ML19031C214

IMC 2600 Fuel Cycle Facility Operational Safety and Safeguards Inspection Program

ML19031C214
Person / Time
Issue date:	03/11/2019
From:	Jeremy Munson NRC/NMSS/DFCSE/LOB
To:
Munson J
Shared Package
ML19031C114, ML19070A016	List:
References
CN 19-010
Download: ML19031C214 (20)

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NRC INSPECTION MANUAL NMSS/FCSE INSPECTION MANUAL CHAPTER 2600 FUEL CYCLE FACILITY OPERATIONAL SAFETY AND SAFEGUARDS INSPECTION PROGRAM Effective Date: 03/11/2019 Issue Date: 03/11/19 i 2600 TABLE OF CONTENTS 2600-01 PURPOSE ................................................................................................................. 1 2600-02 OBJECTIVES ............................................................................................................ 1 2600-03 APPLICABILITY ........................................................................................................ 1 2600-04 DEFINITIONS OF INSPECTION FREQUENCIES .................................................. 1 04.01 As Needed (AN) ............................................................................................................... 1 04.02 Core Inspection Program Completion.............................................................................. 2 2600-05 RESPONSIBILITIES AND AUTHORITIES .............................................................. 2 05.01 Director, Office of Nuclear Material Safety and Safeguards (NMSS) ............................. 2 05.02 Regional Administrator, Region II .................................................................................... 2 05.03 Director, Division of Fuel Cycle Safety, Safeguards, and Environmental Review (FCSE) .......................................................................................................................................... 2 05.04 Director, Division of Fuel Facility Inspection .................................................................... 2 05.05 Director, Nuclear Security and Incident Response (NSIR) ............................................. 3 05.06 Chief, Regional Fuel Facility Inspection Branch .............................................................. 3 05.07 Chief, Programmatic Oversight and Regional Support Branch (PORSB), Division of Fuel Cycle Safety, Safeguards, and Environmental Review ......................................................... 3 05.08 Chief, Material Control & Accounting Branch (MCAB), Division of Fuel Cycle Safety, Safeguards, and Environmental Review ........................................................................................ 3 2600-06 PROGRAM DESCRIPTION ..................................................................................... 3 06.01 General. ............................................................................................................................ 3 06.02 Material Control and Accounting Inspection Program ..................................................... 4 06.03 Physical Protection and Transport of Special Nuclear Material (SNM) Program ........... 4 2600-07 FUEL CYCLE FACILITY INSPECTION PROGRAM ELEMENTS ........................... 4 07.01 Program Elements ........................................................................................................... 4 07.02 Core Inspection Program ................................................................................................. 4 07.03 Plant-specific Reactive Inspections ................................................................................. 5 07.04 Plant-specific Supplemental Inspections ......................................................................... 5 07.05 Generic Safety Issue Inspections .................................................................................... 5 07.06 Licensee Performance Reviews ...................................................................................... 6 07.07 Backshift Inspections ....................................................................................................... 6 07.08 Inspections During the Construction, Preoperational, and Startup Phases .................... 6 2600-08 PROGRAM IMPLEMENTATION .............................................................................. 6 08.01 Master Inspection Plan ..................................................................................................... 6 08.02 Establishment of the Core Inspection Program ............................................................... 6 08.03 Program Adjustments ....................................................................................................... 7 2600-09 EVENT REVIEW AND RESPONSE ......................................................................... 8 2600-10 PLANNING FOR INSPECTIONS ............................................................................. 8 10.01 Inspection Planning .......................................................................................................... 8 10.02 Review of Open Allegations ............................................................................................. 8 2600-11 CONDUCTING INSPECTIONS ................................................................................ 9 11.01 Entrance and Exit Meetings ............................................................................................. 9 11.02 Findings Related to Non-NRC Regulations ................................................................... 10 11.03 Performance-based Inspection Focus ........................................................................... 