Performance Based 

Inspection

Janine F. Katanic, PhD, CHP

Health Physicist, US NRC FSME

and

James L. Thompson

Senior Health Physicist, US NRC Region IV
Objectives

• Discuss performance based inspection 

techniques

• Discuss common misconceptions regarding 

performance based inspections

• Describe the inspection process

• Discuss examples of performance based 

inspections

• Discuss documentation of inspection results
What is 

Performance Based 

Inspection?
Performance Based 

Inspection: 

• Is an observation of a 

licensee’s program and 

activities to determine if 

regulatory and technical 

objectives are being met

• Examines results or 

outcomes rather than a 

prescriptive process, 

technique, or procedure

• Can be used for any type 

of licensed activity
Misconceptions 

Regarding 

Performance Based 

Inspections 
Performance Based 

Inspection Misconceptions: 

• Myth: Doing 

Performance Based 

inspections is a new 

concept

• Fact: Inspectors have 

been using 

Performance Based 

inspection techniques 

for many years
Performance Based 

Inspection Misconceptions: 

• Myth: Performance Based 

inspection takes less time than 

Compliance Based inspection

• Fact: Performance based 

inspection involves actual 

observation of activities in 

progress, which usually takes 

more time than simply reviewing a 

record related to that activity 
Performance Based 

Inspection Misconceptions: 

• Myth: Performance Based 

inspection means I don’t have to 

look at any records or 

documents.

• Fact: A balance must be 

achieved between observing 

licensed activities and reviewing 

licensee records. Record 

reviews may be necessary to 

further inspect and support your 

observations. 
Performance Based 

Inspection Misconceptions: 

• Myth: If the licensee isn’t 

performing licensed activities 

the day of my inspection, I 

can’t do a performance based 

inspection.

• Fact: Performance based 

inspection techniques are not 

just observation of activities in 

progress but also includes 

interviews with workers and 

demonstrations. 
Performance Based 

Inspection Misconceptions:

• Myth: Performance based 

inspecting means that I 

ignore violations of low 

safety significance.

• Fact: Not true; although 

you should spend your 

time observing safetysignificant licensed 

activities, if you happen to 

identify any violation, it 

should be handled through 

the normal enforcement 

process.
Why use Performance Based 

Inspection Techniques?

• Compliance does not always 

equal Safety 

• Inspection results are more 

clearly linked to safety and risk 

significance

• Obtain real-time facts to support 

conclusions

• Enhances licensee corrective 

actions by encouraging them to 

continuously improve 

performance
What is Risk?

• Risk is the relationship between consequence 

and probability 

• Highest risk licensees are inspected more 

frequently and typically more thoroughly (e.g. 

inspection priority codes)

• Similarly, when performing an inspection, we 

should focus on the higher risk-significant 

activities 
Each Inspection is 

a Snapshot in Time

Last 

inspection

TIME

Current

inspection

Observable through 

records reviews, 

interviews

Observable 

through licensee 

performance
Inspection Process

• Prepare for the inspection

• Plan the inspection

• Perform the inspection

– Make Observations

– Evaluate Observations

• Conclude the inspection 

– Overall judgment of licensee performance

– Make findings as appropriate

– Document the inspection results

– Take enforcement actions as appropriate
Prepare for the Inspection 

• Don’t underestimate the value of proper 

preparation

• Be familiar with the applicable 

regulations/requirements

• Review the appropriate inspection 

procedure(s)

• Be familiar with relevant guidance documents 

or other generic communications
Prepare for the Inspection 

• Review the license

– Note any higher risk-significance activities

– Note any uncommon license conditions or unusual 

license tie-downs

– Has the license been amended or renewed since the 

last inspection? Does this warrant additional onsite 

review or follow-up? 
Prepare for the Inspection 

• Review the previous inspection results. 

– Is there anything that warrants follow-up? 

– Are there things that were not reviewed during 

the last inspection?

• Has the licensee reported any events since the 

last inspection? Have events or generic issues 

been identified at similar licensees? 

