**NRC INSPECTION MANUAL CCIB**

MANUAL CHAPTER 2505

PERIODIC ASSESSMENT OF CONSTRUCTION INSPECTION PROGRAM RESULTS

TABLE OF CONTENTS

[2505-01 PURPOSE 1](#purpose)

[2505-02 OBJECTIVES 1](#objectives)

[2505-03 APPLICABILITY 1](#applicability)

[2505-04 DEFINITIONS 2](#definitions)

[2505-05 RESPONSIBILITIES AND AUTHORITIES
5](#responsibilities-and-authorities)

[2505-06 BASIC REQUIREMENTS 7](#basic-requirements)

[06.01 Program Overview 7](#__RefHeading___Toc209075600)

[06.02 Construction Assessment Process. 7](#__RefHeading___Toc209075601)

[06.03 Performance Reviews 8](#__RefHeading___Toc209075602)

[06.04 Program Reviews 11](#program-reviews)

[06.05 Annual Meeting with Licensee 12](#annual-meeting-with-licensee)

[06.06 NRC Responses to Licensee Performance
13](#nrc-responses-to-licensee-performance)

[06.07 Additional Construction Response Table Guidance
17](#additional-construction-response-table-guidance)

[06.08 Corrective Action Program (CAP) Effectiveness Reviews
18](#__RefHeading___Toc209075607)

[06.09 CSFIs 20](#__RefHeading___Toc209075608)

Exhibit 1 Process Activities

Exhibit 2 Construction Response Table

Exhibit 3 Construction Inspection Program

Attachment 1 Revision History for IMC 2505

# 2505-01 PURPOSE

01.01 To establish a transparent and predictable process that
objectively evaluates licensee performance of construction activities
and the effectiveness of licensee/contractor oversight and quality
assurance efforts associated with construction.

01.02 This is the initial issuance of Inspection Manual Chapter (IMC)
2505. The staff recognizes that this IMC will likely undergo significant
revisions during the next several years as both internal and external
stakeholders provide feedback. This initial issuance is intended to
promote such feedback, in order that the inspection program described in
this IMC can benefit from the resulting revisions prior to the start of
construction of future plants. For example, the staff intends to
incorporate areas important to safety culture in the new construction
assessment program; however, the final details of how areas important to
safety culture will be assessed have not been fully developed to date.
These areas will continue to be developed and will be incorporated into
this IMC upon their completion. Time frames listed for conducting or
performing various activities associated with the assessment process are
considered initial estimates and any necessary changes will be made
after the NRC has experience in implementing this IMC.

# 2505-02 OBJECTIVES

02.01 To collect assessment information from construction inspections.

02.02 To arrive at an objective assessment of licensee oversight
performance using Construction Safety Focus Issues (CSFIs), which are
under development, and violations identified during inspections.

02.03 To assist NRC management in making timely and predictable
decisions regarding appropriate agency actions used to oversee, inspect,
and assess licensee performance.

02.04 To provide a process for informing the licensee and the public of
the NRC's assessment and resultant adjustment in inspection oversight
when the changes are a result of licensee performance issues.

02.05 To provide a process to follow up on areas of concern.

# 2505-03 APPLICABILITY

This manual chapter applies to all commercial nuclear reactors in the
construction phase under the 10 CFR Part 52 licensing process. Once the
facility has fully transitioned to the Reactor Oversight Process (ROP)
then Inspection Manual Chapter (IMC) 0305, "Operating Reactor Assessment
Program," will apply. The contents of this manual chapter do not
restrict the NRC from taking any necessary actions to fulfill its
responsibilities under the Atomic Energy Act of 1954 (as amended). The
guidance in IMC 0320, "Operating Reactor Security Assessment Program"
will be used for the assessment of security-related inspection
violations.

# 2505-04 DEFINITIONS

04.01 [Assessment Inputs]{.underline}. As used in this manual chapter,
assessment inputs are the violations and CSFIs (under development)
identified for a respective construction site that are combined in the
assessment process in order to determine appropriate agency actions in
accordance with the Construction Response Table (CRT) (Exhibit 2).
Significant violations (i.e. violations resulting in escalated
enforcement action) are normally considered in the assessment program
for six months from the date of the inspection report in which the
violation is issued or until the NRC accepts the licensee's corrective
actions (i.e., the violation is closed in the Construction Inspection
Program Information Management System (CIPIMS)), whichever is longer.
During the semiannual performance review (SPR), the NRC will determine
if CSFIs exist based on the causes of violations identified during the
assessment period.

04.02 [Assessment Period]{.underline}. A rolling 6-month assessment
period which includes 2 quarters of assessment inputs.

04.03 [Audit]{.underline}. A periodic examination of selected records or
activities to verify their correctness or compliance with predetermined
standards.

04.04 [Communication]{.underline}. With regard to the CRT, communication
between the licensee and the NRC is based on a graded approach. For
declining licensee performance, higher levels of agency management will
review and sign the assessment letters and conduct the annual public
meeting.

04.05 [Construction Assessment Process]{.underline}. A 6-month
assessment period which starts after 1) a limited work authorization
(LWA) and/or a combined operating license has been issued; 2) the NRC
has implemented either IMC 2503 or 2504; and 3) there is sufficient
activity occurring for any assessment to be meaningful. The construction
assessment process will continue until the ROP has been fully
implemented.

04.06 [Combined License]{.underline}. A combined construction permit and
operating license with conditions for a nuclear power facility, issued
pursuant to 10 CFR Part 52, Subpart C.

04.07 [Construction Activities]{.underline}. An NRC regulated activity
associated with the design, fabrication, construction, or testing of
structures, components, or systems at the construction site.

04.08 [Construction Finding]{.underline}. A regulatory violation that is
of greater-than-minor significance and is not associated with a specific
ITAAC.

04.09 [Construction Inspection Program Information Management System
(CIPIMS)]{.underline}. The database that provides the means to document,
report, and track all NRC inspection activities and their results,
including both ITAAC and non-ITAAC related inspections.

04.10 [Construction Performance Review Package (CPRP)]{.underline}. A
document prepared by the regional office and used during the SPR and
Agency Action Review Meeting (AARM) (if applicable). This document is
prepared for all plants.

04.11 [Construction Response Table (CRT)]{.underline}. A table (Exhibit
2) that identifies the range of NRC and licensee actions and the
appropriate level of communication for various levels of licensee
performance. Licensee performance will be assessed quarterly to
determine if assessment input thresholds in the CRT are exceeded.

04.12 [Construction Safety Focus Issue (CSFI)]{.underline}. An issue
identified by the NRC during the SPR of licensee performance concerning
a common cause for violations identified during the assessment period
(under development).

04.13 [Contractor]{.underline}. Any organization or individual under
contract to furnish items or services to a licensee that is engaging in
an NRC regulated activity. It includes the terms consultant, supplier,
fabricator, constructor, vendor, and sub-tier levels of these
organizations, where appropriate.

04.14 [Family of ITAAC]{.underline}. A grouping of ITAAC that are
related through similar construction processes, resulting products, and
general inspection attributes.

04.15 [Inspection]{.underline}. (1) An NRC activity consisting of
examination, observation, or measurement to determine
applicant/licensee/contractor/vendor conformance with requirements
and/or standards. (2) Applicant/licensee/contractor/vendor quality
control measures consisting of examination, observation, or measurements
to determine the conformance of materials, supplies, components, parts,
systems, processes or structures to pre-determined quality requirements.

04.16 [Inspection History]{.underline}. A compilation of the inspection
results for all inspections (construction and vendor inspections,
Problem Identification and Resolution, etc.) conducted by the NRC.