10 11.04 Third Party Assistance ................................................................................................... 10 Issue Date: 03/11/19 ii 2600 11.05 .............................................................. 11 11.06 Inspection Documentation ............................................................................................. 11 11.07 Independent Inspection Effort ........................................................................................ 11 11.08 Open Item Guidance ...................................................................................................... 11 11.09 Witnessing Unsafe Situations ........................................................................................ 12 11.10 Inspector Functions During Period of Lapsed Appropriation ........................................ 12 2600-12 ASSESSING FACILITY PERFORMANCE ............................................................. 13 12.01 Licensee Performance Review (LPR)............................................................................ 13 12.02 Agency Action Review Meeting (AARM) ....................................................................... 13 12.03 Ongoing Assessments of Facility Performance ............................................................. 13 2600-13 ASSESSING PROGRAM IMPLEMENTATION ...................................................... 13 ATTACHMENT 1 Revision History for IMC 2600 .............................................................. Att1-1 Issue Date: 03/11/19 1 2600 2600-01 PURPOSE To establish the policy for the fuel cycle facility inspection program. 2600-02 OBJECTIVES 02.01 To define the minimum core inspection effort to be performed at each type of fuel cycle facility. 02.02 Provide guidance for developing Master Inspection Plans (MIPs) for each facility. 02.03 To establish an inspection program to determine whether licensed fuel cycle facilities are operated safely in accordance with U.S. Nuclear Regulatory Commission (NRC) regulations. 02.04 To determine the causes of declining performance before such performance reaches a level that may result in an undue risk to public health and safety. 02.05 To identify those safety or safeguards significant issues that might have generic applicability. 02.06 To provide guidance for assessing facility performance in real time, interfacing with the Licensee Performance Review (LPR) process, and preparing for the annual Agency Action Review Meeting (AARM). 02.07 Provide guidance for adjusting inspection effort on the basis of facility performance. 2600-03 APPLICABILITY The fuel cycle inspection program applies to operating fuel cycle facilities licensed by the NRC including nuclear fuel fabrication facilities, uranium enrichment plants, and uranium conversion plants. Inspection and assessment activities for facilities undergoing construction, pre-operation, startup, major modifications, or having ceased operations in preparation for decommissioning should be handled on a case-by-case basis. Fuel cycle facilities in non-operating status generally do not pose the same levels of risk as operating facilities. Certain inspection procedures (IPs) may not be applicable in these cases, and others may need to be adjusted to the given situation to reflect the actual level of risk attached to each situation. Facilities with approved Decommissioning Plans, or for which project management responsibility has been transferred out of the Division of Fuel Cycle Safety, Safeguards, and Environmental Review (FCSE), are not addressed in this chapter. 2600-04 DEFINITIONS OF INSPECTION FREQUENCIES 04.01 As Needed (AN). The inspection effort should be performed when the activity or event occurs at the facility as specified in the guidance section of Issue Date: 03/11/19 2 2600 specific inspection procedures (e.g., outages). 04.02 Core Inspection Program Completion. Core Inspection Program completion for an annual inspection cycle is defined to be completion of each core inspection procedure listed in Appendix B for each facility, except where deviations are approved in advance by the Director, FCSE. 2600-05 RESPONSIBILITIES AND AUTHORITIES 05.01 Director, Office of Nuclear Material Safety and Safeguards (NMSS). Provides overall program direction for the fuel cycle inspection program. 05.02 Regional Administrator, Region II. a. Provides direction for management and implementation of the inspection program elements. b. Ensures, within budget limitations, that the regional office staff includes adequate numbers of inspectors in the various disciplines necessary to carry out the inspection program described in this chapter, including that which may be needed for regional supplemental and reactive inspections. c. Directs the implementation of the supplemental inspection program. d. Applies inspection resources, as necessary, to deal with significant issues and problems at specific facilities. 05.03 Director, Division of Fuel Cycle Safety, Safeguards, and Environmental Review. a. Develops and directs the implementation of policies, programs, and procedures for inspecting applicants, licensees, and other entities subject to NRC jurisdiction. b. Assesses the effectiveness, uniformity, and completeness of the fuel cycle inspection program. c. Approves changes to the fuel cycle facility inspection program. d. Approves changes to the MIP that involve proposed deviations from the inspection program described herein. 05.04 Director, Division of Fuel Facility Inspection (DFFI). a. Manages the implementation of the inspection program elements.

