**NRC INSPECTION MANUAL**

IRIB

MANUAL CHAPTER 2515

LIGHT-WATER REACTOR INSPECTION PROGRAM---OPERATIONS PHASE

2515-01 PURPOSE

To establish the policy for the light-water operating reactor inspection
program.

2515-02 OBJECTIVES

02.01 To obtain factual information providing objective evidence that
power reactor facilities are operated safely and licensee activities do
not pose an undue risk to public health and safety.

02.02 To determine the causes of declining performance before such
performance reaches a level that may result in an undue risk to public
health and safety.

02.03 To identify those safety significant issues that may have generic
applicability.

02.04 To provide direction for modifying the baseline inspection program
in the event of a pandemic.

2515-03 APPLICABILITY

This inspection program is implemented when an operating license is
issued for a facility. Portions of the light-water reactor inspection
program for the startup phase (IMC 2514) may also be conducted during
the initial operation of a facility. The light-water reactor inspection
program for the preoperational testing and operational preparedness
phase (IMC 2513) will have been completed by the time this program is in
effect.

This inspection program will remain in effect until the facility is
permanently shut down and enters the post-operational phase (cf. IMC
2561, \"Decommissioning Power Reactor Inspection Program\").

As directed by section 2515-14 and Appendix E of this IMC, inspection
program can be modified in the event of a pandemic that severely reduces
available inspection resources.

2515-04 DEFINITIONS OF INSPECTION FREQUENCIES

04.01 [Triennially or Every Three Years (T)]{.underline}[^1]. The
inspection will be performed at least once during Reactor Oversight
Process (ROP) cycles 1-3, ROP cycles 4-6, ROP cycles 7-9, etc. It is not
intended for this to be based on a rolling 3 year cycle.

04.02 [Biennially or Every Two Years (B)]{.underline}[^2]. The
inspection will be performed at least once during ROP cycles 1-2, ROP
cycles 3-4, ROP cycles 5-6, etc. It is not intended for this to be based
on a rolling 2 year cycle.

04.03 [Annually (A)]{.underline}. The inspection effort will be
performed at least once each calendar year.

04.04 [Semiannually (S)]{.underline}. The inspection effort will be
performed two times each calendar year, once each half calendar year.

04.05 [Quarterly (Q)]{.underline}. The inspection effort will be
performed four times each calendar year, once each calendar quarter.

04.06 [As Needed (AN)]{.underline}. The inspection effort should be
performed when the activity or event occurs at the facility as specified
in the guidance section of specific inspection procedures (e.g.,
refueling outages).

04.07 [Baseline Inspection Program Completion]{.underline}. Baseline
Inspection Program completion for an ROP annual inspection cycle is
defined to be not more than four (4) inspection procedures not
completed, per Region. For the purposes of this definition, each
inspection procedure attachment is counted as a separate inspection
procedure (IP).

This sixteen (16) inspection procedure allowance per year nationwide
equates to an annual completion rate greater than 99.5% (assuming an
average of 3400 total inspection procedures/attachments per year
nationwide - approximately 33 per year X 103 plants). This allowance is
intended to provide for unanticipated disruptions in inspection
scheduling that unavoidably cause an inspection procedure or attachment
to not be completed and presumes that at least the minimum inspection
requirements will otherwise be completed as soon as possible within the
quarter immediately following the annual inspection cycle. Achieving
this level of Baseline Inspection performance provides a basis to
conclude that the intent of the Baseline Inspection Program has been met
and therefore, for the purpose of goal monitoring, can be reported as
complete for that annual cycle.

2515-05 RESPONSIBILITIES AND AUTHORITIES

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

> a\. Provides overall program direction for the reactor inspection
> program.

b\. Develops and directs the implementation of policies, programs, and
procedures for inspecting applicants, licensees, and other entities
subject to NRC jurisdiction.

c\. Assesses the effectiveness, uniformity, and completeness of
implementation of the reactor inspection program.

> d\. In the event of a pandemic, concurs on the regions'
> recommendations to the modification to the inspection program in
> accordance with the direction provided under section 2515-14 and
> Appendix E of this IMC.

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

05.03 [Director, Division of Inspection & Regional Support
(DIRS)]{.underline}. Manages inspection program development within NRR,
develops and prepares revisions to the reactor inspection program,
oversees regional implementation, and serves as the NRR contact with the
regional offices for program development and implementation.

05.04 [Directors, Technical Divisions, NRR]{.underline}. Assists the
Director, DIRS in developing the technical content of and reviewing
periodic revisions to the requirements and guidance contained in
inspection procedures related to their areas of technical expertise.

05.05 [Regional Administrator]{.underline}.

> a\. Provides program direction for management and implementation of
> the inspection program elements performed by their regional office.
>
> b\. Ensures, within budget limitations, that the regional office staff
> includes adequate numbers of inspectors in the various disciplines
> necessary to carry out the inspection program described in this
> chapter, including that which may be needed for regional supplemental
> and reactive inspections.
>
> c\. Directs the implementation of the supplemental inspection program
> in accordance with the guidance in Appendix B of this document.
>
> d\. Applies inspection resources, as necessary, to deal with
> significant issues and problems at specific plants.
>
> e\. *Ensures that line managers assign inspectors who are
> appropriately trained and have the necessary knowledge and skills to
> successfully implement inspection procedures.* \[C2\]
>
> f\. Determines that a pandemic situation which affects inspection
> resource availability has occurred and recommends modification to the
> inspection program in accordance with the direction provided under
> section 2515-14 and Appendix E of this IMC.

2515-06 REGULATORY OVERSIGHT FRAMEWORK

The fundamental building blocks that form the framework for the
regulatory oversight process are seven cornerstones of safety;
initiating events, mitigating systems, barrier integrity, emergency
preparedness, occupational radiation safety, public radiation safety,
and security. These cornerstones have been grouped into three strategic
areas: reactor safety, radiation safety, and safeguards. This framework
is based on the principle that the agency's mission of assuring public
health and safety is met when the agency has reasonable assurance that
licensee's are meeting the objectives of the seven cornerstones of
safety. The reactor inspection program is an integral part, along with
performance indicators (PIs), assessment, and enforcement, of the
reactor oversight process. Acceptable performance in the cornerstones,
as measured by the PIs and the risk-informed baseline inspection
program, is indicative of overall licensee performance that provides for
adequate protection of public health and safety. The PI program
reporting guidelines are in NEI 99-02, "Regulatory Assessment
Performance Indicator Guideline," which is endorsed by the NRC.

Another principle of the framework is that there is a level of licensee
performance in the cornerstones above which the NRC does not need to
engage the licensee beyond some minimum level. When this level of
licensee performance is reached, the risk-informed baseline inspection
and PI programs are sufficient to provide reasonable assurance of public
health and safety.

The supplemental portion of the inspection program will provide more
diagnostic inspections of identified problems and issues beyond the
baseline. Supplemental inspections will be planned in response to issues
that result in crossing an Action Matrix threshold. These changes to the
inspection program are factored into the inspection program through the
assessment process, as further discussed in Section 8.0, below.

2515-07 OPERATING REACTOR INSPECTION PROGRAM ELEMENTS

The inspection program described in this manual chapter is comprised of
the following three major program elements:

> 1\. Risk-Informed Baseline Inspection Program (Baseline) Inspections
>
> 2\. Plant Specific Supplemental Inspections
>
> 3\. Generic Safety Issue, Special, and Infrequent Inspections

Overall, the inspection program emphasizes achieving a balanced look at
a cross section of licensee activities important to plant safety,
reliability, and risk. The baseline inspections constitute an
appropriate level of inspection at plants whose overall performance
remains in the licensee response band. Plants, whose performance is
outside the licensee response band, will receive additional plant
specific supplemental inspection based on their assessed performance in
the cornerstones of safety. Additionally, Appendix D is provided for use
by the resident inspectors in conducting routine activities such as
plant tours that may assist them in identifying potentially risk
significant activities.

