**NRC INSPECTION MANUAL** IRIB

MANUAL CHAPTER 2517

WATTS BAR UNIT 2 CONSTRUCTION INSPECTION PROGRAM

[2517-01
PURPOSE............................................................\...\...\...\...\...\...\...\.....1](#__RefHeading___Toc177435249)

[2517-02
OBJECTIVES..............................................................................1](#objectives)

[2517-03
APPLICABILITY...........................................................................2](#applicability)

[2517-04
DEFINITIONS..............................................................................2](#__RefHeading___Toc177435252)

[2517-05 RESPONSIBILITIES AND
AUTHORITIES.........................................4](#responsibilities-and-authorities)

[2517-06 BACKGROUND AND
OVERVIEW...................................................5](#background-and-overview)

[2517-07 GENERAL INSPECTION POLICY
..................................................6](#general-inspection-policy)

[2517-08 BASIC REQUIREMENTS/POLICY FOR INSPECTION PROGRAM
......10](#basic-requirementspolicy-for-inspection-program)

[2517-09 INSPECTOR TRAINING AND QUALIFICATIONS
.............................12](#__RefHeading___Toc177435257)

[2517-10 INSPECTION FINDINGS AND ENFORCEMENT
..............................12](#inspection-findings-and-enforcement)

[2517-11 ASSESSMENT
.........................................................................14](#assessment)

[2517-12 TRANSITION TO THE ROP ACTIVITIES
........................................19](#transition-to-the-rop-activities)

[2517-13 INTERFACE WITH RELATED PROGRAMS
....................................20](#__RefHeading___Toc177435261)

[2517-14 REFERENCES
.........................................................................20](#references)

Appendix A. Inspection Procedures,Temporary Instructions and Activity
Codes

Appendix B. Documenting Inspection Results

Appendix C. Minor Violations and Findings

Appendix D. WBN Unit 2 Construction Inspector Qualification Requirements

[]{#__RefHeading___Toc177435249 .anchor}2517-01 PURPOSE

01.01 To provide the policies and requirements for the Watts Bar Unit 2
(WBN Unit 2) construction inspection program during that unit\'s
resumption of construction after an approximately 20 year suspension of
construction activities.

01.02 To establish a record of the inspection activities, applicant
actions taken and technical issues resolved to support the decision for
issuing an operating license.

# 2517-02 OBJECTIVES 

02.01 To verify that the WBN Unit 2 inspection status for Inspection
Manual Chapter (IMC) 2512, "Light Water Reactor Inspection Program --
Construction Phase," is understood through a reconstitution of the
inspection program.

02.02 To provide guidance for implementation, planning and scheduling
completion of IMCs 2512; 2513, "Light Water Reactor Inspection Program
-- Preoperational Testing and Operational Preparedness Phase;" and 2514,
"Light Water Reactor Inspection Program Startup Testing Phase."

02.03 To verify the proper implementation of the applicant\'s design
control programs, the installation and testing of modifications, the
Corrective Action Programs (CAPs) and Special Programs (SPs) listed in
Attachment 2 of the WBN Unit 2 Reactivation letter dated August 3, 2007
(Reference 1 in Section 13 of this IMC), and the completion of any
required actions for outstanding generic-communication issues.

02.04 To provide WBN Unit 2-specific requirements for the training and
qualification of construction and post-construction inspectors to ensure
that they have the necessary knowledge and skills to successfully
implement the WBN Unit 2 construction and post construction inspection
program.

02.05 To provide guidance on disposition and documentation of inspection
findings.

02.06 To provide guidance on a WBN Unit 2-specific assessment program to
identify performance trends and determine if an expansion of NRC
inspections is necessary based on inspection findings.

02.07 To confirm the readiness of Structures, Systems, and Components
(SSCs) at WBN Unit 2 to transition to IMC 2513 and IMC 2514 activities
based on inspections of the applicant\'s programs.

02.08 To verify the operational readiness of WBN Unit 2 based on
inspections during its construction, preoperational testing and
operational preparedness, and startup testing phases.

02.09 To provide an objective and documented basis for recommendations
on the issuance of an operating license for WBN Unit 2.

02.10 To provide guidance for the process to transition WBN Unit 2 into
the IMC 2515 reactor oversight process (ROP).

02.11 To provide a mechanism for communicating the status of NRC's
inspection activities, issues and corrective actions to the public and
other external stakeholders.

# 2517-03 APPLICABILITY

03.01 This IMC was developed to provide inspection program guidance for
the WBN Unit 2 construction program. The WBN Unit 2 construction program
has been suspended since the mid-1980's. This inspection program remains
effective through the completion of IMC 2514 activities and the full
implementation of the IMC 2515 reactor oversight process.

03.02 Archived IMCs, Inspection Procedures (IP) and temporary
instructions (TI) will be re-issued and utilized to perform the required
inspections or reviews of outstanding design, licensing, and regulatory
issues for WBN Unit 2. Planned exceptions to IMCs, IPs, and TIs are
discussed in Section 2517-08. These exceptions are necessary because the
IMCs, IPs, and TIs are being re-issued without being updated and contain
outdated references, NRC organizational codes, and processes.

03.03 WBN Unit 2 remains within the scope of the Commission\'s current
Enforcement Policy for nuclear power plants in the construction phase.
Traditional enforcement, i.e. the use of Severity Levels, will be used
for any Severity Level IV and above non-compliances that are identified
during inspections. Once a cornerstone has been determined to be
monitorable under the ROP, then the enforcement for any findings from
NRC inspections for that cornerstone should be administered in
accordance with the Commission's current enforcement policy for
operating reactors.

03.04 The transition of WBN Unit 2 to the full oversight provided by the
ROP will be a phased approach on an individual cornerstone basis with
the understanding that IMC 2515 and IMC 0305 cannot be fully applied
until all cornerstones are monitorable by the ROP. Once a cornerstone is
monitorable by the ROP, IMC 0609 \"Significance Determination Process\"
(SDP) will be utilized to characterize the significance of findings
resulting from the routine inspection effort of IMC 2515 for that
cornerstone.

03.05 Region II may elect to pilot portions of 10 CFR Part 52 inspection
program processes at WBN Unit 2 once they are developed. These pilots
will be conducted in parallel with the process specified in this IMC.

[]{#__RefHeading___Toc177435252 .anchor}2517-04 DEFINITIONS

04.01 [Construction Activities]{.underline}. The set of activities
associated with the construction of the WBN Unit 2 plant including but
not limited to, procurement, erection, modifications, design control,
quality inspection, corrective action program, training and
qualification.

04.02 [Construction Inspector]{.underline}. A qualified NRC staff member
who inspects a sample of safety significant construction documents,
programs and activities as directed by IMC 2512 in order to obtain a
reasonable assurance that they adhere to the applicable design and
licensing requirements.

04.03 [Construction Deficiency Report]{.underline}. A reportable defect
or failure to comply that could create a substantial safety hazard were
it to remain uncorrected (refer to 10 CFR 50.55(e)).

04.04 [Cross-Cutting Aspect]{.underline}. Performance characteristics
that comprise a cross-cutting area component. They are associated with
inspection findings and play a significant role in contributing to the
performance deficiency. The different cross-cutting aspects which can be
ascribed to an inspection finding are fully described in IMC 0305,
"Operating Reactor Assessment Program."

04.05 [Full Oversight of the ROP]{.underline}. For this IMC, the
condition when all cornerstones are monitored by baseline inspection and
either performance indicators (PIs) or compensatory inspections above
the baseline in accordance with IMC 2515. The regulatory response for
findings resulting from such inspections will be in accordance with the
Action Matrix in IMC 0305.

04.06 [Limited Oversight of the ROP]{.underline}. For this IMC, the
condition when some, but not all, the cornerstones are monitorable by
baseline inspection and either PIs or compensatory inspections above the
baseline in accordance with IMC 2515. The regulatory response for
findings resulting from such inspections for any of these cornerstones
will be determined by Region II management.

04.07 [Monitorable Under the ROP]{.underline}. For an individual
cornerstone, it means that the IMC 2515 baseline inspection and either
PIs or compensatory inspections above baseline performed due to the
unavailability of PIs can provide sufficient information for determining
applicant performance for that cornerstone of safety.

04.08 [Performance Deficiency]{.underline}. An issue that is the result
of an applicant not meeting a requirement or standard where the cause
was reasonably within the applicant's ability to foresee and correct,
and that should have been prevented. A performance deficiency can exist
if an applicant fails to meet a self-imposed standard or a standard
required by regulation.

04.09 [Post-construction Activities]{.underline}. The set of activities
associated with the Pre-operational Testing and Operational Preparedness
Phase and the Startup Testing Phase.

04.10 [Post-construction Inspector]{.underline}. A qualified NRC staff
member who inspects a sample of safety significant post construction
documents, programs and activities, as directed by IMCs 2513 and 2514,
in order to obtain a reasonable assurance that they adhere to the
applicable design and licensing requirements.

04.11 [ROP Transition Plan]{.underline}. The requirements developed by
Region II for determining when all the cornerstones of safety can be
deemed to be ready to be monitorable under the ROP. The Transition Plan
mainly consists of transition matrices developed by Region II for each
ROP cornerstone. Each matrix specifies the criteria which must be met
for that cornerstone to be monitorable under the ROP.

# 2517-05 RESPONSIBILITIES AND AUTHORITIES

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

a\. Provides overall program direction for the WBN Unit 2 inspection
program.

b\. Develops policies, programs, and procedures for performing
inspections at WBN Unit 2 within or in addition to the WBN Unit 2
inspection program.

c\. Assesses the effectiveness, uniformity, and completeness of
implementation of the WBN Unit 2 inspection program.

d\. Concurs with the decision of the Regional Administrator for Region
II to transition WBN Unit 2 into the full oversight of the ROP.

05.02 [Associate Director for Operating Reactor Oversight and Licensing
(ADRO)]{.underline} Directs the development of the WBN Unit 2 inspection
program within the Office of Nuclear Reactor Regulation (NRR).

05.03 [Director, Division of Inspection and Regional Support
(DIRS)]{.underline}

a\. Manages WBN Unit 2 inspection program development within NRR.

b\. Develops and prepares revisions to this IMC and other applicable
inspection program documents.

c\. Oversees regional implementation of WBN Unit 2 inspection program.

d\. Serves as the NRR contact with the Region II office for WBN Unit 2
inspection program development and implementation.

05.04 [Director, Division of Operating Reactor Licensing
(DORL)]{.underline}

a\. Serves as NRR contact in regard to licensing and licensing policy
issues related to the WBN Unit 2 inspection program.

b\. Assigns a Project Manager to address day-to-day matters concerning
licensing issues for WBN Unit 2.

c\. Coordinates with Region II to ensure licensing efforts and the
inspection program are integrated.

05.05 [Director, Office of Enforcement (OE)]{.underline}

a\. Ensures consistent application of the enforcement process to
violations of NRC regulations with the appropriate focus on the severity
level of the finding.

b\. Provides representatives as necessary to support the Escalated
Enforcement process in order to ensure consistent application of the
enforcement process.

05.06 [Regional Administrator for Region II]{.underline}

a\. Has responsibility and authority for the overall direction of the
implementation of the WBN Unit 2 inspection program.

b\. Establishes contacts with applicant on inspection-related issues and
any required corrective actions either directly or through the assigned
Region II Branch Chiefs.

c\. Maintains contacts with NRR and the Office of Nuclear Security and
Incident Response (NSIR) on inspection related issues and the overall
WBN Unit 2 inspection program either directly or through the assigned
Region II Branch Chiefs. Ensures routine assessment of applicant
performance in restart activities is considered.

d\. Makes the decision to allow WBN Unit 2 to transition completely to
the full oversight of the ROP with the concurrence of the Director, NRR.

# 2517-06 BACKGROUND AND OVERVIEW

The Tennessee Valley Authority (TVA) is the NRC-regulated applicant for
the Watts Bar Nuclear Plant (WBN) located in southeastern Tennessee. The
WBN site has two Westinghouse-designed pressurized-water reactors. WBN
has a unique licensing history and regulatory framework. TVA received a
construction permit for the unit in 1973 under 10 CFR Part 50.
Construction proceeded until 1985, when Watts Bar Unit 1 (WBN Unit 1)
was thought to be essentially complete and nearly ready to receive an
OL, as documented in NUREG-0847, "Safety Evaluation Report Related to
the Operation of Watts Bar Nuclear Plant, Units 1 and 2," through
Supplement 4.

As a consequence of the identification of a large number of deficiencies
shortly before the WBN Unit 1 license was expected to be issued, the
Nuclear Regulatory Commission (NRC) sent a letter to TVA on September
17, 1985, requesting information under 10 CFR 50.54(f), on TVA's plans
to address the deficiencies for its operating and construction
activities at Watts Bar and TVA's other nuclear facilities. In response
to this letter, TVA developed a Nuclear Performance Plan (NPP) to
address corporate and site-specific issues, establishing programs to
address a wide variety of material, design, and programmatic
deficiencies. WBN Unit 2 construction was suspended at about that time,
with major structures in place and equipment such as reactor coolant
system piping installed. On October 13, 1999, TVA filed a request for
extension of the completion date for Unit 2, and by letter dated July
14, 2000, TVA informed the NRC that WBN Unit 2 meets the NRC's
definition for deferred nuclear plant units as described in the
Commission's Policy Statement on Deferred Plants, 52 FR 38077 (Oct. 14,
1987). On October 24, 2000, the NRC issued an order extending the Unit 2
construction permit to December 31, 2010.

The NRC staff reviewed components of the NPP for WBN Unit 1 and, as
documented in NUREG-1232, Volume 4, "Safety Evaluation Report on
Tennessee Valley Authority: Watts Bar Nuclear Performance Plan, Watts
Bar Unit 1" (January 1990), the staff endorsed the general approaches of
various corrective actions. The staff determined that when implemented
thoroughly, the proposed corrective actions should address the
identified deficiencies for WBN Unit 1; however, no final conclusions
were stated for WBN Unit 2.

TVA addressed WBN Unit 1 construction quality issues as part of the
implementation of its NPP. IMC 2512 was used to ensure that WBN Unit 1
was constructed in accordance with NRC approved design and construction
standards. In 1985, the NRC had completed its initial IMC 2512
inspection program for the construction of WBN Unit 1. However, the
initial WBN inspection program was found to have some weaknesses, which
were identified and corrected after the construction inspection program
was completed for Unit 1, but before the facility was licensed. Because
of the complexity of the rework activities under the NPP, the NRC
implemented a \"reconstitution\" of the construction inspection program
to verify that construction related inspections conducted after 1985 met
the requirements of the IMC 2512 program. The results of this program
were published in NUREG-1528, "Reconstitution of the IMC 2512
Construction Inspection Program for Watts Bar Unit 1." The staff had
completed a substantial number of IMC 2512 inspections for WBN Unit 2,
as well; however, TVA suspended WBN Unit 2 construction before the
inspection program was completed, and the staff then suspended its
licensing and inspection activities.

In a Staff Requirements Memorandum dated July 25, 2007 (ML072060688),
the Commission stated that it "supports a licensing review approach that
employs the current licensing basis for Unit 1 as the reference basis
for the review and licensing of Unit 2," and that "Significant changes
to that licensing basis would be allowed only where the existing backfit
rule would be met as necessary to support dual unit operation."
Licensing review guidance documents will reflect this guidance.

This IMC establishes the policy for the conduct of WBN Unit 2 inspection
program covering WBN Unit 2\'s construction and startup process under
IMCs 2512, 2513, and 2514. All aspects of the WBN Unit 2 construction
project will be inspected in accordance with the Region II inspection
plan and this IMC. Region II will manage all elements of the WBN Unit 2
inspections, e.g., reviews, assessment of applicant corrective actions,
evaluation of findings, tracking open items, and transition to the ROP.

# 2517-07 GENERAL INSPECTION POLICY

07.01 [Reconstitution of WBN Unit 2 Inspection Status]{.underline}

In 1985, the applicant, Tennessee Valley Authority (TVA), certified to
the NRC that construction of WBN Unit 1 was complete and applied for an
operating license. The NRC had identified several problems with the
quality of construction at the facility, and noted that TVA had
initiated corrective actions to resolve these problems. However, the
initial IMC 2512 construction inspection program had failed to identify
all of the problems, and did not reveal the lack of depth and
effectiveness of TVA's corrective actions in identifying and addressing
the root causes. As a result, the NRC concluded that the initial IMC
2512 construction inspection program included some weaknesses as an
overall assessment of construction quality at WBN Unit 1.

