Attachment 2

TECHNICAL BASIS FOR INSPECTION PROGRAM

CONTENTS

1 INTRODUCTION 3

2 METHODOLOGY FOR IDENTIFYING INSPECTABLE AREAS 3

3 BASELINE INSPECTION PROGRAM 3

3.1 PI Verification 6

3.2 Problem Identification and Resolution 6

3.3 Event Follow-up 7

3.4 Plant Status 8

4 SUPPLEMENTAL INSPECTION PROGRAM 8

5 EVENT RESPONSE 9

6 OVERSIGHT OF PLANTS IN EXTENDED SHUTDOWN 10

7 THRESHOLD FOR DOCUMENTING FINDINGS AND INSIGHTS 11

8 OTHER INSPECTION PROGRAM ASPECTS CONSIDERED BUT

NOT INCLUDED 12

FIGURES

Figure 1 IP 71111.01 Basis Summary Sheet 13

Figure 2 IP 71111.02 Basis Summary Sheet 14

Figure 3 IP 71111.03 Basis Summary Sheet 15

Figure 4 IP 71111.04 Basis Summary Sheet 16

Figure 5 IP 71111.05 Basis Summary Sheet 17

Figure 6 IP 71111.06 Basis Summary Sheet 18

Figure 7 IP 71111.07 Basis Summary Sheet 19

Figure 8 IP 71111.08 Basis Summary Sheet 20

Figure 9 IP 71111.09 Basis Summary Sheet 21

Figure 10 IP 71111.10 Basis Summary Sheet 22

Figure 11 IP 71111.11 Basis Summary Sheet 23

Figure 12 IP 71111.12 Basis Summary Sheet 24

Figure 13 IP 71111.13 Basis Summary Sheet 25

Figure 14 IP 71111.14 Basis Summary Sheet 26

Figure 15 IP 71111.15 Basis Summary Sheet 27

Figure 16 IP 71111.16 Basis Summary Sheet 28

Figure 17 IP 71111.17 Basis Summary Sheet 29

Figure 18 IP 71111.18 Basis Summary Sheet 30

Figure 19 IP 71111.19 Basis Summary Sheet 31

Figure 20 IP 71111.20 Basis Summary Sheet 32

Figure 21 IP 71111.21 Basis Summary Sheet 33

Figure 22 IP 71111.22 Basis Summary Sheet 34

Figure 23 IP 71111.23 Basis Summary Sheet 35

Figure 24 IP 71114.01 and IP 71114.06 Basis Summary Sheet 36

Figure 25 IP 71114.02 Basis Summary Sheet 37

Figure 26 IP 71114.03 Basis Summary Sheet 38

Figure 27 IP 71114.04 Basis Summary Sheet 39

Figure 28 IP 71114.05 Basis Summary Sheet 40

Figure 29 IP 71121.01 Basis Summary Sheet 41

Figure 30 IP 71121.02 Basis Summary Sheet 42

Figure 31 IP 71121.03 Basis Summary Sheet 43

Figure 32 IP 71122.01 Basis Summary Sheet 44

Figure 33 IP 71122.02 Basis Summary Sheet 45

Figure 34 IP 71122.03 Basis Summary Sheet 46

Figure 35 IP 71150 Basis Summary Sheet 47

Figure 36 IP 71151 Basis Summary Sheet 48

Figure 37 IP 71152 Basis Summary Sheet 49

Figure 38 IP 71153 Basis Summary Sheet 50

Figure 39 IMC 2515 Basis Summary Sheet 51

Figure 40 IMC 2515, Appendix A Basis Summary Sheet 52

Figure 41 IMC 2515, Appendix B Basis Summary Sheet 53

Figure 42 IMC 2515, Appendix C Basis Summary Sheet 54

Figure 43 IMC 2515, Appendix D Basis Summary Sheet 55

Figure 44 IP 95001 Basis Summary Sheet 56

Figure 45 IP 95002 Basis Summary Sheet 57

Figure 46 IP 95003 Basis Summary Sheet 58

Figure 47 IP 93812 Basis Summary Sheet 59

Figure 48 IMC 0350 Basis Summary Sheet 60

TABLES

Table 1 Inspectable Areas by Cornerstone 61

Table 2 Other Inspection Program Elements Considered But Not Included 63

1 INTRODUCTION

The power reactor inspection program is composed of several elements to
provide indication of licensee performance. The key feature of the
program is the baseline inspection program, which defines the minimum
level of inspection that all plants will receive regardless of
performance. The supplemental inspection program is performed to
independently evaluate the root causes of performance deficiencies when
indications of declining licensee performance are obtained through
either the performance indicators (PIs) or other inspections
(principally the baseline inspection program). Plant events are
inspected to determine their significance and to determine the agency=s
necessary response. Plants in extended shutdowns due to performance
problems are inspected and assessed by a separate inspection process
(i.e., IMC 0350) because many of the PIs and much of the baseline
inspection program would not be applicable.

The risk‑informed baseline inspection program for power reactors defines
the minimum level of planned inspections to evaluate licensee
performance over a 12‑month period. The overall objective of the program
is to monitor all power reactor licensees at a defined level of effort
to assure licensees= performance meets the objectives for each
cornerstone of safety. These cornerstones support the agency=s
performance goals in the NRC=s Strategic Plan.

2 METHODOLOGY FOR IDENTIFYING INSPECTABLE AREAS

The objective in revising the inspection program was to develop a
baseline program that is risk‑informed and performance-based that
identifies the minimum level of inspection required for a plant
(regardless of performance) to give the NRC sufficient information to
determine whether plant performance is acceptable. A key input to this
effort was the regulatory framework and the cornerstones of safety,
which are areas of reactor functions or licensee activities that must be
performed to a certain set of objectives to ensure that the NRC=s
mission is met.

The baseline inspection program was developed using a risk‑informed
approach to determine a comprehensive list of areas to inspect
(inspectable areas) within each cornerstone of safety. These inspectable
areas were selected based on their risk significance (i.e., they are
needed to meet a cornerstone objective as derived from a combination of
probabilistic risk analyses insights, operational experience,
deterministic analyses insights, and regulatory requirements). The scope
of inspection within each inspectable area was determined using the same
risk‑informed approach. The scope of inspection was also modified by the
applicability of a PI. The more fully an indicator measures an area, the
less extensive is the scope of inspection.

3 BASELINE INSPECTION PROGRAM

The baseline inspection program contains certain concepts that are a
change in the approach to conducting inspections from the previous core
inspection program. The key concepts are summarized below:

>  The baseline program is the minimum level of inspection conducted at
> all power reactor facilities, regardless of their performance.
> Licensees performing at a level not requiring additional NRC
> interaction will only be inspected at the baseline inspection level of
> effort.
>
>  Inspections of performance issues beyond the baseline program are
> termed supplemental inspections. This increased inspection effort is
> based on criteria specified in the assessment program to address
> declining licensee performance and is not included in the baseline
> program.
>
>  The scope of the baseline program is defined by inspectable areas
> linked to the cornerstones of safety. The justification for inclusion
> of the inspectable area in the baseline program is described in this
> basis document.
>
>  The baseline program has four parts: (1) inspection in inspectable
> areas in which PIs are not identified and/or in which PIs do not fully
> cover the inspectable area; (2) ongoing verification of the
> information provided in PIs; (3) comprehensive review of licensee
> effectiveness in identifying and resolving problems, and (4) initial
> follow up to plant events and degraded conditions to determine their
> safety significance.
>
>  The process for planning inspections will be based on a 12‑month
> cycle.

Risk has been factored into the baseline inspection program in four
ways: (1) inspectable areas are based on their risk importance in
measuring a cornerstone objective, (2) the inspection frequency, how
many activities to inspect, and how much time to spend inspecting
activities in each inspectable area is based on risk information,
(3) the selection of activities to inspect in each inspectable area is
based on plant‑specific risk information, and (4) inspectors are trained
in the use of risk information.

A panel consisting of Inspection Program Branch and senior regional
managers and their staff developed the sample size and the number of
inspection hours expected to be necessary to complete each of the
inspection procedures, at the inception of the reactor oversight program
(ROP). Sample size and number of hours were developed based on their
expert judgement and relevant risk information on how much inspection
activities would be sufficient to ensure verification that the licensee
was meeting the objectives of all seven cornerstones.

After the first year of implementation of the new ROP, regional
management and inspectors raised concerns regarding the lack of
flexibility in the ROP inspection requirements for both sample size
requirements and number of hours for each inspectable area. They were
concerned with their ability to apply their inspection focus into areas
they felt needed more or less inspection effort based on their overall
knowledge of a specific plant. As a result, in consultation with
regional management, the Inspection Program Branch changed the original
sample size from a single value to a range of values which were -15% to
+15% of the original sample size. The original sample size is the
nominal or average of the -15% and +15% values.

The idea was that any individual plant inspection program could then be
adjusted within these relatively limited ranges based on the
plant-specific insights of the inspectors, but that at a nationwide
program level, the average (i.e., mean) level of samples and effort
would continue to fall in about the middle of these ranges. As
experience with the ROP was accumulated, it was felt that these program
average values and ranges could then be adjusted as needed while still
retaining an appropriate degree of flexibility to accommodate
plant-specific inspection focus needs.

Appendix A to Inspection Manual Chapter 2515 contains a list of baseline
inspection procedures and specifies the required frequency for their
performance. The baseline inspection procedures must be completed at
every plant at a prescribed interval. In certain cases, completion of
some inspection requirements may be accomplished through other
inspections. The expectation is that the regions should normally
complete the nominal (average) number of inspection samples identified
in the inspection procedure. The regions may vary the inspection samples
within the ranges as indicated in each baseline inspection procedure,
based on the licensee performance and inspector insights. For the
purposes of completing the baseline inspection program, the number of
samples completed must be within the range of values specified in each
inspection procedure.

Similar changes were made to the inspection hours in order to maintain
the relationship between the level of inspection resources necessary to
complete the inspection activities and the range of inspection samples
which could be accomplished with each inspection procedure constant.

The program is indicative and not diagnostic. The baseline program
delineates specific inspection activities to evaluate aspects of
licensee programs and processes and their implementation by identifying
findings that are indicative of licensee performance problems.
Inspection findings from the baseline program are evaluated for
significance and used, along with PIs, to assess licensee performance
within the cornerstones of safety. The baseline inspections are not
diagnostic assessments of licensee performance leading to a root cause
determination. Those assessments and root cause determinations are
intended to be reviewed or independently made during supplemental
inspections that are outside the scope of the baseline inspection
program.

The safety performance of nuclear power plants is assessed based on
performance in each cornerstone of safety. Verifying that a licensee
meets the objectives of the cornerstones provides reasonable assurance
that public health and safety are protected. The inspectable areas
verify aspects of the key attributes for each of the associated
cornerstones. The cornerstones to which each inspectable area is
applicable and their link to the attributes they are measuring are
depicted in Table 1 of this Attachment and exhibits 3 through 11 of IMC
0308. Therefore, the baseline inspection program requires that most
inspectable areas be reviewed at each nuclear power plant each year.
Several inspectable areas are reviewed at longer frequencies.

All the important aspects of a cornerstone area are inspected where a PI
has not been established (e.g., design). In cornerstone areas where the
PIs provide only limited indication of performance, the inspectable
areas provide indication of the aspects not measured (e.g., operator
performance during an event). If performance of the cornerstone
objective in a cornerstone area is sufficiently measured by a PI, the
inspection effort in the baseline program only verifies that the PI is
providing the intended data.

Figures 1 through 34 describe the scope of each inspectable area and
explain the basis for why each inspectable area is included in the
baseline program. Reasons for inclusion in the program may be that:
(1) the area is linked to the NRC's mission, (2) the inspectable area
involves a key attribute to a cornerstone of safety, and (3) risk
information justifies including the area in the baseline inspection
program. These inspectable area basis summary sheets discuss the basis
for each inspectable area and include risk insights (from generic risk
analyses and studies), analyses of significant precursor events, and the
risk‑informed judgment of an expert panel of inspectors and risk
analysts. The summary sheet for each inspectable area also identifies
whether a PI applies to the area and what inspections may be needed in
addition to the information provided by the PIs in the area. The
baseline inspection procedures are written to focus on the more
risk‑significant aspects of the inspectable areas as discussed in the
summary sheets, aspects that directly support the desired results and
promote the important attributes of the cornerstones of safety. The
scope of any associated PIs are summarized in the inspectable area
portions of the baseline inspection procedures.

The figures related to the physical protection inspection procedures
were removed because of the Commission=s decision that certain security
information will no longer be publicly available.

In addition to the inspectable areas identified for many of the key
attributes of each cornerstone of safety, the baseline inspection
program also consists of inspection activities devoted to: (1) PI
verification, (2) problem identification and resolution, (3) event
follow‑up, and (4) plant status. As discussed below, Figures 35 through
43 describe the scope and basis for these inspection activities and
other inspection program policies and practices (e.g., Inspection Manual
Chapter \[IMC\] 2515).

3.1 PI Verification

The monitoring of plant performance primarily relies on information
provided by PIs and inspection findings in areas not measured, or not
adequately measured, by PIs. The baseline inspection program will also
selectively collect and review licensee plant‑specific raw data on a
periodic basis to independently verify the accuracy and completeness of
the PI data.

Each PI is verified annually. The annual verification compares the
reported PI data to samples of raw data available (e.g., operating logs,
corrective action program records, maintenance records). Some PIs can be
verified in conjunction with other baseline inspections if the PI is
difficult to accurately verify from plant records. The PI verification
inspection also reviews corrective action program records to determine
if any problems the licensee may have had in collecting PI data were
adequately resolved and updates provided to the NRC.

If a PI is found to be invalid based on inaccurate or incomplete data,
then the associated cornerstone may not be adequately evaluated, and
additional inspections within the areas measured by the PI are
scheduled. The baseline inspection program also provides guidance for
NRC actions in response to incomplete or unreported PIs.

Figures 35 and 36 describe the scope and basis for: (1) the NRC response
to discrepant or unreported PI data and (2) PI verification inspection
activities, respectively.

3.2 Problem Identification and Resolution

The primary means by which licensees maintain an appropriate level of
safety is through an effective problem identification and resolution
(PI&R) program to correct deficiencies involving human performance,
equipment, programs, and procedures. The NRC=s confidence in the
effectiveness of these programs is the basis for the NRC=s policy of
closing lower level violations when they are entered into the licensee=s
corrective action program without independently verifying the final
corrective actions. The inspection program verifies that our confidence
in licensees= programs is still deserved and periodically verifies the
final actions on some of the lower level violations are proper.

The process for evaluating PI&R consists of a performance‑based review
of the licensees' deficiency reporting process, self‑assessments,
quality assurance audits, root cause analyses of events, and corrective
actions. The review of corrective actions includes following them up to
validate their effective implementation. The NRC reviews the licensee's
activities in this area to verify that: (1) the scope of licensees'
identification and resolution programs bounds the key attributes in the
cornerstones; (2) root causes of problems and issues have been properly
determined and corrective actions are timely and effective; and (3) the
generic implication or extent of condition has been appropriately
considered. Issues identified regarding the licensee=s implementation of
its corrective action program are assessed for risk significance using
the Significance Determination Process (SDP).

The NRC program to review activities in this area has three parts. The
first part is conducted during inspection of the associated inspectable
areas within each cornerstone. The second part is a sample of three to
six issues that are selected annually for more in‑depth review. The
third part is a biennial review of the licensee=s PI&R programs. The
biennial review complements the reviews done throughout the year. The
results of the biennial review are then integrated with the PI&R
insights gained via the other inspections.

NRC inspectors use licensees' self‑assessments to help direct these
baseline inspections into worthwhile areas. However, licensees'
self‑assessments will not be used to reduce or replace baseline
inspections. Figure 37 provides additional information on the scope and
basis for PI&R inspections.

3.3 Event Follow‑up

The NRC normally follows up plant events in three ways: (1) events of
low safety significance receive minimal follow up, usually by the
resident inspectors, (2) events of moderate safety significance receive
more follow up, often by one or two regional inspectors, and (3) events
of greater safety significance are followed up by a special team. The
baseline program is designed to initially screen all operational events
and licensee event reports and to follow up only some of the more
routine, noncomplex events. The baseline program includes a procedure
for event follow‑up to be used in conjunction with inspections in the
various inspectable areas. Whether to follow up other events with
regional discretionary resources would depend on the significance of the
event as determined by the baseline inspection program.

Events of low safety significance, such as uncomplicated reactor trips,
are reviewed by resident or region‑based inspectors to verify that the
events are not complicated by conditions such as loss of mitigation
equipment or operator errors. The baseline inspection program=s event
follow‑up procedure focuses the inspector=s initial evaluation of events
on communicating details regarding the event to risk analysts for their
use in determining risk significance. Inspectors will identify equipment
malfunctions and unavailability, operator errors, and other
complications.

The follow‑up of more extensive, nonroutine events is outside of the
scope of the baseline inspection program and would be performed with
reactive inspection resources. The decision to follow up such events
would be made on a case‑by‑case basis by NRC regional management and as
directed by senior NRC management in accordance with NRC Management
Directive (MD) 8.3, \"NRC Incident Investigation Procedures.\"
Significant operational events (defined in MD 8.3) are followed up by a
graded response consisting of inspections such as those conducted by
Incident Investigation Teams (IITs) and Augmented Inspection Teams
(AITs), and Special Inspections (SIs). Follow‑up of these events is
discussed in more detail later in this Attachment.

Figure 38 provides additional information on the scope and basis of
event follow‑up activities performed as part of the baseline inspection
program.

3.4 Plant Status

The primary objective of the plant status activities is to ensure that
the inspectors are aware of current plant conditions and equipment
problems and have a level of understanding of the risk significance of
proposed or ongoing operations, maintenance, and testing by the
licensee. Plant status focuses on identifying and understanding emergent
plant issues, current equipment problems, and ongoing activities and
their overall impact on plant risk. These activities also provide an
independent assessment of the licensee's effectiveness in entering
program, system, and component deficiencies into the corrective action
program.

The plant status portion of the inspection program is important because
it will be used by the inspectors in the risk‑informed process to select
inspection samples and to modify the scope and depth of inspections in
other inspectable areas that support assessment of all cornerstone
areas. This awareness of plant conditions, emerging problems or work,
and activities planned by the licensee is used by the inspectors in
determining which inspection procedures to use and the specific samples
for inspections within the inspectable areas of the baseline inspection
program. Therefore, since plant status is conducted in part to prepare
for other baseline inspection activities, this effort is not considered
part of the direct inspection effort under the baseline program.

Figure 43 provides additional detail regarding the scope and basis of
the plant status activities performed under the baseline inspection
program.

4 SUPPLEMENTAL INSPECTION PROGRAM

The supplemental element of the inspection program was designed to apply
NRC inspection resources in a graded manner when risk significant
performance issues are identified, either by inspection findings
evaluated using the SDP or when PI thresholds are exceeded. Depending on
the risk significance and breadth of the identified performance issues,
the supplemental inspections provide a range of activities including:
oversight of the licensee=s root cause evaluation of the issues;
expansion of the baseline inspection sample 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
multiple cornerstone areas and inspection of cross‑cutting issues. Any
new performance issues identified during the supplemental inspections
are evaluated by the SDP, and new findings issued. The need for
additional NRC actions, including additional supplemental inspections,
are governed by the assessment program Action Matrix.

At the lowest level, the intent of supplemental IP 95001, \"Inspection
For One or Two White Inputs in a Strategic Performance Area,\" is to
review and selectively challenge aspects of the licensee=s root cause
evaluation, but not to perform an independent assessment of the
performance issue. However, the identification by the NRC of significant
issues pertaining to the adequacy of the licensee=s root cause
evaluation may result in the expansion of the procedure as necessary to
independently complete the inspection requirements. Also, the original
performance issue, which is currently retained in the assessment process
for a year, will not be removed from consideration of actions in the
Action Matrix until the weaknesses identified during the supplemental
inspection are addressed and corrected.

The objective of supplemental IP 95002, \"Inspection For One Degraded
Cornerstone or Any Three White Inputs in a Strategic Performance Area,\"
is not only to review and selectively challenge aspects of the
licensee=s root cause evaluation, but to also independently assess the
extent of condition for the individual and collective risk significant
performance issues that warranted this supplemental inspection.

In general, all inspection requirements contained in these two
procedures are intended to be addressed for each issue; however, the
extent that they are reviewed and their specific applicability to the
given issue will necessarily vary. The staff determined that this level
of flexibility was necessary given the various issues that potentially
could lead to supplemental inspections.

Also, these two supplemental inspections are intended to provide the
information the NRC needs in order to assess safety. The NRC can acquire
this information by performing independent inspections or can acquire
the information by reviewing the licensee=s efforts to assess the root
cause of the issue. If the licensee chooses not to provide some of the
information needed to satisfy the inspection requirements, the NRC
always has the option of acquiring this information by independent
inspection.

At the highest level, supplemental IP 95003, \"Supplemental Inspection
for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones,
Multiple Yellow Inputs, or One Red Input,\" is intended to determine the
breadth and depth of safety, organizational, and programmatic issues.
This supplemental procedure is more diagnostic than indicative, and
includes reviews of programs and processes not inspected as part of the
baseline inspection program. While the procedure does allow for focus to
be applied to areas where performance issues have been previously
identified, the procedure requires that some sample reviews be performed
for all key attributes of the effected strategic performance areas. The
rational behind this is that additional NRC assurance is required to
ensure public health and safety, beyond that provided by the baseline
inspection program and the PIs at those facilities where significant
performance issues have been identified. The results of this inspection
will aid the NRC in deciding whether additional regulatory actions are
necessary to assure public health and safety. These additional
regulatory actions could include orders, confirmatory action letters, or
additional supplemental inspections, as necessary to confirm that
corrective actions to the identified performance concerns have been
effective.

Figures 44 through 46 provide additional information on the scope and
basis for each of the supplemental inspection procedures.

5 EVENT RESPONSE

MD 8.3 provides the criteria for NRC investigatory response to
significant operational events involving reactor and non‑reactor
facilities licensed by the NRC. The criteria define several levels of
response, including an IIT and AIT. IITs inspect events having greater
health and safety significance than events inspected by AITs.

As part of the development of the new reactor oversight process (ROP),
MD 8.3 was revised to risk‑inform the deterministic criteria for event
response at reactor facilities. The previous deterministic criteria for
IITs and AITs is now evaluated in conjunction with risk in order to
identify a graded response, based in part on the risk metric. The graded
response will consist of an IIT, AIT, and Special Inspection for the
lowest level of response. The risk metric of conditional core damage
probability (CCDP) is used to best reflect the full extent of any loss
of defense‑in‑depth due to the event, regardless of whether the cause is
due to licensee performance or otherwise. Numerical risk estimation by
itself is not meaningful unless accompanied by an understanding of the
most influential related assumptions and uncertainties.

One comment received during ROP development was that the risk evaluation
to support a prompt NRC determination of the level of response will be
hampered by lack of information in the early stages of the event. In
addition, information from the NRC event response inspection may
significantly revise the risk value and thereby require a different
level of NRC response. This problem stresses the need to use the
deterministic criteria in conjunction with risk insights. In addition,
the program will retain the flexibility, similar to the current
oversight process, to revise the level of response based on new
information and changing risk levels.

Figure 47 provides additional information regarding the scope and basis
for the Special Inspection level of event response.

6 OVERSIGHT OF PLANTS IN EXTENDED SHUTDOWN

During the development of the new ROP, the staff also significantly
revised its process for overseeing plants in an extended shutdown for
performance problems. This process was risk‑informed through new
criteria that better focuses agency attention on those safety
significant issues that contributed to the shutdown. These changes also
made the process more objective by using the Action Matrix and SDP to
establish criteria and thresholds for actions. The new guidance for
plants in extended shutdowns for performance problems was incorporated
into a revision to IMC 0350, \"Staff Guidelines for the Assessment and
Review of Plants that Are Not Under the Routine Reactor Oversight
Process.\" The title for IMC 0350 was later changed to \"Oversight of
Operating Reactor Facilities in a Shutdown Condition Due to Significant
Performance and/or Operational Concerns.\"

The three major aspects of the IMC 0350 process are: (1) the criteria
for placing a plant into the process, (2) the scope of issues for the
IMC 0350 required restart panel, and (3) the criteria for removing a
plant from this process and placing it back into the routine ROP. The
thresholds for placing a plant into the IMC 0350 process have been
risk‑informed and made more objective by using the assessment program
Action Matrix. Consideration is given for placing a plant in the IMC
0350 process when a licensee=s performance is determined to be in the
Multiple/Repetitive Degraded Cornerstone column of the Action Matrix,
and the plant is expected to be shutdown for at least three months.

The second area of the IMC 0350 process is the criteria used to
determine what issues need to resolved before restarting a plant. The
scope of issues to be considered prior to restart has been risk informed
by using the SDP. The issue(s) that have to be resolved before a plant
restarts, and would be within the restart panel=s scope, should have
risk significance (i.e., White, Yellow, or Red), but the issue(s) would
not be limited to any specific performance area.

The third area of the IMC 0350 process is the criteria for returning a
plant to the routine ROP. This criteria also has been risk‑informed by
using the Action Matrix. The approval for exiting the process and
returning a plant to the routine ROP is based on the licensee
satisfactorily resolving all performance issues with low to moderate or
greater risk significance (i.e., White, Yellow, or Red), and has
operated the plant for approximately four calendar quarters while
accumulating PI data needed for the routine assessment process.

After a year of implementation under the ROP, and from the experience
gained with one licensee that was under the IMC 0350 process, the staff
revised the process to clarify the conditions for entering the process,
as well as clarifying the responsibilities of designated positions,
while encouraging the continued collection of PIs, if they remain valid.
In December 2003, IMC 0350 was revised to provide a comprehensive
correlation between aspects of the ROP and the IMC 0350 process, to
provide an enhanced structure to the inspection approach for IMC 0350
plants, and to incorporate other lessons learned and clarifications.
Additional detail on the scope and basis for the IMC 0350 process can be
found in Figure 48.

7 THRESHOLD FOR DOCUMENTING FINDINGS AND INSIGHTS

The ROP uses PIs and inspection findings evaluated for risk in
determining a plant=s performance in meeting the objectives of the seven
cornerstones, and in determining agency actions. Therefore, the format
for inspection reports for the baseline inspection program was developed
to document only those issues that meet a minimum threshold for safety
importance. This change removed from the reports much of the discussion
regarding inspector observations of licensee activities (both positive
and negative), minor findings and minor violations identified by the
inspector, and licensee identified findings of very low significance
that would not be used in objectively assessing performance.

