UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20555-0001

OFFICE OF THE

INSPECTOR GENERAL

December 1, 2016

MEMORANDUM TO: Victor M. McCree

Executive Director for Operations

FROM: Dr. Brett M. Baker /RA/

Assistant Inspector General for Audits

SUBJECT: STATUS OF RECOMMENDATIONS: AUDIT OF NRC’S 

SIGNIFICANCE DETERMINATION PROCESS FOR

REACTOR SAFETY (OIG-16-A-21)

REFERENCE: DEPUTY EXECUTIVE DIRECTOR FOR REACTOR AND 

PREPAREDNESS PROGRAMS MEMORANDUM DATED 

OCTOBER 26, 2016

Attached is the Office of the Inspector General’s analysis and status of 

recommendations as discussed in the agency’s response dated October 26, 2016. 

Based on this response, recommendations 1, 2, 3 and 4 are resolved. Please provide 

a status update on these recommendations by July 28, 2017. 

If you have questions or concerns, please call me at (301) 415-5915 or Paul Rades, 

Team Leader, at (301) 415-6228.

Attachment: As stated

cc: R. Lewis, OEDO

H. Rasouli, OEDO

J. Jolicouer, OEDO

J. Bowen, OEDO

EDO_ACS Distribution Resource
Audit Report

AUDIT OF NRC’S Significance Determination Process for Reactor Safety 

OIG-16-A-21

Status of Recommendations

Recommendation 1: Assess SDP workflow, and establish, communicate, and 

document clear and consistent expectations for staff and 

managers to complete their roles in the SDP.

Agency Response Dated

October 26, 2016: Response

The staff agrees with the recommendation.

Over the past 2 years, the staff has undertaken an 

extensive effort to improve the efficiency and

effectiveness of the SDP based on internal assessment 

activities and as directed by the Commission. As a result, 

the staff has developed proposed changes to the SDP to 

improve management oversight and project planning of 

inspection findings preliminarily determined to be of greater 

than very low safety significance (i.e., greater than Green). 

These proposed changes are part of an initiative known as 

Inspection Finding Resolution Management (IFRM). The 

staff believes that the actions dictated by the IFRM initiative 

meet the intent of the recommendation. Moreover, due to 

the oftentimes complex and variable nature of greater than 

Green inspection findings the staff believes that flexibility is 

needed in setting clear and consistent expectations for staff 

and managers as they complete their roles in the SDP.

Planned actions

The staff will issue inspection oversight program documents 

for trial use that are geared to improve the discipline and 

accountability of deciding on the time and resources used to 

assess inspection findings and their safety significance. 

These documents, with an emphasis on the Inspection 

Finding Review Board (IFRB), will be used to establish, 

communicate, and document clear and consistent 

expectations for all staff and managers involved with 

resolving potentially greater than Green inspection findings. 

More specifically, the IFRB is a regional activity
Audit Report

AUDIT OF NRC’S Significance Determination Process for Reactor Safety 

OIG-16-A-21

Status of Recommendations

Recommendation 1 (cont.): 

comprising all relevant staff and led by a director-level 

Chairman. Assembling the IFRB is done early in the 

process to ensure managers and staff have a common 

understanding of the scope, schedule, and resources 

needed to prepare for the Significance and Enforcement 

Review Panel (SERP). The SERP is responsible for both 

the preliminary and final decisions regarding significance 

determinations of greater than Green findings and 

enforcement issues.

The trial period for IFRM will begin in the autumn of 2016 

and will involve greater than Green inspection findings 

identified across all regions for the initiating events, 

mitigating systems, and barrier integrity cornerstones. After 

the trial period ends, the staff will evaluate the effectiveness

of the procedures to identify any needed changes based on 

lessons learned. The trial period will end no later than 

December 2017, followed by an assessment period to 

address the lessons learned. The staff will document the 

results of the trial period and make the necessary program

changes.

Target date for completion: August 2018

Contact: Nathan T. Sanfilippo, Branch Chief, NRR/DIRS

301-415-8744

OIG Analysis: The proposed actions meet the intent of this 

recommendation. OIG will close this recommendation after 

reviewing appropriate documentation, and other information 

as needed, to verify that staff have undertaken these 

actions as described. 

Status: Resolved.
Audit Report

AUDIT OF NRC’S Significance Determination Process for Reactor Safety 

OIG-16-A-21

Status of Recommendations

Recommendation 2: Clarify IMC 0612 Appendix B issue screening questions, so 

that they are readily understood and easily applied.