TVA responded by withdrawing the application for an operating license
for WBN Unit 1, and developed a series of Corrective Action Programs
(CAPs) and Special Programs (SPs) to resolve the most significant
deficiencies. The NRC reviewed the CAPs and SPs, and determined that, if
properly implemented, these programs should effectively address the
construction deficiencies identified as important. When TVA resumed WBN
Unit 1 construction activities and began implementing the CAPs and SPs,
the NRC inspected the work under a series of Temporary Instructions
(TIs). However, because these TIs were general in nature, they did not
correlate directly with IMC 2512 Inspection Program requirements. The
resulting reconstitution or correlation process was intended to verify
that previously completed construction related plant inspections met the
overall requirements of IMC 2512 as a basis for licensing WBN Unit 1.

Region II will conduct a reconstitution of the IMC 2512 IPs and open
items (e.g., non-cited violations (NCV), un-resolved items (URI),
construction deficiency reports (CDR), violations (VIO)) for WBN Unit 2.
The goals of the reconstitution process will be to compile data on
previous inspections at WBN Unit 2 and combine those historical
inspection results with planned inspections to demonstrate that the IMC
2512 inspections are completed. The applicable IPs are listed in IMC
2512, Appendix I. In addition, the open items identified during the
reconstitution will be inspected for completion. The reconstitution
results will be documented in the quarterly WBN Unit 2 construction
resident inspector report.

Region II will provide each assigned inspector with the information
required to perform the reconstitution for the historical inspection
results needed to complete an inspection procedure. Information provided
will include a historical library of previous construction inspection
reports, database of inspection findings/open items, and other related
documentation. Prior to closing an IP, Region II will verify that the
NRR licensing reviews in areas related to that IP are complete.

Allegations identified during the construction and completion of WBN
Unit 1 will be reviewed to determine applicability and potential impact
to the WBN Unit 2 historical construction inspection results. In
addition, all WBN allegations in the Allegation Management System will
be reviewed during the reconstitution of the inspection program to
determine if additional inspections are needed. Operating experience
from WBN Unit 1 will be reviewed for indications of problems with design
or construction that could impact WBN Unit 2.

If documented inspection results do not provide adequate assurance that
an IMC 2512 inspection procedure can be completed, NRC Region II
management will make a case-by-case decision concerning an alternative
means to establish that the requirements had been satisfied.

Construction Phase TIs will not require reconstitution and will be
completed. A significant amount of previous NRC inspection of
construction activities associated with WBN Unit 2, especially prior to
1985, has occurred. However, very little actual inspection of applicant
activities associated with SPs and CAPs for WBN Unit 2 has occurred.
Additionally, following completion of actions associated with each of
the CAPs and SPs for Unit 2, the applicant will make a closure package
available to the NRC. That closure package should address each of the
line item requirements identified in the TIs. These TIs are listed in
Appendix A. Region II will review the packages against the TIs, verify
the actions specified adequately address the related TI, and perform
inspections of selected items to verify that the actions specified were
completed.

Region II will reconstitute the WBN Unit 2 open items list for generic
issues (such as NRC Generic Letters and Bulletins), CDRs, and previously
documented compliance issues. These open items will be inspected for
completion and closure will be documented in an inspection report.

07.02 [Inspection Program Scheduling and Planning]{.underline}

a\. Region II will develop a site-specific inspection plan and schedule
(IP&S) to complete the inspections required by IMC 2512, IMC 2513, and
IMC 2514; open TIs; and open NRC generic communications such as Generic
Letters and Bulletins. This schedule will take into account IPs
determined to be complete by the reconstitution effort, discussed in
Section 07.01. The IP&S should attempt to minimize the number of
inspections by grouping similar issues and programs together. In
addition, it should provide sufficient flexibility for rescheduling
inspections to accommodate applicant schedule changes. The IP&S will use
RPS and other specific tools to accomplish its purposes.

b\. Region II will coordinate with NRR to verify that IP&S provides
sufficient oversight for construction activities. Region II and NRR will
coordinate inspection and licensing activities to ensure that both
efforts reflect the accepted facility design and as-built condition.
Inspection results identifying differences between the as-built plant
and the licensing basis will be communicated to NRR. Differences between
the as-built plant and the licensing basis may require additional NRR
licensing reviews. Similarly, NRR will notify Region II if licensing
reviews indicate additional inspections are required.

c\. Region II can increase the sample sizes of IPs or TIs as appropriate
without NRR concurrence if budgeted resources will still envelope the
estimated resources to be expended after allowances for any alterations
are made.

d\. IP&S should allow for additional inspections that may be identified
by Region II or NRR. Region II will establish tracking mechanisms for
the large number of historical open items and CDRs that will initially
be open and whose tracking numbers make them unsuitable to track using
the RPS. New items such as NCVs, URIs, CDRs, and VIOs will be tracked
using Reactor Programs System (RPS).

e\. Region II will identify and implement changes to the inspection plan
based on the results of the WBN Unit 2 assessment process discussed in
Section 2517-11.

07.03 [Inspection Policy and Scoping]{.underline}

a\. The IP&S should identify the applicant's program areas, major
modifications, regulatory issues (e.g., applicant's resolution of CAPs
and SPs from the Nuclear Performance Plan implementation on WBN Unit 1
and resolution of generic issues after 1985), and generic and open items
that are being verified by an inspection, when the inspection will be
performed, and the relevant IPs or TIs from those listed in Appendix A
of this IMC. The IPs to be utilized will be reactivated if previously
archived. The following IMC 2512 IPs will not be activated because they
were determined to not be applicable to WBN Unit 2:

-   IP 35051, Site Erected RV - QA Procedures

-   IP 47051, Containment (Post-Tensioning) Procedure Review

-   IP 47053, Containment (Post-Tensioning) Work Observation

-   IP 47055, Containment (Post-Tensioning) Record Review

-   IP 50082, Site Erected RV Procedures (Mechanical)

-   IP 50083, Site Erected RV Work Observation (Mechanical)

-   IP 50085, Site Erected RV Record Review (Mechanical)

-   IP 55092, Site Erected RV Work Observation (Welding and NDE)

Prior to reactivating any archived TIs, it must be determined whether
their original issues were resolved or are not relevant anymore. If
either is the case, then Region II will close out the TI without
reactivating it.

b\. Region II will manage and coordinate the WBN Unit 2 inspection
program, required technical support, and the verification that
inspection hours are being properly charged.

c\. The IP&S will address inspections for IMC 2512, IMC 2513, and IMC
2514. In addition, it will also address additional inspections
identified by Region II management to address construction issues and
NRR during the licensing review, and the transition of WBN Unit 2 into
the full oversight of the ROP.

d\. The IP&S will include inspections to verify that the applicant's
processes for identifying, tracking, and resolving problems at WBN Unit
2 are adequate.

e\. This IMC will establish the justification for allowing each
cornerstone to be monitored by the ROP. Region II will develop a
Transition Plan based on the Transition Matrices for the cornerstones so
that the major steps are identified and defined (refer to Section
2517-12).

f\. The IP&S will either refer to or include the detailed Transition
Matrices to be developed by Region II for the seven cornerstones of
safety.

07.04 [Use of Inspectors]{.underline}

a\. Region II should assign inspectors based on their qualifications.
Specific qualification requirements for the construction inspectors are
discussed in Section 2517-09. Generally, resident inspectors should
verify applicant performance for all general activities while the
regional specialists should perform more specialized activities
(technical reviews associated with specific types of inspections for
each specialist).

b\. Programs and procedures should be reviewed once a performance
problem is identified to ensure the applicant determines the cause and
extent of condition. Inspectors will focus on the applicant\'s efforts
to implement long-term resolutions.

# 2517-08 BASIC REQUIREMENTS/POLICY FOR INSPECTION PROGRAM 

This section provides the basic requirements and policy for the WBN Unit
2 construction inspection program. It also identifies certain exceptions
to the requirements of IMC 0040, IMC 2512, IMC 2513 and IMC 2514 and
offers alternate approaches to meet their intent. Although this section
discusses three different phases of inspection (construction,
preoperational testing and startup testing), all inspections for a
particular phase do not need to be completed before entering the next
phase.

08.01 [Level of Effort.]{.underline} The level of effort will be
determined by Region II in its IP&S. The IP&S will take into account the
total estimated resources allotted in the budget developed jointly by
Region II and NRR. Inspectors should charge to the IPs, TIs and activity
codes listed in Appendix A. Every applicant program, (e.g., CAP or SP)
affecting either SSCs in a single system or multiple systems, will be
inspected per the following:

a\. For each applicant program, inspect its programmatic aspects only
once. This inspection should review the implementing administrative
processes to ensure that quality assurance is instilled in the program.
All applicant CAPs and SPs are listed in Attachment 2 of the WBN Unit 2
Reactivation letter dated August 3, 2007 (Reference 1 in Section 13 of
this IMC). If the programmatic aspects of a program were previously
verified by NRC inspections for WBN Unit 1, then that program does not
have to be re-verified for WBN Unit 2 if it has not been altered, there
is no potential impact on the program as a result of changing the
vendor, and the NRC determines that the program is acceptable for WBN
Unit 2.

b\. An appropriate number of representative samples of the results of
the implementation of each applicant program shall be inspected for
safety-significant SSCs, including any interfacing
non-safety-significant SSCs. The goal can be achieved by inspecting the
SSCs for one system or several systems in which changes were made due to
the implementation of an applicant CAP or SP. The acceptance criteria
for those results for each CAP or SP will be as stated in the respective
package, test procedure verifying the functionality of the results, or
in the basis document for the program. Region II WBN Unit 2 project
management will approve alternate inspection approaches where standard
inspections are impractical.

2.  [Implementation of IMC 0040, IMC 2512, IMC 2513 and IMC
    2514]{.underline}. The WBN Unit 2 construction inspection program
    will comply with the requirements delineated in IMC 0040 for
    document preparation, IMC 2512 for construction inspection
    activities, IMC 2513 for preoperational testing inspection
    activities and IMC 2514 for startup and testing inspection
    activities, using the alternate approaches described below.

a\. The WBN Unit 2 construction inspection program guidance documents
used to implement this program, such as IMCs, IPs and TIs, will not be
updated prior to issuance.

b\. Since the archived IPs and TIs are not being revised, their format
will not comply with the current requirements of IMC 0040.

c\. Some of the organizational codes referenced in the construction
inspection documents may not be current. A cross-reference file on the
WBN Unit 2 Web Page will identify the correct organizations responsible
for the different WBN Unit 2 construction inspection activities. If
after using the cross-reference, questions remain regarding the correct
responsible organization, the inspector should contact the Division of
Construction Projects (DCP) or the WBN Unit 2 Project Manager for
direction.

d\. Some of the references listed in the construction inspection
documents may no longer be valid. In order to meet the intent of Section
05.04 of IMC 0040, a cross-reference file on the WBN Unit 2 Web Page
will provide the correct references to use. In addition, the inspector
can consult Attachment 1 of reference 1. This attachment discusses the
applicability of the various Regulatory Guides for WBN Unit 2 along with
the corresponding level of compliance. The inspector may also seek
clarifications regarding the correct reference documents used at WBN
Unit 2 in the current revision of the Watts Bar Operating License
application Final Safety Analysis Report. If questions regarding the
correct references to use still persist, the inspector is directed to
contact DCP or the WBN Unit 2 Project Manager for direction.

e\. An alternate approach to Section 07.03 of IMC 0040 will be used for
the WBN Unit 2 construction project. The TIs that had been previously
utilized during WBN Unit 1 construction will be reopened for use at WBN
Unit 2. These TIs may remain open for longer than 24 months if
necessary, in order to accommodate the construction schedule of WBN Unit
2. In cases where technical help is needed and the technical contacts
listed in the TIs are no longer available, the inspectors should contact
DCP or the WBN Unit 2 Project Manager for guidance.

f\. Some of the processes listed in the construction IMCs are no longer
utilized. In this case, the alternate processes described in this IMC
should be used. An example of that is Section 2517-11 of this IMC which
provides an alternate applicant performance assessment to the Systematic
Assessment of Licensee Performance (SALP). If after reviewing this
chapter questions remain regarding a specific process, the inspector is
directed to contact DCP or the WBN Unit 2 Project Manager for guidance.

g\. To the extent practical, IMC 2512 will be used to perform
inspections during the construction phase of the WBN Unit 2 project. The
reconstitution effort described in Section 07 of this IMC may result in
some deviations from the requirements of IMC 2512. This may be due to
the inability to find specific inspection reports and/or the
practicality to perform certain inspections. In these cases, Region II
management will make a case-by-case decision regarding acceptable
alternate means to establish that the requirements have been satisfied.
An example of an acceptable justification may be a WBN Unit 1 inspection
report for a similar activity. In all cases, the intent of IMC 2512 will
be met.

h\. The NRC does not plan to implement the Construction Appraisal Team
(CAT) inspection program described in IMC 2512, Section 08.01 for WBN
Unit 2.

i\. Consistent with the exceptions identified above, IMC 2513 and IMC
2514 will be used in their entirety to perform inspections during the
preoperational testing and operational preparedness phase and the
startup testing phase of the WBN Unit 2 project.

j\. Except for the exceptions identified above, IMC 2514 will be used in
its entirety to perform inspections during the startup testing phase of
the WBN Unit 2 project.

[]{#__RefHeading___Toc177435257 .anchor}2517-09 INSPECTOR TRAINING AND
QUALIFICATIONS

Only staff members who have been previously qualified as inspectors
through IMC 1245 or IMC 1252 will be qualified to this section. The
training completed by fully qualified inspectors combined with their
field experience can be used, at management's discretion, to establish
equivalency for many of the activities specified herein. The initial
training and qualification requirements are divided into two phases: the
construction phase and the post construction phase. Refresher and
continuing training activities are required as a means for updating and
maintaining qualification to keep up-to-date on changes to the
inspection program and as a result of lessons learned from industry
events and agency activities. Just-in-time training and additional
specialized training may also be required to support critical inspection
activities. Detailed requirements are listed in Appendix D.

# 2517-10 INSPECTION FINDINGS AND ENFORCEMENT

10.01 [Reports]{.underline}. Routine WBN Unit 2 construction inspection
reports will be issued on a quarterly basis. Appendix B will be used to
evaluate and document construction inspection observations and to
classify them as findings, if appropriate, after they have been placed
in context and assessed for significance. The findings will then be
categorized as violations (VIO), non-cited violations (NCV), minor
violations, open items, or unresolved items.

Traditional enforcement will be in effect for the construction of WBN
Unit 2 until a specific cornerstone is transitioned to the ROP as
discussed in IMC 2517-12. Findings from inspections will be processed in
accordance with 10 CFR Part 2 and applicable enforcement guidance using
traditional enforcement tools, e.g., the use of severity levels and
civil penalties as appropriate. The determination of the severity level
of an apparent violation should consider its significance per Appendix
B, Section 05, and the Commission's current Enforcement Policy.

10.02 [Cross-cutting Aspects]{.underline}. Inspectors will use the
applicable guidance in IMC 0305 Section 06.07 to review inspection
findings to identify the cause(s) associated with the cross-cutting
areas, if any exists. The inspectors should identify the cause(s) that
provide(s) the most meaningful insight into the performance deficiency
and document it with the associated finding in the Inspection Report
(IR). The inspectors will use the cross-cutting aspects defined in IMC
0305.

10.03 [NRC Identified and Self-revealing NCVs]{.underline}. NRC
identified NCVs will be documented in an IR but will not be closed based
on the applicant entering them into their CAP. Self-revealing NCVs will
be treated in the same manner as NRC identified NCVs. The NCVs will be
kept open in RPS pending a followup inspection to verify the adequacy of
the applicant's corrective actions. The results of the followup
inspection will be documented in an IR and the respective RPS open item
will be closed. This exception to the Enforcement Policy is to provide
an auditable trail for more than minor NRC identified violations during
construction to support the final licensing decision.

10.04 [Applicant-identified NCVs]{.underline}. The NRC will consider not
issuing an NOV for applicant-identified items that would fall into the
severity level IV category and if the NCV criteria are met. This
consideration will be based on the results of the NRC's review of the
applicant's corrective action program to be conducted in early 2008.
Applicant-identified violations that are severity level III or higher
will be documented in an Inspection Report and a NOV will be issued.
Applicant-identified violations are those items found through their own
efforts rather than NRC inspections. The NRC will sample these items for
documentation in the corrective action program, adequacy of extent of
condition reviews, and appropriate resolution.

Applicant-identified NCVs will be documented in Section V.X2 of the
report. The documentation will include the requirement(s) violated,
describe how it was violated, identify the applicant's corrective action
tracking number(s), and provide a very brief justification why the
violation is not greater than severity level IV. Section V.X2 must
include the following introductory paragraph:

> "The following violations of very low safety significance were
> identified by the applicant and are violations of NRC requirements
> which meet the criteria of Section VI of the NRC Enforcement Policy
> for being dispositioned as a Non-Cited Violation."

