**NRC INSPECTION MANUAL** DIRS

Manual Chapter 0608

PERFORMANCE INDICATOR PROGRAM

0608-01 PURPOSE

This Inspection Manual Chapter (IMC) provides guidance on the
implementation of the operating Reactor Oversight Process (ROP)
Performance Indicator (PI) Program. It includes guidance on the process
for modifying existing PIs and for developing additional PIs for use in
the oversight process.

0608-02 OBJECTIVE

02.01 To provide policy and guidance regarding implementation of the ROP
PI Program, including data submission, verification, and posting of data
and frequently asked questions (FAQs) on the internal and external web.

02.02 To establish a formal process for responding to questions related
to interpretation of PI reporting guidance and for developing and
implementing changes to the PI Program, including creating new PIs and
making changes to existing PIs or thresholds.

0608-03 APPLICABILITY

This manual chapter applies to all operating commercial nuclear power
reactors.

0608-04 DEFINITIONS

04.01 [NEI 99-02]{.underline} The PI guidance document, which is jointly
produced by the NRC and the Nuclear Energy Institute (NEI), published by
NEI, and entitled "Regulatory Assessment Performance Indicator
Guideline."

04.02 [Feedback Form]{.underline} A form contained in IMC 0801, "Program
Feedback," used by NRC staff to submit a request to the Performance
Assessment Branch (IPAB) of the Office of Nuclear Reactor Regulation
(NRR) for clarification of the PI guidance document.

04.03 [Frequently Asked Question (FAQ)]{.underline} A question from an
external stakeholder regarding the PI Program or its implementation. All
FAQs submitted to the NRC by external stakeholders will be available on
the NRC's internal and external web sites and will be discussed in
public meetings. The web sites are periodically updated to include draft
FAQs (i.e., FAQs for which the response has not yet been approved),
tentatively approved FAQs, and FAQs that have been approved for use.
FAQs can be viewed by cornerstone, PI, posting date, or identification
number.

04.04 [ROP Working Group]{.underline} A group composed of NRC staff and
licensee representatives who meet typically once every month in an open
public meeting to discuss FAQs and other issues related to the ROP PI
Program.

04.05 [Self-Assessment]{.underline} An annual report to the Commission
on the Reactor Oversight Process.

04.06 [Extended Shutdown]{.underline} For the purposes of the PI
Program, a plant is considered to be in extended shutdown when the
reactor has been subcritical for at least six months.

0608-05 RESPONSIBILITIES AND AUTHORITIES

05.01 [Director, Office of Nuclear Reactor Regulation (NRR)]{.underline}

a\. Provides overall policy direction for the PI Program.

b\. Directs the development and implementation of policies, programs,
and procedures for the PI Program and oversight of program effectiveness
and implementation.

05.02 [Director, Division of Inspection and Regional Support
(DIRS)]{.underline}. Manages PI Program development and implementation
within NRR and oversees program implementation and effectiveness.

05.03 [Chief, Performance Assessment Branch]{.underline}

a\. Develops policy, programs, and procedures for implementation of the
PI Program.

b\. Receives and posts PI data and FAQs on the internal and external
web.

c\. Manages and implements the process for responding to questions
related to interpretation of PI reporting guidance and develops and
implements changes to the PI Program, including creating new PIs and
making changes to existing PIs or thresholds.

d\. Assesses PI Program effectiveness and implementation.

05.04 [Regional Administrator]{.underline}. Manages regional
implementation of the PI Program in accordance with the requirements of
this IMC, Management Directive (MD) 8.13, "Reactor Oversight Process,"
Inspection Procedure (IP) 71151, "Performance Indicator Verification,"
and IP 71150, "Discrepant or Unreported Performance Indicator Data."

0608-06 BACKGROUND

06.01 [Framework]{.underline}

The ROP is built upon a framework directly linked to the Agency's
mission. That framework includes cornerstones of safety that focus on
the licensee's ability to (1) limit the frequency of initiating events;
(2) ensure the availability, reliability, and capability of mitigating
systems; (3) ensure the integrity of the fuel cladding, the reactor
coolant system, and containment; (4) ensure the adequacy of the
emergency preparedness functions; (5) protect the public from exposure
to radioactive material releases; (6) protect nuclear plant workers from
exposure to radiation; and (7) provide assurance that the physical
protection system can protect against the design-basis threat of
radiological sabotage.