04.17 [Inspections, Tests, Analyses, and Acceptance Criteria
(ITAAC)]{.underline}. Those inspections, tests, analyses, and acceptance
criteria identified in the combined license that, if met, are necessary
and sufficient to provide reasonable assurance that the facility has
been constructed and will operate in conformity with the license, the
provisions of the Atomic Energy Act, and the Commission's rules and
regulations. The ITAAC identified in a Combined License referencing a
certified design will include the ITAAC defined in the Tier 1
documentation. Site-specific ITAAC, which include emergency planning
ITAAC and ITAAC that are not part of the certified design, will also be
included in a combined license. ITAAC are conditions of the license and
must be satisfactorily completed before an affirmative 10 CFR 52.103 (g)
finding occurs.

04.18 [ITAAC Attributes]{.underline}. A number of common, descriptive
characteristics for each ITAAC that can be analyzed and weighted by a
methodology that allows the ITAAC to be prioritized for inspection
planning.

04.19 [ITAAC Finding]{.underline}. A regulatory violation that is
greater-than-minor, is associated with a specific ITAAC for which the
licensee has issued the ITAAC closure letter, and is material to the
ITAAC acceptance criteria. This type of finding could prevent the ITAAC
from being closed and could require that previously closed ITAAC be
re-opened. An ITAAC finding may be related to a single ITAAC or a family
of ITAAC.

04.20 [ITAAC Matrix]{.underline}. An inspection planning tool that
identifies groups (i.e., families) of ITAAC, based upon common
characteristics, which facilitate the ITAAC inspection sampling process
and provide a consistent model for the inspection of ITAAC at plants of
a similar design (see IMC 2503, Appendix B, for more details).

04.21 [ITAAC-Related Construction Finding]{.underline}. A regulatory
violation that is of greater-than-minor significance and is associated
with a specific ITAAC for which the licensee has not yet issued the
ITAAC closure letter, and is material to the ITAAC acceptance criteria.
This type of finding could prevent the ITAAC from being closed. An
ITAAC-Related Construction Finding may be related to a single ITAAC or a
family of ITAAC.

04.22 [Licensee Action]{.underline}. With regard to the CRT, Licensee
Action consists of anticipated licensee actions in response to overall
performance indicated by the appropriate column of the CRT. If these
actions are not being taken by the licensee, then the NRC may consider
increasing NRC inspections to appropriately address the area(s) of
concern.

04.23 [NRC Inspection]{.underline}. With regard to the CRT, NRC
Inspection consists of the range of NRC inspection activities in
response to licensee performance indicated by the appropriate column of
the CRT.

04.24 [Quality Assurance]{.underline}. Quality Assurance (QA) comprises
all those planned and systematic actions necessary to provide adequate
confidence that a structure, system, or component will perform
satisfactorily in service. Quality Assurance includes quality control.

04.25 [Regulatory Actions]{.underline}. With regard to the CRT,
Regulatory Actions comprise the range of actions that may be taken by
the NRC in response to licensee performance indicated by the appropriate
column of the CRT.

04.26 [Regulatory Performance Meetings]{.underline}. With regard to the
CRT, Regulatory Performance Meetings are held between licensees and the
NRC to discuss corrective actions associated with significant violations
(i.e. violations resulting in escalated enforcement action). Each
significant assessment input shall be discussed in one of the forums
listed below in order to arrive at a shared understanding of the
performance issues, underlying causes, and planned licensee actions.
These meetings may take place at periodic inspection exit meetings
between the NRC and the licensee, a periodic NRC management visit,
conference calls, or public meetings after completion of the expanded
inspection. This meeting should be documented in an inspection report or
a public meeting summary, as appropriate.

04.27 [Safety-Conscious Work Environment (SCWE)]{.underline}. An
environment in which employees feel free to raise safety concerns, both
to their management and to the NRC, without fear of retaliation and
where such concerns are promptly reviewed, given the proper priority
based on their potential safety significance, and appropriately resolved
with timely feedback to employees*.*

04.28 [Safety Culture]{.underline}. That assembly of characteristics and
attitudes in organizations and individuals which establishes that, as an
overriding priority, nuclear plant safety issues receive the attention
warranted by their significance. (This definition for safety culture is
used for operating reactors and may change as a result of future staff
work in the development of safety culture for new reactor construction).

04.29 [Semiannual Performance Review (SPR)]{.underline}. An assessment
conducted on a rolling 6-month timeframe that is principally focused on
licensee performance and the need to reallocate resources and/or add
resources to address licensee performance. The SPR assessment results
will be communicated to the licensee and the public via an SPR
assessment letter.

04.30 [Site Construction Team]{.underline}. The core group of NRC
inspectors assigned to a site under the leadership of a senior resident
inspector.

04.31 [Targeted ITAAC]{.underline}. Targeted ITAAC are ITAAC that have
been rank-ordered based on attributes and associated ITAAC impact. The
targeted ITAAC and others (site-specific, etc) selected for direct
inspection constitute the minimum, or baseline, amount of inspection
that will be done for a particular design. Inspection Procedure (IP
65001) provides more information on the selection of targeted ITAAC for
direct inspection.

# 2505-05 RESPONSIBILITIES AND AUTHORITIES

05.01 [Executive Director for Operations (EDO)]{.underline}.

a\. Oversees the activities described in this manual chapter.

b\. Approves all deviations from the CRT.

c\. Informs the Commission of all approved deviations from the CRT.

05.02 [Director, Office of New Reactors (NRO)]{.underline}.

> a\. Provides overall program direction for the reactor construction
> inspection program.
>
> b\. Assesses the effectiveness, uniformity, and completeness of
> implementation of the construction inspection assessment program.
>
> c\. Ensures that the public is informed of the results of the
> construction inspection assessment program as appropriate.

05.03 [Deputy Regional Administrator for Construction]{.underline}.

> a\. Provides program direction for management and implementation of
> the construction assessments performed by the regional office.
>
> b\. Ensures that the regional office staff includes adequate numbers
> of inspectors in the various disciplines necessary to carry out the
> construction assessment program as described in this chapter.
>
> c\. Ensures that the public is informed of the results of the
> construction assessment program as appropriate.

05.04 [Director, Office of Public Affairs]{.underline}.

Issues press releases following the completion of the SPRs.

05.05 [Director, Division of Construction Inspection and Operational
Programs (NRO/DCIP)]{.underline}.

> a\. Develops construction assessment process guidance.
>
> b\. Collects feedback from the regional office and assesses execution
> of the construction inspection assessment program to ensure consistent
> application.
>
> c\. Recommends, develops, and implements improvements to the
> construction assessment process.
>
> d\. Concurs on proposals by the regional office to extend a violation
> resulting in escalated enforcement beyond that allowed by Section
> 06.01.
>
> e\. Concurs on the increased targeted inspection plan for plants in
> the Expanded Program and Unacceptable Performance columns of the CRT.

05.06 [Regional Division of Construction Projects Director]{.underline}.

> a\. Chairs the SPR meeting.
>
> b\. Approves proposals to re-allocate resources as a result of
> licensee performance issues.

05.07 [Regional Division of Construction Projects Branch
Chiefs]{.underline}.

Approve proposals to re-allocate resources for other than licensee
performance issues.

05.08 [Regional Construction Inspection Staff]{.underline}.

> a\. Administers and implements the construction inspection program and
> issues inspection reports.
>
> b\. Provides NRO with the status of inspections related to specific
> ITAAC.
>
> c\. Acts as the licensee\'s primary NRC contact for the construction
> inspection program.
>
> d\. Coordinates the development of, and revision to, the site
> inspection plan.
>
> e\. Integrates all of the inspection violations and other inputs to
> develop an overall assessment of licensee performance.