Issue Date: 03/11/19 3 2600 b. Develops and updates the MIPs for fuel cycle inspections. c. Coordinates with FCSE to obtain specialized technical expertise, as necessary. 05.05 Director, Nuclear Security and Incident Response (NSIR). a. Oversees the implementation of the safeguards portion of the fuel cycle inspection program (information security/physical security). b. Applies inspection resources, as necessary, to deal with significant issues and problems at specific facilities. 05.06 Chief, Regional Fuel Facility Inspection Branch. a. Implements the fuel cycle inspection program. b. Develops the Branch MIP input. c. Coordinates with other appropriate inspection organizations in assessing facility performance. 05.07 Chief, Programmatic Oversight and Regional Support Branch (PORSB), Division of Fuel Cycle Safety, Safeguards, and Environmental Review. a. Proposes changes to the fuel cycle inspection program. b. Coordinates with Region II and FCSE in assessing facility performance. 05.08 Chief, Material Control & Accounting Branch (MCAB), Division of Fuel Cycle Safety, Safeguards, and Environmental Review. Proposes changes to the material control and accounting (MC&A) portion of the fuel cycle inspection program. 2600-06 PROGRAM DESCRIPTION 06.01 General. The program described herein is designed to determine whether licensed fuel cycle facilities are operated safely and securely and in accordance with regulations and their license. The program defines the minimum core inspection effort to be performed at each type of fuel cycle facility and provides guidance for reactive, supplemental, and generic safety issue inspections. This inspection program also provides guidance on responding to events at licensee facilities. Depending on the significance of an event, additional guidance for determining the level of Issue Date: 03/11/19 4 2600 agency response to an event is contained in NRC Management Directive (MD) 8.3, Incident Investigation Program. 06.02 Material Control and Accounting Inspection Program. This inspection program is described in Inspection Manual Chapter (IMC) 2683, Material Control and Accounting Inspection of Fuel Cycle Facilities. The associated inspections are included in the MIP. 06.03 Physical Protection and Transport of Special Nuclear Material (SNM) Program. This inspection program is described in IMC 2681, Physical Protection and Transport of Special Nuclear Material and Irradiated Fuel Inspections of Fuel Facilities. 2600-07 FUEL CYCLE FACILITY INSPECTION PROGRAM ELEMENTS 07.01 Program Elements. The inspection program described in this IMC is comprised of the following major program elements: a. Core Inspections, including Resident Inspections where applicable. b. Plant Specific Reactive Inspections. c. Plant Specific Supplemental Inspections. d. Generic Safety Issue Inspections. e. Licensee Performance Reviews (LPRs). Inspection procedures identify requirements that the inspectors must consider while evaluating the associated area. These requirements may not be the same as NRC requirements placed on a specific licensee. As such, it is not implied or intended that inspection program requirements are to be levied on the licensee. 07.02 Core Inspection Program. This is the minimum required inspection program appropriate to determine whether there is reasonable assurance a fuel cycle facility is operating safely and securely in accordance with regulatory requirements and to identify indications of declining safety or safeguards performance. Each inspection procedure is complete when the inspection requirements of that procedure are satisfied. The resource estimate in each procedure is an estimate for planning purposes; it is not an expected level of effort. Inspections of different licensees will require different levels of effort to complete the objectives. The resource estimate is an estimate of the nominal effort to meet the objectives. (In some cases, where inspections draw from a suite of available inspection procedures, rather than a single inspection procedure, the suite will be considered as a single procedure for resource planning.) The core inspections for each type of facility are specified in Tables 1 and 2 of Appendix B. Resident inspectors are assigned to certain fuel cycle facilities that require such oversight because of their complexity of operation, risk, or other significant factors. However, a resident inspector may occasionally perform inspections other than resident inspections in coordination with regional management if he/she is qualified to do so. The resident inspection program is Issue Date: 03/11/19 5 2600 described in more detail in Appendix C. 07.03 Plant-specific Reactive Inspections. Reactive inspections include follow-up for events through additional inspections, Special Inspection Teams (SITs), Augmented Inspection Teams (AITs), and Incident Investigation Teams (IITs). A graded approach to reactive inspections is taken depending on the actual or potential risk-significance of an event or conditions. As more information is developed during an inspection, management may change the type of inspection, for example from an AIT to a SIT. In addition to events, reactive inspections may also be conducted for a significant change in the conditions involving licensed activities, such as a threatened or actual strike, a major layoff of plant personnel, or the occurrence (or pending occurrence) of a natural phenomenon or offsite event. 