Issue Date: 03/16/15 1 IP 88075

NRC INSPECTION MANUAL NMSS/FCSE

INSPECTION PROCEDURE 88075

EVENT FOLLOW-UP

PROGRAM APPLICABILITY: 2600

88075-01 INSPECTION OBJECTIVE

01.01 Evaluate licensee events and degraded conditions to provide input in determining the 

need for an Incident Investigation Team (IIT), Augmented Inspection Team (AIT), Special 

Inspection (SI), or other reactive inspection.

01.02 Review written and telephonic licensee event reports (LERs).

88075-02 INSPECTION REQUIREMENTS

02.01 Event Follow Up. This procedure is for initial follow-up to events to make initial 

decisions on the safety significance of an event to determine the NRC response. If an inspector 

is on site, work with regional management to determine the following by observation and 

discussions. If there is no inspector on site, determine the following through discussions with 

licensee representatives. For information gathering related to security, material control and 

accountability (MC&A), or nuclear criticality safety (NCS) issues, involve appropriate staff from 

those organizations in communications with licensee representatives.

a. Observe plant parameters and status, including items relied on for safety (IROFS) and 

other relevant safety control availability. Determine alarms/conditions preceding or

indicating the event.

b. Determine the initial risk-significance of the event considering the information in the 

integrated safety analysis (ISA) Summary, if any, and the level of safety controls or 

IROFS lost or degraded and remaining.

c. Determine whether controls remaining were sufficient to ensure that the performance 

requirements of 10 CFR 70.61 continued to be met.

d. Evaluate performance of mitigating systems and licensee actions.

e. Determine whether the licensee properly classified the event in accordance with 

emergency plan implementing procedures and made timely notifications to NRC and 

state/county governments, as required (10 CFR Parts 20, 26, 40.60, 70.50, 70.52, Part 

70 Appendix A, or license requirements).
Issue Date: 03/16/15 2 IP 88075

f. Communicate details regarding the event to management and staff in the Region and 

Headquarters, as input to their determining the need for an IIT, AIT, SI, or other reactive 

inspection.

g. For events that result in an immediate inspection (IIT, AIT, SI, or other), the Region will 

document the results of the review.

h. For events that do not result in an immediate inspection, provide a paragraph to the 

project or resident inspector concerning the inspector’s review of the event to be 

included in the inspection report documenting the on-site review of the event.

02.02 Event Report Review. Review LERs and related documents regarding the accuracy of 

the LER (e.g., based on independent NRC observations), appropriateness of corrective actions, 

violations of requirements, and generic issues.

88075-03 INSPECTION GUIDANCE

This procedure applies to the various fuel cycle events reportable per NRC regulations. Such 

events include (but are not limited to) criticality safety events reportable under Bulletin 91-

01,”Reporting Loss of Criticality Safety Controls,” and supplements thereto, and the various 

types of events reportable under 10 CFR Sections 40.60 (source material), 70.50 (mainly 

radiological events), 70.52 (criticality and safeguards events), 71.95 (transportation events),

73.71 (safeguards events)) and 20.2201, 20.2202, and 20.2203 (radiological and environmental 

events). It should be noted that those events requiring immediate notification would likely result 

in activation of the NRC Incident Response Plan. In those cases, this procedure would not 

apply. It should also be noted that responses to transportation accidents addressed by 

Inspection Manual Chapter (IMC) 1330,”Response to Transportation Accidents Involving 

Radioactive Materials,” are not considered events covered by this procedure. This procedure 

does not apply to events outside of NRC jurisdiction. For example, chemical events that does

not impact or are not directly related to licensed material activities do not apply to this procedure. 

Occupational Safety and Health Administration (OSHA) events that do not affect the safety of 

licensed material do not apply.

Management Directive (MD) 8.3,”NRC Incident Investigation Program,” defines a significant 

operational event as a radiological, safeguards, or other safety-related operational event at an 

NRC-licensed facility that poses an actual or potential hazard to public health and safety, 

property, or the environment. At fuel cycle facilities, these events include significant unplanned,

degraded conditions identified by the licensee or NRC.

