ML22019A175

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IMC 0612 Appendix B, Issue Screening Directions
ML22019A175
Person / Time
Issue date: 08/08/2022
From: Cauffman C
NRC/NRR/DRO/IRAB
To:
Cauffman C
Shared Package
ML22213A283, ML22160A549 List:
References
CN 22-016, DC 22-013
Download: ML22019A175 (19)
v • d • e


Text

NRC INSPECTION MANUAL IRAB INSPECTION MANUAL CHAPTER 0612 APPENDIX B ISSUE SCREENING DIRECTIONS Effective Date: 08/08/2022

Figure 1: Issue Screening TE1 TE2 1

Is there a Does Issue of Determine willfulness and if Go to A Assess violation in Go to D potentially traditional concern Yes screening should proceed Figure Yes accordance with the Figure willful enforcement identified without delay 2 Enforcement Policy 2 violation? apply?

From B No No willfulness Figure 2 No is the Document NCV per violation an Yes 0611-08 Yes NCV?

Follow both paths Follow both paths ROP Path Does a Traditional Enforcement Path Continue with No violation Yes Document NOV per ROP path exists? No 0611-05 8

Yes Did the finding Should the issue of Document concern be resolved using Yes VLSSIR per involve a No 2 violation?

? the VLSSIR Process? 0611-12 Does  ?

9 enforcement No further evaluation or Yes Screen performance From C discretion Open or close an documentation apply? deficiency when directed Figure URI per 0611-06

? by Figure 2 2 Yes No finding.

Continue with 4 5 6 No Traditional Enforcement path Is the Does (Block TE2) document Evaluate using Is the finding performance the finding per 0611-11 Yes the SDP. Yes licensee- No deficiency screen 3 More- than- Performance (See IMC 0609) identified?

to green?

Minor? deficiency is a

? finding Performance Is there a deficiency exists performance Yes No deficiency? No Green 7 No finding. Minor finding violations may be documented in some Can No Conduct SERP or Identify appropriate cases per 0611-12 significance SRA reviews as cross-cutting be resolved No Yes appropriate aspect(s)

No finding. before issuing (follow outcome the report?

path)

Pending significance determination Assess for cross-cutting aspect(s) under Block 7 Finding with Document FIN(TBD) or AV per Document per preliminary 0611-05 0611-05 significance Use IMC 0612 Appendix G, Emergency Planning Cornerstone - Specific Supplemental Guidance for Appendix B Screening Figures 1 and 2 as a supplement to Appendix B when screening Emergency Panning issues.

Issue Date: 08/08/22 1 0612 App B

Figure 2: Issue Screening (Traditional Enforcement)

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

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

Yes No Yes No Goto B Figure No willfulness 1

9 Screen any performance deficiency Follow Consider URI (for without potential traditional both TE6 underlying violation) enforcement violation paths Go to C Screen performance Follow Screen performance Figure deficiency both deficiency (confirmed) 1 Figure 1 Block 3 paths 9

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 From D Assess violation in a SL-IV or violation licensee absent specific and overriding Figure accordance with the greater Yes No warrant No identified enforcement guidance.

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

NCV?

No Yes Yes Minor violation or Document violation per 0611-11 no violation. Minor violations absent specific and overriding may be documented in some enforcement guidance.

cases per 0611-12 Document violation per 0611-08 Use IMC 0612 Appendix G, Emergency Planning Cornerstone - Specific Supplemental Guidance for Appendix B Screening Figures 1 and 2 as a supplement to Appendix B when screening Emergency Panning issues.

Issue Date: 08/08/22 2 0612 App B

Additional Guidance to Clarify Figures Inspectors will not use the Reactor 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 disposition 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. Issues having greater significance and to a lessor extent involving current licensee performance should be prioritized.

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

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 (MD) 8.4, Management of Backfitting, Forward Fitting, Issue Finality, and Information Requests.

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 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 severity level (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: 08/08/22 3 0612 App B

Block TE2 Does traditional enforcement apply?