Stakeholder feedback during the pilot program indicated that many
inspectors and regional managers were uncomfortable with removing from
inspection reports these \"insights\" into licensees= performance. The
inspectors and regional managers feel they need these observations
(i.e., issues that may have very little or no risk significance
individually) to better assess cross‑cutting areas, such as problem
identification and resolution and human performance. Some licensees also
expressed their concern with no longer having these insights and
observations from NRC inspectors. Therefore, the guidance for inspection
reports was changed to allow inspectors to document observations in
conjunction with and to support a finding.

The assessment program was developed to use objective and repeatable
indications of problems to assist the NRC in assessing licensee
performance and to determine the appropriate level of NRC=s response.
Positive findings, which generally are subjective and usually have no
measurable basis in regulation or safety, were not included in the
assessment process. Therefore, it was decided that they should not be
documented in inspection reports. Stakeholder comment was solicited
during the development and pilot program for the ROP to determine
whether positive inspection findings should be captured and incorporated
into the oversight process.

The consensus was that the NRC does not have objective criteria for
evaluating positive findings. Therefore, because the assessment process
does not explicitly incorporate positive findings, they should not be
documented in inspection reports. However, positive aspects of licensee
operations will be reflected in those items for which the SDP credits
mitigation capabilities, and those positive aspects will be recorded in
inspection reports as assumptions used in characterizing inspection
findings.

Although not documented and used in the assessment process, inspection
observations (both positive and negative) and minor violations should be
verbally communicated to the licensee in routine interactions by the
inspectors during the inspection. It was also considered to be more
appropriate for licensee=s to communicate positive aspects of their
operations to the public.

8 OTHER INSPECTION PROGRAM ASPECTS CONSIDERED BUT NOT INCLUDED

While developing the baseline inspection program, several additional
inspectable areas were considered, but not included in the program.
These other inspectable areas were not included for several reasons,
such as adequate coverage of the area by an existing PI, adequate
coverage by another inspectable area, or having low safety significance
relative to the other inspectable areas in the program. Some of these
additional inspectable areas that were considered, and the basis for not
including them in the baseline inspection program, are listed in Table 2
of this Attachment. In addition to inspectable areas, Table 2 also
includes other inspection program attributes that were considered but
not included.

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Adverse     |                                   |
| Weather Protection                |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Initiating    | **Inspection Procedure:** IP      |
| Events and Mitigating Systems     | 71111.01                          |
+-----------------------------------+-----------------------------------+
| **Scope:** Inspection activities  |                                   |
| in this area focus on evaluating  |                                   |
| the licensee=s readiness for      |                                   |
| protecting mitigating systems and |                                   |
| components from external factors  |                                   |
| such as tornado, hurricane, high  |                                   |
| winds, high temperatures, cold    |                                   |
| weather and other adverse weather |                                   |
| related conditions. This          |                                   |
| inspection focus ensures that     |                                   |
| risk significant systems and      |                                   |
| components will perform within    |                                   |
| the design assumptions for        |                                   |
| adverse weather.                  |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** Inspection of this     |                                   |
| item supports the Initiating      |                                   |
| Events and Mitigating Systems     |                                   |
| cornerstones by ensuring that the |                                   |
| licensee takes steps to reduce    |                                   |
| the effects of weather‑related    |                                   |
| initiating events and the impact  |                                   |
| of adverse weather on key         |                                   |
| portions of mitigating systems.   |                                   |
| Weather conditions leading to     |                                   |
| loss of offsite power, freezing   |                                   |
| temperatures, high temperatures,  |                                   |
| and high winds dominate external  |                                   |
| risk.                             |                                   |
|                                   |                                   |
| The inspection activities are     |                                   |
| intended to verify that the       |                                   |
| licensee has taken the necessary  |                                   |
| steps to demonstrate that the     |                                   |
| reliability, availability and     |                                   |
| functional capability of SSCs and |                                   |
| associated components are         |                                   |
| maintained during adverse weather |                                   |
| conditions. For example,          |                                   |
| operating experience indicates    |                                   |
| that cold weather conditions      |                                   |
| continue to cause intake          |                                   |
| structure icing, process and      |                                   |
| instrument line freezing,         |                                   |
| emergency diesel generator oil    |                                   |
| viscosity problems, essential     |                                   |
| chiller problems, and electrical  |                                   |
| problems leading to loss of       |                                   |
| power. High winds, tornado, and   |                                   |
| hurricane could affect the        |                                   |
| availability of offsite power.    |                                   |
|                                   |                                   |
| Frozen equipment can lead to a    |                                   |
| common cause/mode loss of         |                                   |
| multiple trains and loss of       |                                   |
| equipment in redundant systems    |                                   |
| without any indication of a       |                                   |
| problem until called upon to      |                                   |
| function, which would have a      |                                   |
| significant impact on plant risk. |                                   |
| In addition, high temperature     |                                   |
| conditions can place plant        |                                   |
| equipment and systems in an       |                                   |
| unanalyzed condition, which could |                                   |
| also have a significant impact on |                                   |
| risk.                             |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** There |                                   |
| are no performance indicators     |                                   |
| that have been established that   |                                   |
| can provide information related   |                                   |
| to the adequacy of licensee=s     |                                   |
| readiness for seasonal            |                                   |
| susceptibilities and for any      |                                   |
| impending adverse weather         |                                   |
| conditions.                       |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| December 2001 ‑ Revised procedure |                                   |
| to provide additional             |                                   |
| clarification to the inspection   |                                   |
| requirements and guidance for     |                                   |
| evaluating licensee=s readiness   |                                   |
| for seasonal susceptibilities and |                                   |
| impending weather conditions.     |                                   |
|                                   |                                   |
| January 2002 - Revised to provide |                                   |
| detailed inspection requirements  |                                   |
| and guidance for evaluating       |                                   |
| licensee=s readiness for seasonal |                                   |
| susceptibilities and impending    |                                   |
| weather conditions. In addition,  |                                   |
| the inspection resources estimate |                                   |
| is revised to provide a band for  |                                   |
| more inspection flexibility.      |                                   |
+-----------------------------------+-----------------------------------+

Figure 1 IP 71111.01 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area**: Evaluations |                                   |
| of Changes, Tests, or Experiments |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Initiating    | **Inspection Procedure:** IP      |
| Events, Mitigating Systems,       | 71111.02                          |
| Barrier Integrity                 |                                   |
+-----------------------------------+-----------------------------------+
| **Scope:** This inspection        |                                   |
| monitors the effectiveness of the |                                   |
| licensee=s implementation of      |                                   |
| changes to facility structures,   |                                   |
| systems, and components (SSCs),   |                                   |
| risk significant normal and       |                                   |
| emergency operating procedures,   |                                   |
| test programs, and the updated    |                                   |
| final safety analysis report      |                                   |
| (UFSAR) in accordance with the    |                                   |
| requirements of 10 CFR 50.59.     |                                   |
| This inspection provides          |                                   |
| assurance that required license   |                                   |
| amendments have been obtained. It |                                   |
| verifies aspects of Initiating    |                                   |
| Events, Mitigating Systems and    |                                   |
| Barrier Integrity cornerstones    |                                   |
| for which there are no indicators |                                   |
| to measure performance.           |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** Inspection of this     |                                   |
| area supports the Mitigating      |                                   |
| Systems, Barrier Integrity, and   |                                   |
| Initiating Events cornerstones.   |                                   |
|                                   |                                   |
| Inspection of this item verifies  |                                   |
| that changes to facility and      |                                   |
| procedures as described in the    |                                   |
| UFSAR, and changes to tests and   |                                   |
| experiments not described in the  |                                   |
| UFSAR are in accordance with the  |                                   |
| requirements of 10 CFR 50.59.     |                                   |
| This would provide assurance that |                                   |
| the changes in facility,          |                                   |
| procedures, or test/experiments   |                                   |
| has not reduced the safety        |                                   |
| margins of the SSCs or for        |                                   |
| operation of the plant.           |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** No    |                                   |
| performance indicators have been  |                                   |
| established that can provide      |                                   |
| results related to the adequacy   |                                   |
| of the licensee=s program for     |                                   |
| making changes to the facility.   |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| April 2000 ‑ Requirements for     |                                   |
| reviewing license changes in      |                                   |
| accordance with 10 CFR 50.54 were |                                   |
| deleted from the inspection scope |                                   |
| and basis of this inspection      |                                   |
| procedure, and were incorporated  |                                   |
| into IP 71114.04.                 |                                   |
|                                   |                                   |
| September 2000 - revised to       |                                   |
| eliminate the inconsistencies in  |                                   |
| the procedure regarding           |                                   |
+-----------------------------------+-----------------------------------+

Figure 2 IP 71111.02 Basis Summary Sheet

  -----------------------------------------------------------------------
  **Basis Summary Sheet**             
  ----------------------------------- -----------------------------------
  **Inspectable Area:** Reserved      

  **Cornerstone(s):**                 **Inspection Procedure:** IP
                                      71111.03

  **Scope:** .                        

  **Basis:**                          

  **Performance Indicators:**         

  **Significant Changes in Scope or   
  Basis:**                            
  -----------------------------------------------------------------------

Figure 3 IP 71111.03 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Equipment   |                                   |
| Alignment                         |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Initiating    | **Inspection Procedure:**         |
| Events, Mitigating Systems, and   | IP71111.04                        |
| Barrier Integrity                 |                                   |
+-----------------------------------+-----------------------------------+
| **Scope:** To verify equipment    |                                   |
| alignment and identify any        |                                   |
| discrepancies that impact the     |                                   |
| function(s) of the system and,    |                                   |
| therefore, potentially increase   |                                   |
| risk. This includes conducting    |                                   |
| approximately three partial       |                                   |
| walkdown inspections each         |                                   |
| calendar quarter to verify the    |                                   |
| operability of a redundant or     |                                   |
| backup system/train or a          |                                   |
| remaining operable system/train   |                                   |
| with the highest risk             |                                   |
| significance for the current      |                                   |
| plant configuration (considering  |                                   |
| out‑of‑service, inoperable, or    |                                   |
| degraded equipment); or a         |                                   |
| risk‑significant system/train     |                                   |
| that was recently realigned       |                                   |
| following an extended system      |                                   |
| outage, maintenance,              |                                   |
| modification, or testing; or a    |                                   |
| risk‑significant single‑train     |                                   |
| system. In addition, inspectors   |                                   |
| will perform one complete         |                                   |
| walkdown every 6 months to        |                                   |
| support only the Mitigating       |                                   |
| Systems cornerstone. This         |                                   |
| inspection activity will be       |                                   |
| performed during both shutdown    |                                   |
| and operating conditions.         |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** Inspection of this     |                                   |
| area supports the Initiating      |                                   |
| Events, Mitigating Systems and    |                                   |
| Barrier Integrity cornerstones.   |                                   |
|                                   |                                   |
| The inspection activities are     |                                   |
| intended to verify that the       |                                   |
| licensee has an effective process |                                   |
| for maintaining system            |                                   |
| configuration control, which      |                                   |
| ensures that the functional       |                                   |
| capability of the plant system is |                                   |
| maintained. Systems or components |                                   |
| that are not properly aligned can |                                   |
| lead to the initiation of an      |                                   |
| event and can impact the          |                                   |
| availability and functional       |                                   |
| capability of plant equipment,    |                                   |
| thereby significantly increasing  |                                   |
| the overall risk to the plant.    |                                   |
| Inspection activities would       |                                   |
| normally be performed following   |                                   |
| emergent work activities, planned |                                   |
| removal of risk‑significant       |                                   |
| systems for online maintenance,   |                                   |
| and during outage related         |                                   |
| activities.                       |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:**       |                                   |
| Unavailability and safety system  |                                   |
| functional failure performance    |                                   |
| indicators have been identified.  |                                   |
| Due to the monitoring of a        |                                   |
| limited number of systems, this   |                                   |
| inspection supplements those PIs. |                                   |
| Also, there is no similar PI for  |                                   |
| equipment lineup during shutdown  |                                   |
| conditions, requiring this        |                                   |
| baseline inspection.              |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| None                              |                                   |
+-----------------------------------+-----------------------------------+

Figure 4 IP 71111.04 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Fire        |                                   |
| Protection                        |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Initiating    | **Inspection Procedure:** IP      |
| Events and Mitigating Systems     | 71111.05                          |
+-----------------------------------+-----------------------------------+
| **Scope:** The inspection is      |                                   |
| conducted in three phases. Phase  |                                   |
| one consists of the routine       |                                   |
| inspection conducted by the       |                                   |
| resident inspectors and it        |                                   |
| incorporates a quarterly          |                                   |
| assessment of conditions related  |                                   |
| to ignition sources, control of   |                                   |
| combustible materials, and fire   |                                   |
| protection systems and equipment. |                                   |
| Phase two, also conducted by the  |                                   |
| resident inspectors includes the  |                                   |
| assessment of fire brigade        |                                   |
| staffing, training and            |                                   |
| performance. Phase three is the   |                                   |
| triennial team inspection to      |                                   |
| conduct a design based            |                                   |
| risk‑informed inspection that     |                                   |
| includes the defense‑in‑depth     |                                   |
| elements of the fire protection   |                                   |
| installed to mitigate the         |                                   |
| consequences of a fire. The team  |                                   |
| assesses the capability of        |                                   |
| equipment necessary for plant     |                                   |
| shutdown following a fire.        |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** Inspection of this     |                                   |
| item supports the Initiating      |                                   |
| Events and Mitigating Systems     |                                   |
| cornerstones.                     |                                   |
|                                   |                                   |
| The inspection reviews licensee   |                                   |
| controls designed to minimize the |                                   |
| probability of a fire and the     |                                   |
| availability and reliability of   |                                   |
| equipment necessary to mitigate   |                                   |
| the effects of a fire.            |                                   |
|                                   |                                   |
| Proper implementation of the fire |                                   |
| protection program is important   |                                   |
| to provide defense‑in‑depth       |                                   |
| against fires by maximizing       |                                   |
| prevention, detection,            |                                   |
| suppression, and mitigation       |                                   |
| capabilities for fires. An        |                                   |
| effective program reduces the     |                                   |
| risk of a fire being an           |                                   |
| initiating event. Also, in the    |                                   |
| event of a fire, reliable         |                                   |
| detection, suppression and        |                                   |
| mitigation capabilities ensure    |                                   |
| the plant can be safely shut      |                                   |
| down. Plant specific evaluations  |                                   |
| have shown internal fires to be   |                                   |
| high contributors to risk at some |                                   |
| plants due to the potential for   |                                   |
| damaging redundant systems and    |                                   |
| multiple control circuits and due |                                   |
| to the adverse effect on operator |                                   |
| mitigation strategies.            |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** There |                                   |
| are no performance indicators     |                                   |
| that assess performance in the    |                                   |
| area of fire protection.          |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| March 2001 ‑ The scope of the     |                                   |
| procedure was reduced while       |                                   |
| criteria for review of            |                                   |
| fire‑induced circuit failures of  |                                   |
| associated circuits is the        |                                   |
| subject of a voluntary industry   |                                   |
| initiative. Per this temporary    |                                   |
| revision, the inspector is not    |                                   |
| required to address associated    |                                   |
| circuits issues as a direct line  |                                   |
| of inquiry nor develop associated |                                   |
| circuits inspection findings      |                                   |
| (with certain exceptions          |                                   |
| contained in Section 02.03 of the |                                   |
| procedure). However, in certain   |                                   |
| instances associated circuits     |                                   |
| issues may arise unavoidably and  |                                   |
| indirectly during the inspector=s |                                   |
| review of safe shutdown system    |                                   |
| selection, redundant train        |                                   |
| separation, and the provision of  |                                   |
| independent alternative shutdown  |                                   |
| capabilities (\"byproduct\"       |                                   |
| associated circuits issues).      |                                   |
| These byproduct associated        |                                   |
| circuits issues shall be          |                                   |
| documented as unresolved items    |                                   |
| awaiting generic resolution of    |                                   |
| the related associated circuits   |                                   |
| issues.                           |                                   |
|                                   |                                   |
| March 2003 - Revised to provide   |                                   |
| inspection guidance to evaluate   |                                   |
| licensee manual actions which     |                                   |
| have been incorporated into the   |                                   |
| procedure as Enclosure 2.         |                                   |
|                                   |                                   |
| September 2004 - separated the    |                                   |
| Triennial Fire Protection         |                                   |
| Inspection Procedure (71111.05T)  |                                   |
| from the Quarterly and Annual     |                                   |
| Inspection Procedure              |                                   |
| (71111.05QA). There are no        |                                   |
| substantial changes to the        |                                   |
| Quarterly and                     |                                   |
|                                   |                                   |
| Annual inspection procedure.      |                                   |
|                                   |                                   |
| January 2005 - Reinstated the     |                                   |
| inspection of circuits, with      |                                   |
| enforcement discretion for        |                                   |
| escalated findings extended       |                                   |
| through 2005.                     |                                   |
|                                   |                                   |
| June 2005 - Reissued 71111.05QA   |                                   |
| inspection procedure with new     |                                   |
| guidance to assess fire brigade   |                                   |
| performance.                      |                                   |
+-----------------------------------+-----------------------------------+

Figure 5 IP 71111.05 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Flood       |                                   |
| Protection Measures               |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Initiating    | **Inspection Procedure:** IP      |
| Events and Mitigating Systems     | 71111.06                          |
+-----------------------------------+-----------------------------------+
| **Scope:** Inspection activities  |                                   |
| in this area focus on licensee=s  |                                   |
| readiness to protect the plant    |                                   |
| from potential internal and       |                                   |
| external flooding. These          |                                   |
| inspection activities would       |                                   |
| include walkdown verification of  |                                   |
| key plant areas to verify flood   |                                   |
| protection features, review of    |                                   |
| procedures including verification |                                   |
| of key operator actions credited  |                                   |
| for coping with flood, and        |                                   |
| evaluation of compensatory        |                                   |
| measures during impending         |                                   |
| conditions of flooding or heavy   |                                   |
| rains. The inspection will also   |                                   |
| focus on verifying that the       |                                   |
| licensee=s flooding mitigation    |                                   |
| plans and equipment are           |                                   |
| consistent with the licensee=s    |                                   |
| design requirements and the risk  |                                   |
| analysis assumptions, and         |                                   |
| equipment is routinely tested and |                                   |
| remains fully capable to perform  |                                   |
| the intended functions.           |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** This activity would be |                                   |
| an input to the Initiating Events |                                   |
| and Mitigating Systems            |                                   |
| cornerstones.                     |                                   |
|                                   |                                   |
| Verification of the licensee=s    |                                   |
| implementation of the flood       |                                   |
| control program would be          |                                   |
| performed to insure that the      |                                   |
| facility is capable of            |                                   |
| withstanding potential internal   |                                   |
| and external flooding. Flooding   |                                   |
| would have a significant adverse  |                                   |
| affect on the functional          |                                   |
| capability of safety and risk     |                                   |
| related equipment needed to       |                                   |
| maintain the plant in a safe      |                                   |
| shutdown condition.               |                                   |
|                                   |                                   |
| Flooding due to external and      |                                   |
| internal causes has been shown to |                                   |
| be a significant contributor to   |                                   |
| risk at some facilities. In       |                                   |
| addition, flooding has the        |                                   |
| potential to make multiple trains |                                   |
| of equipment and support          |                                   |
| equipment inoperable which would  |                                   |
| result in a significant increase  |                                   |
| in risk to the plant. Flooding    |                                   |
| also has a significant            |                                   |
| consequence of preventing or      |                                   |
| limiting operator mitigation and  |                                   |
| recovery actions.                 |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** There |                                   |
| are no performance indicators     |                                   |
| that have been established that   |                                   |
| can provide results related to    |                                   |
| the adequacy of the licensee=s    |                                   |
| program for mitigating the        |                                   |
| consequences for flooding. Due to |                                   |
| the rare but possibly risk        |                                   |
| significant nature of flooding    |                                   |
| events, no performance indicator  |                                   |
| was judged to be suitable for     |                                   |
| monitoring licensee performance   |                                   |
| in this area.                     |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| None                              |                                   |
+-----------------------------------+-----------------------------------+

Figure 6 IP 71111.06 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Heat Sink   |                                   |
| Performance                       |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Initiating    | **Inspection Procedure:** IP      |
| Events and Mitigating Systems     | 71111.07                          |
+-----------------------------------+-----------------------------------+
| **Scope:** To verify that any     |                                   |
| potential heat exchanger          |                                   |
| deficiencies which could mask     |                                   |
| degraded performance or common    |                                   |
| cause heat sink performance       |                                   |
| problems that have the potential  |                                   |
| to increase risk are identified.  |                                   |
| Applies to all heat exchangers    |                                   |
| connected to safety related       |                                   |
| service water systems.            |                                   |
|                                   |                                   |
| To verify that the licensee has   |                                   |
| adequately identified and         |                                   |
| resolved heat exchanger/sink      |                                   |
| performance problems that could   |                                   |
| result in initiating events or    |                                   |
| affect multiple heat exchangers   |                                   |
| in mitigating systems and thereby |                                   |
| increase risk.                    |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** Inspection in this     |                                   |
| area supports the Initiating      |                                   |
| Events and Mitigating Systems     |                                   |
| cornerstones by ensuring          |                                   |
| initiating events are not caused  |                                   |
| by a loss of heat sink and that   |                                   |
| mitigating systems heat removal   |                                   |
| capabilities are not degraded.    |                                   |
|                                   |                                   |
| Heat exchangers and heat sinks    |                                   |
| are required to remove decay      |                                   |
| heat, and provide cooling water   |                                   |
| for operating equipment.          |                                   |
| Degradation in performance can    |                                   |
| result in failure to meet system  |                                   |
| success criteria, and lead to     |                                   |
| increased risk primarily due to   |                                   |
| common cause failures. This       |                                   |
| inspectable area verifies aspects |                                   |
| of the associated cornerstones    |                                   |
| for which there are no indicators |                                   |
| to measure performance.           |                                   |
|                                   |                                   |
| The inspection focuses on events  |                                   |
| that could result in the          |                                   |
| simultaneous loss of both the     |                                   |
| normal and ultimate heat sinks    |                                   |
| due to events such as ice         |                                   |
| buildup, grass intrusion or       |                                   |
| blockage of pipes and components  |                                   |
| by other foreign materials, and   |                                   |
| verifying the heat transfer       |                                   |
| capabilities of risk significant  |                                   |
| heat exchangers by observing      |                                   |
| performance testing, reviewing    |                                   |
| the results of those same tests,  |                                   |
| inspection/cleaning, or by        |                                   |
| monitoring licensee=s bio‑fouling |                                   |
| controls.                         |                                   |
|                                   |                                   |
| Also, industry experience has     |                                   |
| shown that many plants have       |                                   |
| experienced significant problems  |                                   |
| with repeated loss of heat sink   |                                   |
| and degraded performance of heat  |                                   |
| exchangers due to problems that   |                                   |
| include corrosion, silting and    |                                   |
| fouling. Since the subject heat   |                                   |
| exchangers do not normally        |                                   |
| operate at design heat loads, it  |                                   |
| is important for the licensee to  |                                   |
| routinely monitor the performance |                                   |
| of the heat exchangers to ensure  |                                   |
| that the heat exchangers are      |                                   |
| capable of meeting their design   |                                   |
| requirements.                     |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** None  |                                   |
| of the established PIs cover this |                                   |
| area.                             |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| April 2000 ‑ The inspection scope |                                   |
| and basis were revised to address |                                   |
| the following: (1) The procedure  |                                   |
| not only addresses heat sinks but |                                   |
| also heat exchangers and the      |                                   |
| different bases for measuring     |                                   |
| their respective performances;    |                                   |
| (2) Heat exchanger heat transfer  |                                   |
| capabilities can be measured not  |                                   |
| only by observing performance     |                                   |
| tests, but by reviewing those     |                                   |
| same tests, inspection/cleaning,  |                                   |
| or by monitoring licensee=s       |                                   |
| bio‑fouling controls; (3) Methods |                                   |
| of measuring the performance of   |                                   |
| heat sinks and their              |                                   |
| subcomponents like piping,        |                                   |
| valves, and pumps within the      |                                   |
| cooling medium servicing the      |                                   |
| ultimate heat sink were included  |                                   |
| in the procedure; and (4) Methods |                                   |
| of measuring the performance of   |                                   |
| heat exchangers based on their    |                                   |
| design basis and design data      |                                   |
| sheets were included in procedure |                                   |
| for all risk significant heat     |                                   |
| exchangers including those in     |                                   |
| closed‑cooling systems.           |                                   |
+-----------------------------------+-----------------------------------+