The supplemental inspections, described in Appendix B, are only
performed as a result of performance issues that are identified by
either performance indicators (PIs), baseline inspections, or event
analysis. The depth and breadth of specific supplemental inspections
chosen for implementation will depend upon the risk characterization of
the issues as shown in the Action Matrix of the reactor assessment
program (IMC 0305, "Operating Reactor Assessment Program").

The need for additional inspections to address emergent generic safety
issues, such as those that were performed for motor-operated valves and
year 2000 issues, will be assessed on a case by case basis. Also, the
need for performing additional inspections to review major licensee
evolutions such as testing and operation of independent spent fuel
storage facilities or steam generator replacements will be assessed.

In addition to the three elements, the inspection program also provides
for the agency's response to operational events. The guidance for
determining the level of response to an event is contained in NRC
Management Directive 8.3, "Incident Investigation Program."

07.01 [Risk-Informed Baseline Inspections]{.underline}. The baseline
inspection program element, described in Appendix A, is to be performed
at all operating reactors. It requires inspections of licensee
performance in the seven cornerstones of safety.

The baseline inspections provide sufficient examination of the plants
and licensee activities to determine, along with performance indicators,
whether licensees are meeting the objectives of all seven cornerstones,
and to identify indications of performance problems to allow further
engagement by the NRC before the objectives of the cornerstones are
compromised.

The inspection procedures included in the baseline inspection program
are based on "inspectable areas" for the seven cornerstones of safety.
The oversight framework

identified key attributes for each cornerstone that need to be verified
to have a reasonable assurance that the cornerstone objectives are met.
Licensee performance within the key attributes is then measured by a
performance indicator, a risk-informed inspectable area, or a
combination of both indicator and inspection.

The baseline inspection procedures are organized by cornerstone and
include the inspectable areas associated with the cornerstone. The
baseline inspections are performance-based and risk-informed and
emphasize the observation and evaluation of ongoing facility operations
and supporting activities affecting the safety function of facility
structures, systems, and components. Appendix D has been provided to
assist the resident inspectors in conducting activities that may
identify potentially risk significant activities. The baseline
inspections are risk informed through (1) the inspectable areas, which
are based on their risk importance in measuring a cornerstone objective;
(2) the inspection frequency and sample size for each inspectable area,
which are based on risk information; and (3) sample selection of
activities and equipment to inspect in each inspectable area, which is
based on risk insights that will be modified by plant-specific
information.

*Appendix A contains a list of baseline inspection procedures and
specifies the required frequency for their performance. The baseline
inspection procedures must be completed at every plant at a prescribed
interval. The expectation is that the regions should normally complete
the nominal (average) number of inspection samples identified in the
inspection procedure. The regions may vary the inspection samples within
the ranges as indicated in each baseline inspection procedure, based on
licensee performance and inspector insights. For the purposes of
completing the baseline inspection program, the number of samples
completed must be within the range of values specified in each
inspection procedure.* \[C2\]

Inspection requirements are the controlling factor in determining the
amount of inspection effort necessary to complete the baseline
inspections. Appendix A provides an estimate of the hours associated
with each inspection procedure for overall resource planning only.

07.02 [Plant Specific Supplemental Inspections]{.underline}.

The supplemental element of the inspection program is designed to apply
NRC inspection assets in an increasing manner when performance issues
are identified, either by inspection findings evaluated using the
significance determination process (SDP) or when performance indicator
thresholds are exceeded. Accordingly, the NRC regional office will
assess the need for supplemental inspections after identifying an
inspection finding categorized as risk significant (i.e., white, yellow,
or red) with the SDP, or when a performance indicator exceeds the
licensee response band threshold. The scope and breadth of these
inspections will be based upon the guidance provided in the assessment
program's Action Matrix and expanded upon in the "Supplemental
Inspection Selection Table" included in Appendix B.

Depending on the risk significance and breadth of the identified
performance issues, the supplemental inspections provide a graded
response, which includes: oversight of the

licensee's root cause evaluation of the issues; expansion of the
baseline inspection sample or a focused team inspection (as necessary to
evaluate extent of condition); or a broad scope, multi-disciplined team
inspection, which would include inspection of multiple cornerstone areas
and inspection of crosscutting issues. Any new issues identified during
the supplemental inspections will be evaluated by the SDP. The need for
additional NRC actions, including additional supplemental inspections,
will be governed by the Action Matrix.

A supplemental inspection will be performed for all white, yellow, or
red issues (either PIs or inspection findings). The region may choose
not to perform a supplemental inspection for white issues identified as
part of a licensee's self assessment, although such exceptions are
expected to be infrequent. In such instances, the region will still
ensure that the issue is entered into the licensee's corrective action
program and that an appropriate evaluation is performed. The licensee's
evaluation for such an issue will be reviewed as part of baseline
inspection procedure 71152, "Identification and Resolution of Problems."
Additionally, the regional offices may choose to propose a deviation
from the Action Matrix when the level of supplemental inspection is not
appropriate for the particular circumstances. Examples of when the level
of supplemental inspection may need to be increased or decreased include
(but are not limited to): 1) a single red finding or performance
indicator that does not appear to be indicative of broad programmatic
concerns, 2) a single red inspection finding or performance indicator,
particularly those that meet the criteria for old design issues, 3)
multiple examples of non-SDP Severity Level III or greater enforcement
actions, 4) a type of finding unanticipated by the SDP that results in
an inappropriate level of regulatory attention when entered into the
Action Matrix. A deviation from the Action Matrix may be authorized in
accordance with IMC 0305, "Operating Reactor Assessment Program."

07.03 [Generic Safety Issues, Special, and Infrequent
Inspections]{.underline}. Concerns with specific safety issues that
arise may be addressed solely through the NRR license review process and
the use of regulatory communications issued to licensees. If the concern
is of safety significance, it may be appropriate to perform a one-time
inspection under the safety issues program element. These inspections
will be established by temporary instructions (TIs). For example, when
it is determined that a safety issue addressed in a bulletin or generic
letter requires inspection verification or follow-up, requirements and
guidance for the inspection will be developed and issued in a TI. Unless
such a TI is issued, inspection follow-up is not required to verify
completion of licensees\' actions discussed in a bulletin or generic
letter. When a TI is issued, overall assessment ratings may be
considered in establishing priorities for conducting these inspections.
The plants to be inspected will be designated in the TIs.

The resources budgeted to safety issues inspections are established by
NRR. It is the intent that the inspections be conducted within the
resources budgeted for that element of the program.

Specific criteria for closing a TI will be addressed in the TI itself.
In general, TIs should not be closed until all relevant safety issue
items have been completed by the licensee and verified by inspection.
However, exceptions may be considered when the licensee\'s schedule for
completing items remaining is acceptable, properly documented, and is
not a critical element to resolving the safety issue.

The need may arise for specific inspections to address major evolutions
limited to a few licensees such as upgrading to a digital control
system. The need for these inspections will also be assessed on a
case-by-case basis and conducted under the guidance of a temporary
instruction.

This element of the inspection program also includes other special or
infrequently performed inspections. These inspections may be in response
to events, infrequent major activities at nuclear power plants, or to
fulfill the NRC's obligations under interagency memoranda of
understanding. The applicable procedures are listed in Appendix C,
"Special and Infrequently Performed Inspections."

07.04 [Related Activities Associated with the Reactor Inspection
Program]{.underline}. All inspections, as well as performance indicators
reported by licensees, provide input to the plant performance assessment
process. The performance assessment process is to be conducted in
accordance with IMC 0305, "Operating Reactor Assessment Program."