# 2505-06 BASIC REQUIREMENTS

1.  []{#__RefHeading___Toc209075600 .anchor}[Program
    Overview]{.underline}. Licensee performance is reviewed using the
    construction assessment process (Exhibit 1) to periodically evaluate
    the inspection history of selected construction activities, other
    inspection activities (i.e., Problem Identification and Resolution
    (PI&R), etc.), enforcement history, allegations, and safety culture
    (to be developed) to determine licensee/contractor/vendor
    effectiveness in assuring construction quality. Based on the
    assessment results, NRC management will determine the appropriate
    level of response to licensee performance in accordance with the CRT
    which is Exhibit 2 to this IMC. Exhibit 3 illustrates how the
    assessment process fits into the overall construction inspection
    program.

2.  []{#__RefHeading___Toc209075601 .anchor}[Construction Assessment
    Process]{.underline}. The construction assessment process will begin
    after a Limited Work Authorization (LWA) and/or a Combined License
    has been issued, the NRC has implemented either IMC 2503 or 2504,
    and there is sufficient activity occurring for any assessment to be
    meaningful. The NRC will notify the licensee when the construction
    assessment process begins. The construction assessment process
    consists of a rolling 6 month assessment period that contains two
    quarters of assessment inputs and will continue until the ROP has
    been fully implemented. The assessment period will use the
    anniversary date that the construction assessment process began.
    Once a plant transitions to the ROP, the assessment process will
    revert to the calendar year process outlined in IMC 0305, "Operating
    Reactor Assessment Program."

The assessment program collects oversight information from continuous
NRC inspections of ongoing construction activities, the results of
periodic PI&R inspections conducted using Inspection Procedure (IP)
40504, "Part 52, Identification and Resolution of Construction
Problems", enforcement history, allegation trends, and safety culture to
provide an integrated assessment of licensee performance. The assessment
process will examine inspection observations and violations documented
in the Construction Inspection Program Information Management System
(CIPIMS) to determine if the licensee has demonstrated that its control
and oversight of construction programs and processes has resulted in
quality products.

The construction assessment process is divided into three basic parts:
continuous assessment, quarterly assessment, and SPR assessment. The
site construction team (including the Branch Chief) will continuously
assess licensee performance in accordance with Section 06.03.a of this
IMC by evaluating violations as they are identified and monitoring the
licensee's schedule and will make inspection plan adjustments as
necessary. A mid-quarter assessment letter may be issued when an
escalated enforcement action has been issued. Quarterly assessments will
be conducted by the site construction team (including the Branch Chief)
in accordance with Section 06.03.b of this IMC. The team will evaluate
violations identified during the most recent quarter and will determine
the appropriate CRT column that applies to licensee performance. If the
licensee has entered a CRT column requiring increased regulatory
response from the previous quarter and a mid-quarter assessment letter
has not been issued, a quarterly assessment letter will be issued to the
licensee. Semiannual performance review assessments will be conducted in
accordance with Section 06.03.c of this IMC. Violations identified
during the previous 6 months or remaining open from previous quarters
will be evaluated to determine if a common cause exists for the
violations warranting the identification of a CSFI (this concept is
under development). The existence of violations resulting in escalated
enforcement and CSFIs, if any, will be used as inputs to determine the
appropriate column of the CRT that applies to the licensee's
performance. The SPR assessment results will be communicated to the
licensee and the public via an SPR assessment letter. Agency response to
assessment results will also be communicated to the licensee and the
public when changes are made as a result of licensee performance issues.
Follow-up agency actions, as applicable, are conducted to ensure that
the licensee's/contractor's/vendor's corrective actions designed to
address performance weaknesses were effective.

The baseline inspection program is the lowest level of required NRC
inspections at each facility which are implemented at a given frequency
stated in the respective inspection procedures. The protocol for
selecting ITAAC for inspection in the baseline program is contained in
IMC-2503 and IP 65001, "Inspections of Inspections, Tests, Analyses, and
Acceptance Criteria (ITAAC) Related Work". The protocol for conducting
non-ITAAC inspections which are part of the baseline inspection program
is contained in IMC-2504. As set forth in both IMC-2503 and IMC-2504,
the observation of construction activities will also include monitoring
the implementation of the Quality Assurance (QA) program by the licensee
and its contractors to evaluate the ability to find and appropriately
characterize and resolve any occurrences of conditions adverse to
quality.

Since the NRC utilizes a sampling methodology, significant issues that
are identified could potentially have broader implications on the
licensee's performance than just the single issue. Based on this,
significant issues (escalated enforcement actions or CSFIs) are the
input to the CRT and will result in the inspection program being
expanded beyond the baseline inspection program to review either
additional samples in the area of concern or to review non-targeted
ITAAC in the area of concern. Significant violations (i.e. violations
resulting in escalated enforcement action) are normally considered in
the assessment program for six months from the date of the inspection
report in which the violation is issued or until the NRC accepts the
licensee's corrective actions (i.e., the violation is closed in CIPIMS),
whichever is longer. A significant violation will no longer be
considered in the assessment process starting with the quarter after the
above conditions have been met unless the NRC has justification to keep
the violation open in accordance with Section 06.07.b. CSFIs will be
carried forward until closed in a SPR assessment letter.

[]{#__RefHeading___Toc209075602 .anchor}06.03 [Performance
Reviews]{.underline}. The overall process for the assessment of licensee
performance consists of the series of actions that are listed below.

> a\. [Continuous Review]{.underline}. The site construction team
> (including the Branch Chief) will continuously monitor the performance
> of their assigned construction sites by evaluating findings as they
> are identified and monitoring the licensee's schedule and will make
> inspection plan adjustments as necessary. The region may issue a
> mid-quarter assessment letter to address an issue, in accordance with
> the CRT, between the normal quarterly assessments if a significant
> inspection violation (i.e. violations resulting in escalated
> enforcement action) is identified.

