Issue Date: 07/28/14 1 2522

NRC INSPECTION MANUAL NRO/CIPB

MANUAL CHAPTER 2522

CONSTRUCTION REACTOR OVERSIGHT PROCESS SELF-ASSESSMENT PROGRAM

2522-01 PURPOSE

The construction reactor oversight process (cROP) self-assessment program evaluates the 

overall effectiveness of the cROP through its success in meeting pre-established goals and 

intended outcomes.

2522-02 OBJECTIVES

02.01 To establish the processes for collecting information and data to support the cROP selfassessment program.

02.02 To establish a process for objectively evaluating the effectiveness of the cROP in 

achieving the goals of being objective, risk-informed, understandable, predictable, open, and 

effective in accordance with NRCs Strategic Plan. 

02.03 To provide timely, objective information to inform program planning and to develop 

recommended improvements to the cROP.

02.04 To inform the Commission, NRC senior management, and the public of the results of 

the cROP self-assessment program, including any conclusions and resultant improvement 

actions.

2522-03 RESPONSIBILITIES AND AUTHORITIES

03.01 Director, Office of New Reactors (NRO). 

a. Oversees and manages the Construction Reactor Oversight Process.

b. Issues the annual cROP self-assessment SECY paper.

03.02 Director, Office of Nuclear Security and Incident Response (NSIR). Provides support 

and data as requested by the Director, NRO.

03.03 Regional Administrator(s). Provide data to support the cROP self-assessment program 

as requested by the Director, NRO.
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03.04 Director, Division of Construction Inspection and Operational Programs (DCIP).

a. Oversees the implementation of the cROP self-assessment program.

b. Develops policies for the cROP self-assessment program.

03.05 Chief, Construction Inspection Program Branch (CIPB).

a. Develops program guidance and procedures for the cROP self-assessment program.

b. Ensures data from all sources are collected and consolidated to facilitate analysis.

c. Recommends and implements improvements to the cROP self-assessment program.

d. Monitors the effectiveness of corrective actions and improvements to the cROP that are 

developed in response to self-assessment findings.

e. Develops the annual cROP self-assessment SECY paper.

f. Ensures program and inspectable area leads are assigned, as applicable.

03.06 cROP Program Area Leads.

a. Collect self-assessment data each calendar year for assigned program area and 

summarize the information for the annual self-assessment report.

b. Develop the annual program evaluation for assigned program area.

03.07 cROP Inspectable Area Leads.

a. Collect data and user experience for assigned inspectable areas and summarize the 

information for the annual self-assessment report.

b. Review and evaluate the implementation of assigned inspection procedures for 

applicable programs and include lessons learned in the information provided for the 

annual self-assessment report.

NOTE: A complete listing of current cROP Program Area Leads and Inspectable Area Leads is 

available through the “points of contact” link from the NRO Construction Reactor Oversight 

Process internal webpage.

2522-04 DEFINITIONS

04.01 Definitions can be found in IMC 2506, “Construction Reactor Oversight Process 

General Guidance and Basis Document.”
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2522-05 DISCUSSION

The cROP is the NRC's primary means of conducting oversight of licensee construction 

activities to provide reasonable assurance that facilities have been constructed and will operate 

in conformity with the license, the provisions of the Atomic Energy Act, and the Commission's 

rules and regulations. The cROP primarily consists of inspections, significance determination 

processes, assessment, and enforcement. 

As noted in IMC 2506, “Construction Reactor Oversight Process General Guidance and Basis 

Document,” the basis of the cROP was derived in many instances from the Reactor Oversight 

Process (ROP). Similar to the ROP, the objectives of the staff in developing the various 

components of the cROP were to provide tools for inspecting and assessing licensee 

performance in a manner that was more risk-informed, objective, predictable, and 

understandable than the previous construction oversight processes. The goals of the cROP 

also include the organizational excellence objectives of openness and effectiveness from the 

NRC’s Strategic Plan. Each of these cROP goals support the NRC’s mission to ensure 

adequate protection of public health and safety and the environment, and to ensure adequate 

protection in the secure use and management of radioactive materials.