• Based on the above, as well as input from your 

management, select the elements for 

inspection
Plan the Inspection

• Inspection Timing

– Perform the inspection 

when the likelihood is 

highest that licensed 

activities, especially 

high risk licensed 

activities, will occur

– Consider any sitespecific training or 

security clearances 

that may be necessary 

for access to the 

licensee’s facility

– Performing inspections 

on the backshift or offnormal hours? 
Plan the Inspection

• Assemble resources

– Your knowledge is the 

best resource

– Select a proper 

instrument for the 

inspection type and 

know how to use it

– Bring or have access 

to any documents you 

might need (e.g. copy 

of the license, 

regulations, previous 

inspection record, etc.)

– Have the necessary 

and appropriate gear 

and equipment to 

observe the licensed 

activities
Perform the Inspection

• At the beginning of the Inspection: 

– If possible, go to the location/area you want to inspect 

first

– Make any “immediate” observations (e.g. there is a 

package containing radioactive material sitting 

unattended in the hallway)

– Ask questions

• What activities are ongoing today?

• What can I observe today?

– Identify the areas you want to focus on and set a 

tentative schedule

– Be flexible! Modify your inspection plan to adjust for the 

opportunity to observe activities
Perform the Inspection

• During the Inspection:

– Observe

• Direct observation of licensed activities is best

• No activities in progress or planned? Indirect 

observation

– Conduct interviews

– Ask for demonstrations and walk-throughs

– Review selected documents

– Maintain constant awareness of what is going 

on around you, look for inspection 

opportunities
Perform the Inspection

• During the Inspection:

– Perform independent measurements, and 

when appropriate collect samples 

– Set the performance example (e.g. frisking 

when leaving an area of use for unsealed 

material)
Perform the Inspection

• During the Inspection:

– Engage/Interface at all levels of licensee 

personnel (e.g. RSO, materials users, 

housekeeping, administrative staff, security 

personnel, etc.) 
Perform the Inspection

• During the Inspection:

– It’s your inspection, not the licensee’s

• Keep your focus

• Take the high road

• Be reasonable

– You are the regulator
Perform the Inspection

• Find your own inspection opportunities

– How to locate temporary job sites prior to the 

office inspection

• Look online or in the phone book for fabrication 

shops, refineries, etc.

• Know where licensed activities are being 

performed from previous inspection records

• Using your survey meter to triangulate work 

locations

• Looking for radiography trucks and well logging 

trucks at gas stations, hotels, and work locations
Perform the Inspection

• Find your own inspection opportunities

– How to locate temporary job sites during the 

office inspection

• Review utilization logs if you are inspecting well 

loggers, radiographers, portable gauges

• Interview workers that routinely use licensed 

material in the field

• Ask management

• You can take a lunch break and look for workers at 

temporary job sites, then report results to 

management upon your return
Interview Skills

– Be approachable

– Have a questioning attitude

– Do not ask “yes or no” questions

– Do not ask leading questions

– Ask open-ended questions

– It is not your time to impress with your knowledge

– Listen to the answer, even if you think you know what the 

answer is (jump to conclusions)

– Watch body language and “non-verbal communication”

– Don’t confront person because of a “wrong answer”

– Repeat the question or ask it a different way

– Try to interview staff away from their supervisors; they may be 

reluctant to talk to you with their management listening in
Pull the String
Evaluate your Observations

• Trust that the licensee has provided you with accurate 

information; then verify the accuracy of selected information 

you obtained from the licensee

– Cross-check some selected records against your 

observations and licensee statements

• Based on what you have observed/heard, are there any 

issues that warrant further inspection effort? Potential 

violations? Safety Issues? Security issues?

– If yes: gather more information

• Is it isolated or is it programmatic?

• Do you understand the cause?

– If no: move on
Examples of 

Compliance Based 

Vs. 

Performance Based Inspection 

Techniques
Leak Tests:

• Compliance Based 

Technique:

– “Show me your last 5 

years of leak test records 

for these gauges.” 

– Then spend 1 hr looking 

at all of them and 

documenting the results in 

your inspection record.
Leak Tests:

• Performance Based 

Technique: 

– “Can you tell me how 

often you leak test this 

gauge?”

– “Can you explain to 

me or demonstrate 

how you would leak 

test this gauge?” 

– “Do you know what 

results would indicate 

there is potentially a 

problem?”