[]{.mark}

> b\. [Quarterly Review]{.underline}. The site construction team
> (including the Branch Chief) will conduct a quarterly (3 month) review
> utilizing inspection findings, enforcement history, allegation trends,
> and safety culture inputs compiled over the previous 6 months. This
> review should be conducted within 4 weeks after the conclusion of each
> quarter of the semiannual assessment period. The CRT shall be utilized
> to identify NRC Actions that should be taken which are not already in
> the existing inspection plan. If the licensee has entered a CRT column
> requiring NRC Actions beyond those that were identified during the
> previous assessment, a quarterly assessment letter will be issued to
> the licensee within 2 weeks after the quarterly review is completed.
>
> If, based on the continuous review discussed above, the region issued
> a mid-quarter assessment letter for any significant inspection
> violations identified during the past quarter, a subsequent quarterly
> assessment letter would not be necessary if its only purpose is to
> re-iterate any issues that had been previously addressed to the
> licensee.
>
> For plants whose performance is in the Expanded Program or
> Unacceptable Performance columns of the CRT, consideration shall be
> given at each quarterly review for engaging senior licensee and agency
> management in discussions associated with taking additional regulatory
> actions to address licensee performance issues. If there are
> significant changes in the inspection plan for a plant in the Expanded
> Program column of the CRT, the region should issue a separate
> quarterly assessment letter in order to ensure the licensee is aware
> of these changes.
>
> c\. [Semiannual Performance Review]{.underline}. The regional office
> will conduct an SPR utilizing the inspection findings compiled over
> the previous 6 months. This review incorporates activities from the
> previous SPR and quarterly review, including consideration of the
> conclusions of any independent assessments. The purpose of considering
> independent assessments is to provide a means of self-assessing the
> NRC inspection and assessment processes. References to independent
> assessments will not be included in the assessment letters. The output
> of this review is an SPR assessment letter to the licensee. The SPR
> and subsequent SPR assessment letters should only discuss issues
> identified during inspections that were completed prior to the end of
> the assessment period. Additional SPR activities include planning
> inspection activities through the next 6 months, discussing any
> potential CSFIs, and developing an input (if applicable) to support
> the AARM. The SPR meeting should be held within 6 weeks of the end of
> the assessment period. The CRT will be used to determine the scope of
> agency actions in response to assessment inputs.
>
> In preparation for the SPR's, the regional office shall develop a
> meeting agenda and a Construction Performance Review Package (CPRP)
> which includes the proposed inspection plan for the plant being
> assessed. The CPRP will assist the regional office in conducting the
> meeting and will form the basis for the SPR assessment letter. These
> packages will also be used at the Performance Review Summary Briefing
> with NRO Senior Management (if applicable) at the AARM (if
> applicable). The CPRP should include background on the facility, the
> applicable CRT column, any significant violations, any CSFIs with an
> evaluation of each, the status of NRC/licensee actions if other than
> in the Baseline Program column, the status of the CAP effectiveness
> reviews, any recommendations, and any other areas of interest (i.e.,
> ITAAC closure status, allegation trends, etc), as well as a proposed
> inspection plan. The regional Allegations Coordinator or the Agency
> Allegations Advisor should be consulted during development of the CPRP
> as necessary if any allegations have been raised. Each page of the
> meeting agenda and CPRP should be clearly marked as "pre-decisional"
> to ensure that the document is handled properly and not inadvertently
> released to the public.
>
> To aid in the discussion and integration of plant issues, the regional
> office should prepare a plant-specific CRT summary that identifies the
> plant-specific items and issues that meet the criteria given in the
> Results row for each CRT column, as applicable. The plant-specific CRT
> summary should display the quarterly status of significant violations,
> CSFIs, and the associated CRT column over a sufficient time line.
>
> The SPR meeting is chaired by the DCP Division Director or his/her
> designee. The regional Branch Chiefs (or designee) present the results
> of the semiannual review to the Deputy Regional Administrator for
> Construction (or designee). Other routine participants should include
> the applicable regional and resident inspectors, a representative from
> the NRO Construction Inspection and Allegations Branch (CCIB),
> applicable Project Managers from Division of New Reactor Licensing,
> and any other additional participants deemed necessary by the regional
> office. The average time allocated for each plant review is intended
> to be between 30 minutes and 2 hours and should be consistent with the
> number and significance of plant issues.
>
> The output of the SPR is the SPR assessment letter to the licensee.
> These letters shall be issued within 3 weeks of the completion of the
> SPR meeting. Signature authority for each SPR assessment letter is
> determined by the most significant column of the CRT that the plant
> has been in over the two quarters of the assessment period. This
> letter shall contain:
>
> 1\. A summary of significant violations (violations resulting in
> escalated enforcement action) that were inputs into the assessment as
> well as discussion of previous action taken by the licensee and the
> agency relative to these issues. Performance issues from previous
> quarters may be discussed if:
>
> \(a\) The agency's response to an issue had not been adequately
> captured in previous correspondence to the licensee.
>
> \(b\) These issues, when combined with assessment inputs from the most
> recent quarter, result in increased regulatory action per the CRT that
> would not be apparent from reviewing only the most recent quarter's
> results.
>
> 2\. A discussion of any deviations from the CRT during the assessment
> period.
>
> 3\. A qualitative discussion of CSFIs, if applicable.
>
> 4\. A discussion of the licensee's progress in addressing a CSFI, if
> documented in the previous SPR assessment letter.
>
> 5\. A discussion of significant (Severity Level III or greater)
> enforcement actions.
>
> 6\. A statement of any actions to be taken by the agency in response
> to safety significant issues, as well as any actions taken by the
> licensee.
>
> 7\. An inspection plan consisting of approximately 6 months of
> activities (from the issuance of the SPR assessment letter).
>
> A Performance Review Summary Briefing may be necessary prior to the
> AARM to summarize licensee performance results with NRO senior
> management. The regional staff will summarize the results of the SPR
> for those plants whose performance in one or more quarters in the
> previous 12 months has been in the Increased Focus Program column,
> Expanded Program column, or Unacceptable Performance column of the
> CRT. The Performance Review Summary Briefing will be scheduled
> approximately 1 month prior to the AARM.
>
> During the Performance Review Summary Briefing, the Director of NRO
> (or designee) will preside over the briefing while the Deputy Regional
> Administrator for Construction (or designee) will lead the discussion
> for the region. The Performance Review Summary Briefing is intended to
> provide information to senior NRO management regarding licensee
> performance. In preparation for the briefing, CCIB will develop an
> agenda for the meeting with input from the regional office. The
> regional office should provide their input to CCIB 3 working days
> prior to the briefing. The purpose of this briefing is for regional
> management to engage headquarters management on those discussion
> plants in order to ensure awareness of the plants to be discussed at
> the AARM and those agency actions already taken in response to plant
> performance.

## 06.04 [Program Reviews]{.underline}

> a\. [Agency Action Review Meeting]{.underline}. The AARM is an annual
> meeting that is chaired by the Executive Director for Operations (EDO)
> or designee and is attended by appropriate senior NRC managers. This
> meeting will include a review of the results of the construction
> inspection program, including a review of approved deviations from the
> CRT, and a discussion about sites under construction with significant
> performance weaknesses (i.e., sites that are in the Expanded Program
> or Unacceptable Performance columns of the CRT). This meeting is more
> completely described in Management Directive 8.14, "Agency Action
> Review Meeting."
>
> b\. [Commission Meeting]{.underline}. The EDO will brief the
> Commission semiannually to convey the results of the AARM, including a
> discussion of any deviations from the CRT. The Commission should be
> briefed within approximately four weeks of the AARM, consistent with
> Commission availability, to ensure that the information presented is
> as current as possible.

## 06.05 [Annual Meeting with Licensee]{.underline}

> a\. [Scheduling]{.underline}. A public meeting with the licensee will
> be conducted on an annual basis following issuance of every second SPR
> assessment letter to discuss the results of the NRC's assessment of
> the licensee's performance over the prior 12 month period. For plants
> that have been in the Expanded Program column or Unacceptable
> Performance column of the CRT during the previous 12 months, these
> meetings should be scheduled within 8 weeks of the end of the
> assessment period. These meetings should be conducted no earlier than
> 1 week after the SPR assessment letter is issued in order to allow
> time for the licensee to review the contents of the letter. The 8-week
> requirement may occasionally be exceeded to accommodate the licensee's
> schedule or regional scheduling conflicts. These meetings may be
> scheduled within 3 months of the issuance of the SPR assessment
> letters for plants that have been in the Baseline Program or Increased
> Focus Program column of the CRT during the previous 12 months. The
> meeting is conducted onsite or in the vicinity of the site and should
> be scheduled to ensure that it is accessible to members of the public.
> The regional office should use this meeting as an opportunity to
> engage interested stakeholders on the performance of construction at
> the plant and the role of the agency in ensuring that the plant is
> being constructed in accordance with the design and NRC regulations.
> NRC management, as specified in the CRT, conducts the public meeting.
> The appropriate level of NRC management to chair this meeting is
> determined by the most significant column of the CRT that the plant
> has been in during the previous 12 months. The highest level of NRC
> management, as allowed in the plant's performance column of the CRT,
> should chair the annual public meeting for those plants that currently
> have CSFIs as described in the SPR assessment letters.
>
> b\. [Meeting Preparation]{.underline}. The region shall notify those
> on distribution for the SPR assessment letters of the meeting with the
> licensee. The region shall notify the media and State and local
> government officials of the meeting with the licensee and the issuance
> of the SPR assessment letter. Commensurate with the level of
> historical interest and/or construction issues, the regional office
> should use the following additional tools to inform members of the
> public of the meeting, as appropriate: press releases, advertisements
> in local newspapers, or letters soliciting attendance to known
> interested parties.
>
> c\. [Conduct of Licensee Meeting]{.underline}. The annual public
> meeting is intended to provide an opportunity for the NRC to engage
> interested stakeholders on the performance of construction of the
> plant and the role of the agency in ensuring that the plant is being
> constructed in accordance with the design and NRC regulations. NRC
> management, as specified in the CRT, will discuss the agency's
> evaluation of licensee performance as documented in the SPR assessment
> letter. This meeting is considered to be a Category 1 meeting in
> accordance with the Commission's policy on public meetings.
>
> The last two SPR assessment letters provide the minimum performance
> information that should be conveyed to the licensee during the annual
> public meeting. However, this does not preclude the presentation of
> additional plant performance information when placed in the proper
> context. The licensee should be given the opportunity to respond at
> the meeting to any information contained in the SPR assessment letter.
> The licensee should also be given the opportunity to present to the
> NRC any new or existing programs that are designed to maintain or
> improve their current performance.
>
> The annual meeting will be a public meeting with the exception that
> the meeting must be closed for such portions which may involve matters
> that should not be publicly disclosed under Section 2.390 of Title 10
> of the Code of Federal Regulations (10 CFR 2.390). Members of the
> public, the press, and government officials from other agencies are
> considered as observers during the conduct of the meeting. However,
> attendees should be given the opportunity to ask questions of the NRC
> representatives after the conclusion of the meeting.

