Issue Date: 04/24/13 1 0102

NRC INSPECTION MANUAL IRIB

MANUAL CHAPTER 0102

OVERSIGHT AND OBJECTIVITY OF

INSPECTORS AND EXAMINERS AT REACTOR FACILITIES

0102-01PURPOSE

Periodic industry feedback and internal reviews have identified the need for continued 

management involvement and oversight of NRC activities conducted at reactor facilities. This 

chapter describes the policy for management involvement and oversight of inspections, operator 

licensing examinations, audits, and other on-site inspection related activities at reactor facilities. 

This policy is intended to ensure the effective direction of activities, communication, and inspector 

objectivity at reactor facilities. Objectivity is the extent to which the inspector or examiner 

implements the NRC=s programs, interfaces with the public and conducts both personal and work 

relationships in an unbiased manner, free from both partiality and antagonism toward a licensee 

or vendor, or the employees of a licensee or vendor, as evidenced by patterns of the inspector=s 

or examiner=s actions.

0102-02POLICY

02.01 General

a. Every level of management must clearly communicate to its subordinates the Agency=s 

expectations regarding the duties of inspectors and examiners and the principles to be 

applied in the performance of those duties.

b. Only trained and qualified individuals having the knowledge and aptitude to perform 

on-site activities in a manner consistent with Agency expectations should be assigned to 

perform independent on-site activities.

c. When on-site activities are initiated, line managers must oversee those activities to 

ensure that the Agency=s expectations and principles regarding inspectors and 

examiners are satisfied.

d. There are no restrictions on the number of site assignments or total time in position for 

resident inspectors provided that the performance of the resident inspector remains 

acceptable as defined by Management Directive 10.67, ANon-SES Performance 

Appraisal System.@ Hence, resident inspectors and their managers should maintain the 

flexibility to make job assignments and career decisions in the best interest of both the 

NRC and the individual.

e. All resident inspectors have a 7-year maximum length of tour. This policy does not 

preclude resident inspectors from relocating for promotions, voluntary reassignments, or 

management-directed reassignments.
Issue Date: 04/24/13 2 0102

f. Throughout this manual chapter the term employee applies to all NRC technical staff who 

performs independent inspections or examinations at power reactor facilities. The term 

inspections apply to inspections, examinations, audits, and reviews conducted by NRC 

technical staff at power reactor facilities.

02.02 Observations. To assess the adequacy of program guidance (e.g., inspection 

procedures, tools, and resources) and verify the adequacy of employee performance, line 

managers must directly observe on-site activities. Those on-site observations should assess the 

adequacy of program guidance and the following individual performance attributes:

a. Safety perspective and the application of safety principles during on-site activities.

b. The adequacy of technical training and preparation for the on-site activity.

c. Knowledge of applicable regulatory requirements, procedures and guidelines (e.g., 

10 CFR, NRC Inspection Manual, inspection procedures, updated final safety analysis 

reports (UFSAR), Operator Licensing Examination Standards, NUREGs, regulatory 

guides, and industry codes and standards).

d. Adherence to agency-wide regulatory positions and policies (e.g., backfit) and avoidance 

of personal interpretations and opinions.

e. Employee objectivity considering the employee=s experience, technical expertise, site 

familiarity, industriousness, overall effectiveness, external and internal pressures, and 

differences of opinion based on valid technical merit.

f. Employee demeanor, professionalism, and interpersonal skills (e.g., ability to 

communicate accurately and effectively with licensees).

g. Effective on-site activity techniques, including in part, evidence of good preparation, a 

performance-based focus, selection of risk-informed samples, emphasis on direct 

observation of activities, use of in-depth probing where appropriate, and sufficient 

emphasis on independently verifying licensee provided information.

02.03 Other Oversight. Direct observation alone is not sufficient. Line managers must take 

an active role in the on-site activities that they oversee. They must engage their employees in 

open, two-way communication regarding their inspection or examination findings so that both 

parties fully understand the issues and the appropriate regulatory approach to those issues. By 

sharing their perceptions, opinions, and philosophies, employees will gain a better understanding 

of what their supervisors expect of them and supervisors will gain valuable insights to the 

capabilities and shortcomings of their employees and the inspection program. Similarly, reviews 

of inspection reports, peer reviews, involvement in enforcement actions, senior management 

debriefings, management self-assessments, involvement in developing mid-cycle and 

end-of-cycle assessment reports, and feedback from licensees can provide additional insights to 

the conduct, objectivity, and performance of employees and managers as well.
Issue Date: 04/24/13 3 0102

0102-03DISCUSSION OF POLICY

Line management is responsible for overseeing employees that conduct on-site activities at 

reactor facilities by clearly establishing and communicating performance expectations, providing 

staff development opportunities, evaluating feedback from reactor licensees, and ensuring that 

on-site activities are performed as intended. Employees should be considered for recognition 

when management finds them exhibiting outstanding performance, superior technical expertise, 

continuing sound judgment and professional behavior. Management is expected not only to hold 

the staff accountable for its actions when instances of performance or conduct inconsistent with 

Agency positions or supervisory expectations are detected, or an employee's objectivity is 

questioned, but also to address any staff developmental needs to prevent recurrence of the 

inappropriate action. Circumstances may arise which require greater management involvement 

above the levels described in these guidelines.

