**NRC INSPECTION MANUAL**	IRIB

INSPECTION MANUAL CHAPTER 0801

# INSPECTION PROGRAM FEEDBACK PROCESS

Effective Date: 03/29/2023

Table of Contents0801-01	PURPOSE	10801-02	OBJECTIVES	10801-03	APPLICABILITY	10801-04	DEFINITIONS	204.01	Feedback Form (FBF)	204.02	Short-Term Feedback	204.03	Long-Term Feedback	20801-05	RESPONSIBILITIES AND AUTHORITIES	205.01	Director, Division of Reactor Oversight, (DRO)	205.02	Division Directors, NMSS, NRR, NSIR, and Regions	205.03	Chiefs, Reactor Assessment/Reactor Inspection Branches (IRAB/IRIB), NRR/DRO	205.04	Chiefs, Inspection Program Branches in NMSS and NSIR	205.05	Feedback Form Review Panel	305.06	Chiefs, Technical Branches, NMSS, NRR, or NSIR	305.07	Originator of Feedback Forms	305.08	TSAB/ IPAT/ TSAT or Branch Chiefs/Team Leads	305.09	NRR Inspection Manual Coordinator.	305.10	Document Lead.	40801-06	INSPECTION PROGRAM FEEDBACK PROCESS TIMELINESS GOALS	40801-07	INSPECTION PROGRAM FEEDBACK PROCESS	507.01	Feedback Form Originator (sections A through D):	507.02	Office Feedback Form Approving Authority (section E):	607.03	NRR Inspection Manual Coordinator (Sections F and G):	607.04	Document Lead (sections F and G):	707.05	Document Lead’s Supervisor (Section G):	807.06	Feedback Form Review Panel:	80801-08	REFERENCES	8Exhibit 1: Inspection Program Feedback Form	Ex1-1Exhibit 2: Example of Document Lead Acceptance Email	Ex2-1Exhibit 3: Inspection Program Feedback Process Flow Chart	Ex3-1Attachment 1: Revision History for IMC 0801	Att1-1

Issue Date: 03/29/23	1	0801

# 0801-01	PURPOSE

This inspection manual chapter (IMC) describes the feedback process used by the Office of Nuclear Materials Safety and Safeguards (NMSS), the Office of Nuclear Reactor Regulation (NRR), and the Office of Nuclear Security and Incident Response (NSIR) to identify and communicate enhancements and resolve problems, concerns, or difficulties encountered in implementing the inspection programs of the Nuclear Regulatory Commission (NRC). The purpose of this feedback process is to improve the effectiveness of agency inspection programs through appropriate feedback elicitation, evaluation, and appropriate program revision.

# 0801-02	OBJECTIVES

The NRC encourages the staff to identify issues that need program-level attention and to suggest changes to improve the effectiveness or implementation of the agency inspection programs. Feedback forms (FBFs) are the vehicle used to suggest such changes. Although feedback is expected to come mostly from staff who implement the agency’s oversight programs, any NRC employee may use the processes described below to make suggestions or recommendations regarding the inspection programs.

02.01	To solicit and document feedback-related inspection program implementation. The NRC encourages the staff to identify and propose changes to improve the effectiveness of agency inspection programs.  Feedback may include, but is not limited to, problems, solutions to problems, or new and innovative ideas to improve program implementation.

02.02	To evaluate and document disposition of received feedback with respect to program changes and provide timely feedback to the submitter.

02.03	To ensure that approved feedback program changes are incorporated into appropriate inspection manual documents and training materials.

# 0801-03	APPLICABILITY

All NRC employees who****have concerns or wish to provide feedback regarding any aspect of inspection or oversight for NMSS, NRR, and NSIR program areas—including interfaces with enforcement or training programs—must follow the procedures outlined in section 0801-07 of this IMC.

The FBF is the formal mechanism for initiating a program-level change to an inspection program document. Revisions to inspection documents should be made using this process, even when changes to inspection documents are the result of a working group, white paper, or industry comments. The process described in this manual chapter is used to collect and manage feedback on all NRC oversight program guidance documents (manual chapters, inspection procedures, temporary instructions, and operator experience smart samples). The process for resolving interpretations of performance indicators is described in IMC 0608, “Performance Indicator Program.” Minor editorial changes are discussed with the document lead but do not require a formal FBF.

