**NRC INSPECTION MANUAL** IRIB

INSPECTION PROCEDURE 71153

FOLLOWUP OF EVENTS AND NOTICES OF ENFORCEMENT DISCRETION

PROGRAM APPLICABILITY: 2515

CORNERSTONES: ALL

71153-01 INSPECTION OBJECTIVE

01.01 Evaluate licensee events and degraded conditions for plant status
and mitigating actions in order to provide input in determining the need
for an Incident Investigation Team (IIT), Augmented Inspection Team
(AIT), or Special Inspection (SI).

01.02 Review written licensee event reports (LERs).

01.03 Review personnel performance during planned non-routine plant
evolutions and/or contribution to unplanned non-routine evolutions,
events and transient operations.

01.04 Review granted Notices of Enforcement Discretion (NOEDs).

71153-02 INSPECTION REQUIREMENTS

02.01 Event Follow Up

> a\. Collect the information necessary to communicate the event details
> to supervision and management for a determination of the appropriate
> agency response. Observe plant parameters and status.
>
> b\. Evaluate performance of mitigating systems and licensee actions.
>
> c\. Confirm that the licensee properly classified the event in
> accordance with emergency action level procedures and made timely
> notifications to NRC and state/county governments, as required (10 CFR
> Parts 20, 50.9, 50.72).
>
> d\. Communicate details regarding the event to management, risk
> analysts and others in the Region and Headquarters as input to
> determining the need for an IIT, AIT, or SI.
>
> e\. Retain observations related to apparent performance issues and
> contributing factors for potential follow-up by the IIT, AIT, SI, or
> appropriate Reactor Oversight Process (ROP) baseline inspection.

02.02 [Event Report Review]{.underline}

LERs and related documents regarding the accuracy of the LER (e.g.,
based on independent NRC observations in an SI), appropriateness of
corrective actions, violations of requirements, and generic issues.

02.03 [Personnel Performance]{.underline}

> a\. Evaluate operator performance in planned and unplanned non-routine
> events and transients. Evaluate the initiating cause of reactor trips
> involving operator errors, and the personnel response to reactor trips
> requiring more than routine operator actions. Determine if the
> response was appropriate and in accordance with procedures and
> training.
>
> b\. For unplanned occurrences, where personnel error was an initiating
> cause, review operator logs, plant computer data, or strip charts
> after stable plant operations have been resumed. For planned
> non-routine evolutions, review the plan for the evolution, procedures,
> briefings, and contingency plans.

02.04 [NOED Review]{.underline}

Review NOED and *related documents to verify the accuracy of the NOED
and its consistency with* licensee oral assertions, and implementation
of compensatory measures and commitments. In addition, assess the
adequacy of licensee corrective actions and root cause determinations,
and determine if NRC requirements have been violated.

71153-03 INSPECTION GUIDANCE

[General]{.underline}

MD 8.3, "NRC Incident Investigation Program," defines a significant
operational event as a radiological, safeguards, or other safety-related
operational event at an NRC-licensed facility that poses an actual or
potential hazard to public health and safety, property, or the
environment. At power reactors, these events include significant
unplanned degraded conditions identified by the licensee or NRC.

The staff uses MD 8.3 and Inspection Manual Chapter (IMC) 0309,
"Reactive Inspection Decision Basis for Reactors", to determine the
appropriate NRC response to a significant operational event

Following notification of an event or during an event, the responding
on-site inspectors provide details regarding plant status and
performance of equipment and personnel to management, event review staff
and regional and headquarters risk analysts. The details are used to
determine the level of agency response, investigatory response if any,
i.e., IIT, AIT, or SI, and any special resources and expertise needed
for event followup. If no reactive inspection is warranted in accordance
with MD 8.3 and IMC 0309, the event would be followed up through the
applicable ROP baseline inspection procedure(s).

Appendix A illustrates the relationship between event response and the
ROP.

Appendix B provides guidance for limiting NRC's impact on licensees
during an event.