Within each cornerstone, a broad sample of data on which to assess
licensee performance in risk-significant areas is gathered from PI data
submitted by licensees and from the NRC's risk-informed baseline
inspections. The PIs are not intended to provide complete coverage of
every aspect of plant design and operation, but they are intended to be
indicative of performance within the related cornerstone.

Data submitted by each licensee are used to calculate PI values. These
values are then compared to objective thresholds to determine the
performance band associated with those values. The bands are color
coded. Plant data for a PI that falls within the "green" band indicates
licensee performance is within the nominal, expected range. The "white"
band indicates that performance is outside of the nominal, expected
range and can be characterized as of low to moderate safety
significance, but performance remains acceptable. Performance in the
"yellow" band indicates a more significant decline in performance and
can be characterized as being of substantial significance. Performance
is considered acceptable, but a reduction in safety margin exists.
Performance in the "red" band indicates a very significant decline in
performance. Changes can be characterized as being of high safety
significance. Performance may be acceptable with a significant reduction
in safety margin or may be unacceptable.

06.02 [Performance Indicators]{.underline}

PIs are a means of obtaining information related to the performance of
certain key attributes in each of the cornerstone areas. They provide
indication of problems that, if uncorrected, may increase the
probability and/or the consequences of an off-normal event. Since not
all aspects of licensee performance can be monitored by PIs, safety
significant areas not covered by PIs will be assessed through
inspection.

a\. For the reactor safety strategic performance area, the objectives of
the cornerstones and PIs are as follows:

1\. [Initiating Events]{.underline} - this cornerstone is intended to
limit the frequency of those events that upset plant stability and
challenge critical safety functions during power operations. Such events
include a reactor trip due to a turbine trip, loss of feedwater, loss of
off-site power, and other reactor transients. The following indicators
are provided in this cornerstone:

• Unplanned scrams (automatic and manual) per 7,000 critical hours

• Scrams with loss of normal heat removal

• Unplanned power changes per 7,000 critical hours

2.  [Mitigating Systems]{.underline} - this cornerstone is intended to
    ensure the availability, reliability, and capability of systems that
    mitigate initiating events to prevent reactor accidents. Mitigating
    systems include those associated with safety injection, residual
    heat removal, and their support systems, such as emergency AC power.
    The following indicators are provided in this cornerstone:

• [Safety System Functional Failures]{.underline} - this PI monitors the
readiness of the most important systems to perform their safety
function(s).

• [Mitigating System Performance Index]{.underline} - this PI is
calculated separately

for each of the following five systems for each reactor type:

BWRs

\- emergency AC power systems

\- high pressure injection systems (high pressure coolant injection,
high

pressure core spray, or feedwater coolant injection)

\- reactor core isolation cooling and/or isolation condenser systems

\- residual heat removal systems (or the equivalent function)

\- cooling water support systems for the above systems

PWRs

\- emergency AC power systems

\- high pressure safety injection systems

\- auxiliary feedwater systems

\- residual heat removal systems (or the equivalent function)

\- cooling water support systems for the above systems

3\. [Barrier Integrity]{.underline} - this cornerstone is intended to
ensure the integrity of the physical barriers designed to protect the
public from radionuclide releases caused by accidents. These barriers
are the fuel cladding, reactor coolant system boundary, and containment.
The following indicators are provided in this cornerstone:

• Reactor Coolant System (RCS) Specific Activity

• RCS Identified (or total) Leak Rate

4\. [Emergency Preparedness]{.underline} - this cornerstone is intended
to ensure that actions taken in accordance with the emergency plan
provide adequate protection of public health and safety during a
radiological emergency. The cornerstone does not include off-site
actions, which are covered by the Federal Emergency Management Agency.
The following indicators are provided in this cornerstone:

• Drill/Exercise Performance

• Emergency Response Organization Drill Participation

• Alert and Notification System Reliability

b\. For the radiation safety area, the cornerstones and PIs are as
follows:

1\. [Occupational Radiation Safety]{.underline} - this cornerstone is
intended to ensure adequate protection of worker health and safety from
exposure to radiation and radioactive materials during routine civilian
nuclear reactor operations. The following indicator is provided in this
cornerstone:

