ML19011A326

IMC 0609 Att 04 Initial Characterization of Findings

ML19011A326
Person / Time
Issue date:	12/13/2019
From:	David Aird NRC/NRR/DRO/IRAB
To:
Aird D, 287-0725, NRR/DRO
Shared Package
ML19014A047, ML19346E483	List:
References
CN 19-040, DC 19-006
Download: ML19011A326 (10)

Text

NRC INSPECTION MANUAL IRAB INSPECTION MANUAL CHAPTER 0609, ATTACHMENT 04 INITIAL CHARACTERIZATION OF FINDINGS Effective Date: 12/20/2019 0609.04-01 PURPOSE The framework described in this attachment to the Significance Determination Process (SDP) is designed to provide guidance to NRC inspectors and management for use in the initial characterization of safety or security findings within the seven safety cornerstones of the Reactor Oversight Process (ROP). The initial characterization of findings is designed to perform three functions:

a. Provide an opportunity to the inspector to document all applicable information regarding the finding, and its associated impact on safety or security, in a consolidated format (Table 1).

b. Support the identification of safety cornerstone(s) affected by the degraded condition or programmatic weakness resulting from the finding (Table 2).

c. Direct the inspector to the appropriate SDP appendix of Inspection Manual Chapter (IMC) 0609 for further evaluation (Table 3).

0609.04-02 GUIDANCE Each finding entering the SDP, regardless of the cornerstone under which it is identified, is by definition a performance deficiency that is more than minor as prescribed in IMC 0612.

Performance deficiencies that are determined to be minor are not findings, and therefore, not subjected to the SDP.

02.01 Finding Consolidated Information Sheet (Table 1)

The objective of Table 1 is to provide the inspector and management the opportunity to document and review all the supporting information pertaining to a finding in a concise format.

Below are detailed descriptions of the table sections to facilitate documentation:

a. Clearly Articulated Finding - Describe the identified performance deficiency and the more than minor determination in accordance with applicable IMC 0612 guidance.

Each finding is treated independently in the SDP.

b. Factual Description of Degraded Condition or Programmatic Weakness - State the facts pertaining to the degraded condition or programmatic weakness without any hypothetical situations, failures, or occurrences. For conditions that involve degraded equipment, include the affected system(s), structure(s), component(s) (SSCs), and/or train(s), to include their associated function(s), and how they impacted safety or security. The Initiating Events, Mitigating Systems, and Barrier Integrity cornerstones Issue Date: 12/13/19 1 0609.04

primarily deal with degraded conditions. For a programmatic weakness, include the affected program(s) and describe how the programmatic weakness impacted safety or security. Other pertinent information to consider are root/apparent/proximate cause evaluations, extent of condition assessments, interdependencies with other systems, perspectives from the licensee, and the duration of the degraded condition or programmatic weakness (i.e., exposure time).

c. Logical Link(s) that Connect(s) the Finding to the Degraded Condition or Programmatic Weakness - Clearly articulate the nexus (i.e., logical link(s)) between the inspection finding and the degraded condition or programmatic weakness. The finding should most often be identified as the proximate cause of the degraded condition or programmatic weakness. The determination of cause need not be based on a rigorous root cause evaluation, but rather on a reasonable assessment and judgment of the staff. If the proximate cause of multiple degraded conditions or programmatic weaknesses is the same, there may be just one independent finding provided that the finding is not defined at a level associated with a cross-cutting area as defined in IMC 0310.

d. Supporting Documentation and References - List the documents used during the inspection process. Examples include, but are not limited to, inspection procedures, plant status, licensee event reports, and condition reports.

NOTE: If Table 1 is used to document information pertaining to a security finding, then the table will have to be properly labeled as Safeguards or Official Use Only - Security Related Information.

02.02 Cornerstones Affected by Degraded Condition or Programmatic Weakness (Table 2)

The objective of Table 2 is to support the identification of safety cornerstones affected by the degraded condition or programmatic weakness resulting from the finding. The affected cornerstones may already have been identified previously (e.g., scope of the inspection procedure, inspector experience and knowledge of the ROP); however, Table 2 helps to support this determination. Below is a description to facilitate filling out Table 2:

a. Read through the degraded conditions and programmatic weaknesses listed in all seven cornerstones and check all that are applicable. For the degraded conditions, many of the options are associated with SSCs and events.

b. Review all the checked boxes and determine which cornerstone(s) are affected by the degraded condition or programmatic weakness.