07.04 Plant-specific Supplemental Inspections. The plant-specific Supplemental Inspections provide diagnostic inspections of identified problems and issues beyond the Core Inspections. Supplemental Inspections are performed as a result of performance issues that are identified by Core Inspections, reactive inspections, or during the LPR. The depth and breadth of specific Supplemental Inspections chosen for implementation will depend upon the risk, safety, or safeguards significance. Supplemental inspections might also be conducted due to allegations. Depending on the risk significance and breadth of the identified performance issues, the supplemental inspections provide a graded response, which includes oversight of the licensees root cause evaluation of the issues, expansion of Core Inspection reviews to increase depth and/or breadth of review, or a focused team inspection (as necessary to evaluate extent of condition); or a broad scope, multi-disciplined team inspection, which would include inspection of areas that appear to be root cause contributors such as a Problem Identification and Resolution system. The decision to conduct a Supplemental Inspection should be made through the assessment process, as further discussed in Section 8.0. For time and labor reporting purposes, supplemental inspections will normally be coded as a Regional Initiative (RI). 07.05 Generic Safety Issue Inspections. Concerns with generic safety or safeguards issues that arise may be addressed solely through the NMSS or NSIR review processes and the use of regulatory communications issued to licensees. Some issues are of such safety or safeguards significance that it is appropriate to perform a one-time inspection under the generic safety issues program element. These inspections may be established by Temporary Instructions (TIs). For example, when it is determined that an issue addressed in a bulletin, generic letter, Nuclear Energy Institute (NEI) initiative, NEI program, or identified by operating experience requires inspection verification or follow-up, requirements and guidance for the inspection will be developed and issued in a TI. Unless such a TI is issued, inspection follow-up is not required to verify completion of licensees actions discussed in a bulletin, generic letter, or NEI program. The plants to be inspected will be designated in the TIs. Specific criteria for closing a TI will be addressed in the TI itself. In general, TIs should not be closed until all relevant safety or safeguards issue items have been completed by the licensee and verified by inspection. However, exceptions may be considered when the licensees schedule for completing items remaining is acceptable, properly documented, and is not a critical element to resolving the safety or safeguards issue. In addition, the need may arise for specific inspections to address major evolutions limited to one or a few licensees, such as adding new process lines or changing the assay of material Issue Date: 03/11/19 6 2600 processed in a facility. The need for these inspections will also be assessed on a case-by-case basis, and they can be conducted under the guidance of a TI or by using existing IPs in a customized inspection plan as Supplemental Inspections. 07.06 Licensee Performance Reviews. LPRs are conducted in accordance with IMC 2604, as part of the overall licensee performance oversight. 07.07 Backshift Inspections. There is not a specific goal for performing backshift inspections. Backshift inspections should be performed for safety and safeguards activities that are ongoing on backshift and whenever required to complete the intended scope of the inspection. (See Appendix C for resident inspector backshift guidance.) 07.08 Inspections During the Construction, Preoperational, and Startup Phases. Inspections for the startup of new or modified facilities are handled on a case-by-case basis through the implementation of a project-specific inspection plan or IMC. 2600-08 PROGRAM IMPLEMENTATION 08.01 Master Inspection Plan. Prior to the start of each calendar year, a MIP will be developed for each of the facilities covered by this IMC. The details of inspections within the MIP will be based on the core inspection program, specific performance issues from the LPR, and ongoing or planned activities at each facility. Inspections that deviate from the core inspections in Appendix B will be approved by the Director, FCSE. For each facility, the MIP will identify all planned inspections to be performed, including Core, Supplemental, or Generic Safety Issue inspections. The estimated staff hours to complete each item on the MIP will also be included. Note that advanced planning for certain activities such as supplemental and reactive inspections may not be possible. The MIP shall be maintained by Region II. These inspections will be coordinated to ensure that: (1) inspections are performed as defined in Appendix B, or modified in writing in accordance with this chapter; (2) inspections do not overlap in such a way to cause undue adverse impacts on normal operations at the facility; and (3) major fuel facility inspection program activities, such as LPRs, can be scheduled with minimum interruption of scheduled inspections. Any inspections that are not to be conducted with the periodicity in Appendix B must be addressed as a program adjustment to the MIP (see Section 08.03). Inspections normally should be announced, with adequate advance notice given to the licensee to ensure that appropriate licensee personnel can be made available and inspectors can arrange to observe certain activities not conducted on a routine basis. However, inspection staffs retain the prerogative to conduct inspections on an unannounced basis where appropriate. Resident inspections for those sites with an assigned resident inspector are considered unannounced. 