• Occupational Exposure Control Effectiveness

2\. [Public Radiation Safety]{.underline} - this cornerstone is intended
to ensure adequate protection of public health and safety from exposure
to radiation and radioactive materials released into the public domain
as a result of routine civilian nuclear reactor operations. These
releases include routine gaseous and liquid radioactive effluent
discharges, the inadvertent release of solid contaminated materials, and
the offsite transport of radioactive materials and wastes. The following
indicator is provided in this cornerstone:

• Radiological Effluent Technical Specifications (RETS)/Offsite Dose
Calculation Manual (ODCM) Radiological Effluent Occurrences

c\. For the safeguards area, the cornerstone and PIs are as follows:

1\. [Physical Protection]{.underline} - this cornerstone is intended to
provide assurance that the physical protection system can protect
against the design basis threat of radiological sabotage. The threat
could come from either external or internal sources. Although the NRC is
actively overseeing the Physical Protection Cornerstone, the Commission
has decided that the related performance indicator, inspection, and
assessment information will not be publicly available.

0608-07 PI DATA SUBMISSION

07.01 [Reporting of PI Data]{.underline}

Reporting of PI data to the NRC is a voluntary program in which all
licensees of operating reactor plants participate. To submit PI data,
licensees send a delimited text file to the NRC at <pidata@nrc.gov>.
Hard copy submissions, in accordance with 10 CFR 50.4 "Written
Communications," are not required, except in the event that the email
submission is unsuccessful. Within two business days of receipt of the
PI data, the NRC will send each licensee a return email to confirm and
authenticate receipt of the data. Licensees have four business days from
receipt of the NRC's email to report any transmission problems to the
NRC.

Once the data are confirmed by the NRC, they are entered into the
Reactor Program System database to calculate the indicator values.
Within five business days from receipt of the licensees' data
transmissions, the NRC will post the data, the indicator values, and
associated graphs on the NRC's internal web site. The regions will be
notified when the PIs are available on the internal web site. This is to
allow the regions an opportunity to become familiar with the PIs and to
identify any obvious inconsistencies prior to public release. Within 10
business days of receipt of the licensees' data transmittals, the NRC
will place the PIs on the NRC's external web site to make them available
to external stakeholders.

07.02 [PI Submission For Plants In Extended Shutdown]{.underline}

An operating commercial nuclear power plant with significant performance
or equipment problems may be shut down for an extended period of time
for a variety of reasons. Licensees may voluntarily or involuntarily
shut down the plant due to significantly degraded performance, major
equipment failures, or a significant plant event. In these cases, the
NRC may make the decision to place the plant under the process described
in Inspection Manual Chapter 0350, "Oversight of Reactor Facilities in a
Shutdown Condition Due to Significant Performance and/or Operational
concerns." Plants in extended shutdown should report PIs in accordance
with the guidance provided in the current version of NEI 99-02.

0608-08 PI VERIFICATION

08.01 Because of the importance of PIs in the ROP as a source of
information regarding performance upon which agency actions will be
based, PI data must be reported accurately. Inspection Procedure 71151,
"Performance Indicator Verification," shall be conducted to review
licensees' PI data collection and reporting activities for adherence to
pertinent guidance. It is expected that licensees will make reasonable,
good faith efforts to comply with the guidance in NEI 99-02. This
includes taking appropriate and timely action to identify and report
performance issues captured by the indicators. It may be necessary for
inspectors to exercise some judgement on the adequacy of licensee
actions to make a reasonable, good faith effort to comply with the
guidance.

Discrepancies with the performance indicator data collection and
reporting or with the actual data should be documented in accordance
with IP 71151 and the requirements of Inspection Manual Chapter 0612,
"Power Reactor Inspection Reports."

Enforcement action will be taken for inaccurate PI reporting in
accordance with the "General Statement of Policy and Procedure for NRC
Enforcement Actions."

08.02 [Discrepant or Unreported PIs]{.underline}

In the event the NRC determines that major discrepancies exist in the PI
data submitted by a licensee that causes the Agency to lose confidence
in the licensee's ability to collect and report PI data accurately, the
affected PI(s) will be classified as discrepant. Examples of situations
in which a PI would be considered to be discrepant may include but are
not limited to the following: (1) recurring errors in the reported data;
(2) recurring instances of incorrect interpretations of NEI 99-02; or
(3) inadequate documentation of PI data.