  • 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 or is enforcement discretion being exercised?

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:

  • 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 Does enforcement discretion apply?

Violations are considered for enforcement discretion under Enforcement Policy Section 3, Use of Enforcement Discretion supplemented by guidance in Enforcement Manual Appendix A, Temporary Enforcement Guidance or under Enforcement Policy Section 9, Interim Enforcement Policies. An enforcement panel is to be conducted for any violation that would be classified greater than Severity Level III or greater than White absent discretion unless specifically authorized by the previosuly mentioned policy and guidance. Violations receiving enforcement discretion are not assessed under the ROP as performance deficiencies consistent with IMC 0308, Attachment 3.

Block 3 Is there a performance deficiency?

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

Issue Date: 08/08/22 4 0612 App B

Block 3 Is there a performance deficiency?

  • 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. Organizational weaknesses should not be identified as performance deficiencies, but should be considered as the CCA. The impact of an organizational weakness could be a performance deficency.

(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.

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 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 4 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?

Issue Date: 08/08/22 5 0612 App B

Block 4 Is the performance deficiency More-than-Minor?

  • 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?

Use IMC 0612, Appendix E, Examples of Minor Issues, or the Security Issues Forum process to inform answers to the screening questions listed above. See IMC 0612, Issue Screening, Section 5 for additional guidance.

Block 5 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).

Block 6 Is the finding licensee-identified?

Consider the definitions in IMC 0612 when determining whether a finding is licensee-identified, NRC-identified, or self-revealing.

Block 7 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. The regional staff may assign more than one cross-cutting aspect when there are unique or complex inspection findings warranting more than one cross-cutting aspect. Confer with the Reactor Assessment Branch Chief (NRR/DRO/IRAB) prior to assigning more than one cross-cutting aspect to a finding.
  • 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.)

Issue Date: 08/08/22 6 0612 App B

Block 8 Should the issue of concern be resolved using the VLSSIR Process?

Very Low Safety Significance Issue Resolution (VLSSIR) is a Process used to discontinue inspection, screening, and evaluation of an issue involving only a licensing basis question. Issue screening shall be discontinued and a VLSSIR will be documented in the report when either Criterion 1 or 2 is met:

Criterion 1: The following are met:

  • The inspection staff has not been able to conclude that the issue of concern is a violation or licensee standard, as described in Block 2, after considering any licensee provided supporting information on why the issue of concern is not in its licensing basis and any relevant information developed during the inspection process.
  • The condition surrounding the issue of concern cannot have any potential to be greater than very low significance (i.e., not greater than Green if the issue was determined to be a finding evaluated using the SDP) nor greater than Severity Level IV if the issue was determined to be a violation subject to traditional enforcement.
  • The resources required to resolve the current licensing basis question would not effectively and efficiently serve the Agencys mission.

Criterion 2: The issue of concern was evaluated using Office Instruction COM-106, Technical Assistance Request (TAR) Process and recommended for no further action because the licensing basis standing is indeterminate and the TAR Safety Significance Determination has determined the issue to be of very low significance and the issue would not be subject to escalated enforcement if determined to be a violation.

Cases may arise where clarification of a requirement through generic processes, interim staff guidance, or other appropriate means may be necessary, outside of inspection and assessment, to address broader safety and regulatory concerns.

See the TAR Process for further information how to address current licensing basis questions that do not meet the above criteria.

Open URIs may be assessed using the above criteria to determine whether they should be closed using the VLSSIR process.

Block 9 Open or Close an URI 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: An URI shall not be used to obtain more information in determining the significance of a finding.

Issue Date: 08/08/22 7 0612 App B

Block 9 Open or Close an URI Close an URI when any one of the following conditions are met:

  • No performance deficiency exists (e.g., issue of concern being evaluated using MD 8.4, the associated violation receives enforcement discretion)
  • The performance deficiency is minor
  • The issue of concern was resolved using the VLSSIR process.