# 0801-04	DEFINITIONS

## 04.01	Feedback Form (FBF)

A formal mechanism to provide input, suggestions, or recommendations to document leads regarding inspection program implementation. Feedback forms may be designated as either short-term or long-term based on the complexity of the issue or topic identified.

## 04.02	Short-Term Feedback

An issue identified in a FBF which allows the resolution to be addressed and answered within 6 to 12 months. Editorial comments would fall under the definition of a short-term resolution that can be addressed—the document revised and issued—within 6 months. If multiple inspection program documents are affected by a single, short-term FBF, the goal is to have all affected documents revised within 6 to 12 months.

## 04.03	Long-Term Feedback

An issue identified in a FBF which will require 12 to 24 months or longer to resolve. These types of resolutions will impact other program guidance as well as the inspection framework. Examples of long-term feedback include substantive policyrelated issues that will require coordination with affected stakeholders--such as regional staff and multiple program offices--and may also include senior leadership, Commission-level interaction, or both.

# 0801-05	RESPONSIBILITIES AND AUTHORITIES

## 05.01	Director, Division of Reactor Oversight, (DRO)

Establishes the policy and monitors the timely execution and effectiveness of the inspection program feedback process.

## 05.02	Division Directors, NMSS, NRR, NSIR, and Regions

Support the timely execution and effectiveness of the inspection program feedback process.

## 05.03	Chiefs, Reactor Assessment/Reactor Inspection Branches (IRAB/IRIB), NRR/DRO

Manage the inspection program feedback process for the ROP.

Schedule and conduct periodic meetings with staff to establish the priority of new FBFs received, review the status of open FBFs, and adjust priorities accordingly to meet the timeliness goals specified in section 0801-06. Ensure the final resolution of feedback is approved by the cognizant technical branch chief or designated official. Approve inspector training as appropriate.

## 05.04	Chiefs, Inspection Program Branches in NMSS and NSIR (Supervisors of Document Leads)

Manage the feedback process in their respective inspection programs. Schedule and conduct periodic staff meetings to establish the priority of new FBFs, review the status of open FBFs, and adjust priorities to meet the timeline goals specified in section 0801-06. Approve inspector training as appropriate.

## 05.05	Feedback Form Review Panel

Upon request by the document lead or branch chief to obtain regional staff input, a panel is convened and chaired by the chief, IRAB or IRIB, to discuss the disposition of longterm FBFs. The FBF review panel consists of the document leads, regional technical support branch chiefs (or Team Leaders), and cognizant technical branch chiefs. The panel adheres to timeliness goals specified in section 0801-06.

## 05.06	Chiefs, Technical Branches, NMSS, NRR, or NSIR

Review, approve, or reject FBFs. Participate in the FBF review panel when requested.

## 05.07	Originator of Feedback Forms

Will contact the document lead for any inspection document editorial changes. For every issue raised to the level of FBF submission, the originator will submit a FBF to their respective regional technical support group (TSAB, IPAT, TSAT) or team lead (branch chief supervisor if HQ staff). The originator submits an individual FBF for every IMC, IP, TI, or OpESS that pertains to the issue and provides comments on substantive issues. The originator fills out sections A through D of the FBF to identify problems, concerns, or difficulties encountered when implementing IMCs, IPs, TIs, or OpESSs. Whenever possible, the submitter will contact the document lead prior to submitting a FBF in order to discuss the document issue.

## 05.08	Technical Support and Assessment Branch (TSAB)/ Inspection Program and Assessment Team (IPAT)/ Technical Support and Administrative Team (TSAT) or Branch Chiefs/Team Leads

Receives FBFs from originator and screens for submission (completeness and validity) within 3 days of receipt. Completes section E of the FBF prior to sending to the ROP_Feedback Resource@nrc.gov email address. Works with DRO to reduce the number of outstanding FBFs—either individually or as part of a FBF review panel.

For FBFs submitted by HQ staff, the submitter’s direct supervisor or branch chief will function as the final reviewer before sending to the “ROP_Feedback Resources” mailbox. When necessary, may request that a FBF review panel be convened.