[Specific Guidance]{.underline}

03.01 [Event Follow Up]{.underline}

> a\. Obtain understanding of plant status, equipment/personnel
> performance and plant management decisions to assist NRC management in
> making an informed evaluation of plant conditions. Observe plant
> parameters and status for mitigating systems/trains and fission
> product barriers. Information sources include drawings, system
> descriptions, control board indications, plant logs, computer data,
> recorders, and licensee personnel.
>
> b\. Evaluate whether the licensee has appropriately resolved event
> issues prior to restart, where applicable, such as by attending
> meetings of the Plant Oversight Review Committee.
>
> c\. No specific guidance.
>
> d\. MD 8.3 and IMC 0309 provide deterministic criteria which are
> applicable to power reactors. Inspectors provide details which help
> determine whether the event meets the deterministic criteria. An IIT,
> AIT, or SI is considered for certain events or degraded conditions
> meeting deterministic criteria without any probabilistic risk input,
> e.g., exceed a safety limit of the licensee's technical
> specifications, site area emergency, significant radiological release,
> significant occupational or public exposure, and safeguards concerns.
>
> Other deterministic criteria related to events or degraded conditions
> are risk informed, e.g., loss of a safety function or multiple
> failures in systems used to mitigate an event. For events meeting
> these criteria, risk analysts estimate Conditional Core Damage
> Probability (CCDP). For degraded conditions meeting these criteria,
> risk analysts estimate Incremental Conditional Core Damage Probability
> (ICCDP). These estimates are often based only on best available
> information at an early stage in the development of the facts. If a
> quantitative CCDP cannot be obtained, the risk analyst provides
> qualitative risk insights. In all cases, the risk guidelines of MD 8.3
> and IMC 0309 are not prescriptive, and are to be used with an
> understanding of the greatest uncertainties. When appropriate, risk
> analysts can also evaluate containment performance by calculating
> Conditional Large Early Release Probability (CLERP) or Incremental
> Conditional Large Early Release Probability (ICLERP).
>
> The above process is described in IMC 0309 and MD 8.3, Part I, Pages 4
> through 8. They include tables which recommend appropriate event
> response options (IIT, AIT, or SI) as a function of CCDP (or ICCDP)
> and CLERP (or ICLERP).
>
> To assist risk analysts, inspectors provide input (in addition to a
> and b above), such as equipment malfunctions/unavailabilities and
> operator errors. Inspectors verify the availability of mitigation
> equipment not required to operate during the event, but which could
> contribute to increased risk if unavailable. If the event corresponds
> to an SDP Phase 2 worksheet (e.g., transient, loss of offsite power),
> the worksheets can identify the most likely core damage sequences that
> include known failure of equipment and/or operator error and the
> remaining mitigation capability for reactor safety. The inspector
> should verify the availability of this mitigation capability.
>
> e\. *Inspectors should provide the followup inspection team leader
> with any information on potential contributing factors that may assist
> the follow up assessment of the event. Information should include any
> issues noted with components of safety culture as described in IMC
> 0305, "Operating Reactor Assessment Program." Information about
> observing a safety conscious work environment is contained in IP
> 71152, \"Identification and Resolution of Problems.\" The information
> is provided for followup by IIT, AIT, SI, or ROP baseline
> inspection(s). The staff assigned to review the event as the agency
> response are responsible for documentation in accordance with the
> procedure governing the activity.* \[C1\]

03.02 Event Report Review

Review written LERs, but not telephone notifications to the NRC
Operations Center for invalid actuations, as allowed in 10 CFR 50.73.
LERs that involve operator errors are reviewed under Section 02.03.
Licensee resolution of issues may be addressed under the Identification
and Resolution of Problems sections of individual baseline inspection
procedures. IMC 0612, "Power Reactor Inspection Reports," covers
documentation of LER reviews.

03.03 Personnel Performance

No guidance

03.04 [NOED Review]{.underline}

Part 9900, Technical Guidance, NOED.TG, "Operations - Notices of
Enforcement Discretion," covers NRC enforcement discretion regarding
conditions such as limiting conditions for operation in power reactor
technical specification. NRC Enforcement Manual (Section 6.4, NOED) on
OE's website covers the need for and processing of enforcement
(http://www.nrc.gov/reading-rm/doc-collections/enforcement/notices/more.html).
OE approval is required if more than a minor violation is involved and
the inspector decides not to pursue an enforcement action, i.e., notice
of violation or a non-cited violation.

71153-04 RESOURCE ESTIMATE

Annual hours for one unit: 105; two units: 115; three units: 120.

71153-05 COMPLETION STATUS

Inspection of the minimum sample size constitutes completion of this
procedure in the Reactor Programs System inspection tracking system.
Minimum sample size (regardless of the number of units) is 1 for event
followup and NOEDs. Event followup includes non-routine and transient
operations involving personnel performance, all reactor trips requiring
more than routine operator response, and all LERs.