08.02 Establishment of the Core Inspection Program. The annual core inspection program for a specific facility is complete when the inspections in Appendix B are completed for that facility. The Agencys ability to assess the adequacy of facility performance is the controlling factor in determining the Issue Date: 03/11/19 7 2600 inspection effort necessary to complete the Core Inspections. Appendix B provides an estimate of the hours associated with each inspection procedure for overall resource planning only. a. The Core Inspection procedures are contained in Table 1 of Appendix B. The inspection effort is expressed for five different facility types: 1. Category I Fuel Fabrication Facilities. 2. Category III Uranium Fuel Fabrication Facilities. 3. Uranium Conversion Facilities. 4. Gas Centrifuge Facilities. 5. Laser Enrichment Facilities. b. Appendix B shows a list of IPs required to be used in the Core Fuel Cycle Facility Inspection Program. They are grouped by Function and Program Area. c. For the MC&A Program Area, inspectors select the appropriate procedures to use from the suite of procedures listed in IMC 2683. Estimated hours for planning are determined using the guidance in the IMC. d. For the Physical Protection Program Area, inspectors conduct the inspection procedures contained in the inspection procedure suites described in IMC 2681. The estimated hours for planning for each suite are contained in Appendix B of this IMC. 08.03 Program Adjustments. The program provides Region II flexibility to adjust the frequencies, focus, and intensiveness of inspections for different functional areas at facilities. Periodic adjustments will be based on LPR results, and will take into account the complexity, risk level, and previous operating history of the facility. Occasional adjustments may also occur in response to other events or activities as determined by DFFI or FCSE management. These adjustments should be coordinated between the DFFI and FCSE Branch Chiefs and documented in a memorandum. If the change impacts the approved MIP, then the change must be approved by the Director, FCSE, and the Director, DFFI, or their designee. Minor adjustments involving the exact timing of an inspection within the calendar year, may be performed at the discretion of DFFI management. It is the intent of the program that line management use the built-in flexibility to make the most effective and efficient use of NRC resources to address changes in plant status and licensee operations. A reasonable allowance for responding to events or special licensee activities should normally be included in resource planning. In some cases, necessary adjustments may be difficult to implement within the constraints imposed by limited inspection resources. In such cases, implementation may involve a shift in the focus of already scheduled inspection resources for the subject facility, or a shift in allocated inspection resources from other facilities that are not exhibiting performance problems. Changes in inspections at a facility that will reduce the planned inspections below that of the MIP must be approved by the MIP change process with appropriate management approvals.

Issue Date: 03/11/19 8 2600 2600-09 EVENT REVIEW AND RESPONSE Region II is responsible for determining the seriousness of reported events and whether an inspection (either reactive or core follow-up) is necessary. This determination is performed in coordination with NMSS and, when appropriate, NSIR. Reported events that are determined to require inspection will be addressed in the inspection report in accordance to IMC 0616. Events that do not require any inspection (e.g., a non-safety related concurrent report) should be entered for tracking in the Reactor Program System, or equivalent tracking database with an appropriate justification. Non-reportable events are those events which fall outside of the NRCs reporting criteria. Although these events are not reported formally to NRC, licensees occasionally contact NRC staff informally to describe the event. Licensees are often required, through license conditions, to maintain records of off-normal events onsite. Inspections should examine non-reportable events, and associated licensee responses, for the particular program area being inspected in order to obtain a perspective on emerging problems or declining performance. Technical details of the issue may provide useful insight on equipment, system reliability, or human performance. The agencys response to significant events is described in NRC MD 8.3, NRC Incident Response Program. 2600-10 PLANNING FOR INSPECTIONS 10.01 Inspection Planning. Prior to conducting an inspection, the inspectors shall prepare an inspection plan. The inspector will do sufficient coordination to identify commitments contained in confirmatory action letters (CALs) or confirmatory orders including ADR confirmatory orders as described in Inspection Procedure 92702. Planning should address the creation of tracking numbers for action items identified in CALs and confirmatory orders if this has not already been done. As a minimum, the inspection plan should state the facility to be inspected (including docket number and report number); the dates of the inspection; names of inspectors conducting the inspection; what procedures or suites of procedures will be used; the events, open items, orders, or any special issues that will be reviewed as part of the inspection; and should include an approval block showing that the plan was approved by the cognizant supervisor. 10.02 Review of Open Allegations. Inspectors shall review all open allegations pertaining to areas which they will be inspecting as part of their inspection preparation. The purpose of this review is to allow inspectors to become aware of concerns in the areas which they may be inspecting. Inspectors shall not document performance of their allegation review in inspection reports. Inspectors shall contact the NMSS or regional allegation coordinator when issues similar to the ones identified in the open allegations are found in order to determine what additional inspections, if any, should be performed.