The six cROP goals are summarized below:

 Objective - decisions are based on factual information and uninfluenced by emotion, 

surmise, or personal prejudice. 

 Risk-informed - risk insights are considered along with other factors (such as 

engineering judgment, safety limits, redundancy, and diversity) to better focus licensee 

and regulatory attention on issues commensurate with their importance to health and 

safety. 

 Understandable - the process and its results are clear and written in plain English.

 Predictable - more than one individual can follow the same defined process and arrive 

at the same conclusion in a consistent manner (i.e., repeatable). 

 Open - the NRC appropriately informs and involves stakeholders in the regulatory 

process.

 Effective - NRC actions are high quality, efficient, timely, and realistic, to enable the 

safe and beneficial use of radioactive materials.

The intended outcomes of the cROP, which help form its basis and are incorporated into the 

various cROP programs, include to successfully:

 Monitor and assess licensee performance

 Identify performance issues through NRC inspection

 Determine the significance of identified performance issues

 Adjust resources to focus on significant performance issues
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 Evaluate the adequacy of corrective actions for performance issues

 Take necessary regulatory actions for significant performance issues

 Communicate inspection and assessment results to stakeholders

 Make program improvements based on stakeholder feedback and lessons learned

It is important that the cROP be periodically evaluated and improved to ensure continued 

achievement of its specified goals and intended outcomes. The staff conducts an annual cROP 

self-assessment to determine the success of the cROP in meeting the goals and intended 

outcomes and reports the results in an annual Commission paper. The staff gathers information 

through the following three methods in conducting the annual cROP self-assessment:

 Performance Metrics

 Program Evaluations by Inspectable Area and Program Area Leads

 Internal and External Surveys

05.01 Performance Metrics. Performance metrics were developed to assess performance 

with respect to the six goals of the cROP. A detailed description of these performance metrics 

is contained in Appendix A. Each metric in Appendix A includes its definition, the criteria to 

determine whether it is met, the organization responsible for gathering the data, and a crossreference to the goals each metric is intended to support. The performance metrics will be 

reviewed as part of the annual cROP self-assessment process to evaluate their efficiency and 

effectiveness in providing a useful assessment of the cROP. Metrics may be added, deleted, or 

modified as necessary to provide a meaningful management tool. As part of the annual metric 

review, NRO/DCIP will evaluate the need to modify or add permanent automated systems to 

obtain needed metric information to minimize the burden on the staff.

05.02 Program Reviews. cROP program and inspectable area leads shall remain cognizant 

of the implementation of their assigned programs and procedures. Throughout the year, they 

shall review construction experience (ConE) issues for resolution and collect and review 

feedback forms written against their assigned areas to (1) assess the adequacy of the IMC or 

inspection procedure for possible improvements to its scope, focus, and guidance, (2) collect 

comments on the cROP from inspectors and licensees, and (3) include lessons learned in their 

assigned area.

The following program reviews will be conducted as a minimum during the annual cROP selfassessment:

 Review of inspection report adequacy using guidance in Exhibit 1 to this IMC

 Analysis of inspection hours and resource expenditures

 Analysis of Construction Inspection Qualification Status

 Construction Experience

 ITAAC Program Developments

In addition to these requirements, at the end of each year, the cROP program and inspectable 

area leads collect metric data and other insights into their areas and analyze the data for the 

previous year. The program and inspectable area leads shall summarize any insights gained, 

significant issues with, and major changes to their assigned areas. These analyses form the 
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basis for the program evaluations and are included in the annual cROP SECY paper. The 

summary input provided for each of the cROP areas is due to CIPB by the end of the 3rd week 

of January each year to support their specific program area evaluation for the annual selfassessment SECY paper. 

05.03 Internal and External Feedback. The staff will solicit and analyze stakeholder feedback

each year regarding cROP effectiveness. Possible methods to obtain feedback include internal 

and external surveys, internal and public meetings, and the IMC/IP change process.