71153-06 REFERENCES

Management Directive 8.3, "NRC Incident Investigation Program"

Inspection Manual Chapter 0305, "Operating Reactor Assessment Program"

Inspection Manual Chapter 0309, "Reactive Inspection Decision Basis for
Reactors"

Inspection Manual Chapter 0609, "Significance Determination Process"

Inspection Manual Chapter 0612, "Power Reactor Inspection Reports"

Inspection Procedure 71152, \"Identification and Resolution of
Problems\"

Inspection Procedure 93800, "Augmented Inspection Team"

Inspection Procedure 93812, "Special Inspection"

Enforcement Manual Section 6.4, "Notice of Enforcement Discretion"

Inspection Manual Part 9900, Technical Guidance, "Operations - Notices
of Enforcement Discretion"

END

Appendix A

RELATIONSHIP OF EVENT FOLLOWUP TO REACTOR OVERSIGHT PROCESS

![](media/image1.wmf)

BLOCK 1A --- A significant operational event is a radiological,
safeguards, or other safety-related operational event that poses an
actual or potential hazard to public health and safety, property, or the
environment.

BLOCK 1B - Significant unplanned degraded conditions may be identified
by the licensee or NRC. Plant configurations due solely to planned
maintenance need not be considered.

BLOCK 1C --- Performance indicator (PI) thresholds are in units of
change in annualized Core Damage Frequency (delta annualized CDF). Some
events, such as reactor trips may also be counted in PI data.

BLOCK 2 --- Licensee notification occurs.

BLOCK 3 --- Licensee notifications in accordance with 10 CFR 50.72 are
one means of activating IP 71153 initial event followup by on-site NRC
inspectors. If an on-site inspector is not immediately available, this
responsibility transfers to the Headquarters Operations Officer until
regional personnel can respond.

BLOCK 4 --- Management Directive 8.3, Part I and IMC 0309 include
deterministic criteria. Events meeting criteria which are not risk
informed may result in IITs, AITs, or SIs. Power reactor events/degraded
conditions meeting risk informed criteria are evaluated for CCDP/ICCDP
or CLERP/ICLERP.

BLOCK 5 --- For events, risk analysts use NRC's Standardized Plant
Analysis of Risk models and other available tools to estimate CCDP,
which accounts for all equipment unavailability, regardless of cause.
For degraded conditions, ICCDP is used for risk significance. Initial
estimates of CCDP/ICCDP may be made within 4-8 hours of receiving
relevant information. Inspectors support risk analysts by providing
event details such as equipment malfunction/unavailability, operator
errors, and equipment out of service for maintenance. For assessing
degraded condition exposure time, assume T/2 if time of unavailability
is unknown. T is the time interval from the last known operability until
discovery of the degraded condition. Inspectors verify availability of
mitigation equipment or containment function that were not required
during the event, but which could contribute to increased risk if
unavailable. Inspectors use plant-specific SDP phase 2 worksheets to
gain qualitative risk insights of events.

BLOCK 6 --- The table in IMC 0309 and on Page 6 of Management Directive
8.3, Part I, lists appropriate power reactor operational event response
options (IIT, AIT, SI) as a function of CCDP (or ICCDP). This
determination considers the uncertainty of influential assumptions and
their effect on risk significance.

BLOCK 7 --- Special Inspections, Augmented Inspection Teams, and
Incident Investigation Teams evaluate events/degraded conditions and
their root causes, and identify licensee performance issues.

BLOCK 8 --- Licensee performance issues are evaluated with the SDP
(considering only performance-related equipment unavailabilities),
placing the issues in delta annualized CDF bands.

BLOCK 9 --- Because PI thresholds are in units of delta annualized CDF,
PIs and SDP results are combined in the NRC Action Matrix to determine
agency responses to the performance issues identified by the event
response.

Appendix B

LIMITING NRC IMPACT DURING EVENTS

I. Inspector Conduct While in the Control Room

For plant events, inspectors must perform sufficient inspection to
develop an independent assessment of plant conditions, which will be
used in making decisions on NRC's responses to an event. Activities that
form the basis for this assessment may include independent measurements,
verifying the accuracy of information, control board walkdowns (to
observe annunciators, process parameters, switch positions, and other
instrumentation), or assessment of licensed operator performance during
ongoing activities.

The NRC\'s goal is to monitor and assess with as little impact on the
licensee as possible and at the same time ensure NRC evaluations are
timely and accurate. During plant events, timely and independent
inspector assessments are crucial; however, the degree of interaction
with operators may be limited in light of ongoing control room
activities. The inspector must use judgement in establishing a balance
between obtaining necessary information and not being intrusive in
licensee response activities. The appropriate balance involves numerous
variables, including safety significance of the event, complexity of the
event, time constraints, and available staff.