When PI data has been determined to be discrepant or is not being
reported by the licensee, IP 71150, "Discrepant or Unreported
Performance Indicator Data," will be conducted. IP 71150 provides for
the performance of selected inspection activities to compensate for the
discrepant or unreported PI data. Regional management should coordinate
activities in this area with IPAB. The selected inspections will be
performed in addition to the baseline inspection. Once the licensee has
corrected the root cause(s) of the discrepant or unreported data and the
NRC has verified that the licensee can collect and report PI data
accurately, oversight of PI reporting in accordance with IP 71151 will
resume.

When a plant has been in an extended shutdown, some PIs may not provide
a meaningful indication of plant performance in the areas they are
intended to monitor. In these situations, the guidance provided in IP
71150 should be followed to obtain sufficient performance information
via the inspection program until the plant has restarted and sufficient
PI data has been collected.

0608-09 QUESTIONS AND FEEDBACK

The NRC has received many questions and comments regarding the PIs over
the years. The staff expects that changes to existing PIs and thresholds
as well as development of new PIs will occur. Therefore the NRC has
established a formal process to address questions and feedback from
internal and external stakeholders, make changes to existing PIs and
thresholds based on lessons learned, and develop new PIs and associated
thresholds. This formal process is provided in Exhibit 1, "PI Process
For Addressing Feedback and Questions." The process consists of the
following four major components: input, evaluation, resolution, and
closure.

The remainder of this IMC describes the formal process. Exhibit 1
(flowchart) may be referred to at any point hereafter to gain an
understanding of the four phases of the formal process. The section
numbers of this IMC are included at corresponding points in the
flowchart to provide easy reference to the write-up of the respective
section.

09.01 [Input]{.underline}

NRC staff, industry, or the public may raise questions or provide
feedback regarding an individual PI. Questions from the NRC staff should
be documented in a Feedback Form

and submitted to IPAB in accordance with IMC 0801. Questions raised by
industry personnel should be documented in an FAQ and submitted to an
industry member of the ROP Working Group. These questions will be
provided to the NRC at periodic public meetings of the ROP Working
Group. Questions raised by the public or other stakeholders should be
submitted via email to the Office of Public Affairs at <opa@nrc.gov.>
Alternatively, questions from the public can be submitted in writing to
the United States Nuclear Regulatory Commission, Office of Public
Affairs, Washington D.C. 20555. Regardless of their origin, all
questions will be addressed in accordance with the process described
below.

An NRC staff member with a question about a PI should first look in NEI
99-02 for guidance. If further clarification is required, he or she
should search the FAQs on the NRC's internal or external web sites. If
neither of these provides sufficient clarification, he or she should
fill out a feedback form from the internal ROP web page. The inspector
may also provide feedback on issues related to PI guidance or
implementation, including observed or perceived instances of unintended
consequences. Feedback forms will be forwarded to regional management
for review and response, as appropriate. The purpose of the regional
review is to allow regional management to be aware of questions or
feedback being submitted and to provide an opportunity for the regions
to resolve the issue for those they believe do not warrant headquarters
review. All forms, including those to which the region has responded,
will then be forwarded to the PIPBCAL email mailbox or mailed to the
Chief, IPAB (mail stop O7H4).

Upon receipt, IPAB will perform an initial screening of each question
and feedback. IPAB will assign a lead reviewer from within IPAB, and one
from the appropriate technical branch, if necessary. The lead reviewer
will forward a reply to the originator within 14 business days to
acknowledge receipt of the form and to inform the originator of the
Feedback Form tracking number. Similarly, NRC will acknowledge receipt
of questions and feedback provided directly to the NRC from members of
the public or from members of industry. This response will be in the
form of written correspondence. All follow-up questions should be
directed to the lead reviewer.

Differences in interpretation of the PI guidance between the inspector
and the licensee are the only issues to be entered, via feedback form,
into the PI feedback process. Issues involving technical differences
should follow already established agency processes such as a task
interface agreement, or a conference call with the NRR technical
reviewer, the licensee, and regional staff.

09.02 [Evaluation of Questions or Feedback]{.underline}

Issues that only require an explanation of the existing guidance will be
promptly resolved. The lead reviewer will provide the originator with
the explanation and the issue will be closed out in accordance with
"Closure" (Section 09.05).

Questions or feedback that require modification to the guidance to
clarify meaning or intent will be addressed in accordance with
"Resolution of Questions and Feedback not Requiring a PI Change"
(Section 09.03).

Questions or feedback in which the resolution would require a new PI or
a change to an existing PI or threshold will be addressed in accordance
with "Resolution of Questions and Feedback Requiring a PI Change"
(Section 09.04) and subsequent steps.