– “What would you do if 

it was found to be 

leaking?” 
Leak Tests:

– If the answers to the above make sense, you 

may wish to review a small sample of 

representative records, and move on.

– If the answers to the above do not make 

sense, or there may be a potential violation, 

dig deeper. 

• Ask to see copies of records, procedures, interview 

other workers, etc.
Written Directives

• Compliance Based 

Technique:

– Look at file with written 

directives and check to 

make sure required 

blocks are filled out

• e.g. patient name, 

radionuclide, treatment 

site, dose per fraction, 

number of fractions, 

total dose

• Performance Based 

Technique:

– Ask the Medical 

Physicist to walk 

through a sample of 

case files and explain 

how they verify that 

the administration is in 

accordance with the 

written directive
Identified Violations

• What is the potential significance of the finding?

• Inform licensee management in a timely manner, but 

commensurate with the significance of the potential 

violation

• Gather supporting information:

– What requirement was violated?

– How did this violation occur?

– When did the violation first occur? How long did it exist? Does it still 

exist?

– Who identified the violation?

– What are the actual or potential safety/security consequences?

– What causal factors that led to this violation?

– Is the violation isolated or programmatic? Extent of condition?

– What are the licensee’s corrective actions to address the violation?
What if I Observe Unsafe 

Conditions?

• Take prompt action if the unsafe condition or violation, if not 

immediately corrected, could result in an a licensee employee or 

member of the public being harmed or could cause harm to the 

environment

– Example: Radiography being performed without performing a 

survey after source retraction

• Tactfully intervene

• Inform the licensee personnel engaged in the activity that the 

activity that is ongoing or is about to be performed is contrary to 

safety or regulatory requirements

• Request corrective actions 

• Immediately notify licensee management and your supervisor

• Licensee pushback? Seek out licensee senior management and 

consult your management for direction.
Corrective Actions

• Try to “prioritize” violations with respect to safety or 

security significance 

– e.g. missing posting on a door vs. unsecured licensed material

• Short Term Corrective Actions:

– Immediate

– Compensatory

– Stops the violation right now but may not be long lasting

• Long Term Corrective Actions:

– Corrects the issue with greater permanence 

– Addresses programmatic weaknesses

– Prevents the violation from recurring
You Can’t Inspect 100% of 

Everything Since the Last 

Inspection 

• Time constraints 

– It takes time to fully develop inspection 

findings

• Don’t panic!

– You or another inspector can come back later 

if necessary to look at other areas, or inspect 

them during the next inspection, or ask your 

management for inspection assistance, etc. 
Things to Avoid When 

Conducting Performance Based 

Inspections

• Allowing an unsafe or unsecure condition to continue 

without saying something immediately/promptly

• Compromising your personal safety or that of licensee 

personnel

• Doing something or asking the licensee to do something 

that will put licensee into non-compliance or be unsafe

• Unnecessary radiation exposure

• Unnecessary security risks
Things to Avoid When 

Conducting Performance 

Based Inspections

• Interrupting patient care

• Unnecessarily delaying scheduled licensee work 

activities

• Making unreasonable demands and impositions on the 

licensee/licensee staff

• “Bossing” licensee staff around

• Damaging licensee equipment
Conclude the inspection 

• Make an overall judgment of licensee performance

• Before leaving the licensee facility

– Explain any findings or preliminary findings

– Cite the specific requirement and how it does not appear they 

are meeting it

– listen to the licensee’s perspective

– Understand what licensee intends to do to correct any identified 

findings

• After leaving the licensee facility

– Discuss with your management

– Gather any additional or follow-up information

– Document the inspection results

– Take enforcement actions as appropriate
Document the Inspection

• Documentation to the licensee

– Should be clear

– Should document the basis for any findings and 

enforcement actions

• Documentation for the file

– Program scope, inspection scope

– Performance observations

– Follow-up on any previous violations and events

– Sufficient information to support any identified 

findings

– Conclusions
Summary

• Performance-based inspections are used to 

determine whether or not a licensee’s 

program activities are executed in a manner 

that ensures safety 

• Prepare-Plan-Perform-Evaluate-Document
Questions?

Janine Katanic

Janine.Katanic@nrc.gov

817-200-1151

James Thompson

James.Thompson@nrc.gov

817-200-1538