The following guidance is provided to establish consistency for
inspector conduct in the control room. When the NRC activates its
emergency response plan, inspectors should follow the guidance in the
applicable emergency response procedure. This guidance is intended for
use in situations where the NRC has not activated its emergency response
plan; however an abnormal event has happened at the plant. Inspectors
should note that some of the guidance, such as inspector location in the
control room and not interrupting operators, apply to all emergency
situations. While this guidance deals mainly with event responses,
specific attributes are applicable to inspector interaction with
operators during normal conditions both in and outside the control room.

> a\. During the initial response to events, the assigned senior
> resident inspector (SRI) or the inspector acting in this capacity is
> in charge of all other NRC inspectors. These inspectors will take
> their direction from the SRI.
>
> b\. The number of inspectors in the control room at any given time
> should be the minimum number needed to accomplish the agency\'s work.
> Typically there should be only one inspector in the control room
> during an event, unless special circumstances warrant additional
> inspectors. If several inspectors or other NRC personnel are in the
> control room during an event, the SRI or resident inspector will be in
> charge of them and will determine and communicate to the other
> inspectors and personnel what, if any, assistance is needed.
>
> c\. Inspectors will adhere to the licensee's established
> administrative policies regarding entry into the restricted or \"at
> the controls\" area of the control room. For example, the inspector
> may need to ask the control room SRO or RO for permission to enter the
> restricted area. Under no circumstances should the inspector demand
> entry into the restricted area. If such entry is denied, the inspector
> should escalate the request to the licensee's management and inform
> NRC management of the problem. For general access to the control room,
> the licensee\'s policy should recognize that inspector access will be
> unannounced. Inspectors who do not routinely enter the control room
> should identity themselves to the operators when they enter the
> control room.
>
> d\. While observing ongoing activities in the control room, the
> inspector should be in a location which is out of the way of operators
> and does not obstruct their view of the reactor controls and
> instrumentation, yet the location provides the inspector with a broad
> view of the control room. An acceptable location outside the
> restricted \"at the controls\" area is preferable. It is recognized
> that short amounts of time in the restricted area may be necessary at
> appropriate stable time periods to verify significant parameters.
>
> e\. Operators should not be interrupted, questioned or otherwise
> distracted from performing their duties while responding to an event
> or while performing other duties where their attention must be focused
> on the task at hand. Also, inspectors should not interfere, interrupt,
> or otherwise disturb communications between operators and
> communications between operators and their supervision.
>
> f\. If an inspector identifies a significant problem or question about
> plant or operator safety that needs to be addressed in an urgent
> manner, then the inspector should discuss it quickly and quietly at a
> time when it will not interrupt ongoing operator actions. This
> discussion should be held with the shift supervisor or emergency
> response manager. However, it may be appropriate to interrupt the
> operator if the inspector feels that an operator action may endanger
> plant personnel or the plant. Inspectors should hold their non-urgent
> questions for a more appropriate time.
>
> g\. NRC personnel communicating with off-site organizations should
> generally do so from outside of the control room. Communication is
> possible from the NRC phone in the TSC or other phones outside the
> control room that have been agreed to with the licensee. It is
> acceptable for the inspector to make a phone call from the control
> room provided the licensee agrees to the use of the phone and the
> phone conversation will not disrupt control room activities.
>
> h\. Because of the authoritative role of the NRC, licensees listen
> carefully to inspectors and may interpret statements, side remarks, or
> observations as directives or requirements. Consequently, open, clear,
> and direct communications between inspectors and licensees are
> particularly important during events.

II\. Conference Calls With Licensees During an Ongoing Event

When initially responding to an event, the NRC is dependent upon
information provided by licensees and inspectors at the plant (typically
resident inspectors). This information is used for initially assessing
events and making decisions about how to respond to the event. The NRC
typically gets this initial information from licensees through their
notification to the NRC Operations Center pursuant to 10 CFR 50.72 or
from conference calls between the NRC staff and the licensee. The NRC
values conference calls as an efficient method of obtaining accurate and
timely information. Such calls promote a mutual understanding of the
facts and any concerns.