Figure 7 IP 71111.07 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Inservice   |                                   |
| Inspection Activities             |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Initiating    | **Inspection Procedure:** IP      |
| Events and Barrier Integrity      | 71111.08                          |
+-----------------------------------+-----------------------------------+
| **Scope:** Inspection activities  |                                   |
| in the area would focus on the    |                                   |
| effectiveness of the licensee=s   |                                   |
| program for inservice inspection  |                                   |
| (ISI), repair, replacement of     |                                   |
| reactor coolant system (RCS)      |                                   |
| pressure retaining components,    |                                   |
| and monitoring of licensee=s      |                                   |
| program for verifying the         |                                   |
| integrity of steam generator (SG) |                                   |
| tubes. Inspection activities      |                                   |
| would include a review of the     |                                   |
| results of the SG tube            |                                   |
| inspections for insitu pressure   |                                   |
| testing, identification of new    |                                   |
| degradation mechanisms for SG     |                                   |
| tubes, confirmation that the      |                                   |
| licensee has taken appropriate    |                                   |
| actions for SG tube leakage,      |                                   |
| repairs, and any foreign material |                                   |
| identified in them, selected      |                                   |
| review of risk significant        |                                   |
| non‑code repairs, and a review or |                                   |
| observation of the reactor vessel |                                   |
| ISI examinations.                 |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** Inspection activities  |                                   |
| in this area primarily support    |                                   |
| the Barrier Integrity             |                                   |
| cornerstone. Activities also      |                                   |
| support the Initiating Events     |                                   |
| cornerstone because ISI           |                                   |
| activities can detect precursors  |                                   |
| to RCS boundary failures.         |                                   |
|                                   |                                   |
| The inspection activities are     |                                   |
| intended to ensure that the       |                                   |
| licensee has an effective program |                                   |
| for monitoring degradation of     |                                   |
| reactor coolant system boundary,  |                                   |
| including steam generator tubes,  |                                   |
| control of non‑code repairs to    |                                   |
| ASME components, and performing   |                                   |
| the required periodic ISI         |                                   |
| examinations.                     |                                   |
|                                   |                                   |
| Degradation of the RCS, SG tubes, |                                   |
| or safety related support systems |                                   |
| would result in a significant     |                                   |
| increase in risk. Degraded piping |                                   |
| or tubes would increase the risk  |                                   |
| impact due to initiation of       |                                   |
| events. In addition, it would     |                                   |
| result in mitigating systems not  |                                   |
| being capable of performing their |                                   |
| intended design functions. Based  |                                   |
| on these considerations,          |                                   |
| inspection activities are         |                                   |
| necessary to ensure that the      |                                   |
| licensee has an effective ISI     |                                   |
| program to ensure that risk       |                                   |
| significant degradation of the    |                                   |
| RCS boundary is identified and is |                                   |
| promptly and appropriately        |                                   |
| corrected.                        |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** There |                                   |
| are no performance indicators     |                                   |
| that have been established that   |                                   |
| can provide results related to    |                                   |
| the adequacy of the licensee=s    |                                   |
| program for ensuring system       |                                   |
| integrity in accordance with ASME |                                   |
| requirements.                     |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| October 2001 ‑ The procedure was  |                                   |
| revised to emphasize the          |                                   |
| inspector review of the           |                                   |
| licensee=s total program for      |                                   |
| ensuring the integrity of SG      |                                   |
| tubes so as to provide clear      |                                   |
| indication of impending problems  |                                   |
| before they could actually        |                                   |
| develop. The inspector no longer  |                                   |
| verifies the results of eddy      |                                   |
| current testing just to ensure    |                                   |
| that scope and expansion criteria |                                   |
| meet technical specifications.    |                                   |
| Significant aspects of insitu     |                                   |
| pressure testing are reviewed     |                                   |
| along with whether licensee has   |                                   |
| identified new degradation        |                                   |
| mechanisms for SG tubes. The      |                                   |
| inspector also confirms that the  |                                   |
| licensee has appropriately        |                                   |
| addressed repairs, leakage, and   |                                   |
| foreign material, and refers any  |                                   |
| serious questions on eddy current |                                   |
| testing to NRC staff with the     |                                   |
| requisite experience.             |                                   |
|                                   |                                   |
| January 2004 - The procedure has  |                                   |
| been revised to add periodic      |                                   |
| inspection requirements and       |                                   |
| guidance for PWR vessel head      |                                   |
| penetrations and boric acid       |                                   |
| corrosion control, and to make    |                                   |
| other minor clarifications. In    |                                   |
| addition, the resource estimate   |                                   |
| for PWR inspection has been       |                                   |
| increased.                        |                                   |
+-----------------------------------+-----------------------------------+

Figure 8 IP 71111.08 Basis Summary Sheet

  -----------------------------------------------------------------------
  **Basis Summary Sheet**             
  ----------------------------------- -----------------------------------
  **Inspectable Area:** Reserved      

  **Cornerstone(s):**                 **Inspection Procedure:** IP
                                      71111.09

  **Scope:**                          

  **Basis:**                          

  **Performance Indicators:**         

  **Significant Changes in Scope or   
  Basis:**                            
  -----------------------------------------------------------------------

Figure 9 IP 71111.09 Basis Summary Sheet

  -----------------------------------------------------------------------
  **Basis Summary Sheet**             
  ----------------------------------- -----------------------------------
  **Inspectable Area:** Reserved      

  **Cornerstone(s):**                 **Inspection Procedure:** IP
                                      71111.10

  **Scope:**                          

  **Basis:**                          

  **Performance Indicators:**         

  **Significant Changes in Scope or   
  Basis:**                            
  -----------------------------------------------------------------------

Figure 10 IP 71111.10 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Licensed    |                                   |
| Operator Requalification Program  |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Mitigating    | **Inspection Procedure:** IP      |
| Systems, Barrier Integrity, and   | 71111.11                          |
| Emergency Preparedness            |                                   |
+-----------------------------------+-----------------------------------+
| **Scope:** Inspection activities  |                                   |
| in this area would focus on the   |                                   |
| effectiveness of the licensee=s   |                                   |
| program for conducting operator   |                                   |
| requalification training.         |                                   |
| Inspection activities would       |                                   |
| include a review of               |                                   |
| requalification examinations, the |                                   |
| remedial training program, the    |                                   |
| training feedback system, and     |                                   |
| programs for ensuring medical     |                                   |
| fitness of licensed operators. In |                                   |
| addition, inspection activities   |                                   |
| also verify that the facility=s   |                                   |
| operating history has been        |                                   |
| factored into the requalification |                                   |
| program and verifies conformance  |                                   |
| with operator license conditions. |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** Inspection of this     |                                   |
| area supports the Mitigating      |                                   |
| Systems, Barrier Integrity and    |                                   |
| Emergency Preparedness            |                                   |
| cornerstones because it can       |                                   |
| assess operator performance       |                                   |
| adequacy in responding to events. |                                   |
|                                   |                                   |
| This inspection evaluates         |                                   |
| operator performance in           |                                   |
| mitigating the consequences of    |                                   |
| events. Poor operator performance |                                   |
| results in increased risk due to  |                                   |
| its impact on the human factors   |                                   |
| terms, assumed operator recovery  |                                   |
| rates and personnel induced       |                                   |
| common cause error rates assumed  |                                   |
| in the facility Individual Plant  |                                   |
| Evaluations (IPE). Human          |                                   |
| performance errors and failure to |                                   |
| recover from accident events are  |                                   |
| the most risk important events at |                                   |
| a facility.                       |                                   |
|                                   |                                   |
| The inspection interval was       |                                   |
| established at a biennial         |                                   |
| frequency to allow for more       |                                   |
| comprehensive inspections of      |                                   |
| licensee requalification program  |                                   |
| cycles that approached 24 months  |                                   |
| in duration.                      |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** There |                                   |
| are no performance indicators     |                                   |
| that have been established that   |                                   |
| can provide results related to    |                                   |
| the adequacy of the licensee=s    |                                   |
| licensed operator requalification |                                   |
| program.                          |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| March 2001 ‑ Added additional     |                                   |
| guidance to allow the conduct of  |                                   |
| this inspection in separate parts |                                   |
| during the biennial inspection    |                                   |
| cycle. This was done to provide   |                                   |
| additional scheduling flexibility |                                   |
| to allow the regions to observe   |                                   |
| portions of the licensed operator |                                   |
| requalification program that      |                                   |
| occur at different times, such as |                                   |
| the annual written exams.         |                                   |
|                                   |                                   |
| August 2002 - Revised to reflect  |                                   |
| the amended 10 CFR Part 55,       |                                   |
| \"Operators\' Licenses,\"         |                                   |
| regarding operator license        |                                   |
| eligibility and the use of        |                                   |
| simulation facilities in operator |                                   |
| licensing (66 FRN 52657, dated    |                                   |
| October 17, 2001). This revision  |                                   |
| provides specific guidance to     |                                   |
| inspector when assessing          |                                   |
| conformance with simulator        |                                   |
| requirements specified in 10 CFR  |                                   |
| 55.46.                            |                                   |
|                                   |                                   |
| December 2003 - Revised to        |                                   |
| include an additional section     |                                   |
| that inspects excessive test item |                                   |
| repetition among comprehensive    |                                   |
| requalification exams that are    |                                   |
| taken by crews undergoing the     |                                   |
| same training program cycle.      |                                   |
|                                   |                                   |
| Excessive item repetition         |                                   |
| adversely affects validity of the |                                   |
| exam.                             |                                   |
+-----------------------------------+-----------------------------------+

Figure 11 IP 71111.11 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Maintenance |                                   |
| Effectiveness                     |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Initiating    | **Inspection Procedure:** IP      |
| Events, Mitigating Systems, and   | 71111.12                          |
| Barrier Integrity                 |                                   |
+-----------------------------------+-----------------------------------+
| **Scope:** To independently       |                                   |
| verify the licensee=s appropriate |                                   |
| handling of structures, systems,  |                                   |
| or components (SSCs) performance  |                                   |
| or condition problems in terms    |                                   |
| of:                               |                                   |
|                                   |                                   |
| ‑ Appropriate work practices;     |                                   |
|                                   |                                   |
| ‑ Identifying common‑cause        |                                   |
| failures;                         |                                   |
|                                   |                                   |
| ‑ Scoping in accordance with 10   |                                   |
| CFR 50.65(b);                     |                                   |
|                                   |                                   |
| ‑ Characterizing reliability      |                                   |
| issues (performance);             |                                   |
|                                   |                                   |
| ‑ Charging unavailability         |                                   |
| (performance);                    |                                   |
|                                   |                                   |
| ‑ Trending key parameters         |                                   |
| (condition monitoring)            |                                   |
|                                   |                                   |
| ‑ 10 CFR 50.65 (a)(1) or (a)(2)   |                                   |
| classification and                |                                   |
| reclassification;                 |                                   |
|                                   |                                   |
| ‑ Appropriateness of performance  |                                   |
| criteria for SSCs/functions       |                                   |
| classified (a)(2) or              |                                   |
|                                   |                                   |
| appropriateness of goals and      |                                   |
| corrective actions for            |                                   |
| SSCs/functions classified (a)(1)  |                                   |
|                                   |                                   |
| The scope of the inspection       |                                   |
| activities would include          |                                   |
| performance issues associated     |                                   |
| with risk significant SSCs        |                                   |
| covered under the maintenance     |                                   |
| rule. This inspection will also   |                                   |
| assess the effectiveness of the   |                                   |
| licensee=s periodic evaluation    |                                   |
| and resulting adjustments among   |                                   |
| those performed pursuant to 10    |                                   |
| CFR 50.65(a)(3) every two years.  |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** Inspection of this     |                                   |
| item supports the Initiating      |                                   |
| Events, Mitigating Systems and    |                                   |
| Barrier Integrity cornerstones.   |                                   |
| Reliability and availability of   |                                   |
| maintenance rule (MR) SSCs as     |                                   |
| monitored or demonstrated under   |                                   |
| the MR directly affect those      |                                   |
| reactor safety cornerstones and   |                                   |
| are dependent upon maintenance    |                                   |
| effectiveness (including work     |                                   |
| practices and common‑cause        |                                   |
| problems).                        |                                   |
|                                   |                                   |
| Proper monitoring and             |                                   |
| implementation of the MR          |                                   |
| attributes should ensure that     |                                   |
| there is a proper balance that    |                                   |
| optimizes availability and        |                                   |
| reliability when removing         |                                   |
| equipment from service for        |                                   |
| preventive maintenance. High      |                                   |
| availability and reliability      |                                   |
| result in a high probability that |                                   |
| accident mitigation systems will  |                                   |
| perform successfully when needed  |                                   |
| and that Barrier Integrity will   |                                   |
| remain effective in preventing    |                                   |
| the release of radioactivity.     |                                   |
| Proper work practices, corrective |                                   |
| actions, and reducing potential   |                                   |
| common cause failures will also   |                                   |
| ensure that the SSCs are capable  |                                   |
| of fulfilling their intended      |                                   |
| safety functions.                 |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** This  |                                   |
| inspection area supplements the   |                                   |
| scram, transient, safety system   |                                   |
| unavailability, and safety system |                                   |
| functional failure performance    |                                   |
| indicators. While these           |                                   |
| indicators provide some insights  |                                   |
| of equipment performance in a     |                                   |
| limited number of safety systems, |                                   |
| they do not provide adequate      |                                   |
| information to monitor the        |                                   |
| equipment performance of systems  |                                   |
| covered under the scope of the    |                                   |
| maintenance rule. In addition,    |                                   |
| inspection activities in this     |                                   |
| area would provide an assessment  |                                   |
| of equipment reliability where a  |                                   |
| performance indicator does not    |                                   |
| exist.                            |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| December 2001 ‑ This IP was       |                                   |
| revised extensively to focus the  |                                   |
| inspection activities on          |                                   |
| reviewing maintenance             |                                   |
| effectiveness issues associated   |                                   |
| with availability, reliability,   |                                   |
| common cause failures, and work   |                                   |
| practices of risk significant     |                                   |
| SSCs.                             |                                   |
|                                   |                                   |
| July 2002 - Revised to clarify    |                                   |
| inspection objectives and to      |                                   |
| improve effectiveness of this     |                                   |
| procedure based on feedback and   |                                   |
| lessons learned from              |                                   |
| implementation. This revision     |                                   |
| provides greater focus on         |                                   |
| reviewing licensee\'s             |                                   |
| effectiveness at performing       |                                   |
| routine maintenance. The revised  |                                   |
| procedure also focuses on review  |                                   |
| of equipment performance issues   |                                   |
| associated with availability and  |                                   |
| reliability, preferably on        |                                   |
| high-risk significant systems,    |                                   |
| maintenance work practices, and   |                                   |
| common cause issues. Sample size  |                                   |
| and inspection resource           |                                   |
| requirements were revised based   |                                   |
| on experience gained from four    |                                   |
| verification and validation       |                                   |
| visits at one site in each        |                                   |
| region.                           |                                   |
+-----------------------------------+-----------------------------------+

Figure 12 IP 71111.12 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Maintenance |                                   |
| Rule Risk Assessments and         |                                   |
| Emergent Work Control             |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Initiating    | **Inspection Procedure:** IP      |
| Events, Mitigating Systems and    | 71111.13                          |
| Barrier Integrity                 |                                   |
+-----------------------------------+-----------------------------------+
| **Scope:** Inspection activities  |                                   |
| in this area would focus on the   |                                   |
| effectiveness of the licensee=s   |                                   |
| configuration controls during     |                                   |
| shutdown and power operations.    |                                   |
| Paragraph (a)(4) of 10 CFR 50.65, |                                   |
| the Maintenance Rule (MR),        |                                   |
| requires licensees to assess and  |                                   |
| manage plant risk related to      |                                   |
| maintenance activities during all |                                   |
| modes of plant operation. The     |                                   |
| inspector would verify that       |                                   |
| before performing maintenance     |                                   |
| activities (including but not     |                                   |
| limited to surveillances,         |                                   |
| post‑maintenance testing, and     |                                   |
| corrective and preventive         |                                   |
| maintenance), the licensees       |                                   |
| assess and manage the increase in |                                   |
| risk that may result from         |                                   |
| configuration change related to   |                                   |
| the proposed maintenance          |                                   |
| activities. The inspectors also   |                                   |
| verify that the licensees         |                                   |
| effectively plan and control      |                                   |
| emergent work activities to       |                                   |
| minimize the probability of       |                                   |
| initiating events, maintain the   |                                   |
| functional capability of          |                                   |
| mitigating systems and maintain   |                                   |
| barrier integrity.                |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** This inspection item   |                                   |
| supports the Mitigating Systems,  |                                   |
| Initiating Events and Barrier     |                                   |
| Integrity cornerstones.           |                                   |
|                                   |                                   |
| Maintenance is the primary means  |                                   |
| of mitigating and managing the    |                                   |
| effects of component degradation  |                                   |
| and failures. Operating           |                                   |
| experience shows that the lack of |                                   |
| maintenance (component            |                                   |
| deficiencies not corrected) or    |                                   |
| improperly performed maintenance  |                                   |
| (maintenance activities not well  |                                   |
| controlled) can greatly           |                                   |
| contribute to the risk for event  |                                   |
| initiation, and may cause SSCs to |                                   |
| not function properly if called   |                                   |
| upon to mitigate the consequence  |                                   |
| of an event. Operating experience |                                   |
| also shows that for risk          |                                   |
| significant events identified     |                                   |
| through the Accident Sequence     |                                   |
| Precursor (ASP) program, work     |                                   |
| control and failure to maintain   |                                   |
| equipment represent the majority  |                                   |
| of causes. Loss of configuration  |                                   |
| control of risk‑significant       |                                   |
| safety equipment can initiate a   |                                   |
| reactor transient and             |                                   |
| simultaneously compromise         |                                   |
| mitigation capability. During     |                                   |
| shutdowns, when equipment is out  |                                   |
| of service for maintenance or     |                                   |
| testing or when off‑normal        |                                   |
| lineups or infrequent tests and   |                                   |
| evolutions are being conducted,   |                                   |
| configuration control problems    |                                   |
| are more likely to result in      |                                   |
| initiating events or loss of      |                                   |
| barrier integrity.                |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** The   |                                   |
| safety system unavailability      |                                   |
| performance indicators provide    |                                   |
| only some information on the      |                                   |
| adequacy of configuration control |                                   |
| of selected systems. Inspections  |                                   |
| will monitor plant configuration  |                                   |
| changes to ensure that the risk   |                                   |
| is assessed and managed properly  |                                   |
| to minimize the probability of    |                                   |
| initiating events, maintain the   |                                   |
| functional capability of          |                                   |
| mitigating systems and maintain   |                                   |
| barrier integrity. This           |                                   |
| inspection supplements the PI.    |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| April 2000 ‑ The emergent work    |                                   |
| inspection requirements and       |                                   |
| guidance were added to the        |                                   |
| procedure since this IP covered   |                                   |
| inspection of configuration       |                                   |
| control issues.                   |                                   |
|                                   |                                   |
| November 2000‑ Revised to clarify |                                   |
| inspection objectives and         |                                   |
| requirements and to provide       |                                   |
| detailed guidance to support the  |                                   |
| 10 CFR 50.65(a)(4) rule change.   |                                   |
|                                   |                                   |
| January 2002 - Revised to provide |                                   |
| bands for inspection resource     |                                   |
| estimates and sample sizes and    |                                   |
| guidance for inspection procedure |                                   |
| status.                           |                                   |
+-----------------------------------+-----------------------------------+

Figure 13 IP 71111.13 Basis Summary Sheet (continued)

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Personnel   |                                   |
| Performance During Nonroutine     |                                   |
| Plant Evolutions                  |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Initiating    | **Inspection Procedure:** IP      |
| Events, Mitigating Systems, and   | 71111.14                          |
| Barrier Integrity                 |                                   |
+-----------------------------------+-----------------------------------+
| **Scope:** The inspection         |                                   |
| activities will be used to        |                                   |
| evaluate operator and equipment   |                                   |
| performance for other than normal |                                   |
| and routine operations. This      |                                   |
| inspection activity will provide  |                                   |
| a vital tie between operator      |                                   |
| performance observed under        |                                   |
| simulated conditions and those    |                                   |
| observed during non‑routine plant |                                   |
| operations. This activity will    |                                   |
| also provide a snapshot of plant  |                                   |
| and equipment performance during  |                                   |
| transient conditions.             |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** This inspection        |                                   |
| primarily supports the Mitigating |                                   |
| Systems and Barrier Integrity     |                                   |
| cornerstones by providing         |                                   |
| assessment of operator            |                                   |
| performance during transient and  |                                   |
| off‑normal operations. Poor       |                                   |
| operator performance could also   |                                   |
| affect the Initiating Events      |                                   |
| cornerstone. In addition to       |                                   |
| providing observations of         |                                   |
| non‑routine plant operations,     |                                   |
| inspections in this area provide  |                                   |
| increased opportunities to        |                                   |
| observe more significant plant    |                                   |
| transients and to evaluate        |                                   |
| operator and equipment            |                                   |
| performance during those          |                                   |
| non‑simulated transient           |                                   |
| conditions.                       |                                   |
|                                   |                                   |
| Operator performance provides a   |                                   |
| vital link in mitigating the      |                                   |
| consequences of improper or       |                                   |
| unforseen equipment performance.  |                                   |
| Degrading operator performance    |                                   |
| results in increased risk due to  |                                   |
| its impact on human factors       |                                   |
| terms, assumed operator recovery  |                                   |
| rates, and personnel induced      |                                   |
| common cause errors.              |                                   |
| Probabilistic risk assessments    |                                   |
| have shown that human errors can  |                                   |
| be very significant contributors  |                                   |
| to risk, in particular during     |                                   |
| recovery from accident events.    |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:**       |                                   |
| Operator performance under        |                                   |
| abnormal plant operating          |                                   |
| conditions cannot be sufficiently |                                   |
| covered by a performance          |                                   |
| indicator because the PIs of      |                                   |
| transients and trips do not       |                                   |
| include near‑miss events.         |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| None                              |                                   |
+-----------------------------------+-----------------------------------+

Figure 14 IP 71111.14 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Operability |                                   |
| Evaluations                       |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Mitigating    | **Inspection Procedure:** IP      |
| Systems and Barrier Integrity     | 71111.15                          |
+-----------------------------------+-----------------------------------+
| **Scope:** Inspection activities  |                                   |
| in this area would focus on the   |                                   |
| evaluation of degraded and        |                                   |
| non‑conforming conditions         |                                   |
| affecting plant systems,          |                                   |
| structures and components (SSCs). |                                   |
| Inspection activities would be    |                                   |
| limited to a review of those      |                                   |
| potentially risk significant      |                                   |
| degraded and non‑conforming       |                                   |
| conditions affecting SSCs that    |                                   |
| are considered to be operable and |                                   |
| fully capable of performing their |                                   |
| design functions based on written |                                   |
| operability evaluations. Initial  |                                   |
| reviews of the operability        |                                   |
| evaluations should be performed   |                                   |
| following formal completion of    |                                   |
| the evaluations by the licensee.  |                                   |
| The inspection would ensure that  |                                   |
| the evaluations include an        |                                   |
| adequate technical justification  |                                   |
| to support the operability        |                                   |
| evaluation and would verify the   |                                   |
| implementation of any             |                                   |
| compensatory measures.            |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** Inspection of this     |                                   |
| item supports the Mitigating      |                                   |
| Systems and Barrier Integrity     |                                   |
| cornerstones by ensuring          |                                   |
| risk‑significant SSCs are fully   |                                   |
| functional to perform their       |                                   |
| design function. Improperly       |                                   |
| evaluated degraded and/or         |                                   |
| non‑conforming conditions may     |                                   |
| result in continued operation     |                                   |
| with an SSC that is not capable   |                                   |
| of performing its design          |                                   |
| function.                         |                                   |
|                                   |                                   |
| The inspection activities are     |                                   |
| intended to verify that the       |                                   |
| licensee has taken the necessary  |                                   |
| steps to demonstrate that the     |                                   |
| reliability, availability and     |                                   |
| functional capability of the SSCs |                                   |
| and associated components are     |                                   |
| maintained although the SSCs are  |                                   |
| degraded and/or non‑conforming in |                                   |
| some way.                         |                                   |
|                                   |                                   |
| As a result of the size and       |                                   |
| complexity of a nuclear power     |                                   |
| plant, degraded and               |                                   |
| non‑conforming conditions are     |                                   |
| frequently identified at all      |                                   |
| plants. Risk‑significant SSCs are |                                   |
| often affected and the degraded   |                                   |
| or non‑conforming condition       |                                   |
| cannot always be corrected        |                                   |
| immediately. An improperly        |                                   |
| evaluated degraded and/or         |                                   |
| non‑conforming condition may      |                                   |
| result in continued operation     |                                   |
| with a SSC that is not capable of |                                   |
| performing its design function    |                                   |
| which would result in operation   |                                   |
| of the plant outside of its       |                                   |
| design and license bases. The     |                                   |
| potential effects on safe         |                                   |
| operation could include the loss  |                                   |
| of redundancy within a safety     |                                   |
| system, the loss of safety        |                                   |
| function or a reduction in the    |                                   |
| safety margin assumed in the      |                                   |
| plant design and analyses.        |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** There |                                   |
| are no performance indicators     |                                   |
| that provide effective assessment |                                   |
| of the quality of operability     |                                   |
| evaluations.                      |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope    |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| January 2002 - Revised to provide |                                   |
| minor clarifications to           |                                   |
| inspection requirements and       |                                   |
| additional inspection guidance    |                                   |
| concerning operability            |                                   |
| evaluations. In addition,         |                                   |
| inspection resource estimates and |                                   |
| inspection level of effort are    |                                   |
| revised to provide a band for     |                                   |
| more inspection flexibility.      |                                   |
|                                   |                                   |
| February 2004 - Revised to        |                                   |
| include deferred modifications to |                                   |
| the inspection sampling list.     |                                   |
+-----------------------------------+-----------------------------------+

Figure 15 IP 71111.15 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Operator    |                                   |
| Workarounds                       |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Mitigating    | **Inspection Procedure:** IP      |
| Systems                           | 71111.16                          |
+-----------------------------------+-----------------------------------+
| **Scope:** Inspection activities  |                                   |
| in this area would focus on plant |                                   |
| and control room deficiencies     |                                   |
| that have the potential to affect |                                   |
| performance in conducting routine |                                   |
| and non‑routine evolutions.       |                                   |
| Detailed inspection activities    |                                   |
| would be limited to those risk    |                                   |
| significant deficiencies that     |                                   |
| could compromise equipment and    |                                   |
| personnel mitigation strategies.  |                                   |
| A review of all deficiencies in a |                                   |
| mitigating system would also be   |                                   |
| conducted to determine if their   |                                   |
| synergistic affects were risk     |                                   |
| significant. The inspection would |                                   |
| focus on those deficiencies that  |                                   |
| are not included in the temporary |                                   |
| modification process and would    |                                   |
| require operator actions that are |                                   |
| in addition to those assumed in   |                                   |
| the initial design.               |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** Operator workarounds   |                                   |
| can have an adverse effect on the |                                   |
| functional capability of a system |                                   |
| in that the system may not be     |                                   |
| capable of performing its design  |                                   |
| function without operator         |                                   |
| intervention. An excessive number |                                   |
| of operator workarounds or those  |                                   |
| requiring complex operator        |                                   |
| actions reduce the effectiveness  |                                   |
| of the operations staff in        |                                   |
| responding to transient           |                                   |
| conditions and will increase the  |                                   |
| chance of operator errors.        |                                   |
| Probabilistic risk analyses have  |                                   |
| identified human errors as        |                                   |
| significant contributors to risk. |                                   |
|                                   |                                   |
| This inspectable area verifies    |                                   |
| aspects of the Mitigating System  |                                   |
| Cornerstone for which there are   |                                   |
| no indicators to measure          |                                   |
| performance.                      |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** There |                                   |
| are no performance indicators     |                                   |
| that have been established that   |                                   |
| can provide results related to    |                                   |
| the adequacy of the licensee=s    |                                   |
| process for controlling operator  |                                   |
| workarounds. Performance          |                                   |
| indicators can not assess the     |                                   |
| significance of operator          |                                   |
| work‑around items.                |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| December 2001 ‑ The procedure has |                                   |
| been revised to highlight the     |                                   |
| difference between all operator   |                                   |
| workarounds and those that are    |                                   |
| deemed risk significant. The      |                                   |
| inspector will review a sample of |                                   |
| risk significant operator         |                                   |
| workarounds to determine if       |                                   |
| singularly any of them are risk   |                                   |
| significant, and he will also     |                                   |
| review all operator workarounds   |                                   |
| for a specific mitigating system  |                                   |
| so as to ascertain whether their  |                                   |
| synergistic aspects could produce |                                   |
| a risk significant concern.       |                                   |
+-----------------------------------+-----------------------------------+