## 05.09	NRR Inspection Manual Coordinator

Responsible for the day-to-day implementation of the FBF process. Receives the new FBF and forwards to the document lead for initial acceptance or nonacceptance based on the criteria in section 07.03 of this manual. Upon acceptance by the document lead, the coordinator assigns the next chronological number to the incoming FBF, populates the FBF database, updates the FBF, inputs the FBF into ADAMS, and notifies both the lead and the originator (including all on the original email to “ROP_Feedback Resource”) of the assignment.

In coordination with the cognizant inspection program branch chief, the coordinator updates assignments during document lead turnover. Upon closure of the FBF, the coordinator processes and uploads the FBF into ADAMS and notifies the originator of the final disposition.

## 05.10	Document Lead

Receives and tracks editorial comments from NRC staff for future document revision. (See IMC 0040 for information on the responsibilities of the document lead.) Receives forwarded email from the Inspection Manual coordinator requesting a preliminary acceptance review of new FBFs and responds with acceptance or non-acceptance based on the criteria in section 07.03a of this manual. Makes initial contact with the originator of the FBF after assignment.

Periodically monitors the status of assigned, open FBFs to ensure the timeliness goals specified in section 0801-06 are met. Reviews and determines the best approach to address and disposition the issue(s) identified in the FBF. Prioritizes the proposed resolution of feedback with supervisor input. Ensures that the final resolution of feedback is consistent with overall inspection program policy and framework. Proposes a resolution path for long-term FBFs including possible consultation with a regional review panel. Documents the basis for resolution of the feedback in the FBF and obtains supervisor approval. Submits completed FBF to the Inspection Manual coordinator for final processing. Identifies and coordinates any changes or revisions with stakeholders when resolution of a FBF entails revision of an IMC, IP, TI, or OpESS. Includes the FBF being closed in the document issuing package that is submitted to the Inspection Manual coordinator, in accordance with IMC 0040.

# 0801-06	INSPECTION PROGRAM FEEDBACK PROCESS TIMELINESS GOALS

If the issue remains unclear after a conversation or email exchange with the document lead, or existing guidance is inadequate, a FBF should be submitted to the supervisor (branch chief or above for HQ staff) or to the TSAB/IPAT/TSAT or TL(BC) (for regional staff) to clearly identify problems, concerns, or difficulties encountered in implementing the affected IMCs, IPs, TIs, or OpESSs.

When a document is received in the “ROP_Feedback Resource” mailbox, the following will occur:

a. The NRR Inspection Manual coordinator will send the initial request for a preliminary acceptance review to the document lead within 10 days from receipt of a new FBF from the originator(s).

b. The document lead will have up to 5 days to accept or reject assignment based on the criteria in section 07.03a of this manual.

c. The coordinator will process the acceptance or rejection within 3 days and respond to both the lead and the submitter with assignment information (FBF No., ADAMS Accession No., and the document lead’s contact information).

The timeliness goals for FBF resolution and final closure are outlined in sections 04.02 and 04.03 of this manual.

If a FBF review panel is convened, the panel will reach a decision on the matter within 1 month from the date the panel is convened. It is acknowledged that in some circumstances this timeline may not be plausible or feasible. In these cases, the panel will decide whether a new approach for a resolution needs to be developed (e.g., consider creating a focus group), and the panel may establish a new deadline which takes into consideration the impact of the delay on overall inspection program implementation.

# 0801-07	INSPECTION PROGRAM FEEDBACK PROCESS

Feedback forms for all inspection programs (NMSS, NRR, NSIR) will be prioritized by each office or region. The prioritized FBFs will be emailed to the NRR Inspection Manual coordinator via ROP_Feedback Resource@nrc.gov. Once accepted, the FBFs will be forwarded to the appropriate staff, placed in ADAMS, and referenced on the non-public FBF SharePoint page.

Whenever possible, the staff is encouraged to contact the document lead with minor editorial changes that do not require a FBF or to discuss possible document changes. (Document leads can be found on the non-public ROP Digital City webpage, under “Communications and Training,” by clicking on “Document Lead.”) If the issue remains unclear after a conversation or email exchange, or existing guidance is inadequate, a FBF should be submitted. The feedback process is depicted in exhibit 3, “Inspection Program Feedback Process Flow Chart.”

## 07.01	Feedback Form Originator (sections A through D):

a. Retrieve the FBF template from ADAMS (ML22224A245).

b. Fill out the FBF by documenting the issue and any proposed recommendations on the FBF. If the draft FBF is returned, resolve any comments made by the regional or HQ approver and resubmit the FBF for their approval.