10.05 [ROP Findings]{.underline}. For those cornerstones monitorable by
the Reactor Oversight Process (ROP), any noncompliances will be
documented and reported under IMC 0612. The significance of
noncompliances will be assessed in accordance with the significance
determination process (SDP) per IMC 0609. Any findings will be
dispositioned in accordance with the ROP for such cornerstones with
enforcement of these findings being handled in accordance with
Commission\'s current Enforcement Policy.

10.06 The same inspection report may include noncompliances assessed by
Appendix B, if the ROP is not applicable, and noncompliances assessed by
IMC 0612, if its cornerstone is monitorable by the ROP.

# 2517-11 ASSESSMENT

11.01 [Overall Assessment Process]{.underline}. Applicant performance
will be reviewed over a 12-month period. The 12-month assessment period
will be January 1 through December 31 of each year. The assessments will
be based on the findings and conclusions documented in NRC IRs. Overall
applicant performance will be based on Severity Level I, II, and III
violations and substantive cross-cutting issues.

11.02 [Performance Reviews]{.underline}. The assessment process consists
of a series of reviews which are described below.

a\. [Quarterly Review]{.underline}. The resident inspectors and Chief,
Construction Projects Branch 3 (CPB3) will conduct a quarterly review
using the inspection findings and inspection report conclusions compiled
over the previous twelve months. The review will be conducted within
five weeks after the conclusion of each quarter of the annual assessment
cycle. An assessment follow-up letter will be issued if the quarterly
review results in changes to the inspection plan. If required, the
assessment follow-up letter should be issued within two weeks after
completing the quarterly review.

b\. [Mid-Cycle Review]{.underline}. Region II will conduct mid-cycle
reviews using documented inspection findings and inspection report
conclusions compiled over the previous twelve months. The output of the
mid-cycle review is a mid-cycle letter.

> In preparation for the mid-cycle review, Region II will prepare a
> summary of all inspection findings (including associated cross-cutting
> aspects) and documented conclusions related to applicant performance
> conducting special programs, a summary of open allegations, and
> proposed inspections.
>
> The mid-cycle review is chaired by the DCP Division Director. The
> Chief, CPB3, should take the lead in presenting the overall results of
> the review to the division director. The DCI branch chiefs shall
> coordinate with the Chief, DCP3, to provide adequate support for the
> presentation and development of the inspection plan. Other
> participants shall include applicable resident inspectors and a
> representative from the Division of Inspection and Regional Support
> (DIRS). Additional participants may include the regional allegations
> coordinator or the agency allegations advisor, and any other
> additional resources deemed necessary by the regional offices. The
> following representatives should also participate if there are
> pertinent performance issues that should be factored into the
> performance assessment: senior representatives from the Division of
> Operating Reactor Licensing, Office of Investigations, Office of
> Enforcement, Office of Nuclear Security and Incident Response, and
> Office of Research
>
> The mid-cycle letter shall be issued within nine weeks of the end of
> the completion of the second quarter assessment period. Refer to IMC
> 0305 Section 06.02.c for examples of the types of items to be included
> in the letter.

c\. [End-of-Cycle Review]{.underline}. Region II will conduct an
end-of-cycle review using documented inspection findings and inspection
report conclusions compiled over the previous twelve months. This review
incorporates activities from the mid-cycle and quarterly reviews.

> In preparation for the end-of-cycle review, Region II will prepare a
> summary of all inspection findings (including associated cross-cutting
> aspects) and documented conclusions related to applicant performance
> conducting special programs, a summary of open allegations, and
> proposed inspections.
>
> The end-of-cycle review is chaired by the Region II Deputy Regional
> Administrator for Construction or his/her designee. The Director, DCP,
> and/or Chief, DCP3, present the results of the annual review to the
> Deputy Regional Administrator for Construction (or designee). The DCI
> branch chiefs shall coordinate with the Chief, DCP3, to provide
> adequate support for the presentation and development of the
> inspection plan. Other routine participants should include DRP and DRS
> branch chiefs, applicable regional and resident inspectors, a
> representative from the Division of Inspection and Regional Support
> (DIRS), the regional Allegations Coordinator or the Agency Allegations
> Advisor, and any other additional participants deemed necessary by the
> regional offices. The following representatives should also
> participate if there are pertinent performance issues that should be
> factored into the performance assessment: senior representatives from
> the Division of Operating Reactor Licensing, Office of Investigations,
> Office of Enforcement, Office of Nuclear Security and Incident
> Response, and Office of Research.
>
> The annual assessment letter shall be issued within nine weeks of the
> end of the assessment cycle. Refer to IMC 0305 Section 06.02.d for
> examples of the types of items to be included in the letter.

11.03 [Annual Meeting with Applicant]{.underline}. Region II will
conduct an end of cycle public meeting in the vicinity of the plant to
communicate the results to the local stakeholders. Region II will
coordinate with NRR for their participation in the meeting. This meeting
should be conducted within 16 weeks of the end of the cycle. Region II
will use the applicable portions of IMC 0305 Section 06.04 as guidance
for conducting this meeting. The WBN Unit 2 annual meeting will be held
separately from the WBN Unit 1 annual meeting.

11.04 [Assessment Areas]{.underline}. The following assessment areas and
associated attributes will be used to assess WBN Unit 2 performance.
Depending on the stage of the construction project, not all assessment
areas would be applicable during a given assessment period.

a\. [Quality Assurance Program]{.underline}. The requirements of the
quality assurance program are effectively implemented.

b\. [Management Oversight and Control]{.underline}

1\. [Construction Activities]{.underline}. Construction activities are
conducted in accordance with the construction permit and quality
assurance program. The applicant recognizes non-routine events affecting
safety and effectively implements the corrective action program.
Effective controls are in place to prevent adverse affects to WBN Unit 1
due to construction activities.

2\. [Maintenance Activities]{.underline}. Maintenance activities are
conducted in accordance with maintenance procedures and the quality
assurance program. Activities are effective in preparing SSCs for
operation. Effective controls are in place to prevent adverse affects to
WBN Unit 1 due to construction activities.

3\. [Engineering Activities]{.underline}. Engineering activities are
conducted in accordance with plant procedures and the quality assurance
plan. Engineering activities are effective in ensuring the plant is
constructed in accordance with the approved design and authorized design
changes.

4\. [System Turnovers]{.underline}. System turnovers are conducted in a
controlled manner. Procedures are effectively implemented to maintain
plant systems until transition to operations. Effective controls are in
place to prevent adverse affects to WBN Unit 1 due to construction
activities.

5\. [Pre-Operational Activities]{.underline}. Pre-operational activities
are effective and ensure systems and components important to the safety
of the plant are fully tested to demonstrate that they satisfy design
requirements. Management controls and procedures necessary for operation
of the facility are effectively implemented. Effective controls are in
place to prevent adverse affects to WBN Unit 1 due to construction
activities.

> 6\. [Startup Testing Activities]{.underline}. Startup testing
> activities are effectively implemented to provide for the safe startup
> testing of the facility during both routine and upset conditions, to
> recognize non-routine events affecting safety, utilize an internal
> reporting system, and to identify and execute corrective actions to
> return the facility to a safe and secure pre-operational condition
> after possible upsets. Effective controls are in place to prevent
> adverse affects to WBN Unit 1.
>
> 7\. [Training and Qualification of Plant Personnel]{.underline}. The
> training and qualification program is effective in training of
> personnel including managers, designers, technical staff, construction
> personnel, technicians, Inspectors and other personnel whose level of
> knowledge is relied on for safety.

c\. [Operational Readiness Activities]{.underline}. Activities completed
during the operational preparedness phase to support the transition from
construction to operation. Since Watts Bar is a dual plant site with one
operating plant, WBN Unit 1, the assessment of these activities should
take into consideration dual plant operation.

1.  [Operations.]{.underline} The operational procedures and the
    technical specifications are adequate and support dual plant
    operation. The operations department is well staffed with qualified
    individuals whose training covers dual plant operation.

2.  [Fire Protection.]{.underline} The applicant has established an
    effective fire protection program to assure the protection of safety
    related SSCs.

3.  [Surveillance Testing.]{.underline} The applicant has established an
    effective surveillance testing program that takes into account dual
    plant operation, and has instituted adequate test and measurement
    equipment controls.

4.  [Plant Water Chemistry.]{.underline} The applicant has identified
    the plant systems affecting water chemistry and has instituted
    effective water chemistry control and analysis processes to assure
    the protection of impacted safety related SSCs.

5\. [Radiation Safety]{.underline}. The radiation safety program is
effective in protecting workers' health and safety from exposure to
radiation. The program is effective in protecting public health and
safety and the environment from exposure to radioactive material
released into the public domain.

6\. [Security]{.underline}. The security program is effective in
protecting the plant against (1) the design basis threat of radiological
sabotage from external or internal threats, and (2) the theft or loss of
radioactive materials.

7\. [Emergency Preparedness]{.underline}. The emergency preparedness
program is effective in protecting the public health and safety in the
event of a radiological emergency."

d\. [Other]{.underline}. These are issues that may arise on an
occasional basis, but are not included in the review on a routine basis
unless the significance of the issue rises to a level that is perceived
to affect the quality of applicant performance. An example of an item
that would be in this category is quality of application and licensing
submittals.

11.05 [Substantive Cross-Cutting Issues]{.underline}. WBN Unit 2
performance reviews will be based on conclusions and findings documented
in NRC IRs. The assessment will also review cross-cutting aspects
associated with the inspection findings. Region II will use the guidance
contained in IMC 0305 Section 06.07 to identify cross-cutting aspects
and themes.

A substantive cross-cutting issue would exist in the [human performance
or PI&R cross-cutting areas]{.underline} if all of the following
criteria were met:

-   Four or more findings with cross-cutting aspects.

-   There is a cross-cutting theme.

-   The agency has a concern with the applicant's scope of efforts or
    progress in addressing the cross-cutting theme.

A substantive cross-cutting issue would exist in the [Safety Conscious
Work Environment (SCWE) cross-cutting area]{.underline} if all of the
following criteria were met:

-   A finding with a cross-cutting aspect in the SCWE cross-cutting
    area.

-   The applicant has received a chilling effect letter OR the applicant
    has received correspondence from the NRC for an enforcement action
    involving discrimination.

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-   There is an impact on SCWE that was not isolated.

-   The agency has a concern with the applicant's scope of efforts or
    progress in addressing the individual and collective performance
    deficiencies.

    6.  [NRC Actions in Response to Applicant Performance
        Issues]{.underline}. The mid-cycle/end-of-cycle assessment
        panels will determine the NRC response to significant
        performance issues. Significant performance issues are defined
        as:

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```
-   Severity Level I, II, and III violations

-   Substantive cross-cutting issue

Possible NRC responses as a result of significant performance issues
include but are not limited to:

-   Increase sample sizes for IPs focused in the area of concern.

-   Require applicant root cause evaluation and corrective action with
    NRC oversight.

-   Focused NRC inspection in area of concern.

-   Focused NRC team inspection in area of concern.

-   Reactive NRC team inspection in area(s) of concern.

-   Applicant performance improvement plan with NRC oversight.

-   Applicant senior managers meet with NRC management.

At the discretion of Region II management, the regulatory responses
prescribed by the ROP Action Matrix may be used even though the Action
Matrix is not in effect prior to the transition of WBN Unit 2 to the
ROP. As an example, following startup a performance deficiency
associated with a mitigating system will be assessed using the SDP.
However, the Mitigating System Cornerstone may not have been
transitioned to the ROP because the performance indicators aren't valid
due to insufficient historical data. Because the performance deficiency
has been assessed using the SDP the ROP Action Matrix could then be used
to determine the appropriate regulatory response.

11.07 The WBN Unit 2 assessment process will not cover assessment areas
that have been transitioned to the ROP per Section 2517-12 of this IMC.
These areas will be assessed using the ROP assessment process.

# 2517-12 TRANSITION TO THE ROP ACTIVITIES 

12.01 The overall approach for transitioning to the ROP will be in
accordance with this IMC as stated below.

a\. The transition of WBN Unit 2 to the ROP will be a phased approach on
an individualized cornerstone basis. The basis for why a certain
cornerstone will be declared ready to be monitorable under the ROP will
be contained in the WBN Unit 2 ROP Transition Plan which shall be
developed by Region II prior to implementation of IMC 2513 at WBN Unit
2.

b\. The Region II Transition Plan will adhere to the guidelines stated
in this IMC and will be composed of Transition Matrices for each
cornerstone. Each Transition Matrix will contain all the records that
verify that a cornerstone is fully monitorable (what inspection criteria
were performed and when; whether inspection criteria were completed in
their entirety or just in part with any exceptions or deviations noted;
what significant open items, startup issues, licensing actions, or
regulatory issues were resolved; the identified inspection findings and
the corresponding applicant corrective actions). Based on the decision
of Region II management with the concurrence of NRR, that cornerstone
will be placed under the oversight of the ROP.

c\. The ROP Transition Plan should specify the required inspection
procedures to be performed, when one or several cornerstones are ready
to be monitored by the ROP. The transition plan should also include
verification that all startup issues, if applicable, have been resolved
and confirm that the applicant's corrective actions were effective.

d\. The ROP Web Site will be updated for WBN Unit 2 inspection findings
and available WBN Unit 2 PI results when all cornerstones are
monitorable by the ROP and the Action Matrix is put into effect.

e\. The transfer of WBN Unit 2 to the full oversight of the ROP will be
by written approval of the Regional Administrator with the concurrence
of NRR. This transfer may occur even if all PIs are not available,
provided compensatory inspections are conducted as provided for by IMC
2515. Prior to this point in time, identifying the need for additional
NRC inspections and determining the response to inspection findings or
events will be by the assigned Region II branch chiefs in accordance
with the assessment process in Section 11 of this IMC. Subsequently, the
ROP will dictate what inspections should be implemented and what PIs
should be reviewed in determining the performance of WBN Unit 2 and also
what will be the regulatory response for inspection findings or events.
[]{#__RefHeading___Toc177435261 .anchor}

# 2517-13 INTERFACE WITH RELATED PROGRAMS

13.01 [Security and Safeguards Inspections]{.underline}. As with all
other cornerstones, Region II will determine, as early as possible, when
the security cornerstone is ready to be monitored under the ROP baseline
and PIs. NRR and Region II will work closely with NSIR to ensure the
physical protection inspections are appropriate for any specific WBN
Unit 2 activities that are unique to WBN Unit 2.

# 2517-14 REFERENCES

1\. W. R. McCollum, Jr., to U.S. Nuclear Regulatory Commission, Watts
Bar Nuclear Plant (WBN) -- Unit 2 -- Reactivation of Construction
Activities\", dated August 3, 2007.

(ADAMS #ML072190047)

END

Appendices:

A. Inspection Procedures, Temporary Instructions and Activity Codes

B. Documenting Inspection Findings

C. Minor Violations and Findings

D. WBN Unit 2 Construction Inspector Qualification Requirements

**APPENDIX A**

Inspection Procedures, Temporary Instructions, and Activity Codes

1\. PURPOSE

To list applicable IPs, TIs, and activity codes for conducting the WBN
Unit 2 construction inspection program.

2\. BACKGROUND

WBN Unit 2 construction was suspended in 1985. Since then, the NRC
inspection processes and tracking systems have changed. The construction
inspection program has undergone revisions including deletions and
additions. In addition, specialized TIs were developed to address
construction issues identified at the TVA sites during the 1980's
including activity codes for tracking inspection efforts.