Figure 16 IP 71111.16 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Permanent   |                                   |
| Plant Modifications               |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Mitigating    | **Inspection Procedure:** IP      |
| Systems and Barrier Integrity     | 71111.17                          |
+-----------------------------------+-----------------------------------+
| **Scope:** Inspection activities  |                                   |
| in this area include the review   |                                   |
| of design, installation,          |                                   |
| configuration control, and        |                                   |
| post‑modification testing for the |                                   |
| potentially risk significant      |                                   |
| permanent modifications of the    |                                   |
| systems, structures, and          |                                   |
| components (SSCs) covered by the  |                                   |
| maintenance rule. Inspection      |                                   |
| activities would also include an  |                                   |
| in‑depth review of changes to the |                                   |
| initial licensed design, design   |                                   |
| basis documents, test procedures  |                                   |
| and normal and emergency          |                                   |
| operating procedures.             |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** Inspection of          |                                   |
| permanent plant modifications     |                                   |
| provides monitoring of the        |                                   |
| licensee=s performance to ensure  |                                   |
| that the design bases for         |                                   |
| risk‑significant SSCs have been   |                                   |
| maintained and that the changes   |                                   |
| have not adversely affected the   |                                   |
| licensing and design bases and    |                                   |
| safety functions of the SSCs.     |                                   |
| Plant modifications may introduce |                                   |
| changes to the assumptions and    |                                   |
| models used in the plant specific |                                   |
| probabilistic risk assessment     |                                   |
| (PRA). Modifications to one       |                                   |
| system may affect the design      |                                   |
| bases and functioning of other    |                                   |
| interfacing systems. Also,        |                                   |
| similar modifications to several  |                                   |
| systems could introduce potential |                                   |
| for common cause failures that    |                                   |
| affect plant risk.                |                                   |
|                                   |                                   |
| Industry experience has shown     |                                   |
| that modifications to             |                                   |
| risk‑significant SSCs can         |                                   |
| adversely affect their            |                                   |
| availability, reliability or      |                                   |
| functional capability. The        |                                   |
| baseline Inspection of permanent  |                                   |
| modifications should focus on:    |                                   |
| (1) compliance with regulations,  |                                   |
| (2) consistency with              |                                   |
| defense‑in‑depth philosophy, (3)  |                                   |
| maintaining sufficient safety     |                                   |
| margins, and (4) acceptability of |                                   |
| the effects on risk.              |                                   |
|                                   |                                   |
| Verification of post‑modification |                                   |
| testing to confirm that the       |                                   |
| objectives of the modification    |                                   |
| are met and verification that the |                                   |
| system is restored to the         |                                   |
| required configuration after      |                                   |
| completion of the modification    |                                   |
| are important. Design             |                                   |
| requirements that cannot be       |                                   |
| verified by testing of the        |                                   |
| modification, such as seismic or  |                                   |
| environmental qualifications      |                                   |
| should also be reviewed.          |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** No    |                                   |
| performance indicators have been  |                                   |
| established that can provide      |                                   |
| results related to the adequacy   |                                   |
| of permanent modifications.       |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| September 2000 - Revised to       |                                   |
| reduce the number of samples      |                                   |
| selected to 5 to 10               |                                   |
| modifications. Requirements were  |                                   |
| added to verify that new SSCs     |                                   |
| added to the plant have been      |                                   |
| reviewed for maintenance rule and |                                   |
| scope and for impact on the plant |                                   |
| specific SDP workarounds.         |                                   |
|                                   |                                   |
| January 2002 - Revised to include |                                   |
| a pre-inspection visit and more   |                                   |
| accurately identify sample size.  |                                   |
| In addition, inspection resource  |                                   |
| estimates and inspection level of |                                   |
| effort are revised to provide a   |                                   |
| band for more inspection          |                                   |
| flexibility.                      |                                   |
+-----------------------------------+-----------------------------------+

Figure 17 IP 71111.17 Basis Summary Sheet

  -----------------------------------------------------------------------
  **Basis Summary Sheet**             
  ----------------------------------- -----------------------------------
  **Inspectable Area:** Reserved      

  **Cornerstone(s):**                 **Inspection Procedure:** IP
                                      71111.18

  **Scope:** .                        

  **Basis:**                          

  **Performance Indicators:**         

  **Significant Changes in Scope or   
  Basis:**                            
  -----------------------------------------------------------------------

Figure 18 IP 71111.18 Basis Summary Sheet

+----------------------------------+-----------------------------------+
| **Basis Summary Sheet**          |                                   |
+==================================+===================================+
| **Inspectable Area:**            |                                   |
| Post‑Maintenance Testing         |                                   |
+----------------------------------+-----------------------------------+
| **Cornerstone(s):** Mitigating   | **Inspection Procedure:** IP      |
| Systems and Barrier Integrity    | 71111.19                          |
+----------------------------------+-----------------------------------+
| **Scope:** Inspection activities |                                   |
| would focus on verification that |                                   |
| the post maintenance test        |                                   |
| procedures and test activities   |                                   |
| were adequate to verify system   |                                   |
| operability and functional       |                                   |
| capability for the maintenance   |                                   |
| that was performed. The          |                                   |
| inspection would focus on        |                                   |
| significant maintenance          |                                   |
| involving high risk significant  |                                   |
| systems or components, in areas  |                                   |
| that have the potential to cause |                                   |
| common mode/cause failures,      |                                   |
| where repetitive failures        |                                   |
| indicate programmatic problems,  |                                   |
| or on maintenance activities     |                                   |
| that have the potential to       |                                   |
| significantly impact risk.       |                                   |
+----------------------------------+-----------------------------------+
| **Basis:** Inspection of this    |                                   |
| item supports the Mitigating     |                                   |
| Systems and Barrier Integrity    |                                   |
| cornerstones.                    |                                   |
|                                  |                                   |
| Post maintenance testing         |                                   |
| provides the final check that a  |                                   |
| system and /or component has     |                                   |
| been returned to its required    |                                   |
| design configuration and will    |                                   |
| perform its design function(s)   |                                   |
| following completion of          |                                   |
| maintenance activities.          |                                   |
| Inadequate maintenance           |                                   |
| activities that are not detected |                                   |
| prior to returning the equipment |                                   |
| to service can result in a       |                                   |
| significant increase in          |                                   |
| unidentified risk for the        |                                   |
| subject system and in common     |                                   |
| mode/cause failures and          |                                   |
| potential for loss of function   |                                   |
| on redundant trains and          |                                   |
| identical components in other    |                                   |
| systems.                         |                                   |
+----------------------------------+-----------------------------------+
| **Performance Indicators:** This |                                   |
| inspection activity will         |                                   |
| supplement PIs (scram,           |                                   |
| transient, and safety system     |                                   |
| unavailability and safety system |                                   |
| functional failure). These PIs   |                                   |
| do not directly measure the      |                                   |
| adequacy of the post‑maintenance |                                   |
| test procedures but indirectly   |                                   |
| confirm the quality of           |                                   |
| maintenance and test procedures. |                                   |
+----------------------------------+-----------------------------------+
|                                  |                                   |
+----------------------------------+-----------------------------------+

Figure 19 IP 71111.19 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Refueling   |                                   |
| and Other Outage Activities       |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Initiating    | **Inspection Procedure:** IP      |
| Events, Mitigating Systems, and   | 71111.20                          |
| Barrier Integrity                 |                                   |
+-----------------------------------+-----------------------------------+
| **Scope:** Inspections focus on   |                                   |
| the licensee=s shutdown risk      |                                   |
| management program and outage     |                                   |
| related activities having the     |                                   |
| potential to impact plant risk.   |                                   |
| Areas include clearance           |                                   |
| activities, reactor coolant       |                                   |
| system instrumentation,           |                                   |
| electrical power, decay heat      |                                   |
| removal monitoring, spent fuel    |                                   |
| pool cooling system operation,    |                                   |
| inventory control, reactivity     |                                   |
| control, containment closure,     |                                   |
| reduced inventory/mid‑loop        |                                   |
| operations, refueling activities, |                                   |
| and heatup/startup activities.    |                                   |
| The inspection also focuses on    |                                   |
| inspection of SSCs in             |                                   |
| containment. The inspection       |                                   |
| applies to planned outages (such  |                                   |
| as refueling outages) as well as  |                                   |
| forced outages.                   |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** Shutdown risk can be   |                                   |
| high for deficiencies that occur  |                                   |
| when vital SSCs are not           |                                   |
| available, such as during the     |                                   |
| fuel handling period of a         |                                   |
| refueling outage and off‑normal   |                                   |
| plant configurations in other     |                                   |
| outage periods. Times of reduced  |                                   |
| inventory are the most critical.  |                                   |
| During outages, barriers to       |                                   |
| prevent radiological releases may |                                   |
| be degraded. Inspection           |                                   |
| activities assess licensee steps  |                                   |
| to preclude events, maintain      |                                   |
| defense in depth, and ensure      |                                   |
| appropriate SSCs are available.   |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** There |                                   |
| are no performance indicators for |                                   |
| licensee performance during       |                                   |
| refueling and other outages.      |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| January 2002 - Revised to         |                                   |
| integrate with IMC 0609, Appendix |                                   |
| G, \"Shutdown Operations          |                                   |
| Significance Determination        |                                   |
| Process,\" regarding risk         |                                   |
| insights and how to evaluate      |                                   |
| inspection findings. It also      |                                   |
| addresses refueling controls,     |                                   |
| improper sequencing of control    |                                   |
| rods or fuel assemblies,          |                                   |
| reactivity control, and methods   |                                   |
| to                                |                                   |
|                                   |                                   |
| ensure fuel assembles are loaded  |                                   |
| in correct positions.             |                                   |
|                                   |                                   |
| November 2003 - Revised to        |                                   |
| address licensee procedures for   |                                   |
| foreign material exclusion,       |                                   |
| instruments tracking plant        |                                   |
| condition changes, training       |                                   |
| procedures for BWR alternate      |                                   |
| decay heat removal. It also cross |                                   |
| references IMC                    |                                   |
|                                   |                                   |
| 2515, Appendix D, \"Plant         |                                   |
| Status\" regarding plant status   |                                   |
| tours of areas accessible only    |                                   |
|                                   |                                   |
| May 2004 - revised to add         |                                   |
| guidance for containment          |                                   |
| inspections, when possible, and   |                                   |
| to add a completion status        |                                   |
| section.                          |                                   |
+-----------------------------------+-----------------------------------+

Figure 20 IP 71111.20 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Safety      |                                   |
| System Design and Performance     |                                   |
| Capability                        |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Mitigating    | **Inspection Procedure:** IP      |
| Systems                           | 71111.21                          |
+-----------------------------------+-----------------------------------+
| **Scope:** Inspection includes    |                                   |
| review of design bases, updated   |                                   |
| final safety analysis report      |                                   |
| (UFSAR), supporting calculations, |                                   |
| as‑built conditions,              |                                   |
| modifications, testing, and       |                                   |
| normal and emergency operations   |                                   |
| of risk‑significant systems and   |                                   |
| interfaces with support systems.  |                                   |
| This would be an in‑depth review  |                                   |
| of a selected risk significant    |                                   |
| system and support systems with   |                                   |
| an emphasis on changes to the     |                                   |
| design bases and normal and       |                                   |
| emergency plant procedures. The   |                                   |
| selection of the system(s) should |                                   |
| be based on systems with high     |                                   |
| probabilistic risk analysis (PRA) |                                   |
| rankings; with design attributes  |                                   |
| not fully demonstrated through    |                                   |
| testing; with significant         |                                   |
| modifications, changes to design  |                                   |
| bases, and operating procedure    |                                   |
| changes; that have not received   |                                   |
| recent NRC review; which have     |                                   |
| multiple maintenance rule         |                                   |
| functions or which support        |                                   |
| multiple systems; which           |                                   |
| complement each other (e.g., for  |                                   |
| a PWR, AFW and pressurizer PORVs; |                                   |
| for a BWR, HPCI and ADS) like     |                                   |
| from a dominant accident sequence |                                   |
| since the systems would be        |                                   |
| complimentary in regard to one    |                                   |
| type of accident; and which are   |                                   |
| contained within the NRC          |                                   |
| risk‑informed notebook for a      |                                   |
| specific plant for a particular   |                                   |
| initiating event.                 |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** Inspection of safety   |                                   |
| system design and performance     |                                   |
| verifies the initial design and   |                                   |
| subsequent modifications and      |                                   |
| provides monitoring of the        |                                   |
| capability of the selected system |                                   |
| to perform its design basis       |                                   |
| functions. The inspection should  |                                   |
| focus on the design and           |                                   |
| functional capability of          |                                   |
| components that are not validated |                                   |
| by in‑plant testing. Also,        |                                   |
| seismic and environmental         |                                   |
| qualifications of the SSCs should |                                   |
| be verified. The PRA assumptions  |                                   |
| and models are based on the       |                                   |
| ability of the as‑built safety    |                                   |
| system to perform its intended    |                                   |
| safety function successfully. If  |                                   |
| the design bases of the system    |                                   |
| had not been correctly            |                                   |
| implemented in the installed      |                                   |
| system, the operation and test    |                                   |
| procedures, and the supporting    |                                   |
| analyses and calculations, the    |                                   |
| system cannot be relied upon to   |                                   |
| meet its design bases and         |                                   |
| performance requirements. The     |                                   |
| design interfaces with support    |                                   |
| systems, such as cooling systems, |                                   |
| ventilation systems, and          |                                   |
| instrument air system, should     |                                   |
| also be reviewed.                 |                                   |
|                                   |                                   |
| The baseline inspection should    |                                   |
| focus on: (1) maintaining design  |                                   |
| bases (2) consistency with        |                                   |
| defense‑in‑depth philosophy, and  |                                   |
| (3) maintaining sufficient safety |                                   |
| margins.                          |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** There |                                   |
| are no performance indicators     |                                   |
| that have been established that   |                                   |
| can provide results related to    |                                   |
| correct implementation of the     |                                   |
| design bases in the as‑built      |                                   |
| system and the associated plant   |                                   |
| documents.                        |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope    |                                   |
| and Basis:**                      |                                   |
|                                   |                                   |
| None                              |                                   |
+-----------------------------------+-----------------------------------+

Figure 21 IP 71111.21 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:**             |                                   |
| Surveillance Testing              |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Mitigating    | **Inspection Procedure:** IP      |
| Systems and Barrier Integrity     | 71111.22                          |
+-----------------------------------+-----------------------------------+
| **Scope:** This inspection will   |                                   |
| focus on verifying that           |                                   |
| surveillance testing (including   |                                   |
| inservice testing) of             |                                   |
| risk‑significant structures,      |                                   |
| systems, and components (SSCs)    |                                   |
| are capable of performing their   |                                   |
| intended safety functions and     |                                   |
| assessing their operational       |                                   |
| readiness. The inspector will     |                                   |
| review surveillance test results  |                                   |
| for adequacy in meeting the       |                                   |
| requirements, observe ongoing     |                                   |
| testing to evaluate human         |                                   |
| performance, and ensure that      |                                   |
| appropriate test acceptance       |                                   |
| criteria is in agreement with     |                                   |
| design requirements.              |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** Inspection of this     |                                   |
| area ensures that safety systems  |                                   |
| are capable of performing their   |                                   |
| safety function and support the   |                                   |
| Mitigating Systems and Barrier    |                                   |
| Integrity Cornerstones. The       |                                   |
| failure to identify and resolve   |                                   |
| performance degradation of        |                                   |
| structures, systems and           |                                   |
| components, could result in long  |                                   |
| periods of unknown equipment      |                                   |
| unavailability. This inspection   |                                   |
| procedure verifies aspects of the |                                   |
| associated cornerstones not       |                                   |
| measured by performance           |                                   |
| indicators.                       |                                   |
|                                   |                                   |
| Surveillance testing including    |                                   |
| inservice testing of pumps and    |                                   |
| valves are required to verify     |                                   |
| that systems and components are   |                                   |
| reliable and functionally capable |                                   |
| of performing their design        |                                   |
| function. Inspection will review  |                                   |
| the adequacy of test procedures   |                                   |
| to test those design functions    |                                   |
| being verified. Important design  |                                   |
| functions not verified by testing |                                   |
| will be subject to risk informed  |                                   |
| design inspection. Surveillance   |                                   |
| testing is the minimum required   |                                   |
| testing specified in the facility |                                   |
| license and ensures that a        |                                   |
| conservative safety margin exists |                                   |
| for system capability. Operating  |                                   |
| experience has shown that test    |                                   |
| procedure deficiencies may        |                                   |
| invalidate previously acceptable  |                                   |
| test results and improper testing |                                   |
| could result in undisclosed       |                                   |
| problems that last until the next |                                   |
| required testing creating long    |                                   |
| periods of unknown equipment      |                                   |
| inoperability.                    |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** The   |                                   |
| PIs indirectly verify the         |                                   |
| adequacy of required surveillance |                                   |
| test activities. This inspection  |                                   |
| is performed to provide insights  |                                   |
| into licensee performance in      |                                   |
| addition to those provided by the |                                   |
| PIs.                              |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| April 2000 ‑ Procedure            |                                   |
| incorporated requirements and     |                                   |
| guidance to review licensee=s     |                                   |
| inservice testing activities,     |                                   |
| containment isolation valve and   |                                   |
| ice condenser system              |                                   |
| surveillances.                    |                                   |
|                                   |                                   |
| January 2002 - Revised to         |                                   |
| incorporated minor changes to the |                                   |
| inspection requirements. In       |                                   |
| addition, inspection resources    |                                   |
| estimates and inspection level of |                                   |
| effort are revised to provide a   |                                   |
| band for more inspection          |                                   |
| flexibility.                      |                                   |
|                                   |                                   |
| May 2004 - Revised to include RCS |                                   |
| leak detection system             |                                   |
| surveillance as part of the       |                                   |
| surveillance testing sample.      |                                   |
| Revision also includes            |                                   |
| surveillance testing attributes   |                                   |
| for reviewing annunciators/alarms |                                   |
| setpoints and alarms response     |                                   |
| procedure actions.                |                                   |
+-----------------------------------+-----------------------------------+

Figure 22 IP 71111.22 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Temporary   |                                   |
| Plant Modifications               |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Mitigating    | **Inspection Procedure:** IP      |
| Systems and Barrier Integrity     | 71111.23                          |
+-----------------------------------+-----------------------------------+
| **Scope:** Inspection activities  |                                   |
| in this area includes a review of |                                   |
| design, installation,             |                                   |
| configuration control, and        |                                   |
| post‑modification testing for     |                                   |
| potentially risk significant      |                                   |
| temporary modifications of the    |                                   |
| systems, structures, and          |                                   |
| components (SSCs) covered by the  |                                   |
| maintenance rule.                 |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** Inspection of this     |                                   |
| area supports the design and      |                                   |
| design control attributes of the  |                                   |
| Mitigating Systems and Barrier    |                                   |
| Integrity cornerstones.           |                                   |
|                                   |                                   |
| Inspection of temporary plant     |                                   |
| modifications provides monitoring |                                   |
| of the licensee=s performance in  |                                   |
| ensuring that the design bases    |                                   |
| for risk‑significant systems,     |                                   |
| SSCs have been maintained and     |                                   |
| that the changes have not         |                                   |
| adversely affected the safety     |                                   |
| functions of the SSCs. Temporary  |                                   |
| modifications may introduce       |                                   |
| change to the assumptions and     |                                   |
| models used in the plant specific |                                   |
| probabilistic risk assessment. A  |                                   |
| temporary change to one system    |                                   |
| may affect the design bases and   |                                   |
| safety functions of other         |                                   |
| interfacing safety systems. An    |                                   |
| increase in the likelihood of the |                                   |
| occurrence of an initiating event |                                   |
| could result from a temporary     |                                   |
| change. Also, similar temporary   |                                   |
| modifications to several systems  |                                   |
| could introduce the potential for |                                   |
| common cause failures that affect |                                   |
| plant risk.                       |                                   |
|                                   |                                   |
| Temporary modifications to        |                                   |
| risk‑significant SSCs may         |                                   |
| adversely affect their            |                                   |
| availability, reliability or      |                                   |
| functional capability. A          |                                   |
| temporary modification may result |                                   |
| in a departure from the design    |                                   |
| basis and system success          |                                   |
| criteria. Temporary or            |                                   |
| unrecognized risk changes due to  |                                   |
| the modification may evolve into  |                                   |
| high risk configurations. This    |                                   |
| inspectable area verifies aspects |                                   |
| of the associated cornerstones    |                                   |
| for which there are no indicators |                                   |
| to measure performance.           |                                   |
|                                   |                                   |
| Industry experience has shown     |                                   |
| that temporary modifications to   |                                   |
| risk‑significant SSCs can         |                                   |
| adversely affect their            |                                   |
| availability, reliability or      |                                   |
| functional capability.            |                                   |
| Verification that all safety      |                                   |
| functions of the system are       |                                   |
| restored after completion of the  |                                   |
| temporary modification is         |                                   |
| important.                        |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** No    |                                   |
| performance indicators have been  |                                   |
| established that can provide      |                                   |
| results related to the adequacy   |                                   |
| of temporary modifications.       |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| January 2002 - revised to provide |                                   |
| guidance on how to adequately     |                                   |
| determine the combined effects of |                                   |
| several temporary modifications   |                                   |
| on the safe operation of the      |                                   |
| plant, and to provide latitude in |                                   |
| sample sizes and estimated        |                                   |
| resources.                        |                                   |
+-----------------------------------+-----------------------------------+

Figure 23 IP 71111.23 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Biennial    |                                   |
| Exercise and Drill Inspection     |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Emergency     | **Inspection Procedure:** IP      |
| Preparedness                      | 71114.01 and IP 71114.06          |
+-----------------------------------+-----------------------------------+
| **Scope:** These inspection areas |                                   |
| are an evaluation of licensee=s   |                                   |
| critique of performance during    |                                   |
| the conduct of drills, exercises  |                                   |
| and appropriate training          |                                   |
| evolutions. This verifies the     |                                   |
| licensee=s ability to identify    |                                   |
| unacceptable performance in the   |                                   |
| implementation of the emergency   |                                   |
| plan. It verifies that the        |                                   |
| critique program used to develop  |                                   |
| the success rate reported by the  |                                   |
| drill/exercise performance (DEP)  |                                   |
| performance indicators (PI)       |                                   |
| represent the actual success rate |                                   |
| of risk significant planning      |                                   |
| standard performance. The         |                                   |
| inspection ensures the efficacy   |                                   |
| and veracity of the licensee      |                                   |
| critique program.                 |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** This inspection area   |                                   |
| supports the EP cornerstone       |                                   |
| through the emergency response    |                                   |
| organization (ERO) Readiness,     |                                   |
| Facilities and Equipment,         |                                   |
| Procedure Quality and ERO         |                                   |
| Performance key attributes.       |                                   |
|                                   |                                   |
| The implementation of the         |                                   |
| Emergency Plan is dependant on    |                                   |
| the performance of the ERO in     |                                   |
| their EP assignments. There are   |                                   |
| many areas important to Plan      |                                   |
| implementation, but the most risk |                                   |
| significant areas (RSPS) of ERO   |                                   |
| performance are:                  |                                   |
|                                   |                                   |
| \$ Timely and accurate            |                                   |
| classification of events;         |                                   |
| including the recognition of      |                                   |
| events as potentially exceeding   |                                   |
| emergency action levels and any   |                                   |
| assessment actions necessary to   |                                   |
| support the classification.       |                                   |
|                                   |                                   |
| \$ Timely and accurate            |                                   |
| notification of offsite           |                                   |
| governmental authorities;         |                                   |
| including adequate performance of |                                   |
| notifications as specified in the |                                   |
| Plan.                             |                                   |
|                                   |                                   |
| \$ Timely and accurate            |                                   |
| development and communication of  |                                   |
| protective action recommendations |                                   |
| to offsite authorities; including |                                   |
| providing protective action       |                                   |
| recommendations (PARs) to         |                                   |
| governmental authorities, the     |                                   |
| decision making process to        |                                   |
| develop the PARs and any accident |                                   |
| assessment necessary to support   |                                   |
| PAR development.                  |                                   |
|                                   |                                   |
| If the ERO consistently performs  |                                   |
| these activities in a timely and  |                                   |
| accurate manner, it indicates     |                                   |
| that the EP program is operating  |                                   |
| within the licensee response band |                                   |
| where NRC can allow licensees to  |                                   |
| address weaknesses with oversight |                                   |
| through a risk informed           |                                   |
| inspection program.               |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:**       |                                   |
|                                   |                                   |
| The DEP PI has been developed to  |                                   |
| indicate performance in the most  |                                   |
| risk significant areas of EP      |                                   |
| (RSPS). However, the statistics   |                                   |
| used to value the DEP PI are      |                                   |
| based on licensee critique of     |                                   |
| RSPS performance in drills,       |                                   |
| exercises and appropriate         |                                   |
| training evolutions. These        |                                   |
| inspections verify the efficacy   |                                   |
| of the licensee critique program. |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| April 2000 ‑ The review of        |                                   |
| licensee correction of weaknesses |                                   |
| was initially performed within    |                                   |
| the scope of 71114.01. This was   |                                   |
| seen as supportive to preparation |                                   |
| for observation of the exercise,  |                                   |
| but proved to be too demanding of |                                   |
| licensee and inspection staff.    |                                   |
| Licensee focus during the week of |                                   |
| the exercise is proper scenario   |                                   |
| conduct. Providing corrective     |                                   |
| action documentation and staff    |                                   |
| for discussion to NRC detracts    |                                   |
| from the primary focus. The       |                                   |
| review of weakness correction was |                                   |
| moved to 71114.05.                |                                   |
+-----------------------------------+-----------------------------------+