2515-08 DISCUSSION

08.01 [General]{.underline}. The inspection program described in
Appendices A, B, and C is intended to provide the framework for managing
inspection resources without being overly prescriptive. At the same
time, a level of inspections necessary to complete pre-defined
objectives at a facility is specified, below which inspection should not
decrease. It is intended to place inspection emphasis on elements of
licensee activities most important to reactor safety, radiation safety,
and safeguards.

*Because ROP uses PIs and inspection findings which are evaluated for
risk to determine whether all cornerstone objectives were met at a
plant, only those inspection findings which rise above a minimum
significance threshold (i.e., findings are greater than minor) are
documented in inspection reports. Therefore, inspection findings which
are determined to be minor do not need to be nor shall be tracked or
trended by either inspectors or regional managers. Instead, minor
findings are to be reported to the licensee for action in accordance
with the licensee's corrective action program. Licensees are expected to
track and trend minor findings and issues as stated in their program.
When implementing inspection procedure 71152, "Problem Identification
and Resolution," inspectors may include minor findings and issues as
part of their semiannual trend review. This review will determine
whether the licensee has adequately identified and corrected an adverse
trend, if any, resulting from all identified deficiencies, including
minor findings, during the period of review.* \[C3\]

Using a performance-based, risk-informed approach, inspectors focus
their attention on activities important to safety. Performance-based
inspection emphasizes observing activities and the results of licensee
programs over reviewing procedures or records. For example, an inspector
may identify an issue through observing a plant activity in progress,
monitoring equipment performance, or the in-plant results of an activity
(e.g., an engineering calculation). Discussions with plant personnel and
reviewing documents should be used to enhance or verify
performance-based observations. These procedures are designed to
emphasize observation of activities, or those portions that are most
risk significant in terms of safety and reliability. It is expected that
resident and region-based inspectors will have the necessary technical
capability to accurately observe and evaluate the activity.

*Regional Division Directors and line managers must ensure that
inspectors assigned to implement the baseline inspection procedures have
the necessary training, knowledge, and skills to successfully implement
the NRR programs. The inspector training and qualification program will
be in accordance with IMC 1245, "Qualification Program for the Office of
Nuclear Reactor Regulation Programs." The following baseline inspection
procedures will normally be performed by regional specialists who have
achieved at least Basic Certification in accordance with IMC 1245:*

-   *IP 71111.02, "Evaluation of Changes, Tests, or Experiments"*

-   *IP 71111.05T, "Fire Protection"*

-   *IP 71111.07B, "Heat Sink Performance"*

-   *IP 71111.08, "Inservice Inspection Activities"*

-   *IP 71111.11B, "Licensed Operator Requalification Program"*

-   *IP 71111.12B, "Maintenance Effectiveness"*

-   *IP 71111.17B, "Permanent Plant Modifications"*

-   *IP 71111.21, "Safety System Design and Performance Capability"*

-   *IP 71114, "Reactor Safety Emergency Preparedness" (all except
    attachment 06)*

-   *IP 71121, "Occupational Radiation Safety" (all attachments)*

-   *IP 71122, "Public Radiation Safety" (all attachments)*

-   *IP 71130, "Physical Protection" (all attachments)*

    *The remaining baseline inspection procedures will normally be
    performed by resident inspectors who are at least basic certified.
    Additionally, based on their qualification and experience, regional
    specialists may also perform baseline inspections other than the
    ones listed above. Likewise, based on their qualifications and
    experience, resident inspectors may also perform baseline inspection
    procedures normally performed by regional specialists.* \[C2\]

    NRC inspectors perform a basic mission in determining whether a
    licensee operates the plant safely and meets current regulatory
    requirements and commitments. Limiting inspection to identification
    of specific instances where a licensee fails to meet such
    requirements and commitments could result in correction of symptoms
    rather than correction of underlying causes of licensee problems.
    The inspection and assessment processes establish thresholds for
    determining the significance of issues and whether those issues may
    require additional evaluation and follow up. Thus, the inspection
    program requires that inspectors and their managers evaluate
    problems to determine if follow up inspections are necessary to
    diagnose whether a safety concern represents an isolated case or may
    signify a broader, more serious problem based on the evaluated
    significance of the issues. Licensee management controls (e.g., QA,
    safety committees, etc.) may need to be examined to determine if
    weaknesses in these controls contributed to identified safety
    concerns.

    The NRC inspection program covers only small samples of licensee
    activities in any particular area. The sample sizes specified in the
    inspection procedures are based on the relative importance of the
    area covered by the procedure to the other areas inspected by the
    program. They are also based on the inspectors choosing a "smart"
    sample instead of a statistically based random sample because the
    risk-informed nature of the inspection program requires the
    inspections to be focused on those aspects of plant operations and
    licensee activities that could pose the greatest risk to public
    health and safety. The philosophy behind this concept is that the
    licensee's processes are effective if they deal properly with the
    items of greatest significance. Some areas (such as reviewing 10 CFR
    50.59 evaluations) do not have a direct connection with risk and
    inspection sample sizes in these areas are chosen to provide
    periodic indications of a licensee's performance in those areas.

    08.02 [Allocation of Resources as a Function of Performance
    Assessment]{.underline}. The results of plant performance
    assessments are an important factor in defining the inspection
    program for each plant. The baseline inspections are the level of
    defined requirements for all plants and additional regional
    supplemental inspections will be planned for plants whose
    performance is below a certain level, i.e., the licensee response
    band. The amount and focus of the additional supplemental
    inspections will be proportional to the plant's assessed performance
    and the nature of the issues that provide the indication of that
    performance. See IMC 0305, "Operating Reactor Assessment Program,"
    for more detailed guidance on responding to issues with licensee
    performance.

    Only baseline inspections, applicable generic safety issues, and
    special and infrequent inspections will be planned and conducted at
    plants whose overall performance (all performance indicators and
    inspection findings) is determined to be in the licensee response
    band.

    Plants whose performance is determined to be outside of the licensee
    response band (see IMC 0305) should have supplemental inspections
    planned to examine the root causes of the change in performance and
    corrective actions of identified findings or safety issues that have
    indicated the performance change.

    08.03 [Allocation of Resources Among Program Elements]{.underline}.
    The allocation of resources among the three principal inspection
    program elements (baseline, supplemental and generic safety issues)
    is provided for each year in the budget process.

    08.04 [Completion of Inspection Procedures]{.underline}. The
    baseline inspection procedures represent the inspection necessary to
    allow the NRC to assess performance. This means that the inspector
    is to perform the requirements most appropriate to the activity
    being inspected in each inspectable area by completing the number of
    inspection activities (samples) within the range of sample values
    specified in each inspection procedure, thus meeting the objectives
    of the procedure.

    *Performance of one inspection procedure sample may be counted as a
    sample for another procedure only if completed inspection
    requirements are common to each procedure.* \[C2\]

    The sample size may be reduced to a number below the minimum value
    in situations where there are an insufficient number of samples with
    appropriate risk significance available for inspection (e.g., a
    reduction of sample size to zero, if necessary, when no samples
    exist). Where no sample is specified, completion of all applicable
    inspection requirements constitutes completion of the procedure. The
    inspection hours estimate, which is included in the inspection
    procedure attachments for planning purposes, should not be used to
    determine whether the inspection attachment was satisfactorily
    completed. This estimate is intended to provide guidelines for
    inspection planning and budgeting.

    Approval by the Director, Division of Inspection & Regional Support
    (DIRS), NRR, is required when the inspection requirements in an
    inspectable area cannot be met. Likewise, each inspection
    requirement contained in the supplemental inspection procedures must
    be adequately addressed.