Issue Date: 03/11/19 9 2600 2600-11 CONDUCTING INSPECTIONS 11.01 Entrance and Exit Meetings. Inspectors are required to meet with licensee management as part of every inspection. An example outline for an entrance and exit meeting is shown in Appendix D. Inspectors should hold an entrance meeting with the senior licensee representative who has responsibility for the areas to be inspected. At the conclusion of an inspection, inspectors must discuss their preliminary findings with the licensees management at a scheduled exit meeting. Potential safety or safeguards significant findings should be promptly communicated to the licensee so that appropriate corrective actions or compensatory measures can be initiated. Management entrance and exit meetings with licensee personnel should be scheduled to have the minimum impact on other licensee activities necessary to ensure the safe operation of the facility. Time spent on scheduled and periodic entrance and exit meetings (including preparing for the meetings) is considered inspection time and should be divided among the procedures being performed for the entire inspection. Daily communications with licensee management are considered to be an integral part of every inspection procedure and the time used for such routine communications should be charged to the inspection procedures used. Communicating inspection observations is also an integral and important part of every inspection, whether done daily during the course of an inspection, or periodically with status meetings. Licensees have expressed the desire to hear inspectors' insights or other operation experience items related to safety/regulatory performance even in instances where they do not reach the threshold for documentation in an inspection report, such as deviations from regulatory guidance. When deciding which observations and insights to pass on to the licensee, inspectors should consider the following: a. Inspectors should share the same insights with their regional managers and the senior resident inspector prior to the exit meeting. b. The insights must relate to areas within NRCs jurisdiction and responsibilities. c. Comments should be objective and supported with examples when possible. Avoid generalizations such as procedure adherence was good. Instead, just state the objective facts: Procedures were followed in each case we observed. Negative observations or insights must be supported with specific examples. d. Inspectors should not express an expectation for actions taken by licensee managers. The inspectors may comment on whether or not the actions comply with NRC requirements. e. Inspectors should determine before the exit if the licensee wants to hear the observations and insights at the exit meeting. If the licensee does not want the observations or insights at the exit meeting, the inspectors should not discuss them. Inspectors may choose to provide the licensee with a pre-exit meeting to communicate inspection results and informal observations to the licensee, if desired by the inspection team and the licensee. The inspectors should coordinate with the licensee management to determine if the details of minor violations and inspector observations should be discussed at the pre-exit meeting in lieu of the formal exit meeting.

Issue Date: 03/11/19 10 2600 f. Inspectors must avoid consulting for the licensee and not advise them on how to improve draft documents or in-process work, or pass on to licensees how others do the same thing. 11.02 Findings Related to Non-NRC Regulations. Inspections might uncover safety issues or other problems outside the scope of NRC regulatory authority. The Occupational Safety and Health Administration (OSHA) has authority and responsibilities regarding plant conditions that result in an occupational risk, but do not affect the safety of licensed radioactive materials. For example, there might be exposure to toxic non-radioactive materials and other industrial hazards in the workplace. NRC supports OSHA by reporting any such conditions it learns about to the licensee, NRC, and OSHA so appropriate action(s) can be initiated. Additional actions are described in IMC 1007, Interfacing Activities Between Regional Offices of NRC and OSHA. Follow-up inspections are not required on the part of the NRC unless the potential hazard directly involves radiological health or safety and is a regulatory issue. NRC has authority and responsibilities regarding radiation risk or chemical risk produced by radioactive materials and for plant conditions that affect the safety of radioactive materials and thus present an increased radiation risk to workers. In all cases where the finding involves a potential effect on the safety of radioactive material, the inspector should ask what actions the licensee plans to take. Findings associated with safety issues that could impact the safety of radioactive materials should be reviewed during subsequent inspections until the licensee has satisfactorily addressed the concern. 11.03 Performance-based Inspection Focus. Inspectors should focus their attention on activities important to safety using a performance-based, risk-informed approach. Performance-based inspection emphasizes observing activities and the results of licensee programs over reviewing procedures or records. For example, an inspector might identify an issue through observing a plant activity in progress, monitoring equipment performance, or the in-plant results of an activity (e.g., an engineering calculation), and then let the observed discrepancy or uncertainty lead to evaluation of other associated areas. Discussions with plant personnel and reviewing documents should be used to enhance or verify performance-based observations. These techniques are designed to emphasize observation of activities or those portions that are most risk-significant in terms of safety or safeguards. Potential risk-significant inspection findings and regulatory non-compliances will be handled in accordance with the NRC Enforcement Policy. Findings not covered by the current license will be forwarded to the appropriate NRC branch for resolution. 