## 06.06 [NRC Responses to Licensee Performance]{.underline} 

> a\. [Description of the Construction Response Table]{.underline}. The
> CRT (Exhibit 2) was developed with the philosophy that, within a
> certain level of performance (i.e., the Baseline Program column),
> licensees would address their performance issues without additional
> NRC engagement beyond the baseline inspection program. Agency action
> beyond the baseline inspection program will normally occur only if
> assessment input thresholds are exceeded. The CRT identifies the range
> of NRC and licensee actions and the appropriate level of communication
> for varying levels of licensee performance.
>
> Overall response to licensee performance will be determined by the
> number of violations that rise to the level of escalated enforcement
> (Severity Level I, II, or III) in combination with the number of CSFIs
> (CSFI concept is under development). The NRC will utilize a graded
> approach in determining the response to the identified issues. This
> graded approach will result in an increase in sampling in the area(s)
> of concern, an increase in the ITAAC being inspected, and/or the
> issuance of a Confirmatory Action Letter (CAL), Demand for
> Information, and/or the issuance of an Order. Increased inspection,
> whether increased sampling or the selection of additional ITAAC, will
> be conducted through the use of expanded inspections.
>
> A few terms are used throughout the discussion of the CRT. These are:
>
> 1\. Regulatory Performance Meetings. Regulatory performance meetings
> are held between licensees and the agency to discuss corrective
> actions associated with significant violations (i.e. violations
> resulting in escalated enforcement action). Each significant
> assessment input shall be discussed in one of the forums listed below
> in order to arrive at a shared understanding of the performance
> issues, underlying causes, and planned licensee actions. These
> meetings may take place at periodic inspection exit meetings between
> the agency and the licensee, a periodic NRC management visit,
> conference calls, or public meetings after completion of the expanded
> inspection. This meeting should be documented in an inspection report
> or a public meeting summary, as appropriate.
>
> 2\. Licensee Action. Anticipated actions by the licensee in response
> to overall performance are indicated by the appropriate column of the
> CRT. If these actions are not being taken by the licensee, then the
> agency may consider increasing the scope of the applicable expanded
> inspection to appropriately address the area(s) of concern. This would
> not be considered a deviation from the CRT in accordance with Section
> 06.07 of this manual chapter.
>
> 3\. NRC Inspection. The range of NRC inspection activities in response
> to performance indicated by the appropriate column of the CRT.
>
> 4\. Regulatory Actions. The range of actions that may be taken by the
> agency in response to performance indicated by the appropriate column
> of the CRT.
>
> 5\. Communication. Communication between the licensee and the NRC is
> based on a graded approach. For declining licensee performance, higher
> levels of agency management will review and sign the assessment
> letters and conduct the annual public meeting.
>
> b\. [Expected Responses for Performance in Each Construction Response
> Table Column]{.underline}. The CRT lists expected NRC and licensee
> actions based on the inputs to the assessment process. Actions are
> graded such that the agency becomes more engaged as licensee
> performance declines. Listed below are the ranges of expected NRC and
> licensee actions for each column of the CRT:
>
> 1\. [CRT Baseline Program Column]{.underline}. Violations that are not
> greater than Severity Level IV and there are no CSFIs. The licensee
> will receive only the baseline inspection program and identified
> deficiencies will be addressed through the licensee's corrective
> action program.
>
> 2\. [CRT Increased Focus Program Column]{.underline}. There are no
> more than a combination of two Severity Level III violations and/or
> CSFIs. The licensee is expected to place the identified deficiencies
> in its corrective action program and perform an evaluation of the root
> and contributing causes. The licensee's evaluation will be reviewed
> during expanded inspection procedure (IP) 90001, "Increased Focus
> Program Inspection." Following completion of the inspection, the
> branch chief or division director should discuss the performance
> deficiencies and the licensee's proposed corrective actions with the
> licensee during a regulatory performance meeting which will normally
> occur at an inspection exit meeting, at a periodic NRC management
> visit, or during a conference call with the licensee.
>
> 3\. [CRT Expanded Program Column]{.underline}. A combination of three
> Severity Level III violations and/or CSFIs, or one Severity Level II
> violation. The licensee is expected to place the identified
> deficiencies in its corrective action program and perform an
> evaluation of the root and contributing causes for both the individual
> and the collective issues.
>
> The licensee's evaluation will be reviewed during IP 90002, "Expanded
> Program Inspection." Also, an independent assessment of the extent of
> condition will be performed by the region using appropriate inspection
> procedures chosen from the tables contained in IP 90002. Following
> completion of the inspection, the Deputy Regional Administrator (or
> designee) should discuss the performance deficiencies and the
> licensee's proposed corrective actions with the licensee during a
> Regulatory Performance Meeting which will normally consist of a public
> meeting with the licensee.
>
> 4\. [CRT Unacceptable Performance Column]{.underline}. One Severity
> Level I violation, multiple Severity Level II violations, or a
> combination of the following: One Severity Level II and a total of
> four Severity Level III violations/CSFIs; or a total of seven Severity
> Level III violations/CSFIs. The licensee is expected to place the
> identified deficiencies in its corrective action program and perform
> an evaluation of the root and contributing causes for both the
> individual and the collective issues. This evaluation may consist of a
> third party assessment.
>
> Expanded inspection procedure IP 90003, "Unacceptable Performance
> Inspection" will be performed to review the breadth and depth of the
> performance deficiencies. The expanded inspection plan must be
> approved by the appropriate regional division director with
> concurrence of the Director of the Division of Construction Inspection
> and Operational Programs (DCIP).
>
> Following the completion of the inspection, the EDO (or designee), in
> conjunction with the Regional Administrator and the Director of NRO,
> will decide whether additional agency actions are warranted. These
> actions could include additional expanded inspection, a Demand for
> Information, a CAL, or issuance of an Order, up to and including a
> stop work order. At a minimum, the regional office will issue a CAL to
> document the licensee's commitments as discussed in their performance
> improvement plan, as well as any other written or verbal commitments.
> The Regional Administrator should document the results of their
> decision in a letter to the licensee. These regulatory actions may
> also be considered prior to the completion of expanded inspection
> procedure IP 90003, if warranted. A Regulatory Performance Meeting
> will be conducted which will normally consist of a public meeting
> between the licensee and the EDO (or designee).
>
> Due to the depth and/or breadth of performance issues reflected by a
> plant being in the Unacceptable Performance column of the CRT, it is
> prudent to ensure that actual performance improvements (which may take
> two or more quarters to achieve) have been made prior to closing out
> the significant violations and exiting the Unacceptable Performance
> column of the CRT. In making this determination, the regional office
> should consider whether:
>
> \(a\) New plant issues or violations that do not reveal similar
> significant performance weaknesses.
>
> \(b\) The licensee's performance improvement program has demonstrated
> sustained improvement.
>
> \(c\) NRC expanded inspections show licensee progress in the principal
> areas of weakness.
>
> \(d\) There were no issues that led the NRC to take additional
> regulatory actions beyond those listed in the Unacceptable Performance
> column of the CRT. Additionally, the licensee has made significant
> progress on any regulatory actions that were imposed (i.e., CALs,
> orders, 50.54(f) letters) because of the performance deficiencies that
> led to the Unacceptable Performance column designation.
>
> After the original significant violations have been closed out, the
> licensee will return to the CRT column that is represented by the
> other outstanding inputs to the CRT. Additionally, for a period of up
> to one year after the initial significant violations have been closed
> out, the regional office may utilize some actions that are consistent
> with the Expanded Program column or Unacceptable Performance column of
> the CRT in order to ensure the appropriate level of agency oversight
> of licensee improvement initiatives. These actions, which do not
> constitute a deviation from the CRT, include senior management
> participation at periodic meetings/site visits focused on reviewing
> the results of improvement initiatives (such as efforts to reduce
> corrective action backlogs and progress in completing the Performance
> Improvement Plan), expanded inspection procedure IP 90003 and CAL
> follow up inspections (not to exceed 240 hours of direct inspection
> without concurrence from the Director, DCIP). The actions taken above
> those required by the CRT shall be discussed at the following SPR
> meetings to ensure an appropriate basis for needing the additional
> actions to oversee the licensee improvement initiatives. These actions
> will also be described in the following SPR assessment letters until
> the end of the extended period of time that the actions consistent
> with the Expanded Program column or Unacceptable Program column are
> taken to address licensee performance issues. All assessment letters
> that address these additional actions shall include CCIB on
> concurrence.
>
> The regional office must convey the specific actions that the licensee
> needs to address to remove the significant violations that caused the
> licensee to enter the Unacceptable Performance column from
> consideration in the assessment program. The correspondence to the
> licensee describing the extension of the significant violation(s) in
> the assessment program beyond the normal period discussed in Section
> 06.01 must be authorized by the appropriate regional division director
> with the concurrence of the Director, DCIP.