1. Header: the FBF number and ADAMS Accession No. are provided by the Inspection Manual coordinator.

2. Section A: Document Number and Title. Insert the IMC/IP/TI/OpESS number and document title.

3. Section B: Summary of Issue/Project-Related Issue. Summarize the issue in a few sentences. If there is a related project or initiative, include that in the appropriate box (such as “2014 Ft. Calhoun Lessons Learned” and the appropriate report accession number).

4. Section C: Description of Issue / Recommendations. Add more details about the issue (from the summary on the first page); include your recommendations to resolve the issue. Check the box at the bottom of the page if you have included additional documentation. Attach this documentation when submitting the FBF.

5. Section D: Originator Submittal Information. Include your name, HQ office or plant name and Region, your supervisor’s name, and the date submitted to your supervisor.

c. Request review and approval from the Office FBF approving authority specified in section 07.02.

## 07.02	Office Feedback Form Approving Authority (section E):

The regional TSAB/IPAT/TSAT BC/TL (or branch chief supervisor for HQ staff)—as the approving authority—reviews and either approves or rejects the FBF. Feedback forms that need clarification are returned to the originator for edits. Rejected FBFs are returned to the submitter with an explanation of the basis for the rejection.

If approved, the approving authority must include remarks regarding the suggested changes made by the submitter. Check the box if these suggested changes are urgent; state the reason for the urgency in the remarks. Sign and date the form and forward the FBF to “ROP_Feedback.Resource@nrc.gov”. For urgent FBFs, also notify the document lead and NRR Inspection Manual coordinator directly.

Feedback forms originating outside of the ROP program will be sent to the “ROP_Feedback.Resource@nrc.gov” email address for assignment and forwarded to the appropriate document lead for consideration.

## 07.03	NRR Inspection Manual Coordinator (Sections F and G):

a. The NRR Inspection Manual coordinator monitors the ROP_Feedback Resource email address for submissions. Upon receipt of a FBF, the coordinator reviews it for completeness and sends a preliminary acceptance review request to the document lead via email to determine whether the FBF should be accepted or rejected from receiving a formal review/evaluation. See exhibit 2 for a sample email.

Forms may be rejected by the document lead for the following reasons:

1. The FBF is incomplete

2. This is a duplicate of another FBF

(a) An existing FBF that identifies the issue is currently under review. If new recommendations are identified, the IMC / IP lead should consider such recommendations when dispositioning the existing feedback form.

(b) A similar FBF or program effort previously attempted to resolve the issue AND no new significant information is presented.

3. Program efforts are currently in progress to resolve the known or related issue. The program effort should consider any related issues or recommendations identified.

b. Once approved, the coordinator completes the following tasks:

1. Enters approved FBFs into the Inspection Program feedback database to assign a unique tracking number

2. Posts the open FBF on the Inspection Program Feedback Forms SharePoint site (non-public)

3. Transmits the FBF link (ADAMS Accession No.) to the document lead, originator, and originator’s approving authority within 3 business days (see section 0801-06).

c. The coordinator returns rejected FBFs to the originator’s approving authority via the ROP_Feedback Resource mailbox.

d. Once final disposition of the FBF is achieved, the coordinator processes the closure based on whether the FBF produced changes via a formal Change Notice (CN):

1. No formal CN: document section H is completed after ensuring that a detailed response to the originator is provided and the form has been signed by both the document lead and their supervisor (section G of the FBF). The completed document is then closed administratively by replacing it in ADAMS and submitting to the Document Processing Center for completion. The originator is notified of the closure via email.

2. If a formal CN is generated, the lead has included the FBF—with section G completed—in the document issuing package for closure; the lead’s supervisor does not need to sign the FBF since the incorporated changes are approved via the document issuing form (DIF). The coordinator replaces the form in ADAMS and closes the FBF with the CN package upon issuance. The originator is notified of the closure via a CN notification email (see IMC 0040) which includes reference to the FBF closure.

3. Once the document is processed in ADAMS, the coordinator updates the SharePoint database with the closure.

e. The coordinator maintains the inspection program feedback database and provides status reports to management and staff when requested. Ongoing status of open and closed FBFs is provided in the ROP Data Trending Dashboard linked to the (non-public) NRR Inspection Program Feedback Forms site.

