**NRC INSPECTION MANUAL** DWM

MANUAL CHAPTER 2561

DECOMMISSIONING POWER REACTOR INSPECTION PROGRAM

2561‑01 PURPOSE

To establish the inspection policy and guidance for decommissioning
power reactors for the Offices of Nuclear Reactor Regulation (NRR) and
Nuclear Material Safety and Safeguards (NMSS).

2561‑02 OBJECTIVES

02.01 To obtain information through direct observation and verification
of licensee activities to determine whether the power reactor is being
decommissioned safely, that spent fuel is safely stored onsite or
transferred to another licensed location, and that site operations and
license termination activities are in conformance with applicable
regulatory requirements, licensee commitments, and management controls.

02.02 To ensure that the licensee\'s systems and techniques for
decommissioning and license termination activities are adequate and in
accordance with regulatory requirements. These systems include, in part,
management and organization effectiveness; self-assessment, auditing,
and corrective actions; design control; maintenance and surveillance;
radiation protection; radioactivity measurements; and, effluent
controls.

02.03 To identify declining trends in performance and perform
inspections to verify that the licensee has resolved the issue(s) before
performance declines below an acceptable level.

02.04 To provide for effective allocation of resources for the
inspection of Part 50 power reactors following permanent cessation of
operation.

2561‑03 APPLICABILITY

This program is to be implemented following the certification date for
the removal of all nuclear fuel from the reactor vessel (10 CFR
50.82(a)(1)(ii)) and is to continue until license termination.

2561‑04 DEFINITIONS

[Permanent Cessation of Power Operations]{.underline}. The permanent
cessation of power operations is a licensee determination certified to
the NRC in writing in accordance with 50.82(a)(1)(i). Following this
certification, the licensee would possess the power reactor structures,
systems, and components, site, and related radioactive material, but be
prohibited by regulation from operating the reactor.

[Decommissioning]{.underline}. The process of removing a reactor
facility safely from the operating mode to a permanent shutdown
condition and reducing the residual radioactivity to a level that
permits \-- (1) release of the property for unrestricted use and
termination of the license; or, (2) release of the property under
restricted conditions and termination of the license.

[Post‑Operation Transitional Phase]{.underline}. The interval between
the final reactor shutdown and establishment of a safe stable
permanently shut-down defueled condition based on the completion of
regulatory and safety milestones (see NRR Office Instruction COM-101 and
NMSS Policy and Procedures Letter P&PL 1-77). During this phase, the
licensee would establish safe shutdown conditions and could conduct
activities to dismantle and decontaminate structures, systems, and
components or place them in a decommissioning configuration. Also, the
licensee will be implementing policies, programs, and plans to reflect
the permanently shut-down and defueled condition of the facility.

[Post-Shutdown Decommissioning Activities Report]{.underline}. A
licensee\'s report required by 10 CFR 50.82(a)(4) that provides a
description of planned decommissioning activities, a schedule for their
accomplishment, an estimate of the decommissioning costs, and a
discussion that provides the reasons for concluding that the
environmental impacts associated with site-specific decommissioning will
be bounded by appropriate previously issued environmental impact
statements.

[Major Decommissioning Activity]{.underline}. For a nuclear power
facility, any activity that results in permanent removal of major
radioactive components, permanently modifies the structure of the
containment (for PWRs, primary containment; for BWRs, the primary and
secondary containments), or results in the dismantling of components or
systems for shipment containing \"greater than Class C\" waste (10 CFR
61.55). The licensee is precluded by regulation from conducting major
decommissioning activities until 90 days after the NRC has received the
Post-Shutdown Decommissioning Activities Report (PSDAR) submittal and
the 50.82(a)(1) certifications have been submitted.

[Major Radioactive Component]{.underline}. For a nuclear power plant,
this includes the reactor vessel and internals, steam generators,
pressurizer, large bore reactor coolant system piping, and other large
components that are radioactive to a comparable degree.

[DECON]{.underline}. The decommissioning method of removing equipment,
structures, and portions of a facility and site containing radioactive
contaminants or decontaminating them to a level that permits release of
the property and termination of the license.

[SAFSTOR]{.underline}. The decommissioning method of placing and
maintaining the nuclear facility in a condition that allows the facility
to be safely stored and subsequently decontaminated utilizing the DECON
method, to permit the release of the property and termination of the
license.

[ENTOMB]{.underline}. A decommissioning alternative in which radioactive
contaminants are encased in a structurally long-lived material. The
entombed structure is appropriately maintained and continued
surveillance is performed until the radioactivity decays to a level
permitting release of the property and license termination.

[Licensing Basis]{.underline}. Is the set of NRC requirements applicable
to a specific plant and a licensee\'s written commitments for ensuring
compliance with and operation within applicable NRC requirements and the
plant-specific design basis (including all modifications and additions
to such commitments over the life of the license) that are docketed and
in effect. The licensing basis includes the NRC regulations and the
appendices thereto; orders; license conditions; exemptions; and
technical specifications. It also includes the plant-specific
design-basis information defined in 10 CFR 50.2 as documented in the
most recent final safety analysis report as required by 10 CFR 50.71 and
the licensee\'s commitments remaining in effect that were made in
docketed licensing correspondence such as licensee responses to NRC
bulletins, generic letters, and enforcement actions, as well as,
licensee commitments documented in required certifications and
submittals, NRC safety evaluations, and licensee event reports.

[Technical Specifications (TS)]{.underline}. An appendix to the facility
license that contains safety requirements, bases, safety limits,
limiting conditions for operation, and administrative requirements to
provide assurance that decommissioning can be conducted safely and in
accordance with regulatory requirements. Terminology such as \"defueled
TSs\" or \"decommissioning TSs\" has been used to describe TSs that have
been amended to reflect the permanent shutdown condition of the reactor.

[Possession-Only License]{.underline}. A possession-only licensee (POL)
was a name for the license retained by a Part 50 licensee that was
amended to reflect the permanent shutdown condition of the facility and
the licensee\'s continued possession of nuclear fuel.