Figure 24 IP 71114.01 and IP 71114.06 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Alert and   |                                   |
| Notification System Testing       |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Emergency     | **Inspection Procedure:** IP      |
| Preparedness                      | 71114.02                          |
+-----------------------------------+-----------------------------------+
| **Scope:** Inspection in this     |                                   |
| area includes a review of testing |                                   |
| activities for the Alert and      |                                   |
| Notification System (ANS) in      |                                   |
| order to assess licensee          |                                   |
| performance.                      |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** This inspection area   |                                   |
| supports the Emergency            |                                   |
| Preparedness (EP) cornerstone     |                                   |
| through the Facilities and        |                                   |
| Equipment key attribute.          |                                   |
|                                   |                                   |
| The ANS is the most important     |                                   |
| system/equipment maintained by    |                                   |
| the EP program. The purpose of    |                                   |
| the EP program is to implement    |                                   |
| adequate measures to protect the  |                                   |
| public health and safety in the   |                                   |
| event of a radiological emergency |                                   |
| and the ANS is the method used    |                                   |
| for notifying the public of the   |                                   |
| need to take such protective      |                                   |
| actions. Generally the licensee   |                                   |
| maintains the ANS and local       |                                   |
| governmental authorities operate  |                                   |
| it when necessary. An ANS with a  |                                   |
| high rate of reliability          |                                   |
| increases the assurance public    |                                   |
| health and safety can be          |                                   |
| protected during an emergency. If |                                   |
| an EP program consistently        |                                   |
| ensures that the ANS is in a high |                                   |
| state of readiness it indicates   |                                   |
| that the EP program is operating  |                                   |
| within the licensee response band |                                   |
| where NRC can allow licensees to  |                                   |
| address weaknesses with oversight |                                   |
| through a risk informed           |                                   |
| inspection program. The ANS       |                                   |
| Reliability PI measures the       |                                   |
| reliability of the ANS. The value |                                   |
| of the PI is based on the results |                                   |
| of the testing program. This      |                                   |
| inspection addresses the testing  |                                   |
| program itself to ensure it meets |                                   |
| national standards (and/or        |                                   |
| commitments) for the testing of   |                                   |
| the ANS.                          |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** A PI, |                                   |
| ANS reliability, addresses        |                                   |
| performance in this area.         |                                   |
| However, for the statistics of    |                                   |
| the PI to be valid, the testing   |                                   |
| program must be conducted in      |                                   |
| accordance with guidance. The     |                                   |
| inspection verifies testing       |                                   |
| program compliance.               |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| None                              |                                   |
+-----------------------------------+-----------------------------------+

Figure 25 IP 71114.02 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Emergency   |                                   |
| Response Organization             |                                   |
| Augmentation Testing              |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Emergency     | **Inspection Procedure:** IP      |
| Preparedness                      | 71114.03                          |
+-----------------------------------+-----------------------------------+
| **Scope:** Inspection in this     |                                   |
| area involves review of licensee  |                                   |
| processes to augment the          |                                   |
| Emergency Response Organization   |                                   |
| (ERO) during emergencies.         |                                   |
| Licensees normally conduct tests  |                                   |
| of the augmentation system and    |                                   |
| the people assigned to the ERO to |                                   |
| ensure that emergency response    |                                   |
| facilities can be staffed in      |                                   |
| accordance with activation goals. |                                   |
| Licensee ability to identify and  |                                   |
| disposition augmentation problems |                                   |
| is also inspected.                |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** This inspection area   |                                   |
| supports the Emergency            |                                   |
| Preparedness (EP) cornerstone     |                                   |
| through the ERO Readiness,        |                                   |
| Procedure Quality and Facilities  |                                   |
| and Equipment key attributes.     |                                   |
|                                   |                                   |
| The licensee system to augment    |                                   |
| the on‑shift staff with ERO       |                                   |
| members is an important process   |                                   |
| in implementing the Emergency     |                                   |
| Plan. This system involves the    |                                   |
| notification of individual ERO    |                                   |
| members, training of ERO members  |                                   |
| in its use, verification that it  |                                   |
| can support facility activation   |                                   |
| goals and testing to ensure       |                                   |
| function.                         |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** No    |                                   |
| PIs were established that cover   |                                   |
| this area.                        |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| None                              |                                   |
+-----------------------------------+-----------------------------------+

Figure 26 IP 71114.03 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Emergency   |                                   |
| Action Level and Emergency Plan   |                                   |
| Changes                           |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Emergency     | **Inspection Procedure:** IP      |
| Preparedness                      | 71114.04                          |
+-----------------------------------+-----------------------------------+
| **Scope:** Inspection activities  |                                   |
| in this area include a review of  |                                   |
| all changes to the Emergency      |                                   |
| Action Levels (EALs) and a        |                                   |
| sampling of changes to the        |                                   |
| Emergency Plan (Plan).            |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** This inspection area   |                                   |
| supports the Emergency            |                                   |
| Preparedness (EP) cornerstone     |                                   |
| through the Procedure Quality key |                                   |
| attribute.                        |                                   |
|                                   |                                   |
| Recognition and subsequent        |                                   |
| classification of events is a     |                                   |
| risk significant activity (RSPS)  |                                   |
| because classification leads to   |                                   |
| activation of the Emergency       |                                   |
| Response Organization,            |                                   |
| notification of governmental      |                                   |
| authorities and in the extreme,   |                                   |
| development of protective action  |                                   |
| recommendations. However, if the  |                                   |
| EAL scheme is not in compliance   |                                   |
| with NRC approved classification  |                                   |
| schemes, the expected emergency   |                                   |
| classification may not occur.     |                                   |
| Appendix E to 10 CFR Part 50,     |                                   |
| requires that NRC approve EALs.   |                                   |
| 10 CFR 50.54(q) states that       |                                   |
| licensees may change emergency    |                                   |
| plans so long as the change does  |                                   |
| not decrease the effectiveness of |                                   |
| the Plan. In accordance with past |                                   |
| practice, NRC allows licensees to |                                   |
| make EAL changes that are not a   |                                   |
| decrease in effectiveness without |                                   |
| prior NRC approval. However, the  |                                   |
| regulations require NRC approval  |                                   |
| of all such changes. This         |                                   |
| inspection is the method for NRC  |                                   |
| review and approval of all EAL    |                                   |
| changes.                          |                                   |
|                                   |                                   |
| Plan changes do not require NRC   |                                   |
| approval so long as they do not   |                                   |
| decrease the effectiveness of the |                                   |
| Plan. This inspection provides    |                                   |
| for review of a sampling of       |                                   |
| licensee plan changes annually to |                                   |
| ensure that licensee processes    |                                   |
| are ensuring that changes do not  |                                   |
| decrease the plan=s               |                                   |
| effectiveness.                    |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** No    |                                   |
| PIs were established that cover   |                                   |
| this area.                        |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| April 2000 ‑ Initially, only the  |                                   |
| EAL element was addressed in this |                                   |
| IP. The plan review was combined  |                                   |
| with an IP which also addressed   |                                   |
| UFSAR and Safeguards Plan         |                                   |
| changes. This was found to be     |                                   |
| cumbersome and the Plan elements  |                                   |
| were placed in this IP.           |                                   |
+-----------------------------------+-----------------------------------+

Figure 27 IP 71114.04 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Correction  |                                   |
| of Emergency Preparedness         |                                   |
| Weaknesses and Deficiencies       |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Emergency     | **Inspection Procedure:** IP      |
| Preparedness                      | 71114.05                          |
+-----------------------------------+-----------------------------------+
| **Scope:** Evaluate licensee      |                                   |
| efforts to correct EP related     |                                   |
| weaknesses and deficiencies       |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** The licensee critique  |                                   |
| program (and other                |                                   |
| self‑assessment processes) should |                                   |
| identify ERO performance and      |                                   |
| other problems that detract from  |                                   |
| Plan implementation. The          |                                   |
| identification of repeat items    |                                   |
| and trends and the disposition of |                                   |
| corrective actions is inspected.  |                                   |
| The ability to identify and       |                                   |
| resolve problems is integral to   |                                   |
| the efficacy of an EP program.    |                                   |
| The ability to identify problems  |                                   |
| is inspected under 71114.01 & .06 |                                   |
| as it relates to the conduct of   |                                   |
| drills and exercises. This        |                                   |
| inspection addresses licensee     |                                   |
| ability to correct identified     |                                   |
| weaknesses in a timely manner.    |                                   |
| The inspection is meant to        |                                   |
| include all licensee efforts that |                                   |
| assess the EP program or the      |                                   |
| performance of the ERO such as:   |                                   |
|                                   |                                   |
| \$ self assessment reports        |                                   |
| including all reports of actual   |                                   |
| events and missed classification  |                                   |
| of actual events,                 |                                   |
|                                   |                                   |
| \$ biennial exercise and drill    |                                   |
| critiques,                        |                                   |
|                                   |                                   |
| \$ audits conducted under 10 CFR  |                                   |
| 50.54(t), and                     |                                   |
|                                   |                                   |
| \$ assessments performed by the   |                                   |
| Quality Assurance organization.   |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** No    |                                   |
| PI=s were established that cover  |                                   |
| this area.                        |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| None                              |                                   |
+-----------------------------------+-----------------------------------+

Figure 28 IP 71114.05 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Access      |                                   |
| Control to Radiologically         |                                   |
| Significant Areas                 |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Occupational  | **Inspection Procedure:** IP      |
| Radiation Safety                  | 71121.01                          |
+-----------------------------------+-----------------------------------+
| **Scope:** This procedure will    |                                   |
| verify that the licensee has      |                                   |
| implemented effective Radiation   |                                   |
| Protection (RP) barrier integrity |                                   |
| to prevent an uncontrolled access |                                   |
| to an airborne, high radiation    |                                   |
| area (HRA) or very high radiation |                                   |
| area (VHRA) that could            |                                   |
| potentially result in an exposure |                                   |
| in excess of regulatory limits.   |                                   |
| RP barrier integrity includes:    |                                   |
| identification and control of the |                                   |
| hazard, administrative controls   |                                   |
| (RWPs, planning, procedures),     |                                   |
| physical barrier integrity or     |                                   |
| engineered controls (e.g.,        |                                   |
| barrier integrity ropes, locked   |                                   |
| doors, shielding, or ventilation  |                                   |
| systems), radiological surveys    |                                   |
| and monitoring (e.g., RP          |                                   |
| technician coverage, personnel    |                                   |
| alarming dosimeter, or remote     |                                   |
| monitoring or surveillance), and  |                                   |
| radiation worker training.        |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** Inspection in this     |                                   |
| area supports the plant           |                                   |
| facilities attribute of the       |                                   |
| Occupational Radiation Safety     |                                   |
| cornerstone.                      |                                   |
|                                   |                                   |
| This inspection will review the   |                                   |
| licensee=s performance in         |                                   |
| instituting the physical and      |                                   |
| administrative controls defined   |                                   |
| in Subparts G, H, I, and J of 10  |                                   |
| CFR Part 20, applicable technical |                                   |
| specifications (TS), and licensee |                                   |
| procedures for airborne areas,    |                                   |
| HRAs and VHRAs, and worker        |                                   |
| adherence to these controls.      |                                   |
|                                   |                                   |
| Radiological risk (i.e.,          |                                   |
| exposure) to a worker must be     |                                   |
| within the occupational exposure  |                                   |
| limits defined in 10 CFR Part 20  |                                   |
| and ALARA to minimize the         |                                   |
| potential for health effects.     |                                   |
| Collectively, the access controls |                                   |
| provide a \"defense‑in‑depth\"    |                                   |
| against a significant exposure.   |                                   |
| Industry experience has           |                                   |
| identified frequent occurrences   |                                   |
| where the failure of multiple     |                                   |
| barrier integrity resulted in an  |                                   |
| uncontrolled entry and, in some   |                                   |
| cases, a significant exposure.    |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** The   |                                   |
| established performance indicator |                                   |
| (PI) does not address airborne    |                                   |
| areas, HRAs with dose rates       |                                   |
| \<1000 mrem/hr, highly            |                                   |
| contaminated areas, or            |                                   |
| occurrences that have a           |                                   |
| substantial potential for an      |                                   |
| exposure in excess of regulatory  |                                   |
| limits.                           |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| March 2002 - Revised as follows:  |                                   |
|                                   |                                   |
| \- The Problem Identification and |                                   |
| Resolution sections have been     |                                   |
| revised to make the sections      |                                   |
| uniform.                          |                                   |
|                                   |                                   |
| \- A new inspection requirement   |                                   |
| and guidance was added to         |                                   |
| Attachment .01 to determine       |                                   |
| licensee compliance with 10 CFR   |                                   |
| Part 20.1101(c).                  |                                   |
|                                   |                                   |
| \- Attachments were revised to    |                                   |
| focus inspections on periods      |                                   |
| before, during, and after         |                                   |
| scheduled outages to give more    |                                   |
| flexibility and to recognize      |                                   |
| ongoing Regional practice when    |                                   |
| planning inspections.             |                                   |
+-----------------------------------+-----------------------------------+

Figure 29 IP 71121.01 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** ALARA       |                                   |
| Planning and Controls             |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Occupational  | **Inspection Procedure:** IP      |
| Radiation Safety                  | 71121.02                          |
+-----------------------------------+-----------------------------------+
| **Scope:** This area will verify  |                                   |
| that the licensee maintains       |                                   |
| occupational exposure as low as   |                                   |
| reasonably achievable (ALARA) by  |                                   |
| properly planning and controlling |                                   |
| radiologically significant work   |                                   |
| activities. Controls, as stated   |                                   |
| here, refer to those physical     |                                   |
| (e.g., locked doors, barrier      |                                   |
| integrity ropes, shielding,       |                                   |
| engineering controls) and         |                                   |
| administrative (e.g., surveys,    |                                   |
| planning, procedures, training,   |                                   |
| monitoring) barrier integrity     |                                   |
| that, in the aggregate, serve to  |                                   |
| mitigate exposure.                |                                   |
|                                   |                                   |
| The focus is whether reasonable   |                                   |
| goals were established for        |                                   |
| radiologically significant work   |                                   |
| which consider previous licensee  |                                   |
| performance and industry          |                                   |
| experience, and whether the       |                                   |
| licensee=s subsequent performance |                                   |
| met those goals. Emphasis should  |                                   |
| be placed on those jobs having a  |                                   |
| high individual and/or collective |                                   |
| dose, being performed in an area  |                                   |
| of higher radiological risk or    |                                   |
| are of concern because of         |                                   |
| industry or licensee experience   |                                   |
| (such as spent fuel pool diving). |                                   |
| This may include observing        |                                   |
| selected activities to verify the |                                   |
| assumptions underlying these      |                                   |
| goals and that the appropriate    |                                   |
| controls were implemented. The    |                                   |
| inspection should also review     |                                   |
| licensee assessments of the ALARA |                                   |
| program to determine whether      |                                   |
| adequate administrative controls, |                                   |
| management oversight, and         |                                   |
| exposure controls (including      |                                   |
| source term reduction) were       |                                   |
| taken.                            |                                   |
|                                   |                                   |
| Specific attention should be      |                                   |
| given to Planned Special          |                                   |
| Exposures and exposures to        |                                   |
| Declared Pregnant Workers,        |                                   |
| because of the inherent risk and  |                                   |
| public interest.                  |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** Inspection in this     |                                   |
| area supports the program/process |                                   |
| attribute of the Occupational     |                                   |
| Radiation Safety cornerstone.     |                                   |
|                                   |                                   |
| This inspection will review       |                                   |
| whether the licensee meets the    |                                   |
| requirements of Subpart B to 10   |                                   |
| CFR Part 20, which requires that  |                                   |
| a Radiation Protection program,   |                                   |
| including procedures and          |                                   |
| engineering controls, be          |                                   |
| instituted to maintain            |                                   |
| occupational dose ALARA. As       |                                   |
| discussed in the Statement of     |                                   |
| Considerations to the 1991 rule   |                                   |
| change (FR Vol. 56, No. 98, page  |                                   |
| 23367), compliance with this      |                                   |
| requirement is judged on whether  |                                   |
| the licensee has incorporated     |                                   |
| measures to track and, if         |                                   |
| necessary, to reduce exposures    |                                   |
| and not whether exposures         |                                   |
| represent an absolute minimum.    |                                   |
|                                   |                                   |
| Radiological risk (i.e.,          |                                   |
| exposure) to a worker should be   |                                   |
| maintained within the             |                                   |
| occupational exposure limits      |                                   |
| defined in 10 CFR Part 20 and     |                                   |
| ALARA to minimize the potential   |                                   |
| for health effects. Effective     |                                   |
| ALARA planning will ensure that   |                                   |
| adequate physical and             |                                   |
| administrative controls are in    |                                   |
| place to mitigate exposure during |                                   |
| radiologically significant work.  |                                   |
| Industry=s experience includes    |                                   |
| frequent events where problems in |                                   |
| this area have resulted in        |                                   |
| unanticipated exposure or a loss  |                                   |
| of control of the work activity.  |                                   |
| Specific attention should be      |                                   |
| given to Planned Special          |                                   |
| Exposures, exposures to Declared  |                                   |
| Pregnant Workers, and to          |                                   |
| activities that challenge the     |                                   |
| maintenance of occupational       |                                   |
| exposure control and ALARA, such  |                                   |
| as outage and refueling planning  |                                   |
| and preparation, emergent work    |                                   |
| activities, and radiological      |                                   |
| events.                           |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** There |                                   |
| is no performance indicator       |                                   |
| established that covers this      |                                   |
| area. Assessment of the ALARA     |                                   |
| program effectiveness is          |                                   |
| site‑specific and highly          |                                   |
| dependent upon operational        |                                   |
| history, work scope, and worker   |                                   |
| experience.                       |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| March 2002 - Revised as follows:  |                                   |
|                                   |                                   |
| \- The Problem Identification and |                                   |
| Resolution sections have been     |                                   |
| revised to make the sections      |                                   |
| uniform.                          |                                   |
|                                   |                                   |
| \- Attachment .02 was modified to |                                   |
| conform with the changes to the   |                                   |
| ALARA SDP and screening Criteria. |                                   |
|                                   |                                   |
| \- Attachments were revised to    |                                   |
| focus inspections on periods      |                                   |
| before, during, and after         |                                   |
| scheduled outages to give more    |                                   |
| flexibility and to recognize      |                                   |
| ongoing Regional practice when    |                                   |
| planning inspections.             |                                   |
|                                   |                                   |
| \- Reduced the estimated          |                                   |
| inspection hours for Attachment   |                                   |
| .02.                              |                                   |
|                                   |                                   |
| \- Asterisks have been added to a |                                   |
| number of inspection requirements |                                   |
| in Attachment .02. The inspection |                                   |
| requirements identified with      |                                   |
| asterisks are optional and should |                                   |
| be inspected as deemed            |                                   |
| appropriate by the Regions for    |                                   |
| plants whose three-year rolling   |                                   |
| average collective dose is not in |                                   |
| the top (lowest dose) quartile.   |                                   |
+-----------------------------------+-----------------------------------+

Figure 30 IP 71121.02 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Radiation   |                                   |
| Monitoring Instrumentation        |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Occupational  | **Inspection Procedure:** IP      |
| Radiation Safety                  | 71121.03                          |
+-----------------------------------+-----------------------------------+
| **Scope:** Inspection of this     |                                   |
| area should ensure that           |                                   |
| criticality monitors, area        |                                   |
| radiation monitors, continuous    |                                   |
| air monitors and applicable       |                                   |
| Radiation Monitoring System       |                                   |
| monitors are reliable and         |                                   |
| accurate in areas where           |                                   |
| activities could result in        |                                   |
| transient HRAs, VHRAs or airborne |                                   |
| areas. This inspection will also  |                                   |
| include the containment dome      |                                   |
| monitors (because of their        |                                   |
| importance in accident analysis   |                                   |
| and classification), portable     |                                   |
| instrumentation used to assess    |                                   |
| radiologically significant areas  |                                   |
| or activities (such as underwater |                                   |
| meters used during diving), and   |                                   |
| bioassay equipment (such as whole |                                   |
| body counters). However, the      |                                   |
| inspection will not include those |                                   |
| monitors that a licensee has      |                                   |
| included under their Maintenance  |                                   |
| Rule program.                     |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** This inspection will   |                                   |
| verify that these monitors are    |                                   |
| calibrated and maintained         |                                   |
| (including verifying alarm        |                                   |
| setpoints) as required by 10 CFR  |                                   |
| Part 20 or a licensee=s technical |                                   |
| specifications and procedures.    |                                   |
|                                   |                                   |
| Radiological risk (i.e.,          |                                   |
| exposure) to a worker should be   |                                   |
| maintained within the             |                                   |
| occupational exposure limits      |                                   |
| defined in 10 CFR Part 20 and     |                                   |
| ALARA to minimize the potential   |                                   |
| for health effects. These         |                                   |
| monitors identify changing        |                                   |
| radiological conditions to        |                                   |
| workers such that actions to      |                                   |
| prevent an overexposure can be    |                                   |
| taken. Industry has experienced   |                                   |
| several events where these        |                                   |
| monitors were the primary         |                                   |
| indication that radiological      |                                   |
| conditions had significantly      |                                   |
| changed as a result of planned or |                                   |
| unplanned activities.             |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** None  |                                   |
| of the established PIs cover this |                                   |
| area. Monitor locations are site  |                                   |
| specific and assessments of their |                                   |
| reliability and accuracy will     |                                   |
| require baseline inspection.      |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| March 2002 - Revised as follows:  |                                   |
|                                   |                                   |
| \- The Problem Identification and |                                   |
| Resolution sections have been     |                                   |
| revised to make the sections      |                                   |
| uniform.                          |                                   |
|                                   |                                   |
| \- Attachments were revised to    |                                   |
| focus inspections on periods      |                                   |
| before, during, and after         |                                   |
| scheduled outages to give more    |                                   |
| flexibility and to recognize      |                                   |
| ongoing Regional practice when    |                                   |
| planning inspections.             |                                   |
+-----------------------------------+-----------------------------------+

Figure 31 IP 71121.03 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Gaseous and |                                   |
| Liquid Effluent Treatment Systems |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Public        | **Inspection Procedure:** IP      |
| Radiation Safety                  | 71122.01                          |
+-----------------------------------+-----------------------------------+
| **Scope:** This area will verify  |                                   |
| that gaseous and liquid           |                                   |
| radioactive effluent treatment    |                                   |
| systems are maintained such that  |                                   |
| radiological releases are         |                                   |
| properly mitigated, monitored and |                                   |
| assessed. The focus is to ensure  |                                   |
| that radiological effluent        |                                   |
| releases are controlled in        |                                   |
| accordance with license           |                                   |
| conditions and regulatory limits, |                                   |
| that system modifications are     |                                   |
| properly performed, and that      |                                   |
| radiological effluent and         |                                   |
| meteorological monitors are       |                                   |
| accurate and reliable. Overall    |                                   |
| system operation (including       |                                   |
| administrative controls) will be  |                                   |
| assessed by reviewing licensee    |                                   |
| problem and resolution            |                                   |
| assessments, the Annual           |                                   |
| Radiological Environmental        |                                   |
| Monitoring Report and the Annual  |                                   |
| Radiological Effluent Release     |                                   |
| Report.                           |                                   |
|                                   |                                   |
| The baseline program consists of  |                                   |
| performing in‑office reviews of   |                                   |
| the Annual Radiological Effluent  |                                   |
| Release Report to verify that the |                                   |
| program is being implemented as   |                                   |
| described in the licensee=s       |                                   |
| Offsite Dose Calculation Manual   |                                   |
| (ODCM). Additional areas of       |                                   |
| review (on‑site) include          |                                   |
| calibration of the gaseous and    |                                   |
| liquid radiological effluent      |                                   |
| monitors, including any           |                                   |
| modifications to the system, the  |                                   |
| calibration and operation of the  |                                   |
| site meteorological monitoring    |                                   |
| system, and modifications to the  |                                   |
| radioactive waste treatment       |                                   |
| system. The baseline inspection   |                                   |
| also includes a walk down of the  |                                   |
| gaseous and liquid radioactive    |                                   |
| processing and monitoring systems |                                   |
| to observe routine activities and |                                   |
| to verify that previously         |                                   |
| identified deficiencies are being |                                   |
| corrected.                        |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** Inspection in this     |                                   |
| area supports the plant           |                                   |
| facilities/equipment and          |                                   |
| instrumentation and               |                                   |
| program/process attributes of the |                                   |
| Public Exposure cornerstone.      |                                   |
|                                   |                                   |
| This inspection will verify that  |                                   |
| gaseous and liquid radioactive    |                                   |
| effluent processing systems are   |                                   |
| maintained as required by General |                                   |
| Design Criteria 60, 63, and 64 of |                                   |
| Appendix A to 10 CFR Part 50,     |                                   |
| Radiological Effluent Technical   |                                   |
| Specifications (RETS) and the     |                                   |
| ODCM.                             |                                   |
|                                   |                                   |
| The dose from radioactive         |                                   |
| effluents is required to be       |                                   |
| maintained within the limits of   |                                   |
| 10 CFR Part 20 and 40 CFR Part    |                                   |
| 190, as well as being As Low As   |                                   |
| is Reasonably Achievable (ALARA)  |                                   |
| to minimize the potential for     |                                   |
| health effects. Doses below the   |                                   |
| design objectives contained in    |                                   |
| Appendix I to 10 CFR Part 50 are  |                                   |
| considered ALARA by the NRC.      |                                   |
| Proper operation of the           |                                   |
| radioactive effluent treatment    |                                   |
| system and release point monitors |                                   |
| will ensure an adequate           |                                   |
| defense‑in‑depth against an       |                                   |
| unmonitored, unanticipated        |                                   |
| release of radioactivity to the   |                                   |
| environment.                      |                                   |
|                                   |                                   |
| The NRC has determined that an    |                                   |
| independent assessment of         |                                   |
| licensee performance in this area |                                   |
| is necessary to ensure that       |                                   |
| adequate protection of the public |                                   |
| health and safety is maintained.  |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** The   |                                   |
| performance indicators (PI) for   |                                   |
| this area adequately address most |                                   |
| aspects of the program/process    |                                   |
| and human performance attributes. |                                   |
| The PI is based on actual         |                                   |
| calculated radiation doses to     |                                   |
| members of the public from the    |                                   |
| routine release of gaseous and    |                                   |
| liquid radioactive effluents.     |                                   |
| Specific radiation dose criteria  |                                   |
| have been established, which if   |                                   |
| exceeded are an indication of     |                                   |
| potential degraded licensee       |                                   |
| performance. Incidents that will  |                                   |
| be tracked as a PI include        |                                   |
| radiological effluent releases    |                                   |
| which result in a calculated dose |                                   |
| to a member of the public in      |                                   |
| excess of the PI value.           |                                   |
|                                   |                                   |
| The PIs do not address accident   |                                   |
| releases, system modifications,   |                                   |
| and meteorological and effluent   |                                   |
| monitor operability. The PIs do   |                                   |
| not address meteorological and    |                                   |
| effluent monitor calibration and  |                                   |
| setpoint verification, thus a     |                                   |
| selective inspection of           |                                   |
| calibration and setpoint records  |                                   |
| is necessary to verify the        |                                   |
| integrity of the PIs.             |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| March 2002 - Revised to allow the |                                   |
| inspector the option to review    |                                   |
| the \"\...system surveillance     |                                   |
| test results or licensee specific |                                   |
| methodology to ensure that the    |                                   |
| system is operating within the    |                                   |
| licensee\'s acceptance            |                                   |
| criteria.\" This revision adds    |                                   |
| inspection flexibility for        |                                   |
| licensees that do not have        |                                   |
| surveillance requirements for     |                                   |
| ventilation equipment.            |                                   |
| Additionally a range of           |                                   |
| inspection hours was established  |                                   |
| based on the actual inspection    |                                   |
| data.                             |                                   |
+-----------------------------------+-----------------------------------+