02.03 SDP Appendix Router (Table 3)

Typically, one affected cornerstone is identified in Table 2. The inspector should use the SDP Appendix Router (Table 3) to determine the appropriate SDP appendix for further evaluation of the finding. If more than one cornerstone is affected, and Table 3 results in direction to one (or multiple) SDP appendices, the inspector and management need to ultimately identify one cornerstone based on reasonable judgment of the situation. If the finding progresses to a detailed risk evaluation, the inspector, Senior Reactor Analyst (SRA), and management should confirm the identified cornerstone based on the proportional contribution from each cornerstone to the total risk estimation.

Issue Date: 12/13/19 2 0609.04

NOTE: If the SDP Appendix Router directs the user to a particular appendix, and upon further evaluation that SDP appendix is not capable of evaluating the finding and associated degraded condition or programmatic weakness, the inspection staff and applicable SRA, with support from management, should determine if IMC 0609, Appendix M is an appropriate tool. A planning Significance and Enforcement Review Panel (SERP) is required before transitioning to Appendix M other than when directed explicitly by procedure. Refer to IMC 0609, Attachment 1 for additional guidance.

0609.04-03 REFERENCES IMC 0310, Aspects Within The Cross-Cutting Areas IMC 0612, Issue Screening IMC 0609, Attachment 1, Significance and Enforcement Review Panel Process IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power IMC 0609, Appendix B, Emergency Preparedness SDP IMC 0609, Appendix C, Occupational Radiation Safety SDP IMC 0609, Appendix D, Public Radiation Safety SDP IMC 0609, Appendix E, Security SDP for Power Reactors IMC 0609, Appendix F, Fire Protection Significance Determination Process IMC 0609, Appendix G, Shutdown Operations SDP IMC 0609, Appendix I, Licensed Operator Requalification SDP IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management SDP IMC 0609, Appendix L, Significance Determination Process for B.5.b IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria END Issue Date: 12/13/19 3 0609.04

Table 1- FINDING CONSOLIDATED INFORMATION SHEET Clearly Articulated Finding:

Factual Description of Degraded Condition or Programmatic Weakness:

Logical link(s) that Connect(s) the Finding to the Degraded Condition or Programmatic Weakness:

Supporting Documentation and

References:

Issue Date: 12/13/19 4 0609.04

Table 2 - CORNERSTONES AFFECTED BY DEGRADED CONDITION OR PROGRAMMATIC WEAKNESS () Check the appropriate boxes INITIATING EVENTS MITIGATING SYSTEMS BARRIER INTEGRITY CORNERSTONE CORNERSTONE CORNERSTONE A. Primary System A. Mitigating Systems and A. Fuel Cladding Integrity LOCA initiator PRA Functionality contributor (e.g., Reactivity Management (e.g., exceed RCS leakage from Core Decay Heat licensed power limit, command and pressurizer heater Removal Degraded control, uncontrolled control rod sleeves, RPV movement, inadvertent RCS dilution or piping Short Term Heat cold water injection) penetrations, Removal Degraded CRDM nozzles, Mismanagement of foreign material PORVs, SRVs, Primary (e.g., Safety exclusion program (e.g. loose parts)

ISLOCA issues, Injection-PWR only; etc.) B. RCS Boundary as a mitigator following main feedwater, HPCI, and RCIC - plant upset (e.g., pressurized thermal B. Transient BWR only) shock) initiator contributor High Pressure-Both (e.g., Types Note: All other RCS boundary issues, such reactor/turbine trip, Low Pressure-Both as leaks, will be considered under the loss of offsite Types Initiating Events Cornerstone.

