristic which inversely relates to the reason why the performance deficiency occurred. The cross-cutting aspect is not a finding.

Note that:

• Typically, the staff will assign no more than one cross-cutting aspect to a finding. On rare occasions, when the regional staff considers that a unique or complex inspection finding warrants more than one cross-cutting aspect, before associating more than one cross-cutting aspect to any finding, the regional office will contact the Performance Assessment Branch Chief (NRR/DIRS/IRAB) for concurrence.

• For a finding to have multiple examples, the same cross-cutting aspect should be associated with each example, consistent with Enforcement Manual Section 2.13.7.

(Unless examples have the same cross-cutting aspect, they cant be examples of the same finding.)

Should the Issue Involving a Current Licensing Basis Question be Closed Using Block 7 the Very Low Safety Significance Issue Resolution (VLSSIR) Process?1 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.

1 Low Safety Significane Issue Resolution Working Group Recommendation memo to Ho K. Nieh, Director Office of Nuclear Reactor Regulation (ML19260G224)

Issue Date: 12/10/20 6 0612 Appendix B

If the question as to whether an issue is within the current licensing basis cannot be resolved without a significant level of effort, then the issue may be closed as part of the VLSSIR process.

This process can be used if all of the following are met:

• The licensee has demonstrated, and provided a supporting basis, that the issue of concern is not in their current licensing basis; and

• The inspector (using the resource estimate in the applicable inspection procedure as a guideline, which may involve NRC Headquarters support) has not been able to conclude whether the issue of concern is part of the plants current licensing basis; and

• 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; and

• The inspectors branch chief concurrence that spending more time researching the current licensing basis is not likely to benefit public health and safety relative to other inspection activities.

If all of the above are met, the issue can be closed by documenting in accordance with IMC 0611-12.03, Very Low Safety Significance Issue Resolution Process or IMC 0611-06, Unresolved Items, if an Unresolved Item (URI) was previously opened on the issue and now requires to be closed.

If all of the above are not met, the issue may be dispositioned as an IMC 0611-06, Unresolved Item, pending completion of further licensee or NRC actions necessary to resolve the item.

NRC actions to resolve the issue may include the application of the COM-106 (TAR) Process.

COM-106 may provide recommendations to inform NRC decisions to be taken to close out the issue, in accordance with its criteria and guidance. Entry into the TAR process will be applicable if the following conditions exist.

• it is a plant-specific issue, and

• issue not of very low safety significance as determined by the SDP, and is

• the issue is associated with (1) plant licensing basis, (2) NRR staff technical position, or (3) risk significance of: plant configuration, event, or operating practice.

Block 8 Consider an URI Inspectors should open an Unresolved Item (URI) when an inspection must exit pending receipt of information required to determine one of the following:

• If there is a performance deficiency

• If the performance deficiency is More-than-Minor

• If the issue of concern is a violation Note: Inspectors may not use a URI to obtain more information to determine the significance of a finding.

Figure 2, Issue Screening (Traditional Enforcement)

Issue Date: 12/10/20 7 0612 Appendix B

Block TE3 Can ROP screening proceed without compromising investigation?

Each issue of concern warranting a willfulness investigation triggers a process to determine whether disposition of the associated ROP performance deficiency may proceed without compromising the OI investigation.

Generally, to preclude the possibility of compromising an ongoing willfulness investigation, inspectors should suspend ROP disposition activities that require licensee interaction until the investigation is complete. However, because SDP insights developed during issue dispositioning are integral to dispositioning most traditional enforcement violations, inspectors should disposition ROP performance deficiencies in a timely manner. So, to balance these competing considerations, whenever ROP disposition activities could possibly compromise an ongoing investigation, the Directors (or their designees) of the OI Field Office, DIRS, the associated Regional Division of Reactor Projects or Safety, and OE should reach a consensus decision on whether ROP dispositioning should be suspended or may proceed during the investigation. The parties involved in this decision should ensure that their specific concerns are considered in order to achieve the two desired agency outcomes - a valid and defendable ROP finding and a valid and defendable violation within the enforcement program.

If the decision is to suspend ROP dispositioning, then as soon as the investigation is sufficiently complete or whenever new information arises that might otherwise warrant reevaluating that decision, the parties involved in the decision should revisit the decision, and change it if change is warranted.

Block TE4 Wait for completion of investigation This block requires enhanced coordination to preclude the possibility of compromising an ongoing investigation by proceeding, prematurely, with ROP disposition activities while simultaneously assuring that ROP disposition activities are not delayed longer than necessary.

Block TE5 Does investigation confirm a willful violation?

In accordance with the Enforcement Policy and Enforcement Manual, OI, upon concluding its investigation will issue a conclusion about willfulness based on the facts collected/developed during investigation. Using the facts/conclusion above, OGC will make a final determination about willfulness.