Upon receipt of licensee notifications (required or courtesy), on-site inspectors provide details 

regarding plant status and performance of equipment and operators to regional and 

headquarters staff and management. The details are used to determine the level of 

investigatory response, if any (i.e., IIT, AIT, or SI).

Appendix A provides guidance for limiting NRC’s impact on licensees during an event.
Issue Date: 03/16/15 3 IP 88075

03.01 Event Follow Up.

a. No specific guidance.

b. Fuel facilities generally do not represent a significant risk to the public. However, some 

risk to the public is possible when materials reach offsite locations. Events that would 

most likely pose some risk to the public include theft of special nuclear material (SNM) 

(safeguards events), certain transportation events and radiological events due to a large 

fire or explosion not contained by facility structures and systems.

c. Significant risks mostly impact workers at the fuel facilities rather than the public. 

Credible events that can cause serious injury or death to the most workers are 

considered the most risk significant. Such events (in order of highest risk) would include 

large fires or explosions, large toxic chemical releases, and criticality accidents. 

d. Use Integrated Safety Analysis (ISA) Summary, Safety Analysis Report, or license 

application to determine the potential consequences and remaining controls.

Inspection Manual Chapter 1301,”Response to Radioactive Material Incidents that do 

not Require Activation of the NRC Incident Response Plan,” indicates that events that 

do not require activation of the NRC Incident Response Plan are to be evaluated for 

determination of safety significance in order to determine further NRC actions. A quick 

review of certain events is needed in order to determine if an immediate NRC response 

is necessary. Events that are reportable in writing within 30 days do not need to be 

reviewed for immediate NRC response, but an evaluation may be needed so that 

appropriate disposition of the event by the licensee can be confirmed and documented 

in a future inspection. The following steps describe the specific actions to be taken by 

staff:

1. Events Required to be Reported Immediately or in One Hour.

(a) Ensure that events required to be reported have been properly reported to 

the Headquarters Operations Officer (HOO).

(b) Screen events upon receipt to determine the potential need for immediate 

NRC action and who has lead responsibility.

(1) Actual Safety Significance. Conduct an informal, qualitative analysis 

of as-found conditions. The analysis should consider the resulting 

consequences of the event, and should not give credit to any 

fortuitous mitigation of the event due to items not identified as 

controls;

(2) Potential Safety Significance. Determine the potential safety 

significance of the event by considering credible failures of 

structures, systems, equipment, and controls that could occur 

concurrently with the actual event. Such potential scenarios should 

be discussed based on the likelihood and associated consequences 

of concurrent failures; and
Issue Date: 03/16/15 4 IP 88075

(3) Regulatory Significance. Determine the potential regulatory 

significance of the event by comparing the event circumstances with 

examples in the current NRC Enforcement Policy. State the 

appropriate apparent severity level for any violation that may be 

associated with the event. If this results in a potential escalated 

enforcement issue, it should be identified to the licensee during the 

event follow-up inspection.

The need for medical consultants, assistance from other Federal or State 

agencies, and/or a special NRC inspection team are to be considered.

(c) Issue a PN and/or MR, as appropriate.

2. Events Required to be Reported within 24 hours.

(a) Ensure that events required to be reported within 24 hours or less have 

been properly reported to the HOO.

(b) Screen events upon receipt to determine the potential need for immediate 

NRC action and who has lead responsibility. The need for medical 

consultants, assistance from other Federal or State agencies, and/or an 

NRC inspection team are to be considered.

(c) Issue a PN and/or MR, as appropriate.

