| REMARKS: | IMC 0609, App H (Containment Integrity Significance Determination Process) is revised to include multiple innovative features that were not included in the previous revision. For example, this revision includes guidance for plant shutdown conditions for both Type A and Type B findings. A process was developed for large early release frequency (LERF) assessment and provides a detailed step-by-step approach supported by road maps and evaluation tables. In addition, a reasonably conservative LERF counting rule and associated worksheet were developed for LERF impact evaluations. IMC 0308, Att 3, App H (Technical Basis for Containment Integrity Significance Determination Process) is added to provide the supporting technical "basis" for IMC 0609, App H. IMC 0609, App J (Steam Generator Tube Integrity Findings Significance Determination Process) is a new procedure to be used to address the risk significance of inspection findings related to degradation of steam generator tubes. The inspector is referred to Appendix J by IMC 609, Appendix A, in the Phase 1 Screening Worksheet. Table 1, Steam Generator Tube Integrity SDP Matrix, of Appendix J presents the information that is used to determine the preliminary significance of inspection findings. It is expected that region based ISI inspectors who normally review licensee steam generator tube integrity test results will be the primary users of Table 1. Resident inspectors may use the guidance but their assessment should be reviewed by the region based ISI inspector. Using Table 1, any finding determined to be White, Yellow, or Red or assessed to be "To Be Determined" must be reviewed by a risk analyst with experience in steam generator tube risk assessment. Analysts who have this expertise are in the Probabilistic Safety Assessment Branch of NRR. Findings determined to be "Green" do not need to be reviewed further by a risk analyst. Appendix J is not to be used for assigning the risk significance of programmatic deficiencies in a licensee�s steam generator testing program when actual tube integrity is unknown due to the deficiency. Programmatic deficiencies that are of greater than minor significance should be forwarded to NRR. IMC 0308, Att 3, App J (Technical Basis for Steam Generator Tube Integrity Findings Significance Determination Process) is added to provide the supporting technical "basis" for IMC 0609, App J. |