Issue Date: 05/01/15 1 2515

NRC INSPECTION MANUAL

IRIB

MANUAL CHAPTER 2515

LIGHT-WATER REACTOR INSPECTION PROGRAM—OPERATIONS PHASE

2515-01 PURPOSE

To establish the policy for the light-water operating reactor inspection program.

2515-02 OBJECTIVES

02.01 To obtain factual information providing objective evidence that power reactor facilities 

are operated safely and licensee activities do not pose an undue risk to public health and safety.

02.02 To determine the causes of declining performance before such performance reaches a 

level that may result in an undue risk to public health and safety.

02.03 To identify those safety significant issues that may have generic applicability.

02.04 To provide direction for modifying the baseline inspection program in the event of a 

pandemic.

2515-03 APPLICABILITY

This inspection program is implemented when an operating license is issued for a facility. 

Portions of the light-water reactor inspection program for the startup phase (IMC 2514) may also 

be conducted during the initial operation of a facility. The light-water reactor inspection program 

for the preoperational testing and operational preparedness phase (IMC 2513) will have been 

completed by the time this program is in effect.

This inspection program will remain in effect until the facility is permanently shut down and 

enters the post-operational phase (cf. IMC 2561, "Decommissioning Power Reactor Inspection 

Program"). The post-operational phase occurs after a licensee submits a written certification to 

cease operation in accordance with 10 CFR 50.82(a)(1)(ii). After the certification is received by 

the NRC, the facility will no longer be subjected to the Reactor Oversight Process (ROP) and 

will transition to the decommissioning inspection program.

As directed by section 2515-14 and Appendix E of this IMC, inspection program can be modified 

in the event of a pandemic that severely reduces available inspection resources.
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2515-04 DEFINITIONS OF INSPECTION FREQUENCIES

04.01 Triennially or Every Three Years (T)1. The inspection will be performed at least once 

during Reactor Oversight Process (ROP) cycles 1-3, ROP cycles 4-6, ROP cycles 7-9, etc. It is 

not intended for this to be based on a rolling 3 year cycle.

04.02 Biennially or Every Two Years (B)1. The inspection will be performed at least once 

during ROP cycles 1-2, ROP cycles 3-4, ROP cycles 5-6, etc. It is not intended for this to be 

based on a rolling 2 year cycle.

04.03 Annually (A). The inspection effort will be performed at least once each calendar year.

04.04 Semiannually (S). The inspection effort will be performed two times each calendar year, 

once each half calendar year.

04.05 Quarterly (Q). The inspection effort will be performed four times each calendar year, 

once each calendar quarter.

04.06 As Needed (AN). The inspection effort should be performed when the activity or event 

occurs at the facility as specified in the guidance section of specific inspection procedures (e.g., 

refueling outages).

04.07 Baseline Inspection Program Completion. Baseline Inspection Program completion for 

an ROP annual inspection cycle is defined to be not more than four (4) inspection procedures 

not completed, per Region (but not more than one procedure not done per plant). For the 

purposes of this definition, each inspection procedure attachment is counted as a separate 

inspection procedure (IP). Licensee schedules are beyond the control of NRC staff. Therefore, 

an unforeseen delay in a licensee schedule that results in not meeting an inspection 

requirement does not reflect non-completion of the baseline inspection program. In such cases, 

the inspection requirement should be completed as soon as the licensee has completed the 

activity.

This sixteen (16) inspection procedure allowance per year nationwide equates to an annual 

completion rate greater than 99.5% (assuming an average of 3400 total inspection 

procedures/attachments per year nationwide - approximately 33 per year X 103 plants). This 

allowance is intended to provide for unanticipated disruptions in inspection scheduling that 

unavoidably cause an inspection procedure or attachment to not be completed and presumes 

that at least the minimum inspection requirements will otherwise be completed as soon as 

possible within the quarter immediately following the annual inspection cycle. Achieving this 

level of Baseline Inspection performance provides a basis to conclude that the intent of the 

Baseline Inspection Program has been met and therefore, for the purpose of goal monitoring, 

can be reported as complete for that annual cycle.

 

1

 For ROP cycles, see Attachment 1
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2515-05 RESPONSIBILITIES AND AUTHORITIES

05.01 Director, Office of Nuclear Reactor Regulation.

a. Provides overall program direction for the reactor inspection program.

b. Develops and directs the implementation of policies, programs, and procedures for 

inspecting applicants, licensees, and other entities subject to NRC jurisdiction.

c. Assesses the effectiveness, uniformity, and completeness of implementation of the 

reactor inspection program.

d. In the event of a pandemic, concurs on the regions’ recommendations to the 

modification to the inspection program in accordance with the direction provided under 

section 2515-14 and Appendix E of this IMC.

05.02 Deputy Director for Reactor Safety Programs. Directs the development of the inspection 

program within the Office of Nuclear Reactor Regulation (NRR).

05.03 Director, Division of Inspection & Regional Support (DIRS). Manages inspection 

program development within NRR, develops and prepares revisions to the reactor inspection 

program, oversees regional implementation, and serves as the NRR contact with the regional 

offices for program development and implementation.

05.04 Directors, Technical Divisions, NRR. Assists the Director, DIRS in developing the 

technical content of and reviewing periodic revisions to the requirements and guidance 

contained in inspection procedures related to their areas of technical expertise.

05.05 Regional Administrator.

a. Provides program direction for management and implementation of the inspection 

program elements performed by their regional office.

b. Ensures, within budget limitations, that the regional office staff includes adequate 

numbers of inspectors in the various disciplines necessary to carry out the inspection 

program described in this chapter, including that which may be needed for regional 

supplemental and reactive inspections.

c. Directs the implementation of the supplemental inspection program in accordance with 

the guidance in Appendix B of this document.

d. Applies inspection resources, as necessary, to deal with significant issues and problems 

at specific plants.

e. Ensures that line managers assign inspectors who are appropriately trained and have 

the necessary knowledge and skills to successfully implement inspection procedures.

[C2]
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f. Determines that a pandemic situation which affects inspection resource availability has 

occurred and recommends modification to the inspection program in accordance with 

the direction provided under section 2515-14 and Appendix E of this IMC.

2515-06 REGULATORY OVERSIGHT FRAMEWORK

The fundamental building blocks that form the framework for the regulatory oversight process 

are seven cornerstones of safety: initiating events, mitigating systems, barrier integrity, 

emergency preparedness, occupational radiation safety, public radiation safety, and security. 

These cornerstones have been grouped into three strategic areas: reactor safety, radiation 

safety, and safeguards. This framework is based on the principle that the agency’s mission of 

assuring public health and safety is met when the agency has reasonable assurance that 

licensee’s are meeting the objectives of the seven cornerstones of safety. The reactor 

inspection program is an integral part of the reactor oversight process, along with performance 

indicators (PIs), assessment, and enforcement. Acceptable performance in the cornerstones, 

as measured by the PIs and the risk-informed baseline inspection program, is indicative of 

overall licensee performance that provides for adequate protection of public health and safety. 

The PI program reporting guidelines are in NEI 99-02, “Regulatory Assessment Performance 

Indicator Guideline,” which is endorsed by the NRC.

Another principle of the framework is that there is a level of licensee performance in the 

cornerstones above which the NRC does not need to engage the licensee beyond some 

minimum level. The risk-informed baseline inspection and PI programs constitute this minimum 

level of regulatory oversight and are sufficient to provide reasonable assurance of public health 

and safety.

The supplemental portion of the inspection program will provide more diagnostic inspections of 

identified problems and issues beyond the baseline. Supplemental inspections will be planned 

in response to issues that result in crossing an Action Matrix threshold. These changes to the 

inspection program are factored into the inspection program through the assessment process, 

as further discussed in Section 8.0, below.

2515-07 OPERATING REACTOR INSPECTION PROGRAM ELEMENTS

The inspection program described in this manual chapter is comprised of the following three 

major program elements:

1. Risk-Informed Baseline Inspection Program (Baseline) Inspections

2. Plant Specific Supplemental Inspections

3. Generic Safety Issue, Special, and Infrequent Inspections

Overall, the inspection program emphasizes achieving a balanced look at a cross section of 

licensee activities important to plant safety, reliability, and risk. The baseline inspections 

constitute an appropriate level of inspection at plants whose overall performance remains in the 
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licensee response band. Plants, whose performance is outside the licensee response band, will 

receive additional plant specific supplemental inspection based on their assessed performance 

in the cornerstones of safety. Additionally, Appendix D is provided for use by the resident 

inspectors in conducting routine activities such as plant tours that may assist them in identifying 

potentially risk significant activities.

The supplemental inspections, described in Appendix B, are only performed as a result of 

performance issues that are identified by performance indicators (PIs), baseline inspections, or 

event analysis. The depth and breadth of specific supplemental inspections chosen for 

implementation will depend upon the risk characterization of the issues as shown in the Action 

Matrix of the reactor assessment program (IMC 0305, “Operating Reactor Assessment 

Program”).