Figure 32 IP 71122.01 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Radioactive |                                   |
| Material Processing and           |                                   |
| Transportation                    |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Public        | **Inspection Procedure:** IP      |
| Radiation Safety                  | 71122.02                          |
+-----------------------------------+-----------------------------------+
| **Scope:** Inspection of this     |                                   |
| area will verify that appropriate |                                   |
| controls are instituted for the   |                                   |
| processing and transportation of  |                                   |
| radioactive material to a         |                                   |
| licensed disposal facility or     |                                   |
| other licensed recipient. The     |                                   |
| focus of the inspection is to     |                                   |
| review the administrative and     |                                   |
| physical controls for the         |                                   |
| processing and transportation of  |                                   |
| radioactive material (i.e., Class |                                   |
| A, B, C, and irradiated fuel      |                                   |
| shipments) to ensure that         |                                   |
| radiation exposure to radiation   |                                   |
| workers and members of the public |                                   |
| are within regulatory limits. The |                                   |
| inspection also includes a        |                                   |
| walkdown of the radioactive waste |                                   |
| processing systems to verify that |                                   |
| the systems are in good material  |                                   |
| condition. During the inspection, |                                   |
| a review and observation is       |                                   |
| performed on a sample of selected |                                   |
| shipping activities having        |                                   |
| risk‑significance (such as Type   |                                   |
| B, C, or irradiated fuel          |                                   |
| shipments), including reviewing   |                                   |
| associated transportation         |                                   |
| records, to provide independent   |                                   |
| validation of the transportation  |                                   |
| program. Emphasis is also given   |                                   |
| to the 10 CFR Part 61 waste       |                                   |
| characterization and stability    |                                   |
| requirements (III.A.3 and III.C.5 |                                   |
| of Subpart G to 10 CFR Part 20).  |                                   |
| The inspection uses licensee      |                                   |
| documentation and assessments for |                                   |
| the review of lesser shipping     |                                   |
| activities (i.e., Type A),        |                                   |
| administrative controls, worker   |                                   |
| training and qualifications, and  |                                   |
| to verify that changes to the     |                                   |
| U.S. Department of Transportation |                                   |
| (DOT) or NRC transportation       |                                   |
| requirements were addressed. All  |                                   |
| transportation events reported to |                                   |
| the Commission or to the licensee |                                   |
| from a State regulatory agency    |                                   |
| are also reviewed.                |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** This inspection will   |                                   |
| verify that the radioactive       |                                   |
| material processing and           |                                   |
| transportation program comply     |                                   |
| with the requirements of 10 CFR   |                                   |
| Parts 20 and 71 and DOT           |                                   |
| regulations 49 CFR Parts 170‑189. |                                   |
| Radioactive material intended for |                                   |
| disposal must also comply with 10 |                                   |
| CFR 61.55 ‑ 61.57 waste           |                                   |
| classification and stability      |                                   |
| requirements.                     |                                   |
|                                   |                                   |
| The regulations contain specific  |                                   |
| physical and administrative       |                                   |
| controls that provide a           |                                   |
| defense‑in‑depth approach for the |                                   |
| safe processing and transport of  |                                   |
| radioactive material, including   |                                   |
| situations involving the breach   |                                   |
| of a loaded transport package.    |                                   |
| Although there is a low frequency |                                   |
| of industry events, the actual or |                                   |
| potential consequence (i.e.,      |                                   |
| significant exposures or release  |                                   |
| of radioactive material) can be   |                                   |
| high. The NRC has determined that |                                   |
| an independent assessment of      |                                   |
| performance in this area is       |                                   |
| necessary to ensure that adequate |                                   |
| protection of public health and   |                                   |
| safety is maintained.             |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** There |                                   |
| is no Performance Indicator for   |                                   |
| this area.                        |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| March 2002 - Revised to add the   |                                   |
| requirement to review the         |                                   |
| licensee\'s audit program to      |                                   |
| verify that it complies with the  |                                   |
| requirements of 10 CFR            |                                   |
| 20.1101(c). The base inspection   |                                   |
| hours were increased and a range  |                                   |
| of inspection hours was           |                                   |
| established based on actual       |                                   |
| inspection hours during the first |                                   |
| year of ROP implementation.       |                                   |
+-----------------------------------+-----------------------------------+

Figure 33 IP 71122.02 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:**             |                                   |
| Radiological Environmental        |                                   |
| Monitoring Program (REMP) and     |                                   |
| Radioactive Material Control      |                                   |
| Program                           |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** Public        | **Inspection Procedure:** IP      |
| Radiation Safety                  | 71122.03                          |
+-----------------------------------+-----------------------------------+
| **Scope:** Inspection of the REMP |                                   |
| is to ensure that the licensee=s  |                                   |
| program reasonably measures the   |                                   |
| effects of radioactive releases   |                                   |
| to the environment. The focus of  |                                   |
| the inspection is on the          |                                   |
| licensee=s program to collect     |                                   |
| environmental samples, process    |                                   |
| the samples (i.e., analyze for    |                                   |
| the type and amount of            |                                   |
| radioactive material), and trend  |                                   |
| the data to determine if there is |                                   |
| an environmental impact from the  |                                   |
| operation of the plant.           |                                   |
|                                   |                                   |
| The inspection of the REMP        |                                   |
| consists of an in‑office review   |                                   |
| of the licensee=s Annual          |                                   |
| Radiological Environmental        |                                   |
| Monitoring Report to verify that  |                                   |
| the REMP was implemented as       |                                   |
| required by the Technical         |                                   |
| Specifications and the ODCM. The  |                                   |
| review includes verifying that    |                                   |
| the environmental sampling is     |                                   |
| representative of the radioactive |                                   |
| effluent release pathways and     |                                   |
| that any problems (e.g., missed   |                                   |
| samples and/or inoperable         |                                   |
| sampling/analyses equipment) are  |                                   |
| being addressed. During the       |                                   |
| on‑site portion of the            |                                   |
| inspection, the inspector will    |                                   |
| perform a walk‑down of the        |                                   |
| licensee=s sampling stations,     |                                   |
| observe environmental sampling    |                                   |
| techniques and analyses           |                                   |
| techniques, and review the        |                                   |
| calibration and maintenance of    |                                   |
| the radiation detection           |                                   |
| instrumentation used for sample   |                                   |
| analysis (if the analysis is      |                                   |
| performed on‑site) for regulatory |                                   |
| compliance.                       |                                   |
|                                   |                                   |
| Inspection of the licensee=s      |                                   |
| Radiological Material Control     |                                   |
| program is to verify that         |                                   |
| licensed radioactive material is  |                                   |
| controlled in accordance with the |                                   |
| requirements of 10 CFR Part 20.   |                                   |
| The focus is to ensure that the   |                                   |
| licensee has a program,           |                                   |
| procedures, and equipment to      |                                   |
| survey potentially contaminated   |                                   |
| material and equipment to ensure  |                                   |
| that licensed radioactive         |                                   |
| material is not inadvertently     |                                   |
| released into the public area.    |                                   |
| The inspection includes direct    |                                   |
| observation of control points the |                                   |
| licensee uses to survey and       |                                   |
| release material and equipment.   |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** The REMP is required   |                                   |
| by Criterion 64 of Appendix A to  |                                   |
| 10 CFR Part 50. The REMP          |                                   |
| supplements the radiological      |                                   |
| effluent monitoring program by    |                                   |
| verifying that any measurable     |                                   |
| concentrations of licensed        |                                   |
| radioactive material and levels   |                                   |
| of radiation in the environment   |                                   |
| are in agreement with the values  |                                   |
| calculated by the licensee=s      |                                   |
| radiological effluent monitoring  |                                   |
| program. The licensee is required |                                   |
| to implement the REMP in          |                                   |
| accordance with its Technical     |                                   |
| Specifications and ODCM. The NRC  |                                   |
| has determined that an            |                                   |
| independent assessment of         |                                   |
| performance in this area is       |                                   |
| necessary to ensure that adequate |                                   |
| protection of the public health   |                                   |
| and safety is maintained.         |                                   |
|                                   |                                   |
| The inspection of the             |                                   |
| Radiological Material Control     |                                   |
| program is to ensure that         |                                   |
| licensed radioactive material is  |                                   |
| controlled in accordance with 10  |                                   |
| CFR Part 20. 10 CFR Part 20,      |                                   |
| Subpart K ‑ Waste Disposal        |                                   |
| contains the acceptable ways to   |                                   |
| dispose of licensed radioactive   |                                   |
| material. Additionally, 10 CFR    |                                   |
| Part 20, Subpart F ‑ Survey and   |                                   |
| Monitoring contains the           |                                   |
| requirement that a radiation      |                                   |
| survey must be performed to       |                                   |
| assess the potential radiological |                                   |
| hazard of licensed radioactive    |                                   |
| material. In combination, these   |                                   |
| requirements form the basis of    |                                   |
| NRC=s inspection program for      |                                   |
| radioactive material control      |                                   |
| programs.                         |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** There |                                   |
| are no Performance Indicators for |                                   |
| these areas.                      |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| None                              |                                   |
+-----------------------------------+-----------------------------------+

Figure 34 IP 71122.03 Basis Summary Sheet

+----------------------------------+-----------------------------------+
| **Basis Summary Sheet**          |                                   |
+==================================+===================================+
| **Inspectable Area:** Discrepant |                                   |
| or Unreported Performance        |                                   |
| Indicator Data                   |                                   |
+----------------------------------+-----------------------------------+
| **Cornerstone(s):** All Seven    | **Inspection Procedure:** IP      |
|                                  | 71150                             |
+----------------------------------+-----------------------------------+
| **Scope:** In the absence of     |                                   |
| reliable licensee‑provided       |                                   |
| performance indicator (PI) data, |                                   |
| the NRC inspector either         |                                   |
| independently obtains PI data or |                                   |
| performs inspections in order to |                                   |
| obtain insights on licensee      |                                   |
| performance.                     |                                   |
+----------------------------------+-----------------------------------+
| **Basis:** SECY‑99‑007 and this  |                                   |
| basis document describe the      |                                   |
| cornerstone attributes           |                                   |
| considered in the development of |                                   |
| each PI. In the absence of       |                                   |
| reliable data for a PI, the      |                                   |
| region performs baseline and     |                                   |
| other inspections which cover    |                                   |
| these attributes.                |                                   |
|                                  |                                   |
| As a function of the particular  |                                   |
| PI, NRC effort for independent   |                                   |
| collection of PI data may be     |                                   |
| significantly greater than for   |                                   |
| the sampling done in PI          |                                   |
| verification, per IP 71151.      |                                   |
| Resource estimates for NRC       |                                   |
| inspection in lieu of obtaining  |                                   |
| PI data are based upon the       |                                   |
| underlying framework of the      |                                   |
| cornerstone, baseline and other  |                                   |
| inspections that could provide   |                                   |
| insights into the cornerstone    |                                   |
| attributes, and the level of     |                                   |
| effort required to achieve the   |                                   |
| inspection objective.            |                                   |
+----------------------------------+-----------------------------------+
| **Significant Changes in Scope   |                                   |
| or Basis:**                      |                                   |
|                                  |                                   |
| September 2000 - Issued to       |                                   |
| obtain PI data when licensees    |                                   |
| fail to provide PI data, or      |                                   |
| provide data having major        |                                   |
| discrepancies, or when NRC loses |                                   |
| confidence in the licensee\'s    |                                   |
| ability to collect and report    |                                   |
| PIs. The IP will also utilize    |                                   |
| inspections for providing        |                                   |
| licensee performance insights    |                                   |
| when NRC is unable to obtain     |                                   |
| reliable PI data.                |                                   |
|                                  |                                   |
| March 2001 - Revised to better   |                                   |
| define the criteria of NRC       |                                   |
| losing confidence in a           |                                   |
| licensee\'s ability to collect   |                                   |
| and report performance           |                                   |
| indicators.                      |                                   |
+----------------------------------+-----------------------------------+

Figure 35 IP 71150 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Performance |                                   |
| Indicator Verification            |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** All Seven     | **Inspection Procedure:** IP      |
|                                   | 71151                             |
+-----------------------------------+-----------------------------------+
| **Scope:** This item includes all |                                   |
| 18 performance indicators (PIs).  |                                   |
| In the verification process,      |                                   |
| historical data prior to ROP      |                                   |
| initial implementation shall not  |                                   |
| be verified unless it pertains to |                                   |
| the safety system unavailability  |                                   |
| PI.                               |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** The objective of this  |                                   |
| inspection is to perform periodic |                                   |
| reviews of PI data to determine   |                                   |
| its accuracy and completeness. PI |                                   |
| verification inspections should   |                                   |
| consist of a \"sampling\" of PI   |                                   |
| data, not validation of the PI    |                                   |
| value.                            |                                   |
|                                   |                                   |
| Each performance indicator will   |                                   |
| be verified once a year. The      |                                   |
| performance indicator             |                                   |
| verifications will be planned     |                                   |
| inspections during which either   |                                   |
| the resident or regional          |                                   |
| inspector will review a sample of |                                   |
| plant records and data against    |                                   |
| the reported performance          |                                   |
| indicators. In addition to the    |                                   |
| review of various plant records,  |                                   |
| the inspector may also, where     |                                   |
| applicable and as needed, observe |                                   |
| the plant activity that generates |                                   |
| a PI data input. These            |                                   |
| observations are performed as     |                                   |
| part of the various inspectable   |                                   |
| areas within the cornerstone      |                                   |
| inspection procedures.            |                                   |
|                                   |                                   |
| A review of licensee self         |                                   |
| assessment shall not be           |                                   |
| substituted for independent       |                                   |
| inspector verification of PIs.    |                                   |
| Inspection intervals for each PI  |                                   |
| should not exceed 15 months, to   |                                   |
| allow some flexibility in         |                                   |
| independently verifying all the   |                                   |
| PIs annually.                     |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| March 2001 ‑ Provided guidance    |                                   |
| for the documentation of minor PI |                                   |
| reporting discrepancies to be     |                                   |
| consistent with the application   |                                   |
| of 10 CFR 50.9 per the revised    |                                   |
| enforcement policy. With a few    |                                   |
| exceptions, minor reporting       |                                   |
| discrepancies should not be       |                                   |
| documented.                       |                                   |
+-----------------------------------+-----------------------------------+

Figure 36 IP 71151 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:**             |                                   |
| Identification and Resolution of  |                                   |
| Problems/Issues                   |                                   |
+-----------------------------------+-----------------------------------+
| **Cornerstone(s):** All seven     | **Inspection Procedure:** IP      |
|                                   | 71152                             |
+-----------------------------------+-----------------------------------+
| **Scope:** This item will verify  |                                   |
| that the licensee has an          |                                   |
| effective problem identification  |                                   |
| and resolution program. Problem   |                                   |
| identification and resolution     |                                   |
| refers to: (1) the deficiency     |                                   |
| reporting process; (2) licensee   |                                   |
| self‑assessments; and (3) Quality |                                   |
| Assurance audits. Additionally,   |                                   |
| in some plants each department    |                                   |
| may have its own problem          |                                   |
| identification and resolution     |                                   |
| program. The focus of the         |                                   |
| inspection is on the licensee=s   |                                   |
| effectiveness in identifying,     |                                   |
| resolving and preventing risk     |                                   |
| significant problems.             |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** The objective of this  |                                   |
| inspection is to ensure that the  |                                   |
| licensee effectively assesses     |                                   |
| performance to identify and       |                                   |
| correct situations that could     |                                   |
| impact the cornerstone            |                                   |
| objectives.                       |                                   |
|                                   |                                   |
| An effective problem              |                                   |
| identification and resolution     |                                   |
| program is the primary means of   |                                   |
| reducing risk by correcting       |                                   |
| deficiencies involving people     |                                   |
| (i.e., training, knowledge and    |                                   |
| skills), processes (i.e.,         |                                   |
| procedures and programs), and     |                                   |
| equipment (i.e., design and       |                                   |
| maintenance) before they manifest |                                   |
| in a significant event affecting  |                                   |
| the health and safety of workers  |                                   |
| or the public. Industry           |                                   |
| experience indicates that         |                                   |
| licensees having an effective     |                                   |
| program for identifying and       |                                   |
| resolving problems also have a    |                                   |
| reduced frequency of events.      |                                   |
|                                   |                                   |
| The inspection should verify      |                                   |
| that: (1) the licensee=s          |                                   |
| assessments of problems and       |                                   |
| issues were of sufficient scope   |                                   |
| to address the key attributes of  |                                   |
| the cornerstone; (2) the risk     |                                   |
| significance of the findings was  |                                   |
| properly assessed; (3) root cause |                                   |
| analyses and corrective actions   |                                   |
| were timely and adequate to       |                                   |
| prevent recurrence; (4) industry  |                                   |
| and NRC generic issues were       |                                   |
| considered; (5) required reports  |                                   |
| to the Commission or input to a   |                                   |
| PI were made; and (6) the         |                                   |
| performance trend indicated by    |                                   |
| the sample set was consistent     |                                   |
| with the applicable PIs.          |                                   |
|                                   |                                   |
| Additional sampling of the        |                                   |
| licensee=s performance assessment |                                   |
| feedback loop is required if: (1) |                                   |
| recurrent issues or highly risk   |                                   |
| significant findings were         |                                   |
| identified; (2) adequate          |                                   |
| corrective actions were not taken |                                   |
| in response to a declining trend  |                                   |
| or performance above a PI         |                                   |
| threshold; or (3) the NRC or      |                                   |
| licensee assessment results       |                                   |
| indicate risk significant         |                                   |
| findings that should have been    |                                   |
| manifested in a negative PI       |                                   |
| trend.                            |                                   |
|                                   |                                   |
| An observed discrepance between   |                                   |
| PI data and NRC or licensee       |                                   |
| findings is indication that       |                                   |
| additional review of PRA          |                                   |
| assumptions, re‑verification of   |                                   |
| applicable PIs and an assessment  |                                   |
| of changing risk may be required. |                                   |
+-----------------------------------+-----------------------------------+
| **Performance Indicators:** None  |                                   |
| of the established PIs cover this |                                   |
| area. However, some insight may   |                                   |
| be obtained from the PIs          |                                   |
| developed for each cornerstone,   |                                   |
| which may reduce the overall      |                                   |
| inspection effort in this area.   |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes in Scope or |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| December 2001 ‑ Decreased the     |                                   |
| frequency of the inspection from  |                                   |
| annual to biennial and added the  |                                   |
| inspection of three to six PI&R   |                                   |
| samples per year. Based on        |                                   |
| experience and lessons learned    |                                   |
| during initial implementation, it |                                   |
| was determined that an annual     |                                   |
| team inspection into PI&R was not |                                   |
| necessary to gain insights into   |                                   |
| licensee performance. This was    |                                   |
| due to the other methods          |                                   |
| available in the inspection       |                                   |
| program to assess PI&R more       |                                   |
| frequently, and the fact that it  |                                   |
| is not likely that significant    |                                   |
| PI&R program degradations would   |                                   |
| occur from one year to the next.  |                                   |
|                                   |                                   |
| September 2003 - revised to       |                                   |
| incorporate recommendations made  |                                   |
| by the PI&R focus group to        |                                   |
| address several items from the    |                                   |
| Davis-Besse Lessons Learned Task  |                                   |
| Force. The changes include        |                                   |
| enhanced requirements regarding   |                                   |
| the routine PI&R reviews          |                                   |
| conducted by resident inspectors, |                                   |
| biennial reviews of longstanding  |                                   |
| issues, and biennial reviews of   |                                   |
| operating experience issues.      |                                   |
+-----------------------------------+-----------------------------------+

Figure 37 IP 71152 Basis Summary Sheet

+----------------------------------+-----------------------------------+
| **Basis Summary Sheet**          |                                   |
+==================================+===================================+
| **Inspectable Area:** Event      |                                   |
| Followup                         |                                   |
+----------------------------------+-----------------------------------+
| **Cornerstone(s):** All Seven    | **Inspection Procedure:** IP      |
|                                  | 71153                             |
+----------------------------------+-----------------------------------+
| **Scope:** Evaluate licensee     |                                   |
| events and degraded conditions   |                                   |
| regarding plant status and       |                                   |
| performance of                   |                                   |
| equipment/operators in order to  |                                   |
| provide input to senior          |                                   |
| management and risk analysts in  |                                   |
| determining the need for an      |                                   |
| Incident Investigation Team      |                                   |
| (IIT), Augmented Investigation   |                                   |
| Team (AIT), or Special           |                                   |
| Inspection (SI). Review written  |                                   |
| event reports.                   |                                   |
+----------------------------------+-----------------------------------+
| **Basis:** In accordance with    |                                   |
| Management Directive 8.3, \"NRC  |                                   |
| Incident Investigation           |                                   |
| Program\", senior NRC management |                                   |
| makes decisions regarding the    |                                   |
| level of investigatory response  |                                   |
| for a significant operational    |                                   |
| event or degraded condition.     |                                   |
| These decisions are based upon   |                                   |
| deterministic and risk criteria. |                                   |
| On‑site inspectors review plant  |                                   |
| status and equipment/operator    |                                   |
| performance in order to provide  |                                   |
| inputs to senior management and  |                                   |
| risk analysts as required to     |                                   |
| evaluate event/degraded          |                                   |
| condition regarding the          |                                   |
| deterministic and risk criteria. |                                   |
|                                  |                                   |
| Inspector effort for events and  |                                   |
| degraded conditions may range    |                                   |
| from minimal up to 24 hours for  |                                   |
| significant operational events   |                                   |
| to allow the inspectors to       |                                   |
| gather sufficient information to |                                   |
| determine the need for an SI,    |                                   |
| AIT, or IIT per the MD 8.3       |                                   |
| criteria. LER review may range   |                                   |
| from 1‑8 hours depending on the  |                                   |
| significance and complexity of   |                                   |
| the issue documented.            |                                   |
+----------------------------------+-----------------------------------+
| **Significant Changes in Scope   |                                   |
| or Basis:**                      |                                   |
|                                  |                                   |
| April 2000 - revised to provide  |                                   |
| inspection requirements and      |                                   |
| guidance for review of event     |                                   |
| reports                          |                                   |
|                                  |                                   |
| March 2001 - revised to better   |                                   |
| define the scope of the          |                                   |
| inspection procedure (IP), to    |                                   |
| expand the definition of power   |                                   |
| reactor events to include        |                                   |
| degraded conditions, and to      |                                   |
| integrate the IP with the        |                                   |
| options for inspection           |                                   |
| activities related to the        |                                   |
| deterministic and risk criteria  |                                   |
| in Management Directive 8.3      |                                   |
|                                  |                                   |
| January 2002 - revised to delete |                                   |
| the previous Appendix A since    |                                   |
| that material was included in MD |                                   |
| 8.3 It also clarifies that       |                                   |
| written LERs are actuations, as  |                                   |
| allowed in 10 CFR 50.73.         |                                   |
|                                  |                                   |
| June 2003 - revised to provide   |                                   |
| clarification that the risk      |                                   |
| metric for events is Conditional |                                   |
| Core Damage Probability (CCDP)   |                                   |
| and the metric for degraded      |                                   |
| conditions is incremental CCDP.  |                                   |
| Also this revision lists         |                                   |
| examples of events addressed by  |                                   |
| this IP in cornerstones outside  |                                   |
| of reactor safety.               |                                   |
+----------------------------------+-----------------------------------+

Figure 38 IP 71153 Basis Summary Sheet

+---------------------------------------+------------------------------+
| **Basis Summary Sheet**               |                              |
+=======================================+==============================+
| **Title:** Light‑Water Reactor        | **Procedure Number:** IMC    |
| Inspection ProgramCOperations Phase   | 2515                         |
+---------------------------------------+------------------------------+
| **Scope:** All commercial power       |                              |
| reactors licensed to operate until    |                              |
| permanently shut down, when they      |                              |
| enter the post‑operational phase      |                              |
| (after the certification date for     |                              |
| removing all nuclear fuel from the    |                              |
| reactor vessel \[10 CFR               |                              |
| 50.82(a)(1)(ii)\])                    |                              |
+---------------------------------------+------------------------------+
| **Basis:** Atomic Energy Act;         |                              |
| 10CFR50.70, \"Inspections\"           |                              |
+---------------------------------------+------------------------------+
| **Significant Changes in Scope or     |                              |
| Basis:**                              |                              |
|                                       |                              |
| April 2000 ‑ Rewritten to accommodate |                              |
| the newly implemented ROP,            |                              |
| recognizing the risk‑informed         |                              |
| baseline inspection program,          |                              |
| supplemental inspections,             |                              |
| cornerstones, and performance         |                              |
| indicators. Includes a discussion of  |                              |
| ROP framework and inspection=s role   |                              |
| in it.                                |                              |
|                                       |                              |
| January 2002 - Revised to clarify     |                              |
| guidance for distributing inspection  |                              |
| effort across units at multi-unit     |                              |
| sites, and focusing efforts if no     |                              |
| inspection opportunities area         |                              |
| available.                            |                              |
|                                       |                              |
| January 2003 - Revised to define what |                              |
| constitutes a baseline inspection     |                              |
| program completion for an annual ROP  |                              |
| inspection cycle.                     |                              |
|                                       |                              |
| February 2004 - Revised to reflect    |                              |
| changes to define the inspection      |                              |
| periodicity requirements for biennial |                              |
| and triennial inspections. Revised to |                              |
| allow early assignment of replacement |                              |
| senior and resident inspectors to a   |                              |
| site prior to the end of the tour of  |                              |
| the incumbent.                        |                              |
|                                       |                              |
| July 2005-Revised to address          |                              |
| recommendations from the Office of    |                              |
| Inspector General\'s audit of the     |                              |
| NRC\'s baseline inspection program:   |                              |
|                                       |                              |
| -   Provided guidance on inspection   |                              |
|     program expectation that nominal  |                              |
|     number of samples should be       |                              |
|     inspected for each inspection     |                              |
|     procedure during a ROP cycle.     |                              |
|                                       |                              |
| -   Provided additional management    |                              |
|     guidance for assigning inspectors |                              |
|     to perform inspection procedures  |                              |
|     to ensure that inspectors are     |                              |
|     adequately qualified for their    |                              |
|     assignments.                      |                              |
|                                       |                              |
| -   Improved inspection guidance on   |                              |
|     whether performance of one        |                              |
|     inspection procedure sample can   |                              |
|     be counted as a sample for        |                              |
|     another                           |                              |
|                                       |                              |
| -   Clarified expectations and        |                              |
|     requirements for which inspection |                              |
|     procedures cannot be deferred,    |                              |
|     plants where procedures cannot be |                              |
|     deferred, criteria for deferring  |                              |
|     a procedure and reporting         |                              |
|     requirements when inspections are |                              |
|     deferred                          |                              |
|                                       |                              |
| -   Added a program requirement for   |                              |
|     regions to maintain an inspection |                              |
|     tracking system so that no more   |                              |
|     than four inspection procedures   |                              |
|     are deferred in a calendar year.  |                              |
+---------------------------------------+------------------------------+