    Inspection procedures identify requirements that the inspector must
    consider while evaluating the associated area. These requirements
    may not be the same as NRC requirements placed on a specific
    licensee. As such, it is not implied or intended that inspection
    program requirements are to be levied on the licensee. Any attempt
    to force inspection program requirements on the licensee constitutes
    misinterpretation of NRC inspection philosophy and misuse of
    inspection requirements.

    Temporary instructions are issued for specific inspection purposes.
    For inspections performed using a temporary instruction, the
    inspector is expected to complete all inspection requirements
    listed.

    08.05 [Baseline Inspection Credit for Operational Safety Review Team
    Effort]{.underline}. The Operational Safety Review Team (OSART)
    review is performed by senior staff members from International
    Atomic Energy Agency member states. The OSART missions offer a means
    of assessing licensee performance and reinforcing plant
    self-assessments through an independent assessment process. OSART's
    focus on the safety and reliability of plant operation. They review
    the operation of the plant and the performance of the plant's
    management and staff rather than the adequacy of the plant's design
    and compliance with its licensing basis. Based on a review of sample
    OSART reports and the OSART guidelines, the staff determined that
    although the

    OSART review is not risk-informed, some areas of the review overlap
    with the ROP baseline inspection program. The NRC believes that it
    would be beneficial for the U.S. nuclear power industry to continue
    its participation in the OSART missions.

    As an incentive to encourage licensee participation in the OSART
    mission, the NRC grant a one-time regulatory credit (reduction in
    baseline inspection program) for those NRC baseline inspections that
    overlap, either in part or fully, with the OSART review.
    Accordingly, a 25 percent ROP baseline inspection credit shall be
    given for the following baseline inspection procedures:

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-   IP 71111.22Q, "Surveillance Test"

-   IP 71111.05Q, "Fire Protection"

-   IP 71121.01A, "Access Control to Radiologically Significant Areas"

-   IP 71121.02B, "ALARA Planning and Controls"

-   IP 71121.03B, "Radiation Monitoring Instrumentation and Protective
    Equipment"

-   IP 71122.01B, "Radioactive Gaseous and Liquid Effluent Treatment and
    Monitoring Systems"

-   IP 71122.02B, "Radioactive Material Processing and Transportation"

-   IP 71122.03B, "Radiological Environmental Monitoring Program and
    Radioactive Material Control Program"

    In addition, a 50 percent ROP baseline inspection credit shall be
    given for the following inspection procedures:

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-   IP 71114.03B, "Emergency Response Organization Augmentation"

-   IP 71114.05B, "Correction of Emergency Preparedness Weaknesses and
    Deficiencies"

-   IP 71152B, "Identification and Resolution of Problems/Issues"

    In order for the region to take one-time credit for reducing
    baseline inspections, the areas for which the credit is to be given
    must have been documented in the OSART report. In addition, an NRC
    staff person should closely monitor the OSART activities, such as
    attending the team's briefings to the licensee. The staff person
    should assess whether the regulatory credit assumptions were
    appropriate. This person also needs a good understanding of the
    issues and recommendations made by the OSART. For NRC planning
    purposes, this effort is estimated to take approximately 40 hours.
    Also, the region should assure that the OSART inspection report is
    made publicly available. Specific OSART findings should not normally
    be referenced or followed-up by the NRC, however, where a
    significant safety issue (potentially greater than Green) or a
    potential violation of an NRC requirement is identified, the NRC
    will independently conduct an appropriate baseline inspection to
    disposition potential violations and assess the significance of the
    finding in accordance with the ROP. These findings will be
    documented in accordance with NRC Inspection Manual Chapter (IMC)
    0612, "Power Reactor Inspection Reports," and will also be processed
    as performance assessment inputs equivalent to NRC identified
    findings in accordance with IMC 0305, "Operating Reactor Assessment
    Program." The staff will perform any additional inspections for
    those findings that have a significance greater than Green in
    accordance with NRC's Action Matrix. The baseline inspection credit
    and NRC staff position described above are communicated to the
    Commission via a memorandum dated July 16, 2003 (Adams Accession
    Numbers: ML031620369, ML030930251, ML0316020346).

    08.06 [Baseline Inspection Program Completion and
    Documentation]{.underline}. The following guideline shall be
    followed when it is expected that required inspections for which the
    region is responsible will not be completed by the end of the
    calendar year:

    *a. The missed inspection(s), if any, must be scheduled such that it
    will be completed during the first quarter of the next calendar
    year.*

    *b. Inspection procedures which should be implemented during a
    refueling outage cannot be deferred.*

    *c. Inspections may only be deferred at a plant in the licensee
    response column of the action matrix.*

    *d. Acceptable reasons for deferring an inspection include
    unanticipated inspection resource demands resulting from providing
    additional regulatory attention to plants which are placed in the
    IMC-0350 process or in multiple/repetitive degraded cornerstone or
    unacceptable performance columns. (Refer to IMC-0305, "Oversight of
    Operating Reactor Facilities in a Shutdown Condition with
    Performance Problems," for a more detail explanation of these
    performance columns.)*

    *e. The Director, Division of Reactor Projects (DRP) must notify the
    Director, Division of Inspection and Regional Support (DIRS), NRR,
    via a memorandum if the region cannot complete all the required
    inspections for which the region is responsible by the end of the
    calendar year. This memorandum should contain a brief explanation
    for the reason(s) for deferring the inspection(s), the proposed
    schedule for completing the deferred inspection(s), and the tracking
    method used for completing the required inspections.*

    *In addition, the regions must maintain an inspection tracking
    system which will allow them to track which inspections cannot be
    completed in the calendar year so that no more than four procedures
    are deferred for completion in the next ROP cycle. \[C2\]*

    The regions should use the guidance provided in IMC 0306,
    "Information Technology Support for the Reactor Oversight Process,"
    to track the baseline inspection program completion for each
    calendar year and to ensure that the inspection procedures not
    performed as required by year's end stay within the four-procedure
    allowance (but not more than one procedure not done per plant).

    By mid-February of each calendar year, the Director of DRP must
    notify the Director, DIRS, NRR, via a memorandum which states that
    the required baseline inspections for which the regions are
    responsible have been completed for the previous calendar year
    inspection cycle in accordance with IMC 2515.

    There are several baseline procedures related to plant security and
    safeguards which are scheduled, conducted, and tracked by the NRC
    Office of Nuclear Security and

    Incident Response (NSIR). The following resolutions were reached at
    a conference call among NRR, regions, and NSIR on March 27, 2006, as
    related to the baseline procedures for which NSIR is responsible:

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-   NSIR will issue a separate memorandum to the Director, DIRS, by
    mid-February of each calendar year certifying completion of the
    required baseline inspections for which NSIR is responsible.

-   NSIR will be responsible for entering information into RPS for the
    baseline procedures which are conducted out of HQ from which NSIR is
    responsible.

    A report that contains the data that support completion of the
    respective NSIR or regional required inspections (Report 8 from the
    Reactor Programs System, Item Reporting module) should be provided
    as an attachment to the memorandum submitted by NSIR and the
    regions.

    08.07 [Program Feedback]{.underline}. The reactor inspection program
    is expected to be dynamic and to respond to changes in the nuclear
    power industry and operational experience. Therefore, the program
    office expects the regions and inspectors to identify problems in
    implementing the program, and to recommend changes to the program
    for consideration by the program office. Any such feedback and
    recommendations should be submitted to IRIB through the associated
    regional office using the ROP feedback process (IMC 0801).

