Issue Date: 02/01/16 1 IMC 2515 Appendix G

NRC INSPECTION MANUAL IRIB

INSPECTION MANUAL CHAPTER 2515 APPENDIX G

BASELINE INSPECTION GUIDANCE FOR POWER REACTORS PREPARING FOR

TRANSITION TO DECOMMISSIONING PHASE 

2515G-01 PURPOSE

This appendix provides guidance and is not a program requirement, to the regional staff for 

nuclear power licensees preparing to transition from an operating power reactor to a 

decommissioning reactor facility. The guidance is specifically for the period that occurs prior to 

the transition from oversight in accordance with Inspection Manual Chapter (IMC) 2515, “LightWater Reactor Inspection Program (ROP) - Operations Phase,” ROP inspection program to IMC 

2561, “Decommissioning Power Reactor Inspection Program.”

2515G-02 BACKGROUND AND OBJECTIVES

The NRC staff developed this guidance using lessons learned from nuclear power plants that 

have permanently ceased operation (e.g., Vermont Yankee (VY), Kewaunee, Crystal River

(CR), and San Onofre Nuclear Generating Station(SONGS)) and are now being inspected and 

assessed under IMC 2561. The guidance applies for the period that occurs prior to the 

transition of oversight from the ROP to IMC 2561, “Decommissioning Power Reactor Inspection 

Program.” The attachments to this appendix provides recommendations on potential 

adjustments to the inspection activities that can be used to perform a more detailed assessment 

of performance in areas potentially impacted by the impending shutdown. 
Issue Date: 02/01/16 Att1 - 1 IMC 2515 Appendix G

Attachment 1 – SUGGESTED INCREASE IN NUMBER OF INSPECTIONS PERFORMED FOR 

THE FOLLOWING AREAS

IP Number Title/Section Comments/Basis for Adjustment 

Associated IMC 2561 

Decommissioning 

Inspection Procedure

71111.04Q 

Equipment 

Alignment/Partial 

Attrition in staffing levels and reduction of

craft skill.

For example, at SONGS, non-licensed 

operators (NLO) were eliminated and the 

licnessed operators assumed the role of 

the NLO outside the control room (e.g. 

equipment manipulations, tagouts, log 

keeping). Ensure licensed operators 

could perfom their newly assumed duties 

that resulted from the staff reduction.

IP 60801 & IP 71801

71111.04S 

Equipment 

Alignment/Complete 

Attrition in staffing levels and reduction of

craft skill.

IP 71801

Review SFP system or 

a SFP support system

71111.11Q

Licensed Operator 

Requalification

Increase the Control Room (CCR)

observation, as staffing challenges may 

arise which may require Senior Reactor 

Operator (SRO)s taking Reactor Operator 

(RO) watches (this was the case at VY). 

Increase observation inside and outside 

the CCR as well as CCR observation 

during plant maneuvering or complex 

surveillances.

IP 41500 (Training and 

Qualification 

Effectiveness) & 

IP 71801

71111.15

Operability 

Determination and 

Functionality 

Assessments

Towards the end of the year, additional 

operability reviews for deferred 

maintenance, skipped surveillances, and 

degraded conditions that are accepted 

as-is. If engineering loses personnel and 

becomes short staffed, the quality of the 

engineering input could degrade for 

operability evaluations. 

71111.18 Plant Modifications

Increasing corrective maintenance 

backlogs

Decrease in problem identification and/or 

resolution.

This can result in an increase in active 

temporary modifications

IP 37801 Safety 

Reviews, Design 

Changes, and 

Modifications

71111.22 Surveillance Testing

Attrition in staffing levels and reduction of

craft skill.

IP 61726 Surveillance 

Observation
Issue Date: 02/01/16 Att2 - 1 IMC 2515 Appendix G

Attachment 2 – SUGGESTED DECREASE IN NUMBER OF INSPECTIONS PERFORMED 

FOR THE FOLLOWING AREAS

IP Number Title/Section Comments 

Decommissioning 

Inspection Procedure as 

Applicable

71111.06

Internal Flood 

Protection 

Measures

Submerged cables for structures, systems 

and components (SSC) that will be taken out 

of service will not pose risk

71111.07A

Heat Sink 

Performance

Consider Spent Fuel Pool (SFP) Heat 

Exanger (HX) or Containment Spray HX 

71111.12

Maintenance 

Effectiveness

Consider 1 annual maintenance effectiveness 

review on an equipment issue or system 

important to spent fuel safety 

Review deferral of preventative maintenance

and surveillance tests

Attention to increasing corrective maintenance 

backlogs

IP 62801 Maintenance 

Rule

71111.13

Maintenance 

Risk 

Assessment 

& Emergent 

Work Control

Given the reduction or elimination of 

preventive maintenance work and planned 

work windows removing systems from 

service, there will be few planned 

maintenance work activities for which 

management of risk will be valuable sample. 

The noted flexibility takes into Account that 

emergent activities will continue to be a focus 

area.