The need for additional inspections to address emergent generic safety issues, such as those 

that were performed for motor-operated valves and year 2000 issues, will be assessed on a 

case by case basis. Also, the need for performing additional inspections to review major 

licensee evolutions such as testing and operation of independent spent fuel storage facilities or 

steam generator replacements will be assessed.

In addition to the three elements, the inspection program also provides for the agency’s 

response to operational events. The guidance for determining the level of response to an event 

is contained in NRC Management Directive 8.3, “Incident Investigation Program.”

07.01 Risk-Informed Baseline Inspections. The baseline inspection program element, 

described in Appendix A, is to be performed at all operating reactors. It requires inspections of 

licensee performance in the seven cornerstones of safety.

The baseline inspections provide sufficient examination of the plants and licensee activities to 

determine, along with performance indicators, whether licensees are meeting the objectives of 

all seven cornerstones, and to identify indications of performance problems to allow further 

engagement by the NRC before the objectives of the cornerstones are compromised.

The inspection procedures included in the baseline inspection program are based on 

“inspectable areas” for the seven cornerstones of safety. The oversight framework 

identified key attributes for each cornerstone that need to be verified to have a reasonable 

assurance that the cornerstone objectives are met. Licensee performance within the key 

attributes is then measured by a performance indicator, a risk-informed inspectable area, or a 

combination of both indicator and inspection.

The baseline inspection procedures are organized by cornerstone and include the inspectable 

areas associated with the cornerstone. The baseline inspections are performance-based and 

risk-informed and emphasize the observation and evaluation of ongoing facility operations and 

supporting activities affecting the safety function of facility structures, systems, and components. 

Appendix D has been provided to assist the resident inspectors in conducting activities that may 

identify potentially risk significant activities. The baseline inspections are risk informed through 

(1) the inspectable areas, which are based on their risk importance in measuring a cornerstone 

objective; (2) the inspection frequency and sample size for each inspectable area, which are 
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based on risk information; and (3) sample selection of activities and equipment to inspect in 

each inspectable area, which is based on risk insights that will be modified by plant-specific 

information.

Appendix A contains a list of baseline inspection procedures and specifies the required 

frequency for their performance. The baseline inspection procedures must be completed at

every plant at a prescribed interval. The expectation is that the regions should normally 

complete the nominal (average) number of inspection samples identified in the inspection 

procedure. The regions may vary the inspection samples within the ranges as indicated in each 

baseline inspection procedure, based on licensee performance and inspector insights. For the 

purposes of completing the baseline inspection program, the number of samples completed 

must be within the range of values specified in each inspection procedure. [C2]

Inspection requirements are the controlling factor in determining the amount of inspection effort 

necessary to complete the baseline inspections. Appendix A provides an estimate of the hours 

associated with each inspection procedure for overall resource planning only.

07.02 Plant Specific Supplemental Inspections.

The supplemental element of the inspection program is designed to apply NRC inspection 

assets in an increasing manner when performance issues are identified, either by inspection 

findings evaluated using the significance determination process (SDP) or when performance 

indicator thresholds are exceeded. Accordingly, the NRC regional office will assess the need 

for supplemental inspections after identifying an inspection finding categorized as risk significant 

(i.e., white, yellow, or red) with the SDP, or when a performance indicator exceeds the licensee 

response band threshold. The scope and breadth of these inspections will be based upon the 

guidance provided in the assessment program’s Action Matrix and expanded upon in the 

“Supplemental Inspection Selection Table” included in Appendix B.

Depending on the risk significance and breadth of the identified performance issues, the 

supplemental inspections provide a graded response, which includes: oversight of the 

licensee’s root cause evaluation of the issues; expansion of the baseline inspection sample or a 

focused team inspection (as necessary to evaluate extent of condition); or a broad scope, multidisciplined team inspection, which would include inspection of multiple cornerstone areas and 

inspection of crosscutting issues. Any new issues identified during the supplemental 

inspections will be evaluated by the SDP. The need for additional NRC actions, including 

additional supplemental inspections, is governed by the Action Matrix.

A supplemental inspection will be performed for all white, yellow, or red issues (either PIs or 

inspection findings). The region may choose not to perform a supplemental inspection for white 

issues identified as part of a licensee’s self-assessment, although such exceptions are expected 

to be infrequent. In such instances, the region will still ensure that the issue is entered into the 

licensee’s corrective action program and that an appropriate evaluation is performed. The 

licensee’s evaluation for such an issue will be reviewed as part of baseline inspection procedure 

71152, “Identification and Resolution of Problems.” Additionally, the regional offices may 

choose to propose a deviation from the Action Matrix when the level of supplemental inspection 

is not appropriate for the particular circumstances. Examples of when the level of supplemental 

inspection may need to be increased or decreased include (but are not limited to): 1) a single 
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red finding or performance indicator that does not appear to be indicative of broad programmatic 

concerns, 2) a single red inspection finding or performance indicator, particularly those that 

meet the criteria for old design issues, 3) multiple examples of non-SDP Severity Level III or 

greater enforcement actions, 4) a type of finding unanticipated by the SDP that results in an 

inappropriate level of regulatory attention when entered into the Action Matrix. A deviation from 

the Action Matrix may be authorized in accordance with IMC 0305, “Operating Reactor 

Assessment Program.”

07.03 Generic Safety Issues, Special, and Infrequent Inspections. Concerns with specific 

safety issues that arise may be addressed solely through the NRR license review process and 

the use of regulatory communications issued to licensees. If the concern is of safety 

significance, it may be appropriate to perform a one-time inspection under the safety issues 

program element. These inspections will be established by temporary instructions (TIs). For 

example, when it is determined that a safety issue addressed in a bulletin or generic letter 

requires inspection verification or follow-up, requirements and guidance for the inspection will be 

developed and issued in a TI. Unless such a TI is issued, inspection follow-up is not required to 

verify completion of licensees' actions discussed in a bulletin or generic letter. When a TI is 

issued, overall assessment ratings may be considered in establishing priorities for conducting 

these inspections. The plants to be inspected will be designated in the TIs.

The resources budgeted to safety issues inspections are established by NRR. It is the intent 

that the inspections be conducted within the resources budgeted for that element of the 

program.

Specific criteria for closing a TI will be addressed in the TI itself. In general, TIs should not be 

closed until all relevant safety issue items have been completed by the licensee and verified by 

inspection. However, exceptions may be considered when the licensee's schedule for 

completing items remaining is acceptable, properly documented, and is not a critical element to 

resolving the safety issue.

The need may arise for specific inspections to address major evolutions limited to a few 

licensees such as upgrading to a digital control system. The need for these inspections will also 

be assessed on a case-by-case basis and conducted under the guidance of a temporary 

instruction.

This element of the inspection program also includes other special or infrequently performed 

inspections. These inspections may be in response to events, infrequent major activities at 

nuclear power plants, or to fulfill the NRC’s obligations under interagency memoranda of 

understanding. The applicable procedures are listed in Appendix C, “Special and Infrequently 

Performed Inspections.”

An existing Appendix A or C inspection procedure may be used to evaluate emerging technical 

issues not related to licensee performance issues. This is not considered an Action Matrix 

deviation and does not require an Action Matrix deviation memorandum per IMC 0305. The 

Regional Administrator should inform the Deputy Executive Director for Reactor and

Preparedness Program and the NRR Office Director in a memorandum in cases where 

resources from multiple offices are involved (approximately 1 FTE or greater) to follow-up on 

technical issue(s). The purpose of the memorandum would be twofold: 1) to inform the DEDO 
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and NRR Office Director of the reason for the additional resources and confirm that the 

resources would come from those already budgeted to the region, and 2) to inform external 

stakeholders of the additional effort being expended and the reason it is not a deviation from the 

ROP. This memorandum should be acknowledged in assessment letters similar to deviation 

memos.

07.04 Related Activities Associated with the Reactor Inspection Program. All inspections, as 

well as performance indicators reported by licensees, provide input to the plant performance 

assessment process. The performance assessment process is to be conducted in accordance 

with IMC 0305, “Operating Reactor Assessment Program.”

2515-08 DISCUSSION

08.01 General. The inspection program described in Appendices A, B, and C is intended to 

provide the framework for managing inspection resources without being overly prescriptive. 

However, the minimum level of inspections necessary to complete pre-defined objectives at a 

facility is specified. Inspections should not decrease below this level. The minimum inspection 

level is intended to place inspection emphasis on elements of licensee activities most important 

to reactor safety, radiation safety, and safeguards.

Because ROP uses PIs and inspection findings which are evaluated for risk to determine 

whether all cornerstone objectives were met at a plant, only those inspection findings which rise 

above a minimum significance threshold (i.e., findings are greater than minor) are documented 

in inspection reports. Therefore, inspection findings which are determined to be minor do not 

need to be nor shall be tracked or trended by either inspectors or regional managers. Instead, 

minor findings shall be reported to the licensee for action in accordance with the licensee’s 

corrective action program. Licensees are expected to track and trend minor findings and issues 

as stated in their program. When implementing inspection procedure 71152, “Problem 

Identification and Resolution,” inspectors may include minor findings and issues as part of their 

semiannual trend review. This review will determine whether the licensee has adequately 

identified and corrected an adverse trend, if any, resulting from all identified deficiencies, 

including minor findings, during the period of review. [C3]

Using a performance-based, risk-informed approach, inspectors focus their attention on 

activities important to safety. Performance-based inspection emphasizes observing activities 

and the results of licensee programs over reviewing procedures or records. For example, an 

inspector may identify an issue through observing a plant activity in progress, monitoring 

equipment performance, or the in-plant results of an activity (e.g., an engineering calculation). 