[License Termination Plan]{.underline}. A plan required by 10 CFR
50.82(a)(9) that includes, in part, a site characterization;
identification of remaining dismantlement activities; plans for site
remediation; detailed plans for the final radiation survey; a
description of the end use of the site, if restricted; an updated
site-specific estimate of remaining decommissioning

costs; and, a supplement to the environmental report describing any new
information or significant environmental change associated with site
decommissioning.

[Independent Spent Fuel Storage Installation (ISFSI)]{.underline}. A
complex designed and constructed for the interim storage of spent
nuclear fuel and other radioactive materials associated with spent fuel
storage. An ISFSI may either have a general license (10 CFR 72, Subpart
K) for a facility located at an operating Part 50 reactor licensee or a
site-specific license (10 CFR 72, Subpart C).

[Quarterly (Qtr)]{.underline}. Performed four times each year so that
the interval between inspections is no less than 2 months or no more
that 4 months.

[Semi-annual (SA)]{.underline}. Performed two times each year so that
the interval between inspections is no less than 4 months and no more
than 8 months.

[Annual (A)]{.underline}. Performed every year so that the interval
between inspections is no less than 9 months and no greater than 15
months.

[When Required (WR)]{.underline}. Performed when the activity or event
occurs at the facility as specified in the guidance section of the
specific inspection procedure.

2561‑05 RESPONSIBILITIES AND AUTHORITIES

05.01 [Director, Office of Nuclear Reactor Regulation and Director,
Office of Nuclear Materials Safety and Safeguards]{.underline}. Provides
overall direction for the decommissioning power reactor inspection
program for assigned power reactor plants.

05.02 [Chief, Decommissioning Branch]{.underline}. Coordinates,
develops, and implements decommissioning power reactor inspection
requirements and policies.

05.03 [Chief, Inspection Program Branch]{.underline}. Provides overall
agency lead for the Reactor Oversight Process and concurs in changes to
IMC 2561 that impacts or potentially affects the inspection of
commercial power reactors in the Post-Operation Transition Phase.

05.04 [Regional Administrator]{.underline}. In concert with
headquarters, directs the implementation of the inspection program for
decommissioning power reactors. Ensures, within budget limitations, that
the regional office staff includes adequate numbers of inspectors in
various disciplines to carry out the inspection program as assigned and
described in this chapter. Determines the need for the temporary
assignment of an inspector at a facility that has permanently shutdown
and the duration and scope of this inspection coverage. Applies
inspection resources, as necessary, to deal with issues and problems
that arise at specific facilities undergoing decommissioning.

2561‑06 DECOMMISSIONING INSPECTION PROGRAM

06.01 [Program Discussion]{.underline}

The decommissioning power reactor inspection program describes the
inspection of decommissioning Part 50 power reactor licensees. This
program should be implemented on or shortly after the licensee-assigned
date for the permanent and safe removal of all fuel from the reactor
vessel and is to continue during all phases of decommissioning.

The decommissioning of power reactors may take a few years or up to 60
years depending on a number of considerations. Further, decommissioning
activities may range from relative inactivity (e.g., SAFSTOR) to
activities that have a greater potential to challenge public health and
safety and the environment (e.g., DECON). Because of this wide range of
decommissioning and safety considerations, this manual chapter
promulgates inspection and inspection program requirements and guidance
necessary to provide reasonable assurance that NRC regulatory oversight
contributes to public health and safety. This inspection program focuses
on ensuring that:

-   Licensee documents are adequately implemented, maintained, and
    reflect the status of decommissioning.

-   Licensee activities, organization, and controls are effective to
    provide reasonable assurance that decommissioning can be conducted
    safely and in accordance with regulatory requirements.

-   NRC staff project oversight and inspection resources are effective,
    consistent, and appropriately focused.

-   Licensee radiation and radioactivity measurement programs provide
    accurate quantification and classification of radioactivity.

These fundamental objectives are promoted by the inspection effort
described and required by the decommissioning core inspections listed in
Appendix A. This effort is divided into functional area assessments to
inspect licensee performance, identify performance trends, preclude
problems, identify weaknesses, and foster corrective actions to
contribute to public health and safety and the protection of the
environment. The inspection program also provides appropriate latitude
for NRC management to administer, plan, and implement site-specific
master inspection plans commensurate, in part, with licensee
performance, site activities, and safety.

The decommissioning inspection program is comprised of two major program
elements: core inspections and discretionary inspections (i.e., reactive
and initiative inspections). The core inspection program element,
detailed in Appendix A, is to be performed at all decommissioning power
reactors. Deviations from the core program should be handled as
discussed in Section 06.04, \"Master Inspection Plans.\" Decommissioning
core inspections include, but are not limited to: organization and
management controls; quality assurance; spent fuel wet storage and
handling, if necessary; maintenance and surveillance; radiation
protection; security; and, safety evaluations. Other core procedures
include those applicable to site and license termination activities and
the transportation of irradiated fuel and other radioactive materials.
The inspection procedures will be reviewed by headquarters and the
regions and revised by headquarters, as necessary, to enhance the
program for the early identification of decommissioning safety problems.

The direct inspection effort associated with the implementation of the
core inspection procedures should, in part, be dependent on the
decommissioning activities being planned or performed at the facility.
For planning purposes, the range of decommissioning activities are
grouped into six categories. These categories are defined as follows:

1\. Post-Operation Transition Phase

2\. Actively Decommissioning, Fuel in the Spent Fuel Pool

3\. Actively Decommissioning, No Fuel in the Spent Fuel Pool

4\. SAFSTOR, Fuel in the Spent Fuel Pool

5\. SAFSTOR, No Fuel in the Spent Fuel Pool

6\. Final Surveys Underway, No Fuel in the Spent Fuel Pool

It is expected that the category, and thus the appropriate direct
inspection effort for a facility, will change over time, based on the
progress of decommissioning at the facility (i.e., an actively
decommissioning facility would be expected to go from category 1 to 2
and eventually to 6 as decommissioning progresses).