    2515-09 INTEGRATED INSPECTION PLANS

    Regional offices must develop annual site-specific inspection plans
    consistent with the inspection planning module of the Reactor
    Program System (RPS) to help manage inspection resources and monitor
    the inspection programs. Under circumstances where the operation of
    multiple units at a site is not comparable (e.g., Salem/Hope Creek),
    the inspection plan should be specific for each unit. The regional
    integrated inspection plan (i.e., the integration of individual site
    or unit plans) should project the planned inspection activities and
    available resources for all sites for at least the next 18 months.
    The integrated plan should also provide for a summary of the
    fraction of regional resources allocated to each of the individual
    program elements discussed in section 2515-06 of this manual chapter
    for each site.

    Planning significant alterations to the baseline inspection program
    for a plant's annual inspection plan to accommodate the plant's
    particular situation needs the concurrence of the Chief, Inspection
    Program Branch. Significant alterations include treating a
    multi-unit site as separate single unit sites, or increasing or
    decreasing the frequency of inspections or sample sizes from those
    stated in the baseline inspection procedures. The factors to
    consider when planning alterations to the baseline inspection
    program at a plant site include (1) known plant activities (or lack
    thereof), (2) the plant's size, design, and age, and (3) complexity
    of the licensee's programs.

    The results of the end-of-cycle and mid-cycle performance reviews,
    conducted in accordance with IMC 0305, shall be used to schedule
    baseline inspections and to determine the amount and focus of
    planned supplemental inspections at each site. The basis for the
    allocation or significant reallocation of resources among the sites
    will be documented. It is expected that the integrated plans will be
    living documents and be reviewed periodically, adjusted, and
    reissued to reflect shifts in plant performance and safety concerns.
    Individual site plans and the regional integrated inspection plan
    should be reviewed by regional management and updated at least
    semiannually as part of the assessment process that is discussed in
    IMC 0305.

    2515-10 INDEPENDENT INSPECTION

    As a general rule, inspections should be conducted in accordance
    with inspection procedures. However, it is not possible to
    anticipate all the unique circumstances that might be encountered
    during the course of a particular inspection and, therefore,
    individual inspectors are expected to exercise initiative in
    conducting inspections, based on their expertise and experience and
    risk insights, as needed to assure that all the inspection
    objectives are met.

    2515-11 INSPECTOR POLICY

    11.01 [Resident Inspector Policy]{.underline}. The resident
    inspectors provide the major onsite NRC presence for direct
    observation and verification of licensees' ongoing activities.
    Appendix D outlines the responsibilities of resident inspectors for
    being aware of major activities and the current status of the plant
    as NRC's onsite representative. The resident inspectors also are
    primary NRC onsite evaluators for events or incidents. See section
    11.3, "Responding to Events and Event Reports," below. The greater
    part of initial event-related inspection effort will be performed by
    the resident inspectors, who may be augmented by other inspectors
    depending on the type and significance of the event. Regional
    managers will decide when normal inspection activities will be
    resumed by those involved with inspecting events.

    The following is the general policy on the extent to which resident
    inspectors are to provide coverage at all sites with one or more
    units licensed for operation.

    1\. For sites with at least two resident inspectors, at least one
    resident inspector or qualified region-based alternate should
    provide site coverage during the regular NRC workday, Monday through
    Friday. The intent of this guidance is that site coverage by someone
    qualified as an inspector not be interrupted for more than three
    consecutive NRC working days (Friday-Tuesday are three consecutive
    working days). Consequently, for extended absences of the resident
    inspectors, such as for attending inspector counterpart meetings,
    arrangements should be made for coverage by region-based staff. The
    region-based inspectors should be qualified in accordance with IMC
    1245, "Inspector Qualifications." However,

    when qualified region-based inspectors are not available, site
    coverage can be provided by an individual that is both knowledgeable
    and experienced in plant operations, and capable of communicating
    with licensee and NRC management on emerging issues and plant
    conditions. In order to maximize NRC\'s efficiency, regional
    management should attempt to schedule region-based inspections for
    this time period.

    2\. The Regional Administrator will be notified when the guidance
    (3 consecutive working days) cannot be met. All exceptions will be
    highlighted in the quarterly update of the regional operating plan.

    3\. For sites with only a single resident inspector (e.g., because
    of a vacancy, training, or extended illness) the guidance described
    above should be followed to the maximum extent possible.

    4\. Inspections performed on Saturdays and Sundays, NRC holidays
    that are concurrent with licensee holidays, and weeknight hours
    between about 10:00 p.m. and 5:00 a.m., are called "deep" backshift
    inspections. There are no set hours for backshift inspections
    because it is expected that the baseline inspection program will
    involve some backshift coverage on a routine basis. Resident
    inspectors should collectively devote at least 50 hours of direct
    inspection and plant status effort per year per site to deep
    backshift inspections. (This is a combined effort; no hours are
    assigned to an individual resident inspector.) These efforts should
    be of at least several hours duration. If deemed appropriate by
    regional management, this coverage may be provided by regional
    inspectors in lieu of or in addition to that performed by resident
    inspectors. Credit may be taken for regional and headquarters
    inspection coverage in achieving deep backshift coverage goals.
    Inspection on holidays will count as deep backshift only if the
    licensee holiday is concurrent with the NRC holiday.

    5\. Inspectors should be sensitive to and avoid being predictable in
    scheduling their backshift and deep backshift coverage. In order to
    maximize the benefit of deep backshift coverage, inspectors should
    not develop a predictable pattern. Effort should be made to spread
    the deep backshift coverage over a variety of days and working
    conditions \[outage, normal operations, weekends, nights (including
    10 pm to 5 am), etc.\].

    6\. There is not a specific goal for performing backshift
    inspections by regional inspectors, but backshift inspections should
    be performed whenever required to complete the intended scope of the
    inspection.

    7.  Regional administrators may permanently assign resident
        inspectors (RIs) to a site up to [twelve months]{.underline}
        prior to the end of the tour of the incumbent inspector. This
        limited "early reassignment" of the resident inspector position,
        should minimize the interruption in inspector site coverage that
        often occurs during the transition of RIs.

        Regional administrators may permanently assign senior resident
        inspectors (SRIs) to a site up to [six months]{.underline} prior
        to the end of the tour of the incumbent inspector. This limited
        "early reassignment" of the senior resident inspector position
        should minimize the interruption in inspector site coverage that
        often occurs during the transition of SRIs. The "early
        reassignment" of SRIs should be minimized.

        Personnel actions associated with individuals selected for early
        assignment will be the same as those who are assigned to the
        site to fill a vacant resident inspector position. However, the
        regions will use the personnel identification code "PIC" code
        "55\" for SRIs and "PIC" code "56\" for RIs for those who have
        been early assigned. The use of these "PIC" codes for the
        resident inspectors results in the administrative/overhead fees
        not being charged to the site. When the departing RI or Senior
        Resident Inspector (SRI) leaves the site, the regions will
        change the "PIC" code for the early assigned resident inspectors
        to "52\" or "53," as appropriate, within one pay period.

        The regions should closely manage the inspection resources at
        the sites which are impacted by this program, such that the
        resources expended to complete the NRC's baseline inspection
        program are not increased solely as a result of the additional
        resident inspector(s) being assigned to the site.

        11.02 [Regional Inspector Policy]{.underline}. Regional
        inspectors conduct inspections as directed by their supervisors.
        In addition to baseline inspection program procedures, regional
        inspectors often will conduct inspections under other program
        elements described in this chapter. Certain aspects of their
        inspection activity may be conducted in the regional office
        (e.g., portions of procedure review and administrative program
        inspection).