05.04 Data Analysis and Recommendation Development. 

NRO/DCIP has the overall responsibility for data collection. A variety of methods are used to 

collect data regarding the performance of the cROP. These methods include data from CIPIMS, 

internal and external stakeholder surveys, independent audits, responses to Federal Register

notices, and information collected via program document reviews. To the extent possible, data 

collection is from agency databases and the need for ad hoc, manually developed data is 

minimized. Since the self-assessment program is relying heavily on the quality of the data 

contained in the CIPIMS database, it is imperative that Region II ensures the accuracy and 

timeliness of the CIPIMS data. 

Data is typically collected quarterly. Data reporting is completed within 30 calendar days of the 

end of the quarter under review. Exhibit 2 to this IMC is a data collection and submittal form 

detailing the specific data elements for which Region II has the lead responsibility for data 

collection. Region II shall complete Exhibit 2 each quarter and forward the completed form to 

NRO_cROP Resource@nrc.gov. 

NRO/DCIP has the overall responsibility for analyzing program data and developing 

recommended improvements to the cROP. Data analysis consists of comparing performance 

metric data with preestablished criteria and determining its meaning or programmatic impact. 

For example, criteria for acceptable cROP performance have been identified for each 

performance metric as detailed in Appendix A. A favorable comparison of data to these criteria

would indicate that the cROP met the process goals and objectives, and no programmatic 

changes would likely be recommended. However, for an unfavorable comparison, more 

analysis may be required to determine causal factors and develop recommended process 

improvements.

The analysis of data also includes evaluating the results of audits conducted on various aspects 

of the cROP, comments collected from internal and external stakeholders, and any other 

insights gained by cROP program area leads.

Due to their direct experience with the inspection and oversight programs gained through 

implementation of the procedures, Region II staff should be consulted during the data analysis 

and recommendation development process to ensure that any regional insights are incorporated 

into the change process.

05.05 Annual Commission Paper. As directed by the Commission, the staff shall forward the 

results of the annual cROP self-assessment in a Commission paper. This Commission paper is 

issued to support the Agency Action Review Meeting (AARM) and the Commission briefing on 
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AARM results that follows. This paper typically addresses any lessons learned from the 

previous year, effectiveness evaluations of any major changes previously made to the cROP, 

the status of issues discussed in the Commission paper from the previous year, and any other 

significant issues affecting the cROP. 

As a minimum, the annual Commission paper will include an evaluation of the construction 

inspection program, the construction Significance Determination Program (SDP), the ITAAC 

closure verification program, enforcement, and the construction assessment program. In 

addition, the staff typically includes discussions and assessments of cROP communication and 

inspector training activities, cROP self-assessment and independent evaluations, cROP 

resource expenditures and other topic areas as warranted. The paper will also include, as 

appropriate, an update on recent issues associated with ITAAC and an update on recent 

domestic and international ConE being incorporated into the NRC’s programs. 

The Commission paper will focus on the effectiveness of recent significant program changes, 

the strengths and weaknesses of the program, and additional planned actions to improve 

program effectiveness. The Commission paper will also present the staff’s overall conclusions 

as to whether the cROP has been successful in meeting its goals and intended. The staff will 

highlight those areas of the cROP that warrant focus in the upcoming year based on the selfassessment results and lessons learned.

END

Attachment 1: Revision History for IMC 2522

Appendix A: cROP Self-Assessment Metrics

Non-publicly available exhibits available from the cROP SharePoint site links, click here:

Exhibit 1, Inspection Report Review Outline

Exhibit 2, Data Collection and Submittal Form
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Attachment 1 - Revision History for IMC 2522

Commitment 

Tracking 

Number

Accession Number 

Issue Date

Change Notice

Description of Change Description of 

Training required 

and Completion Date

Comment and 

Feedback Resolution 

Accession Number

N/A ML12289A044

11/30/2012

CN 12-027

This is the initial issuance of this 

Inspection Manual Chapter. 

Completed a four year search for 

commitments and found none.

N/A ML12289A040

N/A ML14189A211

07/28/2014

CN 14-017

This update is being issued as a minor 

change with no comment period. 

N/A N/A