Caution is needed in scheduling and conducting conference calls when the
calls are held during an ongoing event or situations where heightened
licensee attention is being directed to a plant evolution. While
information obtained in a conference call is extremely valuable to the
NRC\'s overall understanding of a plant event, the overriding goal is
that the call will not interfere or detract from the licensee\'s ability
to safely operate the plant. The following guidance should be used for
conducting conference calls with licenses during abnormal plant
conditions. Examples of abnormal plant conditions would be the
declaration of a Notification of Unusual Event (NOUE) or the use of an
emergency operating procedure (EOP).

> a\. NRC management should decide whether a conference call with the
> licensee is needed and if conducting a conference call is appropriate
> at that particular time. NRC management may want to discuss with
> senior licensee management the possibility of conducting a conference
> call. The stability of the plant is the primary factor in deciding on
> a conference call. Other factors to be considered in this decision
> include: the current level of NRC staff understanding and information
> available for the event; the safety significance of the event; the
> complexity of the event; and the current level of licensee activity in
> mitigating the event.
>
> b\. Generally the licensee should be informed of the NRC\'s desire to
> have a conference call by the senior resident inspector or resident
> inspector if they are available. The licensee must be included in
> deciding the most appropriate time for the call so that the call does
> not interfere with plant response activities. Also the licensee should
> decide which individuals from their staff will participate in the
> call.
>
> When requesting the conference call, the licensee must be clearly
> informed of the NRC\'s desire that the conference call not interfere
> with their response to plant conditions and that delaying the call is
> a valid option for them.
>
> c\. NRC technical staff and management with the right background
> should participate in the conference call to ensure proper questioning
> and understanding of the event and associated issues. The senior NRC
> manager on the call should identify his/her self and is responsible
> for ensuring that the conference call discussions are properly focused
> on important issues and that side issues are discussed at another
> time.
>
> d\. If time allows, an agenda for the conference call should be
> developed to ensure the call remains properly focused. The licensee
> should be informed of the proposed discussion topics and planned NRC
> participants to allow the licensee to prepare for the call.
>
> e\. Any follow-up actions resulting from the conference call should be
> summarized at the end of the call by an NRC manager to ensure the
> licensee clearly understands and agrees with the actions.

ATTACHMENT 1

[Revision History for IP 71153]{.underline}

+--------+--------+---------------------+--------+-------+------------+
| Comm   | Issue  | Description of      | Tr     | Tra   | Comment    |
| itment | Date   | Change              | aining | ining | Resolution |
| Tr     |        |                     | Needed | Compl | Accession  |
| acking |        |                     |        | etion | Number     |
| Number |        |                     |        | Date  |            |
+========+========+=====================+========+=======+============+
| N/A    | 06     | Revision history    | N/A    | N/A   | N/A        |
|        | /22/06 | reviewed for the    |        |       |            |
|        |        | last four years.    |        |       |            |
+--------+--------+---------------------+--------+-------+------------+
| N/A    | 04     | IP 71153 (Event     | None   | N/A   | N/A        |
|        | /04/00 | Followup) is        |        |       |            |
|        |        | revised to provide  |        |       |            |
|        | CN     | inspection          |        |       |            |
|        | 00-005 | requirements and    |        |       |            |
|        |        | guidance for review |        |       |            |
|        |        | of event reports.   |        |       |            |
+--------+--------+---------------------+--------+-------+------------+
| N/A    | 03     | IP 71153 (Event     | None   | N/A   | N/A        |
|        | /06/01 | Followup) has been  |        |       |            |
|        |        | revised to better   |        |       |            |
|        | CN     | define the scope of |        |       |            |
|        | 01-006 | the IP, to expand   |        |       |            |
|        |        | the definition of   |        |       |            |
|        |        | power reactor       |        |       |            |
|        |        | events to include   |        |       |            |
|        |        | degraded            |        |       |            |
|        |        | conditions, and to  |        |       |            |
|        |        | integrate the IP    |        |       |            |
|        |        | with the options    |        |       |            |
|        |        | for inspection      |        |       |            |
|        |        | activities related  |        |       |            |
|        |        | to the              |        |       |            |
|        |        | deterministic and   |        |       |            |
|        |        | risk criteria in MD |        |       |            |
|        |        | 8.3 .               |        |       |            |
+--------+--------+---------------------+--------+-------+------------+