        11.03 [Inspection Coordination]{.underline}. The senior resident
        inspector and the regional Division of Reactor Projects must be
        kept advised of regional and headquarters inspectors' activities
        at the facility. The associated regional branch chief must
        ensure coordination of regional and headquarters inspection
        activities in accordance with IMC 0301, \"Coordination of NRC
        Visits to Commercial Reactor Sites.\"

        Regional and headquarters-based inspectors should contact the
        senior resident inspector before each inspection to get
        information concerning the availability of specific licensee
        personnel and the status of plant conditions that may affect the
        planned inspection. In addition, they should contact the senior
        resident inspector as soon as is convenient after they arrive at
        the site to ensure a coordinated NRC presence at the facility.
        The visiting inspectors should advise the senior resident
        inspector of changes to their planned inspection effort and
        schedule for the exit interview with the licensee. The senior
        resident inspector should inform the regional and headquarters
        inspectors of any unique activities in progress and offer
        specific inspection suggestions. The regional and headquarters
        inspectors should brief the senior resident inspector about the
        results of

        their inspection before the exit meeting with the licensee's
        management. The senior resident inspector (or resident inspector
        in his absence) should attend all exit meetings where
        significant issues are expected to be discussed.

        11.04 [Third Party Assistance]{.underline}. On occasion
        licensees ask inspectors for recommendations for obtaining help
        solving programmatic problems. Inspectors are prohibited from
        recommending the services of individuals or organizations for a
        project under NRC regulatory jurisdiction. Providing such a
        recommendation violates 5 C.F.R. 2635.702, which prohibits
        Federal employees from using public office for endorsement of
        any product, service, or enterprise. For further information
        refer to the Executive Director for Operations' (EDO's) Field
        Policy Manual No. 19, \"Guidance For Recommending Third Party
        Assistance to Licensees,\" which can found at the following
        Internet Web address: http://www.nrc.gov.

        2515-12 GENERAL INSPECTION POLICIES

        12.01 [Management Entrance and Exit Meetings]{.underline}.
        Inspectors are required to meet with licensee management as part
        of every inspection. Region-based inspectors should hold an
        entrance meeting with the senior licensee representative who has
        responsibility for the areas to be inspected. Each inspection
        conducted by resident inspectors and region-based inspectors
        must include discussing inspection results with licensee
        management. At the conclusion of an inspection, inspectors must
        discuss their preliminary findings with the licensee's
        management at a scheduled exit meeting. Management and exit
        meetings with licensee personnel should be scheduled to have the
        minimum impact on other licensee activities necessary to assure
        the safe operation of the plant.

        The duration of exit meetings, the level of detail involved in
        the meetings, and the level of interest of the licensee in the
        exit meeting (as manifested by the number of attendees or their
        positions in the licensee\'s organization) will vary from one
        inspection to another; however, the following guidelines should
        be considered when preparing for exit meetings:

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-   Throughout the inspection process, the principle of \"no surprises\"
    should be observed. Through a combination of regular communications
    during the course of the inspection and pre-exit status meetings
    (for those licensees who wish them) the licensee should have
    knowledge of the issues which will be summarized in the exit meeting
    before the meeting occurs.

-   The inspection exit meeting is an NRC-led meeting convened to allow
    the inspector(s) to present preliminary inspection results to the
    licensee. As such, the NRC representative tasked with leading the
    meeting must maintain control of the meeting, ensuring that the
    discussion remains professional, on-track and efficient. The meeting
    must not be allowed to degrade into a technical debate, a lecture,
    or a discussion of non-inspection-related issues. If the NRC exit
    leader

finds that the purpose of the exit meeting cannot be realized (due, for
example, to an overly argumentative licensee), the meeting should be
terminated and the appropriate NRC manager should be notified.

-   The NRC representative tasked with leading the exit meeting may
    allow the licensee to record the exit meeting (either in audio or
    audio/video formats) provided the NRC is given a copy of the
    recording.

-   The exit meeting should be summary in nature. It is not necessary to
    go into great detail on inspection items that meet regulatory
    requirements; a statement describing the scope of inspection and
    reporting satisfactory performance can suffice.

-   The information presented at an exit meeting is predecisional in
    nature and subsequent management review of the inspection results
    may lead to changes in the characterization of issues; this should
    be made clear at the outset of the meeting. The inspector should
    also point out that if changes are made in the characterization of
    issues, NRC will communicate the changes to the licensee prior to
    the issuance of the inspection report.

-   When findings are involved, the exit meeting should include a
    description of the finding, and the standard which was not met. If
    there is a cross-cutting aspect associated with the finding, it
    needs to be presented at the exit meeting to ensure licensee
    awareness of the cross-cutting aspect.

-   When discussing findings which are potentially greater than green,
    the inspector should communicate the results of the initial SDP
    evaluation or the information needed in order to assess the
    significance.

-   If the licensee expresses strong opinions or disagreement with the
    characterization of an issue presented at the exit meeting, the
    inspector should inform regional management. Such a licensee
    response is not documented in the inspection report.

-   If proprietary information is reviewed in the course of an
    inspection, the inspector should confirm with the licensee at the
    exit meeting that NRC has (or has not) returned proprietary
    materials used during the inspection.

    Time spent on scheduled and periodic entrance and exit meetings
    (including preparing for the meetings) is considered part of
    preparation and documentation of inspections. Entrance meeting time
    is charged to preparation and exit meeting time is charged to
    documentation. Daily communication with licensee management is
    considered to be an integral part of every inspection procedure and
    the time used for such routine communications should be charged to
    the inspection procedures used.

    Communicating inspection observations also is an integral and
    important part of every inspection, whether done daily during the
    course of an inspection, or periodically with status meetings. Many
    licensees have expressed the desire to hear inspector insights
    related to safety/regulatory performance even in instances where
    they do not reach the threshold for documentation in an inspection
    report (see IMC 0612, "Power Reactor Inspection Reports"). When
    deciding which observations and insights to pass on to the licensee,
    inspectors should consider the following:

    1\. Inspectors should share the same insights with their regional
    managers and the senior resident inspector.

    2\. The insights must relate to areas within NRC's jurisdiction and
    responsibilities.

    3\. Comments should be objective and supported with examples when
    possible. Avoid generalizations such as "procedure adherence was
    good." Instead, just state the objective facts: "Procedures were
    followed in each case we observed." Negative observations or
    insights must be supported with specific examples.

    4\. Inspectors should not express an expectation for actions taken
    by licensee managers. The inspector may comment on whether or not
    the actions comply with NRC requirements.

    5\. Inspectors should determine before the exit if the licensee
    wants to hear the observations and insights. If the licensee does
    not want the observations or insights at the exit meeting, the
    inspectors should not discuss them.

    6\. Inspectors should avoid "consulting" for the licensee and not
    advise them on how to improve draft documents or in-process work, or
    pass on to licensees how other licensees do the same thing.

    12.02 [Review of Updated Final Safety Analysis Report
    (UFSAR)]{.underline}.

    For planning inspections, several baseline inspection procedures
    specify reviewing applicable portions of the plant's UFSAR. This
    review is intended to provide the inspectors with design bases
    insights in preparing for inspections and is not intended to be a
    review of UFSAR accuracy. The general focus of the baseline
    inspection program is to monitor licensee performance, therefore
    UFSAR accuracy will not be routinely inspected, although it is a
    source of information for inspections.

    However, the NRC does rely on the accuracy of the UFSAR in making
    informed licensing decisions on changes; therefore limited
    requirements for UFSAR accuracy may be incorporated into specific
    inspection procedures. Perform these inspection requirements as
    directed by the implementing procedure.

    12.03 [Responding to Events and Event Reports]{.underline}. Routine
    events of low significance, such as uncomplicated reactor trips,
    will be followed up by resident or region-based

    inspectors to verify that the events are not complicated by loss of
    mitigation equipment or other factors. This event follow up is part
    of the baseline inspection program, and emphasizes collecting
    information about the event for use by risk analysts in evaluating
    the risk significance of the event to help regional and headquarters
    management determine if a response beyond the baseline program is
    warranted.

