NRC Inspection Manual 0609/Appendix L
text
Appendix L
B.5.b Significance Determination Process
1.0 OBJECTIVE
The objective of this SDP is to accommodate all potential more than minor inspection
findings associated with the development and implementation of guidance and
strategies intended to maintain or restore core cooling, containment, and spent fuel pool
cooling capabilities under the circumstances associated with loss of large areas of the
plant due to explosions or fire as required by Section B.5.b of the Interim Compensatory
Measures (ICM) Order, EA-02-026, dated February 25, 2002, the license conditions
imposed during the implementation of B.5.b, and 10 CFR 50.54(hh)(2) for findings after
March 31, 2010.
2.0 ENTRY CONDITIONS
Each issue entering the SDP process must first be screened to determine its
documentation threshold (i.e. if more than minor in significance) using Inspection
Manual Chapter (IMC) 0612, Appendix B, “Initial Screening.” Issues screened as minor
are not subjected to further SDP screening.
3.0 DEFINITIONS
B.5.b event – a beyond design basis loss of a large area of a reactor plant due to fires
or explosions initiated by a terrorist threat as stated in Attachment 2 to order EA-02-026.
Unrecoverable – an unavailable mitigating strategy is unrecoverable if licensee actions
could neither reasonably correct nor compensate for the conditions creating the
unavailability in time during a B.5.b event for the mitigating strategy to achieve its
objective. The time limit is the time allowed by NEI 06-12, Revision 2, for establishment
of the strategy where applicable, or a reasonable time.
Unavailability – a mitigating strategy is unavailable if its hardware or components are
not functional and ready for intended use, or personnel training and procedures are
inadequate, as described in the licensee submittal and SER supporting the B.5.b
license condition.
Note: These strategies for each operating reactor licensee were reviewed by the
staff who issued a safety evaluation report (SER) to document the commitments
to implement these strategies. The site specific responses delineating each
licensee’s commitment and the SERs are available through the B.5.b Community
of Practice. These responses are not available to the public due to the highly
sensitive nature for plant security contained in these responses.
Issue Date: 12/24/09 L-1 0609, App. L
4.0 GUIDANCE
Record the performance deficiency and factually describe known observations
associated with the deficiency in Table 1 - SDP Screening Worksheet for B.5.b.
Evaluation of the listed attributes may be informative in determining the significance of
the finding. Consider only attributes which relate directly to the significance of the
finding and document the basis for the consideration. If Table 1 is used to document a
performance deficiency and the factual description of the condition, the table will be
properly labeled as Official Use Only – Security Related Information.
TABLE 1 – SDP Screening Worksheet for B.5.b
Inspection Report #
Performance Deficiency (concise
statement clearly stating the deficient licensee
performance)
Factual Description of
Condition (facts about the condition that
resulted from the performance deficiency
without hypothetical failures included)
Systems/Trains Degraded by
Condition or Programmatic
Weakness (list the Hardware, Procedures
or Training)
Extent of Condition (describe what
other strategies are directly affected by the
deficiency)
Exposure Time (Period of time the
performance deficiency existed; and if
opportunity to identify the finding during such
period was missed (operating experience,
licensee=s programs such as surveillance
testing)
Recovery (The likelihood that the
licensee=s recovery actions would successfully
mitigate the performance deficiency)
Cornerstone (For findings that affect
core cooling select Mitigating Systems. For
findings that affect the containment or spent
fuel pool select Barrier Integrity)
____ Mitigating Systems ____ Barrier Integrity
The examples provided for each level of significance in Table 2 – Significance
Characterization, serve as guidance in determining the appropriate characterization for
findings; however, they are neither exhaustive nor controlling. The characterization of
each finding is dependent on the circumstances of the issue defined in Table 1. In
addition, these examples do not create new requirements. Each is intended to illustrate
the significance that the NRC places on a particular type of finding. Each potential
finding must be considered on its own merits to ensure that its significance is
characterized at the level best suited to the circumstances using qualitative engineering
judgment and regulatory oversight experience in each case. This is necessary because
the examples provided are intentionally limited to deter a mechanistic approach or
unreasoned conclusion. With this in mind, the entire spectrum of characterizations
should be considered with the particular finding placed in context in consideration of its
particular circumstances.
Issue Date: 12/24/09 L-2 0609, App. L
Issue Date: 12/24/09 L-3 0609, App. L
TABLE 2 – Significance Characterization
GREEN Unrecoverable unavailability of any individual mitigating strategy.
WHITE 1. Unrecoverable unavailability of multiple mitigating strategies such that SFP
cooling, injection to RPV, or injection to SGs cannot occur, or
2. Unrecoverable unavailability of on-site, self powered, portable pumping
capability, or
3. Substantial inability to perform Command and Control Enhancements.
Examples:
- Unrecoverable unavailability of injection to the reactor vessel or steam generators
(concurrent unavailability of low pressure pumping/depressurization strategies and
unavailability of manual operation of RCIC/Isolation Condenser or turbine (or
diesel) driven AFW)
- Unrecoverable unavailability of SFP internal strategy, SFP external fill strategy,
AND SFP external spray strategy
- Substantial inability to perform Command and Control Enhancements
YELLOW A failure to substantially establish mitigating strategies in one or more of the
following overall mitigating strategies areas:
- Fire fighting response strategies
- Operations to mitigate reactor core fuel damage including command and control
and actions to minimize release
- Operations to mitigate Spent Fuel Pool fuel damage including command and
control and actions to minimize release
RED In an actual B.5.b event, a substantial failure of mitigating strategies to function as
intended (i.e. achieve the strategies’ objectives) in one or more of the following
overall mitigating strategies areas:
- Fire fighting response strategies
- Operations to mitigate reactor core fuel damage including command and control
and actions to minimize release
- Operations to mitigate Spent Fuel Pool fuel damage including command and
control and actions to minimize release
ATTACHMENT 1 – Revision History for IMC 0609 Appendix L
Commitment
Tracking
Number
Issue
Date
Description of Change Training
Needed
Training
Completion
Date
Comment
Resolution
Accession
Number
N/A 12/24/09
CN 09-032
Researched commitments for 4 years and found
none. This Appendix to the IMC 0609,
“Significance Determination Process”
incorporates the lessons learned from the
performance of Temporary Instruction (TI)
2515/171 on Verification of Site Specification
Implementation of B.5.b Phase 2 & 3 Mitigation
Strategies and provides the framework for
determining the significance of B.5.b findings.
None N/A N/A
Issue Date: 12/24/09 Att1-1 0609 App. L, Att. 1