[APPENDIX D]{.underline}

FUEL CYCLE FACILITY INSPECTION PLANNING

ANNUAL INSPECTION PLANNING

[Core Inspections]{.underline}.

During the calendar year, inspections should be planned and scheduled to
complete the Core Inspections required by this Inspection Manual Chapter
(IMC) with any areas of emphasis within the Core Inspections based on
Licensee Performance Review (LPR) results.

[Supplemental Inspections]{.underline}.

Supplemental inspections, based on LPR decisions, on planned new
facilities, recent performance issues, enforcement actions, etc., should
be included in the Plan.

[Inspector Accompaniment Considerations]{.underline}.

Unqualified inspectors and other staff members may accompany qualified
inspectors for qualification, familiarization, or other purposes.
Accompaniments should not impact annual inspection planning.

PLANNING INDIVIDUAL INSPECTIONS

[Elements of Inspection Planning]{.underline}. Planning individual
inspections consists of developing an initial plan, coordinating the
plan, preparing a written plan, and obtaining supervisory approval of
the written plan.

a\. [Initial Planning]{.underline}.

1\. [Inspection Procedures]{.underline}. For planning purposes, the
inspection procedures contain estimates of inspection hours to complete
the procedure. This guidance is the starting point for inspection
planning.

2\. [Recent Safety/Safeguards Inspections (prior two
years)]{.underline}. Planning should include a review of
safety/safeguards inspection reports for trends and issues. A report of
current issues \[i.e., Reactor Programs System (RPS) or Plant Issues
Matrix (PIM)\] should also be obtained to facilitate review.

3\. [LPR Areas Needing Improvement]{.underline}. Specific concerns and
safety/safeguards focus should be obtained from the most recent LPR if
comments were made in the area of focus. The entire LPR should be
reviewed for issues concerning the area of focus. In addition, the
licensee=s response to the LPR issues should be reviewed.

4\. [License Requirements]{.underline}. The inspectors should be
familiar with any license requirements or safety conditions applicable
to the planned inspection and, where applicable, the Integrated Safety
Analysis (ISA) Summary.

5\. [Event History]{.underline}. Inspectors should be familiar with the
reportable event history for each facility and should review carefully
any event occurring since the last inspection.

6\. [Improvement Program Items]{.underline}. If a licensee has a safety
or safeguards improvement program ongoing, inspectors should review the
action items and status.

7\. [Enforcement Actions]{.underline}. If a licensee has open items or a
confirmatory order from a recent enforcement action, inspectors should
review the open items and status.

b\. [Coordination]{.underline}.

1\. [Technical Reviewer Feedback]{.underline}. Technical reviews should
be approached for insight into specific technical issues that may be
addressed during the inspection. Technical reviewers may also provide
suggestions regarding the risk significance of proposed inspection
activities.

2\. [Resident Inspector Input]{.underline}. If the facility has a
Resident Inspector, coordination should be conducted to identify issues
and to avoid duplication of inspection effort.

3\. [Regional Project Inspector Input]{.underline}. Regional fuel cycle
staff should be approached for insight into specific licensee issues and
the significance of identified issues. Coordination with regional staff
will also help to avoid duplication of inspection effort.

4\. [Project Manager Input]{.underline}. The Project Manager for the
facility being inspected should be approached for insight into specific
licensing issues, ISA Summary changes, or concerns that can be addressed
during the inspection.

c\. [Written Plan]{.underline}. Finally, a written plan should be
prepared that specifically addresses the selected inspection procedures
to be inspected and the focus of the inspection. Maintain the inspection
focus on issues with substantive risk significance based on the ten risk
bases listed below. Any special requirements identified by line
management should be listed.

[Risk Focus]{.underline}. For the review areas defined in the inspection
procedure, the inspectors develop a risk focus based on the following
ten risk bases:

1\. Dominant Hazards.

2\. Dominant Risks/Scenarios.

3\. Dominant Controls for Hazards/Risks.

4\. Principle Management Measures.