(d) For events that have been determined initially not to be of high safety, 

safeguards, or regulatory significance, within five working days of the event 

notification, complete a preliminary evaluation of the event. The evaluation 

should include the following information when available:

(1) Background/Causes/Precursors. Include a brief description of the 

process involved and any pertinent process history, an event 

summary that includes the event sequence, and any precursor and 

background information of process conditions leading to the event;

(2) Actual Safety Significance. Conduct an informal, qualitative analysis 

of as-found conditions. The analysis should consider the resulting 

consequences of the event, and should not give credit to any 

fortuitous mitigation of the event due to items not identified as 

controls;

(3) Potential Safety Significance. Determine the potential safety 

significance of the event by considering credible failures of 

structures, systems, equipment, and controls that could occur 

concurrently with the actual event. Such potential scenarios should 
Issue Date: 03/16/15 5 IP 88075

be discussed based on the likelihood and associated consequences 

of concurrent failures;

(4) Regulatory Significance. Determine the potential regulatory 

significance of the event by comparing the event circumstances with 

examples in the current NRC Enforcement Policy. State the 

appropriate apparent severity level for any violation that may be 

associated with the event. If this results in a potential escalated 

enforcement issue, it should be identified to the licensee during the 

event follow-up inspection;

(5) Licensee’s Actions. Review the adequacy of the licensee’s

response to the event, including characterization of the event, and 

immediate and proposed long term corrective actions. Verify that 

the licensee reported the event in accordance with applicable 

regulations and license conditions;

(6) Document NRC Decisions and Actions. Record any decisions or 

actions taken as a result of the preliminary evaluation of the event; 

and 

(7) Document Issues for Inspection Follow-up. Document items to be 

investigated at the next inspection pertaining to the event (causes, 

precursors, corrective actions, etc.). Include these event follow-up 

items in the Inspection Plan.

(e) Upon issuance of an inspection report documenting and closing the event, 

the inspector is to complete a closeout evaluation (using the preliminary 

evaluation as a basis) that references the appropriate inspection report 

number and any additional findings or conclusions. 

e. No specific guidance.

f. MD 8.3 provides criteria which are applicable to fuel cycle facilities. Inspectors provide 

details which help determine whether the event meets the criteria. An IIT or AIT is 

considered for certain events or degraded conditions meeting deterministic criteria, e.g., 

exceed a safety limit of the licensee application, site area emergency, significant 

radiological release, significant occupational or public exposure, and safeguards 

concerns.

Other deterministic criteria related to events or degraded conditions are risk-informed, 

e.g., loss of a safety function or multiple failures in systems used to mitigate an event.

g. No specific guidance.

h. No specific guidance.
Issue Date: 03/16/15 6 IP 88075

03.02 Event Report Review. Review verbal reports and written LERs. Final LER reviews are 

to be done as part of a routine on-site inspection, generally by the technical specialist for the 

safety area involved. IMC 0616,”Fuel Cycle Safety and Safeguards Inspection Reports”

provides guidance on documentation of LER reviews.

Because of potential errors resulting in inspection staff not receiving 30-day reports, inspectors, 

during operations inspections, should inquire about all 30-day reports issued since the last 

operations inspection.

Based on the evaluation of the 30-day events received by mail or through inspection efforts, the 

inspector will determine if further actions (PIM entries and follow-up/closeout evaluations) are 

required.

88075-04 RESOURCE ESTIMATE

Inspector effort may be minimal for events which do not meet the MD 8.3 deterministic criteria, up to 

24 hours for significant operational events, and 1-8 hours for an LER review.

88075-05 REFERENCES

Management Directive 8.3,”NRC Incident Investigation Program”

Inspection Procedure 93800,”Augmented Inspection Team”

Inspection Procedure 93812,”Special Inspection”

Inspection Manual Chapter 0616,” Fuel Cycle Safety and Safeguards Inspection Reports”

88020-06 PROCEDURE COMPLETION

Implementation of this IP is complete when each inspection requirement has been addressed. 

The individual samples to be inspected, and the breadth of the review will be determined by the 

inspector based on the degree of compliance with the requirements observed, the risksignificance of the activity, and the extent of the activity or records available.