## 06.07 [Additional Construction Response Table Guidance]{.underline}

> a\. [Deviations from the CRT]{.underline}. There may be rare instances
> in which the regulatory actions dictated by the CRT may not be
> appropriate. In these instances, the agency may deviate from the CRT
> (which is described in Section 06.06.a of this manual chapter) to
> either increase or decrease agency action. A deviation is defined as
> any regulatory action taken that is inconsistent with the range of
> actions discussed in Section 06.06 of this manual chapter. Deviations
> from the CRT shall be documented in the appropriate letter to the
> licensee (i.e., quarterly or SPR assessment letter) or separate
> docketed correspondence. The EDO shall approve all deviations from the
> CRT and inform the Commission when deviations are approved and
> annually at the Commission meeting on the results of the AARM.
> Memorandums requesting deviations from the CRT should be initiated by
> the Regional Administrator to the EDO and should go through the
> Director of NRO for program office approval. Any deviations from the
> CRT shall be documented in the subsequent SPR assessment letter.
> Letters requesting deviations from the CRT should include a synopsis
> of the licensee performance deficiencies, the required NRC actions per
> the CRT for these inputs, the proposed alternative actions, and the
> region's rationale for requesting the deviation.
>
> b\. [Timeframe for Significant Violations in the Assessment
> Program]{.underline}. Significant violations (i.e. violations
> resulting in escalated enforcement action) are normally considered in
> the assessment program for six months from the date of the inspection
> report in which the violation is issued or until the NRC accepts the
> licensee's corrective actions (i.e., the violation is closed in
> CIPIMS), whichever is longer. There may be instances in which the
> corresponding expanded inspection reveals [substantive]{.underline}
> inadequacies in the licensee's evaluation of the root causes of the
> original performance deficiency, determination of the extent of the
> performance problems, or the actions taken or planned to correct the
> issue. Significant weaknesses in the licensee's evaluation of the
> performance issue may be subject to additional agency actions,
> including additional enforcement actions or an expansion of the
> expanded inspection procedure as necessary to independently acquire
> the necessary information to evaluate the licensee's actions to
> address the performance issue. The regional office must convey the
> specific weaknesses that the licensee needs to address in order to
> remove this violation from consideration in the assessment process.
> This notification should be included in the cover letter of the
> expanded inspection report.
>
> The correspondence to the licensee describing the extension of an
> inspection violation in the assessment process beyond the normal time
> frame must be authorized by the regional division director with
> concurrence of the Director of the Division of Construction Inspection
> and Operational Programs (DCIP). If this approach is taken by the
> agency, the region should issue a violation under 10 CFR Part 50,
> Appendix B, Criterion XVI, "Corrective Action," if applicable.

[]{#__RefHeading___Toc209075607 .anchor}06.08 [Corrective Action Program
(CAP) Effectiveness Reviews]{.underline}. A fundamental goal of the
NRC's oversight of new construction activities is to establish
confidence that licensees (and their contractors/vendors) are detecting
and correcting problems in a manner that ensures quality and safety are
top priorities and that construction activities will be completed in a
manner that ensures each plant is constructed in accordance with the
design and will operate safely. A key premise of NRC oversight is that
weaknesses in a licensee's CAP will manifest themselves as performance
issues that will be identified during the inspection program. Completion
of these objectives is accomplished by resident inspectors screening CAP
issues on a frequent basis, by performing a semiannual trend review, by
sampling issues during each inspection, by follow-up of selected NRC
identified issues, and by performing periodic PI&R team inspections.

The use of non-cited violations (NCVs) as part of the enforcement
process is predicated on a licensee having an adequate CAP into which
identified issues are entered and effectively resolved in a timely
manner. Because the CAP at construction sites will be new and
implemented initially by individuals with limited experience with the
new program and because construction will involve program implementation
by contractors, the NRC will delay the use of NCVs pending confirmation
that the new program is adequate and being adequately implemented.
Therefore, prior to or near the beginning of construction for each
plant, PI&R inspections will be conducted to allow the NRC to gather
sufficient information to make a timely decision that the licensee's CAP
has been adequately demonstrated for the purposes of issuing NCVs. After
the staff has concluded that a licensee's CAP is adequate, the PI&R
inspections will be conducted in accordance with a normal schedule.

Inspections will be conducted in accordance with IP 40505,
"Effectiveness of Process to Identify, Resolve, and Prevent Construction
Problems," to review the CAP program and to review the licensee's
implementation of the CAP. These inspections can be done either as a
single inspection or as two separate inspections. The inspections will
be conducted following the licensee's notification to the NRC that it is
ready for the inspection to be conducted. Since a licensee would need to
have a CAP in place prior to the start of construction, the program
review could be completed before construction begins. For the
implementation inspection, the licensee would need to determine that
sufficient CAP activity has occurred prior to notifying the NRC that it
is ready for the inspection to be conducted. The results of resident and
other inspections (vendor, remote location, specialist inspections, etc)
should be considered along with the results of the PI&R inspections in
formulating a decision.