09.03 [Resolution of Questions or Feedback Not Requiring a PI
Change]{.underline}

The following steps will be performed to resolve questions or feedback
that do not require a PI or threshold change:

a\. The ROP Working Group will review the question and develop a
proposed response. DIRS staff will involve the regions and NRR technical
staff when necessary in developing the response.

b\. The issue will be discussed at a public meeting of the ROP Working
Group to arrive at tentative approval of the question and its proposed
response. Although it is desirable that tentative approval be achieved
by the close of the meeting in which the issue is first discussed, this
portion of the process is iterative and could take several working
meetings. In the event NRC and its stakeholders are unable to reach
alignment on the issue being discussed, the DIRS Director will make the
final decision. Regardless of whether or not tentative approval is
achieved by the conclusion of the meeting, NEI will enter the new FAQs
into a log that contains draft FAQs and will provide a copy of the
electronic file to the NRC. The NRC will make the FAQs available to the
public, industry and other stakeholders on the ROP internal and external
web pages.

c\. Following tentative approval, the FAQ will be held for a waiting
period -- normally until the next regularly scheduled meeting -- to
allow a final opportunity for all stakeholders to review the proposed
FAQ and provide any input. Stakeholders should forward any feedback that
impacts the resolution of the issue to the assigned lead reviewer for
resolution prior to the next scheduled public meeting. The schedule for
upcoming meetings is posted on the ROP web-page.

d\. At the conclusion of the waiting period, the ROP Working Group will
consider any additional input and will issue its final conclusion. IPAB
will then place the approved FAQ on the internal and external web pages
and will notify appropriate internal stakeholders of the resolution. NEI
will notify licensees of the updated FAQ.

e\. NEI 99-02 will be updated periodically, as appropriate, to clarify
the PI reporting guidance based on insights from the resolution of the
FAQs.

09.04 [Resolution of Question/Feedback Requiring A Change]{.underline}

Questions or feedback that raise issues which require more than
clarification of reporting guidance or policy will be addressed as
described below. Resolution may involve creating a new PI, changing an
existing PI, changing a threshold for an existing PI, or changing an
existing PI to reflect a unique plant design features. Each of the
processes share common steps, but will be discussed separately.

Developing new PIs or making changes to existing PIs or thresholds can
require significant NRC resources. Prior to expending those resources,
the DIRS Director will determine whether the proposed change appears to
be feasible and is therefore justified. For those changes that would
clearly not be feasible, the DIRS Director will suspend consideration of
the change and provide a response to the originator that includes a
rationale for not proceeding. The issue will then be closed out.

If a change appears to be feasible, one of the four steps described
below will be followed.

a\. [New PI]{.underline}

When an existing PI is ineffective, consistently generates many FAQs, or
has the potential to be misleading or to create unintended consequences,
there may be a need to develop a new PI. A proposed new PI should
provide indication of licensee performance in the same cornerstone(s) as
the existing PI.

Once the need for a new PI has been determined and the scope of the
information the PI will cover has been identified, the ROP Working Group
will propose a definition for the PI, including draft reporting
criteria. NRC will consider previous lessons learned and any stakeholder
feedback in developing the proposed definition. The proposed PI will be
discussed at a public meeting of the ROP Working Group to develop a
mutually agreed upon definition. The proposed PI will be made available
to internal and external stakeholders for comment via the NRC ROP web
site. Following the comment period, NRC and the Industry ROP Working
Group will review the comments provided and make appropriate changes to
the PI as necessary.

Early consideration should be given to the potential need for OMB
Clearance for the new PI to ensure clearance processing will not
adversely impact final PI implementation. The OMB clearance for PI
reporting, OMB No. 3150-0195, allows additional PIs to be added when
necessary.

Following the development of the final proposed PI definition and
reporting guidance, the NRC must determine the efficacy of the PI. The
PI must be benchmarked against past industry performance data to
determine whether the results obtained from the PI would be indicative
of current plant performance. If historical data are available, the ROP
Working Group will collect the data to determine if the PI can identify
declining performance in a timely manner so that increased regulatory
attention can be applied before performance becomes unacceptable. In the
event that historical data is not available, NRC and the Industry ROP
Working Group will use the best information available.