5\. Dominant Root Causes.

6\. Backlog of Risk Significant Issues.

7\. Unexpected Conditions Identified, Resolved, and Corrected.

8\. Recurring Unexpected Conditions and Root Causes.

9\. Internal Self Assessments.

10\. Safety Conscious Work Environment.

d\. [Supervisory Approval]{.underline}. Supervisory approval of the
written plan is mandatory.

END

**ENTRANCE MEETING OUTLINE**

> Introductory Statement
>
> Inspection number, members
>
> NRC coordination (licensing and region)
>
> Risk focus
>
> Primary Inspection Areas
>
> Plant operations
>
> Recent events and internal infractions
>
> Open items (IFI, VIO, URI)
>
> Coordination with Licensee
>
> Schedule walkdowns
>
> Schedule each major inspection area (am or pm)
>
> Request documentation
>
> Questions
>
> Closing Statement

**EXIT MEETING OUTLINE**

> Introductory Statement
>
> Inspection number, members
>
> Reiterate coordination
>
> Reiterate risk focus
>
> Walkdowns
>
> Areas reviewed
>
> Issues identified
>
> Inspection Focus Areas
>
> Reiterate inspection focus areas
>
> Review findings area by area
>
> Discuss any commitments by licensee
>
> Open Items
>
> Current status of each item
>
> Summary
>
> Review all new issues (IFI, VIO, URI)
>
> Review all commitments by licensee
>
> Questions
>
> Closing Statement

ATTACHMENT 1

Revision History for IMC 2600, Appendix D

+--------+--------+-----------------------+-----+--------+-------------+
| Comm   | Issue  | Description of Change | Tr  | Tr     | Comment     |
| itment | Date   |                       | ain | aining | Resolution  |
| Tr     |        |                       | ing | Comp   | Accession   |
| acking |        |                       | Nee | letion | Number      |
| Number |        |                       | ded | Date   |             |
+--------+--------+-----------------------+-----+--------+-------------+
| N/A    | 04     | Revised to            | N   | N/A    | ML070610222 |
|        | /26/07 | incorporate the new   | one |        |             |
|        |        | inspection procedures |     |        |             |
|        | CN-    | developed to address  |     |        |             |
|        | 07-014 | changes to 10 CFR     |     |        |             |
|        |        | Part 70 and to        |     |        |             |
|        |        | reflect enhancements  |     |        |             |
|        |        | made to the fuel      |     |        |             |
|        |        | facility inspection   |     |        |             |
|        |        | program.              |     |        |             |
|        |        |                       |     |        |             |
|        |        | This Appendix was     |     |        |             |
|        |        | formerly Appendix E   |     |        |             |
|        |        | in the previous       |     |        |             |
|        |        | revision of this IMC. |     |        |             |
|        |        | Changes that were     |     |        |             |
|        |        | made to the           |     |        |             |
|        |        | inspection program    |     |        |             |
|        |        | led to the removal of |     |        |             |
|        |        | Appendix D and        |     |        |             |
|        |        | changing Appendix E   |     |        |             |
|        |        | to D.                 |     |        |             |
+--------+--------+-----------------------+-----+--------+-------------+
| N/A    | 08     | Remove AOFFICIAL USE  | N   | N/A    | ML072070175 |
|        | /15/07 | ONLY - SENSITIVE      | one |        |             |
|        |        | INTERNAL INFORMATION" |     |        |             |
|        | CN-    | designation from      |     |        |             |
|        | 07-025 | entire manual chapter |     |        |             |
|        |        | to make publicly      |     |        |             |
|        |        | available.            |     |        |             |
+--------+--------+-----------------------+-----+--------+-------------+
| N/A    | 03     | Revised to add        | N   | N/A    | N/A         |
|        | /21/08 | enforcement actions   | one |        |             |
|        |        | to inspection         |     |        |             |
|        | CN     | planning.             |     |        |             |
|        | 08-011 |                       |     |        |             |
+--------+--------+-----------------------+-----+--------+-------------+