    The significance of operational events is evaluated using the
    Conditional Core Damage Probability (CCDP) metric, which best
    reflects the full extent of any loss of defense-in-depth due to the
    event, in conjunction with various deterministic criteria to address
    the most influential related assumptions and uncertainties. The
    significance is determined regardless of whether the cause is due to
    licensee performance or otherwise.

    The agency's response to significant events is described in NRC
    Management Directive 8.3, "NRC Incident Response Program." In
    general, significant operational events may be investigated by
    multi-disciplined Incident Investigation Teams (IITs) that are
    initiated by the EDO, and are comprised of both regional and
    headquarters personnel. Operational events of lesser significance
    may be investigated by Augmented Inspection Teams (AITs) that are
    initiated by Regional Administrators. Regional Administrators may
    also initiate special inspection (SI) teams that use only regional
    personnel. The applicable procedures for AITs and SI teams are
    listed in Appendix C, "Special and Infrequently Performed
    Inspections." In addition, for an event of extraordinary safety
    significance or profound regulatory implications, an Accident Review
    Group may be formed that reports directly to the Commission, as
    described in Management Directive 8.9, "Accident Investigation."

    Licensees often notify inspectors of events or conditions in
    anticipation of the inspectors' interest in the issue, but such
    notifications do not exempt the licensee from reporting events and
    conditions through the required regulatory processes. The licensee
    should be made aware that documents that it gives to inspectors are
    subject to Freedom of Information Act requests and may be placed in
    the Public Document Room.

    In addition to reviewing plant events to determine whether the NRC
    should devote additional effort and resources to respond to the
    event, the baseline inspection program screens for potential risk
    significance and possible future inspection all written event
    reports submitted to the NRC by licensees. The review should be
    acknowledged in an inspection report.

    12.04 [Findings Outside of Inspector's Qualifications]{.underline}.
    Inspectors sometimes identify issues or violations outside of the
    inspector's qualifications or expertise. In these cases the
    inspector is responsible for (1) determining if an immediate threat
    to public or worker health or safety exists, and if one does exist
    to notify licensee management immediately, (2) determining if the
    issue is better addressed by an inspector with different
    qualifications (i.e., a specialist inspector). Inspectors may follow
    issues outside of their qualifications or expertise with the
    concurrence of a regional manager responsible for the area
    associated with the issue and the inspector's supervisor.

    Such issues are associated with the most applicable cornerstone and
    inspectable area,

    regardless of the baseline inspection procedure in use when the
    issue is identified. The inspector's time associated with the issue
    is charged to the baseline procedure that best corresponds to the
    issue. If the issue is found during inspections other than baseline
    inspections, the time is charged to the procedure in use.

    12.05 [Communication With Local Public Officials]{.underline}. *As a
    matter of management philosophy, the NRC maintains an "open door"
    policy with regard to access by the public or state and local
    officials to the NRC staff or to publicly available electronic
    documentation concerning a licensee\'s performance. Some local
    officials may desire increased interaction with the NRC\'s regional
    offices and Resident Inspectors. The degree of interaction that is
    considered necessary to enhance openness in the NRC is expected to
    vary widely dependant upon the situation at each plant. In each case
    where inspectors are utilized for this purpose, regional management
    must carefully balance the use of inspection resources to complete
    inspections with the need to enhance openness. Any meeting between
    local emergency preparedness officials and the NRC must be
    coordinated with the Federal Emergency Management Agency (FEMA) in
    accordance with the Memorandum of Understanding between FEMA and the
    NRC*. \[C1\]

    2515-13 POST-LICENSE RENEWAL INSPECTIONS

    13.01 [Post-License Renewal Inspection Effort]{.underline}.
    Inspection Procedure 71003, "Post-Approval Site Inspection for
    License Renewal," is to be implemented to verify that license
    renewal programs and activities have been implemented in accordance
    with the requirements of Title 10 of the Code of Federal
    Regulations, Part 54. This inspection will be performed as a team
    inspection effort and will be performed just once per unit. For that
    reason IP 71003 is listed in Appendix C to this manual chapter.

    13.02 [Budget Planning]{.underline}. IP 71003 is not part of the
    baseline inspection program and is not budgeted as part of the
    baseline inspection program. Therefore, to ensure that inspector
    resources are available to complete this IP when required, planning
    for its performance must be projected a minimum of three years in
    advance of the fiscal year in which it is planned to be used.

    2515-14 INSPECTION PROGRAM MODIFICATIONS IN EVENT OF A PANDEMIC

    In the event of a pandemic, the NRC's Pandemic Response Plan (PRP)
    requires that aspects of the inspection program, identified as
    priority functions, be maintained. Additionally, the NRC's PRP
    allows modifications to less critical aspects of the inspection
    program in order to address limited inspection resources.

    Therefore, "supplemental" and "generic safety" inspections may be
    postponed when authorized by the regional administrator. Baseline
    inspection activities may be reduced commensurate with available
    inspection and licensee resources. Inspections of reactor and
    security events (e.g., special inspections, AITs, and IITs) will
    continue. If necessary, the baseline inspection program will be
    reduced such that only monitoring of key plant parameters and
    activities will be performed by inspectors, if available, or by
    remote means, if no inspectors are available. Normal inspection
    activities will resume once the pandemic has passed and reasonable
    efforts will be made to complete missed baseline inspection
    activities before the end of the calendar year. Appendix E of this
    IMC provides additional background and basis for these actions and
    implementation details.

    END

    Appendices:

    A. Risk-Informed Baseline Inspection Program

    B. Supplemental Inspection Program

    C. Generic, Special, and Infrequent Inspections

    D. Plant Status

    E. Inspection Program Modifications in the Event of a Pandemic

    ATTACHMENT 1

    CHART OF ROP CYCLES

  ----------- ------------ ------------ ------------ ------------ ------------ ------------ ------------
  ROP Year    1            2            3            4            5            6            7

  Start Date  04/01/2000   04/01/2001   01/01/2002   01/01/2003   01/01/2004   01/01/2005   01/01/2006

  End Date    03/31/2001   12/31/2001   12/31/2002   12/31/2003   12/31/2004   12/31/2005   12/31/2006

  Biennial    1^st^                     2^nd^                     3^rd^                     4^th^
  Cycles      Biennial                  Biennial                  Biennial                  Biennial

  Triennial   1^st^                                  2^nd^                                  3^rd^
  Cycles      Triennial                              Triennial                              Triennial
  ----------- ------------ ------------ ------------ ------------ ------------ ------------ ------------

  ----------- ------------ ------------- ------------ ------------ ------------ ------------ ------------
  ROP Year    8            9             10           11           12           13           14

  Start Date  01/01/2007   01//01/2008   01/01/2009   01/01/2010   01/01/2011   01/01/2012   01/01/2013

  End Date    12/31/2007   12/31/2008    12/31/2009   12/31/2010   12/31/2011   12/31/2012   12/31/2013

  Biennial    4^th^        5^th^                      6^th^                     7^th^        
  Cycles      Biennial     Biennial                   Biennial                  Biennial     

  Triennial   3^rd^                                                                          
  Cycles      Triennial                                                                      

                           4^th^                                   5^th^                     
                           Triennial                               Triennial                 
  ----------- ------------ ------------- ------------ ------------ ------------ ------------ ------------

NOTE: The 3^rd^ and 4^th^ triennial cycles overlap in CY2008. If a
triennial inspection is performed in CY2008, the inspection counts for
both the 3^rd^ and 4^th^ triennial cycles and next required inspection
will take place during the 5^th^ triennial cycle.

