**NRC INSPECTION MANUAL**	IRAB

	INSPECTION MANUAL CHAPTER 0609, ATTACHMENT 04

	INITIAL CHARACTERIZATION OF FINDINGS

Effective Date:  12/20/2019

0609.04-01	PURPOSE

The framework described in this attachment to the Significance Determination Process (SDP) is designed to provide guidance to NRC inspectors and management for use in the initial characterization of safety or security findings within the seven safety cornerstones of the Reactor Oversight Process (ROP).  The initial characterization of findings is designed to perform three functions:

a. Provide an opportunity to the inspector to document all applicable information regarding the finding, and its associated impact on safety or security, in a consolidated format (Table 1).

b. Support the identification of safety cornerstone(s) affected by the degraded condition or programmatic weakness resulting from the finding (Table 2).

c. Direct the inspector to the appropriate SDP appendix of Inspection Manual Chapter (IMC) 0609 for further evaluation (Table 3).

0609.04-02	GUIDANCE

Each finding entering the SDP, regardless of the cornerstone under which it is identified, is by definition a performance deficiency that is “more than minor” as prescribed in IMC 0612.  Performance deficiencies that are determined to be “minor” are not findings, and therefore, not subjected to the SDP.

02.01	Finding Consolidated Information Sheet (Table 1)

The objective of Table 1 is to provide the inspector and management the opportunity to document and review all the supporting information pertaining to a finding in a concise format.  Below are detailed descriptions of the table sections to facilitate documentation:

a. Clearly Articulated Finding – Describe the identified performance deficiency and the “more than minor” determination in accordance with applicable IMC 0612 guidance.  Each finding is treated independently in the SDP.

b. Factual Description of Degraded Condition or Programmatic Weakness – State the facts pertaining to the degraded condition or programmatic weakness without any hypothetical situations, failures, or occurrences.  For conditions that involve degraded equipment, include the affected system(s), structure(s), component(s) (SSCs), and/or train(s), to include their associated function(s), and how they impacted safety or security.  The Initiating Events, Mitigating Systems, and Barrier Integrity cornerstones primarily deal with degraded conditions.  For a programmatic weakness, include the affected program(s) and describe how the programmatic weakness impacted safety or security.  Other pertinent information to consider are root/apparent/proximate cause evaluations, extent of condition assessments, interdependencies with other systems, perspectives from the licensee, and the duration of the degraded condition or programmatic weakness (i.e., exposure time).

c. Logical Link(s) that Connect(s) the Finding to the Degraded Condition or Programmatic Weakness – Clearly articulate the nexus (i.e., logical link(s)) between the inspection finding and the degraded condition or programmatic weakness.  The finding should most often be identified as the proximate cause of the degraded condition or programmatic weakness.  The determination of cause need not be based on a rigorous root cause evaluation, but rather on a reasonable assessment and judgment of the staff.  If the proximate cause of multiple degraded conditions or programmatic weaknesses is the same, there may be just one independent finding provided that the finding is not defined at a level associated with a cross-cutting area as defined in IMC 0310.

d. Supporting Documentation and References – List the documents used during the inspection process.  Examples include, but are not limited to, inspection procedures, plant status, licensee event reports, and condition reports.

NOTE:  If Table 1 is used to document information pertaining to a security finding, then the table will have to be properly labeled as Safeguards or Official Use Only - Security Related Information.

02.02	Cornerstones Affected by Degraded Condition or Programmatic Weakness (Table 2)

The objective of Table 2 is to support the identification of safety cornerstones affected by the degraded condition or programmatic weakness resulting from the finding.  The affected cornerstones may already have been identified previously (e.g., scope of the inspection procedure, inspector experience and knowledge of the ROP); however, Table 2 helps to support this determination.  Below is a description to facilitate filling out Table 2:

a. Read through the degraded conditions and programmatic weaknesses listed in all seven cornerstones and check all that are applicable.  For the degraded conditions, many of the options are associated with SSCs and events.

b. Review all the checked boxes and determine which cornerstone(s) are affected by the degraded condition or programmatic weakness.  

02.03	SDP Appendix Router (Table 3)

Typically, one affected cornerstone is identified in Table 2. The inspector should use the SDP Appendix Router (Table 3) to determine the appropriate SDP appendix for further evaluation of the finding.  If more than one cornerstone is affected, and Table 3 results in direction to one (or multiple) SDP appendices, the inspector and management need to ultimately identify one cornerstone based on reasonable judgment of the situation.  If the finding progresses to a detailed risk evaluation, the inspector, Senior Reactor Analyst (SRA), and management should confirm the identified cornerstone based on the proportional contribution from each cornerstone to the total risk estimation.

NOTE:  If the SDP Appendix Router directs the user to a particular appendix, and upon further evaluation that SDP appendix is not capable of evaluating the finding and associated degraded condition or programmatic weakness, the inspection staff and applicable SRA, with support from management, should determine if IMC 0609, Appendix M is an appropriate tool.  A planning Significance and Enforcement Review Panel (SERP) is required before transitioning to Appendix M other than when directed explicitly by procedure.  Refer to IMC 0609, Attachment 1 for additional guidance.

0609.04-03	REFERENCES

IMC 0310, “Aspects Within The Cross-Cutting Areas”

IMC 0612, “Issue Screening”

IMC 0609, Attachment 1, “Significance and Enforcement Review Panel Process”

IMC 0609, Appendix A, “The Significance Determination Process for Findings At-Power”

IMC 0609, Appendix B, “Emergency Preparedness SDP”

IMC 0609, Appendix C, “Occupational Radiation Safety SDP”

IMC 0609, Appendix D, “Public Radiation Safety SDP”

IMC 0609, Appendix E, “Security SDP for Power Reactors” 

IMC 0609, Appendix F, “Fire Protection Significance Determination Process”

IMC 0609, Appendix G, “Shutdown Operations SDP”

IMC 0609, Appendix I, “Licensed Operator Requalification SDP”

IMC 0609, Appendix K, “Maintenance Risk Assessment and Risk Management SDP”

IMC 0609, Appendix L, “Significance Determination Process for B.5.b”

IMC 0609, Appendix M, “Significance Determination Process Using Qualitative Criteria”

END

Issue Date:  12/13/19	5	0609.04

Issue Date:  12/13/19	4	0609.04

Issue Date:  12/13/19	10	0609.04 

Attachment 1 – Revision History for IMC 0609.04

Issue Date:  12/13/19	Att1-1	0609.04

Issue Date:  12/13/19	Att1-2	0609.04