If the proposed PI cannot identify declining performance in a timely
manner, the PI must either be revised prior to proceeding or development
efforts discontinued. Once the PI has been successfully benchmarked, the
ROP Working Group will consider whether the PI will provide information
that is not currently being collected and adds benefits commensurate
with the reporting burden. In the event the PI does not provide
information that would make its continued development and implementation
beneficial, it must be revised or it will be discontinued.

The ROP Working Group will conduct a pilot test or a tabletop exercise
using a representative sample of plants to collect data for the proposed
PI, in addition to continuing to collect data on the existing PIs. The
purpose of this pilot or tabletop exercise is to conduct a real-time
test of the proposed guidance, to establish thresholds, and to determine
the effectiveness of the proposed PI. When the pilot or the tabletop
exercise has been completed, NRC will provide an opportunity for the
industry, public, and other stakeholders to provide feedback. This
feedback, along with lessons learned from the pilot, will be evaluated
by the staff and may be used to modify the proposed PI and/or its
thresholds, as necessary.

In conjunction with adding a PI, NRC will consider whether changes to
the baseline Inspection Program are warranted to eliminate potential
overlap or ensure coverage of key attributes.

After the ROP Working Group has agreed on final changes to the proposed
PI and thresholds, NEI will, in collaboration with the NRC staff, revise
NEI 99-02 . IPAB will update the web page as appropriate to include the
new PI data. The ROP Working Group may conduct training, as deemed
necessary. IPAB will issue a Regulatory Information Summary (RIS) to
inform stakeholders of the new PI and its reporting criteria. The RIS
will also be placed in NRC's Public Document Room and on the external
web-site at
[http://nrr10.nrc.gov/NRR/OVERSIGHT/ASSESS/INDEX.html](http://nrr10.nrc.gov/NRR/OVERSIGHT/ASSESS/INDEX.html.),
which can be accessed from the Inspection Manual of Agency Wide
Applications. IP 71151 will be revised to reflect the new PI.

b\. [Changes To An Existing PI]{.underline}

The process for making a significant change to an existing PI is similar
to creating a new PI. Like the initial steps in creating a new PI, NRC
must ensure that the revised PI will provide an indication of licensee
performance in the key attributes of the cornerstone for which the
existing PI was intended. The ROP Working Group will conduct public
meetings with all stakeholders to discuss and reach agreement on the
proposed change, including the PI definition and reporting criteria. The
proposed change will be made available to internal and external
stakeholders for comment via the NRC ROP web site. Following the comment
period, NRC and NEI will review comments provided and make changes to
the PI as appropriate. This process is iterative and allows all
stakeholders an opportunity to contribute to the process.

If the proposed change is approved, the NRC and NEI will identify a
representative sample of plants that are willing to pilot test the
proposed change by collecting data for the modified PIs while continuing
to provide data on the existing PIs. The purpose of a pilot program is
to conduct a real-time test of the proposed guidance, validate the
thresholds, and ensure the effectiveness of the PI. When the pilot has
been completed, NRC will provide an opportunity for the industry,
public, and other stakeholders to provide feedback. This feedback, along
with lessons learned from the pilot, may be used to modify the proposed
PI as appropriate.

After the ROP Working Group has agreed on final changes to the PI, NEI
will revise NEI 99-02 accordingly and IPAB will update the web page as
appropriate to reflect the changes. The ROP Working Group may conduct
training as deemed necessary. IPAB will issue a RIS to inform
stakeholders of the PI change and approve the use of the new PI. The RIS
will be placed in the NRC's Public Document Room and on its external web
site at
[http://nrr10.nrc.gov/NRR/OVERSIGHT/ASSESS/INDEX.html](http://nrr10.nrc.gov/NRR/OVERSIGHT/ASSESS/INDEX.html.),
which can be accessed from the Inspection Manual of Agency Wide
Applications. Additionally, IP 71151 will be revised to reflect the new
PI.

c\. [Change In Threshold(s)]{.underline}

Thresholds may need to be adjusted based on lessons learned from
experience with individual PIs. Such adjustments is are not intended to
continually raise licensee performance expectations, but rather they are
intended to ensure that the initial thresholds, some of which were
established without the benefit of actual industry performance data, are
performing as intended.

Once the need for a threshold change has been identified, the NRC and
Industry ROP Working Group will meet in a public forum to discuss and
reach agreement on the proposed threshold change. The proposed change
will be made available to internal and external stakeholders for comment
via the NRC ROP web site. Following the comment period, the ROP Working
Group will review the comments in a public meeting. If the Working Group
is unable to reach agreement on a new threshold, the issue will be
elevated to higher levels of NRC management to make the final decision.