Appendix B inspection procedures lists the discretionary inspections
that could be performed (as determined by management) or used as
guidance during the conduct of the core program. Appendix B procedures
include generic safety reviews, team inspections, and functional area
assessments that focus on radiation protection, radioactive material
control, transportation, and other disciplines. These inspection
procedures are referenced from Manual Chapters 2515, 2600, and 2800 to
provide insight into the allocation of resources, completion of
inspection procedures, and follow-up of open items. Discretionary
inspections should augment the core inspection program and assess
particular functional areas, safety concerns, or aspects of licensee
performance.

In summary, the inspection program for power reactor facilities that
have permanently shutdown emphasizes a balanced look at a cross section
of licensee activities important to the conduct of safe decommissioning.
Licensee decommissioning programs and procedures should be assessed to
ensure that they afford a comparable level of quality, rigor, and
effectiveness as those in existence during reactor power operations. The
inspection program also provides Regional Administrators flexibility in
the application of inspection resources to deal with issues and problems
at specific plants.

06.02 [Inspection Procedures]{.underline}

Inspection procedures detailed in Appendix A are either explicitly
applicable to decommissioning power reactors or based on the use of
inspection procedures described in Manual Chapters 2515, 2600, or 2800.
Decommissioning inspection procedures are either core or discretionary,
as described in Section 06.01. Although all inspection requirements need
not be completed for every particular inspection, the objectives of the
inspection procedure shall be met.

06.03 [Direct Inspection Effort]{.underline}

The estimation of inspection hours in each inspection procedure for
decommissioning power reactor licensees refers to the estimated average
times needed to adequately complete inspection procedure requirements at
one unit actively pursuing dismantlement, decontamination,
decommissioning, or as stated in the applicable inspection procedure.
Deviations from the provided estimate should be made based on, in part,
licensee performance, multi-unit site and resident inspection
considerations, the type and schedule of decommissioning activities
being conducted by the licensee, and the radiological source term.

Inspection hour estimates are based on current experience and will be
reviewed and revised periodically. It is expected that actual inspection
hours will vary from site to site and from the estimate depending on the
status of decommissioning. Inspection hours shall be pre-planned,
tailored to the particular licensee, and scheduled. The actual
inspection hours used for a particular inspection procedure shall be
accurately recorded. Planning of estimated inspection hours for
multi-unit sites undergoing decommissioning shall be addressed on a
case-by-case basis as discussed in Section 06.05, \"Periodic Management
Review of Site-Specific Master Inspection Plans.\"

06.04 [Master Inspection Plans]{.underline}

The regional and headquarters staffs should develop site-specific master
inspection plans (MIP) for reactor power facilities undergoing
decommissioning consistent with the guidance in this manual chapter
using the inspection procedures listed in Appendix A and B of this
manual chapter, or an applicable Temporary Instruction (TI), if
necessary. One method could be to review planned licensee activities for
the up-coming year or to the extent reasonably possible based on the
schedular detail in the PSDAR and discussions with licensee management.
The site‑specific master inspection plans should facilitate the
efficient allocation of inspection resources, list the inspection effort
planned for each IP or TI, identify the dates of the inspection, and be
specific for each facility. Master inspection plans should be reviewed
every 6-12 months for a facility characterized as actively
decommissioning or conducting final surveys (Categories 1, 2, 3, and 6)
or every 12-24 months for a SAFSTOR facility (Categories 4 or 5). Master
inspection plans may be incorporated into the Reactor Program System
(RPS). Note: In RPS, for decommissioning power reactors, core
inspections are scheduled as Other Activities.

Every core inspection procedure should be accomplished as described in
this manual chapter and should be placed in a site-specific master
inspection plan. Discretionary procedures could be used to augment the
site-specific inspection plan or used as guidance (and not listed in the
MIP). Discretionary IPs or TIs may be used in lieu of core-designated
IPs as long as the functional area assessments are equivalent. The scope
of a particular IP and its respective requirements may be adjusted by
management, as appropriate, to satisfy the objectives of this manual
chapter as it applies to the specific plant being inspected. A TI may be
required during decommissioning and will be determined on a case‑by‑case
basis. If a core functional area inspection can not or will not be
performed, the region shall inform the headquarters staff in writing.

The following factors should be considered while developing and
implementing a site-specific master inspection plan:

a.  [Design]{.underline}. Some power reactors will have unique designs,
    configurations, and environmental considerations that would bias an
    inspection effort to specific areas of potential concern. For
    example, unique or challenging hydrological conditions at a site
    (such as diversion of the radiological effluent stream, excavation
    of contaminated soils from below a water table, or dredging of soils
    from outfalls or intakes) or shared systems (as discussed below)
    between reactor units, may warrant an increased inspection effort.
    Similarly, technologically advanced contamination removal methods,
    dismantlement techniques, or transportation packaging may require
    enhanced NRC monitoring.

b.  [Plant Status]{.underline}. Plant status will vary from reactor unit
    to unit and depend, in part, on the phase of decommissioning. For
    example, even if a power reactor is in long-term storage, the
    licensee could elect to change system(s) operation, configuration,
    or design to enhance performance or efficiency, or reduce costs.
    These plant status changes may then change the NRC inspection effort
    listed in Appendix A. The plans should also take into account the
    licensee\'s spent fuel storage location and transfer plans;
    criticality and decay heat removal considerations; decommissioning
    fund status; and, planned facility and environmental changes.

c.  [Licensee Performance, Management, and Decommissioning
    Scheduling]{.underline}. The site-specific master inspection plans
    should also be based on licensee performance, staffing plans,
    effectiveness of management oversight and contractor control, and
    the timing and scheduling of significant decommissioning activities.
    Other elements such as the loss of licensee technical expertise and
    nuclear experience should factor into the development of a
    site-specific inspection plan. For example, a lack of detail or
    missing licensee radiological release records (10 CFR 50.75); a
    marked reduction in staff experience or technical expertise or
    significant changes in quality assurance management; or, significant
    problems that originated during reactor power operations may require
    additional NRC inspection assessment.

d.  [Multi-Unit Sites]{.underline}. The inspection plan should take into
    account whether the decommissioning facility shares systems,
    structures, and components (SSCs) with other operating or
    decommissioning units on site. These SSCs could include service
    water, fire water, electrical systems, and radiological effluent
    streams. The amount of direct inspection should be tailored to take
    advantage of the plans, programs, and procedures shared among the
    units or increased to provide assurance that potential
    vulnerabilities are understood and mitigated.