71111.19

Post 

Maintenance 

Testing

Number of maintenance activities will 

decrease

71114.06

EP Drill

Evaluation

As the staffing challenges arise ensure 

adequate staffing for Emergency response
Issue Date: 02/01/16 Att3 - 1 IMC 2515 Appendix G

Attachment 3 – NO CHANGES IN NUMBER OF INSPECTIONS PERFORMED FOR THE 

FOLLOWING AREAS

IP Number Title/Section Comments 

Decommissioning 

Inspection Procedure as 

Applicable

71111.01 

Adverse 

Weather 

Hurricane season 

Cold weather preparation

71111.05A Fire Drill

71111.20 

Refueling 

and Outage 

Activities

Verify SFP Foreign Material Exclusion (FME)

controls and SFP protection 

IP 60801 Spent Fuel 

Pool Safety at PSRs

71151

Performance 

Indicator 

Verification

71152

Problem 

Identification 

& Resolution

Consider focus on maintenance backlog and 

preventive maintenance history

IP 40801, SelfAssessment, Auditing 

and Corrective Action for 

Decommissioning

71153

Event Follow 

up

IMC 2515, 

App D Plant Status

Focus on SSCs necessary for the safe storage 

of spent fuel including security, radiation 

protection, and emergency preparedness

Periodically discuss with licensee 

representatives the status of decommissioning 

activities, problems encountered, and 

performance insights

IP 71801 

Decommissioning 

Performance and Status 

Review
Issue Date: 02/01/16 Att4 - 1 IMC 2515 Appendix G

Attachment 4 - BASELINE INSPECTION PROGRAM TEAM INSPECTIONS:

In addition to the inspection procedures that Resident inspectors complete, baseline inspections 

continue to be conducted by the regional inspectors such as engineering, radiation protection, 

emergency preparedness, operator licensing, and security with focus including but not limited to 

the following: 

 Samples of licensee evaluation and response to License Amendments, Generic Letters, 

Bulletins and Information Notices after shutdown announcement 

 Potential degradation to radiological controls including increase in dose and area of 

contamination on site 

 Evaluation of In Service Inspection deferrals 

 Security IPs remain as scheduled until all spent nuclear fuel (SNF) is removed. 

 Availability of emergency facilities, staffing and operability of emergency sirens 

 For Component Design Basis Inspection (CDBI), IP 71111.21,”Component Design Bases 

Inspection,” if the target date for the permanent shutdown is more than 3 years in the future, 

the next CDBI should occur as normally scheduled within the current triennial period

(sample examples: standby fuel pool cooling system (pump, pump motor and heat 

exchanger), normal fuel pool cooling system isolation valve, review of corrective action for 

NRC Information Notice (IN) 2009-26 – Degraded Neutron Absorber in the Spent Fuel Pool, 

NRC IN 2011-03 – Non-conservative Criticality Safety Analyses for Fuel). If the target date 

for the permanent shutdown is less than 3 years in the future, the Region (in consultation 

with NRR/DIRS) should consider either cancelling the inspection or combining the CDBI with 

evaluations of changes, tests or experiments and permanent plant modifications (IP 

71111.17T, “Evaluations of Changes, Tests and Experiments and Permanent Plant 

Modifications”). Combining the inspections allows flexibility for sample selection to the 

inspectors for covering CDBI and Plant Modifications. 

 A Biennial Problem Identification and Resolution (PI&R) Inspection, if it falls in the last year 

of the shutdown cycle, the region can consider reduced scope of the inspection. A 

decreasing trend for identifying issues and correcting them in a timely manner may be 

evaluated by the resident inspectors routinely.

 Consideration should be given to other baseline team inspections performed on a biennial 

and triennial basis for performance/scope increase or decrease as mentioned in the above 

CDBI and PI&R discussions.
Issue Date: 02/01/16 Att4 - 2 IMC 2515 Appendix G

IP Number Title/Section Last year

Total Inspection 

Hours 

Decommissioning 

Inspection Procedure 

as Applicable

71114.01-.04 Exercise Eval

Emergency Action 

Level (EAL) 

Emergency 

Preparedness 

(EP) changes

Continue as scheduled 

until certification of 

permanent removal of 

fuel

IAW IP IP 88XXX Emergency 

Preparedness

71130.0X Security Baseline 

Inspection

Continue as scheduled 

until certification of 

permanent removal of 

fuel

IAW IP IP 81200, Security

71124.0X Radiation 

Protection (RP) 

Inspections

Continue as scheduled 

until certification of 

permanent removal of 

fuel 

IAW IP IPs 83750, 84750, 

86750 may be used 

as additional 

guidance during 

transition

71152B Problem 

Identification and 

Resolution, 

Biennial 

Inspection

Recommend Reduced 

Scope

212-228 hours 

711111.17T Evaluations of 

Changes, Tests, 

or Experiments 

and Permanent 

Plant 

Modifications

Recommend increased 

sample size due to 

increase number of 

temporary 

modifications 

172-212 hours 

(Maximize)

IP 37001 (Facility 

Modifications), IP 

37700 (Design 

Changes and 

Modifications)

71111.21 Component 

Design Basis 

Inspection

Not Recommended or 

combine with Plant 

Modification

408 hours (+/- 15%)

71111.05T Triennial Fire 

Protection 

Inspection

Adjust schedule and 

scope based on 

licensee’s schedule of

decommissioning 

activities

IAW IP IP 64704 (Fire 

Protection Program)

71111.08 In-Service 

Inspection

Not Recommended 30-42 for Boiling 

Water Reactor 

(BWR)

80-100 for 

Pressurized Water 

Reactor (PWR)

71111.11 Operations 

Training

Recommend in the 1st

two Quarters (QTR)s 

to ensure adequate 

staffing and training

96 hours

71130.11 Material Control 

and Accountability 

Inspection

If it is in the last year of 

the transition cycle use 

the guidance of IP 

85102 from IMC 2561

IAW IP IP 85102 (Material 

Control and 

Accounting –

Reactors) as part of 

IMC 2561

END
Issue Date: 02/01/16 Att5 - 1 IMC 2515 Appendix G

Attachment 5

Revision History for IMC 2515 Appendix G

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, 

Non-Public)

ML15183A264

02/01/16

CN 16-004

Initial issuance. Researched commitments for four 

years and found none. Created to provide guidance 

to the regional staff for nuclear power licensees 

preparing to transition from an operating power 

reactor to a decommissioning reactor facility

ML15188A020