3.  DISCUSSION

The IPs or TIs identified below are available for use in Region II's
inspection plan and schedule. Region II will determine the applicability
of the TIs and IPs to WBN Unit 2 when developing the IP&S. The activity
codes for the WBN Unit 2 project are provided to allow consistent
tracking of resources.

a\. [Inspection Procedures]{.underline}

> Region II will use the IPs listed in:
>
> IMC 2512 Appendix I, LWR -- Construction Phase Inspection Procedures
>
> IMC 2513 Appendix A, LWR -- Preoperational Testing Phase
>
> IMC 2513 Appendix B, LWR -- Operational Preparedness Phase
>
> IMC 2514 Appendix A, Startup Test Program Inspection Procedures

b\. [Temporary Instructions]{.underline}

> Temporary
>
> [Instruction (TI) No.]{.underline} [Temporary Instruction
> Title]{.underline}
>
> TI 2512/07 Region Construction Assessment Team Inspections
>
> TI 2512/15 Inspection of Watts Bar Nuclear Plant Employee Concerns
> Program
>
> TI 2512/16 Inspection of Watts Bar Nuclear Plant Cable Issues
> Corrective Action Program
>
> TI 2512/17 Inspection of Watts Bar Nuclear Plant Cable Tray and
> Supports Corrective Action Program Plan
>
> TI 2512/18 Inspection of Watts Bar Nuclear Plant Electrical Conduit
> and Supports Corrective Action Program Plan
>
> TI 2512/19 Inspection of Watts Bar Nuclear Plant Design Baseline
> Corrective Action Program Plan
>
> TI 2512/20 Inspection of Watts Bar Nuclear Plant Electrical Issues
> Corrective Action Program Plan
>
> TI 2512/21 Inspection of Watts Bar Nuclear Plant Equipment Seismic
> Corrective Action Program Plan
>
> TI 2512/22 Inspection of Watts Bar Nuclear Plant Fire Protection
> Corrective Action Program Plan
>
> TI 2512/23 Inspection of Watts Bar Nuclear Plant Hanger Update
> Corrective Action Program Plan
>
> TI 2512/24 Inspection of Watts Bar Nuclear Plant Heat Code
> Traceability Corrective Action Program Plan
>
> TI 2512/25 Inspection of Watts Bar Nuclear Plant HVAC Duct and
> Supports Corrective Action Program Plan
>
> TI 2512/26 Inspection of Watts Bar Nuclear Plant Instrument Lines
> Corrective Action Program Plan
>
> TI 2512/27 Inspection of Watts Bar Nuclear Plant Piece
> Parts/Procurement Corrective Action Program Plan
>
> TI 2512/28 Inspection of Watts Bar Nuclear Plant QA Records Corrective
> Action Program Plan
>
> TI 2512/29 Inspection of Watts Bar Nuclear Plant Q-List Corrective
> Action Program Plan
>
> TI 2512/30 Inspection of Watts Bar Nuclear Plant Seismic Analysis
> Corrective Action Program Plan
>
> TI 2512/31 Inspection of Watts Bar Nuclear Plant Vendor Information
> Corrective Action Program Plan
>
> TI 2512/32 Inspection of Watts Bar Nuclear Plant Welding Corrective
> Action Program Plan
>
> TI 2512/33 Inspection of Watts Bar Nuclear Plant Concrete Quality
> Special Program
>
> TI 2512/34 Inspection of Watts Bar Nuclear Plant Containment Cooling
> Special Program
>
> TI 2512/35 Inspection of Watts Bar Nuclear Plant Control Room Design
> Review Special Program
>
> TI 2512/36 Inspection of Watts Bar Nuclear Plant Environment
> Qualification Special Program
>
> TI 2512/37 Inspection of Watts Bar Nuclear Plant Master Fuse List
> Special Program
>
> TI 2512/38 Inspection of Watts Bar Nuclear Plant Mechanical Equipment
> Qualification Special Program
>
> TI 2512/39 Inspection of Watts Bar Nuclear Plant Microbe Induced
> Corrosion Special Program
>
> TI 2512/40 Inspection of Watts Bar Nuclear Plant Moderate Energy
> Linebreak Special Program
>
> TI 2512/41 Inspection of Watts Bar Nuclear Plant Radiation Monitoring
> System Special Program
>
> TI 2512/42 Inspection of Watts Bar Nuclear Plant Soil Liquefaction
> Special Program
>
> TI 2512/43 Inspection of Watts Bar Nuclear Plant Special Program
> Use-As-Is CAQRS Special Program

c [Activity Codes]{.underline}

> The following activity codes are to be used for time and labor
> reporting for construction inspection-related effort at Watts Bar,
> Unit 2:
>
> [Activity Code]{.underline} [Description]{.underline}
>
> OA Direct inspection effort - Time spent actually conducting
> inspections related to Watts Bar, Unit 2, construction activities.
> This includes conducting any IPs, TIs, or any other procedures as
> determined by Region II management.
>
> OAD Watts Bar, Unit 2, routine inspection documentation -- Time spent
> documenting the results of Watts Bar, Unit 2, construction inspections
> charged to OA.
>
> OAP Watts Bar, Unit 2, routine inspection preparation -- Time spent
> preparing for Watts Bar, Unit 2, construction inspections charged to
> OA.
>
> AF Watts Bar, Unit 2, allegation followup -- Time spent on inspecting
> allegations related to Watts Bar Unit 2.
>
> AFT Watts Bar, Unit 2, allegation followup travel -- Time spent
> traveling to and from Watts Bar, Unit 2, to support Watts Bar, Unit 2,
> allegation followup.
>
> BJ2 Watts Bar, Unit 2, allegation followup (prep/doc) -- Time spent
> preparing for and documenting the results of allegation followup at
> Watts Bar, Unit 2.
>
> AT Watts Bar, Unit 2, construction inspection related travel - Time
> spent traveling to and from Watts Bar, Unit 2, to support Watts Bar,
> Unit 2, construction inspections
>
> ENF Watts Bar, Unit 2, construction inspection enforcement - Time
> spent processing Watts Bar, Unit 2, construction inspection findings.
>
> COM Watts Bar, Unit 2, construction inspection routine communication -
> Time spent by SRI/RI in non-inspection related activities such as
> drop-in visits by plant management, tours with NRC management,
> teleconferences and discussions with NRC management.
>
> PS Watts Bar, Unit 2, plant status - Time spent by SRI/RI in gathering
> and analyzing information regarding current plant status and ongoing
> activities that are directly applicable to inspection planning.
> Control room and plant walkdowns, attendance at applicant status
> meetings, and inspection entrance and exit meetings.
>
> ASM Watts Bar, Unit2, assessment - All time spent evaluating
> assessment inputs and determining follow-up action. This includes
> preparation, documentation, and conduct of Quarterly, Mid-Cycle,
> End-of-Cycle Reviews, Annual Assessment Meetings, and Meetings with
> Local Officials; and time spent scheduling both baseline and
> supplemental inspection activities.
>
> Resource requirements for these inspection activities will be budgeted
> in the appropriate PA budget code and will be tracked during the
> period prior to Watts Bar 2 transition to IMC 2515. After the date of
> Watts Bar 2 transition to IMC 2515, time and labor reporting for
> inspection-related effort will be done according
>
> to standard ROP reporting procedures.

**APPENDIX B**

Documenting Inspection Results

1\. PURPOSE

To provide guidance for documenting WBN Unit 2 construction inspection
results.

2\. BACKGROUND

WBN Unit 2 is the only construction site currently remaining to be
inspected under the 10 CFR Part 50 construction inspection program. The
IMC that provided guidance for documenting inspection findings for a
construction site no longer exists. This appendix was developed using
the 1998 version of IMC 0610.

3\. DEFINITIONS

[Apparent violation]{.underline}. A potential noncompliance with a
regulatory requirement that has not yet been formally cited as a
violation in a Notice of Violation or order.

[Applicant]{.underline}. The applicant for or the holder of an NRC
license, construction permit, or combined license.

[Closed Item]{.underline}. A matter previously reported as a
noncompliance, an exercise weakness, a licensee event report, an
unresolved item, an inspection follow-up item, or a construction
deficiency report that the inspector concludes has been satisfacto­rily
resolved, based on informat­ion obtained during the current inspecti­on.

[Conclusion]{.underline}. As used in this chapter, an assessment that
relates one or more findings to the broader context of an applicant
program.

[Draft Inspection Report]{.underline}. Any version of the inspection
report before its official issuance.

[Escalated Enforcement Action]{.underline}. A Notice of Violation for
any Severity Level I, II, or III violation (or problem), or a civil
penalty or order based on a violation.

[Finding]{.underline}. A NRC-identified or self-revealing issue of
concern that is associated with an applicant performance deficiency.
Findings may or may not be associated with a regulatory requirement and,
therefore, may or may not result in a violation..

[Inspection]{.underline}. The examination and assessment of any
applicant activity to determine its effectiveness, to ensure safety,
and/or to determine compliance.

[Inspection Document]{.underline}. Any material obtained or developed
during an inspection that is considered to be an NRC record (see below).

[Integrated Inspection Reports]{.underline}. A single inspection report
that combines inputs from all inspections (resident, in-office document
review, and/or one or more visits by regional or headquarters
inspectors) conducted within a specific period.

[Applicant-Identified]{.underline}: For the purpose of this IMC,
"applicant-identified" findings are those findings that are not
NRC-identified or self-revealing. Most, but not all,
applicant-identified findings are discovered through a applicant program
or process. Some examples of applicant programs that likely result in
such findings are testing, drills, critiques, event assessments,
evaluations, or audits conducted by or for the applicant. Other examples
of applicant-identified findings are those findings that are identified
by the applicant as a result of their deliberate and focused observation
during the course of performing their normal duties.

[Minor Violation]{.underline}. A violation that is less significant than
a Severity Level IV violation, is not the subject of formal enforcement
action, and is not usually described in inspection reports or inspection
records.

[Non-Cited Violation (NCV)]{.underline}. A violation for which the staff
chooses to exercise discretion and refrain from issuing a 10 CFR Part
2.201 Notice of Violation.

[Noncompliance]{.underline}. A violation, non-cited violation, or
nonconformance.

[Nonconformance]{.underline}. A vendor\'s or certificate holder\'s
failure to meet a contract requirement related to NRC activities (e.g.,
10 CFR Part 50, Appendix B), where the NRC has not placed the
requirement directly on the vendor or certificate holder.

[Notice of Violation (NOV)]{.underline}. A formal written citation in
accordance with 10 CFR 2.201 that sets forth one or more violations of a
legally binding regulatory requirement.

[NRC Record]{.underline}. Any written, electronic, or photographic
record under legal NRC control that documents the policy or activities
of the NRC or an NRC applicant (see also the definition in 10 CFR Part
9).

[Observation]{.underline}. A fact; any detail noted during an
inspection.

[Open Item]{.underline}. A matter that requires further inspection. The
reason for requiring further inspection may be that the matter has been
identified as a noncompliance, unresolved item, inspector follow-up
item, licensee event report, or Part construction deficiency report.

[Potentially Generic Issue]{.underline}. An inspection finding that may
have implications for other licensees, certificate holders, and vendors
whose facilities or activities are of the same or similar manufacture or
style.

[Regulatory Commitment]{.underline}. An explicit statement to take a
specific action, agreed to or volunteered by an applicant, where the
statement has been submitted in writing on the docket to the NRC.

[Requirement]{.underline}. A legally binding obligation such as a
statute, regulation, license condition, technical specification, or
order.

[Self-revealing]{.underline}. For the purpose of documentation (versus
enforcement), self-revealing findings are those findings that become
self-evident and require no active and deliberate observation by the
applicant or NRC inspectors to determine whether a change in process or
equipment capability or function has occurred. Additionally,
self-revealing findings will normally be documented in the inspection
report for the time period in which the self-revealing event occurred.
Self-revealing findings become readily apparent to either NRC or
applicant personnel through a readily detectable degradation in the
material condition, capability, or functionality of equipment or plant
operations. Self-revealing findings are treated the same as
NRC-identified findings for the purposes of documenting them in
inspection reports. Some examples of self-revealing findings include
those resulting from: failure of emergency equipment to operate;
unanticipated or unplanned actuations; obvious failures of fluid piping
or plant equipment; and identification of large quantities of water in
areas where you would not normally expect such a condition; and
conditions revealed by an alarm.

[Unresolved Item]{.underline}. A matter about which more information is
required to determine whether the issue in question is an acceptable
item, a nonconfor­mance, or a violation.

[Vendor]{.underline}. A supplier of products or services to be used in
an NRC‑licensed or permitted facility or activity. In some cases, the
vendor may be an NRC or Agreement State licensee (e.g., nuclear fuel
fabricator, radioactive waste broker) or the vendor\'s product may be
required to have an NRC Certificate of Compliance (e.g., certain
transport packages such as waste casks or radiography devices).

[Violation]{.underline}. The failure to comply with a legally binding
regulatory requirement, such as a statute, regulation, order, license
condition, or technical specifica­tion.

[Willfulness]{.underline}. An attitude toward compliance with
requirements that ranges from the careless disregard for requirements to
a deliberate intent to violate or to falsify.

4\. RESPONSIBILITIES

All NRC inspectors conducting inspections at WBN Unit 2 are required to
prepare inspection reports in accordance with the guidance provided in
this attachment. General and specific responsibil­ities are listed below.

4.01 [General Responsibilities]{.underline}: ­Each inspection of WBN Unit
2 should be documented in a report consisting of a cover letter, a cover
page, an executive summary, and inspection details.

4.02 [Report Writing]{.underline}

a\. Inspectors have the primary responsibility for ensuring that
observations and findings are accurately reported, that referenced
material is correctly character­ized, and that the scope and depth of
conclusions are adequately supported by documented observations and
findings. Advice and recommendations are not to be included in
inspection reports.

b\. Inspectors are responsible for ensuring that the content of the
report, as issued, is consistent with the content of the exit meeting
presentation. When the report differs significantly from the exit
meeting, the inspector (or the report reviewer) should discuss those
differences with the applicant before the report is issued.

c\. Report writers and reviewers should ensure that inspection reports
follow the general format given in this attachment.

d\. For inspections conducted by regional and resident inspectors, the
report number is in the following form:

> Docket No./Year ‑ sequential number of the report in that year (e.g.,
> 05000360/2007001)
>
> NOTE: The report number format given here is for use in the inspection
> report itself. This format may be modified as needed for other
> applications (e.g., for Inspection Reporting System (IRS) entries),
> due to electronic constraints and other considerations.

4.03 [Report Review and Concurrence]{.underline}

a\. Before issuance, each inspection report should, as a minimum, be
reviewed by a member of NRC management familiar with NRC requirements in
the area inspected.

b\. The report reviewer (i.e., the member of management referred to
above) should establish that conclusions are logically drawn and
sufficiently supported by observations and findings, and that the
observations, findings, and conclusions are consistent with NRC policies
and require­ments.

c\. The report reviewer should ensure that assessments made in the
inspection report represent the judgment of the issuing organization and
established NRC policy rather than solely the personal views of an
individual inspector or group of inspectors.

4.04 [Report Issuance]{.underline}

a\. The applicable division director or designated branch chief is
responsible for the report content, conclusions, and overall regulatory
focus. For integrated construction reports, the Division of Construction
Projects (DCP) division director or the Construction Projects Branch 3
(CPB3) branch chief is responsible for issuing the report to the
applicant.

4.05 [Report Timeliness]{.underline}

a\. [General Timeliness Guidance]{.underline}. Inspection reports should
be issued no later than 45 calendar days after inspection completion­.

> NOTE: Inspection completion is normally defined as the day of the exit
> meeting. For integrated inspection reports, inspection completion is
> normally defined as the last day covered by the inspection report.

b\. [Reports Preceding Escalated Enforcement Actions]{.underline}.
Timeliness goals should be accelerated for inspection reports covering
potential escalated enforcement actions. For specific enforcement
timeliness goals, see the [NRC Enforcement Manual]{.underline}.

c\. [Expedited Reports for Significant Safety Issues]{.underline}.
Whenever an inspector identifies an issue involving significant or
immediate public health and safety concerns, the first priority is
facility and public safety; issues of documentation or enforcement
action are secondary. Based on the circumstances of the case, an
expedited inspection report may be prepared that is limited in scope to
the issue, or expedited enforcement action may be taken before the
inspection report is issued. The [NRC Enforcement Manual]{.underline}
provides additional guidance on matters of immediate public health and
safety concern.

5\. GUIDANCE - INSPECTION REPORT CONTENT

This section relates primarily to matters of content in the inspection
report details. For guidance on the content of report cover letters
refer to IMC 0612. The report should include a paragraph for each
inspection procedure, temporary instruction or generic communication
inspected. The paragraphs should be organized in ascending order.

5.01 [Observations, Findings, and Conclusions]{.underline}. As used in
this chapter, the term \"observation\" refers to a fact\--any detail
noted during an inspection. The term \"finding\" designates an
observation that has been placed in context and assessed for its
significance. The term \"conclusion\" is used for an assessment that
relates one or more findings to the broader context of an applicant
program or an assessment area.

Adherence to the use of these terms is less important than appreciating
the underlying process. Achieving relative consistency in inspection
report content first requires a common understanding of how inspection
observations are assessed for signifi­cance, and how the resulting
findings may be combined to reach a conclusion about the adequacy of the
program or activity inspected.

a\. [Observations]{.underline}. The most basic results of an inspection
are the facts an inspector gathers\--through watching work activities,
examining equipment, interviewing applicant employees, reviewing
records, and other inspection methods. Observations should be factual
and not hunches, speculation, unsubstantiated hearsay, or unverified
opinions.

b\. [Findings]{.underline}. In order to become a finding, an observation
has to be placed in context and assessed for significance by addressing
the following.