Inspections conducted early in decommissioning should be implemented as
described in Appendix A, \"Core Inspection Procedures for
Decommissioning Power Reactors,\" and should: (1) provide sufficient
evidence to confirm that the licensee can or will safely transition into
decommissioning; (2) verify that procedures, programs, and facility
operation implement license requirements and reflect the current
licensing bases as described in the Final Safety Analysis Report, PSDAR,
or other applicable licensing basis documentation; (3) confirm that
management control and oversight are adequate; and, (4) take appropriate
credit for NRC inspections conducted while the unit was operating.

For power reactors in a true SAFSTOR condition, it is not expected that
the licensee will undertake activities that have the potential to
adversely impact public health and safety or the environment. Therefore,
the inspection effort is likely to be at the lower end of the expected
range of decommissioning inspection effort and still maintain an
acceptable, periodic NRC presence at the site. Again, based on NRC
assessment of licensee performance (see Section 06.05) and the conduct
of facility activities, appropriate changes to the inspection plan,
procedure periodicity, or level of effort should be implemented.
Similarly, although a power reactor licensee is in long-term storage,
they may elect to incrementally dismantle their SSCs over the course of
years through the periodic implementation of the 10 CFR 50.59 process.
To account for incremental dismantlement or a facility in SAFSTOR, the
decommissioning inspection program conservatively assumes that licensee
procedures and controls and staff knowledge and cognizance of Part 50
requirements could diminish over time and anticipates that the direct
inspection effort for these sites could increase to a value at the upper
end of the expected range of decommissioning inspection effort.

For a licensee planning or preparing to actively dismantle,
decontaminate, or decommission their facility after a long period of
relative inactivity, the NRC staff expects that the NRC\'s inspection
effort will also accelerate commensurate with licensee activities and
may approach a level of effort for actively decommissioning facilities.

For a licensee planning or conducting irradiated fuel handling
activities, direct inspection effort should be based on the values
provided in Appendix A. Inspection of spent fuel handling could consist
of two phases: an initial inspection and in-process inspections. The
initial inspection could review, in part, training, qualification,
engineered features, and management controls prior to the conduct of the
fuel handling activities. This review should be coordinated with
NMSS/SFPO and their implementation of IPs 60851, 60852, 60853, 60854
60855, 60856, and 81001 such that oversight is staggered, complementary,
and focused on, in part, spent fuel pool activities, conduct of in-plant
operations, and heavy load controls. These NMSS/SFPO dry fuel storage
IPs shall be accomplished in accordance with Manual Chapter 2690,
\"Inspection Program for Dry Storage of Spent Reactor Fuel at
Independent Spent Fuel Storage Installations.\"

In-process inspections should also be coordinated with NMSS/SFPO. These
inspections should include, in part, the in-field inspection of: all
certified fuel handler crews that will conduct activities in the near
future; management oversight and control; quality assurance and
resolution of corrective actions; and, implementation of regulatory
requirements and licensee procedures. Again, NMSS/SFPO inspection
requirements should complement the inspection effort required by this
manual chapter.

The level of NRC inspection oversight for irradiated fuel handling
during decommissioning should be comparable with that conducted for an
operating power reactor, as detailed in Appendix A. This decommissioning
inspection effort could be changed based on licensee performance, the
magnitude of the source term, or the licensee\'s implementation of
engineered design or safety features to preclude or mitigate the
probability and/or consequences of a irradiated fuel handling event.
Similarly, following long periods of fuel handling inactivity, the level
of NRC inspection oversight could approach or exceed that of an
operating power reactor facility.

06.05 [Periodic Management Review of Site-Specific Master Inspection
Plans]{.underline}

The staff should periodically review the site-specific master inspection
plans and adjust the plans to reflect inspection findings or changes in
plant status and decommissioning activities. During these plan reviews,
regional management should take the lead (with headquarters involvement)
in the assessment of decommissioning licensee performance and use these
insights as one of the many possible justifications to change the
site-specific master inspection plan (i.e., increased or decreased
inspection effort, schedule changes, or deletions). This review of
licensee performance should focus on the four major inspection areas of
the decommissioning power reactor inspection program: facility
management and control; decommissioning support activities; spent fuel
safety; and, radiological safety. The regions could coordinate this
review with the periodic Plant Performance Reviews (PPRs) and use the
guidance provided in Manual Chapter 2604, \"Licensee Performance
Review,\" if desired.

Periodic management reviews may include, but need not be limited to:

a.  General plant status and type of fuel storage.

b.  Quality assurance.

c.  Management organization, support, and oversight.

d.  Technical and contractor support and performance.

e.  Decommissioning activities, planning, and scheduling.

f.  Enforcement actions and open items.

g.  Allegation status.

h.  Licensee events.

i.  Housekeeping and material condition.

j.  Status of licensee commitments and regulatory requirements
    (including the verification of exemptions and license amendments).

06.06 [Management Communication with Licensee Representatives and Public
Outreach]{.underline}

In addition to the 10 CFR 50.82 requirements to hold public meetings,
NRC headquarters and regional management should visit the facility to
understand the licensee\'s plans to decommission their facility.
Licensee programs for the control and handling of radioactive materials,
conduct of 50.59s, and configuration control are potential topics to be
discussed for the benefit of both parties. Further, licensee staffing
and retention plans could be discussed and understood to provide
assurance that changes in site staffing, experience, or expertise will
not result in unsafe decommissioning or excessive use of decommissioning
funds. The NRC staff could also ascertain whether the licensee is
planning any significant licensing actions and/or changes to their
programs as understood by the NRC. Licensee plans to maintain and
preserve the licensed configuration of the facility (as described in the
current licensing basis) should be addressed. NRC management should
consider visiting the site prior to development of a site-specific
master inspection plan or a significant change in decommissioning
status. State representation and other interested parties should be
invited to attend these visits.