0102-04OVERSIGHT AND OBJECTIVITY REQUIREMENTS AND GUIDANCE

04.01 General. The requirements and guidance provided in section 0102-04 are to be used by 

NRC managers to verify employee performance and objectivity by direct observation of on-site 

activities at power reactor facilities and through other available indirect methods as needed. 

On-site activities include individual or team inspections, examinations, audits, visits, and reviews. 

NRC employees should use the applicable guidance and requirements of this section in the 

performance of their on-site activities.

04.02 Individual Inspectors, Team Leaders, and Examiners

a. Inspectors, team leaders, chief examiners, and other staff who lead NRC on-site 

activities should develop an appropriate plan, brief and receive approval from the line 

supervisor responsible for the activity on their planned activities, and should provide a 

copy of the inspection, examination, or audit plan to the responsible regional office 

Division of Reactor Projects (DRP) supervisor before the on-site activities begin.

b. All NRC staff who leads NRC on-site activities will conduct an entrance meeting with the 

principal facility personnel before beginning on-site activities. The senior resident 

inspector (SRI), or the resident inspector in the SRI=s absence, should be invited to all 

entrance briefings.

c. All NRC staff who leads NRC on-site activities should brief the immediate line 

supervisors responsible for the activity and the SRI regarding their findings before any 

exit meeting with the facility licensee takes place.

d. Inspectors, team leaders, chief examiners, and other staff who lead or participate in NRC 

on-site activities shall maintain a professional, objective relationship with licensee 

management and staff.

04.03 Senior Resident Inspectors

a. SRIs should routinely brief their immediate supervisor on resident inspection issues and 

findings and should keep their supervisor informed of scheduled exit meetings.
Issue Date: 04/24/13 4 0102

b. SRIs should keep abreast of all NRC on-site activities at the facility to which they are 

assigned. However, minor issues should not be tracked or trended.

c. SRIs should attend entrance and exit meetings. If the SRI is unavailable, other resident 

inspectors should attend in their place. For economy of time, meetings for multiple 

on-site activities should be combined whenever possible.

d. To enhance objectivity, SRIs and resident inspectors shall spend a minimum of one week 

each year inspecting at another site. This inspection may be accomplished by 

participating in a team inspection at another site, or by visiting their backup site for 

familiarization.

04.04 Line Managers

a. Line managers should keep abreast of on-site activities conducted by employees over 

whom they have supervisory authority.

1. Line managers should discuss on-site activity plans with their employees before 

on-site activities begin to ensure the employee's activities are properly scheduled, 

coordinated and focused.

2. Regional DRP line managers should talk with their resident inspectors at each of 

their sites several times a week.

3. Line managers responsible for an on-site activity should discuss the findings and 

concerns with the employees assigned to the activity before the facility exit 

meeting is held. Discussions should focus on potential safety and regulatory 

approaches to issues to ensure mixed messages are not sent to the licensee.

4. Line managers will oversee significance determinations of inspection findings and 

any enforcement decisions involving facilities or activities for which they are 

responsible.

5. Line managers should attend at least one exit meeting annually to observe their 

subordinate inspectors. This expectation can be accomplished by attending an 

exit meeting for their subordinate resident and specialist inspectors if significant 

inspection or examination findings (e.g., potentially greater than green 

significance, possible escalated enforcement or unsatisfactory requalification 

examination) will be discussed. Appropriate line manager shall attend team 

inspection exit meetings as directed by their division directors and should 

supplement the discussion at the meeting, as necessary.

6. Line managers responsible for an on-site activity should promptly and thoroughly 

debrief the assigned employees after the employees leave the site. Line 

managers must promptly intervene and communicate any changes in findings or 

conclusions to DRP management, and shall promptly contact the licensee to 

discuss the changes if necessary.
Issue Date: 04/24/13 5 0102

7. DRP line managers shall ensure the resident inspectors conduct inspections to 

maintain access to and familiarity with their backup sites or, if not assigned a 

backup site, are annually assigned to an inspection at another site. These efforts

should be coordinated to ensure adequate site coverage is maintained at all 

reactor sites.

b. Line managers should ensure that their division director and the regional DRP division 

director are promptly informed of significant safety and regulatory issues identified by 

employees whom they supervise.