END
Issue Date: 03/16/15 App A - 1 IP 88075

APPENDIX A

LIMITING NRC IMPACT DURING EVENTS

I. Inspector Conduct While in the Control Room.

For plant events, inspectors must perform sufficient inspection to develop an independent 

assessment of plant conditions, which will be used in making decisions on NRC’s responses to 

an event. Activities that form the basis for this assessment may include independent 

measurements, verifying the accuracy of information, control board walkdowns (to observe 

annunciators, process parameters, switch positions, and other instrumentation), or assessment 

of licensed operator performance during ongoing activities.

The NRC's goal is to monitor and assess with as little impact on the licensee or certificate holder 

as possible and at the same time ensure NRC evaluations are timely and accurate. During plant 

events, timely and independent inspector assessments are crucial; however, the degree of 

interaction with operators may be limited in light of ongoing control room activities. The 

inspector must use judgement in establishing a balance between obtaining necessary 

information and not being intrusive in licensee response activities. The appropriate balance 

involves numerous variables, including safety significance of the event, complexity of the event, 

time constraints, and available staff.

The following guidance is provided to establish consistency for inspector conduct in the control 

room. When the NRC activates its emergency response plan, inspectors should follow the 

guidance in the applicable emergency response procedure. This guidance is intended for use in 

situations where the NRC has not activated its emergency response plan; however an abnormal 

event has happened at the plant. Inspectors should note that some of the guidance, such as 

inspector location in the control room and not interrupting operators, apply to all emergency 

situations. While this guidance deals mainly with event responses, specific attributes are 

applicable to inspector interaction with operators during normal conditions both in and outside 

the control room.

a. During the initial response to events, the assigned senior resident inspector (SRI) or the 

inspector acting in this capacity is in charge of all other NRC inspectors. These 

inspectors will take their direction from the SRI.

b. The number of inspectors in the control room at any given time should be the minimum 

number needed to accomplish the agency's work. Typically there should be only one 

inspector in the control room during an event, unless special circumstances warrant 

additional inspectors. If several inspectors or other NRC personnel are in the control 

room during an event, the SRI or resident inspector will be in charge of them and will 

determine and communicate to the other inspectors and personnel what, if any, 

assistance is needed.

c. Inspectors will adhere to the licensee’s established administrative policies regarding 

entry into the restricted or "at the controls" area of the control room. For example, the 

inspector may need to ask the control room senior reactor operator (SRO) or reactor 
Issue Date: 03/16/15 App A - 2 IP 88075

operator (RO) for permission to enter the restricted area. Under no circumstances 

should the inspector demand entry into the restricted area. If such entry is denied, the 

inspector should escalate the request to the licensee’s management and inform NRC 

management of the problem. For general access to the control room, the licensee's 

policy should recognize that inspector access will be unannounced. Inspectors who do 

not routinely enter the control room should identity themselves to the operators when 

they enter the control room.

d. While observing ongoing activities in the control room, the inspector should be in a 

location which is out of the way of operators and does not obstruct their view of the 

reactor controls and instrumentation, yet the location provides the inspector with a broad 

view of the control room. An acceptable location outside the restricted "at the controls" 

area is preferable. It is recognized that short amounts of time in the restricted area may 

be necessary at appropriate stable time periods to verify significant parameters.

e. Operators should not be interrupted, questioned or otherwise distracted from performing 

their duties while responding to an event or while performing other duties where their 

attention must be focused on the task at hand. Also, inspectors should not interfere, 

interrupt, or otherwise disturb communications between operators and communications 

between operators and their supervision.

f. If an inspector identifies a significant problem or question about plant or operator safety 

that needs to be addressed in an urgent manner, then the inspector should discuss it 

quickly and quietly at a time when it will not interrupt ongoing operator actions. This 

discussion should be held with the shift supervisor or emergency response manager.

However, it may be appropriate to interrupt the operator if the inspector feels that an 

operator action may endanger plant personnel or the plant. Inspectors should hold their 

non-urgent questions for a more appropriate time.

g. NRC personnel communicating with off-site organizations should generally do so from 

outside of the control room. Communication is possible from the NRC phone in the 

Operation Support Center (OSC) or equivalent or other phones outside the control room 

that have been agreed to with the licensee. It is acceptable for the inspector to make a 

phone call from the control room provided the licensee agrees to the use of the phone 

and the phone conversation will not disrupt control room activities.

h. Because of the authoritative role of the NRC, licensees listen carefully to inspectors and 

may interpret statements, side remarks, or observations as directives or requirements. 