+--------+--------+---------------------+--------+-------+------------+
| N/A    | 01     | IP 71153 (Event     | None   | N/A   | N/A        |
|        | /17/02 | Followup) has been  |        |       |            |
|        |        | revised to delete   |        |       |            |
|        | CN     | the previous        |        |       |            |
|        | 02-001 | Appendix A since    |        |       |            |
|        |        | that material was   |        |       |            |
|        |        | included in         |        |       |            |
|        |        | Management          |        |       |            |
|        |        | Directive 8.3. It   |        |       |            |
|        |        | also clarifies that |        |       |            |
|        |        | written LERs are to |        |       |            |
|        |        | be reviewed, but    |        |       |            |
|        |        | not telephone       |        |       |            |
|        |        | notifications to    |        |       |            |
|        |        | the NRC Operations  |        |       |            |
|        |        | Center for invalid  |        |       |            |
|        |        | actuations, as      |        |       |            |
|        |        | allowed in 10 CFR   |        |       |            |
|        |        | 50.73.              |        |       |            |
+--------+--------+---------------------+--------+-------+------------+
| N/A    | 04     | IP 71153 (Event     | None   | N/A   | N/A        |
|        | /16/02 | Followup) has been  |        |       |            |
|        |        | revised to provide  |        |       |            |
|        | CN     | guidance on         |        |       |            |
|        | 02-017 | assessing degraded  |        |       |            |
|        |        | condition exposure  |        |       |            |
|        |        | time if time of     |        |       |            |
|        |        | unavailability is   |        |       |            |
|        |        | unknown.            |        |       |            |
+--------+--------+---------------------+--------+-------+------------+
| N/A    | 06     | IP 71153 (Event     | None   | N/A   | N/A        |
|        | /24/03 | Followup) this      |        |       |            |
|        |        | clarifies that the  |        |       |            |
|        | CN     | risk metric for     |        |       |            |
|        | 03-020 | events is           |        |       |            |
|        |        | Conditional Core    |        |       |            |
|        |        | Damage Probability  |        |       |            |
|        |        | (CCDP) and the      |        |       |            |
|        |        | metric for degraded |        |       |            |
|        |        | conditions is       |        |       |            |
|        |        | incremental CCDP.   |        |       |            |
|        |        | Also this revision  |        |       |            |
|        |        | lists examples of   |        |       |            |
|        |        | events addressed by |        |       |            |
|        |        | this IP in          |        |       |            |
|        |        | cornerstones        |        |       |            |
|        |        | outside of reactor  |        |       |            |
|        |        | safety.             |        |       |            |
+--------+--------+---------------------+--------+-------+------------+
| C1     | 06     | Incorporate safety  | Ins    | 07/   | M          |
|        | /22/06 | culture into        | pector | 01/06 | L061570089 |
|        |        | inspection          | tr     |       |            |
|        | CN-    | procedures. \"Staff | aining |       |            |
|        | 06-015 | Requirements -      | on use |       |            |
|        |        | SECY-04-0111 -      | of     |       |            |
|        |        | Recommended Staff   | safety |       |            |
|        |        | Actions Regarding   | c      |       |            |
|        |        | Agency Guidance in  | ulture |       |            |
|        |        | the Areas of Safety | in the |       |            |
|        |        | Conscious Work      | ROP.   |       |            |
|        |        | Environment and     |        |       |            |
|        |        | Safety Culture\"    |        |       |            |
|        |        | August 30, 2004     |        |       |            |
+--------+--------+---------------------+--------+-------+------------+
| N/A    | 07     | Add inspections of  | None   | N/A   | M          |
|        | /26/06 | (1) personnel       |        |       | L061770161 |
|        |        | performance during  |        |       |            |
|        | CN-    | planned non-routine |        |       |            |
|        | 06-018 | plant evolutions    |        |       |            |
|        |        | and/or contribution |        |       |            |
|        |        | to unplanned        |        |       |            |
|        |        | non-routine         |        |       |            |
|        |        | evolutions, events  |        |       |            |
|        |        | and transient       |        |       |            |
|        |        | operations          |        |       |            |
|        |        | (previously in IP   |        |       |            |
|        |        | 71111.14); and (2)  |        |       |            |
|        |        | granted Notices of  |        |       |            |
|        |        | Enforcement         |        |       |            |
|        |        | Discretion.         |        |       |            |
+--------+--------+---------------------+--------+-------+------------+
| N/A    | 02     | Clarified the       | None   | N/A   | N/A        |
|        | /12/08 | process of using    |        |       |            |
|        |        | both MD 8.3 and IMC |        |       |            |
|        | CN     | 0309 to determine   |        |       |            |
|        | 08-007 | appropriate         |        |       |            |
|        |        | responses to        |        |       |            |
|        |        | significant         |        |       |            |
|        |        | operational events. |        |       |            |
+--------+--------+---------------------+--------+-------+------------+