c. Line managers shall ensure that inspectors do not track or trend minor issues. This 

means that line managers shall ensure that inspectors are not performing data analysis 

and charting of minor issues.

d. Line managers from the region and Office of Nuclear Safety and Incident Response 

(NSIR) responsible for the Force-on-Force inspections shall observe each of their 

employees, if practicable, during an on-site activity at least once a year. During their 

site visits, line managers may accompany any or all of their employees who are on site at 

the time of their visit. In addition, DRP line managers should visit one of the sites they 

are responsible for once a quarter. These visits may be combined (i.e., accomplished

on one trip rather making two separate trips) for plants which are collocated or nearby

(e.g., Salem/Hope Creek; Fitzpatrick/Nine Mile Point; and Kewaunee/Point 

Beach).These visits should typically include a tour of the RCA. DRP line managers shall 

maintain unescorted access authorization at each of their sites. A DRP line manager, 

branch chief or higher, should typically tour the containment with one of the resident 

inspectors during each plant refueling outage.

Regional operator licensing managers should alternate their field observations between 

examination and inspection activities for their employees who are certified in both areas. 

When observing an examination, the manager should accompany the examiner during a 

complete operating test. Part-time (i.e., reserve) examiners are also subject to periodic 

observation and evaluation while administering operating tests. These observations 

shall:

1. be performed at least every 24 months by the regional operating licensing branch 

chief or a certified chief examiner, and

2. cover at least half of a walk-through (i.e., 5 system job performance measures and 

2 administrative topics) and at least one simulator scenario.

These observations are in addition to and do not replace the annual accompaniments 

required by the part-time examiner=s supervisor.

e. Line managers should continuously assess the performance of their assigned 

employees using a combination of direct observation of the employees' activities during 

site visits and the review of their performance as portrayed in inspection or examination 

reports, telephone conversations, and other indirect methods. A line manager's site 

visit should be of sufficient duration to supplement the indirect methods of assessing the 

performance of their subordinate employees. Line managers should focus on the 

following applicable areas related to assessing their subordinate employees:
Issue Date: 04/24/13 6 0102

1. Does the employee independently verify information from the licensee when 

appropriate?

2. Does the employee adhere to NRC regulatory positions and policies when 

discussing issues with licensee or NRC management, avoiding personal 

interpretations and opinions?

3. Does the employee maintain a professional relationship with the licensee using 

good interpersonal relationship skills?

4. Has the employee provided an accurate and balanced account of licensee 

performance and plant conditions in communications with NRC regional 

management via inspection reports, telephone calls, or other means?

5. How do licensee staff and managers respond to the employee's questions or 

concerns?

6. Is the employee focused on safety significant concerns, applying significance 

determination and enforcement guidance appropriately?

7. Does the employee develop issues without biased interpretation of facts?

8. Are findings adequately supported by the facts?

9. Does the employee conduct exit interviews in accordance with NRC policies and 

practices?

f. Line managers should tour the facility during their site visits. Facility tours should 

include those areas the employees would normally tour on a routine basis. DRP line

manager tours should include an overview of control room activities and inspector 

interactions with control room staff. The tour should be used to provide the line

manager with insights regarding how well the licensee performs and how well the 

employee has characterized the licensee performance in communication with NRC 

regional management.

g. During site visits, line managers should make every effort to have discussions with 

maintenance, operations, radiological controls, engineering and technical support, 

quality control, and senior site managers as applicable. These discussions should 

include quality of licensee interactions with NRC employees or team inspections. Have 

there been significant conflicts or concerns with findings or the manner in which findings 

were communicated to the licensee?

h. Line managers should meet individually with their employees to discuss on-site 

activity-related performance and objectivity issues observed during each site visit.

i. Line managers shall annually document the objectivity of their assigned employees. 

The documentation should address each item of 02.02 a through g that is applicable to 

the employee and activity reviewed. When patterns tend to indicate a loss of objectivity, 

corrective measures should be immediately implemented by regional management.
Issue Date: 04/24/13 7 0102

04.05 Division Directors

a. Division directors should meet with their subordinate line managers on a regular basis 

(e.g., weekly) to discuss on-site activities, including significant findings, trends, and 

potentially generic issues. Their level of involvement should be proportional to the 

significance of the findings. They shall ensure that an appropriate NRC manager is 

present at those on-site activity exit meetings where findings have resulted in an 

apparent significant finding.

b. Division directors or their deputies should average one site visit a month to monitor 

on-site activities for which they are responsible. The DRP division director or deputy 

should make every effort to visit each site at least once every two years. These visits 

should typically include a tour of the RCA in the accompaniment of a site inspector. The 