Block TE6 Screen performance deficiency (Figure 1 Block 3)

The absence of a finding may influence but does not preclude the potential to confirm a willful violation, though it may influence the determination of its severity level and/or civil penalty.

Similarly, the presence of a finding does not preclude the potential to confirm no willful violation. However, if a willful violation is determined to exist, it may influence the determination of its severity level and/or civil penalty.

Block TE7 Confirmed willful violation To disposition violations involving confirmed willfulness, inspectors shall coordinate with the Office of Enforcement through the Regional Enforcement Coordinator. Additional guidance is contained in the Enforcement Policy and Enforcement Manual.

Issue Date: 12/10/20 8 0612 Appendix B

Block TE7 Confirmed willful violation A violation may be considered more significant than the underlying noncompliance if involves willfulness. When determining the severity level of a willful violation, the NRC, in addition to considering the willful aspects, considers the (1) actual safety consequences, (2) potential safety consequences, including the consideration of risk information, and (3) potential for impacting the NRCs ability to perform its regulatory function. A notice of violation is normally required for a willful violation. However, a non-cited violation may still be appropriate. Refer to the Enforcement Policy for additional guidance.

The approval of the Director, Office of Enforcement, with consultation with the Deputy Executive Director as warranted, is required for dispositioning willful violations as non-cited violations.

Block TE8 Does the violation warrant enforcement discretion?

For violations involving enforcement discretion, inspectors shall coordinate their actions with the Regional Enforcement Coordinator. Additional guidance is contained in the Enforcement Policy and Enforcement Manual.

Some enforcement discretion decisions are made on a case-by-case basis in consultation with the Office of Enforcement, while others may be instituted under a temporary Enforcement Guidance Memorandum.

Block 7 Consider a URI See Block 7 for Figure 1 Cornerstone Objectives and Attribute Tables Cornerstone REACTOR SAFETY - Initiating Events Objective To limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations.

Attributes Areas to Measure Design Control Initial Design and Plant Modifications Protection Against Flood Hazard, Fire, Loss of Heat Sink, Toxic Hazard, Switchyard External Factors Activities, Grid Stability Configuration Control Shutdown Equipment Lineup, Operating Equipment Lineup Equipment Availability, Reliability, Maintenance, Barrier Integrity (SGTR, Performance ISLOCA, LOCA (S,M,L)), Refueling/Fuel Handling Equipment Procedure Quality Procedure Adequacy (Maint, Test, Ops)

Human Performance Human Error Issue Date: 12/10/20 9 0612 Appendix B

Cornerstone REACTOR SAFETY - Mitigating Systems Objective To ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage).

Attributes Areas to Measure Design Control Initial Design and Plant Modifications Protection Against Flood Hazard, Fire, Loss of Heat Sink, Toxic Hazard, Seismic, External Factors Weather Configuration Control Shutdown Equipment Lineup, Operating Equipment Lineup Equipment Availability, Reliability Performance Procedure Quality Operating (Post-event) Procedures (AOPs, SOPs, EOPs),

Maintenance and Testing (Pre-event) Procedures Human Performance Human Error (Post-event), Human Error (Pre-event)

Cornerstone REACTOR SAFETY - Barrier Integrity Objective To provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events.

Attributes Areas to Measure (to Maintain Functionality of Fuel Cladding)

Design Control Physics Testing, Core Design Analysis (Thermal Limits, Core Operating Limit Report, Reload Analysis, 10 CFR50.46)

Configuration Control Reactivity Control (Control Rod Position, Reactor Manipulation, Reactor Control Systems), Primary Chemistry Control, Core Configuration (Loading)

Cladding Loose Parts (Common Cause Issues), RCS Activity Level Performance Procedure Quality Procedures which could impact cladding Human Performance Procedure Adherence (FME, Core Loading, Physics Testing, Vessel Assembly, Chemistry, Reactor Manipulation), FME Loose Parts, Common Cause Issues Attributes Areas to Measure (to Maintain Functionality of RCS)

Design Control Plant Modifications Configuration Control System Alignment, Primary/Secondary Chemistry RCS Equipment and RCS Leakage, Active Components of Boundary (Valves, Seals), ISI Barrier Performance Results Procedure Quality Routine OPS/Maintenance Procedures, EOPs and related Off-Normal Procedures invoked by EOPs Human Performance Routine OPS/Maintenance Performance, Post Accident or Event Performance Attributes Areas to Measure (to Maintain Functionality of Containment)

Design Control Plant Modifications, Structural Integrity, Operational Capability Issue Date: 12/10/20 10 0612 Appendix B

Cornerstone REACTOR SAFETY - Barrier Integrity Objective To provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events.