Figure 39 IMC 2515 Basis Summary Sheet

+---------------------------------------+------------------------------+
| **Basis Summary Sheet**               |                              |
+=======================================+==============================+
| **Title:** Risk‑Informed Baseline     | **Procedure Number:** IMC    |
| Inspection Program                    | 2515, Appendix A             |
+---------------------------------------+------------------------------+
| **Scope:** All commercial power       |                              |
| reactors licensed to operate until    |                              |
| permanently shut down and not in an   |                              |
| extended shut down for performance    |                              |
| problems (IMC 0350)                   |                              |
+---------------------------------------+------------------------------+
| **Basis:** Structure and scope of the |                              |
| program based on risk‑informed        |                              |
| decisions on what aspects of licensed |                              |
| operations are important to safety    |                              |
| and risk. Structure, original areas   |                              |
| for inspection, and scope of the      |                              |
| areas are described in SECY‑99‑007,   |                              |
| which formed the basis for the        |                              |
| inspection procedure bases documents. |                              |
| Scope of inspectable areas based on   |                              |
| applicability of any performance      |                              |
| indicators within the area.           |                              |
+---------------------------------------+------------------------------+
| **Significant Changes in Scope or     |                              |
| Basis:**                              |                              |
|                                       |                              |
| April 2000 ‑ Essentially a new        |                              |
| document for the baseline inspection  |                              |
| program. Explains the concept and     |                              |
| philosophies behind the ROP and       |                              |
| baseline inspection concepts.         |                              |
|                                       |                              |
| September 2000 ‑ Revised to correct   |                              |
| the frequency listed for baseline IP  |                              |
| 71111.11 from A/B to Q/B, and to      |                              |
| reflect the change in frequency for   |                              |
| 71130.03 from biennial to triennial.  |                              |
| No change in hours has resulted from  |                              |
| this change.                          |                              |
|                                       |                              |
| March 2001 ‑ Added guidance to        |                              |
| clarify how to close IPs with fewer   |                              |
| samples inspected. Explains the       |                              |
| meaning of the cornerstone tables in  |                              |
| the attachments to IP 71111. Other    |                              |
| changes included editorial changes    |                              |
| and removing duplication with IMC     |                              |
| 2515.                                 |                              |
+---------------------------------------+------------------------------+

Figure 40 IMC 2515, Appendix A Basis Summary Sheet

+---------------------------------------+------------------------------+
| **Basis Summary Sheet**               |                              |
+=======================================+==============================+
| **Title:** Supplemental Inspection    | **Procedure Number:** IMC    |
| Program                               | 2515, Appendix B             |
+---------------------------------------+------------------------------+
| **Scope:** All Seven                  |                              |
+---------------------------------------+------------------------------+
| **Basis:** The NRC=s revised          |                              |
| inspection program includes three     |                              |
| parts: baseline inspections; generic  |                              |
| safety issues and special             |                              |
| inspections; and supplemental         |                              |
| inspections performed as a result of  |                              |
| risk significant performance issues.  |                              |
| The inspection program is designed to |                              |
| apply NRC inspection assets in an     |                              |
| increasing manner when risk           |                              |
| significant performance issues are    |                              |
| identified, either by inspection      |                              |
| findings evaluated using the          |                              |
| significance determination process    |                              |
| (SDP) or when performance indicator   |                              |
| thresholds are exceeded. Accordingly, |                              |
| following the identification of an    |                              |
| inspection finding categorized as     |                              |
| risk significant (i.e., White,        |                              |
| Yellow, or Red) via the SDP, or when  |                              |
| a performance indicator exceeds the   |                              |
| \"licensee response band\" threshold, |                              |
| the NRC regional office will perform  |                              |
| supplemental inspection(s). The scope |                              |
| and breadth of these inspections will |                              |
| be based upon the guidance provided   |                              |
| in the NRC=s assessment \"Action      |                              |
| Matrix\" and the Supplemental         |                              |
| Inspection Table (included in 2515    |                              |
| Appendix B). The supplemental         |                              |
| inspection program is designed to     |                              |
| support the NRC=s goals of            |                              |
| maintaining safety, enhancing         |                              |
| openness, improving the effectiveness |                              |
| and efficiency of the regulatory      |                              |
| process, and reducing unnecessary     |                              |
| regulatory burden.                    |                              |
+---------------------------------------+------------------------------+
| **Significant Changes in Scope or     |                              |
| Basis:**                              |                              |
|                                       |                              |
| September 2000 - revised to include   |                              |
| newly issues IP 62708,                |                              |
| AMotor-Operated Valve Capability@ and |                              |
| to delete IP 50001, ASteam Generator  |                              |
| Replacement Inspection.@ IP 50001 has |                              |
| been moved to IMC 2515, Appendix C.   |                              |
|                                       |                              |
| March 2001 - revised to include newly |                              |
| issued IP 62709, AConfiguration Risk  |                              |
| Assessment and Risk Management        |                              |
| Process.@                             |                              |
|                                       |                              |
| January 2002 - revised to include new |                              |
| Inspection Procedure 62710,           |                              |
| APower-Operated Gate Valve Pressure   |                              |
| Locking and Thermal Binding.@         |                              |
+---------------------------------------+------------------------------+

Figure 41 IMC 2515, Appendix B Basis Summary Sheet

+---------------------------------------+------------------------------+
| **Basis Summary Sheet**               |                              |
+=======================================+==============================+
| **Title:** Special and Infrequently   | **Procedure Number:** IMC    |
| Performed Inspections                 | 2515, Appendix C             |
+---------------------------------------+------------------------------+
| **Scope:** Expected but infrequent    |                              |
| conditions that are outside of the    |                              |
| ROP but warrant NRC oversight.        |                              |
+---------------------------------------+------------------------------+
| **Basis:** The ROP was based on       |                              |
| maintaining safety during normal,     |                              |
| routine operational conditions,       |                              |
| including regularly scheduled         |                              |
| outages. Nonroutine, non-normal       |                              |
| conditions that can have an affect on |                              |
| plant conditions or performance are   |                              |
| overseen on an *ad hoc* basis after   |                              |
| approval by the regional              |                              |
| administrator.                        |                              |
+---------------------------------------+------------------------------+
| **Significant Changes in Scope or     |                              |
| Basis:**                              |                              |
|                                       |                              |
| April 2000 ‑ Initial issuance of      |                              |
| appendix C for ROP.                   |                              |
|                                       |                              |
| September 2000 ‑ Added three IPs that |                              |
| were part of the previous program and |                              |
| are expected to be used infrequently  |                              |
| in the current program: 50001, steam  |                              |
| generator replacement; 92050, QA for  |                              |
| extended construction delays; and     |                              |
| 36100, Part 21 inspections at nuclear |                              |
| power reactors.                       |                              |
|                                       |                              |
| March 2001 ‑ Added IP 60853, on‑site  |                              |
| ISFSI construction. This was added to |                              |
| Appendix C to assure it=s scheduled   |                              |
| should the need arise before IMC 2690 |                              |
| is revised.                           |                              |
|                                       |                              |
| October 2002 - revised to list        |                              |
| Independent Spent Fuel Storage        |                              |
| (ISFSI) Installation inspection       |                              |
| procedures that are funded for NRR    |                              |
| inspections at operating reactor      |                              |
| sites.                                |                              |
|                                       |                              |
| December 2002 - revised to include    |                              |
| addition of 71003, APost Approval     |                              |
| Site Inspection for License Renewal@  |                              |
|                                       |                              |
| February 2003 - revised to include IP |                              |
| 71007, AReactor Vessel Head           |                              |
| Replacement Inspection.@              |                              |
|                                       |                              |
| May 2004 - revised to include         |                              |
| Inspection Procedure for inspecting   |                              |
| Independent Spent Fuel Storage        |                              |
| Installations (ISFSIs) at operating   |                              |
| plants as well as to add Inspection   |                              |
| Procedures 71004, APower Uprate,@ and |                              |
| 71005, AInspector Review of           |                              |
| Licensing-Related Information.@       |                              |
+---------------------------------------+------------------------------+

Figure 42 IMC 2515, Appendix C Basis Summary Sheet

+---------------------------------------+------------------------------+
| **Basis Summary Sheet**               |                              |
+=======================================+==============================+
| **Title:** Plant Status               | **Procedure Number:** IMC    |
|                                       | 2515, Appendix D             |
+---------------------------------------+------------------------------+
| **Scope:** Periodic tours of areas of |                              |
| the plant important to safety and     |                              |
| observation of planning and status    |                              |
| meetings.                             |                              |
+---------------------------------------+------------------------------+
| **Basis:** An important               |                              |
| responsibility of the resident        |                              |
| inspectors is to be aware of plant    |                              |
| conditions and activities. Plant      |                              |
| status provides the mechanism for     |                              |
| residents to tour areas of their      |                              |
| facilities and observe meetings that  |                              |
| would otherwise be limited under the  |                              |
| routine baseline inspection program.  |                              |
| Although the baseline inspection      |                              |
| program is planned, the resident=s    |                              |
| portion is highly dependent on        |                              |
| day‑to‑day activities in the plant.   |                              |
| Plant status, therefore, allows the   |                              |
| residents to determine what is        |                              |
| happening in the plant to better plan |                              |
| which inspections are most            |                              |
| appropriate.                          |                              |
|                                       |                              |
| The plant status activities were      |                              |
| direct inspection under the previous  |                              |
| program through IP 71750, \"Plant     |                              |
| Operations.\" Plant status was        |                              |
| changed from direct inspection effort |                              |
| to other direct effort in the ROP     |                              |
| because it more closely relates to    |                              |
| inspection preparation than actual    |                              |
| inspection.                           |                              |
|                                       |                              |
| Plant status is also related to       |                              |
| performance indicator verification.   |                              |
| Because the resident inspectors will  |                              |
| be frequently touring various areas   |                              |
| of the plant, it is more efficient to |                              |
| have the residents periodically check |                              |
| certain parameters (such as locked    |                              |
| high radiation barriers) during plant |                              |
| status tours than to send an          |                              |
| inspector into the plant for just     |                              |
| that one purpose.                     |                              |
+---------------------------------------+------------------------------+
| **Significant Changes in Scope or     |                              |
| Basis:**                              |                              |
|                                       |                              |
| April 2000 ‑ Initial issuance of      |                              |
| Appendix D.                           |                              |
|                                       |                              |
| September 2003 - Revised to provide   |                              |
| guidance to an inspector on the       |                              |
| requirement to inform the Materials   |                              |
| and Chemical Engineering Branch, NRR, |                              |
| of steam generator tube leaks of      |                              |
| greater than 3 gallons per day.       |                              |
|                                       |                              |
| May 2004 - Revised to provide         |                              |
| guidance to ensure that the licensee  |                              |
| properly monitors for RCS pressure    |                              |
| boundary leakage or potentially       |                              |
| unidentified leakage exceeding        |                              |
| technical specifications limits.      |                              |
| Additional guidance was provided to   |                              |
| monitor licensee=s actions when the   |                              |
| licensee is operating within multiple |                              |
| or repetitive, or unplanned TS action |                              |
| statement entries and to review       |                              |
| licensee=s corrective action entry    |                              |
| summary reports.                      |                              |
|                                       |                              |
| January 2005 - (Change Notice 05-003) |                              |
| IMC 2515, App. D, has been revised to |                              |
| require inspectors to monitor and     |                              |
| trend RCS leakage indications. The    |                              |
| change requires inspectors to review  |                              |
| licensee procedures and action plans  |                              |
| to identify sources of RCS            |                              |
| unidentified leakage. In addition,    |                              |
| guidance and techniques necessary for |                              |
| assessing potential adverse trends    |                              |
| and action levels in response to      |                              |
| increasing levels of RCS unidentified |                              |
| leakage have been provided as an      |                              |
| attachment to this Appendix.          |                              |
+---------------------------------------+------------------------------+

Figure 43 IMC 2515, Appendix D Basis Summary Sheet

+---------------------------------------+------------------------------+
| **Basis Summary Sheet**               |                              |
+=======================================+==============================+
| **Title:** Inspection For One Or Two  | **Procedure Number:** IP     |
| White Inputs In a Strategic           | 95001                        |
| Performance Area                      |                              |
+---------------------------------------+------------------------------+
| **Scope:** This procedure provides    |                              |
| the supplemental response for one or  |                              |
| two White inputs in a strategic       |                              |
| performance area.                     |                              |
+---------------------------------------+------------------------------+
| **Basis:** In order to provide for    |                              |
| adequate protection of public health  |                              |
| and safety, once a risk significant   |                              |
| performance issue is identified, the  |                              |
| NRC needs to ensure that licensees    |                              |
| take actions to identify the causes   |                              |
| of the performance issue and preclude |                              |
| repetition. The most effective and    |                              |
| efficient way for the NRC to          |                              |
| accomplish this objective is allow    |                              |
| the licensee the opportunity to       |                              |
| perform their own evaluation of the   |                              |
| performance issue, and then perform a |                              |
| review of the licensee=s evaluation.  |                              |
| The inspection requirements contained |                              |
| in this procedure represent a         |                              |
| comprehensive set of attributes       |                              |
| related to problem identification,    |                              |
| root cause analysis, and              |                              |
| establishment of corrective actions.  |                              |
| In order to ensure that the causes of |                              |
| the performance issue are identified  |                              |
| and that effective corrective actions |                              |
| are taken to prevent recurrence, it   |                              |
| is expected that the licensee=s       |                              |
| evaluation will generally need to     |                              |
| address each of the inspection        |                              |
| requirements; however, the depth of   |                              |
| the licensee=s analysis may vary      |                              |
| depending on the significance and     |                              |
| complexity of the issue(s). While the |                              |
| inspection requirements do not        |                              |
| necessarily represent NRC             |                              |
| requirements for the licensee,        |                              |
| significant weaknesses in the         |                              |
| licensee=s evaluation may require     |                              |
| that the NRC conduct additional       |                              |
| inspections to acquire the            |                              |
| information independently. The        |                              |
| inspection requirements should be     |                              |
| independent of the specific root      |                              |
| cause methodology chosen by the       |                              |
| licensee.                             |                              |
+---------------------------------------+------------------------------+
| **Significant Changes in Scope or     |                              |
| Basis:**                              |                              |
|                                       |                              |
| June 2003 - revised to clarify        |                              |
| guidance on extent of condition       |                              |
| review and add guidance for           |                              |
| evaluating whether credit should be   |                              |
| given for Aold design issues.@        |                              |
+---------------------------------------+------------------------------+

Figure 44 IP 95001 Basis Summary Sheet

+---------------------------------------+------------------------------+
| **Basis Summary Sheet**               |                              |
+=======================================+==============================+
| **Title:** Inspection For One         | **Procedure Number:** IP     |
| Degraded Cornerstone Or Any Three     | 95002                        |
| White Inputs In a Strategic           |                              |
| Performance Area                      |                              |
+---------------------------------------+------------------------------+
| **Scope:** This procedure provides    |                              |
| the supplemental response for one     |                              |
| degraded cornerstone or three White   |                              |
| inputs in a strategic performance     |                              |
| area. The inspection requirements are |                              |
| generally applicable for single       |                              |
| inspection findings, multiple         |                              |
| inspection findings, and for          |                              |
| performance issues reported by PIs    |                              |
| that might represent more than one    |                              |
| independent event (e.g. multiple      |                              |
| scrams). The scope of this inspection |                              |
| should include all white or yellow    |                              |
| performance issues (inspection        |                              |
| findings or PIs) in the associated    |                              |
| degraded cornerstone or strategic     |                              |
| performance area. For example, if     |                              |
| this procedure is being performed due |                              |
| to a yellow PI in the mitigating      |                              |
| systems cornerstone, the inspection   |                              |
| scope should also include any white   |                              |
| PIs or inspection findings in that    |                              |
| cornerstone. If the procedure is      |                              |
| being performed due to three white    |                              |
| PIs in the reactor safety strategic   |                              |
| performance area, the inspection      |                              |
| scope should include all white PIs in |                              |
| the reactor safety strategic          |                              |
| performance area.                     |                              |
|                                       |                              |
| In the case where a performance       |                              |
| indicator is associated with multiple |                              |
| events or occurrences, or for         |                              |
| evaluations of multiple performance   |                              |
| issues, it is expected that the       |                              |
| licensee=s evaluation would address   |                              |
| each of the events or occurrences     |                              |
| collectively, as well as              |                              |
| individually. In those instances      |                              |
| where the licensee=s evaluation was   |                              |
| previously reviewed as part of        |                              |
| Inspection Procedure 95001, a         |                              |
| re‑review of the evaluation during    |                              |
| this procedure is not required;       |                              |
| however, a review of the licensee=s   |                              |
| collective evaluation for multiple    |                              |
| performance issues would generally    |                              |
| need to be performed.                 |                              |
+---------------------------------------+------------------------------+
| **Basis:** The inspection             |                              |
| requirements contained in this        |                              |
| supplemental inspection procedure     |                              |
| relate to the minimum set of          |                              |
| information that the NRC will         |                              |
| generally need to acquire in order to |                              |
| assure that the causes of risk        |                              |
| significant performance issues are    |                              |
| identified and that appropriate       |                              |
| corrective actions are taken to       |                              |
| prevent recurrence. While the         |                              |
| inspection requirements are generally |                              |
| written to address individual         |                              |
| performance issues, the procedure may |                              |
| also be utilized to assess the        |                              |
| adequacy of licensee=s evaluations    |                              |
| associated with multiple performance  |                              |
| issues. While these inspection        |                              |
| requirements do not necessarily       |                              |
| represent NRC requirements for the    |                              |
| licensee, significant weaknesses in   |                              |
| the licensee=s evaluation may require |                              |
| that the NRC conduct additional       |                              |
| inspections to acquire the            |                              |
| information independently. It is      |                              |
| recognized that the depth of the      |                              |
| licensee=s evaluation may vary        |                              |
| depending on the significance and     |                              |
| complexity of the issues. In some     |                              |
| cases, the answers to specific        |                              |
| inspection requirements will be       |                              |
| self‑evident with little additional   |                              |
| review or analysis required by the    |                              |
| inspectors.                           |                              |
|                                       |                              |
| This procedure also requires an       |                              |
| independent NRC inspection to inspect |                              |
| the adequacy of the licensee=s extent |                              |
| of condition determination. In order  |                              |
| to accomplish this objective, the     |                              |
| inspection team leader should develop |                              |
| a customized inspection plan using    |                              |
| the applicable portions of the        |                              |
| inspection procedure(s) listed in     |                              |
| Appendix B to Inspection Manual       |                              |
| Chapter 2515. The objective should be |                              |
| to independently sample performance,  |                              |
| as necessary to provide assurance     |                              |
| that the licensee=s evaluation        |                              |
| regarding extent of condition is      |                              |
| sufficiently comprehensive. The       |                              |
| intent is not to re‑perform the       |                              |
| licensee=s evaluation, but is to      |                              |
| assess the validity of the licensee=s |                              |
| evaluation by independently sampling  |                              |
| performance within the key attributes |                              |
| of the cornerstone(s) that are        |                              |
| related to the subject performance    |                              |
| issue.                                |                              |
+---------------------------------------+------------------------------+
| **Significant Changes in Scope or     |                              |
| Basis:**                              |                              |
|                                       |                              |
| March 2001 - revised to provide       |                              |
| additional guidance regarding the     |                              |
| scope of the inspection when multiple |                              |
| issues are identified within the      |                              |
| affected cornerstone(s). It also      |                              |
| provides additional guidance          |                              |
| concerning the inspection requirement |                              |
| to perform an independent extent of   |                              |
| condition review.                     |                              |
|                                       |                              |
| June 2003 - revised to clarify        |                              |
| guidance on extent of condition       |                              |
| review and add guidance for           |                              |
| evaluating whether credit should be   |                              |
| given for Aold design issues.@        |                              |
+---------------------------------------+------------------------------+

Figure 45 IP 95002 Basis Summary Sheet

+---------------------------------------+------------------------------+
| **Basis Summary Sheet**               |                              |
+=======================================+==============================+
| **Title:** Supplemental Inspection    | **Procedure Number:** IP     |
| For Repetitive Degraded Cornerstone,  | 95003                        |
| Multiple Degraded Cornerstone,        |                              |
| Multiple Yellow Inputs, Or One Red    |                              |
| Input                                 |                              |
+---------------------------------------+------------------------------+
| **Scope:** This procedure provides    |                              |
| the supplemental response for         |                              |
| repetitive degraded cornerstones,     |                              |
| multiple degraded cornerstones,       |                              |
| multiple Yellow inputs, or one Red    |                              |
| input to the Assessment Action        |                              |
| Matrix.                               |                              |
+---------------------------------------+------------------------------+
| **Basis:** The intent of this         |                              |
| procedure is to provide the NRC with  |                              |
| supplemental information regarding    |                              |
| licensee performance, as necessary to |                              |
| determine the breadth and depth of    |                              |
| safety, organizational, and           |                              |
| programmatic issues. As such, this    |                              |
| procedure is more diagnostic than     |                              |
| indicative, and includes reviews of   |                              |
| programs and processes not inspected  |                              |
| as part of the baseline inspection    |                              |
| program. While the procedure does     |                              |
| allow for focus to be applied to      |                              |
| areas where performance issues have   |                              |
| been previously identified, the       |                              |
| procedure does require that some      |                              |
| sample reviews be performed for all   |                              |
| key attributes of the effected        |                              |
| strategic performance areas. The      |                              |
| rational behind this is that          |                              |
| additional NRC assurance is required  |                              |
| to ensure public health and safety,   |                              |
| beyond that provided by the baseline  |                              |
| inspection program and the            |                              |
| performance indicators at those       |                              |
| facilities where significant          |                              |
| performance issues have been          |                              |
| identified. The results of this       |                              |
| inspection will aid the NRC in        |                              |
| deciding whether additional           |                              |
| regulatory actions are necessary to   |                              |
| assure public health and safety.      |                              |
| These additional regulatory actions   |                              |
| could include orders, confirmatory    |                              |
| action letters, or additional         |                              |
| supplemental inspections, as          |                              |
| necessary to confirm that corrective  |                              |
| actions to the identified performance |                              |
| concerns have been effective.         |                              |
+---------------------------------------+------------------------------+
| **Significant Changes in Scope or     |                              |
| Basis:**                              |                              |
|                                       |                              |
| January 2002 - revised to incorporate |                              |
| lessons learned from the Indian Point |                              |
| 2 inspections, and adds a section on  |                              |
| security, which was not included in   |                              |
| the initial version of this           |                              |
| procedure. IP 95003.01 (Emergency     |                              |
| Preparedness) inspection procedure    |                              |
| was revised to reflect lessons        |                              |
| learned from Indian Point 2           |                              |
| inspections.                          |                              |
+---------------------------------------+------------------------------+

Figure 46 IP 95003 Basis Summary Sheet

+---------------------------------------+------------------------------+
| **Basis Summary Sheet**               |                              |
+=======================================+==============================+
| **Title:** Special Inspection         | **Procedure Number:** IP     |
|                                       | 93812                        |
+---------------------------------------+------------------------------+
| **Scope:** Provides implementing      |                              |
| procedures for Special Inspection     |                              |
| (SI) responses to operational events  |                              |
| and degraded conditions at power      |                              |
| reactor facilities.                   |                              |
+---------------------------------------+------------------------------+
| **Basis:** In accordance with         |                              |
| Management Directive 8.3, \"NRC       |                              |
| Incident Investigation Program\",     |                              |
| significant operational power reactor |                              |
| events and degraded conditions        |                              |
| meeting specific deterministic        |                              |
| criteria are evaluated for risk based |                              |
| on conditional core damage            |                              |
| probability (CCDP) in order to        |                              |
| determine the level of investigatory  |                              |
| response. An SI is considered where   |                              |
| CCDP is between 10^‑4^ and 10^‑6^.    |                              |
| Resources for an SI are less than for |                              |
| an Augmented Inspection Team (AIT) in |                              |
| that they are less in team size and   |                              |
| not augmented with resources external |                              |
| to the region. Special Inspections    |                              |
| were developed to provide an          |                              |
| additional level of Agency response   |                              |
| for those events where some level of  |                              |
| follow‑up above the baseline effort   |                              |
| is appropriate, but the significance  |                              |
| of the event or degraded condition    |                              |
| does not warrant the resources of an  |                              |
| AIT.                                  |                              |
+---------------------------------------+------------------------------+
| **Significant Changes in Scope or     |                              |
| Basis:**                              |                              |
|                                       |                              |
| March 2001 - revised to provide       |                              |
| consistency with Management Directive |                              |
| (MD) 8.3, ANRC Incident Investigation |                              |
| Program,@ and to provide guidance on  |                              |
| preliminary notifications.            |                              |
|                                       |                              |
| October 2002 - revised to provide     |                              |
| guidance on documenting information   |                              |
| relating to events that is in         |                              |
| addition to that currently required   |                              |
| by IMC 0612, APower Reactor           |                              |
| Inspection Reports,@ such as          |                              |
| description/chronology,               |                              |
| risk-significance, and probable       |                              |
| contributing causes.                  |                              |
|                                       |                              |
| July 2003 - revised to reflect        |                              |
| revision to MD 8.3 and to delete the  |                              |
| prohibition for Special Inspections   |                              |
| to review licensee actions related to |                              |
| plant restart.                        |                              |
+---------------------------------------+------------------------------+