11.04 Third Party Assistance. On occasion licensees ask inspectors for recommendations for obtaining help solving programmatic problems. Inspectors are prohibited from recommending the services of individuals or organizations for a project under NRC regulatory jurisdiction. Providing such a recommendation violates 5 CFR 2635.702, which prohibits Federal employees from using public office for endorsement of any product, service, or enterprise. 11.05 Findings Outside of Inspectors Qualifications. Inspectors sometimes identify issues or violations outside of the inspectors qualifications or expertise. In these cases the inspector is responsible for (1) determining if an immediate threat to public or worker health or safety exists, determining if an Issue Date: 03/11/19 11 2600 immediate threat to public or worker health or safety exists, determining if an immediate threat to public or worker health or safety exists, and if one does exist to notify licensee management immediately, and (2) determining if the issue is better addressed by an inspector with different qualifications. Inspectors may follow issues outside of their qualifications or expertise with the concurrence of an NRC manager responsible for the area associated with the issue and the inspectors supervisor. The inspectors time associated with the issue is charged to the baseline procedure that best corresponds to the issue. 11.06 Inspection Documentation. Inspections shall be documented in accordance with the requirements of IMC 0616, Fuel Cycle Safety and Safeguards Inspection Reports. 11.07 Independent Inspection Effort. As a general rule, inspections should be conducted in accordance with inspection procedures. However, it is not possible to anticipate all the unique circumstances that might be encountered during the course of a particular inspection. Therefore, individual inspectors are expected to exercise initiative in conducting inspections, based on their expertise, experience, and risk insights, as needed to ensure that all the inspection objectives are met. 11.08 Open Item Guidance. Inspection findings can be tracked as one of the following types of Open Items: URI: An Unresolved Item (URI) involves an issue that requires more information to determine whether a violation has occurred. Because each URI is a potential safety or safeguards issue, every effort must be made to obtain the required information. As such, the inspector should identify what information is required to close the URI to the licensee at the exit meeting and a schedule for obtaining that information should be obtained. Additionally, the inspector should obtain the licensees rationale for why the process is safe prior to leaving the site (e.g., a compensatory measure is in place, the equipment is shut down, etc.). NOV: A Notice of Violation (NOV) is a citation of non-compliance with NRC requirements. A licensee response is required when corrective actions have not yet been completed by the licensee. The inspector should not leave the site until understanding why the process is safe at that time. NOVs should be closed upon verification that the licensee has implemented the corrective actions that they committed to perform in their response to the NOV as soon as practicable after the date when implementation is scheduled to be complete. The inspectors should review the and short-term and long-term corrective actions. DEV: A Deviation (DEV) is a licensees failure to satisfy a written commitment or conform to the provisions of code, standard, guide, or accepted industry practice when the code, standard, guide, or practice involved has not been made a legally binding requirement by the Commission, but is expected to be implemented. Examples of licensees commitments include responses to bulletins, generic letters, or 10 CFR 70.22(d) requests. These items should be handled in the same manner as a URI.

Issue Date: 03/11/19 12 2600 Open items will be entered in the item tracking system. Closeout of items is the responsibility of the organization that opened them or by another organization by agreement between management of those organizations. If closure occurs in an inspection report issued by another organization, it remains the responsibility of the issuing organization to ensure that the item is closed in a timely manner in the item tracking system. 11.09 Witnessing Unsafe Situations. If NRC inspectors identify unsafe work practices or violations which could lead to an unsafe situation they shall make every reasonable attempt to prevent them from occurring in their presence. When such situations are identified, the inspector shall promptly notify a licensee representative so that corrective preventive measure can be taken. 11.10 Inspector Functions During Period of Lapsed Appropriation. NRC Management Directive 4.5, Contingency Plan for Periods of Lapsed Appropriations, has defined the resident and selected region-based inspector function as an excepted NRC activity that will continue during the period of restricted NRC operations. Both resident and region-based inspectors will continue with their respective functions defined below. a. Region-based inspection function: 1. Includes event response requiring regional specialist expertise. 2. Does not include the approval or issuance of inspection reports. b. Resident inspection function includes the following activities: 1. Completion of all of the following activities that are normally assigned to a resident inspector; including the performance of this manual chapter and its appendices. 2. Completion of reactive inspection activities pursuant to NRC Management Directive 8.3, NRC Incident Investigation Program. The decision to initiate a Regional and Program Office managers. 3. Completions of core, reactive and supplemental inspection activities not covered above that had been or are approved by regional management as being within the technical expertise of the residents at the site and that are scheduled for completion during the period of lapsed appropriation. 4. Emergency response, incident response, allegation, enforcement, public communication, and support for emergency licensing action activities that are typically performed by resident inspectors. c. es that require substantial support or approval from the Regional Office or Program Office. This exclusion includes the issuance of inspection reports under IMC 0616, Fuel Cycle Safety and Safeguards Inspection Reports. The resident inspectors do no inherit signature authority unless it is covered by separate authorization.