Consequently, open, clear, and direct communications between inspectors and 

licensees are particularly important during events.

II. Conference Calls with Licensees During an Ongoing Event.

When initially responding to an event, the NRC is dependent upon information provided by 

licensees and inspectors at the plant (typically resident inspectors). This information is used for 

initially assessing events and making decisions about how to respond to the event. The NRC 

typically gets this initial information from licensees through their notification to the NRC 

Operations Center or from conference calls between the NRC staff and the licensee or 
Issue Date: 03/16/15 App A - 3 IP 88075

certificate holder. The NRC values conference calls as an efficient method of obtaining accurate 

and timely information. Such calls promote a mutual understanding of the facts and any 

concerns.

Caution is needed in scheduling and conducting conference calls when the calls are held during 

an ongoing event or situations where heightened licensee attention is being directed to a plant 

evolution. While information obtained in a conference call is extremely valuable to the NRC's 

overall understanding of a plant event, the overriding goal is that the call will not interfere or 

detract from the licensee's ability to safely operate the plant. The following guidance should be 

used for conducting conference calls with licenses or certificate holders during abnormal plant 

conditions. Examples of abnormal plant conditions would be the declaration of an Alert or the 

use of an emergency operating procedure (EOP).

a. NRC management should decide whether a conference call with the licensee is needed 

and if conducting a conference call is appropriate at that particular time. NRC 

management may want to discuss with senior licensee or certificate holder management 

the possibility of conducting a conference call. The stability of the plant is the primary 

factor in deciding on a conference call. Other factors to be considered in this decision 

include: the current level of NRC staff understanding and information available for the 

event; the safety significance of the event; the complexity of the event; and the current 

level of licensee or certificate holder activity in mitigating the event.

b. Generally the licensee or certificate holder should be informed of the NRC's desire to 

have a conference call by the senior resident inspector or resident inspector if they are 

available. The licensee or certificate holder must be included in deciding the most 

appropriate time for the call so that the call does not interfere with plant response 

activities. Also the licensee or certificate holder should decide which individuals from 

their staff will participate in the call.

c. When requesting the conference call, the licensee or certificate holder must be clearly 

informed of the NRC's desire that the conference call not interfere with their response to

plant conditions and that delaying the call is a valid option for them.

d. NRC technical staff and management with the right background should participate in the 

conference call to ensure proper questioning and understanding of the event and 

associated issues. The senior NRC manager on the call should identify his/her self and 

is responsible for ensuring that the conference call discussions are properly focused on 

important issues and that side issues are discussed at another time.

e. If time allows, an agenda for the conference call should be developed to ensure the call 

remains properly focused. The licensee or certificate holder should be informed of the 

proposed discussion topics and planned NRC participants to allow the licensee to 

prepare for the call.

f. Any follow-up actions resulting from the conference call should be summarized at the 

end of the call by an NRC manager to ensure the licensee clearly understands and 

agrees with the actions.

END
Issue Date: 03/16/15 Att 1-1 IP 88075

ATTACHMENT 1

Revision History for IP 88075

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

(Pre-Decisional, NonPublic)

N/A 07/28/06

CN 06-019

IP 88075 has been issued because of the need for 

a new Inspection Procedure for Event Follow-up.

None ML061780464

N/A ML15005A092

03/16/15

CN 15-004

Editorial changes made:

 Reformatted to comply with IMC-0040, 

Preparing, Revising and Issuing 

Documents for the NRC Inspection Manual

 All references to charge codes removed as 

HRMS guidance is tracked at the Division 

level.

 All references to specific documentation 

requirements have been removed as all 

event-related documentation is tracked 

using the Region II ROI 0704.

None ML15005A103