DRP and DRS division directors or deputies should consider making contact with 

individual licensee managers or unit managers as appropriate to the ongoing and/or 

apparent, security or regulatory impact issues at the site. During site visits, DRP or DRS 

division directors and their deputies should focus their observations on ongoing and/or 

apparent safety and security issues. Also, they should overtly solicit feedback from their 

licensee counterparts regarding implementation of the NRC regulatory programs at their 

facility. Division directors must evaluate the validity of the licensee's adverse comments 

and initiate appropriate action to correct the problem. See section 0102-05, below. In 

addition, the DRP director or deputy should hold a brief personal discussion with the SRI 

and/or resident inspector of each site periodically (i.e., about quarterly) to discuss 

ongoing and/or apparent safety, security or impact issues; this discussion may take place 

during a site visit, during an inspector=s visit to the regional office for other agency 

business, during a periodic inspection debrief, or by telephone. 

c. Division directors shall ensure that the regional administrator is informed of all significant 

safety, security and any issues related to NRC employee performance, identified by or 

resulting from NRC on-site activities.

d. Division directors and their deputies should periodically assess their activities to confirm 

that oversight activities are being performed.

04.06 Regional Administrators

a. Regional administrators, or their deputies, are responsible to ensure sufficient routine 

management communication with each employee to maintain oversight and monitor 

objectivity of the employees when they are on site.

b. Regional administrators or their deputies are responsible for 

monitoring regional management activities and visiting sites to ensure that all sites 

receive adequate attention and that all on-site activities receive adequate safety, security 

and management oversight.

c. The regional administrators shall ensure that the appropriate NRR manager is informed 

of all significant issues.
Issue Date: 04/24/13 8 0102

d. Regional administrators or their deputies should average one power reactor site visit a 

month. During their site visits, regional administrators should focus their observations 

on ongoing and/or apparent safety and security issues. Also, they should overtly solicit 

feedback from their licensee counterparts regarding implementation of the NRC 

regulatory program at their facility. Regional administrators must ensure that adverse 

comments are validated and appropriate corrective actions are initiated. See section 

0102-05, below. Further, Regional Administrators or their deputy should seek 

opportunities for public outreach as appropriate. This might include attendance at public 

exit meetings and other outreach opportunities, as appropriate. Consideration of public 

outreach should be consistent with the Action Matrix guidance.

 e. Regional Administrators should make sure that licensees are aware that there are 

multiple tiers for raising concerns. Concerns regarding regional staff performance 

should be raised with the Regional Administrator, but concerns regarding the Regional 

Administrator should be raised to the EDO.

0102-05 Site Visit Observation Form (NRC Form 649)

A Site Visit Observation Form will be used to document ongoing and/or apparent, security or 

regulatory impact observations, including inspector objectivity, made during Senior Regional 

Manager Site visits. The specificity of comments should be adequate to convey the safety, 

security or regulatory impact issue so that meaningful communications can occur; however, a 

detailed account of the issue is not required. Issues related to security should only be 

documented if they relate to regulatory impact issues. It is not intended that this Form document 

safeguards issues. It will include documentation of actions deemed appropriate by the Regional 

Administrator or Deputy Regional Administrator.

NRR regularly reports to the Commission the results of feedback from licensees on the impact of 

our activities.1 An important part of the report is an analysis of the feedback solicited by regional 

mangers during periodic visits (sections 04.05.b and 04.06.d, above). The feedback obtained 

from licensees by regional managers must be forwarded to the NRR Division of Inspection and 

Regional Support (DIRS), Performance Assessment Branch (IPAB). The feedback should be 

reported to IPAB on NRC Form 649, “Site Visit Observation,” which is available through the DIRS 

Sharepoint site at the provided link. As noted on the form, the completed form can be emailed to 

FeedbackROP.resource@nrc.gov and/or a hard copy forwarded to the IPAB Branch Chief. Note 

that there is a “Submit Via Email” at the bottom of the form that will automatically forward your 

completed form to the appropriate email address.

END

 

1

SRM, ASECY-91-172CRegulatory Impact Survey ReportCFinal,@ dated December 20, 1991, required the staff to 

implement a process to gather feedback from licensees and to annually report the results of the process to the Commission.
Issue Date: 04/24/13 Att1-1 0102

Attachment 1

Revision History for IMC 0102

Commitment 

Tracking 

Number

Accession 

Number

Issue Date

Change Notice

Description of Change Training Required 

and Completion Date

Comment and 

Feedback 

Resolution 

Accession Number

N/A 08/22/05 Revision history reviewed for last four years N/A N/A

N/A ML12012A053

04/24/13

CN 13-012

IMC 0102 was changed to reflect current 

expectations on line management observation of 

NRC inspectors and improved routing of site visit 

observation forms. FFs 0102-1237; -1384; -1598; 

-1617;-1618; and -1648 were closed.

N/A ML13032A115

ML13043A135

ML13043A139

ML13043A142

ML13043A156

ML13043A159

ML13043A164