## 07.04	Document Lead (sections F and G):

a. The lead completes the initial review detailed in section 07.03a and responds to the Inspection Manual coordinator by email with either acceptance or rejection—with a reason provided for the rejection based on the criteria.

b. The lead reviews the FBF, contacts the originator early in the process with a potential draft response, and works with the originator to fully understand the feedback. The draft response should describe how the document lead intends to address the issue if accepted or provide an explanation why the recommendation may not be accepted (FBF rejected). The draft response is replaced in ADAMS.

c. The draft response may include a possible date that the changes will be incorporated in any program documents affected.

d. The lead discusses FBF issues with their supervisor to confirm categorization and priorities. The lead updates the FBF in ADAMS, provides updates for the non-public Inspection Program Feedback Forms SharePoint list, and contacts the originator to discuss and propose an alternative solution, as necessary.

e. The lead or their supervisor may recommend that a FBF review panel be convened to elicit comments by regional staff.

f. The lead forwards the FBF to the appropriate branch chief for review if their recommendation is to reject the FBF.

g. If an approved FBF generates the need for changes to inspection program documents, the lead follows the process to revise documents as outlined in IMC 0040.”

## 07.05	Document Lead’s Supervisor (Section G):

a. Provides input regarding prioritization of FBFs.

b. Regularly reviews open FBFs on the Inspection Program Feedback Forms Share Point page and contacts the document lead regarding any processing delays and decides whether work should be reprioritized as appropriate. Ensures that document leads address FBFs to meet the timeliness goals specified in section 0801-06.

c. Performs final review on closure for all FBFs, including its incorporation into program documents. Recommends inspector training, as appropriate.

d. Requests that a FBF review panel be convened when regional input is desired.

## 07.06	Feedback Form Review Panel:

a. Consists of regional and HQ FBF approving authorities (may occur during the quarterly TSAB meeting), relevant HQ branch chiefs, and the document lead if applicable.

b. Meets to discuss the regional impact of issue(s) raised in the FBF and to reach alignment toward resolution.

c. Outcome decision made within 1 month of the panel’s initial meeting or establishes a new deadline to reach resolution.

d. Panel Chair, or designee, documents the decision in sections E, F, and G on the FBF.

# 0801-08	REFERENCES

IMC 0040, “Preparation, Revision, Issuance, and Ongoing Oversight of NRC Inspection Manual Documents”

IMC 0608, “Performance Indicator Program”

Inspection Program Feedback Forms internal (non-public) website

ROP Feedback Form Dashboard internal (non-public) website

END

Issue Date: 03/29/23	1	0801

Exhibit 1: Inspection Program Feedback Form

[Feedback Form Template (non-public): ML22224A245]

See IMC 0801 for detailed Feedback Form Completion Instructions

Issue Date: 03/29/23	Ex1-1	0801

Exhibit 2: Example of Document Lead Acceptance Email

Document Lead,

A feedback form (attached) was submitted for IP 00000.01; you have been identified as the lead. Please use the Voting buttons to respond.

Please respond with either “acceptance” of assignment of the FBF for formal review OR “non acceptance” based on the following criteria:

Feedback forms should not be accepted for formal review if any of the following criteria are met:

1. Sections in the feedback form are incomplete / not filled in.

2. Duplicate feedback form

(a) An existing feedback form that identifies the issue is currently under review. If new recommendations are identified, the IMC / IP lead should give consideration to such recommendations when dispositioning the existing feedback form.

(b) A similar feedback form or program effort previously attempted to resolve the issue AND no new significant information is presented.

3. Program efforts are currently in progress to resolve the known or related issue. The program effort should give consideration to any related issues or recommendations identified.

If accepted for review by the lead, the form will be formally assigned (FBF number assigned, FBF SharePoint site populated, and input into ADAMS).

Please reply to this email if you have questions or want to elaborate on the reason for non-acceptance.

Issue Date: 03/29/23	Ex2-1	0801

Exhibit 3: Inspection Program Feedback Process Flow Chart

Note: This chart is for the standard FBF process. The program office BC may choose to expedite this process based on the safety significance of the issue or an emergent request.

Issue Date: 03/29/23	E3-1	0801

Attachment 1: Revision History for IMC 0801

Issue Date: 03/29/23	Att1-1	0801

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