Discussions with plant personnel and reviewing documents should be used to enhance or verify 

performance-based observations. These procedures are designed to emphasize observation of 

activities, or those portions that are most risk significant in terms of safety and reliability. It is 

expected that resident and region-based inspectors will have the necessary technical capability 

to accurately observe and evaluate the activity. 

Regional Division Directors and line managers must ensure that inspectors assigned to 

implement the baseline inspection procedures have the necessary training, knowledge, and 

skills to successfully implement the NRR programs. The inspector training and qualification 
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program will be in accordance with IMC 1245, “Qualification Program for the Office of Nuclear 

Reactor Regulation Programs.” The following baseline inspection procedures will normally be 

performed by regional specialists who have achieved at least Basic Certification in accordance 

with IMC 1245:

 IP 71111.05T, “Fire Protection (Triennial)”

 IP 71111.05XT, “Fire Protection-NFPA 805 (Triennial)”

 IP 71111.07, “Heat Sink Performance”

 IP 71111.08, “Inservice Inspection Activities”

 IP 71111.11, “Licensed Operator Requalification Program and Licensed Operator 

Performance”

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

Modifications”

 IP 71111.21, “Component Design Bases Inspection”

 IP 71114, “Reactor Safety Emergency Preparedness” (all attachments)

 IP 71124, “Radiation Safety – Public and Occupational” (all attachments)

 IP 71130, “Security” (all attachments)

The remaining baseline inspection procedures will normally be performed by resident inspectors 

who have achieved basic level (IMC 1245 Appendix A) certification. Additionally, based on their 

qualification and experience, regional specialists may also perform baseline inspections other 

than the ones listed above. Likewise, based on their qualifications and experience, resident 

inspectors may also perform baseline inspection procedures normally performed by regional 

specialists. [C2]

NRC inspectors perform a basic mission in determining whether a licensee operates the plant 

safely and meets current regulatory requirements and commitments. Limiting inspection to 

identification of specific instances where a licensee fails to meet such requirements and 

commitments could result in correction of symptoms rather than correction of underlying causes 

of licensee problems. The inspection and assessment processes establish thresholds for 

determining the significance of issues and whether those issues may require additional 

evaluation and follow up. Thus, the inspection program requires that inspectors and their 

managers evaluate problems to determine if follow up inspections are necessary to diagnose 

whether a safety concern represents an isolated case or may signify a broader, more serious 

problem based on the evaluated significance of the issues. Licensee management controls 

(e.g., QA, safety committees, etc.) may need to be examined to determine if weaknesses in 

these controls contributed to identified safety concerns.

The NRC inspection program covers only small samples of licensee activities in any particular 

area. The sample sizes specified in the inspection procedures are based on the relative 

importance of the area covered by the procedure to the other areas inspected by the program. 

They are also based on the inspectors choosing a “smart” sample instead of a statistically 

based random sample because the risk-informed nature of the inspection program requires the 

inspections to be focused on those aspects of plant operations and licensee activities that could 

pose the greatest risk to public health and safety. The philosophy behind this concept is that 

the licensee’s processes are effective if they deal properly with the items of greatest 

significance. Some areas (such as reviewing 10 CFR 50.59 evaluations) do not have a direct 
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connection with risk and inspection sample sizes in these areas are chosen to provide periodic 

indications of a licensee’s performance in those areas.

Information related to industry operating experience can be useful to NRC inspectors during 

their review of licensee activities. The integration of operating experience into the Reactor 

Oversight Process is discussed in Inspection Manual Chapter 2523, “NRC Application of 

Operating Experience in the Reactor Oversight Process.” Additionally, inspectors are 

encouraged to use previously identified operating experience issues which are associated with 

each of the baseline inspection procedures as part of their inspection preparation. A list of 

these generic communications can be found at NRR webpage titled “Cross Reference of 

Generic Communications with Inspection Procedures," http://nrr10.nrc.gov/rorp/historicalref.html.

08.02 Allocation of Resources as a Function of Performance Assessment. The results of plant 

performance assessments are an important factor in defining the inspection program for each 

plant. The baseline inspections are the level of defined requirements for all plants and 

additional regional supplemental inspections will be planned for plants whose performance is 

below a certain level, i.e., the licensee response band. The amount and focus of the additional 

supplemental inspections will be proportional to the plant’s assessed performance and the 

nature of the issues that provide the indication of that performance. See IMC 0305, “Operating 

Reactor Assessment Program,” for more detailed guidance on responding to issues with 

licensee performance.

Only baseline inspections, applicable generic safety issues, and special and infrequent 

inspections will be planned and conducted at plants whose overall performance (all 

performance indicators and inspection findings) is determined to be in the licensee response 

band.

Plants whose performance is determined to be outside of the licensee response band (see 

IMC 0305) should have supplemental inspections planned to examine the root causes of the 

change in performance and corrective actions of identified findings or safety issues that have 

indicated the performance change.

08.03 Allocation of Resources Among Program Elements. The allocation of resources among 

the three principal inspection program elements (baseline, supplemental and generic safety 

issues) is provided for each year in the budget process.

08.04 Completion of Inspection Procedures. The baseline inspection procedures represent the 

inspection necessary to allow the NRC to assess performance. This means that the inspector is 

to perform the requirements most appropriate to the activity being inspected in order to declare 

an activity (sample) as being satisfactorily completed. The inspection procedure can be 

declared complete when the number of inspection activities (samples) within the range of 

sample values specified in each inspection procedure have been completed, thus meeting the 

objectives of the procedure. 

Performance of one inspection procedure sample may be counted as a sample for another 

procedure only if completed inspection requirements are common to each procedure. [C2]
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The sample size may be reduced to a number below the minimum value in situations where 

there are an insufficient number of samples with appropriate risk significance available for 

inspection (e.g., a reduction of sample size to zero, if necessary, when no samples exist). 

Where no sample is specified, completion of all applicable inspection requirements constitutes 

completion of the procedure. The inspection hours estimate, which is included in the inspection 

procedure attachments for planning purposes, should not be used to determine whether the

inspection attachment was satisfactorily completed. This estimate is intended to provide 

guidelines for inspection planning and budgeting. 

Director, Division of Inspection & Regional Support (DIRS), NRR, should be informed, as soon 

as practicable, when it appears that the ROP baseline inspection program cannot be completed 

at a site. Likewise, each inspection requirement contained in the supplemental inspection 

procedures must be adequately addressed.

Inspection procedures identify requirements that the inspector must consider while evaluating 

the associated area. These requirements may not be the same as NRC requirements placed 

on a specific licensee. As such, it is not implied or intended that inspection program 

requirements are to be levied on the licensee. Any attempt to force inspection program 

requirements on the licensee constitutes misinterpretation of NRC inspection philosophy and 

misuse of inspection requirements.

Temporary instructions are issued for specific inspection purposes. For inspections performed 

using a temporary instruction, the inspector is expected to complete all inspection requirements 

listed.

08.05 Baseline Inspection Credit for Operational Safety Review Team Effort. The Operational 

Safety Review Team (OSART) review is performed by senior staff members from International 

Atomic Energy Agency member states. The OSART missions offer a means of assessing 

licensee performance and reinforcing plant self-assessments through an independent 

assessment process. OSART’s focus is on the safety and reliability of plant operation. They 

review the operation of the plant and the performance of the plant’s management and staff 

rather than the adequacy of the plant’s design and compliance with its licensing basis. Based 

on a review of sample OSART reports and the OSART guidelines, the staff determined that 

although the OSART review is not risk-informed, some areas of the review overlap with the 

ROP baseline inspection program. The NRC believes that it would be beneficial for the U.S. 

nuclear power industry to continue its participation in the OSART missions. 