As decommissioning progresses, additional site visits may be held
periodically or prior to major changes in the status of decommissioning
to gain licensee management insights and perspectives. Focus should be
to understand licensee plans and schedules, and the controls implemented
to provide quality, cost management, and safety. Performance elements
involving radiation dose, curie removal and transportation, scheduler
accuracy, and nuclear and radiological safety could be discussed to
ascertain the licensee\'s assessment of their own performance.
Discussions could include the dissemination of press and public
information; status of site radiological surveys, results and problems;
problems associated with staffing and contractors; and, storage and
transportation of radioactive material. The NRC staff should also
consider inviting State representation and other interested parties to
these discussions.

As a matter of management philosophy, the NRC maintains an "open door"
policy with regard to access by the public or state or local officials
to the NRC staff or to publicly available electronic documentation
concerning a licensee's performance. Some local officials or community
groups may desire increased interaction with the NRC's staff and
inspectors. The degree of interaction that is considered necessary to
enhance public confidence in the NRC is expected to vary widely
dependant upon the situation at each decommissioning 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 public confidence.

06.07 [Use of Resident Inspectors at Decommissioning Power
Reactors]{.underline}

After a licensee permanently ceases power operations, the inspection
program for decommissioning power reactor facilities considers the
following: (1) there will be initial, short-term, resident inspector
coverage; (2) that licensee decommissioning programs and procedures
should be comparable to the rigor, quality, and effectiveness of those
used during reactor power operation; (3) few changes would be expected
in the technical ability and safety perspective of the licensee\'s staff
and management; and, (4) that the primary safety- significant licensee
activities would consist of maintaining safe reactor shutdown,
conducting safe fuel handling and storage, and placing systems (no
longer necessary for the safe facility operation) in a storage
configuration. During this period with a resident inspector staff
assigned, the site-specific inspection will be based on the NRC
Inspection Manual Chapter (IMC) 2515 program. However, the inspection
effort would normally be commensurate with the effort described in this
manual chapter. After the licensee certifies the safe removal of all
nuclear fuel from the reactor vessel, IMC 2561 is implemented, and
resident inspector (or region-based) inspection effort will be based on
the effort in Category 1, "Post-Operation Transition Phase. Therefore,
resident inspectors assigned at decommissioning facilities can be
temporarily detailed to other sites or assignments, as necessary, to
support the NRC\'s mission.

At a single unit power reactor facility that has just shutdown, one of
the two resident inspectors should be detailed from the site shortly
after the establishment of safe reactor shutdown. The remaining
inspector should then stay at the site for a pre-determined period. If
the licensee: (1) plans to enter active decontamination and
dismantlement or if licensee operational performance dictates, the
remaining resident inspector could stay at the site for up to a year;
(2) plans to enter into long-term storage (SAFSTOR), the length of
service of the remaining inspector would be based, in part, on the
licensee\'s decommissioning schedule and the NRC\'s assessment of
licensee performance, and not exceed 6 months; and (3) had a significant
operational event or accident, the assignment of NRC staff to the site
would be based solely on NRC management discretion, not encumbered by
the guidance in this section. For examples one and two above (and for
the multi-unit discussion below), the assignment of resident inspectors
in excess of the 6-month and 12-month periods described respectively,
should be documented by memo to file and agreed upon by the applicable
regional and headquarters Division Directors.

For multi-unit sites that had one or more units permanently shutdown,
the guidelines in the proceeding paragraph would be applicable. However,
the guidelines should be further defined by the following: (1) if all
units are decommissioning and if more than one resident inspector is
assigned to the particular licensee, a Senior Resident Inspector (SRI),
or equivalent, should be assigned to supervise NRC site activities; and
(2) if one unit remains operational and if there are full- or part-time
inspector(s) assigned to the decommissioning unit(s), the
decommissioning inspectors should have a primary chain-of-command to the
applicable regional division management and a secondary reporting
responsibility to the operational-unit SRI when decommissioning
activities have the potential of impacting operating unit safety. This
command structure establishes one \"senior\" NRC representative at the
site to represent the NRC when the need arises and minimizes any
potential adverse impact on the operating-unit resident inspector staff
that may be caused by activities at the decommissioning unit(s).

For multi-unit sites in which there is a mix of operating and
decommissioning reactors, but with no resident inspector coverage at the
decommissioning unit, headquarters or regional management could allocate
decommissioning inspection hours to the operating-reactor resident
inspector staff to conduct periodic informational assessments of the
decommissioning unit(s). Resident inspector time should be charged to
the applicable decommissioning core inspection procedure (Appendix A)
and not to the operating reactor docket. These informational assessments
should focus on observing licensee management meetings or having
discussions with the cognitive decommissioning management staff to
ascertain the status of decommissioning or problems encountered.
Resident inspector activities at the decommissioning unit shall
contribute to the NRC\'s overall mission to ensure adequate protection
of public health and safety and the environment in the use of nuclear
materials and not detract from the effective inspection oversight of the
operating unit(s). For these informational gathering assessments, the
applicable decommissioning IP be charged on a quarterly basis at a unit
in Category 1, 2, or 3 and yearly for a unit in Category 4, 5, or 6.
Follow-up to this routine assessment should be charged as regional
initiative or reactive to the appropriate IMC 2515 or 2561 inspection
procedure after discussion with regional and headquarters management.
For decommissioning event response, resident inspectors could be
utilized in the same manner to assess and report the situation.

Resident and Senior Resident Inspectors assigned to decommissioning
power reactors are expected to rotate in accordance with the NRC Field
Policy Manual, Section 8, \"Resident Inspector Relocation Policy.\" In
no case will resident inspector coverage be removed from the site before
the licensee has certified (and the NRC staff has independently
verified) that the power reactor unit has permanently ceased power
operations and all fuel has been permanently and safely transferred from
the reactor vessel to the spent fuel pool, ISFSI, or other licensed
storage facility. If resident inspector presence is removed, licensee
activities are not of sufficient regulatory or safety importance to
warrant the need to maintain resident inspector coverage.