power, main Secondary - PWR steam/feedwater C. Reactor Containment / Drywell Barrier only (e.g. AFW, main piping feedwater, ADVs) Degraded degradations, internal fires or flooding, etc.) Long Term Heat Actual Breach or Bypass (e.g., leakage Removal Degraded past penetration seals, isolation valves (e.g., ECCS sump that can contribute to ISLOCA, vent C. Support System recirculation, and purge system. Failure of SSCs initiator contributor suppression pool) critical to suppression pool integrity)

(loss of service water, loss of instrument air, DC B. External Event Mitigating Heat Removal, Hydrogen or Pressure power, etc.) Systems (Seismic/Fire/ Control Systems Degraded Flood/Severe Weather D. Steam Protection Degraded) D. Control Room, Auxiliary, Reactor, or Generator Tube Spent Fuel Building Barrier Degraded Rupture (SGTR) C. Reactor Protection System (RPS) E. Spent Fuel Pool (SFP)

E. External Event initiators (limited to D. Fire Brigade Maintaining subcritical conditions fire and internal flooding) E. Flexible Coping Spent Fuel Pool Water Inventory and/or Strategies (FLEX)1 Temperature (i.e., cooling) 1 FLEX strategies are associated with Orders EA-12-051, EA-12-049, or EA-13-109. After implementation of SRM-SECY-16-0142, Orders EA-12-051 and EA-12-049 will be codified in 10 CFR 50.155.

Issue Date: 12/13/19 5 0609.04

EMERGENCY OCCUPATIONAL RADIATION PUBLIC RADIATION PREPAREDNESS SAFETY CORNERSTONE SAFETY CORNERSTONE CORNERSTONE Failure to Comply with a ALARA Planning or Work Radioactive Effluent Release Planning Standard or Risk- Controls Program Significant Planning Standard Exposure or Over-exposure Radioactive Environmental problem Monitoring Program Actual Event Implementation Problem Ability to Assess Dose Radioactive Material Control Compromised Program Transportation or Part 61 SECURITY CORNERSTONE Findings identified under the IMC-2201, Security and Safeguards Inspection Program Issue Date: 12/13/19 6 0609.04

Table 3 - SDP APPENDIX ROUTER If the finding and associated degraded condition or programmatic weakness is in the licensees:

1. Emergency Preparedness cornerstone, STOP. Go to IMC 0609, Appendix B.

2. Occupational Radiation Safety cornerstone, STOP. Go to IMC 0609, Appendix C.

3. Public Radiation Safety cornerstone, STOP. Go to IMC 0609, Appendix D.

4. Security cornerstone, STOP. Go to IMC 0609, Appendix E.

5. Initiating Events, Mitigating Systems, or Barrier Integrity cornerstones, CONTINUE below.

Read sections A thru E and answer the YES or NO questions. If NO is answered to all the questions in sections A thru E, the user is directed to Appendix A.

A. Shutdown, Refueling, and Forced Outages:

1. Does the finding pertain to operations, an event, or degraded condition while the reactor vessel is defueled, relate to fuel handling issues, or involve spent fuel pool issues?

a. If YES STOP. Go to IMC 0609, Appendix A.

b. If NO, Continue.

2. Does the finding pertain to operations, an event, or a degraded condition while the plant was shutdown?

NOTE: Appendix G is applicable during refueling, forced, and maintenance outages starting when the licensee has met the entry conditions for the system used to remove residual heat and ends when this system has been secured during plant heat-up.

a. If YES STOP. Go to IMC 0609, Appendix G.

b. If NO, Continue.

B. Licensed Operator Requalification:

Does the finding involve the operator licensing requalification program or simulator fidelity?

a. If YES STOP. Go to IMC 0609, Appendix I.

b. If NO, Continue.

Issue Date: 12/13/19 7 0609.04

C. Maintenance Rule Risk Assessments:

Does the finding involve the licensees assessment and management of risk associated with performing maintenance activities under all plant (operating or shutdown) conditions in accordance 10 CFR 50.65(a)(4) and the Baseline Inspection Procedure (IP) 71111.13, Maintenance Risk Assessment and Emergent Work Control?

a. If YES STOP. Go to IMC 0609, Appendix K.

b. If NO, Continue.

