ML23074A019

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IMC 2201 Appendix B, Supplemental Inspection Program
ML23074A019
Person / Time
Issue date: 12/06/2023
From: Carl Grigsby
NRC/NSIR/DSO/SOSB
To:
Shared Package
ML23074A026 List:
References
CN 23-035
Download: ML23074A019 (1)


Text

NRC INSPECTION MANUAL NSIR/DSO INSPECTION MANUAL CHAPTER 2201 APPENDIX B SUPPLEMENTAL INSPECTION PROGRAM Effective Date: January 1, 2024 2201B-01 OBJECTIVES AND PHILOSOPHY OF SUPPLEMENTAL INSPECTIONS Supplemental inspections for the security inspection program are designed to support the U.S. Nuclear Regulatory Commissions (NRCs) goals of maintaining safety; enhancing public confidence; improving the effectiveness, efficiency, and realism of the regulatory process; reducing unnecessary regulatory burden; and promoting the common defense and security.

While the security baseline inspection program and performance indicators (PIs) should provide sufficient information to allow the NRC to ensure licensees are maintaining safety at facilities, additional supplemental inspections are required as applicable to provide enhanced information regarding the physical security at facilities where significant performance issues have been identified. These performance issues may be identified either through inspections or when PI thresholds are exceeded.

The breadth and depth of the supplemental inspections increase in proportion to the relative significance of the identified performance issues and are based on the guidance provided in the NRCs action matrix in Inspection Manual Chapter (IMC) 0305, Operating Reactor Assessment Program.

2201B-02 APPLICABILITY The supplemental inspections listed in IMC 2515, Light-Water Reactor Inspection Program Operations Phase, Appendix B, Supplemental Inspection Program, apply to power reactor licensees and are to be conducted by region-based or headquarter-based inspectors.

2201B-03 RESOURCES The resources needed to conduct supplemental inspections may vary considerably due to the complexity of the issue(s) and the thoroughness of the licensees own evaluations and proposed corrective actions. The Office of Nuclear Security and Incident Response will fund all efforts associated with security-related supplemental inspections.

2201B-04 DOCUMENTATION The inspection report written for supplemental inspections should contain the NRCs assessment of each inspection requirement that is included within the scope of the inspection.

Inspection documentation is pursuant to IMC 0611, Power Reactor Inspection Reports.

Security information designation guidance will be adhered to for all inspection reports, temporary instructions, orders, etc. that contain or have the potential to contain Safeguards or other sensitive security-related information. These documents shall be marked and controlled in Issue Date: 12/06/23 1 2201 App B

accordance with Volume 12, Security, of the NRCs management directives or the agencys guidance on sensitive unclassified non-Safeguards information as necessary.

2201B-05 SIGNIFICANCE DETERMINATION FOR POWER REACTORS IMC 2515, Appendix B, Supplemental Inspection Program, contains the program requirements for power reactors. As discussed in paragraphs 1 and 2 above, the significance of findings at commercial power reactors shall be determined using IMC 0609, Appendix E, Security Significance Determination Process.

2201B-06 DESCRIPTION OF SUPPLEMENTAL INSPECTION PROGRAM Generally, the supplemental inspection program utilizes three procedures for a deeper and broader independent assessment of licensee actions as the safety or security significance of a performance issue increases. However, if more specificity is needed in a particular program area, this independent assessment can be augmented with procedures selected from tables that list the procedures by cornerstone and key attributes provided in Appendix B to IMC 2515 (attachment 1, pages 1-5). The list includes baseline inspection procedures of which portions can be repeated with additional samples for a more comprehensive assessment.

Objectives of this independent assessment are to ensure that the licensee has properly identified the scope (extent) of the issues and that the proposed corrective actions are sufficiently comprehensive. Any new issue identified during a supplemental inspection will be evaluated using the applicable significance determination process.

IMC 0305 contains guidance on when to perform each type of supplemental inspection.

The following table is an overview of the supplemental inspection program.

Issue Date: 12/06/23 2 2201 App B

Supplemental Inspection Overview Supplemental Inspection Scope Assessment of Inspection Procedure Findings 95001 Increase in NRC oversight of a. Significant weaknesses in area(s) of concern. the licensees evaluation One or two white inputs in a Supplemental Inspection may result in expansion of strategic performance area; Procedure (IP) 95001. the inspection to Cornerstone objective met independently acquire the with minimal degradation in information necessary to security performance. satisfy the inspection objectives. The original 95002 Expanded NRC oversight in issue may be Held Open area(s) of concern. Sample in the Action Matrix until the One degraded cornerstone increased as appropriate. weaknesses in the Supplemental IP 95002. evaluation are addressed (3 or more white inputs or 1 and corrected.

yellow input), or 3 white inputs in any strategic performance area; Cornerstone objective met with moderate degradation in security performance.

95003 Reactive team inspection in b. Results of this area(s) of concern. supplemental inspection Repetitive degraded Supplemental IP 95003. will be assessed to cornerstone, multiple determine if additional degraded cornerstones, agency actions are multiple yellow inputs or one warranted.

red input; Cornerstone objectives met with longstanding issues or significant degradation in security performance.

2201B-07 ASSESSING INSPECTION FINDINGS If during implementation of IP 95001 or IP 95002, significant weaknesses are identified in the licensees evaluation of the performance issue, the inspection may be expanded as necessary to independently acquire the information necessary to satisfy the inspection requirements. See additional discussion in IMC 2201, Security Inspection Program for Operating Commercial Nuclear Power Reactors, and IMC 2515.

END Issue Date: 12/06/23 3 2201 App B

Attachment 1: Revision History for IMC 2201 Appendix B Commitment Accession Description of Change Description of Comment Resolution Tracking Number Training and Closed Number Issue Date Required and Feedback Form Change Notice Completion Date Accession Number (Pre-Decisional Non-Public Information)

N/A ML040680528 Initial issuance. N/A 02/19/04 CN 04-007 N/A ML081440358 This document has been revised to remove references to N/A ML091380060 09/08/09 programs other than operating power reactor, and update CN 09-021 terminology and format.

N/A ML11209B310 Document revised to provide greater detail concerning the N/A N/A 11/15/11 description of the supplemental inspection program, CN 11-034 eliminate references from IMC 0320, add references to IMC 0305, and minor edits.

N/A ML13234A514 This IMC has been revised to reflect minor administrative N/A ML15209A592 09/22/15 changes.

CN 15-017 N/A ML18031A991 The revision of this IMC was administrative in nature, the N/A ML18031B114 08/20/18 changes applied were to comport with recent changes to CN 18-026 the ROP Action Matrix within IMC 0305, Operating Reactor Assessment Program, that were completed in 2016.

During this administrative revision, a complete SUNSI review was conducted in which the staff concluded that this document should be de-controlled. Consistent with the staffs SUNSI determination, this document has been de-controlled and the SUNSI markings have been removed.

N/A ML23074A019 This IMC has been revised to reflect minor administrative N/A ML23074A018 12/06/23 changes.

CN 23-035 Issue Date: 12/06/23 Att1-1 2201 App B