06.08 [Basic Inspection Process]{.underline}

In addition to the information given below, additional guidance
regarding the basic inspection process can be found in Inspection Manual
Chapters 2515, 2600, and 2800. All inspections should be conducted in a
similar manner in accordance with headquarters staff instructions and
regional administrative processes.

Inspection starts with the planning of core and discretionary
inspections in the master inspection plan, as described in Paragraph
06.04. MIP implementation also includes the coordination of site visits
and inspections to promote regulatory efficiency and effectiveness and
to reduce regulatory burden on the licensee. Then, inspections are
conducted, inspection reports are written, license performance is
assessed, feedback on the decommissioning inspection program should
occur, and this process should repeat until the site is decommissioned.
A basic inspection process should entail:

a.  Preparation for the inspection by reviewing appropriate background
    material (e.g., license, USAR, SER, ER, TSs, PSDAR, hazards analysis
    report(s), final safety analysis report, license termination plan,
    past inspection reports, allegations, open item lists (violations,
    open/unresolved items, deviations, licensee event reports, and other
    pertinent information). Attention should also be paid to licensee
    documents that describe how they will conduct decommissioning (i.e.,
    10 CFR 50.59s, quality assurance plans, etc.).

b.  Preparation of an inspection plan describing the scope and major
    areas of emphasis that will be reviewed, evaluated, or assessed.
    This plan should be reviewed by a supervisor. Depending on regional
    and headquarter\'s assessment of licensee performance, as described
    in this manual chapter, NRC management should determine whether the
    inspection will be announced or unannounced. Observations of
    licensee activities on back or deep back shifts should be
    considered. NRC management should also consider periodically
    observing the conduct of the inspector in-field inspection or the
    exit meeting. Coordination of inspection activities shall be
    conducted in accordance with NRC Inspection Manual Chapter 0301,
    \"Coordination of NRC Visits to Commercial Reactor Sites.\"

c.  Inspectors shall utilize appropriate and calibrated radiation
    detection instrumentation or any other equipment to verify licensee
    activities, if applicable for the inspection. *In-situ* measurements
    with licensee personnel can be beneficial in future determinations
    as to the scope of confirmatory surveys required for the facility.
    The use of an outside contractor may also be considered to perform
    confirmatory *in situ* measurements or laboratory analyses.

d.  Inspectors shall conduct an entrance meeting with the licensee.
    Inspectors should discuss the inspection scope with licensee
    management and articulate whether open items will be reviewed. The
    inspector should state that the inspection may involve the
    observation of facility operations, interviews with staff, document
    reviews, and/or radiation surveys to obtain independent and
    confirmatory data. Appropriate inspection emphasis should be placed
    on observing staff training, equipment operation, and implementation
    of the licensed programs. Any change or potential change to the
    onsite inspection plan should be communicated with appropriate NRC
    management.

> Although unique plant conditions may exist following the permanent
> cessation of reactor power operations, NRC inspectors should not face
> situations in which license conditions, regulatory requirements, or
> licensee commitments do not apply. In cases where unique situations or
> unclear configurations may be identified and considered potentially
> adverse to the conduct of safe decommissioning or public health and
> safety, the inspector(s) should discern whether the licensee is aware
> of the situation and taking appropriate action, if necessary, to
> correct and preclude recurrence. Such cases or problems involving NRC
> requirements and licensee commitments should be raised to the
> responsible NRC manager. Equally important, the inspector should
> determine if the situation is beyond the scope of the inspector\'s
> expertise. If it is beyond the inspector\'s expertise, the inspector
> should promptly inform his or her supervision and make
> recommendations, so that management can determine the urgency of the
> request for assistance, what type of expertise is required, and what
> extent of effort is required.

e.  An exit meeting shall be conducted with licensee management at the
    conclusion of the inspection. The inspection scope and applicable
    findings shall be presented emphasizing their impact on safety.
    Prior to the exit, the inspector\'s supervisor should be briefed on
    the preliminary inspection findings and conclusions and licensee
    corrective actions.

f.  Upon return to the regional or headquarter\'s office, the
    appropriate regional and headquarters personnel should be briefed on
    the inspection findings and conclusions to ascertain whether
    inspection follow-up will occur.

g.  Inspection findings, open items, follow-up items, and conclusions
    shall be documented in accordance with Manual Chapter 0610 and other
    relevant regional or headquarter instructions. Inspections resulting
    from allegations will be documented and dispositioned in accordance
    with Management Directive 8.8.

Because decommissioning involves the reduction of residual radioactivity
to a level that permits release of the property and license termination,
inspections at decommissioning facilities should (in addition to
evaluating and documenting the performance or effectiveness of licensee
programs, processes, and equipment used to provide assurance that
regulatory requirements are met and that decommissioning is conducted
safely) act as a historical record of the licensee\'s ability to
effectively and accurately conduct radiological surveys and
characterizations, manage occupational dose, maintain the facility
licensing and design basis, and control radiological effluents. This
record should help focus inspections in areas of licensee performance
directly related to site release and license termination activities.

06.09 [Decommissioning Inspector]{.underline}

Depending on the inspection plan requirements and upon approval by
headquarters and regional management, an inspector may be assigned to
the site for all or part of decommissioning. This inspector will be the
major onsite presence for the direct observation and verification of
licensee activities in accordance with an approved and documented
inspection plan. Management should document to file the scope of the
onsite inspection effort, specify the duration of the effort based on,
for example, decommissioning activities, milestones, or licensee
performance, and allocate inspection resources as needed.

If onsite coverage is allocated, it is expected that the inspector be
qualified as a Decommissioning Inspector per IMC 1246. The
Decommissioning Inspector shall evaluate site events and conditions and
will perform the largest part of the initial event or condition‑related
inspection effort. The conduct of the decommissioning inspector shall
parallel, in part, that of a resident inspector assigned to an operating
power facility (reference IMC 2515, \"Resident Inspector Policy\" and
the NRC Field Policy Manual). For example, the inspector shall, in part:
independently verify and assess licensee activities and performance;
discuss observations and findings with the licensee; daily discuss
inspection issues with NRC management; and, periodically docket
inspection observations, findings, and conclusions.