> 1\. [Requirements and Standards]{.underline}. To place an observation
> into context, it should be related to a requirement or a standard. For
> example, to place an observation about the applicant\'s replacement of
> in-core detectors with a different design into context, the inspector
> may wish to reference 10 CFR 50, Appendix B, Criterion III, \"Design
> Control,\" or may choose to reference, more specifically, an approved
> applicant procedure.
>
> When the area of the finding is not specifically covered by regulatory
> requirements, the inspector should clearly state the expected standard
> of performance when placing it into context. In such a case, the
> inspector should use inspection procedures and discussions with NRC
> and applicant management to arrive at a clear statement of expected
> performance.

2.  [Assessment of Significance]{.underline}. When assessing the
    significance of an observation, the inspector should answer
    questions such as:

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(a) Is the SSC installed, inspected and/or tested in accordance with its
    design and licensing requirements?

(b) Are any deviations from the original design and licensing
    requirements documented in the applicant's CAP and properly
    reconciled?

(c) Will the deviations have an immediate or latent impact on nuclear
    safety, either directly or indirectly?

(d) Did the applicant maintain configuration management by clearly
    recording the as-built configuration of the SSC and updating
    impacted documentation and databases in a way that promotes
    conservative decision making over the entire life of the plant?

(e) Will inadequate configuration management have the potential to cause
    latent failures or impede conservative operational decision making?

(f) What were the causes?

(g) Inspector or applicant identified?

(h) Should it have been found by the applicant sooner?

(i) Promptness, adequacy and thoroughness of corrective actions.

(j) How does the applicant characterize the significance of this matter?

(k) Who was involved in the issue?

> The above questions are not meant to be all inclusive nor do they
> apply to every situation. The inspector should weigh the circumstances
> impartially, and should include in the report those details that
> contribute to understanding the significance of the
> observation\--regardless of whether they make it appear more severe or
> more benign.
>
> NOTE: Inspectors should always document certain supporting details for
> enforcement-related findings. On the other hand, inspectors should be
> careful not to make direct statements, in the report details,
> regarding the safety significance of the noncompliance (see Section
> 5.04.b).

The inspector should make every effort to understand and fairly
characterize the applicant\'s perspective. In addition, the inspector­\'s
final assessment of a finding\'s signifi­cance should be validated
through discussion with other inspectors and with NRC management.

c\. [Conclusions]{.underline}. Conclusions are general statements of
assessment that relate one or more findings to the broader context of
the applicant program or assessment area inspected. The report writer\'s
task is to match the scope of the conclusions to what the inspection
findings will support and not make them too narrow or too broad;

> 1\. [Conclusion Scope]{.underline}. The scope of a conclusion is
> usually dependent upon what amount of inspection focus was directed
> toward a given area. At a minimum, the conclusion should highlight the
> important details of the finding including the associated requirement
> and the impacted assessment area. In addition, it should include any
> cross-cutting aspects identified using the guidance in IMC-0305,
> Section 06.07.
>
> 2\. [Conclusion Focus]{.underline}. In general, conclusions should
> focus on the capability of the program or activity to accomplish its
> design basis function. In assessing this capability, the conclusion
> statements may take various forms, but they should in all cases be
> concrete and supportable.
>
> \(a\) For inspections of SSCs, conclusions should seek to answer
> questions such as the following:

-   Are the safety functions of the SSC required by either its design or
    licens­ing basis, negatively impacted by the deficiency?

-   Is testing \[and/or maintenance\] adequate to demonstrate that the
    component or system would perform all of the safety functions
    required?

-   Is training adequate to ensure proper operation and maintenance of
    the component or system?

-   Are control functions effective and reliable?

-   Are human factors considerations relating to the component or system
    (e.g., accessibility and labeling of components) adequate to ensure
    proper system operation?

-   Are system procedures adequate to ensure proper system operation
    under normal and accident conditions?

> Additional, similar questions may be developed based on the applicable
> inspection procedure.
>
> \(b\) For an inspection that has focused on an overall program, the
> conclusion should assess the basic capability of that program in
> meeting its safety objectives. In some cases, the safety objectives
> may be found in the applicable inspection procedure. If the safety
> objectives have not been specified elsewhere in the report, the
> conclusion should make the objectives clear.
>
> \(c\) Finally, conclusion statements should note any noncompliances
> described in that section of the report and their associated
> cross-cutting aspects, if any.

5.02 [Thresholds of Significance]{.underline}. As part of maintaining a
focus on safety, inspectors continually use NRC requirements, inspection
procedures, risk assessment documents, industry standards, regional and
headquarters guidance, and their own training and insight to make
judgments about which issues are worth pursuing and which are not.

To communicate effectively, inspection reports must give evidence of
that judgment and prioritization, discussing significant safety issues
in appropriate detail, treating less significant issues succinctly, and
avoiding excess verbiage. To maintain some consistency in how minor
issues are treated, report writers must recognize certain \"thresholds
of significance\": that is, they must use similar criteria in deciding
whether an issue is important enough to document, track or follow up.

The NRC Enforcement Policy acknowledges that some violations of minor
safety, environmental, and regulatory concerns are below the level of
significance of Severity Level (SL) IV violations. Because of their
minor nature, these minor violations are not the subject of formal
enforcement action and are not usually documented in inspection reports.

> NOTE: For additional guidance in this area, see the NRC Enforcement
> Manual and Appendix C of this IMC.

a\. [Minor Violations\--Determining Significance]{.underline}. Use
Appendix C of this IMC to determine the significance of the violations.

b\. [Minor Violations\--Determining Whether to Document]{.underline}. In
general, minor violations should [not]{.underline} be documented;
however, certain exceptions apply. Documentation may be necessary as
part of the resolution to an allegation or to close a Licensee Event
Report (LER) or CDR. In other cases, while the violation itself is
minor, the associated technical information may relate directly to an
issue of agency-wide concern (e.g., the inspection was performed in
response to an NRC Temporary Instruction (TI)). If, for these reasons or
any other reason, the report writers and reviewers wish to document a
minor violation, then it should be documented as a minor violation, with
a reference to Section IV of the NRC Enforcement Policy. For example,
"This failure constitutes a violation of minor significance and is not
subject to formal enforcement action."

c\. [Violations Identified as Part of Applicant
Self-Assessments]{.underline}. Under certain circumstances, even a
violation that could be classified as SL IV ("more-than-minor") need not
be documented. This is generally justified when the violation has been
identified and corrected as part of an applicant self-assessment effort.
As a matter of policy, NRC enforcement seeks to encourage applicant
self-assessment efforts, and seeks to avoid the negative impact that can
result from a redundant NRC emphasis on problems which the applicant's
responsible action has already identified and corrected.

> For example, suppose that while evaluating the applicant's quality
> assurance efforts in the fire protection area, an inspector reviews
> relevant audits and surveillances conducted over the previous year.
> The review reveals that the audits have been probing and thorough; the
> findings are well-developed and technically sound, and include six
> noncompliance issues, four of which might be classified at SL IV.
>
> In such a case, the inspector should follow up on the noncompliances
> and other audit findings to ensure that causes have been appropriate­ly
> assessed, that appropriate and comprehensive corrective actions have
> been taken, and that no new examples of the violations exist.
> Provided, however, that no new problems are revealed by this
> follow-up, the inspector is normally not expected to cite the four
> violations individually, nor to report the details of those violations
> in the inspection report. Instead, the NRC report findings and
> conclusions should assess the adequacy of the applicant's quality
> assurance efforts, including a clear reference to the name, dates, and
> general subject matter of the audit or self-assessment.
>
> NOTE: This expectation only applies to SL IV violations. Even when
> identified through an applicant self-assessment, violations that could
> be categorized at SL III or above must be documented in the inspection
> report and given appropriate follow-up.
>
> If, for any of these reasons, the inspector decides to discuss in the
> inspection report a particular applicant self-assessment finding or
> audit finding, and that finding involves a violation, then the
> violation must be clearly dispositioned in the report. If the criteria
> of Section VI.A.8 of the NRC Enforcement Policy have been met
> (including applicant corrective action, etc.) the SL IV violation
> should be documented as an NCV. If the issue represents a minor
> violation, it should be documented as follows: "This failure
> constitutes a violation of minor significance and is not subject to
> formal enforcement action."
>
> NOTE: The [NRC Enforcement Manual]{.underline} provides additional
> guidance on document­ing and dispositioning violations.

5.03 [Level of Detail]{.underline}. Just as inspectors must use judgment
in determining what issues are worth including in the inspection report,
so they must also determine the appropriate level of detail for issues
that are included. Some issues should be discussed in more detail than
others, based on safety or regulatory significance, technical
complexity, and other factors.

a\. [Level of Detail on Inspection Scope]{.underline}. Describe the
inspection scope. Do not repeat any portion of the Scope in the Findings
section. The scope should include the following:

1.  Identify how the inspection was conducted (i.e., the methods of
    inspection.) Methods can include a walk-down, an in-office review,
    observation of test from the control room, discussion with specific
    personnel, or participation in an exercise.

2.  Identify what was inspected. Include sufficient detail on which and
    how many samples were inspected. If more than six documents were
    reviewed, then list the items in an attachment and reference the
    attachment in the Scope section.

3.  Identify the inspection objectives and the criteria that were used
    to determine whether the applicant is in compliance.

4.  Include inspection dates to clarify inspection scope context if it
    helps with understanding the scope. For example, inspection dates
    may be helpful when discussing event follow-up.

5.  If a substantive portion of the inspection activity was conducted at
    a location other than the plant, (e.g., an in-office review), then
    identify where the inspection took place.

b\. [Level of Detail on Observations and Findings]{.underline}. Once the
inspector has decided that a finding is important enough to be included
in the report, the same questions used in making that decision (see
Section 5.01) can assist in determining the appropriate level of detail.
The following guidance applies:

> 1\. The degree of actual or potential safety consequence associated
> with a finding should be a primary consideration in determining the
> level of appropriate detail. Items of higher significance generally
> merit more discussion.
>
> 2\. If the inspector has concluded that a finding has programmatic
> aspects (e.g., multiple examples of the problem, a related series of
> failures, an underlying procedure or training deficiency, or diverse
> effects resulting from the same root cause), enough detail should be
> given to support this conclusion.
>
> 3\. Findings of greater technical significance\--that is, findings
> that give insights into SSCs or human performance issues, or findings
> that could have generic significance\--should be discussed in
> sufficient detail to communicate those insights.
>
> 4\. When initiating an unresolved item or inspection follow-up item,
> the issue description should provide enough background information
> that a different inspector, using that information, would be equipped
> to perform the follow-up inspection.

5.04 [Documenting Noncompliances]{.underline}. The primary guidance for
all matters related to enforcement, including documentation, is given in
the NRC Enforcement Policy and the NRC Enforcement Manual. These
documents can be found at
http://www.nrc.gov/about-nrc/regulatory/enforcement/guidance.html. The
following discussion summarizes certain aspects of that guidance related
to inspection reports.

a\. [Types of Noncompliances]{.underline}. The manner of documenting a
noncompliance in the inspection report depends on how that noncompliance
will be dispositioned. A noncompliance may be addressed as a
non-escalated enforcement action (i.e., a SL IV violation or a
nonconfor­mance); as an escalated enforcement action (i.e., an apparent
SL I, II, or III violation); or as an NCV.

> If a violation does [not]{.underline} exist (e.g., no requirement
> exists in this area), it may be appropriate to clarify the finding by
> stating that \"this condition \[or event\] does not constitute a
> violation of NRC require­ments.\"
>
> 1\. [Non-Escalated Enforcement Actions]{.underline}. Most violations
> of very low significance (i.e., more than minor concerns) fall into
> the SL IV category. If at the time of issuing the inspection report a
> violation has been categorized at SL IV, and it does not meet the
> criteria for an NRC, then an NOV is generally sent out with the
> inspection report as a "non-escalated" enforcement action. The cover
> letter for reports that include non-escalated enforcement actions
> should follow the appropriate NRC Enforcement Manual guidance.
>
> NOTE: A violation\'s severity level should not be discussed in the
> report details. Whether an NOV accompanies the report or is issued
> later, the designation of severity level is made in the NOV itself.
>
> 2\. [Potential Escalated Enforcement Actions]{.underline}. When an
> issue is being considered for escalated enforcement action, the
> inspection report narrative should refer to the potential
> noncompliance as an \"apparent violation.\" The report details should
> not include any speculation on the severity level of such violations
> nor on expected NRC enforcement sanctions. Potential escalated
> actions, by their nature, require further agency delibera­tion (and,
> usually, additional applicant input) to determine the appropriate
> severity level and NRC action.
>
> Similarly, report narratives that discuss apparent violations should
> be carefully constructed to avoid making explicit conclusions (i.e.,
> final judgments) about the safety significance of the issue. The
> report should include any available details that give evidence of
> safety significance, or that would help in making such a decision;
> however, since a potential escalated enforcement action automati­cally
> entails further evaluative steps, neither the inspection report
> details nor the accompanying cover letter should present a final
> judgment on the issue.
>
> 3\. [Non-Cited Violations]{.underline}. Section VI.A.8 of the NRC
> Enforcement Policy gives specific criteria under which an SL IV
> violation may be documented without an associated NOV or other action.
> When this enforcement discretion is applied, the report should briefly
> describe the circumstances of the violation, briefly describe the
> applicant\'s corrective actions, and conclude with a statement similar
> to the following: \"This non-repetitive, applicant-identified and
> corrected violation is being treated as a Non-Cited Violation,
> consistent with Section VI.A.8 of the NRC Enforcement Poli­cy.\"
>
> In addition, the Enforcement Policy also provides that willful SL IV
> violations may be dispositioned as NCVs provided that they meet the
> four criteria outlined in the Policy. In these cases, the inspection
> report should include additional discussion to address this before
> providing the standard conclusive language. For example: \"Although
> this violation is willful, it was brought to the NRC\'s attention by
> the applicant, it involved isolated acts of a low-level individual,
> and it was addressed by appropriate remedial action. Therefore, this
> non-repetitive, applicant-identified and corrected violation is being
> treated as a Non-Cited Violation, consistent with Section VI.A.8 of
> the [NRC Enforcement Poli­cy]{.underline}.\"
>
> 4\. [Minor Violations]{.underline}. Minor violations should not be
> normally documented in inspection reports. However, to the extent that
> documentation is necessary, the standard language should be used:
> "This failure constitutes a violation of minor significance and is not
> subject to formal enforcement action."

b\. [Supporting Details and Discussions of Safety
Significance]{.underline}. The discussion of noncompliance issues must
be sufficient­ly detailed to substantiate any NRC safety and regulatory
concerns and to support any enforcement sanction the NRC may choose to
issue. To the extent possible, for a violation, the report should state:

-   what requirement was violated;

-   how the violation occurred;

-   when the violation occurred, and how long it existed;

-   who identified it, and when;

-   any actual or potential safety consequence;

-   the root cause (if identified);

-   whether the violation appears isolated or programmatic; and

-   what corrective actions have been taken or planned.

> The degree of detail necessary to support an enforcement action is a
> function of the significance and complexity of the noncomplia­nce.
>
> Although supporting details clearly assist in determining the safety
> significance of the noncompliance, inspectors must be careful to avoid
> making direct statements regarding safety significance in the
> inspection report details. Violation severity levels, as described in
> the NRC Enforcement Policy, are based on the degree of safety
> significance involved. In addition, the NRC Enforcement Policy uses
> the term \"safety significance\" in a specific sense, which involves
> consideration of (1) actual safety consequence, (2) potential safety
> consequence, and (3) regulatory significance (e.g., willfulness or
> management involvement in a noncompli­ance, programmatic breakdowns,
> repetitive violations, etc.). As a result, if an inspection report
> refers to a noncompliance as being \"of low safety significance\"
> (meaning, in a general sense, that the noncompliance did not result in
> any actual adverse impact on plant equipment or personnel), the writer
> may have inadvertently made it difficult for the NRC to subsequently
> decide that the potential for an adverse impact or the regulatory
> significance of the noncompliance warrants issuance of a SL III
> violation.

c\. [Noncompliances Involving Willfulness]{.underline}. Inspection
reports should neither speculate nor reach conclusions about the intent
behind a violation, such as whether it was deliberate, willful, or due
to careless disregard. As with any observation, the report discussion
should include relevant details on the circumstances of the violation
without making a conclusion about the intent of the violator.

> Conclusions about the willfulness of a violation are agency decisions,
> and are normally not made until after the Office of Investigation (OI)
> has completed an investiga­tion and a predecisional enforcement
> conference has been held. A premature or inaccurate discussion of the
> willfulness of an apparent violation in the inspection report could
> result in later conflicts based on additional input and review.
> Inspection reports that include potentially willful violations are to
> be coordinated with OI and the Office of Enforcement (OE).