As an incentive to encourage licensee participation in the OSART mission, the NRC grants a 

one-time regulatory credit (reduction in baseline inspection program) for those NRC baseline 

inspections that overlap, either in part or fully, with the OSART review. Accordingly, a 25 

percent ROP baseline inspection credit shall be given for the following baseline inspection 

procedures:

 IP 71111.22, “Surveillance Testing”

 IP 71111.05AQ, “Fire Protection”

 IP 71124.01, “Radiological Hazard Assessment and Exposure Controls”

 IP 71124.02, “Occupational ALARA Planning and Controls”

 IP 71124.03, “In-Plant Airborne Radioactivity Control and Mitigation”
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 IP 71124.04, “Occupational Dose Assessment”

 IP 71124.05, “Radiation Monitoring Instrumentation”

 IP 71124.06, “Radioactive Gaseous and Liquid Effluent Treatment”

 IP 71124.07, “Radiological Environmental Monitoring Program”

 IP 71124.08, “Radioactive Solid Waste Processing and Radioactive Material

 Handling, Storage, and Transportation”

In addition, a 50 percent ROP baseline inspection credit shall be given for the following 

inspection procedures:

 IP 71114.03, “Emergency Response Organization Staffing and Augmentation System”

 IP 71114.05, “Maintenance of Emergency Preparedness”

 IP 71152B, “Problem Identification and Resolution”

In order for the region to take one-time credit for reducing baseline inspections, the areas for 

which the credit is to be given must have been documented in the OSART report. In addition, 

an NRC staff person should closely monitor the OSART activities, such as attending the team’s 

briefings to the licensee. The staff person should assess whether the regulatory credit 

assumptions were appropriate. This person also needs a good understanding of the issues and 

recommendations made by the OSART. For NRC planning purposes, this effort is estimated to 

take approximately 40 hours. Also, the region should assure that the OSART inspection report 

is made publicly available. Specific OSART findings should not normally be referenced or 

followed-up by the NRC, however, where a significant safety issue (potentially greater than 

Green) or a potential violation of an NRC requirement is identified, the NRC will independently 

conduct an appropriate baseline inspection to disposition potential violations and assess the 

significance of the finding in accordance with the ROP. These findings will be documented in 

accordance with NRC Inspection Manual Chapter (IMC) 0612, “Power Reactor Inspection 

Reports,” and will also be processed as performance assessment inputs equivalent to NRC 

identified findings in accordance with IMC 0305, “Operating Reactor Assessment Program.” 

The staff will perform any additional inspections for those findings that have a significance 

greater than Green in accordance with NRC’s Action Matrix. The baseline inspection credit and 

NRC staff position described above are communicated to the Commission via a memorandum 

dated July 16, 2003 (ADAMS Accession Numbers: ML031620369, ML030930251, 

ML0316020346).

08.06 Baseline Inspection Program Completion and Documentation. The following guideline 

shall be followed when it is expected that required inspections for which the region is 

responsible will not be completed by the end of the calendar year:

a. The missed inspection(s), if any, must be scheduled such that it will be completed during 

the first quarter of the next calendar year.

b. Inspection procedures which should be implemented during a refueling outage cannot 

be deferred.

c. Inspections may only be deferred at a plant in the licensee response column of the 

action matrix.

d. Acceptable reasons for deferring an inspection include unanticipated inspection resource 

demands resulting from providing additional regulatory attention provided to plants which 

are placed in the IMC 0350 process or in multiple/repetitive degraded 
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cornerstone or unacceptable performance columns. (Refer to IMC 0305, “Operating 

Reactor Assessment Program,” for a more detail explanation of these performance 

columns.)

e. The Director, Division of Reactor Projects (DRP) must notify the Director, Division of 

Inspection and Regional Support (DIRS), NRR, via a memorandum if the region cannot 

complete all the required inspections for which the region is responsible by the end of 

the calendar year. This memorandum should contain a brief explanation for the 

reason(s) for deferring the inspection(s), the proposed schedule for completing the 

deferred inspection(s), and the tracking method used for completing the required 

inspections.

In addition, the regions must maintain an inspection tracking system which will allow them to 

track which inspections cannot be completed in the calendar year so that no more than four 

procedures are deferred for completion in the next ROP cycle. [C2]

The regions should use the guidance provided in IMC 0306, “Information Technology Support 

for the Reactor Oversight Process,” to track the baseline inspection program completion for 

each calendar year and to ensure that the inspection procedures not performed as required by 

year’s end stay within the four-procedure allowance (but not more than one procedure not done 

per plant).

By mid-February of each calendar year, the Director of DRP must notify the Director, DIRS, 

NRR, via a memorandum which states that the required baseline inspections for which the 

regions are responsible have been completed for the previous calendar year inspection cycle in 

accordance with IMC 2515.

There are several baseline procedures related to plant security and safeguards which are 

scheduled, conducted, and tracked by the NRC Office of Nuclear Security and 

Incident Response (NSIR). Office of NRR and NSIR and the Regions reached the following 

resolutions regarding the baseline inspection procedures for which NSIR is responsible during a 

conference call among on March 27, 2006:

 NSIR will issue a separate memorandum to the Director, DIRS, by mid-February of each 

calendar year certifying completion of the required baseline inspections for which NSIR 

is responsible.

 NSIR will be responsible for entering information into RPS for the baseline procedures 

which are conducted out of HQ from which NSIR is responsible.

A report containing the data that support completion of the respective NSIR or regional required 

inspections (Report 8 from the Reactor Programs System, Item Reporting module) should be 

provided as an attachment to the memorandum submitted by NSIR and the regions.

08.07 Program Feedback. The reactor inspection program is expected to be dynamic and to 

respond to changes in the nuclear power industry and operational experience. Therefore, the 

program office expects the regions and inspectors to identify problems in implementing the 

program, and to recommend changes to the program for consideration by the program office. 

Any such feedback and recommendations should be submitted to IRIB through the associated 

regional office using the ROP feedback process (IMC 0801).
Issue Date: 05/01/15 14 2515

2515-09 INTEGRATED INSPECTION PLANS

Regional offices must develop annual site-specific inspection plans consistent with the 

inspection planning module of the Reactor Program System (RPS) to help manage inspection 

resources and monitor the inspection programs. Under circumstances where the operation of 

multiple units at a site is not comparable (e.g., Salem/Hope Creek), the inspection plan should 

be specific for each unit. The regional integrated inspection plan (i.e., the integration of 

individual site or unit plans) should project the planned inspection activities and available 

resources for all sites for at least the next 18 months. The integrated plan should also provide 

for a summary of the fraction of regional resources allocated to each of the individual program 

elements discussed in section 2515-06 of this manual chapter for each site.

The Chief of the Reactor Inspection Branch (IRIB) shall concur on significant alterations to the 

baseline inspection program for a plant’s annual inspection plan to accommodate the plant’s 

particular situation. Significant alterations include treating a multi-unit site as separate single 

unit sites, or increasing or decreasing the frequency of inspections or sample sizes from those 

stated in the baseline inspection procedures. The factors to consider when planning alterations 

to the baseline inspection program at a plant site include (1) known plant activities (or lack 

thereof), (2) the plant’s size, design, and age, and (3) complexity of the licensee’s programs.

The results of the end-of-cycle and mid-cycle performance reviews, conducted in accordance 

with IMC 0305, shall be used to schedule baseline inspections and to determine the amount and 

focus of any supplemental or special/infrequent inspections at each site (as defined in Appendix 

B and C of this manual chapter). The basis for the allocation or significant reallocation of 

resources among the sites will be documented. It is expected that the integrated plans will be 

living documents and be reviewed periodically, adjusted, and reissued to reflect shifts in plant 

performance and safety concerns. Individual site plans and the regional integrated inspection 

plan should be reviewed by regional management and updated at least semiannually as part of 

the assessment process that is discussed in IMC 0305.

2515-10 INDEPENDENT INSPECTION

As a general rule, inspections should be conducted in accordance with inspection procedures. 

However, it is not possible to anticipate all the unique circumstances that might be encountered 

during the course of a particular inspection and, therefore, individual inspectors are expected to 

exercise initiative in conducting inspections, based on their expertise, experience, and risk 

insights, as needed to assure that all the inspection objectives are met.

2515-11 INSPECTOR POLICY

11.01 Resident Inspector Policy. The resident inspectors provide the major onsite NRC 

presence for direct observation and verification of licensees’ ongoing activities. Appendix D 

outlines the responsibilities of resident inspectors for being aware of major activities and the 

current status of the plant as NRC’s onsite representative. The resident inspectors also are 
Issue Date: 05/01/15 15 2515

primary NRC onsite evaluators for events or incidents. See section 11.3, “Responding to 

Events and Event Reports,” below. The greater part of initial event-related inspection effort will 

be performed by the resident inspectors, who may be augmented by other inspectors depending 

on the type and significance of the event. Regional managers will decide when normal 

inspection activities will be resumed by those involved with inspecting events.

The following is the general policy on the extent to which resident inspectors are to provide 

coverage at all sites with one or more units licensed for operation.

1. For sites with at least two resident inspectors, at least one resident inspector or qualified 

region-based alternate should provide site coverage during the regular NRC workday, 

Monday through Friday. The intent of this guidance is that site coverage by someone 

qualified as an inspector not be interrupted for more than three consecutive NRC 

working days (Friday-Tuesday are three consecutive working days). Consequently, for 

extended absences of the resident inspectors, such as for attending inspector 

counterpart meetings, arrangements should be made for coverage by region-based staff. 

The region-based inspectors should be qualified in accordance with IMC 1245, 

“Inspector Qualifications.” However, when qualified region-based inspectors are not 

available, site coverage can be provided by an individual that is both knowledgeable and 

experienced in plant operations, and capable of communicating with licensee and NRC 

management on emerging issues and plant conditions. In order to maximize NRC's 

efficiency, regional management should attempt to schedule region-based inspections 

for this time period.

2. The Regional Administrator will be notified when the guidance (3 consecutive working 

days) cannot be met. All exceptions will be highlighted in the quarterly update of the 

regional operating plan.