06.10 [Regional and Headquarters Inspectors]{.underline}

Regional and headquarters inspectors should conduct inspections as
specified in the site-specific master inspection schedule and as
directed by their supervisor.

The regional division responsible for decommissioning inspections of
power reactors that have permanently shutdown, should be kept apprised
of all inspection activities. All inspections shall be coordinated
through the appropriate NRC manager, who is responsible for the
facility, well in advance of the inspection. This contact is to obtain
information on the availability of specific licensee personnel, on the
status of plant conditions that may affect the planned inspection, and
to ensure a coordinated presence onsite. Inspectors should advise their
responsible manager of any changes to the planned inspection scope and
take into consideration management suggestions and perspectives for the
conduct of an effective inspection.

Although unique plant conditions may exist following the permanent
cessation of reactor power operations, NRC inspectors should not face
situations in which license conditions, regulatory requirements, or
licensee commitments do not apply. However, unique situations or unclear
configurations may be identified and considered potentially adverse to
the conduct of safe decommissioning or public health and safety. In
these cases, the inspector should discern whether the licensee is aware
of the situation and taking appropriate action, if necessary, to correct
and preclude recurrence. Such cases and/or problems involving NRC
requirements and licensee commitments should be immediately raised to
appropriate regional and headquarters management. Equally important, the
inspector should determine if the situation is beyond the scope of the
their expertise. If it is beyond their expertise, the inspector should
promptly inform his or her supervision and make recommendations, so that
management can determine the urgency of the request for assistance, what
type of expertise is required, and what extent of effort is required.

Additional oversight or coordination with NMSS may be needed following
approval of the licensing termination program (LTP) to verify or
validate implementation of the LTP. Areas requiring further validation
or verification have been typically listed in the Safety Evaluation
Report that documents the approval of the LTP. These areas may include
items that will be reviewed through the core or discretionary procedure
program, items beyond the scope of the core inspection procedures, or
items that require special expertise for review; e.g., hydrological
evaluations. NMSS/DWM staff may be enlisted to support LTP verification
and validation efforts beyond the scope of the core or discretionary
procedures. The Technical Assistance Request process can be used by
Regional staff to initiate action on items requiring special review.

06.11 [Modifications or Changes to the Facility]{.underline}

An important inspection activity during facility decommissioning is the
assessment of facility design changes and modifications. Changes, tests,
and experiments (CTEs) must be performed in accordance with 10 CFR
50.59, license conditions, and licensee procedures. In addition, 10 CFR
50.82(a)(6) states that decommissioning activities must not: (1)
foreclose release of the site for possible unrestricted use, (2)
significantly increase decommissioning costs, (3) cause any significant
environmental impact not previously reviewed, or (4) violate the terms
of the licensee\'s existing license. The NRC project manager will
participate in an inspection, at least once per year, to assess the
licensee's Safety Evaluation Program.

Further, if decommissioning trust funds are used (10 CFR 50.82(a)(8)),
they must be used for legitimate decommissioning activities; their
expenditure shall not reduce the value of the decommissioning trust fund
below an amount necessary to place and maintain the reactor in a safe
storage condition if unforeseen conditions or expenses arise; and their
withdrawal shall not inhibit the ability of the licensee to complete
funding of any shortfalls in the decommissioning trust needed to ensure
the availability of funds to ultimately release the site and terminate
the license. Decommissioning funds would generally not be allowed for
the development, installation, testing, or operation of a dry spent fuel
storage facility, or non-radiological material dismantlement or
remediation. The headquarters staff has the lead for assessing the
appropriateness of a licensee\'s decommissioning fund allocation.

Before undertaking any major decommissioning activities (as defined by
10 CFR 50.2), the license shall have: (1) certified the permanent
removal of a reactor fuel from the vessel and the permanent cessation of
operations; (2) submitted a PSDAR to the NRC; and, (3) waited 90 days.
Prior to this time, a licensee may undertake any minor decommissioning
activity that does not result in the permanent removal of major
radioactive components (i.e., the steam generators, reactor vessel and
internals, pressurizer, large bore reactor coolant system piping, and
other large components that are radioactive), permanently modifies the
structure of the containment, or results in dismantling components for
shipment containing greater than Class C waste in accordance with 10 CFR
61.55.

Examples of activities that are not considered major decommissioning
activities include: (1) those that could be performed under normal
maintenance and repair; (2) removal of certain, relatively small
radioactive components, such as control rod drive mechanisms, control
rods, pumps, and valves; (3) removal of components similar to that for
maintenance and repair; (4) removal of non‑radioactive components and
structures not required for safety; and, (5) activities related to
radiation and contamination characterization.

END

Appendices

> A. Core Inspection Procedures for Decommissioning Power Reactors

B. Discretionary Inspection Procedures for Decommissioning Power
Reactors

Appendix A

I. Core Inspection Procedures

36801 Organization, Management & Cost Controls at PSRs

37801 Safety Reviews, Design Changes, and Mods at PSRs

40801 Self-Assessment, Auditing, and Corrective Action

71801 Decommissioning Performance and Status Review at PSRs

62801 Maintenance and Surveillance at PSRs

71714 Cold Weather Preparations

81XXX Physical Security Assessment at PSRs

60801 Spent Fuel Pool Safety at PSRs

83750 Occupational Radiation Exposure

83801 Inspection of Final Surveys at PSRs

84750 RadWaste Treatment, and Effluent & Environ Monitoring

86750 Solid RadWaste Management & Transportation of RadMat using TI
2515/133, \"Implementation of Revised 49 CFR Parts 100-179 and 10 CFR
Part 71\"

**II.** **Recommended Average Annual Inspection Hours per
Decommissioning Status**

  --------------- --------------- ----------- ----------- ----------- ----------- ----------- -----------
  Inspection      Inspection      **1**[^1]   **2**[^2]   **3**[^3]   **4**[^4]   **5**[^5]   **6**[^6]
  Procedure       Requirement                                                                 