In order for the licensee to successfully demonstrate to the NRC the
effectiveness of their CAP, the inspections (PI&R, baseline, vendor,
etc) conducted previously cannot have identified any significant issues
related to the CAP. Significant issues are considered to be any Severity
Level I, II, or III violations or any CSFIs related to an area of the
CAP. If significant issues have been previously identified then review
of the licensee's corrective actions for those issues should be
conducted to ensure that effective corrective actions have been taken to
resolve the issues such that there is reasonable assurance that they
will not recur. Both a programmatic and implementation inspection should
be conducted to conclude the licensee's CAP is adequate and being
adequately implemented before a conclusion can be reached on its
effectiveness. The determination of whether or not the licensee's CAP
has been adequately demonstrated for the purpose of issuing NCVs shall
be documented and communicated to the licensee in the PI&R inspection
report(s). The determination will also be documented in the first
assessment report issued following this determination. The criteria for
making a determination of CAP effectiveness are:

-   The licensee has established an adequate program.

-   The licensee has demonstrated adequate effectiveness in identifying
    and documenting problems (indicated by the lack of significant
    violations involving failure to identify and document adverse
    conditions).

-   The licensee has demonstrated adequate effectiveness in correcting
    problems and preventing recurrence (indicated by the lack of
    significant violations involving failure to take corrective action
    and prevent recurrence).

If a licensee's demonstrated CAP implementation degrades then it will be
necessary to evaluate the extent of the degradation to determine if the
enforcement process should revert to no longer issuing NCVs. This
decision will be made based on the nature of identified issues that
indicate a significant degradation of the licensee's CAP. The staff
expects that if the identified issues are significant, then the staff
will have taken escalated enforcement measures in accordance with the
NRC enforcement policy for new construction. Therefore, the issuance of
a Severity Level II violation against the licensee's CAP will be
considered one indicator that the program has sufficiently degraded such
that reverting to issuing Notices of Violations (NOVs) for all NRC
identified violations is appropriate. If the decision is reached to
revert to issuing NOVs, then it should be communicated to the licensee
as part of the assessment of licensee performance (i.e. included in the
SPR assessment letter or in a letter communicating the results of the
NRC quarterly assessment review). Following the licensee's corrective
actions to restore the effectiveness of their CAP, the process described
above to allow the NRC to issue NCVs would need to be repeated as
appropriate (i.e., if the degradation was limited to implementation and
not the program then the programmatic portion of the inspection need not
be re-done).

[]{#__RefHeading___Toc209075608 .anchor}06.09 [CSFIs]{.underline}.

This section is under development. An NRC working group has been tasked
with developing the guidance for this section with input from NRC
stakeholders and upon the completion of NRC's operating reactor efforts
in this area. After completion of the development work this section will
be revised to reflect the updated guidance.

END

EXHIBITS:

1\. Construction Assessment Process Activities

2\. Construction Response Table

3\. Construction Inspection Program

Attachment: Revision History for IMC 2505

Exhibit 1 -- Construction Assessment Process Activities

+---------+--------------+------------+------------+------------------+
| Level   | Frequency/   | Pa         | Desired    | Communication    |
| of      | Timing       | rticipants | Outcome    |                  |
| Review  |              |            |            |                  |
|         |              | (\         |            |                  |
|         |              | *indicates |            |                  |
|         |              | ch         |            |                  |
|         |              | airperson) |            |                  |
+---------+--------------+------------+------------+------------------+
| Con     | Continuous   | BC, PE,    | P          | None required,   |
| tinuous |              | SRI, RI,   | erformance | notify licensee  |
|         |              | regional   | awareness  | by a Quarterly   |
|         |              | i          |            | assessment       |
|         |              | nspectors, |            | letter           |
|         |              | SRAs       |            | [o               |
|         |              |            |            | nly]{.underline} |
|         |              |            |            | if thresholds    |
|         |              |            |            | crossed          |
+---------+--------------+------------+------------+------------------+
| Qu      | Once per     | BC, PE,    | In         | Update data set, |
| arterly | quarter;     | SRI, RI,   | put/verify | notify licensee  |
|         |              | regional   | CIPIMS     | by a Quarterly   |
|         | Four weeks   | i          | data,      | assessment       |
|         | after end of | nspectors, | detect     | letter           |
|         | quarter      | SRAs       | early      | [o               |
|         |              |            | trends     | nly]{.underline} |
|         |              |            |            | if thresholds    |
|         |              |            |            | crossed          |
+---------+--------------+------------+------------+------------------+
| Sem     | At           | DCP\* and  | Detect     | Semiannual       |
| iannual | Semiannual   | DCI DD,    | trends,    | Performance      |
| Perf    | Performance  | DCP and    | plan       | Review letter    |
| ormance | Review;      | DCI BCs    | in         | with an          |
| Review  |              |            | spections, | inspection plan  |
|         | Six weeks    |            | assess     | of approximately |
|         | after end of |            | plant      | 6 months         |
|         | second       |            | pe         |                  |
|         | quarter      |            | rformance, |                  |
|         |              |            | oversight, |                  |
|         |              |            | and        |                  |
|         |              |            | coordinate |                  |
|         |              |            | regional   |                  |
|         |              |            | actions    |                  |
+---------+--------------+------------+------------+------------------+
| Perf    | Two weeks    | NRO Senior | Summarize  | Information to   |
| ormance | after the    | M          | results of | be discussed at  |
| Summary | end of the   | anagement, | the        | Agency Action    |
| Meeting | Semiannual   | DRA,       | Semiannual | Review Meeting   |
|         | Performance  | Regional   | P          |                  |
|         | Review       | BCs, DCIP, | erformance |                  |
|         |              | other HQ   | Review for |                  |
|         |              | offices as | plants in  |                  |
|         |              | a          | other than |                  |
|         |              | ppropriate | the CRT    |                  |
|         |              |            | Baseline   |                  |
|         |              |            | Program    |                  |
|         |              |            | Review     |                  |
|         |              |            | column     |                  |
+---------+--------------+------------+------------+------------------+
| Agency  | Annually/    | EDO\*,DIR  | Review of  | Commission       |
| Action  |              | NRO, DRA,  | the        | briefing         |
| Review  | Several      | DCI/DCP    | appro      |                  |
|         | weeks after  | DDs, DCIP, | priateness |                  |
|         | issuance of  | OE, OI,    | of agency  |                  |
|         | the ROP      | other HQ   | actions    |                  |
|         | annual       | offices as |            |                  |
|         | assessment   | a          |            |                  |
|         | letters      | ppropriate |            |                  |
+---------+--------------+------------+------------+------------------+