Figure 2, Issue Screening (Traditional Enforcement)

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 should 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 promptly. 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, DRO, 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 inapproppriately.

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 the investigation. Using the facts/conclusion above, OGC will make a final determination about willfulness.

Issue Date: 08/08/22 8 0612 App B

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.

Block TE7 Confirmed willful violation Coordinate with the Office of Enforcement through the Regional or Program Office Enforcement Coordinator to disposition violations involving willfulness. See the Enforcement Policy and Enforcement Manual for additional information.

Block TE8 Does the violation warrant enforcement discretion?

For violations involving enforcement discretion, coordinate actions with the Regional or Program Office Enforcement Coordinator. See the Enforcement Policy and Enforcement Manual for additional information.

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 or Interim Enforcement Policies.

Block 9 Consider a URI See Block 9 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: 08/08/22 9 0612 App 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 Issue Date: 08/08/22 10 0612 App 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.

Attributes Areas to Measure (to Maintain Functionality of Containment)

Design Control Plant Modifications, Structural Integrity, Operational Capability 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 Issue Date: 08/08/22 11 0612 App B

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 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: 08/08/22 12 0612 App 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 Protection of Designation and Storage, Processing, Reproduction, and Safeguards Transmitting, Removal and Destruction Information Cyber Security Protection of Systems and Networks, Cyber Security Program Plan and Procedures Issue Date: 08/08/22 13 0612 App B

Attachment 1: Revision History for IMC 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) 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.

ML0308004200 Editorial changes made to reflect title changes to standard No 2/21/2003 ROP terminology. Appendix B was removed as an CN 03-006 attachment to IMC-0612 and was issued as stand alone document.

ML0316106900 Revised to achieve the following: No 6/20/2003 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: 08/08/22 Att1-1 0612 App 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 and 12/03/2008 CN 08-034 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 ID Credit
3. Incorporate IMC 0305 Cross-Cutting Aspect inspection Training guidance ML16154A237
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: 08/08/22 Att1-2 0612 App 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 enforcement ML12205A244 09/07/2012 discretion path to traditional enforcement. FF 0612B-1398, 1439, CN 12-020 1483, 1496, 1507, 1591, 1679, 1680, 1683, 1700, 1703 ML17129A6241 Editorial update made to reflect the splitting of IMC 0612 into 2/13/17 IMC 0611 for documentation and IMC 0612 for issue CN 17-029 screening.

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) process 0612B-1436 (ref: Low Safety Significane Issue Resolution Working ML19220A108 Group Recommendation memo to Ho K. Nieh, Director 0612B-1564 Office of Nuclear Reactor Regulation (ML19260G224)) ML19220A109 0612B-1887 ML19220A110 Issue Date: 08/08/22 Att1-3 0612 App 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) 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 of FBF 0612B - 2268 CN 20-070 licensee ability to foresee and correct, and the definition of ML19220A114 performance deficiency in Block 2. Also modified the FBF 0612B-2415 enforcement bullet in Block 2. ML20345A168 ML21203A356 Clarified the VLSSIR requirements to align with the TAR ML21116A046 07/23/21 process and to addressed FBF 0612B-2427. Established FBF 0612B-2427 CN 21-026 URI closure criteria. ML21113A110 Issue Date: 08/08/22 Att1-4 0612 App 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)

ML22019A175 Updated the VLSSIR and URI consideration and flowchart to Yes Completed ML22160A571 08/08/22 clarify that the presence of traditional enforcement (e.g., on 7/7/22 CN 22-016 impeding the regulatory process) does not preclude VLSSIR and URI documentation. Clarified that violations receiving enforcement discretion are not assessed under the ROP, consistent with IMC 0308 Att 3. Removed guidance that was inconsistent with defining the performance deficiency as the proximate cause of the degraded condition, consistent with IMC 0308 Att 3.

Issue Date: 08/08/22 Att1-5 0612 App B

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