Issue Date: 03/11/19 13 2600 2600-12 ASSESSING FACILITY PERFORMANCE 12.01 Licensee Performance Review (LPR). LPRs are conducted in accordance with IMC 2604 as part of the overall licensee performance oversight. 12.02 Agency Action Review Meeting (AARM). The information and performance assessments arising from the inspection program should be the primary inputs to management discussions in preparation for the annual AARM, which are conducted per MD 8.14Action Review Meeting. 12.03 Ongoing Assessments of Facility Performance. NRC inspectors perform a basic mission in determining whether a licensee operates the facility safely and securely and meets current regulatory requirements. Limiting inspection to identification of specific instances where a licensee fails to meet such requirements and commitments could result in correction of symptoms rather than correction of underlying causes of licensee problems. Thus, the inspection program requires that inspectors and their managers evaluate problems to determine if follow-up inspections are necessary to diagnose whether a safety concern represents an isolated case or may signify a broader, more serious problem based on the evaluated significance of the issues. 2600-13 ASSESSING PROGRAM IMPLEMENTATION NMSS expects inspectors to identify problems in implementing the fuel cycle facility inspection program, and to recommend changes to the program for consideration. Any such feedback and recommendations should be submitted to NMSS/PORSB. END Attachments: Appendix A Guidance for Conducting Fuel Cycle Inspections Appendix B NRC Core Inspection Requirements - Tables 1 and 2 Appendix C Fuel Cycle Resident Inspection Program Appendix D Fuel Cycle Facility Inspection Planning Issue Date: 03/11/19 Att1-1 2600 ATTACHMENT 1 Revision History for IMC 2600 Commitment Tracking Number Accession Number Issue Date Change Notice Description of Change Description of Training Required and Completion Date Comment Resolution and Closed Feedback Form Accession Numbers (Pre-Decisional, Non-Public Information) N/A ML070190057 04/26/07 CN-07-014 Revised to incorporate the new inspection procedures developed to address changes to 10 CFR Part 70 and to reflect enhancements made to the fuel facility inspection program. None ML070190069 N/A ML072070146 08/15/07 CN 07-025 Remove OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION designation from entire manual chapter to make publicly available. None ML072080010 N/A ML080670196 03/21/08 CN 08-011 Revised to incorporate direction regarding follow-up of issues related to confirmatory orders. None N/A Issue Date: 03/11/19 Att1-2 2600 Commitment Tracking Number Accession Number Issue Date Change Notice Description of Change Description of Training Required and Completion Date Comment Resolution and Closed Feedback Form Accession Numbers (Pre-Decisional, Non-Public Information) N/A ML091120247 05/13/09 CN 09-012 Revised to incorporate additional direction regarding follow-up of issues related to confirmatory orders. None N/A N/A ML093170158 12/02/09 CN 09-029 Added requirement for inspectors to review all open allegations pertaining to the inspection during preparation as part of regulatory improvements resulting from Peach Bottom Lessons Learned. Added guidance from the Field Policy Manual (NUREG/BR-0075) on witnessing unsafe situations. None N/A N/A ML093420698 01/27/10 CN 10-003 Revised to incorporate Gas Centrifuge Facility inspections into the fuel facility inspection program. None N/A Issue Date: 03/11/19 Att1-3 2600 Commitment Tracking Number Accession Number Issue Date Change Notice Description of Change Description of Training Required and Completion Date Comment Resolution and Closed Feedback Form Accession Numbers (Pre-Decisional, Non-Public Information) N/A ML15058A287 09/24/15 CN 15-018 Included section on Lapsed Appropriations in reference to changes in MD 4.5 and Oct 4, 2013 briefing memo (ADAMS Accession No. ML13276A057) required by SRM-COMSECY-14-0017 (ADAMS Accession No. ML14196A064). Removed reference to certificates/ Gaseous Diffusion Plants and fuel assembly facilities. Program description general notes were out of date and removed. Updated organizational names and acronyms. Updated organizational roles since implementation of criticality safety, MC&A, and information security inspections moved to Region II. Removed reference to IMC 0610 and replaced with IMC 0616. None ML15058A223 Issue Date: 03/11/19 Att1-4 2600 Commitment Tracking Number Accession Number Issue Date Change Notice Description of Change Description of Training Required and Completion Date Comment Resolution and Closed Feedback Form Accession Numbers (Pre-Decisional, Non-Public Information) N/A ML17299B312 12/20/17 CN 17-030 Editorial changes to reflect latest revisions to IMC 0616 and IMC 2681 and its associated procedures. None N/A N/A ML18099A225 06/12/18 CN 18-015 Removed "implementation of" from section 05.03 (b). This edit was done to clarify the programmatic role of FCSE. None N/A N/A ML19031C214 03/11/19 CN 19-010 Revision to clarify that not all reported events (e.g., non-safety related concurrent reports) require inspection and documentation. None N/A