5.05 [Documentation of Performance-Based Inspection]{.underline}.
Performance-based inspection focuses on issues of safety and
reliabili­ty, with an emphasis on field observation rather than in-office
procedural or record reviews. In addition, performance-based inspection
tends to focus more on results (e.g., does the pump work?) than on
process and method (e.g., was the pump maintenance procedure
well-written?). For most areas of inspection, the range of relevant
regulations, license requirements, industry guidelines, and applicant
regulatory commitments is a mixture of performance-based
(results-oriented; less prescriptive) and compliance-based
(process-oriented; more prescriptive) standards.

a\. [Documenting Performance-Based Issues vs. Compliance-Based
Issues]{.underline}. The first step in documenting \"performance-based\"
findings is understanding the underlying flow of logic, and
differentiating this logic from that of a finding based strictly on
compliance. For compliance issues, the clearest manner of presentation
is usually comparison/contrast, similar to the format of an NOV.

> By contrast, a performance-based finding frequently begins with the
> field observation of a safety or reliability issue (e.g., an equipment
> problem, a deficient work practice, a questionable system response,
> etc.), which results in efforts to place the observation in context,
> pinpoint the root causes, understand any associated problems with the
> underlying processes or methods\--all of which may or may not lead to
> an issue of noncompliance. When documenting such a finding, the
> clearest presentation usually follows the same path of
> discovery\--that is, the narrative (1) begins with a statement of the
> observation, (2) places that observation in the context of related
> findings or circumstances that contribute to understanding its
> significance, (3) explains any known root causes or underlying process
> problems, and (4) leads to a \"bottom-line\" assessment that a
> particular standard was or was not met (if the standard is a
> requirement, this may be a finding of noncompliance).

b\. [Documenting Issues in Areas Not Covered by Regulatory
Requirements]{.underline}. Although the NRC always seeks to focus the
requirements of its regulations and licenses on safety considerations,
mere compliance with those require­ments does not automatically ensure
safety. The NRC\'s safety mandate entails inspection and evaluation of
applicant performance in areas that may not be covered by written
requirements.

> Presumably, judgments made in this realm\--in areas not covered by NRC
> requirements\--must still use some standard as a reference point.
> Various inspection procedures give specific criteria for the inspector
> to use in evaluating an applicant\'s performance\--including some
> criteria that are not directly related to an NRC requirement, and that
> might be more correctly characterized as matters of industry
> convention or standard nuclear safety practices. When inspection
> findings are made in these areas\--that is, when safety issues are
> identified that do not relate directly to a regulatory
> requirement\--the treatment of such findings can be extremely
> difficult.
>
> 1\. [Using Standards in Areas Not Covered by NRC
> Requirements]{.underline}. Whenever possible, the inspector should
> seek to tie the finding to a documented program or expectation (e.g.,
> a generic communication on wrong-component or wrong-train events, an
> applicant\'s previously established self-checking program, etc.). In
> addition, once a clear standard is recognized, the inspector may be
> able to relate these findings to other instances in which the
> applicant\'s performance has not met these expectations.
>
> When multiple problems have been found, the inspector may, depending
> on the circumstances of the case, wish to use a more broad statement
> that applies to more than one of the observations.
>
> 2\. [Addressing the Need for Applicant Corrective Action]{.underline}.
> Since the standards discussed here may be in areas outside NRC
> requirements, they may not be used as the basis for requesting
> applicant corrective action either orally or in the inspection report.
> When safety issues are involved, a responsible applicant will likely
> take corrective actions, and these actions should be documented in the
> inspection report as appropriate.
>
> When questions exist about the adequacy of the applicant\'s taken or
> planned corrective actions, the inspector may choose to create an
> inspection follow-up item to ensure that the applicant\'s later
> actions are evaluated. In addition, if the applicant fails to take
> proper corrective action for a safety matter and the problem recurs or
> additional safety issues result, the applicant may be in noncompliance
> with 10 CFR 50, Appendix B, Criterion XVI, \"Corrective Action.\"
>
> Finally, in extreme cases where the applicant refuses to take
> corrective action for a matter of immediate safety significance, the
> NRC may exercise its authority to impose an order, even if the
> applicant has not violated an existing regulation or license
> condition. Any such situation should result in prompt involvement by
> NRC management (including OE and the Office of General Counsel).
>
> 3\. [Avoiding Inadvertent Backfits]{.underline}. 10 CFR 50.109
> establishes specific regulatory authority for the NRC to impose new
> requirements on reactor applicants involving the addition,
> elimination, or modifica­tion of struc­tures, systems, or components at
> operating facilities. In order to impose a backfit, the Commission
> must make a finding that the action will result in substantial
> additional protection of public health and safety or the common
> defense and security.
>
> 4\. As discussed in NRC Management Directive 8.4, an NRC staff
> recommen­dation that the Commission impose a backfit should only be
> made after extensive deliberation and evaluation of all associated
> circumstan­ces. For routine discussions of safety issues in inspection
> reports, care must be exercised to avoid making an inadvertent
> recommendation that could be construed as an NRC backfit.

5.06 [Treatment of Open Items in Reactor Inspection
Reports]{.underline}. Issues that merit additional inspection are
identified by a unique tracking number and entered into the Inspection
Reporting System by the originating inspector or office. Open items
include unresolved items, violations, LERs, and CDRs.

a\. [Initiating Open Items]{.underline}. The action of initiating an
open item is a commitment of future resources, and should therefore only
be used when some specific applicant action is pending, or when needed
information is not available at the time of the inspection. When the
inspector believes that the additional information may reveal the issue
to be a matter of noncompli­ance, an unresolved item should be initiated.
For an unresolved item, the report should identify the actions or
additional research needed to resolve the issue.

> Issues of noncompliance should always be assigned an IRS number for
> tracking purposes. When an inspection involves multiple violations (or
> multiple examples of a single violation), the inspector should be
> careful to ensure a one-to-one correspon­dence between the number of
> IRS entries and the number of \"contrary to\" statements in the
> accompanying Notice of Violation. The NRC Enforcement Manual provides
> additional guidance on tracking and following up issues of
> noncompliance.
>
> Upon receipt, LERs and CDRs should be entered into the IRS system for
> tracking and follow-up.

b\. [Follow-Up and Closure of Open Items]{.underline}. The level of
detail devoted to closing open items depends on the nature and
significance of the additional information identified. For example, the
closure of an unresolved item should summarize the topic, summarize the
inspector\'s follow-up actions, evaluate the adequacy of the
applicant\'s corrective actions, and include enough detail to justify
the inspector\'s conclusion.

> In closing out a violation, if the applicant\'s \"Response to a Notice
> of Violation\" already has given an accurate description of the root
> cause, corrective actions taken, and other aspects, and the inspector
> identifies no other instances of the violation, the close-out
> description should be correspondingly brief.
>
> Region II may administratively close out an open item that does not
> warrant inspection resources. For example, Region II may review the
> proposed corrective action plan for a Unit 2 open item and compare it
> with what was done for the operating unit. If all of the following
> questions are answered affirmatively about the open item, it can be
> administratively closed and the basis for its closure documented in an
> inspection report:

-   Is it being effectively tracked in the applicant's corrective action
    program or other formal tracking system?

-   Is the applicant proposing the same corrective action or equivalent
    to what was done for a similar open item for Unit 1?

-   Will essentially the same procedures, process, or design change be
    used to correct the issue?

-   Does the inspection record indicate that the item was sufficiently
    inspected and closed on Unit 1 with no problems?

-   Would performance deficiencies associated with the applicant's
    corrective actions likely be detected by the applicant's oversight
    or testing programs or have only minor consequences?

c\. [Treatment of LERs and CDRs]{.underline}. All LERs and CDRs should
be followed up and given formal closure in an inspection report;
however, the level of detail provided in the report will vary depending
on the significance of the LER/CDR and the results of the inspector\'s
follow-up. For example, LERs/CDRs involving minor issues, where no new
equipment, system, or human performance problems are identified, and
where the inspector\'s follow-up does not result in new information or
additional perspec­tives, require only a brief closure statement. On the
other hand, an LER/CDR that involves more than a minor issue, that has
[not]{.underline} been discussed and dispositioned in another section of
this or a previous report, require a closure that provides, at a
minimum, a basic description of the event. This should include the
applicant\'s immediate response and subsequent corrective actions, the
root cause or causes, a summary of the inspector\'s follow-up actions,
and a statement of how the finding was resolved. The discussion should
be brief and concise, except in cases where the NRC\'s information and
perspectives differ from the applicant\'s information and perspec­tives
described in the LER/CDR. If the inspector\'s follow-up does not result
in new information or additional perspectives, the report should not
uselessly reiterate the detailed event description.

> Note that LERs and CDRs frequently involve violations of TSs or other
> require­ments. As with other report findings, if the LER/CDR is
> discussed in a manner that implies a violation may have occurred
> (either as part of the event itself or in the underlying root cause),
> the noncompliance must be clearly disposi­tioned in the report as a
> violation, an apparent violation, or an NCV, as appropriate, or a
> statement included clarifying that \"this event did not constitute a
> violation of NRC requirements.\" If such a violation would normally be
> categorized at SL III, then the inspection report must provide a full
> description of the event and surrounding circumstanc­es, and the matter
> should be treated like any other potential escalated enforcement
> issue.

6\. GUIDANCE - INSPECTION REPORT FORMAT

Whenever possible, NRC inspection reports should conform to the standard
formats described in this section and illustrated in the attached
exhibits. This standardization in format significantly enhances
readability and information retriev­al, which in turn increases
efficiency and improves the ability to integrate inspection results.
Exceptions should be made for major team inspection reports and other
cases where the specifically directed focus of the inspection does not
easily fit into the standardized report outline.

6.01 [Cover Letter]{.underline}. Refer to IMC 0612 Section 11.08 and
Exhibit 4 for guidance on format and content of the cover letter

6.02 [Cover Page]{.underline}. Refer to IMC 0612 Section 11.04 and
Exhibit 3 for guidance on format and content of the cover page.

6.03 [Executive Summary]{.underline}. The summary should be informative
but concise. An ideal inspection report summary will be useful as an
overview tool for applicant management and for NRC staff when preparing
for the periodic assessment or management briefings.

a\. [Introduction]{.underline}. The summary should begin with a one- or
two-sentence introduction that covers the type of inspection, the scope
(i.e., the applicant programs or assessment areas inspected), and any
special details.

b\. [Presentation of Findings, Cross-cutting Aspects and
Conclusions]{.underline}. The list of issues that follows should be in
the same order as the report details (modeled after the standard
inspection report outline included as Exhibit 1). In essence, the
executive summary should be compiled by scanning each report section and
writing a crisp, short summary sentence for each issue of noteworthy
observations, noncompliances, findings, cross-cutting aspects and
conclusions.

> NOTE: Unresolved items should not be discussed in the executive
> summary (i.e., where more information is needed to reach a finding or
> conclusion). If a finding or conclusion [was]{.underline} reached in
> an area related to the open item, the executive summary may include
> that finding or conclusion.
>
> When findings are included in the executive summary, the usefulness of
> those findings will be increased by concisely stating the root cause
> (if the root cause has been determined). In addition, when broad
> conclusions are included indicating unusually negative performance in
> a particular area of inspection focus, the conclusions will be made
> more useful by giving a brief but supportive example.

6.04 [Table of Contents]{.underline}. For reports of significant length
(i.e., in which the report details section exceeds 10 pages), the writer
should consider including a table of contents as an aid to clarity.

6.05 [Report Details: Use of the Standardized Report
Outline]{.underline}. The report details should be topically arranged in
accordance with the standardized report outline, included as Exhibit 1.
This does not mean, of course, that each outline topic should be covered
in each report; however, to the extent that inspection is performed in a
particular area (e.g., inspection of \"general employee training in
radiological protec­tion\"), the resulting findings should be placed in
the corresponding standard section of the report (e.g., in R5 of the
standardized outline; see Exhibit 1).

> NOTE: Conformity to the standardized outline should not result in
> artificially fragmenting an event description or separating report
> details that would logically be presented together.
>
> Regardless of what section the writer finds most appropriate, the
> basic details need only be presented once. Cross-references should be
> made in other sections as appropriate. In the example above, the
> writer might choose to discuss performance of the maintenance
> procedure under M1 (because the most significant result related to how
> the maintenance was conducted), but include cross-references under M5
> or R4 because of implications related to those areas.

6.06 [Report Details: Internal Organization of Specific
Sections]{.underline}. Differences in the nature, significance, and
complexity of individual findings results in considerable variety in how
those findings are organized and presented. However, the overall
organization of each report section should follow the same basic
progression of logic: inspection scope, observations and findings,
cross-cutting aspects and conclusions.

a\. [Inspection Scope]{.underline}. As discussed earlier, this
description should be complete and factual but concise. A tabular format
is frequently the clearest; the inspector can use this format to list
systems and components inspected, specific work activities or plant
evolutions that were monitored, procedures and records reviewed, etc.

b\. [Observations and Findings]{.underline}. This portion of each report
section should be used to present, in a narrative format, the inspection
results. At this stage in the report, the inspector may choose to simply
number issues sequentially, with appropriate subheadings, or may use
another method of organizing the findings.

c\. [Conclusions]{.underline}. In general, each report section should
have a conclusion section, in which the findings are related to the
broader context of the particular applicant program and the impacted
assessment area. The relationship among findings will vary: in some
cases, the conclusions to be drawn will be specific to the individual
report section; in other instances, the findings of several report
sections can be integrated into a broader conclusion. Document any
cross-cutting aspects resulting from the review of inspection findings
using the guidance of IMC-0305, Section 06.07.

> NOTE: When a given section of the report only involves closure of one
> or more open items, a separate conclusion section may not be needed or
> appropriate.

6.07 [Exit Meeting Summary]{.underline}. The final section of each
reactor inspection report should be a brief summary of the exit meeting.
This summary should normally include the following elements:

a\. [Characterization of Applicant Response]{.underline}. In general,
the report should not characterize an applicant\'s exit meeting response
as one of wholehearted acceptance of the inspection findings. If the
applicant generally agreed with the findings presented, the exit meeting
characterization might read as follows:

> EXAMPLE: \"The inspectors presented the inspection results to members
> of applicant management at an exit meeting on June 12, 2007. The
> applicant acknowledged the findings presented.\"
>
> On the other hand, when the applicant disagrees with the inspectors\'
> assessment of a particular finding, this position should be briefly
> and specifically characterized. Specific items discussed elsewhere in
> the report should not be described in this section in detail.

b\. [Applicant Oral Statements and Regulatory Commitments]{.underline}.
If, at the exit meeting or at any other time during the inspec­tion, the
applicant makes an oral statement that it will take a specific action,
the report should attempt to accurately characterize that statement. As
determined by the significance, complexity, subject area, and resource
expenditure involved, the inspector should ensure that such oral
statements are made or endorsed by the proper member of applicant
management. Inspectors should be careful to differentiate between (1)
applicant general descriptions of \"voluntary enhancements\" or general
intent; and (2) oral statements of the applicant\'s intent to make a
specific regulatory commitment (i.e., to submit, on the docket, a
written commitment to take a specific action).

> Because regulatory commitments are a sensitive area, the inspector
> should also ensure that any reporting of such an applicant oral
> statement is accurately characterized. To ensure a clear mutual
> understanding of such issues, when the applicant makes an oral
> statement reflecting the intent to make a regulatory commitment, the
> report issuing office may wish to restate, in the report cover letter,
> the NRC\'s understanding of that proposed commitment, and ask the
> applicant to clarify any differences in understand­ing.

c\. [Absence of Proprietary Information]{.underline}. At the exit
meeting, the inspectors should verify whether or not the applicant
considers any materials provided to or reviewed by the inspectors to be
proprietary.

> NOTE: When an inspection is likely to involve proprietary informa­tion
> (i.e., based on the technical area or other considerations of
> inspection scope), the topic of how to handle such information should
> be discussed at the entrance meeting.
>
> If the applicant does not identify any material as proprietary, the
> exit meeting summary should include a sentence to that effect.
>
> EXAMPLE: \"The inspectors asked the applicant whether any materials
> examined during the inspection should be considered proprietary. No
> proprietary information was identified.\"

d\. [Subsequent Contacts or Changes in NRC Position]{.underline}. The
report writer should briefly discuss any significant contacts between
the inspectors and applicant staff or management that occur after the
exit meeting (e.g., to discuss new information relevant to an inspection
finding). In addition, as discussed earlier, if the NRC\'s position on
an inspection finding changed significantly after the exit meeting, that
change should be discussed with the applicant before the report is
issued.