Figure 47 IP 93812 Basis Summary Sheet

+-----------------------------------+-----------------------------------+
| **Basis Summary Sheet**           |                                   |
+===================================+===================================+
| **Inspectable Area:** Oversight   | **Procedure Number:** IMC 0350    |
| of Operating Reactor Facilities   |                                   |
| in a Shutdown Condition Due to    |                                   |
| Significant Performance and/or    |                                   |
| Operational Concerns              |                                   |
+-----------------------------------+-----------------------------------+
| **Scope:** This manual chapter    |                                   |
| will provide regulatory oversight |                                   |
| for NRC actions and activities    |                                   |
| when a plant has been shutdown    |                                   |
| for performance problems and/or   |                                   |
| after a significant event. This   |                                   |
| oversight will include shutdown,  |                                   |
| resolution of risk‑significant    |                                   |
| issues and identification of root |                                   |
| causes prior to restart, as well  |                                   |
| as oversight for a period of time |                                   |
| after restart. During such time   |                                   |
| as a licensee may be under this   |                                   |
| manual chapter guidance, the      |                                   |
| normal revised oversight process  |                                   |
| is suspended.                     |                                   |
+-----------------------------------+-----------------------------------+
| **Basis:** IMC 0350 was revised   |                                   |
| to incorporate a number of        |                                   |
| risk‑informed insights and new    |                                   |
| ROP regulatory guidance and       |                                   |
| policy. The first area of change  |                                   |
| was to establish risk‑informed    |                                   |
| criteria for entry into this IMC. |                                   |
| The entry conditions of this IMC  |                                   |
| requires as a prerequisite that a |                                   |
| licensee=s performance be         |                                   |
| commensurate with the             |                                   |
| multiple/repetitive degraded      |                                   |
| cornerstone column of the Action  |                                   |
| Matrix, as defined by IMC 0305,   |                                   |
| \"Operating Reactor Assessment    |                                   |
| Program,\" and/or be a result of  |                                   |
| a risk‑significant plant event.   |                                   |
|                                   |                                   |
| The second area to be             |                                   |
| risk‑informed was to provide      |                                   |
| regulatory oversight of risk      |                                   |
| significant issues,               |                                   |
| identification of their root      |                                   |
| causes, and identification of the |                                   |
| extent of condition related to    |                                   |
| these root causes once a licensee |                                   |
| is under the IMC 0350 process.    |                                   |
| This approach aids the staff to   |                                   |
| focus on the risk‑significant     |                                   |
| issues and their root causes,     |                                   |
| wherever they originate, while    |                                   |
| increasing the efficiency and     |                                   |
| effectiveness of the regulatory   |                                   |
| oversight by not expending        |                                   |
| resources where there is little   |                                   |
| or no risk impact.                |                                   |
|                                   |                                   |
| The third major area of           |                                   |
| enhancement is establishing       |                                   |
| criteria for exiting the IMC 0350 |                                   |
| process. The length of time of    |                                   |
| post-restart oversight may vary,  |                                   |
| depending on licensee performance |                                   |
| and resolution of identified      |                                   |
| problems, in order to reestablish |                                   |
| applicable reliable PIs and to    |                                   |
| allow the staff to assess         |                                   |
| licensee performance before a     |                                   |
| return to the routine oversight   |                                   |
| process is warranted.             |                                   |
+-----------------------------------+-----------------------------------+
| **Significant Changes and         |                                   |
| Basis:**                          |                                   |
|                                   |                                   |
| March 1990 - Inspection Manual    |                                   |
| Chapter 0350 issued to codify the |                                   |
| EDO=s directives on the actions   |                                   |
| necessary to authorize the        |                                   |
| restart of nuclear power plant    |                                   |
| that is shut down due to          |                                   |
| significant operational or        |                                   |
| management deficiencies. The IMC  |                                   |
| incorporates lessons learned from |                                   |
| recent restart reviews and        |                                   |
| comments from a GAO report issued |                                   |
| on June 6, 1989 entitled ANRC=s   |                                   |
| Restart Actions Appear            |                                   |
| Reasonable - But Criteria         |                                   |
| Needed.@                          |                                   |
|                                   |                                   |
| January 1993 - revised in         |                                   |
| response to the EDO memorandum of |                                   |
| November 23, 1992, to the         |                                   |
| Commission, ACorrective Action    |                                   |
| Plan for Turkey Point Lessons     |                                   |
| Learned.@ The revision            |                                   |
| incorporates a comprehensive      |                                   |
| restart checklist (Appendix A) to |                                   |
| be used in developing a           |                                   |
| plant-specific restart checklist. |                                   |
|                                   |                                   |
| September 1993 - revised in       |                                   |
| response to the July 28, 1993     |                                   |
| memorandum, AReview of NRC=s      |                                   |
| Restart Review Process,@ from the |                                   |
| Office of the EDO to the Office   |                                   |
| of the Inspector General. This    |                                   |
| revision incorporates             |                                   |
| requirements for tracking and     |                                   |
| documenting the resolution of     |                                   |
| restart issues.                   |                                   |
|                                   |                                   |
| April 1997 - revised to           |                                   |
| incorporate objective and         |                                   |
| measurable acceptance criteria    |                                   |
| for evaluating the effectiveness  |                                   |
| of licensee=s corrective action   |                                   |
| plans for restart approval and to |                                   |
| further emphasize the importance  |                                   |
| that the restart issues be        |                                   |
| clearly defined and communicated  |                                   |
| to the licensee.                  |                                   |
|                                   |                                   |
| December 1997 - revised to        |                                   |
| address new applicants for        |                                   |
| operator licenses while a plant   |                                   |
| is in an extended shutdown        |                                   |
| requiring restart approval.       |                                   |
|                                   |                                   |
| March 2000 - revised to           |                                   |
| incorporate policy and guidance   |                                   |
| relating to the revised reactor   |                                   |
| oversight process (ROP).          |                                   |
|                                   |                                   |
| March 2001 ‑ IMC 0350 was revised |                                   |
| to add clarity to the entry       |                                   |
| conditions for implementing this  |                                   |
| IMC stating that as a             |                                   |
| prerequisite, a regulatory hold   |                                   |
| would be in effect, such as a     |                                   |
| Confirmatory Action Letter or an  |                                   |
| Order, prior to implementing this |                                   |
| manual chapter. An additional     |                                   |
| change included clarification to  |                                   |
| encourage the continued           |                                   |
| collection of PI data throughout  |                                   |
| the shutdown and implementation   |                                   |
| of the IMC 0350 process, if       |                                   |
| practical.                        |                                   |
|                                   |                                   |
| December 2003 - revised to        |                                   |
| provide comprehensive correlation |                                   |
| between aspects of the ROP and    |                                   |
| the IMC 0350 process, to provide  |                                   |
| an enhanced structure to the      |                                   |
| inspection approach for IMC 0350  |                                   |
| plants, and to incorporate other  |                                   |
| lessons learned and               |                                   |
| clarifications.                   |                                   |
+-----------------------------------+-----------------------------------+

Figure 48 IMC 0350 Basis Summary Sheet

+------------------------------+-----+-----+-----+-----+-----+-----+
| Table 1 Inspectable Areas by |     |     |     |     |     |     |
| Cornerstone                  |     |     |     |     |     |     |
+==============================+=====+=====+=====+=====+=====+=====+
| Inspectable Area             | I   | M   | B   | Eme | Occ | Pub |
|                              | nit | iti | arr | rge | upa | lic |
|                              | iat | gat | ier | ncy | tio |     |
|                              | ing | ing |     | Pre | nal | Rad |
|                              |     |     | Int | par |     | iat |
|                              | Eve | S   | egr | edn | Rad | ion |
|                              | nts | yst | ity | ess | iat |     |
|                              |     | ems |     |     | ion | Saf |
|                              |     |     |     |     |     | ety |
|                              |     |     |     |     | Saf |     |
|                              |     |     |     |     | ety |     |
+------------------------------+-----+-----+-----+-----+-----+-----+
| Access control to            |     |     |     |     | X   |     |
| radiologically significant   |     |     |     |     |     |     |
| areas                        |     |     |     |     |     |     |
+------------------------------+-----+-----+-----+-----+-----+-----+
| Adverse weather protection   | X   | X   |     |     |     |     |
+------------------------------+-----+-----+-----+-----+-----+-----+
| ALARA planning and controls  |     |     |     |     | X   |     |
+------------------------------+-----+-----+-----+-----+-----+-----+
| Alert and notification       |     |     |     | X   |     |     |
| system testing               |     |     |     |     |     |     |
+------------------------------+-----+-----+-----+-----+-----+-----+
| Drill evaluation             |     |     |     | X   |     |     |
+------------------------------+-----+-----+-----+-----+-----+-----+
| Emergency response           |     |     |     | X   |     |     |
| organization augmentation    |     |     |     |     |     |     |
| testing                      |     |     |     |     |     |     |
+------------------------------+-----+-----+-----+-----+-----+-----+
| Emergency action level and   |     |     |     | X   |     |     |
| emergency plan changes       |     |     |     |     |     |     |
+------------------------------+-----+-----+-----+-----+-----+-----+
| Equipment alignment          | X   | X   | X   |     |     |     |
+------------------------------+-----+-----+-----+-----+-----+-----+
| Evaluations of changes,      | X   | X   | X   |     |     |     |
| tests, or experiments        |     |     |     |     |     |     |
+------------------------------+-----+-----+-----+-----+-----+-----+
| Exercise evaluation          |     |     |     | X   |     |     |
+------------------------------+-----+-----+-----+-----+-----+-----+
| Fire protection              | X   | X   |     |     |     |     |
+------------------------------+-----+-----+-----+-----+-----+-----+
| Flood protection measures    | X   | X   |     |     |     |     |
+------------------------------+-----+-----+-----+-----+-----+-----+
| Heat sink performance        | X   | X   |     |     |     |     |
+------------------------------+-----+-----+-----+-----+-----+-----+
| Identification and           | X   | X   | X   | X   | X   | X   |
| resolution of problems       |     |     |     |     |     |     |
+------------------------------+-----+-----+-----+-----+-----+-----+
| Inservice inspection         | X   |     | X   |     |     |     |
| activities                   |     |     |     |     |     |     |
+------------------------------+-----+-----+-----+-----+-----+-----+
| Licensed operator            |     | X   | X   |     |     |     |
| requalification              |     |     |     |     |     |     |
+------------------------------+-----+-----+-----+-----+-----+-----+

  ------------------------------- ------------ ------------ ----------- -------------- -------------- -----------
  Table 1 Inspectable Areas by                                                                        
  Cornerstone (continued)                                                                             

  Inspectable Area                Initiating   Mitigating   Barrier     Emergency      Occupational   Public
                                  Events       Systems      Integrity   Preparedness   Radiation      Radiation
                                                                                       Safety         Safety

  Maintenance risk assessments    X            X            X                                         
  and emergent work control                                                                           

  Maintenance effectiveness       X            X            X                                         

  Operability evaluations                      X            X                                         

  Operator workarounds                         X                                                      

  Permanent plant modifications                X            X                                         

  Personnel Performance during    X            X            X                                         
  nonroutine evolutions                                                                               

  Post maintenance testing                     X            X                                         

  Radiation monitoring                                                                 X              
  instrumentation                                                                                     

  Radiation worker performance                                                         X              

  Radioactive material processing                                                                     X
  and transportation                                                                                  

  Radioactive Gaseous and liquid                                                                      X
  effluent treatment and                                                                              
  monitoring systems                                                                                  

  Radiological environmental                                                                          X
  monitoring program                                                                                  

  Refueling and outage activities X            X            X                                         

  Safety system design and                     X                                                      
  performance capability                                                                              

  Surveillance testing                         X            X                                         

  Temporary plant modifications                X            X                                         
  ------------------------------- ------------ ------------ ----------- -------------- -------------- -----------

+-----------+--------+-----------------------------+-------------------+
| **Table 2 |        |                             |                   |
| Other     |        |                             |                   |
| I         |        |                             |                   |
| nspection |        |                             |                   |
| Program   |        |                             |                   |
| Elements  |        |                             |                   |
| C         |        |                             |                   |
| onsidered |        |                             |                   |
| But Not   |        |                             |                   |
| I         |        |                             |                   |
| ncluded** |        |                             |                   |
+===========+========+=============================+===================+
| **In      | **C    | **Scope**                   | **Basis for Not   |
| spectable | orners |                             | Including in      |
| Area or   | tone** |                             | Baseline          |
| Program   |        |                             | Inspection        |
| At        |        |                             | Program**         |
| tribute** |        |                             |                   |
+-----------+--------+-----------------------------+-------------------+
| **Piping  | Init   | Equipment performance,      | Reactor coolant   |
| System    | iating | detecting and correcting    | system piping     |
| E         | Events | component degradation       | generally isn\'t  |
| rosion/Co |        |                             | subject to        |
| rrosion** |        |                             | erosion/corrosion |
|           |        |                             | because of the    |
|           |        |                             | materials used,   |
|           |        |                             | water chemistry   |
|           |        |                             | control, and the  |
|           |        |                             | general absence   |
|           |        |                             | of two‑phase      |
|           |        |                             | (water/steam)     |
|           |        |                             | mixtures. Balance |
|           |        |                             | of plant steam    |
|           |        |                             | piping is subject |
|           |        |                             | to                |
|           |        |                             | e                 |
|           |        |                             | rosion/corrosion. |
|           |        |                             | However, because  |
|           |        |                             | they are balance  |
|           |        |                             | of plant (BOP)    |
|           |        |                             | systems, there    |
|           |        |                             | would be little   |
|           |        |                             | risk impact to    |
|           |        |                             | the reactor core. |
|           |        |                             | The primary       |
|           |        |                             | concern for       |
|           |        |                             | erosion/corrosion |
|           |        |                             | in BOP systems is |
|           |        |                             | personnel safety  |
|           |        |                             | rather than       |
|           |        |                             | reactor safety.   |
|           |        |                             | Additionally,     |
|           |        |                             | significance      |
|           |        |                             | failures would be |
|           |        |                             | tracked by        |
|           |        |                             | performance       |
|           |        |                             | indicators such   |
|           |        |                             | as unplanned      |
|           |        |                             | shutdowns.        |
|           |        |                             | Mitigating        |
|           |        |                             | systems are       |
|           |        |                             | sometimes subject |
|           |        |                             | to                |
|           |        |                             | e                 |
|           |        |                             | rosion/corrosion. |
|           |        |                             | However, that     |
|           |        |                             | particular aspect |
|           |        |                             | of a system can   |
|           |        |                             | be reviewed under |
|           |        |                             | the safety system |
|           |        |                             | design inspection |
|           |        |                             | procedure.        |
+-----------+--------+-----------------------------+-------------------+
| **Pre‑Job | Init   | Human performance           | Covered by PI=s   |
| Briefs**  | iating |                             | (transients,      |
|           | Events |                             | scrams, SSU)      |
+-----------+--------+-----------------------------+-------------------+
| **        | Init   | Design. Sources of          | Considered        |
| Operating | iating | experience including NRC    | covered by PI=s   |
| E         | Events | bulletins, notices, generic | (transients,      |
| xperience |        | letters, vendor reports,    | scrams, SSU)      |
| Review**  | Miti   | and Part 21 notifications.  | design‑related    |
|           | gating |                             | inspections       |
|           | S      |                             |                   |
|           | ystems |                             |                   |
+-----------+--------+-----------------------------+-------------------+
| *         | Init   | Configuration control,      | Covered by PI=s   |
| *Operator | iating | effectiveness of            | (transients,      |
| Shift     | Events | communications between      | scrams)           |
| Tu        |        | operating shifts.           |                   |
| rnovers** | Miti   |                             |                   |
|           | gating |                             |                   |
|           | S      |                             |                   |
|           | ystems |                             |                   |
+-----------+--------+-----------------------------+-------------------+

+-----------+--------+-----------------------------+-------------------+
| **Table 2 |        |                             |                   |
| Other     |        |                             |                   |
| I         |        |                             |                   |
| nspection |        |                             |                   |
| Program   |        |                             |                   |
| Elements  |        |                             |                   |
| C         |        |                             |                   |
| onsidered |        |                             |                   |
| But Not   |        |                             |                   |
| Included  |        |                             |                   |
| (con      |        |                             |                   |
| tinued)** |        |                             |                   |
+===========+========+=============================+===================+
| **In      | **C    | **Scope**                   | **Basis for Not   |
| spectable | orners |                             | Including in      |
| Area or   | tone** |                             | Baseline          |
| Program   |        |                             | Inspection        |
| At        |        |                             | Program**         |
| tribute** |        |                             |                   |
+-----------+--------+-----------------------------+-------------------+
| **Testing | Init   | Inspection activities in    | Incorporated into |
| of Pumps  | iating | this area would be focused  | IP 71111.22,      |
| and       | Events | on the effectiveness of the | \"Surveillance    |
| Valves**  |        | licensee=s program for      | Testing\"         |
|           | Miti   | testing of pumps and valves |                   |
|           | gating | as required by ASME Section |                   |
|           | S      | XI. Inspection activities   |                   |
|           | ystems | in this area would include  |                   |
|           |        | a review of test procedure  |                   |
|           |        | adequacy, testing           |                   |
|           |        | methodology, equipment      |                   |
|           |        | trend results and           |                   |
|           |        | observations of selected    |                   |
|           |        | pump performance testing,   |                   |
|           |        | valve stroke time testing,  |                   |
|           |        | relief valve setpoint       |                   |
|           |        | testing, and check valve    |                   |
|           |        | testing.                    |                   |
+-----------+--------+-----------------------------+-------------------+
| **Spent   | Miti   | Structure, systems, and     | A separate        |
| Fuel      | gating | components associated with  | inspection        |
| Cooling** | S      | handling, and providing     | procedure for     |
|           | ystems | cooling for, spent fuel     | spent fuel        |
|           |        | assemblies.                 | cooling systems   |
|           |        |                             | or fuel movement  |
|           |        |                             | was not developed |
|           |        |                             | because the       |
|           |        |                             | baseline          |
|           |        |                             | inspection        |
|           |        |                             | program is        |
|           |        |                             | primarily based   |
|           |        |                             | on the risk       |
|           |        |                             | associated with   |
|           |        |                             | reactor core      |
|           |        |                             | damage when the   |
|           |        |                             | reactor fuel is   |
|           |        |                             | in the reactor    |
|           |        |                             | vessel. However,  |
|           |        |                             | the baseline      |
|           |        |                             | inspection        |
|           |        |                             | procedure for     |
|           |        |                             | refueling and     |
|           |        |                             | outage activities |
|           |        |                             | does include      |
|           |        |                             | spent fuel        |
|           |        |                             | handling and      |
|           |        |                             | operation of      |
|           |        |                             | spent fuel pool   |
|           |        |                             | cooling systems.  |
|           |        |                             | The guidance in   |
|           |        |                             | the procedure     |
|           |        |                             | includes          |
|           |        |                             | verifying         |
|           |        |                             | availability of   |
|           |        |                             | equipment and     |
|           |        |                             | procedures for    |
|           |        |                             | recovery if spent |
|           |        |                             | fuel cooling is   |
|           |        |                             | lost.             |
+-----------+--------+-----------------------------+-------------------+
| **Motor   | Miti   | The NRC has been inspecting | A separate        |
| ‑Operated | gating | licensees= programs for     | inspection        |
| Valves    | S      | assuring proper performance | procedure for     |
| (MOVs)**  | ystems | of MOVs through Temporary   | MOVs was not      |
|           |        | Instruction 2515/109 since  | necessary since   |
|           |        | 1989. The latest revision   | the baseline      |
|           |        | of the temporary            | inspection        |
|           |        | instruction includes        | program provides  |
|           |        | verifying that licensees    | opportunities to  |
|           |        | are trending valve          | inspect MOVs      |
|           |        | performance and closing     | through several   |
|           |        | previously identified       | inspectable areas |
|           |        | issues.                     | such as safety    |
|           |        |                             | system design and |
|           |        |                             | performance       |
|           |        |                             | capability,       |
|           |        |                             | permanent plant   |
|           |        |                             | modifications,    |
|           |        |                             | and surveillance  |
|           |        |                             | testing. Also,    |
|           |        |                             | the baseline      |
|           |        |                             | inspection        |
|           |        |                             | program places an |
|           |        |                             | emphasis on       |
|           |        |                             | continual         |
|           |        |                             | assessment of a   |
|           |        |                             | licensees=        |
|           |        |                             | corrective action |
|           |        |                             | programs, which   |
|           |        |                             | would include     |
|           |        |                             | problems found    |
|           |        |                             | during the        |
|           |        |                             | implementation of |
|           |        |                             | their programs    |
|           |        |                             | for MOVs.         |
+-----------+--------+-----------------------------+-------------------+
| **        | Miti   | Equipment performance and   | Covered by PIs    |
| Equipment | gating | configuration control       | (transients,      |
| Switching | S      |                             | scrams, ssu)      |
| and       | ystems |                             |                   |
| Tagging** |        |                             |                   |
+-----------+--------+-----------------------------+-------------------+
| **Large   | B      | Inspection activities in    | Incorporated into |
| Co        | arrier | this area would be focused  | IP 71111.22,      |
| ntainment | Int    | on the adequacy of the      | \"Surveillance    |
| Isolation | egrity | licensee=s testing program  | Testing\"         |
| Valve     |        | for large containment       |                   |
| Leak Rate |        | isolation valves that       |                   |
| and       |        | provide a direct flow path  |                   |
| Status    |        | from the containment        |                   |
| Verif     |        | atmosphere to outside       |                   |
| ication** |        | containment. At most        |                   |
|           |        | facilities the inspection   |                   |
|           |        | scope would be limited to   |                   |
|           |        | the containment purge and   |                   |
|           |        | ventilation valves and      |                   |
|           |        | personnel access hatches.   |                   |
|           |        | Inspection activities       |                   |
|           |        | related to leak rate        |                   |
|           |        | testing for most of the     |                   |
|           |        | containment isolation       |                   |
|           |        | valves and/or containment   |                   |
|           |        | Integrity issues would be   |                   |
|           |        | captured by the corrective  |                   |
|           |        | action program inspection   |                   |
|           |        | activities.                 |                   |
+-----------+--------+-----------------------------+-------------------+
| **Fuel    | B      | Inspection includes         | A performance     |
| Barrier   | arrier | verification of operation   | indicator is      |
| Perf      | Int    | of the licensee=s           | provided for RCS  |
| ormance** | egrity | capability and performance  | activity.         |
|           |        | of in‑plant radio‑chemical  |                   |
|           |        | analyses of the reactor     |                   |
|           |        | coolant system (RCS).       |                   |
|           |        | Inspection of fuel cladding |                   |
|           |        | radio‑chemistry analysis    |                   |
|           |        | performance will provide    |                   |
|           |        | assurance that the first    |                   |
|           |        | barrier against release of  |                   |
|           |        | radioactivity to the        |                   |
|           |        | environment is maintained.  |                   |
|           |        | Failure of fuel cladding    |                   |
|           |        | would increase the          |                   |
|           |        | radiation dose to workers   |                   |
|           |        | and potentially to members  |                   |
|           |        | of the public.              |                   |
+-----------+--------+-----------------------------+-------------------+
| **EP      | Eme    | Inspect training program    | Two PI=s, DEP and |
| Training  | rgency | for adequacy, changes and   | ERO, address this |
| Program** | Prepar | the knowledge level and     | area and          |
|           | edness | qualifications of ERO       | therefore a       |
|           |        | members. Emergency          | baseline          |
|           |        | Preparedness is the final   | inspection is not |
|           |        | barrier in the \"defense in | required.         |
|           |        | depth\" NRC regulations     |                   |
|           |        | provide for ensuring the    |                   |
|           |        | public health and safety.   |                   |
|           |        | The training program must   |                   |
|           |        | ensure that ERO members are |                   |
|           |        | adequately prepared to      |                   |
|           |        | perform their assigned EP   |                   |
|           |        | duties. The ERO members     |                   |
|           |        | must be qualified to        |                   |
|           |        | perform their assigned      |                   |
|           |        | duties.                     |                   |
+-----------+--------+-----------------------------+-------------------+

  -------------------------------------------------------------------------------------
  **Table 2 Other                                                  
  Inspection                                                       
  Program                                                          
  Elements                                                         
  Considered But                                                   
  Not Included**                                                   
  --------------- ----------------- ------------------------------ --------------------
  **Inspectable   **Cornerstone**   **Scope**                      **Basis for Not
  Area or Program                                                  Including in
  Attribute**                                                      Baseline Inspection
                                                                   Program**

  **Severe        Emergency         SAMGs include strategies for   The staff concluded
  Accident        Preparedness      dealing with accidents that    that regular
  Management                        impact RCS integrity. SAMGs    inspection of SAMG
  Guidelines                        are sometimes implemented      was not appropriate
  (SAMG)**                          during EP drills and must be   because the
                                    written is such a manner as to guidelines are
                                    not impede implementation of   voluntary and have
                                    the Plan.                      no regulatory basis.
                                                                   The emergency
                                                                   response
                                                                   organization that
                                                                   would implement
                                                                   SAMGs is inspected
                                                                   through EP baseline
                                                                   inspection and
                                                                   performance is
                                                                   covered by two PIs.

  **Radiation     Occupational and  The objective of this area is  Worker performance
  Worker          Public Rad Safety to verify that workers         is a cross cutting
  Performance**                     understand the radiological    area. Since the PIs
                                    hazards associated with        are performance
                                    nuclear plant operation,       based, problems in
                                    effectively identify and       this area should
                                    control these hazards,         result in an
                                    identify and resolve adverse   operational
                                    trends or deficiencies, and    occurrence that
                                    maintain proper oversight of   meets the definition
                                    work.                          of a PI.
  -------------------------------------------------------------------------------------

ATTACHMENT 1

Revision History For IMC 0308 Attachment 2

  ------------ ---------- -------------- -------------- ------------ --------------
  Commitment   Issue Date Description of Training       Training     Comment
  Tracking                Change         Needed         Completion   Resolution
  Number                                                Date         Accession
                                                                     Number

               10/16/06   This IMC has   None           N/A          N/A
                          been revised                               
                          to incorporate                             
                          comments from                              
                          the Commission                             
                          in which the                               
                          term public                                
                          confidence has                             
                          been change to                             
                          openness                                   

                                                                     

                                                                     

                                                                     

                                                                     
  ------------ ---------- -------------- -------------- ------------ --------------