3. For sites with only a single resident inspector (e.g., because of a vacancy, training, or 

extended illness) the guidance described above should be followed to the maximum 

extent possible.

4. Inspections performed on Saturdays and Sundays, NRC holidays that are concurrent 

with licensee holidays, and weeknight hours between about 10:00 p.m. and 5:00 a.m., 

are called “deep” backshift inspections. There are no set hours for backshift inspections 

because it is expected that the baseline inspection program will involve some backshift 

coverage on a routine basis. Resident inspectors should collectively devote at least 

50 hours of direct inspection and plant status effort per year per site to deep backshift 

inspections. (This is a combined effort; no hours are assigned to an individual resident 

inspector.) These efforts should be of at least several hours duration. If deemed 

appropriate by regional management, this coverage may be provided by regional 

inspectors in lieu of or in addition to that performed by resident inspectors. Credit may 

be taken for regional and headquarters inspection coverage in achieving deep backshift 

coverage goals. Inspection on holidays will count as deep backshift only if the licensee 

holiday is concurrent with the NRC holiday. 

5. Inspectors should be sensitive to and avoid being predictable in scheduling their 

backshift and deep backshift coverage. In order to maximize the benefit of deep 
Issue Date: 05/01/15 16 2515

backshift coverage, inspectors should not develop a predictable pattern. Effort should 

be made to spread the deep backshift coverage over a variety of days and working 

conditions [outage, normal operations, weekends, nights (including 10 p.m. to 5 a.m.), 

etc.].

6. There is not a specific goal for performing backshift inspections by regional inspectors, 

but backshift inspections should be performed whenever required to complete the 

intended scope of the inspection.

7. Regional administrators may permanently assign resident inspectors to a site up to 

twelve months prior to the end of the tour of the incumbent inspector. This limited “early 

reassignment” of the resident inspector position, should minimize the interruption in 

inspector site coverage that often occurs during the transition of resident inspectors.

Regional administrators may permanently assign senior resident inspectors to a site up 

to six months prior to the end of the tour of the incumbent inspector. This limited “early 

reassignment” of the senior resident inspector position should minimize the interruption 

in inspector site coverage that often occurs during the transition of senior resident 

inspectors. The “early reassignment” of senior resident inspectors should be minimized.

Personnel actions associated with individuals selected for early assignment will be the 

same as those who are assigned to the site to fill a vacant resident inspector position. 

However, the regions will use the personnel identification code “PIC” code “55" for senior 

resident inspectors and “PIC” code “56" for resident inspectors who have been early 

assigned. The use of these “PIC” codes for the resident inspectors results in the 

administrative/overhead fees not being charged to the site. When the departing 

Resident Inspector or Senior Resident Inspector leaves the site, the regions will change 

the “PIC” code for the early assigned resident inspectors to “52" or “53,” as appropriate, 

within one pay period.

The regions should closely manage the inspection resources at the sites which are 

impacted by this program, such that the resources expended to complete the NRC’s 

baseline inspection program are not increased solely as a result of the additional 

resident inspector(s) being assigned to the site. 

11.02 Regional Inspector Policy. Regional inspectors conduct inspections as directed by their 

supervisors. In addition to baseline inspection program procedures, regional inspectors often 

conduct inspections under other program elements described in this chapter. Certain aspects of 

their inspection activity may be conducted in the regional office (e.g., portions of procedure 

review and administrative program inspection).

11.03 Inspection Coordination. The senior resident inspector and the regional Division of 

Reactor Projects must be kept advised of regional and headquarters inspectors’ activities at the 

facility. The associated regional branch chief must ensure coordination of regional and 

headquarters inspection activities in accordance with IMC 0301, "Coordination of NRC Visits to 

Commercial Reactor Sites."
Issue Date: 05/01/15 17 2515

Regional and headquarters-based inspectors should contact the senior resident inspector 

before each inspection to get information concerning the availability of specific licensee 

personnel and the status of plant conditions that may affect the planned inspection. In addition, 

they should contact the senior resident inspector as soon as is convenient after they arrive at 

the site to ensure a coordinated NRC presence at the facility. The visiting inspectors should 

advise the senior resident inspector of changes to their planned inspection effort and schedule 

for the exit interview with the licensee. The senior resident inspector should inform the regional 

and headquarters inspectors of any unique activities in progress and offer specific inspection 

suggestions. The regional and headquarters inspectors should brief the senior resident 

inspector about the results of their inspection before the exit meeting with the licensee’s 

management. The senior resident inspector (or resident inspector in his absence) should attend 

all exit meetings where significant issues are expected to be discussed.

11.04 Third Party Assistance. On occasion licensees ask inspectors for recommendations for 

obtaining help solving programmatic problems. Inspectors are prohibited from recommending 

the services of individuals or organizations for a project under NRC regulatory jurisdiction. 

Providing such a recommendation violates 5 CFR 2635.702, which prohibits Federal employees 

from using public office for endorsement of any product, service, or enterprise. However, the 

agency also has an obligation to provide assistance where possible in helping individual 

licensees solve problems where the health and safety of the public is involved.

The following guidance is provided to assist employees who receive requests for assistance 

from licensees. Specific procedures implementing this guidance should be available in each 

region and the Office of Nuclear Reactor Regulation. There are two cases presented. Case #1 

is for use when a licensee has a programmatic problem. This case allows time for the licensee 

to conduct research in obtaining assistance. Case #2 is for use when an immediate health and 

safety problem exists. [C4]

Case 1: An NRC employee receives a request for third party assistance from a licensee.

1. The employee shall as soon as practical notify his or her management.

2. Following consultation with management, the staff member may refer the requestor to 

any of the following sources:

a. The current version of the Nuclear News Buyers Guide. If not otherwise available to 

the requestor, a copy of the Buyers Guide can be obtained by contacting the 

American Nuclear Society (Attn: Accounting Department), 555 N. Kensington Ave., 

La Grange Park, Illinois 60525.

b. A licensee that has solved a similar problem (consult with office/regional 

management prior to providing the name). When providing the name of a licensee 

who has solved a similar problem, take special care that a perception of conflict of 

interest is not created and that the licensee is not under an Office of Investigations 

investigation for misconduct.

c. An appropriate professional society such as the American Society for Mechanical 

Engineers or the Health Physics Society.
Issue Date: 05/01/15 18 2515

Case 2: An immediate health and safety issue exists and it is not practical to take the action 

detailed in Case #1.

1. Refer the licensee to an appropriate equipment manufacturer.

2. Consult with NRC management (NRR or regional office). Following management 

approval the employee may refer the licensee to one or more qualified 

consultants/contractors who can provide prompt safety assistance. Special care should 

be taken in connection with providing recommendations concerning consultants with 

whom the recommending staff has a personal or long standing relationship.

3. Following the action, document the event and the justification for the action, and provide 

a copy to the Office of the Executive Director for Operations (OEDO). [C4]

11.05 Resident Inspector Relocation. All resident inspector assignments will stipulate a sevenyear maximum tour length. This policy does not preclude resident inspectors from relocating for 

promotions, voluntary reassignments, or management-directed reassignments. (see SECY-98-

152, "Summary of Issues and Recommended Improvements to the Resident Inspector 

Program," dated June 29, 1998; Staff Requirements Memorandum, "SECY-98-152, "Summary 

of Issues and Recommended Improvements to the Resident Inspector Program," dated August 

21, 1998; and Implementation of the Seven-Year Relocation Policy for Resident Inspectors, 

Memorandum from Hugh Thompson to all Regional Administrators, dated September 21, 1998.)

[C4]

1. Resident inspectors are expected to relocate from the site assignment after 7 years. 

Resident inspectors due to rotate during the winter months or early spring may be 

granted an extension to the summer months with Regional Administrator approval. Any 

other extensions beyond the 7-year maximum tour length must be approved by the 

Deputy Executive Director for Regulatory Programs (DEDR).

2. As resident inspectors approach the 7-year point at a site, the agency will consider 

inspector requests for a lateral transfer. Earlier transfers can be made when consistent 

with agency needs. In either case, resident inspectors are encouraged to make their 

desires and career goals known to their management as far in advance as possible.

3. Resident inspectors should not normally be reassigned to the same facility even after an 

intervening assignment. Reassignments may be made to co-located facilities that would 

cause resident inspectors to interact with a different licensee.

4. This policy applies to total site tour length and it is not affected by a promotion from 

resident inspector to senior resident inspector at a site.

5. Resident inspectors should not be assigned to a different location within the first four 

years after relocating unless specifically approved by the DEDR based on identified 

agency needs.
Issue Date: 05/01/15 19 2515

6. This policy applies to the Resident and Senior Resident Inspectors assigned at any of 

the reactor sites, fuel facilities, and gaseous diffusion plants. [C4]

11.06 Guidelines for Assigning Resident Inspectors to Reactor Sites and Granting Exceptions 

to the Policy. The resident inspector staffing policy is to assign two resident inspectors at single 

and dual unit sites and three resident inspectors at triple unit sites. Exceptions may be granted 

to the policy for assigning resident inspectors to reactor sites. The OEDO is responsible for 

assuring that each exception is consistent with Commission policy (see SECY-99-227, "N+1 

Resident Inspector Staffing Policy," dated September 13, 1999; and Staff Requirements 

Memorandum, “SECY-99-227 - N+1 Resident Inspector Staffing Policy," dated January 11, 

2000).