6.08 [Report Attachment]{.underline}. The areas discussed below should
be included in an attachment at the end of the inspection report.

a\. [Partial List of Persons Contacted]{.underline}. The report writer
should list, by name and title, those individuals who furnished
significant information or were key points of contact during the
inspection (except in cases where there is a need to protect the
identity of an individual). An exhaustive list is neither required nor
desirable; 5 - 10 key individuals are normally sufficient. The list
should include the most senior applicant manager present at the exit
meeting. The list should also include other NRC technical personnel who
had significant involvement, if they were not listed as inspectors on
the cover page.

b\. [List of Items Opened, Closed, and Discussed]{.underline}. The
report should provide a quick-reference list of items opened and closed,
including the item number, the IRS code for the item, and a brief phrase
(10 words or less) describing the item. Open items that were discussed
(but not closed) should also be included in this list.

c\. [List of Acronyms]{.underline}. Reports of significant length (i.e.,
in which the report details section exceeds 10 pages) should generally
include a list of acronyms as an attachment. For reports in which a
relatively small number of acronyms have been used, such a list is
optional. In all cases, however, acronyms should be clearly defined when
first used in text, regardless of whether a list of acronyms follows the
report narrative.

**Appendix B Exhibit 1**

Standard Construction Inspection Report Outline

Cover Letter

Cover Page

Executive Summary

Table of Contents (optional)

Report Details:

Summary of Plant Status

I. Quality Assurance Program

II\. Management Oversight and Controls

C Construction Activities

M Maintenance Activities

E Engineering Activities

SY System Turnovers

P Pre-Operational Activities

SU Startup Testing Activities

T Training and Qualification of Plant Personnel

III Operational Readiness Activities

O Operations

F Fire Protection

ST Surveillance Testing

CH Chemistry

R Radiation Safety

S Security

EP Emergency Preparedness

IV\. Other Activities

V. Management Meetings

X1 Exit Meeting Summary

X2 Applicant-identified Violations

X3 Pre-Decisional Enforcement Conference Summary

X4 Management Meeting Summary

Partial List of Persons Contacted

List of Inspection Procedures Used

List of Items Opened, Closed, and Discussed

List of Documents Reviewed

List of Acronyms (optional)

**APPENDIX C**

Minor Violations and Findings

1\. PURPOSE

This appendix provides guidance to assist inspectors in determining if a
finding or violation is more than minor.

2\. BACKGROUND

This guidance applies to thresholds for documenting findings and
violations in WBN Unit 2 inspection reports. Although the following
examples are all violations of requirements, findings not associated
with requirements should be considered minor if the finding \`is similar
to the example guidance. Minor findings and violations are not the
subject of formal enforcement action or documentation. Failures to
implement requirements that have insignificant safety or regulatory
impact or findings that have no more than minimal risk should normally
be categorized as minor. While applicants must correct minor violations,
minor violations or other minor findings do not normally warrant
documentation in inspection reports or inspection records and do not
warrant enforcement action.

3\. DISCUSSION

Minor violations and findings have no potential to impact quality or
safety, little to no impact on the regulatory process, and no
willfulness. Minor violations and findings will not normally be
documented in a report, unless they are linked to an
applicant-identified issue such as a construction deficiency report,
LER, etc.

A finding should be matched to the specific examples provided to
determine if it is more than minor. If a match is not found, an answer
of "yes" to any of the following questions determines that the finding
is more than minor.

> \(1\) Does the finding represent an improper or uncontrolled work
> practice that can impact quality or safety, involving safety-related
> SSCs?
>
> \(2\) Does the finding represent non-compliance with the requirements
> of a design or fabrication code required by 10 CFR 50.55a?
>
> \(3\) Does the finding represent an inadequate process, procedure, or
> quality oversight function, that if left uncorrected, could adversely
> affect the quality of the fabrication, construction, testing,
> analysis, or records of a safety-related SSC?
>
> \(4\) Does the finding represent a deviation, that if left
> uncorrected, could adversely affect the environmental or seismic
> qualification of an SSC?

The following examples apply the above guidance and demonstrate a
thought process that can be used in making the determination of whether
a violation is minor. Examples of different categories of findings and
violations that may be considered minor include, but are not limited to:

Record Keeping Issues would be minor if they do not preclude the
applicant from being able to take appropriate action on
safety-significant matters, or the NRC from objectively or properly
assessing, auditing, or otherwise evaluating significant activities.

a\. Magnetic particle examination personnel failed to record the
inspection results which revealed the existence of a partial penetration
weld where a full penetration was designated on the design drawing for
the sacrificial shield wall.

> The violation: Failure to follow procedure requirements for recording
> of indications.
>
> Minor because: There were no weld process related flaws identified in
> the weld or surrounding base material, and if the existing partial
> penetration weld could be accepted for service with a drawing change
> and an engineering evaluation.
>
> Not minor if: Partial penetration welds were unacceptable for this
> service and were required to be removed and replaced with full
> penetration welds.

b\. The Welding Engineering Unit (the organization responsible for
generation and issuing of weld maps and weld map change requests) were
not controlling the weld maps and weld map change requests through the
normal Document Control and Records Management system.

> The violation: Failure to follow applicant procedure for the control
> of documents and records.
>
> Minor because: The control system used by the Welding Engineering was
> similar to the control system used in the normal Document Control and
> Records Management system, and personnel using weld maps and weld map
> change requests were familiar with the system.
>
> Not minor if: Weld map change requests were being processed against
> superceded weld maps, or superceded weld maps were being used in the
> field for inspection and documentation of quality-related welding
> activities.

c\. An NRC inspector noted that "purge check" and "fitup" inspection
hold points had not been signed off for a weld that was partially
completed.

> The violation: Failure to follow procedure requirements concerning
> documentation of hold and witness points during welding activities.
>
> Minor because: The issue concerning the failure to document the
> completion of the hold points was documented in the applicant's
> corrective action program and re-inspection of the partial weld showed
> no evidence of problems associated with improper purge or
> out-of-tolerance fitup. The applicant's corrective action document
> will remain open pending completion of radiographic examination of the
> completed weld.
>
> Not minor if: Inspection of the partial or final weld showed
> unacceptable oxidation of the inside weld surface due to lack of
> proper purge during root pass welding, and/or showed unacceptable weld
> configuration indicative of improper fitup.

d\. The records for the installation of some large, high-strength,
bolted, Seismic Class I structural steel connections contained the
serial number for the torque wrench used, but did not contain the serial
number for the torque multiplier required to be attached to the torque
wrench for this type of connection.

> The violation: Failure to follow procedure for the documentation of
> Seismic Class I construction activities.
>
> Minor because: Tool issue records showed that a calibrated torque
> multiplier had been checked out by the same person, and at the same
> time, as the documented torque wrench.
>
> Not minor if: Tool issue records did not support the contention that
> the proper torque-multiplier was used for the job, or a post-use
> calibration check of the torque-multiplier found problems.

Nonsignificant Dimensional, Time, Calculation, or Drawing Discrepancies
would be minor if they are characterized by minor discrepant values
referred to in either the applicant\'s Final Safety Analysis Report
(FSAR) or design documents.

a\. Contractor quality control inspectors did not have appropriate
inspection instructions for evaluation of welds of pipe support strut
end brackets to piping curved surfaces. Such a weld was designated as a
flare-bevel weld with 5/16-inch reinforcement. The bracket actually
used, and not prohibited, did not have a flare configuration; nor was
the pipe curvature sufficient to result in a flare bevel configuration.
The weld was accepted by a quality control inspector. However, the weld
throat was less than specified by design, to the extent that the piping
curvature resulted in weld root gap of greater than 1/8-inch.

> The violation: Failure to follow applicant procedure for inspection of
> weld between pipe support strut end bracket and the piping curved
> surface.
>
> Minor because: While the bracket used did not provide for a flare
> bevel configuration, the use of that bracket was not prohibited. The
> weld should be inspected to the requirements of the existing
> configuration and the designation of the weld corrected.
>
> Not minor if: The weld and/or the bracket had to be repaired, or
> removed and re-welded, because it did not meet any acceptable weld
> configuration requirements.

b\. The applicant failed to conduct a Quality Assurance Program required
annual audit of Training.

> The violation: Failure to conduct periodic audits in accordance with
> the applicant's accepted Quality Assurance Program which endorses
> Regulatory Guide 1.144 regulatory position requiring annual audits.
>
> Minor because: Neither the NRC nor the applicant had identified any
> construction program changes which would have required additional
> training, and neither NRC nor the applicant had identified problems
> which could have been attributed to a lack of training and the time
> between applicant audits did not exceed twice the time period required
> for audits.
>
> Not minor if: Significant changes had been made in one or more
> construction programs and/or problems had been identified in the area
> of Training, or which could be attributed to improper, or lack of
> training, which would have been identified by an audit, or the time
> between audits exceeded twice the time period required for audits.

c\. The installation plans for a 240-volt, electrical circuit connecting
a non-Class 1E circuit with a Class 1E circuit called for the use of
10-gauge wire. The inspector noted that the installation had been done
using 8-gauge wire.

> The violation: Failure to follow procedures, plans, and/or drawings
> for installation of a Class 1E electrical circuit
>
> Minor because: The use of 8-gauge wire does not degrade the circuit,
> and can be accepted as-is.
>
> Not minor if: The applicant's program for connections to Class 1E
> electrical circuits does not allow any deviations from plans and/or
> drawings, or the lowered resistance provided by the 8-gauge wire would
> cause problems with balancing or control of the circuit and must be
> re-worked..

d\. A Seismic Class I support in the turbine building was fabricated
using 4-inch tube steel. The inspector noted that the plan required the
use of 3-inch tube steel for this particular support.

> The violation: Failure to follow procedure for installation of Seismic
> Class I supports.
>
> Minor because: The support design is such that the use of the larger
> structural shape does not degrade the final support, or affect the
> seismic qualification, (e.g., the support is a tripod or box design
> with all the weight of the support directly transferred to the
> foundation,) and the use of over-size material is documented in the
> corrective action program.
>
> Not minor if: The support design is such that the additional weight
> from the over-size material causes increased stress on the attached
> structure and a negative affect on seismic calculations (e.g.,
> cantilever structure attached to a building support,).

Procedural Errors would be minor if they are procedural errors or
inadequate procedures that have no impact on safety-related equipment or
personnel safety.

a\. Five applicant procedures had undergone major revision and each
still contained references to other site procedures which had been
cancelled prior to the date of the revision.

> The violation: Failure to follow applicant procedure for review of
> procedure revisions.
>
> Minor because: Referenced procedures were not required to provide
> information necessary for complete actions required by the revised
> procedure(s)
>
> Not minor if: At least one of the newly revised procedures was written
> in a way that it relied on one of the cancelled procedures to provide
> information, (e.g., acceptance criteria for an inspection,) vital to
> the completion of a procedure action.

b\. A construction contractor's procedure for assembly of safety-related
steel structures referenced a superceded edition of the applicant's
administrative procedure for control of audits and responses to audits.

> The violation: Failure to follow applicant and contractor procedures
> for updating of procedure references.
>
> Minor because: Referenced procedure was not required for
> safety-related construction activities.
>
> Not minor if: Use of superceded procedure had resulted in an audit
> finding not being recorded in the appropriate corrective action
> program.

c\. A contractor crew was found to be using a fabrication drawing which
did not have a recently issued change notice attached.

> The violation: Failure to follow procedure for control of procedures,
> drawings, and plans.
>
> Minor because: The recently issued change notice did not have any
> impact on the section of the drawing in use by the contractor crew,
> and the incident was noted in the applicant's corrective action
> program.
>
> Not minor if: The change notice contained information that had an
> affect on the work activities in progress, or the acceptance criteria
> for the finished product.

d\. During an inspection of construction activities involving
installation of safety-related SSCs, an inspector found a superceded
copy of the installation work procedure beside some tools staged at the
job site.

> The violation: Failure to control out-dated work procedures
>
> Minor because: Work activities were not being conducted in accordance
> with the outdated procedure, the procedure was immediately removed
> from the work area, and the incident was documented in the applicant's
> corrective action program
>
> Not minor if: The outdated procedure was discovered because workers
> were referring to it for direction rather than using the procedure
> provided in the work package.

Work in Progress Findings would be minor if they are identified in the
course of performing work, prior to the applicant having the opportunity
to perform quality control acceptance inspections, checks, or reviews,
which would reasonably be expected to identify and correct them.

a\. During conduct of an ASME Code required liquid penetrant
examination, excess penetrant material was not properly removed prior to
applying the developer during a pre-service inspection (PSI) of five
welds resulting in a surface too pink for proper evaluation of the weld.

> The violation: Failure to follow applicant PSI nondestructive
> examination procedure.
>
> Minor because: This was work in progress. The error was identified
> prior to the documentation and acceptance by the Level II examiner of
> the inspection results, and immediate retest did not reveal any
> unacceptable indications.
>
> Not minor if: Retest of one of the welds revealed an unacceptable
> indication requiring analysis or repair of the weld.

b\. Bends in stainless steel piping were made using an unapproved and
unqualified pipe bender in accordance with an unapproved and unqualified
pipe bending procedure.

> The violation: Failure to follow ASME requirements for qualification
> of pipe bending equipment.
>
> Minor because: Qualification status of the pipe bender and the
> approval and qualification of the pipe bending procedure were
> discovered prior to the pipe bends being welded into the system.
>
> Not minor if: Pipe bends were welded into the system and subsequent
> inspection found that an area of the wall thickness on one or more of
> the pipe bends were found to be below minimum wall thickness
> requirements.

c\. Discovery of the failure to install lock nuts on three anchor bolts
of a safety-related vertical steel structure. Installation of the lock
nuts was specified by the applicable construction drawing. The
installation of the columns had been considered to be complete by the
project contractor installing the column and its bolting.

> The violation: 10 CFR 50, App B, Criterion V, Failure to follow
> requirements of drawing for a safety-related structure.
>
> Minor because: Structure had not yet received required quality control
> review or been accepted by the applicant, and the lock nuts were to
> provide protection against loosening of anchor bolts due to service
> induced vibration.
>
> Not minor if: Quality control review failed to identify missing lock
> nuts, or structure accepted by the applicant, or if acceptance by
> project installation contractor constituted final acceptance for the
> project.

d\. Procedure requirement that piping material be subjected to liquid
penetrant examination after the removal of arc strikes was apparently
not followed,

> The violation: Failure to follow applicant Quality Assurance procedure
> for examination and evaluation of arc strikes.
>
> Minor because: Subsequent evaluation of the arc strike removal sites
> did not reveal any recordable or rejectable indications
>
> Not minor if: One or more arc strike removal sites were found to have
> unacceptable liquid penetrant indications during subsequent
> inspection(s).

e\. Inspector found that a pipe support detail drawing had been
downgraded from Quality Class I to Quality Class II as a result of an
engineering change. (The design change was signed by a "Discipline
Engineer", a "Resident Group Supervisor", and a "Resident Project
Engineer.")

> The "Discipline Engineer" responsible for the engineering change was
> not aware that the FSAR, and the piping isometric drawing, both
> identified the piping system involved as Quality Class I piping. He
> was aware of the general policy that quality classification of a
> support will generally be the same as the classification of the piping
> which it supports.
>
> Subsequently, the responsible design organization issued another
> engineering change which reclassified the identified supports as
> Quality Class I.
>
> The violation: Failure to follow proper procedure for downgrading of
> design requirements.
>
> Minor because: Error discovered prior to fabrication and installation
> of supports, and another engineering change issued to reclassify
> supports as Quality Class 1.
>
> Not minor if: Error not discovered until after installation and
> acceptance of pipe supports, and re-classification to Quality Class 1
> required rework to qualify the supports.

f\. During an inspection of safety-related welding activities, an
inspector discovered that the welding torch cover-gas hook-up for the
welding machine to be used was attached to an Argon gas cylinder instead
of the cylinder for the Helium-Argon mix gas required by the welding
procedure.

> The violation: Failure to follow procedure for the control of special
> processes.
>
> Minor because: The error was discovered and corrected prior to the
> start of welding.
>
> Not minor if: Subsequent inspection disclosed that previous welding
> had been accomplished using the improper cover gas.

g\. During inspection of a piping weld fit-up, an inspector noticed a
"come-along" attached to the run of the piping providing a horizontal
force. When the "come-along" was removed, the piping moved horizontally
and the required weld joint fit-up could not be achieved.

> The violation: Failure to follow procedures for control of
> "cold-spring" in piping systems.
>
> Minor because: The error was discovered prior to the weld fit-up being
> approved and signed off by Quality Assurance, and the problem was
> identified in the corrective action program
>
> Not minor if: The weld fit-up had been approved by Quality Assurance
> and the welder was preparing to tack weld.

h\. During observation of the installation of safety-related
instrumentation and control components, the inspector noted that the
craftsman was preparing to install lugs on the wiring using the wrong
size crimping tool. The resulting installation would have resulted in
connections which could come loose during operation of the equipment.