D. 10 CFR 50.54(hh)(2) Mitigating Strategies:

Is the finding associated with the mitigating strategies to maintain or restore core cooling, containment, and spent fuel pool cooling?

a. If YES STOP. Go to IMC 0609, Appendix L.

b. If NO, Continue.

E. Fire Protection:

1. Does the finding involve discrepancies with the fire brigade?

a. If YES STOP. Go to IMC 0609, Appendix A.

b. If NO, Continue.

2. Does the finding involve: (1) A failure to adequately implement fire prevention and administrative controls for transient combustible materials, transient ignition sources, or hot work activities? (2) Fixed fire protection systems or the ability to confine a fire? (3) Or affect the ability to reach and maintain safe shutdown conditions in case of a fire?

a. If YES STOP. Go to IMC 0609, Appendix F.

b. If NO STOP. Go to IMC 0609, Appendix A.

Issue Date: 12/13/19 8 0609.04

Attachment 1 - Revision History for IMC 0609.04 Commitment Accession Description of Change Description of Comment Resolution Tracking Number Training Required and Closed Number Issue Date and Completion Feedback Resolution Change Notice Date Form Accession Number (Pre-Decisional, Non-Public Information)

N/A ML063060347 Revision History reviewed for last four years. NO ML073460588 01/10/08 IMC0609 Attachment 4 has been created to remove Phase CN 08-002 1 - Characterization and Initial Screening of Findings of the significance determination process (SDP) from IMC0609 Appendix A - At Power.

N/A ML101400531 Removed the Phase 1 screening criteria pertaining to the Senior Reactor ML110240265 06/19/12 Initiating Events, Mitigating Systems, and Barrier Integrity Analysts and CN 12-010 cornerstones and placed the screening criteria in IMC 0609, headquarters staff Closed FBF:

Appendix A. Revised Table 1 so it is applicable to all provided detailed 0609.04-1372 cornerstones. Updated Table 2 to add some more items to instructor-led ML12171A239 the Reactor Safety Performance area. Revised Table 3 to training to 0609.04-1678 clarify which SDP appendices are applicable given the resident ML12171A241 cornerstones of interest and details of the finding. inspectors, region Incorporated feedback from ROPFF 0609.04-1458, based inspectors, 0609.04-1372, and 0609.04-1678. This is a complete and other regional reissue no red line. staff. June 2012 N/A ML16056A317 Table 3, SDP Appendix Router was revised to No training is ML16060A285 10/07/16 accommodate SDP IMC 0609, Appendix O, Significance required.

CN 16-026 Determination Process for Mitigating Strategies and Spent Fuel Pool Instrumentation (Orders EA-12-049 and EA 051).

Issue Date: 12/13/19 Att1-1 0609.04

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

N/A ML19198A195 Made draft publicly available to discuss at the July 31, 2019 N/A N/A 7/17/19 ROP monthly public meeting N/A ML19011A326 Revised document to reflect retirement of IMC 0609 No training is ML19014A064 12/13/19 Appendix O, Significance Determination Process for required.

CN 19-040 Mitigating Strategies and Spent Fuel Pool Instrumentation Closed FBFs:

and to align with changes to IMC 0609 Appendix A (ROPFF 0609.04-2084 0609.04-2295). Table 2 was modified to include support ML19014A099 system initiators (ROPFF 0609.04-2289) and move 0609.04-2295 reactivity management issues to the barrier integrity ML19014A103 cornerstone (ROPFFs 0609.04-2133 and 0609.04-2201). 0609.04-2133 Table 3 was modified to direct users to IMC 0609 Appendix ML19014A100 A for spent fuel pool issues during shutdown (ROPFF 0609.04-2201 0609.04-2084). Document was reviewed and minor changes ML19014A101 were made to allow for use with new reactor designs 0609.04-2289 (AP1000). In accordance with Management Directive 8.13 ML19064A974 and COMSECY-16-0022, the Commission was notified of the described changes via SECY-19-0037, Reactor Oversight Process Self-Assessment for Calendar Year 2018, (ADAMS Accession No. ML19042A100). The Commission was also notified of the revisions in a Commissioner Assistants Note (ADAMS Accession No. ML19302F254).

Issue Date: 12/13/19 Att1-2 0609.04