A Regional Administrator, with Director, Office of Nuclear Reactor Regulation (NRR), approval, 

and in consultation with the Deputy Executive Director for Reactor Programs has the authority to 

establish exceptions to the policy for assigning resident inspectors to plant sites. N+1 

vacancies at multi-unit sites will not be refilled unless unique conditions warrant granting an 

exception. The exception will be justified based primarily on site performance. Flexibility should 

be retained to adjust the number of resident inspectors assigned to a site upward if 

circumstances warrant, such as sites with diverse NSSS vendor designs. [C4]

 The Regions are responsible for assigning resident inspectors to reactor sites in 

accordance with this policy.

 In accordance with Staff Requirements Memorandum, "SECY-99-227 - N+1 Resident 

Inspector Staffing Policy," dated January 11, 2000, the region will not direct 

reassignment of any resident inspector solely to reduce resident staffing to N at multiunit sites.

 The Region is responsible for requesting approval from the Director, NRR, for proposed 

exceptions to the resident inspector staffing policy. The exception request will include 

the Region's basis for the request. A copy will be provided to the Deputy Assistant for 

Operations, Technical, Budget and Performance Management (TBPM), OEDO.

 NRR is responsible for reviewing the exception request and for ensuring that the policy 

for approving exceptions is applied consistently for all Regions.

 The Director, NRR, will notify the Region, in writing, of NRR's decision regarding an 

exception request. The Region may implement the exception on receiving the Director's 

approval. A copy will be provided to the Deputy Assistant for Operations, Technical, 

Budget and Performance Management (TBPM), OEDO.

 The Regions and NRR are responsible for monitoring exception site performance to 

assure exception justifications remain valid. The Regions should review exceptions that 

are performance based at least every two years and forward a renewal exception 

request, if necessary.
Issue Date: 05/01/15 20 2515

 Regional management staff should provide heightened management oversight on 

staffing for sites where the number of resident inspectors assigned is N, such as where 

assigned resident inspectors are absent from the site for extended periods or the 

resident inspectors are not yet qualified.

As an oversight function, OEDO will review exceptions granted after NRR's approval has been 

sent to the Region. This review is intended to assure exceptions conform to Commission 

guidance (SECY-99-227 and associated Staff Requirements Memorandum) and are 

consistently applied.

 If the Region's exception request is approved, NRR will forward an information copy of 

the memorandum granting approval to the Deputy Assistant for Operations, Technical, 

Budget and Performance Management (TBPM), OEDO.

 The Deputy Assistant for Operations, Technical, Budget and Performance Management 

(TBPM), OEDO will have the package reviewed with emphasis on site performance and 

for consistency of application across Regions.

 The Deputy Assistant for Operations, Technical, Budget and Performance Management 

(TBPM), OEDO will inform the Commission as stated in SECY-99-227 of any site where 

performance warrants the assignment of an additional resident inspector. [C4]

11.07 Inspector Functions During Period of Lapsed Appropriation. NRC Management 

Directive 4.5, “Contingency Plan for Periods of Lapsed Appropriations,” has defined the resident 

and selected region-based inspector function as an excepted NRC activity that will continue 

during the period of restricted NRC operations. Both resident and region-based inspectors will 

continue with their respective functions as follows:

1. Resident inspection function which includes the following activities:

 Completion of all of the following activities that are normally assigned to a resident 

inspector:

o IMC 0350, “Oversight Of Reactor Facilities in a Shutdown Condition Due to 

Significant Performance and/or Operational Concerns,” completion of the 

activities that have been assigned to a resident inspector for the site

o IMC 2515, “Light-Water Reactor Inspection Program-Operations Phase,” 

including completion of all core, baseline, IMC 2515, Appendix C, “Special and 

Infrequently Performed Inspections,” and IMC 2515, Appendix D, “Plant Status” 

activities that have been assigned to a resident inspector for the site

o IMC 2516, “Policy and Guidance for the License Renewal Inspection Program”

o IMC 2517, “Watts Bar 2 Inspection Program”

o IMC 2561 “Decommissioning Power Reactor Inspection Program” activities that 

have been assigned to a resident inspector for that site

 Completion of reactive inspection activities pursuant to NRC Management Directive 

8.3, “NRC Incident Investigation Program,” and IMC 0309, “Reactive Inspection 

Decision Basis for Reactors.” The decision to initiate a reactive inspection shall be 
Issue Date: 05/01/15 21 2515

made in consultation with the “excepted function” Regional and Program Office 

managers. The requirement for Senior Risk Analyst participation in establishing the 

risk significance of an event that meets the deterministic criteria is 

waived. Residents and “excepted function” regional managers are granted the 

discretion to use available tools (including SDP screening tools and the licensee’s 

risk tools) as they may be available and appropriate.

 Completion of baseline, Appendix C, reactive, and supplemental inspection activities 

not covered above that have been/are approved by regional management as being 

within the technical expertise of the residents at the site and that have been 

scheduled for completion during the period of lapsed appropriation.

 Emergency response, incident response, allegation, enforcement, public 

communication, and support for emergency licensing action activities that are 

typically performed by resident inspectors.

The resident inspection function does not include implementation of Reactor Oversight 

Process activities or other program activities in the applicable IMCs shown below that 

require substantial support or approval from the Regional Office or a Program Office. 

 IMC 0305, “Operating Reactor Assessment Program”

 IMC 0320, “Operating Reactor Security Assessment Program”

 IMC 0609, “Significance Determination Process”

 IMC 0612, “Power Reactor Inspection Reports”

2. Region-based inspection function which includes the following activities:

 Initial licensing activity

 Event response which would require regional specialist expertise

The region-based inspection function does not include implementation of Reactor Oversight 

Process activities or other program activities in the applicable IMCs shown below that 

require substantial support or approval from the Regional Office or a Program Office. 

 IMC 0305, “Operating Reactor Assessment Program”

 IMC 0320, “Operating Reactor Security Assessment Program”

 IMC 0609, “Significance Determination Process”

 IMC 0612, “Power Reactor Inspection Reports”

2515-12 GENERAL INSPECTION POLICIES

12.01 Management Entrance and Exit Meetings. Inspectors are required to meet with licensee 

management as part of every inspection. Region-based inspectors should hold an entrance 

meeting with the senior licensee representative who has responsibility for the areas to be 

inspected. Each inspection conducted by resident inspectors and region-based inspectors must 

include discussing inspection results with licensee management. At the conclusion of an 

inspection, inspectors must discuss their preliminary findings with the licensee’s management at 
Issue Date: 05/01/15 22 2515

a scheduled exit meeting. Management entrances and exit meetings with licensee personnel 

should be scheduled to have the minimum impact on other licensee activities necessary to 

assure the safe operation of the plant.

The duration of exit meetings, the level of detail involved in the meetings, and the level of 

interest of the licensee in the exit meeting (as manifested by the number of attendees or their 

positions in the licensee's organization) will vary from one inspection to another; however, the 

following guidelines should be considered when preparing for exit meetings:

 Throughout the inspection process, the principle of "no surprises" should be observed. 

Through a combination of regular communications during the course of the inspection 

and pre-exit status meetings (for those licensees who wish them) the licensee should 

have knowledge of the issues that will be summarized in the exit meeting before the 

meeting occurs.

 The inspection exit meeting is an NRC-led meeting convened to allow the inspector(s) to 

present preliminary inspection results to the licensee. As such, the NRC representative 

tasked with leading the meeting must maintain control of the meeting, ensuring that the 

discussion remains professional, on-track and efficient. The meeting must not be 

allowed to degrade into a technical debate, a lecture, or a discussion of non-inspectionrelated issues. If the NRC exit leader finds that the purpose of the exit meeting cannot 

be realized (due, for example, to an overly argumentative licensee), the meeting should 

be terminated and the appropriate NRC manager should be notified.

 The NRC representative tasked with leading the exit meeting may allow the licensee to 

record the exit meeting (either in audio or audio/video formats) provided the NRC is 

given a copy of the recording.

 The exit meeting should be summary in nature. It is not necessary to go into great detail 

on inspection items that meet regulatory requirements; a statement describing the scope 

of inspection and reporting satisfactory performance can suffice.

 The information presented at an exit meeting is predecisional in nature and subsequent 

management review of the inspection results may lead to changes in the 

characterization of issues; this should be made clear at the outset of the meeting. The 

inspector should also point out that if changes are made in the characterization of 

issues, NRC will communicate the changes to the licensee prior to the issuance of the 

inspection report.

 When findings are involved, the exit meeting should include a description of the finding, 

and the standard which was not met. If there is a cross-cutting aspect associated with 

the finding, it shall be presented at the exit meeting to ensure licensee awareness of the 

cross-cutting aspect.