Exhibit 2 - CONSTRUCTION RESPONSE TABLE

+---+------+--------------+--------------+--------------+--------------+
|   |      | Baseline     | Increased    | Expanded     | Unacceptable |
|   |      | Program      | Focus        | Program      | Performance  |
|   |      | column       | Program      | column       | column       |
|   |      |              | column       |              |              |
+---+------+--------------+--------------+--------------+--------------+
| ! |      | Only SL IV   | One or two   | Any          | One SL I     |
| [ |      | violations   | SLIII        | combination  | violation,   |
| ] |      | and no       | violations   | of three SL  | multiple     |
| ( |      | Construction | and/or       | III          | SLII         |
| m |      | Safety Focus | CSFIs.       | violations   | violations,  |
| e |      | Issues       |              | or CSFIs, or | or a         |
| d |      | (CSFIs).     | License      | one SL II    | combination  |
| i |      |              | requirements | violation.   | of the       |
| a |      | License      | met with     |              | following: 1 |
| / |      | requirements | some         | License      | SL II and a  |
| i |      | fully met    | challenges   | requirements | total of     |
| m |      |              | to licensee  | met with     | four SL III  |
| a |      |              |              | some         | viola        |
| g |      |              |              | significant  | tions/CSFIs; |
| e |      |              |              | challenges   | or a total   |
| 1 |      |              |              | to licensee  | of seven SL  |
| . |      |              |              |              | III          |
| w |      |              |              |              | violations   |
| m |      |              |              |              | and /or      |
| f |      |              |              |              | CSFIs.       |
| ) |      |              |              |              |              |
|   |      |              |              |              | Loss of      |
|   |      |              |              |              | Confidence   |
|   |      |              |              |              | to construct |
|   |      |              |              |              | within       |
|   |      |              |              |              | licensing    |
|   |      |              |              |              | requirements |
|   |      |              |              |              | in areas of  |
|   |      |              |              |              | concern      |
+---+------+--------------+--------------+--------------+--------------+
| ! | Re   | None         | Branch Chief | Deputy       | Executive    |
| [ | gula |              | (BC) or      | Regional     | Director for |
| ] | tory |              | Division     | A            | Operations   |
| ( |      |              | Director     | dministrator | (EDO) or     |
| m | Per  |              | (DD) Meet    | (DRA) or     | designee     |
| e | form |              | with         | designee     | meet with    |
| d | ance |              | Licensee     | meet with    | senior       |
| i |      |              |              | senior       | licensee     |
| a | Mee  |              |              | licensee     | management   |
| / | ting |              |              | management   |              |
| i |      |              |              |              |              |
| m |      |              |              |              |              |
| a |      |              |              |              |              |
| g |      |              |              |              |              |
| e |      |              |              |              |              |
| 2 |      |              |              |              |              |
| . |      |              |              |              |              |
| w |      |              |              |              |              |
| m |      |              |              |              |              |
| f |      |              |              |              |              |
| ) |      |              |              |              |              |
+---+------+--------------+--------------+--------------+--------------+
|   | Lice | Licensee     | Licensee     | Licensee     | Licensee     |
|   | nsee | Corrective   | root cause   | cumulative   | Performance  |
|   | Ac   | Action       | evaluation   | root cause   | Improvement  |
|   | tion |              | and          | evaluation   | Plan and     |
|   |      |              | corrective   | with NRC     | Independent  |
|   |      |              | action with  | Oversight.   | inspection   |
|   |      |              | NRC          |              | with NRC     |
|   |      |              | Oversight    |              | Oversight.   |
+---+------+--------------+--------------+--------------+--------------+
|   | NRC  | Baseline     | Limited      | Expanded NRC | Reactive     |
|   | In   | Inspection   | increase in  | oversight in | team         |
|   | spec |              | NRC          | area(s) of   | inspection   |
|   | tion | Program      | oversight of | concern.     | in area(s)   |
|   |      |              | area(s) of   | ITAAC sample | of concern.  |
|   |      |              | concern.     | increased as | Expanded     |
|   |      |              | Expanded     | appropriate. | inspection   |
|   |      |              | Inspection   | Expanded     | in           |
|   |      |              | in           | inspection   | accordance   |
|   |      |              | accordance   | in           | with IP      |
|   |      |              | with IP      | accordance   | 90003.       |
|   |      |              | 90001.       | with IP      |              |
|   |      |              |              | 90002.       |              |
+---+------+--------------+--------------+--------------+--------------+
|   | Re   | None         | Additional   | Additional   | At minimum,  |
|   | gula |              | inspection   | inspection   | issue        |
|   | tory | (Additional  | only.        | only.        | Confirmatory |
|   |      | actions      |              | Evaluate     | Action       |
|   | Act  | considered   | (Additional  | continued    | Letter.      |
|   | ions | for plants   | actions      | use of       | Evaluate     |
|   |      | exiting      | considered   | non-cited    | need for     |
|   |      | Expanded     | for plants   | violations.  | Demand for   |
|   |      | Program      | exiting      | (Additional  | Information  |
|   |      | column or    | Expanded     | actions      | and/or       |
|   |      | Unacceptable | Program      | considered   | Order.       |
|   |      | Performance  | column or    | for plants   | Discontinue  |
|   |      | column).     | Unacceptable | exiting      | use of       |
|   |      |              | Performance  | Unacceptable | non-cited    |
|   |      |              | column).     | Performance  | violations   |
|   |      |              |              | column).     |              |
+---+------+--------------+--------------+--------------+--------------+
| ! | As   | BC or DD     | DD           | DRA          | RA or EDO    |
| [ | sess | review/sign  | review/sign  | review/sign  | review/sign  |
| ] | ment | assessment   | assessment   | assessment   | assessment   |
| ( |      | report (w/   | report       | report       | report (w/   |
| m | Let  | inspection   |              |              | inspection   |
| e | ters | plan)        | (w/          | (w/          | plan)        |
| d |      |              | inspection   | inspection   |              |
| i |      |              | plan)        | plan)        |              |
| a |      |              |              |              |              |
| / |      |              |              |              |              |
| i |      |              |              |              |              |
| m |      |              |              |              |              |
| a |      |              |              |              |              |
| g |      |              |              |              |              |
| e |      |              |              |              |              |
| 3 |      |              |              |              |              |
| . |      |              |              |              |              |
| w |      |              |              |              |              |
| m |      |              |              |              |              |
| f |      |              |              |              |              |
| ) |      |              |              |              |              |
+---+------+--------------+--------------+--------------+--------------+
|   | An   | SRI or BC    | BC or DD     | DRA (or      | EDO (or      |
|   | nual | Meet with    | Meet with    | designee)    | designee)    |
|   | Pu   | Licensee     | Licensee     | Discuss      | Discuss      |
|   | blic |              |              | Performance  | Performance  |
|   |      |              |              | with         | with         |
|   | Mee  |              |              | Licensee     | Licensee     |
|   | ting |              |              |              |              |
+---+------+--------------+--------------+--------------+--------------+
|   | Co   | None         | None         | None         | Commission   |
|   | mmis |              |              |              | Meeting with |
|   | sion |              |              |              | Senior       |
|   |      |              |              |              | Licensee     |
|   | Inv  |              |              |              | Management   |
|   | olve |              |              |              |              |
|   | ment |              |              |              |              |
+---+------+--------------+--------------+--------------+--------------+
|   | IN   |              |              |              |              |
|   | CREA |              |              |              |              |
|   | SING |              |              |              |              |
|   | S    |              |              |              |              |
|   | AFET |              |              |              |              |
|   | Y/RE |              |              |              |              |
|   | GULA |              |              |              |              |
|   | TORY |              |              |              |              |
|   | SIGN |              |              |              |              |
|   | IFIC |              |              |              |              |
|   | ANCE |              |              |              |              |
|   | \    |              |              |              |              |
|   | -\-\ |              |              |              |              |
|   | -\-\ |              |              |              |              |
|   | -\-\ |              |              |              |              |
|   | -\-\ |              |              |              |              |
|   | --\> |              |              |              |              |
+---+------+--------------+--------------+--------------+--------------+

Exhibit 3 - Construction Inspection Program

![](media/image4.wmf)

Attachment 1 - Revision History for IMC 2505

+--------+--------+-------------------+--------+-------+--------------+
| Comm   | Issue  | Description of    | Tr     | Tra   | Comment      |
| itment | Date   | Change            | aining | ining | Resolution   |
| Tr     |        |                   | Re     | Compl | Accession    |
| acking |        |                   | quired | etion | Number       |
| Number |        |                   |        | Date  |              |
+--------+--------+-------------------+--------+-------+--------------+
| N/A    | 10     | New Issue to      | None   | N/A   | ML082480657  |
|        | /20/08 | support Licensing |        |       |              |
|        |        | under 10CFR52.    |        |       |              |
|        | CN     |                   |        |       |              |
|        | 08-029 | CNs for the past  |        |       |              |
|        |        | 4 years were      |        |       |              |
|        |        | reviewed and no   |        |       |              |
|        |        | commitments       |        |       |              |
|        |        | found.            |        |       |              |
+--------+--------+-------------------+--------+-------+--------------+
|        |        |                   |        |       |              |
+--------+--------+-------------------+--------+-------+--------------+
|        |        |                   |        |       |              |
+--------+--------+-------------------+--------+-------+--------------+