IPAB will issue a RIS to inform stakeholders of the threshold change and
will modify the web page accordingly. The RIS will provide guidance on
when the revised threshold will become effective. The RIS will be
forwarded to the regional Directors of Reactor Projects, Reactor Safety,
and Plant Support; inspectors; and NEI. Additionally, the RIS will be
placed in NRC's Public Document Room and on the external web-site,
<http://nrr10.nrc.gov/NRR/OVERSIGHT/ASSESS/INDEX.html.>, which can be
accessed from the Inspection Manual of Agency Wide Applications.

d\. [Unique PI]{.underline}

With multiple reactor designs, plants may have unique design features
that make compliance with the data reporting criteria established in NEI
99-02 impossible, impractical, or ineffective.

In such cases, the ROP Working Group will form a sub-group that includes
representatives of the affected licensees to develop unique criteria to
accommodate plant-type differences. If historical data are available, it
will be collected and used in ths effort. When historical data are
unavailable, an expert panel will be assembled to identify appropriate
thresholds based on experience. The NRC will then follow the remainder
of the guidance outlined in Section C, Change In Threshold(s), to
complete this process.

09.05 [Closure]{.underline}. Once an issue has been resolved, the lead
reviewer will notify the originator of the final response. This
notification will normally occur via email and within 14 business days
after NRC has reached a resolution. The completion date will be entered
into the Feedback Form tracking system and the issue will closed out.

If a licensee disagrees with the resolution documented on a feedback
form, the licensee should submit an FAQ to the ROP Working Group to
present at the next ROP Working Group meeting. The FAQ process outlined
in section 9.03 will be followed.

0608-10 PI REFERENCES

Management Directive 8.13, "Reactor Oversight Process"

SECY-99-007, "Recommendations For Reactor Oversight Process
Improvements"

SECY-99-007A, "Recommendations For Reactor Oversight Process
Improvements (Follow-up to SECY-99-007)"

SECY-00-049, "Results Of The Revised Reactor Oversight Process Pilot
Program"

Temporary Instruction 2515/144, "Performance Indicator Data Collecting
and Reporting Process Review"

Inspection Procedure 71151, "Performance Indicator Verification"

Inspection Procedure 71150, "Discrepant or Unreported Performance
Indicator Data"

NEI 99-02, "Regulatory Assessment Performance Guideline," (Revision 4)

Regulatory Information Summary 99-06, "Voluntary Submission Of
Performance Indicator Data" (collecting and reporting historical data)

Regulatory Information Summary 2000-08, "Voluntary Submission Of
Performance Indicator Data" (collecting and reporting data reflecting
plant performance during full implementation of revised reactor
oversight process)

General Statement of Policy and Procedure for NRC Enforcement Actions

Manual Chapter 0350, "Oversight of Reactor Facilities in a Shutdown
Condition Due to Significant Performance and/or Operational Concerns"

Web-site For Frequently Asked Questions:

http://NRR/OVERSIGHT/ACCESS/FAQs_by_pi_pdf

ROP Web-site:
<http://nrr10.nrc.gov/NRR/ROP_DIGITAL_CITY/ROP_digital_city.html>

END

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ATTACHMENT 1

[Revision History for IMC 0608]{.underline}

+--------+-------+-------------------+----------+---------+------------+
| Comm   | Issue | Description of    | Training | T       | Comment    |
| itment | Date  | Change            | Required | raining | Resolution |
| Tr     |       |                   |          | Com     | Accession  |
| acking |       |                   |          | pletion | Number     |
| Number |       |                   |          | Date    |            |
+--------+-------+-------------------+----------+---------+------------+
| N/A    | 02/   | [IMC              | None     | N/A     | N/A        |
|        | 27/07 | 0608]{.underline} |          |         |            |
|        |       | Delete SSU, add   |          |         |            |
|        | CN    | MSPI; update flow |          |         |            |
|        | 0     | charts; add       |          |         |            |
|        | 7-007 | definitions       |          |         |            |
+--------+-------+-------------------+----------+---------+------------+
|        |       |                   |          |         |            |
+--------+-------+-------------------+----------+---------+------------+
|        |       |                   |          |         |            |
+--------+-------+-------------------+----------+---------+------------+