 When discussing findings that are potentially greater than green, the inspector should 

communicate the results of the initial SDP evaluation or the information needed in order 

to assess the significance.
Issue Date: 05/01/15 23 2515

 If the licensee expresses strong opinions or disagreement with the characterization of an 

issue presented at the exit meeting, the inspector should inform regional management. 

Such a licensee response is not documented in the inspection report.

 If proprietary information is reviewed in the course of an inspection, the inspector should 

confirm with the licensee at the exit meeting that NRC has (or has not) returned 

proprietary materials used during the inspection.

 Oral Statements and Regulatory Commitments: Do not attempt to characterize or 

interpret any oral statements the licensee makes, at the exit meeting or at any other time 

during the inspection, as a commitment. Licensee commitments are documented by 

licensee correspondence, after which they may be referenced in the inspection report. 

Oral statements made or endorsed by a member of licensee management authorized to

make commitments are not regulatory commitments unless they are documented as 

such by the licensee. For further guidance on licensee commitments, see ADAMS 

Accession Nos. ML003680088 (NEI 99-04), ML003680078 (NEI Cover Letter), and 

ML003679799 (SECY 00-045 endorsing NEI 99-04 guidance).

Because regulatory commitments are a sensitive area, ensure that any reporting of 

licensee statements is paraphrased accurately and contain appropriate reference to the 

licensee’s document.

Time spent on scheduled and periodic entrance and exit meetings (including preparing for the 

meetings) is considered part of preparation and documentation of inspections. Entrance 

meeting time is charged to preparation and exit meeting time is charged to documentation. 

Daily communication with licensee management is considered to be an integral part of every 

inspection procedure and the time used for such routine communications should be charged to 

the inspection procedures used.

Communicating inspection observations also is an integral and important part of every 

inspection, whether done daily during the course of an inspection, or periodically with status 

meetings. Many licensees have expressed the desire to hear inspector insights related to 

safety/regulatory performance even in instances where they do not reach the threshold for 

documentation in an inspection report (see IMC 0612, “Power Reactor Inspection Reports”). 

When deciding which observations and insights to pass on to the licensee, inspectors should 

consider the following:

1. Inspectors should share the same insights with their regional managers and the senior

resident inspector.

2. The insights must relate to areas within NRC’s jurisdiction and responsibilities.

3. Comments should be objective and supported with examples when possible. Avoid 

generalizations such as “procedure adherence was good.” Instead, just state the 

objective facts: “Procedures were followed in each case we observed.” Negative 

observations or insights must be supported with specific examples.
Issue Date: 05/01/15 24 2515

4. Inspectors should not express an expectation for licensee managers to take specific 

actions. The inspector may comment on whether or not the actions comply with NRC 

requirements.

5. Inspectors should determine before the exit if the licensee wants to hear the 

observations and insights. If the licensee does not want the observations or insights at 

the exit meeting, the inspectors should not discuss them.

6. Inspectors should avoid “consulting” for the licensee and not advise them on how to 

improve draft documents or in-process work, or pass on to licensees how other 

licensees do the same thing.

12.02 Review of Updated Final Safety Analysis Report (UFSAR). For planning inspections, 

several baseline inspection procedures specify reviewing applicable portions of the plant’s 

UFSAR. This review is intended to provide the inspectors with design bases insights in 

preparing for inspections and is not intended to be a review of UFSAR accuracy. The general 

focus of the baseline inspection program is to monitor licensee performance. Therefore, 

UFSAR accuracy will not be routinely inspected, although it is a source of information for 

inspections.

However, the NRC does rely on the accuracy of the UFSAR in making informed licensing 

decisions on changes. Therefore limited requirements for UFSAR accuracy may be 

incorporated into specific inspection procedures. Perform these inspection requirements as 

directed by the implementing procedure.

12.03 Responding to Events and Event Reports. Routine events of low significance, such as 

uncomplicated reactor trips, will be followed up by resident or region-based inspectors to verify 

that the events are not complicated by loss of mitigation equipment or other factors. This event 

follow up is part of the baseline inspection program, and emphasizes collecting information 

about the event for use by risk analysts in evaluating the risk significance of the event to help 

regional and headquarters management determine if a response beyond the baseline program 

is warranted.

The significance of operational events is evaluated using the Conditional Core Damage 

Probability (CCDP) metric, which best reflects the full extent of any loss of defense-in-depth due 

to the event, in conjunction with various deterministic criteria to address the most influential 

related assumptions and uncertainties. The significance is determined regardless of whether 

the cause is due to licensee performance or otherwise.

The agency’s response to significant events is described in NRC Management Directive 8.3, 

“NRC Incident Response Program.” In general, significant operational events may be 

investigated by multi-disciplined Incident Investigation Teams (IITs) that are initiated by the 

EDO, and are comprised of both regional and headquarters personnel. Operational events of 

lesser significance may be investigated by Augmented Inspection Teams (AITs) that are 

initiated by Regional Administrators. Regional Administrators may also initiate special 

inspection (SI) teams that use only regional personnel. The applicable procedures for AITs and 

SI teams are listed in Appendix C, “Special and Infrequently Performed Inspections.” In 

addition, for an event of extraordinary safety significance or profound regulatory implications, an 
Issue Date: 05/01/15 25 2515

Accident Review Group may be formed that reports directly to the Commission, as described in 

Management Directive 8.9, “Accident Investigation.”

Licensees often notify inspectors of events or conditions in anticipation of the inspectors’ 

interest in the issue, but such notifications do not exempt the licensee from reporting events and 

conditions through the required regulatory processes. The licensee should be made aware that 

documents that it gives to inspectors are subject to Freedom of Information Act requests and 

may be placed in the Public Document Room.

In addition to reviewing plant events to determine whether the NRC should devote additional 

effort and resources to respond to the event, the baseline inspection program screens for 

potential risk significance and possible future inspection all written event reports submitted to 

the NRC by licensees. The review should be acknowledged in an inspection report.

12.04 Findings Outside of Inspector’s Qualifications. Inspectors sometimes identify issues or 

violations outside of the inspector’s qualifications or expertise. In these cases the inspector is 

responsible for (1) determining if an immediate threat to public or worker health or safety exists, 

and if one does exist to notify licensee management immediately, (2) determining if the issue is 

better addressed by an inspector with different qualifications (i.e., a specialist inspector). 

Inspectors may follow issues outside of their qualifications or expertise with the concurrence of 

a regional manager responsible for the area associated with the issue and the inspector’s 

supervisor.

Such issues are associated with the most applicable cornerstone and inspectable area

regardless of the baseline inspection procedure in use when the issue is identified. The 

inspector’s time associated with the issue is charged to the baseline procedure that best 

corresponds to the issue. If the issue is found during inspections other than baseline 

inspections, the time is charged to the procedure in use.

12.05 Communication with Local Public Officials. As a matter of management philosophy, the 

NRC maintains an “open door” policy with regard to access by the public or state and local 

officials to the NRC staff or to publicly available electronic documentation concerning a 

licensee's performance. Some local officials may desire increased interaction with the NRC's 

regional offices and Resident Inspectors. The degree of interaction that is considered 

necessary to enhance openness in the NRC is expected to vary widely depending on the 

situation at each plant. In each case where inspectors are utilized for this purpose, regional 

management must carefully balance the use of inspection resources to complete inspections 

with the need to enhance openness. Any meeting between local emergency preparedness 

officials and the NRC must be coordinated with the Federal Emergency Management Agency 

(FEMA) in accordance with the Memorandum of Understanding between FEMA and the NRC. 

[C1]

12.06 Witnessing Unsafe Situations. When NRC personnel identify unsafe work practices or 

violations which could lead to an unsafe situation, they shall make every reasonable attempt to 

prevent them from occurring or continuing in their presence. When such situations are 

identified, a licensee representative shall promptly be notified so that corrective or preventive 

measures can be taken.
Issue Date: 05/01/15 26 2515

A goal of the NRC inspection program is to witness licensee activities in as close to a normal 

environment as possible. From the assessment of these observations, conclusions are drawn 

relative to the licensee's ability to properly conduct licensed activities. Notwithstanding this 

goal, under no circumstances will an NRC inspector knowingly allow an unsafe work practice or

a violation which could lead to an unsafe situation to occur or continue in his/her presence in 

order to provide a basis for enforcement action. If such a work practice or violation is in 

progress, or is about to occur, the NRC inspector shall immediately bring the situation to the 

attention of the appropriate licensee personnel. This action shall be taken without regard for 

any impact it may have on the ability of the NRC to take future enforcement action. [C4]

2515-13 POST-LICENSE RENEWAL INSPECTIONS

13.01 Post-License Renewal Inspection Effort. IP 71003, “Post-Approval Site Inspection for

License Renewal,” is to be implemented to verify that license renewal programs and activities 

have been implemented in accordance with the requirements of Title 10 of the Code of Federal 

Regulations, Part 54. This inspection will be performed as a team inspection effort and will be 

performed just once per unit. For that reason IP 71003 is listed in Appendix C to this manual 

chapter.

13.02 Budget Planning. IP 71003 is not part of the baseline inspection program and is not 

budgeted as part of the baseline inspection program. Therefore, to ensure that inspector 

resources are available to complete this IP when required, planning for its performance must be 

projected a minimum of three years in advance of the fiscal year in which it is planned to be 

used.