ATTACHMENT 2

Revision History - IMC 2515

  ------------ ------------ ------------------------- ---------- ------------ ------------
  Commitment   Issue Date   Description of Change     Training   Training     Comment
  Tracking                                            Needed     Completion   Resolution
  Number                                                         Date         Accession
                                                                              Number

  C1           07/09/2002   Revised to add a new      NO         N/A          N/A
                            section (12.05) which                             
                            provides guidance on                              
                            increased communication                           
                            between the regional                              
                            offices/resident                                  
                            inspectors and local                              
                            public officials. This                            
                            change was made                                   
                            specifically to satisfy a                         
                            commitment made by NRR to                         
                            resolve a concern which                           
                            arose following the IP2                           
                            tube rupture event where                          
                            the local county official                         
                            wanted increased                                  
                            communication with the                            
                            resident inspectors.                              

  N/A          01/24/2003   Revised to add a section  NO         N/A          N/A
                            04.07 to define baseline                          
                            inspection program                                
                            completion for an ROP                             
                            annual inspection cycle.                          
                            Section 13.02 was also                            
                            added to discuss budget                           
                            planning to perform IP                            
                            71003, "Post-Approval                             
                            Site Inspection for                               
                            License Renewal."                                 
  ------------ ------------ ------------------------- ---------- ------------ ------------

+--------+--------+-------------------------+-----+-------+------------+
| N/A    | 02/0   | Revised to reflect      | NO  | N/A   | N/A        |
|        | 2/2004 | recommended changes to  |     |       |            |
|        |        | define the periodicity  |     |       |            |
|        |        | of biennially and       |     |       |            |
|        |        | triennially. The        |     |       |            |
|        |        | section of inspection   |     |       |            |
|        |        | policy has been revised |     |       |            |
|        |        | to allow early          |     |       |            |
|        |        | assignment of           |     |       |            |
|        |        | replacement senior and  |     |       |            |
|        |        | resident inspectors to  |     |       |            |
|        |        | a site to prior to the  |     |       |            |
|        |        | end of the tour of the  |     |       |            |
|        |        | incumbent inspector.    |     |       |            |
+--------+--------+-------------------------+-----+-------+------------+
| N/A    | 03/3   | Revised to reflect the  | NO  | N/A   | N/A        |
|        | 0/2005 | inspection program      |     |       |            |
|        |        | policy regarding        |     |       |            |
|        |        | baseline inspection     |     |       |            |
|        |        | credit for Operational  |     |       |            |
|        |        | Safety Review Team      |     |       |            |
|        |        | Effort as described in  |     |       |            |
|        |        | memorandum addressed to |     |       |            |
|        |        | the Commission dated    |     |       |            |
|        |        | July 16, 2003.          |     |       |            |
+--------+--------+-------------------------+-----+-------+------------+
| C2     | 07/2   | Revised to address      | NO  | N/A   | N/A        |
|        | 8/2005 | recommendations from a  |     |       |            |
|        |        | Office of Inspector     |     |       |            |
|        |        | General's audit of the  |     |       |            |
|        |        | NRC's baseline          |     |       |            |
|        |        | inspection program      |     |       |            |
|        |        | (OIG-05-06):            |     |       |            |
|        |        |                         |     |       |            |
|        |        | \- provided basis and   |     |       |            |
|        |        | rationale for the       |     |       |            |
|        |        | baseline inspection     |     |       |            |
|        |        | procedure sample size,  |     |       |            |
|        |        | including a discussion  |     |       |            |
|        |        | of when, or why, to use |     |       |            |
|        |        | more than minimum       |     |       |            |
|        |        | samples.                |     |       |            |
|        |        |                         |     |       |            |
|        |        | \- provided additional  |     |       |            |
|        |        | management guidance for |     |       |            |
|        |        | assigning inspectors to |     |       |            |
|        |        | perform inspection      |     |       |            |
|        |        | procedures to ensure    |     |       |            |
|        |        | that inspectors are     |     |       |            |
|        |        | adequately qualified    |     |       |            |
|        |        | for their assignments.  |     |       |            |
|        |        |                         |     |       |            |
|        |        | \- improved inspection  |     |       |            |
|        |        | guidance on whether     |     |       |            |
|        |        | performance of one      |     |       |            |
|        |        | inspection procedure    |     |       |            |
|        |        | sample can be counted   |     |       |            |
|        |        | as a sample for         |     |       |            |
|        |        | another.                |     |       |            |
|        |        |                         |     |       |            |
|        |        | \- clarified            |     |       |            |
|        |        | expectations and        |     |       |            |
|        |        | requirements for which  |     |       |            |
|        |        | inspection procedures   |     |       |            |
|        |        | cannot be deferred,     |     |       |            |
|        |        | plants where procedures |     |       |            |
|        |        | cannot be deferred,     |     |       |            |
|        |        | criteria for deferring  |     |       |            |
|        |        | a procedure and         |     |       |            |
|        |        | reporting requirements  |     |       |            |
|        |        | when inspections are    |     |       |            |
|        |        | deferred.               |     |       |            |
|        |        |                         |     |       |            |
|        |        | \- added a program      |     |       |            |
|        |        | requirement for regions |     |       |            |
|        |        | to maintain an          |     |       |            |
|        |        | inspection tracking     |     |       |            |
|        |        | system so that no more  |     |       |            |
|        |        | than four inspection    |     |       |            |
|        |        | procedures are deferred |     |       |            |
|        |        | in a calendar year.     |     |       |            |
+--------+--------+-------------------------+-----+-------+------------+
| C3     | 11/2   | Revised to address      | NO  | N/A   | N/A        |
|        | 8/2005 | recommendations from a  |     |       |            |
|        |        | Office of Inspector     |     |       |            |
|        |        | General's audit of the  |     |       |            |
|        |        | NRC's baseline          |     |       |            |
|        |        | inspection program      |     |       |            |
|        |        | (OIG-05-06):            |     |       |            |
|        |        |                         |     |       |            |
|        |        | Revised to clarify a    |     |       |            |
|        |        | ROP program expectation |     |       |            |
|        |        | that inspection         |     |       |            |
|        |        | findings which are      |     |       |            |
|        |        | determined to be minor  |     |       |            |
|        |        | do not need to be nor   |     |       |            |
|        |        | shall be tracked or     |     |       |            |
|        |        | trended by either       |     |       |            |
|        |        | inspectors or regional  |     |       |            |
|        |        | managers.               |     |       |            |
+--------+--------+-------------------------+-----+-------+------------+
| N/A    | 01     | Revised to address      | NO  | N/A   | M          |
|        | /26/07 | changes to the          |     |       | L063460228 |
|        |        | inspection program in   |     |       |            |
|        | CN     | the event of a pandemic |     |       |            |
|        | 07-004 | and to clarify baseline |     |       |            |
|        |        | inspection program      |     |       |            |
|        |        | completion reporting    |     |       |            |
|        |        | requirements by the     |     |       |            |
|        |        | regions and NSIR.       |     |       |            |
|        |        |                         |     |       |            |
|        |        | Completed 4 year        |     |       |            |
|        |        | historical change       |     |       |            |
|        |        | notice search.          |     |       |            |
+--------+--------+-------------------------+-----+-------+------------+
| N/A    | 09     | IMC 2515 has been       | NO  | N/A   | M          |
|        | /20/07 | revised to add          |     |       | L071560246 |
|        |        | additional guidance on  |     |       |            |
|        | CN     | the conduct of exit     |     |       |            |
|        | 07-029 | meetings.               |     |       |            |
+--------+--------+-------------------------+-----+-------+------------+
| N/A    | 05     | Added Attachment 1      | NO  | N/A   | N/A        |
|        | /01/08 | "Chart of ROP Cycles"   |     |       |            |
|        |        |                         |     |       |            |
|        | CN     |                         |     |       |            |
|        | 08-014 |                         |     |       |            |
+--------+--------+-------------------------+-----+-------+------------+

[^1]: 1 For ROP cycles, see Attachment 1

[^2]: 1