Configuration Control Containment Boundary Preserved, Containment Design Parameters Maintained SSC and Barrier S/G Tube Integrity, ISLOCA Prevention, Containment Isolation, SSC Performance Reliability/Availability, Risk Important Support Systems Function Procedure Quality Emergency and Operating Procedures, Risk Important Procedures (OPS, Maintenance, Surveillance)

Human Performance Post Accident or Event Performance, Routine OPS/Maintenance Performance Attributes Areas to Measure (to Maintain Radiological Barrier Functionality of Control Room and Auxiliary Building - PWR, and Standby Gas Trains - BWR only)

Design Control Plant Modifications, Structural Integrity Configuration Control Building Boundaries Preserved SSC and Barrier Door, Dampers, Fans, Seals, Instrumentation Performance Procedure Quality EOPs, Abnormal and Routine Operating Procedures, Surveillance Instructions, Maintenance Procedures Human Performance Post Accident or Event Performance, Routine OPS/Maintenance Performance Attributes Areas to Measure (to Maintain Functionality of Spent Fuel Pool Cooling System)

Design Control Plant Modifications, Structural Integrity Configuration Control System Alignment SSC Performance Pumps, Valves, Instrumentation Procedure Quality EOPs, Abnormal and Routine Operating Procedures, Surveillance Instructions, Maintenance Procedures Human Performance Post Accident or Event Performance, Routine OPS/Maintenance Performance Cornerstone REACTOR SAFETY - Emergency Preparedness Objective To ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency.

Attributes Areas to Measure ERO Readiness Duty Roster, ERO Augmentation System, ERO Augmentation Testing, Training Facilities and ANS Testing, Maintenance Surveillance and Testing of Facilities, Equipment Equipment and Communications Systems, Availability of ANS, Use in Drills and Exercises Issue Date: 12/10/20 11 0612 Appendix B

Procedure Quality EAL Changes, Plan Changes, Use in Drills and Exercises ERO Performance Program Elements Meet 50.47(b) Planning Standards, Actual Event Response, Training, Drills, Exercises Offsite EP FEMA Evaluation Cornerstone RADIATION SAFETY - Occupational Radiation Safety Objective To ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation.

Attributes Areas to Measure Plant Plant Equipment Instrumentation, (ARM Cals & Availability, Source Facilities/Equipment Term Control), Procedures (Radiation Protection and Maintenance) and Instrumentation Program & Process Procedures (HPT, Rad Worker, ALARA); Exposure/Contamination Control and Monitoring (Monitoring and RP Controls), ALARA Planning (Management Goals, Measures - Projected Dose)

Human Performance Training (Contractor HPT Quals, Radiation Worker Training, Proficiency)

Issue Date: 12/10/20 12 0612 Appendix B

Cornerstone RADIATION SAFETY - Public Radiation Safety Objective To ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation.

Attributes Areas to Measure Plant Process Radiation Monitors (RMS)

Facilities/Equipment (Modifications, Calibrations, Reliability, Availability), REMP and Instrumentation Equipment, Meteorology Instruments, Transportation Packaging, Procedures (Design/Modifications, Equipment Calculations, Transportation Packages, Counting Labs)

Program & Process Procedures (Process RMs & REMP, Effluent Measurement QC, Transportation Program, Material Release, Meteorological Program, Dose Estimates), Exposure and Radioactivity Material Monitoring and Control (Projected Offsite Dose, Abnormal Release, DOT Package Radiation Limits, Measured Dose)

Human Performance Training (Technician Qualifications, Radiation & Chemical Technician Performance)

Cornerstone SAFEGUARDS - Security Objective To provide assurance that the licensees security system and material control and accountability program use a defense-in-depth approach and can protect against (1) the design basis threat of radiological sabotage from external and internal threats, and (2) the theft or loss of radiological materials.

Attributes Areas to Measure Physical Protection Protected Areas (Barriers, Alarms, Assessment), Vital Areas System (Barriers, Alarms, Assessment)

Access Authorization Personnel Screening, Behavior Observations, Fitness for Duty Access Control Search, Identification Response to Protective Strategy, Implementation of Protective Strategy Contingency Events Material Control and Transportation of Radioactive Material, Records; Procedures, Accounting Inventories Issue Date: 12/10/20 13 0612 Appendix B

Attachment 1 - Revision History for IMC 0612 Appendix B - Issue Screening Commitment Accession Description of Change Training Comment Resolution Tracking Number Required and and Closed Feedback Number Issue Date Completion Form Accession Change Notice Date Number (Pre-Decisional, Non-Public Information) 04/29/2002 IMC 0612 Appendix B removed from IMC 0612 and made a No CN 02-021 standalone document. Unable to locate orignial in ADAMS.

ML030800420 Editorial changes made to reflect title changes to standard No 02/21/2003 ROP terminology. Appendix B was removed as an CN 03-006 attachment to IMC-0612 and was issued as stand alone document.