2515-14 INSPECTION PROGRAM MODIFICATIONS IN EVENT OF A PANDEMIC 

In the event of a pandemic, the NRC’s Pandemic Response Plan (PRP) requires that aspects of 

the inspection program, identified as priority functions, be maintained. Additionally, the NRC’s 

PRP allows modifications to less critical aspects of the inspection program in order to address 

limited inspection resources.

Therefore, “supplemental” and “generic safety” inspections may be postponed when authorized 

by the regional administrator. Baseline inspection activities may be reduced commensurate

with available inspection and licensee resources. Inspections of reactor and security events 

(e.g., special inspections, AITs, and IITs) will continue. If necessary, the baseline inspection 

program will be reduced such that only monitoring of key plant parameters and activities will be 

performed by inspectors, if available, or by remote means, if no inspectors are available. 

Normal inspection activities will resume once the pandemic has passed and reasonable efforts 

will be made to complete missed baseline inspection activities before the end of the calendar 

year. Appendix E of this IMC provides additional background and basis for these actions and 

implementation details.

END
Issue Date: 05/01/15 27 2515

Appendices:

A. Risk-Informed Baseline Inspection Program

B. Supplemental Inspection Program

C. Generic, Special, and Infrequent Inspections

D. Plant Status

E. Inspection Program Modifications in the Event of a Pandemic
Issue Date: 05/01/15 Att1-1 2515

Attachment 1 - Chart of ROP Cycles

ROP Year 1 2 3 4 5 6 7

Start Date 04/01/2000 04/01/2001 01/01/2002 01/01/2003 01/01/2004 01/01/2005 01/01/2006

End Date 03/31/2001 12/31/2001 12/31/2002 12/31/2003 12/31/2004 12/31/2005 12/31/2006

Biennial Cycles 1

st Biennial 2nd Biennial 3rd Biennial 4th Biennial

Triennial Cycles 1

st Triennial 2nd Triennial 3rd Triennial

ROP Year 8 9 10 11 12 13 14

Start Date 01/01/2007 01//01/2008 01/01/2009 01/01/2010 01/01/2011 01/01/2012 01/01/2013

End Date 12/31/2007 12/31/2008 12/31/2009 12/31/2010 12/31/2011 12/31/2012 12/31/2013

Biennial Cycles 4

th Biennial 5th Biennial 6th Biennial 7th Biennial

Triennial Cycles 3

rd Triennial 

4

th Triennial 5th Triennial

NOTE: The 3rd and 4th triennial cycles overlap in CY2008. If a triennial inspection is performed in CY2008, the inspection counts for 

both the 3rd and 4th triennial cycles and next required inspection will take place during the 5th triennial cycle.
Issue Date: 05/01/15 Att1-2 2515

Attachment 1 - Chart of ROP Cycles

ROP Year 15 16 17 18 19 20 21

Start Date 01/01/2014 01/01/2015 01/01/2016 01/01/2017 01/01/2018 01/01/2019 01/01/2020

End Date 12/31/2014 12/31/2015 12/31/2016 12/31/2017 12/31/2018 12/31/2019 12/31/2020

Biennial Cycles 8

th Biennial 9th Biennial 10th Biennial 11th Biennial

Triennial Cycles 6

th Triennial 7th Triennial 8th Triennial

ROP Year 22 23 24 25 26 27 28

Start Date 01/01/2021 01//01/2022 01/01/2023 01/01/2024 01/01/2025 01/01/2026 01/01/2027

End Date 12/31/2021 12/31/2022 12/31/2023 12/31/2024 12/31/2025 12/31/2026 12/31/2027

Biennial Cycles 11th Biennial 12th Biennial 13th Biennial 14th Biennial

Triennial Cycles 8

th Triennial 9th Triennial 10th Triennial

ROP Year 29 30 31 32 33 34 35

Start Date 01/01/2028 01//01/2029 01/01/2030 01/01/2031 01/01/2032 01/01/2033 01/01/2034

End Date 12/31/2028 12/31/2029 12/31/2030 12/31/2031 12/31/2032 12/31/2033 12/31/2034

Biennial Cycles 15th Biennial 16th Biennial 17th Biennial 18th Biennial

Triennial Cycles 10th Triennial 11th Triennial 12th Triennial
Issue Date: 05/01/15 Att2-1 2515

Attachment 2 - Revision History for IMC 2515

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 (PreDecisional, 

Non-Public)

C1 07/09/2002

CN 02-027

Revised to add a new section (12.05) which provides 

guidance on increased communication between the regional 

offices/resident inspectors and local public officials. This 

change was made specifically to satisfy a commitment made 

by NRR to resolve a concern which arose following the IP2 

tube rupture event where the local county official wanted 

increased communication with the resident inspectors.

N/A N/A

N/A 01/24/2003

CN 03-001

Revised to add a section 04.07 to define baseline inspection 

program completion for an ROP annual inspection cycle. 

Section 13.02 was also added to discuss budget planning to 

perform IP 71003, “Post-Approval Site Inspection for License 

Renewal.”

N/A N/A

N/A 02/02/2004

CN 04-003

Revised to reflect recommended changes to define the 

periodicity of biennially and triennially. The section of 

inspection policy has been revised to allow early assignment 

of replacement senior and resident inspectors to a site to prior 

to the end of the tour of the incumbent inspector.

N/A N/A

N/A 03/30/2005

CN 05-009

Revised to reflect the inspection program policy regarding 

baseline inspection credit for Operational Safety Review Team 

Effort as described in memorandum addressed to the 

Commission dated July 16, 2003. 

N/A N/A
Issue Date: 05/01/15 Att2-2 2515

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 (PreDecisional, NonPublic)

C2 07/28/2005

CN 05-021

Revised to address recommendations from a Office of 

Inspector General’s audit of the NRC’s baseline inspection 

program (OIG-05-06):

- provided basis and rationale for the baseline inspection 

procedure sample size, including a discussion of when, or why, 

to use more than minimum samples.

- provided additional management guidance for assigning 

inspectors to perform inspection procedures to ensure that 

inspectors are adequately qualified for their assignments.

- improved inspection guidance on whether performance of one 

inspection procedure sample can be counted as a sample for 

another.

- clarified expectations and requirements for which inspection 

procedures cannot be deferred, plants where procedures 

cannot be deferred, criteria for deferring a procedure and 

reporting requirements when inspections are deferred.

- added a program requirement for regions to maintain an 

inspection tracking system so that no more than four inspection 

procedures are deferred in a calendar year.

N/A N/A
Issue Date: 05/01/15 Att2-3 2515

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 (PreDecisional, NonPublic)

C3 11/28/2005

CN 05-031

Revised to address recommendations from an Office of 

Inspector General’s audit of the NRC’s baseline inspection 

program (OIG-05-06):

Revised to clarify a ROP program expectation that inspection 

findings which are determined to be minor do not need to be 

nor shall be tracked or trended by either inspectors or regional 

managers.

N/A N/A

N/A 01/26/07

CN 07-004

Revised to address changes to the inspection program in the 

event of a pandemic and to clarify baseline inspection program 

completion reporting requirements by the regions and NSIR.

Completed 4 year historical change notice search.

N/A ML063460228

N/A 09/20/07

CN 07-029

IMC 2515 has been revised to add additional guidance on the 

conduct of exit meetings. 

N/A ML071560246

N/A 05/01/08

CN 08-014

Added Attachment 1 “Chart of ROP Cycles” N/A N/A

C4 09/24/09

CN-09-022

Incorporated Executive Director Operations Field Policy Manual 

guidance related to: No. 8 - Resident Inspector Relocation 

Policy, No. 13 - Witnessing Unsafe Situations, No. 18 -

Guidelines for Assigning Resident Inspectors to Reactor Sites 

and Granting Exceptions to the Policy, and No. 19 - Guidance 

for Recommending Third Party Assistance to Licensees 

N/A N/A
Issue Date: 05/01/15 Att2-4 2515

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 (PreDecisional, NonPublic)

N/A ML11279A088

11/19/12

CN-12-026

Incorporated recommendations proposed in feedback forms 

2515-1327; -1409; 1563; -1576; and -1577.

N/A ML12292A313

ML12321A240

ML12321A243

ML12321A244

ML12321A247

ML12321A249

N/A ML13037A177

06/19/13

CN-13-014

Incorporated recommendations proposed in feedback forms 

2515-1733; -1767; and -1790.

N/A ML13109A367

N/A ML13176A336

10/18/13

CN 13-025

IMC 2515 was revised to clarify what constitutes a deviation 

from the ROP, and includes details on transitioning from IMC 

2515 (Operating Reactors) to IMC 2561(Decommissioning); 

Incorporated recommendations proposed in feedback form 

2515-1884.

N/A ML13274A627

N/A ML14321A055

05/01/15

CN 15-009

IMC 2515 was revised to provide guidance to resident and 

region-based inspectors on the scope of their excepted 

functions during period of lapsed appropriation.

N/A ML15107A177