  36801           02.01           16          16          0           3           3           0

                  02.02           14          14          0           3           0           0

                  02.03           10          10          0           2           0           0

                  02.04           8           0           0           0           0           0

                  02.05           4           0           0           0           0           0

  37801           02.01           12          12          12          2           0           0

                  02.02           12          12          0           2           2           0

                  02.03           8           8           0           2           0           0

  40801           02.01           4           4           4           4           4           0

                  02.02           14          14          14          4           4           0

                  02.03           24          24          24          6           6           0

                  02.04           16          16          16          4           4           0

                  02.05           6           6           6           3           3           0

  71801           02.01           8           0           0           0           0           0

                  02.02           8           8           8           1           0           0

                  02.03           10          10          10          0           0           0

                  02.04           6           6           6           0           0           0

  62801           02.01           28          28          28          0           0           0

                  02.02           28          0           0           0           0           0

  71714           all             12          0           0           0           0           0

  817XX           \-              24          24          12          12          12          4

  60801           02.01           5           5           0           5           0           0

                  02.02           5           5           0           5           0           0

                  02.03           5           0           0           0           0           0

                  02.04           5           0           0           0           0           0

                  02.05           5           5           0           5           0           0

  83750           02.01           6           6           6           6           6           6

                  02.02           4           4           2           2           2           2

                  02.03           8           8           8           6           4           4

                  02.04           4           0           0           0           0           0

                  02.05           6           0           0           0           0           0

                  02.06           4           0           0           0           0           0

                  02.07           3           3           3           2           2           3

                  02.08           3           3           3           2           2           3

                  02.09           8           8           8           6           4           4

                  02.10           8           8           8           0           0           4

                  02.11           2           0           0           0           0           0

                  02.12           8           8           8           4           4           4

  83801           02.01           0           4           4           0           0           0

                  02.02           0           20          20          5           5           20

                  02.03           0           10          10          5           5           30

                  02.04           0           28          28          10          10          40

                  02.05           0           0           0           0           0           0

                  02.06           0           16          16          1           1           6

  84750           02.01           4           4           4           2           2           2

                  02.02           2           2           2           2           2           2

                  02.03           6           6           6           4           2           1

                  02.04           2           0           0           0           0           1

                  02.05           8           0           8           0           0           0

                  02.06           2           2           2           2           2           1

                  02.07           2           0           0           0           0           0

                  02.08           2           2           2           2           1           1

                  02.09           4           0           0           0           0           0

                  02.10           2           0           0           0           0           0

                  02.11           2           0           0           0           0           0

                  02.12           2           0           0           0           0           0

                  02.13           2           2           2           2           2           1

  86750           02.01           20          20          20          4           2           4

                  02.02           6           6           6           3           1           2

                  02.03           6           6           6           2           0           0

                  02.04           20          20          20          10          5           10

                  02.05           20          20          20          10          5           10

  **Total Hours** **-**           **473**     **443**     **362**     **155**     **107**     **165**
  --------------- --------------- ----------- ----------- ----------- ----------- ----------- -----------

END

APPENDIX B

Discretionary Procedures for Decommissioning Power Reactors

[IP Number]{.underline} [INSPECTION PROCEDURE TITLE]{.underline}

[PLANT OPERATIONS]{.underline}

42700 Plant Procedures

60705 Preparation for Reactor Fuel Handling

60710 Fuel Handling Activities

71707 Operational Safety Verification

86700 Spent Fuel Pool Activities

93702 Prompt Onsite Response To Events At Operating Power Reactors

[RADIOLOGICAL CONTROLS]{.underline}

80721 Radiological Environmental Monitoring

83722 Radiation Protection, Plant Chemistry and Radwaste: Organization
and Management Controls

83723 Training and Qualifications: General Employee Training, Radiation
Safety, Plant Chemistry, Radwaste and Transportation

83724 External Occupational Exposure Control and Personal Dosimetry

83725 Internal Exposure Control and Assessment

83726 Control of Radioactive Materials and Contamination, Surveys and
Monitoring

83727 Facilities and Equipment

83728 Maintaining Occupational Exposures ALARA

83729 Occupational Radiation Exposure During Extended Outages

84850 Radioactive Waste Management‑Inspection of Waste Generator
Requirements of 10 CFR Part 20 and 10 CFR Part 61

86740 Inspection of Transportation Activities

[MAINTENANCE AND SURVEILLANCE]{.underline}

61726 Surveillance Observation

62706 Maintenance Rule

[SECURITY]{.underline}

81502 Fitness For Duty

85102 Material Control and Accounting ‑ Reactors

[ENGINEERING/TECHNICAL SUPPORT]{.underline}

37001 Facility Modifications

37700 Design Changes and Modifications

41500 Training and Qualification Effectiveness

[SAFETY ASSESSMENT/QUALITY VERIFICATION]{.underline}

35701 Quality Assurance ‑ Annual Review

36800 Organization

39701 Records Program

40500 Evaluation of Licensee Self‑Assessment Capability

90712 In‑office Review of Written Reports of Non‑routine Events At Power
Reactor Facilities

90713 In‑Office Review of Periodic and Special Reports

90714 Non‑routine Reporting Program

92700 Onsite Follow‑up of Written Reports of Non‑routine Events At Power
Reactor Facilities

92701 Follow‑up

92702 Follow‑up On Corrective Actions For Violations and Deviations

[MEETINGS AND OTHER]{.underline}

93001 OSHA Interface Activities

88XXX Emergency Preparedness

64704 Fire Protection Program

END

[^1]: Post-Operation Transition Phase

[^2]: Facility undergoing active decommissioning with spent fuel in the
    spent fuel pool.

[^3]: Facility undergoing active decommissioning with [no]{.underline}
    spent fuel in the spent fuel pool.

[^4]: Facility in SAFSTOR with spent fuel in the spent fuel pool.

[^5]: Facility in SAFSTOR with [no]{.underline} spent fuel in the spent
    fuel pool.

[^6]: Facility in the process of final surveys with [no]{.underline}
    spent fuel in the spent fuel pool.