> The violation: Failure to follow procedure for special processes
> during the installation of safety-related equipment.
>
> Minor because: The error was discovered prior to the use of the
> incorrect tool and the problem was subsequently identified in the
> corrective action program.
>
> Not minor if: The craftsman had already completed previous
> installations using the incorrect tool and those connections had been
> accepted by Quality Assurance.

**Appendix D**

WBN Unit 2 Construction Inspector

Qualification Requirements

1\. PURPOSE

To provide guidance for qualifying inspectors to perform construction
inspections at WBN Unit 2.

2\. BACKGROUND

Construction inspections using IMC 2512, IMC 2513, and IMC 2514 were
last performed in the early 1990's. Since then inspectors have been
qualified using IMC 1245 to conduct inspections at operating plants. No
inspectors have been trained and qualified to conduct construction
inspections for a 10 CFR Part 50 applicants since the early 1990's. An
updated construction inspector qualification has been developed but it
is designed for inspectors performing construction inspections for 10
CFR Part 52 applicants. This appendix provides the qualification
requirements for an IMC 1245 or IMC 1252 qualified inspector to conduct
inspections at WBN Unit 2.

3\. DISCUSSION

a\. [Construction Phase]{.underline}.

Inspectors previously qualified to IMC 1245 and 1252 need to complete
the additional activities listed in Table 1, as applicable, to be fully
qualified for the Construction Phase of WBN Unit 2. Form 1 is used to
document the justification for using equivalent training or experience
in place of a qualification requirement. When completed, a construction
phase inspector certification is issued.

b\. [Post Construction Phase]{.underline}.

> Inspectors previously qualified to IMC 1245 and 1252 need to complete
> the additional activities listed in Table 2, as applicable, to be
> fully qualified for the Post-Construction Phase of WBN Unit 2. Form 2
> is used to document the justification for using equivalent training or
> experience in place of a qualification requirement. When completed, a
> construction phase inspector certification is issued.
>
> c\. [Refresher and Continuing Training]{.underline}
>
> There are no requirements for continuing or refresher training. At
> management's discretion, refresher and continuing training may be
> required as a means for updating and maintaining qualification for
> either individual inspectors or the entire population of WBN Unit 2
> inspectors. The following are some situations that could necessitate
> the need for refresher and continuing training.

1.  Just before a critical and/or complex activity takes place, i.e.,
    just-in-time.

2.  Evidence of declining performance

3.  At the request of inspectors.

4.  As a result of lessons learned from industry events and/or ongoing
    inspection activities.

5.  An inspection area that requires specialized training.

6.  Continuing industrial Safety training caused by changing conditions.

> d\. [Monitoring Program Effectiveness]{.underline}
>
> The implementation of the WBN Unit 2 inspection training and
> qualification program will be monitored by Region II to identify any
> areas where performance may be declining. Staff may use the Feedback
> Process to provide comments and recommendations on the content and
> effectiveness of the inspector qualification program outlined in this
> section. Lessons learned, feedback forms, and changes to the current
> inspection policy and procedures will be reviewed by management for
> possible impacts to the inspector training and qualification program
> outlined in this section.

**Table 1: Construction Phase Inspector Qualification Requirements (for
Inspectors Previously Qualified Under IMC 1245 and/or IMC 1252).**

**Signature Card and Division Director Certification**

  --------------------------------------------------------------------- ------- ------- ----------- -----------------
  *Inspector Name:                                                      *IMC    *IMC    *Employee   *Branch Chief's
  \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_*   1245*   1252*   Initials/   Signature/Date*
                                                                                        Date*       

  **A. Training Courses**                                                                           

  Construction Quality Assurance                                                N/R                 

  Personal Safety at Construction sites                                                             

  **B. Individual Study Activity**                                                                  

  (ISA-WB2-1) IMC 2517, Watts Bar Unit 2 Construction Inspection                                    
  Program                                                                                           

  (ISA-WB2-2) IMC 2512, Light Water Reactor Inspection Program --                                   
  Construction Phase                                                                                
  --------------------------------------------------------------------- ------- ------- ----------- -----------------

N/R: Not Required

**Watts Bar 2 Construction Phase Inspector Qualification**

**Certification**

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

(Name)

Has successfully completed all of the additional training requirements
to be a

**WBN Unit 2 CONSTRUCTION PHASE INSPECTOR**

Branch Chief Signature:
[\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_]{.underline}

Division Director Signature:
[\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_]{.underline}

Date:
[\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_]{.underline}

This signature card and certification must be accompanied by the
appropriate Form 1, Basic Level Equivalency Justification, if
applicable.

  ------------------------------------------------------------------------------------------------
  *Form 1: Construction Phase Equivalency Justification*              
  ------------------------------------------------------------------- ----------------------------
  *Inspector Name:                                                    ***Identify equivalent
  \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_*   training and experience for
                                                                      which the inspector is to be
                                                                      given credit***

  ***A. Training Courses***                                           

  Construction Quality Assurance                                      

  Personal Safety at Construction sites                               

  ***B. Individual Study Activities***                                

  (ISA-WB2-1) IMC 2517, Watts Bar Unit 2 Construction Inspection      
  Program                                                             

  (ISA-WB2-2) IMC 2512, Light Water Reactor Inspection Program --     
  Construction Phase                                                  
  ------------------------------------------------------------------------------------------------

Branch Chief's Recommendation Signature /
Date\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Division Director's Approval Signature /
Date\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Copies to:

Inspector

HR Office

Branch Chief

This form must accompany the Signature Card and Certification, if
applicable.

**Table 2: Post-Construction Phase Inspector Qualification
Requirements**

**Signature Card and Division Director Certification**

  ------------------------------------------------------------------------- ------- ------- ----------- -----------------
  *Inspector Name:                                                          *IMC    *IMC    *Employee   *Branch Chief's
  \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_*   1245*   1252*   Initials/   Signature/Date*
                                                                                            Date*       

  **A. Training Courses**                                                                               

  Westinghouse full series                                                                              

  **B. Individual Study Activity**                                                                      

  (ISA-WB2-1) IMC 2517, Watts Bar Unit 2 Construction Inspection Program                                

  (ISA-WB2-3) IMC 2513, Number range CHAPTERLight Water Reactor Inspection                              
  Program - Preoperational Testing And Operational Preparedness Phase                                   

  (ISA-WB2-4) IMC 2514, Light Water Reactor Inspection Program -- Startup                               
  Testing Phase                                                                                         
  ------------------------------------------------------------------------- ------- ------- ----------- -----------------

**Watts Bar 2 Post-Construction Inspector Qualification**

**Certification**

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

(Name)

Has previously qualified as an inspector under IMC 1245 or IMC 1252

and has successfully completed all of the additional training
requirements to be a

**WBN Unit 2 POST-CONSTRUCTION PHASE INSPECTOR**

Branch Chief Signature:
[\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_]{.underline}

Division Director Signature:
[\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_]{.underline}

Date:
[\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_]{.underline}

This signature card and certification must be accompanied by the
appropriate Form 1, Basic Level Equivalency Justification, if
applicable.

  ------------------------------------------------------------------------------------------------
  *Form 2: Post-Construction Phase Equivalency Justification*         
  ------------------------------------------------------------------- ----------------------------
  *Inspector Name:                                                    ***Identify equivalent
  \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_*   training and experience for
                                                                      which the inspector is to be
                                                                      given credit***

  ***A. Training Courses***                                           

  Westinghouse full series                                            

  ***B. Individual Study Activities***                                

  (ISA-WB2-1) IMC 2517, Watts Bar Unit 2 Construction Inspection      
  Program                                                             

  (ISA-WB2-3) IMC 2513, Number range CHAPTERLight Water Reactor       
  Inspection Program - Preoperational Testing And Operational         
  Preparedness Phase                                                  

  (ISA-WB2-4) IMC 2514, Light Water Reactor Inspection Program --     
  Startup Testing Phase                                               
  ------------------------------------------------------------------------------------------------

Branch Chief's Recommendation Signature /
Date\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Division Director's Approval Signature /
Date\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Copies to:

Inspector

HR Office

Branch Chief

This form must accompany the Signature Card and Certification, if
applicable.

**Basic-level Individual Study Activity**

**TOPIC:** (ISA-WB2-1) IMC 2517, Watts Bar Unit 2 Construction
Inspection Program

**PURPOSE:** The purpose of this activity is to familiarize you with IMC
2517 used to perform construction and post construction inspection
activities at the Watts Bar Unit 2 nuclear power plant up until the time
the plant transitions into the ROP inspection program. During this
activity you will perform the tasks identified below to acquire a
working knowledge of the requirements delineated in IMC 2517.

**COMPETENCY**

**AREAS:** INSPECTION

COMMUNICATION

REGULATORY FRAMEWORK

**LEVEL OF**

**EFFORT:** 8 hours

**REFERENCES:** IMC 2517, Watts Bar Unit 2 Construction Inspection
Program

**EVALUATION**

**CRITERIA:** Upon completion of this activity, you will be asked to
demonstrate your understanding of the requirements delineated in IMC
2517 by successfully addressing the following criteria:

1.  Discuss the purpose of IMC 2517.

2.  Describe the impacts of the long delay in restarting the
    construction of WBN Unit 2.

3.  Describe the general inspection policy of WBN Unit 2.

4.  Discuss how you would use the results of the reconstitution effort
    to plan WBN Unit 2 inspections.

5.  Discuss the purpose and contents of the Inspection Plan and Schedule
    (IP&S) and its relationship to the applicant schedule.

6.  Discuss how Temporary Inspections (TIs) will be addressed at WBN
    Unit 2.

7.  Discuss how plant modifications will be inspected.

8.  Discuss the transition to the ROP.

9.  Discuss the enforcement approach for WBN Unit 2.

> 10\. Discuss the assessment approach for WBN Unit 2.
>
> 11\. Discuss how to process and document inspection findings for WBN
> Unit 2.

**TASKS:** 1. Obtain a paper copy, or locate and bookmark the electronic
location of, IMC 2517 for personal use and future reference.

2\. Review IMC 2517 to gain an understanding of the principles discussed
in the evaluation criteria.

3\. Review and discuss the evaluation criteria with your supervisor.

**DOCUMENTATION:** Construction Inspector Certification Signature Card
Item ISA-WB2-1

**Basic-level Individual Study Activity**

**TOPIC:** (ISA-WB2-2), IMC 2512, Light Water Reactor Inspection Program
-- Construction Phase.

**PURPOSE:** The purpose of this activity is to familiarize you with IMC
2512 which provides inspection requirements and policy for
implementation of the inspection program during construction and major
plant modifications.

**COMPETENCY**

**AREAS:** INSPECTION

COMMUNICATION

REGULATORY FRAMEWORK

**LEVEL OF**

**EFFORT:** 16 hours

**REFERENCES:** IMC 2512, Number range CHAPTERLight Water Reactor
Inspection Program -- Construction Phase

**EVALUATION** Upon completion of this activity, you will be asked to
demonstrate

**CRITERIA:** your understanding of the requirements delineated in IMC
2512 by successfully addressing the following criteria:

1.  State the purpose of IMC 2512.

2.  Describe the relationship between IMC 2512 and IMC 2517.

3.  State the purpose of Construction Milestones.

4.  Describe how the NRC will monitor the WBN Unit 2 project performance
    since SALP is no longer in use?

    **TASKS:** 1. Obtain a paper copy, or locate and bookmark the
    electronic location of, IMC 2512 for personal use and future
    reference.

2\. Review IMC 2512 to gain an understanding of the principles discussed
in the evaluation criteria.

3\. Familiarize yourself with the contents of the Inspection Procedures
(IPs) listed in Appendix I of IMC 2512.

4\. Review and discuss the evaluation criteria with your supervisor.

**DOCUMENTATION:** Construction Inspector Certification Signature Card
Item

ISA-WB2-2

**Basic-level Individual Study Activity**

**TOPIC:** (ISA-WB2-3), IMC 2513, Light Water Reactor Inspection Program
--Preoperational Testing and Operational Preparedness Phase.

**PURPOSE:** The purpose of this activity is to familiarize you with IMC
2513 which provides inspection requirements and policy for
implementation of the inspection program during the Preoperational
Testing and Operational Preparedness Phase of a nuclear power plant.

**COMPETENCY**

**AREAS:** INSPECTION

> COMMUNICATION
>
> REGULATORY FRAMEWORK

**LEVEL OF**

**EFFORT:** 16 hours

**REFERENCES:** IMC 2513, Light Water Reactor Inspection Program
--Preoperational Testing and Operational Preparedness Phase.

**EVALUATION** Upon completion of this activity, you will be asked to
demonstrate

**CRITERIA:** your understanding of the requirements delineated in IMC
2513 by successfully addressing the following criteria:

1.  State the purpose of IMC 2513.

2.  Describe the Categories of the Pre-operational Test Program. Who
    directs them? What do they entail? Why are they done?

3.  Discuss the General Guidance of IMC 2513.

    **TASKS:** 1. Obtain a paper copy, or locate and bookmark the
    electronic location of, IMC 2513 for personal use and future
    reference.

2\. Review IMC 2513 to gain an understanding of the principles discussed
in the evaluation criteria.

3\. Familiarize yourself with the contents of the Inspection Procedures
(IPs) listed in Appendix A of IMC 2513.

4\. Review and discuss the evaluation criteria with your supervisor.

**DOCUMENTATION:** Construction Inspector Certification Signature Card
Item

ISA- WB2-3

**Basic-level Individual Study Activity**

**TOPIC:** (ISA-WB2-4) IMC 2514, Light Water Reactor Inspection Program
-- Startup Testing Phase.

**PURPOSE:** The purpose of this activity is to familiarize you with IMC
2514 which provides inspection requirements and policy for
implementation of the inspection program during the Startup Testing
Phase of a nuclear power plant.

**COMPETENCY**

**AREAS:** INSPECTION

> COMMUNICATION
>
> REGULATORY FRAMEWORK

**LEVEL OF**

**EFFORT:** 16 hours

**REFERENCES:** 1. IMC 2514, Light Water Reactor Inspection Program --
Startup Testing Phase.

2\. Regulatory Guide (RG) 1.68, Initial Test Programs for Water-Cooled
Nuclear Power Plants.

**EVALUATION** Upon completion of this activity, you will be asked to
demonstrate

**CRITERIA:** your understanding of the requirements delineated in IMC
2514 and RG 1.68 by successfully addressing the following criteria:

> 1\. State the purpose of IMC 2514.
>
> 2\. Discuss the General Guidance in IMC 2514 and RG 1.68.
>
> 3\. Describe the three types of the startup testing inspection program
> and associated categories. Discuss the degree of inspection coverage
> for each type.

**TASKS:** 1. Obtain paper copies, or locate and bookmark the electronic
locations of IMC 2514 and RG 1.68 for personal use and future reference.

2\. Review IMC 2514 and RG 1.68 to gain an understanding of the
principles discussed in the evaluation criteria.

3\. Familiarize yourself with the contents of the Inspection Procedures
(IPs) listed in Appendix A of IMC 2514.

4\. Review and discuss the evaluation criteria with your supervisor.

**DOCUMENTATION:** Construction Inspector Certification Signature Card
Item

ISA-WB2-4

##  {#section .unnumbered}

END

Number range CHAPTER Revision History - IMC 2517

+--------+-------+------------------------+-----+-------+-------------+
| Comm   | Issue | Description of Change  | Tr  | Tra   | Comment     |
| itment | Date  |                        | ain | ining | Resolution  |
| Tr     |       |                        | ing | Compl | Accession   |
| acking |       |                        | Nee | etion | Number      |
| Number |       |                        | ded | Date  |             |
+========+=======+========================+=====+=======+=============+
| N/A    | 02/   | Revision history       | NO  | N/A   | ML073330142 |
|        | 15/08 | reviewed for the last  |     |       |             |
|        |       | four years. MC 2517 is |     |       |             |
|        | CN    | being issued to        |     |       |             |
|        | 0     | provide the policies   |     |       |             |
|        | 8-008 | and requirements for   |     |       |             |
|        |       | the Watts Bar Unit 2   |     |       |             |
|        |       | (WBN Unit 2)           |     |       |             |
|        |       | construction           |     |       |             |
|        |       | inspection program     |     |       |             |
|        |       | during that unit\'s    |     |       |             |
|        |       | resumption of          |     |       |             |
|        |       | construction after an  |     |       |             |
|        |       | approximately 20 year  |     |       |             |
|        |       | suspension of          |     |       |             |
|        |       | construction           |     |       |             |
|        |       | activities.            |     |       |             |
+--------+-------+------------------------+-----+-------+-------------+
|        |       |                        |     |       |             |
+--------+-------+------------------------+-----+-------+-------------+
|        |       |                        |     |       |             |
+--------+-------+------------------------+-----+-------+-------------+
|        |       |                        |     |       |             |
+--------+-------+------------------------+-----+-------+-------------+