ML031610690 Revised to achieve the following: No 06/20/2003 1. Consistency with IMC-0306. 2. Present information in the CN 03-021 order in which the activities will normally be performed in the process of developing and transmitting a reactor inspection report. 3. Remove specific enforcement guidance to ensure consistency between the guidance in 0612 and the Enforcement Policy and Manual. 4. Correct incorrect or conflicting information.

ML051400254 Revised to add Question No. 5 to Minor Questions in No 05/19/2005 Section 3 and Question No. 6 to the SDP Questions in CN 05-014 Section 4 to reflect the new maintenance risk assessment and risk management SDP, IMC 0609, Appendix K, Maintenance Rule Risk Assessment and Risk Management.

ML052700266 Revised to clarify the definition of a performance deficiency No 09/30/2005 and a functionality of the control room. Also, the auxiliary CN 05-028 building attribute was added to the cornerstone and objective section.

11/01/2006 Revision history reviewed for the last four years. No Issue Date: 12/10/20 Att1-1 0612 Appendix B

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

ML060400499 Revised definition of performance deficiency to bring the Yes ML063000483 11/02/2006 definition in alignment with the basis for performance 09/06/2006 CN 06-033 deficiency as described in ROP basis document, IMC-0308 attachment 3, Significance Determination Process Basis Document.

ML071720417 Revised flow chart and Section 3 guidance to address No 09/20/2007 feedback forms. Corrected formatting error on page B-7.

CN 07-029 ML082310381 Revised Guidance and Flow Chart to be consistent with Yes ML083220751 12/04/2008 changes to IMC 0612. Updated Cornerstone Objectives 12/03/2008 CN 08-034 and Attributes to be consistent with IMC 0308.

ML091590496 Rewrite Guidance and Flow Charts to: Yes ML091480470 12/24/2009 1. Implement enhanced Traditional Enforcement (TE) 12/10/2009 CN 09-032 integration in ROP

2. Enhance organization and access

3. Incorporate IMC 0305 Cross-Cutting Aspect inspection guidance

4. Address (in part) the following 0612-related ROP Feedback:

a. 1303 - enhance App E Maintenance Rule (MR) examples, remove MR specifics from App B

b. 1355 -enhance Performance Deficiency guidance (e.g. what constitutes a "standard")

c. 1362 - enhance MR minor screening guidance (see 1303)

d. 1366 - enhance minor screening guidance for improved consistency Issue Date: 12/10/20 Att1-2 0612 Appendix B

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

e. 1398 - improve alignment between 0612 and Enforcement Policy (e.g. minor TE Violations)

f. 1418 - enhance minor screening guidance to reduce subjectivity per 2008 Consolidated ROP Internal Self-assessment (CRIS-08)

g. 1419 - enhance guidance for differentiating self-revealing vs. NRC- vs. License ID per CRIS-08

h. 1425 - resolve CCA guidance cross-reference errors

5. Consolidate screening guidance from Section 0612-05 Screening Inspection Results, of IMC 0612-proper into Appendix B screening guidance.

ML12080A204 Complete Reissue. Simplified guidance. Added ML12205A244 09/07/2012 enforcement discretion path to traditional enforcement. FF 0612B-1398, CN 12-020 1439, 1483, 1496, 1507, 1591, 1679, 1680, 1683, 1700, 1703 ML17129A624 Editorial update made to reflect the splitting of IMC 0612 12/13/17 into IMC 0611 for documentation and IMC 0612 for issue CN 17-029 screening.

Issue Date: 12/10/20 Att1-3 0612 Appendix B

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

ML19247C384 Revised to address feedback forms, ANO Lessons Learned ML19247C918 12/12/19 Recommendation 5, and Columbia DPO-2018-001 0612B-1433 CN 19-039 Recommendation 1. Provides new guidance for the Very ML19220A106 Low Safety Significance Issue Resolution (VLSSIR) 0612B-1436 process. ML19220A108 0612B-1564 ML19220A109 0612B-1887 ML19220A110 0612B-1929 ML19316A002 0612B-1934 ML19311C610 0612B-1970 ML19220A111 0612B-1997 ML19316A003 0612B-2014 ML19220A112 0612B-2029 ML19316A004 0612B-2203 ML19220A113 ML20274A209 Revised to incorporate some changes in Figure 1 to align ML20275A010 12/10/20 with IMC 0611. Added clarifying guidance on the concept FBF 0612B - 2268 CN 20-070 of licensee ability to foresee and correct, and the definition ML19220A114 of performance deficiency in Block 2. Also modified the FBF 0612B-2415 enforcement bullet in Block 2. ML20345A168 Issue Date: 12/10/20 Att1-4 0612 Appendix B