Agency Response Dated

October 26, 2016: Response/Planned Actions

The staff agrees with the recommendation.

The staff is evaluating revision to IMC 0612 Appendix E, 

“More than Minor Screening Examples,” in the short term, to 

add an example to illustrate how to apply the more than 

minor screening. The staff is considering accompanying the 

example with added clarification to the terms used in the 

more than minor questions to promote predictability, staff 

understanding, and ease of application. The staff plans to 

complete this evaluation by July 2017 and will make

necessary changes.

Contact: Christopher M. Regan, Branch Chief, NRR/DIRS

301-415-2768

OIG Analysis: The proposed actions meet the intent of this 

recommendation, insofar as guidance for better 

understanding and applying IMC 0612 Appendix B issue 

screening questions can be incorporated into the revision of 

IMC 0612 Appendix E. OIG will close this recommendation 

after reviewing the staff evaluation discussed above, and 

validating the evaluation’s results and application to 

forthcoming guidance.

Status: Resolved.
Audit Report

AUDIT OF NRC’S Significance Determination Process for Reactor Safety 

OIG-16-A-21

Status of Recommendations

Recommendation 3: Implement controls to ensure independent audits of greater 

than Green inspection findings are performed.

Agency response dated

October 26, 2016: Response

The staff agrees with the recommendation.

Inspection Manual Chapter 0307 Appendix A, “Reactor 

Oversight Process Self-Assessment Metrics,” requires 

independent audits of greater than Green inspection 

findings to be performed to ensure significance 

determination results are predictable and repeatable. 

Specifically, Metric R-2, “Predictability and Repeatability of 

Significance Determination Results,” states that greater

than Green inspection findings and the associated 

degraded conditions contain adequate detail to enable an 

independent auditor to trace through the available 

documentation and conclude that the significance 

characterization is reasonably justifiable from both 

programmatic and technical positions. Although this audit 

has been performed in accordance with this metric, and

the metric has been met for many years, the staff has not 

implemented formal controls to ensure that the audit is 

properly documented with supporting information to justify 

the staff’s conclusion that the metric was met.

Planned actions

To ensure consistent, repeatable, and dependable audit 

results going forward, the staff plans to enhance IMC 0307 

Appendix A and/or IMC 0307, “Reactor Oversight Process 

Self-Assessment Program,” to specify the requirement to 

perform and document the evaluation for this and other

metrics. For the calendar year (CY) 2016 evaluation of the 

R-2 metric, the staff will develop instructions to ensure that 

the independent auditor performs and documents the audit 

of greater than Green inspection findings. In addition, the 

staff plans to develop a detailed job guide that includes
Audit Report

AUDIT OF NRC’S Significance Determination Process for Reactor Safety 

OIG-16-A-21

Status of Recommendations

Recommendation 3 (cont.):

instruction for how to perform and document the evaluation 

for all of the metrics. The revision to IMC 0307, Appendix 

A, and the job guide will be developed as the staff performs 

its CY 2016 ROP self-assessment in early 2017 and will be 

implemented when the staff performs its CY 2017 ROP selfassessment.

Target date for completion: June 30, 2017

Contact: Nathan T. Sanfilippo, Branch Chief, NRR/DIRS

301-415-8744

OIG Analysis: The proposed actions meet the intent of this 

recommendation. OIG will close this recommendation after 

reviewing appropriate documentation, and other information 

as needed, to verify that staff have undertaken these 

actions as described. 

Status: Resolved.
Audit Report

AUDIT OF NRC’S Significance Determination Process for Reactor Safety 

OIG-16-A-21

Status of Recommendations

Recommendation 4: Document independent audits of greater than Green 

inspection findings.

Response/Planned actions

The staff agrees with the recommendation.

Although the metric evaluations have been performed and 

documented annually, adequate supporting documentation 

has not been maintained. As noted above, the staff plans 

to enhance IMC 0307 to specify the requirement to perform 

and document the evaluation for this and other metrics.

Target date for completion: June 30, 2017

Contact: Nathan T. Sanfilippo, Branch Chief, NRR/DIRS

301-415-8744

OIG Analysis: The proposed actions meet the intent of this 

recommendation. OIG will close this recommendation after 

reviewing appropriate documentation, and other information 

as needed, to verify that staff have undertaken these 

actions as described. 

Status: Resolved.